45 8roadway. I hill Floor New YIlrk, New York 10006

COZEN O'CONNOR Attorneys for Plaintiffs l'vliLllilci J. Sl)[llIllI, Esq. (MS-7910) 45 8roadway. I hill Floor New YIlrk, New York 10006 (212) S09-9400

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK

FEDERAL INSURANCE COMPANY; PACIFIC INDEMNITY COMPANY; CHUBB CUSTOM INSURANCE COMPANY; CHUBB INDEMNITY INSURANCE COMPANY; CHUBB INSURANCE COMPANY OF CANADA; CHUBB INSURANCE COMPANY OF NEW JERSEY; GREAT NORTHERN IN<;;IIR A N('F ('nMPANV; VIGILANT

INSURANCE COMPANY; ZURICH AMERICAN INSURANCE COMPANY; AMERICAN GUARANTEE AND LIABILITY INSUR.ANCE COMPANY; AMERICAN ZURICH INSURANCE COMPANY; ASSLIRANCE COMPANY OF AMERICA; COLONIAL AMERICAN CASUALTY AND SURETY INSURANCE COMPANY; FIDELITY AND DEPOSIT COMPANY OF MARYLAND; MARYLAND CASUALTY COMPANY; NORTHERN INSURANCE COMPANY OF NEW YORK; STEADFAST INSURANCE COMPANY; VAI.IANT INSURANCE COMPANY; ONE BEACON INSURANCE COMPANY; ONE BEACON AMERICA INSURANCE lUMPANY; AMERICAN EMPLOYERS' INSURANCE COMPANY; THE CAMDEN FIRE INSURANCE ASSOCIATION; HOMELAND INSURANCE COMPANY OF NEW YORK; CRUM & FORSTER INDEMNITY COMPANY; NORTH

CIVIL ACTION NO.

COMPLAINT

JURY TRIAL DEMANU~;U

RIVER INSURANCE COMPANY; 11NITFn STATES FIRE INSURANCE COMPANY; AMERICAN AL TERNATfVE INSURANCE CORPORATfON: GREAT LAKES REINSURANCE UK. PLC; AND TIlE PRINCETON EXCESS & SURPLUS LINES INSURANCE COMPANY

Plaintiffs

v.

AL QAIDA; EGYPTIAN ISLAMIC JIHAD; ASBA T AL-ANSAR; AL GAMA'A AL-ISLAMIYYA; SALAFIST GROUP FOR CALL AND COMBAT; LASHKAR I JANGHVI; LASHKAR-E T A YYlBA; JEMAAH ISLAMIY A ORGANIZATfON; HEZBOLLAH; ABU SA YEF GROUP; ALGERIAN AKMEJ) ISLAMIC GROUP; HAMAS; PALESTINE ISLAMIC JIHAD; THE ISLAMIC REPUBLIC OF IRAN; REPUBLIC OF IRAQ; THE REPUBLIC OF THE SUDAN; SYRIAN ARAB REPUBLIC; THE KINGDOM OF SAUDI ARADlA; OSAMA BIN LADEN; MUHAMMAD ATIF NKiA SUBHI SITTA NK/A ABU HAFS AL-MASRI; SAYF AL-ADL; SHAYKH SA'JD A/KiA MUSTAFA MUHAMMAD AHMAD; ABU HAFS THE MAURITANIAN A/KiA MAHFOUZ OULD AL-WALID A/KiA KHALID AL-SHANQITl; IBN AL-SHA YKH AL-LIB!; ABU ZUBAYDAH A/K/ A ZA YN AL ABJDIN MUHAMMAD HUSAYN TARIQ; ABO AL-HADI AL-IRAQI A/KJA ABU ABDULLAH; A YMAN AL-ZA W AHIRI; THIRWAT SALAH SHIHATA A/KIA MUHAMMAD ALI; TARIQ ANWAR AL-SAYYID AHMAD NKiA FATHI NKiA AMR AL-FATlH; MUHAMMAD SALAH A/KIA NASR FAHMI NASR HASANA YN; MAKHT AB AL-

KHIDAMAT A/KiA AL-KHIFAF; AL-1111 L-'<AD /\L IS!./\MIYA (AlAI); ISI.AMIC ARMY OF ADEN; WAFA H\ J\-1ANITARIAN ORGANIZATION; /\1. RASHID TRUST: MAMOUN DARKAZANLI IMPORT-EXPORT COMPANY; NURJAMAN RIDUAN ISMUDDIN A/K/A HAMBALI; MClJJAMMFD IQBAL ABDURRAHMAN AiKlA/ ABU JIBRIL; BENEVOLENCE INTERNATIONAL FOUNDATION; BENEVOLENCE I'-:TER0iATI00iAL FUND; BOSANSKA IJ)EALNA FUTURA; GLOBAL RELIEF FOUNDATION A/KIA FOUNDATION SECOURS MONDIAL; MOUNIR EL MOT ASSADE(); KAMZl tllNALSHIBH;

ZAKARY A ESSABAR; SAID BAHAJI; TlJRKISTAN ISLAMIC MOVEMENT; ViA 'EL HAMZA JULAIDAN AiKJA ALI IASAN AL MADANI; ADEL BEN SOL lANE; NABIL BENATTIA; Y ASSINE CHEKKOURI; RIADH .IEL/\SSI; MENDI V~<\MMOUN; SAMIR KISHK; TAREK BEN HABIB MAAROUFI; ABDELHALIM RrrvIADNA; MANSOUR THAER; LAD-JAR BE01 MOHAMMED TLlLl; HABIB W ADDANI; AKIDA BANK PRIVATE LIMITED; AKIDA INVESTMENT CO. LTD.; NASREDDIN GROUP INTERNATIONAL HOLDING LTD; NASCO NASREDDIN HOLDING j\S_ NASCOTEX SA; NASREDDIN J.()l ;NDATJON; BA T AQWA FOR COMMERCE AND REAL ESTATE COMPANY LTD.; MIGA-MALA YSIAN SWISS, GULF AND /\FRICAN CHAMBER, GULF CENTER SRL; NASCOSERVICE S,R.L.; NASCO BUSINESS RESIDENCE CENTER SAS DI NASREDDIN AHMED TORTS EC; NASREDDIN COMPANY NASCO SAS DI AHMED TORIS NASSNEDDIN EC; NADA INTERNATIONAL ANSTALT; NASREDDIN INTERNATIONAL

GROl'P LIMITED IlOLDING; THE AID ORCi,4NIZATION OF THE ULEMA; AHMED IDRIS NASREDDIN; YOUSSEF NADA; ABDELKADIR MAHMOUD ES SA YEl); KHALID AL-FA WAZ; ABU HAMZA AL-MASRL MOHAMED BEN BEUiACEM AOUADI; MOKHT AR BOUCiHOUGHA; TAREK CHARAABI; SAMI BEN KHEMAIS ESSID; LASED BEN HENI; SOMALIA BRANCH ut THE AL-HARAMAIN ISLAMIC FOUNDATION; BOSNIAHERZEGOVINA BRANCH OF ALHARAMAIN ISLAMIC FOUNDATION; UMMA TAMEER-E-NAU (UTN); BASHIR-UD-DIN MAHMOOD; ABDUL MAJEED; S.M. TUFAIL; AL BARAKAAT; AI, TAQWA/NADA GROUP; AARAN MONEY WIRE SERVICE, INC.; AL BARAKA EXl'IlANCiE LLC; AL BARAKJ\AT BANK; AL-BARAKAT BANK OF SOMALIA (8SS); AL-BARAKAT FINANCE GROUP; AL-BARAKAT FINANCIAL HOLDING CO.; ALBARAKAT GLOBAL TELECOMMUNICA TIONS; ALBARAKAT GROUP OF COMPANIES SOMALIA LIMITED; AL-BARAKAT INTERNATIONAL A/K/A BARACO CO; AL-BARAKAT INVESTMENTS; ALBARAKAT WIRING SERVICE; AL TAQWA TRADE, PROPERTY AND INDUSTRY COMPANY LIMITED; AS AT TRUST; BANK AL TAQWA LIMITED; BARAKA TRADING COMPANY; BARAKAAT BOSTON; BARAKAAT CONSTRUCTlON COMPANY', RARAKAAT ENTERPRISE; BARAKAA T GROUP OF COMPANIES; BARAKAAT INTERNATIONAL; BARAKAAT INTERNATIONAL FOUNDATION; BARAKAA T INTERNATIONAL, INC.; BARAKAAT NORTH AMERICA, INC.; BARAKAA T RED SEA

4

TELECOMMUNICATIONS; BARAKAAT TELECOMMUNICATIONS CO. SOMALIA; BARAKAT BANK AND REMITTANCES; BARAKA T COMPUTER CONSULTING (BCC); BARAV_AT CONSULTING GROUP (BeG): BARAKAT GLOBAL TELEPHONE COMPANY; BARAKAT lNTERNA TIONAL COMPANIES (BllTJ); BARAKAT POST EXPRESS (BPE); BARAKAT REFRESHMENT COMPANY; BARAKAT WIRE TRANSFER COMPANY; BARAKAT TELECOMMUNICATIONS COMPANY LIMITED (BTELCO); BARAKO TRADING COMPANY, LLC; GLOBAL SERVICES INTERNATIONAL; HEY ATUL UL Y A; NADA MANAGEMENT ORGANIZATION; PARKA TRADING COMPANY; RED SEA BARAKAT COMPANY LIMITED, SOMALIA INTERNATIONAL RELIEF ORGANIZA TlON; SOMALIA INTERNET COMPANY; SOMALIA NETWORK AB; YOUSSEF M. NADA & CO GESELLSCHAFT MBH; YOUSSEF M. NADA; HUSSEIN MAHMUD ABDULLKADlR; ARDlRASIK ADEN; ABBAS ABDI ALI; ABDI ADULAZIZ ALI; YUSAF AHMED ALI; DAHIR UBEIDULLAHI A WEYS; HASSAN DAHlR A WEYS; GARAD .lAMA; ALI GHALEB HlMMAT; ALBERT FREDRICH ARMAND HUBER; LlBAN HUSSEIN; AHMED NUR All JIM' ALE; ABDULLAHI HUSSEIN KAHlE; MOHAMMED MANSOUR; ZEINAB MANSOUR-FATTAH; ABDULLAH AHMED ABDULLAH AlKlA ABU MARIAM AIKIA ABU MOHAMED ALI'vlASRI A/KIA SALEH; HAJJ ABDUL MANAN AGHA AlK/A ABD ALMAN'AM SAIYID; AL HAMATI SWEETS BAKERIES; MUHAMMAD AL-HAMATl AlKiA MOHAMMAD HAMDl SADIQ AL-AHDAL AlKiA ABU

ASIM AL-MAKKI; AMfN AL-HAQ ,\'K/\ DR. AMIN AH HAQ AIKIA MUHAMMAD AMIN AIKIA DR AMfN UL-IIAQ: SAQAR AL-SADA WI; AIIMA[) SA'j[) AL-KADR A/KIA ABU Al:lll AL-KAHMAN AL-KANADl;

AN AS AL-UBY A/KIA ANAS AL-LIBI A/KiA NAZIM AL-RAGHIE NK/A NAZIII ABDUL HAMED AL-RAGHIE A/K/A ANAS AL-SABAI; AHMAD IBRAHIM AL- MUGHASSIL NKiA ABU OMRAN A/KIA AHMED IBRAIIIM AL-MUGHASSIL; ABDELKARIM HUSSEIN MOHAMED AL-NASSER; AL-NUR HONEY PRESS SHOPS A/K/A AL-NUR HONEY l'tN 1 tK; Y ASIN AL-QADI A/K/A SHA YKH Y ASSIN ABDULLAH KADI AII(A Y ASIN KAHDI; SA'D ALSHARIF; AL-SHIF A' HONEY PRESS FOR INDUSTRY AND COMMERCE; Il3RAHIM SALIH MOHAMMED ALYACOUB: AHMED MOHAMMED HAMED ALI A/KIA AHMED MOHAMMED ABDUREHMAN AIKIA Alll I-ATIMA AI KIA ABU ISLAM AiICA ABU KHADIIJAH AIKIA AH,\1ED t-IAMED A/KIA AHMED TIlE EGYPTIAN A/KIA AHMED AHMED A/KIA AHAMAD AL-MASRI NK/A ABU ISLAM AL-SURIR A/KIA AHMED MOHAMMED ALI AlKiA HAMED ALI /\/K/;\ AHMED HEM ED A/KIA AHMED SIIIEB A/KIA SHUAIB; ALI ATWA .A/KiA AMMAR MANSOUR BOUSLIM A/leA HASSAN ROSTOM SALIM; MUHSIN MUSA MATWALLI ATWAH A/K/A ABDEL RAHMAN A/K/A ADDUL RAllMAN AIKIA ABDUL RAHMAN AL-MUHAJIR NKiA MOIIAMMED KA AL-NAMER; BILAL BIN MARWAN; AYADI CHAFIQ BIN MUHAMMAD AlKlA tlt,N MUHAMMAD AIADI AIKIA BEN MUHAMMAD AIADY AlKiA BEN MUHAMMAD AY AD! CHAFIK NKiA

FlEN MlilAMMAD AYADI SHAFIQ; MAMOI iN DARKAZANLI; ALI SAED FllN ALl LLHOORIE A/K/A ALI SAED BIN ALl AL-HOURI A/KIA ALI SAED

FlIN ALI EL-HOURJ: MUSTAFA MOIIAMED rADIIIL NKiA ABO AL WAKIL AL MASRI A/KIA ABU ALNUBI A/KiA HASSAN ALI NKiA ABU ANIS A/leA MOUSTAFA ALI ELBISHY A/KIA MUSTAFA MUHAMAD FADIL A/K/A MUSTAFA FAZULA/KIA HUSSEIN A/K/A ABU JIHAD A/KIA KHALID A/K/A NU MAN A/KiA MUSTAIA MOHAMMED A/K/A ABU YUSSRR: AHMED KHALFAN GHAILANI A/K/A AHMED THE TAN7ANIAN A/K/A rOOPLE NKiA FUPI A/K/A ABU BAKR AHMAD A/KiA A. AHMED A/K/A ABUBAKAR AHRMED A/K/A ABUBAKAR K. AHrv1f~]) AlK/A ABUBAKAR KHALFAN AHMED A/K/f\ ABUBAKARY K. AHMED A/KIA AHMED KHALFAN AHMED A/](/A AHMAD AL TANZANI A/K/A AHMED KHALFAN ALI A/KiA ABli BAKR A/KI A ABUBAKARY KHALyJ\t\ AWvlED GHAILANI NKiA AlvlMED GHAILANI AlKiA AHMAD KHALMAN G1IILANI A/KIA MAHAFUDfI ABUBAKAR AHMED ABDALLAH HUSSEIN A/KIA ABU KHABJ\R A/K/A AHMED KHALFAN A/KIA SHARif'" OMAR MOHAMMED; RIAD I I 1.1 AZI A/K/A ABU-AHMAD ALAMRIKI A/K/A ABU-AHMAD AL-HA WF" A/K/A RASHID ALMAGHRIBI A/KIA ABU-AHMAD ALSHMIID A/K/A M RAED HIJAZI; HA."AN Ill-AI-DIN AlKJAAHMED

GARBA Y A A/KIA SA-ID A/KI A SAMIR SALWWAN; .IAISH-I-MOHAMMED A/K/l\ ARMY OF MOHAMMED; JAM'YAH TA'AWUN AL-ISLAMIA A/KIA JAM'IY AT AL TA'AWUN AL ISLAMIYYA A/KIA JIT A/KiA SOCIETY Of ISLAMIC

COOPERATION; MUFTI RASHID AHMAD LADEHY ANOY AIKIA MUFTI RASHEED AHMA AlKiA MUFTI RAS.HID AHMAD LUDIIiANVI A/K/A MUFTI RASHlD AHMAD WADEHY ANOY; FAZUI ARDUT.I.AH

MOHAMMED AIKJA FAZUL ABDALLA AII(/A FAZUL ADBALLAH A/KIA ABU AISHA AIKJA ABU SElF AL SUDAN! AiKiA fADEl ABDALLAH MOHAMMED ALI AlKJA ABDALLA FAZUL AIKIA ABDALLAH FAZUL AI KIA ABDALLAH MOHAMMED FAZUL AIKIA HAROON FAZUL AI KIA HARUN FAZUL AIKIA HAROON AIKJA FADHIL HAROUN A/KIA HARLIN AIKIA Am I T.T IQMAN AI KIA FAZUL MOHAMMED AlKJA FAZUL ABDILAHI MOHAMMED AIKIA FOUAD MOHAMMED AIKJA fADIL ABDALLAH MUIIAMAD, KHALID SHAIKH MOHAMMED AIKIA SALEM ALI AiKJA FAHD BIN ABDALLA II BIN KHALID A/KJA ASHRAF REFAATNABITII HENIN A/I(/A KHALID ADBUL WADOOD; FAHID MOHAMMED ALLY MSALAM AIIZ/A USAMA AL-KINI A/KJA FAHID MOHAMMED ALLY A/KJA FAHAD ALLY MSALAM A/K/A FAHID MOHAMMED ALI MSALAM AIKIA MOHAMMED ALLY MSALAM AlKJA FAHID MOHAMMED ALI MUSALAAM A/KJA FAHID MUIlAMAD ALI SALEM; RABITATRUST; ANSAR AL-ISLAM (AI) A/K/A ,lUND AL-ISLAM; YOUSSEF ABDAOUI A/K/A ABU ABDULLAH A/KIA ABDELLAH A/KIA ABDULLAH; MOHAMMED AMINE j\KLl A/KIA SAMIR A/KIA KALI SAMI AIKJA ELIAS; MOHREZ AMDOUNI A/KIA FABIO FUSCO A/KIA MOHAMMED HASSAN A/KIA TUALE ABU; CHIHEB BEN MOHAMED A Y ARI AIKJ A ABU HOHEM HICHEM; MONDHER BAAZAOUI AlKJA HAMZA; LIONEL

DUMONT A/K/A BILAL AIKIA HAMZA f\iKA .It\CQLES BROUGERE, MOLISSA BEN AM OR ESSAADl NKiA DAII DAH A/K/A ABDELRAHMMAN A/K/A RFCHIR: RACHlD FEHAR A/KIA AMINEDEL BELGIO NKiA DJAFFAR; BRAHIM BEN HEDlLI HAMAMI; KHALIL JARRA YA A/KIA KHALIL YARRA Y A A/K/A AZIZ BEN NARVAN

