3
Shared Docs
2
Same-Page
3 / 4
Mentions
ed that the legislative history at issue did not clearly evidence Congress' intent regarding retroactivity. Id. That is not the case here. As Judge Katzman of the Second Circuit has recognized, unambiguous legislative history should not be disregarded: When courts construe statutes in ways that respect
legislative history at issue did not clearly evidence Congress' intent regarding retroactivity. Id. That is not the case here. As Judge Katzman of the Second Circuit has recognized, unambiguous legislative history should not be disregarded: When courts construe statutes in ways that respect what legislators cons
"Civil RICO is an unusually potent weapon ... 'courts should strive to flush out frivo- lous RICO allegations at an early stage of the litigation." Katzman v. Victoria's Se- cret, 167 F.R.D. 649, 655 (S.D.N.Y.1996). [74] The Federal complaint asserts a RICO claim under § 1962(a), which states in part
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
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 →. “Civil RICO is an unusually potent weapon . ‘courts should strive to flush out frivo- lous RICO allegations at an early stage of the litigation.’” Katzman v. Victoria’s Se- cret, 167 F.R.D. 649, 655 (S.D.N.Y.1996). [74] The Federal complaint asserts a RICO claim under § 1962(a), which states in part: “
Page: HOUSE_OVERSIGHT_017892 →Entities connected to both Katzman and Second Circuit

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
United States
LOCATION
Department of Justice
ORGANIZATION
Prince Andrew
PERSON
Julie K. Brown
PERSON
Michael Cohen
PERSON
Bradley Edwards
PERSON
Supreme Court
ORGANIZATION
Southern District of New York
ORGANIZATION
New York
LOCATION
George W. Bush
PERSON
Donald Trump
PERSON
Virginia Giuffre
PERSON
Stephen Hawking
PERSON
Colorado
LOCATIONFBI
ORGANIZATIONFederal Bureau of Prisons
ORGANIZATIONLeon Black
PERSONMaria Farmer
PERSON