Preview
SUMMONS - CIVIL For information on STATE OF CONNECTICUT
JD-CV-1 Rev. 2-20 ADA accommodations, SUPERIOR COURT
C.G.S. §§ 51-346, 51-347, 51-349, 51-350, 52-45a, 52-48, 52-259;
contact a court clerk or
P.B. §§ 3-1 through 3-21,8-1, 10-13 www.jud.ct.gov
go to: www.jud.ct.gov/ADA.
Instructions are on page 2.
Q Select if amount, legal interest, or property in demand, not including interest and costs, is LESS than $2,500.
0 Select if amount, legal interest, or property in demand, not including interest and costs, is $2,500 or MORE.
0 Select if claiming other relief in addition to, or in place of, money or damages.
TO: Any proper officer
By authority of the State of Connecticut, you are hereby commanded to make due and legal service of this summons and attached complaint.
Address of court clerk (Number, street, town and zip code) Telephone number of clerk Return Date (Must be a Tuesday)
300 Grand Street, Waterbury, CT 06702 (203 ) 591 -3300 02/16/2021
[x] Judicial District q At (City/Town) Case type code (See list on page 2)
Q Housing Session O Number: Waterbury Major: M Minor: 00
For the plaintiff(s) enter the appearance of:
Juris number (if attorney or law firm)
Name and address of attorney, law firm or plaintiff if self-represented (Number, street, town and zip code)
Pullman & Comley, LLC, 90 State House Square, Hartford, CT 06103 409177
Telephone number Signature of plaintiff (if self-represented)
( 860 )424 - 4379
The attorney or law firm appearing for the plaintiff, or the plaintiff if E-mail address for delivery of papers under Section 10-13 of the
Connecticut Practice Book (if agreed)
self-represented, agrees to accept papers (service) electronically
,—, .—,
in this case under Section 10-13 of the Connecticut Practice Book.
L£J Yes || No jkaplan@pullcom.com
Parties Name (Last, First, Middle Initial) and address of each party (Number; street; P.O. Box; town; state; zip; country, if not USA)
First Name: Islamic American Society of Connecticut, Inc.
P-01
plaintiff Address:120 Schraffts Drive, Waterbury, 06702
Additional Name:
P-02
plaintiff Address:
First Name: Waterbury Islamic Cultural Center, Inc., 130 Scott Road, Waterbury. CT, c/o its agent for service (D-12)
D-01
defendant Address:Kamal Rekaby, 140 Homer Street, Ste A., Waterbury, CT 06704
Additional Name: Hussein Ahmad, 148 High Ridge Road, Naugatuck, CT 06770 (D-13)
D-02
defendant Address:
Additional Name: Ashraf Ibrahim, 62 Pierpont Drive, Unit D5, Waterbury, CT 06705 (D-14)
D-03
defendant Address:
Additional Name:
D-04
defendant Address:
Total number of plaintiffs: 1 Total number of defendants: 14 QJ Form JD-CV-2 attached for additional parties
Notice to each defendant
1. You are being sued. This is a summons in a lawsuit. The complaint attached states the claims the plaintiff is making against you.
2. To receive further notices, you or your attorney must file an Appearance (form JD-CL-12) with the clerk at the address above. Generally,
it must be filed on or before the second day after the Return Date. The Return Date is not a hearing date. You do not have to come to
court on the Return Date unless you receive a separate notice telling you to appear.
3. If you or your attorney do not file an Appearance on time, a default judgment may be entered against you. You can get an Appearance
form at the court address above, or on-line at https://jud.ct.gov/webforms/.
4. If you believe that you have insurance that may cover the claim being made against you in this lawsuit, you should immediately contact
your insurance representative. Other actions you may take are described in the Connecticut Practice Book, which may be found in a
superior court law library or on-line at https://www.jud.ct.gov/Db.htm.
5. If you have questions about the summons and complaint, you should talk to an attorney.
The court staff is not allowed to give advice on legal matters.
Date SigneeKfSignpnd selept^ropenbo^}—
7 Name of person signing
[x~] Commissioner of Superior Court
1/15 72021 □______________________ ClerkJonathan A. Kaplan
If this summons i^lgned by a Clerk: z For Court Use Only
File Date
a. The signing has been done so that the plaintiff(s) will not be denied access to the courts.
b. It is the responsibility of the plaintiff(s) to ensure that service is made in the manner provided by law.
c. The court staff is not permitted to give any legal advice in connection with any lawsuit.
d. The Clerk signing this summons at the request of the plaintiff(s) is not responsible in any way for any
errors or omissions in the summons, any allegations contained in the complaint, or the service of the
summons or complaint.
Signed (Self-representedplaintiff) Date Docket Number
1 certify 1 have read and
understand the above:
Page 1 of 2
Instructions
1. Type or print legibly. If you are a self-represented party, this summons must be signed by a clerk of the court.
2. If there is more than one defendant, make a copy of the summons for each additional defendant. Each defendant must receive a copy of
this summons. Each copy of the summons must show who signed the summons and when it was signed. If there are more than two
plaintiffs or more than four defendants, complete the Civil Summons Continuation of Parties (form JD-CV-2) and attach it to the original
and all copies of the summons.
3. Attach the summons to the complaint, and attach a copy of the summons to each copy of the complaint. Include a copy of the Civil
Summons Continuation of Parties form, if applicable.
4. After service has been made by a proper officer, file the original papers and the officer's return of service with the clerk of the court.
Use this summons for the case type codes shown below.
