1. This is a pro se action, brought by a former federal prosecutor, not a member of the Florida Bar, pursuant to the Florida Consumer Protection act, to enjoin Defendant and his purported Florida charities from continuing fraudulent, deceptive and unconscionable practices, to wit: laundering money for extreme racist, terrorist, and other non-charitable organizations.

Parties

2. Plaintiff is a citizen of the United States and a resident of Pinellas County Florida.

3. Defendant is a citizen of Kuwait and a resident of Hillsboro County, Florida.

4. Defendant is, or was, an officer, managing director and/or registered agent of several purported charities including, but not limited to, the Islamic Concern Project, the International Committee for Palestine and the World Islamic Studies Enterprise, all of which list Hillsborough County as their principal place of business.

Venue

5. Venue is appropriate in Hillsborough County as the situs of Defendant�s residence and as the registered address of his purported charitable corporations.

Jurisdiction

6. The Court has jurisdiction to hear this cause of action pursuant to Chapter 501, Section 211., et. seq., of the Florida Statutes (Florida Deceptive or Unfair Trade and Practices Act (FDUTPA), also known as the Florida �Little FTC� Act, or Consumer Protection Act) which specifically includes non-profit corporations within the jurisdiction of the Court upon complaint of an aggrieved person. The jurisdictional amount of unlawfully laundered, converted, or transferred money is greatly in excess of $15,000.

Standing

7. Plaintiff is an �aggrieved person� within the meaning of the Consumer Protection Act on one or more of the following grounds:

Plaintiff is a donor to one or more of Defendant�s purported charities, and is able to represent the interests of other donors to ensure that their donations are, in fact, used for a charitable purpose.

Plaintiff is a taxpayer whose tax burden was increased by Defendant�s scheme of creating false and fraudulent tax exempt entities in the State of Florida.

Plaintiff is a volunteer officer, member or financial supporter of several legitimate charities working to fight racism and discrimination against Muslims, Jews and Christians, whose contributions of time and money were diminished by unfair competition with Defendant�s scheme of using purported charities to raise funds from the public through fraudulent and deceptive means in support of extreme racist, terrorist and non-charitable purposes.

Plaintiff is a citizen and resident of Florida, whose civil rights have been substantially chilled by the Defendant�s scheme of locating extreme racist and terrorist organizations in the Tampa Bay community.

Fraudulent Application for Tax Exempt Status

8. In 1988, the articles of incorporation of an entity called the Islamic Concern Project (ICP) were filed with the Florida Department of Corporations for registration as a non-profit corporation .

9. Defendant is, or was, an officer, managing director and/or registered agent for ICP.

10. In support of its application for tax exempt status, the articles of incorporation for ICP stated that, in the event of dissolution, the assets of the organization would go to Islamic Trends, a not for profit corporation of the District of Columbia.

11. In truth and in fact, no such organization as Islamic Trends, or anything similar, was ever registered as a non-profit entity with the District of Columbia. 12. Islamic Trends is a fictitious entity created for the purpose of bolstering ICP�s application for non profit corporation status in the State of Florida.

13. ICP�s application for tax exempt status was void ab initio for false and material misstatement of fact.

Bait and Switch

14. After ICP was granted tax exempt status as a non-profit corporation, Defendant established another ICP entity described as the �International Committee for Palestine�.

15. The second ICP, the International Committee for Palestine, is not registered as a non-profit corporation with the State of Florida.

16. The second ICP, the International Committee for Palestine, is not, and never was, entitled or eligible for non-profit status as a charity, religious organization or other tax-exempt status in the State of Florida, or in any State.

17. The second ICP, the International Committee for Palestine, is not registered with the Department of Agriculture and Consumer Affairs for purposes of soliciting contributions from the public.

18. Both ICP entities used the same post-office box registered to Defendant.

19. In truth and in fact, Defendant�s scheme was to solicit funds for the International Committee for Palestine under the guise of a non-profit corporation, the Islamic Concern Project.

20. Defendant and his associates repeatedly solicited funds from the public for the International Committee for Palestine, requesting that the checks for their donations be made out to �ICP�.

21. Defendant and his associates repeatedly solicited funds for the Islamic Concern Project, requesting that the checks for their donations be made out to �ICP�.

