Beruflich Dokumente
Kultur Dokumente
Plaintiffs,
Case No. 18-CV-6615-CS
v.
JAMAL BENOMAR,
Defendant.
I, Jamal Benomar, declare under penalty of perjury pursuant to 28 U.S.C. § 1746 that to
1. I am over 21 years of age, now 61, and have personal knowledge of the facts and matters
attested to in this Declaration. I am competent to be a witness to the facts and matters attested to
in this Declaration.
2. Originally from Morocco, I became a person concerned about and worked on human rights
issues at a very young age. As a student, I peacefully protested to oppose the then-repressive
government of Morocco. I learned early on that standing up for victims of government abuse comes
at a high cost.
3. I was arrested and while in secret detention sometimes tortured and imprisoned for a total
of eight years. While I was detained in prison, my father died. After many years, I was granted
political asylum in the United Kingdom, but I was still exiled from my native country and my
family.
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4. While in prison, I earned a bachelor’s degree and two master’s degrees from the University
of Paris. In exile, I continued my studies and received my doctorate from the University of London.
5. In 2005, while still in exile, my mother died. After nearly twenty years in exile, I returned
to Morocco for the first time to attend my mother’s funeral. As a former political prisoner, I was
offered compensation by the Government of Morocco, which I declined. Instead, I chose to focus
6. I pursued my passion for standing up for victims of human rights abuses by working for
Amnesty International in London as an Africa researcher and team leader. I then joined the Human
Rights Program at the Carter Center at Emory University as the Director. I worked closely with
former U.S. President Jimmy Carter on human rights and conflict resolution.
7. In 1993, I joined the United Nations. During my career at the UN, I worked for the Office
of the High Commissioner for Human Rights, the United Nations Development Programme and
the Department of Political Affairs, and the Executive Office of the Secretary General. I also
served as the Interim Director of the Peacebuilding Support Office and as the Director of Rule of
Law in the Office of the Secretary General. I served both in the field and at the Geneva and New
York headquarters.
8. While working for the United Nations, I helped foreign governments develop and enact
laws to ensure compliance with their international human rights obligations. I also advised them
on governance, rule of law, and conflict-resolution issues. In this capacity, I assisted more than
forty governments in Africa, Latin America, the Middle East, Eastern Europe, and Asia, to ensure
that their laws, policies, and institutions are protective of human rights.
9. I devoted much of my career working in conflict countries, which are by definition some
of the most dangerous places in the world. While in these regions, I often took the lead negotiating
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with various armed groups for the cessation of hostilities and to promote disarmament and peaceful
10. While working for the UN, like many other devoted UN diplomats, I served conflict-ridden
and war-ravaged regions that put me in harm’s way. Twenty-two of my close colleagues were
killed in a suicide bombing of the UN headquarters in Baghdad on August 19, 2003. I was a
member of this team but was not present at the time. On other occasions, I was shot at, including
one incident involving an RPG that miraculously did not explode. In 2014, I was informed that I
was the most at-risk senior official in the UN because of the hostilities in Yemen, where I was then
11. In 2002, I served in Afghanistan after the Taliban regime collapsed to advise on
governance issues. In early 2004, I returned to Iraq and provided advice on the establishment of
the interim government. I later served as the Secretary General’s Envoy to support the National
12. In 2005, I helped establish the United Nations Peacebuilding Commission and
13. In 2006 and 2007, I held many quiet and confidential rounds of talks with leaders of Iraqi
broker a transition deal in Yemen that prevented the country from the imminent outbreak of an all-
out civil war. I was commended for this effort in an official Security Council statement. This deal
was the only negotiated peaceful transition agreement in the context of the Arab Spring and was
hailed by the international community at the time as a model for the peaceful resolution of conflict
as well as a model for UN mediation. In recognition of my work in this regard, I was declared man
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of the year by the Yemen Times and was promoted on August 1, 2012 to the rank of Assistant
Secretary-General.
15. In 2013 and 2014, I was the lead mediator and facilitator of a ten-month-long Yemeni
national dialogue conference that eventually yielded a new governance system in Yemen. I also
supported and facilitated the work of an inclusive constitution-making process that produced a
draft of a new constitution. In this capacity, I worked to ensure that women had the opportunity to
participate effectively in both the national dialogue and in the constitution-making process. The
result was a progressive legal framework for democratic governance, human rights, and the
empowerment of women, including, most prominently, a provision that required that at least 30%
16. Some leaders in the neighboring Gulf Cooperation Council (“GCC”) countries, including
a neighboring country where women were not even allowed to drive, were not pleased with the
and uncertainty of outcome. The UAE and some leaders in Saudi Arabia instead wanted to have
17. It is against this background that the UAE in 2012 began to pressure the Secretary General
of the UN to remove me from my position. The Secretary General declined to yield to the pressure.
