-3-
4.
Illicit federal funding endangers the lives of the Plaintiffs and theirloved ones.5.
Plaintiffs bring this action to stop that funding, demand that illegaldisbursements be divested from the Palestinian Authority, that any future funding be incompliance with U.S. law and regulations and to secure their safety.
JURISDICTION AND VENUE
6.
This Court has jurisdiction over the claims in this action pursuantto 28 U.S.C. §§ 1331 (action arising under the laws of the United States), 1346(a)(2)(United States as defendant), and 1361 (mandamus).7.
Venue lies in this district pursuant to 28 U.S.C. § 1391(b) and (e).8.
Upon information and belief, all Defendants reside in the Districtof Columbia.9.
A substantial part of the events giving rise to this action look placewithin the District of Columbia.
PARTIESA. Plaintiffs
10.
Plaintiff Rachel Bernstein is an American citizen who resides inIsrael. She was injured in a terrorist attack in 1976 in Jerusalem.11.
Plaintiff Stuart Hersh is an American who citizen who resides inIsrael. He was injured in a 1997 suicide bombing in Jerusalem.12.
Plaintiff Ron Moritz is an American citizen who resides in Israel.
Case 1:12-cv-01906 Document 1 Filed 11/26/12 Page 3 of 58