brief - Iran 911 Case

More documents

Recommendations

Info

some of the assassins from Ethiopia and arranged for their protection in Lebanon byHizballah, and, for the assassins‘ team leader, Mustafa Hamza, inside Iran itself. Ex. 7,Bergman Affid. 74. 566. 1996: Osama bin Laden Moves to Afghanistan. U.S., Saudi, andEgyptian political pressure on the Sudanese eventually forced them to expel Osama binLaden in May 1996. Radical Afghan Sunni warlord Gulbuddin Hekmatyar, a strongIranian ally, invited bin Laden to join him in Afghanistan (Hekmatyar and bin Laden hadknown each other during the 1980s Afghan mujaheddin-Soviet war), and bin Ladenrelocated to Afghanistan with the assistance of the Iranian intelligence services. Ex. 15,U.S. Embassy (Islamabad) Cable, November 12, 1996; 57 Ex. 7, Bergman Affid. 64; Ex.2, Timmerman 2nd Affid. 99; see also 9/11 REPORT at p. 65. (See Appendix K for moreinformation on the relationships between Hekmatyar, Iran, bin Laden, and the Taliban.)The U.S. obtained information that ―[i]n the mid-1990s, Mustafa Hamid [a closeassociate of bin Laden] reportedly negotiated a secret relationship between Usama binLaden and Iran, allowing many al Qaida members safe transit through Iran toAfghanistan.‖ Ex. 30.7. June 1996: Khobar Towers, Dharan, Saudi Arabia. On June 25, 1996,terrorists struck the Khobar Towers housing complex in Dhahran, Saudi Arabia, with apowerful truck bomb, killing nineteen (19) U.S. servicemen and wounding some fivehundred (500). Ex. 6, Lopez-Tefft Affid. 162; Ex. 2, Timmerman 2nd Affid. 84. FBI56 In July 1996, Egyptian authorities arrested forty-four (44) Islamists loyal to al Zawahiri. Mubarak‘stop assistant stated publicly that the assassins had been trained in Iran, and Mubarak himself revealedthat ―‗[t]here is information, the source for which is the confessions of the terrorists who were arrested.They confessed that Iran was involved and that it helped Sudan organize this operation.‖ Ex. 2,Timmerman 2nd Affid. 81-83.57 Released under the FOIA to the National Security Archive. Seehttp://www.gwu.edu/~nsarchiv/NSAEBB/NSAEBB227/18.pdf.63
investigators concluded the operation was undertaken on ―‗direct orders from seniorIranian government leaders‘‖ and that the bombers had been trained and funded by theIRGC in Lebanon‘s Bekaa Valley. FBI Director Louis Freeh stated, ―‗[w]e later learnedthat senior members of the Iranian government, including Ministry of Defense, Ministryof Intelligence and Security and the Spiritual Leader‘s office had selected Khobar as theirtarget and commissioned the Saudi Hezbollah to carry out the operation.‘‖ Ex. 6, Lopez-Tefft Affid. 162. Based in part on the testimony of Freeh and his deputy Dale Watsonthat IRGC Qods Force commander General Ahmed Vahidi coordinated the KhobarTowers attack (as well as expert testimony of Dr. Patrick Clawson and Dr. Bruce Tefft,both of whom are expert witnesses in this case), a U.S. district court held that Iran wasfactually and legally responsible for the Khobar Towers bombing. Heiser v. IslamicRepublic of Iran, 466 F.Supp.2d 229 (D.D.C. 2006). The 9/11 Commission alsoexamined classified CIA documents establishing that Vahidi planned the Khobar Towersattack with Ahmad al Mugassil, a Saudi-born al Qaeda operative. 9/11 REPORT, p. 60, n.48. 58 See Ex. 2, Timmerman 2nd Affid. 