Epstein Secrets

detail below.” (Together with NCB and Abdulrahman bin Mahfouz, Khaled bin Mahfouz and Yassin al Kadi are referred to here is ahe “NCB Defendants.”) Al Rajhi Bank played an analogous and equally important role in al-Qaeda’s financial infrastructure, by also providing financial services to al-Qaeda charity front

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

rtising these accounts, Al Rajhi Bank “provid[ed] a mechanism to allow al Qaida’s supporters to deposit funds directly into those accounts.” JA3828. Al Rajhi Bank’s operations are consistent with their support of al-Qaeda front charities. In 1999, Al Rajhi Bank was warned. by United States government officials “t

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

, check clear- ing services, or any other routine banking service.” Jd. In light of the liberal plead- ing standards, however, Judge Robertson denied Al Rajhi Bank’s motion to dismiss and permitted it to request a more defini- tive statement under Rule 12(e). Jd. at 110. The Burnett Plaintiffs provided an 89-parag

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

es assured of its subject matter and personal jurisdiction over NCB, Plaintiffs’ claims are doomed because the Court dismissed similar claims against Al Rajhi Bank, Saudi American Bank, and Arab Bank. NCB contends that Center for Reproductive Law & Policy v. Bush, 304 F.3d 183, 194-95 (2d Cir.2002), supports its