Adams Deposition

Case 3:13-cv-00169-TJM-DEP Document 58-2 Filed 03/26/14 Page 1 of 139
Hussein Adams
3/11/2014
Page 1
UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF NEW YORK
__________________________________________________
THE MUSLIMS OF AMERICA INC.,
Plaintiff,
-against-
Case No.:
3:13-CV-0169
(TJM/DEP)
MARTIN J. MAWYER, PATTI A. PIERUCCI and

CHRISTIAN ACTION NETWORK,
Defendants.
__________________________________________________
Videotaped Deposition of
HUSSEIN ADAMS,
held pursuant to Notice, at the Marriott Hotel,
3801 Vestal Parkway E., Vestal, New York,
commencing at 9:08 a.m., Tuesday, March 11, 2014,
before Brenda J. O'Connor-Marello, CSR, a Certified
Shorthand Reporter and Notary Public in and for the
State of New York.
Anderson Reporting Services, Inc. (614) 326-0177)

www.andersonreporting.com
Hussein Adams
3/11/2014
Page 2
A P P E A R A N C E S
APPEARING FOR THE PLAINTIFF(S):
TAHIRAH AMATUL-WADUD, ESQ.

10 Center Street, Number 306
Chicopee, Massachusetts 01013
e:
tahirah@attorneytahirah.com
p:
413-474-6038
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TAHIRAH H. CLARK, ESQ.

P.O. Box 223
Deposit, New York 13754
Attorneys for Plaintiffs
e:
tahirah.clarkesq@gmail.com
p:
607-205-8825
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APPEARING FOR THE DEFENDANT(S):
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CARROLL, UCKER & HEMMER, LLC

71 N. High Street, Suite 301
Worthington, Ohio 43085
BY:
DAVID W. T. CARROLL, ESQ.
Attorneys for Defendants
e:
dcarroll@cuhlaw.com
p:
614-547-0350
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ALSO PRESENT:
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Cory Lange and Colton Ott - Videographers

Martin Mawyer, Defendant
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Hussein Adams
3/11/2014
Page 3
F E D E R A L
S T I P U L A T I O N S
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IT IS HEREBY STIPULATED AND AGREED by and
between the attorneys for the respective parties
hereto, that filing, sealing, and certifications
are hereby waived;
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IT IS FURTHER STIPULATED AND AGREED that all
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objections, except as to the form of the question,
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shall be reserved to the time of the trial;
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IT IS FURTHER STIPULATED AND AGREED that the
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within Deposition may be signed before any Notary
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Public with the same force and effect as though
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subscribed and sworn to before this Court.
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Hussein Adams
3/11/2014
Page 4
HUSSEIN ADAMS,
called as the witness, hereinbefore named, being
first duly cautioned and sworn or affirmed by
BRENDA J. O'CONNOR-MARELLO, a Certified Court
Reporter and Notary Public in and for the State of
New York, Qualified in Saratoga County, herein to
tell the truth, the whole truth, and nothing but
the truth, was examined and testified as follows:
EXAMINATION
10
BY MR. CARROLL:
11
What is your name and address, please?
12
Hussein Adams.
13
Want me to spell it?
14
15
Or you have it -- you
have the correct spelling?

Q
The same -- the same -- the first name is the same
16
spelling as the middle name of the president of
17
the United States?
18
Yeah.
Correct.
19
I think we have it.
20
Okay.
21
And Adams is pretty easy.
22
Okay.
23
Do you have a middle name?
24
Umar.

Hussein Adams
3/11/2014
Page 5
And your address, please?
2732 Roods Creek Road, Hancock, New York.
And I understand you've given a deposition before
at some point in time?
Um-hum.
So you know -- so you know it's necessary that
your responses be audible, and they should be yes
or no, not uh-uh and um-hum; okay?
Yes.
No problem.
10
And we'd appreciate it if you'd speak up,
11
especially if that thing goes on again, the air
12
unit.
13
having a little bit of trouble hearing you across
14
the table.
15
reporter catches every word, so please do speak up
16
and don't mind me if I ask you to speak up from
17
time to time.
I notice your voice is very soft, and I'm
We want to make sure the court
18
Okay.
19
You were here throughout Mr. Abdul-Haqq's
20
deposition yesterday, weren't you?
21
Correct.
22
And as I asked him, and as I'm sure has been
23
explained to you, a deposition is for many
24
purposes, including us finding out what your

Hussein Adams
3/11/2014
Page 6
testimony would be at the trial of this case.
that end, it is important that you understand the
questions that I ask you.
question you do not understand, will you stop me
so I can explain it?
If I ask you any
Yes, I will.
I also want to be fair with you.
If you feel any
question I ask you is unfair, again, would you
stop me so I can rephrase it?
10
I will.
11
Mr. Adams, where were you born?
12
I was born in Canada, East York.
13
East York?
14
East York.
15
Date of birth?
16
17
And your father is Barry Adams?
18
Yes.
19
Is that his birth name?
20
Yes.
21
Is Hussein Adams your birth name?
22
Yes, it is.
23
So I take it your father was a Muslim when you
24
To
were born?

Hussein Adams
3/11/2014
Page 7
Yes.
You were born into Islam?
I was born Muslim.
Given the date of your birth, I'm pretty sure you
don't remember the beginnings of -- of MOA and the
group that you heard about yesterday following
Sheikh Gilani; correct?
9
10
"Heard about"?
Can you repeat that?
Well, I'm pretty sure you don't have any
11
particular recollections of the group breaking off
12
and following Sheikh Gilani since it happened
13
before you were born.
14
No, I don't.
15
Would you please give me your educational
16
17
background?
A
Let's see.
Two years civil engineering, Seneca
18
College.
Also, I've taken some social science
19
courses at Binghamton University.
20
I'm sorry.
What kind of courses?
21
Just social sciences.
22
Do you have a degree?
23
No, I don't.
24
Do you have a high school diploma?

Hussein Adams
3/11/2014
Page 8
Yes, I do.
Did you go to a -- a government-run high school,
or were you home-schooled?
Both.
Could you explain that, please?
Can I explain that?
Yeah.
Well, I graduated from a government-owned -- ran
high school, but I was also home-schooled
10
previous -- previously, prior to.
11
And what high school did you receive your --
12
Pine Ridge -- Pine Ridge Secondary High School.
13
Is that in the Binghamton area?
14
No.
15
And since high school, would you give me your work
16
17
That's in Canada.
experience, please?
A
Well, what do you want to know?
18
19
Work experience -Q
Starting with high school, what jobs have you
20
held?
21
appreciate it.
22
And if you'd give it to me in sequence, I'd
Just random jobs.
I worked at restaurants.
23
owned my own business.
24
temp agencies quite a bit.
I've
I've worked through the

And that's about it.

Hussein Adams
3/11/2014
Page 9
What business did you have?
I owned a restaurant.
And where was that?
Excuse me?
Where was that?
That was here, Binghamton.
What restaurant was that?
It was called Abus House of Halal.
Abus House of Allah?
10
Of Halal, H-A-L-A-L.
11
What happened to the business?
12
Couldn't keep up with the rent.
13
Currently, I'm the owner of Babahg
14
Enterprises, a clothing business.
15
Would you spell Babahg, please?
16
B-A-B-A-H-G Enterprises.
17
Tell me about that business, please.
18
What would you like to know about it?
19
Well, you say it's a clothing business.
20
Retail,
wholesale?
21
Wholesale and retail.
22
Do you manufacture the clothes?
23
Yes, we do.
24
What sort of clothes?

Hussein Adams
3/11/2014
Page 10
Islamic clothing:
Ladies, gents, children's.
We cater to weddings and different parties.
How long have you had that business?
Since I've been, about, what, 13, 14 years.
Do you have employees?
Just family.
Did you ever do anything with your two years of
civil engineering?
No.
10
When did you move to Hancock, New York?
11
2000.
12
What were the circumstances of your moving?
13
The circumstances?
14
Yes.
15
My wife's from New York.
16
Now, I understand that you have -- let's talk
17
Why did I move?
about MOA.
18
You had an official role with MOA; is that
19
correct?
20
Correct.
21
What was that role?
22
Deputy director.
23
When did you become deputy director of --
24
This was around the same time I came, 2000.

Hussein Adams
3/11/2014
Page 11
What were the duties of deputy director?
The duties of deputy -- the duties up until today,
basically, I'm the deputy director that oversees
all of our locations and departments.
And departments?
Correct.
So what I understand you to be telling me is that
you were deputy director of Muslims of America,
Inc., and you're also now deputy director --
10
TMOA.
11
-- TMOA, The Muslims of America, Inc.?
12
Correct, from that date.
13
Were you also a trustee?
14
Yes.
15
Is that a separate job, or was that --
16
No.
17
Who were the trustees of Muslim of the Americas,
18
19
Inc., from 2000 until it was dissolved?

A
20
21
It's the same, just paperwork.
From 2000 -- I am the trus -- I am one of the

trustees.
22
Well, Muslims of the Americas, Inc., was dissolved

in March 2013, wasn't it?
23
Correct.
24
Yes?

Hussein Adams
3/11/2014
Page 12
Yes.
So who were the trustees from 2000 until it was
3
4
dissolved?
A
5
6
We didn't -- that's the whole thing, we didn't

have paperwork like that.
Well, what other officers did Muslims of the
Americas, Inc., have during the period 2000 until
it was dissolved?
Khadija Smith is the next trustee.
10
Was anybody else an officer of MOA?
11
No.
12
I need to understand the administrative or
13
management structure of MOA.
14
15
Can you explain that to me?

A
16
Well, if you'd be a little more specific, then I

will explain.
17
What you --
18
Well, how is -- how was MOA administered?
19
I mean, in what regards?
20
In regards to anything.
21
Well, as I stated, I'm the deputy director of our
22
organization, and we oversee all of the
23
departments of our community on a national -- on a
24
national level.

Hussein Adams
3/11/2014
Page 13
And what departments does your community have?
These are basic, you know, education, social
services, you know.
Any other departments?
Yeah.
I mean, home economics, you know, sporting
activities.
Are these departments formalized in any way?
That's the thing that you have to understand, is
contrary to what you think or may believe, MOA,
10
one of the biggest problems that existed was there
11
was no paperwork.
12
that organization that was infiltrated.
13
no structure that you are trying to find.
14
understand?
15
There was no establishment of

There was
You
Things were just done.
When we were -- you know, came and were
16
appointed and selected, that was our primary
17
focus, was to try to establish the organization.
18
Okay.
19
Well, we're still doing it.
20
It's kind of a never-ending job?
21
Oh, yeah.
22
Well, how did you go about starting that in 2000
23
24
Tell me how you went about doing that.

We've just started.
Yeah.
when you were appointed as deputy director?

A
That's a long story.

Hussein Adams
3/11/2014
Page 14
Please tell it.
I mean, when you say how I go about it, how did we
go about it, we had to deal with a lot of, as you
saw in the testimony yesterday, the existence of
the previous administration and previous
individuals that held offices.
lot that -- we started -- you know, we didn't even
start on ground level.
history, unaware of what existed and what did not
10
And there was a
And we were unaware of the
exist.
11
Who appointed you as deputy director?
12
My sheikh.
13
Sheikh Gilani?
14
Yes.
15
So what did you do to bring about structure to
16
17
MOA?
A
Well, like I said, the first thing was
18
ascertaining and finding out, you know, as much as
19
we could about the existing corporation, so we
20
thought, the existing organization, so we thought.
21
And it wasn't until we launched our own internal
22
investigation did we find out that MOA was
23
actually never MOA.
24
And that internal investigation began in -- in the

Hussein Adams
3/11/2014
Page 15
1
2
fall of 2012?
A
No.
This was, you know, from 2000 to 2003, when
Jamil Haqq was the primary khalifa, primary
administrator who over -- he was the head chief
officer that oversaw departments and the
organization.
least, to get information, to say the least.
It was very difficult, to say the
When you arrived in 2000, what was Jamil Haqq's

role?
10
I just mentioned, he was the khalifa.
11
He was the khalifa at that time?
12
Yes.
At least he was -- when you're a khalifa for
13
30 years, whether you have been officially removed
14
or not, like the president, people still say
15
president.
16
17
Well, did he -- was he the chief administrator

when you arrived?
18
Yes, he was.
19
I mean, he was acting as chief administrator, not
20
21
just having the title?

A
Well, like I said, from those -- from that time
22
until the next two or three years, he was under
23
investigation.
24
was tremendous turmoil and there was -- the
So I came at a time where there

Hussein Adams
3/11/2014
Page 16
people, the citizens didn't know which way to go,
who to follow, who to believe, who to disbelieve.
And it wasn't until Sheikh Gilani addressed
the community on the nefarious activities that
were taking place amongst and within that current
administration that people gained clarity as to,
you know, what was taking place.
These were nefarious activities by Jamil Haqq?
And his crew and those that associated with him,
10
and the whole Darul Islam movement and those that
11
associated with them.
12
What nefarious activities are you talking about?
13
I don't know.
14
Well, you did an investigation; right?
15
Well, I wasn't -- I wasn't the primary -- I wasn't
16
overseeing the investigation.
17
investigation was already taking place, and
18
basically we came to start anew.
19
When I came, the
You understand?
And it wasn't, you know -- it wasn't to the
20
point -- the investigation wasn't at the point
21
where he was already proven guilty, put it like
22
that.
23
support that.
24
We just had to find substantial evidence to
Now, are we talking about him being involved in

Hussein Adams
3/11/2014
Page 17
drugs, brothels, unemployment fraud, and other
offenses?
Correct.
You know, I'm taking this right out of Sheikh
5
6
Gilani's article.
A
No, I understand.
I don't have information on the drugs, the
brothels, and unemployment fraud.
If you ask me
that question, you understand, I couldn't tell you
10
yes, this was proven or that was proven.
11
yes, that's correct.
12
Who was conducting that investigation?
13
I don't know.
14
15
There were quite a number of
people, over 12 individuals or more.

Q
16
17
But,
Well, give me the names of some of the people who

were conducting the investigation.
I can't give you any names, because like I said, I
18
came into an already -- an investigation that was
19
already taking place.
20
21
22
23
24
And, you know...
Do you know the names of any of the people who

were undertaking the investigation of Jamil Haqq?
Do I know the names of any people who were

undertaking -- I can give you -No, because everyone claimed to be taking

Hussein Adams
3/11/2014
Page 18
part in the investigation.
neighbors, or his -- it wasn't -- it wasn't
official like that.
5
6
His companions, or his
Well, give me the names of some of the people who

claimed to be taking part in the investigation.
Well, the former deputy director -- former deputy
director, Atiq Shahid, was overseeing.
And any
other names, I couldn't tell you because I really
don't have it.
10
Where is Atiq Shahid today?
11
He is in South Carolina.
12
Who would know the names of the people conducting
13
the investigation?
14
Like I said, I couldn't tell you that.
15
You can't -- you don't know the names, and you
16
17
can't tell me who would know the names?

