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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

_________________________________/

AFFIDAVIT

I, Rosine Ghawji, 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 Tennessee, over the age of eighteen and of sound mind.

MY HUSBAND'S SUPPORT OF TERRORISM:

3. I met Dr. Ghawji ("Husband") for the first time in 1986. In early 1987, I traveled to France on business and met him there. It was the first time he told me that he was a very religious Muslim and that he was a member of a group of Muslim militants called the Muslim Brotherhood. He went on to say that he had traveled to Cairo, Egypt with friends before moving to France in order to join the Muslim Brotherhood. He further stated that he and his friends "swore their blood" to defend Islam. 

4. In December 1987, I married my Husband in New York City.

5. We never talked about what he did for the Muslim Brotherhood until years later during a trip to New York City. I had read a book about the life of former Egyptian President Anwar El Sadat. I discussed the book with my husband because I noticed that President Sadat, as a young man, had also been a member of the Muslim Brotherhood. In fact, he had been assassinated by the Muslim Brotherhood.

6. When I told my Husband about President Sadat's connection to the Muslim Brotherhood, he responded by saying that his assassination was justified and consistent with the laws of Islam. He explained that President Sadat was considered a traitor because he tried to make peace with the Jews and that he had "let Islam down." He later went on to say the Muslim Brotherhood were right to kill him.

7. I was first visited by the FBI in 1991 while I stayed in our New York City apartment. The agent was very interested in my Husband's activities and asked explicit questions about my Husband's relationship with a Syrian man. My husband had rented my other apartment at 76th Street and York to a man. The agent warned me that some Syrians were trying to infiltrate the USA to conduct terrorist attacks and that the man who rented my apartment was on a terrorist watch list. He left his business card and told me to call him if I noticed strange activities.

8. From 1987-1992, my Husband had been an avid follower of a blind sheik named Omar Abdel Rahman that controlled a New Jersey Mosque. My Husband and others foreigners that came to visit always also visited the New Jersey Mosque. I went to the Mosque and took Louis my son (who was then a baby) and waited in the women's room for hours waiting for them to finish their meetings. Some of the meetings took place at late hours in the evening, sometimes finishing at 2:00 or 3:00 am. My Husband explained that all night prayers are required by the Koran. On occasion, my Husband visited other Mosques (like the Afrooq Mosque located on Atlantic Avenue in Brooklyn and another one in Queens, NY).

9. My Husband had many strange Arab friends. For example, Dr. Basal Dahyani was one of the visitors that came to see us during that time period. Dr. Dahyani said he was from Colorado. Mr. Dahyani was later arrested by the Police for attempting to kidnap his son and take him out of the country.

10. Mr. Bashar Akkad was also a friend of my Husband. He flew in from Belgium for 2 days in order to bring a package to unknown persons in New Jersey.

11. Mr. Walid was another of my Husband's friends. He flew in from Japan. We drove him to Washington, DC in order to visit some people. We all visited the Mosque in New Jersey.

12. In 1991, Haitham Ghawji ("Haitham"), my Husband's brother and the strangest and most dangerous of his associates, came to NYC with a friend. They also visited the New Jersey Mosque.

13. We moved to Memphis in 1992.

14. In 1993, I saw a letter addressed to my Husband and received phone calls for him from Haitham. Haitham wrote about his intentions to train for Jihad. The letter from Haitham was read and explained to me by Dr. Aljamolhi (who was a friend of ours). Dr. Aljamolhi explained the letter contained disturbing explanations and justifications for killing non-Muslims, provisions which encouraged my Husband to join the Jihad, and leave me, his non-Muslim wife. The letter also pressured my Husband to indoctrinate our sons in militant Islam, including preparing them to "die for Islam."

15. When I confronted my Husband about the letter, he explained Jihad was going to war in order to die for Islam. He also told me that Haitham was going to go "with a bunch of friends and their leader to train for Jihad."

