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

liat- ed. These contacts are not sufficiently "systematic and continuous" to maintain general jurisdiction over a defendant in this action.8' See Helicopteros, 466 U.S. at 416, 104 S.Ct. 1868 (holding that purchas- ing in forum, sending personnel for train- ing in forum, and negotiating a contract in foru

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

affiliat- ed. These contacts are not sufficiently “systematic and continuous” to maintain general jurisdiction over a defendant in this action.** See Helicopteros, 466 U.S. at 416, 104 S.Ct. 1868 (holding that purchas- ing in forum, sending personnel for train- ing in forum, and negotiating a contract in forum

ownership of shares m Texas corporations, on its own, cannot be considered sufficiently systematic and continuous to establish general jurisdiction. Helicopteros, 466 U.S. at 414-16, 104 S.Ct. 1868 (finding CEO’s travel to forum for contract negotiations, employees’ travel to forum for training, receipt of fun

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