| --- |
| 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 |
| ocrElapsed: 0.0 |
| parseTier: "external-legacy" |
| engine: "engine undisclosed (ep-nov-12.greg.technology mirror)" |
| externalSource: "greg-ep-nov-12" |
| externalLicense: "not granted" |
| externalCredit: "ep-nov-12.greg.technology" |
| 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 |
|
|
