brief - Iran 911 Case

Department reports on global terrorism refer to MOIS as Iran‘s key facilitator anddirector of terrorist attacks. See Ex. 8, Clawson Affid. 39; Ex. 13. After the discoveryof MOIS‘ role in a series of assassinations of intellectuals, writers, and dissidents in thelate 1990s, known in Iran as the ―Chain Murders,‖ see Banisadr testimony at 15-16 andinfra at p. 50, led to so-called ―reformists‖ gaining influence within MOIS, the SupremeLeader, Ayatollah Khamenei, would again form a special, unnamed intelligence servicethat operated directly under his control. 29Further, the entire apparatus of the Iranian state and government, and many partsof the private sector, including corporations (e.g., National Iranian Oil Company, IranAir, Iran Shipping Lines), banks (e.g., Central Bank, Bank Sepah), state-run media (e.g.,IRIB television, the Islamic Revolution News Agency (―IRNA‖), KAYHAN and otherdaily newspapers), private individuals, and even charities are at the service of theSupreme Leader, the IRGC, and the MOIS when it comes to support of terrorism. Ex.11, Banisadr testimony, pp. 19-20; Ex. 2, Timmerman 2nd Affid. 91-96, 190-212.(Witness X provides additional evidence concerning the usage of the entire apparatus ofthe Iranian government in the service of terrorism, as well as the use of private entities asfront companies, and the co-opting of other types of private entities and individuals forservice in Iran‘s network of terror.) And Iran‘s extended apparatus of terrorism is verywell funded:You won‘t find in the budget . . . a line item for that type of activity[terrorism]. It began under Mr. Rafsanjani, where every one of theseorgans involved in overseas terrorist activities would have its ownfinancial setup to finance its operations. For instance Vevak, or MOIS,had many companies that supported its operations, and especially the29 Witnesses X, Y, and Z all provide significant additional evidence about the roles of MOIS, thepresident, and the Supreme Leader in the ―Chain Murders,‖ and about the existence, organization, andfunctioning of the intelligence apparatus of the Supreme Leader.46