ABDEL' A/K/A AMRO A/KIA OMAR A/K/A AMROU A/KIA AMR; MOUNIR BEN HABIB JERRAYA A/KIA YARRA Y A; FOUZI JENDOUBI NKiA SAID A/K/A SAMTR; FETHT BEN REBAI MASRI NKiA AMOR NKiA OMAR ABU A/KIA FETHI ALlC; NAJIB OUAZ; AHMED HASNI RARRBO AlK/A ABDALLAH A/K/A ABDULLAH; NEDAL SALEH A/KIA HITEM; ABDELGHA NT M7()T In!; (;1 IT .Rl Jnn!N

H EKMA TY AR; [MAD MUGHNIYEH; MUIIAMMAD OMAR; ISLAMIC INTERNATIONAL BRIGADE; SPECIAL PURPOSE ISLAMIC REGIMENT, RIY ADUS-SALIKHIN RECOGNIZANCE AND SABOTAGE BATTALION OF CHECHEN MARTYRS; PRINCESS HAIFA AL-FAISAL; PRINCE VANDAR IBAN SULTAN; OSAMA BASSNAN; OMAR AL-BAYOUMI; FAHAD ALTHLIMAIRY; WORLD ASSEMBLY OF MUSLIM YOUTH; SHEIKH AHMED SALIM SWEDAN; MUHAMMAD ABUISLAM; ABDULLAH 'QASSIM; HASHIM ABDULRAHMAN; JAMAL AL-BADA WI; MOHAMMED OMAR AL-HARAZI; WAllO AL-SOUROURI; FAn-IA ADBUL RAHMAN; Y ASSER J\L-ALLANl; JAMAL HA KHORSH; AHMAD AL-SHINNI; JAMIL QASIM SAEED; ABU ABDUL RAHMAN; MOHAMED BA Y AZID; ABU MUSAB ZARQA WI; SHEIKH OMAR BAKRI MUHAMMAD; ABDUL FATTAH ZAMMAR; GHASOUB AL ABRASH GHAL YOUN A/KIA ABU MUSAB;

BE]\iSA YAH BELKACEM; SABIR I.AM.AR: WADIH EL-HAGE; WAll KHAN AMIN SHAH; ZACARIAS MOUSSAOUI; THE TALIBAN; MALI/VI ABDUl. KABIR; JALIL SHINWARI~ NOOR .TAUL; ABDEL HUSSEIN; ADU AGAB; NATIONAL ISLAMIC FRONT; HASSAN TURABI; ISS LL-DlN EL SAYED; LASHKAR REDA YA>J-L-ISLAMI; AIiMAD SALAH A/K/A SALIM; ABO AL-MUSHIN ALLIB!; ABDUL RAHMAN KHALED BIN MAHFOUl; ABDUL RAHMAN Y ASIN; ABDULLA AL OBAID; ABDULA BIN LADEI'\; ADVICE AND REFORMATION COMMITTEE; AFCIIAN SUPPORT (,OMMTTTFF; AT

KHALEE.lIA FOR EXPORT PROMOTION AND MARKETING COMPANY; AL-HARAMAIN AIKIA I\L-I-IAi{MvIAIN FOUNDATION,

ENAAM M. ARNANOUT; INTERNATIONAL DEVELOPMENT Fot'NDATION; INTERNATIONAL ISLAMIC RELIEF ORGANIZATION; INTlcRNATIONAL INSTITUTE OF ISL/\MIC THOUGHT; ISLAMIC CULTURAL INSTITUTE OF MILAN; JAMAL BARlINJI; KHALED BIN MAHFOUl; MOHAMMED JAMAL KHALlFA; MOHAMMED SALIM BIN MAHFOUZ; MUSLIM WORLD LEAGUE; NATIONAL COMMERCIAL BANK: PRINCE NA YEF BIN ABDULAZIZ AL SAUD; PRINCE SL'!.. I AN BIN Al:llJULAZIZ AL SAUlJ; RABIII IIADDAH; SAAR FOUNDATION; SAUD! SUDANESE BANK; AL SHAMAL ISLAMIC BANK; SHEIKH ABU BDUL AlIZ NAGI; SHEIK ADIL GALIL BATARGY A/KIA ADEL ABDUL JALIL BATTERJEE; SULEIMAN AHDEL AZIZ AL RAJH!;

TABA INVESTMENTS; TANZANITE KING; ULEMA UNION OF AFGHANISTAN; WAD! AL AQIQ;

10

INFOCUS TECH OF MALA YSIA; Y AZID SUFAA T OF KUALA LUMPUR MALAYSIA; AL-SHA YKH AL-IRAQI; AZZAM SERVICE CENTER; ABU HAlER AL IRAQI; MOHAMMED AL FAISAL AL SAUD; At-HLlRAH CONSTRUCTION AND DEVELOPMENT LIMITED; GUM ARABIC COMPANY LIMITED; AL SIIAMAL rOR INVESTMENT AND DEVELOPMENT; SALEH ABDULLAH KAMEL; AL BARAKA INVESTMENT AND DEVELOPMENT; SAUDI DALLAH AL BARAKA GROUP LLC; ISLAMIC INVESTMENT COMPANY OF THE GULF; DAR-AL-MAAL AL ISLAML AL-BIR SAUDI ORGANIZATION; MOHAMMAD S. MOHAMMAD; TADAMON ISLAMIC BANK; MUSTASIM ABDEL-RAHIM; NATIONAL rUND rOR SOCIAL INSURANCE; ABDUL-RAHHvl MOHAMMED HUSSEIN; At AMN ALOAKHIU; AI, AMN AL-KHARIJI; ABO AL SAMALJ AL-IA'ISH; MOHAMED SADEEK ODEH; ABDEL BARRY; AHMAD SALAH A/K/A SALIM; MAHDI CHAMRAN SA VEHl; MOHAMMED SARKA WI; AL TAWHID; HAT! MOHAMAD AKRAM; ABDALLAH OMAR; UMAR FARUQ; ABO AL-RAHIM AL-NASHIRI; TURKI AL FAISAL AL SAUD A/K/A PRINCE TURKI; PRINCE ABDULLAH AL FAISAL BIN ABDULAZIZ AL SAUD A/KIA PRINCE ABDULLAH; PRINCE SALMAN BIN ABDUL AZIZ AL SAUD A/K/A PRINCE SALMAN; ZOUA YDI A/KIA MUHAMMED GALEB KALAJE ZOAAYOI A/K/A ABU TALHA; MULLAH KAKSHAR; ABDULAZIZ BIN ABDUL RAHMAN AL SAUD; ARAFAT FI-ASAHT: HAYDAR MOHAMED BIN LADEN; MOHAMMED BIN ABDULRAHMAN AL ARIEFY; FAISAL GROUP

11

HOLDING COMPANY; AL FAISALIAH GROlIP; BASHSH HOSPITAL; Ml'SI-IAYT FOR TRADING ESTABLISHMENT; ABDULLAH BIN ABDUL MUHSEN AL TURKI A/K/A AL TlIRKI·. SAlim HlGH COMMISSION NK/A THE SAUDI HIGH RELIEF COMMISSION; ABDUL AZIZ AL IBRAHIM A/K/ A AL IBRAHIM; T AREK i\YOUBI; ALANWA; HBLP AFRICAN PEOPLE; IBRAHIM BIN ABDUL AZIZ AL IBRAHIM FOUNDATION; MERCY INTERNA TIONAL RELIEF AGENCY; ISLAMIC MOVEMENT OF UZBEKIST AN; SAUDI BIN LADEN GROUP; BAKR M. BIN LADEN; SALFM BIN f.Ar1FN; SAI.FH GA7A7; MOHAMMED BAHARETH; ABDULLAH BIN SAID; MOHAMMED NUR RAHMf; TAREK M. BIN LADEN; OMAR M. BIN LADEN, MOHAMMED

DIN LADEN ORGANIZATION; SAUDI 81N LADEN INTERNATIONAL COMPANY; YFSLAM M. BIN LADEN; GLOBAL DIAMOND RESOURCE; IIUMAN CONCERN INTERNATIONAL SOCIETY; TALAL MOHAMMED BAD KOOK; DR. MOHAMAN ALI ELGARI; NEW DIAMOND HOLDINGS; M.M. BADKOOK COMPANY FOR CATERING & TRADING; ALMUSTAQBAL GROUP; NATIONAL MANAGEMENT CONSULTANCY CENTER; AL-RAJHI BANKING & INVESTMENT CORPORATION; SALEH ABDULAZIZ AL-RAml; ABDULLAH SULAIMAN AL-RAJHI; KHALID SlJLAIMAN AL-RAJHI; AL-WATANfA POULTRY; MAR-JAC POULTRY; MAR.lAC INVESTMENTS, INC.; PIEDMONT POULTRY; SALIM BIN MAHFOUZ; SNCB CORPORATE FINANCE LIMITED; SNCB SECURITIES LIMITED IN LONDON; SNCB SECURITIES LIMITED IN NEW YORK; SAUDI ECONOMIC AND DEVELOPMENT

12

COMPANY: ZAKAT COMMITTEE; RED CRESC[NT SAUDI COMMITTEE; HI ESSED RELIEF (MUW AFAQ) roUNDATION: ABDULKARIM

KHALED UUSUF ABDULLA; ARDIII R AllMAN BIN KHALID BIN

MAIlFOLZ: AL-I3lRR; HISHAM; HEZBE-ISLAMI: SAIF AL ISLAM EL MASRY: SYED SULEMAN AHMER; 'vlAZIN :VUi. BAHARETH; SHAHIR ABDULRAOOF BATTERJEE; ZAHlR H. KAZ~ll: MUZAFFAR KHAN; SOLIMAN J. KHUDEIRA; JAMAL NYRABEH; AHMAD A.lA.I: SUCCESS FOU]\;DATION; ABDULRAHMAN ALAMOUDI; AMERICAN MUSLIM FClIJNI)ATlON; MOHAMMFn

OMEISH; ADNAN BASHA; MAHMOUD JABALLAH: ARAFAT EL-ASHl; MORO ISLAMIC LIBERATION FRONT; .IAM/\L AI-IMED MOHAMMED;

MOHAMMED KBATIB; SAUDI JOINT RELlEF COMMITTEE; TAIBAH INTERNATIONAL AIO ASSOCIATION; ISLAMIC ,\FRICAN RELIEF AGENCY; TARIK IIAMDI; FAZEH AHED; SANA13IL AL-KHAIR; SANA-BELL, INC'.: SANABEL AL-KHEER, INC; KHALED NOURI; ABDULLAH M. ALMAIIOI; TAREQ M. AL-SWAIOAN: ABDUL AL-MOSLAH; SALAH HA[)AI ]])H; HASSAN A.A. BAHFZALLAH; M. Y AQUB MIRZA; IHAFl ALI; SAMIR SALAH; IBRAHIM HASSABELLA; HISHAM AL-TALIB; ABU SULA YMAN; AHMED TOTONJl; IQBAL YUNUS; M. OMARASHRAF; MOHAMMED JAGHLIT; MUHAMMAD ASHRAF: SHERIF SEDKY: AFRICAN MUSLIM AGENCY; ARADI, INC.; GROVE CORPORATE, INC.; HERIT AGE EDUCATION TRUST; MEN A CORPORATION; RESTON INVESTMENTS, INC.; SAFA TRUST; STERLING CHARITABLE GIFT FUND; STERLING MANAGEMENT GROUP;

\3

YORK I'OUNDA TION; NATIONAL DEVI.IOPMENT BANK; DALLAH AveC) TRANS ARABIA CO. LTD.; OM.AR AL BA YOUMI A/KiA ABU IMARD: MASJED AL MADINAH AL MIJNA W ARAH A/KIA MAsnn AT. MADINAII AL MUNAWARAH; AQSA ISLAMIC BANK; AQEEL AL-AQEEL; MANSOURI AL-KADI; SOLIMAN H.S. AL-BIITHF, PEROUZ SEDA GHATY, AHMED IBRAHIM AL NAJJAR; ADEL MUHAMMAD SADlQ BIN KAZEM; SAUDI AMERICAN BANK; ABDl:LAZIZ BIN HAMAD; KHALIL A. KOROl; RASHID M. AL ROMAIZAN; ABDULAZIZ BIN HAMAD AL GOSAIBI: SAI!DI C'EMENT C'OMPANY IN DAMMAN; OMAR SULAIMAN ALRAil-II; ARAB CEMENT COMPANY; ZEINAB MANSOUR-FATTOUH; MOIIA\IMED CIIElIADE; IIAZEM RACAB; MOl lAMMED ALCHURBAJJ; MUST AF A AL-KADlR; ABU AL-MAID; AL SHAMAL ISLAMIC BANK AIKIA SIIAMLL HANK A/K/A BANK EL SIIAt\lAR: SULAIMAN AL-ALl; KHALED NOURI; MUSLIM WORLD LEAGUE OFFICES; ABDULLAH BIN SALEH AL-OBAlD; TAHA JABER ALALWANI; INTERNATIONAL INSTITUTE OF ISLAMIC THOUGHT; lBRAIIIM S. ABDULLAH; MOHAMMED BIN FARIS; DR. MAIIMOUD DAKHIL; MOHAMMED AL FAISAL Al SAUD; ABDUL RAHMi\N AL SWAILEM; DELTA OIL COMPN,Y; NIMIR. LLC; ARAB BANK, PLe; DUI3AI ISLAMIC BANK; NADA MANAGEMENT ORGANIZATION, SA; ARY GROLJP; ISLAMIC CULTURAL CENTER OF GENEVA; HANl RAMADAN; THE COMMITTEE FOR THF DFFFNSF OF LEGITIMATE RIGHTS; PROYECTOS Y PROMOCIONES ISO; AFAMIA, SL; COBIS; ABRASH COMPANY;

14

PROMOCIONES Y CONSTRUCCIONES TETUAN PRICOTE, S.A.; CONTRATAS GIOMA; EUROCOVIA OBRAS, S.A.; PROYECTOS Y PROMOCIONES PARDlSE, S.L.; PROYECTOS EDISPAN; GHASOUB AL ABRASH; MUSTAF AHMED AL-HISAWI AIKIA SHEIK SAEED; IMAD EDDIN BARAKAT YARKAS A/K/A ABU DAHDA1-l; MUHAMMED GALEB KALAJE ZUOYADI AlKlA ABU TALHA; BASS AM DALA TI SA TUT; ABDALRAHMAN ALARNOUT ABU ALlER A/K/A ABU OBED; :VI0HAMMED KHAIR AL SAQQA A/K/A ABU AL DARDA; GHASOUB AL ABR.ASH GHAL YOUN A/KIA ABU MUSAB; MOHAMMED ALI SAYED MUSHA YT; MOHAMMED HUSSEIN AL-AMOUDI; ABU OATADA ALFILISTINI A/K/A ABU ISMAIL NKIA ABU UMAR AIKIA ABU OMAR Ol\1AR A/K/A ABU UMAR TAKFIRI NKIA ABU UJ\Ai'.R UMAR AIKIA ALI

SAMMAN UTHMAN NK/A OMAR MAHMOl:D UHlMAN A/K/A UMAR UTHMAN; Y ASSIR AL-SIRRI A/KIA AMiVIAR; MOHAMMED AL MASSARI; LUJAlN AL-IMAN; ZIY AD KHALEEL; IBRAHIM BAH; ABU ZUBAYDAH; MAMDOUH MAHMUD SALIM A/K/A ABU HAlER AL IRAQI; SHEIKH ABDULLAH AZZAM A/KIA ABU MUHAMMED; ABDULLAH SAMIL BAHMADAN; ESSAM AL RIDI; OMAR ABU OMAR; MOHAMMED AU HASAN At MOAYAD; AL FAROOQ MOSQUE: YOUSEF JAM EEL; IBRAHItvJ MUHAMMED AFANDI;

MOHAMMED BIN ABDULLAH ALJOMAITlI; ABDULRAHMAN HASSAN SHARBA TL Y; SALAHUDDIN ABDUL.! A W AD; AHMED ZAKI Y AMANI; AHMAD AL HARBI; MOHAMMED AL-ISSAI; HAMAD HUSSAIN!; ABU RIDA AL SURT A/KIA

15

\JOHAMMED LOA Y BAY AZID; SAUDI IUD CRESCENT; AHMED BRAHIM; AHI: MUSAB AL-ZARQAWI; ABU IBRAHIM AI-MASRI; DAR AL MAAL ;\L ISLAMI TRUST; OMI ADMINISTRATIVE SERVICES, S.A.; ISLAMIC ASSEMBLY OF NORTH AMERICA; SALMAN AL-OUDA; SAFAR AL-HAWALI; SALEH AL-I IUSS;\YEN; SAlVII OlVlAR AL· I ILISSA YEN: MUHAMMED.1. FAKIHI; Ql:EEN CITY CIGARETTES AND CANDY; AGUS BUDIMAN; ALBARAKi\ BANKCORP, INC.; AHlVIED RESSAM; SAID BAHAJI; ZAKARIY A ESSABAR

Defendants

I-hc ahcwe·captioned plaintiffs, by and through their attorneys, Cozen O'Connor,

,;o1l1plaining of the above-captioned defendants, do hereby allege the following:

I. PARTIES

I. Plaintiff, Federal Insurance Company ("Federal"), is a corporation

organizcd and existing under the laws of the State ofIndiana, with a principal place of

business located at 15 Mountain View Road, Warren, New Jersey 07059. At all times

material hereto. Federal was engaged in the business of issuing policies of insurance.

2. Plaintiff, Pacific Indemnity Company ("Pacific"), is a corporation

organll.cd and existing under the laws oftlic State of Wisconsin, with a principal place of

husilless located at 330 East Kilbourne Avenue, Suite I 45(), Milwaukce, Wisconsin

5)2(12 At all times material hereto, Pacific was engaged in the business of issuing

policies of insurance.

16

~. Plaintiff, Chubb Custom Insurance Company ("Chubb Custom"), is a

corporation organIZed and existlllg under the laws of the State of Delaware, with a

princip,lI plar" ol'hIL,illf'" loc:ltrd <11 15 Mountain View Road, Warren, New Jersey

070S'J. At all times material hereto, Chubb Custom was engaged in the business of

issuing policies of insurance.

4. Plaintiff, Chubb Indemnity Insurance Company ("Chubb Indemnity"), is a

corporation organiz.cd and existing under the laws of the State of New York, with a

principal placc ofbusincss located at 55 Water Street, Ncw York, New York 10041. At

all times material hereto, Chubb Indemnity Wd:::' cl1gagc::u iu ll1t: UU:::,illC:::::':::' of i:::;SlIillg


j. FlainliiT, Chubb Insurance Company of Canada ('CICC'), is a corporation

organized and eXlstil1g under the laws of the Province of Ontario, Canada, with a

principal place ot" husiness locatcd at One Financial Plaza, One Adelaide ~treet bast,

Floor 16, Toronto. iv15C 2V'! Ontario, Canada. At all times material hereto. CICC was

engagcd 111 the business 01 issull1g poliCies ollllsurance.

