Epstein Secrets

deter- mine which of the Network's entities have a presence in Virginia and which entities transferred money to Nada and Nasred- din. 10. Mel AJ. Batterjee The Burnett Plaintiffs claim that Defen- dant Mel A.J. Batterjee is an associate of Osama bin Laden. Burnett Complaint 1181. On December 21, 2004,

aider and abettor of al Qaeda and international ter- rorist activities." Id. 11176-77. One of the hijackers on board American Airlines Flight 11, Abdulaziz al-Omari, held an account at Al Rajhi Bank Burnett Complaint 185; Rule 12(e) Statement 1143. Another hijacker, Mohammed Atta, made a transfer to this acco

Adel A.J. Batterjee is an associate of Osama bin Laden. Burnett Complaint 9181. On December 21, 2004, the U.S. Department of Treasury designated Mr. Batterjee as a Specially Designated Global Terrorist. See Dec. 23, 2004 Bierstein let- ter to Court; Exec. Order No. 13224. Mr. Batterjee is the chairman of Al

r, aider and abettor of al Qaeda and international ter- rorist activities.” Jd. 19 76-77. One of the hijackers on board American Airlines Flight 11, Abdulaziz al-Omari, held an account at Al Rajhi Bank. Burnett Complaint 185; Rule 12(e) Statement 1 43. Another hijacker, Mohammed Atta, made a transfer to this account

e, a close bin Laden associate who also headed al-Qaeda charity *50 fronts Benevolence International Foundation and its Saudi parent, Lajnat al Bir.* Batterjee’s primary role in al-Qaeda’s support infrastructure prompted the United States to list him as a Specially Designated Global Terrorist after the Septe

ort included “knowingly and intentionally provid [ing] financial and bank account services” for al-Qaeda front charities and “September 11th hijacker Abdulaziz al-Omari.” JA1062-77, 1784, 2483, 3827-29.'" “Al Rajhi Bank has long known that the[se] *79 accounts ... were being used to solicit and transfer funds to terr