brief - Iran 911 Case

of Mughniyah‘s offices in Beirut.‖ Baer, See No Evil, p. 266. Indeed, ―senior al-Qaedaand Iranian officials met repeatedly during this time‖ [after bin Laden‘s return toAfghanistan in 1996],‖ and ―continued to collaborate in pursuit of their common anti-American agenda.‖ Ex. 8, Clawson Affid. 59. At this time, Iranian and Hizballahtrainers traveled between Iran and Afghanistan, transferring to al Qaeda operatives suchmaterial as blueprints and drawings of bombs, manuals for wireless equipment, andinstruction booklets for avoiding detection by unmanned aircraft. Ex. 7, Bergman Affid.68. (Witness Y testifies about Iran‘s training of al Qaeda cadres in Afghanistan.)As will be discussed in Plaintiffs‘ Second (Sealed) Memorandum of Law, theIranian defector witnesses X, Y, and Z all reveal that Iran did have foreknowledge of the9/11 attacks, that Iran was involved in the design of the 9/11 operation, and that Iranplayed a role in training and preparing for execution of the 9/11 attacks.VII.PLAINTIFFS’ EVIDENCE IS CLEAR AND CONVINCING PROOF OF IRAN’SMATERIAL AND DIRECT SUPPORT FOR AL QAEDAPlaintiffs‘ expert evidence in this case demonstrates clearly and convincingly thatIran and its officials, acting on behalf of the Iranian government and within the scope oftheir offices, provided material support to al Qaeda. 90 In cases regarding the statesponsoredterrorism exception to the FSIA, such as this one, courts rely extensively onsuch expert testimony. E.g., Valore v. Islamic Republic of Iran, 478 F.Supp.2d 101, 105(D.D.C. 2007)(finding Dr. Clawson is a ―renowned expert on Iranian affairs‖ to find that―Hezbollah was a creature of the Iranian government, acting almost entirely under the90 As noted by Chief Judge Lamberth in In Re Islamic Republic of Iran Terrorism Litigation, supra, aplaintiff need not establish that the material support or resources provided by a foreign state for aterrorist act contributed directly to the act from which his claim arises. Nevertheless, much of theevidence presented by the Plaintiffs here establishes that Iran provided material and direct support to alQaeda for the specific purpose of facilitating the 9/11 attacks.94