Most fearsome enemy of Saddam: PI lawyers

Last month, the NYC lawfirm Kreindler & Kreindler filed a consolidated complaint against AQ, Iraq, Sudan, the Taliban, several Saudi princes, at least one person whose name indicates he's from Libya, and just about anyone else you can think of. You can read a copy of the complaint here.

You can read an older article about the predecessor suit 'Suing Bin Laden' (motherjones) and 'Lawsuit: Iraq Knew of Attacks Before 9/11' (FOX). There's more on Salman Pak and the Iraq-AQ connection in 'Cheney, Powell, Rice Mum on Saddam's 9-11 Hijacking School'. For an overview of the connection, see this.

On August 29, 2001, a citizen of the Cayman Islands wrote a letter to a radio host concerning three Afghans who had been detained while trying to enter from, of all places, Cuba: "Mr. Walton we have an urgent situation with the three Afghanistans that we have in our midsts for the past months. I have been convinced that they are agents of Osama Bin Laden - one of the world's greatest terrorist - operating out of - you guessed it - Afghanistan. The three agents here are organizing a major terrorist act against the U.S. via an airline or airlines."

As discussed at the end of "In Castro's Service", the letter's author says it was just "speculation" on his part.

In "Saddam and the Next 9/11: The Iraqi dictator and his son talk about the uses of biological weapons," Peggy Noonan says:

What our readers should understand is that the rulers in Iraq have also long admired the methods of bin Laden and other anti-American terrorists, going back before September 11, 2001. This is clear simply from reading the Iraqi press, which is of course government controlled...

a July 21, 2001, commentary in the Iraqi publication Al-Nasiriya praised bin Laden: "In this man's heart you'll find an insistence, a strange determination that he will reach one day the tunnels of the White House and will bomb it with everything that is in it."

The article recounts bin Laden's attacks on U.S. targets and U.S. efforts "to pressure the Taliban movement so that it would hand them bin Laden, while he continues to smile and still thinks seriously, with the seriousness of the Bedouin of the desert about the way he will try to bomb the Pentagon after he destroys the White House."

The commentary is ominously prescient, especially since it could never have appeared without official sanction. "Bin Laden is a healthy phenomenon in the Arab spirit," it continues, speaking about his goal to "drive off the Marines" from Arabia. Most eerily of all, the writer adds that those Marines "will be going away because the revolutionary bin Laden is insisting very convincingly that he will strike America on the arm that is already hurting. That the man . . . will curse the memory of Frank Sinatra every time he hears his songs." Is that a reference to Sinatra's "New York, New York"? Did Saddam know what would happen two months later?

(Off the Saddam thing momentarily, here's an article called 'Is There a Better Way to Go?' which favors up to a year of, for lack of a better word, bad-ass inspectors and inspections. No word on whether she wants Scott Ritter to go as well; some think he's been, er, comprimised. A chart of Saddam's links with WMD is at http://cns.miis.edu/pubs/other/sjm_cht.htm And, here's an article called 'Autopilot could land hijacked planes'. And, there's 'When the Enemy Is a Liberator'.)

Anyway, click the MORE link right below to read my excerpts of the K&K complaint. All highlighting is as in the original, except I also highlighted occurences of the word 'Iraq'.

28. As early as 1992, AL QAEDA terrorists established close working relations with iraq I 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 ut iraq 's error attacks. The RAQ-AL QAEDA relationship benefitted b>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 benefitted AL QAEDA which received the support, funding, facilities and training needed to carry out its terror campaigns.

29. 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 military or terror training camps contained the fuselage of a Boeing 707 used to teach techniques
for hijacking commercial aircraft to AL QAEDA terrorists. [ed: Salman Pak]

44. At various times from as early as 1989, BIN LADEN, and others known and
unknown, ran terrorist training "camps and guesthouses" in various areas, including
Afghanistan, iraq , IRAN, Pakistan, the SUDAN, Somalia, Kenya, Malaysia, Philippines
and Germany for the use of AL QAEDA and its affiliated groups. Mamdouh Mahmud Salim, ABU HAJER AL IRAQI, an IRAQI, managed some of these training camps and
guesthouses in Afghanistan and Pakistan.

