Epstein Secrets

tions, including al4aecla." Federal Complaint 1 222 Several organizations within the MAR Network, including SAAR Founda- tion, MAR International, Safa Group, Mar-Jac Poultry, Mar-Jac Holdings, Inc., Safa Trust, Inc. and Aradi, Inc., were es- tablished, funded or closely affiliated with Defendant Suleim

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

zations, including al-Qaeda.” Federal Complaint 1222. Several organizations within the SAAR Network, including SAAR Founda- tion, SAAR International, Safa Group, Mar—Jac Poultry, Mar—Jac Holdings, Inc., Safa Trust, Inc. and Aradi, Inc., were es- tablished, funded or closely affiliated with Defendant Suleiman

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)

African Muslim Agency, Mar—Jac Investments, Mar—Jac Poultry, Reston Investments, SAAR Foundation, Safa Trust, where he was the principal signatory on Safa Group checks, and York International; WESTLAW Iqbal Yunus was a director of Child Development Foundation, a SAAR Network entity, and was associated with