16. My Husband flew to Canada immediately after receiving Haitham's letter in order to meet with him and others before they had to leave for Bosnia. The letter, interpreted for me by Dr. Aljamolhi, totally changed my Husband's attitude toward me and our two sons. I tried to reason with my husband and encouraged him to first talk with his brother on the phone in lieu of going to Canada. My husband got very upset with me and told me that I will never be able understand them and that he had to go. Things got very bad between us after that incident.

17. My Husband later told me that Haitham had left to join a Bosnian training camp to fight the Jihad. Haitham trained a man named Rafat Jamal Malawi, whose Memphis' home was raided by the FBI on April 4, 2005; there they found a gruesome video tape of war casualties with Arabic text and voice over, weapons, ammunition, two pictures of Malawi holding a rocket launcher, and $34,000 in cash.

18. In 1993, Haitham called several times from Afghanistan, Turkesjistan, and Bosnia. He mostly talked about needing money.

19. In 1996, my Husband gave Haitham a $13,000.00 check to support his alleged computer business in Bosnia. I never saw that money again. I now know Haitham was working for a company called Benevolence International Foundation (BIF), which the U.S. Government closed because it financed terrorism. BIF's founder Enaam Arnaout was later sentenced to 20 years in federal prison for financing terrorism. Arnout is also the last name of my mother in law.

20. Later that year, Haitham left Bosnia and came to Memphis to visit my Husband. I opposed the visit because I was aware of his brother's negative feelings against my boys and I because we're not Muslim. I felt had no choice because my Husband said that he would kick me out of the house if I did not allow his brother to visit us.

21. My Husband worked most of the time during Haitham's visit. My relationship with my brother-in-law was polite, but distant. He was constantly on the phone calling his friends and reading stuff in Arabic. One night Haitham asked to watch the 11:00 news and did not say a word. He seemed to have been very disappointed about something. The next night, around 2:00 am or 3:00 am, I received a phone call from a man in Saudi Arabia requesting to speak immediately with Haitham. I objected because it was so late at night. The man was very nasty to me on the phone and ordered me to get Haitham immediately.

22. The next day, Haitham asked again to watch the 11:00 o'clock news. When breaking news was reported about the bombing of the Khobar Towers in Saudi Arabia, he jumped to his feet and screamed, "WE GOT THEM." I asked him, "What?" because I was not paying much attention to the news.

23. He then said, "The Americans,… we got them. They think they are going to rule the world, but they do not know what it is to have a war on their own soil, but pretty soon they will."

24. When I looked closely at the bombing described on the TV, I immediately realized what he meant. They were going to do the same thing to the United States.

25. I never mentioned this situation to my Husband. I was afraid of saying anything to him because I knew he would take his brother'side and take it out on me. Days after this incident, my Husband called a friend of his in Florida by the name of Amar Charani, to ask him to get Haitham a job. Haitham left for Florida with a suitcase full of audio tapes with recordings from a man I later identified as Osama Bin Laden (his picture was on the cover of the tapes).

26. Haitham came back from Florida and then left for Canada before going to Syria. Haitham returned from Syria and moved to Florida after quickly getting a work permit from Detroit.

27. Around the same time a lot of his friends from Toronto moved to Orlando also.

28. In 1997, we moved to the house at 3440 Lake Pointe in Memphis where I now live with my two sons. We got a computer for the home for the first time. Starting in 1997, I began to examine all computer activity at the home. This is when I really started to suspect that my Husband's associates were planning some kind of attack against the USA.

29. In the summer of 1998, I met with Father Sartain at St. Louis Catholic church in Memphis. During my confession, I told him about my fears based on the information I learned from my Husband's activities. Father Sartain introduced me to Walter Haynack (who was an ATF officer), who in turn introduced me to FBI Agent Tim Boucher who was from the FBI in Memphis. Father Sartain is now a Bishop in Arkansas.

30. The FBI was very interested in what I had to say and the things I had shown them. They told me to keep our meetings secret. They also told me that I was in a very dangerous situation and that I had to be extremely careful. They also told me that they had Haitham and the family "on their radar screen." I supplied Tim Boucher with many of my Husband's and Haitham's e-mails, pictures and phone numbers I had found in my home computer. The FBI encouraged me to continue my monitoring of our home computer activity and kept on warning me to be extremely cautious and not to tell anyone about my findings.

