I ---
UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF NEW YORK
BRUCE SMITH, in his own
right, as personal representative
of the ESTATE of INGRID SMITH
deceased, and on behalf of all
others similarly situated,
Plaintiff, >
>
V. ) 94-W-5556 (TCP)
>
>
THE SOCIALIST PEOPLE'S LIBYAN
ARAB JAMAHIRIYA; LIBYAN EXTERNAL
SECURITY ORGANIZATION, A/K/A
JAMAHIRIYA SECURITY ORGANIZATION;
LIBYAN ARAB AIRLINES; ABDEL-BASSET
AL1 AL-MEGRAHI, A/WA MR.
BASET, A/K/A AHMED KHALIFA
ABDUSAMED, A/K/A ABDEL BASSET A.
MOHMED, A/WA ABD AL-BASIT
AL-MAQRAHI; and LAMEN KHALIFA
FHIMAH, A/K/A AL AMIN KHALIFA
FHIMAH, A/K/A MR. LAMIN,
Defendants.
FOURTH AMENDED CLASS ACTION COMPLAINT
Plaintiff, Bruce Smith, in his own right, and as personal representative of
wife, Ingrid Smith, and on behalf of all others similarly situated for his complaint
defendants, alleges as follows:
PARTIES
1. Plaintiff Bruce Smith ("Smith") is a citizen of the United States,
2. At the time of her death, Smith's wife, Ingrid Smith, was a citizen of
SNIPPETS:
BRUCE SMITH, in his own right, as personal representative of the ESTATE of INGRID SMITH
THE SOCIALIST PEOPLE'S LIBYAN
ABDEL-BASSET AL1 AL-MEGRAHI, A/WA MR. BASET, A/K/A AHMED KHALIFA ABDUSAMED, A/K/A ABDEL
FHIMAH, A/K/A AL AMIN KHALIFA
Plaintiff, Bruce Smith, in his own right, and as personal representative of his deceased
defendants, alleges as follows:
As described more fully below, Ingrid Smith was killed while an airline passenger, in
Defendant The Socialist People's Libyan Arab Jamahiriya is a foreign
is the Libyan intelligence service through which Libya conducted acts
of extrajudicial killing, aircraft sabotage and other acts of terrorism, including the acts
Defendants Abdel Basset Ali Al-Megrahi, a/k/a Abdelbaset Ali Mohmed, a/k/a
AbdelBaset Ali Mohmed Al Megrahi, a/k/a Mr. Baset, a/k/a Ahmed Khalifa Abdusamad, a/k/a
and at all relevant times were employees and agents of Libya and the JSO.
of the United States under and in accordance with the provisions of 28 U.S.C. 8 1330(Supp.
the United States and other targets in Western nations.
as in the case of Pan Am Flight 103.
killing and aircraft sabotage alleged herein, Libya, the JSO and LAA, through various
Paragraphs 1 through 13 hereof are incorporated herein by reference.
Two hundred forty-three passengers, including Ingrid Smith as well as 16 crew
implementing the deliberate destruction of Pan Am Flight 103 and the deaths of 270 persons,
On or about January 21, 1992, the United Nations Security Council adopted
04 battery upon Ingrid Smith and the decedents of the other class members as set
k> violation of the Antiterrorism Act as set forth in paragraphs 8 1 through 84 herein;
Protection Act, the international laws and treaties set forth in paragraph 11 hereof, and
Judgment on Count I for compensatory damages in the amount
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