Do not use this summons for the following actions:
(a) Family matters (for example divorce, child support, (e)Administrative appeals
custody, paternity, and visitation matters) (f) Proceedings pertaining to arbitration
(b) Any actions or proceedings in which an attachment, (g)Summary Process (Eviction) actions
garnishment or replevy is sought
(h)Entry and Detainer proceedings
(c) Applications for change of name (i)Housing Code Enforcement actions
(d) Probate appeals
Case Type Codes
MAJOR CODE MAJOR CODE
Major/ MINOR DESCRIPTION Major/ MINOR DESCRIPTION
DESCRIPTION Minor
DESCRIPTION Minor
Contracts C 00 Construction - All other Property P00 Foreclosure
C 10 Construction - State and Local P10 Partition
C 20 Insurance Policy P20 Quiet Title/Discharge of Mortgage or Lien
C 30 Specific Performance P30 Asset Forfeiture
C40 Collections P90 All other
C 50 Uninsured/Underinsured Motorist Coverage
C 60 Uniform Limited Liability Company Act - C.G.S. 34-243
C 90 All other Torts (Other T 02 Defective Premises - Private - Snow or Ice
than Vehicular) T03 Defective Premises - Private - Other
Eminent E00 State Highway Condemnation T 11 Defective Premises - Public - Snow or Ice
Domain E 10 Redevelopment Condemnation T 12 Defective Premises - Public - Other
E 20 Other State or Municipal Agencies T20 Products Liability - Other than Vehicular
E30 Public Utilities & Gas Transmission Companies T28 Malpractice - Medical
E90 All other T29 Malpractice - Legal
TSO Malpractice - All other
T40 Assault and Battery
Housing H10 Return of Security Deposit
Housing -
TSO Defamation
H12 Housing -
Rent and/or Damages
T61 Animals - Dog
H40 Housing -
Housing - Audita Querela/lnjunction
T69 Animals - Other
H50 Administrative Appeal
Housing -
T70 False Arrest
H60 Housing -
Municipal Enforcement
T71 Fire Damage
H90 Housing -
All Other
T90 All other
Miscellaneous M00 Injunction
M10 Receivership Vehicular Torts V01 Motor Vehicles* - Driver and/or Passenger(s) vs. Driver(s)
M15 Receivership for Abandoned/Blighted Property V04 Motor Vehicles* - Pedestrian vs. Driver
Mandamus VOS Motor Vehicles* - Property Damage only
M20
M30 Habeas Corpus (extradition, release from Penal Institution) V06 Motor Vehicle* - Products Liability Including Warranty
V09 Motor Vehicle* - All other
M40 Arbitration
V10 Boats
M50 Declaratory Judgment
V20 Airplanes
M63 Bar Discipline
V30 Railroads
M66 Department of Labor Unemployment Compensation
Enforcement V40 Snowmobiles
M68 Bar Discipline - Inactive Status V90 All other
‘Motor Vehicles include cars, trucks,
M70 Municipal Ordinance and Regulation Enforcement
motorcycles, and motor scooters.
M80 Foreign Civil Judgments - C.G.S. 52-604 & C.G.S. 50a-30
M83 Small Claims Transfer to Regular Docket
Wills, Estates W10 Construction of Wills and Trusts
M84 Foreign Protective Order W 90 All other
and Trusts
M89 CH RO Action in the Public Interest - P.A. 19-93
M90 All other
Page 2 of 2
ORDER 421277
DOCKET NO: UWYCV196045396S SUPERIOR COURT
ISLAMIC AMERICAN SOCIETY OF JUDICIAL DISTRICT OF WATERBURY
CONNECTICUT, INC. AT WATERBURY
V.
ASHRAF, JAWAD Et Al 1/11/2021
ORDER
ORDER REGARDING:
12/30/2020 120.00 MOTION TO CITE ADDITIONAL PARTY
The foregoing, having been considered by the Court, is hereby:
ORDER: GRANTED
It is ordered that on or before 2/4/21 the complaint be amended to state facts showing the interest of
Waterbury Islamic Cultural Center, Inc.; Hussein Ahmad and Ashraf Ibrahim in this action and summon
Waterbury Islamic Cultural Center, Inc.; Hussein Ahmad and Ashraf Ibrahim to appear as a defendant in
this action on or before the second day following 2/16/21, by causing some proper officer to serve on the
defendant in the manner prescribed by law a true and attested copy of this order, a true and attested or
certified copy of the complaint in this action as amended, and a Summons Civil Form JD-CV-1 and due
return make.
c
Judicial Notice (JDNO) was sent regarding this order.
421277
Judge: BARBARA N BELLIS
This document may be signed or verified electronically and has the same validity and status as a document with a physical
(pen-to-paper) signature. For more information, see Section I.E. of the State of Connecticut Superior Court E-Services
Procedures and Technical Standards (https://jud.ct.gov/external/super/E-Seivices/e-standards.pdf ), section 51 -193c of the
Connecticut General Statutes and Connecticut Practice Book Section 4-4.
UWYCV196045396S 1/11/2021 Page 1 of 1
RETURN DATE: FEBRUARY 16, 2021
DOCKET NO. UWY-CV19-6045396-S SUPERIOR COURT
ISLAMIC AMERICAN SOCIETY OF J.D. OF WATERBURY
CONNECTICUT, INC.,
PLAINTIFF,
V. AT WATERBURY
JAWAD ASHRAF, SUMERA GHAZI,
OSSAMA ELAWAD, SAED ELAHMAD,
WILLIAM COLSON, ABDEL HAMED,
KAMAL REKABY, AYESHA TARAR,
RIZWAN TARAR, AHMED ABDULRAZAK, JANUARY 15, 2021
JANE DOE AND JOHN DOE, WATERBURY
ISLAMIC CULTURAL CENTER, INC.,
HUSSEIN AHMAD AND ASHRAF IBRAHIM
FIRST AMENDED COMPLAINT
PARTIES
1. The plaintiff is the Islamic American Society of Connecticut, Inc. (“IASC”),
which is a Connecticut corporation with its principal place of business on 95 Schraffts
Drive, Waterbury, Connecticut.
2. The IASC is the title owner of real property located at 95 Schraffts Dr.
Waterbury CT 06705 (the “Masjid Al-Mustafa Mosque”), and 120 Schraffts Dr.
Waterbury, CT 06705 (the “Quran Institute Mosque”), (collectively the “Mosques”).
The IASC holds congregational prayers and Islamic functions at the Mosques.
