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IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT,
IN AND FOR ORANGE COUNTY, FLORIDA

ROSINE COLLIN GHAWJI, INDIVIDUALLY

AND ON BEFIALF OF HER MINOR SON,
T.G., AND MAHER GHAWH, JR.
CaseNo.
Plaintiffs,

01 CA / '-ILP*-^
vs.

AREEJ ZUFARI, MAHER GHAWJI AND

GARY BAYER.

Defendants.

VERIFIED COMPLAINT

Plaintififs, ROSINE COLLIN GHAWJI, individually and on behalf of her minor son,

T.G. and MAHER GHAWJI, JR., by and through their undersigned counsel, hereby sue

AREEJ ZUFARI, MAHER GHAWJI, and GARY BAYER, Defendants, and state:

JURISDICTION. VENUE. AND THE PARTIES:

1. This is an action for damages that exceeds $15,000 exclusive of interest, costs,
and attorneys' fees.

2. Plaintiffs, ROSINE COLLIN GHAWH ("MRS. GHAWJI"), and her minor child,
T.G., who is in her custody, and MAHER GHAWJI, JR. ("LOUIS GHAWJI") are, at all
material times, residents of Shelby Covinty Termessee.
> ,

COMPLAINT
ROSINE COLLIN GHAWJI V. A. ZUFARI, ET AL.

3. Defendant AREEJ ZUFARI ("MS. ZUFARI") is at all material times a resident of

Orange County, Florida and sui juris.

4. Defendant, Maher GHAWJI ("DR. GHAWJI"), is a resident of Shelby County,

Tennessee and is sui juris.

5. Defendant, Dr. GARY BAYER (DR. BAYER), is a resident of Shelby County,

Tennessee, and is sui juris.

6. DR. BAYER is subject to Florida's long Arm jurisdiction statutes by virtue ofhis
phone calls and communications into Florida by, through and wdth DR. GHAWJI and
MS. ZUFARI and involving MS. ZUFARI in the case with the children.

7. Defendant DR. GHAWJI is subject to Florida's long arm jurisdiction statute by virtue
ofhis phone calls and communications into Florida, and his travels to Florida where he
committed the tortuous acts alleged hereui in concert with the other Defendants.

GENERAL ALLEGATIONS

8. MRS. GHAWJI and DR. GHAWH were married in New York on December 25,1987
and lived together as husband and wife imtil their separation on June 19, 2004.

9. MRS. GHAWJI and DR. GHAWJI have two children bom during the marriage;
Plaintiff LOUIS GHAWJI, bom January 16,1989, and T.G., minor in the custody ofand
residing with MRS. GHAWJI in Memphis, Tennessee.

10. DR. GHAWJI was bom and raised in Syria and is a United States citizen by virtue
ofhis marriage to MRS. GHAWH.

11. At all times material to this action, DR. GHAWJI, in concert with Defendant MS.
ZUFARI, conspired to in efifect terrorize MRS. GHAWJI, LOUIS GHAWJI and T.G. He:
 COMPLAINT
ROSINE COLLIN GHAWJI V. A. ZUFARI, ET AL.

a. Told LOUIS GHAWJI and T.G. he would be proud if they blew

themselves up for Allah because it would be a glorification oftheir lives;
b. Told MRS. GHAWJI that he would rather see the children dead than them
not being fundamentalist Muslims.
c. Has secretly taken the minor child's passports, and threatened them and
MRS. GHAWJI with taking them to Syria, a terrorist state on the U.S.
watch list, against their will.
d. Photographed the younger son's birth certificate and e-mailed it to some
unknown individual in order to obtain a new birth certificate or new
passport.
e. Took T.G.'s DNA samples just before he tried to take him to Syria against
his will.
f. Told MRS. GHAWJI that he hated Americans and Jews in the presence of
the rriinor children, and celebrated the deaths of Americans as a result of
terrorist acts, including the September 11,2001 attacks.
g. Threatened MRS. GHAWJI with injecting her with undetectable
medications which would kill her.
h. Told MRS. GHAWJI that he is a member ofthe Muslim Brotherhood, a
violent political movement whose members are swom to "defend Islam"
with their "blood." He accepted this status with a group of fiiends, during
a trip they had made to Cairo, Egypt. He left Syria aroimd 1982, the year
a govemment-led massacre took place in the tovm of Hama - a
Brotherhood stronghold - which resulted in the deaths of 10,000 to 40,000
people. Following the massacre, members ofthe Brotherhood fled Syria,
some leaving for the U.S. or Europe, some joining up with Osama bin
Laden to fight in Afghanistan.
1. Told MRS. GHAWJI that he had a "private life and you better not
interfere with it."
 COMPLAINT
ROSINE COLLIN GHAWJI V. A. ZUFARI, ET AL.

