Plaintiffs respectfully request that this Court deny Defendants’ Motions To Dismiss and permit Plaintiffs’ claims to proceed to discovery and trial. Defendants mislead the Court by portraying Plaintiffs as challenging the State Department’s policies. As explained below, nothing could be further from the truth. Plaintiffs are challenging Mr. Prince’s callous scheme to kill, repeatedly, innocent Iraqis. This scheme was implemented without the knowledge or consent of the State Department. This scheme was motivated by Mr. Prince’s greed and his racist Christian supremacist views. Mr. Prince and his Blackwater companies deceived the State Department, and destroyed evidence that might have led to the detection of the scheme. Mr. Prince’s actions, and those of his alter ego companies, should not evade judicial review. No statutory or decisional law supports Mr. Prince’s claim that he is immune from the rule of law.
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