3. The defendants are as follows:
1
a. Jawad Ashraf, an individual who resides at 97 Idylwood Avenue
Waterbury, Connecticut;
b. Sumera Ghazi, an individual who resides at 97 Idylwood Ave,
Waterbury, Connecticut,
c. Ossama Elawad, an individual who resides at 1049 Summit Road,
Cheshire, Connecticut,
d. Saed Elahmad, an individual who resides at 71 Crystal Brook
Road, Wolcott, Connecticut;
e. William Colson, an individual who resides at 488 South Street,
Bristol, Connecticut;
f. Abdel Hamed, an individual who resides at 95 Invarary Road,
Watertown, Connecticut;
g. Kamal Rekaby, an individual who resides at 85 Cook Road,
Prospect, Connecticut;
h. Ayesha Tarar, an individual who resides at 42 Gayridge Rd, Apt
2-4, Waterbury, CT 06705,
i. Rizwan Tarar, an individual who resides at 116 Maybury Cir, Apt #
5, Waterbury, CT 06705
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j. Ahmed Abdulrazak, an individual who resides at 74 Hamden Ave,
Waterbury, CT 06704,
k. Jane Doe and John Doe, individuals whose names and identities
remain unknown to the Plaintiff despite diligent attempts to discover who
have participated in the actions described below and are part of the
defendants’ group and/or are acting on behalf of or in concert with the
named defendants.
l. Hussein Ahmad± is an individual who resides at 148 High Ridge
Road, Naugatuck, Connecticut 06770. The afore-mentioned defendants
are collectively referred to herein as the “Invitee Defendants.”
m. The Waterbury Islamic Cultural Center, Inc. (“WICC”) is a non
stock corporation created on December 28, 2018. It’s agent for service
is defendant Kamal Rekaby. According to its website, its board of
directors is comprised of defendant Hussein Ahmed as president,
defendant Kamal Rekaby as vice president, defendant Jawad Ashraf as
secretary, and defendants Sajid Colson and Osama Elawad as additional
members of the board. It’s address is listed as 130 Scott Road,
Waterbury, Connecticut.
3
n. Ashraf Ibrahim is an individual who resides at 62 Pierpont Dr. Unit
D5, Waterbury CT 06705. He was formerly employed by IASC as its
Imam, or spiritual leader, and is now the Imam ofWICC.
FACTS COMMON TO ALL COUNTS
4. IASC is a non-profit, non-political, educational and charitable
organization dedicated to the betterment of Muslims in the State of Connecticut.
5. Pursuant to the lASC’s Bylaws, dated December 29, 2007, the Board of
Trustees is the highest governing body of the IASC and has final authority for all
decisions made on behalf of the IASC. The Board of Trustees consists of three (3)
permanent members, who are the founders of the IASC. The permanent members of
the Board of Trustees are Magdy Galal, Naveed Khan and Sultan Ali. The permanent
members of the Board of Trustees helped raise approximately five million dollars to
purchase and construct the Mosques, and contributed substantial sums in personal
donations. The defendants were not part of that group.
6. The Mosques host a variety of events for the Muslim community in the
greater Waterbury area and beyond, including hosting Friday weekly prayer services.
The IASC has members, who have applied for membership, pay annual dues, and
must abide by the rules and regulations of the IASC as set by the Board of Trustees.
4
7. The IASC also permits non-members to attend the Mosques for peaceful
prayer, provided that they subscribe to and uphold the objectives of the mosque and
provided that they abide by the rules and regulations established by the management
of the Mosques, including the Board of Trustees.
8. The Defendants are not members of the IASC. Therefore, they are
merely permitted on to the premises as invitees by the IASC. While on the Mosque
premises, the Defendants are required to pray peacefully, subscribe to and uphold the
objectives of the Mosques and abide by the rules and regulations established by the
management of the Mosques. Defendant Ashraf Ibrahim, while employed by IASC,
was also merely permitted on to the premises as an employee. None of the
Defendants held any ownership or possessory rights to the Mosques.
9. Defendant Ashraf Ibrahim had issues with lASC’s Board of Trustees for
some time and on or about November 30, 2018, defendant Ibrahim, the then-imam
from the Masjid Al-Mustafa Mosque, publicly resigned while delivering a Friday sermon
and made his resignation effective on that same date. The plaintiff and the Trustees
accepted his resignation, and subsequently retained a new Imam.
10. The defendants disagreed with the’ decision to accept the resignation of
its prior Imam and to hire a different Imam in his place. Moreover, defendant Ibrahim -
5
after no longer receiving a salary and additional compensation from the IASC - sought
to return to his former role at IASC. Defendant Ibrahim instigated and encouraged a
campaign to harm the IASC and the Trustees in the hopes of returning to his former
role in order to receive remuneration from lASC’s coffers.
11. Therefore, following defendant Ibrahim’s resignation, the Invitee
Defendants made efforts to harass, threaten and intimidate the plaintiff IASC and the
Trustees, as well as lASC’s Executive Council Staff, members and other attendees, by
causing disruptions at the Mosque. The Defendants’ intent was to usurp control of the
Mosques from the Board of Trustees, reinstate their preferred Imam and oversee the
lASC’s finances including employing defendant Ibrahim and providing him with
compensation.
12. On or about December 7, 2018, the Invitee Defendants disrupted prayer
services by standing and shouting at the newly-hired Imam, the spiritual leader of the
Mosques, and then violently agitating towards anyone who disagreed with the
defendants. The Invitee Defendants had hijacked the prayer hall and violently refused
to allow anyone to pray the time-sensitive mandatory Friday prayer, which is the main
weekly prayer service in the Islam religion, unless and only if their whole demands are
6
met. As a result of this conduct, the plaintiff IASC contacted the police who arrived on
the scene and exercised their authority to keep the peace.
13. On December 12, 2018, December 13, 2018 and December 17, 2018,
the plaintiff IASC sent, via certified mail, cease and desist letters to various
participants in the demonstration, including the defendants, advising them that they
were no longer welcome at the Mosques and that any attempt to enter the Mosques
would be deemed a trespass.
14. The plaintiff IASC also posted signs at the Mosques indicating that
trespassers were not allowed on the property.
15. Despite the fact that the plaintiff expressly revoked the Invitee
Defendants’ permission to enter the Mosque property, the Invitee Defendants
continued to enter the Mosque property, shout and yell at the members of the Board of
Trustees, and shout and yell at the Mosque members and attendees. Specifically, the
defendants have continued to engage in the following conduct:
a. On December 14, 2018, the defendants again disrupted the new
Imam’s prayer services by standing, blockading the pulpit and shouting at the new
Imam. This disturbance made itimpossible for the peaceful prayer to continue. The
7
plaintiff IASC again contacted the police, who had to send nearly a dozen police
officers to stop the defendants.
b. On December 28, 2018, the defendants again entered the
Mosque and, despite being asked to leave, refused to do so. These defendants
caused a disturbance that again prevented the other attendees from peaceful prayer.
