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IN THE COURT OF COMMON PLEAS

CUYAHOGA COUNTY, OHIO

FOUAD SAEED ABDULKADIR,


11490 Bobko Blvd, Parma, OH 44130
Plaintiff,

vs.

OBAY S ALTAHER, 9000 Edgewood Drive,


North Royalton, OH 44133
AHMAD JAMAL, 10250 Kings Way, North
Royalton, OH 44133
AZZAM N. AHMED, 50 Woodburn Dr, Moreland
Hills, OH 44022
MOHAMED ABDELSALAM, 4496 West 137th
St, Cleveland, Ohio 44111
AHMAD S. ANSARI, 8183 Lorraine Dr,
Strongsville, OH 44149
MOHAMMAD M. SOHRABI, 9000 Edgewood
Drive, North Olmsted, OH 44070
TALAL HAMED, 2155 Berkeley Drive, Westlake,
OH 44145
SAMI MOHAMMED, 6025 Pebblebrook Lane,
North Olmsted, OH 44070
MAHMOUD MUHIEDDINE, 7309 Craigmere
Dr., Middleburg Hts, OH 44130

Defendants.

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CASE NO.:
COMPLAINT FOR DAMAGES ARISING
FROM

1.
2.
3.
4.
5.
6.
7.

BATTERY
ASSUALT
AGGRAVATED ASSUALT
HARASSMENT
DEFEMATION
RETALIATION
INTENTIONAL INFLICTION OF
EMOTIONAL DISTRESS
8. BELIEF BASED
DISCRIMINATION
9. NEGLIGENCE
10.INJUCTIVE RELIEF, FOR
COSTS AND FOR PUNITVE
DAMAGES.
JURY TRIAL DEMANDED

NATURE OF THE ACTION


TO THE HONORABLE JUDGE OF COURT:
1.

This is a civil action for compensatory and punitive damages for common law defamation.
Defendants out of bad faith and ill-will have intentionally, recklessly, willfully, and
wantonly created approximately two dozen false statements. Additionally, these
defamatory falsehoods have been spread without privilege in an attempt to destroy the
Plaintiffs professional reputation, civil rights, and religious freedom within the Muslim
community as a respected religious leader.

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2.

As a direct consequence of these unlawful acts, the Plaintiff has suffered severe emotional
distress (post-traumatic stress disorder), as well as financial, interpersonal, and other
damages, all to his detriment. The Defendants actions have forced the plaintiff to hire
attorneys and file suit and he, therefore, has incurred substantial attorneys fees and costs.
PARTIES

3.

Plaintiff Fouad Saeed Abdulkadir is a member of the Islamic Center of Cleveland, a


resident of Ohio and served as an Imam in the Islamic Center of Cleveland from October,
2014 May 2016.

4.

Defendants are citizens and resident of Ohio and at all times relevant hereto were
members of the Islamic Center of Cleveland.

5.

Defendant, OBAY S ALTAHER, an individual, is resident of North Royalton, Cuyahoga


County, Ohio and may be served with process at Defendants home address: 9000
Edgewood Drive, North Royalton, OH 44133.

6.

Defendant, AZZAM N. AHMED, an individual, is resident of Moreland Hills, Cuyahoga


County, Ohio and may be served with process at Defendants home address: 50 Woodburn
Dr, Moreland Hills, OH 44022.

7.

Defendant, AHMAD JAMAL, an individual, is resident of North Royalton, Cuyahoga


County, Ohio and may be served with process at Defendants home address: 10250 Kings
Way, North Royalton, OH 44133.

8.

Defendant, AHMAD S. ANSARI, an individual, is resident of Strongsville, Cuyahoga


County, Ohio and may be served with process at Defendants home address: 8183 Lorraine
Dr, Strongsville, OH 44149.

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9.

Defendant, MOHAMMAD M. SOHRABI, an individual, is resident of North Olmsted,


Cuyahoga County, Ohio and may be served with process at Defendants home address:
9000 Edgewood Drive, North Olmsted, OH 44070.

10.

Defendant, SAMI MOHAMMED, an individual, is resident of North Olmsted, Cuyahoga


County, Ohio and may be served with process at Defendants home address: 6025
Pebblebrook Lane, North Olmsted, OH 44070.

11.

Defendant, TALAL HAMED, an individual, is resident of Westlake, Cuyahoga County,


Ohio and may be served with process at Defendants home address: 2155 Berkeley Drive,
Westlake, OH 44145.

12.