A
I couldn't tell you who would know the names,
18
because like I said, the investigation was already
19
taking place.
You understand?
20
Are you saying the investigation was completed --
21
The investigation --
22
-- when you arrived in 2000?
23
The investigation was already taking place.
24
was next to completion.
It
You understand?

Hussein Adams
3/11/2014
Page 19
The evidence and the information that was
needed was already provided.
I came to start the
new organization and to start, you understand,
anew.
investigate.
here.
So it wasn't -- I didn't come to

Fourteen years later, I'm still
You understand?
How did you find out about the investigation?
I mean, it was publicized.
Where was it publicized?
10
Where was it publicized?
11
It was publicized in Islamic Post.
12
The
people spoke about it, talked about it.
13
Was it in the Islamic Post in the year 2000?
14
It possibly -- you should have received the Pillar
15
of Lies document that exposed Jamil Haqq in -- it
16
was either one of -- between 2000 and 2002, if I'm
17
not mistaken.
18
19
When you came to Hancock, New York, did you know

you would be coming as deputy director?
20
I came as deputy director.
21
Were you told about the investigation of Jamil
22
Haqq before you came to Hancock, New York?
23
Yes.
24
Who told you?

Hussein Adams
3/11/2014
Page 20
Sheikh Gilani.
What did he tell you?
Excuse me?
What did he tell you, yeah.
Exactly that.
Exactly what?
Exactly that -- you know, I don't know verbatim.
I'm not asking verbatim.
I want to know what did
Sheikh Gilani tell you about the investigation
10
11
What did he tell me?
that had been ongoing?

A
12
He told me that this -- that exactly what
13
the information that you have, that you received.
14
You understand?
15
group within the community, a group within the
16
group, and there's a number of things that need to
17
be concluded, and that we're currently
18
investigating him, and so on and so forth.
19
20
That this Jamil Haqq has set up a
And, again, that's not verbatim.

Q
I understand it's not verbatim.
21
Tell me about the so on and so forth.
22
That's just terminology, so on and so forth.
23
Well, it means he told you more than what you just
24
said.

Hussein Adams
3/11/2014
Page 21
2
3
everything that he told me regarding that.

Q
4
5
Well, I can't recollect -- I cannot recall
And what did he tell you your role would be

regarding that investigation?
Regarding the investigation?
We didn't -- what
was discussed was what my role would be as deputy
director of the organization.
All right.
What --
And what challenges -- and what challenges and
10
difficulties that I will be encountered with and
11
face because of what was taking place.
12
13
14
What did he tell you your role would be as deputy

director of the organization?
Exactly that, that we would work hard to rid
15
individuals from our community.
16
standing policy from day one.
17
That's been our
I mean, you can't go into something that I
18
wouldn't understand regarding history because he
19
was totally unaware of a lot that took place prior
20
to him even coming.
21
22
So what did he tell you that your responsibilities

and authority would be?
23
To oversee Muslims of Americas.
24
Now, what does it mean to oversee the Muslims of

Hussein Adams
3/11/2014
Page 22
Americas?
The in charge.
Did you have a supervisory role?
Meaning what?
Well, if you were in charge, you had people that
Supervisory meaning what?
you could direct to assist you in things?
Um-hum.
Yes?
Of course.
10
You said "um-hum," you see.
11
You don't like the um-hums.
12
Yes.
13
It doesn't work on the transcript.
14
Okay.
As I've stated, Mr. Atiq Shahid was the
15
deputy director, former deputy director, and he
16
did his level best to introduce, to assist, to
17
aid, to support, to assist me in the new
18
environment.
19
Why did Sheikh Gilani bring someone in from
20
outside to be deputy director of a place that you
21
had not lived?
22
23
24
Well, I had been back and forth to New York many

times.
I'm also a graduate of 14 of our summer

Hussein Adams
3/11/2014
Page 23
programs that took place in New York and excelled
at that.
Why did he bring somebody in from the outside?

Did he tell you?
I wasn't from the outside.
Well, you were living in Canada at the time,
This is my community.
weren't you?
That's not -- that's not outside.
Well, I don't mean outside --
10
What do you mean?
11
-- the Muslim community.
12
13
Hancock, New York.

A
14
15
I mean outside of
We're a very close-knit community.
We're very
close-knit.
Q
Was it perhaps because he wasn't sure who he could
16
trust in the community and he needed someone from
17
the outside to come in and check that out given --
18
19
I prefer that you rephrase your terminology

"outside."
20
And yes, of course, he needed someone he
21
could trust.
22
my life, I've been trustworthy.
23
24
And I would say for the most part of
I mean, frankly, that seems like a very rational

thing to do, so --

Hussein Adams
3/11/2014
Page 24
To you maybe.
Yes, to me.
So I'm not sure why you're being so
resistent to my questions.
I'm not being resistent to your questions at all.
When you arrived, what happened to Atiq Shahid?
He stayed.
Did he stay in a role as --
He was an assistant.
An adviser to you?
10
Yes.
11
Now, how long did Atiq Shahid stay as an adviser
12
13
to you?
A
14
15
He was there for three, four years, five years.

He's still an adviser.
16
17
He was an adviser.
When did Khadija Smith take on a -- an official

role in your administration?
18
Well, you can ask her, but it's been a few years.
Maybe three, four, five, six years.
19
But not from the beginning, not from 2000?
20
Not from when I arrived, no.
21
When you arrived, did you talk with Atiq Shahid
22
about the investigation that had been conducted?
23
Of course.
24
What did he tell you?

Hussein Adams
3/11/2014
Page 25
You have to be specific.
3
4
what did he tell me?

Q
5
6
What do you mean
What did he tell you about the investigation that

had been performed?
Well, that -- exactly what I told you, that there
was an investigation taking place with this former
khalifa that was the primary administrator of the
community.
And there's been things that have been
10
proven, you understand, regarding criminal
11
activity and other.
12
here.
13
14
15
And we have to move on from
Did he tell you what things had been proven about

criminal activity?
Everything that was printed and published is what
16
was stated, but there's been a lot of hearsay and
17
a lot of, you know -- I can't say what was exactly
18
specifically was proven, no.
19
20
Did you become aware that there was a brothel

running out of Hancock, New York?
21
A who?
22
A brothel?
23
There was no brothel running outside of Hancock,
24
New York.

Hussein Adams
3/11/2014
Page 26
Had Jamil Haqq been expelled as khalifa by the

time --
Yes.
-- you had arrived?
Was he still living in the community?
Yes.
Were any criminal charges brought against
He was handicapped in his bed.
Mr. Haqq?
Criminal charges?
10
Yes.
11
I don't know.
12
You don't know of any?
13
I don't know of any.
14
If criminal charges had been brought, you surely
15
16
would have heard about them, wouldn't you?

A
17
18
I'm in contact with law enforcement on a daily

basis, so, yes.
19
So no criminal charges were ever brought against

Jamil Haqq for his criminal --
20
Not that I know of.
21
Now, Jamil Haqq was not acting alone; is that
22
correct?
23
I'm sure he had his group of people.
24
Well, you know that he had other people within the

Hussein Adams
3/11/2014
Page 27
1
2
community that -A
3
4
he did, anything that he was involved in.

Q
Was anyone expelled from the community besides

Jamil Haqq --
In fact, he wasn't even expelled from the
community, was he?
Was anybody besides Jamil Haqq expelled
from the community because of criminal activity
10
11
I don't know anything that he had, anything that
arising from this investigation?

A
12
Arising from this investigation, I don't know.

From the date of my arrival, we've expelled
13
many individuals, not necessarily in the Hancock
14
community, but throughout our community.
15
Any individual, whether they live in
16
Nebraska, Tallahassee, if they're found and it's
17
proven through our investigation that they're
18
involved in criminal activity, they're immediately
19
not only expelled, but they are handed over to the
20
authorities.
21
Can you give me an example of someone who was
22
expelled and handed over to the authorities from
23
Hancock?
24
That's confidential.

Hussein Adams
3/11/2014
Page 28
I don't believe it is, if they were charged,

criminally charged.
Yeah.
The people who were handed over to the
authorities, were they criminally charged?
Not from Hancock.
No one from Hancock --
No.
-- has been criminally charged?
10
No.
11
All right.
Give me an example of someone from one
12
of the other communities who was criminally
13
charged.
14
An example meaning what?
15
A name, a date, a place.
16
I'm not giving you a name, a date, a place of
17
anyone because you have individuals that have been
18
criminally charged and have served their time and
19
that are now released and are now living their
20
life.
21
That's the primary reason we're in this
22
case, is because we're being attacked inside and
23
out.
24
don't trust Martin Mawyer.
I don't trust Christian Action Network.
And therefore, any

Hussein Adams
3/11/2014
Page 29
information dealing with any individuals that are
part of our community, you won't be given
information on that.
MR. CARROLL:
Would the court
reporter please instruct the witness to
answer the question?
(Request to witness to answer unless
otherwise instructed by his counsel.)
Okay.
Rephrase the question, please.
10
Give me an example, a name of a person who has
11
been criminally charged, turned over to the
12
authorities from one of your communities.
13
Ismail Haqq.
14
Is that I-S-M-A-I-L Haqq?
15
Correct.
16
And what community was he --
17
Virginia.
18
What crime was he charged with?
19
I'm not sure.
20
When did this happen?
21
This was seven years ago, six years ago.
22
He lived in Red House?
23
No, he didn't.
24
He was a member of the Red House community?

Hussein Adams
3/11/2014
Page 30
No, he wasn't.
Where did he live?
I'm not sure.
4
5
He lived in Virginia.
I know he
lived in the state of Virginia.

Q
But he was a member of Muslims of the Americas,

Inc.?
Yes.
Now, you mentioned that Muslims of the Americas,
Inc., has various departments.
10
11
Are those
departments headed by individuals?

A
Yes.
We have a town council in each one of our
12
locations.
And the town council is ran by the
13
mayor, local mayor, local deputy mayor, three
14
councilwomen -- two or three councilwomen, and two
15
or three councilmen.
16
Who is the mayor of Islamberg?
17
The mayor of Islamberg was Rashid Haqq.
18
And we're
currently looking for a new mayor.
19
Why is Rashid Haqq no longer mayor?
20
Well, his term was up.
21
What is the mayor's term?
22
Three years.
23
Is the mayor elected?
24
Yes, he is, or she is.

Hussein Adams
3/11/2014
Page 31
Is it elected by a vote of everybody in the

village?
I mean, I know that not everybody is
necessarily going to come and vote, but everybody
is eligible to vote for them?
Of age, yes.
Who is on the town council of the village of
8
9
Eighteen.
Islamberg?
A
10
I think we submitted -- I'm not sure who are the

current town council, all the names.
11
Well, give me the names you know.
12
I'm not sure of the names that are on the town
13
council.
14
representatives are being replaced.
15
up.
16
17
Like I said, even the council

The term is
Who are the most recent representatives you

remember?
18
Most recent?
19
Yes.
20
Well, you have Ubaidullah Shahid.
21
Spell that, please.
22
U-B-A-I-D-U-L-L-A-H.
23
Anybody else?
24
I can't recall.

Hussein Adams
3/11/2014
Page 32
Was Ubaidullah Shahid the financial officer?
He was an officer.
3
4
I'm not sure if he was the
financial officer or not.

Q
I think that was the name that was on the web site
as the financial officer.
Oh, really?
Would that be consistent with your --
On which web site?
Town of Islamberg.
10
Okay.
11
What did the --
12
What were the duties of the financial
13
14
officer?
A
15
16
What was his duties?
Well, he obviously collected
finances for the community.

Q
17
Are the -- these various -You've evidently organized MOA similar to a
18
town or a village in -- in structure.
19
Am I understanding that correctly?
20
We're still trying to organize Islamberg as a --
21
Would these people who are -- are -- hold offices
22
similar to a town, would they be officers of MOA
23
as well?
24
Officers meaning -- no.

Hussein Adams
3/11/2014
Page 33
Okay.
What's the difference?
Yes.
They're a local officer.
Each location has a
local officer that oversees, to the best of their
ability, you know, their department.
So we're talking about the structure of MOA.
8
9
What constitutes a member of MOA?

A
What constitutes a member of MOA?
10
An upright law-abiding citizen, resident
11
that is willing to abide by and follow, to the
12
best of their ability, the rules and laws of the
13
community as well as the rules and laws in the
14
country that they live in.
15
How does someone become a member of MOA?
16
Again, that has -- there's been no official
17
process.
18
expressed an interest and starting to partake and
19
participate in community activities, then, you
20
know.
21
So if we find an individual that has
I mean, you should know firsthand what Ali
22
Aziz.
Did he sign a membership form?
23
Do you have membership forms?
24
No.

Hussein Adams
3/11/2014
Page 34
Do you keep membership lists?
Do we keep membership lists?
How do you know if somebody is a member or not?
Like I said, it wasn't until recently that we have
No.
been trying to differentiate and sort through
individuals who can actually be, you know,
considered a member of our organization.
Well, what I'm hearing you tell me is that for the

most part, people self-identify as a member, or at
10
least in the past, that's the way they did it.
11
Right.
12
Is there any way that the organization recognized
13
14
15
Correct.
people as members?
A
Recognized?
Well, if an individual, like I said, if he
16
started participating in community events, then --
17
and showed his, you know, willingness to follow
18
our, you know, our rules and laws of our community
19
based on Holy Quran, based on the son of the Holy
20
Last Messenger, peace and blessings be upon him,
21
then that is the most important thing, because
22
within that, you find that any rules and laws of
23
any society can be adhered to and followed if
24
understood and not misinterpreted.

Hussein Adams
3/11/2014
Page 35
How is someone from the outside of the

organization to recognize someone as a member?
How is somebody -- I didn't hear you.
How is someone from outside the organization to
5
6
know whether a particular individual is a member?

A
What do you mean, how is someone from outside to

recognize?
You, yourself, or someone else, you mean?
Yes.
10
Well, you're identified by your work ethic and
11
what you have done, contributed to the community.
12
If you have individuals that have been
13
appointed, individuals that have been selected by
14
the people, which in most cases, we have in each
15
location, then, of course, this individual was
16
selected -- it's not -- people aren't strangers to
17
us.
18
into thinking from an official organization
19
perspective, and it's not like that.
20
understand?
21
You're -- you're trying to wrack your brain
You
Most of my peers, most of the individuals
22
that live in all of our communities, they were
23
born and raised into this community.
24
brother "A" or sister "B", I know who they are.
So if I see

Hussein Adams
3/11/2014
Page 36
And we're very particular in bringing in,
accepting new individuals because, by and large,
most of the time, they don't turn out too well, as
you can see with the individual who infiltrated
our community.
Does -- did MOA have written bylaws?
No.
Did MOA have records of meetings of people who
9
10
administer MOA?
A
11
I mean, I can tell you -- records of meetings

from -- from when?
12
13
From where?
I don't know.
Seriously, I don't know.

