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IN RE TERRORIST ATTACKS ON SEPTEMBER 11, 2001 815
Cite as 349 F.Supp.2d 765 (S.D.N.Y. 2005)

ton Plaintiffs bolster their arguments for
personal jurisdiction by citing to para-
graphs in the complaint in support of each
of the requirements for conspiracy. See
Chrysler Capital Corp., 778 F.Supp. at
1268–69 (outlining cause of action for con-
spiracy).

Plaintiffs claim that Prince Mohamed
and al Qaeda agreed to injure the United
States through acts of international terror-
ism. Ashton Complaint ¶¶ 5, 23 (all defen-
dants are co-conspirators), 51, 105–08
(February 1993 World Trade Center
bombing), 120 (February 1998 fatwa), 130–
36 (1998 embassy bombings), 152–55
(U.S.S. Cole attack), 188, 255, 274–76, 580
(September 11, 2001 attacks); see also
Federal Complaint ¶¶ 66, 72–74 (listing de-
fendants who have “aided and abetted,
conspired with, and provided material sup-
port and resources to, defendant al Qaeda
and/or affiliated FTOs, associations, organ-
izations or persons.”). Next they claim
the September 11 attacks were perpetrat-
ed in furtherance of that common scheme.
Ashton Complaint ¶¶ 23, 188, 610. Ac-
cording to Plaintiffs, Prince Mohamed par-
ticipated in the conspiracy by providing
funding, financial support, and banking
services through FIBS. Id. ¶¶ 48–54, 63–
66, 255, 274–276, 387, 580, 582. Specifical-
ly, Plaintiffs claim:

• On October 17, 1983, Prince Mohamed
became CEO of DMI. Under Prince
Mohamed’s chairmanship, DMI devel-
oped banking, investment and insur-
ance activities in approximately twenty
offices across the world. DMI was
founded in 1981 to foster the spread of
Islamic banking across the Muslim
world and its Board of Directors in-
cluded Haydar Mohamed bin Laden, a
half-brother of Osama bin Laden. Id.
¶ 274.
• Faisal Islamic Bank Sudan was one of
the five main founders of Al Shamal
Islamic Bank .... Al Shamal Islamic
Bank is an instrumental bank in bin
Laden’s financial support network.
Bin Laden used Al Shamal Bank for
the funding of his al Qaeda network
leading up to the 1998 United States
embassy bombings in Africa. Defen-
dant Faisal Islamic Bank was implicat-
ed during Al Fadl’s May 2001 United
States trial testimony regarding the
bombings as holding and managing
bank accounts for al Qaeda operatives.
Id. ¶¶ 274–75.
• As the head of DMI, Prince Mohamed
knew or should have known of these
and other activities and acted as an
aider and abettor and material sponsor
of al Qaeda, bin Laden, and interna-
tional terrorism. Id. ¶ 276.
• U.S. designated terrorists Wa’el Julai-
dan and Yassin Kadi had accounts in a
DMI subsidiary. Ashton Opp. at 25.

Finally, Plaintiffs allege the that attacks in
question caused many deaths, a fact that
no one disputes. Ashton Complaint ¶¶ 23,
610.

In response, Prince Mohamed argues
that Plaintiffs have failed to demonstrate
that he is “present” in the United States
for general personal jurisdiction purposes.
See Helicopteros Nacionales de Colombia,
S.A. v. Hall, 466 U.S. 408, 411–12, 416–18,
104 S.Ct. 1868, 80 L.Ed.2d 404 (1984);
Bersch v. Drexel Firestone, Inc., 519 F.2d
974, 998 (2d Cir.1975) (buying and selling
American securities is insufficient to estab-
lish that defendant was “doing business” in
the United States). Prince Mohamed sub-
mits that some of the contacts on which
Plaintiffs rely are too far removed in time
from September 2001 to be considered by
the Court. See Metro. Life, 84 F.3d at 569
(holding courts should examine a defen-
dant’s contacts with the forum for a rea-
sonable period prior to the date on which
the lawsuit was filed, and finding that six

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