Epstein Secrets

production on this issue—resolution of dis- puted issues of fact.' ") (citing Robinson, 269 F.3d at 141); Leutwyler v. Office of Her Majesty Queen Rania Al-Abdullah, 184 F.Supp.2d 277, 287 (S.D.N.Y.2001) (explaining plaintiff may "rebut the pre- sumption of immunity ... by proffering evidence of record that th

he relocated to Sudan in 1991. Ash- ton. Complaint 1 548; Burnett Complaint 1 317. For example, SBG, through two subsidiaries allegedly supported Osama bin Laden's participation in the construc- tion of the Tahaddi road and Port Sudan Airport. Ashton Complaint 111550; 552, 553; Burnett Complaint 111319-322.

of production on this issue—resolution of dis- puted issues of fact.’”) (citing Robinson, 269 F.3d at 141); Leutwyler v. Office of Her Majesty Queen Rania Al-Abdullah, 184 F.Supp.2d 277, 287 (S.D.N.Y.2001D (explaining plaintiff may “rebut the pre- sumption of immunity ... by proffering evidence of record that the d

e met with members of the Taliban and representa- tives of bin Laden and agreed to not extra- dite bin Laden or close terrorist camps in exchange for bin Laden’s protection of the II, 292 F.Supp.2d at 16. This Court has re- viewed these affidavits and agrees with Judge Robertson’s assessment. For example, one

xtrinsic submissions made by the foreign defendants regarding the scope of their official responsibilities.” Leutwyler v. Office of Her Majesty Queen Rania Al-Abdullah, 184 F.Supp.2d 277, 287 (S.D.N.Y.2001). King Faud authorized Dr. Al—Nafissa to make his declaration concerning SHC. (Al-Nafissa Decl. | 2, at Huffma

haracterized [him] as having ‘directed organizations that have provided financial and logistical support to al-Qa-ida, [he] is the logistics chief of bin Laden’s organization and fought on bin Laden’s side in WESTLAW Afghanistan.’ ” (Ashton Compl. J¥ 304, 312, 523-24; Burnett Compl. J 236, 255, 271; Federal