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e incor- rect.’’’) (internal citations omitted). The Court bears in mind that it is bound by Sec- ond Circuit precedent while Judge Robertson applied D.C. Circuit law. Menowitz v. Brown, 991 F.2d 36, 40-41 (2d Cir.1993) (explaining transferee court is to apply its interpretation of federal law, not that of the
Page: HOUSE_OVERSIGHT_017846 →e war with the United States). 26. Plaintiffs argue that Judge Robertson held them to an unnecessarily stringent theory of causation and submit that the D.C. Circuit’s subsequent decision in Kilburn v. Socialist People’s Libyan Arab Jamahiriya, 376 F.3d 1123 (D.C.Cir.2004), effectively overrules the holding in Burne
Page: HOUSE_OVERSIGHT_017862 →, check clear- ing services, or any other routine banking service.” Jd. In light of the liberal plead- ing standards, however, Judge Robertson denied Al Rajhi Bank’s motion to dismiss and permitted it to request a more defini- tive statement under Rule 12(e). Jd. at 110. The Burnett Plaintiffs provided an 89-parag
Page: HOUSE_OVERSIGHT_017897 →detail below.” (Together with NCB and Abdulrahman bin Mahfouz, Khaled bin Mahfouz and Yassin al Kadi are referred to here is ahe “NCB Defendants.”) Al Rajhi Bank played an analogous and equally important role in al-Qaeda’s financial infrastructure, by also providing financial services to al-Qaeda charity front
Page: HOUSE_OVERSIGHT_023381 →rtising these accounts, Al Rajhi Bank “provid[ed] a mechanism to allow al Qaida’s supporters to deposit funds directly into those accounts.” JA3828. Al Rajhi Bank’s operations are consistent with their support of al-Qaeda front charities. In 1999, Al Rajhi Bank was warned. by United States government officials “t
Page: HOUSE_OVERSIGHT_023389 →fendants’ provision of material support to al-Qaeda was knowing or, at the very least, reckless. The reasonableness of this inference is supported by the D.C. Circuit’s judicial review of habeas petitions brought on behalf of Guantanamo Bay detainees. See, e.g., Al Alwi v. Obama, 653 F.3d 11 (D.C. Cir. 2011); Uthman
Page: HOUSE_OVERSIGHT_023396 →es assured of its subject matter and personal jurisdiction over NCB, Plaintiffs’ claims are doomed because the Court dismissed similar claims against Al Rajhi Bank, Saudi American Bank, and Arab Bank. NCB contends that Center for Reproductive Law & Policy v. Bush, 304 F.3d 183, 194-95 (2d Cir.2002), supports its
Page: HOUSE_OVERSIGHT_017931 →is is another name for the Muslim World League. 5 Plaintiffs bring the Court’s attention to Mwani v. bin Laden, 417 F.3d 1 (D.C.Cir.2005), in which the D.C. Circuit found that Osama bin Laden and al Qaeda were subject to personal jurisdiction under Rule 4(k)(2) because they had “engaged in unabashedly malignant a
Page: HOUSE_OVERSIGHT_017933 →Entities connected to both the D.C. Circuit and Al Rajhi Bank

United States
LOCATION
Supreme Court
ORGANIZATION
Michael Cohen
PERSONSecond Circuit
ORGANIZATION
Bill Clinton
PERSONthe Seventh Circuit
ORGANIZATION
New York
LOCATION
Philadelphia
LOCATION
New York City
LOCATION
Sudan
LOCATION
U.S. Treasury
ORGANIZATIONHaley Robson
PERSON
Alfredo Rodriguez
PERSONCasey
PERSON
Atlanta
LOCATION
Arabia
LOCATION
National Commercial Bank
ORGANIZATION
Saudi Arabia
LOCATION
Baker Botts
PERSONCozen O’Connor
PERSON