Addahoumi V Pastides With Exhibits

3:16-cv-01571-CMC-SVH Date Filed 08/04/17 Entry Number 54 Page 1 of 44
UNITED STATES DISTRICT COURT
DISTRICT OF SOUTH CAROLINA
COLUMBIA DIVISION
--
Sammi H. Addahoumi ) Civil Action No. 3:16-01571-CMC-SVH
)
) COMPLAINT FOR INJUNCTIVE
Plaintiff, ) AND DECLARATORY RELIEF
) AND DAMAGES
v. )
) JURY TRIAL DEMANDED
Harris Pastides,Dennis Pruitt, Bobby Gist, Alisa )
Ligget, Maureen Grewe, Augusta Schneider, )
Timothy Bedford, Leslie G. Wiser, Jr., Josef )
Olmert, Scott Prill the USC Board of Trustees, )
USCPD Officer Newton, and Richard L. Frierson )
)
)
Defendants.
INTRODUCTION
1. On May 16, 2014 Defendant Alisa Liggett, Director of Student Conduct at the University
of South Carolina, without notice or any type of hearing, summarily suspended student
Sammi Addahoumi on the pretextual charge of computer misuse. The decision was
communicated in an email from Grewe and attached letter from Liggett. The email was
-------------~-----ctmeu-Mayt(J;-20t4-despirethefactthatthe-attached-suspension-letter-was-dated-April--~------~-----~
11, 2014. (Exhibit A and Exhibit B)

2. The supposed basis for Liggett's outlandish claim was an email that Addahoumi had sent
to Defendant Leslie Wiser and to Mr. Addahoumi' s classmates. The email, which
contained an attached essay, contained no threats of any kind. (Exhibit C)
3. However, Wiser had become increasingly upset with Addahoumi since the student first
distributed emails to his classmates opposing and analyzing the viewpoints Wiser taught
in the classroom. At all times, Addahoumi's statements in his emails focused on the
academic and political issues raised by Wiser in class, and what he saw as the needless
emphasis on profiling Muslims using discredited and biased sources. (Exhibit F)
4. Just as any citizen would do to petition their government, Addahoumi communicated his
views via essays, blogposts, social media, and e-mails and class discussions with
classmates and instructors.
5. Wiser reported Addahoumi to Defendant Liggett several times, exaggerating and
misrepresenting the circumstances in each instant. Mr. Addahoumi was not informed of
these complaints nor was Addahoumi able to contest these accusations. (Exhibit D)
6. Wiser found Addahoumi's protected free speech activities to be entirely unacceptable,
and he took steps to suppress Addahoumi's exercise of his American birthright- the right
to freedom of expression.
7. Wiser complained about Addahoumi s speech activities to other student "peer leader"
groups, faculty members, and other administrators. He ultimately summoned Addahourni
to a meeting in he castigated the student for questioning his judgment about the subject
matter, for embarrassing him, and for threatening the legacy of his Smart-Policing
and stronger and more direct methods were employed to solve the problem.
8. Wiser and Liggett summarily ejected Addahoumi from his CRJU Homeland Security
classroom after another female student had a violent outburst in response to Addahoumi's
input into the class discussion. As the class discussion focused on domestic and
international terrorism, homeland security, and policing, very sensitive and highly
controversial issues such as race, religion, and politics were discussed regularly. Exhibit
E)
9. Wiser and Liggett proceeded to not only charge and sanction Addahoumi, but summarily
and arbitrarily eject him from class. (Exhibit E)
10. Addahoumi filed a report about the incident to Liggett, Grewe, Schneider, Bedford, and
Prill. The report complained that Wiser ordered Addahoumi to leave the classroom under
threat of arrest in response to the outburst of another student (Exhibit F)
11. Seizing upon the tragic school shootings at Virginia Tech University as a pretext, Wiser
and Liggett took steps to brand Addahoumi as a not only a disruption, but a danger
because of his non-violent speech activities and to remove him from campus. (Exhibit D)
12. Liggett, Wiser, Prill, Grew and others charged, then sanctioned Addahoumi with a
classroom disruption charge for a disruption he was not responsible for. (Exhibit H)
13. Addahoumi was not allowed a hearing despite his repeated requests. Instead, Liggett,
Wiser, and defendants arbitrarily prohibited Addahoumi from returning to class, and
mandated that Addahoumi submit a "pass/fail" research paper. (Exhibit I)
14. Knowing that Addahoumi had to previously had to avail himself of counseling services
for a mandated Behavioral Intervention Team (BIT) assessment, which Liggett herself
had mandated, Liggett and Wiser secretly and repeatedly met with USC counselors, legal
counsel, USCPD, and the USC BIT seeking to justify their decision to expel him not only
from class, but from the university. Defendants willfully misrepresented Addahoumi as a
threat to himself or others despite overwhelming contradictory evidence. (Exhibit K)
15. While the BIT defendants Olmert, Wiser Grewe, Liggett, Schneider and Bedford took
multiple disciplinary actions against Addahoumi, they also declined to clarify or even
provide their Behavioral Intervention Team policies and protocols that were the basis of
Addahoumi's numerous "Charge Letters" accusing Addahoumi with "erratic" speech.
Despite charging and sanctioning Addahoumi for "erratic" speech, no definition of
"erratic" was provided or available. (Exhibit K)
16. The BIT website contains vague and broadly-worded provisions that forbid
erratic" "verbal conduct" (that is, "erratic" speech) so that debates about controversial
topics, like racism, the Middle East, immigration policy, "trigger words," or even
feminism could be subject to investigation and sanction by university authorities due to
others being "offended" or "concerned" or "distressed". (Exhibit L)
17. The USC BIT website states "The following behaviors can all be important signs of
distress. As a member of the Carolina community, you may notice a student exhibiting
one or more of the academic, physical, or emotional signs and decide that something is
clearly wrong. Or you may have a "gut-level feeling" that something is wrong. If the
latter is the case, don't dismiss your feelings or feel that you need to wait for tangible
"proof" that a problem exists". (Exhibit L)
18. A notation of the Carolinian Creed, incorporated each BIT letter of charge to Addahoumi,
states "Promoting Civility, Integrity, and the Ideals set forth in the Carolinian Creed to
~"--~----~~~--~
Foster a better living and learning environment in the University Community." The USC
-----------~----~~----~~------~-~-------~~--~------~~--------~--~---~~-~~--~-~-------~- --~------~--------------------~,~-~--~~-----------------~-----------------~--------~------
BIT policies facilitate a "heckler's veto" for other students who believe they have a right
not be offended or "distress" or "concerned" by discussions of serious social issues. And
they exert a profoundly chilling effect, as penalties for violating the policies contributed
to the investigation of, sanction of, and suspension of Addahoumi in retaliation for his
protected free speech activities.
19. Defendants Olmert, Liggett, Grewe, Schneider, and others repeatedly utilized the
Behavioral Intervention to report, investigate, and sanction Addahoumi for his protected
free speech activities. For instance, Olmert had reported Addahoumi for "criticizing
Israel" (Exhibit K)
20. What Wiser and Liggett learned from the campus counseling center clinical psychologists
Dr. Lara Sheehi and Dr. Bryant Kilbourne, who were consulted in the matter, however,
was that Addahoumi had never exhibited any threatening or violent tendencies and that
he did not represent any danger either to himself or to others. Quite to the contrary,
despite a background in which he had been forced to cope with some difficult family
issues from an early age, Addahoumi had developed into an engaged student and aspiring
academic, was a successful business owner, world traveler and was very much politically
aware and involved. (Exhibit M and Exhibit N)
21. Notwithstanding these facts, and against USC policies clearly stating that unilateral
action would violate basic due process rights, Wiser and Liggett proceeded with their
plan to suspend Addahoumi from USC. Such arbitrary and authoritarian action has no
legitimate place on an American college campus or in any society governed by the rule of
law.
NATURE OF CASE
22 .. This is a federal civil rights action pursuant to 42 U.S.C. 1983. The decision to
suspend Addahoumi from USC and the methods employed to accomplish that objective
violated rights protected by the First and Fourteenth Amendments of the United States
Constitution.
23. In addition defendants' actions violated Addahoumi's rights protected by the Americans
With Disabilities Act, 42 U.S.C. 12131 et seq. (ADA), the Rehabilitation Act of
1973, 29 U.S.C. 701 et seq., the South Carolina Constitution, and the Health Insurance
Portability Accountability Act, ( HIP AA ), Pub. L. 104-191, 110 Stat. 1936 (codified as
amended in scattered sections of 42 U.S.C.). Defendant's actions also constituted a
breach of contract under South Carolina law.
24. Addahoumi seeks, inter alia, an order declaring Defendants actions in violation of the
aforementioned statutes and constitutional provisions. Addahoumi also seeks injunctive
relief and nominal, compensatory, and punitive damages to be determined by an impartial
jury, plus attorneys' fees and costs.
PARTIES
25. Plaintiff Sammi Hassan Addahoumi was a Political Science major, with a minor in
Middle Eastern and Islamic World Studies, at USC until he was arbitrarily and
unconstitutionally suspended by defendants. Addahoumi had only one single 3 hour
class remaining to graduate. Addahoumi is the owner/operator of Samrni' s Deli in
Columbia, South Carolina.
26. Defendant HARRIS PASTIDES (Pastides) is the President of the University of South
Carolina information and belief, resides in or around Columbia, South
Carolina. He is the university's chief executive officer, responsible for the University of
South Carolina's administration and policy-making, and has ultimate authority to approve
the policies and procedures challenged herein that were applied to deprive Plaintiff of his
constitutional rights. Defendant Pastides acted under color of state law and is sued for
injunctive relief in his official capacity.
27. Defendant Dennis Pruitt is Vice President for Student Affairs, Vice Provost and Dean of
Students at the University of South Carolina. Defendant Pruitt acted under color of state
law and is sued for injunctive relief in both his official and personal capacities.
28. The University of South Carolina Board of Trustees is responsible for the development
and enforcement of all USC policies and procedures. The Board of Trustees has been
vested by the State of South Carolina with the ability to sue as well as be sued. The
Defendant Board of Trustees acted under color of state law and is sued in both their
personal and official capacities
29. Defendant Alisa Cooney Liggett is the Director of the USC Office of Student Conduct
and Chair of the Behavioral Intervention Team (BIT). Defendant Liggett has been part of
the USC BIT since its inception and personally develops interventions for students
flagged by or reported to the USC BIT. The Office of Student Conduct acts as the central
reporting place for all referrals to the USC Behavioral Intervention Team. Members of
the BIT facilitate inappropriate interventions into Addahoumi's protected free speech.
Defendant Liggett acted under color of state law and is sued in both her personal and
official capacities.
30. Defendant Maureen Grewe served as the Coordinator for USC Office of Student
Conduct and the USC Behavioral Intervention Team from June 2011 to February 2015.
Defendant Grewe assisted in managing the USC student conduct system, adjudicated
student conduct cases and tracked sanction completion, developed and coordinated
educational programs and workshops on student conduct and ethics, advised the Carolina
Judicial Council, assisted with the management of the Behavioral Intervention Team
(BIT), represented the BIT in student assessment meetings, responded to BIT referrals
and to community members making referrals, coordinated campus partnerships in
response to BIT referrals and intervention "opportunities", assisted with recruitment and
training of conduct administrators, and "promoted adherence to the principle of the
Carolina Creed". Defendant Grewe acted under color of state law and is sued in both her
personal and official capacities.
31. Defendant Augusta Schneider is the Office and Business Manager for the USC BIT and
the USC Office of Student Conduct and Academic Integrity. Defendant Schneider acted
under color of state law and is sued in both her personal and official capacities.
32 .. Defendant Timothy Bedford served as Case Manager for the University of South
Carolina Behavioral Intervention Team from August 2013 to December 2015. Defendant
Bedford provided case management and organization for USC students in "distress",
providing triage, coordinating interventions, assisting in care plan development, and
assisting students in complying with recommendations and adhering to University
policies. Defendant Bedford served as a liaison between the Behavioral Intervention
Team and various campus resources and stakeholders and provided support and outreach
to the USC faculty and staff involved when "students of concern" are identified and
"support" is needed. Defendant Bedford conducted evaluation and assessment procedures

on these findings. Defendant Bedford acted under color of state law and is sued in both
his personal and official capacities.
33. Defendant Leslie G. Wiser, Jr. is an adjunct USC professor in the School of Criminal
Justice, a position which he used to lend academic credibility to the federal "Smart
Policing Initiative" experiment to which USC and the City of Columbia provided
matching funds. Defendant Wiser acted under color of state law and is sued in both his
personal and official capacities.
34. Defendant Josef Olmert is an adjunct professor in the USC political science department.
Defendant Olmert acted under color of state law and is sued in his official and personal
capacity.
35. Defendant Scott Prill is the Deputy Chief of Police for the USC Division of Law
Enforcement and Safety (USCPD). Defendant Prill reported Mr. Addahoumi to Federal
Bureau of Investigation (FBI) on multiple occasions. Defendant Prill referred Mr.
Addahoumi to Defendant Frierson for a forensic psychiatric violence risk assessment in a
memorandum dated April 14, 2014. Defendant Prill acted under color of state law and is
sued in both his personal and official capacities.
36. Defendant Richard L. Frierson is the program director for the Forensic Psychiatry
Fellowship at the University of South Carolina School of Medicine. Defendant Frierson
was paid by Defendants to perform an involuntary forensic psychiatric violent risk
assessment on Mr. Addahoumi without his consent and without his informed consent.
Defendant Frierson was at all relevant times herein, acting under the color and pretext of
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Frierson acted under color of state law and is sued in both his personal and official
capacities.
VENUE
37. Because all defendants reside in the State of South Carolina, with some defendants
residing in this judicial district, venue is properly within this district pursuant to 28
U.S.C. 139l(b)(l).
JURISDICTION
38. Jurisdiction for this suit is conferred in part by 42 U.S.C. 1983, which provides, in part:
"Every person who, under color of any statute, ordinance, regulation, custom or usage, of
any State or Territory, or the District of Columbia, subjects, or causes to be subjected,
any citizen of the United States or other person within the jurisdiction thereof to the
deprivation of any rights, privileges, or immunities secured by the Constitution and laws,
shall be liable to the party injured in an action at law, suit in equity, or other proper
proceeding for redress."
39. Declaratory and injunctive relief are authorized by 28 U.S.C. 2201 and 2202. See also
Fed. R. Civ. P. 65.
40. Attorneys fees are authorized by 42 U.S.C. 1988, 29 U.S.C. 794(b), and 42 U.S.C.
12205.
41. Under 28 U.S.C. 1331and1343(a)(3) & (4), the Court can entertain an action to
redress a deprivation of rights guaranteed by the United States Constitution, and the
Court has jurisdiction under 28 U.S.C. 1367 to hear an action to redress a deprivation of
rights guaranteed by the laws and the Constitution of the State of South Carolina..
FACTUAL AND PROCEDURAL BACKGROUND
42. The allegations set forth in paragraphs 1-41, supra, are incorporated herein by reference.
restaurant and bar in the 5 Points district adjacent to campus, followed by a second
location in 2005, and a third location in 2007. Addahoumi re-enrolled in the Fall of
2012.
44. From the beginning of his time at USC, he actively engaged in student and political
affairs, and did so without major interference by USC officials. Prior to his return to
USC, for example Addahoumi wrote, filmed, and published dozens of articles and videos
for CNN News iReport, many of which were featured on CNN, CNN International, and
on local news outlets. More recently, his primary concerns focused on protection of civil
liberties, Homeland Security, policing, and U.S. foreign policy.
45. Defendants Liggett, Wiser, Prill, and Grewe designed a BIT plan for Addahoumi to serve
as the structure Defendants could use to detect and intervene prior to the emergence of
the supposed violent or self-injurious action. Liggett, Wiser, Prill, Grewe, Frierson, and
other BIT stakeholders investigated reports, culled available data, and even repeatedly
mandated Addahoumi submit to psychological assessment to collect data that better
supported Liggett and Wiser' s own concerns.
46. Liggett, Wiser, Prill, and the USC BIT had three primary functions. Defendants gathered
information, analyzed this information through a series of subjective rubrics or set of
stereotypes, Jungian archetypes, and preconceived social standards, and then developed
and engaged in an intervention into Addahoumi' s free speech, freedom of conscious, and
free thought.
47. Defendants enacted this BIT plan with Addahoumi while using the BIT to establish
supposed "baselines" for Addahoumi's speech, detect alleged patterns, observe any
-~-'=.':''.L.~~:':~'.L<.':'''...':a~Ln.. d coordinate interventions ~ ~,:~~=:.. . .=..~~~~~-~~.......,

Three Phases of the USC BIT Plan for Mr. Addahoumi
48. Phase 1: The USC BIT defendants invasively gathered information from the community
about Addahoumi's protected free speech. This meant advertising and selling the USC
BIT well to the USC community and teaching them what they should report about
Addahoumi's free speech. This meant nurturing the BIT reporters and communicating
back to ensure future BIT reports about Addahoumi's speech.
49. Phase 2: The USC BIT defendants must have some way of analyzing the information
about Addahoumi's speech once it came in. Simply stated, this involved rating the
information into low, moderate and high categories and BIT defendants took
corresponding action and investigated Addahoumi's free speech for each of these risk
ratings.
50. There was no rating for "no risk" and no process to filter out frivolous or false BIT
complaints filed about Addahoumi's speech or to filter out complaints about
Addahoumi' s academic and protected free speech.
51. Defendants utilized the arbitrary, inconsistent and subjective BIT process, a process that
cannot be justified or defended against Addahoumi's protected rights under the First and
Fourteenth Amendments of the U.S. Constitution.
52. The investigative data addressed the full spectrum of information obtained, gathered, and
shared with the BIT defendants about Addahoumi, as defendants investigated his speech,
his work, and his social and family life, and even his protected medical records.
53. Phase 3: Finally, Liggett and USC BIT defendants set in motion multiple interventions to
escalate their portrayal of Addahoumi as a dangerous threat. These included numerous
or threat assessments without consent and with informed consent, unnecessary case
management, and numerous burdensome, stressful, and arbitrary USC BIT and USC
Student Conduct meetings, all to justify defendants' outrageous claims that Addahoumi
was somehow a threat to himself or others.
54. Liggett, Prill, Frierson, and BIT defendants personal intervention into Addahoumi's
protected free speech and freedom of conscious was chosen based on: 1) Liggett as best
positioned to intervene, as director of both the BIT and USC Office of Student Conduct,
2) Prill as most likely to engage the student in a invasive manner utilizing his law
enforcement capacities, and 3) Frierson as the best positioned to increase the extreme
nature of the intervention in his legal and medical capacities to ensure the intervention
would lead to future involuntary and invasive treatment of Addahoumi and his freedom
of speech. (Exhibit Q)
55. Each of these three steps was essential for Liggett and defendants. This is was a circular
process. Once the information about Addahoumi's protected speech and expressive
activities was gathered, an array of bias and subject analysis were completed and the
interventions were conducted, then Liggett and BIT defendants returned right back to the
information gathering stage to begin again.
USC BIT Defendants Practices violated Addahoumi's Protected Freedom of Speech
and Freedom of Conscious
56. Defendants educated the campus community about Addahoumi's behaviors of concern
(his protected speech) and Reporting Procedures.
57. Cultures of reporting Addahoumi's speech did not exist in a vacuum. The members of the
information about his expressive and academic free speech activities, as well as those
activities of Addahoumi that defendants sought to portray as becoming "at risk." There
were no challenges when Liggett and BIT defendants activated, created, and operated
channels of communication that allowed for a flow of information from those who
supposedly had it to those who allegedly needed it-Liggett and BIT member defendants.
(Exhibit R)
58. Liggett and defendants created and nurtured the channels, and mandated their reporting to
empower defendant's information flow regarding Addahoumi's speech. Defendants also
reached out to the campus and related community to inform them what Addahoumi's
concerning speech looked like, what dangerous behaviors were supposedly forthcoming
from Addahoumi, and how to report Addahoumi when concerning protected free speech
was observed or suspected. (Exhibit S)
59. Among other tools, USC BIT defendants used the "D Scale" from the NaBIT A Threat
Assessment tool to create simplistic and alarmist campus language describing
Addahoumi's protected free speech as mental-health related concerns.
60. Liggett's function as BIT Chair and BIT Defendants' roles in the process to empower a
culture of reporting on Addahoumi' s protected free speech, to investigate his free speech,
and to suspend him in violation of his rights to protected free speech, is addressed in
detail in materials distributed during a 2015 BIT training seminar conducted at USC by
defendants via the USC "Southeastern Student Conduct Institute". (Exhibit T)
61. Liggett, Prill, and defendants provided hyperactive, hyper vigilant consultation and
support to faculty, staff, administration, and students in assisting them to surveil, track,
_ -----~ .. --- mo11it()L.Q().f UII!~l1_tLct!1c:1!.e.p9i:J:_ll!!Y_~l1~~Qlil1.KJ2~()-~.!~c:l.fr~~~~~~QlJY~~~()1:1~J:!:1::t~. __ .... --~
could be portrayed as disruptive, threatening, or dangerous. (Exhibit T)

62. Defendants mandated faculty, staff, administration, and student "peer leaders" with
interactions with Addahoumi to refer any concerns to the BIT, and defendants responded,
whether or not appropriate or warranted. Often, what is needed was not a BIT response,
but instead some guidance for the reporting individual on how to manage their
interactions and any resulting emotions with Addahoumi. (Exhibit T)
63. Liggett, Wiser, and BIT defendants did not and would not provide any problem-solving
suggestions, conflict resolution ideas, or classroom/office management mechanisms and
training for addressing any alleged concerns about Addahoumi directly.
64. Instead Liggett and defendants mandated that faculty and staff manage, report, refer, and
to do all three as a critical "prefunction" of Liggett and defendants' BIT plan for
Addahoumi. (Exhibit T)
65. Defendants ensured any concerns continued despite the protected nature of Addahoumi's
speech, so that elevating the matter to a BIT-level response was supposedly needed.
66. In this interactive process, Liggett and BIT defendants coached the reporting individual
to overreaction to Addahoumi's speech concern. Defendants BIT intervention into
Addahoumi's speech made it impossible that a reporting individual could overestimate
the level of concern they perceived about Addahoumi's speech because of the tools,
training, and longitudinal view at their disposal. NAB IT A tools supposedly allowed
Liggett and BIT defendants' greater insight into the appropriate level of concern posed by
varying expressions of Addahoumi' s protected free speech.
67. Liggett, Prill, and BIT defendants served as the central point of contact for individuals
concern or about Mr. Addahoumi's free speech. Defendants
portrayed and misrepresented Addahoumi as spiraling into a potentially harmful state,

and mandated that members of the community pick up on signs and clues to support their
views, called "leakage."
68. While Addahoumi's speech was protected and even trivial, when viewed in the aggregate
Liggett and BIT defendants misrepresented facts to show a supposedly clear picture of
behavioral patterns (Addahoumi's free speech) that need to be addressed sooner rather
than later.
69. Each person possessing information did not attempt to manage it or keep it private or to
themselves, but instead should pass it along to the Liggett and BIT defendants, so that the
BIT could compare it to other information coming in from other sources about
Addahoumi's protect free speech activities. Even educational documents and academic
records of other students were carelessly and recklessly added to Addahoumi's own BIT
record and student conduct file. (Exhibit U)
70. In this way, the BIT detected patterns that they had created, those that "could not be seen
by individual community observers", because they did not exist. Liggett and Defendants
called it the "50,000-foot view", allowing the BIT defendants to see Addahoumi
"holistically", within the context of previous protected free speech over time.
71. Liggett is the permanent BIT chair and also the Director of Student Conduct. Liggett had
authority over student conduct investigations regarding Addahoumi, the ability to impose
summary suspension of Addahoumi, and to mandate BIT psychological assessment of
Addahoumi. Liggett convened the BIT defendants for regular and ad hoc sessions as
needed, was the only liaison between the BIT and the office of student conduct, and was
72. Defendant Prill is the USCPD representative on the BIT. Prill facilitated liaison and false
information exchange regarding Addahoumi's protected speech between campus law
enforcement, the BIT, local law enforcement, SLED, and even federal agencies such as
the FBI and Department of Homeland Security. Prill facilitated BIT access to campus
multimodal and timely warning capacities to deal with Addahoumi's speech, and helped
to implement those unwarranted campus wide warnings about Addahoumi. Prill brought
to the BIT increased levels of threat assessment, liaison with local law enforcement, and
integration/coordination of the campus resources and mechanisms to facilitate BIT
actions.
73. Each and every complaint regarding Addahoumi's speech became a BIT-related matter,
in part because Addahoumi's speech activities represented a media relations issue for
USC and defendants. Media relations influenced and shaped BIT decisions, and
defendants' input helped the BIT to frame sensitive issues in the most alarmist way
possible for media, internal, and public dissemination.
74. BIT defendants tracked Addahoumi's "concerning" speech and expressive activities over
time, monitored patterns, identified trends, and repeatedly was enabled to pick up
Addahoumi when he "dropped off the radar screen inexplicably" by doing nothing at all.
Liggett and BIT defendants utilized the Maxient database system to prevent Addahoumi
from "dropping off the radar," as the Maxient database automated the reminder process
1
for follow up by the BIT or Conduct Office regarding Addahoumi's protected speech.
.. -~--1...for exampJ~_when.Addahol!.mi wa.s_r.efari:e~_!.O...th_t!l3ff2y.et_re.ci11ir.e.<!_I1...foi:.m~interv:e.iiti().n~_lJ11t\V~~'.~oft nudged" by the

reporter (e.g., a faculty member defendats) toward support services would have a "deadline date" (the ter~"~~d bf M~ellt~-d~t~aS"e'"'"'""~---,- ,_'"""-~-----~-,~-~,--~,,~-
provider) assigned to him of two weeks. Two weeks later, Addahoumi's name would automatically come up on the BIT "agenda," for
follow up by the team with either the reporter and/or Addahoumi. Another example was when defendants DID require Addahoumi to submit to
mandated assessment. The "deadline dates" were initially the times of each assessment session, and then (assuming Addahoumi remained in
school) for predetermined unreasonable intervals
75. Liggett and BIT defendants maintained detailed records and minutes of BIT meetings,
actions, interventions taken by the BIT, as well as all follow-up activities and interactions
with Addahoumi. These records were kept by Liggett and defendants in files (or
partitioned databases) that were carelessly intermingled with other campus records (for
example, conduct files, counseling records, etc.). Other BIT defendants kept many
detailed notes and records beyond those maintained in sole possession records/personal
case notes.
76. Liggett and BIT defendants communicated with one another, other departments, and
other universities and schools to maintain continuity in Addahoumi's constitutional
injuries.
77. When defendants had knowledge that Addahoumi had attempted to transfer to another
University, defendants contacted the BIT Chair at the transferee institution to share
Addahoumi's BIT history and records of Addahoumi's free speech activities. This
communication between defendants is documented in the USC BIT Maxient database.
78. Liggett and BIT defendants never evaluated and determined the credibility of any alleged
threat, the seriousness of any supposed threat.
79. Defendants failed to evaluate and determine if Addahoumi appeared to have the
resources, intent, and motivation to carry out any alleged threat, and defendants failed to
make any assessment of legal "true threat" and free speech issues, for evaluation of
Addahoumi' s writings and statements.
80. On March 15, 2014 defendant Wiser filed a BIT incident report about an email and
attached research paper sent to him by Addahoumi. On information and belief, Liggett
then decided to use the email, along with Addahoumi' research essay, and awareness that
Addahoumi had already been forced by mandated BIT assessments to availed himself of
campus counseling, to concoct a claim in retaliation for Addahoumi's speech activities
questioning his Smart Policing program, that Addahoumi represented some kind of
danger. Liggett pursued this strategy with the assistance of defendants Wiser, Grewe,
Bedford, Schneider, Prill, Frierson, and others using the USC BIT to facilitate their
mission. (Exhibit C)
81. On or about April 9, 2014, under orders from Liggett, Defendant Prill of USCPD
contacted Defendant Frierson to inform him that, in Wiser and Liggett' s view,
Addahoumi had threatened Wiser personally via the email and attached research paper.
82. Addahoumi had not exhibited any violent tendencies and had made no threats of any
kind.
83. The BIT protocol centers on mandating contact with those faculty, staff and "peer
leaders" with any interactions with Addahoumi, inform them Addahoumi was
experiencing mental health issues, and mandated that those individuals file BIT incident
reports regarding Ligget' s concerns, and document any observations or information that
would support Liggett's view.
84. On or about April 17, 2014 Addahoumi posted a series of items on his CNN iReport
page, including essays and research papers, that criticized the USC BIT and defendant
Pastides and social media posts regarding a variety of political issues.
85. Ironically, Wiser claimed to interpret Addahoumi's email and the attached Smart Policing
.
research for his cover story that Addahoumi was a threat. In fact,
-----=~~~--=~'------~.. -- ------
Addahoumi made the opposite point, that because of the Virginia Tech tragedy, the
blurred lines between local law enforcement and federal agencies such as the FBI and
DHS were creating a militarized police force. Mr. Addahoumi suggested that as a result
minorities, Muslims, and other people, like himself, would be branded as dangerous when
they were not.
86. On or about April 10, 2014, under the direction of Liggett, defendant Prill contacted
defendant Frierson a forensic psychiatrist employed by USC, and requested that he assess
Liggett's asserted concerns. Addahoumi's history included no mental health records, no
record of threats, violence or even significant confrontations. At no time have issues
related to violence, threats of violence, or violent ideation arisen in Addahoumi' s
academic, social, professional, medical, mental, or legal history.
87. On April 9, 2014 Addahoumi received an official notice of charge from Liggett
mandating a Student Conduct meeting in her office on April 11. During that mandated
meeting Liggett demanded that Addahoumi remove or edit Wiser' s name from the Smart
Policing research paper which Addahoumi had posted to his CNN ireport blog. (Exhibit
H)
88. Addahoumi refused to agree to Liggett's demand to censor, edit, or remove anything
from his CNN iReport page. Defendant Liggett threatened that if Addahoumi did not
sign an agreement to edit his blogpost, he would be suspended for computer misuse and
harassment. Addahoumi refused to sign any such document and demanded a Carolina
Judicial Council hearing regarding any alleged conduct violations. (Exhibit H)
89. On or about April 11th, notwithstanding the abundant evidence that any concerns about
notwithstanding Addahoumi's request for a CJC hearing, Liggett directed that a meeting
be held to discuss her planned response to Addahoumi's protected speech activities.
90. On or about April 11, 2014, Liggett held a meeting regarding Addahoumi which, on
information and belief, Wiser, Grew, Bedford, Prill, Frierson, and others attended. At this
meeting, Defendants, led by Liggett, decided, unilaterally and without any process due to
Addahoumi pursuant to the Constitution or to USC and/or Board policies, to suspend
Addahoumi from USC. Mr. Addahoumi was unaware that he had been suspended and
continued to demand a CJC hearing regarding any alleged conduct violations.
91. On May 16, 2014 Maureen Grewe informed Addahoumi of his suspension from USC via
email and attached suspension letter from Alisa Liggett. Addahoumi was informed of his
suspension when he discovered the email while on campus awaiting a meeting with his
academic advisor. (Exhibit A).
92. The letter stated, in pertinent part, that Addahoumi had been suspended for "computer
misuse" and "using computer resources to harass others in ways that violate institutional
computer use polices". (Exhibit B)
93. The suspension letter also demanded that Addahoumi "agree to willingly engage in any
amount of counseling stipulated by the university". (Exhibit B)
94. The letter also mandated that Addahoumi would "complete an assessment" with
Defendant Frierson and would "complete all treatment recommendations" from Frierson.
It stated that "a delay of more than two weeks in beginning treatment recommendations
could result in a prolonged suspension". (Exhibit B)
95. USC Student Code of Conduct states:
"The Board of Trustees and the president of the university are ultimately responsible for
governing the university. The student conduct system is administered by the Division of
Student Affairs and Academic Support. The Vice President for Student Affairs and
Academic Support, in turn, designates the Office of Student Conduct with administrative
authority and responsibility for Student Conduct policies and procedures. This
responsibility includes formulating and implementing policies and procedures, in
cooperation with other appropriate University bodies, for the consideration of conduct
violations and the imposition of sanctions in an efficient, consistent, fair, legal, and
educationally meaningful manner."
96. The Code of Conduct defines computer misuse. It states "Computer Misuse: In addition
to adhering to the University's Network Access and Acceptable Use" Policy (IT
l.06http://www.sc.edu/policies/itl06.pdf), misusing University computing resources by
intentionally making, receiving, accessing, altering, using, providing or in any way
tampering with files, discs, programs, passwords, messages or other computer users
without their permission is prohibited. Using computer resources to harass others, or in
ways that violate institutional computer use policies, is prohibited".
97. At no time has Addahoumi ever obstructed, disrupted, or attempted to obstruct or disrupt
any campus activities or use computer resources to harass others, or in ways that violate
institutional computer use policies.
98. USC policies for student disciplinary procedures are set forth in the USC student Code of
Conduct. The policy declares that student discipline has been delegated by the President
to the Vice President for Student Affairs and the Dean of Students Office. These policies
include:
"Office of Student Judicial Programs. Investigation of Conduct - Upon receiving a report of

