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Cite as 349 F.Supp.2d 765 (S.D.N.Y. 2005)

Dated September 11, 2001 Ref IMAGES-004-HOUSE_OVERSIGHT_017886.txt Release House Oversight Committee — Epstein Estate Records (Nov 2025) 1 pages

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IN RE TERRORIST ATTACKS ON SEPTEMBER 11, 2001 821 Cite as 349 F.Supp.2d 765 (S.D.N.Y. 2005) company is not sufficient to establish gen- eral personal jurisdiction over Mr. bin Mahfouz. Bersch, 519 F.2d at 998; see also Schenker, 2002 WL 1560788, at *8-5 (finding single bank account in United States constituting small fraction of defen- dant’s total assets is not a sufficient basis for personal jurisdiction). Mr. bin Mah- fouz’s motion to dismiss the Burnett com- plaint as against him for lack of personal jurisdiction is accordingly granted. 8. Saudi Binladin Group, Tariq Bin- ladin, Omar Binladin, and Bakr Binladin The Ashton and Burnett complaints name the Saudi Binladin Group (““SBG”) as a Defendant. The Burnett complaint also names Tariq Binladin, Omar Binladin, and Bakr Binladin, Osama’s half-brothers, as Defendants. In both actions, these Defen- dants move to dismiss the complaint or for a more definite statement. Based in Jeddah, Saudi Arabia, SBG is the successor to a construction company founded by Mohammed Binladin, the fa- ther of Osama bin Laden. Ashton Com- plaint 1543; Burnett Complaint 1311. It is now one of the largest engineering and construction companies in the Arab world and is managed by Osama bin Laden’s half brothers, including defendants Bakr Binladin, who runs SBG, and Tariq Binla- din, who holds a position on the board. Ashton Complaint 1545; Burnett Com- plaint 13138. Tariq Binladin allegedly had a prominent role at ITRO in 1990. Ashton Complaint 1557; Burnett Complaint 1326. Osama bin Laden purportedly used SBG to build an infrastructure in Afghani- stan. Ashton Complaint 19 546, 547; Bur- nett Complaint 11314316. After the So- viets withdrew from Afghanistan in 1989, Osama bin Laden returned to work with SBG in Jeddah. Ashton Complaint 1 548; Burnett Complaint 1317. SBG allegedly continued to support Osama bin Laden after he relocated to Sudan in 1991. Ash- ton Complaint 1548; Burnett Complaint 1317. For example, SBG, through two subsidiaries allegedly supported Osama bin Laden’s participation in the construc- tion of the Tahaddi road and Port Sudan Airport. Ashton Complaint 19550; 552, 553; Burnett Complaint 19319-3822. Plaintiffs claim Osama bin Laden’s name is still listed on SBG corporate records. Ashton Complaint 1558; Burnett Com- plaint 1329. Defendants dispute this and argue he was formally removed from SBG’s ownership documents in June 1993. SBG’s Mem. in Supp. of Motion to Dismiss Ashton Complaint at 2. Plaintiffs also claim that Osama bin Laden never “broke” with his family after he was exiled to Sudan and that SBG continued to provide him financial assistance and engineering support. Ashton Complaint 1549; Bar- nett Complaint 1318. Defendants also dispute this statement and argue that Bakr formally ostracized Osama from the family and the company in a February 1994 statement. SBG’s Mem. in Supp. of Motion to Dismiss Ashton Complaint at 2. SBG “sheltered and directly supported operatives of the al Qaeda terrorist organi- zation.” Ashton Complaint 1555; Burnett Complaint 1324. Mohammad Jamal Khal- ifa, allegedly a key al Qaeda operative, was taken in by a branch of SBG, the Mo- hammed Bin Laden Organization. Ashton Complaint 1555; Burnett Complaint 1324. The Mohammed Bin Laden Organization is allegedly a wholly-owned subsidiary of SBG and its board members include defen- dants Bakr, Tariq, and Omar Binladin. Ashton Complaint 1556; Burnett Com- plaint 91325. Khalifa listed the Mo- hammed Bin Laden Organization address on his visa application. Ashton Complaint 1555; Burnett Complaint 1324. Addition- ally, U.S.-designated terrorist Yassin Ab- dullah al-Kadi was allegedly introduced to HOUSE_OVERSIGHT_017886

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