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Id. 1184; see also Decl. of Jodi Westbrook
document IMAGES-004-HOUSE_OVERSIGHT_017889.txt Dec 5, 1992 House Oversight Committee — Epstein Estate Records (Nov 2025)

…terjee). Mr. Batter- jee allegedly transferred control of BIF to Defendant Enaam M. Arnaout, on Septem- ber 15, 1997.28 Burnett Complaint 1183. In October 2001, Arnaout allegedly told Batterjee he was worried about being un- der scrutiny of the U.S. government and in January 2002...

1533, 1537 (S.D.N.Y.1983) (holding corre
document IMAGES-004-HOUSE_OVERSIGHT_017885.txt House Oversight Committee — Epstein Estate Records (Nov 2025)

…iss is therefore denied without prejudice. 7. Abdulrahman bin Mahfouz Abdulrahman bin Mahfouz is a Defen- dant in the Burnett action. He is the son of Defendant Khalid bin Mahfouz and a director of the Defendant charity Blessed Relief Society, also known as Muwaffaq. Burnett Co...

(Ashton Compl. ¶ 521; Burnett Compl. ¶ 268.) The Charity Initially Received Funding From Its Founders To Help Relocate 250
document (Ashton Compl. ¶ 521; Burnett Compl. ¶ 268.) The charity initially received funding from its founders to help relocate 250 House Oversight Committee — Epstein Estate Records (Nov 2025)

000 displaced refugees. (Ashton Compl. ¶ 522; Burnett Compl. ¶ 269.) Plaintiffs assert that Rabita Trust has actually relocated only a few hundred refugees. (Ashton Compl. ¶ 522; Burnett Compl. ¶ 269.)

Cite as 349 F.Supp.2d 765 (S.D.N.Y. 2005)
document IMAGES-004-HOUSE_OVERSIGHT_017862.txt Sep 11, 2001 House Oversight Committee — Epstein Estate Records (Nov 2025)

…ilburn v. Socialist People’s Libyan Arab Jamahiriya, 376 F.3d 1123 (D.C.Cir.2004), effectively overrules the holding in Burnett IT. See Kilburn, 376 F.3d at 1129 (evaluating a claim under § 1605(a)(7) and holding the requirement for jurisdictional causation was proximate cause)....

Cite as 349 F.Supp.2d 765 (S.D.N.Y. 2005)
document IMAGES-004-HOUSE_OVERSIGHT_017878.txt Sep 11, 2001 House Oversight Committee — Epstein Estate Records (Nov 2025)

…missed without prejudice the claims against Prince Sultan in his personal capacity for lack of person- al jurisdiction. Burnett I, 292 F.Supp.2d at 21-22. He rejected Plaintiffs’ argument that Prince Sultan had purposefully direct- ed his alleged activities at the United States....

nett I, 274 F.Supp.2d at 104. Proximate
document IMAGES-004-HOUSE_OVERSIGHT_017891.txt House Oversight Committee — Epstein Estate Records (Nov 2025)

… may be the natu- ral and probable consequence of knowingly and intentionally providing material sup- port to al Qaeda. Burnett [, 274 F.Supp.2d at 104. [72] Plaintiffs rely on theories of con- certed action liability—conspiracy and aid- ing and abetting—in support of this causa...

Mohammed Jamal Khalifa Headed Iiro’s Philippines Office
document Mohammed Jamal Khalifa headed IIRO’s Philippines office House Oversight Committee — Epstein Estate Records (Nov 2025)

which served as a center of terrorist financing and training. (Ashton Compl. ¶ 310; Burnett Compl. ¶ 234; Federal Compl. ¶¶ 135–36.) Khalifa collected and laundered money for al Qaeda through IIRO’s Phillipines office. (Ashton Compl. ¶ 316; Burnett Compl. ¶ 240.) Through Khalifa

The Burnett Plaintiffs Filed One Opposition Brief In Response To All Of The Saar Network Entities’ Motions
document The Burnett Plaintiffs filed one opposition brief in response to all of the SAAR Network entities’ motions House Oversight Committee — Epstein Estate Records (Nov 2025)

…e Ashton Plaintiffs filed a single opposition brief in response to IIIT’s and Mar–Jac Poultry’s motions to dismiss. The Burnett and Federal Plaintiffs filed separate briefs opposing Mar–Jac Poultry’s motions to dismiss.

Cite as 349 F.Supp.2d 765 (S.D.N.Y. 2005)
document IMAGES-004-HOUSE_OVERSIGHT_017848.txt Sep 11, 2001 House Oversight Committee — Epstein Estate Records (Nov 2025)

…urisdic- tional discovery where plaintiffs’ allega- tions lacked factual specificity to confer jurisdiction)); see also Burnett If, 292 F.Supp.2d at 15 (denying Plaintiffs’ re- quest for discovery from Prince Turki where “suggestions of [his] individual ac- tivity are only conclu...

Cite as 349 F.Supp.2d 765 (S.D.N.Y. 2005)
document IMAGES-004-HOUSE_OVERSIGHT_017860.txt Sep 11, 2001 House Oversight Committee — Epstein Estate Records (Nov 2025)

… disagreed and stated the FSIA “preserves immunity for tort claims unless injury or death occurs in the United States.” Burnett If, 292 F .Supp.2d at 19 n. 4 (quoting Tel-Oren v. Inbyan Arab Republic, 726 F.2d 774, 775 (D.C.Cir.1984)) (Edwards, J., concurring) (some emphasis omit...

The district court dismissed the Burnett ATA claim against Al Rajhi Bank. SPA55-57 (Terrorist Attack
document IMAGES-007-HOUSE_OVERSIGHT_023414.txt Sep 11, 2001 House Oversight Committee — Epstein Estate Records (Nov 2025)

…3, 4302-05, 4314-20, 4528-45. JA3870, 4528-45. JA3724-28, 3832-33, 4302-05, 4314-20. The district court dismissed the Burnett ATA claim against Al Rajhi Bank. SPA55-57 (Terrorist Attacks I). The district court also dismissed the remaining ATA claims against Al Rajhi Bank brough...

Cite as 349 F.Supp.2d 765 (S.D.N.Y. 2005)
document IMAGES-004-HOUSE_OVERSIGHT_017858.txt Sep 11, 2001 House Oversight Committee — Epstein Estate Records (Nov 2025)

…ternal citations omitted). [15] Judge Robertson determined that the commercial activity exception did not apply to the Burnett Plaintiffs’ claims against Prince Sultan and Prince Turki because “the act of contributing to a foun- dation is not within our ordinary under- standing...