Epstein Secrets

WU v. Potter, 343 F.3d 619, 627 (2d Cir.2003) (noting a court may "devistel the procedures [to] ferret out the facts pertinent to jurisdiction"); Marine Midland Bank, N.A. v. Miller, 664 F.2d 899, 904 (2d Cir.1981) (noting a court has considerable procedural leeway in de- ciding whether discovery would assist re

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

association of employees acting within the scope of their employment is not considered "distinct" from their employer. Riverwoods Chaopaqua Corp. v. Marine Midland Bank. NA, 30 F.3d 339, 344 (2d Cir.1994). Further, Plaintiff incorporates paragraphs 1-22 of the Amended Complaint into Count IV. If those allegations

wire and mail fraud occurred over 21-month period); Cofacredit. S.A. v. Windsor Plumbing SupnlY Co., 187 F.3d 229, 242 (2d Cir.1999) (stating that the Second Circuit "has never held a period of less than two years to constitute a `substantial period of time' "); Hughes v. Consol-Pennsylvania Coal Co. 945 F.2d 59

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

, APWU v. Potter, 348 F.3d 619, 627 (2d Cir.2003) (noting a court may “devis[e] the procedures [to] ferret out the facts pertinent to jurisdiction”); Marine Midland Bank, N.A. v. Miller, 664 F.2d 899, 904 (2d Cir.1981) (noting a court has considerable procedural leeway in de- ciding whether discovery would assist res-