brief - Iran 911 Case

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FOREIGN STATE DEFENDANTS: ::THE ISLAMIC REPUBLIC OF IRAN, ::AYATOLLAH ALI-HOSEINI KHAMENEI, ::ALI AKBAR HASHEMI RAFSANJANI, ::IRANIAN MINISTRY OF :INFORMATION AND SECURITY, ::THE ISLAMIC REVOLUTIONARY :GUARD CORPS, ::HEZBOLLAH, :an unincorporated association, ::THE IRANIAN MINISTRY :OF PETROLEUM, ::THE NATIONAL IRANIAN :TANKER CORPORATION, ::THE NATIONAL IRANIAN :OIL CORPORATION, ::THE NATIONAL IRANIAN :GAS COMPANY, ::IRAN AIRLINES, ::THE NATIONAL IRANIAN :PETROCHEMICAL COMPANY, ::IRANIAN MINISTRY OF :ECONOMIC AFFAIRS AND FINANCE, ::IRANIAN MINISTRY OF :COMMERCE, ::IRANIAN MINISTRY OF DEFENSE :AND ARMED FORCES LOGISTICS, ::THE CENTRAL BANK OF THE :ISLAMIC REPUBLIC OF IRAN, et al., ::Defendants. :ii
Page 8: Flatow, 999 F.Supp. at 11. 4 In Aug
Page 13: that torts such as piracy, violatio
Page 16 and 17: demand more or different evidence t
Page 18 and 19: Plaintiffs‘ Second (Sealed) Memor
Page 20 and 21: Ex. 5, Snell Affid. 17 (emphasis ad
Page 22 and 23: within file cabinets full of thousa
Page 24 and 25: Affid. 21. A third al Qaeda detaine
Page 26 and 27: 1. THE EXPERT WITNESSESThe Havlish
Page 28 and 29: the Sheikh Omar Abel Rahman (the
Page 30 and 31: attacks. Kephart‘s analysis concl
Page 32 and 33: foreign terrorist organizations in
Page 34 and 35: Id., 43 and Conclusion (emphasis om
Page 36 and 37: who, for reasons of personal securi
Page 38 and 39: confession of the ―mastermind‖
Page 40 and 41: government and/or some Western inte
Page 42 and 43: investigation.V. IRAN IS THE WORLD
Page 44 and 45: all, of the United States and other
Page 46 and 47: also Appendix G. The leaders of Hiz
Page 48 and 49: overturn any secular law. Id., 21.
Page 50 and 51: Affid. 63; see also Ex. 8, Clawson
Page 52 and 53:
Revolutionary Guards. First of all,
Page 54 and 55:
terrorist attack against America in
Page 56 and 57:
elease the last hostages).3. Hijack
Page 58 and 59:
40, 55-60, 110-12, 132-39, 163, 174
Page 60 and 61:
their divisions and join against th
Page 62 and 63:
Imad Mughniyah and Iranian official
Page 64 and 65:
idged the Sunni-Shi‘a divide to p
Page 66 and 67:
22.3. 1994: AMIA, Buenos Aires, Arg
Page 68 and 69:
some of the assassins from Ethiopia
Page 70 and 71:
verbally congratulated. Ex. 6, Lope
Page 72 and 73:
196-97.The 9/11 REPORT specifically
Page 74 and 75:
weapons.‘‖ Id., 39 (emphasis om
Page 76 and 77:
Part of the factual basis for the 9
Page 78 and 79:
noted, ―8 to 10 of the 14 Saudi
Page 80 and 81:
REPORT, p. 240. The Havlish experts
Page 82 and 83:
Second, as the Commission starkly a
Page 84 and 85:
through Lebanon and Iran, as well a
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sanctuary to Taliban and al Qaeda f
Page 88 and 89:
of Osama bin Laden: ―in late 2001
Page 90 and 91:
said, ―‘there is no question bu
Page 92 and 93:
terrorists, purportedly under house
Page 94 and 95:
deniability.Iran assisted al Qaeda
Page 96 and 97:
evidence regarding the relationship
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must be left [] that might have neg
Page 100 and 101:
order of the Iranians and being fin
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therefore, exceeds the FSIA standar
Page 104 and 105:
Edward H. Rubenstone (PA Bar No. 16
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APPENDICESPLAINTIFFS’ FIRST MEMOR
Page 108 and 109:
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