Dobbins v. Islamic Republic of Iran

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA RICHARD LEE DOBBINS, et al., Plaintiffs, Civil Action No. 24-3271 (BAH) v. Judge Beryl A. Howell ISLAMIC REPUBLIC OF IRAN, Defendant. MEMORANDUM OPINION This action, brought by thirty plaintiffs, arises out of the June 25, 1996, bombing by Hezbollah of the Khobar Towers apartment complex in Dhahran, Saudi Arabia, which housed United States military personnel. See Am. Compl. at 2-3 (Introduction), ECF No. 6. The bombing killed nineteen U.S. Air Force personnel and injured hundreds more, including injuring the four servicemember plaintiffs in this case. Id. ¶¶ 41, 51. The plaintiffs in this case also include the immediate family members of the four injured servicemember plaintiffs and of other servicemembers who were injured in the bombing and were previously awarded damages in other cases arising out of the Khobar Towers bombing. Id. at 3 (Introduction). Based on allegations that defendant, the Islamic Republic of Iran (“Iran”), “provide[d] material support and resources to Hezbollah,” and thereby enabled Hezbollah to carry out “large-scale terrorist operation[s] designed to kill Americans,” id. ¶¶ 33, 39; see also, e.g., id. ¶ 34 (noting that Iran has been found “to be liable as a foreign state supporting international terrorism . . . to victims of state sponsored terrorism for the acts and actions of defendant Hezbollah in cases before this Court”), plaintiffs seek damages for their injuries suffered as a result of the attack pursuant to the terrorism exception to conferral of immunity on foreign sovereigns, under the Foreign Sovereign Immunities Act 1 (“FSIA”), 28 U.S.C. § 1605A. Plaintiffs complied with the FSIA’s requirements for effectuating service on a sovereign defendant, but defendant has failed to enter an appearance or otherwise defend against this action. See 28 U.S.C. § 1608(a)(4); Return of Service/Aff., ECF No. 15; Clerk’s Entry of Default as to Iran, ECF No. 17. Plaintiffs now seek entry of default judgment against defendant as to liability and damages. Pls.’ Mot. for Default J. as to Liability & Damages (“Pls.’ Mot.”), ECF No. 20; Pls.’ Mem. in Supp. of Mot. for Default J. (“Pls.’ Mem.”), ECF No. 21-1. For the reasons detailed below, plaintiffs’ motion is granted in part and denied in part. I. BACKGROUND Fifteen prior decisions have found Iran to be 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, 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), 2 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) (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. April 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 250. 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, 750 F. Supp. 2d at 173; Akins, 332 F. Supp. 3d at 10-11; Schooley, 2019 WL 2717888, at *2, and plaintiffs here argue that “the Islamic Republic of Iran is collaterally estopped in this action from denying that it is liable for the acts and actions of Hezbollah in carrying out the terrorist attack at issue here,” Am. Compl. ¶ 34. 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. EVID. 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 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, 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 courts 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) (Lamberth, C.J.) (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) (Lamberth, C.J.); see also Rimkus, 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.”). 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) (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 The D.C. Circuit has 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) (finding that plaintiffs had “met their burden of producing evidence ‘satisfactory to the court’” to establish subject matter jurisdiction under the FSIA, where the 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 defendants’ interests,” Akins, 332 F. Supp. 3d at 11, plaintiffs’ request for judicial notice to be taken of the evidence presented in other cases, including Akins, Schooley, Blais, Heiser I, Rimkus, Christie, and Gration, is granted. Pls.’ Mem. 5-6 (listing “numerous prior decisions” where “[t]his Court has already found defendant liable for the same terrorist attack”); see Akins, 332 F. Supp. 3d at 11 (stating that “factual evidence developed in other cases involving the same conduct by the same defendants is admissible and may be relied upon in this case”); Pls.’ Mem. at 8 (requesting judicial notice be taken of the “prior findings of fact and supporting evidence imposing liability under Section 1605A” in “ample uncontradicted precedent”). 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 pm 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 Am. Compl. ¶ 41 (describing that the 5 “two men [who] drove a stolen Mercedes Benz tanker truck containing the bomb . . . parked the truck 80-100 feet from a building which housed American personnel”). 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 Am. Compl. ¶ 41 (stating that “[t]he men drove away in a waiting Chevrolet Caprice, which had also been stolen as a getaway vehicle”). Although security guards stationed near the top of one of the towers, Building 131, “started to give warnings about the unusual vehicle location,” the truck exploded “within about 15 minutes.” Heiser I, 466 F. Supp. 2d at 252. The blast “sheared off the face of Building 131,” id., and “caused structural damage in buildings a quarter mile away,” Am. Compl. ¶ 41. 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.” Heiser I, 466 F. Supp. 2d at 252. B. Defendant’s 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, 59 (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 July 2, 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 Iran’s Minister of Intelligence and Security “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 6 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 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, MOIS [(Iran’s Ministry of Intelligence)], and IRGC were 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, MOIS, and IRGC were 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 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 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 thirty plaintiffs in this lawsuit include four servicemembers, who suffered “physical and psychological injuries,” and nine of their immediate family members, as well as seventeen immediate family members of other servicemembers awarded damages in four previous actions arising out of the attack on the Khobar Towers. Am. Compl. ¶¶ 16-32, 51 (explaining that two family member plaintiffs are immediate family members of injured servicemembers who were plaintiffs in Aceto, 2020 WL 619925; thirteen are the immediate family members of injured servicemembers who were plaintiffs in Akins, 332 F. Supp. 3d 1; one is the immediate family member of an injured servicemember who was a plaintiff in Valencia v. Islamic Republic of Iran, 774 F. Supp. 2d 1 (D.D.C. 2010); and one is the immediate family member of an injured servicemember who was a plaintiff in Thole, 2024 WL 2208208). Each of the four servicemember plaintiffs and associated family members are described below, followed by the plaintiffs who are family members of servicemembers awarded damages in Aceto, Akins, Valencia, and Thole. 1. Servicemember Brandan Johns and Three Family Members On June 25, 1996, Brandan Johns was an Environmental and Electrical Specialist in the U.S. Air Force, deployed to Dhahran, Saudi Arabia, and quartered at the Khobar Towers. Decl. of Brandan Johns (“Johns Decl.”) ¶¶ 2, 4-5, ECF No. 21-1 at 2. When the bomb denotated, Johns was lying in his dorm room, and “the window blew out on top of [him].” Id. ¶ 6. As a result of the blast, “[his] whole body felt like it was on fire” as “[t]here was broken glass all over [him], the bed, and on the floor of the room.” Id. He suffered from “bleeding in several parts of [his] body 8 where it had been cut by broken glass.” Id. ¶ 7. Following the bombing, Johns “helped [another servicemember] staunch his blood flow by putting pressure on his wound, and guided him toward the makeshift infirmary and triage center.” Id. ¶ 10. After the