Jackson v. Islamic Republic of Iran

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA SAMMY LEE JACKSON, et al., Plaintiffs, Civil Action No. 24-2304 (BAH) v. Judge Beryl A. Howell ISLAMIC REPUBLIC OF IRAN, Defendant. MEMORANDUM OPINION This action, brought by seventy-six plaintiffs against defendant, the Islamic Republic of Iran (“Iran”), arises out of the June 25, 1996, bombing, executed by Saudi Hezbollah, of the Khobar Towers apartment complex in Dhahran, Saudi Arabia, which housed United States military personnel. See Compl. ¶¶ 1-2, 98, ECF No. 1. The bombing killed nineteen U.S. Air Force personnel and injured hundreds more, including the twenty-four injured servicemember plaintiffs in this case. See id. ¶¶ 1-2; see also id. ¶¶ 8-77. The plaintiffs in this case also include fifty-two immediate family members of seventeen of the twenty-four injured servicemember plaintiffs. See id. ¶¶ 8-83. Based on allegations that “Iran and its agents” provided material support and resources to “the Saudi Hezbollah,” the “terrorist organization that carried out the bombing,” thereby enabling the attack, Iran is named as the sole defendant. See, e.g., id. ¶¶ 88-96; see also id. ¶¶ 92-94 (noting that Iran has repeatedly been found liable for the Khobar Towers attack based on the same factual allegations about its provision of material support and resources). Plaintiffs seek damages for their injuries suffered as a result of the attack pursuant to the terrorism exception to the Foreign Sovereign Immunities Act’s (“FSIA”) general conferral of immunity on foreign sovereigns, 28 U.S.C. § 1605A, and have complied with the FSIA’s requirements for effectuating 1 service on the sovereign defendant, see 28 U.S.C. § 1608(a)(4). Iran has failed to enter an appearance or otherwise defend against this action. See Return of Service, ECF No. 22; Clerk’s Entry of Default, ECF No. 24. Plaintiffs now seek the entry of default judgment against Iran as to liability and damages. See Pls.’ Mot. for Default J. (“Pls.’ Mot.”), ECF No. 29. For the reasons detailed below, plaintiffs’ motion is granted in part and denied in part. I. BACKGROUND Prior decisions of this Court have found Iran liable for the Khobar Towers bombing. See, e.g., Blais v. Islamic Republic of Iran, 459 F. Supp. 2d 40 (D.D.C. 2006) (Lamberth, J.); Est. of Heiser v. Islamic Republic of Iran (“Heiser I”), 466 F. Supp. 2d 229 (D.D.C. 2006) (Lamberth, J.); Rimkus v. Islamic Republic of Iran (“Rimkus II”), 750 F. Supp. 2d 163 (D.D.C. 2010) (Lamberth, C.J.); Akins v. Islamic Republic of Iran, 332 F. Supp. 3d 1 (D.D.C. 2018) (Howell, C.J.); Schooley v. Islamic Republic of Iran, No. 17-cv-1376 (BAH), 2019 WL 2717888 (D.D.C. June 27, 2019) (Howell, C.J.); Aceto v. Islamic Republic of Iran, No. 19-cv-464 (BAH), 2020 WL 619925 (D.D.C. Feb. 7, 2020) (Howell, C.J.); Christie v. Islamic Republic of Iran, No. 19-cv-1289 (BAH), 2020 WL 3606273 (D.D.C. July 2, 2020) (Howell, C.J.); Blank v. Islamic Republic of Iran, No. 19-cv-3645 (BAH), 2021 WL 3021450 (D.D.C. July 17, 2021) (Howell, C.J.); Ackley v. Islamic Republic of Iran, No. 20-cv-621 (BAH), 2022 WL 3354720 (D.D.C. Aug. 12, 2022) (Howell, C.J.); Mustard v. Islamic Republic of Iran, No. 21-cv-163 (BAH), 2023 WL 1778193 (D.D.C. Feb. 6, 2023) (Howell, C.J.); Gration v. Islamic Republic of Iran, No. 21-cv-1859 (BAH), 2023 WL 5221955 (D.D.C. Aug. 15, 2023) (Howell, J.); Thole v. Islamic Republic of Iran, No. 23-cv-793 (BAH), 2024 WL 2208208 (D.D.C. May 16, 2024) (Howell, J.); Est. of Johnson v. Islamic Republic of Iran, No. 23-cv-1689 (BAH), 2024 WL 3225954 (D.D.C. June 28, 2024) 2 (Howell, J.); Breezee v. Islamic Republic of Iran, No. 23-cv-3392 (BAH), 2025 WL 2719250 (D.D.C. Sept. 24, 2025) (Howell, J.); St. John v. Islamic Republic of Iran, No. 23-cv-2333 (BAH), 2026 WL 1532818 (D.D.C. Apr. 6, 2026) (Howell, J.); Dobbins v. Islamic Republic of Iran, No. 24-cv-3271 (BAH), 2026 WL 1943314 (D.D.C. July 6, 2026) (Howell, J.). In Blais and Heiser I, the Court heard evidence and witness testimony about the connection between Iran and the attack on the Khobar Towers. See Blais, 459 F. Supp. 2d at 46 n.4, 48-49; Heiser I, 466 F. Supp. 2d at 249-50. In Heiser I alone, the plaintiffs’ examination of witnesses, including seven expert witnesses, and presentation of other evidence took seventeen days. See 466 F. Supp. 2d at 250. 1 Other cases, including Rimkus, Akins, and Schooley, have concluded that judicial notice of the findings of fact in Blais and Heiser I was appropriate, see Rimkus II, 750 F. Supp. 2d at 173; Akins, 332 F. Supp. 3d at 10-11; Schooley, 2019 WL 2717888, at *2, and plaintiffs here request that this Court “take judicial notice of the evidence in Blais and Heiser I that . . . demonstrates that Iran provided ‘material support and resources’ for the act of extrajudicial killing that constituted the Khobar Towers Attack,” Pls.’ Mem. in Supp. of Mot. for Def. J. (“Pls.’ Mem.”) at 13, ECF No. 29. Rule 201 of the Federal Rules of Evidence authorizes a court to “judicially notice” adjudicative facts that are “not subject to reasonable dispute because” they “can be accurately and readily determined from sources whose accuracy cannot reasonably be questioned.” FED. R. 1 The expert witnesses in Heiser I were: (1) Louis Freeh, the former director of the Federal Bureau of Investigation (“FBI”); (2) Dr. Patrick Clawson, a scholar of Middle Eastern politics who has frequently provided expert testimony regarding Iran’s involvement in sponsoring terrorism; (3) Dr. Bruce Tefft, a founding member of the CIA’s Counterterrorism Bureau and regular consultant on issues of terrorism; (4) Dale Watson, the former deputy counterterrorism chief of the FBI, see Heiser I, 466 F. Supp. 2d at 260-65, 263 n.18; (5) Dr. Thomas Parsons, a medical examiner, see id. at 268; (6) Dr. Dana Cable, a licensed psychologist and expert on the grief process, see id. at 269- 70; and (7) Dr. Herman Miller, an economic consultant, see id. at 273-74. 3 EVID. 201(b). 2 In this District, Rule 201 has been applied frequently to take judicial notice of factual evidence developed in other FSIA proceedings “involving the same conduct by the same defendants,” Akins, 332 F. Supp. 3d at 11, “even when those proceedings have taken place in front of a different judge,” Foley v. Syrian Arab Republic, 249 F. Supp. 3d 186, 191 (D.D.C. 2017) (citing Brewer v. Islamic Republic of Iran, 664 F. Supp. 2d 43, 54 (D.D.C. 2009)). Using judicial notice in this way avoids “the formality of having that evidence reproduced” in each new case. Taylor v. Islamic Republic of Iran, 811 F. Supp. 2d 1, 7 (D.D.C. 2011) (quoting Rimkus II, 750 F. Supp. 2d at 172)); see also Oveissi v. Islamic Republic of Iran, 879 F. Supp. 2d 44, 50 (D.D.C. 2012) (finding that courts are permitted “in subsequent related cases to rely upon the evidence presented in earlier litigation” (internal quotation marks and citation omitted)); Est. of Botvin v. Islamic Republic of Iran, 873 F. Supp. 2d 232, 237 (D.D.C. 2012) (taking “judicial notice of the evidence presented in the earlier cases”). Importantly, taking judicial notice of prior findings “does not conclusively establish the facts found” as to the instant case. Foley, 249 F. Supp. 3d at 191. Instead, “based on judicial notice of the evidence presented in the earlier cases[,] . . . courts may reach their own independent findings of fact.” Anderson v. Islamic Republic of Iran, 753 F. Supp. 2d 68, 75 (D.D.C. 2010); see also Rimkus II, 750 F. Supp. 2d at 172 (“[C]ourts in FSIA litigation have adopted a middle-ground approach that permits courts in subsequent related cases to rely upon the evidence presented in earlier litigation—without necessitating the formality of having that evidence reproduced—to reach their own, independent findings of fact in the cases before them.”). The D.C. Circuit has 2 “[A]djudicative facts are simply the facts of the particular case.” Nat’l Org. for Women v. Soc. Sec. Admin., 736 F.2d 727, 737 n.95 (D.C. Cir. 1984) (Robinson, J., concurring) (per curiam) (quoting FED. R. EVID. 201, Advisory Committee Note). The Rule does not govern judicial notice of “legislative fact[s],” FED. R. EVID. 201(a), which are “those which have relevance to legal reasoning and the lawmaking process, whether in the formulation of a legal principle or ruling by a judge or court or in the enactment of a legislative body,” Nat’l Org. for Women, 736 F.2d at 737 n.95 (quoting FED. R. EVID. 201, Advisory Committee Note). 4 endorsed the use of judicial notice to establish facts in FSIA terrorism cases. See Han Kim v. Democratic People’s Republic of Korea, 774 F.3d 1044, 1049, 1051 (D.C. Cir. 2014) (holding that plaintiffs had “met their burden of producing evidence ‘satisfactory to the court’” to establish subject matter jurisdiction under the FSIA, where the only evidence linking North Korea to the victim’s disappearance was a South Korean court’s conviction of a North Korean agent, of which the district court had taken judicial notice). Persuaded that this approach is both “efficient and sufficiently protective of the absent defendant[’s] interests,” Akins, 332 F. Supp. 3d at 11, plaintiffs’ request to take judicial notice of the evidence presented in Blais and Heiser I is granted, see Pls.’ Mem. at 9-10 (citing this Court’s prior decisions taking judicial notice in Akins and Breezee to support the instant request); see also Akins, 332 F. Supp. 3d at 11 (“[F]actual evidence developed in other cases involving the same conduct by the same defendants is admissible and may be relied upon in this case.”). The evidence regarding the Khobar Towers bombing is summarized below, followed by an overview of the procedural history of this case. A. The Attack on Khobar Towers “The Khobar Towers was a residential complex in Dhahran, Saudi Arabia, which housed the coalition forces charged with monitoring compliance with [United Nations] security council resolutions.” Blais, 459 F. Supp. 2d at 47. Shortly before 10:00 p.m. on June 25, 1996, “a large gasoline tanker truck” drove up to the Khobar Towers complex and parked “alongside the perimeter wall.” Heiser I, 466 F. Supp. 2d at 252; see also Compl. ¶ 89. After parking, the driver of the truck “jumped out, ran into a waiting car that had pulled up near the truck, and sped off.” Heiser I, 466 F. Supp. 2d at 252; see also Compl. ¶ 89. Although security guards stationed near the top of one of the towers, Building 131, “started to give warnings about the unusual vehicle 5 location,” the truck exploded “within about 15 minutes” and the blast “sheared off the face of Building 131.” Heiser I, 466 F. Supp. 2d at 252. Investigations of the attack “determined that the force of the explosion was the equivalent of 20,000 pounds of TNT,” which the U.S. Department of Defense described as “the largest non-nuclear explosion ever up to that time.” Id.; see also Compl. ¶ 90. B. Defendants’ Role in the Attack The U.S. Department of State has designated Iran as a state sponsor of terrorism since January 19, 1984. Blais, 459 F. Supp. 2d at 47; see also, e.g., Fritz v. Islamic Republic of Iran, 320 F. Supp. 3d 48, 77 (D.D.C. 2018); U.S. Dep’t of State, State Sponsors of Terrorism, https://www.state.gov/state-sponsors-of-terrorism [https://perma.cc/VF4X-JQU4] (last visited Sept. 4, 2026). Prior proceedings have found that Iran planned and supported the Khobar Towers bombing. Both Ayatollah Ali Khamenei, the supreme leader of Iran at the time of the attack, and the Iranian Minister of Intelligence and Security at the time, Ali Fallahian, “approved” the attack. Heiser I, 466 F. Supp. 2d at 252. The truck bomb used in the attack was “assembled” at a base in Lebanon’s Bekaa Valley, which base was “jointly operated by the IRGC [(Islamic Revolutionary Guard Corps)] and by the terrorist organization known as Hezbollah.” Id. The individuals who carried out the bombing drove the bomb from this base to Dhahran and called themselves “Saudi Hezbollah.” Id. These factual findings are based in part on testimony provided by four key expert witnesses in Blais and Heiser I, including Louis Freeh, who served as the director of the FBI at the time of the bombing, and Dale Watson, who served as the deputy counterterrorism chief of the FBI at the same time. The testimony of both Freeh and Watson in Heiser I was based on their oversight of 6 the FBI’s “massive and thorough investigation of the attack,” which investigation involved “over 250 agents.” Id.; see also id. at 260-62 (describing the testimony of Freeh and Watson and the basis for each expert’s knowledge of the incident). 3 Based on information gathered in their investigations, both Freeh and Watson testified to their conclusions that “Iran . . . w[as] responsible for the Khobar Towers bombing carried out by Saudi Hezbollah.” Id. at 264; see also Blais, 459 F. Supp. 2d at 48. Additional expert testimony was provided in Heiser I by Dr. Patrick Clawson, who based his opinions on “his involvement on a Commission investigating the bombing, his top-secret security clearance, his discussions with Saudi officials,” and “his academic research on the subject.” 466 F. Supp. 2d at 262. According to Clawson, “the government of Iran . . . w[as] responsible for the Khobar Towers bombing, and . . . Saudi Hezbollah carried out the attack under their direction.” Id. at 253. This opinion was also supported by Dr. Bruce Tefft, a former founding member of the CIA’s counterterrorism bureau, who testified, based on “publicly available sources that were not inconsistent with classified information known to him from his time at the CIA and from his security clearances since that time,” that there was “no question” that Iran was “responsible for planning and supporting the attack on the Khobar Towers” and specifically that the attack “wouldn’t have happened without Iranian support.” Id. at 254. C. The Instant Plaintiffs The seventy-six plaintiffs in this lawsuit include twenty-four servicemembers who allegedly suffered physical and emotional injuries as a result of the Khobar Towers bombing and 3 During this investigation, the FBI interviewed six members of Saudi Hezbollah, each of whom admitted “their complicity in the attack on Khobar Towers, and admitted that senior officials in the Iranian government provided them with funding, planning, training, sponsorship, and travel necessary to carry out the attack on the Khobar Towers.” Heiser I, 466 F. Supp. 2d at 253. This investigation ultimately resulted in an indictment, returned by a grand jury in Alexandria, Virginia, “against 13 identified members of the pro-Iran Saudi Hezbollah organization.” Id. at 252. 