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wealthy Saudis to the Tali- ban and al Qaeda. Ashton Complaint 1259; Federal 1451. Additionally, the Federal Plaintiffs claim that, while Prince Turki was the head of DGI, Saudi Arabian intelligence officers allegedly trained a member of the al Qaecla Spanish cell in explosives and provided mater
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
he orders dismissing those defendants should be vacated so that the district court can apply current law to defendants’ motions. Standard of Review The Second Circuit “review[s] de novo a district court’s dismissal of a complaint pursuant to Rule 12(b)(6), construing the complaint liberally, accepting all factual a
gelbert Schreiber, Jr., Al Shamal Islamic Bank (Shamal), Abdul Rahman al Swailem (Swailem), Tadamon Islamic Bank (Tadamon), Abdullah Muhsen al Turki (Turki), Martin Wachter, Erwin Wachter, Sercor Treuhand Anstalt, and Asat Trust (Asat). Generally, the district court predicated the dismissals of those Ap
Page: HOUSE_OVERSIGHT_023375 →, Suleiman al Rajhi, Schreiber & Zindel Treuhand Anstalt, Frank Zindel, Engelbert Schreiber, Sr., Engelbert Schreiber, Jr., Shamal, Swailem, Tadamon, Turki, Martin *24 Wachter, Erwin Wachter, Sercor Treuhand Anstalt, Asat, Naseef, Ali, Basha, Khalifa, Aqeel, al Kadi, and al-Buthe. Disposition Below As n
Page: HOUSE_OVERSIGHT_023376 →t of the Princes’ ac- tions. [22-24] Pursuant to the Second Cir- cuit’s instruction, the Court must first de- termine whe
the allegations concerning acts tak- en in his personal, as opposed to official, capacity. Id. Judge Robertson dismissed the complaint against Prince Turki for lack of subject matter jurisdiction as well. Id. Prince Sultan and Prince Turki both move to dismiss the complaints against them in Ashton v. Al
Page: HOUSE_OVERSIGHT_017845 →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
Page: HOUSE_OVERSIGHT_017848 →bia’s relationship to NCB. The Supreme Court and Second Circuit agree that there are certain circumstances in whi
906 F.Supp. 204, 210 (S.D.N.Y.1995) (internal quotations omitted); see also Terrorist Attacks I, 349 F.Supp.2d at 788-89 (finding Princes Sultan and Turki were foreign states for FSIA purposes to the extent Plaintiffs alleged liability for actions taken in their official capacities). 1. SHC (51 SHC co
Page: HOUSE_OVERSIGHT_017916 →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)
Page: HOUSE_OVERSIGHT_017917 →Entities connected to both Turki and Second Circuit

Jeffrey Epstein
PERSON
United States
LOCATION
Michael Cohen
PERSON
Bradley Edwards
PERSON
Supreme Court
ORGANIZATION
New York
LOCATION
George W. Bush
PERSON
Virginia Giuffre
PERSONDistrict Court for the Southern District of New York
ORGANIZATION
Marc Rich
PERSON
Alfredo Rodriguez
PERSON
United Kingdom
LOCATION
Philadelphia
LOCATION
Bill Clinton
PERSON
New York City
LOCATION
Barry Diller
PERSON
Houston
LOCATIONHaley Robson
PERSON
Hanson
PERSON
George Mitchell
PERSON