# Schooley v. Islamic Republic of Iran > District Court, District of Columbia · June 27, 2019 URL: https://www.frixlaw.com/law-library/cases/4412107 ## Case - **Court:** District Court, District of Columbia - **Decided:** June 27, 2019 - **Precedential status:** Published - **Opinion:** Opinion - **Judges:** Chief Judge Beryl A. Howell - **Nature of suit:** Civil - **Cited by:** 0 later opinions in the Frix Law Library ## Citator (automated) - No negative treatment found by the automated citator. That is not the same as a confirmation that the case is good law; read the citing cases. - Full citator and citing cases: https://www.frixlaw.com/law-library/cases/4412107 ## Opinion text UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA WILLIAM M. SCHOOLEY, et al., Plaintiffs, Civil Action No. 17-1376 (BAH) v. Chief Judge Beryl A. Howell ISLAMIC REPUBLIC OF IRAN, et al., Defendants. MEMORANDUM OPINION On June 25, 1996, a gasoline tanker, modified to serve as a bomb, exploded with the force of 20,000 pounds of TNT next to the Khobar Towers complex, a residential complex in Dhahran, Saudi Arabia housing coalition forces “charged with monitoring compliance with U.N. Security Council Resolutions.” Pls.’ Amend. Compl. (“Compl.”) ¶¶ 19–21, ECF No. 21. Nineteen U.S. Air Force personnel were killed, and hundreds more were injured, including the 101 service member plaintiffs in this case. Id. ¶¶ 22, 38. The total of 219 plaintiffs in the instant case also include 118 “immediate family members” of the 101 injured service members. Id. ¶ 6. The plaintiffs allege that the three defendants, the Islamic Republic of Iran (“Iran”), the Iranian Ministry of Information and Security (“MOIS”), and the Islamic Revolutionary Guard Corps (“IRGC”), are responsible for the terrorist attack on Khobar Towers, id. ¶ 13, and seek to hold these defendants liable as foreign state sponsors of international terrorism under the Foreign Sovereign Immunities Act (“FSIA”) terrorism exception, 28 U.S.C. § 1605A. The defendants have failed to enter appearances, or defend against this action, despite being properly served, pursuant to 28 U.S.C. § 1608(a)(4). See Return of Service/Affidavit of Summons and Complaint Executed, ECF No. 13; Clerk’s Entry of Default, ECF No. 15. The plaintiffs now seek the entry 1 of a default judgment against the defendants as to liability and damages. Pls.’ Mot. for Judicial Notice of Prior Related Cases and for Default J. as to Liability and Damages Against Iranian Defendants (“Pls.’ Mot.”), ECF No. 146. For the reasons detailed below, the plaintiffs’ motion is granted. I. BACKGROUND “‘[T]he history of litigation’ in this Court ‘stemming from the bombing of Khobar Towers . . . is extensive.’” Akins v. Islamic Republic of Iran, 332 F. Supp. 3d 1, 10 (D.D.C. 2018) (quoting Rimkus v. Islamic Republic of Iran, 750 F. Supp. 2d 163, 167 (D.D.C. 2010) (Lamberth, J.) (citing Blais v. Islamic Republic of Iran, 459 F. Supp. 2d 40, 46–51 (D.D.C. 2006) (Lamberth, J.) and Estate of Heiser v. Islamic Republic of Iran, 466 F. Supp. 2d 229, 248 (D.D.C. 2006) (“Heiser I”) (Lamberth, J.))). Specifically, in Heiser I, the Court heard evidence and witness testimony for 17 days, see Heiser I, 466 F. Supp. 2d at 250, including from 7 expert witnesses.1 The plaintiffs correctly point out that in prior cases “the Court found that the three [instant] Iranian Defendants were liable for the Khobar Towers bombing,” Pls.’ Mem. Supp. Pls.’ Mot. Judicial Notice of Prior Related Cases (“Pls.’ Mem.”) at 2, ECF No. 146, and that they “dealt with identical issues regarding the liability [of these defendants],” id. In light of this prior litigation, plaintiffs request that this Court take “[j]udicial notice of these proceedings.” Id. Rule 201 of the Federal Rules of Evidence authorizes a court to take judicial notice, on its own or at the request of a party, of adjudicative facts that are “not subject to reasonable dispute 1 Expert witnesses testifying in Heiser I included: (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, and (4) Dale Watson, the former Deputy Counterterrorism Chief of the FBI, see Heiser I, 466 F. Supp. 2d at 260–65, as well as (5) Dr. Thomas Parsons, a medical examiner, see id. at 268, (6) Dr. Dana Cable, a licensed psychologist and expert on grief process, see id. at 269–70, and (7) Dr. Herman Miller, an economic consultant, see id. at 273–74. 2 because” they “can be accurately and readily determined from sources whose accuracy cannot reasonably be questioned.” FED. R. EVID. 201(a)–(c). “ʻ[A]djudicative facts are simply the facts of the particular case’ while ‘legislative facts . . . 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, Wash., D.C. Chapter v. Social Sec. Admin., 736 F.2d 727, 737 n.95 (D.C. Cir. 1984) (Robinson, J., concurring) (quoting Advisory Committee Note to FED. R. EVID. 201(a)). Rule 201 has been applied frequently in this Court to take notice of, and rely on, facts found in earlier proceedings, “without necessitating the formality of having that evidence reproduced,” Harrison v. Republic of Sudan, 882 F. Supp. 2d 23, 31 (D.D.C. 2012) (quoting Taylor v. Islamic Republic of Iran, 811 F. Supp. 2d 1, 7 (D.D.C. 2011)), “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) (“Relying on the pleadings and the . . . findings of other judges in this jurisdiction.”)). In this way, rather than require litigants to present such evidence anew in each lawsuit stemming from the same terrorist attack, courts have “determined that the proper approach is one ‘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,’” so that “courts may reach their own independent findings of fact” predicated “on judicial notice of the evidence presented in the earlier cases.” Anderson v. Islamic Republic of Iran, 753 F. Supp. 2d 68, 75 (D.D.C. 2010) (Lamberth, J.) (quoting Rimkus, 750 F. Supp. 2d at 172); see also Foley, 249 F. Supp. 3d at 191 (Kollar-Kotelly, J.) (finding same “approach appropriate” and “tak[ing] judicial notice of the requested findings”); Oveissi v. Islamic Republic of Iran, 879 F. Supp. 2d 3 44, 50 (D.D.C. 2012) (Lamberth, J.) (quoting Rimkus, 750 F. Supp. 2d at 163) (finding courts permitted “in subsequent related cases to rely upon the evidence presented in earlier litigation”); Estate of Botvin v. Islamic Republic of Iran, 873 F. Supp. 2d 232, 237 (D.D.C. 2012) (Lamberth, J.) (taking “judicial notice of the evidence presented in the earlier cases”). Factual evidence developed in other cases “involving the same conduct by the same defendants is admissible and may be relied upon in this case.” Akins, 332 F. Supp. 3d at 11. While factual evidence may be relied upon, judicial findings derived from that evidence are not dispositive because courts must “reach their own, independent findings of fact in the cases before them.” Rimkus, 750 F. Supp. 2d at 172. Persuaded that this approach is both “efficient and sufficiently protective of the absent defendants’ interests,” Akins, 332 F. Supp. 3d at 11, this Court will adopt it and grant the plaintiffs’ request to take judicial notice of the evidence presented in Heiser I, Blais, Valencia v. Islamic Republic of Iran, 774 F. Supp. 2d 1 (D.D.C. 2010), and Rimkus.2 The evidence regarding the terrorist attack at issue 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 U.N. security council resolutions.” Blais, 459 F. Supp. 2d at 47. Ten minutes before 10:00 p.m. on June 25, 1996, “a large gasoline tanker truck pulled up alongside the perimeter wall of the Khobar Towers complex.” Heiser I, 466 F. Supp. 2d at 252; Compl. ¶ 20. The guards on the top of the building “started to give 2 The D.C. Circuit has endorsed the use of judicial notice to establish facts in FSIA terrorism cases. In Han Kim v. Democratic People’s Republic of Korea, 774 F.3d 1044, 1049 (D.C. Cir. 2014), the D.C. Circuit held that the plaintiffs had “met their burden of producing evidence ‘satisfactory to the court’” to establish subject matter jurisdiction under the FSIA, id., 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. See also Owens v. Republic of Sudan, 864 F.3d 751, 789 (D.C. Cir. 2017). 4 warnings about the unusual vehicle location,” but the truck exploded “within about 15 minutes.” Id. ¶ 21. The resulting explosion was the “largest non-nuclear explosion ever up to that time” and was the “equivalent of 20,000 pounds of TNT.” Id. The blast “sheared off the face of Building 131 and damaged every other building in the complex” and killed nineteen U.S. Air Force personnel. Id. ¶ 22. B. The Defendants’ Role Iran is “a foreign state and has been designated a state sponsor of terrorism . . . continuously since January 19, 1984.” Blais, 459 F. Supp. 2d at 47; see also 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/j/ct/list/c14151.htm (last visited June 27, 2019). “[T]he IRGC is a non-traditional instrumentality of Iran,” serving as “the military arm of a kind of shadow government answering directly to the Ayatollah and the mullahs who hold power in Iran.” Blais, 459 F. Supp. 2d at 47. “The IRGC, with its own separate ministry, has evolved into one of the most powerful organizations in Iran and functions as an intelligence organization, both within and beyond Iran’s borders.” Compl. ¶ 10. “The terrorist attack on the Khobar Towers was . . . approved and supported by the Iranian Minister of Intelligence and Security (‘MOIS’) at the time.” Heiser I, 466 F. Supp. 2d at 252. The attack was also “approved by Ayatollah Khameini, the Supreme leader of Iran at the time.” Id. The truck bomb that was used was “assembled at a terrorist base in the Bekaa Valley which was jointly operated by the IRGC and by the terrorist organization known as Hezbollah,” id., and recruited individuals “drove the truck bomb from its assembly point in the Bekaa Valley to Dhahran, Saudi Arabia,” id. 5 The Federal Bureau of Investigation (“FBI”), led by then-director Louis Freeh, “conducted a massive and thorough investigation of the attack, using over 250 agents,” id., under the “day to day oversight” of Dale Watson, then deputy counterterrorism chief of the FBI, id. at 264 n.19. “Based on that investigation, an Alexandria, Virginia, grand jury returned an indictment . . . against 13 identified members of the pro-Iran Saudi Hezballah organization.” Id. at 252. The FBI “obtained a great deal of information linking the defendants to the bombing from interviews with six admitted members of the Saudi Hezbollah organization.” Id. at 252–53. These six members “admitted to the FBI 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 Khobar Towers,” id. at 253, and also “indicated that the selection of the target and the authorization to proceed was done collectively by Iran, MOIS, and IRGC, though the actual preparation and carrying out of the attack was done by the IRGC,” id. “[B]ased on [this] evidence gathered by the FBI,” Freeh has “publicly and unequivocally stated his firm conclusion” that “Iran was responsible for planning and supporting the Khobar Towers attack.” Id. Dr. Patrick Clawson provided expert testimony in Heiser I, “based on his involvement on a Commission investigating the bombing, his top-secret security clearance, his discussions with Saudi officials, as well as his academic research on the subject,” id., that “the IRGC was responsible for providing military training to Hezbollah terrorists as to how to carry out a terrorist attack,” id. Based on these facts, Clawson “stated conclusively his opinion that the government of Iran, MOIS, and IRGC were responsible for the Khobar Towers bombing, and that Saudi Hezbollah carried out the attack under their direction.” Id. Dr. Buce Teft additionally supported Clawson’s “expert opinion,” based on “publicly available sources that were not 6 inconsistent with classified information known to him from his time at the CIA” that “the Islamic Republic of Iran and the Iranian Revolutionary Guards Corp were responsible for planning and supporting the attack on Khobar Towers.” Id. at 253–54. C. The Instant Plaintiffs The plaintiffs in this action include 101 service members who “suffered physical and/or mental and/or emotional injuries as a result of the terrorist attack” on Khobar Towers, Compl. ¶ 6, and 118 of their immediate family members. The service member plaintiffs, and, where applicable, their family member plaintiffs, are described below.3 1. Stacey D. Benfield and Three Family Members On June 25, 1996, Stacey D. Benfield was a Senior Airman in the United States Air Force deployed to Saudi Arabia, stationed at Khobar Towers in Dhahran, Saudi Arabia. Decl. of Stacey D. Benfield (“Benfield Decl.”) (Sept. 5, 2018) ¶ 4, ECF No. 35 (sealed), ECF No. 157 (public version). At the time of the bombing, Benfield was on the third floor of a building near Building 131, the building closest to the detonated gasoline tanker. Id. ¶ 5. He was looking through his patio glass doors when the tanker exploded. Id. “There was a bright flash and a deafening explosion” and Benfield was blown across the room. Id. Benfield regained consciousness as he was being carried from the rubble to the triage center. Id. At the triage center, he was bandaged and sent to a Saudi hospital for treatment. Id. ¶ 6. His “nose was shattered, and [his] lip was ripped in half and hanging from the left side of [his] face, and up into [his] naval cavity. The flesh from [his] nose was hanging on the left side of [his] face.” Id. In 3 Every plaintiff in this case has submitted a sealed declaration, with supporting documentation containing sensitive personal information, and a redacted, public version. The docket numbers for both the public and the sealed versions are reflected in the first citation to each plaintiff’s declaration. Otherwise sealed content referenced in this Memorandum Opinion is unsealed as necessary to explain the Court’s reasoning. See In re WP Co. LLC, 201 F. Supp. 3d 109, 116 n.4 (D.D.C. 2016) (citing United States v. Reeves, 586 F.3d 20, 22 n.1 (D.C. Cir. 2009); United States v. Parnell, 524 F.3d 166, 167 n.1 (2d Cir. 2008) (per curiam)). 