(l. Plaintiff, Chubb Insurance Company of New Jersey ("CICN],,), is a

corporation organized and existing under the laws of the State of New Jersey, with a

principal place oCbusincss located at 15 Mountain View Road, Warren, New Jersey

(l70S'!. At all times material hcreto, CICNJ was engaged in the business of issuing


7. Plaintiff, Great Northern Insurance Company (,"Great Northcm"), is a

corporation organized and existing under the laws of the State of Minnesota, with a

principal place of business located at lOOO Pillsbury Center, Minneapolis, Minnesota

17

55402. At all times material hereto, Great Northern was engaged in the business of


S. Plaintiff, Vigilant Insurance Company ("Vigilant"), is a corporation

organized and existing under the laws of the State of New York, with a principal place of

business located at 55 Water Street, New York, New York 10038. At all times material

hereto, Vigilant was engaged in the business of issuing policies of insurance.

9. Plaintiff, Zurich American Insurance Company ("Zurich"), is a

corporation organized and existing under the laws of the State of New York, with a

principal place of business located at 1400 American Lane, Schaumburl:(, Illinois 60196.

At all times material hereto, Zurich was cngaged in thc business of issuing policies of

insurance.

10. PlaintitT, American Guarantee and Liability Insurance Company

("American Guarantee")' is a corporation organized and existing IInoer th~ hws nrtl",

State "fNew York, with a principal place of business located at 1400 American Lane,

Schauillburg. Illinois 601 ()(L At all tiJ1lf~S l11~tE'rial hereto, An1erican Guarantee was

engaged in the business of issuing policies of insurance.

I I. PlaintifT, American Zurich Insurance Company ("American Zurich"), is a

corporation organized and existing under the laws of the State of Illinois, with a principal

place of business located at 1400 American Lane, Schaumburg, Illinois 60196. At all

times material hereto, American Zurich was engaged in the business of issuing policies of

Insurance.

12. Plaintiff, Assurance Company of America ("Assurance of America"), is a

corporation organized and existing under the laws of the State of New Yv!!\., with a

principal place of business located at 1400 American Lane, Schaumburg, Illinois 60196.

18

At all times material hereto, Assurance of America was engaged in the business of

issuing policics of insurance.

13. Plaintiff, Colonial American Casualty and Surety Insurance Company

("Colonial American"), is a corporation organized and existing under the laws of the

State of Maryland, with a principal place of business located at 1400 American I.ane,

Schaumburg, Illinois 60196. At all times material hereto, Colonial American was


14. Plaintiff, Fidelity and Deposit Company of Maryland ("Fidelity"), is a

corporation organized and existing unrlerthp l.'lw<::: of the State of Maryland, with a

principal place of business located at 1400 American Lanc, Schaumburg, I1linois 60196.

At !l111il1lc~ m~teri::\l hereto, Fidelity 'WCLS engaged in the buoincG3 ofi33uing policicB of

Insurance.

\5. Plaintiff, lVfuryland Casualty COll1pany C']\.1arylund"), is a cOI-P0fatiol1

organi/ed and existing under the laws oflhc State of Maryland, with a principal placc of

business located at 1400 American Lane, Schaumburg, Illinois 60196. At ulltilIlcS

material hereto, Maryland was engaged in the business of issuing policies of insurance.

16. Plainti ff, Northern Insurance Company of New York ("Northern"), is a


principal place ofbusine" lucateu at 1400 American Lane, Schaumburg, Illinois 60196.

At all timcs material hereto, Northern was engaged in the business of issuing policies of

insurance.

17. Plaintiff: Steadfast Insurance Company ("Steadfast"), is a corporation

organized ancl existing under the laws of the State of Delaware, WIth a pnnclpai place of

19

bUSllless located at 1400 American Lane, Schaumburg, Illinois 60196. At all times

material hereto, Steadfast was engaged in the business of issuing policies of insurance.

18. Plaintiff, Valiant Insurance Company ("Valiant"), is a corporation

organized alld existing under the laws of the State of Iowa, with a principal place of

business located at 1400 American Lane, Schaumburg, Illinois 60196. At all times

material hereto, Valiant was engaged in the business of issuing policies of insurance.

I '!. Plaintiff, One Beacon Insurance Company ("One Beacon"), is a

corporation organized and existing under the laws of the Commonwcalth of

\lassachusctts. with a principal place of business locatcd at One Beacon Street, Boston,

Massachusetts 02108. At all times material hereto, One Bcacon was engaged in the

business 01' issuing policies of insurance.

20. Plaintiff, One Beacon America Insurance Company ("One Beacon

;\mcnca"). is a corporation organized and existing under the laws of the Commonwealth

of Massachusetts. with a principal place of business located at One Beacon Street,

Boston, Massachusetts 02108. At all times material hercto, One Beacon America was


21. Plaintiff: American Employers' Insurance Company ("American

Employers"), is a corporation organized and existing under the laws of the

Coml11onwealth of Massachusetts, with a principal place of business located at One

Beacon Strect, Boston, Massachusetts 02108. At all times material hereto, American

Employers was engaged in the business of issuing policies of ins lira nee

22. Plaintiff, The Camden Fire Insurance Association ("Camden"), is a

corporation organized and existing under the laws "fthf'. Slatf' nfNew Jersey, with a

principal place of business located at One Beacon Street, Boston, Massachusetts 02108.

20

At all tlilles Illaterial hereto, Camden was engaged in the business of issuing policies of

inStlranCl:.

2J, PlaintilT, Homeland Insurance Company of New York ("Homeland"), is a


pnnclJ,,1I place of busincss located at One Beacon Street, Boston, Massachusetts 02108,

At all tll11CS material hereto, Homeland was engaged in the business of issuing policies of

insurance.

24. Plaintiff, Crum & Forster Indemnity Company ("('rum & Forster"), is a

corporation organized and existing under the laws of the State of New Jersey, with a

principal place of business located at 305 Madison Avenue, Morristown, New Jersey

07')(,0 At all times lI1aterial hereto, Crum & Forster was engaged in the business of

issuing policies of insurance,

2\ Plaintiff. North River Insurance Company ("Norlh River"), IS:J

corporation organized and existing under the laws ofthc State of New Jersey, with a

principal place ofhllsilless ioc;:lten lit 305 Madison Avenue, Morristown, New Jersey

07960. ;\t all times material hereto, North River was engaged in the business of issuing

policies of insurance,

2(,. Plaintiff, United States Fire Insurance Company ("United States Fire"), is

a corporation organized and existing under the laws of the State of New York, with a

principal place of business located at 395 Madison Avenue, Morristown, New Jersey

07060 At all time material hereto, United Statcs Fire wus cngugcd in the busincs.:; of

issuing policies of insurance,

27. Plaintiff, American Alternative Insurance Corporation ("A1ut::ril,;illl

Alternative"), is a corporation organized and existing under the laws of the State of

21

Delaware, with a principal place of business located at 555 College Road East, Princeton,

New Jersey 0854J. At all tlllles material hereto, American Alternative was engaged in

the business of issuing policies of insurance.

28. Plaintiff, Great Lakes Rcsinsurance U.K. PLC ("Great Lakes"), is a

corporation organized and existing under the laws of the United Kingdom, with a

principal place of business located at I Minster Court, Mincing Lane, London, England

EC3R 7YH. At all times material hereto, Great Lakes was engaged in the business of


29. Plaintiff, The Princeton Excess & Surplus Lines Insurance Company

("Princeton Excess"), is a corporation organized and existing under the laws of the State

of Delaware, with a principal place of business located at 555 College Road Fast.

Princeton, New Jersey 08543. At all times material hereto, Princeton Excess was

engaged in the business of ISSUlllg policies of insurance

30. Defendant, al Qaida, is a designated Foreign Terrorist Organization

("FTO"), pllrsllant 10 ~21 'J of thp Immigration and Nationality Act, as amended by the

Anti-terrorism and Effective Death Penalty Act of 1996. Established by defendant

Osama bin Laden in the late 1980's, al Qaida is a global network of several thousand

terrorist cells, members, associates and supporters, dedicated to the establishment of a

pan-Islamic Calipbate throughout the world. The network's strength is reinforced by its

ties to other FTOs, extremist organizations and sympathetic individuals and State

Sp0l1GOr3. AI Quidn frequently functionB through, 111 concert with; or with the SUppUI t ur,

the terrorist organizations and groups that operate under its umbrella or witb its support.

In February 1 ()98~ a1 Qaida issued afatwa under the banner "the World Islatuic Fluut [UI

22

Jihad Against Jews and Crusaders," saying it was the duty of all Muslims to kill United

States citizens civilian or military - and their allies everywhere.

31. Defendant, Egyptian Islamic Jihad, is a designated FTO, pursuant to §219

of the Immigration and Nationality Act, as amended by the Anti-terrorism and Effective

Death Penalty Act of 1996. Egyptian Islamic Jihad operates in concert, conspires,

exchanges material support and resources, and is otherwise affiliated with al Qaida.

Ayman al-Zawihiri, a prominent leader of Egyptian Islamic Jihad, has served as a

member of al Qaida's leadership council, known as the shura, since al Qaida's inception.

According to the United States govemment, Egyptian Islamic Jihad merged with al Qaida

at somc point prior to June 2001, but retains the capacity to commit acts ofintemational

terrorism independently.

32. Defendant, Asbat al-Ansar, is a designated FTO, pursuant to §219 of the

Immigration and Nationality Act, as amended by the Anti-terrorism and Effective Death

Penalty Act of 1996. Asbat al-Ansar operates in concert, conspires, exchanges material

support and resources, and is otherwise affiliatcd with al Qaida.

33. Defendant, AI Gama'a al-Islamiyya, is a designated FTO, pursuant to

~219 of the Immigration and Nationality Act, as amended by the Anti-terrorism and

Etlectivc Death Penalty Act of 1996. Al Gama'a al-lslamiyya operates in concert,

conspires, exchanges material support ann rr:SOllfces, and is otherwise affiliated with al

Qaida. A senior official of AI Gama'a al-Islamiyya signed al Qaida's February 1998

/at1v(J calling for attacks against the United States.

34. Defendant, Salafist Group for Call and Combat, is a designated FTO,

pursuant to §219 of the Immigration and Nationality Act, as amended by the Anti

terrorism and Effective Death Penalty Act of 1996. Salafist Group for Call and Combat

23

operates in concert. conspires, exchanges material support and resources, and is otherwise

affiliated with al Qaida.

35. Defendant, Lashkar I Janghvi, is a designated FTO, pursuant to §219 of

the Immigration and Nationality Act, as amended by the Anti-terrorism and Effective

Dcath Penalty Act of 1996. Lashkar I Janghvi operates in concert, conspires, exchanges

material support and resources, and is otherwise affiliated with al Qaida.

,(,. Defendant, Lashkar-e Tayyiba, is a designated FTO, pursuant to §219 of

the Immigration and Nationality Act, as amended by the Anti-terrorism and Effective

Death Penalty Act of 1996. Lashkar-e-Tayyiba operates in concert, conspires, exchanges


37. Defendant, Jemaah lslamiya Organization, is a designated FTO, pursuant

to 0219 of the Immigration and Nationality Act, as amended by the Anti-terrorism and

Effective Death Penalty Act of 1996. Jemaah Tslamiya Oreani7<ltinn nprrate.< in concert,

conspires, exchanges material support ,md resources, and is otherwise affiliated with al

Oaida

38. Defendant, Hezbollah, is a designated FTO, pursuant to §219 of the

Illlmigration and Nationality Act, as amended by the Anti-terrorism and Effective Death

Penalty Act of 1996. Hezbollah operates in concert, conspires, exchanges material

support and resources, and is otherwise affiliated with al Qaida. The relationship

between Hezbollah and al Qaida was forged during meetings between Osama bin Laden

and Imnd Mughniyuh, Hczbollah's chief of operations, and hus included coordination on

explosives and tactics training, money laundering, weapons smuggling and acquisition of

forged identification docunl.cnts. According to United State:) iotdlig..::u\;t; ufIh;ial:-)-J

Hezbollah operates under th; direction, and by virtue of the direct license, of the Irarlian

24

and Syrian governments. Hczbollah is, in effect, an agency and instrumcntality of the

Iranian and Syrian governments.

J'J. Defendant, Abu SayefGroup, is a designated FTO, pursuant to §219 of

thc Immigration ami Nationality Act, as amended by the Anti-terrorism and Effective

Death Penalty Act of 1996. Ahu Sayef Group operates in concert, conspires, exchanges


40. Defendant, Algerian Armed Islamic Group alk/a GIA, is a designated

FTO, pursuant to ~21 () of the Immigration and Nationality Act, as amended by the Anti-

terrorism and Effective Death Penalty Act of 1996. Algerian Anned Islamic Group

operates in concert, conspires, exchanges material support and resources, and is otherwise

affiliated with al Qaida.

41. Defendant. HAM AS, is a designated FTO, pursuant to ~219 of the

Immigration and Nationality Act, as amended by the Anti-terrorism and Effective Death

Penalty Act of I ()()h. HAMAS operates in concert, conspires, exchanges material support

and resources. and is otherwise affiliated with al Qaida.

42. Defendant, Palestine Islamic Jihad, is a designated FTO, pursuant to §219

of the Immigration and Nationality Act, as amended by the Anti-terrorism and Effective

Death Penalty Aet of 1996. Palestine Islamic Jihad operates in concert, conspires,

exchanges material support and resources, and is otherwise affiliated with a1 Qaida.

43. Defendant, The Islamic Republic ofIran ("Iran"), is a foreign state within

the 1l1eanins or 28 U.S.C. ~ 1391 (f), and u designated State SponGor of tcrroriSlTI pursuant

to the Export Administration Act of 1979 and the Foreign Assistance Act of 1961.

111. Defendant Iran has long provided material support and resources to al

Qaida. According to United States intelligence reports, the relationship between Iran and

25

i'

al Qaida dates to the early I 09()'s, when ;Ii Q"i(b nffiri"l, met with Iranian intelligence

onicials to establish an anti-American partnership,

45. According to the U.S. goverI1lnent, Iran has harbored, and continues to

harbor, senior members of the al Qaida terrorist network, Iran permits those al Qaida

operatives to lIGC the cloak of Iran';) 5tatc sovereignty to shield al Qaida':,) opt:;tatiuJ1~,

including the recruitment ofncw members, training of terrorist cells, and coordination,

planning and funding of tcrrorist attacks throughout the world,

46, In addition to its extensive direct support of al Qaida, defendant Iran has

long providcd malerial suppOrt and resources to Egyptian Islamic Jihad, Salafist uroup

for Call and C0111bat and Hezbollah, As set forth above, Hezbollah is, in effect, an

agency and lllstrumentailly oj the Iraman government.

47, By virtue of its merger with Egytpian Islamic Jihad, and affiliation with

Salalist Group je)]' Call and Combat and Hezbollah, al Qaida has materially benefited

Ii'om Iran's sponsorship of those [,TOs. Indeed, according to the testimony of Ali

Mohamcd, a U.S. green beret who pleaded gUilty to conspiring with defendant Osama bin

Laden to bomb U.S. embassies in Africa, Iran used Hezbollah to supply explosives and

explosives training to al Qaida operatives.

48. Defendant, Republic of Iraq ("Iraq"), is a foreign state within the meaning

of28 U.S.C ~ 1391(1), and a designated State Sponsor of terrorism pursuant to the Export

Administration Act of 1979 and the Foreign Assistance Act of 1961,

49. Defendant Iraq has long provided material support and resources to al

Qaida, including training in document forgery, bomb making and poison and gas

production.

26

'iO According to the U.S. government, defendant Iraq has harbored senior

members orlhe al Qaida terronst network, Iraq pcnnitted those al Qaida operatives to

use the cloak o t'lraq's state sovereignty to shIeld al Qaida's operations, incJudmg the

recruitment of new members, training or terrorist cells, and coordination, planning and

illl1ding of terrorist attacks throughout the world.

51. At all timcs material hereto, defendant Iraq operated terrorist training

camps within its borders, at which defendant Iraq provided training to members of

vanous terrorist organizations, including members of the al Qaida tcrrorist network, One

such camp was equipped with a commercial airliner fuselage, used by defendant Iraq to

train terrorist operatives, including al Qaida members, in highjacking techniques and

procedures.

52, Defendant, The Republic of Sudan ("Sudan"), is a foreign state within the

meaning of 28 U,S.c. ~ 1391 (I), and a designated State Sponsor of terrorism plmllanl In

the Export Administration Act of 1979 and thc Foreign Assistance Act of 1961, Sudan

maintains an Embassy within the United States at 2210 Massachusetts Avenue, NW,

Washington, D,C, 20008-2831.

5], Defendant Sudan has long provided material support and resources to al

Qaida, According to the United States government, Sudan's support of al Qaida has

included para-military trainine, indoctrination, money, travel documentation, safe

passage and refuge in Sudan.

S4 [)efendant Sudan openly harbored defendant OS~Ul1a bin Laden and mnny

top al Qaida lieutenants between 1991 and 1996, During that time, the Sudanese

govenU11ent pcn11itted Osanla bin Laden to establish 0.1 Qaida training campoS, sct up front

27

companies to move assets and generate new revenues, and to use the cloak of Sudan's

state sovereignty to shield al Qaida's operations.

55. In I 99(), the Sudanese government pennittecl Osama bin Laclen to move to

Afghanistan. where he was welcomed as an honored guest orthe ruling Taliban

government. rather than surrendering him to international authorities for prosecution.

5(" Defendant Sudan continues to harbor members ofthe al Qaida terrorist

network. as well as members of affiliated FTOs, and has recently permitted al Qaida and

other associated terrorist organizations to re-establish training camps within Sudan, and

to otherwise use Sudan as a base to organize their operations and support compatriots

elsewhere.

57. In addition to its extensive direct support ofal Oaida. defendant Sudan has

long provided material support and resources to defendants Egyptian Islamic Jihad and

Ilezbollah.

58. By virtue of its merger with Egytpian Islamic Jihad, and a11lliation with

Ilezboliah. al Qaida has materially benefited from Sudan's sponsorship of those FTOs.

5'J. Defendant, Syrian Arab Republic ("Syria"), is a foreign state within the

meaning 0 r 2S lJ.s.c. q 1391 (I), and a designated State Sponsor of terrorism pursuant to

the bport Administration Act of 1979 and the Foreign Assistance Aet of 1961 .