22. In truth and in fact, Defendant�s scheme was to deceive and mislead consumers who wished to donate to a tax-exempt religious charity, ICP, by diverting their money to another ICP entity, at the same post office box.

23. In truth and in fact, Defendant�s scheme was to use the first ICP as a shell, or front, in order to obtain tax-exempt donations for the second ICP affiliate.

24. In truth and in fact, Defendant co-mingled funds from a non-profit corporation with an unregistered fictitious entity using the same initials and post office box.

25. In truth and in fact, no legal connection or affiliation can exist between the two ICP entities, as one is an unregistered fictitious entity and the other is a registered non-profit corporation.

False Advertising

26. Defendant�s second ICP, the International Committee for Palestine, held itself out to the public as an affiliate of the first ICP.

27. Defendant�s Second ICP, the International Committee for Palestine, published a magazine called �Inquiry� whose Editor-in-Chief was listed on the page one masthead as �Sami A. al-Arian,� the defendant in this action.

28. Beneath Defendant�s name on the �Inquiry� masthead appears the following text: �The Inquiry is published on a bi-monthly basis (Feb., Apr., Jun., Aug., Oct., Dec.) by the Islamic Committee for Palestine (I.C.P.); an affiliate of Islamic Concern Project, Inc., a non-profit organization, P.O. Box 82009.

29. In truth and in fact, Defendant�s advertising was an unfair and deceptive scheme to convince members of the public that the International Committee for Palestine was eligible as an �affiliate� of the first ICP to receive tax deductible contributions as a non-profit organization at the same address.

30. In truth and in fact, the International Committee for Palestine is not now and never has been eligible either for non-profit status, tax exempt status, or to solicit public contributions in any form.

31. In truth and in fact, the International Committee for Palestine should have registered with the Department of Agriculture prior to advertising for contributions from the public, and failed to do so.

32. In truth and in fact, Defendant intended to use false advertising and commingled funds from the first ICP because he knew that the second ICP was an illegal, unlawful and/or criminal organization under state and federal law.

Fraudulent and Fictitious Names:

Alter Ego of a criminal enterprise

33. Defendant�s second ICP, the International Committee for Palestine, is the fictitious name or alter ego of the American branch of the international criminal organization, �Palestinian Islamic Jihad.�

34. The Palestinian Islamic Jihad is also known as Islamic Jihad, the Palestinian Islamic Jihad, PIJ, the Islamic Movement of Palestine, and/or Palestinian Islamic Jihad � Shakiki faction.

35. The Palestinian Islamic Jihad, and its alter egos, have been designated by the Secretary of State as an international terrorist organization, along with Al Qaida, Hamas and Hizbollah.

36. The Secretary of State�s designation prohibits the Palestinian Islamic Jihad, Al Qaida, Hamas and Hizbollah, their agents, officers, supporters and/or affiliates from soliciting contributions within the United States.

37. In his State of the Union Address, President Bush specifically named the Palestinian Islamic Jihad, along with Al Qaida, Hamas and Hizbollah, as the most dangerous and evil terrorist organizations in the world, and promised to continue efforts to identify and staunch the flow of funding for such terrorist organizations.

38. It is a felony, under Federal Law, for any citizen or resident of the United States to solicit or receive contributions for the Palestinian Islamic Jihad, Al Qaida, Hamas or Hizbollah.

39. In truth and in fact, Defendant and his associates devised a criminal scheme to use false organizational names, fictitious organizational identities and fraudulently alleged non-profit status as a means to illegally solicit financial contributions for the Palestinian Islamic Jihad, a terrorist organization banned by the laws and regulations of the United States.

40. According to confidential client sources, the intelligence service of a friendly foreign government alleged that they had wiretapped the Damascus, Syria, headquarters of the Palestinian Islamic Jihad, using highly classified means and methods, which inadvertently intercepted a telephone conversation from an unknown person in Tampa, Florida. [hereinafter the Damascus intercept]

41. According to confidential client sources, the Damascus intercept recorded the voice of an unknown Tampa caller screaming at a senior leader of the Palestinian Islamic Jihad that Hamas [a rival terrorist group] had stolen the public credit for an attack in Israel for which his organization had raised the funds on behalf of the Palestinian Islamic Jihad. The Tampa caller loudly and strenuously complained that Hamas� taking the credit for the killings in Israel was impairing his fund raising efforts in America.