The plaintiff IASC again contacted the police.
c. On December 29, 2018, a group of the defendants again entered
the Mosque and despite being asked to leave, refused to do so. The police were once
again present and witnessed the verbal altercation. The defendants eventually left
after the police involvement.
d. On December 30, 2018, the defendants, and others, gathered in
front of the Mosque, banged on the doors, chanted and shouted at the individuals
inside, demanding to be let in. The police were again contacted.
e. On January 1, 2019, the defendants held what they titled a “Right
of Return” dinner on the Mosque property. The defendants encouraged all individuals,
even those who received cease and desist letters, to enter the Mosque property.
f. While on or around the Mosque property, the defendants have
repeatedly shouted at and yelled at the Mosque attendees in an effort to deter them
8
from entering the Mosque. Their efforts caused the replacement Imam to permanently
resign due to their unrelenting pressure and continuous humiliating attacks on social
media. Defendants ongoing smear campaign derailed the Mosque’s attempt to hire a
new Imam, including contacting Imam candidates directly to discourage them from
pursuing the position. The defendants have also surrounded the Mosque attendees’
vehicles, while shouting and creating an unsafe environment.
16. Even those defendants who complied with the cease and desist letter
continue their harassment campaign by standing on the perimeter of the Mosques to
intimidate, threaten and harass the lASC’s Trustees, Executive Council staff, members
and Mosque attendees. Certain defendants even attacked a congregant’s vehicle as
he exited the premises.
17. The defendants, or those under their direction and control, have also
used the internet and social media to harass, embarrass and otherwise harm the IASC
and the Trustees.
18. Indeed, the defendants have engaged in the following conduct:
a. Facebook: The defendants have misappropriated the Masjid Al
Mustafa Mosque name by creating a fake Facebook account, purporting to be the
Masjid Al Mustafa Mosque. The Mosque’s accurate account name is “Masjid Al
9
Mustafa.” The defendants created a fake account without the space between two of
the words titled, “Masjid Almustafa.” (hereinafter the “Hijacked Account”)
b. On December 19, 2018, through the hijacked account, the
defendants published a Facebook post likening the chairman of the IASC, to
President Donald Trump, which is intended as an insult based on the President’s
rhetoric on immigrants and Muslims.
c. On January 1, 2019, the defendants, through the hijacked “Masjid
Almustafa” account, posted an “Action Notice” in which they requested “ALL
community members . .. including those ‘banned’ in the past,” to attend an event at
the Mosque, “to mark [their] return to [their] rightful place.”
d. On that same date, the defendants falsely announced that the
Board of Trustees had resigned and that any order they issued was “null and void.”
The defendants further falsely claim in this post that the new interim Board of
Trustees consists of defendants Rekaby, Ashraf, Elawad and Colson, as well as
another part of their group, Hussein Ahmed.
e. YouTube: The defendants have also misappropriated the Masjid
Al Mustafa Mosque name to create a fake YouTube account. The Mosque’s accurate
account name is “Masjid Al Mustafa.” The defendants created a fraudulent account
10
titled, “Masjid Almustafa.” The defendants have posted at least three (3) videos
through the fake account.
f. Twitter: The defendants have created a user name titled
“MasjidResist.” Through this account, the defendants have published posts again
describing Magdy Galal, MD, the chairman of the IASC, as a dictator and narcissist
and again likening him to President Donald Trump.
g. Google and other search-engines: The defendants have also
targeted the chairman of the IASC, Magdy Galal. The defendants have
disparaged him by describing him as a “dictator,” a “narcissist,” and “ethically unfit to
perform his duty,” by posting online reviews associated with Dr. Galal’s employer.
These posts falsely purport to be written by patients of Dr. Galal, when in fact they
were posted by the defendants. Indeed, defendants Ayesha Tarar and Rizwan Tarar,
and Jalal Asad, each published posts in their own names. It is apparent from the
content of the anonymous posts that they were written by the defendants, or by
individuals under their direction or control, as the posts include discussion about the
Mosgues.
19. As a result of the defendants’ conduct, the plaintiff IASC was forced to
temporarily close the Mosgues on various occasions, including closing on several
11
Fridays, which is the main prayer service in the Islam religion, and canceling Sunday
school and weekday religious classes.
20. Despite cease and desist letters and police intervention on several
occasions, the defendants refuse to abide by the law. As their actions continue to
escalate and the harassment and intimidation tactics become more outlandish, the
IASC became concerned for the safety and well-being of its members, employees and
attendees.
21. The defendants have worked together to trespass on the Mosques
property, disrupt prayer services, use intimidation tactics to prevent members and
attendees from attending the Mosques and misappropriate the Mosques’ social media
account names to spread false information about the Mosques and the Mosque’s
leadership. There have been multiple overt actions taken by each of the defendants in
furtherance of this scheme, including but not limited to the allegations set forth herein.
The defendants have also directed others under their control and direction to perform
similar actions in support of defendants’ scheme.
22. Defendants’ conduct compelled Plaintiff IASC to commence this action
on January 9, 2019 and seek a temporary injunction against the defendants.
12
23. The Court entered a temporary injunction on January 10, 2019, ordering
the following:
The defendants and those under their direction and control shall cease
and desist from disrupting any Islamic American Society of Connecticut
(IASC) congregational prayers or Islamic functions conducted at the IASC
Mosques located at 95 and 120 Schrafft’s Drive, Waterbury, CT. The term
“disrupting” shall include the following conduct: with intent to cause
inconvenience, annoyance or alarm, he or she (1) engages in fighting or in
violent, tumultuous or threatening behavior; or (2) annoys or interferes
with another person by offensive conduct; or (3) makes unreasonable
noise; or (4) disturbs any lawful assembly or meeting of persons; or (5)
obstructs vehicular or pedestrian traffic; or (6) assaults or strikes another;
or (7) threatens to commit any crime against another person or such other
person’s property; or (8) publicly exhibits, distributes, posts up or
advertises any offensive, indecent or abusive matter concerning any
person; or (9) uses abusive or obscene language or makes an obscene
gesture; or (10) creates a public and hazardous or physically offensive
condition by any act which such person is not licensed or privileged to do.
24. At or around the same time as the commencement of this lawsuit,
several of the defendants commenced an action against the plaintiff IASC and the
Trustees in an action entitled William Colson et al v. Magdy Galal et al in the Judicial
District of Waterbury bearing docket number UWY-C\/19-502467-S (the “Other
Lawsuit”). The defendants sought a declaratory action that they were the lawful
trustees of IASC, and for an accounting and turnover of the corporate books, records
and assets. The Court dismissed the Other Lawsuit for lack of standing pursuant to a
memorandum of decision dated April 16, 2020.