7 addition, he suffered from a “large hole in [his] left eye socket and deep lacerations from the front of [his] hairline to the center/top of [his] head.” Id. He additionally injured his knee and right shoulder. Id. ¶¶ 6, 11. The attack left him with “permanent disfiguring scars on [his] nose, eye, forehead and the top and left side of [his] head.” Id. ¶ 10. A piece of flesh is missing from his upper left eye socket. Id. Though he had surgery to correct the shoulder injury, his knee still causes him pain. Id. ¶ 11. In addition to suffering physical injury, Benfield also suffers from PTSD which has caused “significant hardships in [his] life.” Id. ¶ 12. As a result of his PTSD, Benfield cannot attend fireworks, movies, or football games with his family. Id. He suffers from startle reactions, which have led to threatening behavior. Id. His PTSD has affected his short term memory, which limits his ability to receive an education, id. ¶ 13, and his ability to form relationships, id. ¶ 14. The Department of Veterans Affairs (“VA”) has rated Benfield 80% disabled. Id. ¶ 15; id., Att. (VA Rating Decision, undated), ECF No. 35 at 20; id., Att. (Letter from VA, dated Feb. 22, 2018), ECF No. 35 at 21; see also id., Att. (medical records), ECF No. 35 at 8–17. Three of Benfield’s family members are plaintiffs in this lawsuit: his mother, Gloria J. Brown; his father, Jimmy F. Brown; and his sister, Melena R. Collins. Benfield Decl. ¶ 2; Decl. of Gloria J. Brown (“Gloria Brown Decl.”) (Sept. 5, 2018) ¶ 3, ECF No. 35 (sealed), ECF No. 157 (public). After hearing about the bombing on the television, Benfield’s mother called Benfield’s wife to see if she knew anything. Id. ¶¶ 6–7. She also called the military liaison, who confirmed the attack and informed her that she should call every hour on the hour. Id. ¶ 8. “Finally, shortly before 2:20 a.m. the next morning” the liaison called to advise that Benfield was alive but wounded. Id. Benfield himself called at 6:10 a.m., at which point his mother “finally felt some relief knowing he was indeed alive.” Id. Although relieved, the “effects of the attack 8 on [her] daily life and family life were devastating.” Id. ¶ 9. She was “very proud to have raised [Benfield] to be a happy go lucky, charismatic and loving person that everyone loved,” but since the bombing has had to watch “[her] son change into a withdrawn person who has trouble fitting into life.” Id. ¶ 9. She experiences “extreme grief and distress as a result of the injuries to [her] son” and the “profound impact on [their] relationship.” Id. ¶ 14. She has additionally had to financially support her son “when he was not able to make money because of his injuries.” Id. ¶ 13. Prior to the attack, Benfield’s father and Benfield enjoyed “going to sporting events and watching live music together.” Decl. of Jimmy F. Brown (“Jimmy Brown Decl.”) (Nov. 11, 2018) ¶ 6, ECF No. 35 (sealed), ECF No. 157 (public). Due to the effects of the attack, Brown “[has] not been able to share new experiences with [his] son and create new memories.” Id. ¶ 7. Brown experiences “extreme grief and distress as a result of the injuries to [his] son” and the “profound impact on [their] relationship.” Id. ¶ 11. Due to the effects of Benfield’s PTSD, he no longer enjoys his old favorite hobbies. Id. ¶ 6. Prior to the explosion, Benfield “was never a person prone to engage in fights,” but now “his relationships, including [that with his father], are strained.” Id. ¶ 7. Brown has additionally supported his son when he “found himself out of work or unable to earn enough money” causing him to “[incur] economic losses.” Id. ¶ 8. The inability to aid his son in getting his life back on track has left Brown with overwhelming feelings of helplessness. Id. ¶ 5. The situation has taken a “toll on [Brown’s] overall well- being.” Id. ¶ 7. Benfield’s only sibling, his younger sister, is Melena R. Collins. Decl. of Melena R. Collins (“Melena Collins Decl.”) (Oct. 15, 2018) ¶ 5, ECF No. 35 (sealed), ECF No. 157 (public). Upon hearing of the attack, Collins was unsure if her brother was alive. Id. Even after 9 knowing that he survived, “knowing he was alive, but now how bad he was injured was grueling.” Id. Collins stayed close to the TV and phone for a day or two “waiting to hear or see something, anything.” Id. At midnight on TV, she finally saw her brother being wheeled off a plane in Germany. Id. Upon seeing her brother, she was “overwhelmed with so many emotions. [She] just dropped to the floor and cryied [sic] ‘He is alive!!!’” Id. After the attack, Collins “experienced, and continue[s] to experience, extreme grief and distress as a result of the injuries to [her] brother” and the “profound impact on [their] relationship.” Id. ¶ 11. She finds it “heartbreaking to know he struggles to be a part of a family he was so close to and loved by.” Id. ¶ 6. She additionally finds it “hard to watch [her] parents worry about their son and not be able to help him.” Id. 2. Bryan Brock and One Family Member On June 25, 1996, Bryan Brock was a service member in the U.S. Air Force deployed to Saudi Arabia, stationed at Khobar Towers in Dhahran, Saudi Arabia. Decl. of Bryan Brock (“Brock Decl.”) (Oct. 24, 2018) ¶ 4, ECF No. 36 (sealed), ECF No. 159 (public). At the time of the bombing, Brock was in the common area of his dorm room. Id. ¶ 5. As a result of the explosion, glass shards were blown at him and were later “surgically removed from [his] body.” Id. As one of the few medics at the station, Brock dealt with the most seriously injured. Id. ¶ 6. “[His] office was the make-shift morgue and [he] had to work with dead bodies lying on the floor of [his] office for hours while [they] waited on a freezer truck.” Id. Even after the explosion, “there was so much blood [he] had to cut out the carpet and place a large rug over the blood-stained concrete below and worked over the top of it for over a month.” Id. Upon return home, he was treated at the Air Academy Hospital for PTSD. Id. ¶ 7. He was prescribed medication for trauma, but did not seek additional treatment because of his fear that “having to 10 talk about that night may trigger additional emotional trauma.” Id. As a result of the attack, he was “horrified of loud noises and large trucks and had paranoid thoughts,” id. ¶ 8, and still suffers from the after-effects, id. Brock was offered the Purple Heart for his wounds during the attack but turned it down. Id. ¶ 9. He was also awarded an Air Force Commendation Medal for providing medical treatment in the wake of the blast. Id., Att. (The Air Force Commendation Medal Certificate, dated Dec. 17, 1996), ECF No. 36 at 6; id., Att. (Citation to Accompany the Award of The Air Force Commendation Medal Certificate, no date), ECF No. 36 at 7. Brock’s mother, Joan Locke, is a plaintiff in this lawsuit. At the time of the attack, Locke was at work and informed of the bombing by a colleague. Decl. of Joan C. Locke (“Locke Decl.”) (Oct. 18, 2018) ¶ 5, ECF No. 36 (sealed), ECF No. 159 (public). Upon hearing that the Khobar Towers had been bombed, she “collapsed into [her] chair” because she was “panic stricken, crying in disbelief.” Id. She was driven home and then waited by the phone for hours for news about Brock. Id. ¶ 6. Finally, Brock’s then-wife received news that he was alive. Id. ¶ 7. Locke was later able to communicate with her son over AOL mail and he detailed some of the trauma that he experienced. Id. ¶ 8. As a result of the attack, Locke’s daily and family life have been devastatingly affected. Id. ¶ 10. She has missed days of work due to the stress, and found focusing on her work or her other children hard. Id. She was prescribed medication and sought other medical attention to “help [her] cope with life” and “[her] worry about Bryan.” Id. 3. Mark E. Broda and Two Family Members On June 25, 1996, Mark E. Broda was a Senior Airman in the U.S. Air Force deployed to Saudi Arabia, stationed at Khobar Towers in Dhahran, Saudi Arabia. Decl. of Mark E. Broda (“Broda Decl.”) (Oct. 8, 2018) ¶ 4, ECF No. 37 (sealed), ECF No. 160 (public). Broda had just extended his enlistment voluntarily to go on a 90-day temporary duty. Id. During the bombing, 11 Broda was sitting on his couch in front of sliding glass doors when there was “an extremely bright flash in the room.” Id. ¶ 5. He turned to look at the doors and “was thrown off the couch and into the cinder-block wall a few feet away.” Id. When he looked at his two friends in the room he saw that “there was blood seeping from all over them.” Id. Broda himself had “sustained lacerations on [his] face, hands and shoulder” from the sliding glass door. Id. They were ordered to evacuate and were bussed to local hospitals. Id. ¶¶ 6–7. He was pulled out of line, however, and taken into “the sick call building where others were lying on the floor being treated” and had his lacerations sewn up. Id. ¶ 7. The next day he was ordered for re-evaluation and suffered from “a bout of catatonia when the doctor began asking [him] questions.” Id. ¶ 9. Broda was prescribed a sedative and was put under watch. Id. Broda still stayed to help load the “flag covered caskets of our dead Airmen into an empty cargo plane” and went home as scheduled a few days later. Id. ¶ 10. As a result of the attack, Broda suffers from PTSD, id. ¶ 13, for which he has received counseling “on and off for the last twenty years.” Id. ¶ 15. Even 20 years after being thrown into the cinderblock wall, he “still get[s] severe headaches in the area of [his] head where it hit.” Id. ¶ 15. Broda received the Purple Heart for the injuries he sustained. Id. ¶ 11; id., Att. (Purple Heart Certificate, dated Aug. 6, 1996), ECF No. 37 at 12. The VA has rated Broda as 30% disabled, for which he receives monthly benefits. Id. ¶ 14; id., Att. (Letter from VA, dated Dec. 6, 2012), ECF No. 37 at 38; see also id., Att. (medical records), ECF No. 37 at 14–37. Two of Broda’s family members are plaintiffs in this lawsuit: his mother, Pamela G. Broda, and his sister, Alycia Broda. Broda’s mother first learned of the attack when her oldest daughter called and asked if she had seen the news. Decl. of Pamela G. Broda (“Pamela Broda Decl.”) (Sept. 7, 2018) ¶ 5, ECF No. 37 (sealed), ECF No. 160 (public). This simple question 12 “put her in a sudden panic,” and she turned on the TV to watch and wait for news of her son. Id. She waited “in limbo, fearing for the worst and not knowing the fate of [her] son” for hours until Mark made contact. Id. Upon return home, her son “tried to put up a good front for [Pamela’s] sake” but she knew “he was suffering” and this caused her “a great deal of emotional stress,” which she “inadvertently took [] out on [her] youngest daughter.” Id. ¶ 7. During this time, Broda’s mother “lived under a cloud of emotional stress.” Id. As a result of the attack and Broda’s injuries, his mother experiences “extreme grief and distress.” Id. ¶ 8. Mark Broda’s sister, Alycia A. Broda, also suffered from the ramifications of the attack. His sister first learned of the attack with her mother when her sister called to tell them to turn on the news. Decl. of Alycia A. Broda (“Alycia A. Broda Decl.”) (Sept. 10, 2018) ¶ 5, ECF No. 37 (sealed), ECF No. 160 (public). They were “left in limbo, fearing for the worst and not knowing the fate of [her] brother” for four to five hours until he called. Id. Upon his return home, Broda lived with Alycia and his mother, where they provided “physical and emotional support.” Id. Alycia “started struggling in school, worrying about [her] brother’s mental health.” Id. ¶ 6. Mark’s issues resulting from the attack created tension within the family, and the “mental and emotional strain [their] family endured for years was very hard to overcome.” Id. Alycia still “deal[s] with the secondary stress from Mark’s PTSD.” Id. ¶ 8. 4. Shannon Bump and One Family Member On June 25, 1996, Shannon Bump was a Master Sergeant in the U.S. Air Force deployed to Saudi Arabia, stationed at Khobar Towers in Dhahran, Saudi Arabia. Decl. of Shannon Bump (“Bump Decl.”) (Sept. 6, 2018) ¶ 4, ECF No. 39 (sealed), ECF No. 162 (public). Bump had just finished showering when the attack occurred. Id. ¶ 5. The explosion threw him eight feet back against a wall and showered him with glass. Id. Bump, as the highest-ranking person in his 13 suite, coordinated the evacuation, id., and then ran to the source of the explosion and helped carry the injured away on blankets, id. ¶ 7. At this time, he noticed that he had received a cut on his leg from the initial explosion. Id. This cut left him with scarring. Id. ¶ 10. Bump and the rest of the squadron were made to sit in the gym for two hours while news of the explosions and deaths played on TVs before he was able to contact his wife. Id. ¶ 8. After the compound was shut down, Bump remained behind to load the equipment. Id. ¶ 9. As a result of the attack, Bump “still suffer[s] from emotional distress.” Id. ¶ 12. Bump has difficulty discussing the attack with people, including his wife, and worries about “the stigma of being handicapped, disabled, or emotionally traumatized.” Id. ¶ 12. Bump received the Purple Heart for his injuries. Id. ¶ 11; id., Att. (Purple Heart Certificate, dated Aug. 5, 1996), ECF No. 39 at 8; id., Att. (Certificate of Release or Discharge from Active Duty, confirming medals), ECF No. 39 at 7. Bump’s wife, Valerie Bump, is a plaintiff in this lawsuit. She was running errands when she saw a special news report about the bombing. Decl. of Valerie Bump (“Valerie Bump Decl.”) (Sept. 6, 2018) ¶ 5, ECF No. 39 (sealed), ECF No. 162 (public). She struggled with “the thought that there could even be a chance that [their children] could grow up without their father in their lives.” Id. ¶ 6. She called her husband’s squadron, but they were unable to confirm anything beyond numerous injuries and deaths. Id. ¶ 7. After four to five hours waiting to hear more information, she left the house to get food and returned to a voicemail from her husband. Id. ¶ 8. As a result of the attack, Shannon Bump “experienced, and continue[s] to experience, extreme grief and distress.” Id. ¶ 10. She fears that “something might happen to him” when her husband leaves her for any period of time, and has “anxiety about it before he leaves.” Id. ¶ 10. 