brief - Iran 911 Case

brief - Iran 911 Case brief - Iran 911 Case

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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

January 16, 2009; Ex. 2, Timmerman 2nd Affid. 171. Zarqawi, along with al Qaedacommander Saef al Adel, escaped to <strong>Iran</strong>, staying in the houses of GulbuddinHekmatyar‘s followers, with the tacit permission of <strong>Iran</strong>ian intelligence. He then ―moved. . . across the entire width of <strong>Iran</strong> . . . [and] began setting up terrorist training campsconveniently near the <strong>Iran</strong>ian border, which he crossed over on a regular basis,maintaining an easy relationship with <strong>Iran</strong>ian 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 <strong>Iran</strong>ian security services. Zarqawi was . . . back in <strong>Iran</strong> 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 <strong>Iran</strong> 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 <strong>Iran</strong>ian territory on a regular basis and used <strong>Iran</strong> for clandestinemeetings, activities that implied the complicity of the intelligence services of the IslamicRepublic of <strong>Iran</strong>.‖ Ex. 9, Bruguière Declaration 33. ―It was clear to me that Zarkawihad direct ties to the <strong>Iran</strong>ian regime for his terrorist operations.‖ Id., 41. Indeed, one ofZarqawi‘s ―top deputies‖ arranged transport of deadly poisons from Zarqawi‘s enclave―through <strong>Iran</strong> where they had excellent contacts‖ with ―the full knowledge of the<strong>Iran</strong>ians‖ 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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