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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
proceed with this claim. Wantartabe Realty Corp. v. City of New York 01 Civ. 10137(LAK), 2003 WL 22862646, at *4 (S.D.N.Y. Dec. 3., 2003) (citing Pittman, 149 F.3d at 122-23). 8. Negligence 186-881 In New York, a plaintiff may establish negligent infliction of emotional distress under the bystander
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 →- tious under New York law. Robinson, 269 F.3d at 142. In New York, conspiracy and aiding and abetting are varieties of con- certed action liability. Pittman v. Gray- son, 149 F.8d 111, 122 (@d Cir.1998). There must be “(1) an express or tacit agreement to ‘participate in a common plan or design to commit
Page: HOUSE_OVERSIGHT_017862 →may proceed with this claim. Wantanabe Realty Corp. v. City of New York, 01 Civ. 10187(LAK), 2003 WL 22862646, at *4 (S.D.N-Y. Dec. 3., 2003) (citing Pittman, 149 F.3d at 122-28). 8. Negligence [86-88] In New York, a plaintiff may establish negligent infliction of emotional distress under the bystander o
Page: HOUSE_OVERSIGHT_017895 →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 →e for acting in concert with the primary tortfeasor under either theory, the defendant must know the wrongful nature of the primary actor’s conduct. Pittman v. Grayson, 149 F.3d 111, 122—23 (2d Cir.1998). Accordingly, to survive these Rule 12(b)(1) motions to dismiss, Plaintiffs must plead facts from whic
Page: HOUSE_OVERSIGHT_017919 →Entities connected to both Turki and Yogananda Pittman

United States
LOCATION
Jeffrey Epstein
PERSON
Atlanta
LOCATION
Bradley Edwards
PERSON
UBS AG
ORGANIZATION
Bill Clinton
PERSON
Virginia Giuffre
PERSON
Alfredo Rodriguez
PERSONHaley Robson
PERSON
New York
LOCATION
New York City
LOCATION
Saudi Arabia
LOCATION
Michael Cohen
PERSON
U.S. Treasury
ORGANIZATION
Marc Rich
PERSON
Supreme Court
ORGANIZATIONSecond Circuit
ORGANIZATION
Somalia
LOCATION
al-Qaeda
ORGANIZATION
Arabia
LOCATION