42. The friendly foreign government was concerned that the Palestinian Islamic Jihad had opened a fund-raising cell in America and that a senior member of this group, apparently with direct access to, and influence over, the highest levels of the Palestinian Islamic Jihad, was operating in Tampa, Florida.

43. The friendly foreign government shared the Damascus intercept with an intelligence agency of the United States, upon condition that the source of the information could not be identified, and requested that the US Government ascertain the identity of the unknown senior terrorist leader in Tampa.

44. Subsequently, the U.S. government assisted the friendly foreign government by determining the identity of the Tampa caller, whose voice was conclusively identified as that of the Defendant, Sami Al Arian.

45. The Government of the United States, pursuant to a National Security Letter, examined Defendant�s bank accounts and found numerous instances where large sums of money had been transferred to a person, or persons who resided in the Middle East and his ties to terrorist organizations.

46. The Government of the United States, pursuant to the Foreign Intelligence Surveillance Act, received lawful authorization from the special Federal FISA Court to wiretap the home and offices of Sami Al Arian.

47. In 1994, an American reporter named Steven Emerson produced an award winning PBS documentary, �Jihad in America,� which exposed the fact that terrorist groups were soliciting funds in the United States. Defendant was peripherally named in passing in this documentary as a person linked to terrorist fund-raising in the United States.

48. Defendant falsely and fraudulently claimed to the press and public that he was being victimized as a prominent Muslim educator, that he knew nothing about fundraising for terrorist groups, and that there was no evidence against him.

49. Shortly afterwards, in 1995, the Defendant was informed of the FISA wiretap. The Federal Bureau of Investigation received and executed a lawfully authorized warrant to search the home and offices of Defendant and seize videotapes, documents and bank records in his possession pertaining to the Palestinian Islamic Jihad.

50. Among the records seized by the FBI were Arabic language magazines published in Tampa by the International Committee for Palestine, including an interview with Fathi Shikaki, then head of the Palestinian Islamic Jihad, praising his activities. That article was widely distributed by Shikaki as a publicity handout and the ICP magazines were identified by the Palestinian Islamic Jihad leaders as their official publications.

51. The Arabic-language ICP magazines seized by the FBI appeared on their face to be the official publications of the Palestinian Islamic Jihad as both the logo and name of the Palestinian Islamic Jihad appeared prominently upon the ICP masthead, including those issues personally published by Defendant during his tenure as editor.

52. Among the records seized by the FBI were Defendants� videotapes of his meetings with, and fundraising for, officials of Palestinian Islamic Jihad and other terrorist groups.

53. The Palestinian Islamic Jihad used the funds they solicited through defendant�s publications and fundraising efforts to murder men, women, children and infants in the Middle East through a campaign of bombings, shootings, stabbings and other violent acts.

54. The Palestinian Islamic Jihad is not a charitable organization recognized by the state of Florida or by any State as its funds are used exclusively for assassination or to pay pensions to the families of deceased or captured assassins (�martyrs and prisoners�).

55. The FBI and the Immigration and Naturalization Service prepared a composite videotape from dozens of Defendant�s own videotapes. The FBI�s English language transcript summarizing Defendant�s videotaped speech collection is a publicly available document under the Freedom of Information Act. Plaintiff retains a copy of the same and will reproduce a copy for the Defendant upon request and payment for the copy. [hereinafter cited as FBI tr. P. 1-4].

56. Defendant�s own videotapes confirm that Defendant personally was present and supervised the solicitation of funds for the Palestinian Islamic Jihad while standing in front of Arabic-language posters containing praise for and the logo of the Palestinian Islamic Jihad. [FBI tr. P.2-3]

57. Defendant�s own videotapes confirm that Defendant was present when his associate explained the secret connection between the Islamic Committee for Palestine and the Palestine Islamic Jihad: ��a short briefing about the Islamic Committee for Palestine, it is the active arm of the Islamic Jihad Movement in Palestine, and we like to call it the Islamic Committee for Palestine here for security reasons.� [FBI Tr. P. 2]

58. Defendant falsely claimed to the press and public that he never knew anything about terrorist movements, but Defendant knew, or should have known, that his ICP organization was being used by the Palestinian Islamic Jihad to solicit funds in America since his own videotapes show that he was present on those occasions.

