Epstein Secrets

2d SERIES mainly banks in Arab and Islamic coun- tries. Ashton Complaint 11583; Burnett Complaint 147. It also has banks in Chi- cago, Illinois and Houston, Texas. Bur- nett Complaint II 47. Al Baraka allegedly provided financial infrastructures in Sudan to Osama bin Laden through Defendant charity Al

FTCA). [29,30] There can be little doubt that, as the chairman of the Supreme Council of Islamic Affairs, charged with making rec- ommendations to the Council of Ministers regarding requests for aid from Islamic organizations located abroad, and as the head of the Special Committee of the Council of Ministers, charg

e foreign policy of Saudi Arabia as determined by the Council of Ministers.” Abdulaziz H. Al-Fahad Decl. 15, at Sara E. Krop

utory foreign sovereign immunity and protecting a sovereign’s or sovereign’s agency’s legitimate claim to immunity from discovery.” First City, Texas—Houston, N.A. v. Rafidain Bank, 150 F.3d 172, 176 (2d Cir.1998) (ordering full discovery against defendant over whom court al- ready had subject matter juris

al Haramain Foundation’).) He is also a member of the Council of Ministers and serves on the Supreme Council for Islamic Aff

garding NCB’s FSIA defense would necessarily subject the Kingdom to discovery, which the Court is hesitant to do unnecessarily. See First City, Texas—Houston, N.A. v. Rafidain Bank, 150 F.3d 172, 176 (2d Cir.1998); see also Arriba Ltd. v. Petroleos Mexicanos, 962 F.2d 528, 534 (Sth Cir.1992) (recommending