Defendant MOHAMED ABDELSALAM, an individual, is resident of Cleveland,


Cuyahoga County, Ohio, and may be served with process at Defendants home address:
4496 West 137th St, Cleveland, Ohio 44111

13.

MAHMOUD MUHIDEIN an individual, is resident of Middleburg Hts, Cuyahoga County,


Ohio, and may be served with process at Defendants home address: 7309 Craigmere Dr.,
Middleburg Hts, OH 44130

VENUE AND JURIDICTION


14.

This court has personal jurisdiction of Defendants, and each of them, because they are
residents of and/or doing business in the State of Ohio. The wrongful conduct alleged
against each Defendants, occurred in the County of Cuyahoga, State of Ohio. This is the
proper court because the injury and/or wrongful acts that are the subject of this action
occurred in its jurisdictional area and/or at least one Defendant now resides in its
jurisdictional area.

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Defendants Wrongful Conduct


15.

Over the last several months, the Defendants have engaged in repeated, relentless efforts
to harm Plaintiff Fouad Saeed Abdulkadir.

16.

The Defendants have engaged in a concerted campaign to destroy Plaintiff Fouad Saeed
Abdulkadir reputation and career by spreading numerous defamatory statements against
him.

17.

The defamatory statements and efforts by which the Defendants engaged have harmed
Plaintiff Fouad Saeed Abdulkadir.

18.

Defendant MAHMOUD MUHIEDDINE informed Plaintiff in a warning tone that, good people
have gotten killed in Cleveland and God know what might happen to you, just leave this place.
Such statement in the state of law and order alarmed the Plaintiff, and out of fear for his life and
his familys safety he filed this complaint.

GENERAL ALLEGATIONS
19.

At all times relevant hereto, the Plaintiff was the Imam and Chairman of religious affairs
at the Islamic Center from October, 1, 2014 to May, 23 rd, 2016.

20.

Each Defendant knowingly made false and defamatory statements which were negligent
and reckless which were purposeful, intentional, and with malice.

21.

Defendants profiled and discriminated against Plaintiff Fouad Saeed Abdulkadir to destroy
his image and reputation with the intent to end his employment at the Islamic Center of
Cleveland.

22.

In blatant violation of Ohio law, the Defendants bluntly retaliated against the Plaintiff for
raising legitimate concerns regarding the Defendants breaches of constitution and civil
rights.

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23.

These actions left the Plaintiff no choice but to turn to the judicial system for redress. The
Plaintiff brings these claims in an effort to put an end to the Defendants destructive and
illegal campaign and to hold each of the Defendants responsible for the monetary and
irreparable harm caused.

PLAINTIFFS ORIGINAL PETITION


24.

Plaintiff FOUAD SAEED ABDULKADIR (Plaintiff or Fouad) brings this lawsuit


complaint of the Defendants and would respectfully request the following:
DISCOVERY

25.

Plaintiff respectfully requests Discovery in this case be conducted pursuant to rule


2317.48 of the Ohio Rules of Civil Procedure.
The Plaintiffs complain and for cause of action alleges as follows:

FIRST CAUSE OF ACTION


(Aggravated Assault and Battery)
26.

Plaintiff is an individual and is now, and at all times mentioned in this complaint, a
resident of Cuyahoga County, Ohio.

27.

Defendant Obay S. Altaher is an individual and is now, and at all times mentioned in this
complaint, a resident of Cuyahoga County, Ohio.

28.

On or about January 31st 2016, at approximately 9:00 PM, the plaintiff was on his way to
pay his respect for the death of a respected community member, in the community hall of
Islamic Center of Cleveland.

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29.

Defendant stopped the Plaintiff and asked him to greet him. Plaintiff greeted the
Defendant and turned to go to the funeral.

30.

Defendant then called plaintiff's name and plaintiff turned and faced defendant.
Defendant stood very close to plaintiff, shook his fist in the plaintiff's face, used foul
language, and threatened to strike plaintiff.

31.

As the Plaintiff began to back away from the Defendant, moving toward the community
hall, the Defendant spat into the plaintiffs face. Plaintiff tried to avoid and defendant got
closer to pursue a physical altercation with the Plaintiff.

32.

The President of the Islamic Center, then Akrum Jamal, stood between the Defendant and
the Plaintiff.

33.

Defendant kept on shouting using foul language and continued threatening a physical
altercation with the Plaintiff.

34.

Ahmed Hamed, a community member, attempt to defend the Plaintiff. The Defendant
pushed the aforementioned and threatened a physical altercation with him as well.

35.

