Every indexed document

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 .....

“Saudi American Bank knowingly provided material support and resources to al Qaida” by “finance [ing] many of the projects undertaken by Osama bin Laden and al Qaida in the Sudan during the years that the al Qaida leadership structure opera...

Al Rajhi Bank was warned by United States government officials “that their financial systems were being manipulated or utilized to fund terrorist organizations such as Al Qaeda.” SPA55 (Terrorist Attacks I); JA 2584-86; infra pp. 93-95. “De...

including by making direct donations to them

plaintiffs’ detailed allegations focused on the knowing or reckless nature of the provision of support to al-Qaeda. The particular allegations set forth below are in addition to plaintiffs’ extensive allegations regarding the broader contex...

111 it radically understated the scope and detail surrounding those direct allegations. Far from presenting bare conclusions

“Congress[] clearly expressed [an] intent to cut off the flow of money to terrorists at every point along the causal chain of violence.” Boim I

Heightened Standard In Evaluating Plaintiffs’ Pleadings.

the district court misapplied fundamental legal principles governing the assessment of a complaint and related pleadings upon a motion to dismiss. It also dramatically understated or disregarded the scope

an ATA claim may be predicated on the provision of support without plaintiffs having to establish that the defendants sought to advance any particular terrorist attack -- or even terrorist activities generally -- by the entities or persons....

broadly defined. Congress accomplished this purpose by “codify[ing] general common law tort principles and ... extend[ing] civil liability for acts of international terrorism to the full reaches of traditional tort law.” Boim v. Quranic Lit...