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jurisdiction). “If a plaintiff has identified
document IMAGES-004-HOUSE_OVERSIGHT_017877.txt Mar 16, 2000 House Oversight Committee — Epstein Estate Records (Nov 2025)

812 jurisdiction). “If a plaintiff has identified a genuine issue of jurisdictional fact, juris- dictional discovery is appropriate even in the absence of a prima facie showing as to the existence of jurisdiction.” Daventree, 349 F.Supp.2d 7386 at 761, 2004 WL 2997881, at *20 (c...

present at the time of death or injury to recover under NIED. Bovsun, 61 N.Y.2d at 233. Here, plaint
document IMAGES-007-HOUSE_OVERSIGHT_023406.txt Sep 11, 2001 House Oversight Committee — Epstein Estate Records (Nov 2025)

… under NIED. Bovsun, 61 N.Y.2d at 233. Here, plaintiffs -- many of them the surviving family members of 9/11 victims -- allege that the defendants’ knowing material support of al-Qaeda was instrumental in allowing the organization to develop and perpetrate the 9/11 attacks, e.g.,...

something that isn’t there, they say, ahhh.” And that was before
document IMAGES-008-HOUSE_OVERSIGHT_025026.txt House Oversight Committee — Epstein Estate Records (Nov 2025)

… that was before YouTube, Google, and WikiLeaks. Indeed, an exclusive Newsweek—Daily Beast poll of 1,000 Egyptians reveals that, with the 10th anniversary of 9/11 approaching, a majority (53 percent) don’t believe that al Qaeda was responsible for the Twin Tower attacks, instead...

The Scowcroft Group
email IMAGES-009-HOUSE_OVERSIGHT_026827.txt Nov 14, 2015 House Oversight Committee — Epstein Estate Records (Nov 2025)

The Scowcroft Group 900 17th Street, NW * Suite 500 Washington, DC 20006 — www.scowcroft.com From: Kevin Nealer Date: November 14, 2015 Terrorism - Metrojet and Paris Mark Externalization of ISIS Threat It has been a consensus view in the US and Europe that the dangers pose...

Advisors: Secretary of State Hillary Clinton, Defense Secretary Leon
document IMAGES-011-HOUSE_OVERSIGHT_031956.txt House Oversight Committee — Epstein Estate Records (Nov 2025)

16 Advisors: Secretary of State Hillary Clinton, Defense Secretary Leon Panetta, National Security Advisor Thomas Donilon. On the issues: Afghanistan/Pakistan: "We have put al Qaeda on a path to defeat," Obama announced last June, noting that the 33,000 "surge" troops he sent...

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)

…)) (Edwards, J., concurring) (some emphasis omitted). Courts in the Second Circuit seem to take the opposite approach. “Although cast in terms that may be read to require that only the injury rather than the tortious acts occur in the United States, the Supreme Court has held tha...

designations of Aqeel Al Aqeel and Al Haramain Islamic Foundation); R.977, Ex. E, p. 4 (August 2002
document IMAGES-007-HOUSE_OVERSIGHT_023410.txt Sep 11, 2001 House Oversight Committee — Epstein Estate Records (Nov 2025)

…ST ATTACKS ON SEPTEMBER 11, 2001., 2012 WL 257568 (2012) 20 21 22 23 24 25 26 27 28 29 designations of Aqeel Al Aqeel and Al Haramain Islamic Foundation); R.977, Ex. E, p. 4 (August 2002 FBI Report -- Interview with former Al Qaeda member Jamal Al Fadl); R.277, Ex. 6,...

In re Terrorist Attacks on September 11, 2001, 392 F.Supp.2d 539 (2005)
document IMAGES-004-HOUSE_OVERSIGHT_017915.txt Sep 11, 2001 House Oversight Committee — Epstein Estate Records (Nov 2025)

In re Terrorist Attacks on September 11, 2001, 392 F.Supp.2d 539 (2005) 10 A.L.R. Fed. 2d 789 455, 463; see also Federal RICO Statement Applicable to Saudi Princes at Ex. A.) The Federal Plaintiffs claim Prince Salman “fully intended [SHC] would serve as a vehicle for funding a...

mainly banks in Arab and Islamic coun
document IMAGES-004-HOUSE_OVERSIGHT_017901.txt House Oversight Committee — Epstein Estate Records (Nov 2025)

836 mainly banks in Arab and Islamic coun- tries. Ashton Complaint 1583; Burnett Complaint 147. It also has banks in Chi- cago, Illinois and Houston, Texas. Bur- nett Complaint 147. Al Baraka allegedly provided financial infrastructures in Sudan to Osama bin Laden through Defend...

This attitude shift proved universal across the region. Iraq was almost
document IMAGES-008-HOUSE_OVERSIGHT_025025.txt House Oversight Committee — Epstein Estate Records (Nov 2025)

29 This attitude shift proved universal across the region. Iraq was almost never mentioned, nor was 9/11 or al Qaeda, and rather than rail at what America had imposed on them, the young Arabs instead criticized how America reacted to them. (President Obama’s failure to support E...

need remains what I tried to impress on my negotiators then: realism. A
document IMAGES-009-HOUSE_OVERSIGHT_027860.txt House Oversight Committee — Epstein Estate Records (Nov 2025)

need remains what I tried to impress on my negotiators then: realism. A meticulously informed, utterly unvarnished, understanding of the threats we face, of each altered situation after every success or a failure, and an ability to set aside the background noise and political pre...