JOHN BROWN

&

ASSOCIATES

COURT CONSULTANTS

Honorable Percy Anderson

United States District Court

312 North Spring Street

Los Angeles, CA 90012

September 19, 2008

Re:

Seyed Mahmood Moosavi

Case No. CR-07-S13 (C) -PA

Dear Judge Anderson:

701 EAST THIRD STREET. SUITE 240

LOS ANGELES. CALIFORNIA 90013

TELEPHONE (213) 628·9218

FAX 1213) 628·9718

The following is a social history and assessment of Seyed Mousavi, which has been

prepared at the request of his attorney, Ronald O. Kaye, for consideration at sentencing.

The information in this report is based on a series of interviews with Mr. Mousavi, his

family members, colleagues, friends, and the young people he has mentored. In addition, we

have reviewed case file documents, and have read and considered numerous character reference

letters, which are attached.

GENERAL INFORMATION

Seyed Mousavi, age 49, was found guilty by a jury of filing a false

tax

return

(26 USC

§7206 (1»; impeding administration of

tax

(26 USC §72l2); violating the International

Emergency Economic Powers Act (SO USC §§1701-170S, and 31 CFR §S60) (2 counts);

procurement of citizenship contrary to law (18 USC §142S(a»; and false statement within the

jurisdiction of the federal government (18 USC §1001).

Seyed Mousavi was born on October 20, 19S8 in Abadan, Iran. Until his arrest a year

ago, he lived with his wife Nahid Nabhani in their house in Diamond Bar, California. Their four

children are all working towards their undergraduate and graduate degrees. Mohammed, 28, is

an undergraduate student overseas, where he lives with his wife and infant daughter. Zeinab,27,

is a full scholarship graduate fellow and Ph.D. candidate in electrical engineering at UCLA.

Zahra, 21, has a B.S. in biology from UC Riverside, and is

taking

graduate school prerequisites

Re: Seyed Mahmood Mousavi

September 19, 2008

Page 2

for physician’s assistant school at Citrus College. Seyed Ali, 18, began attending UCLA this

September. The two older children were born in Iran, and the two younger children were born in

the United States.

Seyed Mousavi was the youngest of six children born to Seyed and Dolhe Mousavi. His

siblings all live in Iran and are largely retired. His brothers and sisters worked as physical

laborers for the most part, with the exception of one sister who was a nurse. Both of his parents

are deceased.

Other than the current offense, Mr. Mousavi has no criminal history.

Seyed Mousavi grew up in a house in Abadan, a city near the Iran-Iraq border in the state

of Khuzestan. Seyed recalls his childhood as stable and secure. He describes himself as very

close to his parents, his maternal grandmother, and his large extended family. Seyed’s father

worked as a warehouse manager at the Ahvaz Steel complex in the city of Ahvaz. Three of

Seyed’s older brothers also worked at the steel mill, and years later, Seyed would join them and

work in the same plant.

Seyed attended kindergartenthrough the sixth grade at the Masoud Sead Elementary

School in Abadan. For secondary school, he attended the Mehr Melli School in Ahvaz. In high

school, Seyed learned to read and write English. His high school principal,

, now

79 years old and living in Canoga Park, remembers Seyed in a letter he has written to the Court:

Mr. Mousavi was one of my best students...he distinguished

himself through his obvious care in his school work... His father

was good, noble, and a servant for other people...

Mr. Seyed Mousavi was a simple person, an honest person. He

always helped his classmates with pencils, with pens, with their

homework. Mr. Mousavi was… chosen to lead the prayers

because of his academic success.

Mr.

etter is appended.

Re: Seyed Mahmood Mousavi

September 19, 2008

Page 3

While he was attending high school, Seyed worked several months for an American

company doing business in Jonde Shapoor, Iran. At Stone and Webster Construction, Seyed’s

job duties required him to translate Farsi into English, inspect pipe welds, and maintain electrical

instruments. Several letters of recommendation written by his American supervisors in 1977

attesting to their positive experiences working with Seyed are attached.

