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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
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
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
ges as any other "statement." Nor has Plaintiff demonstrated that the self-defense privilege was "abused" so as to remove the defense. According to the Second Circuit (interpreting New York law), once the defendant has proved that she is entitled to a qualified privilege, there arises a rebuttable presumption of
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
Page: HOUSE_OVERSIGHT_017848 →hort of alleging Prince Sul- tan’s actions were ‘expressly aimed’ or ‘purposefully directed’ at the United States.” Id. at 23 (citing Burger King and Keeton v. Hustler Magazine, Inc., 465 U.S. 770, 774-75, 104 S.Ct. 1478, 79 L.Ed.2d 790 (1984)). Judge Robertson also denied Plaintiffs’ request for discover
Page: HOUSE_OVERSIGHT_017878 →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)
Page: HOUSE_OVERSIGHT_017917 →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
Page: HOUSE_OVERSIGHT_017922 →Entities connected to both Keeton and Second Circuit

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
United States
LOCATION
Prince Andrew
PERSON
Michael Cohen
PERSON
Bradley Edwards
PERSON
Supreme Court
ORGANIZATION
Southern District of New York
ORGANIZATION
George W. Bush
PERSON
New York
LOCATION
Alan Dershowitz
PERSON
Stephen Hawking
PERSONMaria Farmer
PERSON
Marc Rich
PERSON
Alfredo Rodriguez
PERSON
United Kingdom
LOCATION
Martha Stewart
PERSON
Samantha Power
PERSON
Philadelphia
LOCATION
Bill Clinton
PERSON