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,

court ... may refer to that evidence.'" Robinson, 269 F.3d at 140 (quoting Maka- rova v. United States, 201 F.3d 110, 113 (2d Cir2000)); see also Filetech S.A. v. France Telecom S.A, 157 F.3d 922, 932 ante v. Kingdom of Saudi Arabia, 03 Civ. 8591(RCC). EFTA00795047 IN RE TERRORIST ATTACKS ON SEPTEMBER

tates, 201 F.3d 110, 118 (2d Cir.2000)); see also Filetech S.A. v. France Telecom S.A., 157 F.3d 922, 932 ance v

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

y from legal proceedings in this country). Finally, Plaintiffs have not identified a factual dispute that would require jurisdictional discovery. See Filetech S.A. v. France Telecom S.A., 304 F.3d 180, 183 (2d Cir.2002) (finding no abuse of discretion where district court resolved jurisdictional issue without ho

al Foundation (“BIF”) and Adel A.J. Batterjee had. See Terrorist Attacks I, 349 F.Supp.2d at 823-25 (finding Court had personal jurisdiction over Mr. Batterjee based on his designation as a global terrorist, his role with BIF, another designated terrorist, his *561 leadership of BIF’s United States operation