13
25. After the issuance of the temporary injunction in this action and the
dismissal of the Other Lawsuit, the defendants refocused their harassment campaign
from usurping control of the Mosques and IASC to harming and damaging IASC in
order to bolster their own mosque, the defendant WICC.
26. Defendants incorporated WICC on December 28, 2018 and following the
dismissal of the Other Lawsuit, defendants secured a property in Naugatuck to host
WICC’s affairs. WICC subsequently relocated to a location that was less than 0.3
miles from lASC’s Mosques.
27. Defendants continued with their campaign aimed at harassing the IASC
Preview
SUMMONS - CIVIL For information on STATE OF CONNECTICUT JD-CV-1 Rev. 2-20 ADA accommodations, SUPERIOR COURT C.G.S. §§ 51-346, 51-347, 51-349, 51-350, 52-45a, 52-48, 52-259; contact a court clerk or P.B. §§ 3-1 through 3-21,8-1, 10-13 www.jud.ct.gov go to: www.jud.ct.gov/ADA. Instructions are on page 2. Q Select if amount, legal interest, or property in demand, not including interest and costs, is LESS than $2,500. 0 Select if amount, legal interest, or property in demand, not including interest and costs, is $2,500 or MORE. 0 Select if claiming other relief in addition to, or in place of, money or damages. TO: Any proper officer By authority of the State of Connecticut, you are hereby commanded to make due and legal service of this summons and attached complaint. Address of court clerk (Number, street, town and zip code) Telephone number of clerk Return Date (Must be a Tuesday) 300 Grand Street, Waterbury, CT 06702 (203 ) 591 -3300 02/16/2021 [x] Judicial District q At (City/Town) Case type code (See list on page 2) Q Housing Session O Number: Waterbury Major: M Minor: 00 For the plaintiff(s) enter the appearance of: Juris number (if attorney or law firm) Name and address of attorney, law firm or plaintiff if self-represented (Number, street, town and zip code) Pullman & Comley, LLC, 90 State House Square, Hartford, CT 06103 409177 Telephone number Signature of plaintiff (if self-represented) ( 860 )424 - 4379 The attorney or law firm appearing for the plaintiff, or the plaintiff if E-mail address for delivery of papers under Section 10-13 of the Connecticut Practice Book (if agreed) self-represented, agrees to accept papers (service) electronically ,—, .—, in this case under Section 10-13 of the Connecticut Practice Book. L£J Yes || No jkaplan@pullcom.com Parties Name (Last, First, Middle Initial) and address of each party (Number; street; P.O. Box; town; state; zip; country, if not USA) First Name: Islamic American Society of Connecticut, Inc. P-01 plaintiff Address:120 Schraffts Drive, Waterbury, 06702 Additional Name: P-02 plaintiff Address: First Name: Waterbury Islamic Cultural Center, Inc., 130 Scott Road, Waterbury. CT, c/o its agent for service (D-12) D-01 defendant Address:Kamal Rekaby, 140 Homer Street, Ste A., Waterbury, CT 06704 Additional Name: Hussein Ahmad, 148 High Ridge Road, Naugatuck, CT 06770 (D-13) D-02 defendant Address: Additional Name: Ashraf Ibrahim, 62 Pierpont Drive, Unit D5, Waterbury, CT 06705 (D-14) D-03 defendant Address: Additional Name: D-04 defendant Address: Total number of plaintiffs: 1 Total number of defendants: 14 QJ Form JD-CV-2 attached for additional parties Notice to each defendant 1. You are being sued. This is a summons in a lawsuit. The complaint attached states the claims the plaintiff is making against you. 2. To receive further notices, you or your attorney must file an Appearance (form JD-CL-12) with the clerk at the address above. Generally, it must be filed on or before the second day after the Return Date. The Return Date is not a hearing date. You do not have to come to court on the Return Date unless you receive a separate notice telling you to appear. 3. If you or your attorney do not file an Appearance on time, a default judgment may be entered against you. You can get an Appearance form at the court address above, or on-line at https://jud.ct.gov/webforms/. 4. If you believe that you have insurance that may cover the claim being made against you in this lawsuit, you should immediately contact your insurance representative. Other actions you may take are described in the Connecticut Practice Book, which may be found in a superior court law library or on-line at https://www.jud.ct.gov/Db.htm. 5. If you have questions about the summons and complaint, you should talk to an attorney. The court staff is not allowed to give advice on legal matters. Date SigneeKfSignpnd selept^ropenbo^}— 7 Name of person signing [x~] Commissioner of Superior Court 1/15 72021 □______________________ ClerkJonathan A. Kaplan If this summons i^lgned by a Clerk: z For Court Use Only File Date a. The signing has been done so that the plaintiff(s) will not be denied access to the courts. b. It is the responsibility of the plaintiff(s) to ensure that service is made in the manner provided by law. c. The court staff is not permitted to give any legal advice in connection with any lawsuit. d. The Clerk signing this summons at the request of the plaintiff(s) is not responsible in any way for any errors or omissions in the summons, any allegations contained in the complaint, or the service of the summons or complaint. Signed (Self-representedplaintiff) Date Docket Number 1 certify 1 have read and understand the above: Page 1 of 2 Instructions 1. Type or print legibly. If you are a self-represented party, this summons must be signed by a clerk of the court. 2. If there is more than one defendant, make a copy of the summons for each additional defendant. Each defendant must receive a copy of this summons. Each copy of the summons must show who signed the summons and when it was signed. If there are more than two plaintiffs or more than four defendants, complete the Civil Summons Continuation of Parties (form JD-CV-2) and attach it to the original and all copies of the summons. 3. Attach the summons to the complaint, and attach a copy of the summons to each copy of the complaint. Include a copy of the Civil Summons Continuation of Parties form, if applicable. 