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In re Terrorist Attacks on September 11, 2001, 392 F.Supp.2d 539 (2005)
10 A.L.R. Fed. 2d 789

455, 463; see also Federal RICO Statement Applicable to
Saudi Princes at Ex. A.) The Federal Plaintiffs claim
Prince Salman “fully intended [SHC] would serve as a
vehicle for funding and supporting Islamic militants in
Bosnia, including elements of the al Qaida movement.”
(Federal Compl. ¶ 456.) “Prince Salman knowingly failed
to take appropriate actions regarding the management and
use of funds of the SHC in Bosnia.” (Ashton Compl. ¶
457; Burnett Compl. ¶ 406.) On December 30, 2000, the
Embassy of the State of Palestine in Riyadh sent Prince
Salman a letter expressing Yasser Arafat’s concern
regarding the funding of radical organizations in
Palestine. (Ashton Compl. ¶ 291; Burnett Compl. ¶ 402.)
Further, Plaintiffs claim Prince Salman “has a history of
funding Islamic extremism,” because he was named the
Chairman of the General Donation Committee for
Afghanistan in 1980, which gave $39 million to aid the
Afghan mujahideen. (Ashton Compl. ¶ 289; Burnett
Compl. ¶ 400.)

In 1994, Prince Salman allegedly stated that he had
personally raised more than six million Saudi Riyals for
Defendant IIRO and Sanabel al-Kheer. (Federal Compl. ¶
462.) And in 1998, he allegedly donated one million
Saudi Riyals during a fundraising drive by IIRO and
Sanabel al-Kheer. (Federal Compl. ¶ 461.) In 1999,
Prince Salman donated $400,000 during a fundraising
event organized by charity Defendants IIRO, World
Assembly of Muslim Youth (“WAMY”), and
Al–Haramain Foundation for the benefit of Bosnia
Herzegovina and Chechnya. (Ashton Compl. ¶ 290;
Burnett Compl. ¶ 401; Federal Compl. ¶ 461.) Finally,
Plaintiffs claim that members of the Saudi royal family
have assets and do business in the United States. (Ashton
Compl. ¶ 296.)

3. Prince Naif³
Prince Naif has been the Minister of Interior of the
Kingdom of Saudi Arabia since 1975. (Ashton Compl. ¶
286; Federal Compl. ¶ 433; Prince Naif Mem. in Supp.
Mot. to Dismiss at 1, 5.) According to Plaintiffs, the
Minister of Interior “controls the activities of Islamic
Charities and is empowered to verify their legality and
conduct.” (Ashton Compl. ¶ 286; Burnett Compl. ¶ 382;
see also Federal Compl. ¶ 435 (alleging that as Minister
of Interior Prince Naif is “responsible for the oversight of
charities based within Saudi Arabia, including the
operations of the Saudi Joint Relief Committee [ (‘SJRC’)
], Muslim World League [ (‘MWL’) ], IIRO, Saudi Red
Crescent, WAMY, and al Haramain Foundation”).) He is
also a member of the Council of Ministers and serves on
the Supreme Council for Islamic Affairs. (Plaintiff’s

Mem. in Opp’n to Prince Naif’s Mot. at 2–3, 5.)

Plaintiffs claim that “Prince Naif has engaged in a pattern
of conduct that aids, abets, and materially sponsors
international terrorism and Al Qaeda.” (Ashton Compl. ¶¶
288, 255; Burnett Compl. ¶¶ 342, 381; Federal Compl. ¶
434; see also Federal RICO Statement Applicable to
Saudi Princes at Ex. A.) They claim that along with other
Saudi princes, Prince *550 Naif made “monetary payoffs
to Osama bin Laden’s al Qaeda.” (Ashton Compl. ¶ 288;
Burnett Compl. ¶ 381.) “In 1996, according to various
intelligence sources, a group of Saudi princes ... met in
Paris and agreed to continue contributing, sponsoring,
aiding and abetting Osama bin Laden’s terrorist network.”
(Burnett Compl. ¶ 347.) Plaintiffs claim that Prince Naif
and the Saudi government received warnings from the
United States and France that charitable donations to
Islamic charities were being used to fund terrorism. (See
Plaintiffs’ Mem. in Opp’n to Naif’s Mot. to Dismiss at 5.)
Prince Naif was present for one such meeting in 1994
with French Interior Minister Charles Pasqua. (Id.) The
Federal Plaintiffs allege that Prince Naif has used his
position as the Minister of Interior to “protect al Qaida’s
support infrastructure.” (Federal Compl. ¶ 438.)

The Federal complaint further alleges that “[b]etween
1998 and 2000, the Kingdom of Saudi Arabia, through
SJRC, diverted more than $74 million to al Qaida
members and loyalists affiliated with SJRC bureaus.
Throughout this time, [SJRC] was under the supervision
and control of ... Prince Naif.” (Federal Compl. ¶¶ 126,
436.) “Prince Naif also heads the Saudi Committee for
Relief to Afghans, ... [i]n this position, Prince Naif has
channeled substantial financial and logistical support to
sustain al Qaida’s presence and operations in
Afghanistan.” (Id. ¶ 437.) Plaintiffs allege that Prince
Naif is the “Chairman of the Saudi Arabian Committee
for Support of the Intifada al Quds, [which] knowingly
transferred large sums of money to the families of Hamas
terrorists who had executed murderous attacks against
Israelis.” (Ashton Compl. ¶ 287; Burnett Compl. ¶ 379;
Federal Compl. ¶ 439; see also Burnett Compl. ¶ 380
(citing letter written on behalf of Yasser Arafat and
claiming this committee funds radical groups).) As a
result, Plaintiffs assert that “Prince Naif ... supports
suicide martyrs.” (Ashton Compl. ¶ 287; Burnett Compl. ¶
379.) The Federal Plaintiffs also allege that in 2003, U.S.
Senator Charles Schumer asked that Prince Naif be
replaced as Interior Minister because of his
“well-documented history of supporting terrorist
financing and ignoring the evidence when it comes to
investigating terrorist attacks on Americans.” (Federal
Compl. ¶ 441.) Finally, the Federal Plaintiffs claim
Prince Naif made significant personal contributions to

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