46. In 1991, BIN LADEN left Saudi Arabia and relocated in the SUDAN. He
centered his AL QAEDA operations there for the next four years while maintaining offices
and orchestrating terrorist recruitment, training and launching attacks in various parts of the world. BIN LADEN recruited new members in the SUDAN, such as MOHAMED SULEIMAN AL NALFI and at least 200 Afghan Arabs, Saudis, Yemenis and Egyptians
who had fought against the Soviets in Afghanistan and who became part of AL QAEDA's
cell in the SUDAN. ABU HAJER AL-IRAQ i, a/k/a Mamdouh Mahmud Salim, an IRAQI, served as BIN LADEN's top lieutenant in the SUDAN shortly after BIN LADEN's
arrival there.

93. While AL QAEDA's presence was growing in the SUDAN in 1992, the
Government of iraq also had 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, and 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.
94. During the early 1990s, SUDAN's Sheikh HASSAN AL-TURABF of
the NATIONAL ISLAMIC 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.

95. 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 earlier in Kurdistan.

96. Upon information and belief, there have been numerous meetings between
IRAQI INTELLIGENCE agents and high-ranking AL QAEDA terrorists to plan terror attacks. One 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.

99. During the initial planning of the WTC bombing, Mohammed Salameh (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 a/k/a Abdul Basit, an IRAQI INTELLIGENCE
agent, traveled to the United States using travel documents obtained in Kuwait during the
IRAQI occupation of that country in 1991.

100. Ramzi Yousef arrived in New York on September 1, 1992 using an IRAQI
passport 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. 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 left the Phillippines
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.

101. ABDUL RAHMAN YASIN, who was born in the United States to IRAQI
parents but had been raised in IRAQ, within days of the 1993 bombing 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 in 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.

102. 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 remains in IRAQ.

103. 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.

104. 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.

105. 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. KHALID's participation in the planning of these acts of terror was
uncovered by authorities after he and Yousef accidently started a fire in their 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.
KHALID and Yousef fled the country, before they could be arrested.

106. KHALID eventually found sanctuary in Doha, Qatar. In early 1996,
KHALID was visited in Qatar by BIN LADEN. Around the same time, FBI director, Louis
Freeh, wrote to the Qatari government requesting that it surrender KHALID to U.S.
authorities. Not long after the FBI request, with the assistance of Qatari officials, KHALID
fled to Prague, Czech Republic, foiling U.S. attempts to arrest him.
107. KHALID's whereabouts after his escape to Prague in May 1996 are not
known, but documents and AL QAEDA members captured in Afghanistan identified
KHALID as a leader in the AL QAEDA terror network and actively involved in the
planning, logistics and financing of the September 11 th attacks. His participation in the
planned hijacking of U.S. commercial airliners was not new for him. KHALID is a close
associate of ABU ZUBAYDAH, a top BIN LADEN associate who was fully aware of the
targets of the September 11 th hijackers. ZUBAYDAH is in the custody of United States
authorities and is providing some corroborating information about AL QAEDA operations.

IRAQI AND AL QAEDA INTERESTS PUBLICLY MERGE
115. 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."

116. 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.

117. 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.

118. 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 as they had done in Afghanistan in support of their host TALIBAN. 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.

119. On February 22, 1998, BIN LADEN, Khalid Al Fawwaz and AYMAN AL
ZAWAHIRI of the EGYPTIAN ISLAMIC JIHAD issued a fatwa published in the Arabic

123. 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 .

124. 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.

125. 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.

126. 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 dictatornewspaper Al-Quds stating:
The ruling to kill the Americans and their allies -civilians
and military - is an individual duty for every
Muslim who can do it in any country in which it is
possible to do it. . . .

120. 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."

121. 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
trying to develop nuclear weapons.

122. 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.

123. 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 .

124. 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.

125. 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.

126. 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.
127. 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.

U.S. EMBASSY BOMBINGS
128. 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.

129. In July and early August 1998, AL QAEDA terrorists MUSTAFA
MOHAMED FADHIL, Khalfan Khamis Mohamed, AHMED KHALFAN GHAILANI,
FAHID MOHAMMED ALLY MSALAM, AHMED the German, SHEIKH AHMED
SALIM SWEDAN, Mohamed Sadeek Odeh and FAZUL OBDULLAH MOHAMMED
were stationed in Dar es Salaam where they purchased a 1987 Nissan Atlas truck and
outfitted it with oxygen, acetylene tanks, TNT, batteries, detonators, fertilizer and sand
bags, creating a massive bomb to be driven into the U.S. Embassy. Odeh, FAZUL
OBDULLAH MOHAMMED and others who participated in the bombings had been with
BIN LADEN since the early 1990s and BIN LADEN's days in the SUDAN.

