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York, courts determine the “threshold question” of whether a duty of care exists “by balancing facto
document IMAGES-007-HOUSE_OVERSIGHT_023405.txt Sep 11, 2001 House Oversight Committee — Epstein Estate Records (Nov 2025)

…rwhelmingly in support of a duty of care. As the Seventh Circuit has concluded, lending material support to a terrorist organization, even without knowledge of its activities, satisfies the elements of negligence. Boim IT, 549 F.3d at 693. A fortiori, providing support while know...

why the district court disregarded and failed to credit plaintiffs’ extensive, entirely adequate ple
document IMAGES-007-HOUSE_OVERSIGHT_023388.txt Sep 11, 2001 House Oversight Committee — Epstein Estate Records (Nov 2025)

… violence.” Boim J, 291 F.3d at 1021. Congress did this by “attach[ing] liability to all donations to foreign terrorist organizations regardless of the giver’s intent” because “foreign organizations that engage in terrorist activity are so tainted by their criminal conduct that a...

COLLABORATIVE INSIGHTS February 25, 2019
document IMAGES-008-HOUSE_OVERSIGHT_024918.txt Feb 25, 2019 House Oversight Committee — Epstein Estate Records (Nov 2025)

… modified, distributed, transmitted or disclosed, in whole or in part, or in any form or manner, to others outside your organization without the express prior written consent of Cowen. Cowen research reports are distributed simultaneously to all clients eligible to receive such r...

Dismiss, Ex. 16 (Prince Turki, “Allied
document IMAGES-004-HOUSE_OVERSIGHT_017865.txt Sep 17, 2002 House Oversight Committee — Epstein Estate Records (Nov 2025)

…ted by the Plaintiffs on the basis that groups that they are alleged to have supported were not designated as terrorist organizations by the United States government. See Bown I, 291 F.3d at 1002 (noting Hamas was designated a terrorist organization by President Clinton in 1995 a...

Case 1:15-cv-07433 Document1 Filed 09/21/15 Page 5 of 12
document IMAGES-003-HOUSE_OVERSIGHT_015535.txt Dec 23, 2014 House Oversight Committee — Epstein Estate Records (Nov 2025)

…ping others who had also suffered from sexual trafficking and abuse. 24. On December 23, 2014, Giuffre incorporated an organization called Victims Refuse Silence, Inc., a Florida not-for-profit corporation. 25. Giuffre intended Victims Refuse Silence to change and improve the f...

Matthew J. Harrington
document IMAGES-004-HOUSE_OVERSIGHT_017079.txt House Oversight Committee — Epstein Estate Records (Nov 2025)

…ational Justice Mission (IJM) Bunge Limited Harvard Kennedy School Trends London Business School Japan External Trade Organization (JETRO) MasterCard Worldwide Permanent Mission of the People's Republic of China Telkom Group Limited EFG Hermes Holding Siemens AG LANXESS AG...

The Chinese government organizes and pays for exchanges in which participants travel
document IMAGES-006-HOUSE_OVERSIGHT_020583.txt House Oversight Committee — Epstein Estate Records (Nov 2025)

…s” by co-opted foreigners, which, stripped of its rhetoric, is indistinguishable from state-run espionage. Cooperation organizations and advocacy groups Many Sino-US S&T “cooperation” organizations in the United States facilitate these transfers and have individual memberships...

Influence Efforts after Establishing Official Relations, 1979-1988
document IMAGES-005-HOUSE_OVERSIGHT_020471.txt House Oversight Committee — Epstein Estate Records (Nov 2025)

…or such delegations has been the Chinese People’s Institute of Foreign Affairs (CPIFA).? Founded in December 1949, this organization focuses on international issues and foreign policy research and on conducting international exchanges of officials and expanding people-to-people d...

a notorious terrorist organization ... 91
document (a) Reasonable inference based on provision of support to al-Qaeda House Oversight Committee — Epstein Estate Records (Nov 2025)

a notorious terrorist organization ... 91