| --- |
| title: "House Oversight: Estate Documents (Nov 12) (HOUSE_OVERSIGHT_017883)" |
| source: "House Oversight: Estate Documents (Nov 12)" |
| sourceUrl: "https://www.justice.gov/epstein" |
| date: "2026-01-01" |
| category: "House Oversight" |
| eftaNumber: "HOUSE_OVERSIGHT_017883" |
| ocrPages: 1 |
| ocrChars: 3620 |
| 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" |
| --- |
| |
| 818 |
| 349 FEDERAL SUPPLEMENT, 2d SERIES |
| 5-7. He has never supported any person ni's companies is a supporter of Al-Waqf |
| or organization that he has known to par- al-Islami Foundation, a Dutch entity whose |
| ticipate in any terrorist attacks. Id. 19. |
| seminars "have drilled extremist messages |
| Mr. Al-Husani submits that Plaintiffs can- |
| into the heads of thousands of young Mus- |
| not cure the lack of allegations in the |
| lims." "Radical Foundation: In "Law' |
| complaint in its motion papers. Wright v. |
| Seminars, A Saudi Group Spreads Ex- |
| Ernst & Young, LLP, 152 F.3d 169, 178 |
| tremism," Wall St. J., Apr. 15, 2003, at |
| (2d Cir.1998) explaining a party is not |
| Bierstein Aff. Ex. 6. |
| permitted to amend its complaint through |
| [641 Plaintiffs have not established a |
| allegations made in motion papers). |
| prima facie showing of jurisdiction over |
| Mr. Al-Husani also claims that he was |
| Mr. Al-Husani to survive his motion to |
| not properly served because The Interna- |
| dismiss or warrant jurisdictional discovery. |
| tional Herald Tribune has a circulation of The "Golden Chain" does not say what the |
| only 199 in Saudi Arabia and is published |
| Plaintiffs argue it says. It is only a list of |
| in English, and Al Quds Al Arabia is a |
| names found in a charity's office. It does |
| London-based paper banned in the King- |
| not establish Mr. Aljomaih's involvement |
| dom. |
| Even if service was proper, howev- |
| in a terrorist conspiracy culminating in the |
| er, Mr. Al-Husani submits this Court does |
| September 11 attacks and it does not dem- |
| not have personal jurisdiction over him. |
| onstrate that he purposefully directed his |
| The Burnett Plaintiffs claim that Mr. |
| activities at the United States. According- |
| Al-Husani is also implicated by the "Gold- |
| ly, Mr. Al-Husani's motion to dismiss the |
| en Chain," |
| and thus an early supporter of |
| Burnett complaint against him is granted. |
| al Qaeda. |
| Plaintiffs' Opp. to Al-Husani |
| 6. NCB |
| Motion to Dismiss at 10; Bierstein Aff. at |
| Ex. 2 (document listing "Hamad Al Husai- |
| The Court outlined the Ashton and Bur- |
| ni," without indicating when list was writ- |
| nett Plaintiffs' claims against NCB in Part |
| ten, by whom, or for what purpose). The |
| I.B.4. For purposes of the personal juris- |
| Plaintiffs place great weight on the United |
| diction analysis, the Court will assume at |
| States' inclusion of the "Golden Chain" in |
| this point that the FSIA does not provide |
| its proffer of evidence in United States v. |
| for subject matter and personal jurisdic- |
| Arnaout, the government's case against an |
| tion over NCB. Accordingly, the Plaintiffs |
| executive of Defendant charity BIF. See |
| will have to make a prima facie showing to |
| Bierstein Aff. at Ex. 1 (proffer). The |
| survive NCB's motion to dismiss. In that |
| court presiding over that case, however, |
| vein, Plaintiffs argue that NCB purpose- |
| ruled that the document was inadmissible |
| fully directed its activities at the United |
| hearsay. United States v. Arnaout, No. |
| States and participated in a conspiracy |
| that culminated in the attacks of Septem- |
| ber 11. |
| Plaintiffs submit NCB has many con- |
| Al-Husani purposefully directed his activi- |
| tacts with the United States, including a |
| ties toward the United States, making the |
| wholly-owned subsidiary in New York City |
| exercise of personal jurisdiction appropri- through which it operates an international |
| ate. See, e.g. Bierstein Aff. Exs. 9-15 |
| banking business. See, e.g., Aff. of John |
| (detailing al Qaeda's hatred for and actions |
| Fawcett in Support of Ashton Plaintiffs' |
| against the United States). Additionally, |
| Opp. to NCB's Motion to Dismiss (herein- |
| Plaintiffs claim that one of Mr. Al-Husa- |
| after "Fawcett Aff.") 13, Exs. 2 & 3. NCB |
| HOUSE_OVERSIGHT_017883 |
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