Without consent or legal privilege, Defendant OBAY S ALTAHER intentionally assaulted


and physically battered the Plaintiff with the intent to harm the Plaintiff as described herein.
Such conduct was extreme and would be deemed highly offensive to a reasonable person.

36.

As a result of the aforementioned conduct, the Plaintiff suffered psychologically damage.

37.

Defendant intended to cause and did cause a harmful contact.

38.

Defendant OBAY S ALTAHER had knowledge that his conduct was unwelcome and
offensive to Plaintiff, Fouad Saeed Abdulkadir.

39.

Plaintiff did not consent to defendant's act.

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40.

Defendant OBAY S ALTAHER acted with malice, oppression, and with a conscious
disregard of the Plaintiffs rights, making him liable for punitive damages under Ohio
Civil code 2315.2

41.

As a direct and proximate result of defendant's conduct plaintiff suffered mental anguish.
SECOND CAUSE OF ACTION
(Defamation & Verbal Harassment)

42.

Defendant OBAY S ALTAHER made false and defamatory statements negligently,


recklessly, purposefully, and intentionally with malice.

43.

Defendant OBAY S ALTAHER, in fact, knew that his statements concerning Plaintiffs
were false and misleading.

44.

Defendant OBAY S ALTAHERs statements were made public, and disseminated through
various social gatherings to persons and entities of the Cleveland area, and were understood
to be of or concerning the Plaintiff.

45.

The false and defamatory statements made by DEFENDANT OBAY S ALTAHER


concerning the personal, professional, and religious reputation and character of Plaintiff
were made maliciously and with intent to destroy the Plaintiffs professional reputation
and career.

46.

As a direct and proximate result of Defendant OBAY S ALTAHERs statements, Plaintiffs


have suffered pecuniary damage, as well as injury to reputation, impairment to standing
within his community, personal humiliation, pain and suffering, and emotional distress.

WHEREFORE, the Plaintiff respectfully request that this Court enter judgment against the
Defendant for actual, compensatory damages, and punitive damages, in a sum to be determined by
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the court, for costs herein incurred, courts fees, and for such other and further relief as this Court
deems just and proper.

THIRD CAUSE OF ACTION


(Defamation PER SE and Assaults)
47.

Defendant AHMAD JAMAL set out to destroy the plaintiffs professional reputation and
deny his religious freedom at the Islamic Center of Cleveland by creating pre-textual
assertions about his character and job performance.

48.

One such false assertion which the Defendant used was the false claim that since the
Plaintiff investigated the Quran School of the center, that he must be the person who closed
the school.

49.

DEFENDANT AHMAD JAMAL also spread and has continued to spread false and
defamatory statements about Plaintiff in the community of Islamic Center and surrounding
communities.

50.

The false and defamatory statements made by DEFENDANT AHMAD JAMAL


concerning the personal, professional, and religious reputation and character of Plaintiff
were made maliciously and with intent to destroy Plaintiffs professional reputation and
career.

51.

Defendant AHMAD JAMAL attacked Plaintiff Fouad Saeed Abdulkadir verbally and
physically assaulted him by grapping him forcefully with his hand while making false
accusation and statements.

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52.

The statements made by DEFENDANT AHMAD JAMAL clearly designated Plaintiffs


reputation, and accused him of engaging in conduct and having traits incompatible with his
position as a religious leader, and are thus defamatory per se under Ohio law.

53.

Plaintiff Fouad Saeed Abdulkadir suffered life altering emotional harm as a result of
Defendants outrageous, unwanted, harmful and offensive conduct.

54.

As a direct and proximate result of Defendant AHMAD JAMALs conduct, Plaintiff Fouad
Saeed Abdulkadir was released from his position as religious leader of the Islamic Center
of Cleveland.

55.

As a direct and proximate result of Defendant AHMAD JAMALs conduct, Plaintiff Fouad
Saeed Abdulkadir has been impaired in his ability to earn a living as a religious leader, and
has sustained and will continue to sustain loss of income in amount that will be established
at trial.

56.

As a direct and proximate results of Defendant AHMAD JAMALs conduct, Plaintiff


Fouad Saeed Abdulkadir has suffered and will continue to suffer mental anguish and
distress.

57.

As a direct and proximate results of Defendant AHMAD JAMALs conduct, the reputation
of Plaintiff Fouad Saeed Abdulkadir has been damaged and has sustained and will continue
to sustain loss of income in amount that will be established at trial.

WHEREFORE, the Plaintiff request judgement against defendant AHMAD JAMAL for
compensatory and punitive damages, together with cost of the legal suit, and other relief as the
court may deem proper.