Q
Well, I understand that you have explained to me
14
that the organization is fairly informal.
15
were appointed deputy director by Sheikh Gilani,
16
and you came to the -- to Islamberg in the year
17
2000.
18
You
When you came, did you ask whether there
19
were any records of what had gone on before to
20
help you get oriented?
21
22
23
24
Do you think that this is -- you think I would

have been given any records, any information?
I walked into a jungle, pretty much.
that's literally.
And
No records, no documents, no

Hussein Adams
3/11/2014
Page 37
information was given because I was replacing
people.
put.
5
6
That's just straightforward, straight
Have you since found out whether they had any

records?
Well, I mean, I don't know if people scribbled --
scribbled information on notepads or not, but I
haven't seen or I haven't received any records.
Is there an office at -- at Islamberg?
10
Office is, you know, in -- we have a town hall.
11
You understand?
12
is running a department and they --
13
And, you know, mostly if someone
You know, like I said, we're trying to
14
organize ourselves and structure ourselves better,
15
but there's no official office, no.
16
I can appreciate that it's a challenge from what
17
you've described, but I'm trying to understand, in
18
this town hall, do you have a physical office?
19
No, we don't.
Just it's a town hall that we
20
utilize for community activities, group
21
activities, you know.
22
We have a lot of functions, religious
23
24
functions.
Q
Is there --

Hussein Adams
3/11/2014
Page 38
A lot of religious holidays.
I'm sorry.
I didn't mean to interrupt.
Did -- where did Mr. Atiq Shahid do his
work as deputy director?
In his home, like everyone else.
Did he do his own typing?
I don't think he could have typed.
8
9
couldn't tell you.

Q
10
11
Were there any -- was there anybody that helped

with clerical work?
No.
He didn't type documents.
He didn't --
12
that's -- no one assisted.
13
some family members, I don't know.
14
15
finances for -A
Jamil Haqq.
17
Jamil Haqq?
18
Yes.
19
After you arrived --
20
Did he continue to handle the finances
21
after you arrived?

A
23
24
I mean, maybe he got
When you arrived, who was the -- who handled the
16
22
So maybe -- I
He handled -- well, I -- that is very unsure

because they kept a lot away from me.
Who kept a lot away from you?

Hussein Adams
3/11/2014
Page 39
Jamil Haqq and his group.
Who was in Jamil Haqq's group?
Well, when I say "his group," I mean the people
that -- everyone paid dues to Jamil Haqq.
entire community paid their respects to Jamil
Haqq, so I couldn't tell you who was in his group,
per se, but people came and left and -- I mean,
you saw people coming and going, you understand,
and you didn't know who was who and what was what.
10
The
Well, you said people kept things from you, and
11
people in Jamil Haqq's group kept things from you.
12
I want to know who kept things from you.
13
Well, like I said, I couldn't tell you who because
14
there was just a presence, an overwhelming
15
presence, you understand.
16
don't ask this question, you don't associate.
17
understand?
18
of -- you know, that was present within the
19
community.
20
You don't go here, you

You
And that type of aura and that type
Now, how long before you -- before you arrived had
21
Jamil Haqq been expelled from a leadership
22
position?
23
Before I arrived?
24
Yeah.
How long?

Hussein Adams
3/11/2014
Page 40
I don't know how long it was.
I mean, he was --
like I said, you know, it was an ongoing
investigation.
I don't know.
Jamil Haqq had formerly handed -- handled the
finances.
finances after you arrived?
Did Jamil Haqq continue to handle
Well, when I say handled finances, in the time of
Jamil Haqq, there was no council, you understand.
There was no town council.
There were no
10
departments.
11
he -- whether it was covertly or overtly, you
12
know, appointed to deal with, you know, whatever
13
was needed.
14
That was handled by him and whoever
Now, my understanding is that like any
15
organization, like a town, there are expenses that
16
have to be paid, you know, utilities or whatever
17
taxes, and the people would pay money to a common
18
fund in order to pay the community's expenses.
19
To upkeep the community, correct.
20
My question to you, though, is:
21
22
When you arrived,
who was keeping that common fund?

A
Well, like I said, I don't know who was keeping
23
the common fund.
All I knew was Jamil Haqq
24
oversaw that department.

Hussein Adams
3/11/2014
Page 41
That was the past, though, wasn't it?
That was when I arrived.
And when -- afterwards,
we started establishing -- trying to establish
various departments within each community.
But didn't you tell me that Jamil Haqq had been

expelled from a leadership before you arrived?
Yes.
So when you arrived, was Jamil Haqq still managing
9
10
the community funds?

A
It's not like that, you know.
An individual is
11
expelled and whatever took place regarding the --
12
the most part of that investigation, I can't say
13
what he did and what he didn't do, what he handed
14
over, what he didn't, who he spoke to, who he
15
didn't, you understand, and where that went.
16
yes, he was expelled.
17
yes, he was ostracized and eventually removed from
18
our community.
Yes, he was exposed.
But,
And
19
Were the community funds kept in a bank account?
20
I don't know anything about that.
21
When the community expenses were paid, how were
22
they paid?
23
How were they paid?
They were paid.
24
Paid in cash, paid by check?

Hussein Adams
3/11/2014
Page 42
2
3
They could have been.
I'm not the financial
officer.
Q
Well, when you arrived, you were the man in

charge, weren't you?
I was the man that was being groomed, yes.
I thought you were appointed deputy director
7
8
before you came.

A
overnight.
Q
12
13
And like any
position, you don't just learn everything
10
11
I was appointed deputy director.
What did you do to find out about the community

finances?
Well, we couldn't do much to find out about
14
anything, so the goal was to establish, as I've
15
mentioned, these departments and have the
16
community -- let the community have a voice, let
17
the community speak, let the community represent
18
the community.
19
Was one of the departments a financial department?
20
Well, that's -- that's -- as you've stated,
21
22
Ubaidullah Shahid was the financial officer, yes.

Q
23
24
Ubaidullah Shahid was financial officer for MOA

and TMOA later on?
No, I don't -- I don't remember when Ubaidullah

Hussein Adams
3/11/2014
Page 43
was elected.
as the MOA or TMOA financial officer.
I could tell you when he was elected
Well, it seems to me that if somebody's brought in
to be in charge, one of the first things they do
is they learn about the finances for many reasons,
including to know what financial resources there
are to -- to support the community and make
changes.
Didn't you make inquiries as to what the
10
11
financial situation was when you arrived?

A
12
You're not understanding.
But I mean, I could --
I guess you have to ask that question.
13
There was no information, documentation, or
14
anything that was given regarding that.
15
because there were no official records, because
16
there were no official books that were kept, even
17
if it existed, you understand, something is not --
18
is not kept, then how can you give something that
19
you don't have?
20
21
And
So did you start with zero dollars in your

treasury?
22
Zero dollars.
23
So what did you do to build up some treasury?
24
Zero dollars.
Maybe below zero.
Obviously what's necessary.

Hussein Adams
3/11/2014
Page 44
Well, I mean, you know, one of our first things is
we found that many individuals were uneducated.
You understand?
you know, employment or did not have employment.
So that's where we started, encouraging and
assisting the youth, in particular, to go out and
make a better life for themselves, to get educated
and to start earning, you know, income so they can
look after themselves, their family, and help
10
Many individuals could not find,
their community.
11
Did Tariq Shahid resist your coming?
12
No, he didn't.
13
14
Atiq Shahid.
Q
Atiq.
15
Did he cooperate with you when you arrived?
16
Yes.
17
Did you ask Atiq Shahid about financial records?
18
Like I said, there were no financial records that
19
20
existed.
Q
21
I understand.
Did you ask Tariq --
22
Mr. Shahid.
23
Mr. Shahid.
24
I'm sorry, I just -- I'm having some

Hussein Adams
3/11/2014
Page 45
difficulty with the name.
I understand.
Did you ask him about the financial records?
Yeah, we discussed -- we discussed -- I'm sure we
discussed, not the financial records, because,
like I said, I knew they didn't exist, but what we
could do from that point to start structuring the
community better.
I mean, we were in a very bad state, a
10
very, very bad state as a community.
11
said, it's not what you're thinking where you come
12
in and there's an existing, you know, setup, an
13
existing body.
14
It wasn't like that.
So, yes, I was appointed deputy director,
15
but it took many -- up until today.
16
14 years later.
17
And like I
I mean, it's
You got to understand, we had a lot of
18
issues with, you know, youngsters.
We had issues
19
with -- and the first thing that I did was go
20
directly to law enforcement, go directly to the
21
FBI, go directly to those who were overseeing and
22
presiding over, you know, the law.
23
established and that was set up, so that I could
24
know myself without asking anyone what this
And that was

Hussein Adams
3/11/2014
Page 46
individual's, or that individual's, or these
people's history, criminal history, background,
who I can trust and who I couldn't trust.
Who did you talk to in law enforcement?
Steve Benjamin was the head of the FBI.
6
7
He's now
retired.
Q
When you say "head of the FBI," head of the local

office of the FBI?
The Binghamton office, yes.
10
You have to forgive me, I don't know how New York
11
State is organized in that way, but is there --
12
what is the state law enforcement agency that
13
would have jurisdiction over --
14
Albany.
15
Albany?
16
Albany, unless -- the agent in charge is Phil
17
Arizarry.
18
Is this a state police when you say Albany?
19
No, no.
20
Well, that's a city, isn't it?
21
Yeah.
22
As I say, I'm not familiar with how New York is
Albany -- Albany.
Albany, New York.
23
set up.
So I know the questions seem pretty
24
basic, but does the Albany, New York city police

Hussein Adams
3/11/2014
Page 47
have jurisdiction?
No.
Okay.
Jurisdiction -- Albany --
Albany oversees Binghamton, New York.
The FBI, their -- the boss -- the local
bosses of the FBI agents that are here, their
bosses are in Albany.
Well, the FBI is a federal agency.
Yes.
10
When you say "Albany," I take it some people use
11
that as a shorthand for saying it's the state
12
police or state -- Ohio would be highway patrol,
13
but I don't know what New York's is.
14
In Ohio, for example, the county sheriff
15
would have jurisdiction to the county.
16
New York, what state law enforcement officers have
17
jurisdiction over your community area?
18
19
20
In -- in
New York State -- New York State Police

Department.
In our area specifically would be
21
Binghamton Police Department.
22
touch and have been in touch for over 10 years
23
with them.
24
And we're also in
Our contact in that office is Mike Frantz.

Hussein Adams
3/11/2014
Page 48
1
2
Current contact in the FBI is Phil Arizarry.

Q
Now, when you came and discovered that you had
zero treasury, did you appoint anybody to have
control over the finances?
Like I said, from that point on, the community
appointed and elected individuals to run the town
council.
Whose idea was it to organize similar to a

municipality?
10
This was a group -- a group effort.
11
Who decided -- whose idea was it?
12
Like I said, this was a group effort.
Some of the
13
elders, including Atiq Shahid, myself, some of the
14
ladies of the community.
15
When did that happen?
16
The same time.
17
In 2000?
18
In 2000 -- between that 2000-2003 time period.
19
Between the time you arrived and the time that
20
this structure was set up, who handled the
21
finances?
22
23
24
Well, like I said, there were a number of people

that handed -- handled local finances.
After every two, three years, those

Hussein Adams
3/11/2014
Page 49
individuals are replaced and new individuals are
reelected.
individuals.
I don't have the names of the

I'm sure they can be --
Well, you didn't start out the structure until
about 2003.
the structure happened, who was handling the
finances?
So between the time you arrived and
We spoke about and initialized the structure.
And
as I've mentioned, that was not -- that did not
10
happen immediately.
It was something that was,
11
you know, still ongoing because, you know, a lot
12
of things have failed.
13
And most importantly, you can't have an
14
individual overseeing a department that has no
15
experience in that department.
16
someone handling finances or social services
17
that's not qualified to do so.
18
You can't have
Well, what services does the community purchase --
19
in 2000 now, what services did the community
20
purchase from outside?
21
for example.
You mentioned dumpsters,
22
What services?
23
Right.
24
Like -- I'm not understanding.

Hussein Adams
3/11/2014
Page 50
Well, you mentioned dumpsters.
I never -- dumpsters?
3
4
dumpsters.
Q
I thought you said one of the earlier issues you

had to deal with had to do with dumpsters.
No, I never said that.
All right.
8
9
What utilities does the community
purchase from outside?

A
10
11
I never mentioned
Utilities?
Regular utilities:
Lights, water,
gas, phone.
Q
12
All right.
So these utilities have monthly bills,
don't they?
13
Yes.
14
So when you arrived, who was paying the monthly
15
16
Correct.
bills?
A
Who was paying the monthly bills?
I don't know
17
because I didn't see or have any records or have
18
any access to any records.
19
After you arrived --
20
Right.
21
-- and you were the man in charge --
22
Right.
23
-- who was paying the monthly bills?
24
Individuals -- everyone paid their own bill.
I'm

Hussein Adams
3/11/2014
Page 51
not -- each individual, each resident paid
their -- pays their bill.
Was there a town hall at that time?
Yes.
Who paid the bill for the town hall?
I don't know.
After you arrived and you were the man in charge,
8
9
who was paying the bills for the town hall?

A
I don't know who paid the town hall bill, because
10
most likely, the town hall bill was in an
11
individual's name, a personal name, that most
12
likely someone took it upon themselves to pay that
13
bill, because monies didn't exist.
14
15
16
What common expenses does the community have?

talking about common expenses.
As in -- as in what?
17
18
Common, when you say common -Q
What bills does the --
19
I mean, you have a community treasury.
20
21
I'm
You
pay some bills out of it.

A
Yes.
We pay -- we have a masjid, we have a
22
mosque, a house of worship.
23
heating bill.
24
you understand?
Obviously we have a
We have a light bill.
We have --
We have bills for our masjid.

Hussein Adams
3/11/2014
Page 52
2
3
heating and lights and telephone for the mosque?

A
4
5
I don't know.
I can't tell you something I don't
know.
Q
6
7
When you arrived, who was paying the bills for
After you came, you were the man in charge,

weren't you?
I was the man that was in training and put in

charge, yes.
Well, when were you put in charge?
10
Well, it wasn't an official date.
11
12
I gave you that
date because that's the time that I arrived.

Q
13
Well, you said you were appointed by Sheikh Gilani

to be deputy director?
14
Correct.
15
When you came in 2000; right?
16
Correct.
17
Now you're telling me that you were in training
18
19
for some period?

A
Like I also mentioned to you, that like any new
20
position, it takes time to get acquainted.
21
never held or had this position previously.
22
understand?
I've
You
23
Who was training you?
24
Who was -- I told you, Atiq Shahid was my adviser.

Hussein Adams
3/11/2014
Page 53
He assisted me.
could to aid me.
He, you know, did the best he
How long did your training last?
I'm still in training.
While you were in training, were you the man in
charge?
Yes.
When did you take charge of the finances of the
9
10
organization?
A
11
Take charge of the finances?
There were no
finances.
12
And this is what I'm trying to explain to
13
you.
14
poor community.
15
Network finances.
16
This is a very close-knit community, a very

You're thinking Christian Action
That never existed.
When you got individuals that are making
17
$150 a week, that are living in dilapidated mobile
18
homes that barely have running water in their
19
houses, do you think there will be finances within
20
the community?
21
22
You told me that Jamil Haqq was handling the

finances --
23
That's what I was told.
24
In 2003, when the town structure was set up, who

Hussein Adams
3/11/2014
Page 54
1
2
was the first finance officer?

