ex. 2 to ex. a

EXHIBIT 2

Case 1:09-cv-02030-CKK Document 154-3 Filed 05/19/13 of 33

COUNCIL ON AMERICAN-ISLAMIC RELATIONS ACTION NETWORK, INC., ET AL. v. GAUBATZ,

ET AL.

NIHAD AWAD HAMMAD

January 9, 2013

Prepared for you by

Bingham Farms/Southfield • Grand RapidsAnn Arbor • Detroit • Flint • Jackson • Lansing • Mt. Clemens • Saginaw


NIHAD AWAD HAMMADJanuary 9, 2013

Page 1


Page 1

1 UNITED STATES DISTRICT COURT

2 FOR THE DISTRICT OF COLUMBIA

3 - - - - - - - - - - - - - - - - -x

4 COUNCIL ON AMERICAN-ISLAMIC : Civil Action No.

5 RELATIONS ACTION NETWORK, INC., : 09-cv-2030 (CKK-JMF)

6 et al., :

7 Plaintiffs, : Judge Colleen

8 v. : Kollar-Kotelly

9 PAUL DAVID GAUBATZ, et al., :

10 Defendants. :

11 - - - - - - - - - - - - - - - - -x

12

13 Deposition of NIHAD AWAD HAMMAD

14 Washington, DC

15 Wednesday, January 9, 2013

16 10:04 a.m.

17

18

19

20

21

22

23

24 Pages: 1 - 162

25 Reported By: Lee Bursten, RMR, CRR



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1 Deposition of NIHAD AWAD HAMMAD, held at

2 the offices of:

3

4

5 CENTER FOR SECURITY POLICY

6 1901 Pennsylvania Avenue, NW

7 Suite 201

8 Washington, DC 20006

9 (202) 379-4960

10

11

12 Pursuant to notice, before Lee Bursten,

13 Registered Merit Reporter, Certified Realtime

14 Reporter, and Notary Public in and for the District

15 of Columbia, who officiated in administering the oath

16 to the witness.

17

18

19

20

21

22

23

24

25



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1 A P P E A R A N C E S

2 ON BEHALF OF PLAINTIFFS AND THE WITNESS:

3 GADEIR ABBAS, ESQUIRE

4 NADHIRA AL-KHALILI, ESQUIRE

5 COUNCIL ON AMERICAN-ISLAMIC RELATIONS

6 453 New Jersey Avenue, SE


8 (202) 742-6033

9

10 ON BEHALF OF DAVID YERUSHALMI, SOCIETY OF AMERICANS

11 FOR NATIONAL EXISTENCE, AND THE CSP DEFENDANTS:

12 ROBERT J. MUISE, ESQUIRE

13 AMERICAN FREEDOM LAW CENTER

14 P.O. Box 131098

15 Ann Arbor, Michigan 48113

16 (734) 635-3756

17 (Present via telephone)

18

19 ON BEHALF OF THE CSP DEFENDANTS:

20 DAVID YERUSHALMI, ESQUIRE

21 CENTER FOR SECURITY POLICY

22 1901 Pennsylvania Avenue, NW

23 Suite 201


25 (202) 379-4960



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1 A P P E A R A N C E S C O N T I N U E D

2 ON BEHALF OF THE GAUBATZ DEFENDANTS:

3 DANIEL HOROWITZ, ESQUIRE

4 LAW OFFICE OF DANIEL HOROWITZ

5 P.O. Box 1547

6 Lafayette, California 94549

7 (925) 283-1863

8

9 MARTIN GARBUS, ESQUIRE

10 LAW OFFICE OF MARTIN GARBUS

11 3 Park Avenue

12 16th Floor

13 New York, New York 10016

14 (212) 561-3625

15

16 ALSO PRESENT:

17 CHRIS ALLEN GAUBATZ

18

19

20

21

22

23

24

25



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1 C O N T E N T S

2 EXAMINATION OF NIHAD AWAD HAMMAD PAGE

3 By Mr. Yerushalmi 39

4 By Mr. Horowitz 116

5

6

7 E X H I B I T S

8 (Retained by counsel.)