7 fifty-two of their immediate family members. See Compl. ¶ 2; Pls.’ Mem. at 6. Information provided in sworn declarations submitted by each of the servicemember plaintiffs and associated family members, or their purported representatives, is summarized below. 1. Servicemember Sammy Lee Jackson Jr. and Six Family Members On June 25, 1996, Sammy Lee Jackson Jr., was serving as a Staff Sergeant in the U.S. Air Force, deployed to Dhahran, Saudi Arabia, and quartered at the Khobar Towers. Decl. of Sammy Lee Jackson Jr. (“Jackson Decl.”) ¶ 4, ECF No. 29-3 at 1. At the time of the bombing, Jackson was inside the chapel, where he had been participating in a nighttime Bible study that was just ending when the explosion occurred. Id. ¶ 8. The blast’s force “threw [him] across the room on the ground,” and his “ears began to ring immediately.” Id. The explosion also sent glass and debris flying into the chapel, causing “lacerations along [his] arms from glass and material being blown in from the explosion,” as well as “severe bruising from being thrown across the room.” Id. He “worked to help calm people down and get them out of the building,” before “ma[king] [his] way toward [his] dorm,” where he “tr[ied] to stop [his teammate] from bleeding out.” Id. ¶ 9. “There was death and injury and agony all around” him. Id. ¶ 10. The attack caused both “physical[]” and “emotional” injuries. Id. ¶¶ 13-14. In addition to the lacerations and bruising caused by the blast, the bombing left Jackson with “permanent hearing loss and tinnitus,” as well as “breathing problems.” Id. ¶ 13. Emotionally, the attack caused “feelings of isolation, difficulty with loud noises, survivor’s guilt, depression, post-traumatic stress disorder (PTSD), and issues with sleeping,” among other symptoms. Id. ¶ 14. He “went inward” and “stopped being the outgoing, fun-loving guy [he] used to be”; the version of himself that “just kind of disappeared” and whom he is “still trying to find.” Id. ¶ 15. He could no longer attend concerts or “large churches.” Id. He “had a really difficult time sleeping,” felt “irrationally afraid 8 that [a] car pulling up would blow up the house,” and has “problems with nightmares.” Id. ¶¶ 16, 21. Jackson also experienced “emotional detachment,” causing him to struggle to “express [him]self to” his children and to become “estranged” from his then-wife, Anita Cason Lewis, from whom he “eventually divorced.” Id. ¶ 20. Jackson received a disability rating of 80% from the U.S. Department of Veterans Affairs. Id. ¶ 23. Six of Jackson’s family members—his ex-wife, Anita Cason Lewis; mother, Minnie Lee Jackson; children, Samuel Aaron Jackson and Sierra Alexandria Jackson; and siblings, Rosalyn Shantell Jackson and Latricia Renell Small, who is deceased—are also plaintiffs in this case. See Compl. ¶¶ 8-14. Jackson’s ex-wife, Anita Cason Lewis, learned of the Khobar Towers attack while watching CNN. Decl. of Anita Cason Lewis (“Lewis Decl.”) ¶ 10, ECF No. 29-3 at 8. When she saw the news, she began “screaming, crying, and running around the room.” Id. ¶ 11. Lewis later learned that Jackson was alive but injured, and she felt “anxious and worried about how badly he was hurt” as she waited “over a week” for him to come home. Id. ¶¶ 12-13. She “couldn’t sleep, could barely eat for the worry, and . . . hardly even interacted with [her] children.” Id. ¶ 13. After Jackson returned, Lewis “could tell immediately that he was different.” Id. ¶ 14. Before the attack, Jackson’s “personality . . . was big in the best way possible”; he was “very funny and kindhearted,” and Lewis and Jackson “laughed together constantly” and had a marriage that was “precious to [Lewis].” Id. ¶¶ 7-8. Lewis and Jackson had two children together, and Jackson “loved the children and they loved him.” Id. ¶ 9. When Jackson returned, however, he “did not even want to touch” their daughter, Sierra, and when their son, Aaron, “ran up to hug him,” Jackson “just kind of stood there and patted Aaron on the head.” Id. ¶ 14. During Jackson’s nightmares, Lewis was 9 “hit, kicked, and punched hard,” at times leaving “bruises.” Id. ¶ 15. He became “snappy and irritable,” and he started to “push[] [Lewis] away.” Id. ¶ 16. This behavior culminated in an incident when Jackson “began to brutally sodomize” Lewis, during which