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FOURTH CAUSE OF ACTION


(Violation of Ohio Revised code 2921.02)
58.

Plaintiff incorporate by reference as though full set forth herein, each and every
allegation set forth above in this complaint. As a Fourth separate distinct cause of action,
Plaintiff complains against Defendant AHMAD JAMAL as follows:
1. Defendant recklessly and intentionally accused Plaintiff of accepting bribe to
make a public speech to serve the interest of Mr. Ali Faraj.
2. Defendant offered Plaintiff Fouad Saeed Abdulkadir a bribe, 3% out of 2
million dollars if Plaintiff accepted and agreed to make a motivational speech
encouraging his clients to pay him back the money.
3. Ohio Revised code 2921.02, section (C) states, No person, with purpose to
corrupt a witness or improperly to influence a witness with respect to the
witness's testimony in an official proceeding, either before or after the witness
is subpoenaed or sworn, shall promise, offer, or give the witness or another
person any valuable thing or valuable benefit. Defendant AHMAD JAMAL in
his official capacity as Board member of the Islamic Center of Cleveland,
offered viable individual to this ongoing matter Mr. Musa Assad a bribe to side
with him against the Plaintiff.
4. Defendant committed the despicable acts as herein alleged maliciously,
fraudulently and oppressively, with the wrongful intent of injuring Plaintiff,
and have acted with an improper and evil motive amounting to malice, and
fraud and in conscious disregard of Plaintiffs rights.

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WHEREFORE, Plaintiff request judgement against defendant AHMAD JAMAL for


compensatory and punitive damages, together with costs of suit, and other relief as the court may
deem proper.

FIFTH CAUSE OF ACTION


(TORTIOUS INTERFERENCE WITH PROSPECTIVE ECONOMIC ADVANTAGE)
59.

Plaintiff repeats and re-alleges that the allegations of the previous COUNTS as if same
were set forth at length herein.

60.

The proclamation by Defendant AHMAD JAMAL of the false and malicious statements
about the plaintiff set forth in the previous COUNT, as well as other actions and statements
by Defendant, interfered with the prospective economic advantage of the Plaintiff. By
inducing prospective advantages of the plaintiff not to engage as their religious leader, the
Plaintiff suffered damages in amount that will be established at trial.

WHEREFORE, the Plaintiff request judgement against defendant AHMAD JAMAL for
compensatory and punitive damages, together with cost of the legal suit, and other relief as the
court may deem proper.
SIXTH CAUSE OF ACTION
(Defamation PER SE)
61.

Plaintiff repeats and re-alleges the allegation of the previous COUNTS as if same were set
forth at length herein.

62.

Defendant Azzam Ahmed resides at 50 Woodburn Dr., Moreland Hills, OH 44022.

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63.

Publically proclaimed false and defamatory statements about Plaintiff Fouad Saeed
Abdulkadir including, but not limited to, claiming that Fouad Saeed Abdulkadir closed the
school because they refused to give him a financial share, stole public money, was not a fit
religious leader, and that he was a liar and untrustworthy.

64.

The false and defamatory statements made by Azzam Ahmed concerning the personal,
professional, and religious reputation and character of Plaintiff was made maliciously and
with the intent to destroy Plaintiffs professional reputation and career.

65.

The statements made by Azzam Ahmed clearly designated the Plaintiffs reputation along
with accusing him of engaging in inappropriate conduct and exhibiting traits incompatible
with his job as religious leader, and are thus defamatory per se under Ohio law.

66.

As a direct and proximate result of Defendant AZZAM AHMEDs conduct, Plaintiff Fouad
Saeed Abdulkadir has been impaired in his ability to earn a living as a religious leader, and
has sustained and will continue to sustain a loss of income in amount that will be
established at trial.

67.

As a direct and proximate result of Defendant AZZAM AHMEDs conduct, Plaintiff Fouad
Saeed Abdulkadir has suffered and will continue to suffer mental anguish and distress.

68.

As a direct and proximate result of Defendant AZZAM AHMEDs conduct, the reputation
of Plaintiff Fouad Saeed Abdulkadir has been damaged and has sustained and will continue
to sustain a loss of income in amount that will be established at trial.

WHEREFORE, the Plaintiff request judgement against defendant AZZAM AHMED for
compensatory and punitive damages, together with cost of the legal suit, and other relief as the
court may deem proper.
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SEVENTH CAUSE OF ACTION


(Intentional infliction of Emotional Distress)
69.

Plaintiff repeat and re-allege each and every allegation of the foregoing paragraphs as if
fully set forth herein.

70.