(1(). Defendant Syria has long provided material support and resources to

defendant IIc!bollah. According to the U.S. government, Syria has provided safe haven,

financial ~l11d logistical :"lssistance, training facilities and political support for J Iczbollah.

In addition. Syria has for many years facilitated weapons shipments frolll [ran to

Hezbollah. Ao Got forth above, Hezbollah is, in effect, an agency and instrumentality of

the Syrian government.

28

(, I. By virtue of Its affiliation with Hezbollah, al Qaida has materially

benefited !I'om Syria's sponsorship of that FTO.

62. Between 1992 and 2003, defendant Syria continually purchased crude oil

from defendant Iraq, in violation of United Nations Security Council resolutions and

sanctions programs designed to inhibit Iraq's ability to use funds derived from the sale of

Iraq's natural resources to promote international terrorism and pursue the development of

weapons of mass destruction. Through its state controlled bank, Syria assisted Iraq in

laundering revenues realized by Iraq through the illegal oil sales, and through other illicit

activities.

(,3. Syria's violations of the United Nations Security Council resolutions and

sanctions programs, as described above, enabled Iraq to maintain and expand its terrorist

sponsorship programs, including its provision of material support and resources to al

Qaida and afliliated FTOs, persons, organizations. commercial entities and other parties

M. Defendant Syria knew, or should have known, that al Qaida and affiliated

FTOs. persons, organizations. commercial entities and other parties would materially

benefit from Syria's illegal crude oil purchases from Iraq, and from the assistance Syria

provided to Iraq in laundering revenues from the illegal oil sales and other illieit

activities.

GS nefenrhnt. Kingdom of Saudi Arabia ("Saudi Arabia"), is a foreign state

within the meaning of28 U.S.c. ~1391(f). Saudi Arabia maintains an Embassy within

the United States at 601 New Hampshire Avenue, N.W., Wushington. D.C. 20037.

66. Defendant Saudi Arabia has long provided material support and resources

to al Quida, including flll.ancial and logicticul u3si.stance.

29

hi. According to intelligence experts and officials of the U.S. government,

Saudi Arabia has channel cd lIterally millions of dollars to al Qaida, predominantly

through various Saudi based "charities" under the government's effective control,

including defendants Muslim World Lcague, Al Haramain Foundation, International

Islamic RelicI' Organization ("IIRO"), Benevolence International Foundation, l3Iessed

Relief (Muwafaq) Foundation, Rabita Trust and World Assembly of Muslim Youth.

Ddendant Arafat Al-Asalll, the Director of IIRO in Canada and a full-time employee of

Muslim World League, contirnled the Saudi government's control over Muslim World

League and IlRO during Canadian court proceedings, tcstifying as follows:

Lct mc tell you one thing. The Muslim World League, which is the mother of IIRO, is a fully government-funded organization. In other words. I work for the Government of Saudi Arabia. [am an employee of that government. Second, the IIRO is a relIef branch ofthat organization which means that we are controlled in all our activities and pluns by the government of Saudi Arabia. Keep that in

mind, please ... I am paid by my organization which is funded hy the [Saudi] government. . The [IIRO] office, like any other office in the world, herc or in the Muslim World League, has to abide by the pohcy ofthe Government of Saudi Arabia. If anybody deviates from that, he would be fired; he would not work at all with IIRO or with the Muslim World League.

During a July 31,2003 hearing before the Senate Committee on Governmental

Allairs rcgarding terrorism financing, Dr. Dore Gold, the former Israel! Ambassador to

the U111ted Nations, similarly confirmcd the Saudi government's control over several

Saudi based "churitieo" renpol1siblc for funding al Qaidu l :stating as follow::..

[IJt would be incorrect to view these charities as purely non-govelTIl11ental organizations .... [A It the apex of each ulE;dlli"'dliull" bUd,d io d lup Saudi official. The Saudi Grand Mufti, who is also a Saudi cabinet member, chairs the Constituent Council of the Muslim World League. The Saudi Minister of Islamic Affairs chairs the Secretariat of

30

the World Assembly of Muslim Youth and the Administrative Council of al-Haramain. All three organizations have received large charitable contributions from the Saudi royal family that have been detailed in Saudi periodicals.

()~. Uespite its express awareness, tor several years pnor to September 11,

2001, that Saudi "charities" were funneling contributions to al Qaida and other terrorist

causes, Saudi Arabia continued to donate enonnous sums of money to those

organizations. Defendant Saudi Arabia knew, or should have known, that al Qaida and

affiliated FTOs, persons, organizations, commercial entities and other parties would

materially benefit from those contributions, and use the funds received from those

"charities" to finance terrorist attacks against the United States, its nationals and allies.

6'J. Despite its express awareness, for several years prior to September 11,

200 I, that Saudi "charities" were funneling contributions to al Qaida and other terrorist

causes, Saudi Arabia faikd to take appropriate and necessary steps to regulate those

"charities" and otherwise prevent them from continuing to finance tClTorism, in violation

of its obligations under United Nations Security Council Resolutions 49/60,1269,1333

and 1363. In this regard, an Independent Task Force sponsored by the Council on

Foreign Relations to investigate sources of al Qaida funding concluded as follows:

[It] is worth stating clearly and unambiguously what official U.S. govemmcnt spokespersons have not: For years, individuals and charities based in Saudi Arabia have been the most Important sOllrce ot ti.ll1ds for al-Qaeda; and for years, Saudi officials have tumed a blind eye to this problcm.

7U. Defendant Saudi Arabia knew, or should have known, that al Qaida and

affiliated FTOs, persons, organizations, commercial entities and other parties would

matenally benefit trom Saudi Arabla's failure to take appropriate and necessary steps to

31

regulate the "charities" which were funneling contrihutions to al Qaida and otherwise

pre"ent those "charities" from continuing to finance terrorism

71, Defendants, Osama bin Laden; Muhammad Atif a!k/a Subhi Sitta a/kJa

Abu Hals ai-Masri; Sayf al-Adl; Shaykh Sa'id a!k/a Mustafa Muhammad Ahmad; Abu

Ilafs the Mauritanian a/k/a Mahfouz Ould al-Walid a!k/a Khalid al-Shanqiti; Ibn al

Shaykh al-Libi; Abu Zubaydah a!k/a Zayn al Abidin Muhammad Husayn Tariq; Abd al

Ilacli ai-Iraqi a/k/a Abu Abdullah; Ayman al-Zawahiri; Thirwat Salah Shihata alk/a

Muhammad Ali; Tariq Anwar al-Sayyid Ahmad alk/a Fathi a/k/a Amr al-Fatih;

Muhammad Salah aik/a Nasr Fahmi Nasr Hasanayn; Makhtab al-Khidamat a!k/a AI

Khiliri': AI-Itihaad al-Islamiya (AlAI); Islamic Army of Aden; Wafa Humanitarian

Organization; AI-Rashid Trust; Mamoun Darkazanli Import-Export Company; Nurjaman

Riduan Ismucldin a!k/a Hamhali; Mohammed Iqbal Abdurrahman a/k/a! Abu Jibril;

Benevolence International Foundation; Benevolence Intemational Fund; Bosanska

Idealna Flitura; Global Relief Foundation a/k/a Foundation Secours Mondial; MOllnir EI

:Vlotassadeq; Ramzi Binalshibh; Zakarya Essabar; Said Bahaji; Turkistan Islamic

Movement; Wa'el Halllza Julaidan aik/a AI-Hasan al Madani; Adel Ben Soltane; Nabil

8enattra; Yassine Chekkouri; Riadh Jelassi; Mendi Kammoun; Samir Kishk; Tarek Ben

Ilabib Maaroufi; Abdelhalim Rcmadna; Mansour Thaer; Lazhar Ben Mohammed Tlili;

Habrb Waddani; Akida Bank Private Limited; Akirla InvpstlllPnt Co. Ltd.; Nasreddin

Group International Holding Ltd.; Nasco Nasreddin Holding A.S.; Nascotex S,A.;

Nasrcddin FOlll1(hltion; HA Taqw~ for Comn1erce and Real Estate COlnpany Ltd.; Miga -

Malaysian Swiss, Gulfand African Chamber; Gulf Center S,R,L.; Nascoservice S,R,L.;

Nose.o Rusinpss Rf'sirif'ncf' Cf'ntpr SAS Di Nasreddin Aluned Idri. Be; Nasreddin

Company Nasco SAS Di Ahmed Idris Nassneddin EC; Nada Intemationa1 Anstalt;

32

'iasreddin International Group Limited Holding; The Aid Organization of the Ulema;

Ailmed Idris Nasreddin; YousscfNada; Abdclkadir Mahmoud Es Sayed; Kbalid AI

Faw'lI; Abu Ilan12a AI.Masri; Mohamed Ben Bclgaccm Aouadi; Mokhtar Boughougha;

Tarck Cilaraabi; Sami Ben Khemais Essid; Lased Ben Heni; Somalia Branch of the AI

Ilaramain Islamic Foundation; Bosnia-Herzegovina branch of AI-Haramain Islamic

Foundation; LJmma Tameer-E-Nau (UTN); Bashir-Ud-Din Mahmood; Abdul Majeed;

S.M. Tufail; AI-Barakaat; AI TaqwalNada Group; Aaran Money Wire Service, Inc.; AI

Barak<! Exchange LLC; AI Barakaat Bank; AI-Barakat Bank of Somalia (BSS); AI

Barakat finance Group; AI-Barakat Financial Holding Co.; AI-Barakat Global

Telecommunications; AI-Barakat Group of Companies Somalia Limitcd; AI-Barakat

International a/k/a Baraco Co; AI-Barakat Investments; AI-Barakat Wiring Service; AI

Taqwa Trade, Property and Industry Company Limited; ASAT Trust; Bank al Taqwa

Limited: Baraka Trading Company; Barakaat Boston; Barakaa! Construction Company;

Barabat Enterprise; Barakaat Group of Companics; Barakaat International; Barakaat

International Foundation; Barakaat Intemational, Inc.; Barakaa! North America, Inc.;

Barakaat Red Sea Telecommunications; Barakaat Telecommunications Co. Somalia;

Barakat Bank and Remittances; Barakat Computer Consulting (BCC); Barakat

Consulting Group (BeG); Barakat Global Telephone Company; Barakat Intemational

Companies (BleO); Barakat Post Express (BPE); Barakat Refreshment Company;

Barakat Wire Transfer Company; Barakat Telecommunications Company Limited

(BTICLCO): Barako Trading Company, 1.1.e:; Glob"1 Services lntPnl:llional; Heyatul

Ulya; I'\ada Management Organization; Parka Trading Company; Red Sea Barakat

Company l.il11itcci: Somalia Tntemat;on"1 Rel;efOrs"ni",tinn; Somalia Internet

Company; Somalia Network AB; YoussefM. Nada & Co. Gesellschaft MBR; Youssef

33

M. Nacla; Hussein Mahmud Abdullkadir; Abdirasik Aden; Abbas Abdi Ali; Abdi

Adulaziz Ali; Yusaf Ahmed Ali; Dahir Ubeidullahi Aweys; Hassan Dahir Aweys; Garad

.lama; Ali Ghalcb Himmat; Albert Fredrich Armand Huber; Liban Hussein; Ahmed Nur

Ali .lim 'ale; Abdullahi Hussein Kahie; Mohammed Mansour; Zeinab Mansour-Fattah;

Abdullah Ahmed Abdullah a/k/a Abu Mariam a/k/a Abu Mohamed AI-Masri a/k/a Saleh;

Haji Abdul Manan Agha a/k/a Abd AI-Man'am Saiyid; AI-Hamati Sweets Bakeries;

Muhammad AI-Hamali a/k/a Mohammad Hamdi Sadiq AI-Ahdal a/k/a Abu Asim AI

Makki; Amin AI-Haq a/k/a Dr. Amin Ah Haq a/kJa Muhammad Amin a/kJa Dr. Amin UI

Haq; Saqar AI-Sadawi; Ahmad Sa'ld AI-Kadr a/kJa Abu Ahd AI-Rahman AI-Kanadi:

Anas AI-Liby a/k/a Anas AI-Libi a/kJa Nazim AI-Raghic a/kJa Nazih Abdul Hamed AI

Ragillc a/k/a Allas AI-Sabai: Ahmad Ibrahim AI- Mughassil alk/a Abu Omran a/k/a

Ahmed Ibrahim AI-Mughassil; Abdclkarim Hussein Mohamcd AI-Nasser; AI-Nul' Honey

Pn'", Shops a/kh AI-Nlir Honey ('"nl"r: Y"sin AI-Qarli a/k/a Shaykh Y""in Abdullah

Kadl a/k/a Yasin Kahdi: Sa'D AI-Sharif; AI-Shifa' Honey Press for Industry and

COIl1Il1t'ITe~ Ibrahim Salih lV1ohal11111cd AI- Yacoub; Ahn1cd Mohan1111eu H:Ul1Cd Ali a/k/a

Ahmed Mohammed Abdurehman a/kJa Abu Fatima a/kJa Abu Islam a/kJa Abu Khadiijah

a/k/a Ahmed Hamed a/k/a Ahmed the Egyptian a/kJa Ahmed Ahmed a/k/a Ahamad AI

Masri a/k/a Abu Islam AI-Surir a/k/a Ahmcd Mohammed Ali a/k/a Hamed Ali a/kJa

Ahmed Hcmed a/k/a Ahmed Shieb a/k/a Shuaib; Ali Atwa a/k/a Ammar Mansour

Bouslim a/k/a Hassan Rostom Salim; Muhsin Musa Matwalli Atwah a/kJa Abdel Rahman

a/kin Abdul Rahman a/k/a Abdul Rahman Al-Muhajir a/k/a Mohammcd K.A. Al-NuIIIGI;

Bilal Bin Marwan; Ayadi C'hafiq Bin Muhammad aJk/a Ben Muhammad Aiadi a/kJa Ben

Muhammad Aiady a/k1a BClI MUt,"III/lIdC\ Ayaui Chaiik aIkIa Bt:Il Muhammad Ayadi

Shafiq; Mamoun Darkazanli; Ali Saed Bin Ali EI-Hoorie a/kJa Ali Saed Bin Ali AI-Houri

34

alia Ali Sacd Bin Ali EI-Houri; Mustafa Mohamcd Fadhil alk/a Abd AI Wakil AI Masri

,,/k,H Abu AI-Nubi a/k/a Hassan Ali a/k/a Abu Anis alk/a Moustafa Ali Elbishy alk/a

Mustafa Muhamad Fadil a/k/a Mustafa Fazul alk/a Hussein alk/a Abu Jihad alk/a Khalid

a.lkia Nu Man alk/a Mustafa Mohammed alk/a Abu Yussrr; Ahmed Khalfan Ghailani

a/k/a Ahmed the Tanzanian alk/a Foopic a/k/a Fupi alk/a Abu Bakr Ahmad alk/a A.

Ahmed a/k/a Abubakar Ahrmcd alk/a Abubakar K. Ahmcd alk/a Abubakar Khalfan

Ahmcd alk/a Abubakary K. Ahmed alk/a Ahmed Khalfan Ahmed alk/a Ahmad AI

ranzani alkla Ahmcd Khalfan Ali a/k/a Abu Bakr alk/a Abubakary Khalfan Ahmed

Ghailani a/k/a Ammed Ghailani alk/a Ahmad Khalafan Ghilani a/k/a Mahafudh

Abubakar Ahmed Abdallah Hussein alk/a Abu Khabar alkla Ahmed Khalfan alk/a Shariff

Omar Mohammed; Riad Hijazi alkla Abu-Ahmad AI-Amriki alk/a Abu-Ahmad AI

Hawcn a/k/a Rashid AI·Maghribi alk/a Abu-Ahmad AI-Shahid alk/a Ivl Raed Hijazi;

l-IasanIzz-AI-Din alk/a ;\hmcd Garbaya alk/a Sa·ld a/k/a Smnir Salwwan; laish-I·

Mohammcd alkla Army ofMohammcd; .Iam'Yah Ta'Awun AI-Islamia a/k/a Jam'lyat AI

Ta'Awun AI Islamiyya alk/aJiT a/k/a Society of Islamic Coopcration; Mufti Rashid

Ahmad Ladehyanoy a/k/a Mufti Rasheed Ahma alk/a Mufti Rashid Ahmad Ludhianvi

alk/a Mufti Rashid Ahmad Wadehyanoy; Fazul Abdullah Mohammed alk/a Fazul

Abdalla a/k/a Fazul Adballah alk/a Abu Aisha alk/a Abu Seif Al Sudani alk/a Fadel

Abdallah Mohammed Ali alk/a Abdalla Fazul alk/a Ahdallah FazlIl a/k/a Abdallah

Mohammed Fazul alk/a Haroon Fazlll a/k/a Hartin Fazul alk/a Haroon alk/a Fadhil

Harolln alkla Hartin a/k/a Ahll T ,1I'lman a/k/a Fa..,,, I Mohammed a/kJa Fazul Abdilahi

Mohammed a/k/a Fouad Mohammed alk/a Fadil Abdallah Muhamad; Khalid Shaikh

Mohamlll<ecl alk/a Salem Ali a/k/a Fahd Bin Abdallah Bin Khalid a/kJa Ashraf Refaat

Nabith Henin alk/a Khalid Adbul Wadood; Fahid Mohammed Ally Msalarn alk/a Usama

35

.41-KIIlI a/lea Fahid Mohammed Ally alkla Fahad Ally Msalam alk/a Fahid Mohammed

Ali Ylsalal11 a/k/a Mohammed Ally Msalam alk/a Fahid Mohammed Ali Musalaam alk/a

Fahie! Mllhamad Ali Salem; RabitaIrust; Ansar ai-Islam (AI) alkla Jund al-[slam;

Y Ollssci' Abdaoui a/k/a Abu Abdullah alkla Abdellah alk/a Abdullah; Mohammed Amine

Akll aUa Samir alkla Kali Sami alk/a Elias; Mohrez Amdollni alk/a Fabio Fusco alkla

Mohammed Hassan a/kla Iuale Abu; Chiheb Ben Mohamed Ayari alk/a Abu Hohem

Hichcm; Mondhcr Baazaoui alk/a HanlZa; Lionel Dumont alk/a Bilal a/kIa Hamza alkla

.I acqllcs Brollgere; Moussa Ben Amor Essaadi alkla Dah Dah alk/a Abdclrahmman alkla

Bechir; Rachid Fehar a/k/a Amincdel Belgio alk/a Djaffar; Brahim Ben Heddi Hamami;

KhalJ! .Iarraya alk/a Khalil Yarraya alk/a Aziz Ben Narvan Alldel' alkla Amro alkla Omar

