brief - Iran 911 Case

order of the Iranians and being financed almost entirely by the Iranians‖ and ―the [1983]attack [on the Marines barracks in Beirut] itself would have been impossible without theexpress approval of Iranian government leaders at the highest level.‖ Valore v. IslamicRepublic of Iran, 478 F.Supp.2d 101, 105 (D.D.C. 2007); see also Valore v. IslamicRepublic of Iran, 700 F.Supp.2d 52 (D.D.C. 2010)(citing Dr. Patrick Clawson as ―anexpert on Iranian terrorism activities‖); Peterson v. Islamic Republic of Iran, 515F.Supp.2d 25, 51 (D.D.C. 2007)(citing Dr. Clawson as ―a widely-renowned expert onIranian affairs over the past 25 years‖); Estate of Heiser v. Islamic Republic of Iran, 466F.Supp.2d 229 (D.D.C. 2006)(citing both Dr. Bruce Tefft and Dr. Patrick Clawson asexperts in the field of terrorism); Campuzano v. Islamic Republic of Iran, 282 F.Supp.2d258 (D.D.C. 2003)(same). Indeed, the courts have relied on expert testimony to awardpunitive damages against Iran in at least eleven terrorism cases where the plaintiffs metthe ―clear and convincing evidence‖ standard. See Appendix A.Plaintiffs‘ experts are some of the most knowledgeable persons in the world onthe subject of Iran‘s terrorist activities: former members of the 9/11 Commission staff,former CIA case officers, a former chief of the U.S. National Central Bureau ofINTERPOL, noted academics, an accomplished investigative journalist from the UnitedStates, as well as a noted intelligence analyst from Israel, and a highly-regarded formerFrench investigative magistrate judge specialized in terrorism cases. Their opinions,supported by the 9/11 REPORT, U.S. State Department terrorism reports, U.S. TreasuryDepartment reports, court records, FBI and INTERPOL notices, declassified intelligenceagency materials, other governmental documents, open source information, andinformation from intelligence sources, demonstrate clearly and convincingly that Iran95