IN THE CIRCUIT COURT OF SHELBY COUNTY, TENNESSEE FOR THE THIRTIETH JUDICIAL DISTRICT AT MEMPHIS

ROSINE COLLIN GHAWJI,

Plaintiff/Counter-Defendant,

No. CT-003545-04

vs.

MAHER GHAWJI,

Defendant/Counter-Plaintiff

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AFFIDAVIT

I, Joe Kaufman, hereby declare and state as follows:

1. I have personal knowledge of the facts stated in this affidavit.

2. I am a permanent resident of the state of Florida and the graduate of a large well-known university.

3. I have been an investigative journalist for FrontPage Magazine since 2003. Since 1998, I have served as the Chairman of Americans Against Hate, a civil rights organization and terrorism watchdog group.

4. Shortly after the Sep 11, 2001 attacks, I assisted the FBI in an investigation that resulted in the shutting down of a Hamas (the Palestinian terrorist organization) related charity operating out of Deerfield Beach, Florida.

5. In September of 2003, I was invited by Johnnie Byrd, then Florida Speaker of the House, to give expert testimony in front of law enforcement and government representatives at a forum on terrorism and homeland security.

6. This year, I have been a guest speaker at several conferences concerning the issue of terrorism, including the 2006 Intelligence Summit and the 2006 American's Truth Forum Symposium. Since 2003, I have also appeared several times as a counter-terrorism expert on the Fox News Channel.

7. Maher Ghawji is a medical doctor based in Memphis, Tennessee.

8. Maher Ghawji has admitted to his wife of being a member of the Muslim Brotherhood, a violent political movement whose members are sworn to "defend Islam" with their "blood." He accepted this status with a group of friends, during a trip they had made to Cairo, Egypt (Exhibit 1). He left Syria around 1982, the year a government-led massacre took place in the town of Hama - a Brotherhood stronghold - which resulted in the deaths of 10,000 to 40,000 people (Exhibit 2). Following the massacre, members of the Brotherhood fled Syria, some leaving for the U.S. or Europe, some joining up with Osama bin Laden to fight in Afghanistan (Exhibit 3).

9. During his court deposition, on June 4, 2004, Maher Ghawji admitted to the court and to his wife of being a Wahhabi, an adherent to a fanatical religious form of Islam emanating from Saudi Arabia (Exhibit 4 - page 26).

10. Maher Ghawji has exhibited intolerance towards Jews. During the June 2004 deposition, he stated that, when he speaks of his hatred towards Israelis, he mixes up the terms "Israelis" and "Jews." (Exhibit 4 - pages 46-47) When asked the question if he's ever told his wife that he "did not want a child who was Jewish" in his home, he responded, "Correct, I said I don't." (Exhibit 4- page 47). He stated that in his religion, there is an "angel" that "will help the Muslim and they will fight the Jew" and that there is a "rock" and, "if the Jew hide behind it, [the rock] will indicate where that person is." (Exhibit 4- pages 84-85).

11a. Maher Ghawji's son, Louis, has written about how his father wants to "get rid" of all Jews and how his father wants him [Louis] to become a suicide bomber. In an e-mail he sent to a friend on June 24, 2004, he wrote, "And because he [Maher Ghawji] wants to get rid of all Jews and everybody should be muslim and if not all others are idiots and blah blah blah muslim allah blah blah blah wants me to go blow up myself so he would be proud of me…" (Exhibit 5).

11b. Both of Maher Ghawji's sons have discussed how their father hates Jews. In the July 2, 2004 chambers interview with Louis and K.K. Ghawji, the children state the following: K.K. Ghawji: "So, but also, when he watches the TV and hears about Jews, he doesn't - he's like saying I hate the Jews, it is - " Louis Ghawji: "He's always wondering like every time there is one Jew dead, it is always a big fuss…" (Exhibit 5).

12. About Palestinians becoming suicide bombers, Maher Ghawji stated in his June 2004 deposition, "I think this will generate this, I'm not sure, spirit of blowing themselves up or feeling in despair; and when you're in despair evidently like they live, and these people has no education, fifty percent jobless, have no running water after the invasion of Israeli to the Gaza Strip and West Bank, destroy all their infrastructure, evidently they feel miserable; and I said these people -- I don't see why not." (Exhibit 4 - page 82).

13. Maher Ghawji, on a number of occasions, has seemed particularly interested in acquiring his children's passports. During his June 2004 deposition, he admitted to going into his wife's dressing room drawer to take his younger son's passport. This was without his wife's consent or knowledge (Exhibit 4- page 52).