5. Rondal G. Burns and Three Family Members 14 On June 25, 1996, Rondal G. Burns was a Staff Sergeant in the U.S. Air Force deployed to Saudi Arabia, stationed at Khobar Towers in Dhahran, Saudi Arabia. Decl. of Rondal G. Burns (“Rondal Burns Decl.”) (Sept. 18, 2018) ¶ 4, ECF No. 41 (sealed), ECF No. 164 (public). At the time of the attack, Burns was lying on his couch watching television. Id. ¶ 5. The force of the explosion “threw [him] off the couch and head first into the wall behind the second couch in the room.” Id. The next thing he knew, Burns was “behind the second couch on [his] knees screaming [his] head off, crying loudly, and [his] ears were clogged.” Id. Burns’ squadron evacuated and “a medic was called and they bandaged [Burns].” Id. ¶ 7. While outside after the attack, an additional panic ensued when people mistakenly believed insurgents were coming over the fence. Id. ¶ 8. Burns returned home, where he continued to suffer from headaches, but when he went to the emergency room, “whatever doctor was on duty told [him] it was different things.” Id. ¶ 12 Burns suffered a stroke on November 3, 1996, approximately four months after the attack. Id. ¶ 14. Burns was sitting on his couch “watching something, and the next thing [he] knew [he] was crouched over.” Id. ¶ 13. The stroke required treatment in the intensive care unit, and included treatment for epilepsy, speech therapy, and physical therapy. Id. ¶ 14. Burns now suffers from “PTSD because of the bombing, and [] seizures [he has] had since leaving the intensive care unit.” Id. In addition, he has short-term memory loss and depression. Id. ¶¶ 14, 17. As a result of his PTSD, he is “unable to carry out normal life.” Id. ¶ 17. Burns received the Purple Heart, and has a disability rating of 100% by the VA. Id. ¶¶ 17– 18; id., Att. (Purple Heart Certificate, dated Aug. 7, 1996), ECF No. 41 at 11; id., Att. (Letter from VA, dated July 19, 2017), ECF No. 41 at 10. Three of Burns’ family members are plaintiffs in this lawsuit: his wife, Rebekah J. Burns; his daughter, Emeleigh Ledgerwood; and his son, Nickolaus Burns. On the day of the terrorist 15 attack, Burns’ wife returned home from a “leisurely day out with [her] children” to “hysterical phone calls from family.” Decl. of Rebekah J. Burns (“Rebekah Burns Decl.”) (Sept. 17, 2018) ¶ 5, ECF No. 41 (sealed), ECF No. 164 (public). After listening to messages, Burns’ commander called to say that “[her] husband was wounded and given the situation, a full estimate of injuries was going to take days or even months.” Id. When Burns came home, Rebekah “notice[d] differences in his behavior and state of mind,” id. ¶ 8, with his “state of mind [] deteriorating,” id. Burn’s wife has “remained at Rondal’s side every minute of each day,” id. ¶ 11, and this “has impacted [her] personal health, in an enormously negative way,” id. ¶ 10. In addition, the Burns have “incurred substantial economic loss” and loss of property. Id. ¶¶ 15–16. Due to time missed at her work, Rebekah “lost over four years in [her] retirement plan.” Id. ¶ 16. As a result of the attack and the injuries to her husband, Rebekah experiences “extreme grief, distress and emotional injuries” that have yielded a “profound impact on [their] family dynamics.” Id. ¶ 18. Burns’ daughter, Emeleigh, was seven years old at the time of the attack. Decl. of Emeleigh L. Ledgerwood (“Ledgerwood Decl.”) (Oct. 15, 2018) ¶ 8, ECF No. 41 (sealed), ECF No. 164 (public). Even as an adult, Emeleigh has “had to work through [her] baggage” and has “cried over the fact that except for pictures and videos, [her] dad won’t remember walking [her] down the aisle, [her] graduation, or the birth of his grandchildren.” Id. ¶ 9. Emeleigh has had to deal with her father’s condition all her life, and learned to “recognize warning signs that he was going to have a seizure.” Id. ¶ 8. She “worried every time [they] got separated, truly afraid that he had forgotten how to get back to where [they] were supposed to meet.” Id. Burns’ son, Nickolaus, who was six years old at the time of the attack, has also been affected. Decl. of Nickolaus A. Burns (“Nickolaus Burns Decl.”) (Sept. 17, 2018) ¶ 8, ECF No. 41 (sealed), ECF No. 164 (public). Nickolaus found the “effects of the attack on [his] daily life 16 and family life” to be “devastating.” Id. From a young age, he realized that he “would no longer be a child,” but rather “a man, who only had a short time with his father.” Id. ¶ 13. Nickolaus attended speech therapy with his father “as the therapist noticed he responded better when [he] was there.” Id. ¶ 19. While his father suffered from post-traumatic-stress-disorder, “[they] all suffered as he suffered.” Id. ¶ 21. 6. Richard D. Dupree On June 25, 1996, Richard D. Dupree was a Senior Airman in the U.S. Air Force deployed to Saudi Arabia, stationed at Khobar Towers in Dhahran, Saudi Arabia. Decl. of Richard D. Dupree (“Dupree Decl.”) (Oct. 17, 2018) ¶ 3, ECF No. 49 (sealed), ECF No. 182 (public). Just as he was about to fall asleep, “the bed [began] shaking horribly, and the windows blew into the room.” Id. ¶ 4. His door additionally blew off its hinges and “knocked [him] off the bed against the wall, and pinned [him] there,” id., with his legs and feet covered in shrapnel, id. ¶ 5. Ever since the attack, Dupree’s right ear hurts from loud noises. Id. ¶ 6. Though not officially diagnosed, Dupree suffers from PTSD-like symptoms such as “hyper vigilance, avoidance, [and] constant reliving of the event.” Id. ¶ 8. Dupree constantly relives the day of the attack and has “numbing feelings” whenever he is reminded of it. Id. ¶ 11. Dupree received the Purple Heart for his injuries. Id. ¶ 7; id., Att. (Purple Heart Certificate, dated Aug. 26, 1996), ECF No. 49 at 6. 7. Thomas F. Edman and One Family Member On June 25, 1996, Thomas F. Edman was a Captain in the U.S. Air Force deployed to Saudi Arabia, stationed at Khobar Towers in Dhahran, Saudi Arabia. Decl. of Thomas F. Edman (“Edman Decl.”) (Nov. 4, 2018) ¶ 4, ECF No. 50 (sealed), ECF No. 183 (public). Edman was in the building adjacent to the bomb, and his room was on the side where the explosion occurred. 17 Id. ¶ 5. The exterior walls of his apartment were “completely blown in and off.” Id. Edman was blown “up and against the back wall and door frame,” where he was hit with “flying debris that included furnishings in the room, concrete, glass, and other building materials.” Id. The impact of Edman hitting the wall “split [his] side open, fractured [his] pelvis in several places, jammed [his] left shoulder, and bruised the left side of [his] body including [his] left kidney.” Id. ¶ 6. Though his physical wounds “healed after several weeks,” Edman still has “mobility issues with [his] left shoulder and left hip, hearing loss and tinnitus, and kidney issues.” Id. ¶ 10. Due to his injuries in the attack, Edman has received a 40% disability rating from the VA. Id. ¶ 10; id., Att. (VA Rating Decision, no date), ECF No. 50 at 31; id., Att. (VA Rating Decision, dated Jan. 4, 2005), ECF No. 50 at 32; see also id., Att. (medical records), ECF No. 50 at 12–27. In addition to the physical trauma that Edman incurred, he suffers from PTSD-like symptoms, including lack of sleep and other trauma. Id. ¶¶ 12–14. These issues have “persisted for over twenty years.” Id. ¶ 13. Edman was awarded the Purple Heart for the injuries he sustained. Id. ¶ 9; id., Att. (Purple Heart Certificate, dated July 2, 1996), ECF No. 50 at 29. Edman’s wife, Elizabeth Edman, is a plaintiff in this lawsuit. She was at home with her children watching the news when they saw a report of the bombings, and she had the “overriding impulse” to hide the news from her children. Decl. of Elizabeth Edman (“Elizabeth Edman Decl.”) (Oct. 5, 2018) ¶ 5, ECF No. 50 (sealed), ECF No. 183 (public). Edman’s wife received an initial phone call from the squadron an hour after the news report informing her to “sit tight” as they learned more. Id. ¶ 6. After hours passed, she called to ask for news of her husband and was informed “his name was not on any of their three lists (injured, deceased, or okay).” Id. Finally, thirteen hours later, she received a call that he was in a hospital. Id. As a result of the attack, Elizabeth has suffered “emotional distress that also has physical manifestations.” Id. ¶ 7. 18 She is “highly anxious” and has an “extreme fear of bad news,” and additionally has “extreme guilt” that Edman returned home, while other wives’ husbands did not. Id. ¶ 8. In addition to the anxiety and guilt, Elizabeth “still cannot think or talk about Khobar Towers without crying.” Id. ¶ 9. The attack has “robbed [her husband] of spontaneous joy, left [her] anxiety ridden, and has cast a sorrow and sadness upon both of [them] that still lasts twenty-one years later.” Id. ¶ 10. 8. Christopher A. Freeman On June 25, 1996, Christopher Freeman was a First Lieutenant in the U.S. Air Force deployed to Saudi Arabia, stationed at Khobar Towers in Dhahran, Saudi Arabia. Decl. of Christopher A. Freeman (“Freeman Decl.”) (Oct. 12, 2018) ¶ 3, ECF No. 51 (sealed), ECF No. 187 (public). Freeman was located two buildings back from the site of the explosion. Id. ¶ 4. The force of the explosion “threw [him] against the wall and knocked [him] out.” Id. ¶ 5. The force of the explosion broke glass which caused him to suffer multiple lacerations. Id. He was rendered unconscious and suffered from a concussion. Id. He was taken to a makeshift hospital where he received five stitches to stop the “continuous blood flow.” Id. Freeman received the Purple Heart for his injuries. Id. ¶ 6; id., Att. (Special Order GB-458, dated Aug. 5, 1996), ECF No. 51 at 4. 9. Michael W. Goff On June 25, 1996, Michael W. Goff was a Technical Sergeant in the U.S. Air Force deployed to Saudi Arabia, stationed at Khobar Towers in Dhahran, Saudi Arabia. Decl. of Michael W. Goff (“Goff Decl.”) (Sept. 6, 2018) ¶ 3, ECF No. 55 (sealed), ECF No. 190 (public). Goff was in bed at the time of the attack, and felt the “sharp sting and burning sensation” from the glass from his window when the explosion occurred. Id. ¶ 4. Immediately after the 19 explosion, Goff ran out of his suite to check on the safety of others. Id. He was directed to an injured airman who was “lying in a puddle of blood and in a lot of pain.” Id. ¶ 5. Goff applied towels to his wounds to stop the bleeding and directed the remaining service members to evacuate and bring a stretcher back. Id. As a result, Goff was left alone in the building with the airman, where they could “hear wall lockers fall, electricity arcing, and water running from broken pipes.” Id. ¶ 5. While tending to the airman, Goff watched as a “paint crack [grew] into a crack an inch wide” and thought the building would collapse underneath them. Id. No stretcher came, and Goff and three others carried the injured member out on a bed comforter. Id. While carrying him out, Goff slipped twice, injuring his lower back. Id. Goff then worked with his commander to compile a list of missing personnel, which he then read to the squadron. Id. ¶ 6. While doing so he “had to look into the eyes” of the squadron who were looking to him for “help in understanding what had just happened.” Id. ¶ 6. Goff then went to the morgue to help identify bodies, something that has “haunted” him ever since. Id. ¶ 13. At the morgue, Goff saw things that he “never thought could happen to the human body.” Id. ¶ 8. As a result of the attack, Goff suffers from PTSD, id. ¶¶ 9–10, 13, which has affected his emotional state and ability to be in closed spaces, such as elevators, id. ¶ 9. The VA has rated Goff as 60% disabled because of the attack at Khobar Towers. Id. ¶ 13; id., Att. (Letter from VA, dated Dec. 14, 2017), ECF No. 55 at 11; id., Att. (VA Rating Decision, dated July 9, 2007), ECF No. 55 at 12– 13. Goff was awarded the Purple Heart and Air Force Commendation Medal for wounds he received during the attack. Id. ¶ 12; id., Att. (Purple Heart Certificate, undated), ECF No. 55 at 7; id., Att. (Certificate of Release or Discharge from Active Duty, confirming medals), ECF No. 55 at 8; id., Att. (Citation to Accompany the Award of Air Force Commendation Medal), ECF No. 55 at 10. 20 10. Rudolph Grimm On June 25, 1996, Rudolph Grimm II was a Staff Sergeant in the U.S. Air Force deployed to Saudi Arabia, stationed at Khobar Towers in Dhahran, Saudi Arabia. Decl. of Rudolph Grimm II (“Grimm Decl.”) (Sept. 16, 2018) ¶ 3, ECF No. 56 (sealed), ECF No. 192 (public). When the attack occurred, Grimm was sitting on a chair in the medical building, and the “next thing [he] knew [he] was lying on the floor covered in glass and debris.” Id. ¶ 4. Grimm evacuated the building and began triage immediately, helping other injured airmen. Id. While performing CPR on a non-responsive airman, Grimm noticed that he “had a large shard of glass sticking out of [his own] left hand.” Id. ¶ 5. By performing CPR, he had unintentionally pushed it in further. Id. Grimm removed the shard before resuming the aid. Id. After four hours, Grimm was seen for the lacerations on his body, including the glass in his eyes. Id. ¶ 6. After flushing out his eyes, Grimm assisted in relocating the deceased airmen to the temporary morgue. Id. ¶ 7. Upon return to the United States, Grimm was diagnosed with PTSD that “changed [his] life forever.” Id. ¶¶ 9, 11. “Sights, sounds, and even smells trigger [his] PTSD.” Id. ¶ 11. As a result of the attacks, Grimm was awarded the Purple Heart and the VA has rated Grimm 70% disabled, 30% attributable to his PTSD. Id. ¶¶ 10–12; id., Att. (Purple Heart Certificate, dated Aug. 6, 1996), ECF No. 56 at 9; id., Att. (VA Rating Decision, dated Apr. 24, 2007), ECF No. 56 at 6–8. For his actions during the Khobar Towers bombing, Grimm was awarded the Air Force Commendation Medal. Id. ¶ 12; id., Att. (Air Force Commendation Medal Certificate, dated Dec. 2, 1996), ECF No. 56 at 12. 11. Shawn K. Hale On June 25, 1996, Shawn K. Hale was an Airman First Class in the U.S. Air Force deployed to Saudi Arabia, stationed at Khobar Towers in Dhahran, Saudi Arabia. Decl. of 21 Shawn K. Hale (“Hale Decl.”) (Nov. 30, 2018) ¶ 3, ECF No. 57 (sealed), ECF No. 193 (public). Hale was watching TV when the explosion shattered the sliding glass door to his left. Id. ¶ 4. The explosion sent shrapnel into the room, hitting Hale in the face and in his right eye. Id. This laceration “caused corneal damage, along with retina and lens damage” such that he is now virtually blind in his right eye. Id. Hale was escorted out of the building and to the clinic where he could “hear yelling, crying, and sounds of people moving around [him].” Id. ¶ 5. Hale was then taken by ambulance to a hospital where he had the first surgery to remove the shards of glass from his eye. Id. ¶ 6. He had additional surgery when he was transported to Germany, and again in the District of Columbia to replace the lens that was ruptured from the glass. Id. ¶¶ 7–8. In total, Hale has had five surgeries in an attempt to rectify his injuries sustained at Khobar Towers. Id. ¶ 12. His left eye has started to be affected by “a heavier load trying to compensate” for the loss of vision to his right eye. Id. ¶ 4. The injury has “affected [his] life tremendously” as Hale is now forced to wear sunglasses anytime he is outside and has trouble driving at night and with depth perception. Id. ¶ 9. In addition to the physical trauma sustained by his eye, Hale suffers from PTSD that has made it difficult for him to be in certain locations. Id. ¶¶ 10–11. Due to the attack, the VA has given Hale a disability rating of 60%. Id. ¶ 10; id., Att. (Letter from VA, dated April 7, 2017), ECF No. 57 at 19; see also id., Att. (medical records), ECF No. 57 at 6–18. Hale received the Purple Heart for his injuries. Id. ¶ 13; id., Att. (Purple Heart Certificate, dated July 2, 1996), ECF No. 57 at 24. 