My AFFIDAVIT for Bilbro vs. Gov. Nikki Hally, Pres. Barak Obama, et. al.

This affidavit it is part of the public record for the Federal Case: No. 3:16-cv-767

I am PAUL SUTLIFF,  I have become aware of the irreparable harm that could result from South Carolina continuing its receipt of those labeled refugees by the federal Office of Refugee Resettlement Program. In addition I have become aware of misinformation from the South Carolina Plan that will cause irreparable harm to all taxpayers in South Carolina.

I am the author of Civilization Jihad and the Myth of Moderate Islam ©2016 Tate Publishing and Stealth Jihad Phase 2: Infiltrate American Colleges ©2014. I have a BA in Religion and Philosophy from Roberts Wesleyan College and a Masters in Education from Nazareth College of Rochester. One of the honors I have received for this work is to have some of my articles posted on the Middle East Forum’s Campus Watch. My latest articles are currently posted on http://paulsutliff.blogspot.com. Some of my research has benefitted the FBI with information they did not previously have, inhibiting their ability to connect the dots.

This is an update to two previous affidavits (February 10, 2016 and May 20, 2016) considering recent events and the importance they have on this case. This affidavit also includes all the information from the two previous affidavits.

WHAT CAN NOT BE KNOWN AT PRESENT:
ARE BUDGET APPROPRIATIONS FOR RRP ACCURATE?

Due to a lack of ability to provide accuracy in projections for the rest of 2016 and I need more information to compare the State Budget, County Budgets and this State Plan as well as other crucial information to make an informed opinion on this matter. This also makes relevant that the State of South Carolina needs more information, projections and impact statements to make an informed decision regarding the budget appropriations to cover the cost of refugees. I believe there exists material facts in dispute that must be brought before a fact finder. There is just not enough information at present. It should be enough for due diligence to side on stopping the program until this can be investigated and the budget issues can be reviewed by a neutral receiver or legislative audit.

The South Carolina Plan states that the refugee receives $339 in Temporary Assistance for Needy Families (TANF) from the federal government. This does not include the cost of living arrangements. TANF funding is only available to refugees for the first eight months they are in the country. This is why Volunteer Agencies such as those who are defendants in this case immediately take refugees upon their initial arrival, to the Welfare office to apply for state financial assistance. The VolAgs benefit financially as the refugees are weaned off from federal funding and onto state funding.

On top of this South Carolina has claimed they receive adequate funding from the federal government. A simple search using the word “refugee” on USAspending.com reveals that that federal refugee funding in South Carolina has jumped tremendously since President Obama took over.

This year federal funding has dropped so much that from the $ 112,030 the federal government demanded the return of $28,355 resulting in the figure of $83,695. Federal funding may have dropped as small groups of individuals began to raise awareness of the financial cost to tax payers in South Carolina that each refugee brings.

This is not the first time the federal government demanded South Carolina return some funding for refugees. In 2009 they demanded South Carolina return $87,678, stating it was due to a change in the formula for funding refugees.

According to Governing.com, South Carolina spent $9,514 per child on public education. This figure rises dramatically when adding the needs of children who do not speak English and those who may not have had an opportunity for education in their home country. Federal funding does not exist per school district for educating refugees placing a higher tax burden on those living in the area. Additional costs may be incurred if a child is determined to have special needs.

This could bring the costs of educating young refugee children to as high as $17,000 per child. This is an approximate figure given the cost of an educator to communicate with the children in their language and English. It also was arrived at with the possibility of the need to hire a translator for a community that does not have an educator that speaks the language of the refugees and the cost of translations of materials being sent to the parent which are required to be translated into their language.

Not having an accurate number of refugees to expect in South Carolina makes it impossible to determine the amount of cost to tax payers. Further difficulties arise when considering the large amount of possible needs of refugees from medical issues to educational issues. Federal funding may exist for medical issues, however, when they qualify for South Carolina financial assistance they pass the cost to state taxpayers.

WHAT CAN NOT BE KNOWN AT PRESENT:
ARE THOSE LABELED REFUGEES COMPLIANT WITH THE CLASSIFICATION OF REFUGEE AS STATED IN THE 1980 REFUGEE ACT?

President Obama set a goal of bringing 10,000 Syrian refugees to America by September 2016 on September 10, 2015. This goal was set by the President with the knowledge that many of those claiming to be Syrian were not Syrian and that the Refugee Act of 1980 explicitly forbids the immigration of those who have committed persecutory acts on others.

The term 'refugee' does not include any person who ordered, incited, assisted, or otherwise participated in the persecution of any person on account of race, religion, nationality, membership in a particular social group, or political opinion.

(PL 96-212. Sec. 212) The Refugee Resettlement Program started under President Jimmy Carter, through the passing of the Refugee Act of 1980 defined refugees as:

…any person who is outside any country of such person’s nationality or, in the case of
 a person having no nationality, is outside any country in which such person last habitually resided, and who is unable or unwilling to return to, and is unable or unwilling to avail himself or herself of the protection of, that country because of persecution or a well-founded fear of persecution on account of race, religion, nationality, membership in a particular social group, or political opinion. <Emphasis added>

 The 1980 definition of a refugee is a) any person who is outside of their home country and b) who is unable or unwilling to return, c) because of persecution or a well-founded fear of persecution.

