UNITED

STATES

DISTRICT

COURT

SOUTHERN

DISTRICT

OF NEW YORK

BARBARA HANDSCHU, RALPH DiGIA, ALEX McKEIVER, SHABA OM, CURTIS M. POWELL, ABBIE HOFFMAN, MARK A. SEGAL, MICHAEL ZUMOFF, KENNETH THOMAS, ROBERT RUSCH, ANNETTE T. RUBENSTEIN, MICKEY SHERIDAN, JOE SUCHER, STEVEN FISCHLER, HOWARD BLATT, ELLIE BENZONI, on behalf of

71 Civ.

2203

<CSH)

DECLARATION OF

themselves and all others similarly

situated,
Plaintiffs,

SHAMIUR RAHMAN

-againstSPECIAL SERVICES DIVISION, a/k/a Bureau of Special Services; WILLIAM

H.T. SMITH; ARTHUR GRUBERT; MICHAEL WILLIS;
MURPHY;

WILLIAM KNAPP;
POLICE

PATRICK LINDSAY;

DEPARTMENT OF THE

CITY OF NEW YORK;

JOHN V.

and various unknown employees of the Police Department acting as undercover operators and informers,
Defendants.

SHAMIUR
U.S.C. 1746,

RAHMAN,

for

his

declaration

pursuant

to

28

states as follows:

1.

I am a

native

of

Queens,

New York.

My

family

is

from Bangladesh.
and English)

I speak "Banglish"
my family, but

(a mixture
my first

of

Bengali
is

with

language

English.

In January 2012,

I was recruited by a plainclothes ("NYPD") to serve

officer of the New York Police Department

as

an informant.

At

first I thought I was helping to fight

terrorism,

but as

I saw what I was asked to do,

I was more

interested

in

the

money

was

being

paid.

started

at

$1000 per month and by the time I quit I was getting around
$1500 per month.
officer who

I received my instructions
himself "Steve". We met

from a police
and talked in

called

his car and also communicated by text message.

I still have

the text messages I exchanged with him in my cell phone. 2. My assignment was to spy on members of the Muslim

communities
police pretend

in New York.
"create a

I was

told to use a strategy the

This start meant an I was to

called to be

and

capture". and

devout

Muslim

inflammatory

conversation about jihad or terrorism and then capture the

response to send to the NYPD. I did this on numerous

occasions with people I met at mosques and other locations.

3. mosques. sent As part of my work as an informant I visited many I took pictures of the people worshiping there and to the NYPD. I was instructed to listen

the pictures

to what the imams said and to report any radical rhetoric. I recorded who cell phone numbers from the sign up sheet My
too

of

people
boss

attended
never

Islamic
told

instruction
me I was

classes.

NYPD
much

Steve

once

collecting

information, 4. lecture One at

no matter who I was spying on. of my earliest assignments was to at spy John on a

the

Muslim

Student
2

Association

Jay

College in Manhattan.
like jihad or

I was told to report any "buzz words"

speaker. I was also told

revolution by the

to

monitor
me to

the

student

group

itself.
at the

My

NYPD

boss

Steve
to

told

take

pictures

group's

events,

determine

who
I

belonged
took

to

the
of

group

and
in

to

identify
group

its
and

leadership.

pictures

people

the

recorded the license plate numbers of their cars.

5. My NYPD boss Steve told me that the NYPD did not

think

the

John

Jay

Muslim

Student

Association

was

doing

anything wrong,

they just wanted to make sure.

The members

of the MSA were religious Muslims, boss Steve, the

and according to my NYPD Muslim a

NYPD considers being a religious

terrorism indicator.

6.

On

the

instructions events at

of John

my

NYPD

boss

Steve,

attended additional

Jay and

I travelled to

events organized by the Islamic Circle of North America and

the

Muslim

American
to

Society.

was

told

to

spy

on

the
who

speakers
attended.

and

collect

information

about

those

7.
attended
pictures
NYPD.

On
the

the

instructions
Day

of

my
in

NYPD

boss

Steve
and
to

Muslim

parade

Manhattan
these

took
the

of people marching.

I sent

pictures

8. illegal,

never

saw

anyone

spied

on

do

anything 2012,

not even littering. At the end of September,

I decided I did not want to spy on people any longer,

told my NYPD boss Steve that I was quitting. He

and I

offered me

more money to continue but I declined the offer.

9.

believe

that

the

spying

on

the

Muslim

communities
puts

in

New York by the

at risk. If they

NYPD
are

Intelligence
able to

Division
to

everyone

continue

target Muslims,
well.

they will end up spying on other groups as

SHAMIUR

RAHMAN

I declare under penalty of perjury that the

foregoing

is true and correct.

Executed on October 2$ , 2012.