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Case 9:08-cv-80736-KAM Document 319-1 Entered on FLSD Docket 03/24/2015 Page 13 of
document IMAGES-002-HOUSE_OVERSIGHT_014096.txt Mar 24, 2015 House Oversight Committee — Epstein Estate Records (Nov 2025)

…solve the discovery issues presented in this motion (and others) as evidenced by the letter attached as Exhibit B. The Defendant has failed to respond as of the time of the filing of this motion. HOUSE_OVERSIGHT_014096

Dershowitz that we would then believe, in light of your ruling
document IMAGES-001-HOUSE_OVERSIGHT_011342.txt House Oversight Committee — Epstein Estate Records (Nov 2025)

…stand. And one of the reasons we have not proposed a redacted joinder motion, that showed up in a reply brief from the defendant, we didn't move to file a surreply with a possible motion. We think the best way to proceed, and we're happy to get guidance from your Honor, but onc...

*35 The Leaders Of The Mwl And Iiro Similarly Ensconced Well Known Bin Laden Associates As Senior Officials Of Those Organizations
document *35 The leaders of the MWL and IIRO similarly ensconced well known bin Laden associates as senior officials of those organizations House Oversight Committee — Epstein Estate Records (Nov 2025)

thereby providing al-Qaeda with an efficient mechanism to support its global expansion. Defendant Abdullah Naseef met personally with Osama bin Laden around the time of Al-Qaeda’s formation

The Direct Involvement Of Appellee Aqeel And Al Buthe In Orchestrating Al Haramain’s Terrorist Activities Was Also Well Documented. As Defendant Aqeel Himself Stated
document The direct involvement of Appellee Aqeel and al-Buthe in orchestrating al Haramain’s terrorist activities was also well documented. As defendant Aqeel himself stated House Oversight Committee — Epstein Estate Records (Nov 2025)

“[t]he [al Haramain branch] offices’ directors are employees who follow directions of the main office with regards to hiring workers at the offices and making any decisions on cooperation with any party.”42 In designating Aqeel as a terrorist in 2005

For Each Defendant
document For each defendant House Oversight Committee — Epstein Estate Records (Nov 2025)

plaintiffs’ detailed allegations focused on the knowing or reckless nature of the provision of support to al-Qaeda. The particular allegations set forth below are in addition to plaintiffs’ extensive allegations regarding the broader context of al-Qaeda’s use and development of a...

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.

Id. At 239 (Emphasis Added). The Court’s “More Likely Than Not” And “Reasonable Trier Of Fact” Requirements Are Inconsistent With Iqbal/ Twombly
document Id. at 239 (emphasis added). The court’s “more likely than not” and “reasonable trier of fact” requirements are inconsistent with Iqbal/ Twombly House Oversight Committee — Epstein Estate Records (Nov 2025)

which only require that a plaintiff plead facts that permit “the court to draw the reasonable inference that the defendant is liable for the misconduct alleged.” Iqbal

Cite as 349 F.Supp.2d 765 (S.D.N.Y. 2005)
document IMAGES-004-HOUSE_OVERSIGHT_017886.txt Sep 11, 2001 House Oversight Committee — Epstein Estate Records (Nov 2025)

… ladin, Omar Binladin, and Bakr Binladin The Ashton and Burnett complaints name the Saudi Binladin Group (““SBG”) as a Defendant. The Burnett complaint also names Tariq Binladin, Omar Binladin, and Bakr Binladin, Osama’s half-brothers, as Defendants. In both actions, these Defen...

tions that he knew they were funneling
document IMAGES-004-HOUSE_OVERSIGHT_017879.txt House Oversight Committee — Epstein Estate Records (Nov 2025)

…st- ment Company of the Gulf-Bahrain EC (“IICG”), and Faisal Islamic Bank—Sudan (“FIBS”), which are all shareholders of Defendant Al Shamal Islamic Bank.® Ash- ton Complaint 19151, 54; Federal Com- plaint 11307, 309, 473. They claim that Prince Mohamed knew or should have known t...

Saudi Royal family. Ashton Complaint
document IMAGES-004-HOUSE_OVERSIGHT_017851.txt House Oversight Committee — Epstein Estate Records (Nov 2025)

…action. In reviewing this declara- tion, the Court gives “great weight to any extrinsic submissions made by the foreign defendant[ ] regarding the scope of [his] official responsibilities.” Leutwyler, 184 F.Supp.2d at 287 (internal quotation marks omitted). Prince Turki explains...

Cite as 349 F.Supp.2d 765 (S.D.N.Y. 2005)
document IMAGES-004-HOUSE_OVERSIGHT_017890.txt Sep 11, 2001 House Oversight Committee — Epstein Estate Records (Nov 2025)

…terjee’s motion to dismiss the Bur- nett complaint for lack of personal jurisdic- tion is denied. IIT. In considering Defendants’ motions to dismiss for failure to state a claim under Rule 12(b)(6), the Court must “accept all of Plaintiffs’ factual allegations in the com- Fail...

Plaintiff was a witness in that case. She was deposed
document IMAGES-001-HOUSE_OVERSIGHT_011369.txt House Oversight Committee — Epstein Estate Records (Nov 2025)

…ional damages. Again, your Honor, I refer to the federal evidence treatise relied on by plaintiff. In defamation cases, defendants can also prove other liables and rumors about the claimant are circulating, at least if they are widespread, to demonstrate it is not what the defe...

The killing of John Lennon
document IMAGES-004-HOUSE_OVERSIGHT_017304.txt House Oversight Committee — Epstein Estate Records (Nov 2025)

…e based on Chapman’s mental state. He asked me to consult with him on the case, but I didn’t feel comfortable helping a defendant who had killed my former client. So I declined. Several years after Chapman was convicted, I happened to run into Yoko Ono at an art auction. I told...

2007 Utah L. Rev. 861, *916
document IMAGES-004-HOUSE_OVERSIGHT_017675.txt House Oversight Committee — Epstein Estate Records (Nov 2025)

…ck of grounds for subpoenas seeking victim information is more evident when viewed against a legal landscape that gives defendants no right before trial to obtain even the names of government witnesses. Current law provides no basis for the pretrial disclosure of the names and ad...