// typst compile "imi vs UNITED STATES OF AMERICA.typ" #set page(margin: 1in) #set text(font: "EB Garamond", size: 12pt) #align(center)[#text(size: 14pt, weight: "bold")[UNITED STATES DISTRICT COURT]] #align(center)[#text(size: 12pt, weight: "bold")[FOR THE DISTRICT OF #rect(width: 10em, height: 1em, fill: black)]] #align(center)[*imi, on behalf of himself*] #align(center)[*and all others similarly situated,*] #align(center)[*Plaintiff,*] #align(center)[v.] #align(center)[*UNITED STATES OF AMERICA,*] #align(center)[*COMMISSIONER OF INTERNAL REVENUE SERVICE,*] #align(center)[*and ATTORNEY GENERAL OF THE UNITED STATES,*] #align(center)[*in their official capacities,*] #align(center)[*Defendants.*] #align(center)[*Case No.: [To Be Assigned]*] #align(center)[*CLASS ACTION COMPLAINT FOR DECLARATORY JUDGMENT, INJUNCTIVE RELIEF, AND DAMAGES*] = I. INTRODUCTION 1. This class action challenges the Federal Government's recognition and support of Submission (the literal translation of "Islam" from its original Arabic), a social structure that operates as a death cult under the definitions in the Death Cult Recognition and Prohibition Act of 2025 (the "Act"), while masquerading as a religion. By granting Submission tax-exempt status and other benefits under 26 U.S.C. § 501(c)(3), the Government has enabled an entity that imposes a no-exit policy equivalent to death, enforces secrecy and deception, and reduces societal health through censorship and harm—all in violation of fundamental public policy and Plaintiffs' constitutional rights. 2. Plaintiffs seek primarily a declaratory judgment that Submission is a death cult and injunctive relief to dismantle it by revoking federal benefits; secondarily, damages for personal harms, though willing to settle without monetary compensation if primary goals are met. 3. This suit invokes the Court's jurisdiction to enforce public policy against entities that perpetuate evil, as defined in the Act (provably bad for the United States of America's health), drawing from precedents like *Bob Jones University v. United States*, 461 U.S. 574 (1983). = II. JURISDICTION AND VENUE 4. This Court has federal question jurisdiction under 28 U.S.C. § 1331, as this action arises under the U.S. Constitution (First and Fourteenth Amendments), the Declaratory Judgment Act (28 U.S.C. § 2201), and *Bivens v. Six Unknown Named Agents*, 403 U.S. 388 (1971). Supplemental jurisdiction exists under 28 U.S.C. § 1367. 5. Venue is proper under 28 U.S.C. § 1391(e). = III. PARTIES 6. Plaintiff imi is a former member of Submission, forced into it as a child, under its death penalty since teenage years after publicly apostasizing. He brings this on behalf of a proposed class of current/ex-members harmed by Submission and the Government's support. Plaintiff is suing pro se because the threat from Submission is so severe that it is hard to find lawyers who will touch this case. 7. Defendant United States of America is the sovereign entity whose agencies have recognized and supported Submission. 8. Defendant Commissioner of Internal Revenue Service is sued in their official capacity for granting and maintaining Submission's tax-exempt status. 9. Defendant Attorney General of the United States is sued in their official capacity for failing to enforce laws against harmful entities like death cults. = IV. CLASS ALLEGATIONS 10. Plaintiff seeks certification under Fed. R. Civ. P. 23(b)(2) for injunctive/declaratory relief (common questions: Does Submission qualify as a death cult? Has Government enabled it?), and 23(b)(3) for damages if pursued (predominance of common issues over individual). Class is numerous (millions affected, including all American Muslims trapped without consent), typical (shared harms from threats/duress), and adequate (Plaintiff's story mirrors class). Questions predominate; class action superior for efficiency. = V. STATEMENT OF FACTS 11. Submission is a social structure recognized by the Government as a religion, enjoying tax-exempt status and other benefits under 26 U.S.C. § 501(c)(3). However, it meets all criteria of a "death cult" as defined in the Act: (A) Exit is not allowed, enforced by a violent minority (enforcers) imposing death for apostasy. (B) The no-exit condition is secret, concealed from potential members, with the entity pretending to be benign. (C) Members are forced to deceive about its nature under duress; revealing the no-exit rule is akin to attempting to exit the cult. (D) It is provably bad, defined as evil, reducing the health of the United States (cumulative expected lifespan) by perpetuating fear, violence, and