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824 Id. 1184; see also Decl. of Jodi Westbrook Flowers in Opp. to Batterjee Motion to Dismiss (“Flowers Decl.”) Att. 5, p. 7 (BIF record showing $48,464 contribution by Abdel Abdul Jalil Batterjee). Mr. Batter- jee allegedly transferred control of BIF to Defendant Enaam M. Arnaout, on Septem- ber 15, 1997.% Burnett Complaint 1183. In October 2001, Arnaout allegedly told Batterjee he was worried about being un- der scrutiny of the U.S. government and in January 2002, Batterjee requested that Aranout relocate his family to Saudi Ara- bia. 7d. 19217-218. Plaintiffs also claim that Mr. Batterjee’s name is on a BIF list of wealthy Saudi Arabian sponsors of al Qaeda and Osama bin Laden. Jd. 1219. Plaintiffs also claim that Defendant charity WAMY and BIF are closely con- nected and that Mr. Batterjee was the Secretary General of WAMY when he founded BIF in the United States. Jd. 1229; see also Flowers Decl. Att. 4, p. 3 (December 5, 1992 New York Times article quoting Adel A. Batterjee as the chairman of WAMY). In his capacity as Secretary General of WAMY, Mr. Batterjee allegedly commissioned a biography of Osama bin Laden and the origins of al Qaeda, which was jointly published by WAMY and BIF in 1991. Burnett Complaint { 230. With respect to his contacts with the United States, Plaintiffs claim that the documents filed in 1992 in conjunction with the establishment of BIF in Chicago state that Mr. Batterjee is a founder of BIF and that BIF’s founders travel to the United States on a regular basis. See Flowers 38. Mr. Arnaout was “criminally indicted for his role in the September 11, 2001 attacks.” Burnett Complaint 1199. But in its “written plea agreement, the government agreed to dismiss sensational and highly publicized charges of providing material support to ter- rorists and terrorist organizations.” United States v. Arnaout, 282 F.Supp.2d 838, 843 (N.D.111.2003). The Burnett Plaintiffs allege 349 FEDERAL SUPPLEMENT, 2d SERIES Decl. Att. 2, pp. 2-8. In 1993 BIF filed an application to conduct business in Florida and listed Mr. Batterjee as a director with an address in Florida. See id. at Att. 3, p. 4, BIF’s authorization to do business in Florida was revoked on August 26, 1994. Id. at p. 1. Mr. Batterjee disputes the claims against him in a declaration filed in con- junction with his motion to dismiss. Bat- terjee Decl. 18. He states he was born in Saudi Arabia, attended college in the Unit- ed States in the 1960s, and returned to Saudi Arabia. Jd. 113, 5. He claims he was last in the United States in June 2000 for personal reasons. Jd. 15. He denies owning any real property, bank accounts, or investments in the United States. /d. 16. With respect to the allegations con- tained in the complaint, Mr. Batterjee claims BIF was never a branch of Al Bir or vice versa. Jd. 19. He claims he never sent money to BIF in all ofits history. Jd. He states he transferred away all control of BIF in 1998. Jd. He claims he never served as an executive of WAMY, never wrote a biography of Osama bin Laden, and denies having any knowledge of Osa- ma bin Laden’s or al Qaeda’s activities other than what is widely published in the press. Id. 119, 10. Mr. Batterjee also disputes the manner in which he was served. Plaintiffs rea- soned that Al-Quds Al-Arabia had pub- lished Osama bin Laden’s fatwas in the past and could, therefore, reach his sup- porters regardless of their location. Fur- ther, The International Herald Tribune is Mr. Arnaout and Osama bin Laden have ties. For example, law enforcement officials in Bosnia—Herzegovina raided BIF’s offices in March 2002 and allegedly recovered docu- ments establishing direct communications be- tween Mr. Arnaout and Osama bin Laden in the late 1980s and early 1990s. Burnett Com- plaint 17 188, 196, 199. HOUSE_OVERSIGHT_017889