,

ammonia plant supervisor, wrote:

During his employment here he was an electrician working up to

forty men pulling cables. He also worked… on post weld stress

relieving of piping as well as an assistant to the electrical

superintendent. This man is highly recommended for employment

and would make a capable foreman.

After his graduation from high school, Seyed applied to college. His former principal

reports:

Mr. Mousavi passed the entrance exam to enter university at his

first try. This was a very big source of pride for me and for his

family.

Seyed entered the Jonde Shapoor University where he studied physics, ultimately

graduating in the early 1980's. While he was a student, Seyed worked part-time at the Ahvaz

Steel plant with his father and brothers as a precision instrument controller on small mechanical

and electronic parts. He continued at this job for a couple of years after his graduation.

Seyed reached the age of eighteen in 1976, at which time he normally would have been

required to perform military service. However, he failed his physical exam due to astigmatism in

one of his eyes, poor vision, and a bad back. These health problems led to exemption from

military service.

After the Iranian revolution in 1979, Iran was, for a time, in a state of disarray. In the

midst of all this upheaval and change, Iraqi leader, Saddam Hussein, launched a full-scale

1

Mr. Mousavi has consistently maintained that he never served in the military. This contention

would appear to be borne out by a document from the Iranian Section of the Pakistani Embassy

in the United States, which is attached to the defense position re: sentencing .

Re: Seyed Mahmood Mousavi

September 19, 2008

Page 4

invasion of Iran, starting what would become the eight-year Iran-Iraq War. This conflict was

extremely bloody on both sides, costing over half a million lives.

During the eight years of war and instability, many Iranians were conscripted into jobs

they would not have chosen. A number of Seyed Mousavi’s family members were killed as a

result of their city’s proximity to the battlefront. His 16 year-old brother-in-law died in a

bombing attack, and his father died as a result of a car accident caused by gunfire. In total,

Seyed Mousavi estimates that he lost 53 members of his extended family to the carnage of this

war.

Seyed met Nahid Nabhani while she was a physics student at the Jonde Shapoor

University. They married on April 10, 1979, and moved into a house together in Ahvaz. Nahid

had by this time graduated from the university and worked at the local office of the government

oil company in the sales department. She reports that her main duty was to purchase fire safety

equipment for the plant. In 1980, Seyed and Nahid’s first child, Seyed Mohammed, was born,

followed by their daughter Zeinab two years later.

On September 29, 1980, while Seyed and his brother-in-law,

, were

attempting to pass through a war zone in order to pick up Seyed’s aunt, an incendiary device

exploded just a few feet away from them. Seyed suffered severe injuries and, in the resulting

chaos, was separated from

and taken to the Razi Hospital in Ahvaz.

Seyed’s brother-in-law, recollects in his appended letter:

… with my sister’s husband Mr. Seyed Mahmood Mousavi, I went

to Abadan (about 50 km after Ahwaz). We were going to get

Mousavi’s aunt out from Abadan. Abadan was dangerous for her

and too many enemies were around it. We could not because of

harsh bombardment of the armed forces didn't let us to go pass the

border. We wanted to save the aunt. We tried more. Iraq's armed

forces bombard above area, unfortunately my sister’s husband got

injured in this bombardment. I lost him. I couldn’t find him until

later. I saw him in the hospital.

One day later, after a frantic search, Seyed’s wife saw him at the hospital. She recalls

that he was on a bed wearing a cast, which covered his torso. Seyed was badly injured on the

Re: Seyed Mahmood Mousavi

September 19, 2008

Page 5

entire left side of his body, from his shoulder and back down to his calf. He lost the smallest

finger on his left hand and sustained nerve damage throughout his body.

After the initial treatment was administered at the Razi Hospital, Seyed went to a hospital

in Tehran where he was a patient for one month. He underwent multiple surgeries, electric

stimulation with needles, and physical therapy. Seyed subsequently traveled to Vienna, Austria,

in the early 1980’s for further surgeries to help restore mobility to his left arm. He still had

shrapnel inside his body and one fragment was close to his heart. Several pieces of shrapnel

were removed, and a nerve was taken from his leg and transferred to the underarm area.

