| Exhibit A - A $1 trillion lawsuit claims Iraq knew that Osama bin Laden was targeting New York prior to Sept. 11 - and that Saddam Hussein encouraged terrorists because he wanted revenge for losing the Gulf War. The action was filed in Manhattan federal court on behalf of 1,400 victims of the Sept. 11 attacks and their families and names bin Laden, his al Qaeda organization and Iraq as defendants. |
| Exhibit B - The horrific events of September 11th were the result of a world-wide terror conspiracy against the United States involving primarily AL QAEDA and IRAQ, who have conspired for many years to attack the United States and murder United States’ citizens. Defendants supported, conspired, aided and abetted, sponsored, planned and executed the September 11th terror attacks that killed thousands of people and injured many thousands more. |
| Exhibit C - IRAQ has sworn revenge against the United States since 1992 for IRAQ’s humiliating defeat in the Persian Gulf War. Since IRAQ could not defeat the U.S. Military it resorted to terror attacks on U.S. citizens. In order to avoid another confrontation with U.S. Military forces, IRAQ contracted with or sponsored Islamic fundamentalists who were willing to commit terrorist acts on Iraq’s behalf. Indeed in 1993, Iraqi agents tried to destroy the World Trade Center by planting a bomb in the World Trade Center parking garage. |
| Exhibit D - For many years AL QAEDA wanted to drive the United States from the Arabian peninsula, topple Middle East governments supported by the United States, including Egypt and Israel, and create an Islamic empire based upon its narrow
interpretation of the Koran. Over the years, AL QAEDA has grown as it absorbed or allied with other like-minded Islamic terrorist groups, including the EGYPTIAN ISLAMIC JIHAD. |
| Exhibit E - For the last 10 years, IRAQ’s leadership and AL QAEDA shared a virulent hatred of the United States. |
| Exhibit F - As early as 1992, AL QAEDA terrorists established close working relations with IRAQI INTELLIGENCE agents in the Sudan, Afghanistan, IRAQ and elsewhere. Soon thereafter, IRAQI INTELLIGENCE decided to support AL QAEDA and to employ AL QAEDA terrorists to carry out IRAQ’s terror attacks. The IRAQ-AL QAEDA relationship benefited IRAQ because it provided that state with trained terrorists willing to die in terror attacks. As a secular state, IRAQ does not have a large number of citizens wishing to become martyr warriors. Additionally, by using AL QAEDA suicide terrorists, IRAQ, could disavow involvement in attacks and avoid retribution. The relationship benefited AL QAEDA who received support, funding, facilities and training that it needed to carry out its terror campaigns. |
| Exhibit G - During the mid 1990's IRAQ began actively supporting AL QAEDA operations by providing intelligence, training, weapons, supplies, passports, travel documents and financial support to co-conspirators. Significantly, one of IRAQ’s training camps contained the fuselage of a Boeing 707 used to train AL QAEDA terrorists in hijacking commercial aircraft. |
| Exhibit H - AL QAEDA, backed by IRAQ, carried out the September 11th terror attacks with the financial and logistical support of numerous individuals and organizations. These individuals and organizations provided AL QAEDA with the means to recruit, train, and employ thousands of terrorists, including the twenty assigned the ghastly mission to murder United States citizens and destroy U.S. landmarks on September 11, 2001. |
| Exhibit I - Since the early 1990s, IRAQ and IRAQI INTELLIGENCE have used both Iraqi agents and independent “contractors” to commit terrorist acts against the United States in revenge for Iraq’s Gulf War defeat. AL QAEDA was IRAQ’s favorite partner in crime and terror. |
| Exhibit J - Upon information and belief, there have been numerous meetings between IRAQI Intelligence agents and high-ranking AL QAEDA terrorists to plan terror attacks. Once such meeting occurred in 1992, when ZAWAHIRI (EGYPTIAN ISLAMIC JIHAD leader and AL QAEDA officer) met with IRAQI INTELLIGENCE agents in Baghdad, IRAQ over several days. An IRAQI serving with the TALIBAN who fled Afghanistan in the fall of 2001, was captured in Kurdistan and has corroborated this meeting and confirmed that IRAQI contacts with AL QAEDA began in 1992. |
