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IN

THE UNITED STATES DISTRICT COURT


FOR THE SOUTHERN DISTRICT OF NEW YORK


AHMED BAHGAT, et al.

)





)





)
v.




) Civil Action No. 1:13-cv-08894-AT





)





)
ARAB REPUBLIC OF EGYPT, et al. )





)
________________________________________ )

ARAB REPUBLIC OF EGYPTS MOTION TO DISMISS


COMES NOW THE DEFENDANT, Arab Republic of Egypt, by and through its
undersigned counsel, John Hermina, Esquire, and the HERMINA LAW GROUP, and
moves this Honorable Court to dismiss this matter, and as for its reasons, it states:

1. That as the attached Memorandum of Law In Support of the Motion to

Dismiss will show, the Plaintiffs have not made a prima facie case that the Arab
Republic of Egypt (Egypt) does not enjoy immunity pursuant to the Foreign
Sovereign Immunities Act (the FSIA), 28 U.S.C. 1602, et seq. or that any exception
contained within 1605 through 1607 apply to this action.
2. That all of the transactions, which form the basis for the underlying
litigation, were conducted in Egypt, and the Plaintiffs relied on their Egyptian status
in dealing with the National Bank of Egypt, the other Defendant in this case.
Therefore, the expropriation exception does not apply.
3. That all of the transactions complained of were centered in Egypt, and any
alleged financial losses due to any purported seizure occurred in Egypt. Therefore,
the commercial activities exception is also inapplicable to this case.

WHEREFORE, the Government of Egypt respectfully requests that this


Honorable Court dismiss this matter against it.

BY:











Respectfully Submitted,
THE PLAINTIFFS,

/s/ John Hermina_______________


John Hermina, Esq.
HERMINA LAW GROUP
Laurel Lakes Executive Park
8327 Cherry Lane
Laurel, Maryland 20707
John@herminalaw.com
Tel 301-776-2003
Fax 301-490-7913


CERTIFICATE OF SERVICE



I HEREBY CERTIFY that on this 22nd day of June 2014, a copy of the above
Amended Complaint was transmitted to Defendants counsel named below, via the
Courts ECF system.

Ahmed M. Elmokadem, Esquire
4919 Hidden Dune Court
San Diego, CA 92130








/s/ John Hermina


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