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cknowledging re- sponsibility for, such terrorist schemes as the 1993 bombing of the World Trade Cen- ter, the 1998 attack of the U.S. embassies in Kenya and Tanzania, and the 2000 at- tack of the U.S.S. Cole in Yemen." Bur- nett I, 274 F.Supp.2d at 105; see also Ashton Complaint 11105-108 (1993 World
required by Rule 8 "must simply 'give the defendant fair notice of what the plaintiffs claim is and the grounds upon which it rests' ") (quoting Conley, 355 U.S. at 47, 78 S.Ct. 99). When presented with a 12(6)(6) motion, the district court may not consider matters outside of the pleadings without
acknowledging re- sponsibility for, such terrorist schemes as the 1993 bombing of the World Trade Cen- ter, the 1998 attack of the U.S. embassies in Kenya and Tanzania, and the 2000 at- tack of the U.S.S. Cole in Yemen.” Bur- nett [, 274 F.Supp.2d at 105; see also Ashton Complaint 11 105-108 (1993 World
Page: HOUSE_OVERSIGHT_017862 →eyond doubt, “even when the complaint is liberally con- strued, that the plaintiff can prove no set of facts which would entitle him to relief.” Id.; Conley v. Gibson, 355 U.S. 41, 45-46, 78 S.Ct. 99, 2 L.Ed.2d 80 (1957). Federal Rule of Civil Procedure 8(a) requires that a complaint contain “a short and
Page: HOUSE_OVERSIGHT_017890 →“found computer hard drives with photographs of the World Trade Center before and after its collapse as well as photos of United States embassies in Kenya and Tanzania and the U.S.S. Cole.” (Ashton Compl. J 451; Burnett Compl. J 397; Federal Compl. J § 186, 458.) The U.S. forces also apparently found fi
Page: HOUSE_OVERSIGHT_017914 →cts and issues and to dispose of unmeritorious claims.” Swierkiewicz vy. Sorema, N.A., 534 U.S. 506, 512, 122 S.Ct. 992, 152 L.Ed.2d 1 (2002) (citing Conley v. Gibson, 355 U.S. 41, 47, 78 S.Ct. 99, 2 L.Ed.2d 80 (1957), Leatherman v. Tarrant County Narcotics Intelligence & Coordination Unit, 507 U.S. 163,
Page: HOUSE_OVERSIGHT_017925 →Entities connected to both Kenya and Conley

Jeffrey Epstein
PERSON
United States
LOCATION
George W. Bush
PERSON
Donald Trump
PERSON
Bill Clinton
PERSON
Barack Obama
PERSON
Prince Andrew
PERSON
Department of Justice
ORGANIZATION
Virginia Giuffre
PERSONLeon Black
PERSON
Tanzania
LOCATION
Joe Biden
PERSON
Marc Rich
PERSON
Scarlett Johansson
PERSON
New York
LOCATION
Michael Jackson
PERSON
Prince Charles
PERSON
Stephen Hawking
PERSON
Bloomberg L.P.
ORGANIZATION
Julie K. Brown
PERSON