| Exhibit K - While AL QAEDA’s presence was growing in the Sudan in 1992, the Government of IRAQ was also developing close ties with the Sudanese government. Sudan supported IRAQ during the Gulf War and allowed IRAQ to establish a major IRAQI INTELLIGENCE center in the Sudan through IRAQ’s ambassador to Khartoum, Abd al Samad al-Ta’ish. Al Ta’ish was a highly placed IRAQI INTELLIGENCE agent, who brought 35 other intelligence officers with him to the Sudan to establish a base for Iraqi operations. Al Ta’ish remained in the Sudan through the summer of 1998. IRAQ arranged to smuggle scud missiles, chemical weapons and uranium into the Sudan using Sudanese diplomatic mail privileges and other means. Sudan agreed to store this material for IRAQ for safekeeping after the Gulf War to help circumvent U.N. weapons inspections. |
| Exhibit L - During the early 1990s, Sudan’s Sheikh Hassan al-Tourabi of the Islamic National Front arranged meetings between BIN-LADEN and IRAQI INTELLIGENCE officials. BIN LADEN met with FARUQ AL-HIJAZI, an IRAQI INTELLIGENCE agent in the Sudan who would later head IRAQI INTELLIGENCE for SADDAM HUSSEIN. BIN LADEN again met with IRAQI INTELLIGENCE officers in 1994 and 1995 in the Sudan. At these meetings, BIN-LADEN and IRAQI INTELLIGENCE secret service director FARUQ AL-HIJAZI agreed to work together on terrorist projects directed against the U.S. |
| Exhibit M - During his time in Sudan, BIN LADEN became interested in using Iraqi chemical and biological weapons and explored plans to use crop dusting aircraft to disperse toxins as the IRAQI INTELLIGENCE and military had done a few years earlier in Kurdistan. |
| Exhibit N - On February 26, 1993 a bomb was detonated in the World Trade Center underground parking lot, killing six U.S. citizens. IRAQI sponsored terrorists planned, financed, executed and carried out that World Trade Center bombing. |
| Exhibit O - The 1993 WTC bombing, took place on the Friday before the two year anniversary of IRAQ’s defeat in Kuwait, which was February 28, 1991. The anniversary in 1993, was a Sunday and few people would have been working at the World Trade Center that day; and IRAQ and the terrorists wanted to maximize the number of American casualties. |
| Exhibit P - During the initial planning of the WTC bombing, Mahmud Abu Halima (who was later convicted for his role in the bombing) was in regular and frequent contact with his uncle Kadri Abu Bakr, who lived in IRAQ and had been a member of a PLO faction allied with SADDAM HUSSEIN. Shortly after these calls, the mastermind of the bombing, Ramzi Ahmed Yousef, an IRAQI INTELLIGENCE agent, traveled to the United States using travel documents forged in Kuwait during the Iraqi occupation of that country in 1991. |
| Exhibit Q - Ramzi Yousef arrived in New York on September 1, 1992 using an Iraqipassport and requesting asylum. On December 31, 1992, he presented photocopies of passports for Abdul Basit at the Pakistani consulate in New York claiming to be Basit and requesting replacement of his “lost” passport. The real Basit was a Pakistani citizen who had moved to Kuwait and disappeared during the Iraqi occupation in August 1990. IRAQI INTELLIGENCE had access to the Kuwaiti Interior Ministry files and upon information and belief, inserted Yousef’s fingerprints into the file and provided him with photocopies of two older passports from Basit’s file. The Pakistani Consulate, accordingly, provided Yousef a temporary passport, based on the false documents. This provided Yousef with a means to escape the U.S. two days after the World Trade Center bombing. In fleeing the United States after the bombing, Yousef first traveled through Baluchistan, an uncontrolled region of Iran straddling the border of Iran and Pakistan with strong ties to IRAQ. By the following year, 1994, Yousef was living in the Phillippines. He fled there however, after authorities discovered a plan he was working on to bomb United States’ airliners. Yousef fled to Pakistan and was eventually sheltered at an AL QAEDA guesthouse. He was arrested in February 1995 in Pakistan and extradited to the U.S. for prosecution and was eventually convicted in the 1993 World Trade Center bombing conspiracy. |