Defendant SAMI MOHAMMED intentionally acted to threaten, intimidate, frighten, and harm
the Plaintiff including to retaliate and punish the Plaintiff for his exercise of the Plaintiffs First
Amendment right to criticize bad decisions.

71.

The Defendants harmed the Plaintiff out of spite, bitterness, anger, and animosity in retaliation for
the Plaintiffs professional critiques and suggestions for and criticism of the optimal and unwise
decisions.

72.

Defendants actions and omission were intended to frighten, threaten, intimidate, and
manipulate the Plaintiff by causing him emotional distress.

73.

Defendants actions and omission were willful malicious, deliberate, or were done with
reckless indifference to the possibility that such behavior would cause severe emotional
distress and with utter disregard for the consequences of such actions.

74.

Defendants conduct is unreasonable and outrageous and exceeds the bounds tolerated by
decent society, and was done willfully, maliciously and deliberately, or with reckless
indifference, to cause Plaintiff severe mental and emotional pain, distress, and anguish and
loss of enjoyment of life.
EIGHTH CAUSE OF ACTION
(Defamation PER SE)

75.

Defendant MOHAMED ABDELSALAMs accusation that Plaintiff Fouad Saeed


Abdulkadir is a sorcerer is false and defamatory. It was made with common law malicespite and ill-will. It was also made with actual malice-reckless disregard of the truth and/or

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knowing falsity. MOHAMED ABDELSALAM, someone who is Muslim by faith, knows


the impact of such word among the Muslim community. Additionally, he knew the
statement to be false wherein, and lacked the facts necessary to confirm it. Defendant
MOHAMED ABDELSALAM described Plaintiff Fouad Saeed Abdulkadir to be a sorcerer
without regard to the statements falsity and with the intent to discredit, disgrace, and
defame Plaintiff Fouad Saeed Abdulkadir.
76.

Defendant MOHAMED ABDELSALAMs, accusation that Plaintiff Fouad Saeed


Abdulkadir lies is false and defamatory. It is made with common law malice-spite and
ill-will. It is also made with actual malice-reckless disregard of the truth and/or knowing
falsity. Defendant MOHAMED ABDELSALAM described Plaintiff Fouad Saeed
Abdulkadir to be a liar without regard to the statements falsity and with the intent to
discredit, disgrace, and defame Plaintiff Fouad Saeed Abdulkadir.

77.

The statements he is a sorcerer and he lies is libelous per se because the statement on
its face describes Plaintiff Fouad Saeed Abdulkadir as a person lacking faith, honesty, and
integrity. Thus making him a person to be shunned or excluded by those who seek
information and opinion upon which to rely on in the conduct of their affairs. In addition,
the statement prejudices Plaintiff Fouad Saeed Abdulkadir in his profession as the religious
leader of the largest mosque in Northeast Ohio, the chairman of religious affair, as a
preacher, and as public spokesperson for the Islamic center of Cleveland. The statement
impugns his reputation for truthfulness and deter those who must depend on accurate and
truthful information from associating or dealing with him. By falsely labeling Plaintiff
Fouad Saeed Abdulkadir as a sorcerer and liar, the Defendant has made Plaintiff Fouad
Saeed Abdulkadir appear odious, wicked, and ridiculous. By doing so, Defendant

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MOHAMED ABDELSALAM have imposed a false credibility barrier between Plaintiff


FOUAD SAEED ABDULKADIR and the Muslim community in Northeast Ohio.
78.

Defendant MOHAMED ABDELSALAM made the defamatory statement with actual


malice, i.e knowledge of its falsity or with reckless disregard thereof, and with the intent
to injure, debase, and defame Plaintiff Fouad Saeed Abdulkadir; in the alternative,
Defendant made the defamatory statement without due care to the identification of falsity.

79.

As a direct and proximate result of the publication of the untrue and defamatory statement
by the Defendant, Plaintiff FOUAD SAEED ABDULKADIR has been exposed to public
hatred, ridicule, and contempt. The statement has been spread by the Defendant, and has
become a source of embarrassment and humiliation to the Plaintiff Fouad Saeed
Abdulkadir. Plaintiff Fouad Saeed Abdulkadirs character and reputation for faith, honesty,
and integrity cannot be fully restored because of the broad spreading of these statements.
Moreover, his professional standing as a religious leader, his religious role as an Imam in
the community at large will never return to the original state before he was labeled a
sorcerer and a liar. The stigma caused by these defamatory statements will distance others
from trusting his statements and opinions and will cause the community to view him with
loathing and disapprobation. Plaintiff Fouad Saeed Abdulkadir has suffered a terrible
wrong and injury on account of the per se, he lies and he practices magic and the
related content that portrays him as an evil person.