14. The Ghawji sons wrote e-mails and class papers about how their father was in possession of their passports, how he had told them that they were leaving for Syria, and how he threatened to kill them:

15. Syria has been designated by the U.S. State Department as a state sponsor of terrorism (Exhibit 8).

16. During his June 2004 deposition, Maher Ghawji stated that he was planning to take one of his sons to Chicago for the Islamic Society of North America (ISNA) conference. (Exhibit 4 - pages 55-56) ISNA was founded by members of the Muslim Brotherhood, including the North American leader of the Palestinian Islamic Jihad, convicted terrorist Sami Al-Arian (Exhibit 9).

17. In January of 1999, Maher Ghawji issued checks for $300, $1000 and $500 to Mercy International (Exhibit 10), a charity that was implicated in the 1998 U.S. embassy bombings in East Africa, an Al-Qaeda operation. Mercy International was originally created, under the name Human Concern International (HCI), to support the Afghan jihad against the Soviets (Exhibit 11). Maher Ghawji donated to HCI's "Bosnia Fund." (Exhibit 12). The receipt for payment appears to be signed by an "H. Ghawji." (Exhibit 13)

18. Jim Raddatz is an FBI agent involved with the Joint Terrorism Task Force, based in Memphis, Tennessee. In an e-mail to Rosine Ghawji, dated December 17, 2005, Raddatz is quoted as saying, "As far as Maher, I agree. No more talk…action." (Exhibit 14).

19. Maher Ghawji's brother Haitham is named in the U.S. government's evidentiary proffer for convicted terrorist Enaam Arnaout ("Arnout"). Arnaout is the former Director of the Benevolence International Foundation (BIF), a group with a "core mission" to assist Al-Qaeda (Exhibit 15).

20. Haitham Ghawji was a worker for BIF. The Arnaout proffer describes Haitham as a BIF logistics officer tasked to provide direct support to the Bosnian Army (Exhibit 16 - pages 67-68).

21. Maher Ghawji stated, during his June 2004 deposition, that he provided his brother with $13,000 for a computer company venture in war torn Bosnia. (Exhibit 4- pages 32).

22. Haitham Ghawji, in a letter to his brother Maher Ghawji that was received around the middle of 1993 (Exhibit 1), asked Maher if he knew about "holy war." He wrote, "And I have another question for you, my brother. I would like to know what are your thoughts about the Muslim way of holy war? You should be honest with yourself. This is what you should see, and you should think about it." (Exhibit 17).

23. In the 1993 letter to Maher Ghawji, Haitham tells his brother that he should go to Afghanistan to heal wounded Mujahadeen. He wrote, "If you want, you can come to help in the fronts in Afghanistan. There was one doctor there, his name, a Dr. Faleh Al-Libi (from Libya). He took care of the people there [wounded]. He did surgery with candle and flashlight, long into the hours. There is a shortage of doctors to help. We are short in salary. What do you think about visiting them, Maher? And maybe you will improve there [the situation]. My brother Maher, we need to move as Muslims, with all we can do. There isn't time, because the Muslims are being killed from all sides." (Exhibit 17).

24. In the 1993 letter, Haitham Ghawji discusses how Maher and Rosine Ghawji's children must be raised within the religion of Islam. Haitham says that Rosine should have nothing to do with the religious upbringing of the children. He writes, "The child should get up in the morning with the religion, and he shouldn't stop following it. He should follow the ways in the religion with the way that you raise him. And you should spend time with him. This issue is not related to your Christian wife. You are the one that is raising him in the religion. I find here that the child does not listen to what you tell him. Come and pray. My words are strong, and you need to keep the Quran and look forward to the jihad! I want you to swear, this issue of upbringing the kids (your kids now), whoever will raise them, will do so with the laws of the Quran, unlike the mother. Just upbringing the kids in the religion is a victory in itself." (Exhibit 17).

25. In the 1993 letter, Haitham Ghawji describes the evils of Christian women to Maher Ghawji. He writes, "How it happened to us - this marriage with infidel Christians - it's killing us. These Christians are tearing out our insides. The power of the infidels is getting larger than we the Muslims. And Allah will not allow them to return, if their children do not do not follow them [the parents]." (Exhibit 17).

