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Case 1:17-Cv-02651-UA Document 1 Filed 04/12/17 Page 1 of 157 Case 1:17-cv-02651-UA Document 1 Filed 04/12/17 Page 1 of 157 IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK ---------------------------------------------------------------------------------------X THE CHARTER OAK FIRE INSURANCE COMPANY, FIRST FLORIDIAN AUTO AND HOME INSURANCE COMPANY, Case No. THE PREMIER INSURANCE COMPANY OF MASSACHUSETTS, _____________ THE PHOENIX INSURANCE COMPANY, THE STANDARD FIRE INSURANCE COMPANY, THE AUTOMOBILE INSURANCE COMPANY OF HARTFORD, CONNECTICUT, FARMINGTON CASUALTY COMPANY, FIDELITY AND GUARANTY COMPLAINT INSURANCE UNDERWRITERS, INC., FIDELITY AND GUARANTY INSURANCE COMPANY, UNITED STATES FIDELITY AND GUARANTY COMPANY, CONSTITUTION STATE SERVICES, LLC, ST. PAUL MERCURY INSURANCE JURY TRIAL COMPANY, ST. PAUL PROTECTIVE INSURANCE COMPANY, DEMANDED ST. PAUL FIRE AND MARINE INSURANCE COMPANY, ST. PAUL GUARDIAN INSURANCE COMPANY, THE TRAVELERS This Action INDEMNITY COMPANY, THE TRAVELERS INDEMNITY COMPANY OF AMERICA, THE TRAVELERS INDEMNITY Relates to: COMPANY OF CONNECTICUT, TRAVELERS PROPERTY In re: Terrorist CASUALTY COMPANY OF AMERICA, TRAVELERS CASUALTY Attacks on AND SURETY COMPANY, TRAVELERS LLOYDS OF TEXAS September 11, INSURANCE COMPANY, TRAVELERS PERSONAL INSURANCE 2001 COMPANY, TRAVELERS PERSONAL SECURITY INSURANCE COMPANY, TRAVCO INSURANCE COMPANY, TRAVELERS PROPERTY CASUALTY INSURANCE COMPANY, TRAVELERS (03-MD-1570- CASUALTY COMPANY OF CONNECTICUT, and TRAVELERS GBD-SN) CASUALTY AND SURETY COMPANY OF AMERICA, Plaintiffs, v. AL RAJHI BANK, NATIONAL COMMERCIAL BANK, SAUDI BINLADIN GROUP, MOHAMED BINLADIN COMPANY, MOHAMED BINLADIN ORGANIZATION, THE MUSLIM WORLD LEAGUE, INTERNATIONAL ISLAMIC RELIEF ORGANIZATION, WORLD ASSEMBLY OF MUSLIM YOUTH, AL HARAMAIN ISLAMIC FOUNDATION, and DALLAH AVCO TRANS ARABIA, Defendants. --------------------------------------------------------------------------------------X Case 1:17-cv-02651-UA Document 1 Filed 04/12/17 Page 2 of 157 Plaintiffs, The Charter Oak Fire Insurance Company, First Floridian Auto and Home Insurance Company, The Premier Insurance Company of Massachusetts, The Phoenix Insurance Company, The Standard Fire Insurance Company, The Automobile Insurance Company of Hartford, Connecticut, Farmington Casualty Company, Fidelity and Guaranty Insurance Underwriters, Inc., Fidelity and Guaranty Insurance Company, United States Fidelity and Guaranty Company, Constitution State Services LLC, St. Paul Mercury Insurance Company, St. Paul Protective Insurance Company, St. Paul Fire and Marine Insurance Company, St. Paul Guardian Insurance Company, The Travelers Indemnity Company, The Travelers Indemnity Company of America, The Travelers Indemnity Company of Connecticut, Travelers Property Casualty Company of America, Travelers Casualty and Surety Company, Travelers Lloyds of Texas Insurance Company, Travelers Personal Insurance Company, Travelers Personal Security Insurance Company, Travco Insurance Company, Travelers Property Casualty Insurance Company, Travelers Casualty Company of Connecticut, and Travelers Casualty and Surety Company of America, by and through the undersigned counsel, alleges the following upon information and belief: THE PARTIES 1. Plaintiff, The Charter Oak Fire Insurance Company, is a corporation organized and existing under the laws of the State of Connecticut, with its principal place of business located at One Tower Square, Hartford, Connecticut. At all times material hereto, The Charter Oak Fire Insurance Company was engaged in the business of issuing policies of insurance. 2. Plaintiff, First Floridian Auto and Home Insurance Company, is a corporation organized and existing under the laws of the State of Florida with its principal place of business located at 7840 Woodland Center Boulevard, Tampa, Florida. At all times material hereto, First 2 Case 1:17-cv-02651-UA Document 1 Filed 04/12/17 Page 3 of 157 Floridian Auto and Home Insurance Company was engaged in the business of issuing policies of insurance. 3. Plaintiff, The Premier Insurance Company of Massachusetts, is a corporation organized and existing under the laws of the State of Connecticut with its principal place of business located at One Tower Square, Hartford, Connecticut. At all times material hereto, The Premier Insurance Company of Massachusetts was engaged in the business of issuing policies of insurance. 4. Plaintiff, The Phoenix Insurance Company, is a corporation organized and existing under the laws of the State of the State of Connecticut with its principal place of business located at One Tower Square, Hartford, Connecticut. At all times material hereto, The Phoenix Insurance Company was engaged in the business of issuing policies of insurance. 