To this day Seyed reports that he does not have full use of the left side of his body. In

Iran, he was classified as 40% disabled and was issued a “Janbaz”card.

This status confers

certain benefits including a state sponsored retirement plan, free or reduced-cost medical care,

and special job tenure. According to Dr. Marandi (referenced below) the card does not

necessarily denote military service, though many veterans have received disabled status as well.

In the case of Seyed Mousavi, the card indicates that he was injured collaterally to war violence.

Seyed’s first child, Mohammed Mousavi, also was injured due to the war. As an infant

of approximately 2 years, a bombing attack over his house rattled the foundation and caused a

pot of boiling water to spill on him. The child sustained burns over much of his left arm and

hand, resulting in extensive scaring, which can still be seen today.

Seyed reports that, from the time he was a small child, he had dreamed of living and

working in the United States. In 1983, he flew to Texas and rented an apartment close to friends

from Iran who were college students in Austin. Seyed attended English as a Second Language

2

Dr. Sasan Marandi (also known as Seyed Mohammad Marandi), a U.S. citizen born in Virginia,

is a professor of American Studies at the University of Tehran, Iran. In his declaration to the

Court, submitted under separate cover, Dr. Marandi clarifies:

Janbaz status reflects individuals, civilians, volunteers, and

military, who were injured during wartime in Iran...The Iraqi

military was shooting missiles into the civilian parts of the city and

mortar as well as artillery fire was an every day occurrence. A

civilian who was injured during this time period would be eligible

for Janbaz status, which would give the civilian access to certain

benefits from the Iranian government.

Re: Seyed Mahmood Mousavi

September 19, 2008

Page 6

courses at a local school. While in Texas he also visited his American friend

, an

engineer and former supervisor of Seyed’s from Stone and Webster. After a couple of months in

Austin, Seyed flew to Iran to see his family. He returned to the United States and traveled to

California, where he stayed with friends in the San Gabriel Valley and Orange County. In the

next few years, Seyed returned to the United States from Iran, and brought his wife Nahid to see

this country. In 1986, the entire family immigrated, settling in a rented apartment in Alhambra.

After a year in Alhambra, the family moved to Garden Grove. The Mousavis’ third child, Zahra,

was born in 1987, followed by Ali in 1990.

In his first few years in this country, Seyed worked at a series of jobs and businesses, sometimes

juggling two positions simultaneously as he struggled to support his family. He worked as a roadside

assistance tow truck driver in Orange County, and he also worked as a used car salesman. In 1990,

Seyed started Mahdi International Trade Company, where he went into business buying and selling fax

machines, clothes, and other goods, often at area swap meets.

family friend and Senior Application Analyst at the University of

Massachusetts Medical Group, recalls in her letter:

I do remember that [Seyed Mousavi] had a lot of problems with his

back and he did always have a heating pad on it to make him feel

better. He always wanted to work a lot, but it was hard on his back,

especially any hard labor…There would even be a week at a time

when he was in bed because he could not sit or stand due to his

back.

Seyed continued to suffer physical pain, the aftermath of his surgeries and nerve damage.

Perhaps in part because of this pain, his focus turned in an increasingly spiritual direction. He

became involved as a sort of “lay minister” in the Muslim community and was particularly active

in working with youth and efforts to allay sectarian tension.

, board member of both the Islamic Society of Corona and the Islamic

Shura Council of Southern California, observes in his letter:

I have known Seyed Mahmood Mousavi since 1988, and have

always found him to be a selfless, hard-working, generous man.

His dream was for a society of mutual understanding and respect.

He encouraged interfaith dialogue and always emphasized on our

Re: Seyed Mahmood Mousavi

September 19, 2008

Page 7

common grounds rather than the differences between religious

groups. For the American Muslim community, he dedicated his

time to resolve issues amongst the Shiite and Sunni groups, so that

they could shift their focus from disputing amongst themselves to

unifying so that, together, they could better help society.

