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were any developments on Mr. Algibhah s case that triggered this renewed attempt at
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questioning. The agent replied that there was none, reiterating that Mr. Algibhah was not
in any trouble, and that he was trying to bring the matter to a conclusion.
141. Mr. Algibhah has not heard from Agent Artousa since. Mr. Algibhah believes that he
remains on the No Fly List.
142. On multiple occasions over the course of the past few years, Mr. Algibhah s American
Muslim relatives and acquaintances have reported to him that they have been approached
by government agents, including FBI agents, at their places of work or at the airport, and
extensively questioned about Mr. Algibhah. This has caused Mr. Algibhah to be viewed
in his community as someone targeted by law enforcement, resulting in his alienation,
stigmatization, and loss of employment. Since the FBI s attempts to recruit Mr. Algibhah
as an informant, members of Mr. Algibhah s community have taken to distancing
themselves from him. In turn, Mr. Algibhah has also distanced himself from Muslim
organizations, from his mosque and from many in his community. He no longer speaks
with people in his mosque or his community because he is worried that they will report
what he says to the FBI.
143. Mr. Algibhah, who is very close to his daughters and wife, typically visited them in
Yemen at least once every year. Mr. Algibhah has not seen his family since April or May
2009, the last time he was able to travel to Yemen successfully. He has attempted to fly
to Yemen two times since then, and has been denied boarding each time. Upon
information and belief, Mr. Algibhah remains on the No Fly List.
144. Mr. Algibhah s placement on the No Fly List has caused him severe emotional distress.
Mr. Algibhah has also suffered economic loss because of his placement on the No Fly
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List, including but not limited to loss of income and expenses and fees related to the
purchase of airline tickets.
Plaintiff Naveed Shinwari
145. Plaintiff Naveed Shinwari is a lawful permanent resident of the United States and has
lived in the United States since 1998, when he was 14 years old. He currently lives in
West Haven, Connecticut. Mr. Shinwari has been married since January 2012. His wife
resides in Afghanistan. Mr. Shinwari earned a Bachelor of Science degree from Southern
Connecticut State University in Public Health in May 2008. He has worked for a temp
agency, placed on assignment in North Haven, Connecticut, since April 2013. Mr.
Shinwari has never been convicted of a crime or arrested. Mr. Shinwari does not pose,
has never posed, and has never been accused of posing, a threat to aviation safety.
146. On February 26, 2012, after getting married in Afghanistan, Mr. Shinwari was traveling
with his mother, who is a United States citizen, back home to the United States. They
flew from Kabul, Afghanistan to Dubai, United Arab Emirates en route to Omaha,
Nebraska, where they were residing at the time. They flew from Kabul to Dubai but were
then prevented from boarding their connecting Emirates Airlines flight to Houston, Texas.
Airport security officials confiscated Mr. Shinwari s Afghan passport and instructed him
to wait in the terminal. After several hours of waiting, airport security officials returned
the passport and told Mr. Shinwari that he needed to visit the United States embassy
before he would be allowed to fly.
147. That night, after Mr. Shinwari and his mother obtained temporary visas to stay in the
United Arab Emirates and checked into a Dubai hotel, Mr. Shinwari received a phone call
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from FBI Special Agent Steven LNU. Agent Steven LNU told Mr. Shinwari to meet him
the next day at the United States consulate in Dubai.
148. The next day, February 27, 2012, Mr. Shinwari went to the consulate. When he arrived,
Agent Steven LNU and FBI Special Agent John C. Harley III took Mr. Shinwari into an
interrogation room, and instructed Mr. Shinwari to  tell [them] everything. Mr.
Shinwari replied he had no idea why he had been prevented from flying. Agents Harley
and Steven LNU proceeded to interrogate Mr. Shinwari for three to four hours. Agents
Harley and Steven LNU asked Mr. Shinwari whether he had associated with any  bad
guys while in Afghanistan, whether he had visited any training camps, where he had
stayed during his trip, and whether he had traveled to Pakistan. The agents also asked
Mr. Shinwari about his religious activities, including which mosque he attends, and more
general questions about his origin and background. During the interrogation, the agents
sometimes used language that Mr. Shinwari found threatening, and at times Mr. Shinwari
felt coerced to speak. Believing that he had to provide the agents information in order to
return to the United States, Mr. Shinwari answered all of the agents questions. Mr.
Shinwari provided documents to Agents Harley and Steven LNU, including his driver s
license and other identification papers, which the agents photocopied.
149. At several points during the interrogation, Agents Harley and Steven LNU asked Mr.
Shinwari to take a lie detector test. They said that if he took the test, it would help him to
be able to return home to the United States. Mr. Shinwari declined to take the test,
believing he had already been truthful in his answers.
150. At the end of the interrogation, Agents Harley and Steven LNU said they needed to [ Pobierz całość w formacie PDF ]