130. 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.

131. Three days later, on August 7, 1998, at approximately 10:30 a.m., FAZUL,
Al-'Owhali and AZZAM drove a Toyota Dyna truck (outfitted similarly to a Nissan Atlas
truck in Dar Es Salaam) to the U.S. Embassy in Nairobi, Kenya and detonated a large bomb
damaging the Embassy and demolishing a nearby Secretarial College building and
Cooperative Bank building, resulting in the more than 213 deaths (12 Americans) and
injuries to more than 4,500 people.

132. On August 7, 1998 at approximately 10:40 a.m., ten minutes after the
bombing in Kenya, Khalfan Khamis Mohamed and AHMED the German detonated the Dar
Es Salaam bomb in the vicinity of the U.S. Embassy in Dar Es Salaam, Tanzania severely
damaging the Embassy building and resulting in the death of 11 people and injuries to more
than 85 people.

133. On August 7, 1998 shortly before the bombing, Eidarous, an AL QAEDA
member in London, sent a letter to news organizations in Paris, Doha, Qatar and Dubai,
UAE claiming responsibility for the Embassy bombings under the fictitious name Islamic
Army for the Liberation of Holy Places.

134. At the trial in New York of some of the AL QAEDA -U.S. Embassy
bombers, some of the defendants elicited testimony in their defense that cited the poor
living conditions in IRAQ. They blamed those conditions on the U.S.- U.N. sanctions, and
used it as motivation and explanation for the AL QAEDA attacks on the Embassies.

THE 1998 U.S. AIR STRIKES ON AL QAEDA
135. On August 20, 1998, the United States initiated a pre-emptive and retaliatory
air strike with cruise missiles on AL QAEDA training camps in Khost, Afghanistan and
a factory in Khartoum, SUDAN, believed at the time to be a chemical weapons plant used
by the Sudanese and IRAQI governments to manufacture weapons for their use and that of
AL QAEDA terrorists.

136. On August 20, 1998 President Clinton issued a statement on the air strike
Our target was terror . . . our mission was clear to strike at
the network of radical groups affiliated with and funded by
BIN LADEN, perhaps the preeminent organizer and
financier of international terrorism in the world today.

137. 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."

138. 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.

139. 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.

140. 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.

141. 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.

142. 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.

143. 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.

144. 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.

145. 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 liaison between IRAQ, the TALIBAN and AL QAEDA and was rewarded with a
position in the TALIBAN Foreign Ministry.

146. On or about June 1999, during an interview with an Arabic-language
television station, BIN LADEN issued a further threat indicating that all American males
should be killed.

MILLIENIUM PLOT
147. 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."

148. 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.

ATTACK ON U.S.S. COLE
149. 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.

150. 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,113
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.

151. The Yemeni government investigation reported that the terrorists behind the
attack were Islamic extremists who fought the Soviets in the Afghan War and who were
tied to the EGYPTIAN ISLAMIC JIHAD and AL QAEDA and who were trained in
Afghanistan. Four were arrested in Yemen. Jamil Qaseri Saeed Mohammed was arrested
a year later in Pakistan. After his arrest, AL-BADAWI admitted that he received his
instructions to bomb the U.S.S. Cole from AL QAEDA member AL-HARAZI who he had
met during the war in Afghanistan.

152. On June 20, 2001, in a videotape released to the press BIN LADEN appears
to boast that his followers bombed the U.S.S. Cole. The 100-minute tape depicts BIN
LADEN, wearing a Yemeni dagger on his belt and reciting a poem to show that he and AL
QAEDA were not afraid of attacking the United States military:
And in Aden, they charged and destroyed a destroyer that
fearsome people fear, one that evokes horror when it docks
and when it sails.

Video of the damaged destroyer was superimposed with the words in Arabic, "the
destruction of the American Destroyer Cole."

AL QAEDA -SAUDI HIJACKING
153. 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.

154. 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 well coordinated attack in the planning stages at the time and
less than a year away from execution.

IRAQI THREATS
155. 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."

156. 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.

