Epstein Secrets

2d SERIES tions that he knew they were funneling money to terrorists, do not suffice. See Burnett II, 292 F.Supp2d at 23 (citing Burger King and Keeton v. Hustler Maga- zine, Inc., 465 U.S. at 774-75, 104 S.Ct. 1473); see also Exec. Order 13244 (desig- nating certain branches of Al Haramain and BIF

s exception of FSIA; (7) survivors failed to make prima fade showing necessary to establish person- al jurisdiction over Princes and others under New York's long-arm statute; (8) modified due process standard appro- priate for mass torts would not be applied to question of personal juris- diction; (9)

rocess under either the Fifth or Fourteenth Amendment applies. U.S.CA. Const.Amends. 5, 14. 48. Courts 0 ,12(2.5) Personal jurisdiction under the New York long-arm statute requires minimum contacts with New York pursuant to the Fourteenth Amendment. U.S.CA. Const. Amend. 14; N.Y.McKinney's CPLR 3

Kreindler, Marc 5. Moller, Milton G. Sincoff, Noah H. Kushlefsky, Paul S. Edelman, Robert James Spragg, Steven R. Pounian, Kreindler & Kreindler, New York City, Elliot R. Feldman, J. Scott Tarbutton, John M. Popilock, Sean P. Car- ter, Stephen A. Cozen, Cozen O'Connor (Philadelphia), Philadelphia, PA, for

particular disreputable vice of that profession." Id. While explaining defamation per se, this Court quoted the following passage from Prosser and Keeton on the Law of Torts § 112, at 791 (5th ed. 1984): 21 EFTA00595608 Case 1:15-cv-07433-RWS Document 15 Filed 12/01/15 Page 27 of 29 [I]t is action

stituting fault as judged by, at a minimum, a negligence standard, and, it must either cause special harm or constitute defamation per se." 5 Under New York's choice-of-law rules for defamation actions, the general rule is that "the state of the plaintiff's domicile (in this case, Colorado) will usually ha

than does Colorado. Nonetheless, the laws of Colorado and New York are substantially similar. For these reasons, Ms. Maxwell asks the Court to apply New York law, but will note any differences between the two laws when applicable. 7 EFTA00595594 Case 1:15-cv-07433-RWS Document 15 Filed 12/01/15 Page 13

on- al jurisdiction over Princes and others under New York’s long-arm statute; (8 nai modified due process

tate a claim, including Al Rajhi Banking & Investment Corporation (hereinafter “Al Rajhi Bank”)," the Saudi American Bank,” Arab Bank,” NCB, the SAAR Network, Prince Mohamed, Al Baraka In- vestment & Development Corporation and Saleh Abdullah Kamel," Abdulrahman bin Mahfouz, the Saudi Binladin Group, and A

ry where the complaint stated, without any supporting facts, that the defendant “participates in a ‘multina- tional insurance arrangement’ present in the State of New York”); Im re Ski Train Fire in Kaprun, Austria, 230 F.Supp.2d at 410-413 (granting motion to dismiss and denying jurisdictional discovery where complaint

l jurisdiction based on a conspiracy theory under New York’s long-arm statute, plaintiffs must make a prima fa

me and finding a six-year period reasonable). Prince Salman’s deceased son’s contacts with the United States are irrelevant to this Court’s analysis. Keeton vy. Hustler Magazine, Inc., 465 U.S. 770, 781 n. 13, 104 S.Ct. 1473, 79 L.Ed.2d 790 (“Each defendant’s contacts with the forum State must be assessed

re “the interference with a person’s right to possession of real property either by an unlawful act or a lawful act performed in an unlawful manner.” N.Y. State Nat’l Org. for Women v. Terry, 886 F.2d 1339, 1361 (2d Cir.1989). Provided the Federal Plaintiffs plead that Defendants here acted in concert w

Defendants are not individuals. Arndt, 342 F.Supp.2d at 141. The TVPA claims against Tarik Hamdi, Abdulrahman Alamoudi, Wa‘el Jalaidan, and the SAAR Network executives are dismissed because there is no allegation that these Defendants were acting under *566 color of state law. In re: South African Aparthe