brief - Iran 911 Case
brief - Iran 911 Case 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
APPENDICESPLAINTIFFS’ FIRST MEMORANDUM OF LAW IN SUPPORT OF MOTIONFOR ENTRY OF JUDGMENT BY DEFAULT AGAINST SOVEREIGN DEFENDANTS253. Al Qaeda telephone bills of international calls between 1996 and1998 were analyzed by United States investigators, showing that nearly10% of the outgoing calls from Afghanistan went to Iran.254. According to the State Department‘s Patterns of Global Terrorism2000, Iran remained the most active state sponsor of terrorism in 2000.It provided increasing support to numerous terrorist groups, includingthe Lebanese Hezbollah, HAMAS, and the Palestine Islamic Jihad (PIJ),which seek to undermine the Middle East peace negotiations through theuse of terrorism.255. The State Department‘s Patterns of Global Terrorism 2000 alsostated that Iran‘s ―Revolutionary Guard Corps (IRGC) and Ministry ofIntelligence and Security (MOIS) continued to be involved in theplanning and execution of terrorist acts and continued to support avariety of groups that use terrorism to pursue their goals.‖256. In January 2001, Dr. Ayman al-Zawahri and other Al Qaedaleaders met with Iranian intelligence officials at a mountain guesthousenear the town of Varamin, just south of Tehran. The Iranian delegationwas headed by Hojjat-ol eslam Ali Akbar Nateq-Nouri and includedImad Fayez Mugniyeh, a Labanese operative and leader of Hezzbollahwho is credited with numerous terrorist attacks on Americans. Thepurpose of the meeting was to plan and coordinate Iranian support for anupcoming Al Qaeda operation against the United States.257. On May 4, 2001, a second planning meeting between Al Qaeda andIranian intelligence officials was held in Iran. Attendees at this planningmeeting included Khamenei, Rafsanjani, and Bin Laden‘s son, Saad BinLaden. Iranian intelligence memos written in the weeks following themeeting advise Iranian operatives to be prepared for U.S. retaliation foran attack planned for September 2001.APPENDIX EThe Islamic Republic of Iran’s Early Terrorist ConnectionsEven before taking power in 1979, Ayatollah Ruhollah Khomeini, a Shiite Muslim, hadix
- Page 61 and 62: Zawahiri met with Imad Mughniyah, w
- Page 63 and 64: The historic 1993 meeting in Kharto
- Page 65 and 66: continuing terrorist training of al
- Page 67 and 68: the issuance of INTERPOL Red Notice
- Page 69 and 70: investigators concluded the operati
- Page 71 and 72: symbols. Ex. 6, Lopez-Tefft Affid.
- Page 73 and 74: worldwide terrorism is ―a report
- Page 75 and 76: AND TERRORIST TRAVEL, pp. 65-66. Mo
- Page 77 and 78: see Ex. 2, Timmerman 2nd Affid. 148
- Page 79 and 80: that the ―senior Hezbollah operat
- Page 81 and 82: actual foreknowledge of the plannin
- Page 83 and 84: Thus, Iran‘s facilitation of the
- Page 85 and 86: the present day. Testifying before
- Page 87 and 88: January 16, 2009; Ex. 2, Timmerman
- Page 89 and 90: The January 16, 2009, Treasury desi
- Page 91 and 92: Indeed, Iran permitted al Qaeda to
- Page 93 and 94: The fact is that many important ―
- Page 95 and 96: little other than KSM‘s own self-
- Page 97 and 98: terrorism operations against the U.
- Page 99 and 100: of Mughniyah‘s offices in Beirut.
- Page 101 and 102: provided material support to al Qae
- Page 103 and 104: Walter S. Batty, Jr. (PA Bar No. 02
- Page 105 and 106: APPENDICESPLAINTIFFS’ FIRST MEMOR
- Page 107 and 108: APPENDICESPLAINTIFFS’ FIRST MEMOR
- Page 109 and 110: APPENDICESPLAINTIFFS’ FIRST MEMOR
- Page 111: APPENDICESPLAINTIFFS’ FIRST MEMOR
- Page 115 and 116: APPENDICESPLAINTIFFS’ FIRST MEMOR
- Page 117 and 118: APPENDICESPLAINTIFFS’ FIRST MEMOR
- Page 119 and 120: APPENDICESPLAINTIFFS’ FIRST MEMOR
- Page 121 and 122: APPENDICESPLAINTIFFS’ FIRST MEMOR
- Page 123 and 124: APPENDICESPLAINTIFFS’ FIRST MEMOR
- Page 125 and 126: APPENDICESPLAINTIFFS’ FIRST MEMOR
- Page 127: APPENDICESPLAINTIFFS’ FIRST MEMOR
APPENDICESPLAINTIFFS’ FIRST MEMORANDUM OF LAW IN SUPPORT OF MOTIONFOR ENTRY OF JUDGMENT BY DEFAULT AGAINST SOVEREIGN DEFENDANTS253. Al Qaeda telephone bills of international calls between 1996 and1998 were analyzed by United States investigators, showing that nearly10% of the outgoing calls from Afghanistan went to <strong>Iran</strong>.254. According to the State Department‘s Patterns of Global Terrorism2000, <strong>Iran</strong> remained the most active state sponsor of terrorism in 2000.It provided increasing support to numerous terrorist groups, includingthe Lebanese Hezbollah, HAMAS, and the Palestine Islamic Jihad (PIJ),which seek to undermine the Middle East peace negotiations through theuse of terrorism.255. The State Department‘s Patterns of Global Terrorism 2000 alsostated that <strong>Iran</strong>‘s ―Revolutionary Guard Corps (IRGC) and Ministry ofIntelligence and Security (MOIS) continued to be involved in theplanning and execution of terrorist acts and continued to support avariety of groups that use terrorism to pursue their goals.‖256. In January 2001, Dr. Ayman al-Zawahri and other Al Qaedaleaders met with <strong>Iran</strong>ian intelligence officials at a mountain guesthousenear the town of Varamin, just south of Tehran. The <strong>Iran</strong>ian delegationwas headed by Hojjat-ol eslam Ali Akbar Nateq-Nouri and includedImad Fayez Mugniyeh, a Labanese operative and leader of Hezzbollahwho is credited with numerous terrorist attacks on Americans. Thepurpose of the meeting was to plan and coordinate <strong>Iran</strong>ian support for anupcoming Al Qaeda operation against the United States.257. On May 4, 2001, a second planning meeting between Al Qaeda and<strong>Iran</strong>ian intelligence officials was held in <strong>Iran</strong>. Attendees at this planningmeeting included Khamenei, Rafsanjani, and Bin Laden‘s son, Saad BinLaden. <strong>Iran</strong>ian intelligence memos written in the weeks following themeeting advise <strong>Iran</strong>ian operatives to be prepared for U.S. retaliation foran attack planned for September 2001.APPENDIX EThe Islamic Republic of <strong>Iran</strong>’s Early Terrorist ConnectionsEven before taking power in 1979, Ayatollah Ruhollah Khomeini, a Shiite Muslim, hadix
Change language