who, for reasons of personal security, were unable to testify directly. The first, ―Bahram‖(a pseudonym), is an <strong>Iran</strong>ian dissident who, for years, has risked his life by engaging in acampaign of resistance to the Islamic regime. In particular, Bahram and his organizationhave investigated <strong>Iran</strong>‘s terrorism-related financial dealings. Timmerman also relatesinformation obtained from another <strong>Iran</strong>ian defector, ―Colonel B‖ (a pseudonym), a careerofficer of the IRGC who commanded a terrorist training camp inside <strong>Iran</strong>. 18 (Otheraspects of Timmerman‘s second affidavit dealing with the three defector witnesses areredacted; thus, the complete unredacted second affidavit is filed under seal.). . . [T]he ―coordinator‖ of the 9/11 plot, Ramzi Binalshibh met repeatedlywith lead hijacker Mohamad Atta . . . in late 2000 and early 2001, thentraveled to Afghanistan to deliver a progress report . . . to Osama binLaden and his deputy, Ayman al-Zawahiri. En route, Binalshibh stoppedover in <strong>Iran</strong>.. . . .[According to Bundeskriminalamt reports that German federal prosecutorsgave to the Havlish investigation,] Binalshibh . . . flew to <strong>Iran</strong> on January31, 2001. . . . [T]he Germans next picked up his trace on February 28,2001, when Binalshibh returned to Hamburg to empty out the apartmentused by the 9/11 pilots.. . . .I learned from 9/11 Commission staff that the ―senior Hezbollahoperative‖ was clearly identified in the NSA documents as Imad FayezMughniyah, although the Commission ultimately decided against namingMughniyah in the printed version of the report.. . . .[I]t is my expert opinion that senior al Qaeda operatives, including theirtop military planners, sought — and were provided — refuge in <strong>Iran</strong> afterthe 9/11 attacks and that they used <strong>Iran</strong> as a base for additional terroristattacks after 9/11, with the knowledge, approval, and assistance of thehighest levels of <strong>Iran</strong>ian government.Ex. 2, Timmerman 2nd Affid. 148-52, 179, 127 (emphasis omitted).18 For reasons of personal security, neither ―Bahram‖ nor ―Colonel B‖ would agree to testify directly inthis case. However, each was de<strong>brief</strong>ed extensively by Kenneth Timmerman and Timothy Fleming,one of the Havlish attorneys. Ex. S-10, Timmerman 1st Affid. 33-39; 92-93; 99-100; 112.31
2. THE ROBERT BAER PUBLICATIONSFormer CIA case officer Robert Baer 19 has written extensively on <strong>Iran</strong>, Hizballah,and Middle East terrorism. 20 Baer‘s writings provide important information concerning,inter alia, an August 1996 meeting between an <strong>Iran</strong>ian intelligence officer and Osama binLaden in Jalalabad, Afghanistan, at which an agreement (beyond the 1993 Khartoumagreement, see infra, pp. 56-57, 92-93) was reached to engage in joint terrorismoperations, and other evidence showing that 9/11 was not an al Qaeda operation actingalone. Baer‘s writings address the <strong>Iran</strong>ian government‘s thirty-year war against America,its involvement in a long history of terrorist acts against the United States and Americansabroad, <strong>Iran</strong>‘s historical, religious, and geopolitical motivations and aspirations, and thenature of the <strong>Iran</strong>ian state and its government apparatus, including <strong>Iran</strong>‘s SupremeLeader, the IRGC and its Qods Force, and MOIS. The Baer publications also discusshow and why <strong>Iran</strong> surmounted the Sunni-Shi‘a theological divide, <strong>Iran</strong>‘s modus operandiof working through terrorist proxies, including not only its own creation, Hizballah andits master terrorist Imad Mughniyah, but also many Sunni terror organizations. Finally,Baer has challenged the conventional wisdom by refuting the veracity of the ―A to Z‖19 Fluent in Farsi (Persian) and Arabic, Robert Baer worked in the CIA‘s Directorate of Operationsrunning agents (i.e., recruited sources) in the Middle East, including extensive experience in Lebanon,Asia, and Europe. He received the CIA‘s ―Career Intelligence Medal‖ in 1998. Baer, See No Evil, p.267. After his career in the CIA, Baer became a writer, journalist, and documentary film maker, andhe is widely considered to be one of the foremost experts in the world on Middle East terrorism and<strong>Iran</strong>. Baer has appeared on numerous television news and discussion programs, including on the majornetworks, CNN, MSNBC, HBO, BBC, both in the U.S. and in Europe, and on radio. In 2000, Baerworked with CBS‘ 60 MINUTES on an overseas investigation involving an <strong>Iran</strong>ian intelligence defector.20 Robert Baer is the author of three non-fiction books and one novel: See No Evil: The True Story of aGround Soldier in the CIA‟s War on Terrorism (Crown 2002); Sleeping With The Devil: HowWashington Sold Our Soul for Saudi Crude (Crown 2003); Blow The House Down (Crown 2006), anovel which contains a non-fiction ―Author‘s Note‖ at the end; and The Devil We Know: Dealing withthe New <strong>Iran</strong>ian Superpower (Crown 2008). Baer is a regular columnist for TIME magazine and hashad articles published in VANITY FAIR, the WALL STREET JOURNAL, the WASHINGTON POST, and theATLANTIC on the subjects of intelligence, terrorism, international and national security, and <strong>Iran</strong>iannational politics.32
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