002) (“Bowm IT”). Neither of these cases con- cern the tortious activity exception to the FSIA, but they do explain liability under 28. The court in Halberstam outlined the ele- ments of aiding and abetting as: “(1) the party whom the defendant aids must perform a wrongful act that causes an injury; (2) the

nd sub- stantially assist the principal violation.’’ Hal- 349 FEDERAL SUPPLEMENT, 2d SERIES the ATA and for aiding and abetting and conspiracy.“ In Halberstam, the defen- dant was found liable as a joint venturer for a killing that occurred during a burgla- ry at which she was not present. Halber- stam, 705

with the burglar and her assistance in his other illegal ventures "defie[d] credulity that [she] did not know that something illegal was afoot." Halberstam, 705 F2d at 486. In Boirn, the district court had denied a motion to dismiss by U.S.-based charities alleged to have aided and abetted interna- t

also trying to make a point, an important one considering the slapdash nature of the transition team’s staffing protocols: be careful who you hire. Halberstam’s book, published in 1972, is a Tolstoyan effort to understand how great figures of the academic, intellectual, and military world who had served dur