Epstein Secrets

ncis McMahon, Stephanie Wall Fell, Martin F. McMahon and Associ- ates, Thomas Peter Steindler, McDermott, Will and Emery (DC), James Ernest Gauch, Jennifer Allyson Shumaker, Jona- than Chapman Rose, Melissa Danielle Stear, Michael Peter Gurdak, Michael Rol- lin Shumaker, Stephen Joseph Brogan, Timothy John Finn, Jones

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

Francis McMahon, Stephanie Wall Fell, Martin F. McMahon and Associ- ates, Thomas Peter Steindler, McDermott, Will and Emery (DC), James Ernest Gauch, Jennifer Allyson Shumaker, Jona- than Chapman Rose, Melissa Danielle Stear, Michael Peter Gurdak, Michael Rol- lin Shumaker, Stephen Joseph Brogan, Timothy John Finn, Jones Da

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

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

Francis McMahon, Stephanie Wall Fell, Martin F. McMahon, and Associates, Thomas Peter Steindler, McDermott, Will and Emery (DC), James Ermest Gauch, Jennifer Allyson Shumaker, Jonathan Chapman Rose, Melissa Danielle Stear, Michael Peter Gurdak, Michael Rollin Shumaker, Stephen Joseph Brogan, Timothy John Finn, Jones Day (D

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)