brief - Iran 911 Case

foreign terrorist organizations in particular, Israeli investigative journalist and scholarRonen Bergman provides an 80-paragraph affidavit (Ex. 7, redacted, and S-13,unredacted) addressing, inter alia, the early and continuing connections between Iran andal Qaeda, and Iran‘s material aid and support to al Qaeda before and after September 11,2001. Dr. Bergman discusses Iran‘s long terrorist history, its place ―at the center of therise of modern terrorism,‖ its methods, geopolitical motivations, and the founding of itsterrorist proxy organization, Hizballah. Dr. Bergman details the cooperation among Iran,Hizballah (prominently, Imad Mughniyah), and al Qaeda. Dr. Bergman‘s affidavitincludes revelations about the nature and extent of Iranian sponsorship of internationalterrorism known to him as a product of his special relationships with top level Israeliintelligence and military officials.. . . [I]t is my expert opinion that Islamic Republic of Iran was, andis, a benefactor of, and provided material aid, resources, and support toOsama bin Laden and al Qaeda, both before and after the attacks ofSeptember 11, 2001, on the United States. Further, it is my expert opinionthat the Islamic Republic of Iran stands at the center of the rise of modernterrorism, and that Iran consistently supports terrorist operations against anumber of targets throughout the world, including the United States.. . . . This facilitation enabled the acquisition of important traveldocuments, passports, and visa and therefore, entry into the United States.. . . . The [May 14, 2001] memo mandates that the intelligenceapparatus of the Office of the Supreme Leader is to directly supervise alloperations, and it conveys the Supreme Leader‘s ―full support in theimplementation of its future plans.‖ Finally, and significantly, the [May14, 2001] memorandum ―emphasizes that, with regard to cooperation withal Qaeda, no traces must be left that might have negative and irreversibleconsequences, and that [the activity] must be limited to existing contactswith Mughniyah and al Zawahiri.Ex. 7, Bergman Affid. 16-17, 75-76 and Ex. B thereto (emphasis omitted).f. Dr. Patrick Clawson. Noted Iran expert Dr. Patrick L. Clawson has testified as anexpert in dozens of federal court cases regarding Iran‘s state sponsorship of terrorism.27