brief - Iran 911 Case

provided material support to al Qaeda before, contemporaneously with, and after the 9/11attacks.Havlish experts specifically conclude that the evidence is clear and convincingthat Iran materially supported al Qaeda. See Ex. 8, Clawson Affid. 43; Ex. 3, BymanAffid. 14; Ex. 4, Kephart Affid. 79; Ex. 5, Snell Affid. 23. Although each of theHavlish experts‘ affidavits speaks for itself, two passages fairly summarize their views:―It is our expert opinion to a reasonable degree of professional certainty that the IranianRegime‘s use of terror and, specifically, its material support of al Qaeda in multipleterrorist attacks, including 9/11, is beyond question.‖ Ex. 6, Lopez-Tefft Affid. 50(emphasis omitted); see also id., 31-49, 352. ―Iran [has] provide[d] material support toal-Qaeda within the meaning of 18 U.S.C. Section 2339A(b)1.‖ Ex. 8, Clawson Affid.56 (emphasis omitted).While the 9/11 Commission pointedly recommended that the assistance to alQaeda by Iran and Hizballah was a ―topic [that] requires further investigation by the U.S.government,‖ 9/11 REPORT, p. 241 – and obviously it still is, Ex. 3, Byman Affid. 68;Baer, Blow The House Down, pp. 296-97 [author‘s note] – Plaintiffs here submit thattheir own ―further investigation‖ in this case has conclusively demonstrated, by clear andconvincing evidence, the fact of Iran‘s material support, and direct support, for al Qaedaand the 9/11 attacks.VIII.CONCLUSIONThe evidence submitted by the Plaintiffs in this case, even without considering theevidence being filed under seal, is well beyond the evidence required to establish the civilliability of the Islamic Republic of Iran for the September 11, 2001 terrorist attack uponthe United States. The Plaintiffs‘ substantial evidence is clear and convincing, and96