brief - Iran 911 Case

APPENDICESPLAINTIFFS’ FIRST MEMORANDUM OF LAW IN SUPPORT OF MOTIONFOR ENTRY OF JUDGMENT BY DEFAULT AGAINST SOVEREIGN DEFENDANTSstarted to forge connections to Sunni terrorists. Early on, he had a close personal relationshipwith Yasser Arafat, the Sunni leader of the Palestinian Liberation Organization (PLO). Ex. 2,Timmerman 2nd Affid. 5. In 1972, Khomeini signed an accord with Arafat to train Khomeini‘sIslamic fighters at Arafat‘s camps in Lebanon. Almost every leader of the Iranian Revolutionpassed through those PLO training camps, including Khomeini‘s own son, Ahmad Khomeini,and Mustafa Chamran, the first commander of the IRGC. Baer, See No Evil, p. 130; Ex. 2,Timmerman 2nd Affid. 5-7. Khomeini‘s eventual successor, today the Supreme Leader ofIran, Ayatollah Khamenei, served as the liaison between the exiled Khomeini and his Islamicrevolutionaries being trained at the PLO camps in Lebanon. Ex. 2, Timmerman 2nd Affid. 7.Once Khomeini seized power, the very first telephone call he received was from Arafat,and Arafat was the very first foreign ―leader‖ to visit Khomeini, on October 19, 1979, two weeksbefore the seizure of the U.S. Embassy. Id. at 5; Baer, See No Evil, p. 130. On November 4,1979, a student group, acting at the behest of Ayatollah Khomeini, seized the U.S. Embassy inTehran and took fifty-two (52) diplomatic hostages, Ex. 2, Timmerman 2nd Affid. 9, a terroristact without precedent in modern times. In 1979, The CIA‘s report, International Terrorism,stated:“Anti-US sentiment in Iran reached a peak in 1979 with the second takeover of the USEmbassy in Tehran. . . . After the takeover, security forces, acting in concert with theterrorists, guarded the hostages and restricted communications. Rather than activelynegotiating for the release of the hostages, [Iran] government authorities reinforced thedemands of the terrorist.”Ex. 6, Lopez-Tefft Affid. 61 (emphasis omitted). The 444-day Iranian hostage crisis set thex