Whether petitioners/survivors of the atrocities committed by the Laos communist government met their pleading burden under the Alien Tort Claims Act by alleging that the USA conducted a secret war in Laos; made a verbal request and agreement with the King of Laos to hire Hmong people in Laos to fight the secret war in Laos; made a solemn promise from USA President to King of Laos to protect the Hmong no matter who won or lost the war; brought over substantial stockpiles of highest grade (CIA grade) level guns, ammunition, air planes, barrels of poison; all of which was conducted planned out of CIA, Langley, Virginia as official acts of the US government, and then later brokered a peace treaty forced upon the Laos Royals that was immediately thereafter breached by the Laos Communist; resulting in the communist taking possession of all the US CIA weapons, and turning those very weapons into weapons of a genocide against the Hmong people of Laos.

Whether the immunities afforded to heads of state invoked by the Suggestion of Immunity submitted by the United States of America pursuant to 28 USC section 517 for the Laos President and Prime Minister are inapplicable to this case because it involves claims of war crimes involving genocide, sex crimes, torture, evisceration, and other mayhem committed openly against the Hmong people in Laos.

Whether petitioners/survivors of the atrocities committed by the Laos communist government met their pleading burden under the Alien Tort Claims Act