12. MRS. GHAWJI, LOUIS GHAWJI and T.G. are and have been in unmediate fear that
DR. GHAWn will remove LOUIS GHAWJI and T.G. to Syria permanently against their
will, and that he will do them great physical harm if they do not obey his commands.

13. MS. ZUFARI is the spokesperson for the Islamic Society of Central Florida, on
information and belief a terrorist front operation'which at a minimum has aided and
abetted terrorists and/or terrorist organizations, and is, on information and belief, DR.
GHAWJI's mistress, and/or now secretly his wife under lislamic law.

14. MS. ZUFARI is a high profile Muslim advocate in the Orlando, Florida area, but
does not appear to have any income to support her life style.

15. MS. ZUFARI could have been secretly married to DR. GHAWJI in a Muslim
ceremony at the Island Society of Central Florida, where multiple religious marriages are
the norm. ' ' ,

16. On many occasions during DR. GHAWJI's marriage to MRS. GHAWJI, Dr.
GHAWJI made several trips to Orlando, Florida, where he visited MS. ZUFARI, was
seen picking him up at the Orlando Intemational Airport by MS. ZUFARI, and was seen
hugging and kissing her on the lips, acts wliich under Islam are reserved for married
couples.

17. DR. GHAWJI and MS. ZUFARI have also traveled as a couple to Seattle,
Washington, and on information and belief conducted targeting and surveillance
activities on American strategic interests.

18. MS. ZUFARI has visited DR. GHAWJI's family in Syria where she was accepted as
a second wife by his family.

19. DR. GHAWJI's and MS. ZUFARI's goal, through their own actions, and through
DR. GHAWHI's lawyers, David Caywood and John Ryland, and through a compromised
 COMPLAINT
ROSINE COLLIN GHAWJI V. A. ZUFARI, ET AL.

and biased and prejudiced judge in Memphis, Dorma Fields, and a compromised court
appointed psychologist, Defendant DR. BAYER, and other agents and instrumalities, was
and is to inflict severe emotional distress on MRS. GHAWJI, LOUIS GHAWJI and T.G.
in order to get MRS. GHAWJI to relinquish her parental rights, and to coerce LOUIS
GHAWJI and T.G. into submitting to them, in order to allow DR. GHAWJI and MS.
ZUFARI to indoctrinate the children as radical Muslim exfremists.

20. MS. ZUFARI has collaborated and acted in concert with DR. GHAWJI's goal of
taking MRS. GHAWJI's children in order to indoctrinate them to become radical Muslim
extremists.

21. On information and belief, and based on evidence, DR. GHAWJI and MS. ZUFARI
are terrorist collaborators and supporters, at a minimum.

22. DR. GHAWJI's has admitted in a Memphis court deposition, on June 4, 2004,
and to his wife ofbeing a Wahhabi Muslim, an adherent to a fanatical religious form of
Islam emanating from Saudi Arabia.

23. DR. GHAWJI has exhibited intolerance and hate towards Jews. During the June
2004 deposition, he stated that, when he speaks ofhis hatred towards Israelis, he mixes
up the terms "Israelis" and "Jews." 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 Y." He stated that in his religion, there is an "angel" that "w/// help the
Muslim and they will fight the Jew" and that there is a "rock" and, "ifthe Jew hide behind
it, [the rock] will indicate where that person is."

24. DR. GHAWJI's sons have written about how their father wants to kill all Jews.

25. About Palestinians becoming suicide bombers, DR. GHAWJI stated in his June
2004 deposition, "/ 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
 CQMPLAINT
ROSINE COLLIN GHAWJI V. A. ZUFARI, ET AL.

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."

26. DR. 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 vsdfe's dressing room drawer to take his younger son's passport. This was
without his wife's consent or knowledge.

27. The Ghawji sons wrote letters to fiiends and school teachers about how their
father was in possession oftheir passports and how he had told them that they were
leaving for Syria.

28. Syria has been designated by the U.S. State Department as a state sponsor of
terrorism.

29. During his June 2004 deposition, DR. GHAWJI stated that he was planning to
take one ofhis sons to Chicago against his will to attend the Islamic Society of North
America (ISNA) conference. ISNA was founded by members ofthe Muslim
Brotherhood, including the North American leader ofthe Palestinian Islamic Jihad,
convicted terrorist Sami Al-Arian.

30. In January of 1999, DR. GHAWJI issued checks for $300, $1000 and $500 to Mercy
Intemational, a charity that was implicated in the 1998 U.S. embassy bombings in East
Afiica, an AI-Qaeda operation. Mercy Intemational was originally created, under the
name Human Concem Intemational (HCI), to support the Afghan jihad against the
Soviets. DR. GHAWJI donated to HCI's "Bosnia fimd." The receipt for payment
appears to be signed by an "H. Ghavvji".