bombing, Johns “felt concussion symptoms for weeks” and “disoriented and on edge for a long time.” Id. ¶ 14. His roommate Brent Marthaler was killed in the bombing. Id. ¶¶ 3, 13. At Marthaler’s funeral, Johns “was overwhelmed by grief again” and has since “suffered from severe PTSD symptoms,” “sleep problems, anxiety and depression.” Id. ¶¶ 15-16. He received a combined 70% disability rating from the VA, all attributable to PTSD. Id. ¶ 17; id., Ex. B, Brandan Johns VA Disability Benefits Letter (“Johns VA Disability Rating”), ECF No. 21-2 at 11. Three of Johns’ family members—his mother, Rosemary Johns through her estate, father John Johns, and his sister Mary Beth Husing—are also plaintiffs in this lawsuit. Rosemary Johns passed away in 2025, and her husband, John Johns, was named in Rosemary’s will as the personal representative of her estate. Decl. of the Estate of Rosemary Johns via John Johns (“J. Johns Second Decl.”) ¶ 3, ECF No. 21-2 at 15. When Rosemary Johns heard about the attack on television, she was “very upset” and “crying.” Id. ¶ 8. As she waited for news of Brandan, Rosemary “was clearly very distressed.” Id. She “was happy to see Brandan again, but also saddened . . . by the changes in him.” Id. ¶ 12. When John Johns heard from Rosemary about the attack, he and Rosemary “worried that Brandan might be among the victims,” and he “felt helpless and angry at whoever did this.” Decl. of John Johns (“J. Johns First Decl.”) ¶ 6, ECF No. 21-2 at 13. When Brandan returned home, John felt that Brandan “kept things bottled up inside” and “knew he was deeply affected by losing his close friend.” Id. ¶ 8. John thought that Brandan was “never the same after that.” Id. ¶ 9. 9  When Mary Beth Husing heard of the attack, she “was going to head over to [her] parents’ house to tell them the good news that [she] was pregnant” but “held [her] news because [they] were all so focused on what might have happened to Brandan.” Decl. of Mary Beth Husing (“M. Husing Decl.”) ¶ 5, ECF No. 21-2 at 23. Waiting for “more news of Brandan for a long time,” she “was worried and distressed.” Id. ¶ 6. Once Brandan returned home, she noticed Brandan “seemed more quiet and reserved than [she] remembered” and “could tell he had been through some difficult experiences, and that the loss of his best friend weighed on him.” Id. ¶ 8. 2. Servicemember Benjamin Samples and Three Family Members On June 25, 1996, Benjamin Samples was an Air Force Security Officer in the U.S. Air Force, deployed to Dhahran, Saudi Arabia, and quartered at the Khobar Towers. Decl. of Benjamin Shane Samples (“Samples Decl.”) ¶¶ 2-4, ECF No. 21-2 at 25. On the night of the bombing, Samples was in a vehicle at “the gate to leave the residential quarters” when “the blast rocked and shook the vehicle [he was] in, and [he] felt it reverberate through [his] body.” Id. ¶ 5. Samples “realized [they] were under attack and turned the vehicle” toward the source of the blast. Id. ¶ 6. He “tried to provide some security near the blast area” and “established a rough perimeter around the core of the area.” Id. ¶ 9. He had to stay in the Dhahran area for “approximately another 45 days.” Id. ¶ 11. From that time, he recalls “the sight of so much blood everywhere” and that “[t]he smell was awful.” Id. ¶ 12. After returning home, Samples “was angry all the time” and “found it hard to hold a job.” Id. ¶ 13. Having “difficulty in his marriage,” he and his wife divorced. Id. The psychological effects still “plague” Samples, who received a combined 80% disability rating from the VA, 70% attributable to PTSD. Id. ¶¶ 15-16; id., Ex. A, Benjamin Samples VA Disability Benefits Letter (“Samples VA Disability Rating”), ECF No. 21-2 at 29. Neither Benjamin Samples’ declaration 10 nor the documents submitted showing his VA Disability Rating specify what the remaining 10% of the 80% combined rating is attributable to, although he mentions “anxiety, chronic sleep difficulties, depressed mood, impairment of short and long term memory, and impaired impulse control.” Id. ¶ 16. Three of Benjamin’s family members—his mother Carol Samples, former spouse Sandra Conard, and