12. Torrey S. Hardy On June 25, 1996, Torrey S. Hardy was an Airman First Class in the U.S. Air Force deployed to Saudi Arabia, stationed at Khobar Towers in Dhahran, Saudi Arabia. Decl. of Torrey S. Hardy (“Hardy Decl.”) (Sept. 21, 2018) ¶ 4, ECF No. 58 (sealed), ECF No. 194 22 (public). When the attack occurred, Hardy was cleaning the bathroom. Id. ¶ 5. Suddenly, Hardy felt a “tremendous force” and “a portion of the ceiling” fell on him. Id. The mirror in the bathroom shattered and pieces “went into [his] left knee.” Id. After the explosion, Hardy helped his Staff Sergeant evacuate other personnel. Id. ¶ 6. He realized then that the skin “on [his] left knee was hanging down and [he] could literally reach down and move [his] actual knee cap.” Id. Hardy “pulled the debris” from his left knee and wrapped a sock around the wound to slow the bleeding. Id. He continued to assist the injured until his leg gave out on him. Id. ¶ 7. Hardy was then transported to a hospital to have the glass removed from his back and feet. Id. ¶ 8. Hardy retains no feeling in his “left foot right over the top of [his] big toe” and attends physical therapy for both his knee and feet. Id. ¶ 10. Though given the option to retire, Hardy completed twenty years of service. Id. Hardy received the Purple Heart for his injuries. Id. ¶ 13; id., Att. (Purple Heart Certificate, dated Aug. 26, 1996), ECF No. 58 at 62; id., Att. (Certificate of Release or Discharge from Active Duty, confirming medal), ECF No. 58 at 8. Beyond physical injury, Hardy additionally suffers from PTSD, the effects of which persist to this day. Id. ¶ 15. Hardy has received a combined disability rating of 50% from the VA for service-related injuries. Id. ¶ 14; id., Att. (Letter from VA Regional Office, undated), ECF No. 58 at 65; see also id., Att. (medical records), ECF No. 58 at 9–61. 13. Michael J. Harner and Four Family Members On June 25, 1996, Michael J. Harner was a service member in the U.S. Air Force deployed to Saudi Arabia, stationed at Khobar Towers in Dhahran, Saudi Arabia. Decl. of Michael J. Harner (“Harner Decl.”) (Sept. 7, 2018) ¶ 4, ECF No. 59 (sealed), ECF No. 195 (public); see also Plaintiff Michael J. Harner’s Notice of Filing of Supplemental Declaration and Exhibit (Feb. 7, 2019), ECF No. 143 (sealed), ECF No. 196 (public). Harner had just finished a 23 run when he returned to his building, adjacent to the site of the bomb. Id. ¶ 5. Harner had just closed his sliding glass door when the explosion shattered the glass, shooting the pieces “into [his] body over [his] entire head and face, right arm, right shoulder and right leg.” Id. Harner had “a compelling need to exit [his] room” but could not until he stopped the bleeding to his “head and body, which took approximately ten to fifteen minutes.” Id. Harner then made his way to a stairwell where he was carried down six flights of stairs and transported to the triage area. Id. ¶ 6. After being stabilized with “an IV in each arm,” Harner was moved to a local hospital where surgery was performed to repair his wounds. Id. During this time, he was not spoken to in English and only had access to medical staff for twenty-four hours, causing him “severe anxiety with recurring nightmares and hypersensitivity to sounds, movements and personnel which was later diagnosed as PTSD.” Id. ¶¶ 6–7. Harner next was transported to Germany where he underwent further surgery on his “face, head, ear and shoulder.” Id. ¶ 8. The physical injuries sustained by Harner “have been everlasting,” and he continues to have “no feeling in [his] right leg causing [him] to have less strength [than] normal.” Id. ¶ 10. He continues to have “glass ejected through [his] skin” as a result of his head trauma, and the forehead scar tissue he has built up “severely hurts every time it is bumped, even after twenty- two years.” Id. The attack has also caused “severe emotional distress” and PTSD. Id. ¶¶ 11–12; id., Att. (medical records), ECF No. 59 at 7–22. Harner received the Purple Heart for his injuries. Id. ¶ 4; id., Att. (Purple Heart Certificate, dated July 2, 1996), ECF No. 59 at 6. Harner continued to serve in the Air Force, until January 1, 2019, despite the “severe emotional distress and life-long physical injuries that [] limit [his] full capabilities.” Id. ¶ 12. Harner has received a combined disability rating of 90% from the VA for service-related injuries. See Supp. Decl. of 24 Pl. Michael J. Harner (“Harner Supp. Decl.”) ¶ 6, ECF No. 143-1; id., Att. (VA Benefits Decision Letter, dated Jan. 17, 2019), ECF No. 143-1 at 3–22. Four of Harner’s family members are plaintiffs in this lawsuit: his wife, Julia N. Harner; his mother, Nancy Harner; his father, James Harner; and his sister, Michelle Caldwell. On the morning of June 26, 1996, Harner’s wife received a call from her mother-in-law informing her of the attack on her husband’s complex. Decl. of Julia N. Harner (“Julia Harner Decl.”) (Oct. 30, 2018) ¶ 5, ECF No. 59 (sealed), ECF No. 195 (public). At the time, Julia “didn’t realize that ‘Khobar Towers’ was a whole complex” and instead thought that “it was just two high rises that [her] husband lived and worked in.” Id. Julia thought that “the likelihood of him being dead or injured was very high.” Id. She attempted to call to receive more information, but “was not able to get any answers.” Id. Her mother-in-law finally received a call that Harner was alive but injured. Id. When Harner returned home, Julia assisted Harner with his recuperation and had to “pack and unpack his leg with gauze, since part of it could not be closed surgically.” Id. ¶ 6. Julia had to live through a second terrorist attack when her husband was in the Pentagon on 9/11. Id. ¶ 8. Each of Harner’s deployments have been stressful for Julia who has needed therapy “to cope.” Id. Even now, certain situations “can bring all of the emotional turmoil back to the surface” for Julia. Id. Harner’s mother, Nancy Harner, was watching the news with her family while eating dinner when she learned of the bombing at Khobar Towers. Decl. of Nancy S. Harner (“Nancy Harner Decl.”) (Sept. 7, 2018) ¶¶ 4–5, ECF No. 59 (sealed), ECF No. 195 (public). “The horror and grief [she] felt thinking [she] had lost [her] only son, or that he was wounded and [she] could not help, was overwhelming.” Id. ¶ 5. Nancy tried “for hours” to get information until she received a call from someone who said that they “had held [Nancy’s] gravely wounded son until 25 an ambulance came, and that he had lost a lot of blood.” Id. Nancy then saw her son’s “bandaged and bruised face on CNN.” Id. For weeks after the attack, Nancy “could not sleep nor work” and her “hair turned snow white along [her] temples and forehead.” Id. Harner’s transition home has been tough for Nancy, who felt like “he was not himself” which caused her to feel “powerless and vulnerable.” Id. ¶ 6. Harner’s father, James O. Harner, was watching the news with family while eating dinner when he learned of the bombing at Khobar Towers. Decl. of James O. Harner (“James Harner Decl.”) (Sept. 7, 2018) ¶¶ 4–5, ECF No. 59 (sealed), ECF No. 195 (public). He could not get through for information on the phone and “felt like there was no hope.” Id. ¶ 5. Hours later, a nurse called to inform them that Harner was “seriously hurt” and “it sounded like he may not survive.” Id. ¶ 6. James would not be reunited with his son for days “because of the distance and the mass confusion of the transport.” Id. The attack on his son has caused James to be “unable to sleep and [to suffer] from insomnia.” Id. ¶ 7. James felt responsible for the injuries that Harner suffered as he “encouraged him to join the military.” Id. ¶ 8. James’ relationship with his son has changed, “not for the better because of the attack” and finds himself constantly worrying “that something might happen to him.” Id. Harner’s sister, Michelle Caldwell, first learned of the attack from a news report as she ate dinner with her family. Decl. of Michelle A. Caldwell (“Caldwell Decl.”) (Sept. 7, 2018) ¶¶ 4, 6, ECF No. 59 (sealed), ECF No. 195 (public). Michelle was informed hours later that her brother “was alive, but had lost a lot of blood and had severe head and leg injuries.” Id. ¶ 7. As a result of the attack on her brother, Michelle experiences “extreme grief and distress,” id. ¶¶ 5, 9, and avoids certain locations. 14. Gregory R. Hedglin 26 On June 25, 1996, Gregory Richard Hedglin was a Staff Sergeant in the U.S. Air Force deployed to Saudi Arabia, stationed at Khobar Towers in Dhahran, Saudi Arabia. Decl. of Gregory Richard Hedglin (“Hedglin Decl.”) (Nov. 8, 2018) ¶ 3, ECF No. 60 (sealed), ECF No. 197 (public). Hedglin was sitting next to a sliding glass door on his patio when he saw “a very bright white light.” Id. ¶ 4. The explosion knocked out the lights and Hedglin was left in darkness, and then “felt liquid on [his] face and throat. [He] could smell and taste blood.” Id. After evacuating the building with two other service members, he checked himself once he got outside and realized that his “tee shirt was soaked in blood” and he “wrapped [his neck] with a tee shirt someone gave [him].” Id. ¶¶ 4–5. He was moved to the triage area, and then to the hospital to be treated for wounds on his face, neck, right arm and leg. Id. ¶ 5. Hedglin underwent surgery for “life threatening wounds” as his “external jugular was nicked” and was hemorrhaging. Id. ¶ 6. Hedghlin’s right ear drum was also perforated. Id. Hedglin also suffers from PTSD from the attack and this condition “[impedes him] from enjoying a normal life.” Id. ¶ 7; id., Att. (medical records), ECF No. 60 at 10. He received the Purple Heart for his injuries. Id. ¶ 8; id., Att. (Purple Heart Certificate, dated July 2, 1996), ECF No. 60 at 11; id., Att. (Certificate of Release or Discharge from Active Duty, confirming medal), ECF No. 60 at 5. As a result of the injuries received during the attack, Hedglin received a 20% disability rating from the VA. Id. ¶ 6; id., Att. (Letter from VA Regional Office, Oct. 21, 2002), ECF No. 60 at 7–8. 15. David P. Jordan and One Family Member On June 25, 1996, David P. Jordan was a service member in the U.S. Air Force deployed to Saudi Arabia, stationed at Khobar Towers in Dhahran, Saudi Arabia. Decl. of David P. Jordan (“Jordan Decl.”) (filed Dec. 28, 2018) ¶ 4, ECF No. 61 (sealed), ECF No. 203 (public). The force of the explosion threw him against the wall, knocking him unconscious. Id. ¶ 5. When 27 Jordan “came to” he was “covered in broken glass with multiple lacerations and cuts on [his] legs, arms, and head.” Id. Jordan was treated at the clinic at Khobar Towers, where they bandaged his wounds. Id. ¶ 6. Jordan has “developed PTSD from the blast,” along with associated issues. Id. ¶ 7. Jordan’s wife, Ruth Gordon, is a plaintiff in this lawsuit. On June 25, 1996, his wife learned of the attack when her brother-in-law called to inform her. Decl. of Ruth A. Jordan (“Ruth Jordan Decl.”) (Sept. 20, 2018) ¶ 5, ECF No. 61 (sealed), ECF No. 203 (public). After she learned of the attack, “it took the base two days to let [her] know [Jordan] was not among the dead.” Id. Since the attack, Jordan’s “quality of life changed dramatically” and the “situation has been difficult to handle” for his wife. Id. ¶ 6. As a result of the attack, she has “endured extreme mental pain, suffering, grief and anguish, and sustained emotional injury and loss.” Id. ¶ 7. 16. Patrick Kick On June 25, 1996, Patrick H. Kick was a Senior Airman in the U.S. Air Force deployed to Saudi Arabia, stationed at Khobar Towers in Dhahran, Saudi Arabia. Decl. of Patrick H. Kick (“Kick Decl.”) (Sept. 10, 2018) ¶ 3, ECF No. 62 (sealed), ECF No. 204 (public). Kick had just finished a run at the time of the explosion. Id. ¶ 4. Immediately after the explosion, and even though Kick was injured in the attack, receiving cuts and lacerations to both legs, hands, and arms, he cleaned his own wounds “and responded to the bomb site” and “assisted with pulling comrades out, [and] secured the deceased.” Id. Kick was then tasked to provide “personal security for the on-site commander and task force.” Id. Kick suffers from dizziness “that last[s] up to two weeks at a time and happens a few times a year, headaches, sinusitis, and fatigue.” Id. ¶ 5. Kick additionally suffers from PTSD which, in addition to other symptoms, makes it hard 28 for him to visit “[c]rowded areas” and hear loud noises. Id. ¶ 8. Kick has received a 30% disability rating from the VA as a result of the attack on Khobar Towers. Id. ¶ 7; id., Att. (Letter from VA, dated Sept. 5, 2017), ECF No. 62 at 10; see also id., Att. (medical records), ECF No. 62 at 11–12. Kick was awarded both an Air Force Commendation Medal and the Purple Heart. Id. ¶¶ 6, 11; id., Att. (Air Force Commendation Medal Certificate, dated Jan. 14, 1997), ECF No. 62 at 13; id., Att. (Purple Heart Certificate, dated May 13, 1999), ECF No. 62 at 7; id., Att. (Certificate of Release or Discharge from Active Duty, confirming medals), ECF No. 62 at 5. 17. Willard A. Brewster On June 25, 1996, Willard A. Brewster was a service member in the U.S. Air Force deployed to Saudi Arabia, stationed at Khobar Towers in Dhahran, Saudi Arabia. Decl. of Willard A. Brewster (“Brewster Decl.”) (Sept. 12, 2018) ¶ 3, ECF No. 63 (sealed), ECF No. 158 (public). Brewster had his back to a large window in the building adjacent to the explosion. Id. ¶ 4. “The force of the blast propelled [him] into the opposite concrete wall.” Id. Brewster was knocked unconscious, and when he woke up he tried to make his way out of the building. Id. ¶¶ 4–5. He was stopped and advised “not to move [his] left arm too much,” as he had a “substantial open wound” on his left elbow, with “severed tendons.” Id. ¶ 5. He was triaged in a parking lot, and then had surgery in a Saudi Arabian hospital. Id. Brewster continues to experience pain in his elbow during cold weather. Id. In addition to physical injury, Brewster suffers from PTSD as a result of the attack. Id. ¶ 9. His PTSD causes him to have nightmares, sleepless nights, and high anxiety “whenever there are sudden noises.” Id. The VA has given Brewster a disability rating of 90% because of injuries suffered during the attack. Id.; id., Att. (VA Rating Decision, dated March 17, 2015), ECF No. 61 at 32–52; see also id., Att. (medical records), ECF No. 61 at 29 8–27. Brewster received the Purple Heart for his injuries. Id. ¶ 7; id., Att. (Purple Heart Certificate, dated July 2, 1996), ECF No. 61 at 28. 