Document 61: United States District Court (Florida: Southern District) Affidavit. "United States of America, Plaintiff, v. Carlos Cardoen [et al.]" [Charge that Teledyne Wah Chang Albany Illegally Provided a Proscribed Substance, Zirconium, to Cardoen Industries and to Iraq], January 31, 1995.

Former Reagan administration National Security Council staff member Howard Teicher says that after Ronald Reagan signed a national security decision directive calling for the U.S. to do whatever was necessary to prevent Iraq's defeat in the Iran-Iraq war, Director of Central Intelligence William Casey personally led efforts to ensure that Iraq had sufficient weapons, including cluster bombs, and that the U.S. provided Iraq with financial credits, intelligence, and strategic military advice. The CIA also provided Iraq, through third parties that included Israel and Egypt, with military hardware compatible with its Soviet-origin weaponry.

This affidavit was submitted in the course of one of a number of prosecutions, following Iraq's invasion of Kuwait, of U.S. companies charged with illegally delivering military, dual-use, or nuclear-related items to Iraq. (In this case, a Teledyne affiliate was charged will illegally selling zirconium, used in the manufacture of explosives, to the Chilean arms manufacturer Carlos Industries, which used the material to manufacture cluster bombs sold to Iraq.) Many of these firms tried to defend themselves by establishing that providing military materiel to Iraq had been the actual, if covert, policy of the U.S. government. This was a difficult case to make, especially considering the rules of evidence governing investigations involving national security matters.