Every indexed document

plaintiffs allege that DMI Trust and DMI S.A. “directly participate in the oversight and management of DMI Trust’s subsidiary and associate entities.” JA4329. In addition

such as the actual minutes of al Qaeda meetings

but also is inconsistent with the findings of other courts and the Executive branch. For example

the D.C. Circuit has consistently found that habeas petitioners were “part of” al-Qaeda. See Al Alwi

both because the United States must establish its case by a preponderance of evidence (rather than the pre-discovery

including through provision of funds to Tulkarm Charity Committee

Al Rajhi Bank had reason to know of the charities’ “extensive sponsorship of al Qaida’s operations

probably because they find the bank’s vast network and adherence to Islamic principles both convenient and ideologically sound. Senior al-Rajhi family members have long supported Islamic extremists and probably know that terrorists use thei...

and individuals in the midst of al-Qaeda’s network are more likely to be part of al-Qaeda and at least well placed to know the nature of its activities. See Al-Adahi v. Obama

public testimony from a high-level al-Qaeda operative prior to September 11

Bin-Ladin set up the ‘Jihad and Relief” guesthouse in Peshawar to receive volunteers who would arrive after a short stop in the al-Ansar guesthouse in Jeddah. The route of this process passed through the unlicensed Cairo office of the [MWL]

numerous media reports and statements by government officials disclosed similar facts

2001 that the charities supported by defendants were actually fronts for al-Qaeda. JA2483-84. For example

the zakat is often provided in cash to prominent

where the pleadings contained detailed allegations that they provided material support to al-Qaeda. A stark example is the district court’s failure to infer that Al Rajhi Bank knew or had reason to know that it was providing financial servi...

but that those companies have “facilitated financial transactions for

knowingly and intentionally providing financial services to al Qaeda (including mamtaining and servicing al Qaeda bank accounts and accounts used to fund and support al Qaeda)

” DMI Trust “directly and through its subsidiaries and affiliates

Dallah al Baraka “facilitated jihad operations in the world [by] providing Osama bin Laden with financial infrastructures in Sudan ....” R.1233

and provid[ing] a mechanism to allow al Qaida supporters to deposit funds directly into those accounts.” JA3844. These actions were alleged to have been done “[i]n cooperation with the charities operating within al Qaida’s infrastructure .....