59. In truth and in fact, Defendant�s own videotapes show that he was publicly introduced as the President of the International Committee for Palestine, including in his introduction a briefing of his role as the head of the �active arm� of the Palestinian Islamic Jihad in America. [FBI Tr. P.2]

60. In truth and in fact, Defendant�s own videotapes show that he was personally aware that �security reasons� were the cause for the Palestinian Islamic Jihad to call itself the ICP in America. [FBI Tr.2]

61. In truth and in fact, Defendant�s own videotapes show that he was personally present while the same associate, who previously introduced Defendant as President of the �active arm� of the Palestinian Islamic Jihad, stood in Defendant�s presence at an ICP conference to solicit money for the killing of Jews by the Palestinian Islamic Jihad. [FBI Tr. 2]

62. Defendant watched while his associate begged for $500 to kill a Jew: �Donate to the Islamic Jihad! Mida Zalooum from the Islamic Jihad held a dagger and stabbed four of the Jews in [Jerusalem]�The Jihad there is still erupting in Palestine from village to village, I tell you it is not for the [ICP] organizations with respect to everyone but for the Jihad. The Jihad! One of them would leave his house with a knife to stab the Jews � twelve Jews after the events of the Gulf War. Brothers, the intifadah calls you. Five hundred dollars!� [FBI Tr. 2]

63. Defendant knew, or should have known, that his ICP organization was being used to launder money from supporters of the Palestinian Islamic Jihad specifically intended for the killing of Jews because he was present when the audience was told how to make their $500 donations to kill a Jew: �If you write a check, write it for the Islamic Committee for Palestine, I.C.P. Who would add to the five hundred dollars of Hajj Ahmad?� [FBI Tr. P.2]

64. Defendant�s own videotapes show that he did not protest or correct anyone when ICP was described as a false front for Palestinian Islamic Jihad in America, nor was he surprised when it was said that this deception was necessary for �security reasons. � Nor did he object at being introduced as President of the �active arm� of a terrorist group. Nor did he object when ICP conferences were used to raise funds to kill Jews. [FBI Tr. 1-4]

65. The only criticism Defendant made was that the attacks against Israel should not have been suspended while American soldiers were being killed in a war against Saddam Hussein, and that the Islamic Jihad should have continued their : ��protests during the oppressive war why did we stop? Let us continue the protests, let us damn America. Let us damn Israel, let us damn their allies until death. Why do we stop?� (FBI Tr.2].

66. Defendant�s own videotapes show that his colleague Ramadan Abdullah Shallah echoed defendant�s call for more military action by the Palestinian Islamic Jihad against Israel and the Gulf War allies: ��the first solution is to topple the regimes�Now when we go to topple the regimes will it be a picnic, meaning a Sunday picnic, or Jihad? Now, how do we topple the rulers? I say to you, we topple the rulers with Jihad. I propose a way. I say toppling the rulers and rubbing their nose in the dirt and Jihad against them is not terrorism. [FBI Tr. P.2]

67. Defendant�s own videotapes showed that he agreed with his colleague Shallah�s sentiments that killing American, European and NATO soldiers was not terrorism, because they were allies of �subhuman� Jews cursed by God. In Defendant�s own words: �{God] cursed those who are the sons of Israel�Those people God made monkeys and pigs. They kicked you out of your homes�And who did this other than the colonialist arrogant Americans, Europeans and NATO�.Jihad is our path. Victory to Islam, Death to Israel.� [FBI Tr. P.4]

68. Defendant�s own videotapes show that Defendant�s Nazi-style propaganda equating the Jews with subhuman species was heard and understood by his audience as a call for the military form of Jihad with continued killing and violence towards Jews and their western allies.

69. Defendant�s own videotapes calling for Jihad against Jews, Americans, Europeans and NATO allies was heard and understood by his audience as a call for armed violence against Israel and its allies, and not as a call for the more traditional peaceful Islamic interpretation of Jihad.