9 CSP DEPOSITION EXHIBITS PAGE

10 Exhibit 10 Excerpt from Boim versus Quranic 126

11 Literacy Institute deposition

12 transcript

13 Exhibit 11 Screenshot of CAIR website 128

14

15

16

17

18

19

20

21

22

23

24

25



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9 Q Is there any reason I should not be taking

10 your deposition today? For example, are you under

11 medication, under the influence of any drug or

12 alcohol or suffering from any mental disease or

13 defect?

14 A No.

15 Q And that's just a formal question, it

16 appears to me you're lucid and coherent. What is

17 your formal legal name?

18 A Nihad Awad Hammad.

19 Q And as I was beginning to ask you, I note

20 that on many legal documents and also publicly, you

21 represent yourself as Nihad Awad, correct?

22 A Yes.

23 Q Why do you use that shorter name as opposed

24 to your legal name, for example on legal documents?

25 A It's a cultural thing.



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3 Q Mr. Awad, I have placed before you what has

4 been marked as CSP Depo Exhibit Number 6. You'll

5 notice that at the top of every page, if you open

6 that three-ring binder, you will see a Bates number,

7 as we call them. You can ignore the prefixes and go

8 to the last Arabic numerals. Do you see those? So

9 at the very top of the page, I'm now pointing to your

10 first page. You see this Bates 1265?

11 A Yes.

12 Q And so when I refer to a page number or if

13 I might say Bates number, that's the number I'm

14 referring to, not to any other page number that might

15 appear on the document. Is that agreeable?

16 A Okay.

17 Q And every page of Exhibit 6 has a Bates

18 number. They run consecutively. Okay?

19 A Okay.

20 Q I'm going to ask you to turn to Bates 1393

21 of Exhibit 6.

22 A This one?

23 Q Yes. This is a certificate from the

24 government of the District of Columbia identifying

25 the Council on American-Islamic Relations Action



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1 Network Inc. Do you see that?

2 A Yes.

3 Q And do you see that it states that the date

4 of incorporation was the 15th day of September, 1994?

5 A Yes.

6 Q Now, in fact, when -- let's do something

7 else for a minute. You're currently the executive

8 director of the Council on American-Islamic

9 Relations?

10 A Yes.

11 Q Otherwise known as CAIR, correct?

12 A Yes.

13 Q Now, when you -- strike that. You were one

14 of the founding members of CAIR, correct?

15 A Yes.

16 Q In fact, you were one of the founding

17 incorporators of CAIR, correct?

18 A Yes.

19 Q And you founded CAIR in 1994?

20 A Correct.

21 Q And in 1994, it wasn't referred to as the

22 Council on American-Islamic Relations Action Network

23 Inc.; it was just referred to as the Council on

24 American-Islamic Relations, Inc., correct?

25 A I can't remember.



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1 Q You have been the executive director of

2 CAIR that was founded in 1994 from its inception to

3 today?

4 A Yes.

5 Q You also serve on the board of directors at

6 CAIR?

7 A Yes.

8 Q When I use the word "CAIR," I'm referring

9 to this entity that was created in 1994 for which

10 you've served as the executive director from its

11 inception until today. Okay?

12 A Yes.

13 Q If I use a different name, for example, the


15 Inc., I'm referring to that specific entity, okay?

16 A Okay.

17 Q And if I refer to CAIR Foundation Inc., I'm

18 referring to a separate entity. Okay?

19 A Okay.

20 Q What do you understand to be the difference

21 between the Council on American-Islamic Relations

22 Inc. -- CAIR -- and the Council on American-Islamic

23 Relations Action Network Inc.?

24 A I don't know.

25 Q I'm sorry?



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1 A I don't know.

2 Q You don't know the difference between the

3 two?