18. Randy W. Hooker On June 25, 1996, Randy W. Hooker was an Airman First Class in the U.S. Air Force deployed to Saudi Arabia, stationed at Khobar Towers in Dhahran, Saudi Arabia. Decl. of Randy W. Hooker (“Hooker Decl.”) (Sept. 6, 2018) ¶ 3, ECF No. 64 (sealed), ECF No. 198 (public). Hooker was walking back to the barracks when a large flash of light happened, followed by “an immense amount of pressure and deafening noise” that knocked him to the ground. Id. ¶¶ 4–5. Hooker entered Building 131, the site of the blast, to rescue the wounded. Id. ¶ 6. On one of “multiple trips to the upper floors,” Hooker provided self-aid and buddy care to an airman who had been “impaled by debris in his chest and abdomen.” Id. ¶¶ 6–7. After evacuating the injured airmen, Hooker returned to make “several more trips into the building and [assist] where [he] could.” Id. ¶ 7. “Some of the airmen [they] found had already died from bleeding out or being crushed by debris. Others were severely disfigured by flying debris or were impaled by other objects.” Id. Hooker then was transported to the makeshift trauma area where he was treated for injuries to his left knee and right wrist and the lacerations on his arms. Id. ¶ 8. As a result of the attack, Hooker suffers from PTSD. Id. ¶ 10. Just to be able to sleep, Hooker has to take medication “due to vivid dreams of the events from the night of the bombing.” Id. Hooker additionally suffers from flashbacks and does not feel comfortable in crowds. Id. ¶¶ 11–12. Hooker finds it hard to trust people and can “easily detach from people.” Id. ¶ 13. He has received a disability rating of 60% from the VA for injuries sustained during the attack. Id. ¶ 14; id., Att. (VA Rating Decision, dated May 7, 2018), ECF No. 64 at 7. Hooker was awarded the Purple Heart and an Air Force Commendation Medal. Id. ¶ 15; id., Att. (Purple 30 Heart Certificate, dated Aug. 8, 1996), ECF No. 64 at 9; id., Att. (Air Force Commendation Medal Certificate, dated June 26, 1996), ECF No. 64 at 10; id., Att. (Certificate of Release or Discharge from Active Duty, confirming medals), ECF No. 64 at 6. 19. Stephen K. Johnson and Three Family Members On June 25, 1996, Stephen K. Johnson was a Staff Sergeant in the U.S. Air Force deployed to Saudi Arabia, stationed at Khobar Towers in Dhahran, Saudi Arabia. Decl. of Stephen K. Johnson (“Johnson Decl.”) (Sept. 10, 2018) ¶ 4, ECF No. 65 (sealed), ECF No. 202 (public). Johnson was in his bedroom at the time of the attack, and the blast knocked him unconscious for “fifteen to twenty minutes,” until he was found by fellow residents in the building and taken to the triage area where he was tested for a concussion. Id. ¶¶ 5–6. Though Johnson had a traumatic brain injury, he then helped to evacuate other victims. Id. ¶ 6. When Johnson returned to the United States, he developed symptoms of anxiety and was diagnosed with generalized anxiety disorder, including avoiding loud noises and crowds. Id. ¶¶ 8, 10. As a result of the attack, the VA has assigned Johnson a disability rating of 50%. Id. ¶ 9; id., Att. (Letter from VA, dated June 27, 2018), ECF No. 65 at 24–25; see also id., Att. (medical records), ECF No. 65 at 13–23. Johnson was awarded the Purple Heart and the Air Force Achievement Medal for his injuries. Id. ¶ 11; id., Att. (Purple Heart Certificate, dated Aug. 7, 1996), ECF No. 65 at 26; id., Att. (Air Force Commendation Medal Certificate, dated Nov. 26, 1996), ECF No. 65 at 28; id., Att. (Certificate of Release or Discharge from Active Duty, confirming medals), ECF No. 65 at 6. Three of Johnson’s family members are plaintiffs in this lawsuit: his wife, Jessica Jordan; and his two sons, Stephen Johnson II, and Ryan Johnson. Johnson’s wife learned of the attack while watching CNN, Decl. of Jessica D. Johnson (“Jessica Johnson Decl.”) (Oct. 29, 2018) ¶¶ 31 4–5, ECF No. 65 (sealed), ECF No. 202 (public), and she contacted the squadron, “who advised they had no idea about the attack,” id. ¶ 5. She was “terrified [her] husband may have died in the attack.” Id. She received a very brief call from Johnson, enough for him to say “I’m alive. I love you, goodbye,” but she did not learn that he was injured until she spoke to him again two weeks later. Id. ¶ 6. When Johnson returned home, his wife “immediately noticed that he was no longer focused, easily distracted, and always staring off into space.” Id. ¶ 7. She feels that Johnson has “abandoned the family mentally, physically and emotionally as a direct or indirect result of the Khobar Towers attack,” id. ¶ 9, and as a result, she experiences extreme grief and distress due to the injuries to her husband, id. ¶¶ 10–11. Stephen Johnson was six years old at the time of the attack, Decl. of Stephen K. Johnson II (“Stephen Johnson Decl.”) (Sept. 10, 2018) ¶¶ 4–5, ECF No. 65 (sealed), ECF No. 202 (public), and remembers “feeling very scared for [his] father, who [he] had not seen for a month” and being scared for his mother who was “juggling taking care of him and [his] one-year old brother.” Id. ¶ 5. Stephen Johnson experiences “extreme grief and distress” as a result of the injuries to his father. Id. ¶ 7. Ryan Johnson “experienced and continue[s] to experience, extreme grief and distress as a result of the injuries to [his] father.” Decl. of Ryan W. Johnson (“Ryan Johnson Decl.”) (Oct. 31, 2018) ¶¶ 4, 6, ECF No. 65 (sealed), ECF No. 202 (public). He has “grown up with a father who has anxiety issues” which led Ryan Johnson to be “anxious and apprehensive as well, particularly when around him.” Id. ¶ 6. 20. Dana S. Rozelle On June 25, 1996, Dana Rozelle was a service member in the U.S. Air Force deployed to Saudi Arabia, stationed at Khobar Towers in Dhahran, Saudi Arabia. Decl. of Dana S. Rozelle 32 (“Rozelle Decl.”) (Nov. 8, 2018) ¶ 3, ECF No. 80 (sealed), ECF No. 226 (public). Rozelle was preparing for a college final at the time that the blast occurred. Id. ¶ 4. “All of a sudden there was this horrendous roar and stuff flying at [her].” Id. Rozelle noticed that her “windows were missing and the metal shades that covered the windows were on [her] nightstand.” Id. She began to exit the room, but returned to grab a pair of shoes and towels for an injured airman. Id. ¶ 5. Rozelle then assisted in searching other suites to make sure other airmen were not trapped. Id. “[She] had to crawl under and over doors that were blown off the hinges and other debris blown around in the rooms.” Id. When she was outside helping to bring bedding and water from the orderly room, Rozelle saw “a huge orange fireball along the fence,” and a panic ensued because it was believed that insurgents were climbing the fence. Id. ¶ 6. She fled to the dining hall, which was so full of injured people that “[y]ou had to step over them to move about.” Id. ¶ 7. As a result of the attack on Khobar Towers, Rozelle suffered from hearing loss, multiple lacerations and bruises, and trauma to her extremities. Id. ¶ 10. She additionally has developed PTSD, which causes her to “get angry easily” and become “very anxious in crowds and heavy traffic.” Id. ¶ 11. Rozelle has had panic attacks brought on by “a flash of lightening and a clap of thunder.” Id. She attended therapy for her PTSD for a short time. Id. ¶ 13. The VA has given Rozelle a combined 70% disability rating, 50% for her PTSD, 10% for tinnitus, and 20% for shoulder issues. Id. ¶ 13; id., Att. (Letter from VA Regional Office, dated Aug. 13, 2012), ECF No. 80 at 16–18; id., Att. (VA Rating Decision, dated Aug. 8, 2012), ECF No. 80 at 22–26; see also id., Att. (medical records), ECF No. 80 at 11–13. Rozelle was awarded the Purple Heart for her injuries. Id. ¶ 14; id., Att. (Purple Heart Certificate, dated Aug. 26, 1996), ECF No. 80 at 27; id., Att. (Certificate of Release or Discharge from Active Duty, confirming medal), ECF No. 80 at 9. 33 21. Joseph D. Stroud On June 25, 1996, Joseph D. Stroud was a Senior Airman in the U.S. Air Force deployed to Saudi Arabia, stationed at Khobar Towers in Dhahran, Saudi Arabia. Decl. of Joseph D. Stroud (“Stroud Decl.”) (Dec. 27, 2018) ¶ 3, ECF No. 81 (sealed), ECF No. 239 (public). Stroud was shaving in his bathroom when he “heard a loud gust of wind and doors slamming, then felt the explosion.” Id. ¶ 4. The broken end of a coat hook on the door penetrated his shoulder and the door pinned him to the floor. Id. Stroud was able to exit the bathroom and found his roommate “badly injured and barely conscious.” Id. ¶ 5. He picked him up and carried him down two flights of stairs and “what must have been two or three city blocks” to the clinic. Id. Stroud then went back to the building to find his other roommate and help sweep the building. Id. ¶¶ 5–6. Stroud returned to the clinic where he helped carry the injured and mop blood until his own injuries were noticed. Id. ¶ 7. Stroud was sent to the makeshift hospital in the dining hall, where he was told that they were low on Novocain and asked if he could be stitched up without it. Id. The attack on Khobar Towers has left Stroud with “severe back pain” that he has endured for years and he has even been told that there “may still be glass shards on [his] spine.” Id. ¶ 8. In addition to physical injury, Stroud has suffered from severe depression, which he has attempted to self-medicate with alcohol. Id. ¶ 10; see also id., Att. (medical records), ECF No. 81 at 6. Stroud received the Purple Heart for his injuries. Id. ¶ 9; id., Att. (Purple Heart Certificate, dated Aug. 8, 1996), ECF No. 81 at 7; id., Att. (Certificate of Release or Discharge from Active Duty, confirming medals), ECF No. 81 at 5. 22. Kenneth L. Sturdivant On June 25, 1996, Kenneth L. Sturdivant was a Master Sergeant in the U.S. Air Force deployed to Saudi Arabia, stationed at Khobar Towers in Dhahran, Saudi Arabia. Decl. of 34 Kenneth L. Sturdivant (“Sturdivant Decl.”) (Sept. 20, 2018) ¶ 3, ECF No. 82 (sealed), ECF No. 240 (public). Sturdivant was getting ready for bed and was about to turn out his lights when he “heard a loud explosion, which caused [him] to be disoriented.” Id. ¶ 4. Sturdivant gathered himself and began to help people evacuate the building. Id. His commander then told him that he was bleeding, and he found that he had glass fragments in his leg. Id. The attack resulted in Sturdivant sustaining multiple lacerations and glass shrapnel wounds on both of his legs. Id. ¶ 5. In addition to these physical injuries, Sturdivant now suffers from PTSD as a result of the attack, which “changed [his] life forever.” Id. ¶¶ 8–9. The VA has assigned Sturdivant a disability rating of 20% from the bombing. Id. ¶ 7; id., Att. (Letter from VA, dated Dec. 26, 2013), ECF No. 82 at 7. Sturdivant received the Purple Heart for his injuries. Id. ¶ 10; id., Att. (Purple Heart Certificate, dated Aug. 8, 1996), ECF No. 82 at 8; id., Att. (Certificate of Release or Discharge from Active Duty, confirming medal), ECF No. 82 at 5. 23. Bryan D. Scott and Four Family Members On June 25, 1996, Bryan Scott was a Senior Airman in the U.S. Air Force deployed to Saudi Arabia, stationed at Khobar Towers in Dhahran, Saudi Arabia. Decl. of Bryan Scott (“Scott Decl.”) (Sept. 25, 2018) ¶ 4, ECF No. 84 (sealed), ECF No. 234 (public). At the time of the explosion, Scott was standing five feet from a large sliding glass door. Id. ¶ 5. The force of the explosion threw him twenty feet across the room, head first into a concrete wall. Id. “When [he] woke up, [he] had glass shards throughout [his] body.” Id. Scott got up and helped to carry another injured service member out of the building on a blanket. Id. Once outside, Scott realized that his wounds were worse than he thought, and used a shirt to staunch the bleeding from his head, arms, legs and body. Id. ¶ 6. Scott has had significant and severe back issues since returning from deployment. Id. ¶ 7. Scott saw a chiropractor at least three times a week 35 for thirteen years until “[e]ventually [he] had back surgery to try to ease the pain. When the doctor performed the surgery, it was worse than he thought.” Id. Even after his back surgery, Scott is still in daily pain and is unable to “run, or play sports.” Id. ¶ 8. The VA has assigned a disability rating of 60% to Scott in connection with the Khobar Towers attack. Id., Att. (Letter from VA, dated July 4, 2018), ECF No. 84 at 84–85; cf. id. ¶ 9 (stating that service member plaintiff’s VA disability rating is 70%, but without supporting documentation); see also id., Att. (medical records), ECF No. 84 at 7–83. Scott received the Purple Heart for his injuries. Id. ¶ 12; id., Att. (Purple Heart Certificate, dated Aug. 26, 1996), ECF No. 84 at 86; id., Att. (Certificate of Release or Discharge from Active Duty, confirming medals), ECF No. 84 at 5–6. Four of Scott’s family members are plaintiffs in this lawsuit: his mother, Connie Sturgill; his father, Michael Scott; and his two brothers, Michael Scott II, and Jonathan Scott. On the day of the attack, Scott’s mother, Connie Sturgill, had just returned home from a shift as a surgical nurse when she received a call from a friend of her son asking if she had heard from him since the attack. Decl. of Connie Sturgill (“Sturgill Decl.”) (Dec. 27, 2018) ¶¶ 4–5, ECF No. 84 (sealed), ECF No. 234 (public). “There are no words to even begin to describe the numb anguish, hollow panic [she] felt, not knowing if [her] son was dead or alive.” Id. ¶ 6. Sturgill called various numbers but was unable to receive any information about the bombing. Id. In the afternoon of the next day, Sturgill finally received a call from Scott stating that he was alive and safe. Id. ¶ 8. Though her “son’s return home was joyous,” Sturgill suffered and continues to suffer extreme grief and distress as result of the attack. Id. ¶¶ 9, 11. Sturgill has supported Scott, and has even taken off work to care for him while he recovered from surgery. Id. ¶ 10. After Scott’s father, Michael G. Scott, learned that his son “was wounded from the attack, [he] was concerned because [he] could not contact him and find out the extent of his injuries.” 