brief - Iran 911 Case

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APPENDICESPLAINTIFFS’ FIRST MEMORANDUM OF LAW IN SUPPORT OF MOTIONFOR ENTRY OF JUDGMENT BY DEFAULT AGAINST SOVEREIGN DEFENDANTS[Mykonos] operation [killing Kurdish dissidents].‖1997 ―Tehran conducted at least 13 assassinations in 1997.‖ ―The [German] judge furtherstated that the Mykonos [dissident] murders had been approved at the most senior levelsof the Iranian Government by an extra-legal committee whose members included theMinister of Intelligence and Security, the Foreign Minister, the President, and theSupreme Leader.‖ ―In the fall of 1997, Tehran hosted numerous representatives ofterrorist groups . . . at a conference . . . . Participants reportedly discussed the jihad,establishing greater coordination between certain groups, and an increase in support forsome groups.‖1998 ―Iran in 1998 continued to be involved in the planning and execution of terrorist acts . . .[and] Tehran continued . . . to support a variety of groups that use terrorism to pursuetheir goals . . . . Iran supports these groups with varying amounts of training, moneyand/or weapons.‖1999 ―. . . [Iran‘s] state institutions, notably the Revolutionary Guard Corps and the Ministry ofIntelligence and Security, continued to be involved in the planning and execution ofterrorist acts and continued to support a variety of groups that use terrorism to pursuetheir goals.‖ ―A variety of public reports indicate Iran‘s security forces conducted severalbombings against Iranian dissidents abroad.‖ ―Iran also provided support to terroristgroups in North Africa and South and Central Asia, including financial assistance andtraining.‖2000 ―Iran remained the most active state sponsor of terrorism in 2000. Its RevolutionaryGuard Corps (IRGC) and Ministry of Intelligence and Security (MOIS) continued to beinvolved in the planning and the execution of terrorist acts and continued to support avariety of groups that use terrorism to pursue their goals.‖ ―Iran also provide a lowerlevel of support – including funding, training, and logistics assistance – to extremistgroups in . . . Central Asia.‖2001 ―Iran remained the most active state sponsor of terrorism in 2001.‖ ―There are . . .reports that Arab Afghans, including al Qaeda members, used Iran as a transit route toenter and leave Afghanistan.‖2002 ―Iran remained the most active state sponsor of terrorism. Its Islamic RevolutionaryGuard Corps and Ministry of Intelligence and Security were involved in the planning ofand support for terrorist acts and continued to exhort a variety of groups that usedterrorism to pursue their goals.‖ ―Al-Qaeda members have found virtual safehaven therexiv
APPENDICESPLAINTIFFS’ FIRST MEMORANDUM OF LAW IN SUPPORT OF MOTIONFOR ENTRY OF JUDGMENT BY DEFAULT AGAINST SOVEREIGN DEFENDANTS[Iran] and may even be receiving protection from elements of the Iranian Government.‖―Iran also provided support to extremist groups in Central Asia, Afghanistan, and Iraqwith ties to al Qaeda.‖2003 ―After the fall of the Taliban regime in Afghanistan, some al Qaeda members fled to Iranwhere they had found virtual safehaven.‖2004 ―Iran also continued to fail to control the activities of some al Qaeda members who fledto Iran following the fall of the Taliban regime in Afghanistan.‖2005 ―The IRGC was increasingly involved in supplying lethal assistance to Iraqi militantgroups, which destabilizes Iraq.‖2006 ―Iran remained the most active state sponsor of terrorism, its . . . IRGC and . . . MOISwere directly involved in the planning and support of terrorist acts and continued toexhort a variety of groups . . . to use terrorism . . . .‖ ―Iran also continued to fail tocontrol the activities of some al Qaeda members who fled to Iran following the fall of theTaliban regime in Afghanistan.‖2007 ―Iran‘s IRGC-Qods Force continued to provide weapons and financial aid to the Talibanto support anti-U.S. and anti-Coalition activity in Afghanistan.‖ ―Iran remainedunwilling to bring to justice senior al Qaeda members . . . and has refused to publiclyidentify those senior members in its custody.‖ ―Iran also continued to fail to control theactivities of some al Qaeda members who fled to Iran following the fall of the Talibanregime in Afghanistan.‖2008 ―The Qods Force, an elite branch of the . . . IRGC, is the regime‘s primary mechanism forcultivating and supporting terrorists abroad. The Qods Force provided aid in the form ofweapons, training, and funding to HAMAS and other Palestinian terrorist groups,Lebanese Hizballah, Iraq-based militants, and Taliban fighters in Afghanistan.‖ ―Iran‘sIRGC Qods Force provided assistance to the Taliban in Afghanistan. The Qods Forceprovided training to the Taliban on small unit tactics, small arms, explosives, and indirectfire weapons.‖ ―Iran also continued to fail to control the activities of some al Qaedamembers who fled to Iran following the fall of the Taliban regime in Afghanistan.‖―Senior IRGC and Qods Force officials were indicted by the Government of Argentinafor their alleged roles in the 1994 terrorist bombing of the Argentine Israel MutualAssociation which, according to the Argentine State Prosecutor‘s Report, was initiallyproposed by the Qods force.‖2009 ―Iran remained the most active state sponsor of terrorism. Iran‘s financial, material, andxv
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FOREIGN STATE DEFENDANTS: ::THE ISL
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D. CLAIMS ON BEHALF OF NON-U.S. NAT
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In order to revise its pleading to
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cooperated and coordinated with, an
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Indeed, the 9/11 REPORT notes a num
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senior Hezbollah operative. Also in
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Timmerman 2nd Affid. 124. 14Althoug
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facilitating the travel of the 9/11
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officials provided direct and mater
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after September 11, 2001, in the fo
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instrument of foreign and domestic
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Perhaps the leading expert on Iran
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INTERPOL, Edgar A. Adamson attests,
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2. THE ROBERT BAER PUBLICATIONSForm
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Iran provided material and direct s
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Iran‘s anticipation of a retaliat
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every year since 1984. Ex. 3, Byman
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Testimony of Witness X, February 23
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unning through the contemporary Mid
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We Know, p. 127; Ex. 6, Lopez-Tefft
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Department reports on global terror
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terrorist recruits from a variety o
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and al Qaeda, of the ―most formid
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predictable occurrence.‖ Ex. 6, L
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The factual reality - as found by t
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Zawahiri met with Imad Mughniyah, w
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The historic 1993 meeting in Kharto
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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 117: APPENDICESPLAINTIFFS’ FIRST MEMOR
Page 127: APPENDICESPLAINTIFFS’ FIRST MEMOR
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