Seyed Mousavi’s pioneering work in the 1980s of bringing Muslim

scholars of various communities played a role in the formal

establishment of the Shura Council of Southern California in 1995.

Today, the Shura Council contributes to the society through joint

research studies with many interfaith leadership organizations,

collaborative social justice projects with various non-governmental

organizations and community based organizations, and resource

services on Islam and Muslims to academic institutions.

Dr.

, Vice Chairman of the Islamic Society of Orange County, offers in

a similar vein:

I have known brother Mahmood Mousavi for the last 25 years or

so. I have known him as a true bridge builder between not only

Sunni and Shi’ite Muslims, but between people of all faiths and

beliefs as well, I’ve known him as a dedicated person to promote

peace, harmony and understanding between humanity.

Seyed’s

son, writes:

My father’s vision for the Muslims was for them to live in peace

and harmony, and to blend in with American society. In other

words, he dreamed for the Muslims to be part of the salad bar that

makes-up modern day America.

long-time family friend, comments in her letter:

…Seyed Mousavi often organized many holy religious events, to

which he invited anyone he may have known. He organized the

events, but he never considered himself too good to be cleaning

tables or even sweeping floors. I remember always seeing him

running around, greeting people, introducing them to each other,

making sure everyone was comfortable, and he would always

Re: Seyed Mahmood Mousavi

September 19, 2008

Page 8

participate in serving food or tea to others. He would usually be the

last to leave an event, as he would stay to clean the place.

Spokesperson for the Islamic Center of Southern California,

comments in his letter:

Throughout the years, I have been deeply involved in interfaith bridge

building and civic engagement. Twenty five years ago, I met Mr. Seyed

Mousavi who shared my aspirations for building a harmonious society,

where Muslims contribute to the betterment of America. His tone was

always one of compassion, and he always shared his belief that American

pluralism gets the best out of all its components.

Seyed’s immediate family reports that he broke the stereotype of a stern Middle- eastern

father and adopted a more affectionate, American-style demeanor with his own children. Unlike

many Iranian-American parents, Seyed encouraged his children to pursue their true dreams, not

to simply aim for financial success. He and Nahid were strong advocates of education, and the

Mousavi children were each highly encouraged to take their academics seriously.

relates in her letter:

My father never decided for us which field to study, which is a

common practice in Iranian culture. He left that to us to decide.

He also wanted us to enjoy our lives and make trips to different

regions of the world... he wanted us to be out there and experience

living among people.

,

writes:

My father has always been gentle and kind. I remember at day

times he would wrestle with me and at night time he would sleep

besides me. I used to have a very strong hand as a child and one

day as a five year old child I decided to slap my father twice with

all my power. Now my father could have punished me, yet he

refused to do so, and as a good father he let me know that he was

disappointed at me by the look on his face.

Re: Seyed Mahmood Mousavi

September 19, 2008

Page 9

Seyed traveled between Tehran and the United States during the 1990’s. His family also

went to Tehran for a time and the children relearned Farsi. To make ends meet, Seyed also held

part-time jobs selling used cars and sometimes drove a tow truck again. In 1996, Seyed worked

in a Huntington Park shopping center as a sales manager at La Plaza clothing store. Two years

later, he was hired at Radio Shack in Arcadia, California where he was a sales associate for

approximately one year. Seyed reports that he enjoyed the contact with people that characterized

each of these jobs, although he continued to suffer from back problems and injury-related pain.

In 1999, the Mousavi family rented an apartment in La Verne and in late 2001 they

bought the home where they presently reside. Seyed found work in a new business, selling and

installing satellite dishes. The children attended the local public schools where they quickly

established themselves as good students. Mohammed Mousavi, the oldest, graduated from high

school in 1999 and enrolled in classes at Chaffey College in Rancho Cucamonga.

