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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
ting the Princes' or Kingdom's tortious acts or omissions caused Plaintiffs' injuries? 28 U.S.C. § 1605(aX5); Virtual Countries, 300 F.3d at 241; Cargill, 991 F.2d at 1016. "Any terrorist act, including the Septem- ber 11 attacks, might have been the natu- ral and probable consequence of knowingly an
ourt's sub- ject matter jurisdiction, the moving Defen- dants retain the ultimate burden of per- suasion. Virtual Countries, 300 F.3d at 241 (citing Cargill, 991 F2d at 1016); Robinson, 269 F.3d at 141 n. 8 (noting defendant's burden must be met with a preponderance of the evidence). [7] Defendants ma
Court’s sub- ject matter jurisdiction, the moving Defen- dants retain the ultimate burden of per- suasion. Virtual Countries, 300 F.3d at 241 (citing Cargill, 991 F.2d at 1016); Robinson, 269 F.3d at 141 n. 8 (noting defendant’s burden must be met with a preponderance of the evidence). [7] Defendants may
Page: HOUSE_OVERSIGHT_017847 →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
Page: HOUSE_OVERSIGHT_017848 →forward with evidence showing that, under the exceptions to the FSIA, immunity should not be granted.’ ” Virtual Countries, 300 F.3d at 241 (quoting Cargill, 991 F.2d at 1016); see also Terrorist Attacks [, 349 F.Supp.2d at 792-797 (explaining that the possibly relevant exceptions to immunity in this liti
Page: HOUSE_OVERSIGHT_017914 →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
Page: HOUSE_OVERSIGHT_017932 →Entities connected to both Houston and Cargill

Jeffrey Epstein
PERSON
George W. Bush
PERSON
United States
LOCATION
Donald Trump
PERSON
Atlanta
LOCATION
Philadelphia
LOCATION
Prince Charles
PERSON
George Mitchell
PERSON
Bill Clinton
PERSON
New York
LOCATION
Michael Cohen
PERSON
Mike Pence
PERSON
Samantha Power
PERSON
Louisiana
LOCATION
India
LOCATION
San Diego
LOCATION
Supreme Court
ORGANIZATION
Mike Pompeo
PERSON
Oklahoma
LOCATION
Kansas
LOCATION