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ions to statutory, foreign sovereign immunity and protecting a sovereign's or sovereign's agency's legitimate claim to immunity from discovery.'" First City, Texas-Houston, N.A. a Rafulain Bank, 150 F.3d 172, 176 (2d Cir.1998) (ordering full discovery against defendant over whom court al- ready had sub
ned subsidiary of SBG and its board members include defen- dants Bakr, Tariq, and Omar Binladin. Ashton Complaint 1556; Burnett Com- plaint 11325. Khalifa listed the Mo- hammed Bin Laden Organization address on his visa application. Ashton Complaint 1555; Burnett Complaint 1324. Addition- ally, U.S.-d
exceptions to statutory foreign sovereign immunity and protecting a sovereign’s or sovereign’s agency’s legitimate claim to immunity from discovery.” First City, Texas—Houston, N.A. v. Rafidain Bank, 150 F.3d 172, 176 (2d Cir.1998) (ordering full discovery against defendant over whom court al- ready had subje
Page: HOUSE_OVERSIGHT_017848 →-owned subsidiary of SBG and its board members include defen- dants Bakr, Tariq, and Omar Binladin. Ashton Complaint 1556; Burnett Com- plaint 91325. Khalifa listed the Mo- hammed Bin Laden Organization address on his visa application. Ashton Complaint 1555; Burnett Complaint 1324. Addition- ally, U.S.-des
Page: HOUSE_OVERSIGHT_017887 →lippines office, which served as a center of terrorist financing and training. (Ashton Compl. § 310; Burnett Compl. § 234; Federal Compl. §§ 135-36.) Khalifa collected and laundered money for al Qaeda through ITRO’s Phillipines office. (Ashton Compl. J 316; Burnett Compl. J 240.) Through Khalifa, TRO was a
Page: HOUSE_OVERSIGHT_017924 →ally, discovery regarding NCB’s FSIA defense would necessarily subject the Kingdom to discovery, which the Court is hesitant to do unnecessarily. See First City, Texas—Houston, N.A. v. Rafidain Bank, 150 F.3d 172, 176 (2d Cir.1998); see also Arriba Ltd. v. Petroleos Mexicanos, 962 F.2d 528, 534 (Sth Cir.1992)
Page: HOUSE_OVERSIGHT_017932 →Entities connected to both First City and Khalifa

United States
LOCATION
Lebanon
LOCATION
al-Qaeda
ORGANIZATION
Bill Clinton
PERSON
Riyadh
LOCATION
Michael Cohen
PERSON
Alfredo Rodriguez
PERSON
Yemen
LOCATIONthe Council of Ministers
ORGANIZATION
Supreme Court
ORGANIZATION
Saudi Arabia
LOCATION
Osama bin Laden
PERSON
Somalia
LOCATION
United Kingdom
LOCATION
Houston
LOCATIONSecond Circuit
ORGANIZATION
Kenya
LOCATION
White & Case LLP
ORGANIZATIONAl Qaeda Islamic Army
ORGANIZATIONCasey
PERSON