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BRAZILIAN COURT HOTEL AND CONDO · 67 White House Office of Management and Budget · 9 Robert Gold · 6 U.S. Securities and Exchange Commission · 5 Cowen and Company, LLC · 4 Securities and Exchange Commission · 4

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and in responding to the various motions to dismiss
document In presenting their substantive claims and theories of jurisdiction against the defendants House Oversight Committee — Epstein Estate Records (Nov 2025)

and in responding to the various motions to dismiss

In Their Submissions
document In their submissions House Oversight Committee — Epstein Estate Records (Nov 2025)

plaintiffs conceded that Terrorist Attacks III was dispositive as to the immunity defenses asserted by the Saudi Red Crescent Society (SRC) and Saudi Joint Relief Committee for Kosovo and Chechnya (SJRC)

and noted that the Circuit had employed its mini-en banc procedure
document The Court recognized that its holding conflicted with and abrogated the prior panel’s decision in Terrorist Attacks III House Oversight Committee — Epstein Estate Records (Nov 2025)

and noted that the Circuit had employed its mini-en banc procedure

The Direct Involvement Of Appellee Aqeel And Al Buthe In Orchestrating Al Haramain’s Terrorist Activities Was Also Well Documented. As Defendant Aqeel Himself Stated
document The direct involvement of Appellee Aqeel and al-Buthe in orchestrating al Haramain’s terrorist activities was also well documented. As defendant Aqeel himself stated House Oversight Committee — Epstein Estate Records (Nov 2025)

“[t]he [al Haramain branch] offices’ directors are employees who follow directions of the main office with regards to hiring workers at the offices and making any decisions on cooperation with any party.”42 In designating Aqeel as a terrorist in 2005

and Tadamon’s other shareholders included al Qaeda material sponsors FIBS
document *51 Tadamon and the DMI entities were similarly intertwined with al Qaeda’s leadership and other members of al Qaeda’s inner support circle. Osama bin Laden was himself a shareholder in Tadamon House Oversight Committee — Epstein Estate Records (Nov 2025)

and Tadamon’s other shareholders included al Qaeda material sponsors FIBS

In Determining That Plaintiffs’ Pleadings Were Conclusory And Inadequate
document In determining that plaintiffs’ pleadings were conclusory and inadequate House Oversight Committee — Epstein Estate Records (Nov 2025)

the district court misapplied fundamental legal principles governing the assessment of a complaint and related pleadings upon a motion to dismiss. It also dramatically understated or disregarded the scope

Plaintiffs’ Complaints Allege That Saudi American Bank Has Knowingly Provided Various Forms Of Material Support To Al Qaeda. For Example
document Plaintiffs’ complaints allege that Saudi American Bank has knowingly provided various forms of material support to al-Qaeda. For example House Oversight Committee — Epstein Estate Records (Nov 2025)

“Saudi American Bank knowingly provided material support and resources to al Qaida” by “finance [ing] many of the projects undertaken by Osama bin Laden and al Qaida in the Sudan during the years that the al Qaida leadership structure operated from that country ....” JA843-44

Plaintiffs Further Allege That “Saudi American Bank Facilit[Ated] Al Qaida’s Fundraising Efforts” By “Advertis[Ing] The Existence And Numerical Designation Of The Accounts It Maintain[Ed] For Those Charities Throughout The Muslim World
document Plaintiffs further allege that “Saudi American Bank facilit[ated] al Qaida’s fundraising efforts” by “advertis[ing] the existence and numerical designation of the accounts it maintain[ed] for those charities throughout the Muslim world House Oversight Committee — Epstein Estate Records (Nov 2025)

and provid[ing] a mechanism to allow al Qaida supporters to deposit funds directly into those accounts.” JA3844. These actions were alleged to have been done “[i]n cooperation with the charities operating within al Qaida’s infrastructure ....” JA3844. Also