assault she “lost consciousness,” and after which her parents eventually found her “alone, under a blanket and in a pool of [her] own blood” from internal injuries that required surgery. Id. ¶ 19. Lewis and Jackson divorced in 2001, which Lewis describes as “one of the biggest losses of [her] life.” Id. ¶¶ 22-23. Jackson’s mother, Minnie Lee Jackson, learned of the attack when she received a telephone call from her daughter-in-law, Lewis, informing her that her son “had been in a terrorist bombing.” Decl. of Minnie Lee Jackson (“M. Jackson Decl.”) ¶ 9, ECF No. 29-3 at 14. She immediately turned on the television and recognized that the bombing had struck Jackson’s dormitory but for two days did not know whether he was “injured, dead, or alive.” Id. ¶¶ 9-10. During that period, she “could not eat or sleep,” suffered “horrible migraine headaches,” and worried that Sammy would return home traumatized. Id. ¶¶ 9-10. Before the attack, Minnie and Jackson “were like two peas in a pod” and spoke regularly. Id. ¶¶ 6-8. When Jackson finally returned, however, she “immediately” recognized that “[her] son came home a different person.” Id. ¶ 12. Once “joyful,” “confiden[t],” and “full of energy,” he became “reserved,” “hypervigilant,” and reluctant to discuss the bombing, leaving Minnie feeling that she had “lost the joyful and open version of [Jackson] from before the attack.” Id. ¶¶ 12-13. Minnie experienced chronic anxiety, paranoia, and stress, with physical effects including hypertension and Type 2 diabetes that developed after stress-related changes in her eating habits and health. Id. ¶¶ 11, 14-15. Witnessing Jackson’s continuing struggles has remained “extremely depressing and stressful” for her, and although she will always love her son, she “will forever miss the person [he] used to be.” Id. ¶ 16. 10  Jackson’s son, Samuel Aaron Jackson, was nearly six years old and staying at his grandparents’ house when he learned of the attack. Decl. of Samuel Aaron Jackson (“S.A. Jackson Decl.”) ¶¶ 4, 7, ECF No. 29-3 at 17-18. He remembers “a commotion about something on the news,” his mother “breaking down,” and being “scared and confused” as his grandmother trying to distract him from the television and the adults’ conversations. Id. ¶ 7. His grandfather and uncle later explained that his father had been injured but would survive, while many people from the base “were not going to come home.” Id. ¶ 8. Before the attack, Samuel was “a happy kid in a happy home,” and viewed his father as “a superhero,” who taught him to play drums, took him to church, brought him onto the Air Force base, and helped him with schoolwork. Id. ¶¶ 5-6. After the attack, however, his father seemed “kind of lost,” became “withdrawn,” “hypervigilant,” “distant,” and “didn’t want to go places with [Samuel] like he used to.” Id. ¶¶ 9-11. Samuel often heard his parents “argue,” “fight,” “scream,” and “cry,” and “[s]eeing and hearing his parents fight so badly all the time . . . scared [him] and made [him] feel deeply insecure.” Id. ¶¶ 2-13. “[T]hings only got worse” after they divorced because Samuel’s mom “was so hurt and angry from everything after the attack” and “[s]he could be both physically and verbally abusive.” Id. ¶ 14. Samuel developed “night terrors” and “emotional eating,” became “domineering in [his] friendships,” was “always distracted,” and “started acting out,” although he eventually sought therapy, which helped with these difficulties. Id. ¶¶ 13, 15, 17-18. He believes that, absent the bombing, his “parents would have [n]ever divorced,” and he “would have been a lot happier and emotionally healthier.” Id. ¶ 19. Jackson’s daughter, Sierra Alexandria Jackson, was only two months old at the time of the bombing and therefore has no memory of the bombing itself. Decl. of Sierra Alexandria Jackson (“Sierra Jackson Decl.”) ¶¶ 2-4, ECF No. 29-3 at 22. She grew up hearing that, before the attack, 11 Jackson had been “a very loving and attentive father,” who was “extremely family-oriented, fun- loving, outgoing, and caring,” but the father she knew was “distant, reserved, angry, mean, and stern.” Id. ¶¶ 5-6. She explained that she “[e]ffectively . . . grew up without a father” because she “was afraid of him,” he was “verbally abusive” with her, and she “did not want a relationship with him.” Id. ¶¶ 6-7. Sierra also witnessed her father “being physically abusive toward [her] mom” and later her older brother, which “made [her] even more afraid of [her] dad” and left her family “broken and dysfunctional.” Id. ¶¶ 8-9. Her parents divorced when she was “four or five years old” as a result of the “changes in [her] father due to the attack.” Id. ¶ 7. After the divorce, “it was like [Jackson] was a complete