Epstein Secrets

s that he knew were spon- sors of al Qaeda, including IIRO, MWL, WAMY, BIF, the Saudi High Commission, Saudi Joint Relief Committee for Kosovo and Chechnya ("SJRC"), and AI Han- main. Federal Complaint 11451-52. 191 Prince Turki denies the allegations against him in a declaration prepared in concert w

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

ners as bin Laden’s organization grew and expanded its global terrorist and military operations to regions as diverse *30 as the Philippines, Bosnia, Chechnya, Kosovo, Sudan, Ethiopia, Kashmir, Somalia, Palestine, Pakistan, Yemen, Kenya, Tanzania, Egypt, Indonesia, and Malaysia.! Plaintiffs’ pleadings and

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

bia’s relationship to NCB. The Supreme Court and Second Circuit agree that there are certain circumstances in whi

t organized by charity Defendants TTRO, World Assembly of Muslim Youth (“WAMY”), and Al-Haramain Foundation for the benefit of Bosnia Herzegovina and Chechnya. (Ashton Compl. § 290; Burnett Compl. § 401; Federal Compl. § 461.) Finally, Plaintiffs claim that members of the Saudi royal family have assets and

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)