| Exhibit R - ABDUL RAHMAN YASIN, who was born in the United States to IRAQI parents but had been raised in Iraq, was questioned in New York and New Jersey in connection with the World Trade Center bombing, but was released after appearing to cooperate with U.S. officials. He fled the country the next day and traveled to Baghdad, IRAQ. U.S. prosecutors later learned that he, along with others, had prior training in bomb making, and had mixed the chemicals and constructed the bomb that was used on the World Trade Center. IRAQI INTELLIGENCE knew of Yasin’s presence in IRAQ and provided him refuge. On August 4, 1993 Yasin was indicted in absentia for the World Trade Center bombing. |
| Exhibit S - In June 1994 YASIN was seen in Baghdad by an ABC news correspondent who was told that YASIN worked for IRAQI government. U.S. law enforcement officials confirmed that fugitive YASIN has been sheltered in IRAQ, a continuing violation of United Nationals Security Council Resolution 687 which makes it unlawful to harbor a suspected terrorist. In June 2002, YASIN was interviewed in Baghdad by Leslie Stahl from CBS. Yasin still remains in Iraq. |
| Exhibit T - Ramzi Ahmed Yousef, Mohammed Salameh, Nidal Ayyad, Mahmud Abu Halima and Ahmad Mohammed Ajaj were all eventually convicted in the Southern District of New York for the 1993 conspiracy to bomb the World Trade Center. |
| Exhibit U - Following his arrest in 1995, Ramzi Yousef told U.S. investigators that his intent was to create an explosion that would cause one of the World Trade Center Towers to fall over onto the other, destroying both and causing massive American casualties. Yousef had also planned to use sodium cyanide to create a toxic cyanide gas cloud throughout the area that would poison those in the building. Fortunately, the sodium cyanide was consumed in the blast and vaporized. Before the Gulf War, IRAQ had the largest and most diversified terrorist chemical weapons program in stockpiles of sodium cyanide, and had experience in the late 1980's using chemical weapons against its Kurdish population. Upon information and belief, it was IRAQ that supplied Yousef with the sodium cyanide. |
| Exhibit V - During the worldwide hunt for fugitive Ramzi Yousef, he was living in the Phillippines with KHALID SHEIKH MOHAMMED. KHALID SHEIKH MOHAMMED’S involvement in terror activities became known when law enforcement authorities interrupted a plot to blow up a dozen U.S. commercial airliners flying to the United States from Asian cities. MOHAMMED’S participation in the planning of these acts of terror was uncovered by authorities after Yousef accidently started a fire in his apartment in Manila while mixing bomb chemicals. Filipino authorities were suspicious when they saw chemicals, bomb making instructions and timing devices in the apartment and they seized those items along with a computer containing the details of the airliner bombing plans. MOHAMMED and Yousef fled the country, before they could be arrested. |
| Exhibit W - MOHAMMED eventually found sanctuary in Doha, Qatar. In early 1996, MOHAMMED was visited in Qatar by BIN LADEN. Around the same time, FBI director, Louis Freeh, wrote to the Qatari government requesting that it surrender MOHAMMED to U.S. authorities. Not long after the FBI request, with the assistance of Qatari officials, MOHAMMED fled to Prague, Czech Republic, foiling U.S. attempts to arrest him. |
| Exhibit X - MOHAMMED’s whereabouts after his escape to Prague in May 1996 are not known, but documents and AL QAEDA members captured in Afghanistan identified
MOHAMMED as a leader in the AL QAEDA terror network and actively involved in
the planning, logistics and financing of the September 11th attacks. His participation in the planned hijacking of U.S. commercial airliners was not new for him. MOHAMMED is a close associate of ABU ZUBAYDAH, a top BIN LADEN associate who was fully aware of the targets of the September 11th hijackers. ZUBAYDAH is in the custody of United States authorities and is providing some information about AL QAEDA operations. |