85-86.Al Qaeda itself was also involved in the planning and preparations for the KhobarTowers bombing. Osama bin Laden tried to facilitate a shipment of explosives to SaudiArabia, and, on the day of the operation, bin Laden was, according to NSA intercepts,58 This conclusion was recently corroborated by Reza Khalili, a CIA agent who penetrated the IRGC fornearly a decade. According to Khalili, then IRGC-Qods Force General Vahidi was a key operator inIran‘s relationship to al Qaeda, and he met regularly with al Qaeda deputy Ayman al Zawahiri. Ex. 2,Timmerman 2nd Affid. 85-87. Vahidi, now defense minister of Iran, was indicted by Argentina forthe AMIA bombings, and was the subject of one of the INTERPOL Red Notices, which have never beenhonored by Tehran. See Ex. 10, Adamson Affid. 21-33, and pp. 60-61, supra. Vahidi would play amajor role in facilitating the evacuation of al Qaeda operatives from Afghanistan after the U.S.-ledinvasion in the wake of the 9/11 attacks. See infra at pp. 80, 90.64
Page 2:
FOREIGN STATE DEFENDANTS: ::THE ISL
Page 12 and 13:
D. CLAIMS ON BEHALF OF NON-U.S. NAT
Page 15 and 16:
In order to revise its pleading to
Page 17 and 18: cooperated and coordinated with, an
Page 19 and 20: Indeed, the 9/11 REPORT notes a num
Page 21 and 22: senior Hezbollah operative. Also in
Page 23 and 24: Timmerman 2nd Affid. 124. 14Althoug
Page 25 and 26: facilitating the travel of the 9/11
Page 27 and 28: officials provided direct and mater
Page 29 and 30: after September 11, 2001, in the fo
Page 31 and 32: instrument of foreign and domestic
Page 33 and 34: Perhaps the leading expert on Iran
Page 35 and 36: INTERPOL, Edgar A. Adamson attests,
Page 37 and 38: 2. THE ROBERT BAER PUBLICATIONSForm
Page 39 and 40: Iran provided material and direct s
Page 41 and 42: Iran‘s anticipation of a retaliat
Page 43 and 44: every year since 1984. Ex. 3, Byman
Page 45 and 46: Testimony of Witness X, February 23
Page 47 and 48: unning through the contemporary Mid
Page 49 and 50: We Know, p. 127; Ex. 6, Lopez-Tefft
Page 51 and 52: Department reports on global terror
Page 53 and 54: terrorist recruits from a variety o
Page 55 and 56: and al Qaeda, of the ―most formid
Page 57 and 58: predictable occurrence.‖ Ex. 6, L
Page 59 and 60: The factual reality - as found by t
Page 61 and 62: Zawahiri met with Imad Mughniyah, w
Page 63 and 64: The historic 1993 meeting in Kharto
Page 65 and 66: continuing terrorist training of al
Page 67: the issuance of INTERPOL Red Notice
Page 71 and 72: symbols. Ex. 6, Lopez-Tefft Affid.
Page 73 and 74: worldwide terrorism is ―a report
Page 75 and 76: AND TERRORIST TRAVEL, pp. 65-66. Mo
Page 77 and 78: see Ex. 2, Timmerman 2nd Affid. 148
Page 79 and 80: that the ―senior Hezbollah operat
Page 81 and 82: actual foreknowledge of the plannin
Page 83 and 84: Thus, Iran‘s facilitation of the
Page 85 and 86: the present day. Testifying before
Page 87 and 88: January 16, 2009; Ex. 2, Timmerman
Page 89 and 90: The January 16, 2009, Treasury desi
Page 91 and 92: Indeed, Iran permitted al Qaeda to
Page 93 and 94: The fact is that many important ―
Page 95 and 96: little other than KSM‘s own self-
Page 97 and 98: terrorism operations against the U.
Page 99 and 100: of Mughniyah‘s offices in Beirut.
Page 101 and 102: provided material support to al Qae
Page 103 and 104: Walter S. Batty, Jr. (PA Bar No. 02
Page 105 and 106: APPENDICESPLAINTIFFS’ FIRST MEMOR
Page 119 and 120:
APPENDICESPLAINTIFFS’ FIRST MEMOR
Page 121 and 122:
Page 123 and 124:
Page 125 and 126:
Page 127:
show all

brief - Iran 911 Case

Create successful ePaper yourself

Delete template?

Save as template?