s would be proper defendants in TVPA lawsuits. Mohamad Br. at 43-49. For these and other reasons elaborated in the briefs before the Supreme Court in Mohamad, Congress clearly intended the TVPA to provide a remedy against a broader set of defendants that includes entities other than natural persons. IV. T

plaintiffs respectfully request that this Court defer deciding their appeal of the dismissal of ther TVPA claims until the Supreme Court has decided Mohamad and the Court can obtain the benefit thereafter of the parties’ views of the implications of that decision for this case. Alternatively, should Moha

v. Bd. of Educ. of the City Sch. Dist. of N_Y., 631 F.3d 57 (2d Cir, 2011) occeeccccsnsessscsssseecesnsesecesnsesccesnsesecesnsseccesnsseecesnssees Mohamad vy. Rajoub, 132. S. Ct. 454 (2011) nc eeeeeeeeeceesseeeeteeeees Murphy v. Islamic Republic of Iran, 740 F. Supp. 2d 51 (D.D.C. 2010) eccccesecsssset