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

able to Plaintiffs. PDK Labs, 103 F.3cl at 1108. It will not, however, accept legally conclusory assertions or draw "argumenta- tive inferences." Mende v. Milestone Tech, Inc-, 269 F.Supp.2d 246, 251 (S.D.N.Y.2003) (citing Robinson v. Over Military Sales Coip., 21 F.3d 502, 507 (2d Cir.1994)). A.

percprdire. Based upon the residence of the account holder, account type, or product twat some interest ands dvidend payments mar not be subiect to United Slates (US) ardor Puerto Rico 040 Income tares. The dent month,' statement is not intended to be used and (arnot be reared tam for tar purposes. Clients s

arid will tow as 'take was nol available' it were triable to obtain a price fora shinty. - Deposal a securities &nominated ilCUM71-00 other thin U.S &elms an reflected at the eichenge ate as of the statement date. - fcr certain startles fading n non-conformrig denornmmons, price and qualtity(f ac

omp...dire. eased upon the residence of the account holder, account type, or product bye, some interest ardor dnidend payments mat not be subiert to United Stater (US) ardor Puerto Rico (PR) Income Iffier. The dent month st3temen1 r5 not intended to be used and cawed be rek(0 tiCOn 10 lac proposes. Clients sh

SCOTT STACKMAN.LYLE GABRIEL 212-821-7000/800-308-3140 Estimates of value suptaisty Issuers of certa n pr.:grams (MIIM ae genet Sly 'net tact value' Mende» se shown as Issuer eu. value per um'. Pot Private equity funds, ' tsl. value per mat' is a value spclated giadedy, based on the Net And Value (' N

APPLIANCES FOR USE AT HIGH ALTITUDES CAN / CGA 2.17-M91. This appliance may only be installed in an aftermarket permanently located, manufactured (U.S.A only) or mobile home, where not prohibited by local codes. This Direct Vent System Appliance must be installed in accordance with the manufacturers

installed in accordance with the manufacturer's instruction and the Manufactured Home Construction and Safety Standard, Title 24 CFR. Part 3280, in the Untied States, or the Standard for Installation in Mobile Homes, CAN/CSA Z240 Mkt, in Canada. WilkA WARNING! lir HOT GLASS WILL CAUSE BURNS DO NOT TOUCH GLASS

de venomalege. H fer /dom le réinklelieer en suivant lee *Mee sidesaus Ipour Ie ~mondt«) : a) beIgnia le systemo en utaisant nntenupteur ON t OFF. Mende* 5 minute* peur bisser *Rapper toet le gab Puls somt« pons uno *dat do pm. y tempels pees du plancherli mus ambo une odeur de gat ARReitz, Stayer Mi

uesting the position of the United States on Defendant Jeffrey Epstein's Motion to Stay Proceedings [DE 99]. For the reasons set forth below, it is the United States' position that a stay of the proceedings is not necessary and was not contemplated by the Non-Prosecution Agreement between the United States and De

ted States, by and through the undersigned Assistant United States Attorney, and files this response to the Court's Order requesting the position of the United States on Defendant Jeffrey Epstein's Motion to Stay Proceedings [DE 99]. For the reasons set forth below, it is the United States' position that a stay of

8-cv-80119-KAM Document 15-2 Entered on FLSD Docket 06/30/2008 Page 18 of 35 0 0 U tiOnsor & Associates Money r.0e 65 Mendel yes delola ye. Mende pre42 2 A couple days 492' 3 0. we. told you to tate your leySpece pope to... 4 • couplo of days mo? 5 A. Mobady• I's *Mk dad tired at elyM

itizen or U.S. resident alien, • A partnership, corporation, company, or association created or organized in the United States or under the laws of the United States. • An estate (other than a foreign estate), or • A domestic trust (as defined in Regulations section 301.7701-7). Special rules for partnerships.

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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

03 F.3d at 1108. It will not, however, accept legally 349 FEDERAL SUPPLEMENT, 2d SERIES conclusory assertions or draw “argumenta- tive inferences.” Mende v. Milestone Tech, Inc, 269 F.Supp.2d 246, 251 (S.D.N.Y.2003) (citing Robinson v. Over- seas Military Sales Corp., 21 F.3d 502, 507 (2d Cir.1994)).

forum. Cases that cite this headnote Federal Courts @ Terrorism Two officials of Saudi Arabian government did not have such minimum contacts with the United States as to support a finding of general personal jurisdiction, in action alleging their decisions regarding distribution of humanitarian relief funds prov

laints and affidavits in a light most favorable to Plaintiffs, id., but it does not accept conclusory allegations or draw “argumentative inferences.” Mende v. Milestone Tech., Inc., 269 F.Supp.2d 246, 251 (S.D.N.Y.2003) (citing Robinson v. Overseas Military Sales Corp., 21 F.3d 502, 507 (2d Cir.1994)).

n re Terrorist Attacks on September 11, 2001, 392 F.Supp.2d 539 (2005) 10 A.L.R. Fed. 2d 789 purposefully directed his activities toward the United States by making personal contributions to several Saudi-based charities. (Federal Compl. §§ 442-43.) 19! Plaintiffs must make a prima facie showing that P

--- In re Terrorist Attacks on September 11, 2001, 392 F.Supp.2d 539 (2005) 10 A.L.R. Fed. 2d 789 purposefully directed his activities toward the United States by making personal contributions to several Saudi-based charities. (Federal Compl. §§ 442-43.) 19! Plaintiffs must make a prima facie showing