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IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA

RODNEY WRIGHT,

Plaintiff,

No.

vs.

ISLAMIC CENTER OF SOUTH FLORIDA, INC.,

COUNCIL ON AMERICAN ISLAMIC RELATIONS,

CAIR-FLORIDA, INC.

Defendant

_________________________________/

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-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 past year, I have been a guest speaker at several conferences concerning the issue of terrorism, including the 2007 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. The Islamic Center of South Florida (ICOSF), also known as the Pompano Masjid, was incorporated in January of 1984. It is located at 507 NE 6th Street, in Pompano Beach, Florida. (Exhibit 1)

8. The website for the Islamic center is www.icosf.com. (Exhibit 2)

9. Found on every page of the ICOSF website is a link to Islamic Finder, a site that describes in which instances and to what degree a husband is allowed to beat his wife and discusses an impending war between Muslims and "the Jews plus other non-Muslims led by the Antichrist." (Exhibit 3a and 3b)

10. On the previous ICOSF website, www.icsfl.org, there were links contained within it to the Islamic Society of North America (ISNA) and the Islamic Circle of North America (ICNA), two umbrella organizations for radical mosques founded by members of the violent Muslim Brotherhood. (Exhibit 4 and 5)

11. On the previous ICOSF website, there was also a link to the Islamic Assembly of North America (IANA), an organization that was shut down after an 11-count indictment, issued by the U.S. Justice Department, alleged that the group operated websites that "promoted terrorism through suicide bombings and using airplanes as weapons." (Exhibit 4 and 6)

12. In July of 2006, ICOSF brought Hatem Bazian to speak to its congregation. Bazian was a former representative for the Hamas charity, KindHearts, and in April of 2004, he was caught on videotape calling for an intifada (armed uprising) against the United States. (Exhibit 7, 8 and 9)

13. Ayman Sokkarie, while he was Secretary of ICOSF (1996-2001), stated, "Islam will be re-established… and the world will see how just Islam is and how false all other ideologies are. It is just a matter of time." (Exhibit 10 and 11)

14. Hassan Sabri is the imam of the Islamic Center of South Florida (ICOSF).

15. Sabri grew up in Qalqilya of the "Palestinian Territories" and came to the United States via a "special travel document" issued by Israel that expired roughly 20 years ago. (Exhibit 12)

16. In February and March of 2000, Sabri was a teacher at the Islamic Center of Boca Raton (ICBR). (Exhibit 13)

17. During Sabri's time with ICBR, ICBR's website had on it numerous links to www.qoqaz.net (Jihad in Chechnya), one of the main websites raising funds and recruiting fighters for Al-Qaeda and the Taliban prior to 9/11. (Exhibit 14 and 15)

18. ICBR colleagues of Sabri's included: Bassem Alhalabi, a colleage of Palestinian Islamic Jihad leader Sami Al-Arian's, who was charged by the United States government with illegally shipping military equipment to Syria; Sayyed Khawer Ahmad, who was the webmaster for the official website of Hamas's charitable and educational apparatus, the Islamic Association (Al-Jamiya Al-Islamia); Lamya Hashim, the former President of the now-defunct Hamas-related charity, Health Resource Center for Palestine; and Ibrahim Dremali, a radical imam, who has admitted to being placed on the federal "no-fly" list. (Exhibit 16 [word doc], 17, 18, 19 and 20)