Today those labeled as “refugees” are selected and defined not by the American government but by the United Nations. This brings into question whether those labeled as refugees do indeed meet the three criteria listed simply because the UN officially designates those who have lived in a Palestinian controlled zone in Israel all their lives as refugees. A 2007 UN magazine blurs the lines between refugee and migrant. These two terms have very different meaning however the UN magazine Refugee Editor Rupert Coville sees this as a discussion more than a legality. This is yet another reason the UN should not be allowed to select who becomes a refugee in the USA.

Given that the UN does not apply the same definition although they may state they do in print, evaluation of those designated as refugees through various vetting procedures is essential. This becomes especially difficult since it has become public knowledge that the Islamic State is producing fake Syrian passports in exchange for a few hundred dollars. In addition the fact that the Director of the CIA testified on June 15, 2016 before a Congressional hearing that “Islamic State militants are training and attempting to deploy operatives for further attacks on the West ...” should cause a deeper more intense vetting system to be created or lead to a moratorium prohibiting any persons from Syria from entering the US.

In November 2015 a terrorist attack on Paris was committed by at least a few persons who had claimed to be Syrians. One of them, Ahmad al-Mohammad had a Syrian passport that officials believed to be a forgery.

The attack in Paris took place a few weeks after FBI Director James Comey testified (October 22, 2015) before the House Oversight Committee, that there are no databases that can be used to vet persons claiming to be from Syria. Director Comey emphasized that there is no one who can verify these people are who they say they are.

Despite the testimony of top intelligence personnel President Obama increased the amount of persons “vetting/interviewing” persons who claim to be Syrian Refugees for the purpose of bringing them to the USA. The Center for Immigration Study reported that President Obama had placed a “‘temporary processing center’ opened in Amman, Jordan, this February [2016] to speed up the resettlement process from 18-24 months to just three.”

President Obama initiated a system to bring 10,000 refugees to America without proper vetting! From February to April 2016 they conducted 600 interviews a day with a total of over 30,000 interviews conducted for the purpose of streamlining a method to bring unvetted Syrian “refugees” to America. This issue is further complicated by the lack of understanding of whether Syrian Sunni Muslims truly meet the definition of refugee. Do they meet the three conditions?

1. Yes, these persons are outside of the country. 
2. Are Syrians unable or unwilling to return? This is up to the individual. 
3. If persons slated to come to America as “refugees” are Muslim. Are Syrian Muslims facing persecution or do they have a well-founded fear of persecution? The Islamic State is targeting and persecuting : 

       a. Religions other Muslim: mostly Christians and Jews
       b. Shi’ite Muslims
       c. Homosexuals
       d. Journalists
       e. Females – ISIS placed a poster in Mosul to bring out the women for sex jihad.8 f. Muslims against sharia -- This does NOT include those who are fleeing becoming soldiers of the Islamic State.

Those persons who are coming from areas threatened by or currently under control of the Islamic State have no reason to fear persecution IF they do not meet any of the 6 conditions listed above, the Islamic State would not persecute or cause fear of persecution.

Most of those slated to be received by America as “refugees” do not qualify as refugees under the 1980 definition, simply because they have no reason to fear persecution as they are Sunni Muslims and wish to live under Sharia. Sharia is the Arabic word for Islamic law. It is important to understand that in Islam there exists no separation of mosque and state. The local mosque is part of the political machine under Islam. Historically, wherever Muslims rule they force non-Muslims also to obey sharia.

Muslims who want sharia and flee serving the Islamic State are guilty of violating shariah [See Appendix A] under the law the wish upon others.

WHAT CAN BE KNOWN:
IRREPARABLE HARM TO SOUTH CAROLINIANS THROUGH MISINFORMATION

Citizens of South Carolina have been misinformed by the State of South Carolina’s statement on page 7 that “its goals and objectives will comply with those specified in the Refugee Act of 1980, as amended and pertinent official issuances of the Director of the Office of Refugee Resettlement.” Note that the South Carolina state plan does not define the term refugee and by implication infers that its definition comes from the Refugee Act of 1980. This is misinformation to South Carolinians in 2016. The very misapplication of the term refugee threatens to disturb the very purpose for which South Carolina has established an Office of Refugee Resettlement Program.

Misinforming the public of the definition of refugee for those selected to enter South Carolina under this definition will place residents of South Carolina in a position of irreparable harm on several levels. Persons who will be arriving with the label “Refugee” who are “Syrian” are selected not by the United States of America but by the United Nations, a governmental agency outside of the United States of America, that designates persons as refugees who have not left their country. This misinformation given to South Carolina residents will inhibit their ability to understand and prepare for those who are being granted this label.