A
I can't recall.
I can -- not only can I not
recall, but there's no paperwork that existed.
didn't have paperwork like that.
paperwork to exist -- that existed when you're the
finance officer and you're the -- it wasn't until
these last few years that we've tried to
establish --
We
There was no
I mean, look, you -- the people select a
10
person.
11
elected -- I'm talking about back then, 2000,
12
2001, whenever it was, and you have -- again,
13
there's no training.
14
understand?
15
overseeing any department.
16
training in that particular department.
17
to be experienced or have training or have
18
understanding so that it's not a total mess, which
19
has been in the past.
20
21
22
There's no -- you
It's very difficult to have someone

You have to have
You have
When did Mr. Shahid, Ubaidullah Shahid, become the

finance officer?
23
24
And when a person is selected or
I'm not sure of the date.
This is recent, more
recent years.
Q
Is there a bank account for the community?

Hussein Adams
3/11/2014
Page 55
No.
How are the bills paid?
You would have to ask those who -- you know, I
mean, you're not talking about a lot of bills.
You're talking about a phone bill, a light bill, a
gas bill.
You can walk in, drop the money in the box.
You can write a money order.
you -- there's many ways bills can be paid.
10
11
12
You can -- I mean,
Who would I have to talk to to find out about the

finances of the community?
Like I said, again, local councils were
13
established, and individuals were elected and
14
appointed to hold various positions.
15
16
17
Who would I have to talk to to find out about the

finances of the community?
I can't -- there is no one that you can talk to.
18
There's no one that you can talk to.
19
to me.
20
21
All right.
You can talk
Tell me about the finances of the
community, the way it's currently handled.
22
I thought -- I thought we went over that.
23
Well, I've got a lot of "I don't knows," so I'm
24
trying to find out if you don't know, who does

Hussein Adams
3/11/2014
Page 56
1
2
know how the finances are handled.

A
I'll repeat myself.
We have a community.
Within that
community, we have various expenses.
of that community contributes to those various
expenses.
Every member
Does every member of the community contribute to a

common fund from which the expenses are paid?
A common fund?
10
Common fund.
11
What do you mean, "a common fund"?
12
Does someone collect the money and then pay out on
13
the bills?
14
Well, yeah.
Yes.
15
Who?
16
I just told you, Ubaidullah Shahid was the last
17
individual that collected the monies and paid the
18
bills.
19
Now, he might have had family members or --
20
It's not structured like that.
It's not
21
structured where you have individuals that are --
22
if there's a light bill that's due, you ask
23
Brother So and So or Sister So and So, Can you go
24
and pay this light bill?

Hussein Adams
3/11/2014
Page 57
And many individuals in the community have
looked after community expenses out of their
pocket when monies didn't exist.
How long was Mr. Shahid --
Or is it Ms. Shahid?
It's a male?
It's Mr. Shahid.
How long was Mr. Shahid the finance officer?
I'm not sure how long, but like I said, he held
his position, so at least two to three years.
10
You said it was three-year terms?
11
Yeah.
12
Did he hold it for more than one term?
13
If he did -- he might have.
14
Can you think of anybody else who held that job
15
16
Yes.
since 2003?
A
No, because, and, again, it's not an area -- if
17
you're talking about millions of dollars, you need
18
a trained, educated financial officer.
19
you're talking about hundreds of dollars, anybody
20
can do that.
21
You say Mr. Shahid's term ended?
22
Yes.
23
When did it end?
24
Last year, year before.
When

Hussein Adams
3/11/2014
Page 58
When do the terms run from?
Those are three-year terms.
3
4
begin and when do they end?

A
5
6
When do they
They begin when we say begin.
They end when that
term is up.
Q
And you're not sure whether Mr. Shahid's term

ended this year or --
It wasn't this year.
-- more than a year ago?
10
Yeah, it's more than -- more than a year ago.
11
Mr. Shahid's term ended more than a year ago, and
12
13
he has not been replaced?

A
14
No, he has not.
We're actually in the hole as a
community.
15
What do you mean, "in the hole"?
16
In arrears with our bills.
17
Was Mr. Shahid the finance officer at any time
18
after TMOA --
19
No.
20
-- commenced?
21
22
Who is on the town council right now?

A
Like I've stated, we -- we don't have an exist --
23
we are looking to replace the previous town
24
council.

Hussein Adams
3/11/2014
Page 59
How long has it been since you had a town council?
Well, like I said, there's no official town
3
4
council, so I can't say -- I can't give a time.

Q
5
6
Well, didn't you tell me the town council members

were elected?
Yes, when we see that -- you know, things have at

a point.
Like I said, in the last -- last few years,
things have kind of, you know, dismantled.
10
we're trying to regroup.
11
difficult position right now.
12
13
And
And we're in a very
When you had a town council, what was its

function?
14
Function of the town council?
15
Yeah.
16
To look after the community, community needs:
The
17
roads; the, you know, property taxes; make sure
18
that the families that live and exist within that
19
community are taken care of to the best of their
20
ability, that they have food in their cabinets,
21
that the babies can find milk to drink, that
22
people are not suffering and left alone.
23
24
Did the town council have anything to do with

passing rules for the community?

Hussein Adams
3/11/2014
Page 60
Yes, basic rules, you know.
Of course, we oversee, you know, like I
mentioned to you, individuals.
We make sure that
residents of our community are not involved in any
antisocial activity, any criminal activity.
the town council oversees locally on a local
level.
And
Did the town council have regular meetings?
I guess they met when they saw the need to meet.
10
You know, if -- if the community was in
11
detriment of losing the property or -- you know,
12
because of the land taxes that are due, they would
13
have to meet, discuss what their plan of action
14
is.
15
the times, there was no money available.
16
of the times, we found ourself in the hole, as I
17
say.
Go to each individual and -- because most of

And most
18
Did you participate in town-council meetings?
19
No.
20
Did you go to them?
21
No, I didn't.
22
Did the town council, when they passed rules, were
23
24
the rules put in writing?

A
No.

Hussein Adams
3/11/2014
Page 61
It wasn't just a town council.
It's a
community.
things that are relevant to the community, the
community is called.
The community has a voice.
And when the town council discusses
The community has a say.
You're talking about 40, 50 individuals.
You understand?
The community meets, and they
discuss with the community, What do you all think
we should do about, you know, the lights at the
10
mosque that have now been cut off for a week
11
because they're in arrears?
12
13
Did the town council keep minutes of any of its

meetings?
14
I don't know of any minutes.
15
You don't know one way or the other; or no, they
16
17
didn't keep minutes?

A
I don't know one way or the other if they kept
18
minutes, when they kept minutes.
Like I said,
19
this was -- this is a community effort, family
20
effort.
21
Does the town hall have a filing cabinet?
22
No, it doesn't.
23
Does it have computers?
24
No.

Hussein Adams
3/11/2014
Page 62
If any records were kept by the town council,

where would those records be kept?
What type of records?
Any records.
They would be kept in the NYSEG office, which is
the utility.
I mean New York State.
I mean, most records, if -- if there -- you
know, if there were records, these are -- you
know, public receipts of a utility bill, I guess
10
they keep it in a file folder, if you're asking.
11
I don't know -- there's no official office and
12
there's no official filing cabinet and there's
13
no -- it's not like that.
14
like that.
15
The structure is not
If a utility bill comes to the community for the
16
mosque, say, as you indicated is in arrears, who
17
gets it?
18
19
It comes to one of the box numbers in the

community.
20
And who retrieves the information from the box?
21
One of the individuals that represent -- that is
22
appointed to look after the light bill or whatever
23
bill that may be.
24
And who is that right now?

Hussein Adams
3/11/2014
Page 63
That looks after the bills?
Yes.
I'm not sure.
Like I said, it's not an appointed
thing.
goes and checks the box and brings the bill and,
you know, look, this bill has to be paid, and it's
paid.
You might have a random individual that
Someone goes and pays the bill.
Does anybody have the duty to check the Post

Office box on a regular basis?
10
I don't think so.
11
Who has a key to check it?
12
I don't know who has the key.
13
I honestly don't
know who has the key.
14
Have you ever checked the Post Office box?
15
No, I haven't.
16
Never.
MR. CARROLL:
17
bladder break.
18
off the record.
19
I need to take a
Take 15 minutes.
Let's go
* * *
20
(A brief recess was taken.)
21
* * *
22
BY MR. CARROLL:
23
24
Not once.
We're back on the record.

Mr. Adams, you sat through Mr. Abdul-Haqq's

Hussein Adams
3/11/2014
Page 64
deposition yesterday; correct?
Yes, I did.
Is there anything that Mr. Abdul-Haqq said or
testified to you -- testified that you would
disagree with?
No.
Have you ever met Sheikh Gilani?
Yes, I have.
When did you meet him?
10
I've met him a few times.
11
Where did you meet him?
12
Five, six, seven times.
13
Where did you meet him?
14
In Pakistan, Lahore.
15
Five, six, seven times over what period?
16
Last 15, 20 years.
17
Well, did you meet him before you were appointed
18
19
deputy director?
A
What year was that?
20
Ninety-seven was the first year.
21
What was the purpose of the meeting in 1997?
22
We went over as a hiking trip.
There were 10 of
23
us, Islamberg Hiking Club, and we stayed for 30
24
days.

Hussein Adams
3/11/2014
Page 65
You weren't living in Islamberg, New York, at that

time?
No, I wasn't.
The Islamberg Hiking Club that you're talking
about, is that from Islamberg, New York, or is
there another Islamberg somewhere?
No.
How did you happen to be traveling with the
9
10
Islamberg, New York.
Islamberg Hiking Club?

A
How did I happen to be traveling with --
11
These are individuals from our community,
12
13
hikers.
Q
14
15
But you were living in Canada
at the time?
A
16
17
Well, I understand.
Yeah.
Like I expressed earlier, Canada and United
States were one community.

Q
Had you -- how many times had you visited
18
Islamberg, New York, before you were appointed
19
deputy director?
20
21
24
Fourteen, 15, 16 or more.
As I mentioned, also, I've attended, you
22
23
Many times.
know, our summer programs in Islamberg.

Q
Was there family in Islamberg that you were

visiting?

Hussein Adams
3/11/2014
Page 66
No, not at that time.
Now, you mentioned your wife was from New York.
So I assume, perhaps, she was from Islamberg, but
that's not so?
No.
How many times had you met Sheikh Gilani before he
appointed you deputy director for Islamberg?
How many times?
You must have impressed him.
10
Just once.
You don't have to answer that.
11
No, I won't.
12
Who is -- are you --
13
Don't worry.
Maybe you told me this earlier, and I've
14
just forgotten it, but is Islamberg currently
15
between mayors as well?
16
Yes.
17
Who is the previous mayor?
18
The previous mayor was -- who's the previous
19
mayor?
Ibrahim, Ibrahim Rahim.
20
Can you spell Rahim?
21
Rahim, R-A-H-I-M.
22
And that is a male, man?
23
Yes.
24
So Mr. Rahim was mayor.
Correct.

Hussein Adams
3/11/2014
Page 67
How many terms was Mr. Rahim mayor?
One term.
Who was the mayor before Mr. Rahim?
Before Mr. Rahim, who was the mayor?
I mean, it's there.
We can get the names
for you.
I'm sorry.
I said we can get the name of the previous mayor.
You said you can get the names for me?
I can't recall.
10
And you're questioning regarding a local
11
community.
12
oversee all of the communities, so I'm not so much
13
involved in, per se -- yes, I live in Islamberg,
14
but I'm not so involved in just Islamberg.
15
understand?
16
17
Okay.
And what you have to understand is I
You
I work on a broader scale.
When you were initially appointed, were you
initially appointed for just Islamberg?
18
No.
19
You were initially appointed to oversee all the
20
communities?
21
Correct.
22
Is there anybody who is the person that oversees
23
Islamberg primarily as opposed to Islamberg and
24
other communities?

Hussein Adams
3/11/2014
Page 68
Well, we are there, myself and my assistant, you
know, co-worker here, Khadija Smith, so we live
and reside in the community.
Do the other communities have a particular person
who is appointed to oversee the community from
inside that community?
Yes.
What is the title?
That's the mayor of the community.
10
Was this town structure developed for all the
11
communities at the same time, or did it spread
12
from Islamberg?
13
14
15
No.
It was -- that's how -- it was developed all
at the same time.

Q
Did that --
16
That town structure didn't exist before
17
2003, as I understand your testimony.
18
No, it did not.
19
Somewhere we've run across the name M. Hussein
20
21
22
Adams.
A
Is that a different person from you?
Muhammad Hussein Adams.

I can't say it's a different person, but --
23
I do go by that name as well, if that's what
24
you're asking.

Hussein Adams
3/11/2014
Page 69
2
3
Yes.
But when I asked your name, you didn't give
that to me.
A
Why?
It's not an official name.
It's not a legal name.
It's not an official name.
Any individual in Islam can be called --
for example, Atiq Shahid, Muhammad Atiq Shahid out
of reverence and respect of the Holy Last
Messenger, peace and blessings be upon him.
Are there any other names that you go by?
10
No.
11
Who is Khadija Abdis Salaam?
12
I don't know.
13
I apologize for butchering the pronunciation.
14
Oh, Khadija.
She's -- she's not officially a
15
trustee, but she's -- she's also an assistant to
16
our national board.
17
What is the national board?
18
What is it?
19
Yes.
20
It works in the same capacity, oversees the entire
21
22
community, TMOA.
Q
23
24
Was this the same national board for overseeing

MOA?
You said was it the same?

Hussein Adams
3/11/2014
Page 70
Yes.
No.
This is -- this is the newly established
board.
And who's on the national board?
Myself, Khadija Smith, Khadija Salaam, Ahmad Abdul
Mumin.
How do you spell Mumin?
M-U-M-I-N.
Is he also M. Ahmad Abdul Mumin Chowdhury?
10
Yes.
11
Is the Chowdhury name a name of respect for
12
somebody?
13
Yes, it is.
14
For who?
15
For any individual that is -- follows the teaching
16
of the Prophet Muhammad, peace and blessings be
17
upon him, and also follows the Sufi -- Sufi
18
discipline of Sheikh Abdul-Qadir Gilani, the late
19
sheikh of Baghdad.
20
Is Mr. -- I know I'm not pronouncing it correctly,
21
I do apologize for these pronunciations, but is
22
Mr. Mumin a resident of Islamberg?
23
No, he's not.
24
Where is he a resident?

Hussein Adams
3/11/2014
Page 71
He's a resident of Georgia.
How many communities are members of TMOA?
How many communities are?
Yes.
How many -- I didn't hear the last part.
How many communities are part of TMOA?
Officially, three.
What are those communities?
Islamberg; Mariaville, which is right down the
10
street from Islamberg; and the third is South
11
Carolina, I believe.
12
13
Why does a -- why do you have a national board

member from Commerce, Georgia?
14
What do you mean why?
15
Well, I take it Commerce, Georgia, is not
16
17
officially a TMOA community?