'l!k!a Amrou alk/a Amr; Mounir Ben Habib Jerraya a1k/a Varraya; Fouzi Jendoubi alkla

Said aik!a Samir; Fdhi Ben Rcbai Masri alk/a Amor a/k/a Omar Abu alk/a Fethi Alic;

'Jajill Ollaz; Ahmed llasni Rarrbo a/kla Abdallah aJk/a Abdullah; Nedal Saleh alkla

Ilitcm; Abdclghani Mzoudi; Gulbuddin Hckmatyar; [mad Mughniyeh; Muhammad

Ol11ar; Islamic [nternational Brigade; Special Purpose [slamic Regiment; and Riyadus

Salikhin Recognizance and Sabotage Battalion of Chcchen Martyrs, have been

designated as supporters and associates of terrorists by the U.S. government, pursuant to

Executive Order 13224, based on their material support and sponsorship of, or affiliation

with. defendant al Qaida and/or affiliated FIOs, associations, organizations or persons

72. Defendants Princess Haifa A[-Faisal; Prince Vandar [ban Sultan; Osama

13assnan; Om"r AI-Rayntlmi: Fahad Al-Thllmairy·. Wnrld A"embly of Muslim Youth;

Sheikh Ahmed Salim Swedan; Muhammad Abu-Islam; Abdullah 'Qassim; Hashim

4hdlllrahman· lamal AI.Radawi; Mohammed Omar Al-Harazi; Walid Al-Sourouri; Fatha

Adbul Rahman; Vasser Al-Azzani; Jamal Ba Khorsh; Ahmad Al-Shinni;Jamil Qasim

36

Saeed: Abu Abdul Rahman: Mohamed Bayazid; Abu Musab Zarqawi; Sheikh Omar

Bakri Muhammad; Abdul Fattah Zammur; Ghasoub AI Abrash Ghalyoun aJk/a Abu

Musab; Bcnsayah Belkaccm; Sabir Lamar; Wadih Wah Khan Amin Shah;

Zacarias Moussaoui; The Taliban; Maulvi Abdul Kabir; Jalil Shinwari; Noor lalil; Abdel

Hussein; Adu Agab; National Islamic Front; Hassan Turabi; Iss EI-Din EI Sayed; Lashkar

Rcdayan-E-Islami; Ahmad Salah aJk/a Salim; Abd AI-Mush in AI-Libi; Abdul Rahman

Khaled Bin Mahfollz; Abdul Rahman Yasin; Abdulla Al Obaid; Abdula Bin Laden;

Advice and Refol111ation Committee; Afghan Support Committee; Al Khaleejia for

Export Promotion and Marketing Company; AI-Haramain a/k/a AI-Haramain

Foundation; Enaam M. Arnanout; Intcl11ational Development Foundation; Intel11ational

Islamic Relief Organization; Intel11ational Institute of Islamic Thought; Islamic Cultural

Institute of MIlan; Jamal Barzinji; KJluled Bin Mahfouz; Mohammed Jamal Khalifa;

Mohamllled SalIm Bin Mahfouz; Muslim World League; National ComI11ercial Bank;

Prince Nayef Bin Abdulaziz AI Saud; Prinec Sultan Bin Abdulaziz AI Saud; Rabih

Haddah; SAAR Foundation; Saudi Sudanese Bank; Al Shamal Islamic Bank ;Sheikh Abu

Bdul Aziz Nagi; Sheik Adil Galil Batargy aJk/a Adel Abdul Jalil Batterjee; SuIeiman

Abdel Aziz AI Rajhi; Taba Investments; Tanzanite King; Ulema Union of Afghanistan;

Wadi AI Aqiq; Infocus Tech of Malaysia; Yazid Sufaat of Kuala Lumpnr Malaysia; AI

Shaykh AI-Iraqi; Azzam Service Center; Abu Hajer Al Iraqi; Mohammed AI Faisal AI

Saud; AI-Hijrah Construction and Development Limited; Gum Arabic Company Limited;

AI Sham,d For Investment and Development; Saleh Abdullah Kamel; Al Baraka

Investment and Developmcnt; Saudi Dallah Al Baraka Group LLC; Islamic Investment

Company of the Gulf; Dar-AI-Maal AI Islami: AI-Bir Saudi Organization; Mohammaci S

Mohammad; Tadamon Islamic Bank; Mustasim Abdel-Rahim; National Fund for Social

37

Insurance; Abdul-Rahim Mohammed Hussein; AI Amn AI-Dakhili: AI Amn AI-Khariji;

Ahel AI Samad AI-Ta'lsh; Mohamed Sadcek Odeh; Abdcll3arry; Ahmad Salah alk/a

Salim: Mahdi Chamran Savelli; Mnh,mllllt'ri Sarkawi; AI Tawhid; Haji Mohamad Akram;

/\bdallah Omar; Umar Faruq; Abd AI-Rahim AI-Nashiri; Turki AI Faisal AI Saud alk/a

Prince Turki; Prince Abdullah Al FaiGul Bin Abdula~iz Al Suud a1k/a Prince Abdullah;

Prince Salman Bin Abdul Aziz AI Saud a/k/a Prince Salman; Zouaydi alk/a Muhammed

Galcb Kalaje Zoaaydi a/k/a Abu Talha; Mullah Kakshar; Abdulaziz Bin Abdul Rahman

AI Saud; Arafat EI-Asahi; Haydar Mohamed Bin Laden; Mohammed Bin Abdulrahman

AI Ancfy; raisal Group Ilolding Company, AI Fai,alidh OIUU!', B",h,h Huspital;

Musllayt far Trading Establishment; Abdullah Bin Abdul Muhsen AI Turki alk/a AI

TUlki, 3autli High Cuuuuissiuu a/kla Tile Sautli High ReliefCoJl1ll1ission; Abdul Aziz AI

Ibrahim a/kia AI Ibrahim; Tarek Ayoubi; AI Anwa; Help Ati:ican People; Ibrahim Bin

}\[)(Iul A/,i! AI Ibral1im Foundation; Mercy International ReJjef Agency; Islamic

VIOVClllcnt of Uzbekistan; Saudi Bin Laden Group; Bakr M. Bin Laden; Salem Bin

Laden; Saleh Oazaz; Mohammed Hahareth; Abdullah Bm Said; Mohammed Nur Rahmi;

Tarek M. Bin Laden; Omar M. Bin Laden; Mohammed Bin Laden Organization; Saudi

Bin Laden International Company; Y cslam M. Bin Laden; Global Diamond Resource;

I-Iuman Concem Intemational Society; Talal Mohammed Badkook; Dr. Mohaman Ali

Elgari; New Diamond Holdings; M.M. Badkook Company for Catering & Trading; Al

Mustaqbal Group; National Management Consultancy Center; AI-Raj hi Banking &

Investment Corporation; Saleh Abdulaziz AI-Rajhi; Abdullah Sulaiman AI-Rajhi; Khalid

Sulaiman AI-Rajhi; Al··Watania Poultry; Mar-Jac Poultry; Mar-.Tac Investments, Inc.;

Piedmont Poultry; Salim Bin Mahfouz; SNCB Corporate Finance Limited; SNCB

Securities Limited in London; SNCB Securities Limited in New York; Saudi Economic

38

alld Development Company; Zakat Committee; Red Crescent Saudi Committee; Blessed

Relicl' hlllildation; Abdulkarim Khaled Uusuf Abdulla; Abdulrahman Bin Khalid Bin

Mahfoll.c; AI-Birr; Hishum; Hezh-e-Islami; Saif Al Islam EI Masry; Syed Suleman

Ahmcr; Mann M.H. Bahareth; Shahir Abdulraoof Batterjee; Zahir H. Kazmi; Muzaffar

Khan; Soliman l Khudeira; Jamal Nyrabeh; Ahmad Ajaj; Success Foundation;

Abdulrahman Alamoudi; American Muslim Foundation; Mohammed Omeish; Adnan

Basha; Mahmoud Jaballah; Arafat EI-Ashi; Moro Islamic Liberation Front; Jamal Ahmed

Mohammed; Mohammed Khatib; Saudi Joint Relief Committee; Taibah International Aid

Association; Islamic African Relief Agency; Tarik Hamdi; Fazeh Ahed; Sanabil AI

Khair; Sana-Bcll, Inc.; Sanabel AI-Khecr, Inc.; Khalcd Nouri; Abdullah M. AI-Mahdi;

Tarc,] M. AI-Swaidan: Abdul AI-Moslah; Salah Badahdh; Hassan A.A. Bahfzallah; M.

Yaqub Mll7.a; Ihab Ali; Samir Salah; Ibrahim Hassabc1la; Hishalll AI-Talib; Abu

SulaY1l1an; Ahmed Totonji; Iqbal Yunus; M. 01l1ar Ashraf; Mohammed .laghlit;

Muhammad Ashraf; ShcrifSedky; African Muslim Agency; Aradi, Inc.; Grove

Corporatc, Inc.; Heritage Education Trust; Mena Corporation; Reston Investments, Inc.;

Safa Trust; Sterling Charitable Gift Fund; Sterling Management Group; York

Foundation; National Development Bank; Dallah Aveo Trans Arabia Co. Ltd.; Omar Al

Bayoumi a/Ida Abu Imard; Masjed AI Madinah AI Munawarah a/k/a Masjid AI Madinah

AI Munawarah; Aqsa Islamic Bank; Aqeel AI-Aqeel; Mansouri AI-Kadi; Soliman H.S.

AI-Buthe; Perouz Seda Ghaty; Ahmed Ibrahim AI Najjar; Adel Muhammad Sadiq Bin

KaZClll: Saudi American Bank: Abdulaziz Bin Hamad: Khalil A. Kordi; Rashid M AI

ROlllaizan; Abdulaziz Bin Hamad Al Gosaibi; Saudi Cement Company in Damman;

Omar Sulailllan AI-Rajhi: Arab Cement Company: Zeinab Mansour-Fattouh; Mohammed

Chehade; Hazem Ragab; Mohammed Alchurbaji; Mustafa AI-Kadir; Abu AI-Maid; Al

39

Shamal Islamic Bank a/k/a Shamel Bank a/k/a Bank EI Shamar; Sulaiman AI-Ali; Khaled

Nomi; Muslim World League ofliccs; Abdullah Bin saleh AI-Obaid; Taha Jaber AI

Alwani; International Institute oflslamic Thought; Ibrahim S. Abdullah: Mohammed Bin

Faris: Dr. Mahmoud Oakhil; Mohammed AI Faisal AI Saud; Abdul Rahman AI Swailem;

Delta Oil Company; Nimir, LLC; Arab Bank, PLC; Dubai Islamic Bank; Nada

Management Organization, SA; Ary Group; Islamic Cultural Center of Geneva; Hani

Ramadan; The COlllmittee for the Defense of Legitimate Rights; Proycetos Y

Prol11ocioncs ISll; Afamia, SL; Cobis; Abrash Company; Promocioncs Y Construcciones

Tetuan Pricote, S.A.; Contratas Gioma; Eurocovia Obras, S.A.; Proyectos Y Promociones

Pardisc, S.L.; Proyectos Edispan; Ghasoub AI Abrash; Mustaf Ahmed AI-Hisawi alk/a

Sheik Saeed; Il11ad Eddin Barakat Yarkas a/k/a Abu Dahdah; Muhammed Galcb Kalaje

ZuoyadJ a/k/a Abu Talha; Bassam Dalali Satut; Abdalrahman Alarnout Abu Aljer alk/a

Abu obed; Mohamlllcd Khau· Al Saqqa alk/a Abu Al Darda; Ghasoub AI Abrash

GhalYllun a/k/a ;\bu Musab; Mohammed Ali Sayed Mushayt; Mohammcd Husscin AI

Al11oudi; Abu Qatada AI-Filistini a/k/a Abu Ismail alk/a Abu Umar a/k/a Abu Omar

Omar a/k/a Abu Umar Takfiri alk/a Abu Umar umar alkla AIi-Sal11l11an Uthman alk/a

Omar Mahmoud Uthman alkla Umar Uthman; Yassir AI-Sirri alkla Ammar; Mohammed

Al Massari; Lujall1 AI-Iman; Ziyad Khaleel; Ibrahim Bah; Abu Zubaydah; Mamdouh

Mahmud Salim a/k/a Abu Hajcr AI Iraqi; Sheikh Abdullah Azzam alk/a Abu

Muhammed; Abdullah Samil Bahmadan; Essam Al Ridi; Omar Abu Omar; Mohammed

Ali Hasan AI Moayad; AI Farooq Mosque; Yousef Jamee\; Ibrahim Muhammed Afandi;

Mohammed Bin Abdullah AI-Jomaith; Abdulralunan Hassan Sharbatly; Salahuddin

Abduljawad; Ahmed Zaki Yamaui; Ahmad Al Harbi; Mohammed AI-Issai: Hamad

Hussaini; Abu Rida Al Suri alkla Mohammed Loay Bayazid; Saudi Red Crescent;

40

Ahmed Brahim; Abu Musab AI-Zarqawi; Abu Ibrahim AI-Masri; Dar AI Maal AI Islami

Trust: DMI Administrative Services, S,!\.; Islamic Assembly of North America; Salman

AI-Ouda; Safar AI-Hawaii; Saleh Al-Hllssayen; Sami Omar Al-Hussayen; Muhammed],

Fakihi; Queen City Cigarettes and Candy; Agus Budiman; AI-Baraka Bankcorp, Inc,;

Ahmed Ressam; Said Bahaji; Zakariya Essabar, have aided and abetted, conspired with,

and provided material support and resources to, dcfendant al Qaida and/or affiliated

FTOs, associations, organizations or persons,

II. JURISDICTION

73. The jurisdiction ofthis Court is invoked pursuant to 28 U,S,c' § 1331

(federal question), 28 U,S,C, Ii 1332(a)(2) (divcrsity), and 28 US,c' § 1350 (Alien Tort

Claims Act),

74, The jurisdiction of this Court over defendants Iran, Iraq, Sudan, Syria and

Saudi Arabia is invoked pursuant to 28 U,S,c, § 1330, as the claims against those

defendants fall within the exceptions to immunity set forth at 28 U.S.C. §§ 1605(a)(2),

1605(a)(5) and 1605(a)(7) (Foreign Sovereign Immunities Act),

75, Venue in this district is proper pursuant to § 408(b)(3) of the Air

Transportation Safety and System Stabilization Act, 49 U,S,c' § 40101, and 28 U.S,c,

ij§ 1391(b)(2) andI391(f)(l),

III. FACTUAL BACKGROIJND

76. On September 11,2001, nineteen (19) members of the al Qaida terrorist

network hijacked four (4) commercial airliners, and used those planes as weapons in a

coordinated ten-orist attack on the World Trade Center Complex in New York and the

Pentagon in Arlington, Virginia (the "September 11 th Attack"),

4t

,-.

77. The September llih Attack resulted in the tragic loss of several thousand

lives. personal injuries to countless other persons, and property damage on a catastrophic

scale. Jl1cludillg the complete destruction of the World Trade Center Complex.

n. The September ))Ih Attack was a direct, intended and foreseeable product

of a larger conspiracy among the defendants to commit acts of international terrorism

against the United States, its nationals and allies.

79. The conspiracy among the defendants to commit acts ofintemational

terrorism against the United States, its nationals and allics, includcd the provision of

material s"ppmt and resources to defendant al Qaida and affiliated foreign states, FTOs,

persons. organizations, commercial cntities and othcr parties, as discussed above.

so. Absent thp rtlatRrial slIppm! and resources provided by the co-defendants,

both directly and indirectly, al Qaida would not have possessed the financial resources,

I'hyroical assets, membership base, terhl1olneic;]1 knowledge, communication skills. and

global reach required to conceive, plan and execute the September 11 11, Attack.

S I. At the time of the September 111h Attack, plaintiffFcderOlI provided

insurance coverage to the corporations, companies, partnerships, affiliations, persons,

trusts and other pm1ies identified in Column A of Exhibit A hereto, relative to property

and/or business interests located at the conesponding addresses identified in Column B of

exhiiJll A.' In accordance with the terms of the applicable policies of insurance, plaintiff

Federal has made payments to the insureds identified in Exhibit A in an aggregate

~1l1101111t in excess of $929,593,306, d~ :"let forth in grCatCl- dctilil in Column D of Exhibit

A, and expects that it will make additional payments in the future, in compensation for

clalllagcs reSUlting from tht;; S"I1tt;;IIlUt;;1 111h Attack, By virtue of its payrrtcnts to its

Exhibit A is expressly incorporated herem by reterence.

42

insllrcd" plaintdTFcderal is subrogated to its insureds' rights of recovery against any

responsIble tlmel parties.

S2 At the tll11e of the September 11 lh Attack, plaintiff Pacific Indemnity

provided property insurance coverage to the corporations, compat1!es, partnerships,

affiliation" pcr:ion<J, trusts and other parties identifierl in Column A oCExhibit B hereto,

relative to property and/or business interests located at the corresponding addresses

identilicd in Column B of Exhibit B2 In accordance with the terms of the applicable

policIes 0 I' insurance, plaintiff Pacific Indemnity has made aggregate payments to the

insureds ic1ClllitleLi ill ExiJibit D in an amount in exceSG of$8,21;t,390, as set fOlih in

greater detail ill Column D of Exhibit B, and expects that it will make additional

payments in tl1e CLnure, ill CUJllpeW;dlivll [UI ddillagcs resulting from the September 11 th

Attack. By virtue of its payments, plaintiff Pacific Indemnity is subrogated to its

Insurcds rights or recovery against any responsible lhilu Pdltic"

Al the time ofthe September 11 Ih Attack, plaintiff Chubb Custom

provided insurance coverage to the corporations, companies, partnerShips, affiliations,

persons, trusts anel other parties identified in Column A of Exhibit C hereto, relative (0

the property and/or business interests located at the corresponding addresses identified in

Colul1ln \3 of Exhibit ('.' In accordance with (he terms orthe applicable policies of

insurancc, plaintifTChubb Custom has made payments to the insureds identified in

Exhibit (' III an aggregate amount in excess of $612,585, as set forth in greater detail in

Coluntn J) of Exhlhit C, and expects that it will make additional payments in the future,

in compensation for damages resulting from the September 11lh Attack, By virtue of its

ExhibJt 13 ia expre"sly inCOlporated herein by reference.

Exhibit C is expressly incorporated herein by reference.

43

paYlllcn" In ils insureds, plaintiff Chubb Custom is subrogated to its insureds' rights of

recovery against any responsible third parties.

