In Brief:

  • Amini LLC has been engaged as trial counsel in a legal action against defendants, the United Nations Relief and Works Agency (UNRWA) and several of its current and former senior leaders, currently underway before the U.S. District Court for the Southern District of New York.

  • The case asserts that the acts committed by Hamas, with UNRWA’s and the individual defendants’ assistance, constitute torts under international law as well as violating the Torture Victims Protection Act.

  • The lawsuit alleges that UNRWA and its leadership knowingly misdirected over $1 billion to Hamas, a terrorist organization as designated by the United States and other countries, in violation of the law.

  • The U.S. Department of Justice has filed a letter arguing that defendants UNRWA and the individual defendants are entitled to immunity under the treaty known as the Convention on Privileges and Immunities of the United Nations.

  • Amini LLC is challenging this position on behalf of our clients, arguing that UNRWA and the individual defendants are not entitled to immunity for the acts alleged.

  • Several prominent organizations & individuals filed friends of the court briefs.
  • UNRWA and Individual Defendants filed a Memorandum of Law in support of their Motion to Dismiss, challenging the court's jurisdiction and service of process, and asserting entitlement to immunity under the CPIUN and IOIA.
  • Amini LLC filed a Memorandum of Law in Opposition to Defendants’ Motion to Dismiss, arguing that immunity under the CPIUN and IOIA protect only the UN itself, and does not shield UNRWA or the Individual Defendants from accountability for aiding and abetting terrorism.
  • Amini LLC filed a pre-motion letter seeking authorization for alternative service on the remaining overseas defendants, as UNRWA and the U.S.-based defendants had already been served. The letter highlights the impracticality of using The Hague Convention or traditional methods for service, given the defendants’ locations, and requests alternative service via their New York-based counsel.
  • Defendants filed a Reply Memorandum in support of their Motion to Dismiss, reaffirming claims of diplomatic immunity and inviolability under the CPIUN and VCDR, including immunity from service of process.
  • Defendants request the Court deny Amini LLC’s request for alternative service, arguing that Plaintiffs should be required to follow the traditional service methods outlined in the Hague Convention and other applicable procedures.

For more information or inquiries, please contact marketing@aminillc.com.

Documents

Plaintiffs' Complaint Filed by Amini LLC

June 24, 2024

Filed in the US District Court for the Southern District of New York on behalf of 101 plaintiffs (non-U.S. citizen victims of the October 7 Attack and/or their estates & survivors).

The Complaint >>

 

United States Government Asserts Immunity for Defendants

July 30, 2024

The United States Government claimed immunity for the named defendants on grounds that UNRWA is affiliated with the United Nations.

Department of Justice Letter >>

Exhibit 1 >>
Exhibit 2 part 1 >>
Exhibit 2 part 2 >>

Amini LLC’s Opposition to Immunity

September 13, 2024

Argument that UNRWA lacks immunity for the claims brought forth in the government’s letter.

Plaintiff Memorandum of Law Response to Government Immunity Letter >>

U.S. Department of Justice Responds to Plaintiffs' Memorandum of Law

October 18, 2024

The United States Department of Justice's response to plaintiff's Memorandum of Law in opposition to the U.S. Government's claims of immunity for UNRWA and named defendants.

Department of Justice Letter Against Plaintiff Memorandum of Law >>

Amini LLC’s Memorandum of Law in Further Opposition to the US Government’s Immunity Letters

November 8, 2024

Plaintiffs’ Sur-Reply in further opposition to the United States Department of Justice’s Response asserting that the Court should dismiss their claims on immunity grounds.

Amini LLC’s MOL Against US Government’s Immunity Letters >>

Amicus Briefs

September 2024

Several prominent organizations and individuals filed Friends of the Court briefs.

Brief of Amici, A >>

Brief of Amici, B >>

UNRWA and Individual Defendants' Memorandum of Law in Support of Motion to Dismiss

December 16, 2024

UNRWA and Individual Defendants filed a memorandum in support of their Motion to Dismiss, challenging the court's jurisdiction and service of process, in accordance with Federal Rule of Civil Procedure.

Memorandum in Support>>

 

Amini LLC’s Memorandum of Law in Opposition to Defendants’ Motion to Dismiss

January 13, 2025

Amini LLC opposes the Defendants’ Motion to Dismiss, asserting that immunity under the CPIUN and IOIA does not shield UNRWA or the Individual Defendants from accountability for aiding and abetting terrorism. These laws protect only the UN itself, not its affiliated organizations, and do not cover grave violations such as jus cogens offenses.

Exhibit S: Complete list of "subsidiary organs" of the UN General Assembly, which does not include UNRWA>>

Memorandum of Law>>

Amini LLC Pre-Motion Letter Seeking Authorization for Alternative Service for Overseas Defendants

January 13, 2025

Amini LLC filed a pre-motion letter seeking authorization for alternative service on the remaining five overseas defendants, who have not responded to the formal Rule4(d) requests for waiver of service. The letter requests alternative service via the defendants’ New York counsel due to the impracticality of Hague Convention service and traditional methods, which would cause costly and unnecessary delays given their respective countries of residence. 

Pre-motion Letter>>

 

Defendants' Reply Memorandum in Support of Motion to Dismiss

January 21, 2025

Defendants filed a Reply Memorandum in support of their Motion to Dismiss, reasserting claims of diplomatic immunity and inviolability under the CPIUN and VCDR, including immunity from service of process.

Reply Memorandum>>

 

Defendants’ Opposition to Plaintiffs’ Pre-Motion Letter for Alternative Service

January 21, 2025

Defendants argue that the Court should deny Amini LLC’s request for alternative service, contending that Plaintiffs should be required to follow traditional procedures of service established by the Hague Convention or other traditional methods.

Pre-Motion Letter>>

 

About Amini LLC

Amini LLC is a premier boutique litigation practice, distinguished by its team of seasoned trial attorneys who excel in handling complex, high-stakes commercial disputes and achieving multi-million-dollar outcomes for clients. To learn more about our work, please visit our website.

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