157. 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
1 Khalid al Fawwaz was arrested on September 28, 1998 in London and Adel Mohammed
Abdul Almagid Adul Bary, and Ibrahim Eidarous were arrested in London in July 1999, and are
awaiting trial, while Mamdouh Mahmud Salim, an Iraqi and Ali Abdelseoud Mohamed were
arrested in the United States and are also awaiting trial for the Embassy bombings.
less than four months before the single largest terrorist attack in history.

158. On May 29, 2001, Wadih El-Hage, a U.S. citizen believed to be BIN
LADEN's personal secretary, was convicted in the Southern District of New York, along
with Mohamed Sadeek Odeh, Mohammed Rashed Daoud Al-'Owali and Khalfan Khamis
Mohamed, for participating in the conspiracy to bomb the United States Embassies in
Nairobi and Dar es Salaam in August of 1998. BIN LADEN and other AL QAEDA
members were indicted but remain at large.1

IRAQI FORE-KNOWLEDGE OF THE SEPTEMBER 11 TH ATTACKS
Al Nasiriyah News Article

159. 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.

160. Upon information and belief, Iraqi news columnist Naeem Abd Mulhalhal [1]
has been connected with IRAQI INTELLIGENCE since the early 1980s. 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.
161. On July 21, approximately six weeks before the September 11 th attacks,
IRAQI columnist Mulhalhal reported that BIN LADEN was making plans to "demolish
the Pentagon after he destroys the White House."

[1] Khalid al Fawwaz was arrested on September 28, 1998 in London and Adel Mohammed
Abdul Almagid Adul Bary, and Ibrahim Eidarous were arrested in London in July 1999, and are
awaiting trial, while Mamdouh Mahmud Salim, an Iraqi and Ali Abdelseoud Mohamed were
arrested in the United States and are also awaiting trial for the Embassy bombings.

162. 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 every time he hears his songs."
(e.g., "New
York, New York") identifying New York, New York as a target.

163. 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.

164. 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.

165. The information contained in Mulhalhal's published statements were known
prior to the events of September 11 th , and because Mulhalhal has ties to IRAQI intelligence,
it demonstrates foreknowledge of the planned attacks by BIN LADEN and indicates
support by IRAQI co-conspirators.

166. IRAQ's July 21, 2001 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.

167. Additionally, after the suicide boat bombing of the U.S.S. Cole in Yemen
in October 2000, BIN LADEN publicly threatened violence against America while wearing
traditional Yemeni clothing including a Yemeni war dagger. BIN LADEN sought media
attention to taunt the United States and recruit additional Muslim supporters.

PREPARATION FOR SEPTEMBER 11 TH ATTACKS
168. According to U.S. and foreign intelligence officials, in the spring of 2000,
IRAQI INTELLIGENCE agents met with September 11 th 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, AL-SHEHHI entered
the United States on May 29 and JARRAH entered on June 27, to begin preparations for
attacks.

169. According to Czech intelligence sources, on June 2, 2000, MOHAMMAD
ATTA a pilot in training 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.

170. 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.

171. 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 11 th hijacker,
KHALID AL MIDHAR as well.

172. 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. AL-MAMOURI met with September 11 th 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.

175. 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.

187. 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 11 th , he turned to a friend and said, "That's ours."

189. 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.

191. 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.

211. HAJI MOHAMAD AKRAM, a captured BIN LADEN aide told an
interviewer from the Christian Science Monitor that BIN LADEN fled Afghanistan to
IRAN in November 2001. AKRAM said that at the time, BIN LADEN had offers of
sanctuary from iraq and from Iran. AKRAM claimed that IRAN distributed money to AL
QAEDA for distribution to terrorist soldiers and that he himself had received the equivalent
of $1400.

244. The close relationship between OSAMA BIN LADEN and certain
of the highest members of the Saudi Royal family stretches back for a long
period of time and continues to this day.

245. OSAMA BIN LADEN met with Defendant SULTAN BIN
ABDULAZIZ AL SAUD (or "PRINCE SULTAN") after iraq invaded
Kuwait in August 1990. PRINCE SULTAN is the Second Deputy Prime
Minister, Minister of Defense and Aviation, Inspector General, and Chairman
of the Board of Saudi Arabian Airlines, which does business in the United
States and internationally. In the meeting, OSAMA BIN LADEN offered the
engineering equipment available from his family's construction company and
suggested bolstering Saudi forces with Saudi militants who Bin Laden was
willing to recruit.

