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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
r purpose, and (d) the resulting damage or injury." Chrysler Capital Corp. 778 F.Supp. at 1267 (quoting Kashi v. Gratsos, 790 F.2d 1050, 1055 (2d Cir.1986)). To warrant the inference that a defendant was a member of the conspira- cy, Plaintiffs must show that "(a) the de- fendant had an awareness of th
, 259 F. 35, 38, and De- moth United States, 144 F. 363, 366, 6 I.R.A., .S., 424, 7 Ann.Cas. 121; by the decision of the Circuit Court of ala of the Second Circuit in Reed ■ United States, 2 Cir., 96 F2d 785, 787, rtlorarl denied 305 U.S. 612, 59 S.Ct. 71, 83 LEd. 399; and by the rulin of the Supreme Court
ely on the defendant's status as a U.S. cit- izen is firmly estallished by our precedent. See, e.g.. United States Walczak, 783 F.2d 852, 854 (9th Cir.1986) (holding that jurisdiction over a U.S. citizen who violated a federal statute while in Canada los proper under the nationality principle); McKee!
t 1313. Hoffenberg suggests that United States v. Leonard, 50 F.3d 1152, 1158 (2d Cir.I995), suggests a high- er standard of proof. In Leonard, the Second Circuit instructed that "the district court should consider any evidence with a significant degree of probative value, and should rest its finding on evid
allis, 28 F.3d 1399, 1409 (5th Cir.1994); United States v. Fitch, 964 F.2d 571, 574 (6th Cir.1992); United Stales v. Brown, 801 F.2d 352, 354 (8th Cir.1986). F1418. United States v. Tilley, 964 F.2d 66, 70 (Id Cir.1992) FN19. Dallis, 28 F.3d at 1409; Tilley, 964 F.2d at 70; United States v. Crawford,
Entities connected to both Second Circuit and Cir.1986

Jeffrey Epstein
PERSON
Ghislaine Maxwell
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United States
LOCATIONthe Southern District
LOCATION
Department of Justice
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Julie K. Brown
PERSONJane Doe
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Michael Cohen
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Bradley Edwards
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Southern District of New York
ORGANIZATION
David Boies
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New York
LOCATIONMartin Weinberg
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George W. Bush
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Donald Trump
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Michael Jackson
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Virginia Giuffre
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Alan Dershowitz
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Paul Cassell
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