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UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x BARBARA HANDSCHU, et al., -against- Plaintiffs 71 Civ. 2203 (CSH) Declaration ofbernard Haykel SPECIAL SERVICES DIVISION, a/k/a Bureau of Special Services, et al. Defendants BERNARD HAYKEL declares under the terms of28 USC sec. 1746: 1. My name is Bernard Haykel and I am a full professor with tenure ofnear Eastern Studies at Princeton University where I teach courses and conduct research on Islamic law, Islamic political movements and the modern politics ofthe Middle East. I have studied Islamic fundamentalist movements since 1989, having conducted fieldwork in Lebanon, Yemen, Saudi Arabia, Jordan and India. I was a Fulbright Scholar in Yemen (1992-93) and have since returned to the Middle East and South Asia on a yearly basis. My doctoral dissertation, for which I received my Ph.D. from the University ofoxford in England, focuses on the life and work ofthe one ofthe most important modern Islamic fundamentalist thinkers, the scholar Muhammad al- Shawkani. Aside from writing numerous articles in refereed journals in my field as well as two books, I have since 9/11 advised the office ofprime Minister Tony Blair as well as the CIA and other US government agencies on how to conduct the war on terrorism and on how to understand and defeat the ideology ofal-qaeda.

2. I have been asked by plaintiffs' counsel to comment on various Islamic ideologies and groupsand will do so belowconcerning those with whichi am familiar. I list each ideology or group and providea summary of what I know about it. 3. Salafism and Salafis: Salafism refers to a particular Islamic theology that is literalist in its interpretation of the text of Islamic revelation, which are the Koranand the traditions of sayings and deeds of the Prophet Muhammad. Persons who adhere to Salafism's theology are referred to as Salafis. These seek to live life as closely as possible as they think the Prophet Muhammad and his companions did, and tend to vilify Muslims who disagree with their interpretation of Islam. In particular they target for abuse Shii and Sufi Muslims because they consider these groups to have erred from the original message of Islam. In political terms, Salafis are divided along a broad spectrum ofgroups. On one end ofthis spectrum are the quietistor non-political Salafis who shun formal and organized politicson principle. They refuse to vote or to adhere to political partiesfor example. In the middle of the spectrum are politically active Salafis who seek to influence politics by participating in non-violent processes that would lead them into positions of power. On the other end of the spectrum are violent activist Salafis who believe that only through violence can their vision ofsociety be instituted and accomplished. The violent Salafis, aka Salafi-Jihadis are a numerical minority, and amongst these one can count such groups as Al-Qaeda and its various affiliates. The violence that Al-Qaeda has inflicted, especially on other Muslims, has made this group unpopular with other Muslims. 4. Wahhabism and Wahhabi: Wahhabism is an Islamic ideology that subscribes to the views and teachings of an Arabian religious reformer called Muhammad ibn Abd al-wahhab (d. 1792). This reformer's ideas are rooted in Salafi theology and his writings form the basis ofthe

reigning political and religious ideology of the Kingdom of Saudi Arabia today. A Wahhabi is a follower ofwahhabism. A majority ofwahhabis are non-political or quietist. Strict Wahhabis are intolerant ofother non-wahhabi Muslims, thinkingthem to be in error, and often are unfriendly to non-muslim personsand non-muslim ideas and practices. Traditional Wahhabis, such as the scholars in the employ of Saudi Arabia, are against the Salafis who are engaged in politics and consider Al-Qaeda to constitute a deviant ideology that should be fought. One consequence ofthis is that Al-Qaeda's followers have been either killed or imprisoned in Saudi Arabia. 5. The Council on American Islamic Relations (CAIR): an American civil rights organization that was founded in 1994 and that is concerned with Muslim affairs in the US and Canada. CAIR is not known to have been involved with any terrorist group or to advocate ideologies associated with such groups as Al-Qaeda or the Muslim Brotherhood. 6. Islamic Circle ofnorth America (ICNA): an American Muslim organization that is concerned with the welfare and betterment ofmuslims in the US and with the propagation ofislam in America. It is dominated by Muslims of South Asian descent and organizes annual conferences around the country. 7. Sayyid Qutb: An influential Egyptian ideologue ofthe Muslim Brotherhood. He was sentenced and executed by the government of Egypt in 1966 and his teachings, which have a radical edge against non-muslim governments and peoples, have been appropriated and invoked by radical groups, including Al-Qaeda. 8. Muslim Brotherhood (MB): The Muslim Brotherhood is a transnational Islamist political and social organization, centered on Egypt but maintains a loose affiliation with sister organizations in othercountries throughout the world. It has formally renounced violence in Egypt

