brief - Iran 911 Case

APPENDICESPLAINTIFFS’ FIRST MEMORANDUM OF LAW IN SUPPORT OF MOTIONFOR ENTRY OF JUDGMENT BY DEFAULT AGAINST SOVEREIGN DEFENDANTSthe Islamic Republic of Iran, 90 F.Supp.2d 107 (D.D.C. 2000), andCicippio v. The Islamic Republic of Iran, 18 F.Supp. 2d 62 (D.D.C.1998).221. Since the time Iran was designated by the Department of State as astate sponsor of terrorism, a large body of evidence has been collectedand analyzed which shows conclusively that Iran views terrorism as aninstrument of state policy, like diplomacy or military power - a tool tobe used to further political objectives. The evidence shows that Iran has,over the years, directly carried out assassinations, bombings and otherterrorist acts against its enemies. It has also provided direct and indirectsupport to international terrorist groups in the form of money, training,sanctuary, documentation, intelligence, weapons and other types ofassistance, including to defendant Al Qaeda.222. To carry out its policy of terrorism and support for terrorist groups,Iran has created and used government organizations includingintelligence ministries, the military, special groups and various types ofcovert entities which are part of the government and are directlyanswerable to, and receive instructions from, the regime in power.223. As described above, Iran acted through its officials, officers,agents, employees, agencies and instrumentalities in providing materialsupport and resources to defendants Al Qaeda, Bin Laden and otherdefendants. The support provided by Iran to Bin Laden and Al Qaedaassisted in and contributed to the preparation and execution of the plansthat culminated in the Terrorist Hijacked Flights and the extrajudicialkilling of the Decedents.224. The following defendants, collectively referred to as the ―IranianInstrumentalities,‖ were among the officials, officers, agents,employees, agencies and instrumentalities through which Iran caused,supported and contributed to the terrorist acts that resulted in the deathof the Decedents: (the list of Instrumentalities includes Hezbollah, AlQaeda, and Osama Bin Laden).252. In the second half of November 1997, Ayatollah Ali Khameneiconvened a meeting with General Rahim Safavi and Ahmad Vahidi, theformer commander of al-Quds Forces, to discuss the establishment of anew elite terrorist force to carry out spectacular, but deniable, terroriststrikes against the United States and the West.viii