In re Terrorist Attacks on September 11, 2001, 392 F.Supp.2d 539 (2005) 10 A.L.R. Fed. 2d 789 Once we understand the word “conduct” to require Wa‘el Jalaidan, TRO, Tarik Hamdi, Abdulrahman some degree of direction and the word “participate” to Alamoudi, Mar—Jac Poultry, and the SAAR Network require some part in that direction, the meaning of § executives. Terrorist Attacks I, 349 F.Supp.2d at 829; 1962(c) comes into focus. In order to “participate, N.Y. C.P.L.R. 215(3). To the extent the Ashton and directly or directly, in the conduct of such Burnett Plaintiffs plead that Defendants are liable for the enterprise’s affairs,’ one must have some part in September 11 attacks as co-conspirators or aiders or directing those affairs. Of course, the word abettors of al Qaeda, they will have pled a claim for relief “participate” makes clear that RICO liability is not for intentional infliction of emotional distress, which limited to those with primary responsibility for the requires extreme and outrageous conduct, intent to cause enterprise’s affairs, just as the phrase “directly or severe emotional distress, a causal connection between indirectly’ makes clear that RICO liability is not the conduct and the injury, and severe emotional distress. limited to those with a formal position in the enterprise, See Stuto v. Fleishman, 164 F.3d 820, 827 (2d Cir.1999). but some part in directing the enterprise’s affairs is The Federal Plaintiffs’ trespass claims require “the required. interference with a person’s right to possession of real property either by an unlawful act or a lawful act Id. at 179, 113 S.Ct. 1163. Therefore “to state a claim for performed in an unlawful manner.” N.Y. State Nat’] Org. liability under § 1962(c), Plaintiffs must allege that the for Women y. Terry, 886 F.2d 1339, 1361 (2d Cir.1989). [Defendants] participated ‘in the operation or Provided the Federal Plaintiffs plead that Defendants here management of the enterprise itself,’ which requires that acted in