4. After service has been made by a proper officer, file the original papers and the officer's return of service with the clerk of the court. Use this summons for the case type codes shown below. Do not use this summons for the following actions: (a) Family matters (for example divorce, child support, (e)Administrative appeals custody, paternity, and visitation matters) (f) Proceedings pertaining to arbitration (b) Any actions or proceedings in which an attachment, (g)Summary Process (Eviction) actions garnishment or replevy is sought (h)Entry and Detainer proceedings (c) Applications for change of name (i)Housing Code Enforcement actions (d) Probate appeals Case Type Codes MAJOR CODE MAJOR CODE Major/ MINOR DESCRIPTION Major/ MINOR DESCRIPTION DESCRIPTION Minor DESCRIPTION Minor Contracts C 00 Construction - All other Property P00 Foreclosure C 10 Construction - State and Local P10 Partition C 20 Insurance Policy P20 Quiet Title/Discharge of Mortgage or Lien C 30 Specific Performance P30 Asset Forfeiture C40 Collections P90 All other C 50 Uninsured/Underinsured Motorist Coverage C 60 Uniform Limited Liability Company Act - C.G.S. 34-243 C 90 All other Torts (Other T 02 Defective Premises - Private - Snow or Ice than Vehicular) T03 Defective Premises - Private - Other Eminent E00 State Highway Condemnation T 11 Defective Premises - Public - Snow or Ice Domain E 10 Redevelopment Condemnation T 12 Defective Premises - Public - Other E 20 Other State or Municipal Agencies T20 Products Liability - Other than Vehicular E30 Public Utilities & Gas Transmission Companies T28 Malpractice - Medical E90 All other T29 Malpractice - Legal TSO Malpractice - All other T40 Assault and Battery Housing H10 Return of Security Deposit Housing - TSO Defamation H12 Housing - Rent and/or Damages T61 Animals - Dog H40 Housing - Housing - Audita Querela/lnjunction T69 Animals - Other H50 Administrative Appeal Housing - T70 False Arrest H60 Housing - Municipal Enforcement T71 Fire Damage H90 Housing - All Other T90 All other Miscellaneous M00 Injunction M10 Receivership Vehicular Torts V01 Motor Vehicles* - Driver and/or Passenger(s) vs. Driver(s) M15 Receivership for Abandoned/Blighted Property V04 Motor Vehicles* - Pedestrian vs. Driver Mandamus VOS Motor Vehicles* - Property Damage only M20 M30 Habeas Corpus (extradition, release from Penal Institution) V06 Motor Vehicle* - Products Liability Including Warranty V09 Motor Vehicle* - All other M40 Arbitration V10 Boats M50 Declaratory Judgment V20 Airplanes M63 Bar Discipline V30 Railroads M66 Department of Labor Unemployment Compensation Enforcement V40 Snowmobiles M68 Bar Discipline - Inactive Status V90 All other ‘Motor Vehicles include cars, trucks, M70 Municipal Ordinance and Regulation Enforcement motorcycles, and motor scooters. M80 Foreign Civil Judgments - C.G.S. 52-604 & C.G.S. 50a-30 M83 Small Claims Transfer to Regular Docket Wills, Estates W10 Construction of Wills and Trusts M84 Foreign Protective Order W 90 All other and Trusts M89 CH RO Action in the Public Interest - P.A. 19-93 M90 All other Page 2 of 2 ORDER 421277 DOCKET NO: UWYCV196045396S SUPERIOR COURT ISLAMIC AMERICAN SOCIETY OF JUDICIAL DISTRICT OF WATERBURY CONNECTICUT, INC. AT WATERBURY V. ASHRAF, JAWAD Et Al 1/11/2021 ORDER ORDER REGARDING: 12/30/2020 120.00 MOTION TO CITE ADDITIONAL PARTY The foregoing, having been considered by the Court, is hereby: ORDER: GRANTED It is ordered that on or before 2/4/21 the complaint be amended to state facts showing the interest of Waterbury Islamic Cultural Center, Inc.; Hussein Ahmad and Ashraf Ibrahim in this action and summon Waterbury Islamic Cultural Center, Inc.; Hussein Ahmad and Ashraf Ibrahim to appear as a defendant in this action on or before the second day following 2/16/21, by causing some proper officer to serve on the defendant in the manner prescribed by law a true and attested copy of this order, a true and attested or certified copy of the complaint in this action as amended, and a Summons Civil Form JD-CV-1 and due return make. c Judicial Notice (JDNO) was sent regarding this order. 421277 Judge: BARBARA N BELLIS This document may be signed or verified electronically and has the same validity and status as a document with a physical (pen-to-paper) signature. For more information, see Section I.E. of the State of Connecticut Superior Court E-Services Procedures and Technical Standards (https://jud.ct.gov/external/super/E-Seivices/e-standards.pdf ), section 51 -193c of the Connecticut General Statutes and Connecticut Practice Book Section 4-4. UWYCV196045396S 1/11/2021 Page 1 of 1 RETURN DATE: FEBRUARY 16, 2021 DOCKET NO. UWY-CV19-6045396-S SUPERIOR COURT ISLAMIC AMERICAN SOCIETY OF J.D. OF WATERBURY CONNECTICUT, INC., PLAINTIFF, V. AT WATERBURY JAWAD ASHRAF, SUMERA GHAZI, OSSAMA ELAWAD, SAED ELAHMAD, WILLIAM COLSON, ABDEL HAMED, KAMAL REKABY, AYESHA TARAR, RIZWAN TARAR, AHMED ABDULRAZAK, JANUARY 15, 2021 JANE DOE AND JOHN DOE, WATERBURY ISLAMIC CULTURAL CENTER, INC., HUSSEIN AHMAD AND ASHRAF IBRAHIM FIRST AMENDED COMPLAINT PARTIES 1. The plaintiff is the Islamic American Society of Connecticut, Inc. (“IASC”), which is a Connecticut corporation with its principal place of business on 95 Schraffts Drive, Waterbury, Connecticut. 2. The IASC is the title owner of real property located at 95 Schraffts Dr. Waterbury CT 06705 (the “Masjid Al-Mustafa Mosque”), and 120 Schraffts Dr. Waterbury, CT 06705 (the “Quran Institute Mosque”), (collectively the “Mosques”). The IASC holds congregational prayers and Islamic functions at the Mosques. 3. The defendants are as follows: 1 a. Jawad Ashraf, an individual who resides at 97 Idylwood Avenue Waterbury, Connecticut; b. Sumera Ghazi, an individual who resides at 97 Idylwood Ave, Waterbury, Connecticut, c. Ossama Elawad, an individual who resides at 1049 Summit Road, Cheshire, Connecticut, d. Saed Elahmad, an individual who resides at 71 Crystal Brook Road, Wolcott, Connecticut; e. William Colson, an individual who resides at 488 South Street, Bristol, Connecticut; f. Abdel Hamed, an individual who resides at 95 Invarary Road, Watertown, Connecticut; g. Kamal Rekaby, an individual who resides at 85 Cook Road, Prospect, Connecticut; h. Ayesha Tarar, an individual who resides at 42 Gayridge Rd, Apt 2-4, Waterbury, CT 06705, i. Rizwan Tarar, an individual who resides at 116 Maybury Cir, Apt # 5, Waterbury, CT 06705 2 j. Ahmed Abdulrazak, an individual who resides at 74 Hamden Ave, Waterbury, CT 06704, k. Jane Doe and John Doe, individuals whose names and identities remain unknown to the Plaintiff despite diligent attempts to discover who have participated in the actions described below and are part of the defendants’ group and/or are acting on behalf of or in concert with the named defendants. l. Hussein Ahmad± is an individual who resides at 148 High Ridge Road, Naugatuck, Connecticut 06770. The afore-mentioned defendants are collectively referred to herein as the “Invitee Defendants.” m. The Waterbury Islamic Cultural Center, Inc. (“WICC”) is a non stock corporation created on December 28, 2018. It’s agent for service is defendant Kamal Rekaby. According to its website, its board of directors is comprised of defendant Hussein Ahmed as president, defendant Kamal Rekaby as vice president, defendant Jawad Ashraf as secretary, and defendants Sajid Colson and Osama Elawad as additional members of the board. It’s address is listed as 130 Scott Road, Waterbury, Connecticut. 