31. From 1999 to 2000, my experiences with my Husband and his associates further reinforced my belief that an attack against the USA was imminent. I contacted FBI Agent Tim Boucher while I was on vacation in France to inform him of the latest e-mail exchange because I found it highly disturbing. The cities that were listed as targets in those e-mails were New York City, Washington, DC, Miami, and Las Vegas. The e-mails were very explicit. I remember seeing a picture attached to an e-mail that depicted a skeleton representing death; the skeleton's hand held a map of the USA. On the map you could see lights flashing from different cities, but the above mentioned cities were outlined and destroyed. Tim Boucher said he contacted the FBI in Washington, and they said not to worry because other intelligence sources suggested attacks would occur outside of the USA.

32. On September 11, 2001, a few hours before the attack, we received an e-mail from Haitham announcing that some of his friends were coming to the U.S. and to please welcome them. I secretly gave that e-mail to FBI Agent Tim Boucher.

33. I later confronted my Husband about Haitham's e-mail who said it was a joke. He forwarded it to Dr. Guerra (a cardiologist from Brazil living in Memphis). Dr. Guerra concurred that the e-mail should be given to the FBI.

34. Tim Boucher retired from the FBI soon after 9/11/01 and left me an e-mail address to communicate with him just in case I needed him. The e-mail address he gave me was rascaldoggie@aol.com.

35. I refused to work with another FBI Agent after Tim's retirement.

36. In October 2001, we were visited by a Mathew Drake from Washington, DC. I think he was a government agent. He wanted an explanation about my Husband's brother Haitham. When Mathew Drake was at our home, FBI agent Tim Boucher called him and Mr. Drake left.

37. On or about December of 2001, we were invited to Dr. Gaber 's house for dinner. Another Doctor friend of ours, Dr Amiri, had just returned from Iran. He explained how difficult it had been to board a plane. Dr. Amiri went on to say that it is going to be impossible to bring something harmful onto a plane due to the new security measures. My Husband responded with a very frightening answer. He said: "Don't worry , we will find another way to get them." Dr Amiri, his wife, and I were all shocked.

38. Our second son Tarek (K.K.) was born in Memphis on July 8, 2002.

39. In September 2002, my Husband wanted the boys and me to go to Syria with him. When I refused to go or let him take the boys we had a terrible argument and he became increasingly violent.

40. He argued with me about Israel and what he calls "the Jews." For example, I taught French at that time to a little Russian Jewish boy. Once my Husband came home at the same time the boy's mother came to pick him up. He was very calm while they were there, but as soon as they left he exploded and he told me not to have that "F@#! Jew in his house" and that I could not teach French to him anymore. He then said I was a "Zionist" and that "he knew what to do with Zionists." He also threatened to kill me in bed and stated that he was a very good doctor and that he knew how to inject me with poison that no one would be able to detect or trace to determine the cause of death. He also mentioned that he could hire a hit man in downtown Memphis to shoot me. He also said he was a Wahabi Muslim. I did not know that; I thought he was a regular Sunni Muslim.

41. Life with him at the house became so frightening that one of my friends told me that she knew somebody in the FBI that I should contact because it would be safer for me. I told her that the FBI was slow and very inefficient for terrorism. She said her FBI friend was a well-known, local guy, and a good man. She then referred me to a man named Jim Raddatz ("Raddatz"). When we met he gave me his business card, which portrayed him as a Task Force officer with the Memphis FBI counter-terrorism division.

42. Raddatz and I had numerous meetings. He monitored our lives on an almost daily basis. He had me wear a recording device he called "a wire" for days in order to get more information about what was going on in the house. He was also asking me to monitor the Internet. He was interested in a Pay Pal like account my Husband used to make a donation of $500.00 to a fraudulent charity: Kindhearts Foundation. I later learned the Kindhearts Foundation had been set up to collect money for the Palestinian terror organization named Hamas. My Husband did not hide or deny his financial contributions to Hamas from me, but he said he could not use the word Hamas publicly because the US had labeled it a terror organization.

43. In the summer of 2003, my Husband tried again to take us all to Syria. I refused and left for France with the boys where I felt they were safe.