The following year, Zeinab graduated high school and went on to attend Chaffey College

for two years. In 2001, she transferred to Caltech in Pasadena as a full academic scholarship

electrical engineering major. Zeinab graduated with honors from Caltech three years later and

went for graduate studies to the University of Michigan where she received her Master’s degree

in 2006. She is now pursuing her Ph.D. at UCLA with a full scholarship and fellowship.

The Mousavis’ next daughter, Zahra, graduated from the University of California,

Riverside, in 2008 with a degree in biology. She is taking her prerequisite classes at Citrus

College and plans to enter a Physician’s Assistant program next fall. In the meantime, she works

as a college tutor and spends her free time volunteering at local hospitals and with youth

programs at the mosque Seyed co-founded.

In 2006, Ali started a robotics club at Diamond Bar High School. Ali’s school team

ultimately made a 30” x 20” radio-controlled, battery-powered car. At Caltech, on a volunteer

basis, Ali helped to conduct research in the field of bioengineering with Professor Joel Burdick.

That position has grown into a paid summer job. Ali is attending UCLA this fall as a freshman

and will major in astrophysics and philosophy. He has been selected for the honors program,

which requires a GPA in the top 3% of the entering student body. Ali states that he plans to

become a professor.

For many years, Seyed had taken part in the American Muslim community through his

work with the Shura Council and mosques in the area. He had also taught various classes for

children. However, he wanted to specifically make an English language curriculum that catered

Re: Seyed Mahmood Mousavi

September 19, 2008

Page 10

to the needs of American Muslim children. In 1999, he rented rooms on the second floor above a

Union 76 gas station in Upland where religious services were held for approximately a month.

In that time, Seyed made arrangements to share expenses in a small mosque called Ahlul-Beyt in

Pomona, which principally served Arabic speaking Muslims from Iraq. The community that

Seyed helped form borrowed space there and was based in the mosque in Pomona through 2004.

According to many of the individuals who were interviewed and whose letters have been

received, Seyed stepped out of the traditional hierarchy and adopted a more liberal vision of

Islam than was typical in local mosques. He insisted that the program of speakers begin with

speeches made by children, followed by scholars and Imams, the equivalent of priests.

Civil Engineer and father of two of the youth who attend the Al-

Nabi Mosque, was one of many who expressed such thoughts:

Mr. Mousavi also made great effort to invite scholars who are well

informed with Islam and are also well aware of the American culture.

These speeches not only helped the older generation to understand the

problems our children deal with in today’s society, but more importantly

helped our youth find their place in the society as American Muslims.

Perhaps most importantly, Seyed provided a forum for young people to express the

concerns that they were often afraid to tell their tradition-bound parents.

, a LAUSD junior high school history teacher, writes in his letter to the

Court:

As an American Muslim youth growing up in the southern

California Muslim community, it can be difficult to know your

place in American society, especially with the current issues

related to terrorism and the Middle East. With all the negative

portrayals of Islam and Muslims around the world, it is easy to feel

intimidated and alienated, and want to detach yourself from the

rest of society, a common reaction of many American Muslim

youth. However, Your Honor, through his works and example,

Mr. Mousavi has shown us that this is not the right attitude. Rather

than being negative and detach ourselves from society, we should

make even more of an effort to interact and develop relationships

with those around us, regardless of race and religion...

Re: Seyed Mahmood Mousavi

September 19, 2008

Page 11

professor of Islamic studies at

, comments:

He would often call me, my brother, or my friends, and implore us

to attend these classes– and sometimes even to teach these weekly

sessions... there is absolutely nothing more important than having

older, successful Muslim youths serve as role models for those in

elementary and high school, those who often feel lost, confused

about their identities, and as if they do not belong anywhere. I

know for a fact that none of us would have attended those classes

or volunteered to teach if it were not for Mr. Mousavi’s weekly

phone calls.

writes:

I am an addict in recovery. Seyed devoted so much of his time and

energy to helping me…

...He also gave me the job of hosting the nightly religious program

at the mosque in front of all the people attending. I looked like a

total fool, made jokes about the women covered in their head

scarves, and I made jokes about Muslim extremists. The silence

was deafening. But he listened to all the complaints, and the

following week, he made me do it again. I kept getting a little

better and better, less offensive and more sincere. I started to go to

AA meetings. I started to prepare to speak Saturday nights. I began

to look my parents in the eyes.

mother of

, discusses her

son’s situation in her letter:

We,

parents, are thankful to Mr. Mousavi for all the

help he gave to

which helped save him from his own

mistakes. Mr. Mousavi always … taught him everything that he

needed to know about becoming a better person. With his

encouragement,

cleaned up his life, and has become a son

to be truly proud of.

