| --- |
| title: "House Oversight: Estate Documents (Nov 12) (HOUSE_OVERSIGHT_017914)" |
| source: "House Oversight: Estate Documents (Nov 12)" |
| sourceUrl: "https://www.justice.gov/epstein" |
| date: "2026-01-01" |
| category: "House Oversight" |
| eftaNumber: "HOUSE_OVERSIGHT_017914" |
| ocrPages: 1 |
| ocrChars: 5031 |
| 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" |
| --- |
| |
| In re Terrorist Attacks on September 11, 2001, 392 F.Supp.2d 539 (2005) |
| 10 A.L.R. Fed. 2d 789 |
| Countries v. Republic of South Africa, 300 F.3d 230, 241 |
| (2d Cir.2002) (quoting Cargill Int'/ S.A. v. M/T PAVEL |
| DYBENKO, 991 F.2d 1012, 1016 (2d Cir.1993)). "Then, |
| F.3d at 241 (quoting Cargill, 991 F.2d at 1016); see also |
| Terrorist Attacks I, 349 F.Supp.2d at 792-797 (explaining |
| that the possibly relevant exceptions to immunity in this |
| litigation include the commercial activities, torts, and |
| state sponsor of terrorism exceptions). Determining |
| whether this burden is met involves a review [of the |
| allegations in the complaint, the undisputed facts, if any, |
| placed before [the court] by the parties, and—if the |
| plaintiff comes forward with sufficient evidence to carry |
| its burden of production on this issue-[resolution of] |
| disputed issues of fact.' " Virtual Countries, 300 F.3d at |
| 241 (quoting Robinson, 269 F.3d at 141). Throughout the |
| inquiry, Defendants retain the burden of persuasion, |
| which they must meet by a preponderance of the |
| evidence. Virtual Countries, 300 F.3d at 241; see also |
| Robinson, 269 F.3d at 141 n. 8. |
| SHC's financial records fail to account for $41 million. |
| (Ashton Compl. T 456; Burnett Compl. T 407; Federal |
| Compl. 4 460.) SHC allegedly made donations to charity |
| Defendant Taibah and the bin Laden Establishment. |
| (Ashton Compl. 1T 376, 462 (relying on 1995 bin Laden |
| interview); Burnett Compl. T 298.) Plaintiffs also claim |
| that SHC is responsible for "importing the extreme form |
| of Saudi Islam, Wahhabism" to Bosnia. (Ashton Compl. T |
| 447; Burnett Compl. { 393.) |
| The Federal Plaintiffs allege that al Qaeda fighters began |
| entering Bosnia-Herzegovina in 1992 disguised as SHC |
| relief workers. (Federal Compl. T 183.) On October 21, |
| 2001, a group of Algerians who were supposedly part of |
| the al Qaeda network were arrested in |
| Herzegovina on charges of terrorism directed at the |
| United States embassy. (Ashton Compl. IT 448-49; |
| Burnett Compl. 41 394-95.) One of the arrested, Sabir |
| Lamar, apparently worked for SHC as an Arabic language |
| teacher. (Ashton Compl. T 450; Burnett Compl. T 396.) |
| Also in October 2001, Plaintiffs claim that United States |
| forces raided the Sarajevo branch of SHC and "found |
| computer hard drives with photographs of the World |
| Trade Center before and after its collapse as well as |
| photos of United States embassies in Kenya and Tanzania |
| and the U.S.S. Cole." (Ashton Compl. T 451; Burnett |
| Compl. T 397; Federal Compl. I T 186, 458.) The U.S. |
| forces also apparently found files on pesticides and crop |
| dusters, the locations |
| of Washington government |
| buildings, fake State Department badges, and cash. |
| (Ashton Compl. 11 451, 453; Burnett Compl. IT 397, 399; |
| Federal Compl. IT 186, 459.) After the raid, the Financial |
| Police of the Federation of Bosnia Herzegovina Ministry |
| of Finance analyzed the seized documents and stated that |
| some did "not belong in the scope of work of a |
| humanitarian organization." (Federal Compl. 11 187, 459; |
| see also Ashton Compl. T 452; Burnett Compl. 1 398.) |
| The Federal Plaintiffs claim that the SHC "has long acted |
| as a fully integrated component of al Qaida's logistical |
| and financial support infrastructure ... [and that the attacks |
| of September 11 were] a direct, intended and foreseeable |
| product of [its] participation in al Qaida's jihadist |
| campaign." (Federal Compl. 1T 182, 189.) |
| A. Allegations Against Defendants Asserting |
| Foreign Sovereign Immunity |
| 1. Saudi High Commission! |
| President of the Council of *548 Ministers of Saudi |
| Saudi High Relief Commission, by High Order 17419. |
| (Ashton Compl. T 446; Burnett Compl. T 392; Federal |
| Compl. 4 180; see also SHC Mem. in Sup. Mot. to |
| Dismiss at 3.) The same High Order named Defendant |
| Prince Salman the President of SHC. (Ashton Compl. T |
| 446; Burnett Compl. T 392; SHC Mem. in Sup. Mot. to |
| Dismiss at 3. |
| SHC allegedly has contributed $600 million to aid |
| "Bosnian Muslims impoverished by the country's recent |
| civil war." (Ashton Compl. 9 446; Burnett Compl. 1 392.) |
| Plaintiffs claim, however, that SHC does not provide |
| support to the needy but actually diverts funds for terrorist |
| activities. (Ashton Compl. 9 454; Burnett Compl. ° 404.) |
| *549 2. Prince Salman? |
| In support, Plaintiffs allege that Prince Salman received a |
| Prince Salman is a member of the Kingdom of Saudi |
| letter in September 2000 from a Bosnian association |
| Arabia's Council of Ministers, the governor of the |
| claiming SHC did not provide charitable assistance, and |
| province of Riyadh, and the President of Defendant SHC. |
| that none of the money collected after the fall of |
| (Prince Salman Mem. in Sup. Mot. to Dismiss at 2.) |
| Srebrenica in July 1995 actually reached the Srebrenican |
| Plaintiffs allege that Prince Salman provided material |
| people. (Ashton Compl. 19 454-55; Burnett Com pl. 11 |
| support to Osama bin Laden and al Qaeda. (Ashton |
| 404-05; Federal Compl. 11 185, 457.) Plaintiffs claim |
| Compl. T 255; Burnett Compl. T 403; Federal Compl. TT |
| WESTLAW © 2019 Thomson Reuters. No claim to original U.S. Government Works. |
| HOUSE_OVERSIGHT_017914 |
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