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In Response To Defendants’ Motions Seeking Dismissal For Lack Of Personal Jurisdiction And/Or Subject Matter Jurisdiction And Under The Foreign Sovereign Immunities Act (Fsia)
document In response to defendants’ motions seeking dismissal for lack of personal jurisdiction and/or subject matter jurisdiction and under the Foreign Sovereign Immunities Act (FSIA) House Oversight Committee — Epstein Estate Records (Nov 2025)

plaintiffs supplemented their already detailed allegations record relevant to those jurisdictional disputes through extrinsic information and evidence filed in support of their oppositions to the Defendants’ motions to dismiss. These materials *12 included

Together With Abdullah Azzam
document Together with Abdullah Azzam House Oversight Committee — Epstein Estate Records (Nov 2025)

bin Laden founded the Maktab al Khidmat (“Office of Services”) to facilitate the provision of financial and logistic support to the mujahedeen.9 Throughout the Afghan jihad

*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

The Ata Is Directed At Preventing And Providing Recovery For Acts Of Material Support To Terrorism
document The ATA is directed at preventing and providing recovery for acts of material support to terrorism House Oversight Committee — Epstein Estate Records (Nov 2025)

broadly defined. Congress accomplished this purpose by “codify[ing] general common law tort principles and ... extend[ing] civil liability for acts of international terrorism to the full reaches of traditional tort law.” Boim v. Quranic Literacy Inst & Holy Land Found. for Relief...

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...

Al Rajhi Bank’s Operations Are Consistent With Their Support Of Al Qaeda Front Charities. In 1999
document Al Rajhi Bank’s operations are consistent with their support of al-Qaeda front charities. In 1999 House Oversight Committee — Epstein Estate Records (Nov 2025)

Al Rajhi Bank was warned by United States government officials “that their financial systems were being manipulated or utilized to fund terrorist organizations such as Al Qaeda.” SPA55 (Terrorist Attacks I); JA 2584-86; infra pp. 93-95. “Despite these warnings

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

*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

Since The September 11Th Attacks
document Since the September 11th Attacks House Oversight Committee — Epstein Estate Records (Nov 2025)

the Security Council has continued to condemn international terrorism and the provision of material support for terrorism and to assert that it poses a serious threat to peace and security. See

Robert Trivers Is An Evolutionary Biologist And Sociobiologist
document Robert Trivers is an evolutionary biologist and sociobiologist House Oversight Committee — Epstein Estate Records (Nov 2025)

who some consider to be one of the most influential evolutionary theorists alive today. Robert is one of the scientists who has received support from Jeffrey.

CNCConGon | El Brexit tambiA@n define el futuro del futbol ingl[A@s | 23 Jun 2016, 0 | neutral
document IMAGES-001-HOUSE_OVERSIGHT_011196.txt Jun 23, 2016 House Oversight Committee — Epstein Estate Records (Nov 2025)

CNCConGon | El Brexit tambiA@n define el futuro del futbol ingl[A@s | 23 Jun 2016, 0 | neutral gora https://t.co/aNAjri6x55 06:04 - CEST AnthonySwi | RT @Irelandbrexit: Great response from people of 23 Jun 2016, 16 | positive nhoe Sheffield today. If we can maximise our LEAVE tur...

Each partner giving each other explicit permission for "things to not be okay”
document IMAGES-005-HOUSE_OVERSIGHT_018656.txt House Oversight Committee — Epstein Estate Records (Nov 2025)

* Each partner giving each other explicit permission for "things to not be okay” afterwards * Having someone on hand that each partner can talk to afterwards -- not necessarily the same person for everyone involved. This person could be an observer, or might know everyone involv...