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In Response To Defendants’ Motions Seeking Dismissal For Lack Of Personal Jurisdiction And/Or Subject Matter Jurisdiction And Under The Foreign Sovereign Immunities Act (Fsia)
document In response to defendants’ motions seeking dismissal for lack of personal jurisdiction and/or subject matter jurisdiction and under the Foreign Sovereign Immunities Act (FSIA) House Oversight Committee — Epstein Estate Records (Nov 2025)

plaintiffs supplemented their already detailed allegations record relevant to those jurisdictional disputes through extrinsic information and evidence filed in support of their oppositions to the Defendants’ motions to dismiss. These materials *12 included

In Their Submissions
document In their submissions House Oversight Committee — Epstein Estate Records (Nov 2025)

plaintiffs conceded that Terrorist Attacks III was dispositive as to the immunity defenses asserted by the Saudi Red Crescent Society (SRC) and Saudi Joint Relief Committee for Kosovo and Chechnya (SJRC)

In An Effort To Narrow The Scope Of These Appeals
document In an effort to narrow the scope of these appeals House Oversight Committee — Epstein Estate Records (Nov 2025)

plaintiffs in all cases agreed voluntarily to withdrew the appeals as to twenty-two defendants.6 Several additional non-dispositive stipulations of dismissal were filed in individual cases as to other Appellees. As a result

*70 Under Both Theories Of Liability
document *70 Under both theories of liability House Oversight Committee — Epstein Estate Records (Nov 2025)

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 receiving that support. See

In Determining That Plaintiffs’ Pleadings Were Conclusory And Inadequate
document In determining that plaintiffs’ pleadings were conclusory and inadequate House Oversight Committee — Epstein Estate Records (Nov 2025)

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

Application Of This Heightened Standard Is Especially Misguided In Light Of Congress’s Intent That The Ata Reach Just The Conduct That Plaintiffs Allege. That Is
document Application of this heightened standard is especially misguided in light of Congress’s intent that the ATA reach just the conduct that plaintiffs allege. That is House Oversight Committee — Epstein Estate Records (Nov 2025)

“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

Plaintiffs’ Complaints Allege That Saudi American Bank Has Knowingly Provided Various Forms Of Material Support To Al Qaeda. For Example
document Plaintiffs’ complaints allege that Saudi American Bank has knowingly provided various forms of material support to al-Qaeda. For example House Oversight Committee — Epstein Estate Records (Nov 2025)

“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 operated from that country ....” JA843-44

Plaintiffs Further Allege That “Saudi American Bank Facilit[Ated] Al Qaida’s Fundraising Efforts” By “Advertis[Ing] The Existence And Numerical Designation Of The Accounts It Maintain[Ed] For Those Charities Throughout The Muslim World
document Plaintiffs further allege that “Saudi American Bank facilit[ated] al Qaida’s fundraising efforts” by “advertis[ing] the existence and numerical designation of the accounts it maintain[ed] for those charities throughout the Muslim world House Oversight Committee — Epstein Estate Records (Nov 2025)

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 ....” JA3844. Also

Plaintiffs Further Allege That Beginning In 1983
document Plaintiffs further allege that beginning in 1983 House Oversight Committee — Epstein Estate Records (Nov 2025)

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

The Plaintiffs Also Provided Sufficient Allegations Connecting The Defendants To The Center Of Al Qaeda’s Network Of Terrorism
document The plaintiffs also provided sufficient allegations connecting the defendants to the center of al-Qaeda’s network of terrorism House Oversight Committee — Epstein Estate Records (Nov 2025)

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

Sufficient Factual Allegations Of A Connection Between The Material Support Provided And The Acts Of Terrorism That Caused Plaintiffs’ Injuries
document sufficient factual allegations of a connection between the material support provided and the acts of terrorism that caused plaintiffs’ injuries House Oversight Committee — Epstein Estate Records (Nov 2025)

such that a reasonable trier of fact could conclude that it was more likely than not that the support provided by the defendant assisted the terrorists in the commission of the terrorist act.

*147 For Those Claims That Are Subject To New York’s Statute Of Limitations
document *147 For those claims that are subject to New York’s statute of limitations House Oversight Committee — Epstein Estate Records (Nov 2025)

the district court should have applied equitable tolling principles. All of plaintiffs’ claims arise from the defendants’ participation in the conspiracy to conduct terrorist attacks against the United States

November 5, 2004, when the Court heard
document IMAGES-004-HOUSE_OVERSIGHT_017847.txt Nov 5, 2004 House Oversight Committee — Epstein Estate Records (Nov 2025)

782 November 5, 2004, when the Court heard oral argument from the Kingdom of Saudi Arabia in its motion to dismiss the Federal Insurance complaint. I. Subject Matter Jurisdiction Under the FSIA [2-4] Under the FSIA, a foreign state and its instrumentalities are presumed im- mu...