Epstein Secrets

y and decided without an evidentiary hearing, Plaintiffs need only make a prima facie showing that personal jurisdiction ex- ists. PDK Labs, Inc. a Friedlander, 103 F.3d 1105, 1108 (2d Cir.1997); AL Trade Finance, Ina a Petra Bank, 989 F.2d 76, 79 (2c1 Cir.1993). Plaintiffs may rely en- tirely on factual

0 (hereinafter "Supp. Al-Wohai- bi Aff."). a. Status of the PIF In Filler v. Hanvit Bank, a case with facts very similar to those presented here, the Second Circuit reiterated Dole Food's requirement of direct ownership for instru- mentality status. Two defendants were commercial banks majority-owned by the Ko

t of the Princes’ ac- tions. [22-24] Pursuant to the Second Cir- cuit’s instruction, the Court must first de- termine whe

very least, discovery should be ordered circumspectly and only to verify allega- tions of specific facts crucial to an immuni- ty determination.”)). The Second Circuit has instructed “that generally a plaintiff may be allowed limited discovery with re- spect to the jurisdictional issue; but until [plaintiff] has sho

ry and decided without an evidentiary hearing, Plaintiffs need only make a prima facie showing that personal jurisdiction ex- ists. PDK Labs, Inc. v. Friedlander, 103 F.8d 1105, 1108 @d Cir.1997); AZ. Trade Finance, Inc. v. Petra Bank, 989 F.2d 76, 79 (2d Cir.1993). Plaintiffs may rely en- tirely on factual al

bia’s relationship to NCB. The Supreme Court and Second Circuit agree that there are certain circumstances in whi

Accordingly, the only dispute regarding SHC’s status is whether it is an organ of the Kingdom. In Filler v. Hanvit Bank, 378 F.3d 213 (2d Cir.2004), the Second Circuit considered various factors to determine whether an entity could be considered an organ of a foreign sovereign. Jd. at 217. The factors include: (1)

Civil Procedure 12(b)(2), Plaintiffs must make a prima facie showing that personal jurisdiction exists over each moving Defendant. PDK Labs, Inc. v. Friedlander, 103 F.3d 1105, 1108 (Qd Cir.1997). The Court reviews the complaints and affidavits in a light most favorable to Plaintiffs, id., but it does not acc