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See supra p. 56 n.89. The Golden Chain has also been used by the U.S. Treasury Department in designa
document IMAGES-007-HOUSE_OVERSIGHT_023398.txt Sep 11, 2001 House Oversight Committee — Epstein Estate Records (Nov 2025)

…ts. See supra p. 55 n.86. The district court committed further error by failing to credit plaintiffs’ allegations that DMI Trust, Dallah al Baraka, and Saleh Abdullah Kamel controlled their subsidiaries that provided material support to al-Qaeda. See SPA245, 247 (Terrorist Attac...

Cite as 349 F.Supp.2d 765 (S.D.N.Y. 2005)
document TEXT-001-HOUSE_OVERSIGHT_017830.txt Sep 11, 2001 House Oversight Committee — Epstein Estate Records (Nov 2025)

…aintiffs, with respect to his alleged donations, ‘‘[a]t best, Prince Sultan was grossly negligent in the oversight and administration of charitable funds, knowing they would be used to sponsor international terrorism, but turning a blind eye. At worse, Prince Sultan directly aide...

the recipients of their support advanced al-Qaeda’s activities -- despite plaintiffs’ detailed plead
document IMAGES-007-HOUSE_OVERSIGHT_023376.txt Sep 11, 2001 House Oversight Committee — Epstein Estate Records (Nov 2025)

…eals now focus on the dismissals for failure to state a claim of defendants Al Rajhi Bank, Saudi American Bank (SAMBA), DMI Trust, Kamel, and Dallah al Baraka, and the dismissals for lack of personal jurisdiction of defendants Abdullah bin Laden, Bakr bin Laden, Omar bin Laden, T...

The Plaintiffs’ Allegations Met This Standard. For Example
document The plaintiffs’ allegations met this standard. For example House Oversight Committee — Epstein Estate Records (Nov 2025)

plaintiffs allege that DMI Trust and DMI S.A. “directly participate in the oversight and management of DMI Trust’s subsidiary and associate entities.” JA4329. In addition

remaining defendants, who allegedly held more junior positions in foreign governments, was unclear.
document IMAGES-007-HOUSE_OVERSIGHT_023375.txt Sep 11, 2001 House Oversight Committee — Epstein Estate Records (Nov 2025)

…en, Bakr bin Laden, Omar bin Laden, Tariq bin Laden, Yeslam bin Laden, Dallah Avco Trans-Arabia Co. Ltd. (Dallah Avco), DMI Administrative Services, Faisal Islamic Bank, Saleh al Hussayen, Yousef Jameel, Abdulrahman bin Mahfouz, Khaled bin Mahfouz, National Commercial Bank (NCB),...

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)

…, SPA111-15 (SAMBA IN). See infra 82 n.113. SPA245 (Terrorist Attacks V). SPA246-47 (Terrorist Attacks V); SPA109-10 (DMI-Kamel); SPA59-60 (Terrorist Attacks J). SPA246-47 (Terrorist Attacks V); SPA109-10 (DMI-Kamel); SPA59-60 (Terrorist Attacks I). See infra pp. Point I.C (d...

from the founders and most senior officials of al-Qaeda’s partners in the financial industry, many o
document IMAGES-007-HOUSE_OVERSIGHT_023382.txt Sep 11, 2001 House Oversight Committee — Epstein Estate Records (Nov 2025)

…gnated by the United States under Executive Order 13224 based on its role in sponsoring al-Qaeda.” *31 Tadamon and the DMI entities were similarly intertwined with al Qaeda’s leadership and other members of al Qaeda’s inner support circle. Osama bin Laden was himself a sharehold...

” DMI Trust “directly and through its subsidiaries and affiliates
document The complaints allege that as one of the central banking entities used by Saudi Arabia beginning in the early 1980s to “channel[l massive financial support for the spread of ... the radical brand of Islam at the heart *87 of the al Qaida ideology House Oversight Committee — Epstein Estate Records (Nov 2025)

DMI Trust “directly and through its subsidiaries and affiliates

DMI and its affiliates and subsidiaries continued
document contributed to these charities was being used to support terrorist activities House Oversight Committee — Epstein Estate Records (Nov 2025)

DMI and its affiliates and subsidiaries continued

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)

…od that applies to these intentional torts. SPA232 n.6 (Terrorist Attacks V); SPA210 (Terrorist Attacks IV); SPA101-02 (DMI-Kamel); SPA87-88 (Terrorist Attacks I); SPA53 (Terrorist Attacks J) (citing Holmes v. Lorch, 329 F. Supp. 2d 516, 523 (S.D.N.Y. 2004)); N.Y. C.P.L.R. 215(3)...