3 n. Ashraf Ibrahim is an individual who resides at 62 Pierpont Dr. Unit D5, Waterbury CT 06705. He was formerly employed by IASC as its Imam, or spiritual leader, and is now the Imam ofWICC. FACTS COMMON TO ALL COUNTS 4. IASC is a non-profit, non-political, educational and charitable organization dedicated to the betterment of Muslims in the State of Connecticut. 5. Pursuant to the lASC’s Bylaws, dated December 29, 2007, the Board of Trustees is the highest governing body of the IASC and has final authority for all decisions made on behalf of the IASC. The Board of Trustees consists of three (3) permanent members, who are the founders of the IASC. The permanent members of the Board of Trustees are Magdy Galal, Naveed Khan and Sultan Ali. The permanent members of the Board of Trustees helped raise approximately five million dollars to purchase and construct the Mosques, and contributed substantial sums in personal donations. The defendants were not part of that group. 6. The Mosques host a variety of events for the Muslim community in the greater Waterbury area and beyond, including hosting Friday weekly prayer services. The IASC has members, who have applied for membership, pay annual dues, and must abide by the rules and regulations of the IASC as set by the Board of Trustees. 4 7. The IASC also permits non-members to attend the Mosques for peaceful prayer, provided that they subscribe to and uphold the objectives of the mosque and provided that they abide by the rules and regulations established by the management of the Mosques, including the Board of Trustees. 8. The Defendants are not members of the IASC. Therefore, they are merely permitted on to the premises as invitees by the IASC. While on the Mosque premises, the Defendants are required to pray peacefully, subscribe to and uphold the objectives of the Mosques and abide by the rules and regulations established by the management of the Mosques. Defendant Ashraf Ibrahim, while employed by IASC, was also merely permitted on to the premises as an employee. None of the Defendants held any ownership or possessory rights to the Mosques. 9. Defendant Ashraf Ibrahim had issues with lASC’s Board of Trustees for some time and on or about November 30, 2018, defendant Ibrahim, the then-imam from the Masjid Al-Mustafa Mosque, publicly resigned while delivering a Friday sermon and made his resignation effective on that same date. The plaintiff and the Trustees accepted his resignation, and subsequently retained a new Imam. 10. The defendants disagreed with the’ decision to accept the resignation of its prior Imam and to hire a different Imam in his place. Moreover, defendant Ibrahim - 5 after no longer receiving a salary and additional compensation from the IASC - sought to return to his former role at IASC. Defendant Ibrahim instigated and encouraged a campaign to harm the IASC and the Trustees in the hopes of returning to his former role in order to receive remuneration from lASC’s coffers. 11. Therefore, following defendant Ibrahim’s resignation, the Invitee Defendants made efforts to harass, threaten and intimidate the plaintiff IASC and the Trustees, as well as lASC’s Executive Council Staff, members and other attendees, by causing disruptions at the Mosque. The Defendants’ intent was to usurp control of the Mosques from the Board of Trustees, reinstate their preferred Imam and oversee the lASC’s finances including employing defendant Ibrahim and providing him with compensation. 12. On or about December 7, 2018, the Invitee Defendants disrupted prayer services by standing and shouting at the newly-hired Imam, the spiritual leader of the Mosques, and then violently agitating towards anyone who disagreed with the defendants. The Invitee Defendants had hijacked the prayer hall and violently refused to allow anyone to pray the time-sensitive mandatory Friday prayer, which is the main weekly prayer service in the Islam religion, unless and only if their whole demands are 6 met. As a result of this conduct, the plaintiff IASC contacted the police who arrived on the scene and exercised their authority to keep the peace. 13. On December 12, 2018, December 13, 2018 and December 17, 2018, the plaintiff IASC sent, via certified mail, cease and desist letters to various participants in the demonstration, including the defendants, advising them that they were no longer welcome at the Mosques and that any attempt to enter the Mosques would be deemed a trespass. 14. The plaintiff IASC also posted signs at the Mosques indicating that trespassers were not allowed on the property. 15. Despite the fact that the plaintiff expressly revoked the Invitee Defendants’ permission to enter the Mosque property, the Invitee Defendants continued to enter the Mosque property, shout and yell at the members of the Board of Trustees, and shout and yell at the Mosque members and attendees. Specifically, the defendants have continued to engage in the following conduct: a. On December 14, 2018, the defendants again disrupted the new Imam’s prayer services by standing, blockading the pulpit and shouting at the new Imam. This disturbance made itimpossible for the peaceful prayer to continue. The 7 plaintiff IASC again contacted the police, who had to send nearly a dozen police officers to stop the defendants. b. On December 28, 2018, the defendants again entered the Mosque and, despite being asked to leave, refused to do so. These defendants caused a disturbance that again prevented the other attendees from peaceful prayer. The plaintiff IASC again contacted the police. c. On December 29, 2018, a group of the defendants again entered the Mosque and despite being asked to leave, refused to do so. The police were once again present and witnessed the verbal altercation. The defendants eventually left after the police involvement. d. On December 30, 2018, the defendants, and others, gathered in front of the Mosque, banged on the doors, chanted and shouted at the individuals inside, demanding to be let in. The police were again contacted. e. On January 1, 2019, the defendants held what they titled a “Right of Return” dinner on the Mosque property. The defendants encouraged all individuals, even those who received cease and desist letters, to enter the Mosque property. f. While on or around the Mosque property, the defendants have repeatedly shouted at and yelled at the Mosque attendees in an effort to deter them 8 from entering the Mosque. Their efforts caused the replacement Imam to permanently resign due to their unrelenting pressure and continuous humiliating attacks on social media. Defendants ongoing smear campaign derailed the Mosque’s attempt to hire a new Imam, including contacting Imam candidates directly to discourage them from pursuing the position. The defendants have also surrounded the Mosque attendees’ vehicles, while shouting and creating an unsafe environment. 