31. Jim Raddatz is a Tennessee law enforcement officer assigned to an FBI Joint
Terrorism Task Force, based in Memphis, Tennessee. In an e-mail to MRS. GHAWJI,
 COMPLAINT
ROSINE COLLIN GHAWJI V. A. ZUFARI, ET AL.

dated December 17, 2005, Raddatz is quoted as saying, "As far as Maher, I agree. No
more talk.. .action."

32. DR. GHAWJI's brother Haitham's name is set forth in the U.S. government's
evidentiary proffer for convicted terrorist Eneiam Amaout ("Amout"). Amaout is the
former Director ofthe Benevolence Intemational Foundation (BIF), a group with a "core
mission" to assist Al-Qaeda.

33. Haitham Ghawji was employed by BIF. The Amaout indictment describes
Haitham as a BIF logistics ofificer tasked with providing direct support to the Bosnian
Army.

34. DR. GHAWJI stated, during his June 2004 deposition, that he provided his
brother with $13,000 for a computer company venture in war tom Bosnia.

35. Haitham Ghawji in a letter to his brother, DR. GHAWJI that wais received around the
middle of 1993 asked Maher if he knew about "holy war." He wrote, "Andl have
another question for you, my brother. I would like to know what are your thoughts about
the Muslim way of holy wen-? You should be honest with yourself. This is what you
should see, and you should think about it."

36. hi the 1993 letter to DR. GHAWJI, Haitham tells his brother that he should go to
Afghanistan to heal wounded Mujahadeen. He wrote, "Ifyou 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."
 COMPLAINT
ROSINE COLLIN GHAWJI V. A. ZUFARI, ET AL.

37. In the 1993 letter, Haitham Ghawji discusses how Maher and MRS. GHAWJI's
children should be raised. Haitham says that Rosine should have nothing to do with the
religious upbringing ofthe children. He writes, "The child should get up in the morning
with the religion, and he shouldn't stop following it. He shouldfollow the ways in the
religion with the way Ihatyou raise him. Andyou 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, andyou need to keep the Quran and lookforward 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 ofthe Quran, unlike the mother. Just upbringing the kids in the religion
is a victory in itself."

38. In the 1993 letter, Haitham Ghawji also describes the evils of Christian women to
DR. 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 ofthe infidels
is getting larger than we the Muslims. And Allah will not allow them to return, if their
children do not do notfollow them [the parents] 7

39. Throughout the 1993 letter, Haitham Ghawji refers to DR. GHAWJI as an
"important agent," a "Sheikh," and a "commander7

40. Haitham Ghawji has been linked to convicted felon Rafat Jamal Mawlawi, who
also is connected to Enaam Amaout ("Amouf). 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 casli, 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 Eastem coimtries."

41. In 2002, Amout was indicted by a grand jury in the U.S. District Court for the
Northem District of Illinois. The case was assigned case number 02 CR 892.
 COMPLAINT
ROSINE COLLIN GHAWJI V. A. ZUFARI, ET AL.

42. In 2002, the U.S. Attomey's Office filed a "Govemment Evidentiary Profifer
Supporting the Admissibility of Co-Conspirator Statements". On page 67 ofthat profifer,
the U.S. Govemment indicated that "H. GHAWJI" (referring to DR. GHAWJI's relative)
was an employee of BIF that oh November 17, 2005 sent a memo to Amout describing
"the delivery of 200 tents from BIF to the Bosnian government in October 1995 ". H
GHA WJI also described his meeting with Bosnian government officials and summarized
the government's needs", which logistical support oftheir war fighting capabilities. On
that memo H. GHAWJI wrote the following passage:

"Now let us go to the army needsz The fifth corpus in the Bihac area need the
followingz Tents, sleeping bags, other equipment for outdoor activities, kitchen sets
for camping, medicines as antibiotics, bandages, military shoes, field cars, and
foodsr

43. The U.S. Government's proffer goes on to state that Amout'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".

AA. A July 3, 1995 letter from another BIF employee indicated that "brother Hamad had
arrived ahd was going to Bosnia the next day". Another letter to Amout "marked urgent,
indicating that the Institute should not be contacted as circumstances are not convenient
these days".

45. In one ofthe pictures found at Mawlawi's residence, Haitham GHAWJI has been
identified by Mawlawi as being the individual assisting him in the firing ofthe grenade
launcher. The identification of Haitham was confirmed to MRS. GHAWJI by agent Jim
Raddatz who took MRS. GHAWJI with him downtown in order to retrieve for her an
original ofthe picture. Jim Raddatz later testified in court that others had identified
Haitham in the picture.
 COMPLAINT
ROSINE COLLIN GHAWJI V. A. ZUFARI, ET AL.

