brief - Iran 911 Case

cooperated and coordinated with, and assisted each other in, the planning, training for,and implementation of a series of terrorist attacks against American and Western interestsabroad. This terrorist alliance continued throughout the preparations for the 9/11 attacks,involving planning, facilitation of the hijackers‘ travel, and training. After the 9/11attacks, Iran and Hizballah again gave material support to al Qaeda by facilitating theescape of some of al Qaeda‘s leadership, as well as many of its operatives, and theirfamilies, from the U.S.-led invasion of Afghanistan. Iran thereafter provided – and to thepresent day continues to provide – safe haven for al Qaeda leaders and rank-and-filemembers inside Iran. From that post-9/11 safe haven inside Iran, senior al Qaedamembers have continued to direct terrorist operations against the U.S. and its allies.In sum, Iran has directly and materially supported al Qaeda generally before,during, and after 9/11, and gave direct and material support to al Qaeda specifically inregard to the September 11, 2001 attacks upon America.Contemporaneously with filing this Memorandum, Plaintiffs are filing a MotionFor Leave to File Under Seal additional evidence comprising videotaped testimony anddocuments from three fact witnesses, Witnesses ―X,‖ ―Y,‖ and ―Z,‖ who are all defectorsfrom the Iranian government. Ex. S-1 through S-8. The evidence from Witnesses X, Y,and Z circumstantially and directly implicates Iran and Hizballah in the 9/11 attacks,through Iran‘s and Hizballah‘s foreknowledge of, and complicity in, the overall designof, and preparations for, the 9/11 attacks, involving, but not limited to, facilitation of thehijackers‘ international travel, training, and through Iran‘s provision of safe haven for alQaeda after the attacks. Plaintiffs discuss the sealed evidence of Iran‘s material anddirect support of al Qaeda, which covers many areas not addressed at all in this brief, in12