brief - Iran 911 Case
brief - Iran 911 Case brief - Iran 911 Case
Affid. 21. A third al Qaeda detainee, Tawfiq bin Attash, a/k/a ―Khallad,‖ alsoconfirmed to interrogators ―that Iranian immigration inspectors had been directed ‗not toplace telltale stamps in the passports of [al Qaeda] travelers.‘‖ Id., 18.Thus, the 9/11 Commission included the brief two-page summary of ―Assistancefrom Hezbollah and Iran to al Qaeda.‖ However, the Commissioners ended this sectionwith a pointed conclusion regarding the topic of Iranian and Hizballah complicity in theevents of September 11, 2001:“We believe this topic requires further investigation by the U.S. government.”9/11 REPORT, p. 241 (emphasis added). 15 There is no public indication whatsoever thatthe U.S. government has, to date, pursued any such ―further investigation.‖ Theundersigned attorneys have done so, collectively making 22 trips abroad and conferringwith key witnesses and innumerable officials, experts, and consultants. Herewith, theypresent the evidence produced by the Havlish investigation.B. “FURTHER INVESTIGATION”Most importantly, the ―further investigation‖ requested by the 9/11 Commissionhas been conducted, not by the government, but by the Havlish attorneys who have foundexactly the evidence that the 9/11 Commission indicated it had not found, specifically,that Iran and Hizballah were aware of the planning for the 9/11 attacks, and, further, thatIran and Hizballah were complicit in that planning. As detailed herein, the evidenceshows that Iran provided material support, indeed, direct assistance, to al Qaeda by15 ―The Executive Director of the 9/11 Commission, Phillip Zelikow, noted in an e-mail dated March 14,2007 to NEW YORK TIMES reporter Philip Shenon regarding Iranian involvement in 9/11: ‗In effect, allwe could do was present a set of questions that only the US government could answer, with furtherwork, and ask the government to do that work. . . . I never felt complacent, and remain ready tobelieve that someone may, in the future, find evidence we missed or didn‘t know about.‘‖ Ex. 6,Lopez-Tefft Affid. 123.19
facilitating the travel of the 9/11 hijackers, and by providing for the hijackers‘ security inthe months prior to September 11, 2001, as they were preparing for the attack. As the9/11 attacks approached, on May 14, 2001, the head of the Supreme Leader‘s intelligenceapparatus wrote a memorandum to Iranian intelligence operatives directing them to―support . . . al-Qaeda‘s future plans,‖ alerting them to potential ―negative futureconsequences of this cooperation [between Iran and al Qaeda], and cautioning theoperatives to limit their interaction to the ―existing contacts with [Imad] Mughniyah [ofHizballah] and [bin Laden deputy Ayman] al-Zawahiri.‖ Ex. 7, Bergman Affid. 75-76,and Ex. B thereto. Furthermore, after the 9/11 attacks, Iran provided safe haven to alQaeda leaders, members, and their families – inside Iran. As is detailed in Plaintiffs‘Second (Sealed) Memorandum, the evidence further shows that Iran originated thegeneral design of the 9/11 attacks and Iran provided material support to al Qaeda inconnection with the recruitment and training of the 9/11 hijackers as well.The Havlish Plaintiffs submit substantial evidence from both expert witnesses andfact witnesses to support their Motion for Entry of Judgment in this case. All of thetestimony is erected upon solid foundations: the experts‘ affidavits are supported by theireminent qualifications in their fields of study and, as set forth below, a plethora ofbackground evidence. This expert and documentary evidence alone – independent of theadditional compelling fact evidence filed under seal – provides clear and convincingsupport for the entry of judgment in this case. Further, the fact witnesses testify in detailregarding the means by which they obtained the insider information and knowledge towhich they testify.20
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Affid. 21. A third al Qaeda detainee, Tawfiq bin Attash, a/k/a ―Khallad,‖ alsoconfirmed to interrogators ―that <strong>Iran</strong>ian immigration inspectors had been directed ‗not toplace telltale stamps in the passports of [al Qaeda] travelers.‘‖ Id., 18.Thus, the 9/11 Commission included the <strong>brief</strong> two-page summary of ―Assistancefrom Hezbollah and <strong>Iran</strong> to al Qaeda.‖ However, the Commissioners ended this sectionwith a pointed conclusion regarding the topic of <strong>Iran</strong>ian and Hizballah complicity in theevents of September 11, 2001:“We believe this topic requires further investigation by the U.S. government.”9/11 REPORT, p. 241 (emphasis added). 15 There is no public indication whatsoever thatthe U.S. government has, to date, pursued any such ―further investigation.‖ Theundersigned attorneys have done so, collectively making 22 trips abroad and conferringwith key witnesses and innumerable officials, experts, and consultants. Herewith, theypresent the evidence produced by the Havlish investigation.B. “FURTHER INVESTIGATION”Most importantly, the ―further investigation‖ requested by the 9/11 Commissionhas been conducted, not by the government, but by the Havlish attorneys who have foundexactly the evidence that the 9/11 Commission indicated it had not found, specifically,that <strong>Iran</strong> and Hizballah were aware of the planning for the 9/11 attacks, and, further, that<strong>Iran</strong> and Hizballah were complicit in that planning. As detailed herein, the evidenceshows that <strong>Iran</strong> provided material support, indeed, direct assistance, to al Qaeda by15 ―The Executive Director of the 9/11 Commission, Phillip Zelikow, noted in an e-mail dated March 14,2007 to NEW YORK TIMES reporter Philip Shenon regarding <strong>Iran</strong>ian involvement in 9/11: ‗In effect, allwe could do was present a set of questions that only the US government could answer, with furtherwork, and ask the government to do that work. . . . I never felt complacent, and remain ready tobelieve that someone may, in the future, find evidence we missed or didn‘t know about.‘‖ Ex. 6,Lopez-Tefft Affid. 123.19
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