stranger,” and she “hated” visiting him because he remained “mean and scary and unpredictable.” Id. ¶ 10. Sierra developed anxiety, including “horrible social anxiety,” that persists today, as she “struggle[s] to make friends” and “became a big people- pleaser.” Id. ¶ 17. She believes the attack created a “domino effect” that traumatized her entire family, leaving her to grow up “without a dad present in [her] life” and with “an angry and broken mom.” Id. ¶¶ 18-19. Ultimately, she attests that her life would have been “so much better, so much more whole,” had the attack never occurred. Id. Jackson’s sister, Rosalyn Shantell Jackson, learned of the attack on her brother’s housing complex when she was fourteen years old and Jackson’s wife called their home to report the bombing. Decl. of Rosalyn Shantell Jackson (“R. Jackson Decl.”) ¶¶ 4, 9, ECF No. 29-3 at 27-28. Rosalyn recalled her mother “holding [Rosalyn] in her arms and screaming and crying,” repeatedly saying, “I need to talk to my child.” Id. ¶ 9. Rosalyn feared her brother had “been mangled or lost his legs.” Id. ¶ 10. When Jackson finally returned home, Rosalyn was relieved he was alive but immediately recognized that he had changed “physically and emotionally,” becoming “reserved” and no longer the “happy-go-lucky version” of her brother. Id. ¶¶ 11-13. Before the attack, 12 Rosalyn viewed Jackson as “like Superman.” Id. ¶ 5. He was “protective” of her, she “looked up to and admired him,” and they stayed in contact regularly while he was deployed. Id. ¶¶ 5-6. After the attack, they “did not speak as frequently,” and she “fe[lt] the need to be careful with [her] words so that [she] d[id] not say something that might trigger painful memories.” Id. ¶ 13. Rosalyn “became extremely sensitive to anything related to war and anxious in response to news, conversations, or content related to war,” as evidenced by her panic attack while watching a movie about combat. Id. ¶ 15. Even today, she thinks about the attack “at least once a month,” checks on Jackson every Fourth of July during the fireworks, and remains “filled with sorrow” for what her brother endured and for the “loss of the father-figure [she] once had in him.” Id. ¶¶ 15-17. Jackson’s sister, Latricia Renell Small, passed away in 2023 and her husband, Michael Small, seeks to represent her estate. Decl. of Michael Small as Representative of Latricia Renell Small (“Small Decl.”) ¶¶ 2, 4-5, ECF No. 29-3 at 32. This representative’s declaration attests that: When Latricia learned of the attack, she was “visibly disturbed” and “very distress[ed]” because she did not know whether her brother was alive or dead. Id. ¶ 10. Before the attack, Latricia and Jackson had a “very strong bond,” since they were “only one year” apart in age. Id. ¶ 8. “[S]he looked up to him,” they “kept in contact” “[e]ven when [Jackson] was far away from home,” and he remained “an extremely important person in her life.” Id. ¶ 8. After the bombing, Latricia was “overwhelmed with emotion” and “would sporadically . . . reflect on the past and her memories with [Jackson].” Id. ¶ 11. When Jackson returned home, Latricia “felt that [he] became distant from her and [her] children,” and she believed she would “never [be] able to regain the closeness that she once had with [him].” Id. ¶ 12. Latricia developed “deep sadness and anxiety,” “withdr[ew] into herself,” and “even distanced herself from [her husband] because [he] reminded her of [Jackson].” Id. ¶ 13. Within a year of the bombing, Latricia “became pregnant with twins 13 but lost one of the twins during pregnancy,” which her husband believed was “contributed to” by the stress she experienced following the attack. Id. ¶ 14. She “became very overprotective” of her children, which her husband believes “permanently damaged them as men.” Id. ¶ 15. Latricia lived with “the profound and lasting effects of the Khobar Towers bombing” until her death. Id. ¶¶ 5, 16. 2. Servicemember Russell Davin Barile and One Family Member On June 25, 1996, Russell Davin Barile was serving as a Captain Pilot and Chief of Current Operations for the U.S. Air Force in Dhahran, Saudi Arabia. Decl. of Russell Davin Barile (“Barile First Decl.”) ¶¶ 2, 4, ECF No. 29-4 at 1. At the time of the bombing, he was at the gym, when “[t]he doors of the gym were blown off completely and the mirrors broke off the walls,” and the explosion was “so strikingly loud” that he initially believed it was an airplane crash. Id. ¶ 9. His ears were ringing—“something that, unfortunately, never went away”—and after escaping the gym, he “saw many wounded service members coming from the dormitory buildings.” Id. He spent the night evacuating injured personnel, “ignoring [his own] physical injuries, and