36 Decl. of Michael G. Scott (“Michael G. Scott Decl.”) (Dec. 27, 2018) ¶¶ 4–5, ECF No. 84 (sealed), ECF No. 234 (public). Scott was reunited with his son after six months and found it “extremely painful” to wait to see his son in person to “judge his recovery condition.” Id. ¶ 6. As a result of the attack, Scott experiences “extreme grief and distress.” Id. ¶ 7. Scott’s brother, Michael, first learned about the attack from one of Scott’s friends. Decl. of Michael Scott II (“Michael Scott II Decl.”) (Sept. 11, 2018) ¶ 5, ECF No. 84 (sealed), ECF No. 234 (public). They did not have any news of whether Scott had survived until he was able to call their mother to say that he was alive. Id. ¶ 7. “During that time, each of [them] suffered painfully not knowing what the outcome was going to be for him, and how it would change [their] family.” Id. ¶ 5. This “uncertainty affected [Michael Scott’s] focus and job performance at work.” Id. ¶ 6. The attack on his brother has also “altered [his] mood, which affected [his] personal relationships.” Id. Since his brother’s return, Michael has “suffered mental anguish, experienced anger and aggression by watching him suffer.” Id. ¶ 8. Scott’s other brother, Jonathan, learned from his mother that his brother was at the site of the bombing. Decl. of Jonathan L. Scott (“Jonathan Scott Decl.”) (Dec. 27, 2018) ¶¶ 4–5, ECF No. 84 (sealed), ECF No. 234 (public). “[They] didn’t hear from Bryan for almost a full day. As the hours got longer [they] all thought that the news was bad.” Id. ¶ 6. When Jonathan finally saw his brother get off the plane in Kentucky it was “like Christmas Day.” Id. ¶ 7. Jonathan decided to “postpone [his] career for a year to help him recover,” id. ¶ 8, but “it [has] been terrible” watching his brother struggle with his back injuries, “and even worse his behavior quirks since the attack,” id. ¶ 9. 24. Brian E. Volk 37 On June 25, 1996, Brian Volk was a Sergeant in the U.S. Air Force deployed to Saudi Arabia, stationed at Khobar Towers in Dhahran, Saudi Arabia. Decl. of Brian E. Volk (“Volk Decl.”) (Nov. 6, 2018) ¶ 3, ECF No. 85 (sealed), ECF No. 246 (public). Volk was preparing for work when the bomb went off. Id. ¶ 4. The force of the bomb caused the nearby sliding glass door to shatter and cover Volk and his friend with glass and metal. Id. “[They] flew into the concrete wall behind [them], and [he] was knocked unconscious for about 20 seconds.” Id. Volk woke up to a cut over his right eye, glass in his arm, and metal in his hip. Id. ¶ 5. Though his “ears were ringing” and his “eyes were full of blood,” Volk used his medical kit and headed towards the blast site to assist others. Id. ¶¶ 5–6. After Volk assisted in rescuing two service members, Volk was treated at the trauma center. Id. ¶¶ 6–7. As a result of the attack, Volk required surgery to repair a “torn right eyelid; [] approximately seven sutures on [his] right forearm; and one suture on the right eye.” Id. ¶ 8. The explosion has left Volk’s face “disfigured.” Id. Volk has additionally required a kidney transplant, and suffers from a brain ischemia. Id. ¶ 9. Besides physical injury, Volk has been diagnosed with PTSD. Id. ¶ 7. The VA has assigned Volk a combined disability rating of 100%. Id. ¶ 10; id., Att. (Letter from VA, dated July 8, 2018), ECF No. 85 at 40; id., Att. (VA Rating Decision, dated Jan. 27, 2014), ECF No. 85 at 34–39; see also id., Att. (medical records), ECF No. 85 at 6–33. Volk received the Purple Heart Award for his injuries. Id. ¶ 11; id., Att. (Purple Heart Certificate, dated Aug. 5, 1996), ECF No. 85 at 42. 25. Zachary S. Sutton On June 25, 1996, Zachary S. Sutton was a Senior Airman in the U.S. Air Force deployed to Saudi Arabia, stationed at Khobar Towers in Dhahran, Saudi Arabia. Decl. of Zachary S. Sutton (“Sutton Decl.”) (Sept. 21, 2018) ¶ 3, ECF No. 86 (sealed), ECF No. 241 (public). Sutton 38 was just falling asleep when the explosion threw him from his bed. Id. ¶ 4. Despite the fact that Sutton had received several cuts to his head and face, he remained on site to administer first aid and transport wounded service members to triage. Id. ¶¶ 4–5. Sutton then went to the triage area where he received sutures and had a piece of glass removed from his eye. Id. ¶ 5. Sutton now suffers from PTSD as a result of the attack, id. ¶ 6, and no longer goes out in public if there are crowds due to panic attacks, id. ¶ 7. Sutton has received a combined disability rating of 60% from the VA due to service-related injuries. Id. ¶ 6; id., Att. (Letter from VA, dated Dec. 12, 2016), ECF No. 86 at 14; see also id., Att. (medical records), ECF No. 86 at 7–8. Sutton received the Purple Heart and Air Force Commendation Medal. Id. ¶¶ 5, 8; id., Att. (Purple Heart Certificate, dated Aug. 26, 1996), ECF No. 86 at 9; id., Att. (Air Force Commendation Medal Certificate, dated Oct. 23, 1996), ECF No. 86 at 15–16; id., Att. (Certificate of Release or Discharge from Active Duty, confirming medals), ECF No. 86 at 5–6. 26. Clifford L. Thomas and Four Family Members On June 25, 1996, Clifford L. Thomas was a service member in the U.S. Air Force deployed to Saudi Arabia, stationed at Khobar Towers in Dhahran, Saudi Arabia. Decl. of Clifford L. Thomas (“Thomas Decl.”) (Oct. 23, 2018) ¶ 4, ECF No. 87 (sealed), ECF No. 242 (public). Thomas was in his bedroom when the explosion forced him into his wall locker which collapsed on him, knocking him unconscious. Id. ¶ 5. When he became conscious, Thomas made his way outside the building and was helped to his meeting place. Id. The explosion had caused multiple lacerations, shrapnel wounds from glass, and a concussion and traumatic brain injury. Id. Thomas was taken for treatment to King Fizel University Hospital, where he was hospitalized for the concussion for three days. Id. ¶¶ 5–6. In addition to physical injury, Thomas now suffers from PTSD from the attack, which condition has caused him “difficulty at home, at 39 work, and at all social functions.” Id. ¶ 7. The VA has assigned Thomas a 50% disability rating for his PTSD, and a combined disability rating of 100%. Id.; id., Att. (VA Rating Decision, undated), ECF No. 87 at 7–8; id., Att. (medical records), ECF No. 87 at 6. Thomas received the Purple Heart Award for his injuries. Id. ¶ 8; id., Att. (Certificate of Release or Discharge from Active Duty, confirming medal), ECF No. 87 at 5. Four of Thomas’ family members are plaintiffs in this lawsuit: his wife, Margaret Thomas; his daughter, Camilla Thomas-Harris; and his two sons, Cedrick Thomas and Adrian Thomas. Thomas’ wife, Margaret Thomas, was at a class when she received an “extremely disturbing” call from her children that their father was in the Khobar Towers attack. Decl. of Margaret L. Thomas (“Margaret Thomas Decl.”) (Sept. 10, 2018) ¶¶ 4–5, ECF No. 87 (sealed), ECF No. 242 (public). Her “children were screaming and crying, totally in fear and upset as they screamed that their father had been blown up in a bombing. They had heard a news report on the evening news.” Id. ¶ 5. She raced home to comfort her children and was in “total fear and heart- wrenching agony for at least twelve to eighteen hours, not knowing if [her] husband was alive or dead” until she received a call the next day from her husband’s First Sergeant. Id. She was told that he had been injured and was at an off-base hospital. Id. Once Thomas returned home, Margaret Thomas took care of her husband as she was not working that summer. Id. ¶ 6. The “psychological and emotional distress and memory” of the attack still affect Margaret Thomas to this day, and she has “suffered watching [her] husband suffer from the symptoms of PTSD.” Id. ¶ 7. Thomas’ daughter, Camilla Thomas-Harris, was fourteen years old at the time of the attack. Decl. of Camilla T. Thomas-Harris (“Camilla Thomas-Harris Decl.”) (Sept. 11, 2018) ¶¶ 4–5, ECF No. 87 (sealed), ECF No. 242 (public). Camilla was at home when a relative called to 40 tell her to turn on the news, where she saw the remnants of her father’s dorm after the bombing. Id. ¶ 5. This news was “traumatic” and she “immediately thought [her] father was dead.” Id. Her brother called to alert her mother, but they did not learn anything about their father for twelve to eighteen hours. Id. Once her father returned home, she “helped where [she] could” and helped her mother care for her father by “giving him his medication and [] proper wound care.” Id. ¶ 6. While most of her classmates “were preparing for their first year of high school, [she] was preparing and dealing with helping [her] father get back to normal, and learning how to cope with him having PTSD.” Id. She suffers from the effects of the “emotional and psychological distress” that the memory of the event has on her. Id. ¶ 7. Even now, when she “see[s] or hear[s] of a bombing or shooting, [she] regress[es] back to [her] experience from that evening in 1996.” Id. Thomas’ son, Cedrick Thomas, was sixteen years old at the time of the attack. Decl. of Cedrick C. Thomas (“Cedrick Thomas Decl.”) (Oct. 15, 2018) ¶¶ 4–5, ECF No. 87 (sealed), ECF No. 242 (public). Cedrick received a call from a relative that he should turn on the news, where he saw the bombed building in which his father was staying. Id. ¶ 5. Cedrick then had to call his mother and inform her of the news of the attack on Khobar Towers. Id. ¶ 6. “Experiencing her reaction by phone while managing [his] siblings’ reactions and, at the same time, believing [his] father had been killed made the situation the most emotionally fearful time in [his] life.” Id. Cedrick did not know that his father survived until eighteen hours later. Id. ¶ 5. Once his father was home, his father began displaying signs of PTSD. Id. ¶ 7. Cedrick has “continued to feel the effects of his [father’s] PTSD, even after [he] left home and began [his] own family well into [his] late twenties.” Id. He had to act “as an emotional care-giver” to both his mother and his 41 father. Id. ¶ 8. Having to “assist [his] parents in this manner proved to be difficult and stressful for [him].” Id. Thomas’ other son, Adrian Thomas, was twelve at the time of the attack. Decl. of Adrian D. Thomas (“Adrian Thomas Decl.”) (Sept. 20, 2018) ¶¶ 4–5, ECF No. 87 (sealed), ECF No. 242 (public). Once he saw the news report that there was a bombing at Khobar Towers, Adrian was “scared, crying, screaming and overtaken with grief.” Id. ¶ 5. He was in “total fear, heart- wrenching agony, and unprecedented grief for at least eighteen hours, not knowing the state of [his] father.” Id. The effects of the attack on his father have taken “many forms” in Adrian Thomas’ life, causing “severe anxiety” and other symptoms. Id. ¶ 8. The “traumatic experience” has been “life lasting” and is an “ongoing healing process” for Adrian Thomas. Id. ¶ 9. 27. Robert G. Siler On June 25, 1996, Robert G. Siler was a service member in the U.S. Air Force deployed to Saudi Arabia, stationed at Khobar Towers in Dhahran, Saudi Arabia. Decl. of Robert G. Siler (“Siler Decl.”) (Oct. 26, 2018) ¶ 3, ECF No. 88 (sealed), ECF No. 236 (public). Siler was asleep at the time of the attack and was woken by falling debris. Id. ¶ 4. He felt his way out of the room and accidentally stepped on his friend who was on the ground “wet with blood, but breathing.” Id. Siler instructed another service member to exit and carried his friend out of the building over his shoulder. Id. Once outside, he loaded his friend on a bus to be taken to triage. Id. ¶ 5. At triage, “personnel saw that [he] was covered in blood” and transferred Siler to a safe zone, where he was given pain medication. Id. ¶ 6. Siler would have to wait thirty-six hours before he was able to make a three-minute phone call to his family. Id. ¶ 7. As a result of the attack, Siler suffered from “a separated shoulder, [] a concussion, multiple lacerations, [] glass 42 shrapnel wounds to [his] head and body, black eyes, and facial bruising.” Id. ¶ 8. Siler continues to have “chronic pain and limited use of [his] shoulder.” Id. ¶ 10. The VA has given Siler a disability rating of 40% due to physical injuries. Id. ¶ 11; id., Att. (Letter from VA, dated July 29, 2014), ECF No. 88 at 19; see also id., Att. (medical records), ECF No. 88 at 6–18. In addition, Siler suffers from PTSD which causes him to have trouble sleeping, become “very jumpy” when startled, and “fearful.” Id. ¶ 11. Siler received the Purple Heart and the Air Force Achievement Medal. Id. ¶ 9; id., Att. (Certificate of Release or Discharge from Active Duty, confirming medals), ECF No. 88 at 5. 28. Leighton Reid and One Family Member On June 25, 1996, Leighton Reid was a service member in the U.S. Air Force deployed to Saudi Arabia, stationed at Khobar Towers in Dhahran, Saudi Arabia. Decl. of Leighton J. Reid (“Reid Decl.”) (Nov. 11, 2018) ¶ 4, ECF No. 89 (sealed), ECF No. 222 (public). Reid was taking a smoke break when he first noticed “a suspicious individual standing next to a vehicle parked on the grass” close to his building. Id. ¶ 5. Reid observed as the individual “flashed the headlights of the vehicle three times.” Id. A couple of minutes later, he heard “what [he] thought were three distinct rifle shots, that turned out to be the detonators on the explosive laden vehicle that was trying to back into building 131 next door.” Id. The force of the explosion slammed Reid into a metal desk, knocking him out briefly. Id. He immediately began to provide aid for injured airmen and helped to initiate the search and rescue for his building. Id. ¶ 6. Though he attempted to staunch the bleeding of one profusely injured airman, that airman passed away in Reid’s arms. Id. Reid himself was injured but received only self-aid for “several nights.” Id. ¶ 7. The explosion had caused Reid to suffer from “glass wounds to [his] ears, head, neck, legs, and feet.” Id. His neck and spine were compressed, requiring decompression 43 surgery. Id. He has additionally been diagnosed with PTSD as a result of the attack. Id. ¶ 8. Reid has received a combined disability rating of 60% from the VA. Id ¶ 8; id., Att. (Letter from VA, dated May 25, 2018), ECF No. 89 at 16–17; id., Att. (Letter from VA, dated May 10, 2018), ECF No. 89 at 14–15; id., Att. (medical records), ECF No. 89 at 18–67. Reid received an Air Force Commendation Medal for his actions after the bombing and the Purple Heart for the injuries he sustained. Id. ¶ 7; id., Att. (Air Force Commendation Medal Certificate, dated Jan. 4, 1997), ECF No. 89 at 13; id., Att. (Special Order from Department of the Air Force, dated Aug. 6, 1996, confirming Purple Heart), ECF No. 89 at 12; id., Att. (Certificate of Release or Discharge from Active Service, confirming medals), ECF No. 89 at 7. One of Reid’s family members is a plaintiff in this lawsuit: his son, Sean Reid, who was babysitting when his step-mother called and told him about the attack. Decl. of Sean C. Reid (“Sean Reid Decl.”) (Sept. 12, 2018) ¶¶ 4–5, ECF No. 89 (sealed), ECF No. 222 (public). He turned on the TV and saw what “reminded [him] of the Oklahoma City Bombing and it made [him] very distraught thinking that [his] father could suffer the same fate as the victims of that bombing.” Id. ¶ 5. Sean spent “the rest of the day glued to the television,” but was not able to hear from his father that he survived until “twenty-four to thirty-six hours after [he] first heard of the incident.” Id. ¶ 6. The effects of the attack on Sean Reid’s life have been “devastating.” Id. ¶ 7. He still suffers from anxiety, for which he takes medication, and the “profound impact” the attack has had on his relationship with his father causes him “extreme grief and distress.” Id. ¶ 9. 