IRREPARABLE HARM TO SOUTH CAROLINA RESIDENTS FINANCIALLY

The South Carolina State Plan utilizes a shell game of delivering important information which enables them to deliver a message replete in propaganda that would otherwise inform South Carolina residents of intentional increases in the use of their tax dollars to bring persons labeled refugees into the state.
On page 7 of the State Plan it defines the goals and objectives of the Plan to “to promote refugee economic self-sufficiency at the earliest possible time.” It then provides objectives clearly defining the usage of federal tax dollars:
     a. Provide cash, medical and any other emergency assistance needed by individuals eligible for Refugee Resettlement services in order for them to obtain adequate living conditions.

    b. Provide the necessary tools and opportunities for the elimination of obstacles standing in the way of refugees eligible for resettlement services while moving toward economic self-sufficiency and social self-reliance.

What is not stated in these objectives is a clear difficulty that exists currently in getting persons who receive forms of public assistance independent. Page 7 does outline the usage of federal tax dollars for:

• Refugee Cash Assistance (RCA)
• Temporary Assistance for Needy Families (TANF)
• Family Independence (FI)
• Refugee Medical Assistance (RMA)
• Refugee Social Services (RSS),

Volunteer Agencies (VolAgs) contract to provide services and are paid by the amount of refugees to whom they render services. VolAgs rush refugees to the State Welfare offices to increase the amount the agency is able to keep per refugee versus paying out to meet the needs of the refugees. This is done because the moment a refuge arrives in the state they immediately qualify to receive state tax payer financed public assistance. As refugees receive more state financial assistance and less federal assistance this is marked as progressing a refugee towards independence. This is stated on page 10 of the State Plan.

Public assistance almost immediately is provided to assist in the cost of housing these new residents to the state of South Carolina. It can be argued that they are cutting to the head of the line in need of assistance since when they arrive their situation is defined as destitute, since they come without previous arrangements for employment.

A further burden to South Carolina residents occurs as refugees qualify for Medicaid and the Refugee Medical Assistance (RMA). Instead of RMA picking up the majority of costs, it becomes employed to meet a bare minimum of costs when Medicaid does not cover a medical issue.

Education is compulsory in South Carolina as it is throughout the USA. This creates an additional burden on taxpayers. As stated previously, the cost of educating students from non-English speaking countries is higher than those refugees who do speak English since th non-English speakers are guaranteed instruction by a Teacher of English as a Second Language (TESOL). Dependent on the amount of refugees in a school district this could require additional teachers and staff to render services. This does not even take into account whether the students are functioning on grade level or need additional Special Education services. Assessments of educational needs versus abilities in a variety of areas such as an English Comprehension before placing students in appropriate educational settings require local tax dollars. The State Plan does not address these financial expenses.

School districts generally are the venue which private agencies rely on to provide adult education in reading and in English as a second language. This also places additional costs to local level and state level.

Omission of facts further complicate things as the State Plan is specifically addressed to those classified as Refugees. For this reason alone it is entirely inadequate. According to the US Department of State: Refugees are admitted to the U.S. as refugees and remain in that status for 12 months. They are, however, authorized and expected to work during this time. After 12 months, they are required to adjust their status to that of Permanent Resident Alien. They can apply for citizenship after having been resident in the United States for five years.

The South Carolina State Plan does not address who pays for those who after 12 months have had their status mandatorily adjusted to Lawful Permanent Resident (LPR). This cost is necessarily passed off to the South Carolina tax payer. After 5 years of living in the USA refugees who finish the naturalization process can become citizens with no requirement of employment made.

It is standard practice for those coordinating state programs of Refugee Resettlement to operate deceitfully by misinforming the public about the federal funds for refugees. They hold a press conference about a federal funding for refugees. They talk about a 5 year program. But at no time to do they tell the press that these funds are for 5 years’ worth of refugees and they payments are only for the first 8 months of their being in the USA. This has been verified by this author through FOIAs. In many cases the misinformation is much easier because they do not even inform the public that a state plan for refugees has been written.

Not stated is that federal funds such as TANF are only available to refugees for the eight months ONLY! This means that IF a refugee and his/her family have no employment after 8 months possibly due to language barriers, South Carolina taxpayers WILL pick up the bill.

Taken separately these costs may not seem much. However if South Carolina takes in a small percentage of the 30,000 President Obama set as an objective of which 10,000 Syrian refugees are to arrive by September the financial impact on tax payers could be catastrophic. This does not even go into the South Carolina budget difficulties which clearly outline issues with not having enough revenue to meet the needs of the government. Where will these funds come from if not from a tax increase on South Carolina residents? Which thus proves irreparable financial harm to residents of South Carolina.

IRREPARABLE HARM FROM NON-ASSIMILATION
South Carolina’s residents have been misled to believe that a purpose of the Refugee Resettlement Program is to assist refugees in the assimilation process. The South Carolina State Plan is missing any statement regarding adaptation and assimilation outside of language proficiency and employability. Part of this misinformation comes from past actions of the federal and state ORRP towards assisting refugees in their attainment of assimilation into their new country.

