Epstein Secrets

ernation- al Islamic Relief Organization (“IIRO”),'* Al Haramain,'” Muslim World League (““MWL”)," and the World A

on- al jurisdiction over Princes and others under New York’s long-arm statute; (8 nai modified due process

tate a claim, including Al Rajhi Banking & Investment Corporation (hereinafter “Al Rajhi Bank”)," the Saudi American Bank,” Arab Bank,” NCB, the SAAR Network, Prince Mohamed, Al Baraka In- vestment & Development Corporation and Saleh Abdullah Kamel," Abdulrahman bin Mahfouz, the Saudi Binladin Group, and A

ic Relief Organization (“IIRO”),'* Al Haramain,'” Muslim World League (““MWL”)," and the World Assembly of Muslim Youth “WAMY”).! Ashton Com- denied Al Haramain’s motion to dismiss the Burnett action. Burnett I, 274 F.Supp.2d at 107. 18. MWL is the parent of IIRO. See, e.g., Bur- nett Complaint {| 236. 19. WA

ising funds for HIRO, Sanabel-al Kheer, WAMY, and Al-Haramain. As for other contacts with the United States, Pr

l jurisdiction based on a conspiracy theory under New York’s long-arm statute, plaintiffs must make a prima fa

539 (2005) 10 A.L.R. Fed. 2d 789 Saudi-based charities that were sponsors of al Qaida’s operations, including ITRO, MWL, WAMY, BIF, SHC, SJRC, and al Haramain. (Federal Compl. Jf 442-43.) 31 The Federal Plaintiffs seek leave to supplement the record against Prince Salman and Prince Naif with an article tha

re “the interference with a person’s right to possession of real property either by an unlawful act or a lawful act performed in an unlawful manner.” N.Y. State Nat’l Org. for Women v. Terry, 886 F.2d 1339, 1361 (2d Cir.1989). Provided the Federal Plaintiffs plead that Defendants here acted in concert w

Defendants are not individuals. Arndt, 342 F.Supp.2d at 141. The TVPA claims against Tarik Hamdi, Abdulrahman Alamoudi, Wa‘el Jalaidan, and the SAAR Network executives are dismissed because there is no allegation that these Defendants were acting under *566 color of state law. In re: South African Aparthe

Dep’t of State, 373 F.3d 152 (D.C. Cir, 2004) occceeesescsnsesssesnseeesesnseeecesnseeenesnseeeeesnseenesnseees Neumeier v. Kuehner, 286 N.E.2d 454 (N.Y. 1972) ccs Redding v. Edwards, 569 F. Supp. 2d 129 (D.D.C. 2008) ........ Rivera v. Heyman, 157 F.3d 101 (2d Cir, 1998) eee Salahi v. Obama, 625 F.3d

8 (2010) eee *vili Schneberger v. Wheeler, 859 F.2d 1477 (11th Cir. L988), sarcasm cena enemies Sickles v. Montgomery Ward & Co., 167 N.Y.S.2d 977 (N.Y. SUP CH 1987) ccnscencnmmennencnmennencmmennennmmaennencmen Sinaltrainal v. Coca-Cola Co., 578 F.3d 1252 (11th Cir. DOO) sesceveescecswrencernccccreee

al Qaeda training camps in Afghanistan, as confirmed by a 1996 CIA Report.“! The direct involvement of Appellee Aqeel and al-Buthe in orchestrating al Haramain’s terrorist activities was also well documented. As defendant Aqeel himself stated, “[t]he [al Haramain branch] offices’ directors are employees who fo