A
Um-hum.
Well, we have board members.
Like I
18
said, we oversee all of our villages, all of our
19
communities.
20
that can represent the south, southern locations.
21
All right.
It only makes sense to have someone
Now, you say officially three
22
communities are part of The Muslims of America,
23
Inc.
24
Why -- what do you mean by the

Hussein Adams
3/11/2014
Page 72
1
2
qualification "officially"?
A
3
4
Paperwork that actually are incorporated under

that name.
We understand that there was an investigation
conducted beginning in the fall of 2012 by
Ms. Amatul-Wadud's office.
What led up to that?
What led up to the investigation?

Well, again, going back to trying to get
paperworks in order and trying to situate and
10
organize our community properly where it can be,
11
you know, an official community.
12
there was already suspicion because we didn't have
13
information.
14
never saw -- you never saw any documentation that
15
showed or proved that Islamberg was incorporated.
16
You understand?
17
going back to which I stated to you earlier, it
18
wasn't shown.
19
submitted.
20
were expelled and officers changed, that stuff was
21
not handed over.
22
We -- I mean,
You know, it was just hearsay.
You
And that's something that, again,
It wasn't something that was
You understand?
Because individuals
You understand?
And that happened in 2000.
Now we're talking
23
about a much longer time later.
So I'm trying to
24
find out what the sequence of events was that led

Hussein Adams
3/11/2014
Page 73
1
2
up to the investigation.
A
Well, like I said, you know, to the best of our
ability, started trying to look into, ourselves,
as individuals that were not official in any
capacity, to paperwork to -- you understand?
can't go and acquire information on an
organization and not show proof that you're part
of or associated or connected; right?
You
So --
So what did you do?
10
Well, we consulted with our lawyers and we started
11
12
trying to -- to acquire that information.

Q
13
Are you talking about Ms. Clark and

Ms. Amatul-Wadud?
14
Ms. Amatul Wadud.
15
So if I'm understanding what you're telling me
16
correctly, things began when you were just trying
17
to gather the paperwork, if any existed, that
18
would show that Islamberg or MOA was incorporated?
19
Correct.
20
Now, at that time, you were using the -- the name
21
Muslims of the Americas?
22
Yes, so we thought.
23
And so what did you find out about when there was
24
an investigation into the incorporation papers?

Hussein Adams
3/11/2014
Page 74
We found out that Muslims of the Americas didn't
exist, that the former entity, as what it was
explained to you yesterday by one of the
individuals that was -- you know, dealt with that,
it was still on file and record of our
organization being under the Ikhwanul Muslimun.
Which is Muslim Brotherhood?
What do you mean "which is"?
Well, Ikhwanul Muslimun means Muslim Brotherhood.
10
Okay.
Well, if it means that, I'm not -- I'm not
11
versed in that to say that, you know, which means
12
what, yeah.
13
14
Well, Ikhwanul Muslimun was the problem -- one of

the -- one of the problems with Jamil Haqq; right?
15
Correct.
16
So when did that investigation begin?
17
Was that in -- in the fall of 2012?
18
Yes.
19
Why did it take you so many years to begin to
20
21
wonder about the paperwork for it?

A
Because we were simply told that it existed.
And
22
not only that it existed, we didn't really see a
23
need to utilize, you understand, or to be
24
recognized, or the importance, should I say, of

Hussein Adams
3/11/2014
Page 75
making sure, you understand, we were who they said
we were.
4
5
Was there an event that gave rise to your need to

know?
Well, like I said, there was -- you know, even up
until today, I'm sure there's, you know,
individuals that are talking about the Jamil Haqq
era.
30-something years, however long it was.
You understand?
10
You're talking about
And there was just too much -- I'll say
11
there was just so much lack of information that
12
existed, you understand, when you're just
13
following -- blindly following, you understand,
14
you know, because so and so said this or this
15
individual because he's an elder or because
16
he's -- you understand, has been respected in the
17
community.
18
I mean, Muhammad Hasib, who was here
19
yesterday, Abdul-Haqq, he's been from the onset.
20
You understand?
21
younger individual, you're not going to assume or
22
even think that there's a problem that that
23
exists.
24
You're not going to -- as a
You understand?
I understand.
So it wasn't done.
I think what you're telling me is

Hussein Adams
3/11/2014
Page 76
you had an elder, a respected member of the
community was telling you it was so and it felt
disrespectful to question him?
Correct.
But my question is:
6
7
Was there an event that made
you feel like you had to question it?

A
Well, like I said, I mean, we paid property taxes
every year for the community, thousands of dollars
that's collected within the residents, like any
10
community.
11
community in order and, you know, you got to
12
make -- because as far as -- as far as I'm
13
concerned, we have communities that are paying
14
more monies than they should be paying because
15
structure is not in order.
16
And when you start trying to get your
You understand?
If you have a structure or site on a
17
particular community, and I'm speaking about any
18
community within TMOA, that, say, an abandoned
19
building, you understand, or vacant mobile home,
20
you're paying taxes on that mobile home, you're
21
paying taxes on that structure or that site
22
because you haven't updated your paperwork.
23
trying to, again, structure the community properly
24
and acquire proper paperwork, and also dig into,
So in

Hussein Adams
3/11/2014
Page 77
you understand, as much as we could what -- what's
going on, why can't we see anything, this was --
this was sought.
So if I'm understanding you correctly, you were --
got to wondering if you were a religious
corporation, were you perhaps exempt from property
taxes, and you were going to do the background
paperwork to find out?
Exactly.
10
How was the investigation conducted?
11
It wasn't -- I wouldn't say it was an
12
investigation.
It was a simple call to the county
13
clerk's office looking for -- because when our
14
property taxes are paid, they're paid in cash.
15
You understand?
16
what, you know, the amounts that are paid, you
17
know, for each year.
18
clerk's office looking for Muslims of Americas, it
19
didn't exist.
20
Are you referring to Ikhwanul Muslimun?
21
she knew, I don't know, and that did exist.
22
was the first red flag, you understand, that there
23
was something going on with the paperwork that we
24
weren't aware of.
You know, they have records of
And in contacting the county
But what the clerk did state was,

However
That

Hussein Adams
3/11/2014
Page 78
So eventually, you located the amendment to the

Articles of Incorporation.
Was that filed in Kings County?
I'm not -- paperwork questions, I'm not sure.
But you found that piece of paper.
6
7
happened from there?

A
8
9
What are you referring to, the original -original Ikhwanul Muslimun paperwork?
10
11
The amendment to the Articles of Incorporation

that Mr. Abdul-Haqq talked about.
12
I don't know.
I'm not sure what you're referring
to.
13
MR. CARROLL:
14
We need to go off the
record for just one moment.
15
* * *
16
(A brief recess was taken.)
17
* * *
18
BY MR. CARROLL:
19
20
And what
All right.
Back on the record.
Mr. Adams, the -- somehow the amendment to
21
the Articles of Incorporation was discovered and
22
the problem with it being an amendment to the
23
Ikhwanul Muslimun articles was uncovered.
24
How did things progress from there?

Hussein Adams
3/11/2014
Page 79
Regarding the community?
Well, I mean, with respect to the ultimate
decision to do a dissolution and formation of a
new corporation.
Well, exactly that.
previous corporation and established a new one.
MR. CARROLL:
And I gave it to you yesterday.
10
MS. AMATUL-WADUD:
12
Okay.
* * *
13
(Exhibit 4 herein was officially
14
marked for identification.)
15
* * *
16
BY MR. CARROLL:
17
18
I'm handing you what's been marked Deposition

Exhibit 4.
19
I'll ask you if you can identify it?

A
21
Yes.
For the dissolution of Muslims of Americas,
Inc., pursuant to religious corporation.

Q
23
24
This
is the petition for dissolution.
11
22
Let's mark this as
Exhibit 4.
20
We dissolved -- dissolved the
Now, this is the petition for dissolution that you

and Ms. Smith signed; is that correct?
Yes.

Hussein Adams
3/11/2014
Page 80
Is it your signature that appears at the end?
Yes.
Now, the actual petition had some additional
exhibits, but they're not in Exhibit 4; correct?
Say that again.
The initial petition, when it was filed in the
court, had some exhibits that were attached to it,
but those are not contained in Exhibit 4; correct?
I don't know.
10
Okay.
Now, leading up to the filing of the
11
petition for dissolution of Muslims of the
12
Americas, Inc., was there a -- well, was there a
13
vote by anyone with respect to doing that?
14
To dissolve the corporation?
15
Yes.
16
No.
17
Was there a --
18
You acted, as you and Ms. Smith, as a
19
majority of the board of MOA in -- in filing the
20
petition; correct?
21
Yes.
22
Were you the only members of the board at that
23
24
point?
A
Yes.

Hussein Adams
3/11/2014
Page 81
Members of what, the MOA board?
Yes.
Like I said, we have the names that I gave you,
but they're not officially trustees of the
organization.
Now, was there any other paperwork that was
involved in the -- in the dissolution aside from
the filing and the exhibits?
No, not that I know of.
10
Well, I understand that there were some -- I
11
presume there were some deeds from the old
12
corporation to the new corporation.
13
14
15
You would have to ask my lawyer.

I mean, yeah, there were deeds, obviously.
Were there any other minutes, documents,
16
agreements, assignments, bills of sale, anything
17
like that that were part of this transaction?
18
That were part of the dissolution transaction?
19
Dissolution and the formation of the new entity.
20
I don't know of any documents.
21
don't -- I mean, I can't even --
22
Some of the documents that you might have
23
24
You know, I
right there, you'd have to show it to me first.

Q
I'm not aware of any documents.
I'm just trying

Hussein Adams
3/11/2014
Page 82
to find out if there are any that I should ask
for.
4
5
I don't know of any.
I don't know of any
documents.
Q
Did The Muslims of America, Inc., own any property
other than the real estate that's identified in
the petition?
Other than the real estate?
Other property.
10
11
Other properties?
I think personal property,
equipment, anything at all.

A
No.
I mean, even personal -- even like other
12
communities, it wasn't owned by Muslims of
13
Americas.
14
15
And I understand the real estate is identified in

the petition.
16
Right.
17
So we know about that.
18
I'm just wondering if there's any other
19
property of any kind or nature that Muslims of
20
America, Inc., owned or transferred to The Muslims
21
of America, Inc.?
22
No, I don't know of any.
23
Okay.
24
I think I gave you what I did know, the three

Hussein Adams
3/11/2014
Page 83
1
2
names.
Q
Well, distinguishing between real estate and other
types of property -- I mean, your coat is a type
of property, for example, computers are a type of
property.
else transferred besides real estate.
I was wondering if there was anything
No.
Now, what changes were there in the organization
that were made with the formation of --
10
Well, let me step back a second.
11
We can agree that The Muslims of America,
12
Inc., was incorporated January 24th, 2013;
13
correct?
14
Yes.
15
So out with the old and in with the new; right?
16
Correct.
17
With the new organization, what other changes,
18
structural administrative changes, did you make
19
for The Muslims of America, Inc.?
20
21
Structural administrative changes?
There haven't
been any.
22
Well, you have a new board of directors; right?
23
I mean, that was -- yeah.
24
Does TMOA have a set of bylaws?
MOA, TMOA.

Hussein Adams
3/11/2014
Page 84
We started formulating a set of bylaws.
Do you now have a set of bylaws, or are they still
3
4
in the process?
A
5
6
have started formulating.

Q
7
8
They're still in the process, but we have -- we
So bylaws are in process, but have not yet been

adopted; is that correct?
Well, there are different bylaws that have been

adopted for years, but have not been official, you
10
understand, regarding membership, you know, what
11
classifies -- what classifies an individual as a
12
member and -- yeah.
13
Are these writings?
14
Are they writings?
15
Yes.
16
These bylaws that you're saying have been
17
18
in place for years, are they in writing?

A
19
20
That's...
We have -- yeah, we have some.
If I'm not
mistaken, we have some bylaws in writing.

Q
If I were to ask for these documents and call them
21
bylaws, would that adequately describe them so you
22
would know what I was asking for?
23
Yeah.
That's not a problem.
24
Have these bylaws that were in place for years

Hussein Adams
3/11/2014
Page 85
with MOA, have they been adopted for use with
TMOA?
They've been changed or we've -- we've -- I mean,
we didn't use MOA as an example, if that's what
you're asking.
Okay.
Tell me how that did work.
What, establishing the bylaws?
Yes.
Well, like I said, things that have been said and
10
not put in, you know, official documentation, we
11
started establishing, put in -- you know, put in
12
the paper.
13
14
You indicated your current bylaws are in process,

but have not yet been adopted.
15
Have there been other things that have been
16
17
officially adopted in writing by TMOA?

A
18
TMOA is new.
We just -- we just, just
incorporated TMOA.
19
Well, you just incorporated over a year ago.
20
Right.
21
Do the directors of TMOA hold regular directors'
22
That's why I said it's a work in progress.
meetings?
23
No.
24
Have there been any directors' minutes?

Hussein Adams
3/11/2014
Page 86
We conference, teleconference.
Have there been any minutes taken of --
I'm sure we have some minutes, yes.
Who is the keeper of the minutes?
Keeper of the -- Yasmeen Begum.
How do you spell last name?
B-E-G-U-M.
Now, she reduces the minutes to writing?
Yes.
10
She's the keeper -- she takes minutes of the
meetings.
11
Does she give everybody copies of them?
12
Sometimes.
13
Is she the person who is now the keeper of the
14
written records for the corporation?
15
Yes.
16
Does she have an official title?
17
She's secretary.
18
Was she appointed by a meeting of the directors --
19
Yes.
20
-- or trustees?
21
Yeah.
22
Does the new corporation have a treasurer?
23
A treasurer?
24
No.
We have -- she acts -- I guess
an acting treasurer, Khadija Salaam.

Hussein Adams
3/11/2014
Page 87
Does the new corporation have a bank account?
Does the new corporation have a president?
That's my acting role.
Does it have any other officers?
In the corporation?
Yes.
Those names that I gave you.
Well, you said there was a secretary, an acting
10
treasurer, and an acting president.
11
We have head of the social services, Tahara.
12
Tahara?
13
Khaliq is K-H-A-L-I-Q.
14
Now, what is the job of the head of social
15
16
services?
A
17
She oversees social services.
She oversees the
social service department on a national level.
18
What sort of social services does she oversee?
19
Social services.
20
21
Different cases within the
community.
She has maybe domestic violence.
Anything
22
that would fit under social services, you know,
23
marriage, divorce, counseling.
24
And again, these individuals oversee on a

Hussein Adams
3/11/2014
Page 88
national level, meaning thereby they have set up
or at least have representatives locally in each
local location.
Now, you told me earlier that TMOA has only three
official locations.
So the national oversight,
does that include the unofficial locations?
Yes.
Unofficial locations would be like Red House,
Virginia?
10
Correct.
11
What other unofficial locations are there?
12
Red House, Virginia; Commerce, Georgia; Odum,
13
Georgia; Texas; Tennessee.
14
Texas is what city?
15
Sweeny.
16
Tennessee is what city?
17
Dover.
18
Dover?
19
Dover, correct.
20
Any others?
21
I gave three:
22
Texas; Tennessee; Georgia; Georgia;
south Carolina; Virginia; Canada.
23
Where in Canada?
24
Where was -- Barry's Bay.