4 A Yes.

5 Q And do you know the difference between the


7 Inc. and CAIR Foundation Inc.?

8 A Almost.

9 Q Before we go to the "almost," let me ask

10 you, what do you understand the Council on

11 American-Islamic Relations Action Network Inc. to be?

12 A Well, over the years, the organization was

13 just at the beginning, one name. Then the board met

14 and changed names and did different registration. So

15 I don't recall the similarities or differences

16 between the organizations. All I know now is we have

17 I believe CAIR Foundation and CAIR Action Network.

18 Q So let's shorten the names, as you just

19 have, I think that's a good use. If we say CAIR

20 Action Network, we're going to be referring to the


22 Inc., agreeable?

23 A Okay.

24 Q And that is the organization you just

25 described as CAIR Action Network, correct?



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1 A Yes.

2 Q And if we refer to CAIR Foundation, we're

3 referring to CAIR Foundation Inc.?

4 A Okay.

5 Q Is that agreeable?

6 A That's fine.

7 Q Now, you indicated that when you

8 incorporated CAIR Inc., and again, that's our

9 shorthand for the Council on American-Islamic

10 Relations Inc., correct?

11 A Okay.

12 Q And that was the organization that you

13 began in 1994, correct?

14 A Yes.

15 Q And you recall that being its name,

16 correct?

17 A Yes.

18 Q At some point in time, that organization's

19 board changed its name; is that what you understand

20 to have taken place?

21 A Vaguely. My memory is vague.

22 Q So you're not sure whether they changed the

23 name of CAIR Inc. or whether they just started a new

24 organization called CAIR Action Network?

25 A Well, the board met several times with



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1 different lawyers. And I'm not privy to the exact

2 language that was used at the time. It's been maybe

3 quite some time.

4 Q And just to be clear, I understand you're

5 not an attorney. Are you?

6 A No.

7 Q And so I'm not asking for any legal

8 opinion. I'm simply asking for your understanding

9 and your knowledge. And that's all I will ask for

10 the entire day. Okay?

11 A Okay.

12 Q I'll take CSP Exhibit 6 back for just a

13 moment. I'm going to hand you what's been marked as

14 CSP Deposition Exhibit 5. If you would open that

15 three-ring binder to the first page, which is Bates

16 1217. Do you see the Bates stamp at the very top?

17 A Yes.

18 Q Now, in addition, there is a second group

19 of documents. Let me just for the record, and I

20 already indicated when we were talking about all the

21 exhibits, these documents were provided to us by your

22 counsel, Mr. Abbas, yesterday, as an additional

23 production in this case. And I'm looking at a Form

24 1120 dated 2010 on Bates 1217. Do you see that?

25 A Yes.



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1 Q And do you see the name of the filer on

2 this particular IRS document, Council on

3 American-Islamic Relations Inc.?

4 A Yes.

5 Q And you see at the bottom of this page that

6 the date of the preparation is 9/16, 2012?

7 A Yes.

8 Q If I ask you to turn your attention to the

9 box on the form labeled B as in boy, it's right

10 underneath the 2010 top right. Do you see that?

11 A Which one?

12 Q The box labeled B. And it has a number for

13 the employer identification number 04-3617757.

14 A This one. Okay.

15 Q Do you see that?

16 A Yes.

17 Q Are you familiar with CAIR Inc.'s employer

18 identification number?

19 A No.

20 Q Are you familiar with CAIR Action Network's

21 employer identification number?

22 A No.

23 Q So that number doesn't mean anything to

24 you?

25 A No.



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1 Q Now, if you turn your attention to the

2 bottom of the page, do you see where it has a

3 signature line and it has a printed box, "Sign here"?

4 A Yes.

5 Q And then if you follow that signature line

6 across, you see that there's a place for signature, a

7 date, and it identifies the signor as a director. Do

8 you see that?

9 A Yes.

10 Q Are you still a director of CAIR Inc.?

11 A Yes.

12 Q And would you be the one that would sign

13 this IRS filing?

14 A After the CPA prepares it.

15 Q Have you seen this document before? And in

16 fact, it consists of several pages, and you can flip

17 through it if it would help, through Bates 1239.