| Exhibit Y - In 1992 and 1993, AL QAEDA trained terrorists in Somalia and attempted to incite an Islamic jihad there against U.S. military forces stationed in Mogadishu, Somalia by working with Somali warlord, General Farah Adid. BIN LADEN issued a fatwa urging Muslims to attack the U.S. and U.N. military forces stationed there during Operation Restore Hope. BIN Laden, Mamdouh Mahmud Salim, MUHAMMAD ATEF, SAIF AL ADEL, ABDULLAH AHMED ABDULLAH, MUHSIN MUSA MATWALLI ATWAH, a/ka "Abdel Rahman," FAZUL ABDULLAH MOHAMMED, a/k/a "Harun," AHMED MOHAMED HAMED ALI and MOHAMED SADEEK ODEH, along with Abu Ubaidah al Banshiri, provided weapons, military training and assistance to the Somali tribes working for Adid who were opposed to the U.N. intervention in Somalia and urged them to attack U.S. military personnel. On October 3 and 4, 1993, these forces did attack U.S. military personnel in Mogadishu and killed 18 U.S. servicemen. |
| Exhibit Z - From 1996 until 2001, BIN LADEN with the financial and logistical support of OMAR and others in the TALIBAN and IRAQ and IRAQI INTELLIGENCE, created, supplied and operated at least five training camps in order to create an “Islamic Foreign Legion” capable of attacking their enemies throughout the world. These camps trained men from 15 nations in guerrilla warfare, terrorist activities, rocket warfare, demolition and bombing, including the use of mines, grenades, TNT, nitroglycerine and plastic explosives. Classes were also given in “how to kill a policeman” and “traps, murder and terrorist moves.” |
| Exhibit Aa - In February 1997, BIN LADEN publicly expressed his support for IRAQ in its conflict with the United States stating: “The hearts of the Muslims are filled with hatred towards the United States of America and the American president for American conduct towards IRAQ.” |
| Exhibit Bb - Having decided to carry out acts of terrorism, SADDAM HUSSEIN, with the advice and prompting of his son and IRAQI INTELLIGENCE chief, QUSAY HUSSEIN and his other son UDAY HUSSEIN, head of an IRAQI INTELLIGENCE Subdivision known as the “Fedayeen” and “Al-Qare,” concluded that a campaign of terrorist attacks against the United States, under the banner of BIN LADEN and AL QAEDA, was the most effective means of both deflecting U.S. attempts to topple his regime and obtaining IRAQI revenge. |
| Exhibit Cc - IRAQ upon information and belief, agreed to supply arms to AL QAEDA and provide AL QAEDA with access to and training in the use of chemical and biological weapons and agreed to instruct AL QAEDA terror trainers at its Salman Pak camp in Baghdad that contained a Boeing 707 used to practice hijacking. IRAQ also agreed to supply AL QAEDA terrorists with new identities and passports from Yemen and the United Arab Emirates. |
| Exhibit Dd - AL QAEDA agreed to provide protection from political opponents to IRAQ and SADDAM HUSSEIN, and to commit assassinations and other acts of violence to create instability in regions of IRAQ, particularly Kurdistan, to assist the regime of SADDAM HUSSEIN. AL QAEDA further agreed to provide trained terrorists, assassins and martyrs to carry out terror attacks in concert with IRAQ against their common enemies, including the United States. |
| Exhibit Ee - In their February 22, 1998 fatwa, BIN LADEN and AL QAEDA expressly referenced the United States’ “continuing aggression” towards IRAQ as one of their reasons for calling on all Muslims to kill Americans “wherever and whenever” they are found: The best proof of this is the Americans’ continuing aggression against the Iraqi people using the [Arabian] Peninsula as a staging post, even though all its rulers are against their territories being used to that end, still they are helpless. The BIN LADEN and AL QAEDA fatwa also cited the alleged “great devastation inflicted on the Iraqi people” by the United States, as well as the United States alleged “eagerness to destroy Iraq.” |
| Exhibit Ff - Additional fatwas of a similar nature were issued in May 1998 and published in Al-Quds under the banner of the ULEMA UNION OF AFGHANISTAN. A May 29, 1998 fatwa issued by BIN LADEN called for the use of a nuclear bomb to “terrorize the Jews and Crusaders who were enemies of God.” At the time BIN LADEN was seeking to obtain nuclear material from IRAQ and others who possessed nuclear material and was in the process of developing nuclear weapons. |
| Exhibit Gg - Between April 25 and May 1, 1998, two of BIN LADEN’s senior military commanders, MUHAMMAD ABU-ISLAM and ABDULLAH QASSIM, visited Baghdad for discussions with SADDAM HUSSEIN’s son -- QUSAY HUSSEIN -- the “czar” of IRAQI INTELLIGENCE. |