29. Brandie R. Shaffer On June 25, 1996, Brandie R. Shaffer was a Senior Airman in the U.S. Air Force deployed to Saudi Arabia, stationed at Khobar Towers in Dhahran, Saudi Arabia. Decl. of Brandie R. Shaffer (“Shaffer Decl.”) (Sept. 10, 2018) ¶ 3, ECF No. 90 (sealed), ECF No. 235 44 (public). Shaffer was on patrol at the front gate when she received a report over the radio about suspicious activity. Id. ¶ 4. Immediately afterwards she received a call requesting “immediate assistance to evacuate the building.” Id. Before she was able to arrive, Shaffer “heard and felt the blast and saw the huge mushroom cloud” and thought they “would all die.” Id. Shaffer ran towards the blast site and aided an injured airman to triage and then helped with the evacuation and search of the buildings. Id. When she reached her room she realized that if she “had been there and in the bed, [she] would have been seriously injured by the air conditioning unit that fell on [her] bed and all of the debris and glass that seemed to be everywhere.” Id. To this day, Shaffer suffers from survivor’s guilt and doesn’t “understand why [she] was sparred and nineteen others were not.” Id. ¶ 5. When she first returned home, she “slept with a gun on [her] chest.” Id. ¶ 6. As a result of the attack, Shaffer suffers from anxiety and Chronic Adjustment Disorder. Id. ¶¶ 6–7. The VA has assigned Shaffer a 70% disability rating due to her Chronic Adjustment Disorder. Id. ¶ 10; id., Att. (Letter from the VA, dated July 2, 2018), ECF No. 90 at 8–9; id., Att. (Fax from VA, dated July 3, 2018), ECF No. 90 at 10–12. Shaffer was awarded the Air Force Commendation Medal. Id. ¶ 8; id., Att. (Air Force Commendation Medal Certificate, dated Jan. 14, 1997), ECF No. 90 at 6–7. 30. Artis R. Coleman and Two Family Members On June 25, 1996, Artis R. Coleman was a Staff Sergeant in the U.S. Air Force deployed to Saudi Arabia, stationed at Khobar Towers in Dhahran, Saudi Arabia. Decl. of Artis R. Coleman (“Coleman Decl.”) (Dec. 27, 2018) ¶ 4, ECF No. 91 (sealed), ECF No. 173 (public). Coleman was in his room when he saw a “very bright flash” and the ceiling collapsed “burying [him] in concrete and shattered glass,” knocking him unconscious. Id. ¶ 5. When he awoke, fellow airmen were wrapping his head and then helped him out of the building. Id. Coleman 45 was taken via ambulance to a hospital where he was seen for head trauma, lacerations and glass in his feet. Id. ¶ 6. After the bombing, Coleman started having “headaches [that] were so severe that it seemed like something was trying to get out of [his] head.” Id. ¶ 9. A year after the attack, Coleman had a brain aneurysm on his right side and underwent surgery where they then found an unruptured aneurysm on his left side. Id. ¶ 10. After the two aneurysm surgeries, Coleman’s “legs and feet began to hurt all the time.” Id. ¶ 14. Coleman additionally suffers from depression, for which he takes anti-depressants, and PTSD. Id. ¶¶ 11, 17. The VA has assigned Coleman a disability rating of 100% due to his PTSD and mental ailments. Id. ¶ 18; id., Att. (Letter from VA, dated Feb. 16, 2017), ECF No. 91 at 25; id., Att. (medical records), ECF No. 91 at 6–20. Coleman received the Purple Heart for his injuries. Id. ¶ 19; id., Att. (Purple Heart Certificate, dated July 2, 1996), ECF No. 91 at 26. Two of Coleman’s family members are plaintiffs in this lawsuit: his wife, Betty Coleman; and his son, Artis Coleman Jr. Betty first learned of the attack when she was told, by the wife of Coleman’s co-worker, that Coleman had died. Decl. of Betty A. Coleman (“Betty Coleman Decl.”) (Sept. 5, 2018) ¶ 5, ECF No. 91 (sealed), ECF No. 173 (public). “This was the most catastrophic news [she had] ever received, and [she] was told this alone, at night with no one to console [her] or offer comfort.” Id. The next morning, Betty called her husband’s squadron and was informed that she would be contacted later with information. Id. ¶ 6. During a two-day wait for information, she “sustained an insurmountable amount of anguish.” Id. She then received a call informing her that her husband was not inside the building and was fine, but then received a call later stating that he was inside the building and had passed away. Id. Finally, she received the news that her husband had been inside the building but was alive and injured in a hospital. Id. “The contradictory information about [her] husband’s life fueled [her] with anguish and 46 grief.” Id. ¶ 7. Coleman returned home, and a year after the attack, had his first aneurysm surgery. Id. ¶ 10. While her husband was in a coma, Betty was told that she had complications to her pregnancy at the same time she “didn’t know if [her] husband would live or die.” Id. Betty is her husband’s primary caregiver and has sustained “severe economic losses” as a result of her husband’s complete disability. Id. ¶ 11. In addition, she has started having “symptoms of body aches, migraine[] headaches, vertigo and sleep problems.” Id. ¶ 13. Her headaches have become so severe that she has had to go to the hospital for CT scans. Id. The attack on Khobar Towers has caused Betty Coleman to “endure[] extreme mental pain, suffering, grief and anguish.” Id. ¶ 14. Coleman’s son, Artis Coleman Jr., had his “life [] changed forever” and the “effects of the attack on [his] daily and family life have been devastating.” Decl. of Artis Coleman Jr. (“Artis Coleman Decl.”) (Sept. 21, 2018) ¶¶ 4, 6, 10, ECF No. 91 (sealed), ECF No. 173 (public). He had a father who could no longer demonstrate “all the techniques he learned from playing basketball” and he “cannot remember the last time [his father] rode a rollercoaster, ran or jumped.” Id. ¶¶ 5–6. Artis Coleman Jr. has done the best he can “physically and emotionally,” but the attack has caused him “extreme mental pain, suffering, grief and anguish.” Id. ¶¶ 9–10. 31. Laurence P. Oliver On June 25, 1996, Laurence P. Oliver was a Senior Airman in the U.S. Air Force deployed to Saudi Arabia, stationed at Khobar Towers in Dhahran, Saudi Arabia. Decl. of Laurence P. Oliver (“Oliver Decl.”) (Sept. 11, 2018) ¶ 3, ECF No. 92 (sealed), ECF No. 218 (public). Oliver had just returned from the city and was still in his civilian clothes at the time of the attack. Id. ¶ 4. He was “approximately three hundred yards” from the attack, which “took [them] completely by surprise.” Id. After the attack, Oliver gathered himself and went to the 47 armory for a weapon and body armor before returning to help. Id. Once back at the site of the attack, Oliver realized that “there was blood everywhere and chaos ensued all around.” Id. He assumed duties as the area supervisor and coordinated “clearing and controlling the entry control point for responding emergency units.” Id. ¶ 5. The attack on Khobar Towers has caused Oliver to develop PTSD. Id. ¶ 7. He has been “in a high state of high anxiety for over twenty years” and gets “maybe 4 hours of sleep a night.” Id. ¶ 8. Oliver has received a combined total disability rating of 90% from the VA. Id. ¶ 7; id., Att. (VA Rating Decision, undated), ECF No. 92 at 7; id., Att. (Letter from VA, dated Aug. 24, 2018), ECF No. 92 at 8–9. Oliver received an Air Force Achievement Medal for the injuries he sustained. Id. ¶ 6; id., Att. (Air Force Achievement Medal Certificate, dated Dec. 19, 1996), ECF No. 92 at 6. 32. Grady W. Tucker Jr. and One Family Member On June 25, 1996, Grady W. Tucker Jr. was a Staff Sergeant in the U.S. Air Force deployed to Saudi Arabia, stationed at Khobar Towers in Dhahran, Saudi Arabia. Decl. of Grady W. Tucker Jr. (“Tucker Jr. Decl.”) (Dec. 27, 2018) ¶ 4, ECF No. 93 (sealed), ECF No. 244 (public). Tucker Jr. was in his dormitory building when the force of the explosion threw him across the room, causing “blows to the head, neck, and back,” in addition to tearing all the ligaments in his left wrist. Id. ¶¶ 5–6. He had surgery to repair the torn ligaments and still suffers from permanent nerve damage in his left wrist. Id. In addition to physical injury, Tucker Jr. suffers from PTSD and anxiety, which contribute to a “poor quality of life.” Id. Tucker Jr. was assigned a combined disability rating of 100% by the VA. Id. ¶ 7; id., Att. (Letter from VA, dated May 11, 2017), ECF No. 93 at 4. Tucker received the Purple Heart for his injuries. Id. ¶ 8; id., Att. (Purple Heart Certificate, dated Aug. 7, 1996), ECF No. 93 at 5. 48 One of Tucker’s family members is a plaintiff in this lawsuit: his father, Grady W. Tucker Sr. Decl. of Grady W. Tucker, Sr. (“Tucker Sr. Decl.”) (Dec. 19, 2018) ¶ 4, ECF No. 93 (sealed), ECF No. 244 (public). Tucker’s father was playing cards when he first learned of the attack and turned on the news. Id. ¶ 5. Though the news did not provide much information at first, his father became “very scared” when they said the word “barracks.” Id. He returned home to a voicemail that his son was alive, but he “just knew” that something was wrong. Id. He later received a call from his son informing him that he was injured. Id. Tucker’s father has “sustained emotional distress due to the injuries [his] son suffered,” and remains “emotionally scarred.” Id. ¶¶ 7–8. 33. Jon C. Schamber On June 25, 1996, Jon C. Schamber was an Airman First Class in the U.S. Air Force deployed to Saudi Arabia, stationed at Khobar Towers in Dhahran, Saudi Arabia. Decl. of Jon C. Schamber (“Schamber Decl.”) (filed Dec. 28, 2018) ¶ 3, ECF No. 94 (sealed), ECF No. 228 (public). Schamber was watching television when the “TV went black and the sudden blast pressure picked [him] up and threw [him] into a cement wall.” Id. ¶ 4. Schamber was knocked unconscious and woke up “in a pool of blood and debris,” with “severe lacerations to the inside of [his] right knee that made it impossible to walk.” Id. ¶¶ 4, 5. He later woke up in a Saudi Arabian hospital. Id. ¶ 5. After three surgeries on his legs to “attempt to repair a quadriceps tendon, [and] close up several severe lacerations,” Schamber suffers from “drop foot,” “peroneal nerve damage” and “traumatic arthritis,” as well as “chronic pain to this day.” Id. ¶ 6. He additionally suffers from PTSD and has been prescribed anti-anxiety medication. Id. ¶¶ 8–9. Schamber has received a combined disability rating of 90% from the VA. Id. ¶ 10; id., Att. (Letter from VA, dated Mar. 9, 2017), ECF No. 94 at 22–23; see also id., Att. (medical records), 49 ECF No. 94 at 7–19. Schamber received the Purple Heart for his injuries. Id. ¶ 11; id., Att. (Purple Heart Certificate, dated July 2, 1996), ECF No. 94 at 24. 34. Brian E. Vanhorn On June 25, 1996, Brian E. Vanhorn was a Senior Airman in the U.S. Air Force deployed to Saudi Arabia, stationed at Khobar Towers in Dhahran, Saudi Arabia. Decl. of Brian E. Vanhorn (“Vanhorn Decl.”) (Dec. 27, 2018) ¶ 3, ECF No. 101 (sealed), ECF No. 245 (public). Vanhorn was packing to be deployed home when the bomb went off. Id. ¶ 4. He was “thrown backwards up against the wall” and landed on the floor. Id. After gathering himself and removing “bits of glass” embedded in his skin, he “had to pry open the door that had been jammed shut” to exit the suite. Id. ¶¶ 5–6. Vanhorn made his way “[t]hrough the chaos” to the stairs, seeing “blood everywhere on the walls, floors and even in the stairwell.” Id. ¶ 6. He was directed to a triage area where, after seeing the severity of the injuries, he declined treatment. Id. ¶ 7. Vanhorn sustained “multiple lacerations and glass shrapnel wounds” in addition to “trauma to [his] head, body and extremities.” Id. ¶ 8. The attack on Khobar Towers has caused Vanhorn to develop PTSD. Id. ¶ 9. He lost “not just one but twelve of [his] very close friends” and lives with survivors’ guilt. Id. ¶ 11. Vanhorn has received a combined disability rating of 30% by the VA. Id. ¶ 9; id., Att. (Letter from VA, dated June 30, 2018), ECF No. 101 at 9. Vanhorn received the Purple Heart for his injuries. Id. ¶ 8; id., Att. (Purple Heart Certificate, dated Aug. 26, 1996), ECF No. 101 at 8; id., Att. (Certificate of Release or Discharge from Active Duty, confirming medal), ECF No. 101 at 5. 35. Travis W. Wyatt On June 25, 1996, Travis W. Wyatt was a 19-year-old service member in the U.S. Air Force deployed to Saudi Arabia, stationed at Khobar Towers in Dhahran, Saudi Arabia. Decl. of 50 Travis W. Wyatt (“Wyatt Decl.”) (Dec. 27, 2018) ¶¶ 3, 7, ECF No. 102 (sealed), ECF No. 257 (public). He was in bed going to sleep when he suddenly “felt pressure all around [him]” and “[e]verything went black, and the room filled with smoke.” Id. ¶ 4. After evacuating, he saw “total chaos outside,” where there were “bodies and blood everywhere.” Id. ¶ 5. Wyatt had some glass removed from his feet, and three days later had shards of glass removed with a needle without anesthetic. Id. ¶ 6. When he returned home, Wyatt was prescribed medicine for “acute anxiety.” Id. ¶ 7. Due to the “traumatic psychological issues resulting from the attack,” Wyatt has developed PTSD and received a combined VA disability rating of 70%. Id. ¶¶ 8, 9; id., Att. (VA Rating Decision, dated Jan. 3, 2008), ECF No. 102 at 25–27; see also id., Att. (medical records), ECF No. 102 at 6–24. Wyatt received the Purple Heart. Id. ¶ 10; id., Att. (Certificate of Release or Discharge from Active Duty, confirming medal), ECF No. 102 at 5. 