26. Throughout the 1993 letter, Haitham Ghawji refers to Maher Ghawji as an "important agent," a "Sheikh," and a "commander." (Exhibit 17)

27. Haitham Ghawji has been linked to convicted felon Rafat Jamal Mawlawi, who also is connected to Enaam Arnaout ("Arnout"). On April 4, 2005, the FBI conducted a raid on Mawlawi's residence. According to the Memphis Flyer, found was a hidden stash of loaded weapons and ammunition clips, $34,000 in cash, two pictures of Mawlawi shouldering a rocket-propelled grenade launcher, a gruesome videotape of war casualties with Arabic text and voiceover, and more than 20 passports to Morocco, Syria, Iran, and other Middle Eastern countries." (Exhibit 18a & 18b).

28. In 2002, Arnout was indicted by a Grand Jury in the U.S. District Court for the District of Illinois (Exhibit 19). The case was assigned case number 02 CR 892.

29. In 2002, the U.S. Attorney's Office filed a "Government Evidentiary Proffer Supporting the Admissibility of Co-Conspirator Statements". On page 67 of that proffer, the U.S. Government indicated that "H. Ghawji" (referring to Dr. Ghawji's relative) was an employee of BIF that, on November 17, 2005, sent a memo to Arnout describing "the delivery of 200 tents from BIF to the Bosnian government in October 1995." H. Ghawji also "described his meeting with [Bosnian] government officials and summarized the government's needs," which logistical support of their war fighting capabilities. On that memo H. Ghawji wrote the following passage:

"Now let us go to the army needs: The fifth corpus in the Bihac area need the following: Tents, sleeping bags, other equipment for outdoor activities, kitchen sets for camping, medicines as antibiotics, bandages, Military shoes, field cars, and foods." (Exhibit 16 - page 68).

30. The U.S. Government's proffer goes on to state that Arnout's July 2, 1995 letter indicated "that a man named Hamad with no beard and mustache will be coming to Zagreb and is to be taken to brother Haitham [Ghawji] as soon as possible."

31. A July 3, 1995 letter from another BIF employee indicated that "brother Hamad had arrived and was going to Bosnia the next day." Another letter to Arnout "marked 'urgent,' indicating that the 'Institute' should not be contacted as 'circumstances are not convenient these days.'" (Exhibit 16 - page 68).

32. In one of the pictures found at Mawlawi's residence, Haitham Ghawji has been identified by FBI agents, as well as by Rosine Ghawji, as being the individual assisting Mawlawi in the firing of the grenade launcher (Exhibit 20).

33. Areej Zufari has a personal relationship with Dr. Maher Ghawji. All signs indicate that this relationship is an adulterous one (Exhibit 21).

34. Areej Zufari is the spokeswoman (Exhibit 22) for the Islamic Society of Central Florida (ISCF), an umbrella organization for seven Central Florida mosques, the majority of which are located in Orlando. The organization has numerous ties to Islamic extremist groups and individuals.

35. In December of 2003, the Universal Heritage Foundation (UHF), a former Islamic educational institution, held a three day conference in Kissimmee, Florida. The keynote speaker was supposed to be Shaikh Abdur-Rahman Al-Sudais, the chief cleric of the Grand Mosque in Mecca. Prior to being invited to speak at the event, Al-Sudais, on Saudi television, had called for the murders of Jews, Christians and Americans (Exhibit 23a). He has stated that Jews must be "annihilated," and he referred to Jews as "the scum of the human race, the rats of the world, the killers of prophets, and the grandsons of monkeys and pigs." (Exhibit 23b)

36. After UHF received negative press concerning Al-Sudais, UHF announced that the cleric's appearance was cancelled. Speaking as the ISCF spokeswoman, according to the Orlando Sentinel, Areej Zufari defended Al-Sudais stating that "attempted censure of the speakers is un-American." (Exhibit 22) About this, best-selling author and director of Jihad Watch, Robert Spencer, stated, "Evidently Zufari would have us welcome with open arms those who would destroy us." (Exhibit 24).

37. Currently, on the homepage of the ISCF website, the following statement is found: "We have made arrangements with ISLAMIC RELIEF to deliver aid to the victims of the earthquake." On the website, ISCF explicitly tells its viewers to "DONATE GENEROUSLY TO THE EARTHQUAKE RELIEF FUND." (Exhibit 25).

38. In December of 2004, ISCF co-sponsored an Islamic Relief concert. The flyer for the event states, "Fundraising proceeds to benefit Islamic Relief orphans." (Exhibit 26).

39. Islamic Relief, a charity based in the UK, with numerous satellite offices around the world, has been labeled by the government of Israel a terrorist front for Hamas. According to the UK publication, the Guardian, Israel accused the charity of "providing funds and assistance to Hamas." In May of 2006, Israel deported the head of Islamic Relief's Gaza operations, Ayaz Ali. (Exhibit 27).