| Exhibit Hh - QUSAY HUSSEIN’s participation in those meetings highlights the importance of the talks in both symbolic and practical terms. Upon information and belief, as a direct result of these meetings, IRAQ again made commitments to provide training, intelligence, clandestine Saudi border crossings, financial support and weapons and explosives to AL QAEDA. |
| Exhibit Ii - IRAQI INTELLIGENCE officials met with BIN LADEN in Afghanistan several more times. A second group of BIN LADEN and AL QAEDA operatives from Saudi Arabia were then trained by IRAQI INTELLIGENCE in IRAQ to smuggle weapons and explosives into Saudi Arabia and other countries, which they later accomplished in an effort to carry out future terrorist acts of violence. A third group of BIN LADEN and AL QAEDA operatives received a month of sophisticated guerrilla operations training from IRAQI INTELLIGENCE officials later in the Summer of 1998. |
| Exhibit Jj - Despite philosophical and religious differences with SADDAM HUSSEIN, BIN LADEN continually sought to strengthen and reinforce the support he and AL QAEDA received from IRAQ. In mid-July 1998, BIN LADEN sent Dr. AYMAN AL-ZAWAHIRI, the Egyptian co-founder of AL QAEDA, to IRAQ to meet with senior Iraqi officials, including Iraqi vice president TAHA YASSIN RAMADAN. Upon information and belief, the purpose of this meeting was to discuss and plan a joint strategy for a terrorist campaign against the United States. |
| Exhibit Kk - Upon information and belief, IRAQI INTELLIGENCE officials pledged IRAQ’s full support and cooperation on the condition that BIN LADEN and AL QAEDA promised not to incite those groups inside IRAQ opposed to the regime of
Iraqi dictator SADDAM HUSSEIN. |
| Exhibit Ll - During the July 1998 visit ZAWAHIRI toured an IRAQI military base and nuclear and chemical weapons facility near al-Fallujah in IRAQ and upon information and belief, observed training by IRAQI INTELLIGENCE officials of AL QAEDA operatives at the al-Nasiriyah military and chemical weapons facility in IRAQ. |
| Exhibit Mm - To demonstrate its commitment to IRAQ and its anti-U.S. policies, in the Spring of 1998, AL QAEDA planned terrorist bombing attacks on the U.S. Embassies in Nairobi, Kenya and Dar Es Salaam, Tanzania. FAZUL ABDULLAH MOHAMED, Khalfan Khamis Mohamed, MUSTAFA MOHAMED FADHIL, Mohamed Rashed Daoud Al-‘Owali, SHEIKH AHMED SALIM SWEDAN, FAHID MOHAMED ALLY MSALAM and an individual known as ABDULLAH AZZAM were chosen as some of the AL QAEDA terrorists who would conduct the coordinated attacks in Nairobi and Dar Es Salaam. |
| Exhibit Nn - On July 30, 1998, IRAQ warned it would take action unless the United Nations embargo was lifted. IRAQ blamed the United States for the United Nations embargo. On August 4, 1998, IRAQ, refused to cooperate with the United Nations weapons inspectors in IRAQ and talks for a resolution of the crisis collapsed, causing U.N. inspectors to leave. |
| Exhibit Oo - In December 1998, after a stand off between the U.N. and IRAQ and a discovery of weapons violations in IRAQ, the U.S. led U.N. allies in a four-day air strike on IRAQ. Iraqi Trade Minister MUHAMMAD MAHDI SALAH then stated that he expected terrorist activities against the United States to increase as a result of the bombing of IRAQ. The Arabic language daily newspaper Al-Quds Al-Arabic cited the cooperation between IRAQ, BIN LADEN and AL QAEDA in a late December 1998 editorial, which predicted that “President SADDAM HUSSEIN, whose country was subjected to a four day air strike, will look for support in taking revenge on the United States and Britain by cooperating with Saudi oppositionist Osama Bin-Laden, whom the United States considers to be the most wanted person in the world.” The editorial noted that this type of cooperation was already taking place, considering that “Bin-Laden was planning on moving to IRAQ before the recent strike.” |
| Exhibit Pp - Following the December 1998 air strikes on IRAQ, SADDAM HUSSEIN dispatched FARUQ AL-HIJAZI to Kandahar, Afghanistan in order to meet with BIN LADEN and plot their revenge. |
