brief - Iran 911 Case

terrorists, purportedly under house arrest. Ex. 2, Timmerman 2nd Affid. 178. However,in July 2004, upon release of the 9/11 REPORT, President George W. Bush stated publiclythat Iran was still ―‗harboring al Qaeda leadership.‘‖ Id., p. 47, n. 56; see also Ex. 29.Further, U.S. Secretary of Defense Donald Rumsfeld said, ―We know Iran is activelysending terrorists down through Damascus into the Bekka Valley where they trainterrorists, then engage in acts against countries in the region and elsewhere.‖ Ex. 6,Lopez-Tefft Affid. 288 (emphasis omitted). Recently, Britain‘s former prime minister,Tony Blair, confirmed the continuing critical alliance between al Qaeda and Iran. In aJanuary 2011 interview, Blair confirmed that Iran is supportive of terrorist groups andstated that the West cannot deal with al Qaeda unless it deals with Iran. Ex. 37.Meanwhile, Iran has persistently refused ―to publicly identify senior members [ofal Qaeda allegedly being held] in Iranian custody on the grounds of ‗security . . .‘‖ and―Iran has resisted calls to transfer custody of its al-Qaida detainees to their countries oforigin or third countries for further interrogation and trial.‖ Ex. 13, 2003 Patterns ofGlobal Terrorism, U.S. State Department (released April 29, 2004); 83 see Ex. 6, Lopez-Tefft Affid. 90. On the contrary, Iran appears to have permitted top al Qaeda leaders,such as Saef al Adel, Sa‘ad bin Laden, and Suleiman Abu Ghaith to ―travel freely indeparting from Iran‖ when they wanted to do so, an option ―that would constitute animportant material support to al-Qaeda.‖ Ex. 8, Clawson Affid. 63; Ex. 6, Lopez-TefftAffid. 318, 320; Ex. 35, Congressional Research Service, ―Iran: Concerns and PolicyResponses (March 4, 2011), p. 48. The status quo has persisted in the years since. 8483 Ex. 13; see http://www.state.gov/s/ct/rls/crt/2003/31644.htm.84 See Ex. 13, Patterns of Global Terrorism, U.S. State Department 2007 edition (released April 30,2008), http://www.state.gov/s/ct/rls/crt/2007/103711.htm; 2008 edition (released April 29, 2009),http://www.state.gov/s/ct/rls/crt/2008/122438.htm; and 2009 edition (released August 2010),87