84. At the time of the S8plcmber 11 th Attack, plaintiff Chubb Indemnity

provided insurance coverage to the corporations, companies, partnerships, affiliations,

pet SUtto, It "oto and other purtics identified in Column A of Exhibit D bereto, relative to

property and/or business interests located at the corresponding addresses identified in

Column B of Exhibit D.' In accordance with the terms of the applicable policies of

insurance, plaintiff Chubb Indemnity has made payments to the insureds identified in

~Xh1111t U in an aggregate <1IIlOUllL ill exec:ss 0[$3,688,161, as sot forth in greater det3il in

Column D of Exhibit D, and expects that it will make additional payments in the future,

in compensatIOn tor tlamages reSulting [Wilt lite 3qJlelllLci 11 th Attack. By virtue of its

payments to its insureds, plaintilTChubb Indemnity is subrogated to its insureds' rights of

recovery against any responSible tl1tre! parties.

SS. At the timc ofthc September 111h Attack, plaintiffCICC provided

insurance coverage to the corporatIons, affiliations, companies, partnersl1ips, persoIls,

trusts anc! other parties identified in Column A of Exhibit E hereto, relative to property

andlor business interests located at the corresponding addresses identified in Column B of

Exhibit Eo' In accordance with the terms of the applicable policies of in sura nee, plaintiff

CICC has made payments to the insureds identified in Exhibit E in an aggregate amount

in excess of$32,876,547, as set forth in greater detail in Column D of Exhibit E, and

expects that it will make additional payments in the future, in compensation for damages

resulting from the September 11 til Attack. By virtue of its payments to its insureds,

Exhibit D i~ expressly incorporated herein by reference

Exhibit E is expressly incorporated herein by reference.

44

plainti ff eICC is subrogated to its insureds' rIghts ofrecovery against any responsible

third parties

o(J, At the time of the September II til Attack, plaintiff CleN] provided


trusts am! other parties identified in Column A of Exhibit F hereto, relative to properly

and/or business interests located at the corresponding addresses identified in Column B of

Exhibit F." In accordance with the ten1lS ofthe applicable policies of insurance, plaintiff

CICN.! has made payments to the insureds identified in Exhibit F in an aggregate amount

in nee'" nf$21 R,692, as set forth in greater detail in Column 0 of Exhibit F, and expects

that it will make additional payments in the future, in compensation for damages resulting

il'om the Septpmber II til Attack, Bv virtue of its payments to its insureds, plaintiff

CleN.! is subrogated to its insureds' rights of recovery agalllst any responsible third

87, At the time of the September 11 til Attack, plaintiff Great Northern

provided insurance coverage to the C":orporations. c0111panies, palincrships, affiliations,

pcrsons, trusts and other parties identified in Column A of Exhibit G hereto, relative to


Columll B of Exhibit G7 In accordance with the terms of the applicable policies of

ill~lIlallCC, plaintlffGrcat Northern has n1ade paytnents to the -insllrco.c.: irlentified in

Exhibit G in an aggregate amount in excess of$470,547,313, as set forth in greater detail

ill CUIUIIIIl D uf Exhibit G, and cxpcctn that it '.vill make additional payn1ents in thf':

tll(ure, ill compensation for damages resulting from the September 11 th Attack. By virtue

Exhibit F tS expressly incorporated herein by reference, ExhIbIt U IS expressly incorporaIed herein by fefelellce.

45

orits payments to its lllsureds, plaintiff Great Northern is subrogated to its insureds'

rights orrccovcry agalllst any responsible third parties,

88, At the time ofthe September 11 til Attack, plaintiffVtgilant provided


ImsTs and other parties identified in Column A of Exhibit H hereto, relative to propet1y


Exhibit H,' III accordance with the terms oflhe applicable policies of insurance, plaintiff

Vigilant has madc payments to the insureds identified in Exhibit H in an aggregate

amount in eXCeSS of S29,31 0,073, as set forth in greater detail in Column D of Exhibit H,

and expects that it will make additional payments in the future, in compensation for

dumuse" reculting li'0m the, September 11 lil Attack, By virtue of its payments to its

insureds, plalntitTVigiJant is subrogated to its insureds' rights ofrecovcry against any

rcspollt:>iblc third parties:

8'), ,\t the time of the September II 'h Attack, plaintiff Zurich provided

insurance covcrasc to the corporations, ~Ilmpanies. partnerships, affiliations, persons,

trusts alld other parties identi fied in Column A of Exhibit I hereto, relative to property


Exhibit I." III accordance with the terms of the applicable policies of insurance, plaintiff

Zurich lla~ made payments to the insureds identified in Exhibit 1 in an aggregate anlolmt

ill excess of $42(),'!4 7 JIJ2, as set forth in greater detail in Column D of Exhibit I, and

expects that it \villllwkt: adLiitional payments in the future, in compens~ttion for L-bm~l~p-s

resulting f1"Om the Septcmber Il'h Attack, By virtue of its payments to its insureds,

Exhibit H IS expressly mcorporated herein by reference, Exhibit I is expressly Incorporated herein by reference.

46

plaintitT Zurich is subrogated to its insureds' rights of recovery against any responsible

third parties.

<)0. At the time of the September 11 til Attack, plaintiff American Guarantee


persons, trusts and other parties identifIed in Column A of Exhibit J hereto, relative to


Column B of Exhibit .JIO In accordance with the terms of the applicable policies of

insurance, plaintiff American Guarantee has made payments to the insureds identified in

Exhibit.l in an aggregate amount in excess of $42,208,222, as set forth in greater detail in

Column D of Exhibit.1, and expects that it will make additional payments in the future, in

compensation lor damages resulting from the September II th Attack. By virtue of its

payments to its IJ1surec1s, plaintiff American Guarantee is subrogated to its insureds'

rights of recovery against any responsible third parties.

01. :\t thc time of the Septcmber 11th Attack, plaintiff American Zurich


persons, trusts and other parties identified in Column A of Exhibit K hereto, relative to


Column B of Exhibit K. t I In accordance with the terms of the applicable policies of

insurance, plaintiff American Zurich has made payments to the insureds identified in

Exhibit K in an aggregate amount in excess of$2,181,146, as set forth in greater detail in

Column D of Exhibit K, ""n pxppcts that it will make additional payments in the future,

in compensation for damages resulting from the September 11 th Attack. By virtue of its

tl Exhibit J is expressly incorporated herein by reference. exhibit K i.s expressly incorporated herein by reference.

47

1~',\YI11CIlI" to it,; insureds, phintiff American Zurich is subrogated to its insureds' rights of

IcCll\'CrY agai11st any responsible third parties.

')2. At the time of the September lllh Attack. plaintiff Assurance of America

prtwidcci insurance coverage to the corporations, companies, partnerships, affiliations,

persons, truslS dlHJ other parties identified in C01Ull111 A of Exhihit L hereto. relative to

propcrty anel/or business interests located at the corresponding addresses identified in

Column B of Exhibit L. I 2 In accordance with the terms of the applicable policies of

Insurance, p lainti f1' Assurance of America has made payments to the insureds identified

III ~Xhll1Jt L in an aggregate aIlIUUlll ill excess 0[$1,993,302, as sct forth in greater det::lil

in Column D of Exhibit L, and expects that it will make additional payments in the

future, III compensatIon for damages resullillg [lUlIl tl.e September Illh Attack. By virtue

of its payments to its insureds, plaintiff Assurance of America is subrogated to its

insureds' nghts of recovery aga1l1st any responsible (hinl parlies.

In. At the time of the September 11lh Attack, plaintiff Colonial American

provided lnsurance coverage to the corporations, companies, partnerships, affilialiu11s,

persons, trusts and other parties identified in Column A of Exhibit M hereto, relative to

property andior business interests located at the corresponding addresses identified in

Colul11n B of Exhibit M.13 In accordance with the terms of the applicable policies of

insurance, plaintiff Colonial American has made payments to the 1l1sureds Identified in

Exhibit M in an aggregate amount in excess of$20,OOO, as set forth in greater detail in

Colul1ln 1) of Exhibit M, and expects that it will make additional payments in the future,

1Il compensation lor damages resulting Ii"om the September Illh Attack. By virtue of its

Kxhibit L is expressly incorpor~tpfi he:rf'in hy n~fp.rf':nc.e Exhibi t M is expressly inCOIporated herein by reference.

48

payments to its insureds, plaintiff Colonial American is subrogated to its insureds' rights

of recovery agall1st any responsible third partIes.

94. At the time of the September 11th Attack. plaintiff Fidelity provided


trusts am! other parties identified in Column A of Exhibit N hereto, relative to property

and/or business mterests located at the corresponding addresses identified in Column B of

Exhibit N14 In accordance with the terms of the applicable policies of insurance,

plainti ff Fidelity has made payments to the insureds identified in Exhibit N in an

aggregate amount in excess of $1 ,559,298, as set forth in greater detail in Column D of

Exhibit N, and expects that it will make additional payments in the future, in

compensation for damages resulting from the September II th Attack. By virtue of its

payments to its insureds, plaintiff Fidelity is subrogated to its insureds' rights of recovery

against any responsible third parties.

<)). ilt tile till1e of the Septell1ber I I til Attack, plaintiff Maryland provided

in<;llI'once coveragc to the corporations, companies, partnerships, affiliations, persons,

trusts and other parties identified in Column A of Exhibit 0 hereto, relative to property

and/or business lIlterests located at the corresponding addresses identified in Column B of

Exhibit 0." In accordance with the terms of the applicable policies of insurance,

plaintiff Maryland hos made payments to the insureds identified in Exhibit 0 in an

aggregate amount in excess of $420,000, as set forth in greater detail in Column Dol'

Exhibit 0, and expects that it will m"ke additional payments in the future, in

compensation for damages resulting from the September II <h Attack. By virtue of its

15 Exhibit N is expressly incorporated herein by reference. EAhibit 0 i.s cxprc33ly incorporated herein by reference.

49

paymcnts to ItS insureds, plaintiff Maryland is subrogated to its insureds' rights of

recDvery against any responsible third pm1ies,

l)(" At the time ofthe September 11th Attack, plaintiff Northern provided


Irllsts ami other parties identified in Column A of Exhibit P hereto, relative to property


Exhibit p,l(, In accordance with the tenns of the applicable policies of insurance, plaintiff

Northern has made payments to the insureds identified in Exhibit P in an aggregate

amount in pu"" 0[:1;1.036,068, as set forth in greater detail in Column 0 of Exhibit P,

and expects that it will make additional payments in the future, in compensation for

cblllascs resultinz fi-nm the September 11 Ih Attack, By virtue of its payments to its

insureds, plaintilTNorthcrn is subrogated to its insureds' rights of recovery against any

r€:Gponsible third parties

97, At the time of the September ll'h Attack, plaintiff Steadfast provided

insurance coverage to the cOlvorations, compnnies? partnerships, affiliations, persons,

trusts and other parties identified in Column A of Exhibit Q hereto, relative to property


Exhibit Q17 In accordance with the terms of the applicable policies of insurance,

plaiIlliff StEmlfast has made payments to the insureds identified in Exhibit Q in an

aggregate amount in excess of $237,432, as set forth in greater detail in Column 0 of

ExllibiL Q, alLu t:.:{pccts that it will 111ukc additional puymentf; in the future, in

compensation for damages resulting trom the September 11th Attack, By virtue of its

Exhibit P is expressly incorporated herein by reference, bXhlblt (J IS expreSSly incorporared herein by referem.::t::.

50

paymcnts to its insureds, plaintiff Steadfast is subrogated to its insureds' rights of

recovery against any responsible third parties,

t)~ At the time of the September II th Attack, plaintiff Valiant provided

tnsurance coverage to the corporations, companies, partnerships, affiliations, persons,

trusts and other parties identified in Column A of Exhibit R hereto, relative to property

andior business interests located at thc corresponding addresses identified in Column B of

Exhibit Rlo In accordance with the terms of the applicable policies of insurance, plaintiff

Valiant anticipatcs that it may make paymcnts to the insureds identified in Exhibit R in

the illlurc, in compensation lor damages resulting from the September Illh Attack. By

virtue of any such paymcnts to its insureds, plaintiffYaliant will become subrogated to

its insureds' rights ofreeovery against any responsible third parties.

99. At the time of the September 11 '1, Attack, plaintiff One Beacon, through

policIes of insurance issued by One Beacon or by its predecessors in interest, General

f\ccidcnt. Commercial Union and CGU, providcd insurancc coverage to the corporations,

CDIllP:llli"" partnerships. al1iliations, persons, trusts and other pm1ies identified in

Column A of Exhibit S hereto, relative to property and/or business interests located at the

corresponding addresses identified in Column B of Exhibit S.'<) In accordance with the

terms of the applicable policies of insurance, plaintiff One Beacon has made payments to

the im3llreds identified in Exhibit S in an aggregate amount in excess of$161,874,055, as

set forth in greater detail in Column D of Exhibit S, and expects that it will make

additional payrnents in the future, in r,nmpp.llsation for danlagcs resulting from the

September 11111 Attack. By virtue of its payments to its insureds, plaintiff One Beacon is

subrogated to it3 insureds' rights of recovery again..::.t ;1ny re~pon~ihle third parties.

Exhibit R is expressly incorporated herein by reference. E,>\,11ihit S i:> cxprc.:ssly incorporated herein by reference.

51

lOll. At the time of the September Illh Attack, plaintiff Crum & Forster

prm Iclcrl insurance coverage to the corporations, companies, partnerships, affiliations,

persons, trusts and other parties identified in Column A of Exhibit T hereto, relative to

propertv allll/or business interests located at the corresponding addresses identified in

Colul11n 8 of Exhibit T 20 In accordance with the tem1S of the applicable policies of

insurance, plaintiffCrum & Forster has made payments to the insureds identified in

Exhibit T in <1n aggregate amount in excess of $44,300, as set forth in greater detail in

Column D of Exhibit T, and expects that it will make additional payments in the future,

III compensation for damages resulting from the September Illh Attack. By virtue of its

payme'nts to its insureds, plaintif[Crum & Forster is subrogated to its insureds' rights of

1111. At the lime of the September 11111 Attack, plaintiff North River provided

insurance ccweraE':" 10 the corporations, companies, partnerships, affiliations, persons,

trllslS 'Illd Olher parties identified in Column A of Exhibit U hereto, relative to property

"ndillr business interests lo,,"lcd at the con'esponding addresses identified in Column B of

Exhibit U." In accordance with the terms of the applicable policies of insurance,

plalllil tT North River has made payments to the insureds identified in Exhibit U in an

agt'I'cgate amollnt in excess 0[$3,407,432, as set forth in greater detail in Column D of

c.\hibit Li, and expects tbat it will make additional payments in the future, in

compcnsation for damages resulting from the September 111h Attack, By virtue of its

Pil)'JIJl:lll:) tu it;:;; in~urcd5, pluintiffNorth River is s;;ubrogated to it'> in~l1rf';rls' riehts of

recovery against any responsible third parties,

21)

Exhibit T is expressly incorporated herein by reference. exhIbit U IS expressly incorporated hereinuy 11;[I::U::;1I\..-1:;.

52

1112. At the timc of the September 11 11, Attack, plaintiff United States Fire

provided II1SlIrancc coverage to the corporations, companies, partnerships, affiliations,

persons, trusts and other parties identified in Column A of Exhibit V hereto, relative to

properly and/or business intercsts located at the corresponding addresses identified in

Column B of Exhibit y22 In accordance with the tern1S of the applicable policies of

insurance, plaintiff United States Fire has made payments to the insureds identified in

Exhibit Y ill an aggregate amount in excess of $64,885,487, as set forth in greater detail

in Column D of Exhibit Y, and expects that it will make additional paymcnts in the

lilll\J'C. in compensation for damages resulting from the September 11 11, Attack. By virtue

of its payments to its insureds, plaintiff United States Fire is subrogated to its insurcds'

l'i8hl' nf recovery against any responsible third parties.

I (n. At the time oCthe Septembcr 1111> Attack, plaintiff Americall Alternative

prm'ltleri insllronce coverage to the corporations, companies, partnerships, affiliations,

persons, trusts and other parties idcntified in Column A of Exhibit W hereto, relative to

properly allLilor husiness interests located at the corresponding addresses identified in

Column B of Exhibit W 2J In accordance with the terms of the applicable policies of

insurance, plaintiff American Alternative has made payments to the insureds identified in

Exhibit W In an aggregate amount in excess of $2, 119,967, as set forth in grcater detail in

Column D of Exhibit W, and expects th"1 it will make additional payments in the future,

in compensation for damages resulting from the September 11 th Attack. By virtue of its

pdYlllcnt:5 to it~) in~ilIrcdG, plaintiff Alnerican Alternative i, sllhroented to its insureds'

rights of recovery against any responsible third parties.

Exhibit V is expressly incorporated herein by reference. Exhibit W is expressly illCUlVulall;U hncin by reference.

53

104. At the time of the September II II, Attack, plaintiff Great Lakes provided

inslirance coverage to the corporations, companies, partnerships, affiliations, persons,

(rusts and other parties identified in Column A of Exhibit X hereto, relative to property

and/or business interests located at the cOlTcsponding addresses identified in Column B of

Exhibit XH In accordance with the terms of the applicable policies of insurance,

plaintiff Great Lakes has made payments to the insureds identified in Exhibit X in an

aggregate amount in excess of$48,112,347, as set forth in greater detail in Column D of

Exhibit X, and expects that it will make additional payments in the future, in

compensation for damages resulting from the September lllh Attack. By virtue of its

payments to its insureds, plaintiff Great Lakes is subrogated to its insureds' rights of

rtCClwcry against any responsible third parties.

IUS. At the time of the September I 1"1 Attack, plaintiff Princeton Excess


persons, trusts and other parties identified in Column A of Exhibit Y hereto, relative to

property :mo/or business interests located at the corresponding addresses identified in

Column B of Exhibit Y." ln accordance with the tenns of the applicable policies of

insurance, plaintiff Princeton Excess has made payments to the insureds identified in

Exhibit Y in an aggregate amount in excess of$925,925, as set forth in greater detail in

Column D of Exhibit Y, and expects thot it will make additional payments in the future,

in compensation for damages resulting from the September 11 Ih Attack. By virtue of its

payment3 to itG inGureds, plo.intiffPrinceton Excess j, "lIhrne:lteo to lts insureds' rights of

recovery against any responsible third parties.

Exhibit X is expressly incorporated herein by reterence. Exhibit Y is t:xptt:ssly iUI.:-UlpOl-atcd hel-cin by reference.

