brief - Iran 911 Case

idged the Sunni-Shi‘a divide to produce, in Robert Baer‘s phrase, the ―most formidableterrorist coalition in history.‖ Baer, See No Evil, p. 269.E. A Coordinated Campaign by “History’s Most Formidable TerroristCoalition”The creation of the Iran-Hizballah-al Qaeda terror alliance was followed, asdetailed below, by a string of terrorist strikes directly against the U.S. and its allies.Meanwhile, Ayman al Zawahiri repeatedly visited Tehran and met with officers ofMOIS, including chief Ali Fallahian, and Qods Force chief Ahmad Vahidi. Ex. 7,Bergman Affid. 67; Ex. 6, Lopez-Tefft Affid. 170-71; Ex. 2, Timmerman 2nd Affid.55. 52 At the same time, the al Qaeda-Iran-Hizballah terrorist training arrangementcontinued throughout the 1990s and beyond. Ex. 6, Lopez-Tefft Affid. 50, 58, 104,108-11, 135, 138, 151-52, 169, 179, 182-83, 194, 293, 341-42; Ex. 7, Bergman Affid.53, 61, 68; Ex. 2, Timmerman 2nd Affid. 60-67. Imad Mughniyah himselfcoordinated the training activities, including the training of al Qaeda personnel, withIranian government officials in Iran and with IRGC officers working undercover at theIranian embassy in Beirut, Lebanon. At all times, the Supreme Leader was aware thatHizballah was training foreign terrorists. See Ex. 11, Banisadr testimony, pp. 32-33.(Witnesses X, Y, and Z all provide additional information about Mughniyah‘s role in theAffid. 33-40, 43; a pact of ―mutual cooperation,‖ Ex. 8, Clawson Affid. 47; a ―strategic plan‖leading to ―extensive cooperation,‖ Ex. 2, Timmerman 2nd Affid. 48, 52; a ―strategic relationship,‖Baer, See No Evil, p. 251; a ―collaborative relationship‖ of ―close coordination,‖ Ex. 6, Lopez-TefftAffid. 39, 42; an ―alliance dedicated to a complete rearrangement of the world order.‖ Id., 56.However, the exact nature of the Iran-al Qaeda relationship ―is not relevant to the issue of whether Iranprovides material support to al-Qaeda within the meaning of 18 U.S.C. Section 2339A(b)1 before,during and after September 11, 2001.‖ Ex. 8, Clawson Affid. 57.52 A few years later, shortly after September 11, 2001, when Ayman al Zawahiri was by mistake in Iran,it was Fallahian (or his successor as MOIS chief, Ali Younesi) and/or Vahidi, who arranged forZawahiri‘s speedy release. The incident highlights ―the close ties that existed between top levels of alQaeda and Iran, particularly Iran‘s intelligence community and the IRGC. Ex. 6, Lopez-Tefft Affid.171.59