| Exhibit Qq - QUSAY HUSSEIN also dispatched representatives to follow-up with BIN LADEN and obtain his firm commitment to exact revenge against the United States for the December 1998 bombing campaign. IRAQ offered BIN LADEN and AL QAEDA an open-ended commitment to joint operations against the United States and its “moderate” Arab allies in exchange for an absolute guarantee that BIN LADEN, AL QAEDA and their allies would not attempt to overthrow SADDAM HUSSEIN’s regime in IRAQ. |
| Exhibit Rr - To demonstrate IRAQ’s commitment to BIN LADEN and AL QAEDA, HIJAZI presented BIN LADEN with a pack of blank, official Yemeni passports, supplied to IRAQI INTELLIGENCE from their Yemeni contacts. HIJAZI’s visit to Kandahar was followed by a contingent of IRAQI INTELLIGENCE officials who provided additional training and instruction to BIN LADEN and AL QAEDA operatives in Afghanistan. These Iraqi officials included members of “Unit 999,” a group of elite IRAQI INTELLIGENCE officials who provided advanced sabotage and infiltration training and instruction to AL QAEDA operatives. |
| Exhibit Ss - At that meeting, upon information and belief, BIN LADEN, AL QAEDA and IRAQ agreed to join efforts in a detailed, coordinated plan for a protracted terrorist war against the United States. |
| Exhibit Tt - IRAQ also agreed to provide BIN LADEN and AL QAEDA with the assistance of an expert in chemical weapons; and BIN LADEN agreed to hunt down Iraqi opposition leaders who cooperated with the United States against HUSSEIN. In furtherance of this agreement, BIN LADEN agreed to have a group of AL QAEDA’s “Afghan” Arabs enter IRAQ to fight Kurdish dissidents. |
| Exhibit Uu - IRAQ maintains an advanced chemical and biological weapons program and is one of only three countries in the world producing a highly developed weaponized anthrax. Some time during or after 1998, IRAQ agreed to help BIN LADEN and AL QAEDA develop a laboratory in Afghanistan designed to produce anthrax. |
| Exhibit Vv - In addition to the al-Nasiriyah and Salman Pak training camps, by January 1999, BIN LADEN and AL QAEDA operatives were being trained by IRAQI INTELLIGENCE and military officers at other training camps on the outskirts of Baghdad. |
| Exhibit Ww - In January 1999, IRAQ began reorganizing and mobilizing IRAQI INTELLIGENCE front operations throughout Europe in support of BIN LADEN and AL QAEDA. HAQI ISMAIL, believed to be a member of the IRAQ’S MUKHABARAT Secret Service, left IRAQ to train in an Afghanistan AL QAEDA camp. ISMAIL was believed to be a liason between IRAQ, the TALIBAN and AL QAEDA and was rewarded with a position in the TALIBAN Foreign Ministry. |
Exhibit Xx - On December 14, 1999, Ahmed Ressam, an AL QAEDA operative, was arrested while driving a truck from Canada into the United States at Port Angeles, Washington. The truck was loaded with bomb making materials and detonators. Ressam later confessed to, and was convicted of conducting an AL QAEDA plan to detonate a large bomb at Los Angeles International Airport on New Year’s Day 2000. AL QAEDA terrorists ABU JAFFER AL-JAZIRI, BIN LADEN’s longtime IRAQI assistant, and MAHFUZ OUL AL-WALID, a/k/a Khaled Al-Shanguiti, a/k/a Abu Hafs, a/k/a “the Mauritanian,” were both identified as orchestrating the so called “Millennium Plot.” Both are believed to have been killed in Afghanistan in January 2002 during fighting with United States Armed Forces.
In April 2000, UDAY HUSSEIN, as a birthday gift to his father, SADDAM HUSSEIN, assembled a squad of 1,200 trained men called AL QARE. Thirty of them were dispatched with UAE passports to points around the world to standby for orders to commit acts of sabotage, urban warfare and hijacking. |
| Exhibit Yy - In the spring of 2000, IRAQI INTELLIGENCE began planning to attack United States warships in the Persian Gulf in an effort to prompt a United States withdrawal. IRAQ sought suicide bombers who would employ small boats packed with explosives to ram United States’ warships. |
| Exhibit Zz - On October 12, 2000, IRAQI INTELLIGENCE and members of AL QAEDA including BIN LADEN, JAMAL AL-BADAWI, KHALID AL-MIDHAR, MOHAMMED OMAR AL-HARAZI, WALID AL-SOUROURI, FATHA ADBUL RAHMAN, YASSER AL-AZZANI, JAMAL BA KHORSH, AHMAD AL-SHINNI, RAED HIJAZI, JAMIL QASIM SAEED MOHAMMED, as well as the two suicide boat bombers Abd Al-Mushin Al-Taifi (deceased) (and a suspect in the August 1998 Embassy bombings) and Hassan Said Awadh Khemeri (deceased) carried out their plan to bomb the U.S.S. Cole by ramming a small boat loaded with explosives into the side of the ship as it was anchored in the harbor at Aden, Yemen, resulting in the deaths of 17 American sailors and injuring an additional 39. |
