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 DEFENDANTSoverall has been estimated to range between $300 and 500 million annually. Ex. 8, ClawsonAffid. 66-67.)APPENDIX HImad MughniyahWhen Yasser Arafat and his PLO fled to Tunisia, he left behind some of his operatives.One of Arafat‘s ―Force 17‖ bodyguards, Imad Fayez Mughniyah, was recruited by senior IRGCofficer Hossein Mosleh (a/k/a ―Sheikh Hossein‖). Baer, The Devil We Know, pp. 62-65; Ex. 2,Timmerman 2nd Affid. 14. Mughniyah went to work in Hizballah‘s IJO. Baer, The Devil WeKnow, pp. 64-65. An especially talented and ruthless terrorist operative, director, andcoordinator, Mughniyah would rise to become Hizballah‘s chief of terrorist operations, a positionhe would hold, with notorious success, until his assassination in Damascus, Syria, in February2008. Ex. 2, Timmerman 2nd Affid. 14; Ex. 6, Lopez-Tefft Affid. 204; Ex. 7, Bergman Affid.29-32; Baer, The Devil We Know, pp. 78-86, 229. Mughniyah was on the FBI‘s ―MostWanted‖ list for 21 years, and for good reason: his terrorist record includes a string of heinouscrimes against American citizens, including bombings, hijackings, kidnappings, torture, and coldbloodedmurder. Ex. 7, Bergman Affid. 29-32; Ex. 2, Timmerman 2nd Affid. 14-46.Throughout his notorious terrorist career, Imad Mughniyah was an agent of the Iranianregime. § He lived in Iran for many years. Ex. 7, Bergman Affid. 31, 40-41. At the time of his§ Imad Mughniyah had a direct reporting relationship to Iranian intelligence and a direct role in Iran‘sxviii
APPENDICESPLAINTIFFS’ FIRST MEMORANDUM OF LAW IN SUPPORT OF MOTIONFOR ENTRY OF JUDGMENT BY DEFAULT AGAINST SOVEREIGN DEFENDANTSassassination by, ironically, car bomb, in February 2008, the Iranian government heaped praiseupon him. In a message of condolence to Hizballah leader Hassan Nasrallah, Iran‘s SupremeLeader said, ―the lives and deaths of such people [as Mughniyah] is a heroic story inspiring allnations, giving the youths a role-model, a clear prospect, and the way to realize it.‖ Ex. 6, Lopez-Tefft Affid. 363. Thus, it was a man who conceived, designed, planned, commanded, andcarried out terrorist operations that killed hundreds of people, more than any other single figure inthe world, who Iran‘s Supreme Leader‘s invoked as a role model for children. **APPENDIX IOsama bin Laden’s al Shamal BankWhile in Sudan, Osama bin Laden set up financial supports, connected to Iran andHizballah, for al Qaeda in Sudan. He founded al Shamal Islamic Bank and funded it with some$50 million. Ex. 6, Lopez-Tefft Affid. 140-42; Ex. 2, Timmerman 2nd Affid. 94; Ex. 14,U.S. Department of State Fact Sheet: ―Usama Bin Ladin: Islamic Extremist Financier,‖ Augustsponsorship of terrorist activities. Israeli intelligence, which tracked Mughniyah with even greater intensitythan did the U.S., termed Mughniyah ―a triple Hizballah-Iran-al Qaeda agent and terrorist ‗executive.‘‖ Ex. 6,Lopez-Tefft Affid. 205. (The sealed testimony of Witnesses X, Y, and Z provide additional significantinformation about Imad Mughniyah and his subordinate relationship to the Iranian government.)** According to the numerous American and Israeli media outlets, an indictment filed on January 17, 2011 by theprosecutor for the UN Special Tribunal for Lebanon names the Supreme Leader Ayatollah Khamenei as givingthe order to assassinate Lebanese Prime Minister Rafik Hariri in 2005, Iran‘s Qods Force as conveying to orderto Hizballah, and Hizballah military leader Imad Mughniyah as carrying out the assassination with a Hizballahteam. Just days earlier, Hizballah walked out on the Lebanese government, causing its collapse, because theacting prime minister, Saad Hariri, son of the slain leader, would not renounce the UN Special Tribunal. Whenthe indictment was filed, Hizballah leader Hassan Nasrallah threatened to ―cut the hands off‖ of anyoneattempting to arrest Hizballah members for the crime. See Ex. 34.xix
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APPENDICESPLAINTIFFS’ FIRST MEMORANDUM OF LAW IN SUPPORT OF MOTIONFOR ENTRY OF JUDGMENT BY DEFAULT AGAINST SOVEREIGN DEFENDANTSassassination by, ironically, car bomb, in February 2008, the <strong>Iran</strong>ian government heaped praiseupon him. In a message of condolence to Hizballah leader Hassan Nasrallah, <strong>Iran</strong>‘s SupremeLeader said, ―the lives and deaths of such people [as Mughniyah] is a heroic story inspiring allnations, giving the youths a role-model, a clear prospect, and the way to realize it.‖ Ex. 6, Lopez-Tefft Affid. 363. Thus, it was a man who conceived, designed, planned, commanded, andcarried out terrorist operations that killed hundreds of people, more than any other single figure inthe world, who <strong>Iran</strong>‘s Supreme Leader‘s invoked as a role model for children. **APPENDIX IOsama bin Laden’s al Shamal BankWhile in Sudan, Osama bin Laden set up financial supports, connected to <strong>Iran</strong> andHizballah, for al Qaeda in Sudan. He founded al Shamal Islamic Bank and funded it with some$50 million. Ex. 6, Lopez-Tefft Affid. 140-42; Ex. 2, Timmerman 2nd Affid. 94; Ex. 14,U.S. Department of State Fact Sheet: ―Usama Bin Ladin: Islamic Extremist Financier,‖ Augustsponsorship of terrorist activities. Israeli intelligence, which tracked Mughniyah with even greater intensitythan did the U.S., termed Mughniyah ―a triple Hizballah-<strong>Iran</strong>-al Qaeda agent and terrorist ‗executive.‘‖ Ex. 6,Lopez-Tefft Affid. 205. (The sealed testimony of Witnesses X, Y, and Z provide additional significantinformation about Imad Mughniyah and his subordinate relationship to the <strong>Iran</strong>ian government.)** According to the numerous American and Israeli media outlets, an indictment filed on January 17, 2011 by theprosecutor for the UN Special Tribunal for Lebanon names the Supreme Leader Ayatollah Khamenei as givingthe order to assassinate Lebanese Prime Minister Rafik Hariri in 2005, <strong>Iran</strong>‘s Qods Force as conveying to orderto Hizballah, and Hizballah military leader Imad Mughniyah as carrying out the assassination with a Hizballahteam. Just days earlier, Hizballah walked out on the Lebanese government, causing its collapse, because theacting prime minister, Saad Hariri, son of the slain leader, would not renounce the UN Special Tribunal. Whenthe indictment was filed, Hizballah leader Hassan Nasrallah threatened to ―cut the hands off‖ of anyoneattempting to arrest Hizballah members for the crime. See Ex. 34.xix
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