80.

As a direct and proximate results of Defendant MOHAMED ABDELSALAMs conduct,


the reputation of Plaintiff Fouad Saeed Abdulkadir has been damaged and has sustained
and will continue to sustain loss of income in amount that will be established at trial.

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WHEREFORE, the Plaintiff request judgement against defendant MOHAMED ABDELSALAM


for compensatory and punitive damages, together with cost of the legal suit, and other relief as the
court may deem proper.

NINETH CAUSE OF ACTION


(Defamation PER SE)
81.

Defendant TALAL HAMED, accusation that Plaintiff Fouad Saeed Abdulkadir is a Child
Molester is false and extremely defamatory. It is made with common law malice-spite and
ill-will. It is also made with actual malice-reckless disregard of the truth and/or knowing
falsity. TALAL HAMED is a board member in the Islamic Center and was amongst the
group of people defaming the plaintiff. Defendant TALAL HAMED described Plaintiff
Fouad Saeed Abdulkadir as being a child molester without regard to the statements falsity
or with the intent to discredit, disgrace, and defame Plaintiff Fouad Saeed Abdulkadir.

82.

The statements he is a child molester is libelous per se because the statement on its face
describes Plaintiff Fouad Saeed Abdulkadir as a person lacking faith, honesty and integrity,
making him a person to be shunned or excluded by those who seek information and opinion
upon which to rely in the conduct of their affairs. In addition, the statement prejudices
Plaintiff Fouad Saeed Abdulkadir in his profession as the religious leader of the largest
mosque in Northeast Ohio, as a chairman of religious affair, as a preacher, and as public
spokesperson. The statement impugns his reputation for truthfulness and deter those who
must depend on accurate and truthful information from associating or dealing with him. By
falsely labeling Plaintiff a child molester the Defendant have made Plaintiff appear as a
predator, odious, wicked and criminal. By so doing, Defendant TALAL HAMED have

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imposed a false credibility barrier between Plaintiff and the Muslim community in
Northeast Ohio.
83.

Defendant made the defamatory statement with actual malice, i.e with knowledge of its
falsity and with reckless disregard thereof, and with the intent to injure, debase and defame
Plaintiff Fouad Saeed Abdulkadir; in the alternative, Defendant made the defamatory
statement without due care to the identification of falsity.

84.

As direct and proximate result of the publication of the untrue and defamatory statement
by the Defendant, Plaintiff has been exposed to public hatred, ridicule, and contempt. The
statement has been spread by the Defendant and by numerous others, and has become a
source of great embarrassment and humiliation to Plaintiff. Plaintiffs character and
reputation for faith, honesty, and integrity cannot be fully restored because of the broad
spreading of the statement. Moreover, his professional standing as a religious leader, his
religious role as an Imam, and in the community at large will never be as it was before he
was labeled a child molester. The stigma caused by the defamatory statement will disused
others from trusting his statement and opinions; and will cause the community to view him
with loathing and disapprobation as a sex offender. Plaintiff Fouad Saeed Abdulkadir has
suffered a terrible wrong and injury on account of the per se, he is a child molester and
the related content that portrays him as an evil person.

85.

As a direct and proximate results of Defendants conduct, the reputation of Plaintiff Fouad
Saeed Abdulkadir has been damaged and has sustained and will continue to sustain loss of
income in amount that will be established at trial.

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WHEREFORE, Plaintiff request judgement against defendant TALA HAMED for compensatory
and punitive damages, together with costs of suit, and other relief as the court may deem proper.

TENTH CAUSE OF ACTION


(Intentional Infliction of Emotional Distress)
86.

The Defendants actions were extreme and outrageous beyond bounds of decency so as to
be deemed intolerable in a civilized community. The Defendants intentionally and
recklessly caused the Plaintiff Fouad Saeed Abdulkadir to suffer severe emotional distress.
The recitation of the Defendants actions arouses resentment in an average member of the
community and causes them to exclaim outrageous.

87.

Defendants Ansari and Soharabi were parts of the group above who intentionally
assassinated the Plaintiffs character and participating in destroying his career.

88.

Defendant MOHAMED SOHRABI described the Plaintiff as such he is a hypocrite, and


Defendant Ansari described Plaintiff as Wahabi.

89.

This conduct by the Defendants was intended to cause the Plaintiff emotional distress and
was done with reckless disregard of the possibility of causing the Plaintiff emotional
distress.