| Exhibit aa - On October 14, 2000, just two days after the attack on the U.S.S. Cole, two Saudis hijacked a Boeing 777 from Saudi Arabia and had it flown to Baghdad, IRAQ. The hijackers were given “asylum” in IRAQ. They were extensively interviewed in the Iraqi press and criticized the Saudi government. |
| Exhibit bb - Upon information and belief, this hijacking was a message between BIN LADEN and IRAQ intended to demonstrate that AL QAEDA terrorists could seize control of large commercial aircraft that could be used as a weapon in the hands of suicide terrorists, foreshadowing a coordinated attack that was less than a year away and planning was well underway in 2000. |
| Exhibit cc - On January 22, 2001, the Arab language newspaper Al Watan Al Arabi, reported that SADDAM HUSSEIN and his sons had called for an Arab alliance to “launch a global terrorist war against the United States and its allies.” The newspaper characterized HUSSEIN’s statement as calling for an uncompromising campaign and “scorched earth policy.” |
| Exhibit dd - In May 2001, AL QAEDA operatives in Kurdistan assassinated Franso Hariri, a member of the Kurdish Democratic Party, as part of a deal with SADDAM HUSSEIN. The killing of Hariri created instability in the region by damaging relations between the co-leaders of Kurdistan. This benefitted the HUSSEIN regime in IRAQ. |
| Exhibit ee - In May 2001, Iraqi physician and kidney specialist Dr. Mohammed Khayal was dispatched from Baghdad to Afghanistan for three days to treat BIN LADEN’s kidney problem, further demonstrating the important relationship between IRAQ and BIN LADEN less than four months before the single largest terrorist attack in history. |
| Exhibit ff - During the May 2001 trial of some of the AL QAEDA defendants who bombed the U.S. Embassies in Africa, the defendents expressed sympathy, solidarity and support for IRAQ and condemnation for the United States and was their motivation for the bombings. |
| Exhibit gg - IRAQ knew in advance that AL QAEDA was planning to attack U.S. landmarks and civilians in September 2001 in Washington and New York and supported the planned attacks. |
| Exhibit hh - Upon information and belief, Iraqi news columnist Naeem Abd Mulhalhal has been connected with IRAQI intelligence since the early 1980s. As such, he comments on matters of IRAQI political interest for the Al Nasiriyah newspaper, a weekly paper published in the provincial capital city of Al Nasiriyah. On September 1, 2001 he was honored for his “documentation of important events and heroic deeds that proud Iraqis have accomplished" and praised by SADDAM HUSSEIN. In addition, Al Nasiriyah also contains a military base that is believed to contain a chemical weapons storage facility. IRAQ had previously denied access to this base to UN weapons inspectors. It was visited by ZAWAHIRI as early as 1998 and AL QAEDA terrorists trained there for several years. |
| Exhibit ii - On July 21, approximately six weeks before the September 11th attacks, IRAQI columnist Mulhalhal reported that BIN LADEN was making plans to “demolish the Pentagon after he destroys the White House.” |
| Exhibit jj - Mulhalhal’s July 21 article further informed that BIN LADEN would strike America “on the arm that is already hurting.” Upon information and belief, this references a second IRAQI sponsored attack on the World Trade Center. This interpretation is further bolstered by another reference to New York as “[BIN LADEN] will curse the memory of Frank Sinatra everytime he hears his songs.” (e.g., “New York, New York”) identifying New York, New York as a target.,/font> |
Exhibit kk - Mulhalhal further indicated, “The wings of a dove and the bullet are all but one and the same in the heart of a believer.” (Emphasis supplied) This appears to be a reference to the use of commercial aircraft as a weapon. The information was reported in an IRAQI newspaper who’s editor-in-chief serves as secretary to UDAY HUSSEIN’S Iraqi Syndicate of Journalists. The article expressed IRAQI admiration and support for BIN LADEN’s plans and its appearance in the newspaper would clearly have to be endorsed by SADDAM HUSSEIN himself.