alleged misconduct, or upon his or her own initiative, the Director of Judicial Affairs or
designee may review relevant evidence and consult with relevant parties regarding the
incident in question. If the evidence warrants disciplinary action, the Office of Student
Judicial Programs will send written or email notification to the accused student or student
organization representative indicating the nature of the activity in question."
99. Each and every complaint about Addahoumi centered on his free speech. In each and
every instance, Defendant Liggett chose to investigate, charge and sanction Addahoumi.
100. Addahoumi was not told who had charged him with "computer misuse". He was
not told which exact email he had been charged for. Addahoumi was not informed of the
contents or source of any BIT report or Student Conduct report. (Exhibit 0 and Exhibit P)
101. The student or student organization representative is given the opportunity to
meet with the Director of Judicial Affairs or designee to discuss the allegations.
102. Addahoumi was not informed of any of his accusers. Defendant Liggett simply
told Addahoumi that he had been found responsible. Liggett directly and arbitrarily
denied Addahoumi a formal Carolina Judicial Council hearing, despite Addahoumi's
numerous requests. (Exhibit 0 and Exhibit P)
103. Liggett suspended Addahoumi on April 11, 2014. There was no discussion of the
exact allegation or who had made any allegations. If the student fails to meet with the
Director or designee, a hold may be placed on the student's registration preventing
him/her from registering for future classes until the matter is resolved.
104. In late April and early May Addahoumi found he was unable to register for the
one single class required for him to graduate. He was informed by the USC registrar
office of a hold on his registration from the Office of Student Conduct.
105. Additionally, the student may be charged with a violation of the "failure to
comply" provision of the student code of conduct (section E.15). A student organization
may be restricted from any or all activities until the representative meets with the
sanction by considering available evidence.

106. Liggett repeatedly threatened Addahoumi with the charge of "Failure to Comply"
if he did not attend her numerous BIT meetings and assessments. Addahoumi repeatedly
asked Liggett what rule he had broken and repeatedly asked for a Carolina Judicial
Council hearing among his peers. (Exhibit 0 and Exhibit P)
107. ST AF6.26 states At the conclusion of this discussion regarding the charges, the
Director or designee may either drop the charges if they are unsupported by evidence, or
offer the following options to resolve the charges.
108. Despite each and every complaint being unsupported by any evidence
whatsoever, defendants Liggett and Grewe, and others investigated and sanctioned
Addahoumi.
109. Per STAF626 students are in entitled to an informal hearing with the Director or
designee (The Director or designee may decline to hear the case in this manner and
require one of the following two options). An informal hearing allows the charged party
(ies) to present evidence for consideration and suggest witnesses that the Director or
designee may consider interviewing before a decision is rendered.
110. At no time for was Addahoumi allowed to present evidence to Liggett during their
numerous mandated meetings and BIT assessments. At no time was Addahoumi allowed
to suggest witnesses or present evidence that Liggett might have considered reviewing or
interviewing before any decisions were rendered. (Exhibit 0 and Exhibit P)
111. Per STAF626, the Director or designee may contact other parties who have
knowledge/information regarding the incident in question. The charged student(s)
~
/student
-
waives the right to question such parties or otherwise
participate in an evidentiary hearing. Defendant Liggett interviewed only the
complainant, never once actually bothering to interview any witnesses.
112. Per STAF6.26 students have the right to a formal hearing with the Director or
designee (the Director or designee may decline to hear the case and require that a
Carolina Judicial Council Hearing be held). This option allows the party(ies) charged to
respond to the charges, present witnesses and present questions for the witnesses to
answer. Formal hearings are tape-recorded. Within ten(lO) university business days of
this hearing, barring special circumstances requiring an extension of this time limit, the
Director or designee will send the charged party(ies) written notification which indicates
the finding of "responsible" or "not responsible" for the charges, and any sanctions
imposed subsequent to a finding of responsibility.
113. None of these rights or procedures were afforded to Addahoumi. This was
despite the documented fact that Addahoumi specifically and repeatedly asked for,
requested, and demanded a Carolina Judicial Council Hearing.
114. Per STAF6.26 Students are expected to comply with and respond appropriately to
the reasonable and lawful requests of University officials in the performance of their
duties. Students are expected to appear at conduct hearings to respond to allegations or
testify as a witness when reasonably notified to do so. A failure to properly comply with
or complete a sanction or obligation resulting from a conduct hearing or adjudication may
also be considered failure to comply with an official request.
115. Mr. Addahoumi was repeatedly threatened with charges of "Failure to Comply"
116. Liggett informed Addahoumi that his computer misuse charge was related to
harassment charges. (Exhibit 0 and Exhibit P)
117. USC Student Non-Discrimination and Non-Harassment Policy (STAF624) states,
in part:
"The University is also committed to the principles of academic freedom and believes
that a learning environment where the open exchange of ideas is encouraged is integral to
the mission of the University. The University vigorously embraces students' rights to the
legitimate freedom of expression, speech, and association. Nothing in this policy is
intended to impede the exercise of those rights protected under the First Amendment of
the U.S. Constitution. The University recognizes that the conduct prohibited in this
policy extends to behavior and speech that is not constitutionally protected and which
limits or denies the rights of students to participate or benefit in the educational
program."
118. Regarding harassment STAF624 states, in part:
" Harassment is a specific type of illegal discrimination. It includes conduct (oral,

written, graphic, or physical) which is directed against any student or group of students
because of or based upon one or more of the characteristics articulated in Section II
above, that is sufficiently severe, pervasive, or persistent so as to interfere with or limit
the ability of an individual or group to participate in or benefit from the programs,
services, and activities provided by the University. Such harmful conduct may include,
but is not limited to, objectionable epithets, demeaning depictions or treatment, and
threatened or actual abuse or harm. Harassment does not include the use of materials by
students or discussions involving students related to any characteristic articulated in
Section !!for academic purposes appropriate to the academic context" (Emphasis
added).
119. Liggett informed Addahoumi that his computer misuse charge was related to
accusations of harassment, yet Addahoumi was never informed who he supposedly
harassed nor how he supposedly harassed them. (Exhibit 0 and Exhibit P)
120. Upon information and belief, Liggett intended to frame Addahoumi's email to
Wiser as harassment, despite STAF624 clearly stating that "Harassment does not include
the use of materials by students or discussions involving students related to any

characteristic articulated in Section II for academic purposes appropriate to the academic
context."
121. Most importantly, as per STAF6.26, the right of students are stated as follows:
A. Rights of Those Charged With Violations of the Code of Conduct
a. Those individuals and groups charged with violations have the following rights that are
protected throughout the hearing process.
b. The right to be notified in writing of their rights in the conduct process.
c. The right to be notified in writing of the charges against him/her/them with sufficient
time to prepare for a hearing. In the event that additional charges are brought, a further
written notice must be forwarded to the student(s) or student organization(s). The charged
student(s) or student organization(s) may waive the right to separate written notice of
additional charges in order to expedite the hearing process.
d. The right to be notified of the date, time, and place of formal hearings at least three (3)
University business days prior to the hearing.
e. The right to know the nature and source of the evidence used in a hearing process. This
includes the right to review all documents and exhibits to be introduced at a hearing as
well as a list of witnesses asked to testify at the hearing, upon the student's request.
f. The right to present evidence on one's own behalf.
g. The right to elect not to appear at the hearing, in which case the hearing shall be
conducted in the absence of the charged party(ies).
h. The right to refuse to answer any questions or make a statement. However, the hearing
draw inferences from this refusal.
i. The right to present questions for the witnesses to answer. The Hearing Officer/Council
may rule on relevance of these questions.
j. The right to be accompanied by an advisor throughout the hearing process. The advisor,
with the written permission of the charged student(s) or student organization(s), may:
i.Advise the accused regarding preparation for the hearing;
ii. Accompany the accused to all conduct proceedings;
iii. Have access to evidence to be introduced at the hearing
122. None of the above promised rights to USC students was afforded to Addahoumi
and all were directly and indirectly denied upon his request, from demanding a Carolina
Judicial Hearing, to demanding access to complaints and evidence, to confronting his
accusers. (Exhibit 0 and Exhibit P)
123. Per STAF6.26 any person charged with a violation of University rules shall have,
when needed, the aid of the University in the reasonable attainment of the information
necessary to answer the charges, or requesting the attendance of witnesses at the hearing.
124. Addahoumi was constantly and systematically denied any information necessary
to answer the charges or request the attendance of any witnesses at any hearing. (Exhibit
0 and Exhibit P)
125. Per STAF6.26 the charged party(ies) is/are responsible for presenting his/her own
case; advisors are therefore not permitted to speak to the hearing authority or participate
directly in any hearing.
126. Addahoumi was not allowed the responsibility for presenting his own case to
defendants.
127. The standard of proof utilized in all hearings and appeals to resolve Code of
Conduct charges shall be that of "preponderance of evidence" may be introduced at the
hearing.
128. Mr. Addahoumi was not allowed to present any evidence and was not afforded
any hearing.
129. As Per STAF6.26: the University may impose emergency action upon a student or
student organization when there is reason to believe, based upon available evidence, that
the student/student organization poses an immediate threat to the safety, health or welfare
of persons, property or to the orderly operation of the University. This action is warranted
by potential or threatened danger or disruption, and indicated when the nature or
immediacy of the threat requires immediate action.
130. Defendants have never had any reason, based upon available evidence, that
Addahoumi posed an immediate threat to the safety, health or welfare of persons,
property or to the orderly operation of the University. (Exhibit M and Exhibit N)
131. As per ST AF6.26 the action is interim in nature, pending the outcome of conduct
procedures. Violations of the below actions will result in a minimum of an immediate
one-year suspension as well as any other disciplinary action. Emergency action
authorized by this policy includes:
a. Emergency Suspension, Individual Student(s) - This action requires a student to leave
University property immediately, and not return during the suspension period, and/or
comply with other stated conditions for a specified period. Emergency suspension may be
for Emergency Limitation of Privileges, Individual Student - This action may place a
limitation on a student's eligibility for certain privileges, or participate in or attend certain
events (or certain kinds of events) without the suspension of enrollment status. This
action may prohibit a student's presence on University property or certain facilities, or
impose conditions that must be met in order for that student to have certain privileges,
participate in activities, or attend events. The Office of Student Judicial Programs may
impose this action.
132. When emergency action is taken against a student or student organization, the
student or student organization is given notice explaining the nature, reason for, and
duration of the action, as well as any conditions that may apply. A student notified of
such action shall, upon written request, be given an opportunity to meet with the
University authority taking the action within five (5) university business days from the
date of the request. This meeting shall be held to consider only the following issues
related to the emergency action:
a. The reliability of information alleging misconduct; and
b. Whether the conduct or surrounding circumstances reasonably indicate the student's
presence on campus or continued unrestricted participation in campus affairs or the
organization's unrestricted activities would pose a threat to the safety, health, or welfare
of persons or property and/or interfere with the orderly operation of the University. It is
not the purpose of the meeting to hear evidence concerning responsibility related to
pending or possible charges against the student.
133. None of the above stated procedures or rights were afford Addahoumi. Upon
information and USC has no
administrative suspension of which Addahoumi was the victim.

134. No provision exists in either the USC student handbook, Student Code of
Conduct, or in Board of Trustees policies for unilaterally imposed administrative
withdrawal such as that imposed on Addahoumi.
135. This conduct system extends to and applies to STAF the general principles of the
Statement of Student Rights and Freedoms within the Academic Community to specific
actions and responsibilities of students and student organizations at the University of
South Carolina. STAF628 states:
"Academic institutions exist for the transmission of knowledge, the pursuit of truth, the
development of students, and the general well-being of society. Free inquiry and free
expression are indispensable to the attainment of these goals. As members of the
academic community, students should be encouraged to develop the capacity for critical
judgment and to engage in a sustained and independent search for truth. Institutional
procedures for achieving these purposes may vary from campus to campus, but the
minimal standards of academic freedom of students outlined below are essential to any
community of scholars.
Freedom to teach and freedom to learn are inseparable facts of academic freedom. The
freedom to learn depends upon appropriate opportunities and conditions in the classroom,
on the campus, and in the larger community. Students should exercise their freedom with
responsibility.
The responsibility to secure and to respect general conditions conducive to the freedom to
learn is shared by all members of the academic community.
The university has a duty to develop policies and procedures that provide and safeguard
this freedom. Such policies and procedures should be developed within the framework of
general standards with the broadest possible participation of the members of the academic
community. The purpose of this statement is to enumerate the essential provisions for
student freedom to learn.
FREEDOM OF ACCESS TO HIGHER EDUCATION
The admissions policies of the university are a matter of institutional choice provided that
the university makes clear the characteristics and expectations of the students that it
considers relevant to success in the institutional program. Under no circumstances
. shouida-studentbebfilred from-adnussion-on-tlieb~isisof race.-creea~-seX,Ilruialcap,~-
religion, ancestry, national origin, genetics, sexual orientation or veteran status. Thus,
within the limits of its facilities, the university should be open to all students who are
qualified according to its admission standards.
IN THE CLASSROOM
The professor in the classroom and in conference should encourage free discussion,
inquiry, and expression. Student performance should be evaluated solely on an academic
basis, not opinions or conduct in matters unrelated to academic standards.
PROTECTION OF FREEDOM OF EXPRESSION
Students should be free to take reasoned exceptions to the data or views offered in any
course of study and to reserve judgment about matters of opinion, but they are
responsible for learning the content of any course of study for which they are enrolled.
PROTECTION AGAINST IMPROPER ACADEMIC EVALUATION
Students should have protection through orderly procedures against prejudiced or

capricious academic evaluation. At the same time, they are responsible for maintaining
standards of academic performance established for each course in which they are
enrolled.
PROTECTION AGAINST IMPROPER DISCLOSURE
Information about student views, beliefs, and political associations which professors
acquire in the course of their work as instructors, advisors, and counselors should be
considered confidential. Protection against improper disclosure is a serious professional
obligation. Judgments of ability and character may be provided under appropriate
circumstances, normally with the knowledge and consent of the student.
The University of South Carolina strives to protect this educational community and to
maintain social behavior among its students and student organizations. Consistent with its
purposes, reasonable efforts will be made to foster the personal and social development
of those students who are held accountable for violations of University social regulations.
The purpose of this document is to set forth the specific authority and responsibility of
the University in maintaining social behavior, the educational behavior, the educational
process of determining student and student organization accountability for violating the
regulations, and the proper procedural safeguards to be followed in this process to insure
fundamental fairness and protect the students and student organizations from unfair
imposition of serious penalties and sanctions.
. -- - Students, no less than other citizens, are entitled to be secure in their personal lodgings,
paperS,and effects-aga1nsTumeasonabTesearcliesanase1zures~Searcnesandseizuresby
law enforcement personnel incident to investigations or arrests are conducted only under
proper warrant. This does not prohibit normal inspections of University housing or other
facilities for maintenance, health, or safety purposes.
Students enjoy the same freedoms of speech and peaceable assembly as all citizens, but
they are under certain legal obligations in the exercise of these freedoms by virtue of their
membership in the University community. Expression may be subjected to reasonable
regulations of time, place, number of persons, and form under established regulations.
Expression in the form of action that materially interferes with the normal activities of the
institution or invades the rights of others is prohibited. The University is pledged to
protect lawful exercise of the rights of free speech and assembly and will invoke
appropriate legal and disciplinary sanctions when necessary in the pursuit of this goal.
136. None of these promises, rights, assurances, or guarantees of academic freedom or
due process was afforded to Addahoumi. Each BIT incident report or student conduct
complaint focused solely on protect academic and political speech. Each complaint about
Addahoumi's protect speech resulted in Addahoumi being investigated, sanctioned, and
suspended.
137. STAF6.26 further states:
"We, the undersigned members of the Carolina community, pledge to all Carolinians,
present and future, that we support and will defend your freedom of thought, conscience,
inquiry, speech, expression, and communication. It is our moral obligation to defend the
basic rights of all to free speech and expression, whether we support those views or not.
We therefore oppose all attempts by Carolina faculty and administrators to silence,
suppress, or "prosecute criminally" thought and speech deemed vulgar, controversial,
unpopular, insensitive, offensive, inappropriate, subversive, or blasphemous. We regard
any effort by the University to censor and punish thought and speech as especially
disgraceful.
All students everywhere have a right to think, learn, and speak in an environment free of
faculty or administrative threats, intimidation, harassment, coercion, and indoctrination.
Know this: Carolinians are legally entitled to the full protection of the First Amendment.
Any denial of this right is illegal, unconstitutional, and a betrayal of Carolina's
commitment to providing its students with a marketplace of ideas.
In the name of genuine tolerance and diversity, let there be no thought crimes or thought
police at the University of South Carolina. Our campus must be a refuge for free thought
and which includes ideas that we do not like or that make us feel uncomfortable.
Let all Carolinians unite to fight error and prejudice with rational arguments, critical
investigation, and unfettered debate, which requires upholding the principle of free
speech uncompromisingly.
We therefore pledge that we shall work tirelessly to fight censorship and to keep alive the
spirit of open-minded inquiry at the University of South Carolina."
138. None of the above stated promises were afforded to Addahoumi. In fact, quite the
opposite occurred as the USC Behavioral Intervention Team, Office of Student Conduct,
and USCPD defendants did quite literally become thought police, and did, in fact,
sanction Addahoumi with unconstitutional Doublespeak, and continue to sanction
Addahoumi, merely for thought crimes and protected free speech.
COUNTl
42 U.S.C. 1983: FREE SPEECH CLAUSE VIOLATION
(ALL DEFENDANTS IN THEIR PERSONAL AND OFFICIAL CAPACITIES)
139. Addahoumi realleges each fact set forth in paragraphs 1 through 138 of this
complaint and incorporates them herein by reference.
140. Addahoumi's activities online, in research, and on campus were speech acts
protected from infringement by the First Amendment of the U.S. Constitution.
141. Defendants actions in conspiring to suspend Addahoumi from USC were

142. Defendants stated reasons for suspending Addahoumi from USC were pretextual
and had no rational basis, being wholly contradicted by the views of mental health
professionals, communicated to Defendants, that Addahoumi posed no threat to self or
others at any time.
143. Because the law is clearly established in this area, and because Defendants had
(and have) fair warning that expelling a student from a public university in retaliation for
the exercise of First Amendment freedoms is unconstitutional, Defendants are liable, and
the individual Defendants are liable in their official capacities, for violating Addahoumi's
First Amendment rights.
144. The denial of constitutional rights is irreparable injury per se, and Addahoumi is
entitled to declaratory and injunctive relief.
COUNT2
42 U.S.C. 1983: PROCEDURAL AND SUBSTANTIVE DUE PROCESS
146. The South Carolina Constitution; and the Due Process Clause of the Fourteenth
Amendment, guarantee that no person shall be deprived of life, liberty or property
without due process of law.
147. Students at
such that due process must be afforded them prior to the denial of those interests. At a
minimum, this includes notice and an opportunity to be heard. See Goss v. Lopez, 419
U.S. 565, 574 (1975); Bd. of Curators v. Horowitz, 435 U.S. 78, 86 (1978).
148. At no time have Defendants provided Addahoumi with these essential rights.
149. In light of the Boards and USC defendants' retaliatory actions and the injuries to
Addahoumi arising therefrom, the State of South Carolina's procedures will not provide
Addahoumi with an adequate pre- or post-deprivation remedy to cure the erroneous
deprivation of his property rights and liberty interests
(and have) fair warning that denying Addahoumi the right to a public education, as well
as a fair and open hearing prior to suspending him from USC was unconstitutional,
Defendants are liable for violating Addahoumi s rights protected by the Fourteenth
Amendment.
entitled to declaratory and injunctive relief. In addition, Addahoumi is entitled to
damages to be determined by an impartial jury.
COUNT3
42 U.S.C. 1983: INDIVIDUAL LIABILITY
FREE SPEECH CLAUSE VIOLATION
152.
.........................................................................
Addahoumi realleges each fact set forth in paragraphs 1through138 of this
~-~~

153. Addahoumi's activities online, in class, and on campus were speech acts protected
from infringement by the First Amendment of the U.S. Constitution.
154. Defendants' actions in conspiring to suspend Addahoumi from USC were taken in
retaliation for Addahoumi's exercise of his First Amendment freedoms.
155. Defendants stated reasons for suspending Addahoumi from USC were pretextual
and had no rational basis, being wholly contradicted by the views of mental health
professionals, communicated to Defendants, that Addahoumi posed no threat to self or
others at any time.
(and have) fair warning that expelling a student from a public university in retaliation for
the exercise of First Amendment freedoms is unconstitutional, the individual Defendants
are personally liable in their individual capacities for violating Addahoumi's First
Amendment rights.
entitled to declaratory and injunctive relief and to compensatory damages to be
determined by an impartial jury. In addition, Addahoumi is entitled to punitive damages
for Defendants willful and malicious violation of his First Amendment rights.
COUNT4
42 U.S.C. 1983: PROCEDURAL AND SUBSTANTIVE DUE PROCESS
(INDIVIDUAL DEFENDANTS IN PERSONAL AND OFFICIAL CAPACITIES)
158. Addahoumi ........."'""""'"'"' each fact set forth in paragraphs 1 through 138 of this

159. The South Carolina Constitution; and the Due Process Clause of the Fourteenth
Amendment guarantee that no person shall be deprived of life, liberty or property without
due process of law.
160. Students at public universities enjoy a protected property interest in their
education such that due process must be afforded them prior to the denial of those
interests. At a minimum, this includes notice and an opportunity to be heard. See Goss v.
Lopez, 419 U.S. 565, 574 (1975); Bd. of Curators v. Horowitz, 435 U.S. 78, 86 (1978).
161. At no time have Defendants provided Addahoumi with these essential rights.
Because the law is clearly established in this area, and because Defendants had (and
have) fair warning that denying Addahoumi the right to a public education, as well as a
fair and open hearing prior to suspending him from USC was unconstitutional,
Defendants are individually liable for violating Addahoumi' s rights protected by the
Fourteenth Amendment.
entitled to declaratory and injunctive relief and to compensatory damages to be
determined by an impartial jury. In addition, Addahoumi is entitled to punitive damages
for Defendants willful and malicious violation of his Due Process rights.
COUNTS
BREACH OF CONTRACT
(ALL DEFENDANTS AND BOARD OF TRUSTEES IN THEIR OFFICIAL AND
PERSONAL CAPACITIES)
164. The USC Board of Trustees policies and provisions in the USC Student Code of
Conduct, as well as contracts for student housing, and academic freedom establish a
binding agreement between these Defendants and each USC student. Incorporated into
this agreement is Defendants obligation to follow the procedures they have established
for student discipline and suspension.
165. Defendants failed to follow these binding procedures.
166. The State of South Carolina State Legislature has waived the sovereign immunity
of the State and its departments and agencies for claims for breach of written contracts.
167. Defendants actions in failing to provide the procedures and rights guaranteed by
their own policies have imposed substantial economic harm upon Addahoumi, who has
lost the academic benefits of the classes he was unable to complete, has suffered
reputational harm, has been forced to bear the financial burden of legal fees and costs,
and has been forced to downsize his restaurant due to the stress, and has been unable to
continue his studies at another institution.
168. Defendants actions constitute breach of contract, and Addahoumi is entitled to
compensatory damages to be determined by an impartial jury. Incorporated into this
agreement is Defendants obligation to follow the procedures they have established for
student ~iu~i ,iiic~

..
169. Defendants failed to follow these binding procedures.

170. The South Carolina State Legislature has waived the sovereign immunity
of the State and its departments and agencies for claims for breach of written contracts.
171. Defendants actions in failing to provide the procedures and rights guaranteed by
their own policies have imposed substantial economic harm upon Addahoumi, who has
lost the academic benefits of the classes he was unable to complete, has suffered
reputational harm, has been forced to bear the financial burden of ineligibility of
enrolling at another public university at great lifetime earning expense, and has been
forced to downsize his business due to extreme stress at being the denied the right to
continue his studies and being his constitutionally mandated rights and protections.
172. Defendants actions constitute breach of contract, and Addahoumi is entitled to
compensatory damages to be determined by an impartial jury.
COUNT6
AMERICANS WITH DISABILITIES ACT
(ALL DEFENDANTS IN OFFICIAL AND PERSONAL CAPACITIES)
174. Because Defendants' regarded Addahoumi as being disabled with mental
disabilities and related to Addahoumi was mandated
both to receive counseling and denied accommodation from USC during his time as a
student there. The defendants repeatedly regarded Addahoumi as disabled with mental
illnesses that challenged and substantially limited Addahoumi's life activities, including
his educational activities and constitute qualified disabilities pursuant to the Americans
With Disabilities Act, 42 U.S.C. 12131 et seq. (ADA).
175. Defendants cynical and pretextual use of his status subjected Addahoumi to
intentional discrimination on the basis of and by reason of his disability, in violation of
Title II of the ADA.
176. Addahoumi is entitled to declaratory and injunctive relief and compensatory
damages to be determined by an impartial jury pursuant to 42 U.S.C. 12133.
177. Addahoumi is entitled, as well, to recover attorneys fees associated with this
action. 29 U.S.C. 794(b); 42 U.S.C. 12205.
COUNT7
REHABILITATION ACT
(ALL DEFENDANTS IN OFFICIAL CAPACITIES)
179. Defendants actions subjected Addahoumi to intentional discrimination on the
basis of and by reason of his disability, in violation of Section 504 of the Rehabilitation
180. Addahoumi is entitled to declaratory and injunctive relief and compensatory
damages to be determined by an impartial jury.
181. Addahoumi is entitled, as well, to recover attorneys associated with this action. 29
u.s.c. 794(b).
COUNTS
m -42 U.S.C. 1983 and 42 U.S.C. 1985
CONSPIRACY
(ALL DEFENDANTS IN OFFICIAL AND PERSONAL CAPACITIES)
183. All of the Defendants and other co-conspirators, known and not yet known to
Addahoumi, utilizing the USC Behavioral Intervention Team, reached an agreement
amongst themselves to investigate Addahoumi's free speech, sanction Addahoumi for his
free speech, and suspend Addahoumi from USC for his protected free speech, all in
violation of Addahoumi's constitutional rights, as described above.
184. In this manner, the Defendants, acting in concert with other known and unknown
co-conspirators, conspired to accomplish an unlawful purpose by an unlawful means.
185. In furtherance of the conspiracy, each of the co-conspirators committed overt acts
and was an otherwise willful participant in joint activity.
~~ ...... J~6., ..........J'h.~ miS(;Q!lQUCtcl~~Iibe.QglJQi~Q!l!lJ~.CJ.~()J:>j~.c:;!!Y~!Y.t!Ill"~':iS.Q!l(l~l~~Q W':l~
undertaken intentionally with willful indifference to Addahoumi's constitutional rights.

