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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

The Plaintiffs Also Provided Sufficient Allegations Connecting The Defendants To The Center Of Al Qaeda’s Network Of Terrorism
document The plaintiffs also provided sufficient allegations connecting the defendants to the center of al-Qaeda’s network of terrorism House Oversight Committee — Epstein Estate Records (Nov 2025)

and individuals in the midst of al-Qaeda’s network are more likely to be part of al-Qaeda and at least well placed to know the nature of its activities. See Al-Adahi v. Obama

*118 In Addition
document *118 In addition House Oversight Committee — Epstein Estate Records (Nov 2025)

the inference that support for al-Qaeda in the early and mid 1990s contributed to al-Qaeda’s capabilities and terrorist activities only a few years later