brief - Iran 911 Case

Iran‘s anticipation of a retaliatory strike in the event its role in 9/11 werediscovered;Iran‘s provision of terrorist training, including airliner hijacking, toforeign Sunni Arab ―hardliners‖ – al Qaeda – inside Iran; andThe existence nature, and organization of a separate intelligence apparatusin the office of Iran‘s Supreme Leader.b. Abolhassan Banisadr. A fourth fact witness is the first president of theIslamic Republic of Iran, Abolhassan Banisadr. A key figure in the Islamic Revolutionthat brought Ayatollah Ruhollah Khomeini to power, Banisadr became a familiar face tothe American public during the 444-day hostage crisis of 1979-1981. He was ousted byKhomeini during his term as president and has since lived in exile in France. Banisadr‘ssworn videotaped testimony in this case, Ex. 11, addresses the nature and motivations ofthe Iranian government and state, the role of Iran‘s Supreme Leader, Iran‘s usage ofterrorism as a tool of domestic and foreign policy, and the availability of the entireapparatus of the government, state, and private individuals and entities in the service ofIran‘s state sponsorship of terror.c. Kenneth R. Timmerman. Additional factual evidence in the form of asealed affidavit comes from investigative journalist Kenneth R. Timmerman. Ex. S-10,Timmerman 2nd Affidavit. Timmerman participated in the Havlish investigation, findingand making contact with, and, along with Timothy B. Fleming, a Havlish attorney,debriefing the three defectors, Witnesses X, Y, and Z, as well as Mr. Banisadr.Timmerman‘s first affidavit addresses his role in the investigation and provides factscorroborating certain aspects of the testimony of the MOIS defector witnesses, includingTimmerman‘s own communications with one of them in the days after September 11,2001. Timmerman also discusses key documents discovered during the Havlish36