Obaid Nadani Decl. 12 at Notice of HRH

784 Obaid Nadani Decl. 12 at Notice of HRH Prince Sultan Bin Abdulaziz al-Saud’s Mo- tion to Dismiss Certain Consolidated Com- plaints Ex. 1 (hereinafter “Nadani Decl.”’); Consolidated Jeffress Decl. 14; Federal Complaint 1427; Sultan Bio. As such, he is the third-highest ranking member of the Saudi government. Especially relevant here, Prince Sultan is the Chairman of the Supreme Council of Islamic Affairs, which was established in 1995 and is responsible for the Kingdom’s Islamic policy abroad. Consolidated Jef- fress Decl. 15; Ashton Complaint { 265; Federal Complaint 1427. Prince Sultan disagrees with Plaintiffs’ claim that the Supreme Council monitors and approves domestic and foreign charitable giving on behalf of the Kingdom. Prince Sultan pre- fers the characterization that the Supreme Council “carr[ies] out the foreign policy of Saudi Arabia as determined by the Council of Ministers.” Abdulaziz H. Al-Fahad Decl. 15, at Sara E. Kropf Decl. Ex. 2. Finally, Prince Sultan, as the head of the Special Committee of the Council of Minis- ters, which is a foreign policy advisory resource for King Saud, exercises authori- ty over disbursements by the Special Com- mittee. Consolidated Jeffress Decl. 16. In the past, these disbursements, which are government funded, have included grants to Islamic charities. /d. at 16. The various complaints make substan- tially similar accusations against Prince Sultan. See Consolidated Jeffress Decl. 16. IIRO is allegedly an al Qaeda front that has been tied to the 1993 World Trade Center attack and the 1998 embassy bombings. See, e.g., Burnett Complaint 11 156, 240, 242. 17. Beginning in 2002, certain branches of Al Haramain were designated by the United States as terrorist organizations. See Exec. Order No. 13224, 31 C.F.R. 595, available at http://www.treas.gov/offices/enforce- ment/ofac/sanctions/tl lter.pdf (hereinafter “Exec. Order No. 13224’). Judge Robertson 349 FEDERAL SUPPLEMENT, 2d SERIES Ex. C (summarizing allegations against Prince Sultan in consolidated complaints). Prince Sultan is alleged to have met with Osama bin Laden after Iraq invaded Ku- wait in the summer of 1990. Ashton Com- plaint 1253; Burnett Complaint 1340. At that meeting, which Prince Turki also at- tended, bin Laden purportedly offered his family’s support to Saudi military forces. Ashton Complaint 1253. Plaintiffs allege that, at the time of the Gulf War, Prince Sultan “took radical stands against west- ern countries and publicly supported and funded several Islamic charities that were sponsoring Osama bin Laden and al Qaeda operations.” Ashton Complaint 1266; Burnett Complaint 1353. After the at- tacks of September 11, Prince Sultan alleg- edly advocated against granting the Unit- ed States use of Saudi military bases to stage attacks against Afghanistan. Ash- ton Complaint 1273; Burnett Complaint 1 356. Prince Sultan allegedly made personal contributions, totaling $6,000,000 since 1994, to various Islamic charities that Plaintiffs claim sponsor or support al Qae- da. Ashton Complaint 1269; Burnett Complaint 1359; Federal Complaint { 430. The specific charities that Prince Sultan donated to include Defendants Internation- al Islamic Relief Organization (“IIRO”),'* Al Haramain,'” Muslim World League (““MWL”)," and the World Assembly of Muslim Youth “WAMY”).! Ashton Com- denied Al Haramain’s motion to dismiss the Burnett action. Burnett I, 274 F.Supp.2d at 107. 18. MWL is the parent of IIRO. See, e.g., Bur- nett Complaint {| 236. 19. WAMY is a suspected al Qaeda front, alleg- edly “preaching good ... while plotting evil,” connected to charity Defendant Benevolence International Foundation (“BIF’). BIF is now a designated terrorist, but it previously concealed its relationship with Osama bin HOUSE_OVERSIGHT_017849