it openly used Defendants Al Shamal Islamic Bank (“Al Shamal’”) and Faisal
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Al Shamal *45 and FIBS are referred to herein as the
*° Al Shamal maintained accounts for Osama bin Laden and several other al-Qaeda officials
partnered with al-Qaeda by mamtaining accounts for al-Qaeda and by embedding
and by virtue of the longstanding ties between senior executives of NCB
Khaled bin Mahfouz and Yassin al Kadi are referred to here is ahe “NCB Defendants.”)
and because senior Al Rajhi Bank officials
plaintiffs’ pleadings and supplemental materials allege that support for al-Qaeda’s agenda emanated
our making videos that defa me Mohammed and so on. Again
and not a small one. It is becoming increasingly
and from violating Section 15(a) of the Securities Exchange Act
the SEC instituted a proceeding pursuant to Section 15(b}(6) of the Exchange Act and
and Section 17(a) of the Securities Act.
inadequate supervision and other grounds for liability arising from injuries or
You mentioned you were friends with Tom Barrack and I wondered if you might introduce me to