187. As a direct and proximate result of the illicit agreement referenced above,
Addahoumi's rights were violated and he suffered substantial and irreparable harm,
including lost income, the loss of a prospective position as a graduate student at another
University, out of pocket expenses, and severe emotional distress.
WHEREFORE, Addahoumi prays:
(a) That the Court grant Addahoumi declaratory and injunctive relief, and
award compensatory and punitive damages against the Defendants for violating his
rights protected by the First and Fourteenth Amendments to free expression and due
process; and that the Court grant Addahoumi declaratory and injunctive relief and
compensatory damages against the Defendants for violating his rights protected by
the ADA and the Rehabilitation Act, all in an amount to be determined by the
enlightened conscience of an impartial jury;
(b) That the Court award Addahoumi his reasonable costs and attorneys fees in
bringing this action in an amount to be determined at trial;
(g) That Addahoumi be granted a trial by jury on all issues so triable; and
(h) That Addahoumi be granted such other and further relief as the Court
deems just and proper.
(i) That Addahoumi be reinstated as a student and to his prior status at USC.
(j) That Addahoumi's education record that includes any Office of Student Conduct
and Behavioral Intervention Team Records and notes be expunged and destroyed in full and that
any restrictions on Addahoumi's access to USC campus and property be removed.
Respectfully submitted,
/\~ ...
---~'::?.:~~---------------------------------------._ _____ _
Sarnmi Addahoumi
910 Lacy Street
Columbia, SC 29201
(803) 741-4845
delimansc@gmail.com
3:16-cv-01571-CMC-SVH Date Filed 08/04/17 Entry Number 54-1 Page 1 of 149
EXHIBIT A
From: GREWE, MAUREEN

:;,uo11ec1: IMPORTANT!
M~a.y 1),_?014 al?:Q3 PM
THOMPSON, J. LICORISH
Sam mi,
It appears that per the letter attached, you have been notified by Ms. Liggett that you have been
suspended and should not be on campus or you can be arrested for trespassing. It has come to our
attention that you were on campus this morning. Please note, if you are on campus again without
written permission from Ms. Liggett, you will be arrested for trespassing.
Maureen Grewe
Coordinator for Student Conduct & Behavioral Intervention
University of South Carolina
901 Sumter Street, Suite 201
Columbia, SC 29208
Office: 803.777.4333/ Fax 803.777.1393
grewe@mailbox.sc.edu
PLEASE NOTE:
The information transmitted in this email is intended only for the person(s) or entity(ties) to which it is addressed and
may contain confidential and/or legally privileged material. If you received this in error, please contact the sender and
delete the material from any computer. Any review, retransmission, dissemination or other use of, or taking of any
action in reliance upon, this information by persons or entities other than the intended recipient is prohibited.
ConductHrgOutcomeltr(
Email)( 4).pdf
----------------B
E XHIBIT
~
~
~
rtttllJ~Tltm
~
~
UNIVERSITY OF
SOUIHQ\ROUNA
April 11, 2014
Student Conduct and Academic Integrity
Division of Student Affairs and Academic Support
Sammi Addahoumi
Sent electronically to addahoum@email.sc.edu
PERSONAL AND CONFIDENTIAL
Regarding Case Numb~~
Dear Mr. Addahoumi,
Thank you for meeting with me regarding an incident report suggesting that you may have been
responsible for violating USC's Student Code of Conduct. These student conduct meetings were
designed to educate students about community standards and to hold students accountable when those
standards are breached. I hope it achieved that purpose.
In that meeting you acknowledged the essential accuracy of the report and agreed to have the resulting
Code of Conduct charges resolved through a conduct hearing.
Your Code of Conduct charges and findings are as follows:
1. Misuse of Identification or University Resources - Computers --
You agreed to complete the following sanctions:
You are suspended from the University of South Carolina beginning May 13, 2014 and continuing
through December 10, 2014. You are required to vacate the campus by May 13, 2014. You are
prohibited from returning to campus or USC property without written permission from this office.
Failure to comply with this request may result in your arrest for trespassing.
To begin the re-enrollment process you must schedule a re-enrollment meeting for 30 minutes with
your conduct administrator prior to your registration hold being removed. In that meeting you will
discuss your progress and your goals for the new semester.
Students who miss a Fall or Spring semester must complete the online application at
www.sc.edu/admissions by the following deadlines:
Spring: November 1
Summer I: May 1
Fall: July 1
With respect to the information listed above, the following additional sanctions/stipulations apply:
James F. Byrnes Building 90 I Sumter Street, Suite 201 Columbia, South Carolina 29208
803/777-4333 Fax 803/777-1393 http://www.sc.edu/osc/
An Equal Opportunity Institution
1. Samfui has agreed to willingly engage ili any amollilt of cotifiselihg stipulated by the university.
Sammi will complete an assessment with Dr. Richard Frierson by Friday April 18 at a time to be
communicated to him once we are able to contact Dr. Frierson.
Failure to complete this assessment within the week will result in immediate suspension on April 18.
2. Sammi will complete all treatment recommendations from Dr. Frierson. A delay of more than two
weeks in beginning the treatment recommendations could result in a prolonged suspension.
Sammi is ineligible to re-enroll until he has provided documentation of completion to the student
cgnduct o;f;g~e
~ This resolution is in conjunction with case 13-1730.
Failure to complete these sanctions will result in a hold being placed on your registration and an
additional charge of "~.ailure to Comply", which can result in further sanctions.
If you have a documentej:). disability that would require accommodations to complete these sanctions,
please contact the Office of Student Disability Services at 777-6142.
If you have questions about your case or about your sanctions, please contact me immediately.
Additional information about policies and the conduct process can be found on-line at
www.sc.edu/osc.
Sincerely,
Alisa Cooney Liggett

Executive Director of Student Conduct and Academic Integrity
EXHIBITC
5111/2016 https://maxfs-useast-001.s3.amazonaws.com/uscosjp/efc/00144371?response-cache-control=must-revalidate%2C post-check%3D0%2C pre-check%3...
Quick Print
BIT
\ 1 BIT
2013113001 -----. \r\e It
Sammi Hassan Addahoumi
GENDER: Male DOB: 1983-02-07

SID: F39404713 ETHNICITY: Not Hispanic or Latino;WH
HOUSING: Off Campus ROOM:
ATHLETICS: Not Athlete GREEK: Alpha Tau Omega Inactive

HONORS: Not Honors ROTC: Not Veteran
CLASSIFICATION: Senior MAJOR: Political Science
Last: 0.000 Cume:
GPAs: EMAIL: addahoum@email.sc.edu.
2.247
ACADEMIC
ADVISOR:
LOCAL INFO
Address: 1621 Main St Apt A Columbia SC 29201-2817

Local Phone: 8033196941 Cell Phone: 8033196941
PERMANENT INFO

Phone: 8033191867
Emergency Contact:
INCIDENT: 2014-03-15 3:44 am email

Description: Mr. Addahoumi sent me an email threatening to sue me if I did not give him a
passmg grailefor a paper lie subiintteamtlie emaiT:-Tliepapeffilers to meas a sociopatlr ancr~~~~.~~~~
dishonest. The level of hate demonstrated in the paper and its rambling nature are disturbing.
Given the wide mood swings I have observed, especially between our last meeting and the
3/15 email, I have serious concerns about Mr. Addahoumi's stability. You may recall that Mr.
Addahoumi was removed from my class during the Fall semester because of his disruptive
behavior. I agreed to allow him to finish the course by submitting a paper. I thought he and I
had agreed on a topic, and I have earlier email documentation of my guidance to him. I had
https://maxfs-useast-001.s3.amazonaws.com/uscosjp/efc/00144371?response-cache-control=must-revalidate%2C%20post-check%3D0%2C%20pre-check%3... 1/2
5111/2016 http;://maxfs-useast-001.s3.amazonaws.com/uscosjp/efc/00144371?response-cache-control=must-revalidate%2C post-check%3D0%2C pre-check%3..
nol. made? a demand for the paper's submission.

I an now concerned for my safety and that of my family.
I have not responded to Mr. Addahoumi's email.
I can attach documents (including documentation of guidance for his assignment) but I do not
see a place on this form fodo so. The 3715 email follows: "'I I wislithings could have
been different. Here is the paper which i owe you . As were discussed no rubric for the paper,
I took it upon myself to tell the story that explains exactly why you did not want me in your
class. Truth is very very dangerous. This is passing paper. IF you decide to make things
difficult by failing me, you can add one more lawsuit that you will face in the city if
Columbia. I wish you well. And I wish we could have beautiful music together instead of this
awful noise. Sammi Addahoumi"
REPORTED BY:
CHARGES: BIT-Erratic behavior
TAGS:
REFERRED B Y : -
-
NOTES
The infonnation contained on these pages is privileged and confidential information intended solely for the Individual or entity who has
accessed it for official purposes and by lawful means. Any dissemination, distribution, or copy of this communication is strictly
prohibited. If you have received this communication in error; please immediately notify us by telephone at (803) 777-4333 and retum
the original message to us via the U.S. Postal Service at 901 Sumter St. Columbia, SC 29201, without retaining a copy.
"Smart Policing" the Columbia, SC "Knowledge Based" economy - CNN iReport Page I of 11
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Posted March 12, 2014 by
delimansc
By delimansc I Posted March 12, 2014 j Columbia, South Carolina
Columbia, South Carolina
More from delimansc
The South Carolina Black Experience: From the Back

of the Bus to Shot in the Back
US High School bans Arabic Against All Odds "You've just got to do what's right," Greene told WIS, "and I was always a
The Eric Garner Manifesto: Reflections on America person-if I feel it's right, I'm going to say it, even if you disagree with it and
from Benghazi
2+2 stiff= 4 (even in Libya} even if ifs going to hurt me-I'm going to tell you the truth. Because, in the
Heart of the Gazbah.
long run, we owe it to everybody: to the citizens of Columbia and the officers
working there to always do what's right, and that's what I did."
,,~,,~,~,,,, __,,__,,,,_,,~-,,-,_--,,--- ,,,,,,_,,~,,-,,~-1twaS"because'1Jtthar,!3rnene-said'r'OrrnerCOlomblE1ChTefOfPOl1ce Ranay"'"""-~"-,~
Scott fired her.
http://ireport.cnn.com/docs/DOC-1104487 7/31/2017
"Smart Policing" the Columbia, SC "Knowledge Based" economy - CNN iReport Page 2of11
In Columbia, South Carolina, innocent people are under attack and have
h6where to run. All layers of government have failed, from the local, to the
state, even the federal level. To deny or overlook the situation any longer,
Damascus even for one more day, has ceased being simply a matter of politely ignoring
the awkward elephant in the room.
Steel
The level of perversion commands either absolute opposition or absolute
complacency. Officer Greene has a right to be angry. So does the widow of
Tom Sponseller. As well as former Columbia Chief of Police, Tandy Carter,
Andre Williams and Shannon Williams and all their families, neighbors, and
friends who have been wronged. Lest we beg that what happened to them
should happen to us tomorrow. Most importantly we must apologize to the
homeless of Columbia for allowing David Navarro to literally take food out of
their mouths by stealing their donated thanksgiving turkey dinners to distribute
in what has to be the pettiest form of patronage that I have seen, to the extent
that it is embarrassing even to read about. Petty is as petty does and petty
cash was was flying like "Don't Tell Mom the Babysitter's Dead!" making life in
Columbia like an AIPAC picked box of chocolates. We always know what we
are going to get. We can end this now .
foreverspin"' We must give them what is their right: an investigation. What kind of
criminals can be associated with the modus operandi that would involve
concealed rooms behind rooms in benign looking utility closets? The kind that
hack into your phone, your laptop, your server, and your bank account.
Our suspect, however, hacks for a living; therefore it is called tapping, or in

this case splitting. Also, our suspect has proven by his ineptitude that he is
above the law and has been awarded Executive Merits from the highest office
in the world to prove it. More so, our suspect is the worst kind of sociopath: a
crooked cop paid to be an deceptive data broker, who dabbles in peddling
DARPA funded Unit 8200 Unix open-source database mining, packet sniffing
death gadgets that come with their own iPhone app, and servers to boot.
These Smart Policing scams cost billions of dollars, suckering in the "client"
with an initial "buy in" that then devours a City Police Department by eating
itself alive with power and suspicion and corruption until it is a mere shell for
and by the shadow data brokers-turned power-brokers who make
arrangements for those who play ball and corresponding arrangements for
those who make trouble.
There can be no trouble. In clubs like the Citadel, Air Force, the Military
---~--~---~----~--------------lndustrial.complex,and/or-l0cal-police,iH3anbe-verydangerot:1stoplayball,----------~--
and deadly not to. The machine will always need an upgrade and always need
and an analyst, even if all she does is profile poor black males into those that
she has arrested and/or slept with and those she has yet to arrest, and/or
sleep with. Not surprisingly the correlation between the two is systematic.
http://ireport.cnn.com/docs/DOC-l 104487 7/31/2017

There is no longer any room for polite irrationality as we find our politicians
addicted to the evils for which they break not only our Jaws, but Jaws which are
higher and predate all of us, universalist codes of right and wrong, of moral
and immoral, of good and evil, and most importantly, the separation of the
two, for without separation, there can be no distinction.
The very real and very current Segregation of black from white in Columbia,
S.C has been cloaked with such exaggerated integration that we have the
audacity to call it knowledge based. How knowledgeable is it to ignore that
Columbia, S.C. has nearly year round bright sunny skies? The most corrupt of
all weave hydrogen fuel cell, biodiesel, dried Camel dung, and a cheap Agile
Power Point slides while being paid by SCANA to criminalize residential solar
panels.
Hundreds and Hundred of Billions of Hospitality tax extortion dollars are

laundered through companies that either exist on paper only. or "tech"
companies whose innovation includes how to destroy the U.S. Constitution,
not to mention the world, as fronts for DARPA or Unit 8200.
Corporations like CNA and Harris Computing are now using the Black citizens
of Columbia as lab rats in authoritarian surveillance experiments labeled
under the guise of "Smart Policing". These amount to designating and area a
"hot spot", then finding crimes to fit them, even if it means creating crime, as in
5 Points, while somehow, because a computer is used, it is call "evidence
based", for a Jack thereof no doubt, like another great authoritarian meme,
"Patriot Act".
The militarization of the City of Columbia Police Department should show

anyone who can see a solar powered sun that these experiments will not end
well. At least not for the poor, the Black, the dissenters, or anyone who
attempts an audit of one single unaccountable billion exacted from the flesh of
Columbia taxpayers.
It will be a war that the poor, the Black and the dissenters of Columbia will be
the first to feel. The militarized Columbia police must be acknowledged. They
must be curtailed. If the Federal government feels compelled to purge its
weapons of war and population control for any purpose other than the
preparing Ruben Santiago for martial law, Columbia will gladly take whatever
is metal. With enough scrap metal, we could perhaps build a whole metro
__,_,,____,___,,_,__,___,__,~~,----------~-----,---,~~,H--- before those in p_oweLallo,WJboi;e~ho-1oiLtoJ{eepJbemjn_powei:,-the-Black--~-----~~-~
community, luxuries such as public transportation.
http://ireport.cnn.com/docs/DOC-l l 04487 7/31/2017

I am a white southern male, born and raised in Columbia, SC with 5

generations of family that have lived, as I do now, and have died, as I can only
hope to, within and just outside of Columbia city limits. The House family of
Lexington County is heritage.
The symbol of hate, of oppression, of Ben Tillman of Nathanial Bedford

Forrest, of Albert Pike and all those who control the strings of Columbia's
Marionette City Council Theatre, with performances of agonizing over the
Morals and Dogmas of our city, it is a tired performance of sad yet ruthless
desperation and addiction to power.
I cannot ignore how, after billions spent on concept studies, Columbia City
council secretly, and in the most closed of bids, selected the preselected
English Socialist 3rd Universal model of Fascist "Smart Policing." R.
Buckminister Fuller would not approve, thought Pike would be quite pleased.
Your flag is a bloody rag that shames our fathers and their fathers and all
before them.
I refuse not only to believe the lies; I refuse to sit quietly, complacently, while
they are fed to others under the guise of truth. If my real Southern Heritage is
symbolized in the Battle Flag of the Army of Northern Virginia, or "Confederate
Flag", where is my Plantation? Where is my Ole Southern Home? Where is
my Tara, my Millwood ruins? We were slaves ourselves, and the worst in us
was fooled into fighting a rich man's war, not even because it was of our
choosing, but because the sanctity of our home had been desecrated by
invaders, occupiers, who tried to dictate to us our own thoughts and burned
plantations that were not even ours, yet we were implanted with a need for
vengeance and a lesser "other" so that the fallacy of logic could exist that poor
white sharecrops actually gave a damn about slavery other than from a need
for someone to feel superior to in our own misery. The banality of humanity
does not make us human. It takes away from it.
My family, every generation, were poor white sharecroppers. And I could not
be more proud. My Heritage is a history that has been distorted and rewritten
for and by the same elite 1% who have profited from the evolution of Slavery.
The truth is that there were not enough poor white sharecroppers, slaves to
the land and the company store, to die as aristocratic fodder, or at least, not
enough to win. The Union had more, as the factories gnawed bone and flesh
like a tech cotton sawy mill. We were no match.
We were the 99% that did not own slaves, for we were slaves ourselves. Our
~~~~~~~~~sfavery;~our~chains;wer~implyra1T1ore:indentared;-t:loa1<ecrtorm ofSlavery,
"servitude", for the sharecroppers and mill workers who are my heritage were
slaves of debt to the same master and same overseer in the same company
store. Today it is the cash advance - tile loans. The extended stay. The lottery
whose very name desperately tries to cloak what it clearly is: a poor tax, and

"Smart Policing" the Columbia, SC "Knowledge Based" economy - CNN iReport Page 5ofl1
more often than not a poor Black tax. But it is, in fact, a colorblind tax. It is a
Black poor tax only because we refuse to admit that we all suffer, whether it is
our own money or society that is wasted.
Do not mistake or let them spin the reality of Black Columbians bearing the
burden of systematic vice devised to ensure that the true worth of their ethnic
capital is never realized. A worker for USC once threatened me with a brick
when I spastically refused to relent in my questioning of where he was taking
the ethnic capital of Black Columbia, of South Carolina. I was afraid it would
be thrown away. This worker thought he was just replacing old bricks, worn,
chipped, grooved and smoothed with the age of a painful past
He was simply a landscaper laying nice new corporate sponsored bricks that
now fan the historic USC Horseshoe, many being "donations" from tax breaks
as tax breaks. For someone who refuses to deny the history, each old brick
which the worker removed was priceless, like the gold bullion of Black capital,
for it was by the bleeding hands and broken backs of Black men enslaved as
slaves and now slaves to a false history of romanticized slavery that the very
bricks of the USC Horseshoe were laid.
Instead of thinking in terms of good and evil, we have been deceived into
thinking, acting, and speaking, only in terms of Black or White, a self-
perpetuating otherness, while the only shades of grey to which we are not
blind consist entirely of two classes, according to our elected officials at least,
those with feathers or those with dots. Yet the saddest part of all is that such
uneducated, racist drivel is perpetuated, even by its victims, in an pathetic
belief that colluding with that same evil somehow deflects it, tricks it, makes it
somehow less savage by constructing still another other whose fabricated
inequity will be inherently exponential as one lie necessitates another.
It is the banality of human nature that we can only tolerate such victimization
by mirroring our misery; passing the bigoted buck onto another victim, yet
scream with such irrational terror from conjured threats that we have, with
great certainty, created for our own morbid and economic amusement.
We will find that USC is not only home to America's first political scientist,
Liber, it is also home to the very man who would corrupt the sanctity of the
American home, setting precedent for the surveillance state that has corrupted
not only the Leiber code, not only the 41h, and 1"1, but every single other U.S.
Constitutionally mandated right. America and our laws once meant something
other than being terrified into blind, illegal, immoral, and unending wars.
The man who once defiled the sanctity of the American home by stealing the
trashcan of an American citizen from his American driveway, this same evil
lurks in the shadows of Columbia as his exponentially imbalanced brain has
http://ireport.cnn.com/docs/DOC-l 104487 713112017

conjured, has constructed, so great an enemy, that he no longer digs through

used tampons for scrapes of post-it notes. So great was the power he
achieved and so easily was he able to dismiss any protests, that he has even
brainwashed himself in a lethal blowback whereby he proffers from the
expertise in the very misery which he constructed.
So expertly did he harnessed all the evil in himself that his conjured,
fabricated enemy has torn to shreds the societal fabric of America. No one
spoke up to stop him at your driveway and now he coaches others right into
your most private, intimate, personal thoughts.
Today, Leslie Wiser deals in digital waste, as he helps himself, and absolutely
anyone else that will pay, to not only your computer's recycle bin but also to
the thoughts which may not even be known to you, about thoughts you have
yet to have, for he records them, stores them, and sells them in real time as
you Google the information to construct your own thoughts and opinions. It
Leslie Wiser who decides whether your thoughts make you a profitable
customer or a profitable terrorist, or both as those who stop buying become
enemies of the State.
Mayor Steven Benjamin has broken the very laws that separate human beings
from animals. Mayor Steven Benjamin is not only void of intellectual or tactical
qualifications; he is an empty shell, void of humanity. In His proposals, his
schemes, we will find that the only feelings in his body are addictions to
money, power, lust, and the unabashed prostitution of himself and Columbia
to anyone and everyone who promises to secure these for him.
In not addressing the problem, in ignoring one law, one life, we have laid
waste to the objective truth, the reality that once protected us all. It has now
become dangerous to speak the truth; for we have been forced into a Twilight
Zone of conjured truths where people in power have only one requirement to
maintain the status quo:
Memories must be short, for the best memories are the shortest memories for
they need only be capable of remembering fear and hate, as a scared
customer is always a happy customer, just as hindsight is always 20/20 and
slavery always "wasn't that bad".
To remember the debate between City Council and Steve Benjamim over who
could access a crime scene is to admit to yourself and Ruben Santiago that
you are no idiot and you refuse to be taken as one.
One innocent woman's life was ruined forever one early Columbia morning
and we became accessories to a crime and our own oppressors when we
allowed the criminals to investigate themselves. The poor, poor woman,
Deborah Rubens, never even saw him, the evil, flying at top speed at her in
his luxury sedan. I think he hated her because she refused to be at the mercy
of his merciless excuse for a bus system. How dare she.
It was the evil that we can ignore no longer, and he was invisible because it
was only technically morning, still dark as night, when Mayor-Elect Steven
Benjamin, after an all night binge following his victory party at the Clarion
Townhouse hotel, was so impaired in his driving, in his decision making
capability, that he did not have his headlights on while recklessly driving
nearly 100 miles per hour though my, our, downtown Columbia.
He broke her skull and we break it over and over again every day we ignore
that initial crime, for it was a singular genocide that we have exacerbated
through complacent denial that has eroded our fabric of life. That poor woman
could not defend herself, nor seek justice against her attacker. Those that
investigated such criminal acts of high power found themselves victims of their
own mockery of justice as Columbia City Hall and the Columbia Police station
became a den of lies, suspicion, extortion, and sexual depravity.
It is that nihilist depravity which right now, under our watch, yet under our
noses, that now takes the form of "consultants" who are allowed, encouraged,
to masquerade as teachers and professors at the University of South Carolina
and "analysts" or "community resource officers" at the Columbia Police
Department, all of whom spend their days surrounded by vulnerable,
impressionable people. There are people who wish to combine Richland
County and the City of Columbia police and for them, they must approve, as
did Sheriff Leon Lott, of their officers arresting drunken distraught girls who
are not resisting arrest, but resisting rape and the predation of authority.
What if no video existed of the demented molestation that took place that night
on Devine Street in Buffalo Wild Wings? The officer, Allen Derrick, broke both
written and unwritten laws with such disgusting acuity, yet for Leon Lott, this
was justice to those who dared resist the penetration of usurped and absolute
authority. So sure, he will be happy to take over a few more promising social
deviants in the CPD.
There are now not only innocent careers being ruined by corruption, not only
livelihoods, but even human lives; those lives who dare express dissent are
worthless to those sworn to protect and/or represent them.
~~~~--~,-----~-,--,--,~--~,,-,,-~,-~,----,,--,-, ,~---~,-~~~-~--Columbia,.BouttLCarolioa,_aodJl.merica_as_a.wholahaar,aacbed_aJlieaking,_~---~-,~-~--~--~
point that is as evident at City Hall as it is on Capital Hill. Elected and

appointed officials, having long since blurred any distinction between the two,
have sold their positions of office in the same Faustian bargain which
promises that position, and to secure it, in exchange for keeping power out of

"Smart Policing" the Columbia, SC "Knowledge Based" economy - CNN iReport Page 8ofl1
the hands of Black South Carolinians by keeping them poor, uneducated, and
feeling like strangers in their own home.
This is not a battle that we can ignore, for it is a war not of our choosing. The
people, leaders, the officials, we are in a state of undeclared war of both
information and bullets. The City of Columbia Police Department, Columbia
City Council, City management, and even the University of South Carolina and
USCPD, brought back Jim Crowe 3.0 as a database that redlines by default,
whose hate and fear is written in code that perpetuates an anachronistic ghost
in the machine.
Today, the cameras in 5 Points save the modern slave trader from having to
look in the mouth of a Black man to decide how much that much that life is
worth. Thermal imaging technology can capture by the megapixel the
inhumanity of stripping and prodding of the selling block, whereby Ruben
Santiago decides who is of the field and who is of the house. Alvin S. Glenn
Detention Center is 100% young black males, not because they are a threat,
but because they are young, black, and male. We do not have to live like this.
The SC hospitality tax is a front to fund one elite white minority in keeping
capital out of the hands of the black majority. Whether wars or lnnovistas, bad
investments are bad only to those who pay their costs.
There are millions and billions and billions to fund studies, research groups,
pyramid schemes, and publicly funded-privately profited speculation bubbles,
though never a dime for a bus system so spitefully pitiful that every single soul
in Columbia should be deeply shamed.
I have watched my fellow citizens, fellow human being, shuffled from forgotten
cinder block projects, to decaying cinder block schools, to cinder block prison
cells. Columbia's Hospitality tax is cruel and racist joke that provides billions
and billions in a twisted, demented scam, running in circles trying to ignore the
anachronistic black hole that waves as a sign to Black America, to Black
South Carolinians, that they are not welcome nor wanted, nor even
acknowledged. We do not have to live like this.
I owe everything that I have, everything that I am, to Columbia, SC. It is for
this reason that I am compelled to stand, even if alone, against those who
have ravaged the generous hospitality and gambled the very future of my city,
of your city, of our Columbia. There is an ominous cloud of deceit, corruption,
-- -- -~---~ ---~~- -- - -~. -- ......~.bate,-and.betrayaLtbatbas.darkeoei:Lo.uLcity_witbJngrained, systematicL and --~---~----~~
insatiable greed.

As of late, this precipice has achieved critical mass, whereby we now risk
loosing everything for absolutely nothing, as the parasitic nature of what we
are facing only disengages when it's host is void of not only resources, but
void of the humanity which allows for life even without resources.
The city of Columbia is under attack by Columba City Council and it's gang
those who wish to take for themselves from Columbia what can only be had
' though the decimation those among us who have an obligation to protect,
either by oath or by birth, our city, and all those who call it home.
We do not have to live like this and I refuse to allow incompetent, criminal
officials, their collaborating media, and business interests to say otherwise, for
what they offer, what they push, is a carefully constructed and controlled
narrative that defies reality, yet is so elaborate, the fallacies can be cloaked
again and again, until they are revealed at last, in the final stages of financial
and moral default.
I know that Mayor Steve Benjamin is corrupt and void of morals, not because
of opinions I hold, but of facts I do not ignore. Mayer Benjamin has absolutely
no shame. It is as if his body has a physical dependence on pillaging
Columbia's Water and Sewer fund, the Hospitality tax and even the City of
Columbia worker's retirement fund. He shows no concern for the welfare of
Columbia, as he maliciously, even spitefully, formulates outlandish schemes
and suspicious policies that destroy any chance for its workers or citizens to
be secure in their eventual vulnerability.
Two months ago, the street, literally the road, in front of my restaurant
collapsed, just gave way, buckling like a third world warzone or the result of
some natural disaster in a distant land where starving people and structural
collapses are expected of cruel and indifferent government officials. I half
expected the City of Columbia Police Department to come steaming though
like Patton in their U.N. convoy, tossing out bags of rice for Palmetto warlords
to form over.
As Beltline Boulevard disintegrated, crumbling under it's own weight, the

criminally neglected water and sewer system was finally exposed, both literally
and figuratively. Even then, what should have been a rational choice, fixing
the road, was simply ignored. Because the city no longer has it's own road
crew, a gaping hole became a gaping wound as the bureaucratic psycho
circus of collecting bids on the project subsumed any actual work.
Residents of the surrounding Sherwood Forest area could be forgiven for

thinking that their government had not only forgotten about them, but knew
quite well and simply did not even care, as no effort or consideration was
extended to the the welfare of residents whether by informing them of the

project timeline OR EVEN have the common decency to let residents know
whether if was safe to drink the water coming out of their own facet.
A water boil advisory was issued for the first hour, then no information was
offered for the next 2 months. I did not know whether if was safe to serve my
customers any more than parents across the street knew if they were bathing
their children in city water contaminated with sewage.
If felt so sorry for all of my neighbors, many elderly, as I observed them go

back and forth during construction, looking for a way just to get home though
the sprawled and expansive disaster area that peaked in confusion at morning
and evening rush hours. Hourly, the same cars went back and forth, forced to
navigate the disorganized and sloppily chaotic ad hoc worksite left nightly by
road contractors, exacerbated with unnecessary confusion and the
unavoidable knowledge that a small problem had been allowed to manifest
into an almost unbearable daily, hourly, inconvenience.
On one corner, I was reminded of my home away from home, Benghazi, when
a resident, recognizing the absence of government, took matters into his own
hands, resulting a thoughtfully simple handwritten sign, taped to a chair,
graciously informing drivers which routes were accessible and which were not.
Where it merely confusion and/or only inconvenience which residents
suffered, the handwritten signage would have been a nice gesture. The reality
is direr and demands accountability, for the sign was not about the
convenience of drivers, but solely for the safety of the neighborhood children.
I find it unfathomable, unthinkable, and irreprehensible, that City officials could

not even extend the decency of facilitating a detour route through the
construction, leaving the our children to mowed over by distracted and
frustrated drivers who used our streets and yards to bypass the mess for
weeks before work even began.
Weeks and weeks went by before work even began.
My business, Sammi's Deli was forced to close, as were all others, including
Lizard's Thicket, and Dollar General. and upon reopening, the slow crawl of
the work closed the road resulting in sales figures that were unsustainable.
Had the road been closed another week, it may have broken me. The pillaging
,~,_,_,,_, ___,,__ ~~,,,,,,,.,,~,_,,_,,,,..,,,,,...,..,,,.,,,,..,, ...~~-,,.oLtheJ,ll,.lateLan.d.S,aw.erJund,_andJts,dire~Lc.ons~.quJ~!l.e<e.S, affect not only my __ ,,.,,_,_---~
own business and livelihood, but Mayor Benjamin's criminal greed and
nefarious neglect directly put in jeopardy the welfare of my workers. Though it
was costly, I did not lose my house or car. For at least two of my employees,

"Smart Policing" the Columbia, SC "Knowledge Based" economy - CNN iReport Page 11 of 11
however, those two days, which they could not work, meant that they had no
gas to get to work once the initial chaos had subsided.
These are realities which Steve Benjamin, Ruben Santiago, and Leslie Wiser
know absolutely nothing about, for these are not constructed and have no
agenda, no sponsor, no shadow executive board. It is simply the achievement
of Total Information Awareness through the recognition that there is no such
thing as Total Information Awareness and, above all, that anytime anyone
claims or seeks Total Information Awareness, they seek and claim the
omnipotence of God. As this is hardly something that can hardly come with a
written guarantee, I cannot support it as a concerned taxpayer, nor as a
human being.
iReport 101 We are Everywhere Get Help Tools

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EXHIBITD
Behavioral Intervention Team Incident Report

Submitted on September 20, 2013 at 1:43:45 pm EDT
Last modified September 20, 2013 at 1:47:38 pm EDT
Type: Behavioral Intervention Team Incident Report
Urgency: Critical
Incident Date: 2013-09-17

Incident Time:
Reported by Incident Location: On campus classroom 203 Currell College and v
Blackboard email
Name:
Title:
Email:
Phone:
Address:
Involved Parties
Sammi Addahoumi (F39404713) 1983-02-07 addahoum@email.sc.edu 8033196941

Off Campus
Incident Description
* Description
Mr. Addahoumi has been disruptive in class (Terrorism and Homeland Security CRJU 491T) by speaking without
being recognized in order to advance his view of foreign affairs. I thought I had managed these in-class disruptions,
but Mr. Addahoumi sent an inappropriate email on Blackboard on 9/17 to the entire class and to me, which was
brought to my attention this morning. The email was disrespectful towards me, challenging my qualifications to teach
and suggesting I had an agenda. In the email, he said, "bin Laden was 100% made by America" and "Hamas was
created by Israel." He denounced one topic I covered as "Zionist propaganda." After reading it, other students in the
class today expressed safety concerns about Mr. Addahoumi to the Staff. A Staffmember made me aware of
Facebook postings by Mr. Addahoumi that show individuals holding firearms and making hand gestures. I have
contacted the EOC Office and Student Conduct, both of which recommended I report this incident via BIT.
*Are there any effects/impacts of the behavior?

