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HOUSE_OVERSIGHT_023388

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In re: TERRORIST ATTACKS ON SEPTEMBER 11, 2001., 2012 WL 257568 (2012) why the district court disregarded and failed to credit plaintiffs’ extensive, entirely adequate pleadings, see infra Point I.B.2; failed to draw reasonable inferences from those pleadings, see infra *76 I.B.3; and declined to accept the truth of the facts alleged by plaintiffs, see infra Point LB.4. Application of this heightened standard is especially misguided in light of Congress’s intent that the ATA reach just the conduct that plaintiffs allege. That is, “Congress[] clearly expressed [an] intent to cut off the flow of money to terrorists at every point along the causal chain of violence.” Boim J, 291 F.3d at 1021. Congress did this by “attach[ing] liability to all donations to foreign terrorist organizations regardless of the giver’s intent” because “foreign organizations that engage in terrorist activity are so tainted by their criminal conduct that any contribution to such an organization facilitates that conduct.” Jd. at 1027. Moreover, Congress enacted Section 2339B, a criminal provision incorporated through the ATA, out of a “concern that terrorist organizations could raise funds ‘under the cloak of a humanitarian or charitable exercise.’ ” Weiss, 453 F. Supp. 2d at 626 (quoting H.R. Rep. 104-393, at 43 (1995)). That statute was designed to “ ‘severely restrict the ability of terrorist organizations to raise much needed funds for their terrorist acts within the United States.’ ” Jd. Any effort to impose a heightened pleading standard upon terrorism-related *77 cases, as the district court did, thus “thwart[s] Congress’ clearly expressed intent.” Boim J, 291 F.3d at 1021. 2. The District Court Understated and Ignored Plaintiffs’ Extensive Pleadings Addressing Defendants’ Knowing and Reckless Support of Terrorism. Although the district court acknowledged that plaintiffs had in certain respects pled that the defendants knowingly provided support to al-Qaeda," it radically understated the

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