90.

The Plaintiff suffered severe emotional distress as a result of Defendants outrageous


conduct. The Plaintiff has suffered, and continues to suffer, severe mental distress,
suffering, and anguish as a result of the defendants outrageous conduct. Reacting to his

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discharge with humiliation, embarrassment, anger, disappointment, and worry; all of which
is substantial and enduring.
ELEVENTH CAUSE OF ACTION
(DEFAMATION Against All Defendants)
91.

Plaintiff incorporates by reference as though fully set forth herein, each and every
allegation set forth above in this complaint. As an eight, separate and distinct cause of
action, Plaintiff complains against Defendants as follow:

92.

Plaintiff is informed and believes, and therefore alleges, that Defendants, recklessly and
intentionally caused excessive and unsolicited internal and external publication of
defamation, of and concerning Plaintiff Fouad Saeed Abdulkadir, to the Muslim
community of Cleveland or at least or at least some. These false and defamatory statements
included express and implied accusations that the Plaintiff was incompetent in his work,
profession, knowledge, and that he was engaging in improper and unethical sexual conduct
with community members.

93.

These statements were defamatory per se insofar as they related to Plaintiffs qualifications
in his profession.

94.

While the precise date of these publications are not known to the Plaintiff Fouad Saeed
Abdulkadir, the Plaintiff was informed and believes that these various publications started
in or about October 2015 which has continued to the present, and that it was foreseeable
that they would be re-published by the Defendants and a non-privileged third parties to
whom the Defendants spread the defamatory statements.

95.

During the above described time-frame, the Defendants did negligently, recklessly, and
intentionally cause excessive and unsolicited publication of defamation, of and concerning

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Plaintiff Fouad Saeed Abdulkadir, to a third party who had no need or desire to know. The
third party to whom the Defendants published this defamation are believed to include, but
are not limited to the other Defendants named in this Action, and each of them, as well as
the Doe Defendants.
96.

These defamatory publications consisted or oral, knowingly false and unprivileged


communications, tending directly to injure the Plaintiff and his personal and professional
reputation along with casting him in a false light.

97.

In addition, the Plaintiff has been compelled to self-disclose this false information and
untrue statements. Plaintiff is informed and believes that because of the negligent, reckless,
and intentional publications made by Defendants, and each of them, that it was foreseeable
that these statements would be published and re-published.

98.

Plaintiff is informed and believes and fears that these unprivileged defamatory statements
will continue to be published by the Defendants and will be re-published by their recipients,
all to the ongoing harm an injury to Plaintiffs business, professional, and personal
reputation.

99.

The defamatory meaning of all the above-described, false and defamatory statements and
their reference to the Plaintiff was understood by the Defendants. These statements were
false and were understood as assertion of fact, and not as opinion.

100.

Each of these false defamatory per se publications (as set forth above) were negligently,
recklessly, and intentionally published in a manner equating to malice and abuse of any
alleged conditional privilege. These publications, and each of them, were made with hatred,
ill will, and intent to vex, harass, annoy, and injure the Plaintiff to justify the illegal and
cruel actions of the Defendants. Furthermore, causing damage to the Plaintiffs

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professional and personal reputation, and for the purpose of causing the Plaintiff to be
terminated and subsequent retaliation for the Plaintiff reporting and opposing corruption,
discrimination, and harassment.
101.

Each of these publications by the Defendants had been made with the knowledge that no
investigation supported the unsubstantiated and false statements. The Defendants
published these statements knowing them to be false and unsubstantiated by any reasonable
investigation.

102.

Not only did Defendants have no reasonable basis to believe these statements, but the
Defendants also had no belief in the truth of these statements and, in fact, knew the
statements to be false.

103.

Defendants committed these acts with alleged maliciously, fraudulently, and oppressively,
with the wrongful intent of injuring the Plaintiff, and have acted with an improper and evil
motive amounting to malice, fraud, and conscious disregard of the Plaintiffs rights.
Because these acts taken toward Plaintiff were carried out in a deliberate, cold, callous, and
intentional manner in order to injure and damage the Plaintiff, he is entitled to recover
punitive damages from Defendants in amount according to the proof.
TWELFTH CAUSE OF ACTION

(INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS Against All Defendants)


104.

Plaintiff incorporates by reference as though fully set forth herein, each andvery allegation
set forth above in this Complaint. As a ninth, separate and distinct claim for relief, Plaintiff
complains against Defendants:

105.

This is an action for, among other things, damages, pursuant to the common law of the
State of Ohio.

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106.