18 That would be the end of that Form 1120.

19 A Okay. So...

20 Q Are you familiar with that document?


22 Q Do you recall signing this document?

23 A I have to see if I did.

24 Q But you don't recall sitting here today

25 whether you signed it or not?



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1 A Well, I sign documents when we send them to

2 the IRS, but I need to see the actual one to see if I

3 did or not.

4 Q I understand. I'm simply asking, do you

5 recall today having signed the document?

6 A I have to see if I did or not.

7 Q Right. Meaning that you don't recall

8 sitting here, without the document in front of you,

9 signed --

10 A Yes.

11 Q -- whether you signed it or not?

12 A Yes. I can't tell you.

13 Q Again --

14 A Unless I see the actual document.

15 Q Okay. Again, I'll ask both of us to slow

16 down. Let me finish my question and then when you

17 respond, okay?

18 A Sure.

19 Q At the bottom of Bates 1217, the first page

20 of this document, at the bottom of the page, it says,

21 "Paid preparer use only," and there's a name, G. F.

22 Joey Musmar CPA of Miller Musmar PC. Do you see

23 that?

24 A Yes.

25 Q Do you know who that individual and that



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1 firm are?

2 A Yes.

3 Q Who are they?

4 A A CPA who work with us on office filings.

5 Q And sitting here today, do you understand

6 what this filing is for?

7 A It says "US Corporation Income Tax Return,

8 2010."

9 Q And it's for the Council on

10 American-Islamic Relations Inc., correct?

11 A Yes.

12 Q And that is the organization that you

13 founded and for which you serve as the executive

14 director?

15 A Yes.

16 Q Are you paid for your services as an

17 executive director of CAIR Inc.?

18 A Yes.

19 Q And have you been paid for your services

20 throughout CAIR Inc.'s existence?

21 A Yes.

22 Q Now, we talked a little bit earlier about

23 CAIR Action Network and CAIR Foundation, correct?

24 A Yes.

25 Q And you had some idea about the distinction



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1 between those two entities. Would you tell me what

2 you understand to be the difference between those two

3 entities?

4 A No, I cannot tell you exactly.

5 Q Do you serve in any official capacity for

6 CAIR Action Network?

7 A I think I'm a board member.

8 Q A board member. Are you executive director

9 or an officer of that company?

10 A I'm executive director of CAIR Foundation.

11 Q So you serve as the executive director of

12 CAIR Inc. and of CAIR Foundation?

13 A CAIR Foundation.

14 Q Did you not testify earlier that you serve

15 as the executive director of CAIR Inc.?

16 A No, I said CAIR Foundation.

17 Q Okay. So again, looking --

18 A I told you that -- are you done?

19 Q Please.

20 A The names have changed over the years. And

21 I'm not privy to the exact distinction between the

22 various organizations. I serve in my capacity as

23 executive director of CAIR Foundation. And I have a

24 good understanding of what this organization is.

25 Q I didn't hear the last part.



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1 A I have a good idea of that organization,

2 what that represents, and my capacity in that

3 organization.

4 Q I direct your attention again to the first

5 page of CSP Depo Exhibit 5. And we were talking

6 about the Council on American-Islamic Relations Inc.

7 Form 1120 2010 filing. Do you see that?

8 A This one?

9 Q Yes.

10 A Yes.

11 Q And I asked you if you were the executive

12 director of this organization. And your answer was

13 yes. Is your answer now that you are not the

14 executive director of the Council on American-Islamic

15 Relations Inc.?

16 A Okay. I think you're confusing me.

17 Q And I don't mean to.

18 A Okay.

19 Q So let's start over.

20 A Okay.

21 Q What is your relationship to the Council on

22 American-Islamic Relations Inc., the organization

23 that filed this Form 1120 in the year 2010, which is

24 CSP Depo Exhibit 5, Bates number 1217?

25 MR. ABBAS: Objection, mischaracterizes the



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1 document.

2 BY MR. YERUSHALMI:

3 Q Go ahead.

4 A You asked -- you gave me a document. It

5 doesn't have my signature. Do you have the original

6 document where I can verify?

