Epstein Secrets

able to Plaintiffs. PDK Labs, 103 F.3cl at 1108. It will not, however, accept legally conclusory assertions or draw "argumenta- tive inferences." Mende v. Milestone Tech, Inc-, 269 F.Supp.2d 246, 251 (S.D.N.Y.2003) (citing Robinson v. Over Military Sales Coip., 21 F.3d 502, 507 (2d Cir.1994)). A.

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

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

03 F.3d at 1108. It will not, however, accept legally 349 FEDERAL SUPPLEMENT, 2d SERIES conclusory assertions or draw “argumenta- tive inferences.” Mende v. Milestone Tech, Inc, 269 F.Supp.2d 246, 251 (S.D.N.Y.2003) (citing Robinson v. Over- seas Military Sales Corp., 21 F.3d 502, 507 (2d Cir.1994)).

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

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)

laints and affidavits in a light most favorable to Plaintiffs, id., but it does not accept conclusory allegations or draw “argumentative inferences.” Mende v. Milestone Tech., Inc., 269 F.Supp.2d 246, 251 (S.D.N.Y.2003) (citing Robinson v. Overseas Military Sales Corp., 21 F.3d 502, 507 (2d Cir.1994)).