brief - Iran 911 Case

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