44. My Husband went to Syria at the same time, and taking a lot of money with him as usual.

45. During that trip to France in the summer of 2003, my Husband told me told me to "take a good look at my country because it would be the last time you will see it." The statement upset me terribly because I didn't know whether it was a death threat, a threat to never allow me to return to France, or that he knew about plans to destroy or attack it.

46. At that time I also secured $50,000 dollars in each of the boys' custodial account to prevent my Husband from completely wasting our money through donations and the stock market. My Husband had lost tremendous amounts of money by buying and selling losing stocks through his Ameritrade accounts.

47. In October 2003, my Husband cut off financial support to me and the boys. He closed the joint bank account with my name and cancelled the credit cards. We survived for almost one year on a credit line and one credit card that was still in my name. In June 2004, my Husband told me he had taken the children's passports and was ready to take the children to Syria three days later. The children opposed the trip but were told they had no choice but to go. They suffered terribly by the thought of having to go to Syria. He had plane tickets and seemed intent on taking the children to Syria.

48. I called Raddatz and told him about my Husband's cruel and abusive behavior. He said it would be a good idea to leave the house and secure a restraining order against my Husband. I contacted Attorney Kay Turner. Raddatz also spoke with her. I was so afraid of my Husband that I had to leave the house with the boys to an undisclosed location until the restraining order was put into effect.

49. The police removed my Husband from our home and all of his personal belongings. The boys and I then moved back into the house. When my Husband found out that I had filed for separation, he in turn filed for divorce.

50. Raddatz told me that I should have to talk to the boys and tell them not to go anywhere with their father and to run away if they were ever taken to an airport. Raddatz spoke to the policemen who were in the house to take my Husband away. Attorney Turner and I went to court. Kay Turner succeeded in getting an order preventing my Husband from harming me or the kids.

51. In June 20, 2004, Judge Donna Fields ("Judge Fields") met with my two sons to determine child visitation for my Husband. Despite all the children's pleas to the contrary, Judge Fields ordered the child visitation to occur with their father every other Sunday.

52. There were months in 2004 that were filled with strange events. Our home was broken into and the house alarm would go off at strange times.

53. I contacted Raddatz every time it seemed somebody had broken into the house. He would send the Police and would sometimes even inspect the house himself. He once found strange foot prints in the attic. He decided to put cameras in the house that would record 24 hours a day. He instructed me to watch the tapes and to give him the tapes in the event I saw something unusual. One night I saw a shadow coming through the garage door. It was obvious on the tape and I gave him the tape. He watched the tape and said the tape was black. Raddatz was the only person who knew where I was going or where I was staying if I had to leave Memphis with the children. For example, one day the boys and I had to go to Nashville. While coming back from Nashville a black SUV passed our Mercedes ML320 at a very high speed. An occupant in the black SUV opened a window and threw a big black ball at us. The ball destroyed the car's side mirror. I did not lose control of the car, but pulled over and called the police. I called Raddatz immediately. He was on his way to Mississippi when he told me to forget about it because I did not have any proof that the attack was connected to My Husband.

54. Raddatz also told me that he knew a lot about my Husband. He believed my Husband led a double life, one as a respected Memphis Dr., and another as terrorist financier with connections in Florida he could not talk to me about. He said he was in charge of the investigation into my Husband's illegal activities and that FBI agent Matt Chapman, his supervisor at that time, had given him nine men to help him. A few of them came to my house and examined our computer. Another man searched the house for hidden microphones or cameras. Raddatz also showed me a lot of pictures of men and asked me if I knew them or if my Husband knew them. Some of them I identified as my Husband's associates and some of them I did not know. Jim also told me that he had evidence that suggested my Husband was providing financial support to the Kindhearts Foundation, which was raising money for Hamas. He also told me that the FBI knew that his brother Haitham was implicated in the Khobar Tower attacks in Saudi Arabia, but they could not do anything about it because he had fled the U.S. Raddatz also told me that he had involved the CIA and was also meeting with the Israeli security service known as the Mossad.

