To continue from the affidavits of Attorney Howard M. Squadron and Minister Ava Muhammad:

Attorney Squadron cites in his seventh paragraph, out-of-context, twisted, distorted, gnarled, perverted, warped and malicious excerpts from a few of Minister Farrakhan's writings and speeches over the years. What was his stated source? The Anti-Defamation League, or "ADL," who are guilty of what they are supposed to be against--defamation.

In his eight paragraph he states, "Significantly ,plaintiffs' lead counsel in this litigation, Ava Muhammad, herself has used blatant anti-Semitism as a means of describing this lawsuit to members of the Nation of Islam. In a speech Ms. Muhammad gave on September 24, 1994, about this litigation, an audiotape of which is sold by mail order throughout the country, Ms. Muhammad explained to members of the Nation of Islam that 'the law offices of Mr. Squadron on Fifth Avenue' were seeking to depose Minister Farrakhan and were demanding documents from the Nation of Islam. ... Ms. Muhammad told her followers that the Nation of Islam had said 'No' to those requests. She then stated the following to her audience:

"Why does America, white America, Fifth Avenue America, Jew America want to destroy this one Black man.'"

"....Ms. Muhammad's inflammatory statement was obviously intended to incite her followers against me and my firm."

He used but one sentence from her speech to make his point, which comes in his next paragraph. Are those here exact words? If so, what exactly was the context in which she spoke those words?

What is the context? Context, according to Webster's Dictionary, means "the parts of a written or spoken statement that precede or follow a specific word or passage and can influence its meaning or effect; the set of circumstances or facts that surround a particular event, situation, etc.

Did he distort her meaning, and what was his state of mind out of which his words came?

In his ninth paragraph: "It is clear from the foregoing, that by requiring defendant's counsel to travel to Chicago to take the deposition of Minister Farrakhan at the headquarters of the Nation of Islam, this court is sending me and whoever accompanies me into a situation that very well may prejudice defendants' ability to obtain full and fair discovery in this lawsuit. In view of Ms. Muhammad's statements about this firm and this case, no member of my firm should be placed in the situation of having to take Minister Farrakhan's deposition in his headquarters among his followers.

In his next paragraph he adds: "Moreover, as set forth in the accompanying memorandum of law and affidavits, there is absolutely no legal or factual basis (not to mention the relief was not requested by the plaintiffs) for permitting out-of-state plaintiffs, who commenced this lawsuit in New York, against New York defendants, to force the defendants to travel out-of-state to take a plaintiff's deposition."

Finally, he concludes in his eleventh paragraph: "Accordingly, it is respectfully requested that this Court grant defendants' motion to reargue and/or renew and modify the March 23 Order to direct that the deposition take place in a room at the courthouse of the New York State Supreme Court at 60 Centre Street or in my firm's offices in New York City."

How did Minister Ava Muhammad respond? Here is part of it from paragraph's eight through number twelve.

No. 8: "Defendants arrogance and disrespect for the Plaintiff's stature as a world-renowned spiritual leader is displayed in their reference to reports of Minister Farrakhan's travels. Minister Farrakhan's schedule is none of their business. The fact that he took a vacation or gave a lecture in a place outside of Chicago, Illinois does not entitle defendants to absorb three days of his valuable time to harass and annoy him about a topic which he has addressed thoroughly in documents which they have in their possession."

No. 9: "Defendants have attempted to use these pleadings to submit negative propaganda material in an effort to inflame the Court, hoping the Court will adopt defendants' damaged perception of reality. Defendants use their computer software and their connections with the FBI to monitor every move the Plaintiff's make, to transcribe every word that is spoken, to reproduce every word that is written. They edit and select part of the data they have gathered and present it to the Court in a manner calculated to arouse anger and hostility toward the Plaintiffs and to produce an outcome favorable to themselves. This pattern of surveillance and monitoring constitutes a program of harassment that should result in sanctions and penalties against the Defendants, the least of which should be a prohibition against taking any depositions from Plaintiffs."

For well over ten years the United States government has hired--spent the tax payer's money--over one-hundred persons to spy on the Honorable Louis Farrakhan, morning, noon and night.

She continues, No. 10: "The statement that Minister Farrakhan is 'capable' of appearing in New York City is gratuitous. Mr. Squadron is 'capable' of boarding a plane and traveling to Chicago. Mr. Squadron, though he characterizes himself as 'widely-known,' was completely unknown to the Plaintiffs prior to this action."

Now I am asking the readers to pay particular attention to these words of hers. It will prove to be very significant:

"Now, he chooses to spew false and libelous statements that are as venomous as those published by his clients. Unbeknownst to the Plaintiffs, Mr. Squadron appointed himself to 'conduct the deposition of Minister Farrakhan personally.'

"Neither the Court nor the Plaintiffs requested Mr. Squadron to conduct the deposition. Thus, his statement, 'I submit this affidavit so that the Court can understand the full impact of its order,' is not only bizarre, it is display of contempt for the Court. The March 23rd Order would not have the 'effect of require me (Squadron) to depose Minister Farrakhan' if Mr. Squadron had not determined, in his own mind, that he would seize this opportunity of a lifetime. He is distressed, however, that it is not to take place in his office, where he planned to do his very best to humiliate Minister Farrakhan. Therefore, he has submitted a document containing thinly-veiled threats that the April 19th Order is politically incorrect, insofar as Mr. Squadron, the American Jewish Congress, and the ADL are concerned (Page 2, paragraph 5, Squadron affidavit).

No. 11: "Mr. Squadron does not believe that he would be placed in an 'intimidating atmosphere' in Chicago, Illinois. It is indignation, not intimidation that he suffers from. It is significant that such prominent Jewish leaders as Rabbi Marx and Rabbi Shulman of Chicago have dined in the home of Minister Farrakhan. The well-known columnist Irving Kupcinet has also been a dinner guest of the Minister's home. Ms. Barbara Walter's and her staff spent and entire day with Minister Farrakhan in his home, preparing an interview that was subsequently televised on '20-20'.

"Plaintiff's attorneys have had to travel to and from New York, Chicago and Washington, D.C. and New York and Atlanta, nearly a dozen times to handle this litigation, and we are still in the early stages of pre-trial discovery. It is Plaintiffs and their attorneys who would have reason to be intimidated by having to go into what we now know to be the openly hostile environment that is Squadron's law firm."

No. 12: "Mr. Squadron represents a defendant which has earned millions of dollars publicly and falsely condemning Minister Farrakhan. Mr. Squadron has submitted a 50-page document produced by the Anti-Defamation League, an organization characterized by the Los Angeles Times as a 'spy network,' and which works hand in hand with governmental intelligence-gathering agencies to discredit, divide and ultimately destroy individuals and organizations which do not agree with their stated goals and objectives. A series of reports on the ADL is attached as Exhibit A."

More next issues, Allah willing.