T4 B5 9-11 Families Suit- Motion To Dismiss Fdr- Entire Contents- Court Docs- 1st Pgs Scanned For Reference 284

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

THOMAS BURNETT, et al.,

) ) Plaintiffs, ) ) v. ) ) AL BARAKA INVESTMENT AND ) DEVELOPMENT CORPORATION, et al. ) ) Defendants. )

Civil Action No. 1:02CVO 1616 Judge Robertson

DEFENDANT HIS ROYAL HIGHNESS PRINCE SULTAN BIN ABDULAZIZ AL-SAUD'S MOTION TO DISMISS

Baker Botts L.L.P. The Warner 1299 Pennsylvania Avenue, N.W. Washington, D.C. 20004-2400 (202) 639-7700

April 7, 2003

DC01:34I955.6

Attorneys for Defendant His Royal Highness Prince Sultan bin Abdulaziz Al-Saud

EXHIBIT 1

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

THOMAS BURNETT, el a/.,

Plaintiffs,

) )

) ) v. ) ) AL BARAKA INVESTMENT AND ) DEVELOPMENT CORPORATION, et at. ) Defendants.

Civil Action No. 1:02CV01616 Judge Robertson

) )

DECLARATION OF ABDULAZIZ H. Ai FAHAD I, Abdulaziz H. Al Fahad, declare as follows: 1. This declaration is given at the request of United States counsel for His Royal Highness Prince Sultan bin Abdulaziz Al-Saud, to describe certain matters of fact and law in connection with Prince Sultan's motion to dismiss the complaint in this action. I have been retained by Prince Sultan and am being compensated for my work in this matter. 2. I *m a lawyer admitted to practice in the Kingdom of Saudi Arabia. I was born and raised in Saudi Arabia, and received an undergraduate, graduate and legal education in the United States. I received a B.A. degree in economics from Michigan State University in 1979, an M.A. In International Relations from the Johns Hopkins University School of Advanced International Studies in 1980, and a J.D. degree from Yale Law School in 1984. During 19841985,1 was a Post-Doctoral Fellow at the Harvard's Center for Middle Eastern Studies and a Research Fellow at Harvard Law School. 3. Currently I am the principal of the Law Office of Abdulaziz H. Fahad in Riyadh, in affiliation with the United States law firm Akin; Gump, Strauss Hauer & Feld. I am a member of the Academic Committee, Legal Experts Commission, Council of Ministers (which is charged with translating official government documents); a member of the Advisory Commission of the Supreme Economic Council; and a member of the International Trade Committee of the Council of Saudi Chambers of Commerce and Industry. I have occasionally taught and written on Middle Eastern law, politics and economics. I am also a licensed Arabic to English translator, holding Licence No. 138 issued by the Mininistry of Commerce of the Kingdom of Saudi Arabia.

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

THOMAS BURNETT, et al.> Plaintiffs,

) ) )

) ) ) ALBARAKA INVESTMENT AND ) DEVELOPMENT CORPORATION, «t al. ) ) Defendants. ) v.

EXHIBIT 2

Civil Action No. 1:02CV01616 Judge Robertson

DECLARATION OF SALEH ABDULLAH AL SAYKHAN, MANAGER OF FINANCIAL ADMINISTRATION OF THE INTERNATIONAL ISLAMIC RELIEF ORGANIZATION

IN THE NAME OF GOD, THE MERCIFUL, THE COMPASSIONATE, I, Saleh Abdullah Al Saykhan, state as follows: 1.

I am the Director of Financial Administration of the International Islamic

Relief Organization ("I1RO"), an international charitable organization with headquarters in Jeddah, Kingdom of Saudi Arabia. I have held my current position for approximately two months. Based on that experience, I have personal knowledge of the IIRO's internal operations and charitable activities. The statements made in this declaration are based on that personal knowledge. I understand that this declaration may be submitted to an American court in connection with a lawsuit that has been filed against His Royal Highness Prince Sultan bin Abdulaziz Al-Saud ("Prince Sultan"). 2.

The IIRO is an Islamic charitable organization established by the World

Muslim League in 1978 to provide relief and humanitarian assistance to people in need around the world. The IIRO's headquarters are located in Jeddah, Kingdom of Saudi Arabia, and it has