South Carolina residents need to know that the federal Office of Refugee Resettlement Program has removed any hope of asking persons in the program to assimilate. The last recorded usage of “assimilate/assimilation” by the Office of Refugee Resettlement Program according to their search engine was in 2006. The preferred term by ORRP today is “integration. The change in terminology is vast! “Assimilate” according to Merriam-Webster means “to adopt the ways of another culture: to fully become part of a different society, country, etc.” Whereas the definition of “Integrate” can mean either “to combine (two or more things) to form or create something” or “to make (a person or group) part of a larger group or organization.” No expectation or burden is placed on the refugee to adapt using the term integrate, the burden is placed on those around the refugee to adapt to meet their needs.

Integration and assimilation have been objected to by Islamic clerics. Considering that President Obama is not sending South Carolina any minority religions and is sending only Syrian refugees who are Sunni Muslims these clerics’ fatwas have special significance. Specifically, Fatwas (Islamic ordinance carrying an equal weight with Sharia) have been issued that order Muslims who are in non-Muslim lands (Dar al-Harb) to place their religious identity above national or ethnic identities. Sheikh Yusuf al-Qaradawi, an Islamic jurist, the founder of the European Council for Fatwa and Research (1997), which is based in London, wrote just such a fatwa (Qararat wa-Fatawa al-Majlis al-Urubbi lil-Ifta wa al-Buhuth [Decisions and religious edicts of the European Council for Fatwa and Research] (Cairo: Dar al-Tawj'i wa al-Nashr al-Islamiya, 2002), pp. 5-10.) In this there are only two duties directed toward a Muslim’s new country. The first is to call non-believers to Islam. The second is to champion the rights of Muslims.

How is this problematic?
Problem #1 – Culture clash through sexual misconduct and other crimes 

On the Eve of 2016 in Cologne, Germany the first occurrence of a European “Taharrush gamea”11 was recorded. A “Tahrrush gamea” is a gang rape/gang molestation of non-Muslim women by Muslim men. Reports vary on the amount of women who were raped or molested. The BBC 12 reported at least one woman was raped and indicated the problem was not happening in Cologne alone! It was happening Hamburg and elsewhere the only commonality was the influx of Muslim Middle Eastern or North African men being the perpetrators. As of January 27th 820 crimes were reported to have happened almost of which are charged against persons described as Middle Eastern or North African males.

The sexual molestation and rapes that occurred in Cologne are not exclusive to Germany. Islamic culture based on Sharia treats women as second class citizens. A charge of rape is generally unheard of since a woman’s testimony is not considered equal to that of a man in court. In Islamic countries this means a woman may not report a rape without 2 female witnesses or she must have 1 male witness (o24.7). False allegation charges are placed against those who do not have sufficient witnesses the penalties are severe.

Wilson Chowdhry, the Chairman of the British Pakistani Christian Association (BCPA) and a known human rights activists reported on January 20, 2016 of three Pakistani young women who were attacked in Pakistan. The women were refusing the advances of three Muslims men. They said No to sex before marriage. The response of one of their attackers was, “How dare you run away from us, Christian girls are only meant for one thing the pleasure of Muslim men.” This statement is reflective of Sharia concerning dhimmis (non-Muslims) living in an Islamic governed region (09.8). Stories of sexual assault and rape as noted previously in Islamic governments are unreportable crimes without the proper witnesses creating a culture of permissiveness. Bringing men from these cultures thus places females of various ages at risk of irreparable harm. As shown in Cologne, Germany it also places the men at risk who try to protect them.

Problem #2 - Bullying 
Additional issues exist within school environments where Muslims are inching their way towards 18% of the student body. Schools in Birmingham, England, there was a report of “Trojan Horse Schools” which gave cause for a national investigation in charges of prejudice for Islam and against local cultures which including segregating girls from boys and bullying. Islamic educators and administrators themselves were noted as bullying non-Muslims in the report to the House of Commons in July 2014.  This culture of bullying non-Muslims was taught by example to students. The example of Muslim adults bullying adults who were not Muslim is reason enough to have cause for concern for the safety of Mr. Bilbro’s daughter. Will she be safe if she attends a school filled with Syrian refugee children who expect others to conform to the example of sharia in their home? This is an important question because under sharia women are not expected to say no and complain because they do not have equal rights. Mr. Bilbro’s daughter should not have to suffer because the coming Syrian refugees refuse to adapt to the host culture of their new home.

Problem #3 – Culture clash through unreasonable work demands
In 2008, about 400 employees mostly Somalians who entered the USA as refugees walked off the job at JBS Swift Co. in dispute against not being granted time off to prayer at sundown during Ramadan. Of those 400, 250 were suspended and 120 were able to keep their jobs when they chose to go to back to work despite attempts to force the company to comply with their demands through hundreds of Muslims refusing to come in to work. In December 2015, at the very same company that had met many of the demands of their Muslim employees through bargaining that outlined how employees could take prayer breaks and in rooms designated for Muslim prayers when accommodation was possible, 150 Muslims were fired for walking off the job after the company refused to stop production so they could pray as a large group. These actions were attempts to force an employer who is not Muslim to comply with Sharia. The large Somalian Muslim “refugee” population in this area gave the perpetrators the belief they can force non-Muslims to comply with their beliefs. This would cause major issues with food safety, contamination endangerment, which would also cause undue hardship on their employer. Thus the potential for irreparable damage from enclaves of Muslims in a work place who will demand compliance with Sharia could lead to lost income including the creation of violations of food safety protocols as demonstrated by the example provided.

