brief - Iran 911 Case

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