I understand two students may want to drop the class becausae they fear Mr. Addahoumi.
* Have you made any attempts to address the behavior? How did the individual respond to the attempts?
I thought I had managed the in-class behavior. I have not replied to, or otherwise addressed, the email.
* Do you have any other information about the individual that might be relevant?
A Staffmember conducted an internet search and learned Mr. Addahoumi has a criminal record. In addition, the
Staffer reported to me that his Facebook posts are alarming, including several in which weapons are displayed.
I have not been successful in being able to forward the email because it is in Blackboard.
* What is your relationship to the student?

Instructor-teacher only.
Pending JR #00009564
Submitted from 129.252.60.42 and routed to Tim Bedford (Behavioral Intervention Team Case Manager)
Modified by Tim Bedford on September 20, 2013 at 1:47:38 pm EDTfrom 129.252.93.129
5/11/2016 htlps://ma><fs-useast-001.s3.amazonaws.com/uscosjp/efc/00128130?response-cache-control=must-revalidate%2C post-check%3D0%2C pre-check%3...
Case Resolution Form

2013039101
Sammi Hassan Addahoumi F39404713 1983-02-07 BIT
Name I.D. Number DOB Role
Student Information
Off Campus Senior
Housing Room Number Classification
8033196941 8033196941 addahoum@email.sc.edu Political Science

local Phone Cell Phone Email Address Academic Major
Not Athlete Alpha Tau Omega Inactive Not Honors Not Veteran
Athletic Affiliation Greek Affiliation Honors Program ROTC Affiliation
I. Incident Information
2013-09-17 On campus classroom
Incident Date Incident Time Incident Location
II. Hearing Type Hearing/Resolution Conduct Administrator(s)

Date
Chair of Behavioral Intervention
BIT 2013-09-27
Team (Alisa Liggett)
III. Charge{s} / Issue{s) Finding

i. BIT-Erratic behavior FIO
Parental/Guardian Notification: No
IV. Sanctions/ Actions

BIT soft intervention
V. Additional Sanctions/Stipulations
VI. Rationale
Resolved through soft intervention with course instructor. Also, Scott Prill and the FBI looked into the
matter and saw no threat.
All costs for counseling, tests, and intakes are subject to change and are the student's responsibility. Failed, dilute, missed, late, or
forged tests = a failed test and may result in immediate suspension. Unless otherwise indicated, all essays, letters, and proof of
resolution or completion should be delivered to the Office of Student Conduct and Academic Integrity, 901 Sumter Street, Suite 201.
By signing this form, I acknowledge that my rights as a charged student involved in the disciplinary process have been explained to
me. Refer to the Carolina Community, available on line at http://www.sa.sc.edu/carolinacommunity/ for a complete description. I
further acknowledge that my receipt of a copy of this form constitutes notice of all findings and sanctions herein. Should one or more
_,,, __,,__ of the sanctions include services fr<!l!!J:Jl~J;oullseling and Human_l)evelopn:ient Center (CHDC), I give permission for the CHDC to
release information regarding my dates of attendance to the Office of StUdent Conauct~_,,__,,~,~,____,_,__,~,~-----,-------~~-_,__,__,___ _
Student agrees to these findings and sanctions
FOR OFFIC! USE ONLY

CC List
EXHIBITE
A Incident Report
Submitted on October 11, 2013at10:13:01 am EDT
LJNl\'ERSITY
n&. OF
Last modified October 11, 2013at10:22:14 am EDT
Type:
Urgency:
Conduct Incident Report
Critical
SOUJHQ1ROUNA. Incident Date: 2013-10-11

Incident Time: 8:40 am
Reported by Incident Location: On campus classroom Room 203, Currell Colleg
Name:
Title:
--- ___Ernajl: ------- ---
Phone:
Address:
Reasons for Report
--DisorderlyConducl,:OisruptiveActivity--=--
Involved persons
Sammi Addahoumi (F39404713) 1983-02-07 addahoum@email.sc.edu 8033196941

Male. --- Off Campus - - - -
Following disruptive classroom behavior for which Mr. Addahoumi had been previously counseled by -
and me, Mr. Addahoumi today chose to speak out of tum in class. He refused all attempts to channe~
input into part of an orderly discussion. Despite at least three cautions from me about conforming to counseling he
hael"'feeeive&by'*Waitfn{t't0'9e"reeognizedwtospeak.,Mr~ddahottmHnterrt1pted't>ther.gtudentswhonac:H~eeA~------
recognized, and he interrupted me. Sadly, Mr. Addahoumi has a viewpoint that could benefit a healthy debate about
policy matters, but he seems disinclined to participate other than as the final authority. It should be noted that I have
never ignored his request to speak.
After it was clear that Mr. Addahoumi had no interest in participating in an orderly discussion, I told him to leave the
classroom. After initially refusing to leave, he complied; however, he made comments on his way out of the room
suggesting that the members of the class were not interested in learning about terrorism.
m about his continued participation in the class. They have expressed to

and me their concern for their safety. One student left the classroom while
y me to refrain from his outbursts.
Again, this fellowed eounseling-by~d-me-eoneerfling-tf'te...!'rules--eHhe road" for classroom-behavior----
Pending IR #00009858
Submitted frotIL129.252.fi0.42-andmutedto_QfficeotStudent-Conduct-(Genera/--Account)-~-------~--------------------~----~ -~-----~--------~---~------
Modified by Office of Student Conduct on October 11, 2013 at 10:22:14 am EDT from 129.252.92.35
EXHIBITF
\
Submitted on October 11, 2013 at 9:47:27 am EDT

U'N~VER:S.ITY 01' Urgency: Critical
SOlJIH(?\ROIJNt\ Incident Date: 2013-10-11

Incident Time: 8:15 am
Reported by Incident Location: On campus classroom Currell College 203
Name: Sammi Hassan Addahoumi
Title: Student
Email: addahoum@email.sc.edu
Phone: 8032376116
Address: 910 Lacy Street
Involved Parties
Leslie Wiser () Wiserjr@mailbox.sc.edu 8037776503
* Description
"Professor" or rather Agent Wiser, has direct conflict of interests in teaching a class on "terrorism". He is an FBI
agent who also contracts as a private security consultant based on his involvement with the FBI.
In regarding the subject matter, he has targeted Islam and Arabs using populist and widely discounted sources rather
than academically credible and widely available material.
Such an involvement with the FBI or other organizations has led any and all lectures to be merely regurgitation of
overly biased, discriminatory, and agenda led opinion rather fact.
Instead of being a judge or non biased 3rd party, his his teaching the class in relation to the one sided perspective of
parties interested in persecuting Arab and Muslims. It is a class of biased opinions and dis proven allegations rather
than academic facts.
* Are there any effects/impacts of the behavior?

Students are lied to repeatedly, making the learning environment impossible without a critical assessment of his
teaching materials and lectures based on widely agreed upon academic criteria.
Repeated attempts have been made with no effect, despite reluctantly addressing obvious discrepancies when they
have been brought to light only under after my own suggestion based on my own intensive reviews of the wide
ranging subject matter.
The truth only comes out when I bring it out. His lectures are biased to the point of targeting Muslim, Arab, or even
African American students.
----~..:'!_Qe-yew-Fiave.aRY-Gther-iRfor:mation--about.theJndivJduaUhalmigbibeJ:elffilant2______.____._........__..~----------------
All of his material is provided by the FBI or associated agencies, resulting in far from academic elements, even a
market or profit driven approach that perpetuates stereotypes to further FBI interests.
We should be learning how to protect the constitution rather than learning from agencies seeking to weaken it.

I enrolled in the class to fill academic requirements but such a thing requires academics and not special interests
monopolizing the learning environment.
Here is the truth:

Somehow all of this escapes his lecture on the topic and he refused to allow me to present it as contradicting his
conflicted interest, and forced me to leave the classroom.
http://www.theguardian.com/world/2012/mar/20/fbi-informant
EXHIBITH
\
~
~
nttn1fnttn
~ ~
UNIVERSITY OF
SOUIHQ\ROLINA
October 11, 2013
Sam.mi Addahoumi
Regarding Case Number: 2013063501
Dear Mr. Addahoumi,
Based on the severity of the ongoing alleged classroom disruption and the on the alleged incident
occurring this morning, you will not be permitted to attend CRJU 491 until these allegations are
resolved. Failing to comply with this directive will result in an additional Code of Conduct charge. If
someone in the class feels threatened and calls the police because you are not permitted to be present,
it could result in arrest.
I want to reiterate what I left on your voicemail. Your removal from the course is a possibility if you
are found in violation of the Code. If you are removed on Monday, you will receive a WF. If you
remove yourself today, by withdrawing on VIP, you will receive a W. Person to person, I urge you to
weigh the gamble of adding an F to this situation.
I attempted to contact you by phone at noon to be sure you received this and so that we could talk
about it, but it appears you have forwarded your voicemail to the restaurant's voicemail and out of
respect for you, I didn't want to leave details of this information there.
I will see you for our meeting on Monday at 3:30pm.
Sincerely,

James F. Byrnes Building 901 Sumter Street, Suite 201 Columbia, South Carolina 29208
An Equal Opporrunity lnstirucion
Page 1 of 2
Case Resc~i~taon form

2013187501
Sammi Hassan Addahoumi F39404""/13 '1983-02-07 BIT
Student Information
Off Campus Senior
80331~6941 8033196941 addahoum@email.sc.edu Political Science

Local Phone Cell Phone Email Address Academic Major
Alpha Tau Omega Not Honors Not

Not Athlete
Inactive Veteran
...............................................................................................................................................................................,.................................................................................................................................................
<t
.
Information
2014-04-06 10:00 am Off campus
Incident Date Incidtmt Time Incident Location
Hearing/ Resolution C d t Ad 1 1 t t ( )
Date on uc m n s ra or s
Executive Director of Student
Conduct Hearing 2014-04-11 Conduct and Academic (Alisa
Cooney Liggett)
)I Finding
1. Misuse of Identification or University Resource!: -
Computers
/Actions
Suspension effective May 13, 2014 until9-e.0el'ffber:lo~012t\
I Sanctions/Stipulationy }
1. Sar;1mi has agreed to willingly ensa!1fin any arno1Jnt of -"ffi\nseli9g stipulated by the university.
Sammi will complete an assess11J.erlt wlrfh Dr. Rich3r ri'E3rson ~riday ,April 18 at a time to be
communicated to him once w~re ab e,_to contact Dr. iers rr:"
Failure to complete this assessment witnin--t.he.w.~~~wrn . result in immediate suspension on April
18.
2. Sammi will'complete all treatment recommendations from Dr. Frierson. A delay of more than two
weeks in beginning the treatment recommendations could result in a prolong~d suspension.
Sammi is ineligible to re-enroll until he has provided documentation of completion to the student
This resolution is in conjunction with case 13-1 '/30.
l
https ://cm.maxient.com/cm/CRFform.php 4/11/2014
Page 2of2
. . . .
. :~-~~:., ; ~
This offense is in violation of two charges of the Stl!Jdent c6.d~mico'nduct)s Misuse of Comppter
Resources policy: :
a. failL1re to l_dherl to the university's Network Abc~ss ahdAcceptable Use Rolicy_whichvstates,
"Dissemination of unofficial, unsplicited mass communications via University information technology
assets is prohibited. Violation of any portion of ttlis'p61icy may result in immtrediate loss of access to
University information technology assets, initiati~n oflegal.aetion by the Univers.ity, and/or
disciplinary action."
b. using computer resources to harass others or:in. ways that violate institutional computer use
policies
Sammi said that he is not out to get Mr. Wiser ar?d that the postirig was a mistake. As such, it is a
recommendation from Ms. Liggett, not a requireilr~nt from the univer~ity, that he act in congruence
~
1
with his statements by either: \'
1. removing the post ;;~ j
2. keeping th~ post up, but removing any indii!id~i.:tl'sni'fnes, thus allowing his opinions regarding
1
.*~":::.
.
his concerns about the CPD to be heard : .
Ms. Liggett will not follow-up on this but will allowiSamm~to determine the course .
............................!:.............................................................................................................................";. 1 ~ A~t.::~!;.:.::~~~........................................................................................................................................
...
~
and Intakes are subject to change anp are the student's responsibility. F111lled 1 dilute, mlslilecl, or
a test and may result In Immediate suspenslo\t Unless otherwise lndl!=illted, 111lf el!!'.ll!Y$ 1 ll'ltterl!, i!lfid prnor
;0illl1on or :;01npleuon slioulcl he delivered to the Office of student Conduct and Academic Integrity, 901 Sumtew Strel!lt, Suite ;WL
rorm, I acknowlecfge that my as a charged stwdent Involved In the dlsc:lpllnary process 111iv11 bel!ln !!lipltiin@d to
Caiol1n21 Comrnunlty, available at http://www.sa.sc.edu/carollnacommunlty/ for a completei del'Jerlption. r rurtlil#r
of this form constitutes notice of all Findings and sanctions herein, Should on!l or mort' of th0
th12 and Hl)man Develo~ment Center (CHDC), I give permission fdr the CHDC to
rny elates of Jttendance to the Office of Conduct.
l
Pl.ease select an O:,i;..n aria sign below:
+
0 Student agrees to these findings and santtions
0 Student desires CJC hearing

:~'{'~ ,\
0 Student desires a Restorative Jj!tice Co~1ference

&"" :
Date~------
Administrator Signature: - - - - - - - - - - - - -
CC List
https://cm.maxient.com/cm/CRFform. php 4/11/2014

EXHIBITK
Cose Zb122,24o t
~ Incident Report
~
Submitted on April 23, 2013 at 11 :20:42 am EDT
~:t Type: Conduct Incident Report

lfNl\'fill.:SITY <>F Urgency: Normal
SOlJIHQ\ROIJNA Incident Date: 2013-04-23

Incident Time:
Reported by Incident Location: On campus classroom Gambrell 201
Name:
Title:
---
Email:
Phone:
Address:
Reasons for Report
BIT-Erratic behavior, Disruptive Activity
Involved persons
Sammi Addahoumi () addahoum@email.sc.edu

Alleged Male
Incident description
I received this morning (April 23, 2013) a phone call from an adjunct instructor, who is teaching a
Political Science course for us in the Evening School schedule (POLI E483 Middle East Politics, which meets MW at
5:30 in Gambrell Room 201 }. - expressed considerable concern about a student in his class, Sammi
Addahoumi, who I believe is an undergraduate major in Political Science. My understanding is that this student, who
is in part Libyan, has had considerable outside-the-classroom contact with the instructor, reflecting at least in part the
student's interest in Middle East politics and the instructor's background s among other things the brother of
a former Israeli Prime Minister). My understanding is that this relationship was non-problematic. But, . .said this
morning, "something has changed," this student has become in the past "six weeks or so" very "vitriolic" and agitated,
and has "expressed hatred" at the instructor and Israel apparently both inside and outside the classroom. ,
said that the student at least once "yelled and screamed in the classroom," and has recently been "emailing students
in the class" attacking/criticizing? . I asked specifically if felt threatened or fearful and while I did not get
a straight answer, I think he does feel threatened; although w h a t - explicitly expressed was concern for the
student, not for himself.
Pending IR #USCB308291397
Submitted from 129.252.70.24 and routed to Office of Student Conduct (General Account)
5/11/2016 https://maxfs-useast-001.s3.amazonaws.com/uscosjp/efc/0011989nresponse-cache-control=must-revalidate%2C post-check%3D0%2C pre-check%3D ...
Case Resolution Form

2012212401
SAMMI HASSAN ADDAHOUMI 01000732 1983-02-07 BIT
Student Information
OFF CAMPUS JUNIOR
803-203-7851 ADDAHOUM@EMAIL.SC.EDU ~~T~N~~CIENCES -POLITICAL

Local Phone Cell Email Address Academic Major
Phone
NOT ATHLETE ALPHA TAU OMEGA No No
II. Hearing Type ~==ing/Resolution Conduct Administrator(s)

Coordinator - OSC and BIT
2013-06-03
(Maureen Grewe)
III. Charge{s) / Issue(s) finding

i. BIT-Erratic behavior Responsible
IV. Sanctions I Actions
VI. Rationale
Came to the appointments and is continuing to see Lara
All costs for counseling, tests, and intakes are subject to change and are the student's responsibility. Failed, dilute, missed, late, or
forged tests = a failed test and may result in immediate suspension. Unless otherwise indicated, all essays, letters, and proof of
resolution or completion should be delivered to the Office of Student Conduct and Academic Integrity, 901 Sumter Street, Suite 201.
By signing this form, I acknowledge that my rights as a charged student involved in the disciplinary process have been explained to
me. Refer to the Carolina Community, available online at http://www.sa.sc.edu/carolinacommunity/ for a complete description. I
further acknowledge that my receipt of a copy of this form constitutes notice of all findings and sanctions herein. Should one or more
of the sanctions include services from the Counseling and Human Development Center (CHDC}, I give permission for the CHDC to
release information regarding my dates of attendance to the Office of Student Conduct.
Student agrees to these findings and sanctions
FOR OFFICE USE ONlY

CC list
https://maxfs-useast-Oo1.s3.amazonaws.com/uscosjp/efc/00119897?response-cache-control=must-revalidate%2C%20post-check%3D0%2C%20pre-check%3... 1/2
'
UNIVERSITY OF
SOUIBQ\ROLINA
BEHAVIORAL INTERVENTION TEAM
May7, 2013
SAMMI ADDAHOUMI
Sent electronically to ADDAHOUM@EMAIL.SC.EDU

,;, '
Regarding Case Number(~012212401 \.
Dear Mr. Addahoumi,
The University of South Carolina is concerned about the well-being of all of its students. I have
received information that you may have been engaged in behavior(s) that have caused some concern
about your safety, health and/or well-being in the USC community. I hope that your situation is
improving. The university has a Behavioral Intervention Team (BIT) and policies regarding acute
health and safety incidents, behaviors that are self-injurious, and behaviors that are disruptive to the
mission of the university.
Due to these concerns and policies, you must meet attend two meetings. Their will be two meetings
one will be with a member of the BIT and then the other meeting you will be assessed by a counselor
in the Counseling and Human Development Center (CHDC). Your first meeting is in the CHDC with
counselor, Bryant Kilbourn on the 7th floor of the James F. Byrnes building to begin your assessment
on May 8, 2013 at 2:00pm. Students must arrive 15 minutes early to the CHDC to complete
paperwork. You should inform the receptionist that you received a BIT letter. Your second meeting is
with a BIT member so that we can answer any questions and explain the concern and the next steps.-
This second meeting is on May 8, 2013 at 3:30pm with Julia Thompson in the Byrnes Building Suite
201 (901 Sumter St.).
The total assessment will conclude after four meetings at intervals to be determined by a counselor at
the CHDC. After you have been assessed by a counselor at the CHDC, the university's Behavioral
Intervention Team will discuss the situation and make a determination that takes into consideration
your best interest as well as the best interest of the University community.
Only information regarding your attendance and compliance with this request will be shared with
members of the BIT. The content of any counseling sessions will only be shared with the members of
the BIT with your consent or in accordance with the counselor's professional and legal standards and
guidelines.
----~-~--lfyou-arealready-see~1lfoviderfilld~oul&prefertO""havehimfherverify-that7oua:r~engagedand-~-~-----~
attending your appointments, please call him/her at 803-777-5223 and request that they contact us with
any information that you are willing to release.
"P1w.uonNc; Cwu.rn: lNn;mun: ANO n1E lm;..11.s SEr Fm1T111N rim C,11w1.1Nl\N C11.1!1'1J
n1 Fosrrn A BnTl!ll. LIVING ANO L111NING ENVllWNMI!NT IN rill! VNtvE11snT CoMAWNnT
j,\Ml!S 90 I SuMTEll STREET. SL11TE 20 I Cm.UMlllA. SouT11 CAROLINA 29208

F. BYRNES Bun.DtNc:
803/777-4333 fax 803 / 777-1393 11TTP:l\\Ww.sc:.rnu.osJP1
AN ArnRM:\T1vi: At:TION EQUAi. Ol'ro1tn1l'li1Tr li'\ST1n1T10!'I:
Ifyou have a disability and would benefit from reasonable accommodations or having a representative
from Student Disability Services (SDS) accompany you, please contact our office and the SDS at
777-6142 at least 48 hours prior to your appointment time.
Our goal is to be educational and maintain the standards of the institution we share. If you would like
additional information about your rights or the conduct process, please reference
http://www.sc.edu/policies/staf626.pdf. We appreciate your cooperation and look forward to meeting
with you.
If you have questions about your case or about your sanctions, please contact me immediately
803-777-4333. Additional information about policies and the conduct process can be found on-line at
www.sc.edu/osc.
I look forward to meeting you.
Sincerely,
Julia Licorish Thompson

Assistant Director of Student Conduct
EXHIBIT I
SCHNEIDER, AUGUSTA
,.., m1Prr lnital appointment
October 11, 2013 at 10:27 AM
Good morning, Mr. Addahoumi,
I have attached an initial appointment letter from the Department of Student Conduct. Alisa
Liggett would like to meet with you on Monday at 3:30pm. Please read the attached letter.
Thank you,
Jlugusta Scfineider
Business and Office Manager
University of South Carolina
Office of Student Conduct and Academic Integrity
901 Sumter Street, Suite 201
James F. Byrnes Building
Columbia, SC 29208
803-777-4333 Fax 803-777-1393
Sammi Addahoumi intial

appointment letter.pdf
~
~
niflfntm
~ ~
UNIVERSITY OF
SOUIHQ\ROUN\
October 11, 2013
Sam.mi Addahoumi
Dear Mr. Addahoumi,
The mission of Student Conduct and Academic Integrity is to promote individual student development
and a campus climate of civility and accountability. We aim to advance responsible community
citizenship through promotion of the Carolinian Creed.
Our office has recently received information suggesting you may have been involved in or been a
witness to an alleged violation of the Student Code of Conduct. This information concerns an incident
that occurred on in class.
A meeting has been set for you on October 14, 2013 at 3:30pm in the Student Conduct office in the*
James F. Byrnes Building (at the open end of the Horseshoe) in Suite 201. In this meeting we will
discuss the incident report, what happened, your rights, your assessment of how your actions did or did
not uphold the Carolinian Creed, and (should you be found responsible for a violation) the resolution
options available.
Failure to keep your appointment may result in a hold on your registration, an additional Code of
Conduct charge of Failure to Comply and/or completing the hearing without the benefit of your
participation.
If your case involves a violation of the alcohol policy and you are under the age of 21, please know in
advance that you will be making a phone call to your parents during this meeting.
If you have a disability and would benefit from reasonable accommodations or having a representative
from Student Disability Services (SDS) accompany you, please contact our office and the SDS at
803-777-6142 at least 48 hours prior to your appointment time. If you have a verifiable class conflict
with this appointment time, please call 777-4333 to reschedule at least 24 hours before your
appointment.
Our goal is to be educational and maintain the standards of the institution we share. If you would like
additional information about your rights or the conduct process, please reference
http://www.housing.sc.edu/osc/pdf/StudentCodeofConductFINAL.pdf. We appreciate your

James F. Byrnes Building 901 Sumter Street, Suite 201 Columbia, South Carolina 29208
An Equal Opporrunity Institution
cooperation and look forward to meeting with you.
Sincerely,

- \
~
~
m11l1fflfm
UNIVERSITY
~ OF
SOUIHQ\ROUNA
October 15, 2013
Sammi Addahoumi
Dear Mr. Addahoumi,
Thank you for meeting with me regarding an incident report suggesting that you may have been
responsible for violating USC's Student Code of Conduct. These student conduct meetings were
designed to educate students about community standards and to hold students accountable when those
standards are breached. I hope it achieved that purpose.
In that meeting you acknowledged the essential accuracy of the report and agreed to have the resulting
Code of Conduct charges resolved through a conduct hearing.
Your Code of Conduct charges and findings are as follows:
1. Disruptive Activity - Classroom Disruption -- Responsible
You agreed to complete the following sanctions:
You are restricted from CRJU 491. Your presence in CRJU 491 without express written consent of the
Student Conduct and Academic Integrity will constitute a failure to comply and will result in
immediate disciplinary action up to and including summary suspension from the University.
You must complete a period of Conduct Probation beginning October 14, 2013 and continuing through
October 14, 2014. During this probationary period, any additional violations of University po.licy may
result in more severe sanctions, including suspension from the University.
With respect to the information listed above, the following additional sanctions/stipulations apply:
Sammi will not return to the classroom, but has willingly offered to propose an alternative plan to
Professor Wiser to finish the course in an independent study style in which he either completes
synopsis/analysis of the daily readings and completes the on-line tests, or completes a literature review
with parameters
James F. Byrnes Building 901 Sumter Street, Suite 201 Columbia. South Carolina 29208
803/777-4333 Fax 803/777-1393 http:/ /www.sc.edu/osc/
An Equal Opporrunity Institution
Failure to complete!hese S!lllctions will result ina hold being placed on your registration and an
additional charge of "Failure to Comply", which can result in further sanctions.
If you have a documented disability that would require accommodations to complete these sanctions,
please contact the Office of Student Disability Services at 777-6142.
If you have questions about your case or about your sanctions, please contact me immediately.
Additional information about policies and the conduct process can be found on-line at
www.sc.edu/osc.
Sincerely,

\ Page 1 of2
Case Resolution form

2013063501
Sammi Hassan Addahoumi F39404713 1983-02-07 BIT
Student Information
Off Campus Senior
803-319-1867 803-319-
addahoum@email.sc.edu Political Science
1867
Local Phone Cell Phone Email Address Academic Major
Alpha Tau Omega Not Honors Not

Not Athlete
Inactive Veteran
II. Hearing Type ~::!ing/Resolutlon Conduct Adminlstrator(s)

Executive Director of Student
Conduct Hearing 2013-10-14 Conduct and Academic (Alisa
Cooney Liggett)
HI. Charge(s) / Issue(s) Finding

i. Disruptive Activity - Classroom Disruption Responsible
IV. Sanctions /Actions

Restricted from CRJU 491
Conduct Probation effective October 14, 2013 until October 14, 2014. During this
probationary period, any additional violations of University policy may result in more severe
sanctions, including suspension from the University.
Sammi will not return to the classroom, but has willingly offered to propose an alternative plan to
Professor Wiser to finish the course in an independent study style in which he either completes
synopsis/analysis of the daily readings and completes the on-line tests, or completes a literature
review with parameters agreed upon by both.
VI. Rationale
Sammi has apologized for disrupting the classroom and is willing to apologize to the class to
<~<<-~-----<--~elimiRate-the-pereeptien-that-he~waRte(;He-undermin~PFefesser~Wiser-:-He~~eager~for~.+esglutiGi+-~---~--<<-<<<<<<~
that limits any negative effects he has on other students while still being able to complete the
course.
All co.;,ts for counseling, lests, and intakes are subject to change and ;;ire the stuclent~. msponi;,illlllty. filllf.'f.1, dih1tL,, rn,,,~..:11, IM.c, M
=
for gecl tests 11 tailed test and may result in immediate suspension. Unless ot11e1wlse lndlcalt:cl, all essay~, letter;., aml pwol of
https://cm.maxient.com/cm/CRFform.php 10/14/2013
Page 2of2
re,.,olution or con1plcllon s11ould Lie d~llvered to tl1e Office of Student Conduc1: ;;ind AC.:ildm11c tn~egnty, 901. SL11nter StrEeL, ~.u11.e /o 1
B~ signing ttiis form, l ack1101;,,1edge that my iights as a charged student fr1volved 1!1 tile d1sdplinary process have 11een exj1lainifrl fo ri1e.
Refer to the Carolina Community, available online at http://www.sa.sc.edL1/carollnacornrnunily/ tor a complete description. I flll"ther
acknowledge tl1at my recelpl: of a copy of this form constllutes nollcc of all f1Mlngs and sanctions herein. Should one or mori,i of lhi:
s<'!nctions include ~;ervices from t11c Counseling and Human Development Centt!r (CHDC), I give permission tor tl1e CliDC to release
in P.:llrnation regarding my dates of attenclance to the OFFlr.e of Student Con due~.
Please select an option and sign below:
L e n t agrees to those findings and sanctions

0 Student desires CJC hearing
0 Student desires a Restorative Justice Conference
Date: ~/fqf!_!_
Date: ID-('f.- f-3
CC List
https://cm.maxient.com/cm/CRFform.php 10/14/2013
EXHIBITL
Behavioral Intervention Team I Behavioral Intervention Team Page 1of1
Reasons for BIT referral

1. Self-injurious behavior/ suicidal ideation or attempt
Behaviors include, but are not limited to: talk of suicide or suicidal action
2. Erratic behavior (including online activities) that disrupts the mission and/or normal proceedings of University students, faculty, staff, or
community.
Behaviors include, but are not limited to: threats of a weapon on campus, significant inappropriate disruption to community, potential
for safety being compromised
Complete Incident Report Here

FOR ALL EMERGENCIES, especially after hours or on weekends CALL 803-777-4215 first
https://www.sa.sc.edu/bit/ 7/31/2017
Why I Behavioral Intervention Team Page 1of1
Why Be Concerned?
As members of the University of South Carolina community it is our duty to uphold the values set forth by the Carolinian Creed; namely to
"respect the dignity of all persons and demonstrate concern for others". As the eyes and ears of our community it is every Gamecock's
responsibility to take action and assist those students who show any type of behavior that could threaten their own safety or the well-being
of the University community. We all play a vital role in ensuring the safety of our students. The BIT strongly encourages you to utilize Its
referral services to continue to better our students and to further enhance our community. Please know the success of this process hinges
on community commitment to reporting concerns.Thank you for reviewing the Behavioral Intervention Team site. If you have any further
questions or have comments, please call a BIT member at 803-m-4333.
ll ..... "'."',,.*_....... .
allf.*
Timeline
ABIT case tokes from a week to a semester to resolve.
Change lakes time.
https://www.sa.sc.edu/bit/why/ 7/31/2017
What I Behavioral Intervention Team Page 1of1
"'7hat should I be concerned about?
The following behaviors can all be important signs of distress. As a member of the Carolina community. you may notice a student
exhibiting one or more of the academic. physical, or emotional signs and decide that something is clearly wrong. Or you may have a "gut-
level feeling" that something is wrong. If the latter is the case, don't dismiss your feelings or feel that you need to wait for tangible "proof'
that a problem exists. A simple check-in with the student may help you get a better sense of the student's situation.
PHYSICAL SIGNS EMOTIONAL SIGNS
ACADEMIC SIGNS IMPORTANT TO NOTE
NOTE: In cases where a studenfs behavior poses an imminent threat to you or another, contact Police immediately at 911.
https://www.sa.sc.edu/bit/what/ 7/31/2017
Referral I Behavioral Intervention Team Page 1of1
o=
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Referrals can be made by completing the electronic referral form. The on-line form allows for 24-hour reporling; however, please note that
referrals may not be handled until the next business day.

