brief - Iran 911 Case

Iran provided material and direct support by aiding and abetting al Qaeda members whoevaded the American-led military forces that uprooted al Qaeda and overthrew theTaliban regime in Afghanistan in late 2001. ―Few if any noted terrorism experts woulddispute that Iran provides material support to al-Qaeda within the meaning of 18 U.S.C.Section 2339A(b)1.‖ Ex. 8, Clawson Affid. 56 (emphasis omitted).3. THE FACT WITNESSESThe Havlish Plaintiffs also submit, under seal at present, approximately twentyeight(28) hours of sworn fact witness testimony, via videotaped depositions of fourIranian witnesses. Three of these witnesses are defectors from the Iranian governmentwho testify to their knowledge of Iranian government complicity in the 9/11 attacks –before, contemporaneously with, and after, the attacks, supported by government lettersand memoranda, photographs, and organizational charts. The factual evidence alsoincludes a sealed affidavit of an American investigative journalist who corroboratescertain aspects of the sealed testimony, provides details concerning the Havlish fieldinvestigation which produced the factual testimony of the four Iranian witnesses, anddiscloses additional supporting facts and sources.a. Witnesses X, Y, and Z. Three of the Havlish fact witnesses are defectorsIran‘s secretive Ministry of Information and Security (―MOIS‖), roughly the equivalentof the U.S. Central Intelligence Agency, who worked in positions that gave them accessto sensitive information regarding Iran‘s state sponsorship of terrorism. Very little of theevidence contained in the sealed testimony of Witnesses X, Y, and Z (Ex. S-1, S-2, S-3,S-4, S-5, S-6, and S-7), discussed in Plaintiffs‘ Second (Sealed) Memorandum, has beenbrought to light in any public forum, although some of it is apparently known to the U.S.34