sister Meredith Kitchen—are also plaintiffs in this lawsuit. When Carol first heard about the bombing in a phone call while working at a nursing home, she “asked to be given the rest of the day off to return home.” Decl. of Carol Samples (“C. Samples Decl.”) ¶ 6, ECF No. 21-2 at 31. She “was anxious and terrified that Ben might have been hurt or possibly even killed” and “alternated between panic, anxiety, and hope.” Id. ¶ 7. When Benjamin returned home, Carol “thought Ben was changed,” as he “was more withdrawn and reserved” after the attack, which “was a life-changing experience for him” and “one that caused [her] great emotional distress when it happened and later on when [she] saw the effects on [her] son.” Id. ¶ 11. When Sandra Conard got a call from Benjamin’s commanding officer informing her of the bombing, she “experienced deep anxiety and concern.” Decl. of Sandra Conard (“S. Conard Decl.”) ¶¶ 5-6, ECF No. 21-2 at 33. When “two white-uniformed military personnel” approached her door, her “emotional distress reached a very high level” and she “tried to suppress the thought that they were coming to let [her] know that Ben had died.” Id. ¶ 7. When Benjamin returned home, Sandra noticed that he “seemed withdrawn,” “was quick to anger,” and “sometimes erupted into rants that seemed close to turning into violent actions” and made Sandra feel “threatened.” Id. ¶ 9. Before the attack, Benjamin was a “cheerful and steady young man.” Id. ¶ 11. After the attack, “he seemed to struggle with inner demons but wouldn’t open up about them.” Id. Sandra found the changes in Benjamin “difficult for [her] to deal with.” Id. ¶ 9. While she “can’t say that 11 what Ben went through at the Khobar Towers in 1996 was the sole cause” of their divorce, “it certainly contributed to it.” Id. ¶ 12. When Meredith Kitchen first heard about the attack in a call from her mother, she “was frightened and worried.” Decl. of Meredith Kitchen (“M. Kitchen Decl.”) ¶ 7, ECF No. 21-2 at 36. When Benjamin returned home, “[h]e was not his usual outgoing and cheerful self,” “avoided crowds and seemed more short-tempered,” and “was prone to expressions of ‘road rage.’” Id. ¶ 8. He was also “less communicative,” and Meredith “felt he distanced himself from [her] as well as from others.” Id. ¶ 9. She “felt substantial emotional distress as a result of this loss” and the wait before learning Benjamin survived without any physical injury. Id. ¶ 10. 3. Servicemember Maxaminneo King and One Family Member On June 25, 1996, Maxaminneo King was a Communications Tactical Systems Supervisor in the U.S. Army, deployed to Dhahran, Saudi Arabia, and quartered at the Khobar Towers. Decl. of Maxaminneo King (“King Decl.”) ¶ 2, 4-5, ECF No. 21-2 at 38. When the bomb detonated, King was “jarred out of [his] sleep by the explosion” and “fe[lt] the large and heavy window air conditioner unit just a few inches from [his] nose next to [him] on [his] pillow.” Id. ¶¶ 6-7. After evacuating, since he was on a team “in charge of emergency communications,” he went back into the building “with flashlights to try to set up communications” and “worked throughout the night,” supplying “body bags and emergency air lifts . . . to evacuate the badly wounded back to Germany.” Id. ¶¶ 12-14. King received an Air Force Achievement Medal with Valor for his work setting up emergency communications that night. Id. ¶ 15; id., Ex. A, Maxaminneo King Air Force Achievement Medal Certificate, ECF No. 21-2 at 43. In the aftermath of the attack, King “suffered severe consequences,” experiencing “many symptoms of PTSD.” Id. ¶ 17. While he continues to receive treatment, his “life has never been 12 the same since the attack,” and “[n]ot a day goes by that [he doesn’t] see and feel the A/C unit on the pillow next to [his] head, the darkness, the screams of others, and the panic of that night.” Id. ¶¶ 17, 20. As “one of the few service members there who was in the Army” instead of the Air Force, he also feels “more isolated than most other Khobar survivors.” Id. ¶ 19. King was rated 100% disabled by the VA due to PTSD alone. Id. ¶ 18; id., Ex. B, Maxaminneo King