All IRAQI news media is strictly controlled and censored by the government of SADDAM HUSSEIN and is under the direct oversight of UDAY HUSSEIN. Various members of IRAQI intelligence work at and control the content of each and every newspaper published inside IRAQ. |
| Exhibit ll - The information contained in Mulhalhal’s published statements were known prior to the events of September 11th, and that Mulhalhal has ties to IRAQI intelligence, demonstrates foreknowledge of the planned attacks by BIN LADEN and indicates support by IRAQI co-conspirators. |
| Exhibit mm - IRAQ’s July 21 public statements also exemplify the BIN LADEN pattern of publicly threatening violent strikes against the United States prior to and after committing them. For example, weeks before the August 1998 AL QAEDA attacks on the U.S. embassies in Africa, BIN LADEN threatened U.S. civilians and shortly thereafter, bombed the embassies in Kenya and Tanzania within minutes of each other, killing 223 civilians. |
| Exhibit mm - According to U.S. and foreign intelligence officials, in the spring of 2000, IRAQI INTELLIGENCE agents met with September 11th pilot hijackers ZAID SAMIR JARRAH and MARWAN AL-SHEHHI in Dubai, UAE in order to advance the hijacking of U.S. aircraft to commit terrorist acts. Not long after the meeting, ALSHEHHI entered the United States on May 29 and JARRAH entered on June 27, to begin preparations for attacks. |
| Exhibit nn - According to Czech intelligence sources, on June 2, 2000, MOHAMMAD ATTA a pilot and the operational leader of the September 11, 2001 terrorist attacks traveled to Prague to meet other co-conspirators. The following day, ATTA arrived at Newark International Airport in the United States. |
| Exhibit oo - According to the FBI, from July 2000 through March 2001, ATTA, SHEHHI, HANJOUR, JARRAH and HAMZI traveled to the U.S. where they resided and took pilot courses to learn to fly the Boeing 747, 757, 767 and Airbus A320 in furtherance of the AL QAEDA IRAQI conspiracy to hijack U.S. aircraft to commit terrorist acts. |
| Exhibit pp - Upon information and belief, sometime between April 8-11, 2001, ATTA left Florida where he was a flight student, to again meet in Prague with IRAQI INTELLIGENCE agent AL-ANI. ATTA returned to Florida and within two weeks opened a Sun County Bank account with $100,000 sent through a money changer in the UAE. Later in 2001, AL-ANI was expelled from the Czech Republic for espionage activities. Other intelligence reports indicate that AL-ANI met with another September 11th hijacker, KHALID AL MIDHAR as well. |
| Exhibit qq - Italian security sources reported that IRAQ made use of its embassy in Rome to foster and cultivate IRAQ’s partnership with BIN LADEN and AL QAEDA. HABIB FARIS ABDULLAH AL-MAMOURI, a general in the IRAQI SECRET SERVICE, and a member of IRAQ’s M-8 Special Operations branch, who was responsible for developing links with Islamist militants in Pakistan and Afghanistan, was stationed in Rome as an “instructor” for children of Iraqi diplomats. ALMAMOURI met with September 11th pilot hijacker MOHAMMED ATTA in Rome, Hamburg and Prague. AL-MAMOURI has not been seen in Rome since July 2001, shortly after he last met with ATTA. |
| Exhibit rr - On July 7, 2001 two members of the IRAQ MUKHABARAT, ABU AGAB and ABU WA’EL traveled together from Germany to Afghanistan and eventually to Kurdistan. ABU WA’EL trained at AL QAEDA terror camps and became the authority for fundamentalist groups operating in Kurdistan, intent on crushing opposition to SADDAM HUSSEIN. |
| Exhibit ss - SADDAM HUSSEIN is the only national leader in the world who publicly praised the attacks and said that the United States of America deserved them. IRAQ has offered sanctuary to BIN LADEN and TALIBAN leaders. Abu Zeinab al- Quarairy, an Iraqi defector who was an officer in the MUKHABARAT and was familiar with its operations, reported that when he learned about the World Trade Center attacks on September 11th, he turned to a friend and said, “That’s ours.” |
| Exhibit tt - Upon information and belief, several hundred AL QAEDA members, including ABU ABDUL RAHMAN fled Afghanistan for Kurdistan in IRAQ to try to take control of towns not under the control of SADDAM HUSSEIN and IRAQ, including Halabja, Tawela and Biyarah. On September 23, 2001, Kurdish forces ousted Ansar al Islam from Halabja, but the Islamic fundamentalist group remained in control of Tawela and Biyarah. |
| Exhibit uu - Israeli intelligence sources verify that for the past two years, IRAQI INTELLIGENCE officers have been shuttling back and forth between Baghdad and Afghanistan. According to the Israelis, one of these IRAQI INTELLIGENCE officers, SALAH SULEIMAN, was captured in October 2001 by Pakistani officials near the border between Pakistan and Afghanistan. |
| Exhibit vv - In March 2002, U.S. and allied forces discovered a laboratory near Kandahar, Afghanistan that was designed to produce weapons grade anthrax. Upon information and belief, IRAQI INTELLIGENCE agents were supplying technology, materials and training to develop this facility in coordination with AL QAEDA and the TALIBAN. |
| Exhibit vv - Instruction documents on an artillery weapon known as the “Super Gun” were found in AL QAEDA camps when they were captured by U.S. forces in the winter of 2001-2002. IRAQ is the only state known to have purchased and assembled the super gun, a weapon so large it must be constructed in segments. It has a range of several hundred miles. |