246. This offer was also made to Defendant TURKI AL FAISAL AL
SAUD (or "PRINCE TURKI"), the then Chief of Saudi Intelligence, or
Istakhbarat. PRINCE TURKI had an ongoing relationship with OSAMA BIN
LADEN from the time that they first met in Islamabad, Pakistan at the Saudi
embassy, during the Soviet Union's occupation of Afghanistan.

247. Defendant MOHAMMED AL FAISAL AL SAUD (or "PRINCE
MOHAMMED" or PRINCE MOHAMMED AL FAISAL") is involved in the
financing, aiding and abetting and material support of OSAMA BIN LADEN,
AL QAEDA, and international terrorism in part through FAISAL ISLAMIC
BANK and AL SHAMAL ISLAMIC BANK in the Sudan. PRINCE
ABDULLAH AL FAISAL BIN ABDULAZIZ AL SAUD (or "PRINCE
ABDULLAH" or "PRINCE ABDULLAH AL FAISAL") and PRINCE NAIF
BIN ABDULAZIZ AL SAUD (or "PRINCE NAIF") are also engaged in the
aiding and abetting or material sponsorship of OSAMA BIN LADEN, AL
QAEDA, and international terrorism as described herein. SALMAN BIN
ABDUL AZIZ AL SAUD (or "PRINCE SALMAN") has also provided
material support to Osama bin Laden, and AL QAEDA.

248. PRINCE TURKI was head of Saudi Arabia's Department of
General Intelligence (Istakhbarat) from 1977 until 2001. As such, he was in a
position to know the threat posed by BIN LADEN, AL QAEDA, the
TALIBAN, and the extremist and violent perversion of jihad and hatred that the
Saudi religious schools were encouraging in young students. PRINCE TURKI
abruptly left his position in or around August 30, 2001, when he was dismissed
as chief of Saudi Intelligence just prior to the September 11, 2001 attacks.

249. PRINCE TURKI met personally with OSAMA BIN LADEN at
least five times while in Pakistan and Afghanistan during the mid-eighties to
mid-nineties. PRINCE TURKI also had meetings with the TALIBAN in 1998
and 1999. In 1995, while the Saudi Istakhbarat was headed by PRINCE
TURKI, he decided to give massive financial and material support to the
TALIBAN.

250. Defendants TURKI AL FAISAL AL SAUD and MOHAMMED
AL FAISAL AL SAUD had close financial ties with AL QAEDA financier
ZOUAYDI.

251. MULLAH KAKSHAR is a senior TALIBAN official who
defected and provided a sworn statement regarding the transfer of funds from
wealthy Saudis directly to AL QAEDA and OSAMA BIN LADEN in
Afghanistan. MULLAH KAKSHAR's sworn statement implicates PRINCE
TURKI as the facilitator of these money transfers in support of the TALIBAN,
AL QAEDA, and international terrorism.

252. In 1996, according to various intelligence sources, a group of
Saudi princes and prominent Saudi business leaders met in Paris and agreed to
continue contributing, sponsoring, aiding and abetting OSAMA BIN LADEN's
terrorist network.

253. In July of 1998, a meeting occurred in Kandahar, Afghanistan that
led to an
agreement between certain Saudis and the TALIBAN. The participants were
PRINCE TURKI, the TALIBAN leaders, as well as senior Pakistani
intelligence officers of the ISI and representatives of OSAMA BIN LADEN.
The agreement reached stipulated that OSAMA BIN LADEN and his followers
would not use the infrastructure in Afghanistan to subvert the royal families'
control of Saudi government and in return, the Saudis would make sure that no
demands would be acceded to for the extradition of terrorist individuals, such
as OSAMA BIN LADEN, nor permit the closure of terrorist facilities and
camps. PRINCE TURKI also promised to provide oil and generous financial
assistance to both the TALIBAN in Afghanistan and to Pakistan. After the
meeting, 400 new pick-up trucks arrived in Kandahar for the TALIBAN, still
bearing Dubai license plates.

254. PRINCE TURKI was instrumental in arranging a meeting in
Kandahar between Iraqi senior intelligence operative, the Ambassador to
Turkey FARUQ AL-HIJAZI, and OSAMA BIN LADEN, in December of 1998.

255. Istakhbarat served as a facilitator of OSAMA BIN LADEN's
network of charities, foundations, and other funding sources. PRINCE TURKI
has recently been named as an ambassador from Saudi Arabia to the United
Kingdom.