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 DEFENDANTS14, 1996. †† The al Shamal Bank and another al Qaeda front company, Taba Investments,establish direct connections between bin Laden and attacks against U.S. targets carried out by alQaeda and Hizballah with funding from the bank‘s accounts, and also financial connectionsbetween bin Laden and Iran. Ex. 6, Lopez-Tefft Affid. 140-46; Ex. S-10, Timmerman 1stAffid. 102-110; Ex. 2, Timmerman 2nd Affid. 91-96.One of these direct connections, seemingly incongruous but actually demonstrating theIranian capacity for pragmatic action in its own interests, as well as its sponsorship of terrorism,involved Iran‘s hated enemy, Saddam Hussein, with whom Iran had recently fought a savageeight-year war. An Iranian opposition group, the Iranian People‘s Fedaii Guerillas of Iran, firstreported, on February 16, 1996, that senior IRGC officers were profiting by helping SaddamHussein evade U.N. oil sanctions. At that time, the group‘s spokesman, who used the nom deguerre ―Bahram,‖ submitted thirty-three (33) pages of documents to U.N. Secretary GeneralBoutros Boutros-Ghali, including contracts, invoices, shipping documents, and bank telexes,relating to a 1994 contract for the sale by Iraq, at deeply discounted prices, of refined petroleumproducts to Iran. The contract was negotiated by top aides to the IRGC commander, MajorGeneral Mohsen Rezai, with Iraqi intermediaries in Paris, France.Under the scheme, Iraqi oil tanker trucks monthly brought 30,000 metric tons of dieselfuel and 50,000 metric tons of gasoline to an Iranian border post controlled by the IRGC. TheIRGC then took possession of the oil products and sold them at a profit on the international†† Available online on the website of the U.S. Embassy in Tel Aviv, Israel, seehttp://usembassy-israel.org.il/publish/press/state/archive/august/sd4_8-15.htm.xx
APPENDICESPLAINTIFFS’ FIRST MEMORANDUM OF LAW IN SUPPORT OF MOTIONFOR ENTRY OF JUDGMENT BY DEFAULT AGAINST SOVEREIGN DEFENDANTSmarket. Among the documents ―Bahram‖ presented was a performance bond issued by theseller‘s bank, dated April 6, 1994, in favor of the al Shamal Islamic Bank in Khartoum, Sudan,the ultimate buyer of the diesel fuel. By selling oil through Osama bin Laden‘s own bank, the alShamal Islamic Bank, and facilitating the clandestine oil shipments in violation of the UnitedNations embargo on Saddam Hussein‘s regime in Iraq, Iran contributed to bin Laden‘s financialprofit. Ex. 2, Timmerman 2nd Affid. 91-96.APPENDIX J1999-2000: Terrorist Training CampsA Havlish attorney, Timothy Fleming, along with investigator Kenneth Timmerman,debriefed a career IRGC officer, ―Colonel B,‖ who served as the superintendent of a Sunniterrorist training camp at Sahel-e rouh, about forty (40) kilometers west of Rasht, Iran, on theCaspian Sea. From 1999 to 2000, ―Colonel B‖ ran the Shahid Mohammad Beglou camp, whichspecialized in training the cadres of a variety of terrorist groups loosely affiliated with al Qaeda.Syrians, Lebanese, Azeris, Libyans, Iraqi Arabs, and Iraqi Kurds – all Sunnis – came to theBeglou camp for 60-day training sessions. Ex. 2, Timmerman 2nd Affid. 61-67. Colonel B‘sinformation is consistent with an announcement by Turkish authorities in November 1999 ofarrests of a number of al Qaeda terrorists, including Kurds and Algerians, who had enteredTurkey from Iran in June 1999 intending to carry out terrorist attacks aimed at disrupting theupcoming summit of the Conference on European Cooperation and Security. Underxxi
- Page 73 and 74: worldwide terrorism is ―a report
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APPENDICESPLAINTIFFS’ FIRST MEMORANDUM OF LAW IN SUPPORT OF MOTIONFOR ENTRY OF JUDGMENT BY DEFAULT AGAINST SOVEREIGN DEFENDANTSmarket. Among the documents ―Bahram‖ presented was a performance bond issued by theseller‘s bank, dated April 6, 1994, in favor of the al Shamal Islamic Bank in Khartoum, Sudan,the ultimate buyer of the diesel fuel. By selling oil through Osama bin Laden‘s own bank, the alShamal Islamic Bank, and facilitating the clandestine oil shipments in violation of the UnitedNations embargo on Saddam Hussein‘s regime in Iraq, <strong>Iran</strong> contributed to bin Laden‘s financialprofit. Ex. 2, Timmerman 2nd Affid. 91-96.APPENDIX J1999-2000: Terrorist Training CampsA Havlish attorney, Timothy Fleming, along with investigator Kenneth Timmerman,de<strong>brief</strong>ed a career IRGC officer, ―Colonel B,‖ who served as the superintendent of a Sunniterrorist training camp at Sahel-e rouh, about forty (40) kilometers west of Rasht, <strong>Iran</strong>, on theCaspian Sea. From 1999 to 2000, ―Colonel B‖ ran the Shahid Mohammad Beglou camp, whichspecialized in training the cadres of a variety of terrorist groups loosely affiliated with al Qaeda.Syrians, Lebanese, Azeris, Libyans, Iraqi Arabs, and Iraqi Kurds – all Sunnis – came to theBeglou camp for 60-day training sessions. Ex. 2, Timmerman 2nd Affid. 61-67. Colonel B‘sinformation is consistent with an announcement by Turkish authorities in November 1999 ofarrests of a number of al Qaeda terrorists, including Kurds and Algerians, who had enteredTurkey from <strong>Iran</strong> in June 1999 intending to carry out terrorist attacks aimed at disrupting theupcoming summit of the Conference on European Cooperation and Security. Underxxi
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