54

IOh. At the time of the September 11th Attack, plaintiff Federal provided

workers· compensation insurance coverage to the employers identitled in Column A of

Exhibit!. hereto, fl.)!" the benefit ofthe employees identified in Column B of Exhibit Z, in

accordance with the workers' compensation laws of the States identified in Column C of

Exhibit L cr, As a result of the September II Ih Attack, while in the course and scope of

their cmp loyment, the employees identified in Column B of Exhibit Z were injured or

killed. As a result of such injuries and deaths, and in accordance with the tefms of the

appltcable policies of insurance, plaintiff Federal has made workers' compensation

benet'l I"tyments. includin.l(, but not limited to, payments for medical bills, funeral

expenses, death bene tits and wage replacement benefits to, or on behalf of, either injured

employe.". r1Plwnr1~nts of deceased employees, or statutory designees, as identitled in

Column D of ExhibIt Z (hereinafter "claimants"). Plaintiff Federal may be obligated to

make 1\'ll1r~ pnymcnt< of workers' compensation bcnellts to, or on behalf of certain

claimants. lix which a claim is made herein. By virtue of the payments described above,

plainti iT Federal is subrogated 10 any right, claim. demand or callse of action that exists Of

may exist for the benefit of those claimants and employers arising from the September

II II> l\llack and resulting injuries to claimants or death to claimants' decedents.

107. To the extent required by the applicable workers' compensation statute,

plainldT Federal has provided the requisite notice to c.1nimants, in writing via certilled or

registered mail, that their failure to commence an action against the defendants within the

speCific ::'ldtutorily prescribed time limit would operate as an a~~i8nmpllt ()ftheir cause of

action against the defendants to the Plaintiff. Claimants failed to commence such an

actioll alld tlIt; l,dU:5C of act'Lon against the defendants to recover dama8P~ for injl1rie~ or

ExhIbIt Z IS expressly incorporated herein by n:::ft::It::IlCC.

55

death to claimants, or claimants' decedents, arising out of the September Illh Attack was

thereby duly assigned to plaintIff Federal pursuant to the applicable workers'

compcnsalJon statute.

I U8. At the time of the September 11 11; Attack, plaintiff Pacific provided

workers' compensation insurance coverage to the employers identified in Column A of

Exhibit AA hereto, for the benefit of the employees identified in Column B of Exhibit

AA, in accordance with the workers' compensation laws of the States identified in

COIUIllIl C of Exhibit AA. 27 As a result of the September 11 11; Attack, while in the course

and scope of their employment, the employees identified in Column B of Exhibit AA

were injured or killed. As a rcsult of such injuries and deaths, and in accordance with the

tpm" of the applicable policies of insurance, plaintiff Pacific has made workers'

compensation benefit payments, including, but not limited to, payments for medical bills,

fllll~r:11 expenses. death benefits and wage replacement benefits to, or on behalf of, eithcr

injured employees, dependents of deceased employees, or statutory designees, as

identified in ~olumn 0 of Exhibit AA (hereinafter "claimants"). Plaintiff Pacific may be

obligated to make future payments of workers , compensation benefits to, or on behalfof

certain claimants, for which a claim is made herein. By virtue of the payments described

above, plaintiff Pacific is subrogated to any right, claim, demand or cause of action that

exists or may exist for the benefit o[those claimants and employers arising from the

September 111h Attack and resulting injuries to claimants or death to claimants'

dcccdcntG.


plaintiff Pacific hus provided the requisite notice to chim""t~. in writing via certified or

Exllibit AA is cXPlc::,::.ly incorporated herein by reference.

56

rcglstC'rcd mail, that their failure to commence an action against the defendants within the

spccliic statutorily prescribed tune limit would operate as an assignment of their cause of

action agall1si the defendants to tbe PlaintIff. Claimants failed to commence such an

action and the cause of action against the defendants to recover damages for injuries or

death to claimants, or claimants' decedents, arising out of the September 11 th Attack was

thereby duly assigned to plaintifIPacific pursuant to the applicable workers'

compensation statute.

110. At the time of the September 11th Attack, plaintiff Great Northern

provided workers' compensation insurance coverage to the employers identified in

Column A of Exhibit 1313 hereto, for the benefit ofthc employees identified in Column 13

of Exhibit 1313, in accordance with the workers' compensation laws of the States

Identified in Column C of Exhibit BE. ~R As a result ofthe September 11111 Attack, while

tnlh", course ami scope ofthcir employment, the employees identified in Column B of

Exhibit BB were injured or killed. As a result of such injuries and deaths, and in

accnrchnce with the terms of the applicable policies of insurance, plaintiff Great Northern

has made workers' compensation benefit payments, including, but not limited to,

payments for mecJical bills, funeral expenses, death benefits and wage replacement

benefits to, or on behalf of, either injured employees, dependents of deceased employees,

or statutory designees, as identified in Column 0 of Exhibit BB (hereinafter "claimants").

Plaintiff Great Northern may be obligated to make future payments of workers'

compensation benefits to, or on hp.h~lf of certain claimants, for which a clain1 is made

herein. By virtue of the payments described above, plaintiff Great Northern is subrogated

to uny right, claim, demand or cause of action thaI "lIi.<t.< nr may exist for the benefit of

ExlJilJit BB i5 cxprc5.31y incorpora.ted herein by reference.

57

those claImants and employers arising from the September 11th Attaek and resulting

mjurJcs to claimants or death to claimants' decedents.


plaintiff Great Northern has provided the requisite notice to claimants, in writing via

certified or registered mail, that their failure to commence an action against the

defendants within the specific statutorily prescribed time limit would operate as an

assignment of their cause of action against the defendants to the Plaintiff. Claimants

Cai led to commence such an action and the cause of action against the defendants to

l"CCO\1Cr rhll1:1zes for injuries or death to c1ailnants, Of claimants' decedents, arising out of

the September 11th Attack was thereby duly assigned to plaintiff Great Northern pursuant

to the ClpplicClblp wnrkPrs' compensation statute.

112. At the time ofthe Scptember 11th Attack, plaintiffVigilunl provided

wot'ker,' COl11pcl1SGtion il1smancc covcrage 10 the employers identified in Column A of

Exhibit CC hereto, for the benefit orthe employees identified in Column B of Exhibit

CC, in accordance with the workers' comp~nsntion laws ofthc States identified in

Column C of Exhibit CC 2<) As a result of the September 11th Attack, while in the coursc

and scope oftheir employment, the employees identified in Column B of Exhibit CC

were injured or killed. As a result of such injuries and deaths, and in accordance with the

ten"s urthe applicablc policies of insurance, plaintiff Vigilant has made workers'

compcnsation bcnefit payments, including, but not limited to, payments for medical bills,

fUIlt::1 a1 \;ii.pt;:;IlSC;~, death benefits and \vuge replacement benefits to, or on behalf of, P-lthpr


ide11lilkll ill CululIJll D of Exhibit CC (hereinafter "claimants"). Plaintiff Vigilant may be

ExhibIt CC IS expreSSly incorporated herein by reference.

58

ohligated to make future payments of workers' compensation benefIts to, or on behalf of

ccrtam cLumants, f(w which a claim is made herein. By virtue of the payments described

above, plall1tiff Vigilant is subrogated to any right, claim, demand or cause of action that

exists or may exist for the benefit of those claimants and employers arising from the

Septclllber Il'h Attack and resulting injuries to claimants or death to claimants'

decedents.


plaintJlT Vigilant has provided the requisite notice to claimants, in writing via certified or

registered III ail , that their failure to commence an action against the defendants within the

specifiC statutorily prescribed time limit would operate as an assignment of their cause of

'\l,tio11 ":!:linst the defendants to the Plaintiff. Claimants failed to commence such an

action ilnd the cause of action against the defendants to recover damages for injuries or

death to chim"nts, or claimants' decedents, arising out of tile September 11 Ih Attack was

therehy duly assigned to plaintiff Vigilant pursuant to the applicable workers'

compensation St~1ttltp-3()

114. At the time ofthe September Il'h Attack, plaintiff One Beacon, through

policies of insurance issued by One Beacon or by its predecessor in interest General

ACCident, provided workers' compensation insurance coverage to the employers

Identified in Column A of Exhibit DO hereto, for the henefit orthe employees identified

III Column B of Exhibit ~O, in accordance with the workers' compensation laws of the

111 Pla1l1tiffVigilant is bringing its clatm for workers' compensation payments made to c1aimant(s) Ilndt'l" the workers' compensation laws of New Jersey in the name of such c1aimant(s)~ and/or their personal representatives In the case of deceased employees, to the use of plaintiff Vigilant, p-ursuant to Exhibit cc hereto. For purposes of protecting the identities of the individuals involved, pursuant to the accompanying Motion for Ently ofa Confidentiality Order, the names of sllchplaintiffs/clairnants are being set forth in Exhibit CC and incorporated herein to the same extent as if specifically identified in the caption and body of [hIS Complaim.

59

States idcntilied in Column C of Exhibit DD3l As a result of the September ll'h Attack,

while in the course and scope of their employment, the employees identified in Column B

of Exhibit DD were injured or killed. As a result of such injuries and deaths, and in

accordance with the terms of the applicable policies of insurance, plaintiff One Beacon

has made workers' compensation benefit payments, including, but not limited to,

payments for medical bills, funeral expenses, death benefits and wage replacement

benefits to, or on behalf of, either injured employees, dependents of deceased employees,

or statutory designees, as identified in Column D of Exhibit DD (hereinafter

"claimants"). Plaintiff One Beacon may be obligated to make future payments of

workers' compensation benefits to, or on behalf of certain claimants, for which a claim is

111,,,1,, herein. By virtue or the payments described above, plaintiff One Beacon is

subrogated to any right, claim, demand or cause of action that exist or may exist for the

benefit ,)J"th",,, clnimants and employers arising from the September II th Attack and

resulting injuries to claimants or death to claimants' decedents.

115. To the extent required by tbe applicable workers' compensation statute,

piaintiffOne Beacon has provided the requisite notice to claimants, in writing via

certified or registered mail, that their failure to commence an action against the

defendants within the speci fie statutorily prescribed time limit would operate as an

assignment of their cause of action against the defendants to the Plaintiff. Claimants

failed to commence such an action and the cause of action against the defendants to

recover dUInugC3 for injuries Of death to claimants, or c1aim:1nt~' fkcerlents, rlrising out of

the September II th Attack was thereby duly assigned to plaintiff One Beacon pursuant to

Exhibit DD is expressly iuculpUlaleLllu::u:;iu 'loy IcfClcncc.

60

the applicable workers' compcnsation statute.'1

l1C, At the time of the September ll'h Attack, plaintiff American Employers

provided workers' compensation insurance coverage to the employers identified in

Column A of Exhibit EE hereto, for the benefit of the employees identified in Column B

of Exhibit EE, in accordance with the workers' compensation laws of the States identified

in Column C of Exhibit EE. 33 As a result of the September 11th Attack, while in the

course and scope of their employment, the employees identified in Column B of Exhibit

EE were injured or killed. As a result of such injuries and deaths, and in accordance with

the terms of the applicable policies of insurance, plaintiff American Employers has made

workers' compensation benefit paymcnts, including, but not limited to, payments for

medical bills, funeral expenses, death benefits and wage replacement benefits to, or on

behalf oC either injured employees. dependents of those employees killed, or statutory

designees. as idenli fled in Column 0 of Exhibit EE (hereinafter "claimants"). Plaintiff

American Employers may be obligated to make future payments of workers'

compemation benefits to. or on behalf of certain claimants, for which a claim is made

herein. By virtue of the payments described above, plaintiff American Employers is

subrogated to any right, claim. demand or cause of action that exists or may exist for the

benefit of those claimants and employers arising from the September ll'h Attack and

resulting injuries to claimants or death to claimants decedents.

Plaintiff One I3eacon is bringing its claim for workers' compensation payments made to claimant(s) under the workers' compensation laws of New Jersey in the name of such claimant(s), and/or their personal representatives in the case of deceased employees, to the use of plaintiff One Beacon, PUl::'Udllt tv exhibit DD hereto. For purposes of protecting the idl"ntitip~ of the individuals involved. pursuant to the accompanying Motion for Entry of a Confidentiality Order, the names of such plaintiffsiclaimants are being set forth in Exhibit DD and incorporated heiein to the same extent as if specifically identified in the caption and body of this Complaint.

Exhibil EE j:, cAI-Jfc::; ... ly incorporated herein by reference.

61


plaintiff American Employers has provided the requisite notice to claImants, in writing

via certi tlcd or registered mall, that their failure to commence an action against the

deICndants within the specific statutorily prescribed time limit would operate as an

:Issignment of their cause of action against the defendants to the Plaintiff Claimants


recover damages for injuries or death to claimants, or claimants' decedents, arising out of

the September Illh Attack was thereby duly assigned to plaintiff American Employers

pursuant to thp applicable workers' compensation statute.

I 18. At the time of the September jjlh Attack, plaintiff One Beacon America

provided worker,' e0)11prnsotioll insnranee coverage to lhe employers identified in

('lllumil ;\ of Exhibit FF hereto, for the benefit of the employees identified in Column B

of Exhibit FF, ill accordance with th~ workers' compensation laws of the States identified

ill Columll C ,,{,Exhibit FF. 34 As a result of the September 1111. Attack, while in the

course und scope of their employment, the employ~es identified in Column B of Exhibit

FF were injured or killed, As a result of such injuries and deaths, and in accordance with

the terms of the applicable policies of insurance, plaintiff One Beacon America has made

workers' compensation benefit payments, including, but not limited to, payments for

medical bilb, funeral expenses, death benefits and wage replacelnent benefits to, or on

behalf 01-, either injured employees, dependents of deceased employees, or statutory

llesignccs, as itklllifi~d in Column D of Exhibit FF (hereinafter "claimants"). Plaintiff

One Beacon America may be obligated to make future payments o[workers'

compensation benefit~ Lv, VI vn behalf of certain claimants, tor which a claim is made

Exhibit FF is expressly Incorporated herein by reference.

62

herein. By virtue of the payments described above, plaintiff One Beacon America is

subrogated to any right. claim, demand or cause of action that exists or may exist for the

bene lit of those claimants and employers arising from the September II til Attack and

resulting injuries to c1aimauts or death to claimants' decedents.

II '!. To the extent required by the applicable workers' compensation statute,

plaintiff One Beacon America has provided the requisite notice to claimants, in writing

via certified or registered mail, that their failure to commence an action against the


assignment ofthcir cause of action against the defendants to the Plaintiff. Claimants

t'liled to commence such an action and the cause of action against the defendants to

recover damages for injuries or death to claimants, or claimants' decedents, arising out of

the September I I'll Attack was thereby duly assigned to plaintiff One Beacon America

pursuant to the applicable workers' compensation statute.

120. ;\t the time of the September II th Attack, plaintiff Camden provided

workers' compensation insurance coverage to the employers identified in Column A of

Exhibit GG hereto, for the benefit of the employees identified in Column B of Exhibit

GG, in accordance with the workers' compensation Jaws of the States identified in

Column C of Exhibit GG. -" As a result of the September I 1111 Attack, while in the course

ond scope of their employment, the employees identified in Column B of Exhibit GG

were injured or ki lied. As a result of such injuries and deaths, and in accordance with the

(enns ofthc applicablp policies of insurance, plaintiff Camden has made workers'

compensation benefit payments, including, but not limited to, payments for medical bills,

funeral expenses, deoth benefits and wage replar'''t11ent henefits to, or on behalf of, either

:'oS Exhibit GG is exprcssly incorporated herein by reference.

63

InJured employees, dependents of deceased employees, or statutory designees, as

identifiecl in Column 0 of Exhibit GG (hereinafter "claimants"). Plaintiff Camden may

be obligated to make fllture payments of workers' compensation benefits to, or on behalf

of certain claimants, for which a claim is made herein. By virtue of the payments

described above, plaintiff Camden is subrogated to any right, claim, demand or cause of

action that exists or may exist for the benefit of those claimants and employers arising

from the Septcmber II th Attack and resulting injuries to claimants or death to claimants'

decedents.

11 I To the extent required bv the applicable workers' compensation statute,

plaintiff Camden has provided the requisite notice to claimants, in writing via certified or

registered l11"il. th:1t their failure to commence an action against the defendants within the

specific statutorily prescribed time limit would operate as an assignment of their cause of

aclion aijainst the defendnnts to the Plaintiff Claimants failed to commence sllch an

action and the cause of action against the defendants to recover damages for injuries or

death to cloimants, or claimants' decedents, arising out of the September 11th Attack was

thereby duly assigned to plaintiff Camden pursuant to the applicable workers'

C01l1pcnsation statute. 36

122. At the time of the September 11 til Attack, plaintiff Homeland provided

wurkcu.,' cOinpensation insurance coverage to the en1ployers identified in Column A of

Exhibit HH hereto, for the benefit of the employees identified in Column B of Exhibit

Htl, ill accUllhllll-C with the V'I""orkcrs' cot11penGotion laws of the States identified in

Plall1tiff Camden is bringing its claim for workers' compensation paymenls made to claimant(s) under the worker'" ('()mpf':nsatinJ) laws of New Jersey in the name of such claimant(s), andlor their personal representatives in the case of deceased employees, to the use of plaintiff Camden, pursuant to Exhibit GG hereto. For purposes of protecting the identities of the individuals involved, pursuant to the accompanying Motion for Entry of a Confidentiality Order, the names of such plaintiffs/claimants are being set forth in Exhibit C;C; and mCOIllorated herein to the same extent as if specifically identified in the caption and body of this Complaint.

64

Column (' of Exhibit HH.'] As a result of the September 11,

1; Attack. while in the course

and scope oftbeir employment, the employees identified in Column B of Exhibit HH

were inJured or killed. As a result of such mjuries and deaths, and in accordance with the

terms <li'the applicable policies of insurance, plaintiff Homeland has made workers'

compensation bene lit payments, including, but not limited to, payments lor medical bills,

i'uneral expenses, death benefits and wage replacement benetlts to, or on behalf of, either


icicnti lied In Column 0 of Exhibit HH (hereinafter "claimants"). Plaintiff Homeland may

be obli~ated to makc future payments of workers' compensation benefits to, or on behalf

ofccI1ain clmmants. lor which a claim is made herein. By virtue of the payments

described above. plaintiff Homeland is subrogated to any right, claim, demand or cause

of action that exists or may exist for the benefit of those claimants and employers arising

from Ill" September 11,

1; Attack and resulting injuries to claimants or death to claimants'

decedents.

I 7, To the extent required by the applicable workers' compensation statute,

plainti IT Homcland provided the requisite notice to claimants, in writing via certified or

registered mail, that their failure to commence an action against the defendants within the

speedie statutorily prescribed time limit would operate as an assignment of their cause of

action "sainst the defendants to the Plaintiff. Claimants failed to commence such an

actiun and the cause of action against the defendants to recover damages for injuries or

death to t:lnimuntG, or claimants' decedents, arising out nfthf' S~rte111her 11 th Attack was

thereby duly assigned to plaintiff Homeland pursuant to the applicable workers'

compcn::Hltion 3tntute.