Hussein Adams
3/11/2014
Page 89
I'm sorry, I didn't catch the word.
Barry's Bay.
Michigan?
Michigan as well.
Are there any others?
Unofficial?
Yes.
We have a community in Alaska.
Where?
10
It's just outside of Anchorage.
11
Any others?
12
No.
13
The reason I ask is you gave me three official,
That's it.
14
and then one, two, three, four, five, six, seven,
15
eight unofficial.
16
complaint made reference to 12.
17
18
Okay.
That's a total of 11.
I'd have to think.

California.
19
And city?
20
I don't have the city.
21
22
23
24
The
Somewhere -- I don't know.
Somewhere outside of Los Angeles.

Q
Now, news reports have made reference to 22

communities.
Would that be inaccurate?

Hussein Adams
3/11/2014
Page 90
You said "news reports"?
News reports including DVDs produced by -- by your
folks.
Well, maybe there were other locations included.
What written communications do you have with the
6
7
various communities?
A
We -- we send, you know, memos, updates regarding
our religious holidays, regarding our eids, our
celebrations, our festivities, our
10
Muslim-Christian program, our dialogues, our
11
interfaith programs, so on and so forth.
12
Now, back when it was MOA -- back when there was
13
MOA, or whatever it was, was it the same set of
14
communities that were official and unofficial?
15
No, because we newly incorporated TMOA.
16
Well, I'm talking about back before TMOA.
17
18
Were
the same communities official and unofficial?

A
Before TMOA, we -- I don't know if we had any
19
official communities.
20
like I said, paperwork wasn't established like
21
that.
22
established like that.
23
24
I mean, if -- you know,
Our organization wasn't set up and
We might have a community in Commerce,

Georgia, let's say, for example, that have come

Hussein Adams
3/11/2014
Page 91
together, the residents, you know, have come
together, you know, put their monies together,
resources together, purchased the community or the
property, and they, you know, do what is best to
try to acquire that property, you understand,
utilizing who can -- you know, an individual that
can acquire that property.
Does TMOA have a public-relations director?
That was Muhammad Hasib Abdul-Haqq.
10
Muhammad
Hasib Abdul-Haqq was the MOA -- MOA director.
11
Okay.
What about TMOA?
12
TMOA is Matthew Gardner.
13
Where is Matthew Gardner?
14
He's in Virginia.
15
Red House?
16
Yes.
17
How many inhabitants does Islamberg have?
18
Forty, 50.
19
How about Mariaville?
20
Maybe four.
21
Four?
22
Four.
23
How many South Carolina?
24
Ten.

Hussein Adams
3/11/2014
Page 92
How many Red House?
Red House, about the same as Islamberg, 40 to 50.
Now, the three official communities, are there any
formalities that are coming with TMOA as to
membership?
Yes.
They're not in place yet, I take it?
No, because if something is -- if individuals are
found we can't make someone an individual -- a
10
member of our community if we come -- you know,
11
receive information that they shouldn't be.
12
That makes sense to me.
13
14
Okay.
A
15
16
Do you now have a membership list?
We have the list that we submitted.
I think we've
submitted it to you.
Q
17
I've received one, but I, frankly, haven't opened

it, yet.
18
Does that list contain people at all three
19
villages?
20
I thought that list was for the Hancock community.
21
Okay.
22
So the list only contains names from
Hancock?
23
If that's what was requested.
24
Well, I believe it was a list of all members of

Hussein Adams
3/11/2014
Page 93
TMOA that was requested, but is that what was
submitted?
As I say, I haven't looked at it yet.
Okay.
It was given to me in a sealed envelope, and it
I'm not sure.
remains in that sealed envelope.
So why didn't you open it?
I'll be happy to answer that question off the
record.
I really would.
10
Okay.
11
As you sit here today, Exhibit 4 that you signed -
12
and please feel free to take a minute to look it
13
over - I want to make sure you still agree with
14
everything that's in it.
15
I signed it.
16
I understand.
But...
17
* * *
18
(Pause for review of Exhibit 4
19
documents.)
20
21
* * *
Q
22
Are you comfortable with the accuracy of

everything that is in Exhibit 4 that you signed?
23
Yes.
24
Are you familiar with a video that's been

Hussein Adams
3/11/2014
Page 94
described to me as the Arabiya video, Arabiya --
Yes.
-- A-R-A-B-I-Y-A?
Yes.
That video says there are 22 additional
communities besides Hancock.
Any idea what additional communities it
might be talking about that you haven't told me
about?
10
No.
11
How old is that video?
12
I don't know.
13
14
Maybe six years, seven years, five
years.
Q
15
I just wondered if there had been some changes

over the years.
16
I'm sure there have.
17
Have you lost communities over the years?
18
Have we lost communities?
19
So you don't know why the Arabiya video would say
20
21
We've lost individuals.
there's 22 additional communities in -A
The Arabiya video, the person that produced the
22
video, that's what you're referring to that says
23
there's 22 villages?
24
I'm saying that the information given on the video

Hussein Adams
3/11/2014
Page 95
1
2
is that there are 22 additional communities.

A
3
4
That's the Arabiya channel that produced the

video.
Okay.
Basically what you're telling me is you're
not responsible for the information that they --
Correct.
Tell me about the other entities that are
associated with TMOA and how they're associated.
And what I have in mind is the
10
International Quranic University, the entity that
11
publishes books and materials and videos.
12
about those entities.
13
Tell me
I don't know about those entities, but that's our
14
entity that publishes our books, Quranic Open
15
University.
It's under Zavia Books.
16
Zavia Books, is that a corporation?
17
I'm not sure if it's -- yeah, I think it is a
18
corporation.
19
And where is it operated from?
20
It doesn't have an official office.
It operates
21
in Islamberg.
You know, Islamberg is the
22
headquarters of our community, of TMOA.
23
Is the work of Zavia Books done at Islamberg?
24
Well, we do have a small printing press, yes.
And

Hussein Adams
3/11/2014
Page 96
1
2
it's also printed in Pakistan.

Q
And what I'm trying to figure out is corporate

relationships.
Who's the owner of Zavia Books?
There's no owner.
Is it a non-profit corporation?
We print material that we produce and that we --
you know, we have a lot of interfaith programs.
We have a lot of, you know, dialogue with
10
Christians and other denominations, and a lot of
11
that material is given to them.
12
13
Yes, but I'm looking for the entity that Zavia

Books is.
14
Is it an incorporated entity?
15
I think it's an incorporated entity.
16
Where --
17
Paperwork, yes.
18
Where is it incorporated?
19
I don't know.
20
Is it incorporated in New York?
21
It might be incorporated in New York.
22
Now, you said International Quranic Open
23
24
I'm not sure.
University is under Zavia Books?

A
No.

Hussein Adams
3/11/2014
Page 97
Then I misunderstood.
2
3
What is International -A
International Quranic Open University is a
university that we are still trying to make
official to the point where we can confer degrees.
And currently and what we've been doing,
we've been issuing just sort of certifications
in -- you know, during our summer programs with
men and ladies.
And that's very broad, you know.
10
We have religious classes, we have secular
11
subjects, we have Sufi classes; and that all falls
12
under IQOU.
13
Is IQOU an entity?
14
Yes.
15
Is it incorporated?
16
It should be incorporated.
17
Where?
18
In either New York State or Delaware, if I'm not
19
20
mistaken.
Q
21
And you seem a little uncertain about the answer,

but who should I ask about that?
22
About the incorporation?
23
Yes.
24
Mrs. Clark.

Hussein Adams
3/11/2014
Page 98
Does IQOU have a board of directors or trustees?
No, it doesn't.
Does it have bylaws?
No.
What about Zavia Books, does it have a board of
directors or trustees?
No, it doesn't.
Who's in charge of the operations of Zavia Books?
No one is in charge.
10
I mean, it's over -- our
sheikh oversees Zavia Books.
11
Sheikh Gilani?
12
Sheikh Gilani.
13
How does he accomplish his oversight from
14
Pakistan?
15
His oversight meaning what?
16
When you say he oversees it.
17
Yeah, he oversees it.
18
How does he accomplish that oversight?
19
He oversees it.
20
We just recently printed, which I think we
21
gave you a copy as well, the latest EGM journal,
22
which is Holy Quron methodology that he
23
established.
And pamphlets, magazines, brochures
24
are printed.
And that's how it was done.

Hussein Adams
3/11/2014
Page 99
I actually bought a book from Zavia one time.
Okay.
And it came in a very professionally -- very
professional hard --
Wrapping.
-- cover.
And how is that done?
8
9
You have facilities
in Islamberg?
A
There's a -- there's a Zavia Books web site that
10
you can purchase -- these books can be purchased
11
on.
12
How are these books produced?
13
How are they produced?
14
Yeah.
15
Do you contract for the production, or do
16
17
you have the facilities on site?

A
We have a small printing press that prints 75
18
pages.
19
that's printed in Lahore because it's cheaper, but
20
we're trying to -- we're trying to get
21
better-quality printing.
22
very good quality books.
23
24
Anything larger that we want to print,
But they've produced
Who makes the decision what books to print and

publish?

Hussein Adams
3/11/2014
Page 100
Well, anybody doesn't just print.
That would be
with the trustees and Sheikh Gilani.
So you're part of that decision-making process?
Yes.
So when you're talking about the trustees, you're
talking about the trustees of TMOA?
TMOA.
What other entities are associated with TMOA?
What other entities?
10
Well, who does your videos?
11
Whoever is available.
12
Are they published under the umbrella of Zavia
13
14
There are no other entities.
Books?
A
Yes.
15
MS. AMATUL-WADUD:
16
Attorney Carroll,
can we take a break for a minute?
17
MR. CARROLL:
18
Absolutely.
19
Absolutely.
Any time.
We'll go off the record.
20
* * *
21
(A lunch recess was taken.)
22
* * *
23
BY MR. CARROLL:
24
Let's go back on the record.

Hussein Adams
3/11/2014
Page 101
We were talking about organizations
affiliated with Muslims of America and The Muslims
of America -- sorry, Muslims of the Americas,
Inc., and The Muslims of America, Inc., and we
were talking about Zavia Books and IQOU.
Is The Islamic Post an organization
affiliated with TMOA?
Yes.
And it was affiliated with MOA before?
10
Yes.
11
What is the nature of the organization or the
12
entity?
13
It's our publication.
14
What's the nature of the entity?
15
Is that a corporation?
16
Yes.
17
Do you know where that's incorporated?
18
Maybe in New York State.
19
Could it be South Carolina?
20
South Carolina.
21
Are there any other organizations affiliated with
22
23
24
South Carolina, yes.
Muslims of America?
A
Not that I know of.
Not that I can recall, unless
you refresh my memory.

Hussein Adams
3/11/2014
Page 102
Are you familiar with an organization called

Soldiers of Allah?
No.
Have you ever heard of it before?
Yes.
How did you hear of it?
How did I hear about it?
Yes.
I heard about it -- I think I heard about it
10
online.
11
Are you aware that is --
12
I did not know -- I did not know it was an
13
organization.
14
I don't know if it is or not, but --
15
Right.
16
-- maybe now is a good time to -- to ask this.
17
I'm going to show you just a few, really,
18
seconds of a video.
19
have the source saying the Christian Action
20
Network on it, but -- oh, dear.
21
22
23
And the original video didn't
* * *
(Pause for review of video.)
* * *
24

Hussein Adams
3/11/2014
Page 103
BY MR. CARROLL:
Do you recognize who's speaking?
Yes.
Who is it?
Sheikh Gilani.
And do you hear him just say he was announcing an
7
8
international organization, Soldiers of Allah?

A
9
10
If that's what -- it sounded like what he said,

right.
11
I recognize the sound was not the finest.

Are you aware -- does that refresh your
12
recollection about an international organization
13
known as Soldiers of Allah?
14
No, it doesn't.
15
Were you aware before today that Sheikh Gilani
16
announced the formation of an international
17
organization called Soldiers of Allah?
18
I saw on the video that CAN sent to us, yes.
19
The same video you just --
20
Correct.
21
-- saw a portion of?
22
Correct.
23
And you also heard Sheikh Gilani refer to training
24
under -- in partner under the auspices of MOA;

Hussein Adams
3/11/2014
Page 104
right?
No, I don't -- I didn't hear that.
Are you aware of any military-type training done
at Islamberg?
No, none whatsoever.
But you heard Mr. Abdul-Haqq talk about some
training of the ladies that were shown and
depicted in a video on Ryan Morrow's video; right?
Mr. Abdul-Haqq, yes.
10
But that was before your time?
11
Yes, it was.
12
You're not aware of any since --
13
No.
14
-- you had become the deputy director?
15
No.
16
Now, you talked earlier about the investigation
17
that was begun because of -- well, it was
18
discovered as a result of -- bad question.
19
We talked earlier about an investigation
20
that was done after it was discovered that there
21
were forged signatures on an amendment to the
22
Articles of Incorporation of Ikhwanul Muslimun to
23
rename it as Muslims of the Americas, Inc.?
24
Right.

Hussein Adams
3/11/2014
Page 105
Right.
How did you discover that the -- the
3
4
signatures on the amendment were forged?

A
5
6
Well, first off, it's not -- simply not his

signature.
Now, are you saying to me --
7
8
That's the first part.
How do you know that was not his signature?

A
Well, those who know Sheikh Gilani's signature

knows his signature, number 1.
10
Number 2, we confirmed it by sending a copy
11
of the document to him, in which he looked at and
12
confirmed with us that that was not his signature.
13
Number 3, the individual that -- whose
14
name, who is still alive, Muhammad Hasib
15
Abdul-Haqq, when he was confronted and approached
16
about this, that's when we continued.
17
18
Were you the person that confronted

Mr. Abdul-Haqq?
19
Yes.
20
Tell me how that conversation went.
21
Initially, there was denial, and followed by an
22
investigation basically going into the paperwork
23
of the community and --
24
You know, I mean, initially, like I said,

Hussein Adams
3/11/2014
Page 106
1
2
there was denial.

