Riad Elsolh Hamad
Plaintiff
vs.
Center for the Study of Popular Culture, & David Horowitz & Center for Jewish Community Studies & * The State of Texas & Joe Kaufman & Americans Against Hate & Daniel Pipes Campus Watch & CB Accounts & MilitantIslammonitor.org & Freerepublic. LLC & Jim Robinson Defendants.

Plaintiff’s Motion For A Partial Summary Judgment, A Motion To Set A Trial Date By Jury To Determine Damages and A Motion For An Injunction Order

To the Honorable Judge Sam Sparks:
Comes Now, Riad Elsolh Hamad, a United States citizen, resident of Austin, Travis County, Texas and pursuant to Rule 56 of the Federal Rules of Civil Procedure and files his Plaintiff’s Motion For A Summary Judgment and An Order To Set A Trial Date By Jury To Determine Damages and shows:

Parties
Plaintiff Riad Elsolh Hamad is a United States citizen, resident of Austin, Travis County, Texas whose address is 4807 White Elm Drive, Austin Texas 78749. Plaintiff Hamad works as a middle school teacher for Austin Independent School District and operates a business for selling arts and crafts, electronics and maintenance in central Texas and throughout the United States. The business was established in the early 1990’s and expanded after the year 2002 to distribute its products in over 1000 cities in the United States through the web site http://www.PCWF.ORG. (Palestine Children’s Welfare Fund.) PCWF was one of the names that Plaintiff used for his business to sell arts and crafts made by men and women refugees in the refugee camps of occupied Palestine.

Defendants are: Center for the Study of Popular Culture, 4401 Wilshire Drive, 4th Floor, Los Angeles, California 90010 whose phone number is (323) 556-2550 and David Horowitz, Editor in Chief of http://www.Frontpagemag.org in his personal capacity and he can be served at Center for the Study of Popular Culture 4401 Wilshire Drive, 4th Floor, Los Angeles, California 90010 whose phone number is (323) 556-2550. Center For Jewish Community Studies whose address is 5800 Park Heights Avenue, Baltimore, MD 21215 USA http://www.cjcs.net/ and they are and affiliate of the Jerusalem Center for Public Affairs.

Jerusalem Center for Public affairs http://www.jcpa.org/ is the institute that publishes a web site titled “N G O-Monitor.org” as show in the link below http://www.ngo-monitor.org/archives/infofile.htm USA and the State of Texas and it can be served through its Attorney General Greg Abott at Office of the Attorney General, 300 W. 15th Street, Austin, TX 78701.

Joe Kaufman, Chairman of Americans Against Hate in his personal capacity and Americans Against Hate and both parties can be served at their address at his declared places of business, 3601 West Commercial, Suite 24, Fort Laurderdale, Florida, 33306. Daniel Pipes in his individual capacity and he can be served at Campus Watch, 1500 Walnut Street, Suite 1050, Philadelphia, PA 19102. Campus Watch and they can be served at Campus Watch, 1500 Walnut Street, Suite 1050, Philadelphia, PA 19102. MilitantIslammonitor.org and they can be served at through CB ACCOUNTS, INC. 1101 MAIN STREET, SUITE 300,PO BOX 1289 ,PEORIA ,IL ,61602 and Freerepublic. LLC and Jim Robinson in his personal capacity and they can be served at P.O.Box: 9771, Fresno, CA 93794

Jurisdiction
Jurisdiction of this Court is appropriate due to constitutional questions, The Sherman Act, The Civil Rights Act of 1964, The Hobbs Act, The Lanham Act, Federal Telecommunication Act of 1996, The RICO Act, the Federal Trademark Dilution Act; Texas Business and Commerce Code, Texas Trademark statues and due to diversity of jurisdiction and the fact that Plaintiff lives and works in Texas while Defendants live and operate in various cities and states around the United States and Israel.

Venue
Venue is appropriate in the Western District, Austin Division since actions by Defendants actions resulted in damages that took place in Austin and Travis County Texas where Plaintiff lives and works. Defendants are still interfering with and harming Plaintiff’s personal and business interests in Austin, Travis County, Texas and throughout the United States. Venue is also appropriate due to the diversity of the jurisdiction of the parties and actions taken by Defendants in various states and nations.

Nature of Action
This action arises from Defendants’ publication of various articles and allegedly “research analysis” containing false information on their web sites listed above in item I “Parties” regarding Plaintiff and his business and “political” activities. Also, Defendants did and are still engaged in the publication of allegations accusing Plaintiff of engagement in illegal terrorist actions and recruitment for “Jihad”, violent and terrorist acts against Jews and possibly United States citizens. Plaintiff would like to draw the attention of the honorable Court to Exhibits 1, 2, 3,4,5 and 6 where Defendants alleged in their publications that Plaintiff operates an “Islamic charity” with “links to terrorism in the West Bank and Gaza.” The links for the online articles are below:

Exhibit:1 http://www.frontpagemag.com/Articles/ReadArticle.asp?ID=8394
Exhibit:2 http://www.discoverthenetwork.org/groupProfile.asp?grpid=6381
Exhibit 3: http://www.ngo-monitor.org/editions/v1n09/v1n09-4.htm
Exhibit 4: http://www.ngo-monitor.org/editions/v1n10/v1n10-2.htm
Exhibit 5: http://www.militantislammonitor.org/article/id/19
Exhibit 6: http://www.campus-watch.org/article/id/704

Additionally, Plaintiff would like to draw the attention of the Honorable Court to Exhibits 3 and 5 and the links above where Defendants have a link with the following statement:
“Humanitarian NGO’s in the West Bank and Gaza linked to terrorist organizations.” The statement can be seen on the bottom of (Exhibit 3) while the same statement can be seen on the left side of (Exhibit 4) and the links with the same numbers. Besides, in exhibit 1, Defendants falsely claim that Plaintiff Riad Elsolh Hamad directs an “Islamic Charity” and is allegedly using his business as an instrument in “recruiting for Jihad” through a “charity” based in Gaza, Palestine. All three statements and allegations are absolute lies, false, unsubstantiated and published with intentional disregard of the truth and reality to harm Plaintiff and damage his name and business interests. The statements were published deliberately, maliciously and willfully in order portray Plaintiff as a violent, hateful, criminal and extremist person who threatens the safety of his community and that of the United States of America and humanity as a whole. Defendants claim in their web site that the “research” is “solid” and not a matter of opinion which is protected by the Constitution of the United States and the State of Texas.

Plaintiff brought this action for Libel and Slander, Malicious Libel, Malicious Slander, Defamation of Character, Defamation of Character With Intent To Cause Mental Anguish, Libeling and Slandering a Business Name, Defamation through Fraud of a Business Name, Interference With a Business Contract, Torturous Interference With A Business Contract, Conspiracy to Interfere With a Business Contract, Interference With Interstate Commerce, Conspiracy To Interfere With Interstate Commerce, Interference With Internet Commerce, Conspiracy To Interfere with Internet Commerce, Intentional Infliction of Mental Anguish And Anxiety With The Intent to Injure, Invasion of Privacy, Fraud, Negligence, Gross Negligence, Disparagement of a Business Name, Disparagement of Products, Dilution of a Business Name, Torturous Interference With Prospective Business Advantage, Violation Of Federal Dilution Act 15 U.S.C. 1125(c) and will address each one of Defendants’ unlawful actions below…

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