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 DEFENDANTSlogistic support for terrorist and militant groups throughout the Middle East and CentralAsia had a direct impact on international efforts to promote peace, threatened economicstability in the Gulf and undermined the growth of democracy.‖ ―The Qods Force, theexternal operations branch of the Islamic Revolutionary Guard Corps (IRGC), is theregime‘s primary mechanism for cultivating and supporting terrorists abroad. . . . Iranhas provided hundreds of millions of dollars in support to Lebanese Hizballah and hastrained thousands of Hizballah fighters at camps in Iran.‖ ―Iran‘s Qods Force providedtraining to the Taliban in Afghanistan on small unit tactics, small arms, explosives, andindirect fire weapons.‖ ―Iran remained unwilling to bring to justice senior al-Qa‘ida(AQ) members it continued to detain, and refused to publicly identify those seniormembers in its custody.‖APPENDIX GIran’s Creation of Hizballah as a Terrorist ProxyWhen Israel invaded Lebanon on June 6, 1982, Iran dispatched a force of its IRGC andMOIS to create and train a force to assist the PLO‘s resistance to the Israelis. Thus, Iran createdHizballah (the ―Party of God‖) as an extension of the Iranian Revolution into Lebanon. Ex. 7,Bergman Affid. 25; Ex. 6, Lopez-Tefft Affid. 28; Ex. 2, Timmerman 2nd Affid. 12-14; Ex.8, Clawson Affid. 36. In November 1982, the IRGC, using the Lebanese militant group IslamicAmal as a proxy, seized the Sheikh Abdallah army barracks from the Lebanese government‘spolice force at Balabakk in the Bekaa Valley, renaming it ―Camp Imam Ali.‖ This camp becamethe headquarters of Hizballah and the IRGC in Lebanon (and would be the place where manykidnapped hostages were imprisoned, including CIA station chief William Buckley). † Ex. 7,Bergman Affid. 28; Baer, See No Evil, pp. 73, 100-02; Baer, The Devil We Know, p. 67.† Hizballah today is the ruling de facto government of much of Lebanon. Ex. 7, Bergman Affid. 23; The DevilWe Know, pp. 191-94.xvi
APPENDICESPLAINTIFFS’ FIRST MEMORANDUM OF LAW IN SUPPORT OF MOTIONFOR ENTRY OF JUDGMENT BY DEFAULT AGAINST SOVEREIGN DEFENDANTSFrom the beginning, Hizballah served as a terrorist proxy organization for Iran, with aspecial wing, the Islamic Jihad Organization (IJO), created specifically for the purpose of servingas a front for Iranian terrorism, in effect, a cover name for terrorist operations run by Iran‘s IRGCaround the world. Baer, The Devil We Know, pp. 63-66; Baer, See No Evil, pp. 262-64, 274; Ex.3, Byman Affid. 20; Ex. 7, Bergman Affid. 25. ‡ The U.S. State Department designatedHizballah a ―foreign terrorist organization‖ in 1997. Ex. 6, Lopez-Tefft Affid. 63; Ex. 7,Bergman Affid. 22.―Iran‘s involvement in Hizballah‘s creation, large-scale funding, constant provision oftraining, and role in Hizballah‘s leadership councils has given Iran an important role in theLebanese organization. Iran trusts Hizballah and Hizballah trusts Iran – one of the closestrelationships in history between a terrorist group and its sponsor.‖ Ex. 3, Byman Affid. 44.The IRGC‘s relationship with Hizballah is extremely close, funneling money and weapons fromIran to Hizballah since the 1980s. Ex. 8, Clawson Affid. 36; Ex. 7, Bergman Affid. 27. Formore than a quarter century since its creation, Hizballah has received from Iran $100-300 millionin direct financial support – annually – which funding was controlled, originally, by AyatollahKhomeini‘s close associate (and Iran‘s former ambassador to Syria and Sudan) Hojat al Islam AliAkbar Mohtashemi-Pour. Ex. 8, Clawson Affid. 66; Ex. 6, Lopez-Tefft Affid. 31; Ex. 7,Bergman Affid. 26; Ex. 11, Banisadr testimony, p. 31. (Iran‘s financial support for terrorism‡ Iran would found a similar terrorist organization, for a similar purpose, some twenty-five (25) years later whenit created, in league with Osama bin Laden, al Qaeda-in-Iraq, headed by Abu Musab Zarqawi, which fueled theinsurgency that created some much chaos in Iraq during the latter half of the 2000s. See Ex. 6, Lopez-TefftAffid. 228, 281-86; 302, 308, 310.xvii
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APPENDICESPLAINTIFFS’ FIRST MEMORANDUM OF LAW IN SUPPORT OF MOTIONFOR ENTRY OF JUDGMENT BY DEFAULT AGAINST SOVEREIGN DEFENDANTSlogistic support for terrorist and militant groups throughout the Middle East and CentralAsia had a direct impact on international efforts to promote peace, threatened economicstability in the Gulf and undermined the growth of democracy.‖ ―The Qods Force, theexternal operations branch of the Islamic Revolutionary Guard Corps (IRGC), is theregime‘s primary mechanism for cultivating and supporting terrorists abroad. . . . <strong>Iran</strong>has provided hundreds of millions of dollars in support to Lebanese Hizballah and hastrained thousands of Hizballah fighters at camps in <strong>Iran</strong>.‖ ―<strong>Iran</strong>‘s Qods Force providedtraining to the Taliban in Afghanistan on small unit tactics, small arms, explosives, andindirect fire weapons.‖ ―<strong>Iran</strong> remained unwilling to bring to justice senior al-Qa‘ida(AQ) members it continued to detain, and refused to publicly identify those seniormembers in its custody.‖APPENDIX G<strong>Iran</strong>’s Creation of Hizballah as a Terrorist ProxyWhen Israel invaded Lebanon on June 6, 1982, <strong>Iran</strong> dispatched a force of its IRGC andMOIS to create and train a force to assist the PLO‘s resistance to the Israelis. Thus, <strong>Iran</strong> createdHizballah (the ―Party of God‖) as an extension of the <strong>Iran</strong>ian Revolution into Lebanon. Ex. 7,Bergman Affid. 25; Ex. 6, Lopez-Tefft Affid. 28; Ex. 2, Timmerman 2nd Affid. 12-14; Ex.8, Clawson Affid. 36. In November 1982, the IRGC, using the Lebanese militant group IslamicAmal as a proxy, seized the Sheikh Abdallah army barracks from the Lebanese government‘spolice force at Balabakk in the Bekaa Valley, renaming it ―Camp Imam Ali.‖ This camp becamethe headquarters of Hizballah and the IRGC in Lebanon (and would be the place where manykidnapped hostages were imprisoned, including CIA station chief William Buckley). † Ex. 7,Bergman Affid. 28; Baer, See No Evil, pp. 73, 100-02; Baer, The Devil We Know, p. 67.† Hizballah today is the ruling de facto government of much of Lebanon. Ex. 7, Bergman Affid. 23; The DevilWe Know, pp. 191-94.xvi
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