55. Raddatz was doing surveillance when my Husband and I attended a fundraising breakfast for the Kindhearts Foundation. Raddatz was outside pretending to be walking a dog and watching every person coming to the fundraiser.

56. Raddatz also let me know in advance that the FBI was going to arrest my neighbor from Palestine. The FBI did eventually raid our Palestinian neighbor's home in the spring of 2005; four of the occupants of that neighbor's house are still in jail.

57. Raddatz also told me that my Husband called the FBI office to ask Eric Jackson to "remove the Ghawji name from the no fly list." Jim told me that Eric Jackson was angry with my Husband and had told him: "you have until the 19 th to bring me the information I requested… I can put you in Jail or deport you."

58. Despite all these facts, the court psychologist issued reports on the children's examinations that completely ignored the fact that my Husband directly supports terrorism.

59. Dr. Bayer's (the court appointed psychologist that examined my children) report was based on phone conversations between Raddatz and Dr. Patricia Kelley (another court appointed psychologist that evaluated the children). For reasons I cannot fully explain, Raddatz told Dr. Kelley that I was wrong and that my Husband should have more visitation rights. He also told her not to let the boys go to France. Raddatz also had private meetings with the Judge. Judge Fields mentioned their private meetings in the court transcript documenting the December 2005 hearing.

60. When I confronted Raddatz about his testimony he told me that he could not comment on my Husband's terrorist connections because the investigation into his criminal activity was still pending. He did say to me that he told the Attorney Turner and the Dr. Kelly that I was very credible. Later, Eric Jackson called me and asked me to stop talking with Jim Raddatz. Raddatz later e-mailed me saying that he did not care about what Eric Jackson had said and that as far as my Husband was concerned "it was time for action."

61. My Husband told me that he called Raddatz once to ask him to let one of his friends "pass at the airport" in Cincinnati without being checked and that Raddatz had helped him. Dr Ghawji also told me that he thought Raddatz was not very smart. After their meeting with Eric Jackson, the FBI supervisor, Raddatz told my Husband "don't worry, the black guy does not know what he is talking about; they have nothing against you I will help you."Even my Husband said he was very surprised by Raddatz statement.

MY HUSBAND'S CRUEL AND ABUSIVE BEHAVIOR:

62. From 1992-1997, my Husband was never home. He was constantly working at different hospitals out of town, and spending at least 150 nights a year away from home.

63. I was always alone with the children. When he was home he claimed he was tired and slept most of the time. I never complained about his work schedule or his shifts. I never prevented him from going to work. In fact, I supported his work.

64. Life in our home became increasingly intolerable starting around the fourth year of our marriage. My Husband became obsessed with militant Islam. He also became very nasty and violent towards the children and me.

65. After September 11, 2001, we were not allowed to watch the news because he was upset by what he called the pro-American "propaganda" produced by the American news corporations about 9-11. My Husband said that the 3,000 American deaths at the Twin Towers were "nothing" compared to the number of people that were killed by Americans around the world.

66. He constantly expressed his true feelings, which are full of hate, towards the US, Jews and Israel. We could not watch any show on TV that included anybody with a Jewish name. He forced me to turn off the television any time a man and a woman kissed or became intimate on the screen.

67. He continuously said that American civilization was corrupt and that "he couldn't take it anymore." He started to praise suicide bombers in Israel and made it clear that he would not hesitate to sacrifice his own children if necessary and would blow himself up too. I argued with him many times about this.

68. He attempted to indoctrinate the boys to become what he called "good Muslims." I would have compromised with him over the issue of religion but for his militant beliefs and support for terrorism.

69. One day my youngest son KK told him he didn't like Muslims. My husband told him he better be a good Muslim or "you are not my son anymore." He then came back to the living room, looked directly at me and said ," if the children are not good Muslims, I would rather see them dead." This was a terrifying experience.

70. My Husband was rarely ever at the house. He eventually took all of his paperwork to the office. When he was home, he was very mean and demanding to all of us. The boys were afraid of him and when he would drive into the driveway they would immediately run to their rooms and close the doors.

