Case 1:10-cv-01035-LMB -JFA Document 1-1 Filed 09/16/10 Page 1 of 8

EXHIBIT A
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VIRGINIA:
IN THE CIRCUIT COURT OF FAIRFAX COUNTY..
i'J f:;:i:32
FARZAD DARUI,

Plaintiff,
2 0 10-8311
Civil Action No.

THE ISLAMIC CENTER OF

WASHINGTON, DC,
SERVE: By private process.

and

DR. ABDULLAH M. KHOUJ,

in his individual capacity,
SERVE: By private process.

Defendants.

COMPLAINT

Plaintiff Farzad Darui, by counsel, states as follows for his Complaint:

THE PARTIES

1. Plaintiff Farzad Darui, an adult individual, is a citizen of Virginia and a resident

of Fairfax County.

2. PlaintiffDarui wasthe manager ofthe Islamic Centerof Washington, DC, from

1994 to August 2006.

3. At all relevant times, plaintiffDarui was a Director and the Chief Executive

Officer of Zaal, Inc.

4. Atall relevant times, plaintiff Darui was the President of Blue Line Travel, Inc.
5. Defendant Islamic Center of Washington, DC ("Center"), is a non-stock

corporation organized under the laws of the District of Columbia.

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6. Defendant Dr. Abdullah M. Khouj is an adult individual and a resident of Fairfax

County. He is a citizen of Saudi Arabia, working and living in the United States from 1984 to

September 2002 pursuant to anA-1 (Diplomatic) visa, and from October 2002 through the
present pursuant to an R (Religious) visa.

7. At all relevant times, Khouj was the Chief Imam and Director of the Center.

PROCEDURAL HISTORY

8. On September 15,2006, The Islamic Center filed a civil complaint against Darui
in the United States District Court for the Eastern District ofVirginia alleging, among other
things, that Darui had unlawfully taken money from the Center.

9. Khouj and, upon information and belief, a co-conspirator provided the allegations
for the civil complaint.

10. The civil complaint alleged the Islamic Center, the sole plaintiff, tobe the victim
of Darui's conduct.

11. At issue in the civil suit were checks written from the so-called "Special
Account," which was opened and held inthe name and social security number of "Dr. Abdullah
M. Khouj."

12. All the checks listed in the civil complaint were written on the "Special Account."
13. The civil complaint contained numerous false statements, such as: "Khouj did not
authorize payment[s]" to the two businesses ofDarui; Darui "changed the payee names" on
certain Center checks after "Khouj signed" them; and the Center's accounting firm told Khouj it
was not in possession of "any" of the Center's cancelled checks.

14. Khouj was well aware that, throughout the relevant time period, the Islamic
Center did not own the "Special Account." In fact, the account was Khouj's personal bank
 Case 1:10-cv-01035-LMB -JFA Document 1-1 Filed 09/16/10 Page 4 of 8

account as it was in his name, under his social security number, and he was the sole signatory.

Khouj wrote checks for certain personal expenditures from the account as well as expenses for

the Center.

15. In response to Darui's Motion to Dismiss the civil suit, Khouj madedeclarations

under penaltyof perjury in a six-page affidavit, which contained numerous false statements. The

affidavit was unwittingly prepared by Williams & Connolly LLP, the law firm thatfiled the civil
complaint on behalf of the Center.

16. The Center later voluntarily dismissed the civil suit, and the Orderof Dismissal

was signed on December 14, 2006.

17. The termination of the civil suit was not unfavorable to Darui.

18. Khouj falsely told Williams & Connolly LLP and falsely stated inhis affidavit
filed during the civil suit that the un-cashed checks were originally made payable to the Center's
vendors and that Darui subsequently altered these checks bychanging the payee to one ofhis
businesses, Zaal, Inc. or Blue LineTravel, Inc. and then cashed them.

19. Also, as abasis for the civil suit, Khouj falsely told Williams &Connolly LLP
and falsely stated inhis affidavit filed during the civil suit that he had never seen orheard of Zaal
or Blue Line and had never authorized checks to those businesses. However:

a. Khouj personally purchased several plane tickets and at least one money order
from Blue Line Travel from 2001 to 2003;

b. Khouj authorized and signed a check from the Islamic Center Administrative
Account (#7866) for $437 to purchase a plane ticket from Blue Line Travel
for a co-conspirator's brother;
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c. Khouj signed a contractwith Darui that specifically refers to "Zaal." The

contract was regarding repayment to Darui for providing housing, food, and

cash, at Khouj's request, for Debbi Estrada, one of Khouj's"wives" or

mistresses;

d. When Khouj made his regular visits to Estrada, who was residing atDarui's
apartment building, he passed an entranceway sign that read "Zaal, Inc."

