3
Shared Docs
1
Same-Page
3 / 4
Mentions
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
ting the Princes' or Kingdom's tortious acts or omissions caused Plaintiffs' injuries? 28 U.S.C. § 1605(aX5); Virtual Countries, 300 F.3d at 241; Cargill, 991 F.2d at 1016. "Any terrorist act, including the Septem- ber 11 attacks, might have been the natu- ral and probable consequence of knowingly an
ourt's sub- ject matter jurisdiction, the moving Defen- dants retain the ultimate burden of per- suasion. Virtual Countries, 300 F.3d at 241 (citing Cargill, 991 F2d at 1016); Robinson, 269 F.3d at 141 n. 8 (noting defendant's burden must be met with a preponderance of the evidence). [7] Defendants ma
Court’s sub- ject matter jurisdiction, the moving Defen- dants retain the ultimate burden of per- suasion. Virtual Countries, 300 F.3d at 241 (citing Cargill, 991 F.2d at 1016); Robinson, 269 F.3d at 141 n. 8 (noting defendant’s burden must be met with a preponderance of the evidence). [7] Defendants may
Page: HOUSE_OVERSIGHT_017847 →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 →forward with evidence showing that, under the exceptions to the FSIA, immunity should not be granted.’ ” Virtual Countries, 300 F.3d at 241 (quoting Cargill, 991 F.2d at 1016); see also Terrorist Attacks [, 349 F.Supp.2d at 792-797 (explaining that the possibly relevant exceptions to immunity in this liti
Page: HOUSE_OVERSIGHT_017914 →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 Cargill

United States
LOCATION
Bill Clinton
PERSONSecond Circuit
ORGANIZATION
Bradley Edwards
PERSON
Michael Cohen
PERSON
Philadelphia
LOCATION
Terry
PERSON
Khalifa
PERSON
Alfredo Rodriguez
PERSONHaley Robson
PERSON
Georgina Chapman
PERSON
Houston
LOCATION
Atlanta
LOCATION
Kenya
LOCATION
U.S. Treasury
ORGANIZATION
Supreme Court
ORGANIZATIONAshton
PERSON
Stephen Joseph
PERSONCasey
PERSONConley
PERSON