Defendants engaged in the outrageous conduct herein above alleged with wanton and
reckless disregard of the probability of causing the Plaintiff to suffer severe emotional
distress.

107.

As approximate result of the extreme and outrageous conduct engaged in by the


Defendants, the Plaintiff suffered humiliation, mental anguish, and extreme emotional and
physical distress. All to his general damage in amount according to proof at trial.

108.

Defendants conduct as herein alleged was malicious and oppressive in that it was conduct
and carried on by the Defendants in a willful and conscious disregard of the Plaintiffs
rights and subjected him to cruel and unjust hardship. Plaintiff is therefore entitled to an
award of punitive damage against the Defendants.

109.

As a direct, foreseeable, and legal result of Defendants unlawful acts, the Plaintiff has
suffered and continues to suffer substantial losses in earnings, bonuses, and other
employment benefits. In addition to expenses incurred for obtaining alternative
employment, the Plaintiff has suffered and continues to suffer humiliation, embarrassment,
severe mental and emotional distress, and discomfort, all to the Plaintiffs damage in an
amount to be proven at trial.

110.

The Plaintiff, individually, incorporates by reference as though full set forth herein, every
allegation set forth above in this Compliant. As a ninth, separate and distinct cause of
action, the Plaintiff complains against the Defendants as follow:
1. Defendants owned the Plaintiff a duty of care not cause him emotional distress.
2. Defendants breached this duty of care by way of their own conduct as alleged
hereinabove.

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3. Defendants conduct starting in 2015 and continuing into the present has caused the
Plaintiff emotional distress.
4. As a proximate result of Defendants extreme and outrageous acts, the Plaintiff has
suffered emotional distress, humiliation, and embarrassment.
5. Defendants conduct has caused and continues to cause the Plaintiff substantial loss of
earning and benefits, cost of legal action, embarrassment, and anguish, all to his
damage in an amount according to proof.
THIRTEENTH CAUSE OF ACTION
(CIVIL CONSPIRACY Against All Defendants)
111.

Plaintiff re-alleges and incorporates herein by reference the preceding


paragraphs, inclusive, as though fully set forth herein.
112.

Starting in or about 2015, Defendants among other began a campaign to knowingly


and willfully conspire and agree amongst themselves to discriminate against
Plaintiff based on his beliefs. The Defendants, and each of them, knowingly and
willfully conspired to permit, facilitate, and cooperate in and/or cover-up the illegal
conduct, including the misconduct of Defendant AHMAD JAMAL.

113.

As a proximate result of the wrongful actions of the Defendants, and each of them,
the Plaintiff has suffered and will continue to suffer harm including but not limited
to lost earnings, wages and employment, humiliation, embarrassment, damages to
his professional reputation, and mental anguish.

114.

The Plaintiff is further informed and believes and on that basis alleges that
Defendants acted and continue to act with full knowledge of the consequences and
damage being caused to the Plaintiff by their actions and that the Defendants

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actions are willful, malicious, and oppressive. Accordingly, the Plaintiff is entitled
to punitive damages in an amount determined by the Jury at trial.

PRAYER FOR RELIEF


Wherefore Plaintiff Fouad Saeed Abdulkadir prays for judgment against the Defendants, and
each of them, as follow:
1. The Defendants Libel per se has caused him irreparable damages in excess of
$ 450,000 [ Four Hundred Fifty thousand dollars] for which he seeks
recompense from the Defendants jointly and severally in this litigation.
2. The untrue defamatory statements made by the Defendants was made with
actual malice and is subject to punitive damages to which he is entitled from
the Defendants jointly and severally in this litigation.
3. For an award of money judgement for mental pain and anguish and severe
emotional distress;
4. For an award of money judgement for defamation per se;
5. For an award of money judgement for libel per se;
6. For declarative and injunctive relief; and
7. For any other relief is just and proper.
Wherefore, Plaintiff Fouad Saeed Abdulkadir demands compensatory damages of at least
$450,000.00 [ Four hundred Fifty thousand dollars] and punitive damages atop compensatory
damages in an amount deemed just, along with costs and such other and further relief as justice
requires.

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JURY TRIAL DEMAND


Pursuant to Fed. R. Civ Proc. 38, Plaintiff in above captioned matter demands a trial by jury of all
issues in this matter and respectfully requests this matter to be placed on the jury docket.

DATED: August 22, 2016

Fouad Saeed Abdulkadir

_________________________
Fouad Saeed Abdulakdir
11490 Bobko Blvd, Parma
OHIO 44130
fouad.saeed@gamil.com
+1 (510) 394-7574

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