70. Defendant�s own videotapes show that Defendant�s audience understood and echoed his extremely racist commands as a call for racial violence, and replied with their commitment to: �kicking out the sons of monkeys and pigs from the land of Isra and Miraj�.Directing all the rifles at the first and last enemy of the Islamic nation, and that is the sons of the monkeys and pigs, the Jews.� [FBI Tr. P.4]

71. While Defendant is free to express any political opinion he chooses, and even use public forums for the incitement of hatred towards Jews, the incitement of violent acts is not protected speech under the First Amendment, nor is the incitement of racial violence a permitted charitable purpose under the laws of the State of Florida.

72. In truth and in fact, Defendant�s extreme racism and incitements to violence fall far below the minimum threshold of good moral character required for an officer or director of a non-profit corporation under Florida Law.

73. In truth and in fact, Defendant�s scheme to advocate hate crimes and solicit funds for the purpose of carrying out racial violence under the guise of a Florida charity is an unconscionable, deceptive and unfair business practice under the Florida Consumer Protection Act.

74. Defendant�s charities were fronts for networking with other terrorist groups.

75. Under the guise of an ICP educational conference, Defendant and/or his agents and servants, repeatedly invited known international terrorists and leaders of extreme racist organizations to the United States. [FBI tr. P.1]

76. Defendant�s own videotapes show that Defendant regretted that some of the people he invited were prevented from attending his ICP conference, including the �Blind Sheik� who was later investigated for the first bombing of the Twin Trade Towers, and was afterwards convicted of another conspiracy to bomb New York landmarks. [FBI Tr. P.1]

77. In order to facilitate the process of obtaining visas for terrorists to attend Defendant�s terrorist conventions, Defendant, his agents and servants incorporated yet another purported non-profit entity in the State of Florida known as the �World Islamic Studies Enterprise.� (WISE).

78. Defendant, his agents and servants, deceived a public university of the State of Florida into granting WISE a quasi-official educational affiliation, without disclosing to University officials that WISE would serve as a front for ICP and the Palestinian Islamic Jihad, which deception was an unfair, unconscionable and deceptive practice designed to mislead the public at large and a public university in particular .

79. In truth and in fact, Defendant had covertly merged ICP and WISE, using the same �ICP-WISE� post-office box for both, registered in the name of Defendant. Defendant�s ICP agents and servants were installed as the directors and/or employees of WISE.

80. The pre-eminence of the ICP-WISE organization in the world of terrorism became evident in 1995 when Fathi Shikaki, head of the Palestinian Islamic Jihad, was assassinated. One of defendant�s subordinates from ICP-WISE moved to Damascus, Syria to become Secretary General of the Palestinian Islamic Jihad.

81. In truth and in fact, Defendant�s unfair, deceptive and unconscionable scheme was to use WISE�s educational affiliation as a means of evading federal immigration scrutiny. The ICP-WISE connection to a public University enabled terrorists to more readily obtain temporary visas to attend terrorist conventions which appeared to the federal immigration officials to be legitimate educational conferences sponsored by a public university of the State of Florida.

82. As a result of Defendant�s scheme to expand his purported charitable fronts in Florida, many additional terrorists were able to obtain visas to the United States to attend Defendant�s terrorist conventions.

83. In truth and in fact, the purpose of Defendant�s scheme to use charitable fronts to facilitate immigration was to enable terrorists from around the world to enter the United States for the purpose of discussing a merger with Defendant�s Palestinian Islamic Jihad or at least coordinate their terrorist activities in the future.

84. Among the documents discovered in Defendant�s residence by the FBI was a strategic plan, drawn up by one of Defendant�s �students�, for establishing armed �militia� organizations within those states which provided minimal supervision of non-profit entities.

85. In truth and in fact, all of Defendant�s purported charitable organizations were part of a strategic scheme to further the cause of international terrorism. Having students draw up plans for an armed militia is neither a charitable nor an educational purpose within the meaning of Florida law.