... ... MAKING AREFERRAL . .. .... ..
ll
.

What happens when I make a referral?
When a referral is submitted through the BIT website, each team member immediately receives the report via email.
The team evaluates each report and a member of the BIT wlil reach out to the student of concern to assess any resources needed and
collaboratively develop an action plan with the student to reduce obstades for their success at USC.
BIT members will assist the student in coordinating with resources and check in on their progress.
In the event that a student is perceived to be at risk of harm to self or others, BIT will coordinate with appropriate University offices to
assist the student
BIT may determine that there is no need to take any further action but will monitor the situation and concern.
The student(s) involved are contacted by a member of BIT and could be instructed to participate in an assessment process at Counseling
and PsychiatJy. Students who parlicipate in an assessment (up to four sessions) are frequently given treatment plans which may or may
not be required, depending on the severity of the concern. While the team is designed to address the most critical student cases involving
erratic behavior, or behaviors which pose a threat to self or others, many student issues are resolved through an informal meeting wffh a
member of the BIT. Students who fail to comply with the request for assessment or to follow through with treatment plans could be referred
to the University's student conduct system and charged with "failure to comply with an official university request.
https://www.sa.sc.edu/bit/referral/ 7/31/2017
How I Behavioral Intervention Team Page 1of1
How
Doi
Help?
Please consider the following:
Speaking with the student individually

Filling out a BIT referral
Show you care, connect on a feeling level, listen.
"I'm concerned about you and noticed you haven't been sleeping, eating, going to class, etc."
"How are you feeling?"
Reflect back their feelings and paraphrase: "What I hear you say is that you are in a great deal of pain and feel hopeless."
"I'm glad you called."
Listen with respect Individuals in distress want understanding and care.
Ask about suicide directly.
"Sometimes when people feel sad, they have thoughts of killing themselves. Have you had such thoughts?"
"Are you thinking of kHling yourself?"
"Have you considered suicide?" "How would you go about it?" "When would you do that?"
Remember, asking about suicide does NOT put the idea in people's minds.
Get help. Explore options. Offer resources.
"What would help now?" "Who can, who usually helps?" "How can I help?"
Get assistance. Avoid trying to be the only lifeline for this person. Seek out resources even if it means breaking a confidence.
"How would you feel about going to the Counseling Center? Let's call right now. I'll walk over with you to see a counselor."
Counseling and Psychiatry, 803-777-5223, Monday through Friday, 8 a.m. to 5 p.m., Byrnes Building, 7th floor. After hours, listen to
the voice message for emergency numbers.
National Suicide Prevention Lifeline 1-800-273-TALK
Call 911 or 7-9111 if this is an acute crisis.
What Not To Do
Do not promise to keep the person's thoughts of suicide a secret.

Do not leave the person alone.
Do not offer simple solutions.
Do not suggest drugs or alcohol as a solution.
https://www.sa.sc.edu/bit/how/ 7/31/2017
Who I Behavioral Intervention Team Page 1of1

'

Behavioral Intervention
Team
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.:-::::::::::::
. . . . . . . . . . . . CORE TEAM MEMBERS.:-:::-:-:-:-:-:-:-:::1
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Byrnes 201
803-i77-4333
Heailh Cenlar Byrnes i04

803-m-3175 ao3-m-s223
1600 Homp!on Annex Po!lerson Hall

803-i77-l215 803-i77 -4283
Ad hoc members include:
Disability Services
Student Ombudsperson
Student Life
Sexual Assault & Violence Intervention
Campus Wellness
Academic department representatives
General Counsel
https://www.sa.sc.edu/bit/who/ 7/31/2017
Treatment I Behavioral Intervention Team Page 1 of2

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:.::.:: :" :.::.::.::.:::.:.:::.:.:::.:TREATMENT OPTIONS ...... a a a a a
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SOFT INTERVENTION CHECK-IN MEETING
ASSESSMENT AT COUNSELING & PSYCHIATRY
REFERRAL TO OFF-CAMPUS COMMUNITY AGENCIES
INTENSIVE OUTPATIENT PROGRAMS OR MORE INTENSIVE CARE
REFERRALS TO OTHER USC CAMPUS PARTNER OFFICES
Off-Campus Assessment/ Intake
Each treatment facility in our area has their own process for handling new clients. In-general, you can expect that the assessment will last
1-3 hours depending upon your circumstances. There may be initial paperwork to complete. Make sure you take your health insurance
cards with you and present this upon arrival. A licensed mental health clinician will complete your assessment, which will require them to
ask you a broad range of questions. Once finished they will provide you with feedback regarding their findings and what treatment(s) are
best suited for your individual needs. Please make sure to sign a release of information waiver to have the information faxed to the BIT al
803-777-1393.
Six-Week Alcohol/Drug Use Group
The standard six-week group takes a psycho-educational approach to providing information and insight regarding the use of substances. II
meets once per week over a six week period. The format is modular and a different topic is presented each week. Topics range from: the
impact of substances, South Carolina laws and minimizing risky behaviors. Attendees are expected to actively participate. The general
goals of the group are to help students make informed decisions about their substance use, to explore the role of substances in their lives
and to focus on risk reduction.
Intensive Outpatient Treatment
We occasionally have contact with students who are in need of substance use treatment services that cannot be provided on-campus.
They are often in-need of Intensive Outpatient Treatment (IOP). This is a form of outpatient counseling wherein treatment is received 3 or 4 <_< ___<_<__<_____<________<___________<~----<----
-------~----------11mes~K.There are mree suCh programs lnllleColumbla area arid they provideSeiVlCesduring day andevenTng hours. The lengths--
of the counseling sessions vary, but are usually two to three hours each. If you have been referred for IOP you may find the following
information to be useful:
Local Programs
Lexington/Richland Alcohol & Drug Abuse Commission (LRADAC)
https://www .sa.sc.edu/bit/treatment/ 7/31/2017

Treatment I Behavioral Intervention Team Page 2 of2
2711 Colonial Drive, Columbia, SC 29203 Phone: 726-9300 Internet: www.lradac.org Services: Day & evening programs
Palmetto Richland Springs
Richland Medical Park Drive, Columbia, SC 29203 Phone: 434-4813 Internet: www.palmettohealth.org
Titree Rivers Hospital
2900 Sunset Boulevard, West Columbia, SC 29169 Phone: 796-9911 Internet: www.threeriversbehavioral.org Services: Mostly evening
programs Private for-profit hospital-based
Additional Information
It is recommended that you call ahead before visiting with one of these programs. They will be able to prnvide more specific information
about their hours of operation, fees, health insurance acceptance and answer any questions that you may have.
If you have commercial health insurance (such as Blue Cross, Aetna, Cigna, etc) you should take your insurance card with you when you
go for your first appointment and present it to them. (*) Please Note: Fees, hours of operation, phone numbers and other information are
subject to change. We are providing this data to you in-order to assist with connecting you to one of these programs. Nothing in this
document should be considered definitive; please contact each program for specific up-to-date information.
https://www .sa.sc.edu/bit/treatment/ 7/31/2017

FAQs for Referrers I Behavioral Intervention Team Page 1of1
What do I do if I know a student who may need to be referred to the BIT process? If you feel there is an immediate threat call USC
Police at or 803-7n-4215, or call 911 and tell dispatch if and where you are on campus. To make a referral, go to Incident Report page.
You will be asked for basic infonnation about the student, how to contact you (in case the BIT has follow-up questions) and for a
description of the incident or behaviors that prompted the referral. Should I talk to the student about referring them to the BIT
process? You are the Behavioral Intervention Team's best resource because you are familiar to the student. If you are comfortable doing
so, tell the student that you are concerned and ask if the student is OK. In many cases the student will indicate that they could use some
help and you can refer them to Counseling and Psychiatry at http://www.sa.sc.edulshs/chdc. Referring students to Counseling and
Psychiatry and the BIT covers all bases. Who can make a BIT referral?
Anyone who feels a student is a threat to themselves and/or the community can make a BIT referral; including students, parents, faculty
and staff, and other community members.
What happens after I make the referral?
The team of members from Counseling and Psychiatry, Office of Student Conduct (OSC), University Housing, USC Police, and Student
Health Services receive your referral by email and are able to take the information and make a decision about whether the student should
be assessed by Counseling and Psychiatry. Reporting is the most critical step. To make a BIT referral, please go to http://www.sc.edulBIT
and click on the red Incident Report button in the center of the BIT homepage. Refer to the Resources page find contact information and
explanations on how these departments can assist you.
What happens to the student in the BIT process?
If the team determines the student is appropriate for the BIT process, he/she will be contacted and instructed to participate in an
assessment at Counseling and Psychiatry. The type of assessment is dependent on the behavior. Students are generally required to
participate in a minimum of 4 sessions of assessment by a Counseling and Psychiatry staff member. Students with involuntary
hospitalizations due to substance use will complete an assessment and will be given an individualized treatment plan that may include a 6-
week skills based group, individual counseling, or treatment In the community.
How do I know if it is a BIT issue or if it is more appropriately handled by other campus resources?
You do not have to make this determination; the BIT will do it for you. The most critical step is that you report it at http://www.sc.edu!BIT. If
another campus resource is more appropriate, the BIT will refer the student and handle the transfer of information.
Typically, behaviors that pose a threat to safety or that cause a significant community disruption qualify as BIT, while students who
experience other mental health issues are appropriate referrals to Counseling and Psychiatry at http://www.sa.sc.edu/shs/chdc or 803-777-
5223.
https://www .sa.sc.edu/bit/faqs/ 7/31/2017

FAQs for Students I Behavioral Intervention Team Page 1 of2
What is the purpose of the BIT?
As a result of growing national trends on college campuses of mental health issues and the increase in hospitalizations and deaths due to
alcohol consumption, the University of South Carolina created the Behavioral Intervention Team (Bin. In order to promote the safety and
health of its students, the BIT addresses student behaviors that are disruptive and may include mental health and/or safety issues.
What does the BIT do?
The Behavioral Intervention Team consists of a group of qualified and dedicated USC professionals whose mission is to:
Balance the individual needs of the student and those of the greater campus community
Provide a structured positive method for addressing student behaviors that impact the university community and may involve mental
health and/or safety issues
Manage each case Individually
Initiate appropriate intervention without resorting to punitive measures
Eliminate "fragmented care"
How will the BIT process help me?
As a result of participating in the Behavioral Intervention Team, students will:
1. Be able to articulate campus resources, supports and services that are applicable to their needs.
2. Have an understanding Of their concerning behaviors and how those behaviors affect themselves and our community.
3. Be able to identify positive/healthy changes in their behavior.
What is the best way to contact the BIT?
The Behavioral Intervention Team may be reached by calling (803) 777-4333 or you may set up an appointment to visit us in the James F.
Byrnes Building, Suite 201. We are directly across from the Horseshoe on the comer of College and Sumter Streets. There is metered
parking available on College Streel
Why is BIT contacting me?
You are a Gamecock and someone else in our community was concerned about you and a behavior they observed. USC is particularly
concerned about high-risk behaviors by students due to the threat these behaviors pose to student health, safety, and academic success.
You received an email to come in for a meeting to be able to hear the concern and share your story wilh a member of the BIT who can help
conn~ct you to the appropriate resources.
What if I have a hold on my registration?
If you have a hold on your registration, it is most likely for one of the following reasons:
Failure to attend a scheduled meeting with your BIT administrator or Counseling and Psychiatry appointment
Failure to complete the action plan assigned to you
You will have to attend a meeting or complete the action(s) before the hold is removed.
Is this BIT case going to be on my transcript?
No. BIT cases are not punitive and not on your academic record and there is no notation on your transcripl
The records of cases are kept confidential and will only be shared with your written permission or if there is an immediate health and safety
risk.
Will I lose my scholarships because of this BIT report?
https://www .sa.sc.edu/bit/faqs-for-students/ 7/31/2017

FAQs for Students I Behavioral Intervention Team Page 2 of2
No. If a student's Individual scholarship provider requires a conduct clearance, information regarding your BIT case will not be shared.
Can I bring someone with me to my BIT meeting?
Yes. A student can bring an advisor to a BIT meeting. The advisor can be faculty, staff, student, family member, parent or attorney. Please
note that any advisor requires that the student signs a FERPA (Family Educational Rights and Privacy Act) release form allowing them
access to their confidential case.
https://www.sa.sc.edu/bit/faqs-for-students/ 7/31/2017
Forms I Behavioral Intervention Team Page 1of1
a:=
o=
FERPA Waiver
Medical Release Fonn
Community Provider Report
https://www.sa.sc.edu/bit/forms/ 7/31/2017
Behavioral Intervention Team Incident Report Page 1 of6
A.
'* llNl\'UtSffY 01'
SOUIHO\ROLINA
Behavioral Intervention Team Incident

Report
For interpersonal violence reports, please visit Stop Sexual Assault

(http://sc.edu/stopsexualassault).
Background Information
Enable additional features by logging in (https://cm.maxient.com/reportingform.php?

UnivofSouthCarolina&layout id=3&promptforauth=true).
Your full name:
Your position/title:
Your phone number:
https://cm.maxient.com/reportingform.php?Univo:fSouthCarolina&layout id=3 7/31/2017

Your email address:
Your physical address:
Date of incident (Required):
Open Calendar
YYYY-MM-DD
Time of incident
Location of incident (Required):
Please select a location ...
Specific location:
Involved Parties
https://cm.maxient.com/reportingform.php?UnivofSouthCarolina&layout_id=3 7/31/2017
Select Gender
Please choose ...
Select Role
ID Number
DOB (YYYY-MM-DD)
Phone number
Email address
Hall/Address
Add another
Please provide a detailed description of the incident/behaviors you have

obseNed. Use specific, concise, and objective language. Forward any
additional information to the Office of Student Conduct at osc@sc.edu with
the subject heading BIT. Please call 803-777-4333 if you have additional
questions.
Behavioral Intervention Team Incident Report Page 4of6
Description (Required)
Personal, emotional, or behavioral concerns for this student. Check any that apply. (Required)
D Suicide Attempt
D Suicidal Ideation
D Self-injurious behaviors/cutting
D Disordered eating behaviors
D Emotional distress
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l Q/ 21I20i4 1'0E .9~,S't FU- Ag~pe P:r:!.~:r,y C~re --- A!:i:ten~'

10/1512614 02:23 80343429tr.:i U5C FORE1'5IC PSVO~ PAGE
Forensic Psych.i~try Fellowship

USCSOM
15 Medical park
Columbia, South Carolina 29203
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ADDAHOUMI, SAMMI (id #24366, dab: 02/0711983)

10/15!2014. WED 15: 51 FAX Al1'-l?e Pri~ry Cli!re -- Al:henlll
I
VIOLENCE RISK ASSESSMENT
PORENSIC SE!RVICES OIV,SION
DEPARTMENT OF NEUROPSYCHIATRY AND BEHAVIORAL SCIENCE
UNIVERSITY OF SOUTH CAROLINA SCHOOL OF MEDICINE
NAME: Sammi Hase.an Addanouml
DATE OF BIRTH: February 7. 1983
.DATES OF EVALUATION: AprH 26, 2014 and May 14, 2014
EXAMINERS: Richard L Frierson, M.D., D.F.A.?.A.

Professor of Cltnlcal Psychiatry and
Vice Chair for Education
Dept. of Neuropsyohiatry and Behavioral Science
University of South Caronna School of Medicine
Stephanie Chapman, O~O.,

Fellow In Forensic Psychiatry
REASON FOR REFERRAL
Sammi Hassan Addahouml is a 31-year-olef male who is referred for a violence risk
assessment by SoOtt W. Prm. Deputy Chief of Police of the University of South Carolina
(USC) Division of Law Enforcement and Safety. This vlolence risk assessment was
requested due to Mr. Addahouml's disruptive behavior in the classroom and disturbing
comments and accusations about professors at use.
SOURCES Of INFORMATION
1. Memorandum of Scott W. Prnl of h USC Division of Law Enforcement and
Safety dated Aprfl 14, 2014. .
2. CNN World article by Greg Botelho and Oana Ford dated August 22, 2011.
3. Behavioral lntel"llention Team referrals dated April 23, 2013; August 131 2013;
September 17, 2013; October 11, 2013; March 15, 2014; April 6, 2014; April 7,
2014.
4. Email from Natasha White to Patricia Armstrong dated September 24, 2013.
.. 5. The Guardian article by Paul Harris dat&d March 20, 201.2.
a. letter from Alisa Liggett to Mr. Addahoumt dated October 11, 2013.
7. Emails between Le&lie Wiser. Jr. and Mr. Addahouml dated November6, 2013
to November 8, 2013.
ADDAHOUMI, SAMMI (id #24366, dob: 02/0711983)

10/15/:?014 ffED 15:51 FAX Ag11.pe Pri~ry C11.re ~-- Athen11. ~0031012
8. Email from Leslie Wiser, Jr. to AJisa Liggett dated March 17. 2014.
9. CNN tRep,ort by Mr. Addahoumi dated April 5. 2014.
10. Posts to Mr. Addahoumrs Twitter account dated March 25, 2014 to April 2, 2014.
11. Incident Report by Offtoer A.IVL Bolin dated April 7; 2014.
12. case si.Jpplementa RepQl't by Investigator A.O. Owens dated April 10, 2014.
13. lnoldent Report by Officer EmmanueJ OeJesus dated May 12, 2012.
14. Incident Report by Offtcer Kyle Giibert dated December 27. 2011.
15. Incident Report by Officer Robert Pitcher dated November 30, 2010.
16. Incident Report by Officer Ryan Johnson dated December 31l. 2010.
17. Incident Report dated May 24, 201 O.
'18. incident Report by Officer Rodney Hartwell dated August 22, 2007.
19. EmaU frcm AllQa Liggett to Scott Prill dated AprN 11. 2014.
20, WLTX news article dated March 1, 2012.
21. WACH news article dated Aprit 17, 2012.
22. W1S news articfa dated Aprlf 19, 2012.
23. A five mfnute encounter with Mr. Addahoumi on April 251 2014.
24. ~~A 15 minute interview wfth Mr. Addahoumi's father on April 25, 2014.
25. A one hour and 45 minute cftnlcal forensic Interview With Mr. Addahouml Qn May
14,-2G14.
26. A 15 minute Interview with Mr. Addahouml's fa1her on May 14, 2014.
STATEMENT OF NONCONFIDENTIAUTY
Prior to this evaluation, Mr. Addahouml was informed of the non-confklantla' nature of
this evaluation. Specifically, he was informed that the evaluatk>n was requested by the
USC Division of Law Enforcement and Safety ancl that a report would be prepared and
delivered to the Deputy Chief of Pollce Scott W. Prill; He voJeed an understanding of
this 1lmltation Of confidentiality and agreed to proceed With the evaluation.
CHIEF COMPLAlNT
"USC is a joke. I have no Intention of returning to USC."
PERTINENT STATEMENTS AND INFORMATION RESULTING IN THE REFERRAL
Mr. Addahoumi Is a 31 ...year-old male who was born in America after his father fled
Libya In the 1970's. He ts a dual citizen. He traveled to Libya on multiple occasions
and reported the 8\ISflts of the collapse of the Gaddafl regime in 2012 through a CNN
Jntematlonal blog. He was a student at USC from 2001 to 2003 and returned tn 2013.
Slnee that time, feculty, staff. and students have filed n'lfJltiple reports exprassing their
concern about his behavior:
ADDAHOUMI, SAMMI (id #24366, dob: 02/07/1983)

I 10H51'0l4 '!!O" 15 5' FU . . . ., Pr1-r1 Oaro --- A'hona
This evaluation waa lnitially scheduled for April 25, 2014. Mr. Addahouml presented to
the USC Department of Nuropsychiatry with his father. Before the evaluation could
begin, Mr. Addahouml stated that he could not complete it because he was busy
studying for finals. He appeared very agitated, demanding that we read a book written
by a USC Professor about Arab/Jew relatlcns. We spoke briefly wfth his father who
reported that Mr. Adda ho um I had not been actrng normally and that he was very
ci>neerned about him. He was provided Instructions on how to go to the probate court
to obtain an order of detention so that Mr. Addahouml could be detained and taken to
tile Emergency Room for a mental evaluation.
-On April 20, 2.014, Professor Oon Fowler forwarded a course paper written by Mr.
Addahouml for his Polltlcs and the Mass Media class. Professor Fowler expressed
concern about remarks that were made in the paper. In the paper Mr. Addahoumi
wrttes, "It is through South Caronna that Israel is preparing for a constructed war and
Libya Is the gateway through which It will be facllltsted." He further notes "Columbia,
SC ts home of the OHS SLED FUSION Center where Is obvious threat ls being ignored
as Israeli technology is spread and embedded tnto every Mpeot of life [sic] ...
Mr. Addahoumi presented for the second time on May 14, 2014 with his father. At the
beginning of the evaluation, he set up an IPad on the table, stating that he had Vkfeos
and pictures that would help to explain his ooncems. It was later d!teo'1efed that he
was secretly recording the Avaluatfon (without pemtleslQn) with the intention' of posting it
to aocial media. When asked if he knew the reason for the evaluation, he staled that ha
wished to provide a history of event& that would better explain what had recen1Jy
transpired at USC. Over the next 15 minutes, he talked contfnuausly without
Interruption by the examiners. He began by explainlng how his fa'ther was born into a
poor Muslim famlly, birthed by a nun, and oircumcleed by a Jew. He sard that there is a
way for Christians, Musnms. and Jews. to co..exfst He then stated that there are real
problems with the world that are not being addressed by USC. He provided his
educational history with USC and work history wi1h Sammi's Oeti (see Scciaf History
section). After saverat attempts to redirect him, the issue at hand was addressed.
He exptained that "things being taught at USC a.re Incorrect,. He stated that the
professors he has disagreed with at USC are Dr. Yosef Olmert and Professor Leslie
Wieer, Jr. Regarding Dr. Olmert, he explained that he purchased all the books that
were on his syflabus. From there; he vitent Into a lengthy discussion about the Clash of
Civilizatlons theory In a post-Cold War world. He was redirected back to the topic after
several attempts by the examrnera. Regarding Professor Wiser, he stated that he was
teaching the students lies about Musllms. He s~id that Initially he (Mr. AddahoumO
wourd approaoh him (Professor wrser) after class to tell him of his own experience in

l0/15!20l4 WED 15:52 FAX ~~po Hr~l'llltry C~ro ~-- Ath~n~
the Middle East He alleged that Professor Wiser stated, "I don't care If It's right I like
what it says.,. He said that after that conversation. he began to raise hla hand In class
beeauge he "wouldn't allow him to teach lies to his students.'' He said that Professor
Wiser was targeting him when he ~an to talk about "home grown terrorism.'" He
stated that on one occasion he was asked to leave the ciassroom after ane\Mr student
complained about Mr. Addahoumi to Professor Wiser.
He stated that he had used e'Wery avenue pcaible to address his concerns about his
professors. He added that he had been targeted by Or. Olrnert; Professor Wiser, and
lsraeU student organizations on campus. He stated that Alisa Liggett is working tn
~reion" with Professor Wiser because they sit on the same board. He said 'ltlat she
caned his father to inform him of his grades for the semester and balleved this was
against use policy. He added that he be!l&Ved she was a zrcmlst and had tt out for
11
1
[him]." He sald, "It's Ike a secret community. She won t acc&pt the fads I prasel'\t to
her... He than began discussing the 11Black Ops" in the Columbia PoUce Department and
deaorlbed the officers as "a bunch of idiots." He stated that Tom Sponseller did not
commit suioide and that he had taken photographs of the area where he was found. He
expressed that he beJ{eved Professor Wfser helped to cover up the d~th of Mr.
Sponseller. When asked if there was anything he regretted about how he had handled
himself at USC, he stated, 11Signing up for Wisers class.,. He then went on to state that
bUHons of dollars are invested In the hospitar.t.y department In South Csrollna and "that
type of thinking" le what caused the death of Tom Sponseller.
'\/Vhen asked how he was doing overall, he stated, "I'm doing well." He explained that
he spends the majority of his time working and also enjoys spending time with his
younger brother. He estimated that his current sleep pattern was ~I." but admitted
that it had not been well in the last semester beoouse his ''family is being destroyed In
Ubya..- He stated that the longest time he had continuously remained awake was one
day. He would not fuliy answer questions about his sleep. He reported that his appetite
was good. When ask~ about his thinking, he stated. "I think on a different level - a
higher level of thinking than others." He suggested that his thoughts ara not racing. but
that others' thoughts are just slow. Regarding special abilities, he stated that he
predicted a politicat event and referred us to CNN. He felt that his energy level was
higher than ottiers because there ls more work for him to do. He denied audttory or
visual hallucinations, but mentioned that the City of Columbia has a drone program and
he has seen drones flying over the O!ympla area.
Mr. Addahoumi made numerous statements during the evaluation that appear
grandiose. He states that he could hav~ stayed In Libya and gotten a position from the
President because he had been on CNN. He also exaggerated his Involvement with his
ADDAHOUMI, SAMMI (id #24366, dab: 02/07/1983) !4JD371~60

10!2lf201.4 TUE 9: 59' FAX Aq!!.p!! Fril.11#-ry Cs.re --- Al:nen!!. ',
10/l6/2al4 E2~23 8034342985 USC ~OREtlSIC PSYCH PAC-E 0'7112
father's deft businesses, Implying that he managed and ran one of the two delis. He
reports he has six employees and that he works from 1O am to 10 pm. This was
contradicted by his father on Interview who states Mr. Addahoumf works about three
hours a day and does not m~nage the deli.
At. the conclusfon of the evaluation, Mr. AddahoumJ was asked to sign a release form to
obtain mec:Uoaf records from his primary care physician. He intt!ally refused and became
agitated, leaving the bulk.ting. When he returned he took the pen from one of the
examiners and said, "Fine. I'll sign it." He quickly signed the form. He exited the
-buildlng again, then retumed 1 took the release foim and crumbled It up. He was then
instructed to take a laboratory test form to a lacal lab in order to obtain a urfne drug
$CC'een. (Urine drug screens are standard procedurea In vlclence risk assessments].
He became agitated again and began to yell profanity. He refused to comptete the
testing. The form was grven to hts father and they exited the building.
PSYCRrATRIC HISTORY
Mr. Addahoumi denied a histof}' of Inpatient or outpatient psychiatric treafmenL He

reported that he was diagnosed in the past few years with Attention Oeficlt/Hyperactfvlty
OfSorder (AOHD} by his prfmary ca"' physician, Dr. Bilr Robtnson, and Is pree.orllJed the
stfmurant medication dextroamphetamine/amphetamlne (Adderall).
ALCOHOL AND SUBSTANCE USE HISTORY
He reported that ha drank alcohol when he first attended USC from 2001 to 2003. He
stated that he was convicted of a DU& during that time period. He statad that his use
has been rare since that time and hhs last drink was in the summer of 2013.
He reported first using marijuana (cannabis) in high ach(l(l(, He stated that his use
continued Into colfege and he smoked onoa a week.. He reported being charged With
simple possess.Ion of mal'fjuana on several occasions. He stated that his last use was
in 2001, though records indicate that his arrest& for simple possession were from 201 o
to 2012. When asked questions about these charges1 he was unwll!Jng to answer
questions.
He denled a hfstory of the use of cocaine, hallucinogens, ecstasy, intravenous drugs,