19. In August of 2000, ICOSF placed on its website a lecture Sabri had made to the congregation, entitled 'Kosova! What can we learn?' In it, he denounces the United States as being the enemy of Islam. He states the following: "Allah (SWT) tells us, in the Quran, that the kuffar [non-Muslim/infidel] will continue to fight Muslims - will continue to put a plan after a plan and implement a plan after a plan - until Islam will cease to be and until Muslims are either liquidated or they have joined the Christian or the Jewish faith… And it is imperative upon us as Muslims belonging to the Ummah of Islam to understand exactly what's happening to our brothers, not only for the sake of understanding alone, but so that we will know what the enemies of Islam are planning, and so that we will plan ourselves… [The United States] is calling its people and its army and its nation to rush to the help of Muslims, but in reality this is not what's going on. In reality what's going on is that they want to mobilize Muslims and to use the vigor and the vim that Muslims can generate - to use their money and to use their souls and to use their lives - so that they will further [the United States'] plans in that part of the world… [D]o not rely on the kuffar, because if you do so, you will suffer." (Exhibit 21)

20. In April of 2002, Sabri attended an anti-Israel rally at Miami's Holocaust Memorial, where his group made light of Nazi atrocities. (Exhibit 12)

21. In September of 2002, Sabri participated in an event that included numerous Islamist radicals, including Zulfiqar Ali Shah, the former South Asian director of the Hamas charity, KindHearts. (Exhibit 22, 23 and 24)

22. On a radio show, at the start of 2003, Sabri stated his belief that Jews have no right to Jerusalem and that Allah should "rid Beit Al-Maqdis [Jerusalem] of them sooner rather than later." As well, on the show, he rationalized a statement in Islamic Hadith - what he termed "a prophesy" - calling on Muslims to murder Jews. (Exhibit 25)

23. On the same show, Sabri defended another imam's (Ibrahim Dremali's) appearance as a character witness at a hearing for Adham Hassoun, a fundraiser for terrorist charities shut down by the United States government for funneling millions of dollars to Hamas and Al-Qaeda. (Exhibit 25 and 26)

24. CAIR or the Council on American-Islamic Relations has acted as the voice of ICOSB, defending ICOSB in the media against those that are against the building of a new ICOSB mosque in the city of Pompano Beach. (Exhibit 27)

25. CAIR was created, in June of 1994, by three leaders from the Islamic Association for Palestine (IAP), Nihad Awad, Omar Ahmad and Rafiq Jaber. (Exhibit 28 [pdf])

26. The IAP was the brainchild of Mousa Abu Marzook, who resides in Damascus, Syria as the Deputy Political Bureau Chief and the Spokesman of Hamas. (Exhibit 29 and 30)

27. In October of 1998, the former FBI Chief of Counter-Terrorism, Oliver "Buck" Revell, stated, "IAP is a Hamas front. It's controlled by Hamas, it brings Hamas leaders to the U.S., it does propaganda for Hamas." (Exhibit 31)

28. Hamas is on the U.S. State Department list of Foreign Terrorist Organizations. (Exhibit 32)

29. The IAP was shut down, in 2005, after the group was found liable for the murder of an American boy, David Boim, who was killed during a Hamas attack in Israel. (Exhibit 33)

30. In 1993, in Philadelphia, future leaders of CAIR met to discuss ways in which they could raise money within the United States for Hamas. (Exhibit 34)

31. One of the future CAIR leaders at the Philadelphia meeting and the former Chairman of the IAP was Ghassan Elashi. (Exhibit 34)

32. In January of 2006, Elashi was sentenced to seven years in prison for financing Hamas. (Exhibit 35)

33. Nihad Awad, one of the founders of CAIR and current National Executive Director of CAIR, was the Public Relations Director for the IAP prior to CAIR being created. (Exhibit 28 [pdf])

34. In March of 1994, Awad stated at Barry University in Miami Shores, Florida, "After I researched the situation inside and outside Palestine, I am in support of the Hamas movement more than the PLO…" (Exhibit 36)

35. Omar Ahmad, one of the founders of CAIR and one of the attendees at the Philadelphia meeting, was the President of the IAP prior to CAIR being created. (Exhibit 28 [pdf])

36. In July of 1998, as National Chairman of CAIR, Ahmad stated at Flamingo Palace in Fremont, California, "Islam isn't in America to be equal to any other faith but to become dominant. The Koran, the Muslim book of scripture, should be the highest authority in America, and Islam the only accepted religion on Earth." (Exhibit 37)