and Tunisia and is formally active in politics in both countries. The president ofegypt today belongs to this movement. In the past, the MB was persecuted by nationalist governments and it has gone from advocating a more radical ideology to one that seeks political change through gradual and non-violent means. The MB competes politically and ideologically with Salafis. 9. Hamas: This is the branch ofthe Muslim Brotherhood in the Palestinian territories and since 2006 has ruled the Gaza strip. Hamas refuses to recognize Israel and seeks to re-conquer all ofhistoric Palestine. It is committed to armed struggle as the method for accomplishing this. It has offered Israel 10-year truce periods. Hamas has confined its military activities to Israel and the Palestinian territories and is not known to have engaged in any violent acts outside this area. It is politically active in other countries and some of its leaders are based overseas. 10. Palestinian Islamic Jihad (PIJ): a small Palestinian militant organization that has been supported by the Islamic Republic of Iran and Hezbollah in Lebanon. It is committed to violent struggle against Israel and to its elimination. The US government considers PIJ a terrorist organization. 11. World Assembly ofmuslim Youth (WAMY): a non-governmental organization that is modeled on the YMCA and funded largely by the government ofsaudi Arabia and is headquartered in Riyadh, Saudi Arabia. This organization is focused on organizing Muslim youth activities and the propagation of Sunni Islamic values and teachings amongst them. There have been reports that WAMY had been involved in the funding of violent Jihadi activities and causes, but these remain unsubstantiated. WAMY has been supportive ofcauses that involve attacks on Muslims or some form ofdiscrimination against them, such as in Bosnia, Chechnya, the Philippines, but it is not evidentthat the support for these has involved more than humanitarian aid

and political advocacy. Since 9/11, the Saudi government has monitored WAMY closely to make certain that it is not involved in any way in the support ofgroups such as Al-Qaeda. 12. Muslim World League (MWL): This is a non-governmental organization that was established in 1962 under the aegis of the government of Saudi Arabia, which still largely funds its activities. The MWL was created to help fight against Pan-Arab nationalism and socialism and has since become an instrument of pan-islamicsolidarity, benevolentaction and legal standardization as well as helping the missionof propagating Islam around the world. The MWL has observer status at the UN and has since 9/11 been closely monitored by the Saudi government to ascertain that it is not involved in the support of violent jihadi groups, ideologies or activities. 13. Muslim American Society (MAS): This is a nonprofit organization that was founded in 1993 and appearsto be the formal face of the Muslim Brotherhood organization in the United States. MAS has been involved in educational activities among US Muslims and has tried to organize the community but I am not aware that it has been involved in any violent or terror activity in the United States. 14. Salafi Society of North America: an organization that adheres to Salafi teachings and has a presence in one mosque in Brooklyn. 15. Tablighi Jamaat (TJ): A transnational Islamic movement that seeks to reform Islam at a grassroots level through greater adherence to the obligations of the faith (e.g., prayer, fasting etc.). It was founded in India in 1926and has a large following in South Asia. The movement has maintained an apolitical stance and has shunned intra-muslim disputes. It can be compared to the Chabad movement in Judaism and is often the entry point for many Muslims seeking to become more practicing adherents ofthe faith.