Inhalants, or prescription medications not prescribed to him. He denied a hlstOry of
treatment for drug or alcohol use. He reported that he smokes one peek of cigarettes
over three days.
ADDAHOUMI, SAMMI (id #24366, dob: 02/07/1983) ~0391060

10121/2014 T~E 9:59 FAX Aga~o Prt~ry Caro --- Achena
10/15/2814 az: 23 ee34.'342995 use FORENSIC PSYCH PAGE 09112
MEDICAL HISTORY
He denied a history of medical problem$ or drug allergies. He reported that he was rn a

moped accident fn the past flat required the placement of a steel rod in hhi teg.
FAMLY HISTORY
He denied a family histoiy of mental Illness or substance abuse. This was confirmed by
his father. He reported that his mother passed away from complications from Systemic
'Lupus ~rythematosus (SLE) when he was an infant
SOCtAL HISTORY
He reported that h was born and raised in the Columbia. SC area. He indicated that
his IY1'0!fler paesed away when he was Jess than a year old. He was raised mainly by
his faffier with some assistance from flls maternal aunt He recalled that his ctiHdhood
was .,great'' and denied a history of phystQaJ or sexual abuse. His father remarried when
he was 15 years old. He has a Younger brother who ls 15 years old. Mr. Addahouml
currently resides alone in his own home In the Olympia area of Columbia, SC.
He described himself as a good student ln grade school and noted that he received
recognition from Duke Univerelty. He was enrolled In regular classes. He recalled that
he was suspended on one or two oooaslone for sklpping schooJ. He denied a history of
fighting, stea&lng, cruelty to animals, or fire i:ietttng. He attended USC for the first time
from 2001 to 2003. He was a member cf the Alpha Tau Omega fratemlty and described
himself as "frat-tastic.1t He stated that he "leftlfalted out" In 2003. He returned to USC In
2013 to complete his degree. His stated that l'lis current major Is PoUtlcal Science with
a minor In lsle1mJc Warfel History and Mlddle Eastem Studies. He estimated that his
gradea this semester were not good. 11 Records Indicate that his current GPA is 2.241
not includrng thie semester. Records further indicate that he was registered for six
classes this semester. He withdrew from three classes (Intermediate Arabic, Topics in
Polltfcal Science, General Applicat Programming) and made an A (Natlonallsm/Etf'tnk:ity
- World Porrtics), C (Polltica and the Mass Media), and C+ (lntroductlcn to Earth} In fu9
remalnlng classes. He stated that he pfans to compreta his degree at either the
University of Southem California at Berkeley or in Italy.
He reported that he began working at his father's dell C'Samm1s Deli") at a young age.
He said that he began working there fuH time after he left USC !n 2003. He said that he
was the owner of three locations, the ~ner of tvvo locations, and that his father
owns another locatfon. Samml's Dell currently has two open locations. He stated that

10/lS/2014 WED 15:53 FAX ~~~e Pri~ry C~re ~~- Achen~
he works "from 10 a.m. to 10 p.m." seven days a week. His father incHcated that Mr.
Addahouml ctieoks on the Beltline Blvd. location for two to three hours per day and
does marketing work.
Mr. Addahoumi dened being invotved in a current relationanlp. He reported he once

dated a girl for three years. He stated that he waa planning on doing an arranged
marriage because they have a higher success rate. He denied having children.
He reported a history of arrests for almple possession of marijuana and OUt Records
Indicate that he was arrested in 2007 for drMng with a suspended license. In May of
'2010. a police report was ftled by an lndMdual who sold a moped to Mr. Addahoumt and
was corrtacted several days later asking for a reful)d because he had wrecked the
moped. He added that Mr. Addahouml stated that ult was going to be a sad day for the
people in apartmGnt 314. In November 2010, a police report was fifed by a woman
after she alleged that Mr. Addahouml threw a box ot food at her when he delfvered it
In DeCember of 2010, he was arrestad for driving wffh a suspended license and was
afso charged with simple posseesioo of martjuana. In December of 2011, he was
arrested for driving with a suspended license and was also charged with simple
possession of manJuana. In May of 2012, he was charged with simple po!Osession of
marijuana after being seen on camera making a transaction with another lndMduaJ.
VK>LENCE HISTORY
He denied a hlstcry of early legal difficulty, Including stealing, cruelty to animals, or fire
setting, He would not have met diagnostio criteria for Conduct Oieorder. I-le has been
arrQteci for simple possessfon of marijuana and DUI. However, he denies a history of
violence. His father confirmed that he does not have a history of violence. Mr.
Addahouml denied gun 0\11/nershlp and his father confirmed this information. Records
Indicate that he does not have a concealed weapons permit.
MENTAL STATUS EXAMINATION
Mr. Addahouml preaented as a tall and thin mare. He appeared his stated age of :31
years old. He was dressed In casuaf attire. He was sweating profusely throughout the
interview. When he &tood up at the end of the Interview his back was drenched in
sweat despite operant air oonditioni11g In the office. His grooming was satisfactory. He
dispfayed psychomotor agitation. He was mostly cooperative with parts of the
&Vtiluation thi;.t did not involve questions about USC. Hs became more Irritable and
uncooperatiVe wf'len discussing the Incidents at USC and his past marijuana use. He

~ 10_0:_51~22:4_1'1'3D_!.5: 53 FAX Ag!Lpo Pri~ry C1tro --~ Al::hon1t
maintained appropr!Qte eye contact for the majority of the evaluation, but stared at
times. His speech was pressured and loud at times. His thought process was
$lgnificant for tangentlalfty and flight of Ideas. He was dtfftoult to redirect. There was no
evldence of suicidal ideation or homicidal fdea.tion. He denied a history of auditory or
visual halluclnations. Ha did not appear to be responding to lntemat stimull. His claims
against the faculty and staff at USC a.nd members of the police department appeared
delusional. He descrtied his mood as "fine, exoept last semester when I was being
targeted." His affect (outward expressron of emotion) was Irritable and Intense.
He was atert and oriented to the date, place, person, and situation. He correctly spelled
"world fOrward rand backward. He became lrrttabl9 when asked to subtract serial Ts
from 100 (a common test of concentration). He refused to attempt the task. tie
registered three objects and recalled two Of the objects after five minutes. He recalled
the third oblect when given a prompt. We found no evidence of ellntca!ly stgnlficant long
or short term memory impairment. He demonstrated an ability to think absne.tly In a
comparison of objects and Interpretation of proverbs. His level of 1ntel1igence appeared
to be-very high. In contrast to recent Ufe events, he displayed reasonable judgment
when posed with a hypothetical emergency sltUatlcn.
ADDmONAL INFORMATION
On May 14, 2014t Mr. Addahownfs father was inttiuviewed briefly. He reports that Mr.
Addahouml appeared to be doing better since ~xams were over. He does not view his
son as mentally ill but believes he has a time management and anger problem. He
denied knowledge that his son Is using drugs. He reports that things went well for his
son during the falt semester but that hls son seemed to have f)l'Qblems in the spring
semester. He reported that there had been a definite change in behavior In his son.
After this evaluation, Mr. Addahoumi made a highly inappropriate Twitter post, referrin,g
to Alisa Liggett as a zionlst \IVhorebag and a dirty one at that". He also posted a
recording of the ht 75 minutes of this evaluation on Facebook and CNN iReports. He
also emailed Ms. Liggett wfth the Behavioral Intervention Team and stated "The
University of South Carofina does not know what it lost today". He made an
inappropriate remark In the email about Dr. Cl1apman (one of the examiners in this
evaluatioo).
DIAGNOSTIC IMPRESSION
Mr. Addahoumi dbip!ayed the forlowing symptoms of mania during the evaluation:
lrrltabllity, grandiosity, pressured speech, fflght of ideas, and distractibility. Hrs dramatic
I _!!'"""-"' '""
FU '9P Pr<'=? Care --- atoona
~011/\)12
I attempts to expose members of thll USC faculty, staff, and police department for
alleged cttmlna' aotMty represent an Increase In goal-directed activity Therefore he
would meet diagnostic criteria for Bipolar Disorder. However, the cause of his mood
eymptoms le unclear. Given his history of cannabis and amphetamine use, it Is
esaential that llllolt substances be ruled ~ as a possible oause. This ds particularly a
possibility given the amount that Mr. Addahoumi was sweating which did not appear to
be related to anJ<fety. For that reason, we are assigning hlm the diagnosis of Bipolar
Disorder, Not Otherwise Speelfled, Provisional. Additionally, we note that a Substance.-
Induced Mood DISOrdeF needs to be ruled out.
,_.e reported a histOIY of regular marijuana (cannabis) use during his high school and
college years. He has been arrested on muttiple occasions for simple pcssessk:>n of
marijuana in recent years. HOWE!\/$1'1 he has not encountered substance-related legal
problems in the past 12 monttis. For this reason, we are assigning the diagnosis of
History of Cannabis Abuse.
AXIS T: Bipolar Disorder, Not Otherwise Specified, Provtslonai

Rule Out Substance-.tnduced Mood Disorder
History of Cannabis Abuse
AXIS II: Deferred
AXlS UI: None
AXIS iv: Academic difficulties
AXIS V;. 40
VIOLENCE RISK ASSESSMENT
There is little medical evideflce that Mure violent acts can be successfully predicted by
mental health professionals. Therefore. despite opinions contained in this report, there
is no guarantee that Mr. Addahouml will not behave In a violent manner.
Risk factors for violence can be classified into two categories. Static risk factors are
factors whfoh cannot be modmed. tn Mt. Addahoumi 1s particular ease, his static risk
factors include the fact that he Is male and single_ Dynamic risk factors are factors
which are modifiable. ln his partloular case, the dynamic factors tnclude the presence of
mental Inness and substance use.
There are several protective factors as well. Mr. Addahouml has never engaged in
serious vlolant acts In the past. Therefore, If he were to engage in a serious vloient act,
he would be an outlier statistically. He reportedly he has not used marijuana in several
years and malntslning sobriety from thrs substance would be another protective factor.
I -
""J!20.14,.!!"D-15' '-' FAX ..... '"'"'"" care - "no \1:1012/\H2
According to both him and hls fattier, he does not have access to weapons at the
present time.
RECOMMENDED INTERVENTIONS TO REDUCE THE RlSK OF FUTURE VIOLENCE
1. tn order to return to USC as a student, It la imperative that Mr. Addahouml be

evaluated and treated by a Pl!YChiab1st He must comply wtth the psychiatrist's
t.reatrnent plan which will likely include regular follow-up appointments and
psychla:tric medication. Mr. Addahoomi must agree to allow USC to receive
periodic lndependent documentation that he ls under the care of a psyehlatrist
and Is complkint with the treatment p!an.
2. Mr. Addahoumi has a hlstoJY of marijuana 0$$. Additionalty, he has taken

prescriptlon amphetamines In the recent past. These sube.1ances can cause
and/or won1en symptoms of mental Ulness, especially irrftabUlty, disorganized
Jhinklng and grandiosity. Therefore, it Is recommended that he avokf alcohol and
all iUicit drugs. He should work with his psychiatrist to determine the appropriate
presedption medications. Before Mr. Addahoum' is altowed to return to campus,
lt iS recommended that he demonstrate abstlnance from illlclt substances by
agreeing to three separate urine drug screens to be obtained at times determined
by the University. Additionally, If he returns to campus he shoufd agree to
random periodic drug screens for up to a six month period.
3. If at any point Mr. Addahoumi Is beUeved to be a danger to himself or others, It

~ recommended that a d&tentlon order be completed at the Richland County
Probate Court This will ensure that he Will be transported by law enforcement to
the hospltal for a psychiatric evaluation.
If I can ba of further assistance, please

.. do not hesitate to contact me at rny office .
rs , M.O., D.F AP.A.

teal Psychiatry and Vice ChaLr for Education
Document History
Date /Time Action Action By Status Priority Assigned To Action Note

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10/17/14 08:34am Reclassify document- Clinical Document


10/1512014 NRO 15:51 FAX .nqape Prim&ry C~re ~~- Athe~~ !,;'ll00110l2
University Specialty ClinicsrDepartment ofNeu.ropsychiatry and Behavioral Science

Authorization to Use/Discfose Infonnation
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my attacnt 011 WbefJl.er l provide lllltbortation for tile reiqu.ested use of disclowre.
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r W1ds11lnd tltat infon:aation med or Cfbclosed pursuant to this ewthorlzation may be SUbject to re-disclosure by coo roolpicnt nnd
may m!I Jo:iaor b11 protected. by htw. .
I undmtand that r havo the right to withdraw this autborluiiOl'I by sending a 'f/l'iUen notloc: to d'!c Department ol'NfllltOpsycblntry,
A.ttrt: Cllnf.c Office Manapr, 15 Medfoal Parle~ Suite 141, Colinnbl~ S.C 2926:3. J understand that withdrawal Is not efl'eettvc for
actions taken pri~to the withdrawal.
A11tho1'b:atlon expires on the CoHowing date or ev111Jt; _ _I~
__ _'J..;;/_,--=-ff-+---------------
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SfgQature of:Patlent!I Pannt. Printed Name or Patlents

Guni"dinn, or ~cp"tentmtive Data
Pan:nt, Guai:dlanl'or
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DEPARTl\llENT OF NEUROPSYCHIATRY 15 J\tlEDlCAL PAR , SUITE 141,
COLUMBIA, SC 29203 PHONE : (803) 434-4300 FAX: (803) 434-4351
EXHIBITR

Submitted on May 6, 2014at10:20:15 am EDT

Urgency: Normal
Incident Date: 2014-05..05

Incident Time: 4:30 pm
Reoorted by Incident Location: On campus - other disturbing email
Name:
Title:
Email:
Phone:
Address:
Involved Parties
Sammi Addahoumi (01000732) addahoum@email.sc.edu (803) 237-6116

Male
* Description
I received a disturbing email from Sammi yesterday (will forward to osc@sc.edu), which included a link to a writing he
apparently authored. Sammi's behavior has become increasingly odd in the past year, but yesterday's email came
after no contact with him since early January. The piece of writing he attached in this email contained many elements
which raised my level of concern, for many reasons. Also, it contained references to a number of faculty as well as
references to statements made by Dr. Pastides.
Frankly, all of this could signify nothing, but it could also be very significant. I am also going to make a all to the
above number to give a "heads up" on this report.

see above
see above
see above

see above
* What is the purpose of this report?

I am not sure
Submitted from 129.252.70.23 and routed to Tim Bedford {Behavioral lnteNention Team Case Manager)
EXHIBITS
A
Submitted on May 6, 2014 at 10:20:15 am EDT
~R Type: Behavioral Intervention Team Incident Report

LfNl\.'ERSITY QI' Urgency: Normal
SCUIHQ\ROUNA Incident Date: 2014-05-05

Incident Time: 4:30pm
Reported by Incident Location: On campus - other disturbing email
Name:
Title:
Email:
Phone:
Address:
Involved Parties
Sammi Addahoumi (01000732) addahoum@email.sc.edu {803) 237-6116

Male
* Description
* Are there any effectsnmpacts of the behavior?

see above
see above
see above

see above

I am not sure
\ \ \
Sammi Addahoumi
POLI 362 Fowler
Libya: Spectrum of Rediscovery
04/20/2014
"The essence of academic freedom is the free exchange of diverse ideas and opinions. I
am in agreement with the Association of Public and Land-grant Universities that, .,
"Freedom of inquiry and expression are the foundational principles of [this] vital wor1'
and.free exchange of ideas is its lifeblood." F()r these reasons, I stand with colleagues
throughout the country in strong opposition to a boycott of Israeli academic institution."
-Harris Pastides,
-President, the University of South Carolina
On AP.ril 17, 2014, the University of South Carolina welcomed acclaimed author and
scholar Katherine Hall Bates to sp~ak in honor of Professor Donald Fowler and to mark
Professor Fowler's 501h year with the USC colleges of political science and mass
. .
communications, a career spanning half a century that began iri 1964.
By his own huble admission, Don Fowler has instructed at least half of South Carolina's
state legislators that now congregate under Columbia's State House dome. Very rare is
there to be found one man who has made so encompassing an impact inside the
classroom and out, as part of both th~ South Carolina and ~ational Democratic Party, as
well as the patriarch of a fan1ily and communications firm who continue to shape local
c~pus, state, and national dialogue. In her lecture, Kathrin Hall Bates examined how
two worlds, that of the media and that of the political, have been misrepresented in what
she identified as "The Assault on Fact in American Politics".
In honoring Professor Don Fowler for his academic nonpartisanship,,there is a gap that
can only be explored in relation to the statements of USC President Harris Pastides, for
any such assault on fact in American politics is undeniably rooted in the assault on fact in
--------~~-American-aca<lemTa:-As-the hom.e of thefirstpol iticafsciencedepartn1entTn-the.u;lt~<l-----------~-

States of America, USC has a responsibility, if not a mandate, to exemplify all IS
noble in the pursuit of higher wisdom, a responsibility that has historic precedence and
which is now being undermined with unprecedented impunity.
At the University of South Carolina, there is a nearly irreducible divide between the
knowing subject and the object that is known. I believe that Libya is the prism by which
this gulf can be breached and what follows is an attempt to examine a universal history
whereby it may be possible to build a new understanding of the theories and models from
which we derive modaJities of politics, academics, and the unifying factor, which divides
them, religion.
In his lectures, Professor Donald Fowler relays noble principles that are compromised by
the statements of USC president Harris Pastides as academic debate is curtailed. We will
examine how the statements of President Pastides betray noble principle of academic
freedom that is mandated in the Carolina Creed. Programs such as the Behavioral
Intervention Team (BIT) at USC are implemented at great cost and resource to twist
freedom of expression into classroom disturbances that stifle academic debate through
intimidation.
Professor Don Fowler is but one of many professors at USC whose impact inside the
classroom can be paralleled only by impacts made outside the classroom. I will use my
own first hand research, from USC to Benghazi, Libya and juxtapose what is known and
can be proven as fact against what is offered at USC and we will find that the difference
is a matter not of religion or politics, but of American national security.
The Middle Eastern and Islam World Studies program at USC has been eliminated by
__ --~----~-~-~-~~~~~l5,E~~E~pr_~~-l1r~~J:b~l!tQT}ITQ!~!h~_narrati v.~~arding the_ Mid.die .F.L&St.Jiruilslamic_worJd_..~---~-----------~~--------

and ensures that what very little does reach the classroom, or evening news., has
filtered and scrubbed to be void of all reality.
This is despite a critical knowledge gap in all areas of study regarding the region, from
language to religion, to politics, and history. This silent, hidden, academic boycott of
Middle Eastern studies is in spite of an overwhelming demand expressed by students, the
policy continues in blatant disregard for basic academic freedoms of debate and equality
of ideas.
Specialists such as Waleed El-Ansary and the International Common Word project that
he brought to USC have been targeted and eliminated, as even guest speakers are banned
from delivering lectures that do not conform strictly within pro Zionist agendas. Agents
of Israeli Zionist propaganda outlets are sold to students as Middle Eastern experts in a
disturbing scenario whereby the classroom is used to make people dumber. This
handicaps generations of citizens who cannot make informed decisions nor interpret
current events in the world as they relate to their own lives with any meaningful
perspective.
Having taken part in the Arab Spring and having witnessed Arab Muslims march in
protest to demand and die for Democracy, I mentioned to Professor Leslie Wiser after his
very first very first lecture, centering on Samuel Huntington's Clash of Civilizations, that
the Arab world did, in fact, want to modernize and, did, in fact, want Democracy. 1 was
given quite the rebuttal: "I don't care if it is right", replied Professor Wiser, "I like what it
says". This coming from a terrorism expert who t had to enlighten regarding the
origins of Osama Bin Laden, as his class on terrorism was void on actual terrorism as it
every lesson while avoiding the American origins of the Saudi Terror network that exits
until today, connecting Benghazi and Syria, securing his profession as a terrorism
analyst.
Another example lies in Professor Josef Olmert. Dr. Josef Olmert is a doctor in the same
sense that Dr. Saif al Islam Gaddafi is a doctor, that is, accredited by the discredited
London School of Economics, obtained through selling academic integrity. Dr. Olmert
has not even the most elementary understanding of Middle Eastern Politics, something
that his own brother makes known at every opportunity.
Dr. Olmert's brother, Ehud Olmert, served as both Mayor of Jerusalem and as Israeli
Prime Minister, yet now sits in an Israeli jail cell because of illegal bribes accepted by his
brother, Dr. Josef Olmert. In what became known as the Holy Land Corruption case, Dr.
Yosef, or "Yossi'', Olmert was given envelopes stuffed with cash to influence his brother,
in his position as former Mayor of Jerusalem, regarding an illegal Israeli housing
development. Dr. Josef Olmert has published 3 books of racist Zionist literature that
serve to reinforce notions of racial superiority and religious discrimination. Dr. Olmert is
the circular error that can be found in statements of the use president and those noble
principles relayed so ideally in the lecture delivered by Mrs. Kathrin Bates in honor of
Donald Fowler, as well as those so expertly articulated in the lectures delivered in the
classroom of Don Fowler himself.
I have not been to Afghanistan, nor have I been to Jraq. I do, however, spend my summer
months walking across Egypt, Tunisia, and most extensively, Libya. When not
backpacking, hitchhiking, or otherwise wandering around North Africa, I reside where I
----~----------~wasborn -anaralsed;Coluffib1a, Soiith-Carolina:-1was born with one tooflnthe mosque-~--~----~--<-<<<--<---~<--<~-----