71. Despite his $450,000 salary, he was always very cheap and refused to pay for extra curricular activities like soccer or chess tournaments. He continuously complained about having to pay for activities that benefited the children, but had no problem writing large checks to his brother Haitham and other terrorists. In fact, he lost hundreds of thousands of dollars in the stock market by buying losing stocks. I found this contradiction very strange. He would do anything to save money and yet he was willing to lose hundreds of thousands with "a click of a mouse" with volatile stocks. He did not seem to be bothered by it. He kept on doing that even when I asked him to stop. I can only reason that his losses in the stock market were somehow related to his money laundering and terror financing activities.

72. My husband never took us out to a restaurant unless we were traveling and didn't have access to a kitchen. We never went to see a movie as a family.

73. In June of 2004, my Husband again told me he was going to Syria, took the boys' passports and reserved plane tickets for a flight leaving the following Monday. I refused because I feared he would kidnap them and divorce me in my absence in Syria under their very male chauvinist divorce laws.

74. Another time during the summer of 2004, during one of my Husband's child visitation days, he took the boys with their pellet guns to a large parcel of private property on the Mississippi river. Raddatz called me and said the police had spotted my Husband's car, that it seemed to have been abandoned, and that they were looking for him and the boys. Signs were posted on the property that read, "Private Property – No Trespassing." My Husband had ignored the signs, parked the car illegally in a ditch, and took the boys into somebody's private property without their permission.

75. While they were shooting the air guns, a person who lived in the vicinity called the Police. When the police showed up they examined my Husband's license plate number and called for more police cars. When the reinforcements arrived, they aimed their rifles at the boys and their father. They asked them to walk slowly and to put down their guns. My Husband told the boys not to listen to the Police and he started to argue with the them. The boys were very frightened. The police searched my Husband's car and then let them go. The boys remained scared and emotionally affected by that incident for many months afterwards.

76. I was terribly upset because first I thought he had kidnapped the children and later because of the trauma he caused them. When I requested a Police report from Raddatz he said there would be no report. Meanwhile, Raddatz kept me informed of the FBI investigation into my Husband, his brothers and friends.

77. During the summer of 2005, my Husband took the children to the Shelby farm lake to float around on a small pedal boat. Shelby farm lake laws prohibit swimming or bathing in the lake because it is dangerous to swim there. The children later told me that when they were in the middle of the lake, he told the children to disregard the signs and jump in the water.

78. Several times this year, my Husband has allowed my son KK (who is only 14 years old) to drive the car in town. KK does not have a Driver's License or Learner's permit. I fear my Husband continues to have disregard for K.K.'s safety during his time alone with the boy.

79. I have witnessed my Husband lie several times to the Police during traffic stops. Each time my Husband is stopped by the Police for speeding in Shelby County, he gets away with it by saying he is a Doctor and is on his way to the hospital. He has lied to Police in for that purpose while the children were in the car. He would tell the kids later that "when you are a doctor you are above the law."

80. My Husband has been cheating on me with a woman from Orlando. Her name is Areej Zufari, a Muslim woman who is also a spokesperson for the Islamic Society of Central Florida. He has made several trips to see Ms. Zufari there since 2004. I hired a private investigator to follow him. He got pictures of my Husband being picked up at the Orlando, Florida airport by Ms. Zufari, him staying at her home overnight, and them kissing in public. They've also traveled together to Seattle. This summer, Ms. Zufari traveled to Syria where she was introduced to my Husband's family (my in-laws) as his fiancée.

81. My Husband and Ms. Zufari have exchanged many love letters and e-mails, some of which I have had the misfortune of reading.

82. My children and I have been seriously traumatized not only by my Husband's infidelity, but also by his cruel imposition of militant Muslim values. They have been further traumatized by the Court appointed psychologist's recent attempt to get them to talk to their father about his mistress.

STATE OF TENNESSEE

COUNTY OF _____________________

Subscribed and sworn to me this ______ day of ____________, by ______________.

__________________________________

Signature of Notary Public-State of Tennessee

______________________________________________

(Print, type or stamp commissioned name of Notary Public)

Personally known ________________ OR Produced identification________________

Type of identification produced:___________________________________________


 

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