Further examples of the cultural differences of Islamic persons who express a belief that sharia can be found in 2007 when approximately 675 Muslim cab drivers refused to transport persons with alcohol or guide dogs. The issue with Muslim cab drivers refusing services to the blind because they have a guide dog has increased since 2007 especially in large cities as is shown by recent articles on this topic this past year ("Los Angeles Cabbies Could Lose Permits over Prejudice." Seattlepi.com. February 2, 2016. Accessed February 18, 2016. http://www.seattlepi.com/news/us/article/Los-Angeles-cabbies-could-lose-permits-over-6801600.php).

Non-assimilation or a refusal to adapt to American culture and the insistent belief that persons in America must accept sharia and comply with it, create dangerous situations in workplaces that can lead to irreparable harm. Blind persons with guide dogs being refused by Muslim cab drivers can place the blind and others who own service dogs such as veterans in places that could cause them irreparable harm. It should be noted that this vocation is a favorite of persons entering the American work environment as refugees. It enables them a sense of being self-employed in many cases.

Problem #4 – Islamic enclaves create fear in those who protect us
Islamic enclaves from migrants/refugees who have left several counties including Syria to have a better financial situation or otherwise and have ended up in various countries in Europe have resulted in areas that the police and other emergency services fear to tread. This fear of the Islamic community has extended to not informing the general population of a s eries of crimes because of fear of reprisal from the Islamic communities.

Note that these enclaves were not created by a large amount of Muslims moving into an area at the same time. These communities were created by Muslims moving in one by one until an area was designated as a sharia zone. There are currently several sharia zones aka NO-GO Zones throughout Europe. These have been documented almost daily in the European media.

This addresses another missing area in the State Plan. What happens when refugees move and create a haven safety by living close to each other? What happens when they become the majority in an area? What happens when non-Muslims want to simply pass through? Islamic communities are growing in America partially through the social engineering of organizations of the Muslim Brotherhood in North American. As stated previously the State Plan does not address what is an acceptable amount of persons to be taken in in any given area of the state? In addition, the State Plan does not address what data the state actually has on successful refugee placements of Islamic refugees. Islamic is pointed out specifically, because that is whom President Obama personally directed to be designated as refugees for America. Not knowing this data is an additional reason for due diligence to side on stopping the program until this can be investigated.

IRREPARABLE HARM FROM UNSANITARY CONDITIONS
Islamic migrants/”refugees” who have made it to Europe have been found to have been urinating and defecating in public. These actions have caused towns and other levels of government to hand out leaflets explaining that this is forbidden in European culture. In Cologne and Bonn, Germany leaflets teaching this and other elements about German culture such as accepting men and women as equals were handed out on January 27th. Such public actions by refugees would create unsanitary conditions leading to potential bio-hazards.

IRREPARABLE HARM FROM TERRORIST INFILTRATION
Terrorist infiltration through the Refugee Resettlement Program is not something new! We have seen it in 2009 when two Al Qaeda operatives were located in Bowling Green, Kentucky as refugees. These two when caught bragged of having attacked US troops and having bomb making experience. At the time House Committee on Homeland Security Chairman Michael McCaul stated, "I wouldn't be surprised if there were many more than that, and these are trained terrorists in the art of bomb making that are inside the United States; and quite frankly, from a homeland security perspective, that really concerns me."

It has been public knowledge since the Guardian on November 17, 2015 wrote of the ease and simplicity of obtaining a fake Syrian Passport. The article further states that the European border officials have no way to authenticate Syrian passports. This statement agrees with what FBI Director, James Comey’s testimony before the House Oversight Committee on October 22, 2015 in that there are no databases that can be used to verify people are who they say they are. Letting person’s enter who cannot be vetted poses safety and security risks to individuals in America and places the nation’s security at risk. Above all it denies the stated requirement to deny person’s the title of refugee who have been persecutors.

Denying that there are ISIS agents in the United States or those willing to take action as Lone Wolf Terrorists amongst those claiming to be Syrian refugees denies articles written even by Muslims themselves. One such article, written by The Muslim Issue published an article on February 2015 spoke of the threat by the Islamic State (IS) to send 500,000 jihadists amongst the migrants to Europe.

To date there have been 103 persons arrested or killed as Islamic State/ ISIS supporters. The Threat Knowledge Group maintains a database on their arrests. Of those listed 38 are classified as having been refugees (see Appendix C).

WHAT CAN BE KNOWN: 
THE THREAT OF THE 2ND GENERATION OF MUSLIM REFUGEES 
The attack in Orlando, Florida serves as a reminder that many of those who have pledged allegiance to the Islamic State and have been arrested are not only the first generation of Sunni Muslim refugees to America, they are also the children of refugees who were born and raised here.

