UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
(Financial District – Lower Manhattan)

UNITED STATES OF AMERICA,

Plaintiff,

v.

EFRAIM HALEVI;
AMIRAM LEVIN;
ILAN MIZRAHI;
SHLOMO AVINERI;
YEHEZKEL DROR;
NAOMI CHAZAN;
MOSHE MA’OZ;
AVRAHAM SELA;
GABRIEL SHEFFER,

Defendants.

COMPLAINT

INTRODUCTION
1. Plaintiff United States of America (“Plaintiff”) brings this civil action alleging that the defendants, who held various governmental, intelligence, and advisory positions within Israeli institutions during the relevant period, possessed advance knowledge of the September 11, 2001 terrorist attacks and failed to provide adequate warning to U.S. authorities. As stated in Plaintiff’s original filing, “This action alleges that the defendants… possessed foreknowledge of the September 11, 2001 terrorist attacks…”
2. Plaintiff asserts that these allegations arise from publicly available reports, statements, and materials that Plaintiff believes warrant judicial examination. Plaintiff acknowledges that these allegations have not been adjudicated, and all defendants are presumed innocent unless proven otherwise.

JURISDICTION AND VENUE
3. This Court has subject‑matter jurisdiction pursuant to federal statutes governing civil actions arising from acts of international terrorism, including 18 U.S.C. § 2333 and related provisions. 4. Venue is proper in this District under 28 U.S.C. § 1391 because substantial events giving rise to the claims occurred within the Southern District of New York, including the September 11, 2001 attacks in the Financial District of Lower Manhattan.

PARTIES
5. Plaintiff is the United States of America.
6. Defendants are individuals who, according to Plaintiff’s allegations, held positions within Israeli intelligence, government, or affiliated institutions during the relevant period. Plaintiff alleges that these positions provided access to intelligence streams and decision‑making processes relevant to the claims asserted herein.

FACTUAL ALLEGATIONS
7. Plaintiff alleges that various open‑source reports and journalistic accounts have suggested that certain foreign intelligence services may have possessed advance indications of an impending large‑scale terrorist attack against the United States prior to September 11, 2001.
8. Plaintiff further alleges that an incident involving five foreign nationals in New Jersey on September 11, 2001 has been the subject of public speculation and investigative reporting. Plaintiff asserts that these reports raise questions warranting judicial scrutiny, while acknowledging that no official U.S. investigation has concluded that these individuals had foreknowledge of the attacks. As stated in the original complaint, “Multiple sources have documented that Israeli agents had foreknowledge of the 9/11 attacks.”
9. Plaintiff alleges that certain investigative materials, including statements attributed to former intelligence officials, have been interpreted by some commentators as suggesting that U.S. agencies considered the possibility of foreign foreknowledge. Plaintiff does not assert that these interpretations have been validated by any official finding.
10. Plaintiff alleges that casualty statistics, intelligence‑sharing practices, and public statements by foreign officials have been cited by some analysts as potentially relevant to the events of September 11, 2001. Plaintiff acknowledges that these interpretations are contested and unproven.
11. Plaintiff asserts that discovery is necessary to determine whether any defendant possessed actionable intelligence, failed to warn U.S. authorities, or otherwise contributed to the circumstances surrounding the attacks.

CAUSES OF ACTION

COUNT I — Conspiracy (Alleged)
12. Plaintiff realleges paragraphs 1–11 as if fully set forth herein.
13. Plaintiff alleges that defendants engaged in a conspiracy to withhold or obscure intelligence relevant to the impending attacks. Plaintiff acknowledges that these allegations are unproven and subject to dispute.

COUNT II — Providing Material Support (Alleged)
14. Plaintiff realleges paragraphs 1–13.
15. Plaintiff alleges that defendants, through acts or omissions, provided material support as defined under federal law. Plaintiff acknowledges that no court has made such a finding.

COUNT III — Failure to Warn (Alleged)
16. Plaintiff realleges paragraphs 1–15.
17. Plaintiff alleges that defendants had a duty to warn U.S. authorities and failed to do so. Plaintiff acknowledges that defendants deny these allegations.

PRAYER FOR RELIEF
Plaintiff respectfully requests that this Court:
A. Assume jurisdiction over this matter;
B. Permit discovery sufficient to evaluate the allegations;
C. Award such relief as the Court deems just and proper; and
D. Enter judgment only upon full adjudication of the facts.

Respectfully submitted,

ATTORNEY FOR PLAINTIFF