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Saudi Royal family. Ashton Complaint
1261; Burnett Complaint 1348. Plaintiffs
allege Prince Turki facilitated money
transfers from wealthy Saudis to the Tali-
ban and al Qaeda. Ashton Complaint
1259; Federal 1451. Additionally, the
Federal Plaintiffs claim that, while Prince
Turki was the head of DGI, Saudi Arabian
intelligence officers allegedly trained a
member of the al Qaeda Spanish cell in
explosives and provided material support
to two of the September 11 hijackers.
Federal Complaint 1449. The Federal
complaint also alleges that Prince Turki
made personal contributions to Saudi-
based charities that he knew were spon-
sors of al Qaeda, including IIRO, MWL,
WAMY, BIF, the Saudi High Commission,
Saudi Joint Relief Committee for Kosovo
and Chechnya (“SJRC”), and Al Hara-
main. Federal Complaint 11 451-52.
[9] Prince Turki denies the allegations
against him in a declaration prepared in
concert with his motion to dismiss the D.C.
Burnett action. In reviewing this declara-
tion, the Court gives “great weight to any
extrinsic submissions made by the foreign
defendant[ ] regarding the scope of [his]
official responsibilities.” Leutwyler, 184
F.Supp.2d at 287 (internal quotation marks
omitted). Prince Turki explains that the
DGI “is involved in the collection and anal-
ysis of foreign intelligence and in carrying
out foreign operations.” Decl. of HRH
Prince Turki 15, at HRH Prince Turki’s
Motion to Dismiss Certain Consolidated
Complaints Ex. 1 (hereinafter “Prince
Turki Decl.”). He was active in Saudi
Arabia’s efforts to combat terrorism gen-
erally and the threat posed by Osama bin
Laden and al Qaeda specifically, and
served on a joint information-sharing com-
mittee with the United States beginning in
1997. fd. 196, 10. He states that all of
his interactions with Osama bin Laden and
the Taliban were part of his official func-
349 FEDERAL SUPPLEMENT, 2d SERIES
tions. Jd. 15. In June 1998, King Fahd
sent Prince Turki to Kandahar to meet
with the Taliban and to relay the official
Saudi request that Osama bin Laden be
extradited to Saudi Arabia for trial. Id.
111. The Taliban denied the Saudi re-
quest and Saudi Arabia subsequently sus-
pended diplomatic relations with the Tali-
ban in September 1998. Jd. 113. Prince
Turki denies facilitating money transfers
to Osama bin Laden or al Qaeda, he denies
offering material assistance to Osama bin
Laden, his representatives, or al Qaeda in
return for their not attacking Saudi Ara-
bia, he denies promising or providing oil or
financial assistance to the Taliban, and de-
nies ever hearing of the Syrian financier
Mr. Zouaydi, with whom he is alleged to
have ties. Jd. 1914, 16, 17.
3. Kingdom of Saudi Arabia
The Federal Plaintiffs claim that “[mlore
than any other factor, al Qaida’s phenome-
nal growth and development into a sophis-
ticated global terrorist network were made
possible by the massive financial, logistical
and other support it received from the
Kingdom of Saudi Arabia, members of the
Saudi Royal family, and prominent mem-
bers of Saudi society.” Federal Complaint
91398. Further, the Federal Plaintiffs al-
lege September 11 was “a direct, intended
and foreseeable product of the Kingdom of
Saudi Arabia’s participation in al Qaida’s
jihadist campaign.” Jd. 1425. Specifical-
ly, the Kingdom allegedly maintained and
controlled several of the charities within al
Qaeda’s infrastructure. Id. 1399. The
Federal Plaintiffs claim Saudi Arabia knew
the threat that these charities posed par-
ticularly to the United States, and did
nothing to stop it. Jd. 19400-02. The
Kingdom allegedly used its relationship
with the Taliban to sustain al Qaeda in the
mid-1990s. /d. 19408, 407. To the extent
the Federal Plaintiffs rely on actions by
members of the Saudi Royal family as
allegations against the Kingdom, they
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