It is important to analyze the data available to us on those who have been arrested or killed in the midst of a Jihad. What they do have in common is not discussed in the major media outlets. That being that Muslims refugees are raising young Muslim children who desire to see sharia in America and that this desire is causing young Muslim men and women from their teens to mid 30s to take actions to either join the Islamic State overseas or to follow the orders of their Caliph and commit an act of terror here in the USA.

Sadly data on 2nd generation jihadists is not currently available. What is known is the Orlando attacker’s father supports the Taliban whom our troops fought in Afghanistan. The Orlando attack however brings a concern that those raised in Islamic refugee/immigrant homes of parents with what the government deems as views that are “extremist” nay have a predilection towards joining a terror group.

However, through news stories I have located six persons who were second generation immigrants/refugees of the 103 who were arrested or killed for aiding the Islamic State or ISIS as they were formerly known (see Appendix D). This number could be higher since all minors names and information was not given. Note that this number does not include persons before the creation of ISIS.

CONCLUSION
For the foregoing reasons, as well as those in the original papers filed by the Plaintiff, this Court should enter the temporary injunction/restraining order requested by Plaintiffs.
Respectfully submitted,
_______________________________
Paul Sutliff
June 19, 2016

Appendix A

al-Misri, A. i. (1997). Reliance of the Traveller: A Classic Manual of Islamic Sacred law. (N. M. Keller, Trans.) Beltsville, MD: Amana Publications, p. 600-602.

THE OBLIGATORY CHARACTER OF JIHAD

o9.1 Jihad is a communal obligation (def: c3.2). When enough people perform it to successfully accomplish it, it is no longer obligatory upon others (O: the evidence for which is the Prophet's saying (Allah bless him and give him peace), 

"He who provides the equipment for a soldier in jihad has himself performed jihad," and Allah Most High having said:

 "Those of the believers who are unhurt but sit behind are not equal to those who fight in Allah's path with their property and lives. Allah has preferred those who fight with their property and lives a whole degree above those who sit behind. And to each, Allah has promised great good" (Koran 4:95).

If none of those concerned perform jihad, and it does not happen at all, then everyone who is aware that it is obligatory is guilty of sin, if there was a possibility of having performed it. In the time of the Prophet (Allah bless him and give him peace) jihad was a communal obligation after his emigration (hijra) to Medina. As for subsequent times, there are two possible states in respect to non-Muslims.

The first is when they are in their own countries, in which case jihad (def: o9.8) is a communal obligation, and this is what our author is speaking of when he says, "Jihad is a communal obligation," meaning upon the Muslims each year. The second state is when non-Muslims invade a Muslim country or near to one, in which case jihad is personally obligatory (def: c3.2) upon the inhabitants of that country, who must repel the non-Muslims with whatever they can).

o9.2 Jihad is personally obligatory upon all those present in the battle lines (A: and to flee is an enormity (dis: p11)) (O: provided one is able to fight. If unable, because of
illness or the death of one's mount when not able to fight on foot, or because one no longer has a weapon, then one may leave. One may also leave if the opposing non-Muslim army is more than twice the size of the Muslim force).

o9.3 Jihad is also (O: personally) obligatory for everyone (O: able to perform it, male or female, old or young) when the enemy has surrounded the Muslims (O: on every side, having entered our territory, even if the land consists of ruins, wilderness, or mountains, for non-Muslim forces entering Muslim lands is a weighty matter that cannot be ignored, but must be met with effort and struggle to repel them by every possible means. All of which is if conditions permit gathering (A: the above-mentioned) people, provisioning them, and readying them for war. If conditions do not permit this, as when the enemy has overrun the Muslims such that they are unable to provision or prepare themselves for war, then whoever is found by non-Muslim and knows he will be killed if captured is obliged to defend himself in whatever way possible. But if not certain that he will be killed, meaning that he might or might not be, as when he might merely be taken captive, and he knows he will be killed if he does not surrender, then he may either surrender or fight. A woman too has a choice between fighting or surrendering if she is certain that she will not be subjected to an indecent act if captured. If uncertain that she will be safe from such an act, she is obliged to fight, and surrender is not permissible).

WHO IS OBLIGED TO FIGHT IN JIHAD

o9.4 Those called upon (O: to perform jihad when it is a communal obligation are every able bodied man who has reached puberty and is sane.o9.5 The following may not fight in jihad:(1) Someone in debt, unless his creditor gives him leave;(2) or someone with at least one Muslim parent, until they give their permission; unless the Muslims are surrounded by the enemy, in which case it is permissible for them to fight without permission.o9.6 It is offensive to conduct a military expedition against hostile non-Muslims without the caliph's permission (A: though if there is no caliph (def: o25), no permission is
required).o9.7 Muslims may not seek help from non-Muslims allies unless the Muslims are considerably outnumbered and the allies are of goodwill towards the Muslims.

