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In re: TERRORIST ATTACKS ON SEPTEMBER 11, 2001., 2012 WL 257568 (2012)

and other financiers associated with the Golden Chain enabled bin Laden and Al Qaeda to replace lost financial assets and establish a base in Afghanistan following their abrupt departure from Sudan in 1996.89

The Golden Chain thus provides a list of the most significant donors to al-Qaeda. These donors, moreover, did not give money to al-Qaeda unwittingly, through an al Qaeda front masquerading as a legitimate charity; they were, rather, bin Ladin's original list of financial backers for his al-Qaeda enterprise. The appearance on this list of Khalid bin Mahfouz and Sulaiman al Rajhi is strong evidence of their knowing and active financial support of al-Qaeda.

In addition to the positions within their respective financial institutions, Khalid bin Mahfouz, Suleiman al Rajhi, and Abdullah al Rajhi also played significant roles in al-Qaeda charity fronts. As mentioned above, bin Mahfouz founded Muwafaq Foundation along with Defendant al Kadi, with the intent that it would serve as a front for al-Qaeda *55 operations.90 Al Rajhi served as a Board Member of the IIRO, and also founded the SAAR Foundation, a U.S. based charity established by al Rajhi to support Islamic extremists.91 These allegations and facts concerning their longstanding ties to bin Laden, and positions within financial institutions and charities with documented links to al-Qaeda, place bin Mahfouz and al Rajhi at the center of the al-Qaeda financial and logistic network.

Al-Qaeda's Additional Wealthy Financiers

A number of other wealthy financiers and sponsors played critical roles in the advancement of the al-Qaeda enterprise, by providing much of the funding al-Qaeda needed to sustain its global operations, estimated by the U.S. government at more than $30 million per year in the period immediately preceding the September 11th Attacks.92 These wealthy individual sponsors included defendants Bakr bin Laden, Tariq bin Laden, Yeslam bin Laden, Omar bin Laden, Abdullah bin Laden (collectively the "Bin Laden Brothers"), Yousef Jameel, and Saleh Kamel--Bakr bin Laden, *56 Jameel, and Kamel, along with Khalid bin Mahfouz and Suleiman al Rajhi, are identified as primary al-Qaeda financiers in the Golden Chain.93

Bakr, Tariq, Omar, and Yeslam bin Laden are Osama's half-brothers. Bakr, Tariq, and Omar are alleged to have used their positions within the Saudi Binladin Group, the bin Laden family construction empire, to channel support to their sibling Osama after he formed al-Qaeda and made clear his intent to conduct jihad against the United States.94 Consistent with those allegations, the National Commission on Terrorist Attacks' Staff Monograph on terrorist financing confirms that Osama bin Laden continued to receive disbursements from SBG following the establishment of al-Qaeda in 1988 through 1993 or 1994, to a tune of approximately $1 million per year, until the Saudi government allegedly "forced the Bin Ladin family to find a buyer for Usama's share of the family company."95 Bin Laden used those funds to provide economic support to the National Islamic Front regime, a central component of the bargain under which the *57 NIF provided safehaven, training camps and other support for al-Qaeda.96 In addition, Bakr is a member of the Golden Chain, and a primary contributor to al-Qaeda front charity IIRO.97

Abdullah bin Laden sponsored al-Qaeda through his roles in establishing two US branches of al-Qaeda front charities, Taibah International and WAMY USA, both of which have extensive ties to al-Qaeda.98 Yeslam bin Laden supported al-Qaeda through the management of Swiss bank accounts for Osama's benefit.99

Defendants Kamel and Jameel also are members of the Golden Chain.100 Both are alleged to have longstanding ties to al-Qaeda, and to have supported al-Qaeda through a variety of channels.101 Jameel's sponsorship of al-Qaeda flowed largely through purported charities, known to Jameel to be al-Qaeda fronts.102 Kamel also contributed generously to al-Qaeda through its known charity fronts, and also *58 supported al-Qaeda through various businesses and financial institutions under his control, including Defendant-Appellee Dalian al Baraka.103

*59 Summary of Argument

The district court concluded that plaintiffs had failed to state a claim against certain defendants under the Anti-Terrorism Act

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