86. Defendant�s plan for a merger of terrorist groups was motivated in part by a lack of funds to continue paying blood bounties to the families of suicide bombers (�martyrs and prisoners�), and in part by his desire to unify and coordinate his Islamic Jihad�s movement�s activities with better known terrorist groups such as Hamas.

87. In 1995, the FBI seized the following handwritten letter from Defendant�s residence, which document was declassified in December 2000:

�The movement�s financial situation is very difficult and it cannot fulfill its responsibilities toward the martyrs and prisoners. Despite this, it carries out distinctive operations which all the Arab armies lacked the strength to execute. The link with the brothers in Hamas is very good and making steady progress, and there are serious attempts at unification and permanent coordination. (FBI Translation from the hand-written Arabic, p. 2, par. 1, signed �Your brother, Sami al-Arian�)

88. In truth and in fact, Defendant�s scheme of using Florida charitable and University fronts to attempt �unification and permanent coordination� of international terrorist organizations was an unfair, deceptive and unconscionable practice in violation of the Florida Consumer Protection Act.

Money laundering

89. In 1995, the FBI discovered checks drawn on the bank account of the �International Committee for Palestine� signed by Defendant, which checks were cashed by Defendant�s contacts in the Middle East.

90. Neither the State of Florida, the University of South Florida, nor Defendant�s Florida organizations have registered any non-profit charity or tax exempt subsidiary in the Middle East.

91. In truth and in fact, Defendant�s ICP checks were �blood bounties� paid by the Defendant to the families of suicide bombers (�martyrs and prisoners�) or to other terrorist operatives of the Palestinian Islamic Jihad.

92. In an INS case against one of Defendant�s subordinates in IPC-Wise-Palestinian Islamic Jihad, the Justice Department submitted a secret in camera FBI affidavit (now redacted and declassified) summarizing the numerous crimes committed by Defendant, citing evidence seized from Defendant�s home and office as well as from classified intelligence sources. Plaintiff retains a copy of the same and will reproduce a copy for the Defendant upon request and payment for the copy. [In the matter of Mazon Al-Najjar, Immigration Court, Bradenton Florida, File No. A26 599 077, Unclassified Summary of FBI ex parte, In Camera Declaration, hereinafter cited as �FBI Affidavit�]

93. Although that defendant�s name was blacked out in the redacted declassified version, his identity can be determined from his description in the FBI affidavit as the holder of a doctorate degree, the brother-in-law of the deportee, the co-signer of checks, a person whose home and office were searched by the FBI in 1995, and the person who was introduced at an ICP conference as President of the active arm of the Palestinian Islamic Jihad. [FBI Affidavit, pp. 6-8, 11-14]

94. Defendant Al Arian is the only person in the world with a blacked out name eight spaces long who matches all these criteria. Similarly, his close associate, Dr. Shallah, is the only person in the world with a blacked out name seven spaces long who is now Secretary General of the Palestinian Islamic Jihad.

95. The FBI Affidavit also quotes from, and summarizes, the terrorist �Manifest� or by-laws of the Palestinian Islamic Jihad, a copy of which was discovered in Defendant�s residence: �The Manifest rejects any peaceful solution for the Palestinian Cause, affirming Jihad and martyrdom as �the only choices for liberation. One of the �Political Constants of the Movements� is [t]he creation of a situation of terror, instability and panic in the souls (minds) of Zionists and especially the group of settlers,� and one of the �most important means and methods of action� is �[a]doption of the guerilla war system.� [FBI Affidavit, p. 8].

96. A cursory examination of the secret FBI Affidavit reveals that the Department of Justice had substantial evidence to show that Defendant had committed numerous crimes, including mail fraud, tax fraud and was the head of a Racketeer Influenced Corrupt Organization (RICO) for money laundering.

97. Specifically, the evidence collected by the Department of Justice directly confirms the gravamen of this Complaint, that Defendant used a Florida charity as a front for terrorist money laundering: �The ICP has served as a vehicle by which PIJ has raised funds to support terrorist activities in the Occupied Territories.� [FBI Affidavit, p. 11, Para. 24].

