Epstein Secrets

contacts throughout the United States, while under the Fourteenth Amendment only the con- tacts with the forum state may be consid- ered." Chew v. Dietrich, 143 F.3d 24, 28 n. 4 (2d Cir.1998). Here, personal jurisdic- tion under the New York long-arm statute requires minimum contacts with New York pur

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

’s contacts throughout the United States, while under the Fourteenth Amendment only the con- tacts with the forum state may be consid- ered.” Chew v. Dietrich, 143 F.3d 24, 28 n. 4 (2d Cir.1998). Here, personal jurisdic- tion under the New York long-arm statute requires minimum contacts with New York pursua

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)

efendant’s contacts throughout the United States, while under the Fourteenth Amendment only contacts with the forum state may be considered.” Chew v. Dietrich, 143 F.3d 24, 28 n. 4 (2d Cir.1998). Plaintiffs claim that Rule 4(k)’s minimum contacts requirement is satisfied because the Defendants have purpose