not yet processing the emotional ones.” Id. During the rescue effort, he discovered the “lifeless body” of his friend and “watched several pararescuemen attempt to resuscitate the motionless corpse of another crewman,” who was also a “close friend[].” Id. ¶ 10. These experiences left him overwhelmed with “shock,” “deep sadness,” and “rage towards the terrorists.” Id. The following morning, he returned to retrieve his belongings and found that the building “reeked of rot from human remains and spoiled food,” a smell he describes as “sickening and traumatic.” Id. ¶ 11. Following the attack, Barile suffered “permanent partial hearing loss,” chronic tinnitus, and asthma caused by inhaling blast debris, requiring daily inhaler use. Id. ¶ 14. He also developed survivor’s guilt, repeatedly thinking that “if I had still been in my room, I would be dead,” which 14 “continues to haunt [him].” Id. ¶ 15. He experiences “flashbacks,” triggered by odors such as garbage, diesel fuel, and fertilizer, as well as nightmares, chronic insomnia, hypervigilance, paranoia, and memories of his friends’ bodies. Id. ¶¶ 16, 19-20. He is no longer “able to enjoy [his] hobbies,” like running, weightlifting, and surfing, “hardly engage[s] in any social events,” “started drinking heavily,” has a “difficult time focusing,” and found himself “lost in dark thoughts and memories of the attack.” Id. ¶¶ 17-18. Barile received a 60% disability rating from the U.S. Department of Veterans Affairs. Id. ¶ 14. Barile’s mother, Margaret Barile, who passed away in 2012, is also a named plaintiff in this lawsuit, and Barile seeks to serve as the representative of her estate. Decl. of Russell Davin Barile as Representative of Margaret Barile (“Barile Second Decl.”) ¶¶ 2, 5, ECF No. 29-4 at 6. This representative’s declaration attests that: Margaret learned of the attack on television and “feared the worst” for her son until she spoke with him the following day, during which call she was “very emotional.” Id. ¶ 10. Before the attack, Margaret and Barile “shared a close relationship” and “would frequently keep in touch,” and Margaret was “very sociable and involved in her local community,” serving as a church librarian and schoolteacher. Id. ¶¶ 8-9. After the attack, she became “incredibly worried and anxious about [Barile’s] safety,” and “[w]atching television became her priority, even over socializing and spending time with her friends or helping out at church,” because she was “so . . . fixated on all the horrible things that could possibly happen to [him].” Id. ¶ 11. She also developed insomnia, depression, and a significantly decreased appetite. Id. ¶ 12. “Even at the end of her life,” “she would become very emotional” during military-related news or discussions. Id. ¶ 13. 15  3. Servicemember Laura Susanne Bergstrom and One Family Member Laura Susanne Bergstrom was a Public Affairs Officer in the U.S. Air Force, deployed to Dhahran, Saudi Arabia, and quartered at the Khobar Towers at the time of the attack. Decl. of Laura Susanne Bergstrom (“Bergstrom Decl.”) ¶ 5, ECF No. 29-5 at 1. She was in bed reading when “a massive explosion shook the building, shattering the windows and plunging [her] into darkness.” Id. ¶ 7. Initially believing she was in an earthquake because “the ground was shaking so violently,” she “sustained some abrasions from the broken glass on the bottom of [her] feet” before she grabbed her shoes, dressed quickly, and carefully evacuated. Id. Outside, she encountered “injured and bloodied people everywhere,” realized the base had been attacked, and “felt a deep sense of panic, fear, and confusion.” Id. ¶ 8. In the immediate aftermath, she worked “relentlessly” in her Public Affairs role, “effectively re-living the attack over and over again” while coordinating the base’s communications, “often without sleep or food.” Id. ¶ 9. She felt “exhausted” and “unjust[ly]” “blamed by [her] superiors,” and her “confidence was shaken,” leading her to leave the Air Force earlier than planned and abandon her goal of a lifelong military career. Id. Following the attack, Bergstrom developed insomnia, “difficulties with hearing loud noises,” “loss of appetite,” “recurring nightmares” of the bomb crater, anxiety, “survivor’s guilt,” and “painful” recurring eye styes brought on by stress and exhaustion. Id. ¶ 11. She withdrew from social activities, experienced a “loss of confidence,” and “did not talk to anyone about what [she] was feeling.” Id. ¶ 10. Her “anxiety and insecurities increased after the attack,” contributing to the breakdown of her first marriage, and she continues to struggle with social gatherings, “controlling [her] anger,” and “emotional volatility,” which “created distance” in her relationship