censorship. (E) It relies on a minimal number of enforcers to maintain rules, as the cost of exit—death—is sufficiently threatening and real to ensure compliance with only a few enforcers required; this ratio leverages secrecy and censorship to sustain the no-exit policy and reduce information flow. 12. Evidence includes: Physical books in Submission's places of teaching (mosques) explicitly stating death penalties for ex-members, such as Sahih Bukhari (e.g., Volume 9, Book 84, Number 57: "Whoever changed his Islamic religion, then kill him."), Sahih Muslim, Sunan Abu Dawud, Sunan Ibn Majah, and Sunan an-Nasa'i, all containing statements [Hadiths] mandating execution for apostasy; Verses from Submission's main book [Quran] interpreted by scholars to justify death (e.g., Quran 4:89: "But if they turn renegades, seize them and slay them wherever ye find them"); scholarly works from all major schools of Submission law (Hanafi, Maliki, Shafi'i, Hanbali, Ja'fari) agreeing on death for male apostates refusing repentance, as in Reliance of the Traveller (Shafi'i: "When a person... voluntarily apostatizes from Islam, he deserves to be killed") and Tahrir al-Wasilah (Shi'ite: apostates condemned to death after refusal to repent); affidavits from ex-members; expert analyses showing health reductions due to fear and violence perpetuated by these teachings. 13. The Government has aided Submission by granting tax exemptions, allowing deductions for contributions, and providing implicit legitimacy, despite its harmful practices. This violates public policy against entities that deny freedom and impose death threats, akin to racial discrimination in *Bob Jones*. 14. As noted in the Act's Finding (4), allowing death cults restricts First Amendment rights of all citizens by enabling coercive structures that undermine free speech and association. 15. The Government's actions establish or favor a harmful "religion" in violation of the Establishment Clause (First Amendment) and deny equal protection (Fourteenth Amendment) by treating harmful cults as legitimate. Submission teaches death for ex-members via books in all teaching sites (mosques), trapping class members in fear, as evidenced by consensus in biographies [Hadiths] of the late founder of Submission (e.g., Sahih Bukhari: "The blood of a Muslim... cannot be shed except... the one who reverts from Islam (apostate)") and scholarly edicts [fatwas] (e.g., Yusuf Al-Qaradawi: apostates to be punished by death). Furthermore, the entity teaches its members and enforcers that its rules supersede local laws. = VI. PLAINTIFF'S PERSONAL ALLEGATIONS *(Replaceable for other class members.)* 16. Plaintiff was forced to join Submission as a child and apostasized publicly as a teenager and has been under its death penalty for apostasy for several decades, causing severe depression, anxiety, and difficulty providing for family. 17. This distress stems from knowing an entity seeks Plaintiff's death for thoughts and beliefs, impacting a highly skilled individual: top graduate in pure math from Germany's premier university and twofold world champion in computing fields. 18. The Government's support has exacerbated these harms by legitimizing Submission, preventing Plaintiff from fully escaping its shadow. = VII. CAUSES OF ACTION == First Cause: Violation of First Amendment (Establishment Clause) 19. By recognizing and benefiting Submission, Defendants have established a harmful cult as religion, violating Plaintiffs' rights and public policy. == Second Cause: Violation of Fourteenth Amendment (Equal Protection/Due Process) 20. Defendants' actions arbitrarily favor harmful entities, denying Plaintiffs equal protection and substantive due process by enabling threats to life and liberty. == Third Cause: Declaratory Judgment 21. A controversy exists; Plaintiffs seek declaration that Submission is a death cult and Government support violates law/policy. = VIII. PRAYER FOR RELIEF WHEREFORE, Plaintiffs pray: A. Class certification. B. Declaratory judgment that Submission is a death cult. C. Permanent injunction revoking tax-exempt status/benefits, prohibiting assistance, and requiring public statement. D. Compensatory damages of \$1,000,000 (or such amount as the Court deems just) for emotional/economic harms, though Plaintiffs offer to forego if primary relief granted. E. Attorney's fees, costs, and other just relief. Respectfully submitted, /s/ imi \ imi, Pro Se \ The United States Of America \ [Date: November 8, 2025]

Hundreds of child marriages revealed in Germany - with girls as young as 11 married to Iraqis, Syrians and Pakistanis trib.al/T6ycgHY