36. William M. Schooley On June 25, 1996, William M. Schooley was a service member in the U.S. Air Force deployed to Saudi Arabia, stationed at Khobar Towers in Dhahran, Saudi Arabia. Decl. of William M. Schooley (“Schooley Decl.”) (filed Dec. 28, 2018) ¶ 3, ECF No. 103 (sealed), ECF No. 231 (public). On the night of the bombing, Schooley was in his bedroom, when, “[w]ithout warning the whole room began violently shaking.” Id. ¶¶ 4–5. A metal wall locker “began to shimmy its way across the room” toward Schooley, who “curled up in a ball on [his] bed, covering [his] head with [his] arms, as the rumbling and shaking continued on and on.” Id. The locker eventually fell on Schooley, who “shoved it off.” Id. ¶ 6. When the “chaos subsided,” Schooley made his way out to the hallway to check on his suitemates. Id. “Broken glass was everywhere and [they] had to make [their] way through rubble.” Id. ¶ 7. Schooley and his suitemates began checking to see if people they saw were seriously injured. Id. ¶ 9. All around 51 him, he saw “airmen tending to their fallen comrades.” Id. ¶ 10. Schooley used his bare hands to move barbed wire and debris in order to clear a pathway for the injured to be removed from the building closest to the truck bomb. Id. ¶ 12. He then “went to the nearby picnic tables to provide first aid to the wounded,” but he “felt completely helpless because [they] had no medical supplies and [their] training was so limited.” Id. ¶¶ 13, 14. After the bombing, Schooley began to suffer from PTSD, with “nightmares, insomnia, anxiety, hypervigilance, headaches, and constant[] [thoughts] about the bombing.” Id. ¶ 20. Due to his symptoms, the attack “changed [his] life forever.” Id. ¶ 23. Schooley was medically retired from the Air Force in 1999 because of his PTSD. Id. ¶ 21. The VA has rated Schooley 70% disabled for PTSD. Id. ¶ 25; id., Att. (Letter from VA, dated Feb. 25, 2017), ECF No. 103 at 73; id., Att. (Letter from VA, dated Oct. 31, 2003), ECF No. 103 at 75; see also id., Att. (medical records), ECF No. 103 at 10–12, 36–38, 40, 43–46, 70–72. Schooley was approved for Combat-Related Special Compensation because of his PTSD. Id. ¶ 26; id., Att. (Letter from Department of the Air Force Headquarters Air Force Personnel Center, dated Jan. 29, 2009), ECF No. 103 at 76. Schooley was awarded an Air Force Achievement Medal and a Certificate of Appreciation. Id., Att. (Air Force Achievement Medal Certificate, dated Aug. 21, 1997), ECF No. 103 at 79; id., Att. (Certificate of Appreciation, dated June 27, 1996), ECF No. 103 at 86. 37. Jereme D. Schuchard and One Family Member On June 25, 1996, Jereme Schuchard was a service member in the U.S. Air Force deployed to Saudi Arabia, stationed at Khobar Towers in Dhahran, Saudi Arabia. Decl. of Jereme D. Schuchard (“Schuchard Decl.”) (Sept. 11, 2018) ¶ 4, ECF No. 110 (sealed), ECF No. 232 (public); see also Plaintiff Jereme D. Schuchard’s Notice of Errata (Jan. 24, 2019), ECF No. 136 (sealed), ECF No. 233 (public). Schuchard was at his dinner table when the “concussion 52 wave explode[d] through the window and shatter[ed] it into large shards.” Schuchard Decl. ¶ 5. Even though he dove “toward the floor behind a chair” to shield himself from the “flying broken glass,” Schuchard was knocked unconscious. Id. ¶¶ 6–7. When he woke up, he helped to triage other people. Id. ¶ 7. While helping, he was told that he was injured on his “back, neck, left arm and left shoulder” and received sutures with no anesthesia. Id. Schuchard now suffers from “constant neck and back pain,” for which he will have to wear a brace for the rest of his life. Id. ¶ 9. His doctor also believes that he suffers from a Traumatic Brain Injury, and has occasional vision problems and tinnitus. Id. In addition to physical injury, Schuchard suffers from PTSD and has “frequent nightmares.” Id. ¶ 12. The VA has assigned Schuchard a disability rating of 40% as a result of the attack. Id. ¶ 10; id., Att. (VA Rating Decision, dated May 10, 2011), ECF No. 110 at 8–9; see also id., Att. (medical records), ECF No. 110 at 10–19. Though Schuchard would have wanted to stay in the Air Force, he was forced to retire in 1999 due to his injuries from the attack. Id. ¶ 9. Schuchard received the Purple Heart and Airforce Commendation Medal. Id. ¶ 8; id., Att. (Purple Heart Certificate, dated Aug. 5, 1996), ECF No. 110 at 6; id., Att. (Certificate of Release or Discharge from Active Duty, confirming medals), ECF No. 110 at 5; id., Att. (Air Force Commendation Medal Certificate, dated Dec. 23, 1996), ECF No. 110 at 7. One of Schuchard’s family members is a plaintiff in this lawsuit: his mother Brenda Munoz. Decl. of Brenda G. Munoz (“Munoz Decl.”) (Sept. 13, 2018) ¶¶ 2, 4, ECF No. 110 (sealed), ECF No. 232 (public); see also Plaintiff Jereme D. Schuchard’s Notice of Errata, ECF No. 136 (sealed), ECF Nos. 232, 233 (public). His mother first learned of the attack when her daughter called her “almost hysterical.” Munoz Decl. ¶ 5. Munoz drove home and turned on the news for more information about her son. Id. ¶ 6. “I could not eat or sleep. All I could do was pray that my son was alive.” Id. “Approximately eighty hours later,” she received a short call 53 from Schuchard letting her know that he was alive. Id. Schuchard would not return home for one hundred and thirty-four days. Id. ¶ 7. Munoz has experienced “extreme grief and distress” as a result of the attack. Id. ¶¶ 5, 12. She feels like “the young man he was no longer exists” and “mourn[s] his loss every day.” Id. ¶ 12. The “[p]rolonged stress” has caused her health to deteriorate. Id. 38. Mitchell D. Wright and Three Family Members On June 25, 1996, Mitchell D. Wright was a Technical Sergeant in the U.S. Air Force deployed to Saudi Arabia, stationed at Khobar Towers in Dhahran, Saudi Arabia. Decl. of Mitchell D. Wright (“Wright Decl.”) (Nov. 12, 2018) ¶ 4, ECF No. 112 (sealed), ECF No. 256 (public). Wright was cleaning his dormitory bathroom, in preparation for returning home, when the explosion “shattered a bathroom window, sending glass flying into [his] face.” Id. ¶ 5. “Broken glass pierced both of [his] eyes, detached both retinas, and shattered tissue in [his] eyes.” Id. Wright was taken by ambulance to a Saudi hospital, later evacuated to Germany, and then transferred to the Walter Reed Medical Center in Washington, D.C. where he was hospitalized for three months. Id. ¶ 6. After two eight-hour operations to restore his vision, Wright has only “corrected near and far vision of 20/200” in his right eye, and only “light perception” in his left eye. Id. ¶¶ 6–7. Wright cannot drive or “read regular print” and often falls while walking due to his poor depth perception. Id. ¶ 9. In addition to his visual impairment, Wright suffers from PTSD from the attack, which includes “constant nightmares.” Id. ¶ 10. As a result of his injuries, the VA has assigned Wright a disability rating of 90%. Id. ¶ 8; id., Att. (Letter from VA, dated Feb. 10, 2017), ECF No. 112 at 162–63; see also id., Att. (medical records), ECF No. 112 at 6–142. Wright received the Purple Heart for injuries 54 sustained in the attack. Id. ¶ 11; id., Att. (Purple Heart Certificate, dated July 2, 1996), ECF No. 112 at 165. Three of Wright’s family members are plaintiffs in this lawsuit: his wife, Patricia Wright; his daughter, Elin Brown; and his son, Erik Wright. On the day of the attack, his wife Patricia was leaving her house when she received a phone call that there had been an attack on her husband’s housing unit. Decl. of Patricia Wright (“Patricia Wright Decl.”) (Sept. 11, 2018) ¶ 5, ECF No. 112 (sealed), ECF No. 256 (public). Patricia was left in “grueling limbo” for almost two days before she received a call that her husband had been badly injured. Id. ¶¶ 5–6. She was reunited with her husband a few days later and accompanied him to Washington, D.C. for treatment for three months. Id. ¶¶ 7, 10. The attack on Khobar Towers has impacted Patricia’s personal health and well-being “in an enormously negative way,” including causing depression. Id. ¶¶ 12–13. She has incurred economic loss as she can no longer work full time and is the “primary and sole care-giver” of her husband. Id. ¶ 15. She had worked as a preschool teacher before the attack but resigned due to her husband’s injuries. Id. ¶ 17. Wright’s daughter, Elin Brown, was at a band meeting with a friend when her mother told her to spend the night at her friend’s house. Decl. of Elin C. Brown (“Brown Decl.”) (Sept. 11, 2018) ¶¶ 4–5, ECF No. 112 (sealed), ECF No. 256 (public). The next day, she returned home and her mother told her that her father was in an attack and she did not know if he survived. Id. “[She] immediately started to cry, fearing that [they] had lost [her] father.” Id. It was not until the next night when they learned that he had survived but was seriously injured. Id. The family was asked to be “the face of the families” and greet the injured when returning home. Id. ¶ 6. After seeing her father carried out of the plane on a stretcher, Elin and her brother were sent to live with their grandparents for the summer while her father recovered. Id. ¶ 7. As a 55 result of the attack, Elin suffers from depression. Id. ¶ 11. She is “unable to watch anything regarding military servicemen or women and their families without crying, even a simple commercial.” Id. Wright’s son, Erik Wright, learned about the attack when he heard his sister crying and asked his mom what had happened. Decl. of Erik Mitchell Wright (“Erik Wright Decl.”) (Sept. 11, 2018) ¶¶ 4–5, ECF No. 112 (sealed), ECF No. 256 (public). He did not know if his father had survived and “[t]he feelings of anguish and uncertainty were truly overwhelming.” Id. ¶ 5. The next night, he learned that his father was badly injured, but alive. Id. ¶ 6. Erik was able to see his father briefly at the Air Force base, but then would not see his father again for twelve weeks. Id. ¶ 7. He has had to take care of his father since he was nine years old, and still is his father’s “guide” when they walk anywhere. Id. ¶ 8. Erik suffers from various emotional problems as a result of the injuries to his father. Id. ¶ 12. 39. The Estate of Hector M. Gonzalez-Pastrana and Four Family Members On June 25, 1996, Hector Manuel Gonzalez-Pastrana was a Master Sergeant in the U.S. Air Force deployed to Saudi Arabia, stationed at Khobar Towers in Dhahran, Saudi Arabia.4 Decl. of Diana Gonzalez-Pastrana, Personal Representative of the Estate of Hector Manuel Gonzalez-Pastrana (“Estate of Hector Manuel Gonzalez-Pastrana Decl.”) (Dec. 27, 2018) ¶ 10, ECF No. 113 (sealed), ECF No. 191 (public). Gonzalez-Pastrana had just fallen asleep when the attack occurred. Id. ¶ 11. “He sustained lacerations to both feet from walking barefoot on broken glass, glass fragments embedded in his head, and trauma to his body.” Id. Although he was in “great pain,” Gonzalez-Pastrana returned to his dorm multiple times to rescue the 4 Hector Manuel Gonzalez-Pastrana is deceased and this declaration was filed on behalf of his estate by his wife Diana Gonzalez. Decl. of Diana Gonzalez-Pastrana, Personal Representative of the Estate of Hector Manuel Gonzalez-Pastrana (“Estate of Hector Manuel Gonzalez-Pastrana Decl.”) (Dec. 27, 2018) ¶ 10, ECF No. 113 (sealed), ECF No. 191 (public). 56 wounded. Id. ¶ 12. “The blast had knocked out the electricity and it was so dark that they had to move slowly, pressing their bodies against the walls to ensure there was a floor, not a hole that they could fall through.” Id. ¶ 13. He “had never seen so much blood in his life.” Id. ¶ 12. After the attack, his “personality completely changed” and “[h]e began to drink excessively, and no longer participated in family activities and outings.” Id. ¶¶ 16–17. Gonzalez-Pastrana was diagnosed with “PTSD featuring paranoia, panic attacks, anxiety, patrolling behavior, flashbacks, anger, nightmares, disorientation, and controlling behavior.” Id. ¶ 20. “He was also diagnosed with hypertension; chronic fatigue . . . chronic lower back pain . . . tinnitus; and migraines” and the VA has rated him 100% disabled. Id. ¶¶ 21, 26; id., Att. (Letter from VA, dated Dec. 12, 2016), ECF No. 113 at 33. Even though he was prescribed “a number of medications for his medical and psychiatric conditions,” his condition deteriorated to the point that he “wouldn’t even take a shower in the house.” Id. ¶¶ 23–27. Gonzalez-Pastrana died at home “on March 4, 2017, when he was only forty-eight years old, from a heart attack caused by his hypertension.” Id. ¶ 31. The VA determined that his death was service connected. Id. ¶ 33; id., Att. (VA Rating Decision, dated May 2, 2017), ECF No. 113 at 37–38. Gonzalez-Pastrana received the Purple Heart for his injuries. Id. ¶ 15; id., Att. (Purple Heart Certificate, dated Oct. 8, 1996), ECF No. 113 at 19; id., Att. (Certificate of Release or Discharge from Active Duty, confirming medal), ECF No. 113 at 18. Gonzalez-Pastrana is survived by three family members who are plaintiffs in this lawsuit: his wife, Diana Gonzalez-Pastrana; his two sons, Hector Gonzalez Jr. and Jose D. Gonzalez; and his daughter, Natasha Gonzalez. Decl. of Diana Gonzalez-Pastrana (“Diana Gonzalez-Pastrana Decl.”) (Dec. 27, 2018) ¶¶ 2, 8, ECF No. 113 (sealed), ECF No. 191 (public). For his wife Diana, “[l]osing [her] husband was like losing a part of [herself].” Id. ¶ 34. They “grew up in 57 Puerto Rico together” and had been married since 1985. Id. ¶ 5. In 1992, Diana was diagnosed with lupus and her husband “always supported [her] and was [her] caregiver during the most difficult moments of [her] illness.” Id. ¶ 6. When her husband returned from the attack, he “became [] physically and mentally distant.” Id. ¶ 14. He began going on tours of duty more frequently, even choosing to go to Korea by himself for a year, leaving her to take care of their three children alone while sick. Id. ¶ 17. Her husband’s health declined until he ultimately passed away at home due to his hypertension. Id. ¶¶ 27, 32. For her, this was the “worst day of [her] life. All of [her] hopes and dreams of him one day getting better went up in flames.” Id. ¶ 27. Gonzalez-Pastrana’s oldest son, Hector Gonzalez Jr., was ten years old when he learned that his father’s housing complex had been bombed. Decl. of Hector Gonzalez Jr. (“Hector Gonzalez Jr. Decl.”) (Dec. 27, 2018) ¶¶ 4–5, ECF No. 113 (sealed), ECF No. 191 (public). His mother received a phone call and “started screaming and crying” and “[s]he immediately turned on the TV and started to watch the reports coming in.” Id. ¶ 5. Hector would not see his father for a month until he came home. Id. ¶ 7. As a result of the attack, and the death of his father, he has suffered from “profound grief and sadness.” Id. ¶ 9. When his father was not breathing, his mother called Hector, who, based on his own training, “knew that they wouldn’t be able to revive him.” Id. Gonzalez-Pastrana’s youngest son, Jose Gonzalez, was one year old at the time of the bombing in Khobar Towers. Decl. of Jose D. Gonzalez (“Jose D. Gonzalez Decl.”) (Dec. 27, 2018) ¶¶ 4–5, ECF No. 113 (sealed), ECF No. 191 (public). His father was still “a very good father,” though his family said that “he was a very different man” before the attack. Id. ¶ 5. His father did suffer from alcoholism and paranoia, which got worse in the months leading up to his 58 father’s death. Id. ¶¶ 8–9. “The most painful part” for Jose was when his dad passed away suddenly. Id. ¶ 12. His sister had gone to check on their father and found that he was not breathing, and he “rushed to start performing CPR on him.” Id. The death of his father “devastated [him] and [his] whole family.” Id. Jose felt “ter [Text truncated at 120,000 characters. The full text is on the page linked above.] --- Source: Frix Law Library, https://www.frixlaw.com/law-library/cases/4412107. Public record. Not legal advice.