and conspiracy.” Presbyterian Church of Sudan v. Talrs- man Energy, Inc., 244 F.Supp.2d 289, 311 (S.D.N.Y.2003). According

w, Kadic, 70 F.3d at 240, and the ATCA includes “actions premised on a theory of aiding and abetting and conspiracy.” Presbyterian Church of Sudan v. Talisman Energy, Inc., 244 F.Supp.2d 289, 311 (S.D.N.Y.2003). The ATCA, therefore, may provide a basis of recovery for those Plaintiffs who are aliens. The Federal Plaint