46. MS. ZUFARI has an extramarital relationship with DR. GHAWJI.

47. MS. ZUFARI is the spokeswoman for the Islamic Society of Cenfral Florida
(ISCF), an umbrella organization for seven Cenfral Florida mosques, the majority of
which are located in Orlando. The organization has numerous ties to Islamic exfremist
groups and individuals.

48. 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 Sheikh 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. He has
stated that Jews must be "annihilated," and he referred to Jews as "the scum ofthe human
race, the rats ofthe world, the killers of prophets, and the grandsons of monkeys and
pigs7

49. After UHF received negative press conceming 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 ofthe speakers is un-American." 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."

50. Currently, on the homepage ofthe ISCF website, the following statement is
found: "We have made arrangements with ISLAMIC RELLEF to deliver aid to the victims
of the earthquake." On the website, ISCF explicitly tells its viewers to "DONATE
GENEROUSLY TO THE EARTHQUAKE RELIEF FUND7

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

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 COMPLAINT
ROSINE COLLIN GHAWJI V. A. ZUFARI, ET AL.

52. Islamic Relief, a charity based in the UK, with numerous satellite offices aroimd
the world, has been labeled by the govemment of Israel a terrorist front for Hamas.
According to the UK pubUcation, the Guardian, Israel accused the charity of "providing
fimds and assistance to Hamas." In May of 2006, Israel deported the head of Islamic
Reliefs Gaza operations, Ayaz Ali.

53. 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.

54. Siraj Wahhaj is found on the U.S. Attomey's list of potential co-conspirators to
the 1993 bombing ofthe World Trade Center. Two ofthe 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 ofthe conspiracy, Sheikh Omar
Abdel-Rahman. At the bombing trial, Wahhaj testified on behalf of Abdel-Rahman.

55. 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."

56. ISCF is affiliated with and holds classes for the Muslim Students Association
(MSA) ofthe University of Cenfral Florida (UCF).

57. In March of 2006, the MSA of UCF invited Ibrahim Dremali, the Imam ofthe
Islamic Center of I)es Moines, to speak at its 2-day conference, entitled 'Retuming to
Our Rabb.' 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. In October of 2000, Dremali spoke at a rally where Israeli flags were bumed
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."

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 COMPLAINT
ROSINE COLLIN GHAWJI V. A. ZUFARI, ET AL.

58. 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.

59. 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 ofOrlando. 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 I920's, to fight
against England's colonization ofthe Middle East.

60. One ofthe organizers ofthe conference, Zulfiqar Ali Shah, three years later, became
the South Asia Dfrector of Kind Hearts, a charity shut down by the U.S. Govemment in
Febmary of 2006 for raising millions of dollars for Hamas. 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 ofMedina), where the Jews used to live until their expulsion
by Prophet Muhammad. That's the pinnacle oftheir motives." Dr. Ghawji told Mrs.
Ghawji he gave money to Kind heart and that he knew the money was ftinneled to
Hamas, but that used the Kind Heart name because Hamas had been identified as a
terrorist organization. A special fundraising for Kindheart monitored by agent Jim
Raddatz was held in the "Clubhouse" located on Kerby Parkway, Memphis, in 2003.

61. In the past, 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." And comparing the religion of Islam to Christianity, Musri stated, "We don't
want the Muslims to end up with 700 determinations of Islam."

62. DR. BAYER is a psychologist that has been involved in the evaluation ofthe parties.

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 COMPLAINT
ROSINE COLLIN GHA w n V. A. ZUFARI, ET AL.

63. DR. BAYER'S has intentionally and negligently disregarded all evidence of DR.
GHAWJI's and MS. ZUFARI's terrorist ties in his reports regarding the mental health of
MRS. GHAWJI, LOUIS GHAWJI and T.G.

64. DR. GHAWJI has enlisted DR. BAYER to assist him and MS. ZUFARI in thefr
efforts to get MRS. GHAWJI to relinquish custody ofthe GHAWJI children, and to get
the children to submit to them and be raised as radical Muslim exfremists.

65. DR. BAYER was enlisted by DR. GHAWJI, and MS. ZUFARI, and on mformation
and belief, MS. ZUFARI, to tell frie kids about MS. ZUFARI, his misfress. .

66. On information and belief, DR. BAYER has made phone calls into Florida, and/or
used Defendant DR. GHAWJI as a conduit ia communicating with MS. ZUFARI in
Florida in furtherance ofhis conspiracy with DR. GHAWJI and MS. ZUFARI.