🚨 AMERICA'S ISLAMIC TAKEOVER CAIR FOUNDER UNVEILS 20-YEAR POLITICAL TAKEOVER STRATEGY FROM U.S. MOSQUE.... “We Will Write Our Own Narrative… We Will Produce Lawmakers… We May Have a Supreme Court Judge.” Two years ago, CAIR founder Nihad Awad revealed a structured, long-term political strategy aimed at transforming America’s legal, media, academic, and political systems, openly laid out from the pulpit of an American mosque in Maryland. Awad described what he called a “framework for success” for the Muslim community - a generational plan to convert mosques into operational hubs, scholarships into recruitment pipelines, and CAIR into a permanent legal-political enforcement arm. “We have almost 4,000 mosques in America… That’s the infrastructure of the Muslim community,” Awad declared. “Establish a scholarship fund… for five students: one to study journalism, one filmmaking, one law, one political science, and one history.” 🔺 He then spelled out the scale and purpose of the project: “If we start in 2025 or 2026… four years from now we will have 4,000 new journalists, filmmakers, lawyers, political scientists, and history students.” And the end goal: “Twenty years from now, the Muslim community will have 50,000 attorneys, 50,000 journalists, 50,000 filmmakers, 50,000 professors… We will write our own history. We will write our own narrative.” “The Muslim community will be able to produce policymakers and lawmakers… We may have 50 members of Congress, five senators, and potentially a Supreme Court judge.” 🔺 This is a blueprint for institutional capture. Mosque Money → Political Infrastructure Awad explicitly instructs mosque leadership to establish annual scholarship funds to finance careers in: • Journalism • Filmmaking • Law • Political science • History These are media, legal, and political power lanes. By his own words, the purpose is not education for its own sake - it is narrative control, policymaking influence, and long-term political dominance. 🔺 CAIR Named as the Enforcement Vehicle Awad directly names CAIR as the institutional engine for execution: “Allah has blessed us to create an organization called CAIR - the Council on American-Islamic Relations… The purpose of it is to empower the American Muslim community socially and politically and defend the rights of American Muslims.” 🔺 “CAIR Is Not Afraid to Sue the U.S. Government” Awad openly boasts about courtroom warfare against federal agencies: “CAIR is not afraid to sue the U.S. government. In fact, we did many times.” “We sued the FBI… it went all the way to the Supreme Court… and the result was 9–0 in favor of CAIR.” He frames litigation not as accountability - but as strategic leverage: “That shows our nation is still in good shape. But we need political and legal advocates… If we are safe, we will succeed as Muslims.” This is not grievance rhetoric; it is power-building doctrine. 🚨 Awad’s own words confirm: • A 20-year political growth plan • A mosque-funded recruitment pipeline • A media and narrative-control strategy • A lawfare-based pressure apparatus • An explicit goal of placing Muslims into Congress, the Senate, and even the Supreme Court • CAIR positioned as the institutional weapon to enforce it They Told Us the Plan - Now It’s in Motion Awad presented a step-by-step roadmap for building political, legal, and media dominance - using American mosques as infrastructure nodes and CAIR as the enforcement arm. WHERE IS THE FEDERAL GOVERNMENT - WHY ARE THEY NOT PROTECTING AMERICA FROM THIS TERROR-TIED ORGANIZATION!? WHY DOES OUR FEDERAL GOVERNMENT REFUSE TO SHUT DOWN CAIR!?

Abdul El-Sayed repeatedly denied having Muslim Brotherhood family members on @MeetThePress today. But @FreeBeacon found posts from @AbdulElSayed’s sister stating: “My family has long been Muslim Brotherhood.” She said some have been “jailed” over ties to the Islamist group. freebeacon.com/democrats/abd…

NOW: Reporters confront NYC Mayor Zohran Mamdani with questions about October 7 and his anti-Israel statement about the horrific Hamas attack. "Is there a line that you would add to your statement? Is there one you would take out?" Mamdani refuses to answer either question, instead describing the anniversary as a day of mourning for both sides of the conflict. He then accuses Israel's government of using the Hamas attacks to justify what he describes as an ongoing genocide: "We know that it brings up the most horrific memories for so many in the city, and also, for others, it is a day that is continuing, and it's in the Israeli government's use of it as a justification for a genocide."