. Batter- jee allegedly transferred control of BIF to Defendant Enaam M. Arnaout, on Septem- ber 15, 1997.28 Burnett Complaint 1183. In October 2001, Arnaout allegedly told Batterjee he was worried about being un- der scrutiny of the U.S. government and in January 2002, Batterjee requested that Aranout rel

what purpose). The Plaintiffs place great weight on the United States’ inclusion of the “Golden Chain” in its proffer of evidence in United States v. Arnaout, the government’s case against an executive of Defendant charity BIF. See Bierstein Aff. at Ex. 1 (proffer). The court presiding over that case, howe

raid -- was relied upon by the Government in an Evidentiary Proffer of al-Qaeda sponsor, Enaam Arnaout, and also referenced and used as a resource in Arnaout’s sentencing hearing. See supra pp. 54-55 nn.85-86. It was cited in the 9/11 Commission’s Final Report in July 2004, see supra pp. 25-26 & n.8, and t