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BRAZILIAN COURT HOTEL AND CONDO · 67 U.S. Attorney’s Office · 34 White House Office of Management and Budget · 9 Apollo Global Management · 8 U.S. Attorney's Office for the Southern District of Florida · 6 Ares Management L.P · 5

25,430 documents found

By The Day
document BY THE DAY House Oversight Committee — Epstein Estate Records (Nov 2025)

SO | WILL REPEAT MY PIECE AND PETER’S RESPONSE TO IT (IN

Contrary To The Defendants’ Tireless Efforts To Cast Plaintiffs’ Pleadings As Conclusory
document Contrary to the defendants’ tireless efforts to cast plaintiffs’ pleadings as conclusory House Oversight Committee — Epstein Estate Records (Nov 2025)

this Court commented in relation to a prior appeal in this *32 proceeding that plaintiffs’ allegations concerning the terrorist activities of the purported charities “include a wealth of detail (conscientiously cited to published and unpublished sources) that

*35 The Leaders Of The Mwl And Iiro Similarly Ensconced Well Known Bin Laden Associates As Senior Officials Of Those Organizations
document *35 The leaders of the MWL and IIRO similarly ensconced well known bin Laden associates as senior officials of those organizations House Oversight Committee — Epstein Estate Records (Nov 2025)

thereby providing al-Qaeda with an efficient mechanism to support its global expansion. Defendant Abdullah Naseef met personally with Osama bin Laden around the time of Al-Qaeda’s formation

All These Errors Were Evident In The Court’s Treatment Of The Ata Claims. Congress Intended The Ata To Provide Relief Broadly For U.s. Citizens Injured By An Act Of International Terrorism
document All these errors were evident in the court’s treatment of the ATA claims. Congress intended the ATA to provide relief broadly for U.S. citizens injured by an act of international terrorism House Oversight Committee — Epstein Estate Records (Nov 2025)

and the district court acknowledged that recovery could be predicated on the provision of material support to a terrorist organization such as al-Qaeda when the supporter knows the nature of the recipient. The court concluded

For Each Defendant
document For each defendant House Oversight Committee — Epstein Estate Records (Nov 2025)

plaintiffs’ detailed allegations focused on the knowing or reckless nature of the provision of support to al-Qaeda. The particular allegations set forth below are in addition to plaintiffs’ extensive allegations regarding the broader context of al-Qaeda’s use and development of a...

These Allegations And Al Qaeda’s Notorious Nature Make Plain The District Court’s Failure To Draw A Reasonable Inference That The Defendants Had The Requisite Mental State Of Knowingly Or Recklessly Advancing The Efforts Of A Terrorist Organization
document These allegations and al-Qaeda’s notorious nature make plain the district court’s failure to draw a reasonable inference that the defendants had the requisite mental state of knowingly or recklessly advancing the efforts of a terrorist organization House Oversight Committee — Epstein Estate Records (Nov 2025)

where the pleadings contained detailed allegations that they provided material support to al-Qaeda. A stark example is the district court’s failure to infer that Al Rajhi Bank knew or had reason to know that it was providing financial services to al-Qaeda

Sufficient Factual Allegations Of A Connection Between The Material Support Provided And The Acts Of Terrorism That Caused Plaintiffs’ Injuries
document sufficient factual allegations of a connection between the material support provided and the acts of terrorism that caused plaintiffs’ injuries House Oversight Committee — Epstein Estate Records (Nov 2025)

such that a reasonable trier of fact could conclude that it was more likely than not that the support provided by the defendant assisted the terrorists in the commission of the terrorist act.

Id. At 239 (Emphasis Added). The Court’s “More Likely Than Not” And “Reasonable Trier Of Fact” Requirements Are Inconsistent With Iqbal/ Twombly
document Id. at 239 (emphasis added). The court’s “more likely than not” and “reasonable trier of fact” requirements are inconsistent with Iqbal/ Twombly House Oversight Committee — Epstein Estate Records (Nov 2025)

which only require that a plaintiff plead facts that permit “the court to draw the reasonable inference that the defendant is liable for the misconduct alleged.” Iqbal

Kue
document KUE House Oversight Committee — Epstein Estate Records (Nov 2025)

THIS MEMORANDUM AND ANY INFORMATION FURNISHED IN CONNECTION HEREWITH

Of The Company
document OF THE COMPANY House Oversight Committee — Epstein Estate Records (Nov 2025)

THE GENERAL PARTNER AND THE TERMS OF THE OFFERING

Your Examination Of The Company
document YOUR EXAMINATION OF THE COMPANY House Oversight Committee — Epstein Estate Records (Nov 2025)

THE GENERAL PARTNER AND THE TERMS OF THIS

Information About The Company
document INFORMATION ABOUT THE COMPANY House Oversight Committee — Epstein Estate Records (Nov 2025)

THE GENERAL PARTNER AND THE UNITS TO VERIFY THE

Sophisticated Investors
document SOPHISTICATED INVESTORS House Oversight Committee — Epstein Estate Records (Nov 2025)

AND MAY NOT BE REPRODUCED OR USED FOR ANY OTHER

Of The Russian Federation
document OF THE RUSSIAN FEDERATION House Oversight Committee — Epstein Estate Records (Nov 2025)

AND HENCE THE UNITS ARE NOT ELIGIBLE FOR INITIAL