Epstein Secrets

. C. Defendants' Status as Foreign States for FSIA Purposes The Court must first determine if the moving Defendants are "foreign states" for 22. Zakat is required almsgiving by all Mus- lims. See, e.g., Emmet Complaint at 275; id. 140. EFTA00795052 788 349 FEDERAL SUPPLEMENT, 2d SERIES purpose

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

5. C. Defendants’ Status as States for FSIA Purposes The Court must first determine if the moving Defendants are “foreign states” for Foreign 22. Zakat is required almsgiving by all Mus- lims. See, e.g., Burnett Complaint at 275; id. 140. HOUSE_OVERSIGHT_017852 --- PAGE BREAK --- 788 purposes of

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

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

ionally allege that “DMI [Trust] and its affiliated and subsidiary companies have known that many of the ostensible charities to which they channeled Zakat and Haraam funds were, in fact, fronts for al Qaeda [, including ITRO and MWL].” *88 JA4337. “Despite the actual knowledge that money contributed to