brief - Iran 911 Case

APPENDICESPLAINTIFFS’ FIRST MEMORANDUM OF LAW IN SUPPORT OF MOTIONFOR ENTRY OF JUDGMENT BY DEFAULT AGAINST SOVEREIGN DEFENDANTS1990 ―Iran‘s extensive support for terrorism continued during 1990 . . . Iran has used itsintelligence services extensively to facilitate and conduct terrorist attacks. . . .‖ ―Irancontinued to strengthen its relationship with Muslim extremists throughout the world,often providing them with advice and financial assistance.‖1991 ―Iran has used conferences . . . held in Iran during the period 19-22 October . . . tomaintain contact with numerous terrorist groups.‖ ―Iran also continued its practice ofassassinating dissidents.‖ ―Iranian intelligence services continue to facilitate and conductterrorist attacks, particularly against regime opponents living abroad. This policy isundertaken with the approval of the highest levels of the regime, although thegovernment routinely denies involvement in assassination of dissidents or in terroristattacks carried out by pro-Iranian groups.‖1992 ―The Iranian Regime has practiced state terrorism since it took power in 1979; it iscurrently the deadliest state sponsor and has achieved a worldwide reach.‖ ―Iranianagents or surrogate groups conducted over 20 attacks in 1992.‖ ―. . . Tehran‘s leadersview terrorism as a valid tool to accomplish the regime‘s political objectives, and acts ofterrorism are approved at the highest level of government in Iran.‖1993 ―Iran remains the world‘s most active and most dangerous state sponsor of terrorism,through its own state agents and the radical groups it supports.‖1994 ―Iran continues to use terrorism as ruthlessly as it did under Khomeini and supportsgroups, such as Hizballah, that pose a threat to Americans.‖ ―Iran is still the most activestate sponsor of international terrorism and continues to be directly involved in planningand executing terrorist acts. . . . Iran is also the world‘s preeminent state sponsor ofextremist Islamic and Palestinian groups, providing funds, weapons, and training.‖1995 ―Although Tehran tried to project a moderate image in the West, it continued toassassinate dissidents abroad and maintained its support and financing of groups that posea threat to US citizens.‖ ―Iran remains the premier state sponsor of internationalterrorism and is deeply involved in the planning and execution of terrorist acts both by itsown agents and by surrogate groups.‖1996 ―Iran remained the premier state sponsor of terrorism in 1996. It continued to beinvolved in the planning and execution of terrorist acts by its own agents and bysurrogates . . . .‖ ―Iran continued to provide support – including money, weapons, andtraining to a variety of terrorist groups . . . .‖ ―German prosecutors charged IranianSupreme Leader Khamenei and Iranian President Rafsanjani with approving thexiii