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

1996 WL 36312S, at •7 (S.D.N.Y. June 28, 1996) (quoting Hecht v. Commerce Clearing House, 897 F2d 21, 26 n. 4 (2d Cir.1990)); see also Schmidt v. Fleet Bank, 16 F.Supp2d 340, 354 (S.D.N.Y.1998) ("Bare and conclusory alle- gations are insufficient to withstand a mo- tion to dismiss and a plaintiff must pl

nu SDNY_GM_02759137 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00246059 EFTA01330522 FORM APPROVED OMB NO. 2120.0042 La ta UNITED STATES OF AMERICA U. S. DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION . ADMINISTRATION AIRCRAFT BILL OF SALE ha ., 0 0 6 5 9 8 -,J MIME RESPROED . • llis 11 NI

of Right Options, LLC in and to the following: one (1) Raytheon Aircraft Company model 400A aircraft bearing manufacturer's serial number RK-260 and United States Registration Number N7S7TA, together with two (2) Pratt & Whitney Canada, LTD. model JT15D-5 aircraft engines bearing manufacturer's serial numbers

rs in immediately available cleared funds by wire transfer in accordance with the wire transfer instructions shown on Schedule A attached hereto, to Fleet Bank, or to such other account or bank as may from time to time be designated by Lender. (b) Maturity Date. The Maturity Date with respect to any Exten

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