“commercial activity” exception, a plaintiff must: 1.) identify specific assets, such as accounts or funds, of the sovereign; 2.) that are located within the United States; and 3.) used for a “commercial activity” within the United States; as well as 4.) demonstrate that the “commercial activity” is the same activity upon which the plaintiffs claim is based. 28 U.S.C. § 1610(a)(2); see also Walters v. Indus. and Commercial Bank of China, Ltd., 651 F.3d 280, 297 (2d Cir.2011). As the plaintiff has the burden to identify assets that come within the Section 1610(a)(2) exception, courts have recognized the necessity of limited jurisdictional discovery to establish whether a claim comes within the exception. See, e.g., Arriba Ltd. v. Petroleos Mexicanos, 962 F.2d 528, 534 (5th Cir.1992) (<HOLDING>); Filus v. Lot Polish Airlines, 907 F.2d 1328,
holding immunity from liability is not jurisdictional recognizing the role of limited jurisdictional discovery to verify allegations of specific facts crucial to an immunity determination holding that while as a general matter discovery should be freely permitted  j jurisdictional discovery is justified only if the plaintiff reasonably demonstrates that it can supplement its jurisdictional allegations through discovery recognizing the need for limited jurisdictional discovery to establish exception to the fsia holding that a discovery exception to a statute of limitation applies only to the discovery of facts not discovery of the law