Disability Benefits Letter (“King VA Disability Rating”), ECF No. 21-2 at 45. King’s daughter, Cykia Kenyatta King, is also a plaintiff in this lawsuit. Prior to the attack, Cykia and her father “had a very loving father and daughter relationship.” Decl. of Cykia Kenyatta King (“C. King Decl.”) ¶ 3, ECF No. 21-2 at 47. Cykia was approximately 13 years old at the time of the attack. Id. ¶ 2. Before the attack, Maxaminneo “was outgoing and sociable” and “spent a lot of time with [Cykia].” Id. When Cykia’s mother told her about the bombing, she “was devastated and upset,” feeling like her “whole life had been turned upside down.” Id. ¶¶ 4-5. When her father returned home, Cykia noticed that “he was not the same person and [their] relationship as father and daughter was never the same” as he, “tormented by inner demons that [she] could not know about,” grew “more distant and less involved in [her] life.” Id. ¶¶ 6-7. Once, Maxaminneo “jumped out of bed and was crouching next to it,” and Cykia realized that he “was re-living what had happened to him.” Id. ¶ 8. She feels that she “lost a very loving and involved parent in 1996.” Id. ¶ 11. 4. Servicemember Richard Lee Dobbins and Two Family Members On June 25, 1996, Richard Lee Dobbins was an Aircraft Maintenance Planning and Control Specialist in the U.S. Air Force, deployed to Dhahran, Saudi Arabia, and quartered at the Khobar Towers. Decl. of Richard Lee Dobbins (“Dobbins Decl.”) ¶¶ 3-5, ECF No. 21-1 at 49. At the time of the bombing, he was in his dorm room. Id. ¶ 5. When the bomb detonated, he “felt a rush of 13 wind above [his] face” and “metal shutters on the window above [his] head protruding over [his] bed and into the room.” Id. Following the bombing, he “crawled over the rubble to find where people were buried or stuck,” “pulled quite a few people out of the rubble and enabled them to be carried off to receive medical care,” and “went back and also pulled others who were no longer alive out of there.” Id. ¶ 7. He “spent the next 7 or 8 hours helping to sew up the wounded, even though [he] had no prior medical experience.” Id. ¶ 9. Since the bombing, Dobbins has “nightmares,” “emotional problems,” and PTSD. Id. ¶ 12. He experiences “hypervigilance and an acute ‘flight or fight’ response to ordinary everyday situations.” Id. For example, “any sort of shaking, such as a small earthquake [he] was in” or “any news story on the television about a violent attack or a bombing,” “triggers intense fear.” Id. ¶ 16. He and his wife divorced around 2002, and, in his view, “a lot of the problems [they] had were caused by what [he] now realize[s] is PTSD.” Id. ¶ 12. He applied for a VA disability rating but had not received one at the time plaintiffs’ motion was filed. Id. ¶ 14. Two of Dobbins’ family members—his former spouse Stephanie Burwell Guzik and daughter Alexandra Katherine Burwell Dobbins—are also plaintiffs in this lawsuit. Stephanie does not recall how exactly she heard of the attack but possibly heard through “word of mouth from other relatives of Airmen stationed there.” Decl. of Stephanie Burwell Guzik (“S. Guzik Decl.”) ¶ 5, ECF No. 21-2 at 57. Watching the news, she “felt terrible” and “worried that Richard may have been killed or severely injured.” Id. ¶ 6. After speaking to someone in his squadron, she initially “felt relieved and reassured,” but the uncertainty regarding Richard’s life and condition “started [her] cycle of anxiety and worry over again.” Id. ¶¶ 6-7. When she couldn’t explain to her daughter “why anyone would want to hurt her daddy,” she “broke down and cried.” Id. ¶ 8. When Richard finally returned home, Stephanie “noticed some changes in Richard” over time, as 14 he “didn’t want to talk about what had happened” and “became very controlling,” “short tempered[,] and aggressive,” all of which “escalated to an incident of domestic violence.” Id. ¶¶ 10-11. She and Richard divorced in 2002, and she believes he “was neither a good husband nor a good father” after the attack and has “no doubt that the trauma of that attack and its aftermath caused this change in Richard.” Id. ¶¶ 13-14. Their daughter, Alexandra