Appendix B:

1915 Ottoman Fatwa

The holy war of today is obligatory on every Muslim, and this present moment and this moment is the only opportune one for it. Patience and indifference in these times is a grave mistake. The massacre of unbelievers (and only those who command us) whether they are found in public or private places is now our duty, as it is in Allah’s words “Take them and kill them wherever you find them. Behold we have delivered them into your hands, and from you, must issue supreme sovereignty.” The slaying of one unbeliever (of those who rule over us) in public or private shall be called an additional life for Islamism, and will be recompensed by Allah.

Let every Muslim know that his reward for so doing shall be doubled by our Allah who created heaven and earth. It is will accounted him as a great precept, and his recompense will be greater than fasting on “Ramadan.” He will be saved from the terrors of the day of Judgment – the day of the resurrection of the dead. Who is the man who refuses to enjoy such a reward? for such a small deed?

The faithful Muslim with warm attachment to his faith and believing in the resurrection of the dead does not approach nor befriend the foes of Islam. Such attitude is not according to common sense. The man who does so is far from the religion of Islam. You are astonished why we are so estranged from the unbelievers? But why are you not surprised at your own conduct towards them? What excuse will you give not to Allah, but to your brethren? If you believe in Allah, in his faith and apostle, hear the words of our sages recorded by his holy prophet. “You believer take not the Jews and Christians as friends unto you, He who loves them shall be called on of them.” “Allah shall not foster the tyrants.” You believers accept not unto you friends of these who abuse your faith and mock thereof. They are called unbelievers, and you hearken unto the words of Allah of you believe. Therefore if after you put to heart to these sacred words, perhaps they have been spoken to you by Allah not acquire unto us Jewish or Christian friends. From these holy words you will realize it is forbidden us to approach those who mock our faith – Jews and Christians, for then Allah forbid, All forbid we shall be deemed by the almighty as of one of them Allah forbid.

After all this how can we believe in the sincerity of your faith when you befriend and love unbelievers, and accept their Government without any rising without attempting to expel them from your country. Therefore arise and purify yourselves of such deeds. Arise to the Jihad {Holy War} no matter what it costs so as to carry into execution this sacred deed. It is furthermore said in the Koran, “if your fathers if children taken unto them friends of the unbelievers, estrange yourselves even from them.”

Beloved you have not taken to heart these holy words, and you are following an unrighteous path, and therefore why have you pity on your religion. Arouse, arouse, and let not this opportunity pass. You approach the unbeliever so as to enjoy their greatness and honor, and have forgotten Allah’s words. To thee O Allah belongs the strength and honor. Therefore, take to heart out holy aims for realization and honor will ultimately follow. If not we are afraid that your name will not be remembered among Muslims.

The Muslim religion enjoins us to set aside some money for Government expenses and for preparations of a Jihad {Holy War}. The rest of your tithes and contributions you are duty bound to send to the capital of the Caliphatic to help them to glorify the name of Allah, through the medium of the Caliph.

Let all Muslims know that the Jihad {Holy War} is created for the purpose. We trust in Allah that Islamic lands will rise from the humiliation and become faithfully tied to the capital of the Caliphate, so as to be called dar al-Islam {“the lands of Islam”}. This is our hope and God help us to carry through our holy aims to a successfully issue for the sake of our holy Prophet. Dear Brethren!

A Jihad {Holy War} is a sacred duty and for your information let it be known that the armies of the Caliph is ready an in three divisions, as follows: War in secret, war by word of mouth, and physical war.

1) Jihad in secret. This is the easiest and simplest. In this case it is to suppose that every unbeliever is an enemy to persecute and exterminate him from the face of the earth. There is not a Muslim in the world who is not inspired by this idea. However in the Koran it said: “That such a war is not enough for a Muslim whether young or old, and must also participate in the other parts of the Holy War.”

2) Jihad by word of mouth. That is to say fighting by writing and speaking. This kind of war for example should pertain to the Muslims of the Caucasus. They should have commenced this war three or four months ago, because their actual position does not permit them to but the carrying on of such warfare. Every Muslim is in duty bound to write and speak against the unbelievers when actual circumstances do not permit him to assume more stringent measures, as for instances in the Caucasus. Therefore every writer must use his pen in favor of such a war.

3) Physical Jihad. This means actual fighting in the fullest sense of the word. This kind of war is also subdivided into two parts, viz: The lesser and greater war.

a. The lesser jihad, is when a certain section of Muslims rise to fight against their enemies in combination with their compatriots in the war sphere only, without summoning the aid of Muslims of other lands. For example the Sinoussians war with the Italians in Tripoli. Even in such a case every Muslim should offer material and moral help and not follow the course of the Egyptian Government took in the Italian war when acting under the advice of the unbelieving English Government they declared themselves neutral. This sin shall never be forgiven them. However our Egyptian brethren have helped us to a certain degree financially and morally in the last two wars and in spite of their unbelieving rulers forwarded their collections on our behalf to the Capital of the Caliphate.

