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ision regarding placement of a water hose on a ship was an operational function and there- fore not discretionary and not protected by the FSIA); Napolitano v. Tishman Constr. Corp., No. 96 Civ. 4402(5.1), 1998 WL 102789, at •4 (E.D.N.Y. Feb. 26, 1998) (finding purchasing consulate buildings and hir
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
decision regarding placement of a water hose on a ship was an operational function and there- fore not discretionary and not protected by the FSIA); Napolitano v. Tishman Constr. Corp., No. 96 Civ. 4402(SJ), 1998 WL 102789, at *4 (E.D.N.Y. Feb. 26, 1998) (finding purchasing consulate buildings and hiring con
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 →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 →level, are protected by the immunity.’ ” Marchisella v. Gov't of Japan, No. 02 Civ. 10023(DC), 2004 WL 307248, at *2 (S.D.N.Y. Feb.17, 2004) (quoting Napolitano vy. Tishman Constr. Corp., No. 96 Civ. 4402(SJ), 1998 WL 102789, at *4 (E.D.N.Y. Feb.26, 1998)). Here, since SHC, Prince Salman, and Prince Naif are
Page: HOUSE_OVERSIGHT_017918 →Entities connected to both Napolitano and Cargill

Jeffrey Epstein
PERSON
United States
LOCATION
Supreme Court
ORGANIZATION
George Mitchell
PERSON
George W. Bush
PERSON
Eric Schmidt
PERSON
Bradley Edwards
PERSONCasey
PERSON
New York
LOCATION
David Boies
PERSON
Bill Clinton
PERSONGibson
PERSONWright
PERSONDarren Indyke
PERSON
United Kingdom
LOCATION
Nelson
PERSON
Prince Charles
PERSON
Louisiana
LOCATION
Alfredo Rodriguez
PERSONSecond Circuit
ORGANIZATION