98. As the statute of limitations concerning terrorist money laundering has been retroactively extended by Section 809 of the Patriot Act, there is no legal reason why the Defendant could not be subjected to criminal prosecution by State or Federal authorities

99. Moreover, no statute of limitations issue could possibly arise because a) Defendant continues to cash checks for charitable contributions made out to ICP , or b) Defendant continues to solicit funds for his purported charitable entities, or c) Defendant continues to deceive consumers by making false, unfair and deceptive public statements to the media denying that either he or his entities were connected to terrorism in any way, or d) creating still more charitable fronts as part of an ongoing criminal enterprise, or e) continuing to incite racial hatred at annual conventions of other terrorist and militant organizations, or f) continuing to receive laundered money under the guise of a Florida charity or religious organization, or g) continuing to provide funding, support and equipment to other terrorist organizations including Al Qaida.

100. Instead of being arrested, Defendant has been free to continue and expand his scheme of creating even more non-profit and other corporations for terrorist money laundering within the State of Florida. A computer check of the Department of Corporations of the State of Florida shows that Defendant�s name currently appears as the managing director of several new entities whose activities are ongoing to the present day.

101. The creation of new charitable entities is essential for the continuation of Defendant�s unfair and deceptive scheme, as the assets and accounts of his old entity, WISE, have been, and remain frozen, by order of the Secretary of the Treasury. [FBI Affidavit, p.7, n.9, freeze order renewed in August 2000]

102. In each year since the 1995 FBI raid on Defendant�s home and offices, both President Clinton and President Bush have used their statutory authority to designate Defendant�s Palestinian Islamic Jihad as a continuing threat to peace in the Middle East and as an �extraordinary threat to the national security, foreign policy and economy of the United States.� [FBI Affidavit, P.7]

103. The current Attorney General has publicly threatened to arrest anyone suspected of terrorism even for spitting on a sidewalk. Yet, Defendant is allowed to continue his activates in an open and outrageous manner, continually lying to the media and the public about his �charitable� fronts for terrorism and even demanding his job back at a state university on grounds of academic freedom of speech.

104. Despite the fact that it was Defendant�s own financial records, videotapes and records that were used as evidence to imprison his subordinate pending deportation as a threat to national security, Defendant himself has never been arrested, imprisoned, indicted or prosecuted in any form or forum..

105. Defendant�s application for American citizenship has been administratively suspended, but no denaturalization procedures have been initiated against him. Defendant�s WISE accounts have been frozen, but no civil or criminal forfeiture proceedings have been initiated to seize them. His personal assets have never been attached as fruits of a criminal enterprise.

106. The Department of Justice still has custody of the original videotapes, documents and records seized from Defendant�s home in the 1995 FBI raid, but these records have not been made public apart from a few translated excerpts submitted in the Al Najjar deportation case in which Defendant�s name was blacked out.

107. The Department of Justice made copies of the tapes and other evidence seized in the 1995 FBI raid and returned one set of the copies to Defendant. However, Defendant has refused to release them to the media, although he falsely claims that the evidence shows that he has no connection to terrorism.

108. Defendant�s recent brazen appearances on local, state and national television (in which he reiterates lies easily disproved by his own videotapes demonstrating his overwhelming connection to terrorism) is evidence of his awareness that he is untouchable, unarrestable, or otherwise beyond the reach of federal law enforcement.

109. As evidenced by the FBI affidavit, the Federal Government has intentionally withheld from the public even more information concerning Defendant�s criminal activities in Florida on the grounds that it is classified for reasons of national security relating to the �foreign relations, or economic interests of the United States.� [FBI Affidavit, p.2, n.1]

110. Under the Freedom of Information Act, classified information may be withheld from the public when it might prove �embarrassing to a foreign government.�

111. Under the Florida Consumer Protection Act, Florida Statute 501.206 (5) classified information held by the Federal government may be reviewed in confidence by a Florida Court in order to determine whether an unfair, deceptive or unconscionable trade or practice has occurred.

112. For the reasons set forth hereinafter, reasonable grounds exist for the court to request sua sponte copies of all classified evidence pertaining to Defendant held by the Federal Government for an in camera determination as to whether Defendant�s conduct constituted an unfair, deceptive or unconscionable trade or practice under Florida Law.