40. In February of 2003, ISCF announced on its website that its affiliated Muslim Social Services group was sponsoring a fundraising dinner featuring Brooklyn Imam Siraj Wahhaj. (Exhibit 28).

41. Siraj Wahhaj is found on the U.S. Attorney's list of potential co-conspirators to the 1993 bombing of the World Trade Center (Exhibit 29). Two of the persons convicted in relation to the attack worshipped at Wahhaj's At Taqwa Mosque. They are explosives expert Rodney Clement Hampton-El and the spiritual leader of the conspiracy, Sheikh Omar Abdel-Rahman. At the bombing trial, Wahhaj testified on behalf of Abdel-Rahman (Exhibit 30).

42. In an audio taped sermon he gave at his mosque, referring to the United States, Wahhaj stated : "In time, this so-called democracy will crumble, and there will be nothing. And the only thing that will remain will be Islam." (Exhibit 30).

43. ISCF is affiliated with and holds classes for the Muslim Students Association (MSA) of the University of Central Florida (UCF). (Exhibit 31a & 31b).

44. In March of 2006, the MSA of UCF invited Ibrahim Dremali, the Imam of the Islamic Center of Des Moines, to speak at its 2-day conference, entitled 'Returning to Our Rabb.' (Exhibit 32). Dremali had previously been a representative for an organization that has told its followers to give "material support" to groups connected to Al-Qaeda and the Taliban (Exhibit 33a & 33b). In October of 2000, Dremali spoke at a rally where Israeli flags were burned and the crowd shouted, "With jihad we'll claim our land, Zionist blood will wet the sand." Dremali told the audience "not to be sad for those who were martyred and to not be afraid to die for what they believe in." (Exhibit 34).

45. The MSA of UCF currently sponsors a Xanga blog ring, which includes a blog titled 'deep on thought,' that features posters from the terrorist group Hezbollah. (Exhibit 35).

46. In December of 2002, ISCF paired up with the Islamic Society of North America (ISNA) and the Islamic Circle of North America (ICNA) to sponsor a five day conference in the city of Orlando (Exhibit 36). Both ISNA and ICNA, through their relationship to the Muslim Students Association (MSA) and Jamaat e-Islami (Pakistan), are organizations connected to the violent Muslim Brotherhood, a group founded in Egypt, in the 1920's, to fight against England's colonization of the Middle East (Exhibit 37 & 38).

47. One of the organizers of the conference, Zulfiqar Ali Shah, three years later, became the South Asia Director of Kind Hearts (Exhibit 39), a charity shut down by the U.S. Government in February of 2006 for raising millions of dollars for Hamas (Exhibit 40). In June of 2001, Shah is quoted in an article as saying, "If we are unable to stop the Jews now, their next stop is Yathrib (The Prophet's city of Medina), where the Jews used to live until their expulsion by Prophet Muhammad. That's the pinnacle of their motives." (Exhibit 41).

48. In the past, ISCF President Muhammad Musri has made disturbing statements about Christians and Christianity. According to the St. Petersburg Times, "Musri believes that many Arabs who say they were converted are lying and that they were actually Christians all along. He thinks they are using tales of conversion to get financial backing from evangelical ministries." (Exhibit 42) And comparing the religion of Islam to Christianity, Musri stated, "We don't want the Muslims to end up with 700 determinations of Islam." (Exhibit 43).

48. When Maher Ghawji and Areej Zufari traveled to Seattle, Washington in July of 2006 (supposedly to attend a wedding), they took numerous photos. One of the photos appears to have been taken from inside a warehouse overlooking an industrial area near the water. The other photos include pictures of various high-rise buildings, a passenger cruise liner, and two famous Seattle landmarks, the Sky Tower and the Helix Pedestrian Bridge. It is my reasoned opinion that these photographs were surveillance photos of possible targets (Exhibit 44).

49. It is my reasoned opinion that, based on the facts in this case and my qualifications and expertise in the field of terrorism, Dr. Maher Ghawji and Areej Zufari -- because of their past and present affiliations with radical Islamist individuals and groups, and because of their extremist statements and beliefs -- are a danger to society, in general, and a danger to Maher and Rosine Ghawji's children, specifically. I am of the belief that at a minimum, Dr. Ghawji and his brother Haitham Ghawji are terrorist collaborators who have provided material support to terrorist interests inside the United States and abroad.

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