37. Randall Todd "Ismail" Royer was the Civil Rights Coordinator for CAIR. (Exhibit 38)

38. During his employment with CAIR, in September of 2001, Royer was in contact with Lashkar-e-Taiba, an Al-Qaeda-related terrorist organization located in Pakistan. (Exhibit 39 and 40)

39. In April of 2004, Royer was sentenced to 20 years in prison for his terrorist activities. (Exhibit 40)

40. Sami Al-Arian was one of the co-founders of the IAP. (Exhibit 41)

41. Al-Arian was the North American leader of Palestinian Islamic Jihad (PIJ). (Exhibit 42)

42. PIJ is on the U.S. State Department list of Foreign Terrorist Organizations. (Exhibit 32)

43. In May of 2006, Al-Arian was sentenced to 57 months in prison for providing material support to PIJ. (Exhibit 43)

44. In February of 2007, CAIR, along with other Muslim Brotherhood-related organizations, called for its followers to fast in solidarity with Al-Arian, who was, at the time, in the middle of a hunger strike. (Exhibit 44)

45. In February of 2007, CAIR called on its followers to write letters to government officials in support of Al-Arian. (Exhibit 45)

46. In March of 2007, CAIR repeatedly called on its followers to ask Attorney General Alberto Gonzalez to free Al-Arian from prison. (Exhibit 46)

47. In September of 2003, during the Senate Judiciary Subcommittee on Terrorism, Technology and Homeland Security, Senator Charles Schumer (D-New York) stated that CAIR leaders have "intimate links with Hamas" and that CAIR has known "ties to terrorism." (Exhibit 47)

48. In September of 2003, during the Senate Judiciary Subcommittee on Terrorism, Technology and Homeland Security, Senator Dick Durban (D-Illinois) stated that CAIR is "unusual in its extreme rhetoric and its associations with groups that are suspect." (Exhibit 47)

49. In December of 2006, Senator Barbara Boxer rescinded an award her office had given to the Executive Director of CAIR-Sacramento, Basim Elkarra, in part for CAIR's refusal to condemn Hamas and Hezbollah as terrorist organizations. (Exhibit 48)

50. Starting in December of 2006, within the course of 13 days, four CAIR leaders, including the National Executive Director of CAIR, the National Communications Director of CAIR, the National Legal Director of CAIR, and the Executive Director of CAIR-Sacramento, refused to condemn Hamas and Hezbollah as terrorist organizations. (Exhibit 48, 49, 50 and 51)

51. In the Spring of 1998, the former FBI Chief of Counter-Terrorism, Steve Pomerantz, stated, "…CAIR, its leaders, and its activities, effectively give aid to international terrorist groups. Unfortunately, CAIR is but one of a new generation of new groups in the United States that hide under a veneer of 'civil rights' or 'academic' status but in fact are tethered to a platform that support terrorism. The degree to which these groups are able to deceive the American public and intimidate writers and counter-terrorist officials will be a significant ingredient in whether this country will be rendered more vulnerable to terrorism in future years." (Exhibit 31)

52. It is my reasoned opinion that, based on the facts in this case and my qualifications and expertise in the field of terrorism, both the Islamic Center of South Florida (ISCOF) and the Council on American-Islamic Relations (CAIR) are working together to bring a 27,000 square foot mosque to the city of Pompano Beach, Florida for no other reason than to spread radical Islam throughout the area. This mosque, if built, will indeed be a threat to the local neighborhood, to South Florida, and to the United States in general.

_________________________________

(TYPE/PRINT NAME)

STATE OF _______________________

COUNTY OF _____________________

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

__________________________________

Signature of Notary Public-State of Florida

______________________________________________

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

Personally known ________________ OR Produced identification________________

Type of identification produced:___________________________________________


 

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