67. DR. BAYER, in concert with DR. GHAWH and MS. ZUFARI, intentionally
inflected severe emotional disfress on MRS. GHAWJI, LOUIS GHAWJI and T.G. by
wrongfiilly attempting to make her and the children believe she is delusional and/or
mentally ill, as well as inflict severe emotional disfress on the children by telling them
about their father's exframarital relationship with MS. ZUFARI, as well as disparaging
MRS. GHAWJI's general counsel Larry Klayman, and his expert, Joe Kaufinan, and
predicting to the children that Mrs. Ghavvji will lose her fight for custody and that T.G.
will be subject to the custody of DR. GHAWJI.

COUNT I; INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS

BY DEFENDANT MS. ZUFARI

68. Plaintiffs reallege and reaver paragraphs 1-67 ofthe Complaint as if fully stated
herein.

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 COMPLAINT
ROSINE COLLIN GHAWH V. A. ZUFARI, ET AL.

69. On various occasions from 2003 to present, Defendant MS. ZUFARI conspfred and
acted in concert with the other Defendants:

a. To coerce MRS. GHAWJI into relinquishing her custody ofthe GHAWJI

children and to have the children submit to be raised as radical Muslim
exfremists.
b. To flaunt her Muslim religious fervor as a better parental and spousal
altemative to MRS. GHAWJI, who is Christian.
c. To visit DR. GHAWJI's family in Syria and put herself out to be DR.
GHAWJI's second wife.
d. To encourage DR. GHAWJI to threaten MRS. GHAWJI with takfrig
LOUIS GHAWJI and T.G. from MRS. GHAWH so they could properiy
indoctrinate them in radical Muslim exfremism.

70. The acts ofDefendant described in paragraph 69 ofthis Complaint were done
willfully, maliciously, oufrageously, deliberately, and purposely with the intention to
inflict emotional disfress upon Plaintiffs, coerce MRS. GHAWJI to relinquish custody of
her children and coerce the children to submit to DR. GHAWJI's and MS. ZUFARI's
will that they become radical Muslim exfremists. Such acts were done in reckless
disregard of causing MRS. GHAWJI, LOUIS GHAWJI and T.G. severe emotional
disfress and physical harm. These acts did in fact result in severe and exfreme emotional
disfress to Plaintiffs and causing emotional and physical harm to Plaintiffs.

71. As a dfrect and proximate result ofthe Defendant's acts alleged aboye, Plaintififs
were caused to suffer and grievous mental and emotional suffering, loss of sleep, flight,
anguish, shock, nervousness, anxiety, and their daily activities have been severely
harmed, both emotionally and physically. Plaintiffs continue to be fearful, anxious, and
nervous.
WHEREFORE, Plaintiffs pray for judgment agamst Defendant MS. ZUFARI as
follows:

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 COMPLAINT
ROSINE COLLIN GHAWJI V. A. ZUFARI, ET AL.

a. Actual and compensatory damages in excess of $ 5,000,000.00.

b. Costs associated with the suit and such Other relief as the Court deems just and
proper.

COUNT n . INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS BY

DEFENDANT DR. GHAWJI.

72. Plaintififs reallege and reaver paragraphs 1-71 ofthe Complaint as if fully stated
herein.

73. On various occasions from 1996 to present. Defendant DR. GHAWJI:

a. Told Plaintiff LOUIS GHAWJI and T.G. he would be proud if they blew
themselves up for Allah because it would be a glorification oftheir lives;
b. Told T.G. that T.G. would be living with him and MS. ZUFARI because
MRS. GHAWJI has a mental problem;
c. Told MRS. GHAWJI tiiat he would ratiier see LOUIS GHAWJI and T.G.
dead than them not being radical Muslim exfremists.
d. Has secretly taken the LOUIS GHAWJI and T.G.'s passports and
threatened MRS. GHAWJI with taking tiiem to Syria.
e. Took T.G.'s DNA samples just before he tried to take him to Syria against
his will.
f Photographed T.G.'s birth certificate and e-mailed it to some unknown
individual in order to obtain a Syrian birth certificate or new passport,
g. Told MRS. GHAWn, LOUIS GHAWJI and T.G. tiiat he hated Americans
and Jews, and celebrated the deaths of Americans as a result of terrorist
acts, including the September 11, 2001 attacks;
h. Threatened MRS. GHAWJI with injecting her with undetectable
medications which would kill her if she did not submit to his will,
i. Visited MS. ZUFARI in Florida many times to engage in an exframarital
relationship with her and then flaunted this relationship to LOUIS
GHAWJI and T.G.