and one foot in the church, as though conceived on some long lost platform that once
straddled a divide across the Atlantic to Atlantis, from the beginning of history and the
first man, to convoluted notions of the End of History and the Last Man. f't.
,,__v'--'~
.
_,.- 0'.'i1.
I have seen tablets upon which the Alpha, the Tau, and the Omega, were reinterpreted
into the Father, the Son, and the Holy Spirit, where Greek become Latin, yet for me these
were innovations, for I have slept in Garden of Hesperides, drank from the River Lenthe,
have swam in the lake where St. George did slay his Dragon, and have seen the signs of
God that became Judaism as stories of creation, flood, diaspora, and renewal have been
reinterpreted as Jew become Gentile and Jesus become Isa.
I know the true Shibboleth is but the mark of the Fascia, for I have walked from Carthage
to Alexandria and experienced the forgotten layers of history in between. I have lost
count how many times I have been to Rome, yet I remember so well the Africa in which
St. Mark was John Mark and where he took refuge from the persecution of the Romans
are hills and mountains whose cisterns still rise and fall with the Libyan Wadis. I have
slept in Wadi Marcus and seen his captors in the Arch of Marcus Arelius as I came to
learn the African memory of St. Mark.
I have camped at the Pillars of Hercules upon the Syrtic Divide and know that there is no
Clash of Civilizations for I slept quite soundly where East and West meet North and
South at the Gulf of Sidra, the center of the Ancient World.
From the Oracle of Siwa to Peachtree Rock, I have seen the seashells and the wild figs
that share wavelengths on a hidden spectrum and I have plucked both from the earth like
truth that that is to be revealed through the Libyan Sibyl, the Libyan prism.
l agree with Don Fowler that Politics are the most pervasive aspect of any society and
that there are no aspects of lite which are not effocted by politics, more so than even
religion, to the extent that the Bell curve of the American political spectrum can relegate
no less than half of the population to having no worth what so ever, in ways that wars or
religions never have. While Western secular systems of beliefs often label religion as the
lead cause of war, it is the convolution of secular politics, which allows religion to guide
foreign policy that is far more dangerous.
That America seeks to spread democracy while it is itself a Republic belies the fact that
what America seeks to spread is not democracy per se, but secular government that
interprets support oflsrael as a religious mandate. This is can be observed in America's
involvement with the current Egyptian regime and it's banishment of the Muslim
Brotherhood from the political process. After a less than public visit by Michelle
Bachman and other U.S. lawmakers to General Sisi, the widely popular political party
was outlawed and a violent crackdown imposed upon anyone who identifies with the
Muslim Brotherhood. Democracy was outlawed, and a military dictatorship was
legitimized with the sole requirement, recognition of Israel, accepted in place of
Democracy, with mass executions for any who resist.
The same South Carolina legislature which has been so imbued with the higher ideals that
fill the articulate lectures of Professor Don Fowler is the same sole group of State
lawmakers that have the used taxpayer resources of a secular government to declare a
religious mandate to support the state of Israel based on subjective interpretations of the
Old Testament and passed a South Carolina Resolution outlining said interpretations as
though they had been revealed on atop Mt. Sinai, on the same stone tablets as the Ten
Commandments.
This resolution would be quaint, even expected in the Bible belt where conservative
fundamentalist Christianity drives political Zionism with as much messianic fever as the
very principles of Theodore Herzl himself Yet this is the gap between the knowing
subject and the object that is known.
As student of ancient philosophy and biblical texts, I know that word Zionism is an
invention of the 19th Century and that Libya, as well as Uganda, were examined by both
the British and the World Jewish Council as the British Jewish colonies.
I know that the idea of Zionism is one of Eastern European Communist roots for the
kibbutz's that formed the early settlement were definitive of many Marxist principles of
community ownership, and that, in and of itself, is but Plato speaking through Athenian
Jews who infused the Torah with mystic signs they interpreted all around them in
Alexandria and Cyrene. I have seen Punic-Libyan that would become Hebrew and that
Arabic and Hebrew share so many words that they are deviations of one another, not.
unlike the Jew and the Arab 1 Semitic genealogical deviations from the same father,
Abraham.
1 know in all likelihood that Plato himself came into knowledge in Alexandria, for his
final chapter of his most famous work, the Republic was at best inspired, and worst
stolen, from the works of Zoroaster he came into contact with there, in the ancient city
where Jews took up two of the five living quarters and the Ancient Rites of Alexander
were preserved.
lt is my belief that those in South Carolina, in all of America, who defend Zionism know
not what they defend and that has caused not only confusion in government, but has put
America's national security at risk and has destabilized the entire world in the process.
In 1983 Jon Han1ilton qeveloped the PROMIS software with a federal grant from the U.S.
Justice Department. The software was developed by Hamilton based on his previous
experience with the NSA in early voice recognition in Vietnam. This software forms the
basis for every surveillance tool that has been made since, for it's initial purpose of
tracking cases for the US Justice Department now functions in every variation of tracking
that is limited only by Moore's Law and the law of expanding networks.
The Israeli government stole this software through Rafi Eitan while he used the alias of
"Dr. Ore" to observe a product demonstration. What would follow is a case that has been
ignored and now haunts America like the ghost in the machine that it truly is. It is a case
of Israel stealing American technology and innovation through a backdoor which has
been built into every device, every sensor, whether it connects to the Internet or not. It
is a Trojan door that has played man in the middle in an ongoing denial of service attack.
It s is the distance between the knowing subject and the object that is known. This
software was built into every computer and every device that every country uses to track
every one of it's citizens, every one of it's customers, every one of it's voters, and
everyone of it's enemies.
I agree with Donald Fowler that technology is an amazing thing. It has indeed, changed
politics in fundamental ways. It was Bull Conner on TV screens in living rooms across
the country that gave injustice the exposure needed to stop it. Yet a gag order was placed
f
1
a boycott, against the exposure needed to stop the batons and the dogs still bite and strike
and segregate by race.
Not only does the state of Israel not have a constitution, it is a state that by its very nature
is based on racial supremacy, on racial exclusion, on colonial expansionist ideals that
have never fit within the realm of America foreign policy. If we are to be a secular
society, then surely we must recognize the highest law of the natural world, of the secular
world, is the law of self-preservation. By this we fool ourselves into submission by
failing to address weaknesses that are exploited in our ignorance. Such is the issue of
terrorism and cyber security, just as it was the U.S.S. Liberty.
The common factor between the destabilization of America and Li.bya is a man by the
name Ari Ben Menashe. A former Mossad agent, Ben Menashe played a significant role
in reengineering the PROMIS software with a hidden backdoor that could be used to
remotely monitor the software without detection. This software forms the core database
that has played a role in every major scandal and crime of the last 30 years from the
BCCJ bank scandal to the al Qaeda network to which this technology was sold.
This backdoor was sold to Libyan leader Muarnar Qaddafi in the form of surveillance
technologies that only reached the light of day during the 2011 Libyan Revolution.
Libya is the prism by which the Mysteries of both the Ancient and modern can be
dissected, through spectrum analysis as much as biblical archeology, for there are secrets
at both ends that become apparent.
Libya has always been a target for empire and the tools of empire, whether the first
concentration camps or the first aerial bomb. It was America's first enemy, whether the
~~~pectr.1.mu1f1errorism.w.as~efined.for..themass{;onsumptioffduringBarbarrWars~
Operation Prairie Fire, or constructed for CNN primetime via it's continuation into
Operation Odyssey Dawn.
In Libya, America was given it's first lesson in terrorism and the lesson plans have gone
from for Jeft secuJar revolutionary Marxist ideologies to the opposite end of the spectrum,
that of far right religious extremism in the form of al Qaeda. It was Qaddafi who issued
the first INTERPOL arrest warrant for Osama Bin Laden, the modem definition of
terrorism, and Gaddafi who first defined terrorism for America whether in Berlin, Rome,
London, or over Lockerbie, Scotland. It is Libya that continues to define terrorism as the
alleged new base for al Qaeda. All are simply lesson plans, nothing more, but only for
those who can read signs in the chaos and pick out signals from noise. The chaos today
in Libya is not anarchy, but orchestrated misery, and that orchestration is done at the
highest leve]s of American and Israeli government.
Ari Ben Menashe, this very minute, is working with a separatist movement in Eastern
Libya that is being used to construct a division in the county that is to be split along the
Syrtic divide, between East and West, between Roman Tripolitania and Greek Cyrenecia.
This movement, led by militia leader Ibrahim Jathran, has hired Ben Menashe to lobby
the American and Russian governments to compete both in recognition of the separatist
movement and exploitation of the oil, gas, and port facilities it controls in Eastern Libya.
This is at the same time that another Israeli citizen, former US Senator Joe Lieberman; is
under contract to Libyan politician Basit Jgtet to lobby the American government to
recognize and facilitate his power struggle in Tripoli. Igtet, in his New Plan for Libya
platform, alleges to be the only avenue by which to unite the country, i.e., keeping at bay
------~--------~-------- ------the-separ-ati~t-movementledby-Jathrarrand-lobbied-ro-the~rltlforbr.BenMenashe:---------- -----~--~~--~-----

The former Prime Minister, Ali Zeidan, was ousted after failing to prevent an
from the Eastern Libya, under the control of Jathran, from leaving Libya to be sold
black market.
Only in Israeli papers was it noted that when the U.S. intercepted this oil tanker after
Zeidan's failure to do so, that two Israeli nationals were arrested for their part in
orchestrating and facilitating the stolen oil to market, perhaps to Russian or Israeli
brokers. America is now set to occupy Libya at any moment due to unrest and chaos,
caused as Israel and America steer both sides of Libya, the East and West, into a
constructed war that America and Israel will profit from. Don Fowler must know that
nothing can be good and proper or good and done in Libya while Roger Tamraz works
with the separatist movement of Eastern Libya to market it's oil, while at the same time
working to bolster Basit Jget, his Swiss, Qatari, and Israeli connection in the West of
Libya. The Israelis are now using Roger Tamraz to destabilize Libya in the same manor
he committed war crimes of genocide in Lebanon, that is, a man in the middle, denial of
service attack that is, in fact, an Israeli trapdoor which plays both sides of every conflict
in a Talmudic divide and conquer strategy that now seeks to divide South Carolina for the
rule oflaw as it has Eastern & Western Libya, manipulating markets all the while.
These are the secrets seen only through the Libyan prism for they reveal a pattern of
constructed wars, whether in Iraq or Syria.
The connection between al Qaeda and Saddam Husain is rooted in a lie told by a Libyan
who was kidnapped and tortured in the process known as extraordinary rendition. This
man lied, invented stories, because it was what his torturers wanted to hear, and he later
...recanted~~Y~tthisfalse inteHigeneewasbroughtbeforetheUnitedNaticms~and usedlO

justify the war in Iraq that continues to this day. The Sinjar files found in Iraq cannot
isolated from the fact that Libyans make up the largest single number of foreign fighters
in Syria. America's "ghost flights" only became real when files were discovered in the
office of Libyan Intelligence Chief Musa Kusa. These files and the charges brought forth
based on evidence found in them now prevent many members of the CIA from stepping
foot in Europe for fear of immediate arrest for the kidnapping and torture of European
citizen!}.
The American media hides these facts to the extent that the chaos now unfolding in Libya
can be labeled the result of al Qaeda, when in fact it is a result of the same destructive
force by which America's Silicon Valley has transplanted to Tel Aviv, while the research
costs are born by America
It is through South Carolina that Israel is preparing for a constructed war and Libya is the
gateway through which it will be facilitated. Israel will exploit the Jewish heritage in
both South Carolina and Libya to pave way for this war that plans to pit Zionism against
Fascism and whose construction is fast underway in the Ukraine.
Charleston is the center for the upcoming Star Wars and the greatest threat that America
faces is not from Islam or terrorism but the Savannah River Site. There, in South
Carolina, is a catastrophe waiting to happen. The nuclear waste of an entire nation, spent
waste even from Libya, is now stored indefinitely at SRS. There is a geological fault line
that runs across the J-20 interstate, which is the lifeline to Charleston.
The most destructive earthquake ever recorded on the US Eastern Seaboard occurred
along this same fault line in 1897. There have been 2 earthquakes since the beginning of
2otit~-andiris very concei vaolethanhese were bunremors, wari11ngs1gns0Talarger~~~--

event to come. Columbia, SC is home the DHS SLED FUSION Center wbacii
threat is being ignored as Israeli technology is spread and embedded into every ll!ipm.li
life. America has lost all semblance of sovereignty as politicians at the lowest and IUf!!I'
levels of government are not accountable to citizens but to the two forces by which
American foreign policy is forged: the Israeli Lobby and the Military Industrial
Complex. These two forces make or break both candidates and elections and the
resulting governments are at the mercy of their earthly creators. Two factors work in
hiding this from the American voters: fear and the resulting hate. These are products of
a media that is but a representation of the public psyche. It is crafted for an audience that
is perceived of as nihilist at best and depraved at worst by invisible power structures
whose capitalism is, in fact, cloaked fascism, for the Invisible hand of the market is but
for pub1ic consumption. There is insider trading at unseen levels whereby a single group
can facilitate constant war to prevent the surplus of excess capital. Wars are not fought to
eliminate threats but to eliminate the surplus of capital that frees a population from toiling
away for the basic needs of life. The inconceivable tragedies preserved in the Talmud of
famine, exodus, and hardships are interpretations of the earliest of Jewish history and that
history was shaped and preserved in Libya in clay vessels which still sit beneath the sand.
The boycott against the Israeli boycott is a boycott of Judaic history that is denied and
perverted by the state ofisrael. The physical state oflsrael is an affront to God that
represents the fatalistic notion that God has failed, has turned his back on the Jews,
whether in the first Libyan Holocaust or the second European Holocaust, or in the failed
attempts of Libyan Zealots against the Roman Empire. Israel and the Talmudic
incantations that legitimize it have put themselves above God, against God, and therefore
unaccountable in playing God.
Populations are intentionally curbed in wars of sectarian, religious, and ethnic strife that
have been studied and enacted upon the world with entities such as the IMF and United
Nations whose true purpose is cloaked in semantics and sealed in classified evidence
which is locked behind the chambers of secret governments, embodied in the Club of
Rome. The optimal model for population control has not changed, as Al Gore simply
reprinted the same exact tlow chart from Limits to Growth that can only be compared to
the inspirational literature of Herbert Kahn in its clarity and call for action.
South Carolina and Libya have both become targets for Israeli expansion and it is the
spectrum between them that is hidden and denied by politicians and academics who have
yet to practice what they preach, must less teach. This is the burden of Libyan
rediscovery that represents a universal history whose truths can breach the divide
between the subject that knows and the object that is known.
~-
l!NIVEl\SITY
SCXJIHQ\ROUNA.

min1fmn
OF
Submitted on May 6, 2014 at 1Q:?():15~m l:DL
Type:
Urgency:
Normal
Incident Date: 2014-05-05

Incident Time: 4:30 pm
Reported by Incident Location: On campus other disturbing email
Name:
Title:
Email:
Phone:
Address:
Involved Parties
Sammi Addahoumi (01000732) addahoum@email.sc.edu (803) 237-6116

Male
* Description

see above
see above
see above

see above

I am not sure
\ 2J \ \
Sammi Addahoumi
POLI 362 'Fowfer
Libya: Spectrum of Rediscovery
04/20/2014
"The essence of academic freedom is the free exchange of diverse ideas and opinions. I
am in agreement with the Association of Public and Land-grant Universities that,
"Freedom of inquiry and expression are the foundational principles of [this] vital wort#
and free exchange of ideas is its lifeblood." F()r these reasons, I stand with colleagues -
throughout the country in strong opposition to a boycott of Israeli academic institution."
-Harris Pastides,
-President, the University of South Carolina
On AP.ril 17, 2014, the University of South Carolina welcomed acclaimed author and
scholar Katherine Hall Bates to speak in honor of Professor Donald Fowler and to mark
'
Professor Fowler's 501h year with the USC colleges of political science and mass
. .
communications, a career spann1ng half a century that began irf 1964.
By his own huble admission, Don Fowler has instructed at least half of South Carolina's
state legislators that now congregate under Columbia's State House dome. Very rare is
there to be found one man who has made so encompassing an impact inside the
classroom and out, as part of both th~ South Carolina and National Democratic Party, as
well as the patriarch of a family and communications firm who continue to shape local
ca~pus, state, and national dialogue. In her lecture, Kathrin Hall Bates examined how
two worlds, that of the media and that of the political, have been misrepresented in what
she identified as "The Assault on Fact in American Politics".
In honoring Professor Don Fowler for his academic nonpartisanship,,there is a gap that
can only be explored in relation to the statements of USC President Harris Pastides, for
any such assault on fact in American politics is undeniably rooted in the assault on fact in
-
States of America, USC has a responsibility, if not a mandate, to exemplify all tlmt is
noble in the pursuit of higher wisdom, a responsibility that has historic precedence and
which is now being undennined with unprecedented impunity.
At the University of South Carolina, there is a nearly irreducible divide between the
knowing subject and the object that is known. I believe that Libya is the prism by which
this gulf can be breached and what fol lows is an attempt to examine a universal history
whereby it may be possible to build a new understanding of the theories and models from
which we derive modalities of politics, academics, and the unifying factor, which divides
them, religion.
In his lectures, Professor Donald Fowler relays noble principles that are compromised by
the statements of USC president Harris Pastides as academic debate is curtailed. We will
examine how the statements of President Pastides betray noble principle of academic
freedom that is mandated in the Carolina Creed. Progran1s such as the Behavioral
Intervention Team (BIT) at USC are implemented at great cost and resource to twist
freedom of expression into classroom disturbances that stifle academic debate through
intimidation.
Professor Don Fowler is but one of many professors at USC whose impact inside the
classroom can be paralleled only by impacts made outside the classroom. 1will use my
own first hand research, from USC to Benghazi, Libya and juxtapose what is known and
can be proven as fact against what is offered at USC and we will find that the difference
is a matter not of religion or politics, but of American national security.
The Middle Eastern and lslam World Studies program at USC has been eliminated by
the Middle East and Islamic world

and ensures that what very little does reach the classroom, or evening news, has heal
filtered and scrubbed to be void of all reality.
This is despite a critical knowledge gap in all areas of study regarding the region, from
language to religion, to politics, and history. This silent, hidden, academic boycott of
Middle Eastern studies is in spite of an overwhelming demand expressed by students, the
policy continues in blatant disregard for basic academic freedoms of debate and equality
of ideas.
Specialists such as Waleed El-Ansary and the International Common Word project that
he brought to USC have been targeted and eliminated, as even guest speakers are banned
from delivering lectures that do not conform strictly within pro Zionist agendas. Agents
of Israeli Zionist propaganda outlets are sold to students as Middle Eastern experts in a
disturbing scenario whereby the classroom is used to make people dumber. This
handicaps generations of citizens who cannot make informed decisions nor interpret
current events in the world as they relate to their own lives with any meaningful
perspective.
Having taken part in the Arab Spring and having witnessed Arab Muslims march in
protest to demand and die for Democracy, l mentioned to Professor Leslie Wiser after his
very first very first lecture, centering on Samuel Huntington's Clash of Civilizations, that
the Arab world did, in fact, want to modernize and, did, in fact, want Democracy. I was
given quite the rebuttal: "I don't care if it is right", replied Professor Wiser, "I like what it
says". This coming from a terrorism expert who I had to enlighten regarding the
origins of Osama Bin Laden, as his class on terrorism was void on actual terrorism as it
relates to history or fact. It was a terrorism course that demonized Islam and Arabs in
every lesson while avoiding the American origins of the Saudi Terror netvvork that exits
until today, connecting Benghazi and Syria, securing his profession as a terrorism
analyst.
Another example lies in Professor Josef Olmert. Dr. JosefOlmert is a doctor in the same
sense that Dr. Saif al Islam Gaddafi is a doctor, that is, accredited by the discredited
London School of Economics, obtained through selling academic integrity. Dr. Olmert
has not even the most elementary understanding of Middle Eastern Politics, something
that his own brother makes known at every opportunity.
Dr. Olmert's brother, Ehud Olmert, served as both Mayor of Jerusalem and as Israeli
Prime Minister, yet now sits in an Israeli jail cell because of illegal bribes accepted by his
brother, Dr. Josef Olmert. In what became known as the Holy Land Corruption case, Dr.
Yosef, or "Yossi", Olmert was given envelopes stuffed with cash to influence his brother,
in his position as former Mayor of Jerusalem, regarding an illegal Israeli housing
development. Dr. Josef Olmert has published 3 books of racist Zionist literature that
serve to reinforce notions of racial superiority and religious discrimination. Dr. Olmert is
the circular error that can be found in statements of the USC president and those noble
principles relayed so ideally in the lecture delivered by Mrs. Kathrin Bates in honor of
Donald Fowler, as well as those so expertly articulated in the lectures delivered in the
classroom of Don Fowler himself.
I have not been to Afghanistan, nor have I been to Iraq. I do, however, spend my summer
months walking across Egypt, Tunisia, and most extensively, Libya. When not
backpacking, hitchhiking, or otherwise wandering around North Africa, I reside where I
~-~~-~~~~~~~---~~~~~as-born~ndtaised;eotumbia;Soutlrearolina~~lwasburn-wit~fooriITTlr~nrosque-~~~~~
~
and one foot in the church, as though conceived on some long lost platform that once ' :t.'!'\!
l~t./~f
straddled a divide across the Atlantic to Atlantis, from the beginning of history and the,'. :.::.1...j ~
r J,,;f", j;..-_,,..<~
111 1J./l~ ;.,
)f./~v ' 1 ~ju 1fl fjffJ.t
, II I,,7 _ s,~ ,<V'J
first man, to convoluted notions of the End of Ht story and the Last Man.
(} I). -""! .; !!-
,,- 0r" /. 1
I have seen tablets upon which the Alpha, the Tau, and the Omega, were reinterpreted ~.
into the Father, the Son, and the Holy Spirit, where Greek become Latin, yet for me these
were innovations, for I have slept in Garden of Hesperides, drank from the River Lenthe,
have swam in the lake where St. George did slay his Dragon, and have seen the signs of
God that became Judaism as stories of creation, flood, diaspora, and renewal have been
reinterpreted as Jew become Gentile and Jesus become Isa.
I know the true Shibboleth is but the mark of the Fascia, for I have walked from Carthage
to Alexandria and experienced the forgotten layers of history in between. I have lost
count how many times I have been to Rome, yet I remember so well the Africa in which
St. Mark was John Mark and where he took refuge from the persecution of the Romans
are hills and mountains whose cisterns still rise and fall with the Libyan Wadis. I have
slept in Wadi Marcus and seen his captors in the Arch of Marcus Arelius as I came to
learn the African memory of St. Mark.
I have camped at the Pillars of Hercules upon the Syrtic Divide and know that there is no
Clash of Civilizations for I slept quite soundly where East and West meet North and
South at the Gulf of Sidra, the center of the Ancient World.
From the Oracle of Siwa to Peachtree Rock, I have seen the seashells and the wild figs
that share wavelengths on a hidden spectrum and I have plucked both from the earth like
truth that that is to be revealed through the Libyan Sibyl, the Libyan prism.
I agree with Don Fowler that Politics are the most pervasive aspect of any society and
that there are no aspects of life which are not effected by politics, more so than even
religion, to the extent that the Bell curve of the American political spectrum can relegate
no less than half of the population to having no worth what so ever, in ways that wars or
religions never have. While Western secular systems of beliefs often label religion as the
lead cause of war, it is the convolution of secular politics, which allows religion to guide
foreign policy that is far more dangerous.
That America seeks to spread democracy while it is itself a Republic belies the fact that
what America seeks to spread is not democracy per se, but secular government that
interprets support ofisrael as a religious mandate. This is can be observed in America's
involvement with the current Egyptian regime and it's banishment of the Muslim
Brotherhood from the political process. After a- less than public visit by Michelle
Baclunan and other U.S. lawmakers to General Sisi, the widely popular political party
was outlawed and a violent crackdown imposed upon anyone who identifies with the
Muslim Brotherhood. Democracy was outlawed, and a military dictatorship was
legitimized with the sole requirement, recognition of Israel, accepted in place of
Democracy, with mass executions for any who resist.
The same South Carolina legislature which has been so imbued with the higher ideals that
fill the articulate lectures of Professor Don Fowler is the same sole group of State
lawmakers that have the used taxpayer resources of a secular government to declare a
religious mandate to support the state of Israel based on subjective interpretations of the
Old Testament and passed a South Carolina Resolution outlining said interpretations as
though they had been revealed on atop Mt. Sinai, on the same stone tablets as the Ten
Commandments.
This resolution would be quaint, even expected in the Bible belt where conservative
fundamentalist Christianity drives political Zionism with as much messianic fever as the
very principles of Theodore Herzl himself Yet this is the gap between the knowing
subject and the object that is known.
As student of ancient philosophy and biblical texts, I know that word Zionism is an
invention of the 19th Century and that Libya, as well as Uganda, were examined by both
the British and the World Jewish Council as the British Jewish colonies.
I know that the idea of Zionism is one of Eastern European Communist roots for the
kibbutz's that formed the early settlement were definitive of many Marxist principles of
community ownership, and that, in and of itself, is but Plato speaking through Athenian
Jews who infused the Torah with mystic signs they interpreted all around them in
Alexandria and Cyrene. I have seen Punic-Libyan that would become Hebrew and that
Arabic and Hebrew share so many words that they are deviations of one another, not
unlike the Jew and the Arab, Semitic genealogical deviations from the same father,
Abraham.
J know in all likelihood that Plato himself came into knowledge in Alexandria, for his
final chapter of his most famous work, the Republic was at best inspired, and worst
stolen, from the works of Zoroaster he came into contact with there, in the ancient city
where Jews took up two of the five living quarters and the Ancient Rites of Alexander
were preserved.
lt is my belief that those in South Carolina, in all of America, who defend Zionism know
not what they defend and that has caused not only confusion in government, but has put
America's national security at risk and has destabilized the entire world in the process.
In 1983 Jon Hamilton qeveloped the PROMIS software with a federal grant from the U.S.
Justice Department. The software was developed by Hamilton based on his previous
experience with the NSA in early voice recognition in Vietnam. This software forms the
basis for every surveillance tool that has been made since, for it's initial purpose of
tracking cases for the US Justice Department now functions in every variation of tracking
that is limited only by Moore's Law and the law of expanding networks.
The Israeli government stole this software through Rafi Eitan while he used the alias of
"Dr. Ore" to observe a product demonstration. What would follow is a case that has been
ignored and now haunts America like the ghost in the machine that it truly is. It is a case
of Israel stealing American technology and innovation through a backdoor which has
been built into every device, every sensor, whether it connects to the Internet or not. It
is a Trojan door that has played man in the middle in an ongoing denial of service attack.
It s is the distance between the knowing subject and the object that is known. This
software was built into every comput~r and every device that every country uses to track
every one of it's citizens, every one of it's customers, every one of it's voters, and
everyone of it's enemies.
I agree with Donald Fowler that technology is an amazing thing. It has indeed, changed
politics in fundamental ways. It was Bull Conner on TV screens in living rooms across
the country that gave injustice the exposure needed to stop it. Yet a gag order was placed
f
/
/
a boycott, against the exposure needed to stop the batons and the dogs still bite and strike
and segregate by race.
Not only does the state of Israel not have a constitution, it is a state that by its very nature
is based on racial supremacy, on racial exclusion, on colonial expansionist ideals that
have never fit within the realm of America foreign policy. If we are to be a secular
society, then surely we must recognize the highest law of the natural world, of the secular
world, is the law of self-preservation. By this we fool ourselves into submission by
failing to address weaknesses that are exploited in our ignorance. Such is the issue of
terrorism and cyber security, just as it was the U.S.S. Liberty.
.
The common factor between the destabilization of America and Libya is a man by the
name Ari Ben Menashe. A former Mossad agent, Ben Menashe played a significant role
in reengineering the PROMIS software with a hidden backdoor that could be used to
remotely monitor the software without detection. This software forms the core database
that has played a role in every major scandal and crime of the last 30 years from the
BCCJ bank scandal to the al Qaeda network to which this technology was sold.
This backdoor was sold to Libyan leader Muamar Gaddafi in the fonn of surveillance
technologies that only reached the light of day during the 2011 Libyan Revolution.
Libya is the prism by which the Mysteries of both the Ancient and modern can be
dissected, through spectrum analysis as much as biblical archeology, for there are secrets
at both ends that become apparent.
Libya has always been a target for empire and the tools of empire, whether the first
concentration camps or the first aerial bomb. It was America's first enemy, whether the
,SJ1e_c.trum.0Jterrorism.was.definedJor:.tbe.massc0Rsumptionduring-Barbary-Wars,
Operation Prairie Fire, or constructed for CNN primetime via it's continuation into
Operation Odyssey Dawn.
In Libya, America was given it's first lesson in terrorism and the lesson plans have gone
from far left secular revolutionary Marxist ideologies to the opposite end of the spectrum,
that of far right religious extremism in the form of al Qaeda. It was Gaddafi who issued
the first lNTERPOL arrest warrant for Osama Bin Laden, the modem definition of
terrorism, and Gaddafi who first defined terrorism for America whether in Berlin, Rome,
London, or over Lockerbie, Scotland. It is Libya that continues to define terrorism as the
alleged new base for al Qaeda. All are simply lesson plans, nothing more, but only for
those who can read signs in the chaos and pick out signals from noise. The chaos today
in Libya is not anarchy, but orchestrated misery, and that orchestration is done at the
highest levels of American and Israeli government.
Ari Ben Menashe, this very minute, is working with a separatist movement in Eastern
Libya that is being used to construct a division in the county that is to be split along the
Syrtic divide, between East and West, between Roman Tripolitania and Greek Cyrenecia.
This movement, led by militia leader Ibrahim Jathran, has hired Ben Menashe to lobby
the American and Russian governments to compete both in recognition of the separatist
movement and exploitation of the oil, gas, and port facilities it controls in Eastern Libya.
This is at the same time that another Israeli citizen, former US Senator Joe Lieberman; is
under contract to Libyan politician Basit Igtet to lobby the American government to
recognize and facilitate his power struggle in Tripoli. Igtet, in his New Plan for Libya
platform, alleges to be the only avenue by which to unite the country, i.e., keeping at bay
~~~~---~--the-separ.at.i.st-meement-ledl:>y..J.athran..and.~Qbbied.t~.the-wotl.d-for~-Ben-Menasher-~-~---~---~-------
The former Prime Minister, Ali Zeidan, was ousted after failing to prevent an
from the Eastern Libya, under the control of Jathran, from leaving Libya to be sold
black market.
Only in Israeli papers was it noted that when the U.S. intercepted this oil tanker after
Zeidan' s failure to do so, that two Israeli nationals were arrested for their part in
orchestrating and facilitating the stolen oil to market, perhaps to Russian or Israeli
brokers. America is now set to occupy Libya at any moment due to unrest and chaos,
caused as Israel and America steer both sides of Libya, the East and West, into a
constructed war that America and Israel will profit from. Don Fowler must know that
nothing can be good and proper or good and done in Libya while Roger Tamraz works
with the separatist movement of Eastern Libya to market it's oil, while at the same time
working to bolster Basit Jget, his Swiss, Qatari, and Israeli connection in the West of
Libya. The Israelis are now using Roger Tamraz to destabilize Libya in the same manor
he committed war crimes of genocide in Lebanon, that is, a man in the middle, denial of
service attack that is, in fact, an Israeli trapdoor which plays both sides of every conflict
in a Talmudic divide and conquer strategy that now seeks to divide South Carolina for the
rule of law as it has Eastern & Western Libya, manipulating markets all the while.
These are the secrets seen only through the Libyan prism for they reveal a pattern of
constructed wars, whether in Iraq or Syria.
The connection between al Qaeda and Saddam Husain is rooted in a lie told by a Libyan
who was kidnapped and tortured in the process known as extraordinary rendition. This
man lied, invented stories, because it was what his torturers wanted to hear, and he Jater
... .recanted... Yetthis.false.intel.Ugencewas braughtbefore theHnitedNation~arrdusedTo

justify the war in Iraq that continues to this day. The Sinjar files found in Iraq cannot
isolated from the fact that Libyans make up the largest single number of foreign fighta-s
in Syria. America's "ghost flights" only became rea] when files were discovered in the
office of Libyan Intelligence Chief Musa Kusa. These files and the charges brought forth
based on evidence found in them now prevent many members of the CIA from stepping
foot in Europe for fear of immediate arrest for the kidnapping and torture of European
citizens.
The American media hides these facts to the extent that the chaos now unfolding in Libya
can be labeled the result of al Qaeda, when in fact it is a result of the same destructive
force by which America's Silicon Valley has transplanted to Tel Aviv, while the research
costs are born by America
It is through South Carolina that Israel is preparing for a constructed war and Libya is the
gateway through which it will be facilitated. Israel will exploit the Jewish heritage in
both South Carolina and Libya to pave way for this war that plans to pit Zionism against
Fascism and whose construction is fast underway in the Ukraine.
Charleston is the center for the upcoming Star Wars and the greatest threat that America
faces is not from Islam or terrorism but the Savannah River Site. There, in South
Carolina, is a catastrophe waiting to happen. The nuclear waste of an entire nation, spent
waste even from Libya, is now stored indefinitely at SRS. There is a geological fault line
that runs across the I-20 interstate, which is the lifeline to Charleston.
The most destructive earthquake ever recorded on the US Eastern Seaboard occurred
along this same fault line in 1897. There have been 2 earthquakes since the beginning of
--~~~~-~-----~-~~~~~~"2()t4~anditts-very-con1:'eiva:ble~thatthese-were-buttremurs;-wamirrg-sigrrsufa-1arger-~ --~~-----------~~---~
event to come. Columbia, SC is home the DHS SLED FUSION Center Ulh-'iiilliiilllll
threat is being ignored as Israeli technology is spread and embedded into every asped1111f
life. America has lost all semblance of sovereignty as politicians at the lowest and IDl!ll
levels of government are not accountable to citizens but to the two forces by which
American foreign policy is forged: the Israeli Lobby and the Military Industrial
Complex. These two forces make or break both candidates and elections and the
resulting governments are at the mercy of their earthly creators. Two factors work in
hiding this from the American voters: fear and the resulting hate. These are products of
a media that is but a representation of the public psyche. It is crafted for an audience that
is perceived of as nihilist at best and depraved at worst by invisible power structures
whose capitalism is, in fact, cloaked fascism, for the Invisible hand of the market is but
for pubJic consumption. There is insider trading at unseen levels whereby a single group
can facilitate constant war to prevent the surplus of excess capital. Wars are not fought to
eliminate threats but to eliminate the surplus of capital that frees a population from toiling
away for the basic needs of life. The inconceivable tragedies preserved in the Talmud of
famine, exodus, and hardships are interpretations of the earliest of Jewish history and that
history was shaped and preserved in Libya in clay vessels which still sit beneath the sand.
The boycott against the Israeli boycott is a boycott of Judaic history that is denied and
perverted by the state oflsrael. The physical state oflsrael is an affront to God that
represents the fatalistic notion that God has failed, has turned his back on the Jews,
whether in the first Libyan Holocaust or the second European Holocaust, or in the failed
attempts of Libyan Zealots against the Roman Empire. Israel and the Talmudic
incantations that legitimize it have put themselves above God, against God, and therefore
unaccountable in playing God.
Populations are intentionally curbed in wars of sectarian, religious, and ethnic strife that
have been studied and enacted upon the world with entities such as the IMF and United
Nations whose true purpose is cloaked in semantics and sealed in classified evidence
which is locked behind the chambers of secret governments, embodied in the Club of
Rome. The optimal model for population control has not changed, as Al Gore simply
reprinted the same exact tlow chart from Limits to Growth that can only be compared to
the inspirational literature of Herbert Kahn in its clarity and call for action.
South Carolina and Libya have both become targets for Israeli expansion and it is the
spectrum between them that is hidden and denied by politicians and academics who have
yet to practice what they preach, must less teach. This is the burden of Libyan
rediscovery that represents a universal history whose truths can breach the divide
between the subject that knows and the object that is known.
EXHIBITT
8/2/2017
Behavioral Intervention Team

BIT Chair
Creating an Environment of Calm and Directed Leadership
Note: Dangerousness and violence from a student, faculty,

or staff member is difficult, if not impossible, to accurately
predict. This training topic offers research based techniques
and theories to provide a foundational understanding
and improved awareness of the potential risk. The training
or tool should not be seen as a guarantee or offer any
assurance that violence will be prevented.
2016, The NCH ERM Group, LLC, All rights reserved,
1
8/2/2017
What is Behavior Intervention
Behavior Intervention is:
~ NOT Crises Response/Management.

~ NOT Threat Assessment.
~ A professional structured approach to address a

Person of Concern (POC} by deescalating harmful
behaviors.
!\:> 2016, The NCHERM Group, LLC. All rights reserved.
2
8/2/2017
"This is highly confidently, so, yes, we built a little fort"
llDDll 2016. The NCHERM Group, LLC. All rights reserved.
What is Behavior Intervention
2016, The NCHERM Group, LLC. All rights reserved.
3
8/2/2017
Team Composition
I Team Membership (2014 data):
Counseling 92%+ Human Resources 29%+

Police/Campus Safety 88%+ Student Activities 21%
Dean of Students 75%+ Case Manager 20%
Residential Life 59% Legal Counsel 17%
Academic Affairs 53%+ Athletics 13%
Health Services 40% Admissions 8%
VP Student Affairs 40% Greek Life 4%
Faculty 30%+
lllDll1 2016, The NCH ERM Group, LLC. All rights reserved,
Team Leadership
Team Leadership (2014 data):

Dean of Students 44% Counseling 6%
VPSA 24% Police/Safety 3%
Student Conduct 9% Other/Misc 14%
Leadership Qualities:
> Charismatic.
> Power to enforce policy and make change.
> Can build coalitions and trust.
> Focus on training and larger issues for team.
2016, The NCHERM Group, LLC. All rights reserved.
4
8/2/2017
What Tools are Available?

