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,

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

he orders dismissing those defendants should be vacated so that the district court can apply current law to defendants’ motions. Standard of Review The Second Circuit “review[s] de novo a district court’s dismissal of a complaint pursuant to Rule 12(b)(6), construing the complaint liberally, accepting all factual a

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

favor.” Amaker v. N.Y. State Dep’t of *63 Corr. Servs., 435 F. App’x 52, 54 (2d Cir. 2011) (quoting Chambers v. Time Warner, Inc., 282 F.3d 147, 152 (2d Cir. 2002)). WESTLAW HOUSE_OVERSIGHT_023384 --- PAGE BREAK --- In re: TERRORIST ATTACKS ON SEPTEMBER 11, 2001., 2012 WL 257568 (2012) Argument I. Th

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

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

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)

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