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 COMPLAINT
ROSINE COLLIN GHAWJI V. A. ZUFARI, ET AL.

j. Flaunted MS. ZUFARI's Muslim fervor as a better parental altemative to

MRS. GHAWJI who is Christian,
k. Upon information and belief married MS. ZUFARI in the Muslim
fradition without divorcing MRS. GHAWJI.
1. Told MRS. GHAWn, tiiat for a little as $ 1,000.00, he would be able to
hfre a "hitman" in Memphis' black community to kill her.
m. Threatened to take LOUIS GHAWJI and T.G. from MRS. GHAWJI so he
and MS. ZUFARI could properly indoctrinate them in radical Muslim
exfremism.
n. Took a sword from displayed for sale in Value City, a Memphis
department store, pressed it against MRS. GHAWJI, simulated
slashing her throat, and told her "that's what I would like to do with that
sword."
o. Told MRS. GHAWJI that he had a "private life and you better not
interfere with it."

74. The acts ofDefendant described in paragraph 73 ofthis Complaint were done
willfully, maliciously, oufrageously, deliberately, and purposely with the intention to
inflict emotional disfress upon MRS. GHAWJI, LOUIS GHAWJI and T.G., coerce MRS.
GHAWJI to relinquish custody of LOUIS GHAWJI and T.G. and coerce LOUIS
GHAWJI and T.G. to submit to DR. GHAWH's and Ms. ZUFARI's will tiiat tiiey
become radical Muslim extremists. Such acts were done in reckless disregard of causing
Plaintififs severe emotional disfress and physical harm. These acts did in fact result in
severe and extreme emotional disfress causing great psychological and physical harm to
Plaintiffs.

75. As a direct and proximate result ofthe Defendant's acts alleged above, Plaintififs
was caused to suffer severe and grievous mental and emotional suffering, loss of sleep,
fright, anguish, shock, nervousness, anxiety, and their daily activities have been severely
harmed, both emotionally and physically. Plaintiffs continue to be fearfiil, anxious, and
nervous.

16
 COMPLAINT
ROSINE COLLIN GHAWJI V. A. ZUFARI, ET AL.

WHEREFORE, Plaintiffs pray for judgment against Defendant DR. GHAWJI as

follows:
a. Actual arid compensatory damages in excess of $12,500,000.00.
b. Costs associated with the suit and such other relief as the Court deems just and
proper.

COUNT III. INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS BY

DEFENDANT DR. BAYER

77. Plaintiffs reallege and reaver paragraphs 1-76 ofthe Complaint as if fully stated
herein.

78. On various occasions from 2004 to present. Defendant DR. BAYER:

a. Conspfred and acted in concert with Defendant DR. GHAWJI and

Defendant MS. ZUFARI to coerce MRS. GHAWJI mto relinquishing her
custody of LOUIS GHAWJI and T.G. and coerce LOUIS GHAWJI and
T.G. into submitting to the will of DR. GHAWJI and MS. ZUFARI.
b. Was enlisted and compromised by Defendant DR. GHAWJI, and
Defendant MS. ZUFARI, to give biased mental health evaluations that
disregarded evidence ofDefendant DR. GHAWJI's and Defendant MS.
ZUFARI's collaboration and ties with terrorists.
c. Wrongfiilly attempted to make LOUIS GHAWJI and T.G. believe that
their mother is delusional and/or suffers from a mental illness in
furtherance ofhis conspiracy with Defendant DR. GHAWJI and
Defendant MS. ZUFARI.
d. Attempted to validate and flount DR. GHAWH's and MS. ZUFARI's
exframarital relationship during so called therapeutic sessions to coerce
LOUIS GHAWJI and T.G. to submit to tiie will of DR. GHAWJI and MS.
ZUFARI to raise the children as radical Muslim exfremists.

17
 a.

COMPLAINT
ROSINE COLLIN GHAWJI V. A. ZUFARI, ET AL.

e. Wrongfiilly tiireatened tiie LOUIS GHAWJI and T.G. in front of LOUIS

GHAWJI and T.G. to involuntarily commit the children to a psychiatric
hospital if they did not consent to staying ovemight with DR. GHAWJI.
f Misrepresented to LOUIS that he would have tiie FBI tell LOUIS tiiat DR.
GHAWJI is not a terrorist ui fiirtherance ofhis conspiracy with Defendant
DR. BAYER and Defendant MS. ZUFARI.
g. Misrepresented to T.G. that he needed to be medicated for Attention
Deficit Disorder, which he does not have,
h. Told LOUIS GHAWJI and T.G. tiiat tiieir motiier is crazy and tiiat she
would lose her divorce case and custody of her children,
i. Told LOUIS GHAWJI and T.G that thefr mother's general counsel, Larry
Klayman, is lying and helping her only for publicity and other
disparagements,
j. In a threatening manner, told LOUIS GHAWJI, while still a minor, that
the FBI wanted huri to stay with DR. GHAWJI.