Q
Now, I'm big on chronology.
I like to know how
things happened and in what order.
I located a copy of the Certificate of
Amendment of the corporation printed out in my
file over the lunch break.
interesting things I see about it -- I'm going to
show it to you.
previously been identified.
10
And one of the
This is the same document that's
MR. CARROLL:
Let's mark this as
11
Deposition Exhibit 5.
12
* * *
13
(Deposition Exhibit 5 herein was
14
officially marked for identification.)
15
* * *
16
BY MR. CARROLL:
17
Now, Mr. Adams, on the second page, you may note
18
that there is a -- a certificate.
The original of
19
this document was -- this was Exhibit A to the
20
petition as filed in the Delaware county -- with
21
the Delaware county clerk.
22
showing that -- that a certified copy was made of
23
this on October 4th, 2011, from the records of
24
Kings County, New York.
There's a certificate

Hussein Adams
3/11/2014
Page 107
Do you see that?
Yes, I do.
Does that refresh your recollection at all as to
when this all began?
No.
I assume that it had to have begun before
October 4th, 2011, that you began searching for
the record.
Searching for the --
10
The record.
11
Yeah.
12
I mean, you indicated earlier you were trying to
13
find the paperwork to confirm the existence of the
14
corporation, and somebody went searching for the
15
records.
16
chronology here.
17
dates are difficult, and it's sometimes helpful to
18
have documents that have dates on them.
19
And I'm just trying to fill in a

And I realize that sometimes
So I assume that search must have begun
20
before October 4th, 2011.
21
Possibly, yes.
22
You just don't recall one way or the other?
23
No.
24
I've got to say, I kind of admired the

Hussein Adams
3/11/2014
Page 108
researchability and ingenuity of some of the
finest documents in Kings County, all things
considered.
hard work.
I think it was -- had to be a lot of
Now, you also indicated you don't recall
any precipitating event that caused this
investigation to begin; is that correct?
I didn't say that.
Oh, okay.
10
Do you recall a precipitating event that
11
12
caused this investigation to begin?

A
I stated that from the effects of Jamil Haqq and
13
the effects of -- I also stated that we wanted to
14
get our paperwork in order.
15
land taxes were too high.
16
acquire -- you know, of course, obviously we
17
needed paperwork to do that.
18
obtain that paperwork, we found out it didn't
19
exist.
20
You understand?
Our
And we wanted to
And in trying to
Are there any differences between at this point
21
what it takes to be a TMOA member versus an MOA
22
member?
23
24
It's one in the same organization.
TMOA was just
established under a new entity, a clean, new

Hussein Adams
3/11/2014
Page 109
organization that had no attachments and had no --
didn't have any trail.
Have you ever fired a weapon or weapons in Holy

Islamberg?
Holy -- no.
What about in Islamberg?
No.
Holy Islamberg is South Carolina?
Holy Islamville.
10
Oh, I'm sorry.
11
No, I haven't.
12
Is there a shooting range in Islamberg?
13
No.
14
Is there a graveyard in --
15
There's a graveyard.
16
When was the graveyard established?
17
I couldn't tell you.
18
It pre-existed your coming?
19
Yes, it definitely did.
20
And I have some understanding that there was a --
21
successful work on y'all part to get approval from
22
the state with respect to --
23
Yes.
24
-- that graveyard after some disputatious period;

Hussein Adams
3/11/2014
Page 110
is that right?
Correct.
Has there ever been any explosive material
detonated inside Islamberg?
Absolutely not.
Are there any weapons stored or located inside
Islamberg?
Absolutely not.
Is there any ammunition located inside Islamberg?
10
Absolutely not.
11
And if there is, you're referring to
12
individuals' personal firearms.
13
So there may be, but they would be individuals?
14
Correct.
15
16
I thought you said stored.

Q
Have any members of TMOA -- TMOA received any
17
firearms training under the auspices of MOA or
18
TMOA at any location inside the United States?
19
No.
20
Who controls --
21
Not that I know of, I'll say.
You mentioned the Islamic Post.
And I
22
assume the Islamic Post Online is the same
23
organization as the printed Islamic Post; is that
24
correct?

Hussein Adams
3/11/2014
Page 111
Yes.
Who controls the content of The Islamic Post?
There's no one person that controls the content.
That's correct.
There's a team that's been formulated.
Who is the team?
There's quite a large team.
It's at least 25
individuals.
Is there a chief editor?
Khadija Smith is -- oversees.
10
Now, Sheikh Gilani has written articles appearing
11
in the Islamic Post Online; right?
12
Yes.
13
At least he has a By Line.
14
I understand that sometimes folks like that
15
have ghostwriters, but, to your knowledge, has the
16
Islamic Post Online ever published an article by
17
Sheikh Gilani that was erroneously attributed to
18
him?
19
Has the Islamic Post published?
20
Yes.
21
No.
22
And Sheikh Gilani's never denied he was the author
23
of an article appearing under his by line in the
24
Islamic Post?

Hussein Adams
3/11/2014
Page 112
To your knowledge, is there anyone who has worked
or is still working for the Islamic Post Online
who's deceitful, dishonest, or untrustworthy in
any way?
No.
So if you saw an article on the Islamic Post
Online under Sheikh Gilani's By Line, you would
have confidence that Sheikh Gilani was either the
10
author or he had approved it as authored?
11
Correct.
12
What is the process for Sheikh Gilani submitting
13
printed or online articles to the Islamic Post?
14
The process?
15
Yes.
16
The article is submitted, it's proofed, it's
17
edited, it's printed.
18
Submitted to whom?
19
To the Islamic Post team.
20
Is it sent to all 25 members, or is it sent to the
21
22
23
24
chief editor?
A
Yeah, the chief editor receives it.

There's different departments:
Layout
department, editing department, magazine

Hussein Adams
3/11/2014
Page 113
1
2
department.
Q
Now, are you familiar with an article,
January 23rd, 2013, "Sufi Leader Al Sheikh Gilani:
America Beware of Ikhwanul Muslimun"?
It sounds -- it sounds like it exists.
And I'm happy to show you.
Here's -- here's a
copy.
you to be comfortable that I'm -- I'm correctly
reading it -- from it to you, if you wish.
10
There's no need to mark it.
I just want
The article begins saying that "Ikhwanul
11
Muslimun is the deadliest onwing of the Wahhabis."
12
The very first line, do you see that?
13
Yes.
14
You agree with that; right?
15
Yes.
16
In the article, and I can't point you to exactly
17
where, it states that "TMOA has gotten rid of
18
Wahhabi Ikhwanul Muslimun in America."
19
How has -- if you agree with that
20
statement, how has TMOA gotten rid of Ikhwanul
21
Muslimun in America?
22
Well, we started with Jamil Haqq.
23
the leader.
24
administrator.
We started with
We started with the chief

And from there, anything

Hussein Adams
3/11/2014
Page 114
associated or attached to him or that entity was
dissolved, was destroyed.
Are you aware of any Ikhwanul Muslimun anywhere
else outside the Gilani followers Sufi
organization?
No.
Ikhwanul Muslimun are actually Sunni, aren't they?
Ikhwanul Muslimun -- I mean, to my knowledge,
there's a number of different people that carry
10
that name.
11
But they're essentially Sunni as opposed to Sufi?
12
Which Ikhwanul Muslimun?
13
Previously, this one
here that we're referring to?
14
Well, whatever ones --
15
I don't know what they were.
I mean, they -- they
16
were infiltrated by the Wahhabis and influenced by
17
the Wahhabis.
18
In the article, it refers to Jamil Haqq, we've
19
talked about before, forming a hit team that I
20
understood from Mr. Abdul-Haqq yesterday means
21
people who kill people.
22
Do you have any information about this hit
23
24
team that's referred to -A
No, I don't.

Hussein Adams
3/11/2014
Page 115
-- in the article?
Have you heard anything?
No.
I mean, I just wondered whether you heard they
succeeded in killing anybody?
That's before my time.
The article states that "Muslim villages are being
attacked by automatic weapons, and no one is
arrested."
10
11
Which Muslim villages have been attacked -A
South Carolina, Virginia, New York, Texas.
12
have been many.
13
litigation right now.
There
That's why we're in this
14
When was New York attacked with automatic weapons?
15
I can't give you a date, but there have been
16
attacks before my time.
17
Before your time.
So before -- before 2000?
18
There have been attacks, yes.
19
When was Texas attacked with automatic weapons?
20
Four days ago.
21
How do you know they were automatic weapons?
22
I really don't know if they were automatic weapons
23
or not, but the vehicle that drove by shot rounds
24
out of their vehicle.

Hussein Adams
3/11/2014
Page 116
Do you have an understanding what an automatic
weapon is as compared to semiautomatic or
otherwise?
Yeah, I think I have an understanding.
Semiautomatic -- would you like to explain it to
7
8
me?
Q
What's the difference between an automatic weapon

and a weapon that's not an automatic weapon?
10
I don't know too much about guns.
11
When was South Carolina attacked with --
12
South Carolina was just recently attacked as well.
13
Last -- this past summer.
14
With automatic weapons?
15
With weapons.
16
The weapon that was found at the
17
individual's home was a handgun, if I'm not
18
mistaken.
19
20
And who else did you say?
New York, Texas, South
Carolina?
21
Yeah.
22
Who else was attacked with an automatic weapon?
23
Virginia was attacked as well.
24
Where?

Hussein Adams
3/11/2014
Page 117
Red House.
Was attacked with automatic weapons?
Was attacked.
4
5
Over 15 bullet holes were riddled
in our sign.
Q
Now, Red House -- let's talk about the Texas

attack that was four days ago.
7
8
Red House, Virginia.
What do you know about that attack?

A
A vehicle drove by and let off rounds towards our

community.
10
It was reported to the police and it's
under investigation.
11
Did they shoot up a sign, or did --
12
They just shot.
13
And that falls on the heels of the public release
14
of the FBI report identifying the Sweeny, Texas,
15
compound as a terrorist compound?
16
17
18
The FBI never identified the Sweeny, Texas,

community as a terrorist compound.
Are you aware that a recently released FBI report
19
states that based upon information uncovered by
20
the Albany division, MOA members have participated
21
in 10 murders, one disappearance, three fire
22
bombings, one attempted fire bombing, and two
23
explosive bombings with one attempted bombing?
24
That's incorrect, invalid.

Hussein Adams
3/11/2014
Page 118
Are you aware that the FBI report states that?
I'm aware --
When I asked the FBI, they stated they --
Which document is this?
Well, I'm asking if you're aware that the FBI --
Yes.
It doesn't make it
official.
Are you aware that MOA and TMOA has never
been on the terrorist lists and have never been
10
11
It's in the newspaper.
classified as a terrorist organization?

Q
Now, let's talk about the incorporation of TMOA.
12
Was --
13
Who approved the incorporation papers for
14
the incorporation of TMOA?
15
The trustees.
16
And that would be you and Ms. Smith?
17
Correct.
18
Is there anybody else?
19
Our board.
20
Trustees and our board, the names that
I gave you earlier.
21
The national board?
22
Yes.
23
That would be yourself, Khadija Smith, Khadija
24
Salaam, and Ahmad Abdul Mumin; is that correct?

Hussein Adams
3/11/2014
Page 119
Yes, it is.
That's four people?
I mentioned another name.
Spell that.
K-H-A-L-I-Q.
So those five people?
It should be six.
Who are we missing?
Tahara Khaliq.
Tahara Khaliq, Mumin, Salaam, Smith, and
10
Adams.
11
Rashid.
12
Muhammad Rashid Abdul-Haqq.
13
Muhammad Rashid Abdul-Haqq.
And that's a different person --
14
Yes.
15
-- from the person we talked to yesterday?
16
Yes.
17
Now, in your -- in your petition, you recite and
18
Ms. Smith recites history going back 32 years to
19
the formation of MOA.
20
I don't know how old Ms. Smith is, but I'm
21
pretty sure that she's nowhere near my age, but
22
she'd have to be to actually remember that.
23
24
So my question to you is:
What is the
source, your source, for the information about the

Hussein Adams
3/11/2014
Page 120
32 years of history before you came to Hancock,
New York?
That's just a general -- that's the existence --
the time period the organization has been
existing.
I understand.
I'm asking for your source for the
information or -- maybe that's not fair to you.
You probably didn't draft this, did you?
Correct.
10
You did sign it, but you didn't draft it?
11
That's right.
12
Who did draft it?
13
Whichever name is on there.
14
Well, your name is on there.
15
Is that Ms. Clark?
Ms. Smith's name is
on there.
16
Okay.
We signed it.
17
Now, are you aware of anyone besides Christian
18
Action Network, Martin Mawyer, and Patti Pierucci
19
calling your communities and the MOA a terrorist
20
organization?
21
Sure.
22
Who else?
23
The Clarion Project.
24
Anybody else?

Hussein Adams
3/11/2014
Page 121
I'm sure there are many.
I wouldn't know off the
top of my head.
Yet, you didn't sue them?
Right.
Why didn't you?
Why didn't we sue Clarion Project?
One or the others.
Well, I think -- I think all that information is
in all the information that you've received
10
already.
11
Why didn't you sue Paul Williams?
12
There are many people we can sue.
Don't get it
13
wrong, there are many people we can sue, but
14
Christian Action Network have gone out of their
15
way to spread hate.
16
campaign.
17
And it's an ongoing hate
We're being attacked.
We've been attacked
18
and we're being attacked.
Our community is
19
constantly threatened, constantly looking over
20
their shoulder, wondering what individual is going
21
to take the law into their own hands after reading
22
something that's published on a web site, after
23
receiving a documentation or information that this
24
organization is a terrorist organization; that

Hussein Adams
3/11/2014
Page 122
within the United States of America, there exist
terrorist compounds and we should do something
about it.
here.
5
6
Now, you think about it.

Q
7
8
And they live here and they reside
Christian Action Network was not the first to

identify your organization -- MOA, I should say --
Christian Action Network printed a book, "Twilight

in America," a false, false book that's built up
10
and filled with hate, with lies, and they tried
11
their level best by utilizing an individual, an
12
informant, whom tried his level best to infiltrate
13
our community.
14
15
The informant you're talking about worked for the

New York Police Department?
16
New York Police Department, correct.
17
He didn't work for Christian Action Network, did
18
he?
19
I don't know who else he worked for.
20
You don't have any information that you believe he
21
worked for Christian Action Network, do you?
22
No, I don't.
23
Now, you've indicated many people have claimed
24
that MOA was a terrorist organization besides

Hussein Adams
3/11/2014
Page 123
1
2
Christian Action Network; correct?

A
3
4
I didn't indicate that -- that claimed was a

terrorist -- yes, spread Islamaphobia.
Did you --
Do you have any information that would lead
you to believe that Christian Action Network,
Martin Mawyer, Patti Pierucci did not have a
reasonable basis for making the statements that
they made in their book?
10
We've submitted that information.
11
No, I'm sorry.
12
You need to answer the question.
Do you have any information that they
13
lacked a reasonable basis to believe that -- that
14
the information they printed in the book was true?
15
16
No.
Official documented information, if that's
17
what you're referring to, no.
18
All right.
19
It's going to be okay.
20
I had a question at the top of my head and it kind
21
The -It will be all right.
of flew out.
22
I fully understand.
23
You signed answers to interrogatories stating an
24
Trust me.
amount that you believed were appropriate damages.