Katherine Burwell Dobbins, was four years old when the attack happened. Decl. of Alexandra Katherine Burwell Dobbins (“A. Dobbins Decl.”) ¶ 3, ECF No. 21- 2 at 60. While her “recollection of that time is hazy,” she recalls “there was a day when [her] mother was watching the news a lot and seemed very upset about something.” Id. When Richard returned, she remembers that he “seemed ‘checked out’ of any parenting role,” becoming “distant, uninvolved, and emotionally unavailable.” Id. ¶ 9. She now realizes that “turmoil between [Richard] and [her] mother was because of his PTSD,” and that “there is a good chance they would never have gotten divorced were it not for the after-effects of what he went through at the Khobar Towers attack.” Id. ¶ 10. 5. Three Family Members of Greg Leinenbach Greg Leinenbach is a servicemember, who was injured in the Khobar Towers bombing and was a plaintiff in Akins, in which litigation he received an award of $5,000,000 based, inter alia, on his 50% VA Disability Rating and description of his injuries. Akins, 332 F. Supp. 3d at 23, 41. Three of his family members—his father Gary Leinenbach, Sr. (“Gary, Sr.”), brother Gary Leinenbach, Jr. (“Gary, Jr.”), and sister Shannon Leinenbach—are plaintiffs in this lawsuit. Gary, Sr., and Greg “were all part of a close and loving family,” and “remained very close” after Greg enlisted in the Air Force. Decl. of Gary Leinenbach, Sr. (“G. Leinenbach, Sr. Decl.”) ¶¶ 3-4, ECF No. 21-2 at 63. When Gary, Sr., saw the attack on television, he “was in shock.” Id. 15 ¶ 5. The wait “was . . . very hectic and agonizing,” and “very painful” during the few days before he heard from Greg. Id. ¶ 7. After Greg returned, he was “quick to anger,” “seemed to withdraw from social activities,” and “didn’t really want to talk about what had happened to him.” Id. ¶ 9. Gary, Sr., feels “bad for Greg and for [their] whole family” and “a lot of anger toward the people who did this.” Id. ¶ 10. Gary, Jr., was “at college when [his] dad called to tell [him] the terrible news” about the bombing, which news left him feeling “distraught, not knowing whether Greg had survived or whether he was badly hurt.” Decl. of Gary Leinenbach, Jr. (“G. Leinenbach, Jr. Decl.”) ¶¶ 6-7, ECF No. 21-2 at 65. Since Greg returned, “he [i]s different” and “has to excuse himself to leave” if “in a larger stadium or before large crowds.” Id. ¶ 9. Gary, Jr., “kn[ows] [Greg] ha[s] been through a lot,” and he still “shows signs of what he has been through.” Id. Shannon Leinenbach was “deeply worried and distressed” when she saw a news story about the attack on Khobar Towers, and she called her father, who “confirmed [her] worst fears” that Greg had been at Khobar Towers during the attack. Decl. of Shannon Leinenbach (“S. Leinenbach Decl.”) ¶ 5, ECF No. 21-2 at 67. Shannon and Greg “always had a good brother-sister relationship.” Id. ¶ 3. Before the attack, Shannon had known Greg as a “cheerful outgoing person.” Id. ¶ 7. After the attack, she “could tell he had been through something traumatic,” but the “terrible” attack “drew [the family] closer together.” Id. ¶¶ 7-8. 6. Two Family Members of Tracy Matt Winter Tracy Matt Winter is a servicemember, who was injured in the Khobar Towers bombing and was a plaintiff in Akins, in which litigation he received an award of $2,500,000 based, inter alia, on his 70% VA Disability Rating, and the fact that he suffered “severe emotional injury accompanied by relatively minor physical injuries.” Akins, 332 F. Supp. 3d at 27, 41 (quoting 16 Khaliq v. Republic of Sudan, 33 F. Supp. 29, 33 (D.D.C. 2014)). Two of his family members— brother Anthony Winter and sister Shannon Stiles—are plaintiffs in this lawsuit. When Anthony Winter heard of the attack from his own Marine commander while he “was out on field training exercises,” he was “anxious and worried.” Decl. of Anthony Winter (“A. Winter Decl.”) ¶¶ 6-7, ECF No. 21-2 at 69. Growing up, Anthony “admired” his brother, who “influenced [him] to enlist in the Marines.” Id. ¶¶ 3-4. After the attack, Tracy was “no longer outgoing” as he had been before the attack. Id. ¶ 9. “Tracy had some