79. The acts ofDefendant described in paragraph 78 ofthis Complaint and elsewhere
were done willfiilly, maliciously, oufrageously, deliberately, and purposely with the
intention to inflict emotional disfress upon the Plaintiffs, coerce MRS. GHAWJI to
relinquish custody of her children, and coerce LOUIS GHAWJI and T.G. to submit to
DR. GHAWJI's and Ms. ZUFARI's will that they become radical Muslim extremists.
Such acts were done in reckless disregard of causing Plaintiffs emotional distress and
physical harm. These acts did in fact result in severe and exfreme emotional disfress.

80. As a direct and proximate result ofthe Defendant's acts alleged above, Plaintiffs
were caused to incur severe and grievous mental, emotional, and physical suffering, loss
of sleep, flight, anguish, shock, nervousness, anxiety. Plaintiffs continue to be fearfiil,
anxious, and nervous.

WHEREFORE, Plaintiffs pray for judgment against Defendant DR. BAYER as

follows:

18
 4- ^ . * .

COMPLAINT
ROSINE COLLIN GHAWJI V. A. ZUFARI, ET AL.

a. Actual and compensatory damages in excess of $ 7,500,000.00.

b. Costs associated with the suit and such other relief as the Court deems just and
proper.
COUNT TV. NEGLIGENCE BY DEFENDANT DR. BAYER
81. Plaintiffs reallege and reaver paragraphs 1-80 ofthe Complaint as if fully stated
herein.

82. Defendant DR. BAYER owed a duty of care to LOUIS GHAWJI and T.G. in his role

as court-appointed psychologist in counseling LOUIS GHAWJI and T.G. for thefr

psychological well-being and, in particular, their relationships with MRS. GHAWJI and

DR. GHAWJI.

83. Defendant DR. BAYER, acting in concert with DR. GHAWH and MS. ZUFARI,

negligently beached the duty of care owed to LOUIS GHAWJI and T.G. in ways which

include, but are not limited, to the following:

k. Conspfred and acted in concert with Defendant DR. GHAWJI and

Defendant MS. ZUFARI to coerce MRS. GHAWJI into relinquishing her
custody of LOUIS GHAWJI and T.G. and coerce LOUIS GHAWJI and
T.G. into submitting to tiie will of DR. GHAWH and MS. ZUFARI.
1. Was enlisted and compromised by Defendant DR. GHAWJI, and
Defendant MS. ZUFARI, to give biased mental health evaluations that
disregarded evidence ofDefendant DR. GHAWJI's and Defendant MS.
ZUFARI's collaboration and ties with terrorists.
m. Wrongfully attempted to make LOUIS GHAWJI and T.G. believe that
thefr mother is delusional and/or suffers from a mental illness in
furtherance ofhis conspiracy with Defendant DR. GHAWJI and
Defendant MS. ZUFARI.
n. Attempted to validate and flount DR. GHAWJI's and MS. ZUFARI's
exframarital relationship during so called therapeutic sessions to coerce

19
 COMPLAINT
ROSINE COLLIN GHAWJI V. A. ZUFARI, ET AL.

LOUIS GHAWJI and T.G. to submit to tiie will of DR. GHAWJI and MS.
ZUFARI to raise the children as radical Muslim exfremists.
o. Wrongfiilly tiireatened tiie LOUIS GHAWn and T.G. in front of LOUIS
GHAWJI and T.G. to involuntarily commit the children to a psychiatric
hospital if they did not consent to staying ovemight with DR. GHAWJI.
p. Misrepresented to LOUIS that he would have tiie FBI tell LOUIS tiiat DR.
GHAWJI is not a terrorist in fiirtherance ofhis conspfracy with Defendant
DR. BAYER and Defendant MS. ZUFARI.
q. Misrepresented to T.G. that he needed to be medicated for Attention
Deficit Disorder, which he does not have,
r. Told LOUIS GHAWJI and T.G. tiiat thefr motiier is crazy and that she
would lose her divorce case and custody of her children,
s. Told LOUIS GHAWJI and T.G that thefr mother's general counsel, Larry
Klayman, is lying and helping her only for publicity and other
disparagements,
t. In a threatening manner. Told LOUIS GHAWJI, while still a minor, that
tiie FBI wanted him to stay witii DR. GHAWJI.

84. The negligent acts ofDefendant DR. BAER, described in paragraph 83 ofthis
Complaint and elsewhere, were done, as previously alleged, in conjunction with the
conspfracy between DR. GHAWJI and MS. ZUFARI.