Hussein Adams
3/11/2014
Page 124
Correct.
Compensatory damages of $18 million.
Correct.
Do you have any - the legal word is pecuniary -
out-of-pocket expense damages that you can
identify out of that?
No.
This $18 million is all damage to reputation?
Absolutely, if not more.
10
Understand one thing, when individuals
11
migrate, take up and leave your community, never
12
to be seen and heard again because of acts of
13
terrorism that have been committed with Islamberg
14
being the target, Muslims of the Americas, TMOA,
15
being the target, that's a lot of damages because
16
you are affecting people's lives forever.
17
You're not accusing Christian Action Network,
18
Martin Mawyer, or Patti Pierucci of being directly
19
responsible for --
20
Sure, they are.
21
-- any acts?
22
Why not?
23
You're not aware of Christian Action Network,
24
They printed "Twilight in America."
Martin Mawyer, or Patti Pierucci instructing

Hussein Adams
3/11/2014
Page 125
1
2
anybody to go attack your villages?

A
I don't have any, no.
I don't have -- I don't
have any information that they instructed any
individuals to go and attack our villages.
You don't have any information that they approved

any individuals attacking your villages, do you?
It was on Christian Action Network's web site.
That they approved it?
That stating this community -- this compound in
10
Red House, Virginia, before the attacks took
11
place, giving the address of the community,
12
stating -- giving false information about the
13
community.
14
was, the community was attacked.
15
What does that add up to?
16
17
Two, three days later, whatever it
What does that
tell us?
Q
18
There are no words of approval or suggestion that

anybody attack your village; isn't that true?
19
From Christian Action Network?
20
That's right.
21
No.
22
No, that's not true?
23
No, we don't.
24
Was there a vote in the organization to authorize

Hussein Adams
3/11/2014
Page 126
1
2
the filing of this lawsuit?

A
Was there a vote within the organization?
That was discussed amongst the national
council and that decision was taken along with
Sheikh Gilani.
Were there minutes of the organization meeting

reflecting that vote?
No.
Who was present for that vote?
10
The entire council.
11
When did you first become aware of Martin Mawyer?
12
I can't remember.
Possibly it was through an
13
article that he printed about our community.
14
Don't ask me which article because there have been
15
so many.
16
Did you ever invite Martin Mawyer to Islamberg?
17
Did I invite someone that is printing negativity
18
19
about our community to Islamberg?

Q
No.
Well, you believe that -- or at least you
20
testified that what Christian Action Network,
21
Martin Mawyer, and Patti Pierucci believe is going
22
on in Islamberg is not; right?
23
24
Correct.
Not believe.
It's a fact.
It's not.

Hussein Adams
3/11/2014
Page 127
Did you ever make any outreach to Martin Mawyer,
Patti Pierucci, or Christian Action Network to
educate them --
Yes.
We've sent videos.
documentary videos, newspapers.
When did you do that?
I can't give you a date.
8
9
We've sent, you know,

Yes, we have.
This was -- this must
have been in the early -- early on.

Q
10
Do you have any records that you made that

outreach?
11
There could be records there.
12
If you sent videos and newspapers --
13
I mean, we kept the receipt?
14
Well, was there a cover letter?
15
I don't know.
16
Who did it?
17
Who did what, sent the information?
18
Who did the sending?
19
Most likely, it was Muhammad Hasib Abdul-Haqq.
20
Did he send copies of any cover letters to you or
21
I'm not sure.
I really don't know.
anyone else in doing it?
22
No.
23
And do you acknowledge that the United States
24
I didn't see anything.
government has identified MOA as being

Hussein Adams
3/11/2014
Page 128
Jamaat ul-Fuqra?
No.
You don't concede that?
No.
MR. CARROLL:
I need just a moment,
but I believe I am about done just in time
for your requested afternoon break.
MS. AMATUL-WADUD:
I'll do a little
redirect of him.
10
BY MR. CARROLL:
11
12
How many members have you lost as a result of

attacks on your villages?
13
I can't give you a count, but we've lost a lot.
14
Can we bracket a number?
15
Well, when I say "lost" in response to your
16
question, when you have an individual that does
17
not want to associate with your community anymore,
18
but still wants to practice Islam or still wants
19
to be a Muslim, they've disassociated themselves
20
with the organization, but they've continued on
21
and still practicing their religion.
22
technically, we've lost, but they still might have
23
family members.
24
members of the community members.
So
They still might have family

Hussein Adams
3/11/2014
Page 129
Now, when you say lost, TMOA has three official

villages; correct?
Correct.
How many people have been lost from the three
5
6
official villages?
A
Well, like I said, 15, 20 years ago, the
population on Islamberg was more than triple.
We've had individuals that have lost their jobs.
We've had individuals that have been, you know,
10
suspended from work or lost their jobs or have
11
been just so terrified to continue on that they've
12
left.
13
14
How many individuals have you lost in those three

official villages since --
15
I told you --
16
-- the publication of the book in 2012?
17
Publication of "Twilight in America"?
18
I mean, to give you a number would be
19
inaccurate.
20
Abdul Aziz was tormented, was abused.
21
understand?
22
point where a young girl was forced to have a
23
child.
24
The -- the wife that married Ali

You
And this type of -- of -- to the
He disappeared.
Are you talking about something Ali Aziz did?

Hussein Adams
3/11/2014
Page 130
Ali Aziz, who was hired by the NYPD, yes.
Christian Action Network isn't responsible for Ali
3
4
Aziz, is it?
A
5
6
And Christian Action Network published Ali Abdul

Aziz -- that was your main source; right?
Ali Aziz's time on Islamberg was before the
publication of "Twilight in America"; isn't that
true?
Correct.
10
So none of what you're talking about happened
11
after the publication of "Twilight in America";
12
right?
13
I just gave you one example.
14
The one example didn't happen before the
15
publication of "Twilight in America"; isn't that
16
right?
17
18
19
The marriage and the -- the -- yes, that led up to

the publication of "Twilight in America."
My question to you, though, is how many people
20
have you lost since the publication of "Twilight
21
in America"?
22
Again, I can't give you a number how many people
23
we lost because many individuals -- if I say 25,
24
if I say 50, if I say a hundred, they're gone.

Hussein Adams
3/11/2014
Page 131
How many --
We don't have a count.
3
4
We don't have a number.
If I have a number, I'll give you the number.

Q
I'm talking about your three official villages.
Is it more than two?
Of course.
Is it less than 10?
Is it less?
From your three official villages?
10
Yes.
11
Is it less than 20?
12
I would say at least 15 to 20.
13
14
No, it's more than 10.
And, again, that's
a number.
Q
15
Have you understood the questions I've asked you

here today?
16
Yes, I did.
17
I've been fair with you, haven't I?
18
Sure.
19
MR. CARROLL:
20
Do you have questions?
21
MS. AMATUL-WADUD:
22
Yes, just a couple
of redirect questions.
23
24
Thank you.
EXAMINATION
BY MS. AMATUL-WADUD:

Hussein Adams
3/11/2014
Page 132
You testified that a Yasmeen Begum serves as

secretary for TMOA.
Did you testify to that?
As secretary, yes.
And do you mean that she's an officer secretary or
an assistant, like clerical secretary?
Clerical secretary.
Okay.
records for TMOA?
10
11
So who is the officer who's the keeper of

Officers, if it's more than
one.
A
Yasmeen Abdul -- Yasmeen is the clerical -- she
12
keeps the -- I was asked earlier who keeps the
13
minutes for meetings.
14
15
Okay.
And who's the officer that she reports to?
Who's the official keeper?
16
Khadija Salaam.
17
Regarding the incorporation of IQOU, did you
18
submit answers to interrogatories that addressed
19
that question?
20
Yes.
21
Okay.
22
And those answers were that it was
incorporated in Delaware?
23
Yes.
24
Okay.
You were questioned about whether or not -

Hussein Adams
3/11/2014
Page 133
and I'm going to kind of paraphrase this
question - that the three defendants -- if you had
proof that the three defendants approved,
sanctioned, or directed others to harm TMOA.
Do you remember answering that question?
Yes.
Okay.
You're aware, also, that the plaintiffs,
being your organization, has an outstanding motion
to compel discovery against defendants; is that
10
right?
11
Yes.
12
And do you believe that you've received enough
13
information to be able to answer that question
14
honestly from them in discovery yet?
15
Yes.
16
Do you believe that you've received enough
17
information from the defendants in order to know
18
the answer to that question?
19
20
21
22
23
No.
MR. CARROLL:
Objection.
Asked and
answered.
MS. AMATUL-WADUD:
Okay.
It's
reserved.
24

Hussein Adams
3/11/2014
Page 134
Have you received all of the information from the
defendants in order to answer the question as to
whether they have directly advocated or sanctioned
harming the villages --
No.
-- of TMOA?
And you also are aware that the defendants
have the right under the process of discovery to
10
inspect the properties of TMOA; isn't that right?
11
Correct.
12
And you have not received a request from the
13
defendants to come and inspect any of the
14
properties?
15
MR. CARROLL:
Objection.
17
MR. CARROLL:
Objection.
18
MS. AMATUL-WADUD:
16
19
No.
Okay.
He has the
right to answer.
20
21
You have not received a request --
22
No, we haven't.
23
-- in discovery?
24
Leading.
MS. AMATUL-WADUD:
Thank you.

Hussein Adams
3/11/2014
Page 135
No further questions.
MR. CARROLL:
3
4
Okay.
You want to
advise him on his rights?

MS. AMATUL-WADUD:
You're going to
review any transcript and sign, not waive
your right; is that right?
THE WITNESS:
MS. AMATUL-WADUD:
Okay.
And also, for the
record, this deposition was given in
10
accordance with the two orders, the
11
confidentiality order and the order of the
12
court, as to how discovery will be treated
13
in this matter.
14
record.
15
16
17
18
19
20
21
And that's just on the
MR. CARROLL:
Off the record.
* * *
(Whereupon, it is duly noted the
witness' signature is reserved.
Thereafter, the proceedings
concluded at 1:55 p.m.)
* * *
22
23
24

Hussein Adams
3/11/2014
Page 136
I N D E X
TO TESTIMONY
WITNESS
EXAMINATION BY
HUSSEIN ADAMS
Mr. Carroll ..........
PAGE
4
Ms. Amatul-Wadud ..... 132
6
7
TO EXHIBITS (Attached)
MARKED FOR ID
Defendant's 4
DESCRIPTION
PAGE
Application filed with the
10
Supreme Court of the State of
11
New York, County of Delaware,
12
for dissolution of Muslims of
13
the Americas, Inc. ........
79
14
15
Defendant's 5
Certificate of Amendment... 106
16
17
18
INFORMATION/REQUESTS
19
Documents
20
(No requests)
Page
21
22
23
Marked Questions
24
(No marked questions)
Page/Line

Hussein Adams
3/11/2014
Page 137
CERTIFICATION
STATE OF NEW YORK
COUNTY OF
4
5
I, HUSSEIN ADAMS, have read the foregoing
record of my testimony taken at the time and place
noted in the heading hereof, and I do hereby
acknowledge it to be a true and correct transcript
of the same.
10
11
______________________________
12
HUSSEIN ADAMS
13
14
15
Sworn to, before me, this_____________ day
16
of__________________, 20___.
17
18
____________________________________________
19
Notary Public, State of New York.
20
Registration No.:___________________________.
21
Qualified in ________________________ County.
22
My commission expires ______________________.
23
24

Hussein Adams
3/11/2014
Page 138
1
2
CERTIFICATION
3
4
5
I, BRENDA J. O'CONNOR-MARELLO, a
Certified Shorthand Reporter and Notary Public in
and for the State of New York, do hereby certify
that the foregoing record taken by me at the time
and place noted in the heading hereof is a true and
10
accurate transcript of the same, to the best of my
11
knowledge and belief.
12
13
14
15
16
_________________________________
17
BRENDA J. O'CONNOR-MARELLO, CSR
18
License No.:
001088-1
19
20
21
22
23
24

CERTIFICATION
2
3
I, BRENDA J. O'CONNOR-MARELLO, a Certified
Shorthand Reporter and Notary Public in and for the
State of New York, do hereby certify that the
foregoing record taken by me at the time and place
noted in the heading hereof is a true and
acc~rate
10
transcript of the same 1 to the best of my knowledge
11
and belief.
12
13
14
15
16
17
18
19
20
21
22
23
J.
O'CONNOR-MARELLO, CSR
License No. :
001088-1

Adams Deposition

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Adams Deposition

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Case 3:13-cv-00169-TJM-DEP Document 58-2 Filed 03/26/14 Page 1 of 139

UNITED STATES DISTRICT COURT

MARTIN J. MAWYER, PATTI A. PIERUCCI and

Anderson Reporting Services, Inc. (614) 326-0177)

Case 3:13-cv-00169-TJM-DEP Document 58-2 Filed 03/26/14 Page 2 of 139

APPEARING FOR THE PLAINTIFF(S):

TAHIRAH AMATUL-WADUD, ESQ.

TAHIRAH H. CLARK, ESQ.

APPEARING FOR THE DEFENDANT(S):

CARROLL, UCKER & HEMMER, LLC

Cory Lange and Colton Ott - Videographers

Case 3:13-cv-00169-TJM-DEP Document 58-2 Filed 03/26/14 Page 3 of 139

IT IS HEREBY STIPULATED AND AGREED by and

between the attorneys for the respective parties

hereto, that filing, sealing, and certifications

are hereby waived;

IT IS FURTHER STIPULATED AND AGREED that all

objections, except as to the form of the question,

shall be reserved to the time of the trial;

IT IS FURTHER STIPULATED AND AGREED that the

within Deposition may be signed before any Notary

Public with the same force and effect as though

subscribed and sworn to before this Court.

Anderson Reporting Services, Inc. (614) 326-0177)

Case 3:13-cv-00169-TJM-DEP Document 58-2 Filed 03/26/14 Page 4 of 139

called as the witness, hereinbefore named, being

first duly cautioned and sworn or affirmed by

BRENDA J. O'CONNOR-MARELLO, a Certified Court

Reporter and Notary Public in and for the State of

New York, Qualified in Saratoga County, herein to

tell the truth, the whole truth, and nothing but

the truth, was examined and testified as follows:

What is your name and address, please?

Want me to spell it?

Or you have it -- you

have the correct spelling?

The same -- the same -- the first name is the same

spelling as the middle name of the president of

the United States?

I think we have it.

And Adams is pretty easy.

Do you have a middle name?

Anderson Reporting Services, Inc. (614) 326-0177)

Case 3:13-cv-00169-TJM-DEP Document 58-2 Filed 03/26/14 Page 5 of 139

And your address, please?

2732 Roods Creek Road, Hancock, New York.

And I understand you've given a deposition before

at some point in time?

So you know -- so you know it's necessary that

your responses be audible, and they should be yes

or no, not uh-uh and um-hum; okay?

And we'd appreciate it if you'd speak up,

especially if that thing goes on again, the air

having a little bit of trouble hearing you across

reporter catches every word, so please do speak up

and don't mind me if I ask you to speak up from

I notice your voice is very soft, and I'm

We want to make sure the court

You were here throughout Mr. Abdul-Haqq's

deposition yesterday, weren't you?

And as I asked him, and as I'm sure has been

explained to you, a deposition is for many

purposes, including us finding out what your

Anderson Reporting Services, Inc. (614) 326-0177)