113. Such a 501.206 (5) determination is particularly appropriate where, as set forth below, reasonable grounds exist to suspect that the continued classification of Defendant�s activities would be injurious to the national interest, and /or would assist Defendant in continuing his unfair, deceptive and unconscionable acts against Florida citizens in the future, and /or that the information was improperly classified to protect former and present federal officials from embarrassment.

Money Laundering for the Saudi Government

114. In truth and in fact, Defendant was allowed to continue his terrorist operations in Florida under a veil of secrecy and classification because any prosecution of Defendant would reveal that Defendant was a small, but significant part of a global money laundering network operated under the guise of purported American charities run by the Government of Saudi Arabia.

115. According to publicly available testimony from one of Defendant�s ICP subordinates, the largest single source of Defendant�s funding was from what appeared to be a public tax-exempt charity at 555 Grove Street, Herndon, Virginia which transferred hundreds of thousands of dollars to Defendant�s charities in Florida.

116. According to confidential client sources, shortly after discovering that 55 Grove Street was the primary source of Defendant�s funding, the Department of State requested that the Justice Department terminate their 1995 criminal investigation of Defendant and bring no charges against him in the future, which order was reluctantly obeyed.

117. It is a matter of public record that 555 Grove Street is the address used by four interrelated foundations, institutes and charities with more than a billion dollars of assets donated by or through agents of the Government of Saudi Arabia. Each year the 555 Grove street charities donated more than a million dollars to selected organizations such as Defendant�s inside the United States.

118. After 1995, the follow up investigation of Defendant�s connection to suspicious activities at 555 Grove Street was turned over to John O�Neill, publicly identified as a senior official of the FBI then responsible for collecting and collating counter-terrorist intelligence from all US government sources.

119. John O�Neill later resigned his position with the FBI, stating to his friends that he was disgusted with the way the Saudis were being protected. According to press sources, O�Neill�s resignation honestly surprised President Bush who immediately demanded a complete secret review of the US Government�s policy towards protecting Saudi Arabian activities in the United States.

120. In truth and in fact, the Government of Saudi Arabia has used their charitable fronts in America to fund hate groups, racist organizations, and terrorist operations like defendants within the United States for the last thirty years.

121. In truth and in fact, the Government of Saudi Arabia has used their charitable fronts in America to launder money through groups like Defendant�s to fund overseas terrorist groups including Palestinian Islamic Jihad, Hamas, Hizbollah and Al Qaida for the last fifteen years, all for the purpose of wrecking the peace process and preventing the creation of an independent, Palestinian State.

122. The first documented instance where the Saudi Government misused a charitable front was in the 1970�s in connection with a group called �The American Friends of ABN� the predominant organization within the Saudi funded �World Anti-Communist League.� The CIA warned Congress in a secret document [now declassified] to have no contact with the ABN as the organization�s leadership consisted almost exclusively of former Nazi War Criminals and collaborators from Nazi puppet regimes. [Scott Anderson, et al., Inside the League]. From the 1970�s onwards, it was an �article of faith� among CIA employees that the surest way to end one�s government career was to investigate the Saudis. Similar complaints by FBI agents have also been reported in the press

123. During the 1980�s, following the collapse of the Soviet Union, the Saudis began to take over the direct funding of terrorist groups such as Hamas and Palestinian Islamic Jihad, headquartered in the former communist state of Syria. As Oliver North noted in his autobiography, every time he wanted to do something about counter-terrorism, he was told to stop because it would embarrass the Saudi Government.

124. In 1988, Jonathan Pollard, a similarly frustrated Naval Intelligence analyst, gave the State of Israel a highly classified American list of Saudi Arabian and other Arab intelligence agents, including Osama Bin Laden. Pollard was given a life sentence in large part because of the embarrassment caused to Arab governments.

125. During the 1990�s, the Saudis used domestic terrorist groups like Defendant�s to launder money overseas for attacks against the State of Israel, and for the support of other terrorist groups to include the Al Qaida movement.

126. After many delays, the Saudi policy review, which had been prompted by John O�Neill�s resignation in disgust from the FBI, was finally set for September 11, 2002 at the White House. Unfortunately, on that date John O�Neill, he was present at his new job as Chief of Security for the Twin Trade Towers and was killed in the attack. It is a tragic irony that the Federal Government�s dela