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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
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engine: engine undisclosed (ep-nov-12.greg.technology mirror)
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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