Instead, I was promoted twice, first, as previously stated, in August 2012, to the rank of Assistant
Secretary General, and then, on January 1, 2015, to the high rank of Under Secretary General.
Security Council resolutions and statements adopted during my tenure from 2011 to 2015 routinely
18. When the situation escalated and Houthi rebels marched on the Yemeni city of Sana’a and
took control of all the state institutions, in violation of all previous agreements and Security
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Council resolutions, most diplomatic missions left the country. I stayed despite the precarious
security situation and notwithstanding a demarche from the Saudis who urged the Secretary
General to instruct me to leave. I remained in Sana’a, fully engaged in my diplomatic efforts with
all sides of the conflict. After the house arrest of the Yemeni President by the Houthis, I engaged
in intensive negotiations for his release. He escaped in the midst of the negotiations. My efforts
yielded, among other things, the release of the Prime Minister and other ministers who were then
19. Also at this time, when the United States government decided to evacuate all its Embassy
personnel, the Houthis blocked the passage of hundreds of Americans, including about a hundred
U.S. military personnel, and threatened to invade the U.S. Embassy compound. At the request of
the U.S. Ambassador, I met with the Houthis and obtained safe passage of the U.S. Ambassador
and hundreds of his staff. I led a UN security team that escorted the Ambassador and his staff
through numerous checkpoints controlled by the Houthi militia. I also secured guarantees from the
Houthis that they would not breach the U.S. Embassy. When the U.S. Ambassador was finally able
to leave Yemen, he texted me while taking off, “Thank you Jamal. You are a Hero.”
20. From early January 2015 through March 2015, I presided over a new round of an inclusive
approximately 65 plenary and working group meetings and had approximately 150 bilateral
meetings with different political actors. The negotiations led to a new consensus and the parties
were very close to finalizing a comprehensive agreement—with core elements of a power sharing
agreement finalized. The only remaining sticking point was the future of the presidency.
21. During the four years I spent as Special Envoy on Yemen, I traveled to Yemen more than
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22. On March 26, 2015, the Saudis and the Emiratis, with the support of Qatar, Bahrain,
Morocco, and other countries, suddenly and unexpectedly launched a military campaign to defeat
the Houthis and forces loyal to former President Saleh and install a government dominated by their
imminent agreement among the parties. I vocally expressed my opposition to interference by all
foreign powers in Yemeni politics and warned against the destabilizing consequences of this ill
thought-out military intervention. In taking this position, I had the full support of the UN Secretary
General.
23. Saudi Arabia and the UAE strongly criticized my position, but I refused to back off from
what I considered a principled position — consistent with international law and Security Council
resolutions. It is against this background that I stepped down from my position as Special Envoy
to Yemen.
24. In my final briefing to the UN Security Council on Yemen, in April 2015, I expressed
regret that despite my numerous reports on the systematic acts of obstruction by a number of
Yemeni leaders and groups, the Security Council did not act on my warnings more swiftly and
strongly. I also highlighted that war crimes may have been committed during the Saudi-led
Coalition bombing as there was evidence that the Coalition targeted civilians and civilian
infrastructure, such as hospitals and schools. I spoke about the need for an independent
investigation to ensure accountability for violations of international human rights and human rights
law. I explained to the Security Council that the Saudi-led military intervention effectively aborted
the conclusion of a Yemeni agreement. I highlighted to the Security Council that if the UN is to
continue to play a meaningful and constructive role, our main capital – integrity and impartiality
– must be preserved. The UN must continue to have the space to engage in dialogue with all parties,
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including controversial actors and groups. I stressed that Yemenis should be afforded the
opportunity to determine their future free from interference and coercion from outside forces.
25. Because of my position on Yemen, and based on my final briefing to the Security Council,
the Saudi and UAE governments mobilized their respective State media, both in print and on air,
against me. I received thousands of hate messages and even death threats as a result. I was once
harassed in the street in New York by a group of Saudi-Coalition supporters who videoed the
incident and widely circulated it on the internet. This orchestrated campaign continued for several
weeks.
26. In early 2017, I was informed that Crown Prince Mohamed Bin Zaid, the de facto leader
of the UAE, intervened with the UN Secretary General to urge him not to appoint me as the
27. Now that it is four years after the Saudi-led military intervention, I believe my position on
Yemen is vindicated because most foreign policy experts agree that foreign military intervention
in Yemen proved to be catastrophic. More than 10,000 civilians died; widespread war crimes have
been committed in the context of the conflict; and the country is now experiencing what many
people believe is the worse famine and humanitarian disaster in the world.
