brief - Iran 911 Case

We Know, p. 127; Ex. 6, Lopez-Tefft Affid. 23. It has its own arms procurementnetwork and its own prisons. IRGC officers have powers of arrest, and they hold aplurality of seats in the parliament. It owns and controls Imam Khomeini InternationalAirport in Tehran. 28 Indeed, the IRGC is a major factor in the Iranian economy: it ownshundreds of companies and commercial interests, particularly in the oil and gas sector,telecommunications and infrastructure, and it holds billions of dollars in assets andgovernment contracts. For example, one IRGC company has been awarded contractsworth billions of dollars by government agencies and the National Iranian Oil Company.Baer, The Devil We Know, pp. 34-35; Ex. 8, Clawson Affid. 37; Ex. 2, Timmerman 2ndAffid. 202; see also Ex. 11, Banisadr testimony, pp. 19-20.The IRGC also has a special foreign division, known as the Qods (or Quds,meaning ―Jerusalem‖) Force, which ―is the arm of the IRGC that works with militantorganizations abroad and promotes terrorism overseas . . . .‖ Ex. 3, Byman Affid. 62;see also Ex. 6, Lopez-Tefft 25; Ex. 11, Banisadr testimony, p. 19. (The sealedtestimony of Witnesses X, Y, and Z provide additional information about the activities ofthe Qods Force in international terrorism.) The Qods Force has a long history ofengaging in coups, insurgencies, assassinations, kidnappings, bombings, and armsdealing. It has a well-deserved reputation for being the most organized, disciplined, andviolent terrorist organization in the world. Baer, The Devil We Know, pp. 35-36. TheIRGC and its Qods Force are ―deeply integrated into the regime‘s leadership,‖ ―[t]heIRGC commander reports directly to Iran‘s Supreme Leader,‖ and ―in some instances theIRGC is the most important voice in determining Iran‘s foreign policy.‖ Ex. 3, Byman28 The IRGC‘s nearly arbitrary power was evident by the manner in which it simply seized the new ImamKhomeini International Airport just before its opening and dedication in May 2004. The IRGC nowowns and controls everything there. Baer, The Devil We Know, p. 72.44