7 Q Well, that would be an interesting

8 question. This is the document that your attorneys

9 provided to us yesterday.

10 A Okay.

11 Q As the most recent filings of the Council

12 on American-Islamic Relations Inc. And I'm simply

13 asking you what your relationship is to this

14 organization, the Council on American-Islamic

15 Relations Inc. Now, if you don't know, you don't

16 know. It's not a trick question.

17 A It does not have my name here.

18 Q Right.

19 A So if I have my name, I will have better

20 memory to answer your question more correctly.

21 Q Okay. Now, you do recognize that CPA firm

22 we just looked at at the bottom, Miller Musmar PC.

23 A Yes.

24 Q And they are the accounting firm for which

25 organization?



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1 A I think they do filing, in my

2 understanding, for the entities that -- under the

3 auspices of the organization.

4 Q And to the best of your understanding, what

5 are those organizations that are under the auspices

6 of CAIR?

7 A I do not have exact description of those

8 organizations. But I know that this CPA that you

9 mentioned does accounting for the organizations that

10 we are involved in.

11 Q Now, I don't want exact descriptions. I

12 just want the name of those organizations that fall

13 under the auspices of CAIR.

14 A You mentioned several names for me. And

15 it's confusing. So I speak to the Court now. So if

16 I do not know exactly, I should not tell you

17 something I'm not 100 percent sure.

18 Q That's absolutely correct.

19 A Yes.

20 Q And so the answers to various questions can

21 be a substantive answer if you know, if it requires a

22 specific answer. It can be a yes if it's a yes-no

23 question. It can be a no. And it can be I don't

24 know. Correct?

25 A Yes.



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1 Q So do you know the names of any

2 organizations "under the auspices of CAIR"?

3 A I know that I work for CAIR Foundation.

4 Q Is there a name of any other organization

5 under the auspices of CAIR?

6 A I think our attorneys have a better grasp

7 of those entities. And since I'm speaking to the

8 Court, I will not be accurate if I give you a

9 different answer than what I gave you.

10 Q Is CAIR Foundation Inc. under the auspices

11 of CAIR?

12 A We have been using the CAIR name in

13 different capacities now from the beginning of this

14 deposition, so do you mean "CAIR" equals CAIR

15 Foundation, in your question to me?

16 Q No. Let's define -- and to be clear, it

17 was your term, "under the auspices of CAIR." So

18 let's just put that aside for now.

19 A Maybe that wasn't accurate.

20 Q And sometimes my questions aren't accurate

21 as well, and the record will make that clear at the

22 end of the day. So let's step back for a moment.

23 And you see the address on this Form 1120, 453 New

24 Jersey Avenue, Southeast, Washington, DC, 20003?

25 A 453 New Jersey Avenue, Southeast, yes.



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1 Q Are those the offices of the organization

2 CAIR, C-A-I-R?

3 A Yes.

4 Q Are those the offices of the organization

5 you sometimes refer to as CAIR National?

6 A Yes.

7 Q When you use the word "CAIR" alone and

8 "CAIR National," are you referring to the same

9 organization?

10 A Yes. The organization I work with, which

11 is CAIR Foundation. And sometimes people refer to it

12 CAIR, and sometimes they refer to it CAIR National.

13 Q So you refer to CAIR or CAIR National --

14 strike that. When you refer to CAIR or CAIR

15 National, you're referring to CAIR Foundation Inc.?

16 A The organization I work for.

17 Q Are there any other organizations related

18 to CAIR Foundation Inc. that exist at that address,

19 453 New Jersey Avenue, Southeast, Washington, DC,

20 20003?

21 A That's a technical question. And I think

22 our lawyers would have a better description and

23 ability to answer that.

24 Q Do you know of any organizations associated

25 or related to CAIR in any way, shape, or form that



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1 operate out of those offices?

2 A No.

3 Q You have testified that you are the current

4 executive director of CAIR Foundation, correct?

5 A Yes.

6 Q And how long have you been the executive

7 director of CAIR Foundation?