with her second husband and her children. Id. ¶¶ 12-13. Approximately ten years after the attack, 16 she sought treatment and was diagnosed with depression and Post-Traumatic Stress Disorder (PTSD). Id. ¶ 14. She has taken antidepressants for approximately fifteen years but continues to experience severe PTSD symptoms, including “tears, a racing heartbeat, . . . sweating,” and “intense emotions” whenever reminded of the bombing. Id. ¶¶ 14-15. Bergstrom believes that, absent the attack, she “would have continued [her] military career,” “enjoyed healthier relationships,” and had a “significantly better” life. Id. ¶ 16. Bergstrom received a 60% disability rating from the U.S. Department of Veterans Affairs. Id. ¶ 14. Bergstrom’s mother, Virginia Lee Simmons, is also a plaintiff in this lawsuit. Virginia learned of the attack when a neighbor told her that the housing complex where her daughter was stationed had been bombed. Decl. of Virginia Lee Simmons (“Simmons Decl.”) ¶ 8, ECF No. 29-5 at 6. She immediately went into shock, “could not stop crying,” was “hyperventilating,” and remembered “just walking in circles around the house, scared and so stressed.” Id. ¶ 8. After a “couple days,” she learned Bergstrom had survived by seeing her interviewed on CNN and later spoke with her by phone, where Bergstrom explained that “she was ‘okay’” but “her dorm room had been destroyed.” Id. ¶¶ 10-11. Simmons “sobb[ed] through the whole call” and remains deeply emotional when recalling that conversation. Id. ¶ 11. Before the attack, Virginia and Bergstrom were “very close”; Virginia saw Bergstrom as her “best friend,” and they “spoke over the phone at least once a week” after Bergstrom joined the Air Force. Id. ¶¶ 6-7. Following the bombing, Virginia noticed that Bergstrom became “volatile” and “very blunt,” and Virginia “wanted to protect her, but [she] couldn’t.” Id. ¶¶ 12-13. For “several months,” Virginia would sometimes “start crying uncontrollably,” “could not sleep,” and “completely lost [her] appetite.” Id. ¶¶ 14-16. She is still “reminded of the day of the attack whenever [she] encounter[s] any 17 military-related discussions, news or media posts,” and believes that “[t]he attack has left lasting negative impacts on [her] family.” Id. ¶ 18. 4. Servicemember Jessica Francine Bradshaw and One Family Member On June 25, 1996, Jessica Francine Bradshaw was a Security Forces Specialist in the U.S. Air Force, deployed to Dhahran, Saudi Arabia, and quartered at the Khobar Towers. Decl. of Jessica Francine Bradshaw (“Bradshaw Decl.”) ¶ 5, ECF No. 29-6 at 1. Bradshaw was outside her dorm room when “the bomb detonated.” Id. ¶ 7. She recalled “a blinding flash, a deafening explosion, and debris filling the hallway as the building was plunged into darkness.” Id. She inhaled dust and debris, suffered “lacerations on [her] face and left toe from shattered glass,” and evacuated in the dark while “bumping into furniture along the way.” Id. Despite her injuries, she “assist[ed] other injured airmen with first aid and transportation for medical care” before being assigned to secure the base perimeter because officials believed they remained under attack. Id. Bradshaw felt “numb with shock at the scale of destruction and devastation all around [her].” Id. In the days that followed, she saw “bloody footprints,” “blood on the handrails and sidewalk,” and “coffins containing the bodies of those who were killed” in the bombing—images she “will never be able to forget.” Id. ¶ 9. She subsequently worked 15-to-18-hour shifts “under highly stressful and demoralizing conditions,” was “made to feel as though [she] had failed in [her] duty by not preventing the attack,” and ultimately left the Air Force in 1997 after the attack “permanently damaged [her] sense of belonging in the Air Force.” Id. ¶ 10. Following the attack, Bradshaw developed asthma from “inhaling the dust and debris during and in the aftermath of the attack,” requiring daily inhalers, steroids, and antibiotics because her “right lung no longer inflate[s] air properly,” as well as “severe” stress-induced eczema with recurrent flare-ups. Id. ¶ 8. She was diagnosed with PTSD and continues to suffer from 18 “flashbacks, anxiety, depression, sleep disorders and nightmares, anger,” “fear of loud noises,” “detachment from loved ones,” and an “inability to communicate with others.” Id. ¶ 11. Darkness triggers vivid memories of the attack, and she has “never been able to sleep in the dark since.” Id. ¶ 12. She developed “binge eating,” high blood pressure, declining self-esteem, and “impulsive behaviors,” including “impulsively cut[ting] [her] hair,” and she began “smoking cigars to cope with [her] anxiety.” Id. ¶¶ 14-15. Her first marriage en