85. As a dfrect and proximate result ofthe Defendant's negligent acts alleged above,
Plaintiffs were caused to incur severe and grievous mental, emotional, and physical
suffering, loss of sleep, fright, anguish, shock, nervousness, anxiety. Plaintiffs continue
to be fearful, anxious, and nervous.

WHEREFORE, Plaintiffs pray for judgment against Defendant DR. BAYER as

follows:

20
 COMPLAINT ,
ROSINE COLLIN GHAWJI V. A, ZUFARI, ET AL.

a. Actual and compensatory damages m excess of $ 7,500,000.00.

b. Costs associated with the suit and such other relief as the Court deems just and
proper.

COUNT V: CONSPIRACY

86. Plaintiffs reallege and reaver paragraphs 1-85 ofthe Complaint as if fiilly stated
herein.

87. Defendants, each and every one of them, jointly and severally, entered into a
conspfracy to fiirther and commit the over acts and practices with the intent and effect of
severely damaging Plaintiffs emotionally and physically, including, but not limited to:
a. Conspiring to coerce MRS. GHAWJI into relinquishing her parerital rights
over the GHAWJI children in order to facilitate their indoctrination into
radical Muslim exfremism and coerce LOUIS GHAWJI and T.G. into
submitting to the will of DR. GHAWJI and MS. ZUFARI to be indoctrinated
as radical Muslim exfremists.
b. Discredit substantiated allegations made by MRS. GHAWJI, LOUIS
GHAWJI and T.G. agamst Defendants DR. GHAWJI and MS. ZUFARI to tiie
effect that they are terrorist collaborators and/or have ties to terrorism.
c. Try to make MRS. GHAWJI, her fiiends, family and associates believe that
she is mentally ill.
d. Harm LOUIS GHAWJI and T.G. by telling tiiem oftiie exframarital
relationship between MS. ZUFARI & DR. GHAWJI.
e. Other facts as alleged in this Complaint.

WHEREFORE, Plaintiffs pray for actual, compensatory, non-economic, and

econonuc damages, and an award of attomey's fees and costs in excess of
$25,000,000.00, and such other relief as this court deem just and proper, against each and
every Defendant, jointly and severally.

DEMAND FOR JURY TRIAL

21
 COMPLAINT
ROSINE COLLIN GHAWJI V. A. ZUFARI, ET AL.

Plaintiffs demand a jury trial on all issues so triable.

Dated this ^ ^ day of February, 2007

Respectfiilly Submitted,

KLAYMAN, ESQ.
T^m4a.AYMAN LAW FIRM, P.A.
^I Bar.No: ^lA^TLl'd
601 Brickell Key Drive, Suite 404
Mianii, Florida 33131
leklavman(a),bellsouth.net
305-579-3455 (tel)
305-579-3454(fax)

22
 COMPLAINT

I, Louis Maher Ghawji, swear that tfae foregoing is accurate and true to tfae best ofmy
knowledge and belief.

Daled: ( y ' / l ^ / o 7
V . 6 M A H E R GHAWJI

STATE OF w _)
)ss:
COUNTyOF pAjojfcjy J

The foregoing instrument was acknowledged before me tfais z^^ dayof

January 2 0 0 7 J ( L O U B ^ 4 A H E R GHAWJI, who is personally known to me or who has
produced TTV/ <io<fe<r .v^/ '^e-L-5-e . as identification.
'77'-'7:(7;^_
f'UBLJC t a

^ ' ^ ^ LARGS5 -J^B NOTARYPUBLIC

%-.^- ^ w^^mmmmMmmiiM^'
Dated this '^~ I "^day of Jahtifiyr2007

Respectfully Submitted,
\

I, ROSINE C GSA.WJI, on behalf ofm>'5e]f andraylainor chittJ, T.G., sv^'car tbat tb$
foregdng is accurate aad tnw to the b!5t ofray Jcnowledge aad bdie ^

^ , ^ ( > 7 ^

STATB OF / g / ? / ? r 5 > g )
)ss:
COUNTTtOF 5 / ' g / ^ & ^ )

Tlur aregQit|g mstromcnt was acknowledged beibre mo this ^ fc: day of

'2007. ROSINE C GHAWJI, wito is personally JctKWtti to me or who has
produced <^ /^- i7>r,'Y4j^^^ ^ r C . as idemilicaiioii.

NOTARYi - B ^ .Lie

Dated this ^ ' ^ daycf< -2007 . ^ , H l lil !<'.;,

f / OF .
S -; T5aSE "- I

\ \ piEa.c ..\ *

fctnat.K'?