Mandated Assessment Tests
The Minnesota Multlphask:PersonalltyTest
TheBetkDepresslonlnventory
TheBeckAn:detylnventory
The Firestone Assessment of Violent Thoughts
SIVR8
The Strummed lntl!rview for Violenu Risk Aueunumt
VIOLENCE RISK
ASSESSMENT
!SIVRA-35)isathirty-~4teminventortd~grn.d OF THE WRIITEN
b~ Bri;in Van8funt, Ed.O,, thit is used to<1Hlst lleh;iviaral
WORD
lnMrvention Tummem~nandclinlti!stioffln
conducting;imonthoroughandrese1rch-~s'!'dviolence
riskaHes5fllent.~SIVRA-35isdlffignedmuslstwlth
individualsidentifiedas~~ited,severe,ore..tr1>mer!sk
bytheNaBfTAThrHIAsSfl$1Tle1TtTooloruslngsimll:u
methodologies.
http://nablta.org/resourcll$/threat-auessmenMools/ Other Tools/ Information
Sources
AcademlcTranscrlpts
Application
FlnandalAidTranscrJpts
currentbl!I
Social Medla
Humanlntelllgence:talktopeop[e
D2T

Class Attendance& Current Grades
PolkeReports
11111111 2016, The NCHERM Group, LLC, All rights reserved.
OVERALL& HARM TO OTHERS

ll!MTAL & BEHAVIORAL HEALTH, OENERAUZell RISK RUBRIC NIHE LEVElS OI' HOSTILtlY ANO
"THE D-8CALf" vtOl.EllCE
..
DYSREGULATIONIDECOllPENSATIDN
A l"f-1t""!J"'rnl!uhvg11~1~.9"1:tultu
A """"'
~~~"'w-~u,..-
NaBITA A Ofrfiumttnill-i&tll4teg..i.teemil"..w:n,
togrut""\lrif,beil-1'"4t~ij
4 l''Qf~diu:"n-l,:ltl.ciM-<>1-t.tF
Threat .. =~::::,:::;;KI,_,,,....,.,
A Atrnilof9"'1,._1"fo''l'O'd~w11.~mtmt
Assessment :tdMw1rm
... 0ttl'l'!ffff'111;1l'(til&tltll<l!lh
Tool DISTURBANCE
S..t.iit-..rn.........,-~~~lfm<>d"''""""
*"7.atttm~IO<!W<r---Pkl:m:m

~"'#f""""'<dtt-.n,..,.~tlUU.r*""""'~do<
t<wmlth~uoiflrnx;u!M:C'
..
........
tTRAJKfaltTI
10
5
8/2/2017
NaBITA OVERAU& HARM TO OTHERS

Threat Assessment GENERALIZED RISK RUBRIC NINE LEVELS OF HOSTIUTY AND
VIOlEllCE
Tool
OYSREGULATIONIDECOllPENSA.TION
.&. M11WfW!!.llla:J~~9$.t:"I?~
.. _,,_.~-i
4 tt...u..,~._..,rriM...,.,,,ilt~!lri,...,..,
A Oef;otlrtmstiili<U.at~~~~
:ogrr,11111<\Wl'.!Nh-!"id~<Pt
4,,..,fa.....i1te~.itahff-..m .... mr
4 ~tll~lttr~wot.U!~<"'1ftv-tf
pt<ltect~
11~ ... .,,.~,.i,,..i...,,~ .. ,~,,,.,;.,,,

_ , .. ~IU?>'llUUH
..........
llDDll Cl 2016, The NCH ERM Group, LLC. All rights reserved. 11
6
8/2/2017
lllDlll 13
The Process
Coaching for the BIT Chair
The BIT Chair can be a daunting seat. There are many moving parts related to an
active BIT case, most of which are very dynamic in nature.
Effective Team leaders must have a working knowledge of data collection,

investigations, assessments tools such as the NaBITA Threat Assessment Tool
the SIVRA-35, VRAW2 , and an understanding of related mental health tests
and their results.
While the BIT Chair is responsible for ensuring that many tasks are completed,
they are not responsible for performing each.
In addition, the Chair must possess the skills necessary to conduct an

outcome based BIT meeting.
14
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8/2/2017
The Process
Coaching for the BIT Chair - Defining the Problem
The BIT Chair Responsibilities:
Receives reports,
Sets the agenda,
Coordinates the gathered data,
Conducts interviews,
Performs assessments,
Presents the information to the Team,
Makes determinations,
Issues directives,
Administers the Case Management Program,
Trains the Team, and
Produces the Annual Report.
WAIT A MINUTE!
llDDl1 15
The Process
1. Default to a one person show and simply inform the Team at
meetings
11" F04AY."t' MA'!"PI!.~ ... I C~1' I\ ~........

AW'P ,_,.a'Bcitrf C.A;.45. /
16
8
8/2/2017
The Process
Coaching for the BIT Chair- Defining the Problem
meetings
2. Have difficulty managing the process flow of a case or a meeting as a
whole,
rm just saying - can't be at a crossroads

and in uncharted t:enltoly.N
t '-~~'' ~-----~---~------'""'' ___ , ~--- __ ~-- ''''''~~~~ ,,n,, ~~ , "'~ ,,,_, ~-----~J
1111111 17
The Process
meetings
2. Have difficulty managing the process flow of a case or a meeting as a
whole,
3. Become overwhelmed with BIT on top of other responsibilities.
"S~ 'I"' - to. 44AI ~.

to. euu ii~~." Bill Newman
18
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8/2/2017
The Process
Coaching for the BIT Chair - Head Coach
What Good Coaches Do
1. Understand the Game

Mass Shootings at Virginia Tech: Report of the Review Panel: This is the official findings of the review
panel from August 2007 http://www.schoolshooters.info/PL/Qfficial Reports.html
Drysdale, D., Modzelenski, W., & Simions, A. (2010). Campus attacks: Targeted violence affecting
institutions of higher education. U.S. Secrete Service, U.S. Department of Homeland Security, Office of
Safe and Drug-Free Schools, U.S. Department of Education, and Federal Bureau of Investigation, U.S.
Department of Justice. Washington, D.C., 2010.
IHDlll 19
The Process
panel from August 2007 http://www.schoolshooters.info/PL/Official Reports.html
Drysdale, D., Modzelenski, W., & Simions,A. (2010). Campus attacks: Targeted violence affecting
Preventing the Preventable, NaBITA's 2011 Whitepaper
20
10
8/2/2017
The Process
panel from August 2007 http://www.schoolshooters.info/PUOfficial Reoorts.html
Drysdale, D., Modzelenski, W., & Simians, A. (2010). Campus attacks: Targeted violence affecting
Preventing the Preventable, NaBITA's 2011 Whitepaper
Attend a NaBITA, BIT Best Practices Certification Course
Join other professional associations such as: ATAP & ASCA
Subscribe to newsletters and periodicals such as:

Campus Legal Advisor,
Student Affairs Today, and
Fr~SCA
Higher Education Law in America (Center for Education & Employment Law)
Attend:
The ASCA Donald D. Gehring Academy for Student Conduct Administration
BllDll1 National Conference for Law and Higher Education, Stetson University.
21
The Process
2. Hire an Assistant Coach

Assistant BIT Chair (not a co-chair)
Establish the meeting agenda
Conduct interviews and brief BIT
Has full edit rights in reports

The best way to get someone to come to
Runs the BIT meeting in the absence of the a party is give them something to bring.
Chair and has the authority to call an
emergency meeting
Members of the BIT should have a reason
to be at the meeting.
11
8/2/2017
The Process
3. Recruit Good Players

Dean of Students
Chief of Police
Director for Residence Life

Your players must have policy and practice
Case Manager
experience in their respective areas and have
Director of the Counseling Center the authority to take independent action.
Academic Dean
Human Resources Director
lllDJll 23
The Process
4. Teach the Game

Review Case Studies & Current Events
Instruct team members on how to use assessment

tools
Utilize webinars and video training
Encourage attendance at regional and national

conferences Yes Bob, I must agree that you certainly did rock that
analysis of The Firestone Assessment of Violent 17wugllfs.
Empower Team members to bring their expertise to
the table
24
12
8/2/2017
The Process
2. Hire an Assistant Coach "I skate to where the puck is going to be,
3. Recruit Good Players not where it has been."
Wayne Gretzky
4. Teach the Game
5. Manage the Game
Keep the Team on task and on the agenda, your time is limited if you have the right people at the table
Look for opportunities to bring a Team member to the front
Sort through the hype; understand that emotions are in the room but don't let emotions run the room
Ask probing questions I review similar cases
Encourage alternative scenarios (what it's)
Understand - Leaders look away from the balll
lllDJll 25
The Process
4. Teach the Game
5. Manage the Game
6. Post-Game Review
Grab an old case and bring it back to the table with fresh eyes
and greater experience.
"It's like deja-vu, all over again."

Yogi Berra
13
8/2/2017
The Process
Coaching for the BIT Chair - The Traffic Cop
27
2016, Shadow Horse Counseling & Consulting, LLC. All rights reserved,
14
8/2/2017
The Process
Coaching for the BIT Chair - The Traffic Cop
The BIT Chair Responsibilities:

Receives reports Administers The NaBITA Threat Assessment Tool
Sets the agenda Trains the Team and Campus
Coordinates the gathered data SIVRA-35 I VRAW2
Conducts interviews Administers mental health testing
Performs assessments Directs Actionable Case Flow Charts
Presents the information to the Team Data entry
Makes determinations Keeping up with current law
Issues directives Editing documents and mani
Administers the Case Management
Program ~~~~~~~~~~~~~~~~..Jlllo
Trains the Team AS

the BIT Chair. I had to say:
Produces the Annual Report .___".S_T_~o_P_!_T_h_i_s_is_w_h_a.;...t.;...l_w_i_ll_t_o_d_o_.
"""""--'
BHJDl1 29
The Process
CASE STUDY #1
A reports comes to your attention:
1. How did it arrive?
2. Status of the reporter? (Faculty, Student, Staff, other)
3. Status of the person of concern?
4. Cursory look with the NaBITA Threat Assessment Tool
a) Harm to Self?
b) Harm to Others?
c) Neither?
5. Start directing traffic
30
15
8/2/2017
Incident Reporting Form
Submitted on September 16, 20XX at 12:51:06 Type: Non-Academic Misconduct

Urgency: normal Incident Date: 20XX-09-16
Incident Time: 12:51 pm Incident Location: internet
Reported by
Name: Suzie Scott Title: President of KLS
Email: scott_suzie@gmail.com
Reasons for Report

CSU Creed Violation, Disorderly Conduct, Harassment
Involved persons
Becky Simpleton Alleged Female
Suzie Scott Victim Female
Incident description
On Tuesday, September 16th, 20XX at 12:51 pm, Suzie Scott received an email notification from
twitter stating that Becky Simpleton requested to follow her. Becky Simpleton has been notified
previously and in writing that she is not to contact Suzie Scott at all even via social media.
Ms. Simpleton has had a previous BIT report filled out about her for harassment of Ms. Scott that
has occurred for over a year. There were also meetings with both parties and the perimeters were
defined.
Ms. Simpleton has broken these rules and therefore is committing "Disorderly Conduct with failure
to comply with University personnel"
31
NaBITA THREAT ASSESSMENT TOOL
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----
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32
16
8/2/2017
2016, Shadow Horse Counseling & Consulting, LLC. All rights reserved,
The Process
CASE STUDY #2
A reports comes to your attention:
1. How did it arrive?
2. Status of the reporter? (Faculty, Student, Staff, other)
3. Status of the person of concern?
4. Cursory look with the NaBITA Threat Assessment Tool
a) Harm to Self?
b) Harm to Others?
c) Neither?
5. Start directing traffic
34
17
8/2/2017
Incident Reporting Form
Submitted on November 21, 20XX at 9:52:06 am EST Type: Academic Misconduct

Urgency: Critical Incident Date:
20XX-11-20
Incident Time: 3:00 pm Incident
Location: internet
Reported by
Na'me: Jim Bob Smith Title:
Professor
Email: smithjimbob@gmail.com
Reasons for Report

Academic Integrity, Aggressive Behavior, Concern with Statements Made, Concern with Written
Material, Drastic Change in Behavior, Suspicious Behavior, Uneasy feeling, General Wellness
Concern, Harassment, Falsification of University Records or Giving False Statements
Involved persons
Debbie Johnson (909XXXXXXX) Victim Female
William Swanson (909XXXXXXX) Alleged Male
I called Dean Brown this morning to discuss a FaceBook page found by a member of our
Science Club at the URL: https://www.facebook.com/scienceclub
Mr. William Swanson claims to be a Catholic Bishop on sabbatical, an ex-CIA agent, a convicted
felon, a therapist, social worker, an airplane pilot who flies over faculty houses, and the list goes
on ...
He created a FaceBook page for the so-called: Behavioral Anthropology and Social Psychology
program, with its own improvised University logo. Debbie Johnson and I were unaware of this
until this week he attempted to "Like" our Science Club FB page. He was immediately blocked by
a student administrator. Attached is a zip archive with screen shots.
Please note the following:
The "About" section states that the page is affiliated with the University and both
this his remarks that accompany posted news items misrepresent the fields of
archaeology. It misrepresents what we do in anthropology at the University and
exhibits a profound misunderstanding of the discipline;
In the "Like" Section, he has "Liked" the Society for American Archaeology, the
American Anthropological Association, Prinston University (my alma mater), and a
range of other academic societies and therefore has widely propagated this
misrepresentation.
Among his posted Images are photos of an archaeological field excavation directed
by Ms. Johnson for which he has no permission to post; Other images infringe on
intellectual property as they include bone specimens presently under analysis and
not-yet published by Ms. Johnson and her student research assistants;
Scrolling down the FB page, on the left side is a YouTube "tutorial" (?) on "How to
Conduct a Basic Archaeological Survey" that he presents on a blackboard. Worse,
he does not understand archaeological survey.
Because: 1) he has already received a BIT warning yet he persists in these kinds of
inappropriate behavior, and
2) he has described his "CIA-training" which presupposes familiarity with firearms, I
am concerned for the safety of all students interacting with the program.
Please give this matter your prompt attention.
18
8/2/2017
2016, Shadow Horse Counseling & Consulting, LLC. All rights reserved.
Na81TA THREAT ASSESSMENT TOOL
______
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___
.........,._...,..,.,
-
#--.___.---.
----
,, ...... ..
. __ __ _
"'*-_
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.
38
19
8/2/2017
Book signing and lecture idea.
William Swanson Fri, Nov 19, 2013 at 2:27 AM
To: Dean of Students
Hi Dean, I was wondering if it was possible to schedule some time and space this Fall to conduct a
book signing and lecture on the book's subject matter (the complimentary nature of Science and
Religion). If it is, who would I contact to do that? I already have flyers and such made by the publisher
and the publisher will be assisting me with press releases and advertising the event.
I just need a place and I thought campus would be great.
Also, I have books coming and want to give you a signed copy. Is that OK?
Thanks
William Swanson Author of:
XXXXXX: XXXXXXXXX(2013)
xxxxxxx xxx xxxx xxxxx (2011)
Aaron Reese Fri, Jul 19, 2013 at 12:32 PM
To: William Swanson
I would appreciate a copy, thank you. Let me look into your question - I'll get back with you.
Dr. XXX XXXXX

Dean of Students
XXXXXXX State
Mon, Nov 23, 2013 at 5:59 PM
To: William Swanson
William,
This is my first request from a student to do a book signing, etc. so I had to do some research. All such
student requests should go through Mr. Smith. He is the University liaison for our campus bookstore
(which is a 3rd party outsource). They will make any decisions and arrangements.
Again, congratulations on being published again.

Dean Brown
On Fri, Jul 23, 2013 at 2:27 AM, William Swanson wrote:
To: Dean of Students
Yay! Thank you so much Dean.
Also, ref earlier situation. I have decided to seek some therapy from the VA. It is free for me there, too.
The Th. there believes that I may be hypersensitive due to PTSD manifesting as a result of the shooting
of my partner and several other cases before and after that. That has been very enlightening to me.
Makes me a lot more conscious of what I am actually perceiving vs. what is truly being communicated.
I had no idea that the mere mention of a stimulus would elicit a response.
I don! know what I would do without your help, though. It was your suggestion that led me there.
20
8/2/2017
Mon, Nov 24, 2013 at 6:20 PM
To: William Swanson
William,
Good deal. .
I wish all the best. It sounds like things are moving in the right direction.
Dr. Brown
Dean of Students
XXXXXXX State
41
21
8/2/2017
Teta1 &con: 1ano ~ ..

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lC 2016, Shadow Horse Counseling & Consulting, LLC. All rights reserved.
22
8/2/2017
case Resolution fom1
WiUwn Swanson 909- 1973-04-3!> Affeged

Name J.O. Number DOB Role
J, Incident Infomiatlon
20"-11-20 3.00pm Ottlef
Incident Date Incident Timt- lnodent L.ocanon
II. Hearing Type ~e:!lrtg/Resolutlon Hearing Offker(s)
""""'"""""'""""'
111. Charge{s) / bsue(s) Finding
l.fals!ficabaoofUmverstyRecOf'C!s/fal:seStal!ments NIA
2. Olsauerty Conduct NIA
3. Harassment NfA
4. Harassment NIA
ParentaJ/Guarrllan Notlflcatlom No
IV. sanctions/ Actions

A Dean of students Hot! IStntemanonthestuaenrsrec.on::tmtM suctltlrrle'flesupplteSalOeeded
educatlDnal transcnpts and mmpletes the necessary readmiS$IOO process Tntte iS no speell'ic
expirabondate.
v. Additional sanctions/stipulations
VI. Rationale 45
k. per-BITdisaJsslon, lhestudent hasnolS\WledaloFthenecessaryan:lmlsmglransaiptStrom
previ:>ustyattended cdlegesandootversitleswhlcharereqwred by COiumbus state Thelasl:aciMtyinhiS Ille
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11
46
23
8/2/2017
Behavioral Intervention Team

BIT Chair
24
~ .
EXHIBITU
Gtt~e 20\3~1so\
Safi Khan
Latin 110
Michael Dodd
The End of Combat
There was fighting for many hours and several gladiators were being killed.
His brother Marcus and other Romans were also walking home was leading Lucius
home. In the middle of the arena, slaves were doing much. The arena, filed with
blood and bodies was being cleaned and the bodies of the animals was being hauled
away to a place where the bodies were being cute and the meat was given to the
people.
Here, very much blood was being covered by new band. Lighter wounds of
the other gladiators were being cared for on the same but others who had greater
wounds were being carried to the doctor. Dead gladiators were being carried by the
slaves to the trained who to bury them.
In other location, Probus and Astacius were talking about the fights. Probus
is German and Astacius is Umbricus. "Today, we are lucky Probus. We swore and
other to be burned, to be bound, to be battered, to be kiJled with a sword-
nevertheless we live."
"Yes, you spoke correctly," said Probus. "We fought well and without serious
injury. But the other unlucky ones also fought well and now are dead." While they
speak much, they watch those dead who were being slowly carried away by the
servants to the wagon. Among those dead, a small corpse of a beast fight, still
holding the club of Hercules was being observed. This beast fight, named Celsus,
was mounded by his friends Probus and Astacius. The Oscan had always been a
faithful friend.
These carts were carrying not only dead gladiators, but those animals and
destitute who died in the sand. Those dead who were free men were being returned
to their families. The criminals, who had done many evil deeds, were carried to a
place named Puticuli.
Towards this place, the destitute, criminals, and others who were of no
importance''were always being carried and were being thrown into a pit.
EXHIBITV
5111/.2016 https://maxfs-useast-001.s3.amazooaws.com~jp/elb/001443717response-cache==musf:.revalidate%2C post..check%300%2C ire-check%3...
Quick Print
BIT
2013113001 ---.. v1eo rd ? Cl \ 1 Cf BIT
Sammi Hassan Addahoumi
GENDER: Male DOB: 1983-02-07

SID: F39404713 ETHNICITY: Not Hispanic or Latino;WH
HOUSING: Off Campus ROOM:
ATHLETICS: Not Athlete GREEK: Alpha Tau Omega Inactive

HONORS: Not Honors ROTC: Not Veteran
CLASSIFICATION: Senior MAJOR: Political Science
Last: 0.000 Cume:
GPAs: EMAIL: addahoum@email.sc.edu.
2.247
ACADEMIC
ADVISOR:
LOCAL INFO

Local Phone: 8033196941 Cell Phone: 8033196941
PERMANENT INFO

Phone: 8033191867
Emergency Contact:
INCIDENT: 2014-03-15 3:44 am email

Description: Mr. Addahoumi sent me an email threatening to sue me if I did not give him a
--~~ing grade. for..a..naper he~s:ubmittedinthe email Ihe.papei:.refers.to..me.$..a.sociopath--and---~~~~
dishonest. The level of hate demonstrated in the paper and its rambling nature are disturbing.
Given the wide mood swings I have observed, especially between our last meeting and the
3/15 email, I have serious concerns about Mr. Addahoumi's stability. You may recall that Mr.
Addahoumi was removed from my class during the Fall semester because of his disruptive
behavior. I agreed to allow him to finish the course by submitting a paper. I thought he ai.nd I
had agreed on a topic, and I have earlier email documentation of my guidance to him. I had
https://maxfs-useast-001.s3.amazonaws.comluscosjpfefcl00144371?response-cache-control==must-revalidate%2C%20post-check%300%2C%20pre-check%3... 1/2
5111Q016 hlfpo:/lmaxfs..useast-001.s3.anazanaws.ccmJuscplel'cl0014437~=muskevalidate%2C past-check%300%2C i:n-check%3..
not IIlilltt a demand for the paper's submission.

I an now concerned for my safety and that of my family.
I have not responded tO Mr. Addahoum.i's email.
I can attach documents (including documentation of guidance for his assignment) but I do not
see a place on this form to do so. The 3/15 email follows: 'ii 12 [ I wish things could haye
been different Here is the paper which i owe you . As were discussed no rubric for the paper,
~---~--~--~IJookltuponm_yself to tellth~sto~-~euet]y;vhyymttlidnotwantmeinyour-------~----~--------
class. Truth is very very dangerous. This is passing paper. IF you decide to make things
difficult by failing me, you can add one more lawsuit that you will face in the city if
Columbia. I wish you well. And I wish we could have beautiful music together instead of this
awful noise. Sammi Addahoumi"
REPORTEDB~..._. ._._
CHARGES: BIT-Erratic behavior

TAGS:
REFERRED B Y : -
- g saaa a
NOTES
The infolTllation contained on these pages is privileged and confidential infotmation intended solely for the individual or entity who has
accessed it for official purposes and by lawful means. Any dissemination, distribution, or copy of this communication is strictly
prohibited. If you have received this communication in error, please immediately notify us by telephone at (803) 7n-4333 and retum
the otiginal message to us via the U.S. Postal Service at 901 Sumter St. Columbia, SC 29201, without retaining a copy.
"
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Page 144 of 149 Entry Number 54-1 Date Filed 08/04/17 3:16-cv-01571-CMC-SVH
EXHIBITO
ADDAHOUMI, SAMMI
Sammi Addahoumi
April 12, 2014 at 11 :43 AM
Mrs. Liggett,
Once again, thank you for your call.
After looking over the paper work, and having a better idea from you over the phone regarding what exactly my infraction was, I would
certainly much rather have my fate in the hands of 12 of my peers.
I am actually still quite confused as to the exact nature of the violation. I urge you to reconsider, and if not, please adjust the process so that
the hearing among my peers is an option.
Thank you again,
Sammi Addahoumi
And which dean would I address my concerns about mr. Wisers lack of teaching credentials and prejudiced nature of his lesson plans?
Sent from my iPhone

EXHIBITP
LIGGETT, ALISA
Rlj:: Sammi Addahoumi
April 15, 2014at12:17 PM
ADDAHOUMI, SAMMI
Sammi,
Please read this with the intention I intend, which is to spend your energy productively, not to be snarky
(my primary concern).
To request a CJC student conduct hearing regarding computer misuse et al charges as an avenue to
address your concerns about being.targeted is akin to taking I-95 south to get to Spaiianburg. You will
spend a lot of time and frustration trying to get somewhere and realize you have gotten no closer
because it cannot possibly get you to your destination.
The office of Equal Oppo1iunity Programs investigates allegations that involve being treated differently
because of race and/or religion.
A panel of three 19-22 year olds and two faculty/staff members cannot do that. What they will focus the
hearing on is whether emailing two classes you were not enrolled in using university resources is against
the verbage of the policy (the policy is word for word in your letter and email). Then they will address
whether the fact that three recipients of it felt scared enough to report it to authorities warrants further
code violations. They would have read the posting that is accusatory and decide whether it warranted a
harassment charge. So this conduct case that is otherwise resolved would get bigger and bigger, and you
would not accomplish the options that you just listed below. Because the panel do not deal with
disciplining faculty.
Worst case scenario they suspend you immediately and you lose the semester. You told me that
finishing this semester was the most important thing on Friday, so I'm worried that now you would risk
it. If you lost it, and they couldn't address the issues you so desperately wai1t addressed, the situation is
worse. You are getting on the on ramp San1mi, and I just want you to check your map.
Alisa
From: ADDAHOUMI, SAMMI [mailto:addahoum@email.sc.edu]

Sent: Monday, April 14, 2014 10:32 PM
To: LIGGETT, ALISA
Subject: Sammi Addahoumi
Mrs. Liggett,
Thank you for your concern. Once again, I am still unaware of the nature of my violation, as it
was not made clear. Please find time tomorrow as I have a fourteen day window in which to file
grievances. I must be clear: at no time was I informed of exactly what code I allegedly violated,
nor how exactly how said policy was violated, nor was I afford even proper documents which
---~-would have allowed for my own retrospection orcontestation~The horrors of war, the horror.of_____
death, I have seen and been made stronger for it. That being said, the blatant and unaddressed
racially and religiously centered verbal and psychological abuse, however, are recognized as
crimes even in times of war.
After examining your paperwork and reality of the situation, there is no doubt that I approached
you with my complaints of being targeted by both Josef Olmert and Leslie Wiser. Instead of
acknowledging my very valid concerns regarding the both individuals specifically targeting me
due to my race, my religion, my beliefs, and my background, and my character.
Once, again, given the circumstances, I humbly request you either reconsider your actions or
initiate a review among my peers. Only one person has to see what I have with dire urgency
brought to your attention repeatedly: That other than the 2 documented racial, ethnic, and
religious attacks that were clearly documented and ignored, no other issues with any other
professors or staff has occurred, nor will it. This due to the fact that all of my other professors
have absolutely no reason to hate, target and victimize an earnest student just for being Arab,
Muslim, Libyan, or of mixed race and/or cultural background, for aside from the two
documented exceptions, the faculty at USC are professional educators with all of the academic
and moral integrity due such positions.
Indeed, make no mistake, the situation was allowed by you to degenerate into problem I now
face, whereby such concerted neglect has threatened my very emotional, mental, and physical
well being.
Please address these concerns as soon as possible and consider this last attempt I will make to
remedy the situation at your office level, as my repeated yet ignored requests have begun to take
their toll in scale of grievance and academic consequences, whereby your failure to properly
address my complaints of discrimination has effected my ability to concentrate on my academic
coursework.
Give me a charge so that I can fight it, otherwise, please address the hostile environment that
has been repeatedly brought to the attention of your office. I do not feel safe, physically or
mentally, while my concerns are ignored. Please consider this correspondence my final attempt
to solve the matter without due representation.
Thank you again,
Sammi Addahoumi
(803) 237-6116
Neale Lourie,
Lourie Law Firm, LLC
1450 Harden Street Extension
Columbia, SC 29201
(803) 753-1856

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3:16-cv-01571-CMC-SVH Date Filed 08/04/17 Entry Number 54 Page 1 of 44

UNITED STATES DISTRICT COURT

DISTRICT OF SOUTH CAROLINA

11, 2014. (Exhibit A and Exhibit B)

contained an attached essay, contained no threats of any kind. (Exhibit C)

emphasis on profiling Muslims using discredited and biased sources. (Exhibit F)

classmates and instructors.

5. Wiser reported Addahoumi to Defendant Liggett several times, exaggerating and

6. Wiser found Addahoumi's protected free speech activities to be entirely unacceptable,

groups, faculty members, and other administrators. He ultimately summoned Addahourni

and arbitrarily eject him from class. (Exhibit E)

threat of arrest in response to the outburst of another student (Exhibit F)

mandated that Addahoumi submit a "pass/fail" research paper. (Exhibit I)

threat to himself or others despite overwhelming contradictory evidence. (Exhibit K)

Addahoumi's numerous "Charge Letters" accusing Addahoumi with "erratic" speech.

Despite charging and sanctioning Addahoumi for "erratic" speech, no definition of

"erratic" was provided or available. (Exhibit K)

feminism could be subject to investigation and sanction by university authorities due to

others being "offended" or "concerned" or "distressed". (Exhibit L)

"proof" that a problem exists". (Exhibit L)

not be offended or "distress" or "concerned" by discussions of serious social issues. And

protected free speech activities.

aware and involved. (Exhibit M and Exhibit N)

amended in scattered sections of 42 U.S.C.). Defendant's actions also constituted a

breach of contract under South Carolina law.

aforementioned statutes and constitutional provisions. Addahoumi also seeks injunctive

relief and nominal, compensatory, and punitive damages to be determined by an impartial

jury, plus attorneys' fees and costs.

unconstitutionally suspended by defendants. Addahoumi had only one single 3 hour

class remaining to graduate. Addahoumi is the owner/operator of Samrni' s Deli in

Columbia, South Carolina.

Carolina information and belief, resides in or around Columbia, South

injunctive relief in his official capacity.

personal and official capacities

and to community members making referrals, coordinated campus partnerships in

training of conduct administrators, and "promoted adherence to the principle of the

personal and official capacities.

providing triage, coordinating interventions, assisting in care plan development, and

assisting students in complying with recommendations and adhering to University

policies. Defendant Bedford served as a liaison between the Behavioral Intervention

"support" is needed. Defendant Bedford conducted evaluation and assessment procedures

his personal and official capacities.

personal and official capacities.

Bureau of Investigation (FBI) on multiple occasions. Defendant Prill referred Mr.

Addahoumi to Defendant Frierson for a forensic psychiatric violence risk assessment in a

sued in both his personal and official capacities.

Fellowship at the University of South Carolina School of Medicine. Defendant Frierson

was paid by Defendants to perform an involuntary forensic psychiatric violent risk

...... ~-~~ .Jheir.E:nthority~.~gents ~gc:lgffic.ers._9.f_the !I!liY.er~i!Y.9LSouth .~~Qlina. D.ef.en<:l@.L~-~

Fed. R. Civ. P. 65.

FACTUAL AND PROCEDURAL BACKGROUND

liberties, Homeland Security, policing, and U.S. foreign policy.

mandated Addahoumi submit to psychological assessment to collect data that better

supported Liggett and Wiser' s own concerns.

information, analyzed this information through a series of subjective rubrics or set of

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back to ensure future BIT reports about Addahoumi's speech.

complaints filed about Addahoumi's speech or to filter out complaints about

Addahoumi' s academic and protected free speech.

Fourteenth Amendments of the U.S. Constitution.

escalate their portrayal of Addahoumi as a dangerous threat. These included numerous

was somehow a threat to himself or others.

information gathering stage to begin again.

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