Exhibit HH is eXfJtessly im"vqJol"<J.tcd herein by reference.

65

124. At the time of the September 111h Attack, plaintiff United States Fire

provided workers' compensation insurance coverage to the employers idenllfied in

Column A of Exhibit \I hereto, for the benefit of the employees identified In Column B of

Exhibit 11, in accordance with the workers' compensation laws of the States identified in

Column C of Exhibit ll." As a result of the September 111h Attack, while in the course

and scope of their employment, the employees identified in C01umn B of Exhibit II were

injured or killed. As a result of such injuries and deaths, and in accordance with the

terms orthe applicable policies of insurance, plaintiff United States Fire has made

wnrk~rs' compensation benefit payments, including, but not limited to, payments for

medical bills, funeral expenses, death benefits and wage replacement benefits to, or on

beholf 0f. pitlwr injmed employees, dependents of deceased employees, or statutory

designees, as idcntiJicd in Column D of Exhibit II (hereinafter "claimants") Plallltiff

United States Firc I11"Y be ohligated to make future payments of workers' compensation

henellts to, or on behal f of certain claimants, for which a claim is made herein. By virtue

of the payments describrd ahove, plaintiff United States Fire is subrogated to any right,

claim, demand or cause of action that exists or may exist for the benefit of those

claimants and employers arising from the September 111h Attack and resulting injuries to

claimants or death to claimants' decedents.

125. To the extent required by the applicable workers' compens~tion statute,

plaintiff United States Fire has provided the requisite notice to claimants, in writing via

L:t:::1 tifit.:d ur registered mail, thtlt their failure to commence an action against the


assignn1ent or tht:il l:(.lI.l~C; of action against_the defendants to the PlaIntiff. Claimants

ExhIbIt 11 IS expreSSly incorporated herein by reference.

66


recove!, damages tor injuries or death to claimants, or claimants' decedents, arising out of

the September 11'" Attack w,,, thereby duly assigned to plaintiff United States Fire

pursuant to the applicable workers' compensation statute.

COUNT I PLAINTIFFS V. ALL DEFENDANTS

TRESPASS

126. Plaintiffs incorporate the previous allegations by reference.

127. The September ll'h Attack constituted au intentional and unlawful

trespass upon the real and personal property ofplailltif[,' i,,,urcd,, to which plaintiffs'

insureds did not consent.

128. As set forth above, the ::;eptember 11 ," Anack \Va, d uilclA, intended and

foreseeable product of a larger conspiracy among the defendants to commit acts of

international tCITorism against thc LJnlteu ::;tates, Its nationals and allies.

129. The conspiracy among the defendants to commit acts of international

telTorism against the United States, its nationals and alltes, included the provision of

material support and resources to defendant al Qaida and affiliated foreign states, FTOs,

persons, organizations, commercial entities and other parties.

130. The co-defendants knew, or should have known, that their provision of

material support and resourccs to al Qaida and affiliated foreign states, FTOs, persons,

organizations, commercial entities and other parties would result in an unlawful trespass

upon the real and personal property of plaintiffs' insureds.

131. The damages suffered by plaintiffs, as described in greater detail herein

and in the Exhibits attached hereto, were the direct and proximate result of the aforesaid

trespass upon the real and personal property of plaintiffs' insureds.

67

WHEREFORE, plaintiffs demand judgment against the defendants, jointly and

severally, for an amount m excess of $4,000,000,000, treble damages pursuant to 18

U.Se. ~2333 tlnd 18 U.S.c. ~ 1964, punitive damages, pre and post-judgment interest,

costs of this action, attorney's fees and such other and further relief as the Court may

deem appropriate under the circumstances.

COUNT II PLAINTIFFS Y, ALL DEFENDANTS

WRONGFUL DEATH


133. As a result of the September 11 11, Attack, certain ofplamtttts' l11sureds'

employees were killed, as set forth in the Exhibits attachcd hereto.

134. As a result oflhe intentional, willful and malicious killing of plaintiffs'

insureds' employees, the family members of plaintiffs' insureds' decedent employees

have suffered severe and permanent injurics, damages and losses, including, but not

limited 10, the following:

a) Economic damages, including but not limited to pecuniary losses, past and future wage losses, loss of support, loss of services, loss of parental care and guidance, and loss of prospective inheritance; and

h) Non-economic damages, including but not limited to the loss of consortium, solatium, society, companionship, care, comfort, love, mental anguiSh, bereavement and grief.

WHEREFORE, plamtltts dcmandjudgmcnt againSlll1e deferu.lallls,juilllly dUU

severally, for an amount in excess of $20,000,000,000, treble damages pursuant to 18

U.S.c. §2333 auu 18 U.S.C. § 1964, punitive damage", pre and post-judgment interest,

costs of this action and such other and further relief as the Court may deem appropriate

under the circumstances.

68

COUNT JIl PLAINTIFFS V. ALL DEFENDANTS

SURVIV AL ACTION

I ~5. Plaintiffs incorporate the previous allegatIOns by reference.

I ~(,. As a result of their deaths, plaintiffs' insureds' decedent cmployees lost

tbe enjoyment of life tbat they would have had if they had not been killcd.

1.17. Before their deaths, plaintiffs' insureds' decedent employees suffered

conscious pain and suffering, and fear of their impending deaths.

WHERFFORF, plaintiffs demandjudgmcnt against the defendants, jointly and

sevcrally. for an amount in excess of $1 0,000,000,000, treble damages pursuant to 18

u.s.c 02333 and 18 U.S.c. § 1964, punitive damagcs, pre and post-judgment interest,



COUNT IV PLAINTIFFS V. ALL DEFENDANTS

ASSAULT AND BATTERY


139. As a result of the September 11th Attack, the employees ofplaintiffs'

insureds were placed in apprehension of harmful andlor offensive bodily contact, and

were subjected to offensive and harmful contact to which they did not consent, as a result

of which they were killed or seriously injured.

140. The employees of plaintiffs' insureds who were injured but not killed as a

result of the September II th Attack suffered serious and permanent personal injuries,

severe mental and emotional anguish and suffering, impairment of their respective

69

earnin," capacities, which impairment will continue indefinitely into the future, as well as

tin<ll1clallosses and expenses,

I:) I The employees of plaintiffs' insureds who were injured but not killed as a

result of the September Illh Attack have been obligated to receive and undergo medical

attention ami care and to expend various amounts of money and incur various expenses

for the treatment oftheir injuries, and will be obligated to continue to expend additional

SlllllS or money or inclir further sllch expenses for an indefinite period of time,

WH EREFORE, plaintiffs demand judgment against the defendants, jointly and

severally, lor an amount in excess of $1 0,000,000,000, treble damage3 purGuant to 18

U,S,C ~n33 and 18 U,S,C 91964, punitive damages, pre and post-judgment interest,

COSlS or lliis dctiulJ and .5uch other and further relief as thE? Cnllrt m:ly deem appropriate

under the circllmstances,

COUNT V PLAINTIFFS V. ALL DEFENDANTS

INTENTIONAL AND/OR NEGLIGENT INFLICTION OF EMOTIONAL DISTRESS

142, Plaintiffs incorporate the previous allegations by reference,

14J, The defendants knew or should have known that their actions in

furtherance of the conspiracy to commit acts of international terrorism against the United

State, its nationals and allies, including the September lllh Attack, would result in the

l1lunlcr and serious injury of innocent persons, leaving the victims and their family

memhers with severe :md permanent physical, psychological and emotional injuries.

144, The defendants' actions in furtherance of the conspiracy to commit acts of

international terrorism against the United States, its nationals and allies, including the

70

September Illb Attack, wcre intentional, malicious, willful, unconscionable, reckless

and/or negligent.

145, As a direct and proximate result of the defendants' intentional, malicious,

willful, unconscionable, reckless and/or negligent actions, plaintiffs' assIgnors have

suffered ami will continuc to suffer severe and permanent emotional distress and anxiety,

psychological distrcss and permanent mental injury and impairment, requiring ongoing

and long-term expcnses for medical services, counseling and care, as well as other

economic losses.

WHEREFORE, plallltlffs demand jUdgment agairrsllhe defendants, jointly and


Li.().c'. ~25J3 and 18 U.C"3.C. ~i 1964, punitive damage::>, pro und post-judgment intere-;t,

costs of tl1lS ,Ktlon and such other and further relief as the Court may deem appropriate

under the cil"cLlrnstances.

COUNT VI PLAINTIFFS V. ALL DEFENDANTS

TORTURE VICTIM PROTECTION ACT


147. The conduct of the defendants, as described in greater dctail above,

SUbjected the employees of pia in tiff,' insureds to torture and/or extrajudicial killing,

within the meaning of the Torture Victim Protection Act, Pub.L. 102-256, 106 Stat. 73.

148 The actions of the defendan.ts in fnrthpT::lnC':p. of the extrajudicial killing and

torture of plaintiffs' insureds' employees were carried out under actual or apparent

authority, or color of luw, of a foreign nation 0[' nations

71

1..\'), The defendants' actions in furtherance of the conspiracy to commit acts of


September Illh Attack, were in vIOlation ofthe law of nations.

150, Pursuant to the Torture Victim Protection Act, the defendants are liable for

the extrajducial killing and torture of the employees ofplaintifTs' insureds.


scverally. for an amount in excess of $25,000,000,000, treble damages pursuant to 18

USC 02333 and 18 U.S.c. §1964, punitive damages, pre and post-judgment interest,

COStS or this actiull dud such other and further relief:18 the Court may deem ~rrToprlate


COUNT VII PLAINTIFFS V. ALL DEFENDANTS

CONSPIRACY


152. As Get forth in greater detail above, the rlefenrlants conspired to commit

acts oi'inte1l1ational terrorism against the United States, its nationals and allies, which

conspiracy included the provision of material support and resources to defendant al Qaida

and affiliated foreign states, FTOs, persons, organizations, commercial entities and other

punlCS

153. The September 11 'h Attack was a direct, forcseeable and intended product

orll1c conspiracy <:UI1lJJlg the defendants to C0111mit act3 of international terrorism against

the United States, its nationals and allies.

154. The damag<" ,u[[clcd by plaintiffs and plaintiffs' u33ignoro, uo described

in greater detail herein and in the Exhibits attached hereto, were the direct and proximate

72

result ortlle aforesaid conspiracy among the defendants to commit acts of international

terrorism against the Utlited States, its nationals and allies.

WHEREfORE, plalllt1tts demand jUdgment againsllhc defcluJanl" juintly and

severally. for an amount 111 excess of $35,000,000,000, treble damages pursuant to 18

u .S.C. ~233.3 anel 18 U .S.C. ~ 19(J4, !-,unitivc dan1agc:s, pre und pont judgn1cnt interest,



COl INT VIII PLAINTIFFS V. ALL DEFENDANTS

18 U.S.c. § 1962(a) - CIVIL RICO

155. Plaintiff's incmporate the previous allegations by reference.

156. In tl1rtherance ofthetr conspiracy to commit acts of international terrorism

against the United Stato&;, its l1a1ionals and allies, the nef"nnants engaged in a pattern of

racketeering activity which included, without limitation: acts of murder, kidnapping,

(11 son, robbery, and extortion; dealings in controlled substances and listed C.h~l11icals: the

falsitlcation ofidentitlcation documents; the unlawful procurement, reproduction, sale

and usc of naturalization and citizenship papers, passports and visas; the obstruction of

federal and state criminal investigations; and financial institution and mail fraud.

157. The dan1age, suffered by plaintiffs and plaintiffs' assignors, as described


result of the aforesaid paltell! vI' IClcketecring activity by the defendants, acting

individually and in concert with one another.


severally. for an amount in excess of$35,000,000,000, treble damages pursuant to 18

73

USC ~2333 and 18 USc. ~ 1064, punitive damages, pre and post-judgment interest,

costs ofthis action, attol11ey's fees and sneh other and further rclief as the Court may

deenl appropriate under the Circumstances,

COUNT IX J'LAINTIFFS V. ALL DEFENDANTS

AIDING AND ABETTING

158, Plaintiffs incorporate the previous allegations by reference,

15<), Through the material support and resources provided to al Qaida, the eo-

defendants aided and abetted al Qaida in its campaign to commit acts of international

terrorism against the United States, its nationals, and allies,

160. The September 11 110 Attack was a direct, intended and foreseeable product

of the atding and abetting of al Qaida by the co-defendants.

161 The damages suftered by plaintitTs and plaintiffs' assignors, as described


result of the aforesaid aiding and abetting of al Qaida by the co-defendants, acting

individually and in concert with one another.



U.S,c. ~2333 alld 18 U.S.c. ~ 1 ')64, punitive damages, pre and post-judgment interest,


deern appropriate under thf': C'.lrC:1l111stances.

74

COUNT X

PLAINTIFFS V. ALL DEFENDANTS 18 U.S.c. § 2333

162. Plaintiffs incorporate the previous allegmions by refelellcc;.

1 (,J. The September 11 th Attack constitutes an act of international terrorism

within the meaning of 18 U.S.c. § 2331.

164. As a result of the September 11 Ih Attack, plaintiffs' insureds suffered

injuries to their real and personal property, as described in greater detail herein and in the

Exhibits attached hereto.

1(,). As a result of the September Ill" Attack, the employees of plaintiffs'

insureds suffered injuries to their person, as described in greater detail herein and in the

bhibits attached hereto.

166. By virtue of their participation in the conspiracy to commit acts of

lIlternational terrorism against the United States, its nationals and allies, including the

September 11 Ih Attack, the defendants are liable to plaintiffs for threefold all damages

resulting hom the September 11 Ih Attack, costs of this suit and attorney's fees, pursuant

to 18 U.S.c. § 2333.

WHEREFORE, plaintiffs demand jUdgment against the defendants, jointly and


USC. §2333 and 18 U.S.c. § 1964, punitive damages, pre and post-judgment interest,


under 1 he circumstances.

75

COUNT XI PLAINTIFFS V. ALL DEFENDANTS

NEGLIGENCE

167. Plaintiffs incorporate the previous allegations by refe.ellce.

16R. As set fOlih above, the September II·h Attack was a direct, intended and

!orcsecablc product of a larger conspiracy among the defendants to commit acts uf

international terrorism against the United States, its nationals and allies.

169. The conspiracy among the defendants to commit acts of international

terrorism against the United States, its nationals and allies, included the provision of

material support and resources to defendant al Qaida and affiliated foreIgn states, FTUs,

persons. organizations, commercial entities and other parties.

170. By virtue of their paliicipation in the conspiracy to commit acts of


September 11 11, Attack, the defendants negligently, intentionally, recklessly, willfully and

wantonly breached duties of care owed to plainti ffs and the employees of plaintiffs'

insureds.

171. The damages suffered by plaintiffs and plaintiffs' assignors, as described

in greater detail herein and in the Exhibits attached hereto, werc the direct and proximate

result of the aforesaid breaches of care by the defendants.


"0v 0roll1', 1'01' an amount in excp« of'h'lS,OOO.OOO.OOO. treble damages pursuant to 18

\i.S.C 92333 and 18 U.S.c. § 1964, punitive damages, pre and post-judgment interest,

~osts of this action. attorney's fees and such other and further relief as the Court may


76

-'; .:~ ::,

COUNT XII PLAINTIFFS V. ALL DFFRNDANTS

PUNITIVE DAMAGES

172 Plaintiffs incorporate the previous allegations by reference.

173. The defendants' actions in furtherance of the conspiracy to commit acts of

international terrorism against the United States, its nationals and allies. were intentional,

malicious, willful, unconscionable and reckless.

174. By virtue of their intentional, willful, unconscionable and reckless actions,

defendants arc jointly and severally liable to plaintiffs for punitive damages.

WIiEREfORE, pidilltif[> demand judgment against the defendants, jointly and

severally. for punitive damages in an amount in excess of $200,000,000,000.

JURY DEMAND

Plaintiffs demand a trial by jury as to all claims so triable.

WHEREFORE, plaintiffs demand:

Count I Trespass - $4,000,000,000 lor resulting propeI1y damages, business interruption losses and related injuries;

Count II - Wrongful Death - $50,000,000 for each wrongful death assignor;

Count III - Survival Action - $25,000,000 for each wrongful death assignor:

Count IV - Assault and Battery - $15,000,000 for each assignor;

C())mt V- Intentional anc\Jor Negligent Infliction of Emotional Distress -5)20,000,000 for each assignor;

Count VI ToI1ure Victim Protection Act - $50,000,000 for each

Count VII - Conspiracy- $50,000,000 for each assignor, and $4,000,000,000 for property damages, business interruption losses and J daLt::u illj urics;

77

Count VJll- Civil RICO - treble damages in the amount of$150,000,000 for each assignor, and $12,000,000,000 for all property damages, business interruption losses and related il~uries claimed herein;

Count IX Aiding and Abetting - $50,000,000 for each assignor, and $4,000,000,000 for prnp~rty damages. business interruption losses and related injuries;

Count X - Violation of 18 U.s.c. ~ 2333 - treble damages in the amount ur$IS0,000,OOO for each assignor, and $12,000,000,000 for all prnp"rty damages, business interruption losses and related injuries claimed herein;

Count XI- Negligence - $50,000,000 for each assignor, and ~4,OOO.000,000 for property damages, business interruption losses and related injuries;

Count XII - Punitive Damages - Punitive damages in the amount of ~300,000,000 for each assIgnor, and $50,000,000,000 for all prupelly damages, business interruption losses and related inj uries claimed herein.

Dated: New York, New Yurk September 10, 2003

OF COUNSEL:

STEPHEN A. COZEN, ESQUIRE ELLIOTT R. FELDMAN, ESQUIRE SEAN P. CARTER, ESQUIRE JOHN M. POPILOCK, ESQUIRE J. SCOTT TARBUTTON, ESQUIRE COZEN O'CONNOR 1900 Market Street Philadelphia, PA 19103 (215) 665-2000

BY:

COZEN O'CONNOR

'1t<LJ"~, MICHAELJ. SOM~SQ. (MS-7910) 45 Broadway Atrium, 161h Floor New York, NY 10006 212-509-9400

78

ALL EXHIDITS APPENDED TO PLAINTIFFS' COMPT .ATNT

ARE FILED UNDER SEAL PURSUANT TO THE ORDER ISSUED

BY THE HONORABLE ROBERT PATTERSON, JR., Cj

DATED SEPTEMBER yt,2003

.... -

: f~~t~:~ :;I~d~~"di±:'~~~fI::::sh~,is

Documents

45 8roadway. I hill Floor New YIlrk, New York 10006