8 A Since it was registered.

9 Q And when was it registered?

10 A I don't recall exactly.

11 Q Would it be approximately 1994?

12 A Well, from the beginning of the deposition,

13 we said that I was one of the incorporators of the

14 name you mentioned to me. Then CAIR Foundation

15 probably took this name at a later date. I do not

16 have that date.

17 Q Is it your understanding that CAIR

18 Foundation is a successor entity to whatever that

19 organization was in 1994?

20 MR. ABBAS: Objection, vague as to what

21 "successor entity" means.

22 A I do not understand your question.


24 Q Fair enough. I'm going to take CSP

25 Deposition Exhibit 5 back. And I'm going to put



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1 before you again CSP Deposition Exhibit 6. And I'm

2 going to ask you to turn to Bates 1394. Mr. Awad,

3 are you at Bates 1394 of CSP Deposition Exhibit 6?

4 This number at the top. Do you see that?

5 A Yes.

6 Q This is a certificate from the government

7 of the District of Columbia. And it reads as

8 follows: "This is to certify that all applicable

9 provisions of the District of Columbia Nonprofit

10 Corporation Act have been complied with and

11 accordingly this certificate of incorporation is

12 hereby issued to Council on American-Islamic

13 Relations Inc. as of September 15th, 1994."

14 Do you see that?

15 A Yes.

16 Q Did you have anything to do with the

17 founding of the Council on American-Islamic Relations

18 Inc. on September 15th, 1994?

19 A Yes.

20 Q And what was your involvement in 1994

21 post-September 15th with the Council on


23 A I believe I was one of the incorporators,

24 if I'm not mistaken.

25 Q Other than being an incorporator, did you



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1 have any other role?


3 Q And subsequently, to today, have you had

4 any relationship or association with the Council on


6 A I just needed to know if -- what you mean

7 by any role besides my being an incorporator.

8 Q Fair enough. Did you serve on the board of

9 directors at any time from September 15, 1994 until

10 today, on the Council on American-Islamic Relations

11 Inc.?

12 A It's been 19 years, so I don't have exact

13 memory of how these evolved over time.

14 Q But my question was from 1994 to the

15 present. So it includes very recent memory. So I'll

16 ask it again.

17 A I --

18 Q One second, Mr. Awad. So I will ask it

19 again. Have you served on the board at any time from

20 September 15th, 1994, until today, on the Council on


22 A I served as a member of the board on

23 Council on American-Islamic Relations, abbreviated

24 with CAIR, since the beginning, 1994.

25 Q When you say "abbreviated with CAIR," what



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1 does that mean?

2 A Because the organization's acronym is CAIR,

3 C-A-I-R. Now, the variations of the names as we have

4 been saying since the beginning of the deposition

5 varies. It's confusing. And I'm not an attorney.

6 So just my affiliation with the organization is being

7 an executive director of CAIR.

8 Those names have changed over the time.

9 There have been some registration and reregistration.

10 I'm not privy to the details of the variations of the

11 names, if any.

12 Q And that's a perfectly legitimate answer.

13 Thank you.

14 A Okay.

15 Q I would have you turn to the next page,

16 Bates 1395, of CSP Depo Exhibit 6. And you will see

17 that this document represents the articles of

18 incorporation that were filed on September 15, 1994

19 of the Council on American-Islamic Relations Inc. in

20 the District of Columbia. And this document runs

21 through Bates 1399.

22 Are you familiar with this document,

23 Mr. Awad?

24 A It's been a long time.

25 Q I understand that. My question is, are you



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1 familiar with this document?

2 A Yes.

3 Q Let me --

4 A Qualifying also my answer, it's been a long

5 time.

6 Q It has been. And for those of us long of

7 tooth, it's an even longer period of time.

8 A Right.

9 Q Let me ask you to turn to Bates 1398 of

10 Exhibit 6. Are you there, Mr. Awad?

11 A Yes, sir.

12 Q You see under article IX, a listing of the

13 directors of the Council on American-Islamic

14 Relations Inc. which is also referred to as CAIR?

15 A Yes.

16 Q Could you read those names that are listed

17 there, please.

