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sanctuary to Taliban and al Qaeda fighters, an offer that was accepted. Ex. 6, Lopez-Tefft Affid. 278. Osama bin Laden‘s old friend, Gulbuddin Hekmatyar, still in exile inIran near the Afghan border, was particularly instrumental, ―using his relationship withthe Iranian regime to facilitate the passage of hundreds of al Qaeda terrorists into Iranianterritory . . . .‖ Ex. 6, Lopez-Tefft Affid. 129 (emphasis omitted). Also important to theevacuation were Imad Mughniyah, Ex. 6, Lopez-Tefft Affid. 290, and Iran‘s Qods Forcecommander Ahmad Vahidi, 79 who maintained a close relationship with Ayman alZawahiri. Ex. 6, Lopez-Tefft Affid. 280. A Western diplomat in Afghanistan said,―[t]he Iranian Revolutionary Guard has an eye on everything that happens along theborder. Of course they know that Taliban and al Qaeda fighters are getting across.‖ Ex.6, Lopez-Tefft Affid. 279 (emphasis omitted); see also Ex. 2, Timmerman 2nd Affid.172-73. According to Havlish expert Dr. Patrick Clawson, a U.S. government officialconfirmed that, in 2001-02, Iranian officials had acknowledged they had permitted theseal Qaeda members into Iran. Ex. 8, Clawson Affid. 60. The Iranian exile ―Bahram‖and his Fedaii Guerillas organization identified safe houses outside of Tehran wherenearly 800 al Qaeda fighters and their families were housed. Ex. 2, Timmerman 2ndAffid. 173. (Witness Y provides additional evidence regarding Iran‘s safe harboring ofhundreds of al Qaeda operatives and their families after the U.S.-led invasion ofAfghanistan.)1. Abu Musab al Zarqawi. Among the high-level al Qaeda officials whoarrived through the protected transit route were Saad bin Laden and the man who wouldsoon lead al Qaeda in Iraq, Abu Musab al Zarqawi. Ex. 30, U.S. Treasury Designation,79 Vahidi was promoted to Iran‘s Minister of Defense in August 2009, despite the fact that he was stillthe subject of an INTERPOL Red Notice for his involvement in the 1994 AMIA bombing and is knownto have been deeply involved in the Khobar Towers bombing. See pp. 64-65, 70, supra.81
January 16, 2009; Ex. 2, Timmerman 2nd Affid. 171. Zarqawi, along with al Qaedacommander Saef al Adel, escaped to Iran, staying in the houses of GulbuddinHekmatyar‘s followers, with the tacit permission of Iranian intelligence. He then ―moved. . . across the entire width of Iran . . . [and] began setting up terrorist training campsconveniently near the Iranian border, which he crossed over on a regular basis,maintaining an easy relationship with Iranian security forces on the other side.‖ Ex. 6,Lopez-Tefft Affid. 281-82 (emphasis omitted). Later, Zarqawi ―was living in Tehran . .. under the protection of Iranian security services. Zarqawi was . . . back in Iran as ofOctober 2003, where he continued to operate with the full knowledge of the regime inTehran . . . .‖ Id., 283 (emphasis omitted). ―‗Zarqawi spent more time in Iran thananywhere else after September 11 . . . .‘‖ Ex. 8, Clawson Affid. 51 (quoting noted alQaeda expert Peter Bergen)(emphasis omitted).French Judge Jean-Louis Bruguière‘s investigations established that Zarqawi‘s―group traveled through Iranian territory on a regular basis and used Iran for clandestinemeetings, activities that implied the complicity of the intelligence services of the IslamicRepublic of Iran.‖ Ex. 9, Bruguière Declaration 33. ―It was clear to me that Zarkawihad direct ties to the Iranian regime for his terrorist operations.‖ Id., 41. Indeed, one ofZarqawi‘s ―top deputies‖ arranged transport of deadly poisons from Zarqawi‘s enclave―through Iran where they had excellent contacts‖ with ―the full knowledge of theIranians‖ to destinations overseas for use in terrorist attacks. Id., 34, 37-41.2. January 16, 2009: U.S. Treasury Department Designation. A U.S.Treasury Department designation of Saad bin Laden as an ―international terrorist‖ underExecutive Order 13224 (targeting terrorists and terrorist supporters) said of the eldest son82
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FOREIGN STATE DEFENDANTS: ::THE ISL
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D. CLAIMS ON BEHALF OF NON-U.S. NAT
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In order to revise its pleading to
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cooperated and coordinated with, an
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Indeed, the 9/11 REPORT notes a num
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senior Hezbollah operative. Also in
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Timmerman 2nd Affid. 124. 14Althoug
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facilitating the travel of the 9/11
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officials provided direct and mater
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after September 11, 2001, in the fo
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instrument of foreign and domestic
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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
Page 81 and 82: actual foreknowledge of the plannin
Page 83 and 84: Thus, Iran‘s facilitation of the
Page 85: the present day. Testifying before
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 127: APPENDICESPLAINTIFFS’ FIRST MEMOR
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