Epstein Secrets

hat they were members of conspiracy pursuant to New York long-arm statute, or that they had any general business contacts with United States. 18 U.S.C.A. § 2331 et seq.; N.Y.McKinney's CPLR 302(a)(2). 68. Federal Courts C=97 Jurisdictional discovery was warrant- ed, at dismissal stage of Antiterrori

rrorism Act (ATA) suit by survivors of victims of September 11, 2001 attacks, as to issue whether company purposefully directed its activities at United Slates, for purposes of personal jurisdiction. 18 U.S.C.A. § 2331 et seq.; Fed.Rules Civ.Proc.Rule 12(b)(2), 28 U.S.CA. 101. Federal Civil Procedure (3=

ts with the United States generally, but in- sufficient contacts with any one state in particular. Fed.R.Civ.P. 4(k)(2) advisory committee's note; United Stales v. Intl. Bhd, of Teamsters, 945 F.Supp. 609, 616- 17 (S.D.N.Y.1996). For jurisdiction under Rule 4(k)(2), there must be a federal claim, personal

dismissed for lack of per- sonal jurisdiction. 3. Plaintiffs Are Entitled to Jurisdic- tional Discovery as to Privatbank's Investing Activities in the United States [37] Plaintiffs point out that Privat- bank's website and its 2001 Annual Report state that Privatbank engages in transac- tions involving securiti

some conceivable non-discretionary tortious act falls within the purview of these generic allegations under the appli- cable substantive law. 28 U.S.C.A. 1605(a)(5). 28. International Law C=10.33 In determining whether functions are discretionary, for purposes of the discre- tionary function except

ditional notions of fair play and substantial justice." Intl Shoe Co v. Washington, 326 U.S. 310, 316, 66 S.Ct. 154, 90 L.Ed. 95 (1945); see also World-Wide Volkswagen Corp. v. Wood- son, 444 U.S. 286, 292, 100 S.Ct. 559, 62 L.Ed.2d 490 (1980). The minimum con- tacts requirement is also known as "fair warning," such tha

e* does work :here and the reply was affirmative. MILITARY SERVICE I Asked the Person Spoken to whether defendant was in active military service of the United States or of the State of New York in any capacity whatever, and received a negative reply The source of my information and the grounds of my belief are th

t contacts the defendant has with the forum, measured against the burden of the defendant in defending in that forum. Godfrey, 18 V.I. at 68-69 and World-Wide Volkswagen Corp. v Woodson, 444 U.S. 286 292(1980). 12 EFTA00309192 Plaintiffs' Opposition to Defendant's Motion to Dismiss Epstein el al. it Fanelli Paneling.

fficient con- tacts with the United States as a whole but is not subject to jurisdiction in any particu- lar state, requires contacts with the United States as a whole. U.S.C.A. Const.Amend. 5; Fed.Rules Civ.Proc.Rule 4(k)(2), 28 U.S.C.A. 50. Constitutional Law ¢=305(5) The due process minimum contacts

has sufficient con- tacts with the United States as a whole but is not subject to jurisdiction in any particu- lar state, requires contacts with the United States as a whole. U.S.C.A. Const.Amend. 5; Fed.Rules Civ.Proc.Rule 4(k)(2), 28 U.S.C.A. 50. Constitutional Law ¢=305(5) The due process minimum co

t, but in the manner of a private player within it, the foreign sover- eign’s actions are ‘commercial’ within the meaning of the FSIA.” Weltover, 504 U.S. at 614, 112 S.Ct. 2160. Courts must in- quire whether the foreign state’s actions “are the type of actions by which a private party engages in trade a

Teamsters, 945 F.Supp. at 617. a. Purposefully Directed Activities Theory Personal jurisdiction based on Rule 4(k) requires minimum contacts with the Unit- ed States to satisfy Fifth Amendment due process requirements. Plaintiffs claim these requirements are met because De- fendants purposefully directed their ac