18 A From the top?

19 Q From the top.

20 A Rafeeq, R-A-F-E-E-Q, J-A-B-E-R.

21 Q Let me just repeat for the record so

22 everybody can hear. Rafeeq Jaber, R-A-F-E-E-Q,

23 J-A-B-E-R. Correct?

24 A Yes.

25 Q And do you know a Rafeeq Jaber?



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1 A Yes.

2 Q And do you recall him serving on the


4 Relations in 1994?

5 A Yes.

6 Q And would you read the next name, please.

7 A Omar Ahmad.

8 Q And again for the record, that's spelled

9 O-M-A-R, last name A-H-M-A-D; is that correct?

10 A Yes.

11 Q And do you recall Mr. Ahmad serving on the

12 board of directors of the Council on American-Islamic

13 Relations Inc. in 1994?

14 A Yes.

15 Q And do you know a Mr. Omar Ahmad?

16 A Yes.

17 Q And the last name, please.

18 A Nehad Hammad.

19 Q And that's spelled N-E-H-A-D, H-A-M-M-A-D,

20 correct?

21 A Correct.

22 Q And would that be you?

23 A Yes.

24 Q And do you recall serving on the board of




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1 Relations Inc. in 1994?

2 A Yes.

3 Q I would like you, on the same page, to

4 focus your attention to article X. That's Bates 1398

5 of Exhibit 6. Can you read the names of the initial

6 incorporators, please.

7 A Rafeeq Jaber.

8 Q And was that the same Rafeeq Jaber that we

9 saw above as a board member?

10 A It looks like it.

11 Q In fact, it's the same address, correct?

12 A It looks like it.

13 Q And the next name on the list of initial

14 incorporators, please?

15 A Omar Ahmad.

16 Q And do you know if that's the same Omar

17 Ahmad that's listed as a board member?

18 A I believe so.

19 Q Do you recall that Mr. Jaber and Mr. Ahmad

20 were your co-incorporators in 1994?

21 A Yes.

22 Q And of course, the last name under article

23 X is your name, correct?

24 A Yes.

25 Q So the three of you gentlemen served as the



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1 initial incorporators and also the initial board

2 members, correct?

3 A Correct.

4 Q Were there any other board members that you

5 can recall?

6 A No, I can't recall.

7 Q If you turn to the next page, just for the

8 record, Bates 1399 of CSP Depo Exhibit Number 6, you

9 see the signatures of all three of you gentlemen, and

10 they're all notarized. Do you see that?

11 A Yes.

12 Q Does that appear to be your signature under

13 the "Nehad Hammad" signature line or above it?

14 A Yes.

15 Q Now, I'm interested in Mr. Ahmad, Omar

16 Ahmad, who served with you as a co-incorporator and

17 co-board member for CAIR Inc. or Council on

18 American-Islamic Relations Inc. And if I say "CAIR"

19 or "CAIR Inc.," we're referring to this organization

20 that we have been looking at now, the Council on

21 American-Islamic Relations Inc., incorporated in

22 1994. Is that agreeable?



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3 Q Other than serving as a board member and as

4 the initial incorporator of CAIR Inc., did you have

5 any other role over the years with CAIR Inc.?

6 A As I said, I have been the founding

7 executive director of CAIR from day one until now.

8 Q Until now?

9 A Yes.

10 Q Now, Mr. Omar Ahmad served as an initial

11 board member with you in CAIR Inc., the Council on

12 American-Islamic Relations Inc., and as a

13 co-incorporator. How long was Mr. Ahmad involved

14 with CAIR Inc.?

15 MR. ABBAS: Objection, relevance.


17 Q Go ahead and answer.

18 A For a number of years.

19 Q Do you recall when his relationship ended?

20 A I can't exactly remember the date; but yes,

21 it ended years ago.

22


ex. 2 to ex. a

Documents

nihad awad hammadjanuary

ckk document

n c e s2

n c e s c o n t i n

csp defendants

gaubatz defendants

behalf of david yerushalmi

behalf of plaintiffs