brief - Iran 911 Case
brief - Iran 911 Case brief - Iran 911 Case
Second, as the Commission starkly acknowledged in the Report,additional facts plainly remained to be uncovered . . . .Ex. 5, Snell Affid. 22; see also Ex. 6, Lopez-Tefft Affid. 121.Still, according to an interview of a 9/11 Commission staff member who reviewedthe NSA material, the documents showed that the Iranian border inspectors had beenordered not to put telltale stamps in the operatives‘ passports and that the Iranians werefully aware they were helping operatives who were part of an organization preparingattacks against the United States. Ex. 2, Timmerman 2nd Affid. 123-24. Indeed, the9/11 Commission‘s investigation found that the conspiracy involved ―a specific terroristtravel operation,‖ Ex. 4, Kephart Affid. 37, including movement of the hijackers aroundthe globe and into the United States without their travel to al Qaeda‘s training camps inAfghanistan being discoverable. One key feature of this ―terrorist travel operation‖ was―passports with possible indicators of extremism that dated back to the 1993 World TradeCenter attack‖ carried by at least three 76 of the hijackers:Id., 67.It is probable that such an indicator was an al Qaeda ―calling card‖ usedby the broad jihadi-terrorist community in general to identify themselvescovertly, and that Iranian border authorities were aware of this covertcalling card and thus, knew when not to stamp Iranian travel stamps into alQaeda passports.As concluded by former 9/11 Commission staffer Janice Kephart:. . . the actions of Iranian border authorities, in refraining from stampingthe passports of the Saudi hijackers, vastly increased the likelihood of theoperational success of the 9/11 plot. Shielding the Saudis‘ passports fromindicia of travel to Iran and Afghanistan was perceived as essential toprevent potential confiscation of passports by Saudi authorities, and alsoto hide complicity of Iran in supporting al Qaeda.. . . .76 Only six of the nineteen hijackers‘ passports were found after the attack. Id., 31.77
Thus, Iran‘s facilitation of the hijackers‘ ―terrorist travel‖operation, involving Imad Mughniyah, constituted material support –indeed, direct support – for al Qaeda‘s 9/11 attacks.Id., 66, 71 (emphasis omitted).The fact that Iranian border inspectors were directed not to place telltale stamps inthe passports of these future hijackers traveling to and from Afghanistan constituted vitaldirect and material support for the 9/11 operation. The actions of the ―senior Hizballahoperative,‖ Imad Mughniyah, and his ―associate‖ and a ―top commander‖ of Hizballah, inescorting 9/11 hijackers on flights to and from Iran and coordinating passport and visaacquisition activities in Saudi Arabia also constituted direct and material support for the9/11 conspiracy. 9/11 REPORT, pp. 240-41; Ex. 4, Kephart Affid. passim and 3-5, 66,71, 79; Ex. 6, Lopez-Tefft Affid. 104-07; 112-20; 264; Ex. 3, Byman Affid. 32; 46-47, 49-50; Ex. 2, Timmerman 2nd Affid. 120-24; Ex. 7, Bergman Affid. 17; Ex. 8,Clawson Affid. 48-49; 59.Indeed, the participation of Imad Mughniyah, a known agent of Iran and a topterrorist commander of Iran‘s proxy, Hizballah, as well as Mughniyah‘s associate, in thefacilitation of the travel of 9/11 hijackers, and in coordinating their activities in SaudiArabia, during the critical period in late 2000 when the hijackers were completing theirtraining and obtaining clean Saudi passports and U.S. visas, compels the conclusion thatIran had actual foreknowledge of the 9/11 plot. Ex. 4, Kephart Affid. 70.Mughniyah‘s personal role in the hijackers‘ travel into Beirut and Iranafter they had obtained U.S. visas in Saudi Arabia, and his coordination ofhijackers‘ activities in Saudi Arabia, means that Iran must have had actualadvance knowledge of an impending terrorist attack against United Statesinterests, most likely on U.S. territory, involving more than one al Qaedaoperative. That attack turned out to be 9/11.Id. A terrorist of Mughniyah‘s importance could not be acting as travel facilitator78
- 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 and 68: the issuance of INTERPOL Red Notice
- Page 69 and 70: investigators concluded the operati
- 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
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- Page 87 and 88: January 16, 2009; Ex. 2, Timmerman
- Page 89 and 90: The January 16, 2009, Treasury desi
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- Page 93 and 94: The fact is that many important ―
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- 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
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Thus, <strong>Iran</strong>‘s facilitation of the hijackers‘ ―terrorist travel‖operation, involving Imad Mughniyah, constituted material support –indeed, direct support – for al Qaeda‘s 9/11 attacks.Id., 66, 71 (emphasis omitted).The fact that <strong>Iran</strong>ian border inspectors were directed not to place telltale stamps inthe passports of these future hijackers traveling to and from Afghanistan constituted vitaldirect and material support for the 9/11 operation. The actions of the ―senior Hizballahoperative,‖ Imad Mughniyah, and his ―associate‖ and a ―top commander‖ of Hizballah, inescorting 9/11 hijackers on flights to and from <strong>Iran</strong> and coordinating passport and visaacquisition activities in Saudi Arabia also constituted direct and material support for the9/11 conspiracy. 9/11 REPORT, pp. 240-41; Ex. 4, Kephart Affid. passim and 3-5, 66,71, 79; Ex. 6, Lopez-Tefft Affid. 104-07; 112-20; 264; Ex. 3, Byman Affid. 32; 46-47, 49-50; Ex. 2, Timmerman 2nd Affid. 120-24; Ex. 7, Bergman Affid. 17; Ex. 8,Clawson Affid. 48-49; 59.Indeed, the participation of Imad Mughniyah, a known agent of <strong>Iran</strong> and a topterrorist commander of <strong>Iran</strong>‘s proxy, Hizballah, as well as Mughniyah‘s associate, in thefacilitation of the travel of 9/11 hijackers, and in coordinating their activities in SaudiArabia, during the critical period in late 2000 when the hijackers were completing theirtraining and obtaining clean Saudi passports and U.S. visas, compels the conclusion that<strong>Iran</strong> had actual foreknowledge of the 9/11 plot. Ex. 4, Kephart Affid. 70.Mughniyah‘s personal role in the hijackers‘ travel into Beirut and <strong>Iran</strong>after they had obtained U.S. visas in Saudi Arabia, and his coordination ofhijackers‘ activities in Saudi Arabia, means that <strong>Iran</strong> must have had actualadvance knowledge of an impending terrorist attack against United Statesinterests, most likely on U.S. territory, involving more than one al Qaedaoperative. That attack turned out to be 9/11.Id. A terrorist of Mughniyah‘s importance could not be acting as travel facilitator78
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