Every provincial governor may proclaim a lesser Jihad {Holy War}, nevertheless for prestige sake it is necessary to obtain the permission of the Caliph for so doing, as the late Sheik Vaadi did when he proclaimed a lesser Jihad {Holy War} on the French. A greater Jihad {Holy War}, is that which is proclaimed by the whole of Islam in union with all the Muslims throughout the world, such a war can only be called out by the Caliph himself, and as soon as a Muslim hears this call he must hasten to his brethren’s assistance, an example, our proclamation of today. There is no doubt at all that he who shall assist in this great Jihad {Holy War}, shall be doubly recompensed by heaven. He who shall fall in this war shall die a hero’s death on the battlefield for sanctifying Allah’s name and that of the Prophet.
Thou O Allah pour out thy mercy to arouse the heats of the Muslim children to his holy proclamation. Give ample reward to the victims that shall fall in glorifying thy name and that if thy prophet, for thou art the hoard of righteousness.

Now let us mention here the means to be adopted in carrying on this Jihad {holy war}, as follows:

Every private individual can fight with deadly weapons, as for example. Here is the following illustration of the late Egyptian Verdani who shot the unbelieving Butros Gal Pacha the friend of the English with a revolver. The murder of one of the English police Commissioner Bavaro in India by one of our Indian brethren. The killing of one of the officials of Kansch on his coming from Mecca by the Prophet’s friend”Abu Bazir El Pachbi,” peace be unto him! Abdallah ibn Aatickand four colleagues killed “Abu Raafa Ibn El Hakiki.” The leader of the Jews so famous for his enmity to Islamism. This was executed by our Prophet’s command, so did Avrala Ibn Ravacha and his friends when they killed Ocher Ibn Dawas one of the Jewish dignitaries. There are many instances of similar of cases. Lord of the Universal What fails us now, and should not some of us go forth to fight this sacred war for exalting thy glorious name? What could not happen were some individuals among us, men of courage and stout hearted kill the principal Christian men of the Triple Alliance, the foes of Islam. By so doing they would wipe their names from the face of the earth. Thou O Allah art responsible if you will not inspire every Muslim, with the holy spirit, to in this this jihad {holy war}. The second method is to fight this war secretly and deceitfully. This method is well known to every Muslim. This system has special advantages where the number of Muslims is inferior to that of the unbelievers. When the prophecy of Allah inspired our Prophet, “Fight for Allah with those who fight against you,” he began to do in secret, and in this way. At first he sent some of his soldiers accompanied by an officer to fight his enemies. Of course only men of exceptional bravery were chosen by the prophet to carry on these expeditions. They formed secret expeditions which ultimately number fifty or sixty which harassed and fought the enemy. Of the first were the expeditions of Hamsha Ibn Abed El Matlav, Abidu Ibn Cahart, Saad Habas, Gzid ibn Chartah, Abu Maslaam Asham ibn Taabet, Manzur ibn Omar, Abed el Rahman ven Oof and AbouTaleb.

It is also the duty of the Muslim of today to follow this method – to arm small riding parties which we hope will bring as much use and advantage at the present moment particularly in the towns of Caucasus, Turkistan, India, and Java. Perpetually harassing the enemy by such means brings great advantage. To prepare such expeditions in our days there are many facilities, but what is certain to us is that these secret raids bring much benefit. Therefore every individual should endeavor to organize such raids, and perhaps in the same way as our holy Prophet did when he entered “Bachlaf El Fazul.”

The third method is actual war in the offensive. The commander in Chief of such a war is to be the Caliph of all Muslims or his substitute as it was in the battles of “Badr” and “Uhud.” In thee battles our prophet personally was in command of the forces. As it is well known to you, dear brethren, that the participation in the great Jihad {holy war} is obligatory upon every Muslim, so you should know hot to prosecute it. Therefore, dear brethren arouse and trust in Allah, and choose the method most appropriate for you according to the requirements of your places. Do not delay a moment, the time has ultimately arrived for this matter. As the center of the Caliphate has not the power to send armed forces to help you in your respective places, therefore you yourselves must arm and prepare and unite as one man with some powerful nation if it be necessary, and to commence the Jihad {holy war}. Support yourselves on Allah’s mercy, observe and guard over all the precepts of Islamism, and do estrange yourselves from politics. If any political difficulties shall confront you, bring them to the notice of your diplomatic brethren in the capital of the Caliph, from who you will receive the necessary advice. And whereas our Muslim code enjoins and compels us to fight in the jihad {holy war}, it also commands us to distinguish between those who love Islam and the Caliph, for they are virtuous, just, powerful and on good terms with us, and though of a different faith to ours, we are commanded to protect them.

SOURCE: 1915 Ottoman Fatwa cited in Bostom, A. (2008). (Italics denote corrections. Mussulman and Mohamadians replaced with Muslim. Holy War has Jihad inserted. God is changed to Allah.
MISSING: The Fatwa according to Ambassador Morgenthau was over 10,000 words in English. This is a little over 2,000. Left off here are two paragraphs informing Muslims that states they should not kill Germans and Austrians.
(Revisions include: 1) returning the word” Jihad” where it previously stated “War,” 2)Changing the archaic term” Mahomedans” to “Muslim.” ~P. Sutliff

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