other misfortunes” that Anthony believes “were related to the psychological effects of the bombing.” Id. ¶ 10. At one point, Tracy was in jail and could not arrange the funeral of his “young son” who “died in an accident,” so Anthony handled it, believing that Tracy ending up in jail “was as a result of what the bombing did to [Tracy].” Id. ¶ 11. While “Tracy is doing better,” Anthony believes he “has never forgotten what happened” at the attack that “had a life-changing effect on him and all of [them] in the family.” Id. ¶ 12. Shannon Stiles was working at a restaurant with her mother when she heard of the attack and was “extremely concerned and worried” and “terrified that [she] may have lost [her] brother.” Decl. of Shannon Stiles (“S. Stiles Decl.”) ¶¶ 5-6, ECF No. 21-2 at 72. Before the attack, Shannon “felt close to [Tracy]” and “was pleased that he did stay in touch” after enlisting in the Air Force. Id. ¶¶ 3-4. After the attack, Tracy “was not the same person or the same personality” and “broke up with his girlfriend,” who he had been with since high school. Id. ¶ 7. She is “pretty sure” the “attack and its aftermath have hurt him a lot” and “all of [them] in the family.” Id. ¶ 8. 7. Five Family Members of Eric Ziegler Eric Ziegler is a servicemember, who was injured in the Khobar Towers bombing and was a plaintiff in Akins, in which litigation he received an award of $5,000,000 based, inter alia, on his 17 100% VA Disability Rating. Akins, 332 F. Supp. 3d at 24, 41. Five of his family members— mother Sheryl Ziegler, daughter Sarah Nordin, brother Andrew Ziegler, and sisters Rhonda Crabtree and Amy Ziegler—are plaintiffs in this lawsuit. When Sheryl heard about the attack on the radio, she “felt a terrible chill go through [her] whole body” and was “extremely distressed and worried” that “something very bad had happened to Eric.” Decl. of Sheryl Ziegler (“S. Ziegler Decl.”) ¶ 6, ECF No. 21-2 at 74. While she “was so glad to hear that he was alive,” she “was still very distressed and worried” to “not know the full extent of his injuries.” Id. ¶ 8. She knows that what Eric “had been through must have been traumatic and had taken a psychological toll on him” and that “he suffered more than [she] knew at the time.” Id. ¶¶ 10-11. Sarah Nordin was less than one year old when the attack happened and has “no recollection of being told about it at the time.” Decl. of Sarah Nordin (“S. Nordin Decl.”) ¶ 3, ECF No. 21-2 at 77. Her mother told her about the attack when she was growing up, and she realized over time “how much it had affected [her] father and his relationship with all his children, including [her].” Id. ¶ 3. While Sarah enjoyed spending time with Eric, she “quickly realized . . . that he was physically impaired,” which she felt “held him back and deprived [her] of some elements of his companionship.” Id. ¶ 7. While Sarah felt Eric “cared for [her] and showed [her] some affection and warmth,” she also noticed “he seemed distant and pre-occupied much of the time.” Id. ¶ 10. Sarah believes “that this distance and lack of presence [were] because of the after-effects of what he experienced at the attack,” and she “missed having a father who was more involved and present in [her] life.” Id. ¶¶ 10-11. Andrew Ziegler was “distraught” when he heard about the “traumatic” news of the bombing in a call from his mother. Decl. of Andrew Ziegler (“An. Ziegler Decl.”) ¶¶ 8-9, ECF No. 21-2 at 80. He and Eric were “very close and part of a loving family.” Id. ¶ 3. Before the 18 attack, Eric was an “upbeat cheerful older brother” to Andrew. Id. ¶ 11. After Eric returned, while “[i]t was good to see Eric in the flesh, even though he was still in a hospital bed and all bandaged up,” Andrew has realized over time that “Eric came back from that experience a changed man,” suffering from “physical injuries” and “some psychological harm.” Id. ¶¶ 10-11. Rhonda Crabtree felt “very upset and worried that [she] might have lost [her] brother” when she heard about the attack on the radio and in a call with her mother, after which she “was allowed to go home early from work.” Decl. of Rhonda Crabtre