5. Plaintiff, The Standard Fire Insurance Company, is a corporation organized and existing under the laws of the State of Connecticut with its principal place of business located at One Tower Square, Hartford, Connecticut. At all times material hereto, The Standard Fire Insurance Company was engaged in the business of issuing policies of insurance. 6. Plaintiff, The Automobile Insurance Company of Hartford, Connecticut, is a corporation organized and existing under the laws of the State of Connecticut with its principal place of business located at One Tower Square, Hartford, Connecticut. At all times material hereto, The Automobile Insurance Company of Hartford, Connecticut was engaged in the business of issuing policies of insurance. 7. Plaintiff, Farmington Casualty Company, is a corporation organized and existing under the laws of the State of Connecticut with its principal place of business located at One Tower 3 Case 1:17-cv-02651-UA Document 1 Filed 04/12/17 Page 4 of 157 Square, Hartford, Connecticut. At all times material hereto, Farmington Casualty Company was engaged in the business of issuing policies of insurance. 8. Plaintiff, Fidelity and Guaranty Insurance Underwriters, Inc., is a corporation organized and existing under the laws of the State of Wisconsin with its principal place of business located at One Tower Square, Hartford Connecticut. At all times material hereto, Fidelity and Guaranty Insurance Underwriters, Inc. was engaged in the business of issuing policies of insurance. 9. Plaintiff, Fidelity and Guaranty Insurance Company, is a corporation organized and existing under the laws of the State of Iowa, with its principal place of business located at One Tower Square, Hartford, Connecticut. At all times material hereto, Fidelity and Guaranty Insurance Company was engaged in the business of issuing policies of insurance. 10. Plaintiff, United States Fidelity and Guaranty Company, is a corporation organized and existing under the laws of the State of Connecticut, with its principal place of business located at One Tower Square, Hartford, Connecticut. At all times material hereto, United States Fidelity and Guaranty Company, was engaged in the business of issuing policies of insurance. 11. Plaintiff, Constitution State Services, LLC, is a limited liability company organized and existing under the laws of the State of Delaware with its principal place of business located at One Tower Square, Hartford, Connecticut. At all times material hereto, Constitution State Services LLC was engaged in the business of claim administration and recovery services. 12. Plaintiff, St. Paul Mercury Insurance Company, is a corporation organized and existing under the laws of the State of Connecticut with its principal place of business located at One Tower Square, Hartford, Connecticut. At all times material hereto, St. Paul Mercury Insurance Company was engaged in the business of issuing policies of insurance. 4 Case 1:17-cv-02651-UA Document 1 Filed 04/12/17 Page 5 of 157 13. Plaintiff, St. Paul Protective Insurance Company, is a corporation organized and existing under the laws of the State of Connecticut with its principal place of business located at One Tower Square, Hartford, Connecticut. At all times material hereto, St. Paul Protective Insurance Company was engaged in the business of issuing policies of insurance. 14. Plaintiff, St. Paul Fire and Marine Insurance Company, is a corporation organized and existing under the laws of the State of Connecticut with its principal place of business located at One Tower Square, Hartford, Connecticut. At all times material hereto, St. Paul Fire and Marine Insurance Company was engaged in the business of issuing policies of insurance. Pursuant to a merger in 2003, St. Paul Fire and Marine Insurance Company is the legal successor in interest to St. Paul Insurance Company of Illinois. At all times material hereto, St. Paul Insurance Company of Illinois was engaged in the business of issuing policies of insurance. Pursuant to a merger in 2016, St. Paul Fire and Marine Insurance Company is the legal successor in interest to St. Paul Fire and Casualty Company. At all times material hereto, St. Paul Fire and Casualty Company was engaged in the business of issuing policies of insurance. 15. Plaintiff, St. Paul Guardian Insurance Company, is a corporation organized and existing under the laws of the State of Connecticut with its principal place of business located at One Tower Square, Hartford, Connecticut. At all times material hereto, St. Paul Guardian Insurance Company was engaged in the business of issuing policies of insurance. 16. Plaintiff, The Travelers Indemnity Company, is a corporation organized and existing under the laws of the State of Connecticut with its principal place of business located at One Tower Square, Hartford,
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