20. Bank of America provided photocopies of the cashed checks.

21. Documentary evidence of the false allegations is based on photocopies of

documents, including un-cashed checks, provided exclusively by the Royal Embassy ofSaudi
Arabia.

22. Forthe most part, each photocopy of a cashed checkfrom Bank of America has a

"twin," that is, a photocopy, provided bythe Saudi Embassy, of anun-cashed check with the
same check number, date, and amount to be paid. For most sets of"twins" only the payee is
different, with thecashed check made payable to oneof Darui's businesses and the un-cashed
check made payable to a Center vendor.

23. Some "twin" checks (with the same number, date, and amount) have different
notations in the memo line.

24. There are also some "twin" checks (with the same number, date, and amount)
where neither the payee on the cashed check nor the payee on the un-cashed check bears any
relationship to Darui or his businesses. These checks were omitted from the civil complaint.
25. In fact, Khouj signed and authorized the cashed checks to Darui's businesses
because he owed Darui for the housing and upkeep oftwo ofhis "wives" or mistresses, Estrada
and Noufissa Zouhri.
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26. Thecivil suit was brought based solely on photocopies; there wasnot one original

allegedly altered check—moreover, noneof the copied cashed checks shows anysign of

alteration.

27. Themalicious and unwarranted filing of the civil suit generated significant

publicity, including articles in The Washington Post and The Washington Times.

28. Thesham lawsuit, the attendant publicity, and additional false statements by

Khouj led directly to the issuance ofsearch warrants for Darui's home and businesses, resulting
in a seizure of his property.

29. The sham lawsuit, the attendant publicity, and additional false statements by
Khouj also led directly to the issuance of an arrest warrant for Darui, resulting in arrest of his
person.

30. As a result of Khouj's false allegations, Darui was removed from his jobas
manager of theIslamic Center, which he held for over twelve years.

31. The sham lawsuit and the attendant publicity caused additional special injury to
Darui.

COUNT 1: MALICIOUS PROSECUTION

32. The allegations of paragraphs 1 through 31 are incorporated.

33. The acts set forth above were committed bydefendants.

34. The civil action was seton foot bythe defendants and terminated in a manner not
unfavorable to the plaintiff.

35. The civil action was procured with cooperation of thedefendants.

36. The civil action was without probable cause.

37. The civil action was malicious.

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38. Darui suffered special injury, including but not limited to arrest ofhis person and
seizure of his property.

39. The defendants' acts proximately caused damages to Darui.

WHEREFORE, Farzad Darui requests judgment in his favor and against defendants in

the amount of five million dollars, plus the costs of this proceeding.

COUNT 2: CONSPIRACY TO COMMIT MALICIOUS PROSECUTION

40. The allegations set forth in paragraphs 1 through 31 areincorporated.

41. The defendants and others combined, agreed, and engaged in concerted action to

commit the tort ofmalicious prosecution.

42. The defendants therefore combined, agreed, and engaged in concerted action to
accomplish an unlawful purpose.
43. The defendants also combined, agreed, and engaged in concerted action to
accomplish their purpose by unlawful means.
44 The defendants- acts in furtherance ofthe conspiracy caused damages to Dami.
45. Khouj had an independent personal stake in the outcome ofthe conspiracy dueto
hisdesiretohidehispaymentstoDaruifortheupkeepofhis wives orm
1 ~fw,c "wives" or mistresses from certain

neople in the Saudi Embassy. .

• A^m in his favor and against defendants in
WHEREFORE, Farzad Darui requests judgment in his
the amount offivemillion dollars, plus the costs ofthis proceeding.
nypyrraMAND

PUintiffre^s atrial by jury on a., issue, so triab.*.

FARZAD DARUI
By Counsel
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WEBSTER BOOK LLP

Q4_
Steven T. WebJterfVSB No. 31975)
Aaron S. Book (VSB No. 43868)
300 N. Washington Street, Suite 404
Alexandria, Virginia 22314
888-987-9991 Phone & Fax
abook@websterbook.com
Counsel for Plaintiff