16. Even those defendants who complied with the cease and desist letter continue their harassment campaign by standing on the perimeter of the Mosques to intimidate, threaten and harass the lASC’s Trustees, Executive Council staff, members and Mosque attendees. Certain defendants even attacked a congregant’s vehicle as he exited the premises. 17. The defendants, or those under their direction and control, have also used the internet and social media to harass, embarrass and otherwise harm the IASC and the Trustees. 18. Indeed, the defendants have engaged in the following conduct: a. Facebook: The defendants have misappropriated the Masjid Al Mustafa Mosque name by creating a fake Facebook account, purporting to be the Masjid Al Mustafa Mosque. The Mosque’s accurate account name is “Masjid Al 9 Mustafa.” The defendants created a fake account without the space between two of the words titled, “Masjid Almustafa.” (hereinafter the “Hijacked Account”) b. On December 19, 2018, through the hijacked account, the defendants published a Facebook post likening the chairman of the IASC, to President Donald Trump, which is intended as an insult based on the President’s rhetoric on immigrants and Muslims. c. On January 1, 2019, the defendants, through the hijacked “Masjid Almustafa” account, posted an “Action Notice” in which they requested “ALL community members . .. including those ‘banned’ in the past,” to attend an event at the Mosque, “to mark [their] return to [their] rightful place.” d. On that same date, the defendants falsely announced that the Board of Trustees had resigned and that any order they issued was “null and void.” The defendants further falsely claim in this post that the new interim Board of Trustees consists of defendants Rekaby, Ashraf, Elawad and Colson, as well as another part of their group, Hussein Ahmed. e. YouTube: The defendants have also misappropriated the Masjid Al Mustafa Mosque name to create a fake YouTube account. The Mosque’s accurate account name is “Masjid Al Mustafa.” The defendants created a fraudulent account 10 titled, “Masjid Almustafa.” The defendants have posted at least three (3) videos through the fake account. f. Twitter: The defendants have created a user name titled “MasjidResist.” Through this account, the defendants have published posts again describing Magdy Galal, MD, the chairman of the IASC, as a dictator and narcissist and again likening him to President Donald Trump. g. Google and other search-engines: The defendants have also targeted the chairman of the IASC, Magdy Galal. The defendants have disparaged him by describing him as a “dictator,” a “narcissist,” and “ethically unfit to perform his duty,” by posting online reviews associated with Dr. Galal’s employer. These posts falsely purport to be written by patients of Dr. Galal, when in fact they were posted by the defendants. Indeed, defendants Ayesha Tarar and Rizwan Tarar, and Jalal Asad, each published posts in their own names. It is apparent from the content of the anonymous posts that they were written by the defendants, or by individuals under their direction or control, as the posts include discussion about the Mosgues. 19. As a result of the defendants’ conduct, the plaintiff IASC was forced to temporarily close the Mosgues on various occasions, including closing on several 11 Fridays, which is the main prayer service in the Islam religion, and canceling Sunday school and weekday religious classes. 20. Despite cease and desist letters and police intervention on several occasions, the defendants refuse to abide by the law. As their actions continue to escalate and the harassment and intimidation tactics become more outlandish, the IASC became concerned for the safety and well-being of its members, employees and attendees. 21. The defendants have worked together to trespass on the Mosques property, disrupt prayer services, use intimidation tactics to prevent members and attendees from attending the Mosques and misappropriate the Mosques’ social media account names to spread false information about the Mosques and the Mosque’s leadership. There have been multiple overt actions taken by each of the defendants in furtherance of this scheme, including but not limited to the allegations set forth herein. The defendants have also directed others under their control and direction to perform similar actions in support of defendants’ scheme. 22. Defendants’ conduct compelled Plaintiff IASC to commence this action on January 9, 2019 and seek a temporary injunction against the defendants. 12 23. The Court entered a temporary injunction on January 10, 2019, ordering the following: The defendants and those under their direction and control shall cease and desist from disrupting any Islamic American Society of Connecticut (IASC) congregational prayers or Islamic functions conducted at the IASC Mosques located at 95 and 120 Schrafft’s Drive, Waterbury, CT. The term “disrupting” shall include the following conduct: with intent to cause inconvenience, annoyance or alarm, he or she (1) engages in fighting or in violent, tumultuous or threatening behavior; or (2) annoys or interferes with another person by offensive conduct; or (3) makes unreasonable noise; or (4) disturbs any lawful assembly or meeting of persons; or (5) obstructs vehicular or pedestrian traffic; or (6) assaults or strikes another; or (7) threatens to commit any crime against another person or such other person’s property; or (8) publicly exhibits, distributes, posts up or advertises any offensive, indecent or abusive matter concerning any person; or (9) uses abusive or obscene language or makes an obscene gesture; or (10) creates a public and hazardous or physically offensive condition by any act which such person is not licensed or privileged to do. 24. At or around the same time as the commencement of this lawsuit, several of the defendants commenced an action against the plaintiff IASC and the Trustees in an action entitled William Colson et al v. Magdy Galal et al in the Judicial District of Waterbury bearing docket number UWY-C\/19-502467-S (the “Other Lawsuit”). The defendants sought a declaratory action that they were the lawful trustees of IASC, and for an accounting and turnover of the corporate books, records and assets. The Court dismissed the Other Lawsuit for lack of standing pursuant to a memorandum of decision dated April 16, 2020. 13 25. After the issuance of the temporary injunction in this action and the dismissal of the Other Lawsuit, the defendants refocused their harassment campaign from usurping control of the Mosques and IASC to harming and damaging IASC in order to bolster their own mosque, the defendant WICC. 26. Defendants incorporated WICC on December 28, 2018 and following the dismissal of the Other Lawsuit, defendants secured a property in Naugatuck to host WICC’s affairs. WICC subsequently relocated to a location that was less than 0.3 miles from lASC’s Mosques. 27. Defendants continued with their campaign aimed at harassing the IASC