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title: 'House Oversight: Estate Documents (Nov 12) (HOUSE_OVERSIGHT_017897)'
source: 'House Oversight: Estate Documents (Nov 12)'
sourceUrl: https://www.justice.gov/epstein
date: '2026-01-01'
category: House Oversight
eftaNumber: HOUSE_OVERSIGHT_017897
ocrPages: 1
ocrChars: 3055
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parseTier: external-legacy
engine: engine undisclosed (ep-nov-12.greg.technology mirror)
externalSource: greg-ep-nov-12
externalLicense: not granted
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externalUrl: https://ep-nov-12.greg.technology
832 349 FEDERAL SUPPLEMENT, 2d SERIES from Al Rajhi accounts. Id. In "December 1999, Al Rajhi directly funded Tulkarm Charity Committee, a known front for Ha- mas." Id. 971. Members of the Al Rajhi family, which owns and controls Al Rajhi Bank, are al- leged to have ties to Osama bin Laden's personal secretary. Id. 179. The Al Ra- Virginia. Id. 1480-84. Finally, Al Rajhi family members are allegedly closely asso- ciated with wealthy donors to Osama bin Id. 185 (alleging ties with the Golden Chain). Judge Robertson found that the only allegation in the Third Amended Burnett Complaint that stated a claim upon which relief could be granted was that Al Rajhi Bank acted as an instrument "of terror, in raising, facilitating and transferring money to terrorist organizations." Burnett I, 274 F.Supp.2d at 109 (quoting Burnett Com- plaint I46). Judge Robertson noted that there was no support "for the proposition Al Rajhi Bank argues that Plaintiffs of- fer no factual allegations in support of their conclusion that Al Rajhi Bank had to know that the charities it supported through Zakat and Hararm payments were really fronts for al Qaeda. Al Rajhi Bank contends it had a legal and religious duty to make its charitable donations and any terrorist activity by the recipient char- ities was unknown to Al Rajhi Bank. See Rule 12(e) Statement 11 26, 29. Contrary to Plaintiffs' arguments, Al Rajhi Bank submits it did not have a duty, or a right, to inspect the Defendant charities' finan- cial transactions to ascertain the ultimate destination of its donations. But see Rule 12(e) Statement 132 ("Al Rajhi is required to determine that the ultimate recipients of these contributions fall within one of the categories prescribed in the Quran for re- cipients of Zakat."). Al Rajhi Bank sub- mits that SAMA did not implement any duty to investigate Zakat payments after its meeting with representatives of the Na- tional Security Council and Office of For- eign Assets Control. that a bank is liable for injuries done with money that passes through its hands in the [95] Plaintiffs do not allege that Al form of deposits, withdrawals, check clear- Rajhi Bank provided direct material sup- ing services, or any other routine banking port to al Qaeda. Rather, Plaintiffs claim service." Id. In light of the liberal plead- Al Rajhi Bank aided and abetted the Sep- ing standards, however, Judge Robertson tember 11 terrorists by donating to certain denied Al Raihi Bank's motion to dismiss Defendant charities and acting as the bank and permitted it to request a more defini- for these Defendants. New York law and the courts interpreting the ATA in Boim make very clear that concerted action lia- 89-paragraph response on August 27, bility requires general knowledge of the primary actor's conduct. See Pittman, 149 F.3d at 123; Boim II, 291 F.3d at 1023; Boim III, 340 F.Supp.2d at 906. • Even 12(b)(6). 40. Under Islamic banking laws, Hararm is explain that al Qaeda takes advantage of th inder-regulated Islamic bankin® system te HOUSE_OVERSIGHT_017897