28. After stepping down as Special Envoy to Yemen, in late 2015 and 2016, I worked with
the Secretary General of the UN as the Under Secretary General for Conflict Prevention including
in Burundi
29. I have been privileged to work very closely with many governments around the world and
those with whom I have worked know that I am comfortable speaking truth to power. Throughout
my career, I advised on sensitive political issues and, at all times, upheld UN norms and values
and urged national leaders to resolve their disputes by peaceful means. I hope, and believe, I am
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known in the international community for my impartiality, my integrity, and for upholding UN
ideals. I have consistently tried to promote justice and the rule of law worldwide.
30. On July 1, 2017, I left the UN after twenty-four years of dedication to the work of that
organization. I was then asked to advise the Kingdom of Morocco by becoming an official in the
31. Since November 1, 2017, I have served as a diplomat with the highest diplomatic rank of
Affairs and International Cooperation of the Kingdom of Morocco. As such, I have advised
Morocco and acted on its behalf on a wide range of foreign policy issues throughout this time. I
work in my position on a full-time basis in New York and, of course, traveling to Morocco and
other foreign countries as is warranted. I do not engage in any systematic trade or business activity
32. Among my responsibilities on behalf of Morocco has been to promote peace and dialogue
with others in the region in the face of unprecedented division that has its roots over many years
but which hit a flashpoint in 2017. Specifically, on June 5, 2017, Saudi Arabia, the UAE and other
Gulf States severed diplomatic ties with and imposed a blockade against Qatar. Press reports
suggest that the dispute was instigated by the UAE, which allegedly orchestrated a hack of Qatar’s
media outlets and attributed false statements to the Emir of Qatar. This was one of many issues
that I became involved with when I began my work at the Mission in November 2017.
33. Many countries, including the U.S., expressed concern because they recognized the
potential for this dispute to quickly escalate. The U.S. repeatedly called for a quick resolution of
the dispute, which threatened to lead to military conflict between some of the countries. Morocco
too was alarmed by the dangerous developments. Morocco’s interests often converge with other
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countries in the Middle East because a stable Middle East benefits all countries there. Knowing
my history of successful mediation, officials in Morocco requested my advice on how to end the
34. In this capacity, and in recognition that a resolution of the crisis with Qatar and an end to
the war in Yemen would serve Morocco’s interests, I provided, as a Moroccan diplomat, foreign
policy advice to a number of regional actors, including Qatar, regarding how best to achieve a
peaceful resolution to these conflicts and the steps I believed were necessary not only to resolve
the blockade and bring an end to the war in Yemen, but, more generally, how to reconcile
differences among the states so that the region might enjoy a greater measure of stability and
harmony.
35. Morocco had initially participated in the Saudi-led bombing campaign in Yemen but
withdrew in 2016. Starting in 2017, I then worked with Morocco and its partners to promote a
peaceful resolution of the conflict. It is against this background that I maintained contact with all
the main Yemeni political actors and advised a number of regional and international actors, at their
request, and in close consultation and cooperation with the government of Morocco.
36. I hold a valid Diplomatic Passport issued by the Kingdom of Morocco, and I possess a
valid G-1 Diplomatic visa issued by the United States on 1 November 2017.
37. Starting after Elliott Broidy brought a lawsuit in California, my family and I became the
subjects of tremendous harassment. A car or cars would park outside our family house for long
periods, including at night. On June 23, 2018, while I was on international travel, a red car with
New York tags HGK 2676 closely followed my 18-year-old daughter from the moment she left
our house and proceeded to follow her for approximately 80 miles, from her running errands in
Westchester, New York, all the way to Highland, New York, where friends of her met her at the
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car and photographed the vehicle. Within a couple of days of this incident, a different red car
38. The acts of harassment intensified after the filing of the New York action, which included,
among other things, surveillance of my house, calls from a person who falsely claimed to be a
customer service agent of certain carriers or vendors asking for personal information and access
to our account information, and eventually sustained, repeated attempts to access my and other
39. It was after harassing events occurred that I consulted with colleagues in the Government.
They expressed concern for my family and me, and it was suggested to me that we seek US
identification credentials to see if that could either help avoid, stop or respond to these acts of
harassment. The Permanent Mission then began the process of seeking such a credential.
40. In addition to the harassment, since the lawsuits were filed, but especially since the October
10, 2018 hearing in this matter, I have become the subject of articles, attack videos and news clips
published by media known to be arms of or sympathetic to the Kingdom of Saudi Arabia or the
UAE. Some of these articles or publications make false accusations about my work and
mischaracterize the allegations made by the complaint in this case. Anonymous sources are used
41. It is my belief that the harassment and the media campaign now being engaged against me
are the result of my work at the UN and as a Moroccan diplomat, and relates to some of the policies
I promoted while in those capacities with respect to issues relating to Yemen and the GCC
countries.
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Executed at New York, New York, this 31st day of October 2018.
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