16. Hizb al-tahrir (HT): A transnational Sunni Muslim organization founded in 1953 by Taqi ul-din al-nabhani and committed to thecreation of a unitary Islamic state, called the Caliphate. This state will erase all existing national borders, uniting Muslims under the leadership of a single leader called the caliph. It is not clear whether this movement advocates violent struggle (jihad) as a means for attaining its ultimate goal. It has followers in many countries and has been active in the United Kingdom and in Central Asia. 17. Islamic Thinkers Society (ITS): A Muslim group based in the NY metropolitan region that seeks to establish the Caliphate, a unitary, global Muslim state that is ruled in accordance with Islamic law. The ITS appears to be a group that follows the teachings of the Hizb al-tahrirmovement and founder, and its method for spreading its teachings and ideology is through preaching and proselytism. 18. Dar ut Tawheed or TawheedNYC.com: a group that is committed to Salafi teachings. Its online materials offera selection of texts and videos that are Salafi in orientation. Some ofthe materials are shared by Salafi Jihadis, but this is not necessarily indicative that this group is jihadi in orientation. 19. Al-Muhajiroun: a British-based Islamist organization that has been banned by the British government for promoting and praising terrorist activity, including the 9/11 attack. Al- Muhajiroun is a splinter group that shares many of Hizb al-tahrir's ideology suchas calling for the establishment of the Caliphate (a unitary Islamic state). Al-Muhajiroun have also been accused of anti-semitism and for helping British Muslimsjoin militant groups in Chechnya and other locations. 20. Islam Chatra Shibir: A student political organization in Bangladesh that is

associated with the Jamaat-e-Islami movement, seeking to establish an Islamic state based on Islamic law. 21. Lashkar-e-Taiba: A Pakistani terrorist organization that has the backing of the Pakistani government and its intelligence service. Founded in 1990, it has been involved in numerous terroristattacks on India. Its statedobjective is to liberate in Indian-ruled Kashmirand to establish an Islamic state in South Asia. 22. Sipah-e-Sahaba: A Pakistani Islamist and terrorist organization that has been banned in Pakistan. Its principal aim is to attack the Shiisin Pakistan and to establish a Sunni Islamic state in Pakistan and to restore the caliphate. 23. Hezbollah: A Shiite Islamic movement and political party in Lebanon and a proxy of Iran's. Hezbollahis a militant organization that has fought Israel during its occupation of Lebanon and is committed to Israel's destruction. It has on occasion been involved in violent terror acts outside the local arena oflebanon and Israel and there are widespread allegations that Hezbollah has sleeper cells in the US. Some of its sympathizers have been accused and sentenced for raising funds illegally in the US. The US government considers Hezbollah a terrorist organization. 24. Jamaat-e-Islami (JI): A Pakistani political organization that seeks to create an Islamic state ruled in accordance with Islamic law. Its founder is Abu ATa Maududi, an ideologue whose ideas underpin the JI's political program. This is a vanguard party, similar to the Muslim Brotherhood and committed to similar goals. 25. The Islamic Organization of North American: An American organizationthat is South Asian in leadership and origin. It is committed to preaching and spreading the Islamic faith

and to the teachings ofabu ATa Maududi, a Pakistani ideologue who had a vision ofan Islamic state based on the application ofislamic law. 26. United Muslims ofamerica: an American Muslim non-profit corporation established in 1982 and which appears to act as an umbrella group for other US Muslim organizations. It states that it is a Muslim public affairs organization whose "mission is to educate and encourage American Muslims to actively participate in the mainstream social, economic, civic and political activities in America." It appears to be a lobbying group that promotes Muslim causes, both domestically and internationally. 27. Al-Azhar University: The oldest and most venerable institution ofreligious learning in the Muslim world. It is Sunni by affiliation and has been a bulwark against radical (i.e. violent) Islamism for much ofthe 20 and 21 centuries. It has been seen as being co-opted by the Egyptian state, and its scholars have been loyal mouthpieces of the government in Cairo, which has been at war with Islamists until the fall of President Mubarak. The Muslim Brotherhood, which now rules through the president ofegypt, regards al-azhar as an institution that stands firmly against Islamism and Islamists. I declare under the penalty ofperjury that the foregoing is true and correct. Executed on December 7, 2012 Bernard Haykel &x 1