Re: Seyed Mahmood Mousavi

September 19, 2008

Page 12

a community college student, writes:

He cared about youth the way he cared about his own children, and

he brought unity to the Iranian community...The zenith of my

adolescent years occurred at Ahlul-Beyt. Some of my closest

friendships– people with whom I was able to relate– were formed

in this mosque. This was a place where I could not only socialize,

but I learned my religion in a safe, clean environment. While my

school friends spent their Saturday nights partying, I was learning

my religion without breaking any laws.

an undergraduate student at UCLA, writes:

As a Muslim youth living in this country, I face many challenges,

and it is difficult for me to keep my faith strong. Mr. Mousavi has

been conscious to always bring interesting and well-known

speakers who understand American culture and are able to engage

even us young people. He has done so much to bridge the gap

between my generation and my parent’s generation... We do

community service, we have social activities, and we organize

skits and special programs for Mother’s Day and Father’s Day...

a mother of three, writes:

After taking part in the youth classes, a noticeable change took

place in my two teenage daughters. They began to care for such

things as forgiveness and respect... Now, they actively participate

in such things as volunteering at our local hospital or feeding the

homeless in downtown Los Angeles.

, who traveled to Hajj with her young children, stated:

Hajj was a great adventure for [my children]. They enjoyed the

fact that they were the youngest in the caravan and were the

center of attention by Mr. Mousavi. He has always been especially

considerate of the youth and their needs. He has been an advocate

of giving the younger generation opportunities to express themselves.

At the end of the Hajj trip, during the farewell ceremony, Mr. Mousavi

encouraged the children and youth to speak about the trip and express

their opinion to the adults.

Re: Seyed Mahmood Mousavi

September 19, 2008

Page 13

While the many hours Seyed devoted to the projects described above made him highly

respected within his community it has sometimes hard for his family to have to share him with so

many others.

relates:

I have been very resentful of the time that my father gave to

others. He has always been ready, willing, and able to take

care of the needs of people as he found them. Honestly, I

felt cheated of his time. I wanted my father’s time and

attention. The little girl inside of me was always calling out,

“I want my Daddy.” But my Daddy was busy. I see now that

my father looked at his own children and saw that we had what

we needed, while others didn’t. We had a strong family, while

many others only had chaos. He saw that we were fine, so he

was safe to give time and money to people who needed it. I

can see now that he really did make a positive impact on the

lives of many, especially many of the youth, whose lives truly

have been changed for the better. Their parents had the

responsibility to take care of them, but if they weren’t, then

my father would. He didn’t brag about it; he didn’t humiliate

the parents for failures; he didn’t act judgmentally to the youth;

he simple stepped in and, with a caring hand, helped the youth

to refocus and improve. Now, I can appreciate that.

In 2000, Seyed helped establish the Hejrat Foundation, a non-profit religious,

educational, and charitable organization. Under this umbrella, Seyed hoped to build a religious

educational center, a mosque, and a major charity for all people in need of assistance. The Al-

Nabi congregation had outgrown its borrowed facility in Pomona, and Seyed and many of the

community members wanted to have their own mosque, which would permit them to have larger

gatherings and better rooms for the elementary and teenage children’s classes. They also wanted

to be able to have programs during the week, particularly during the major Islamic holidays. In

2004, after looking for several months, Seyed found a property in West Covina next to the 10

freeway. Seyed undertook much of the renovation work himself and gave jobs to those who he

felt needed them most, people who were down on their luck and needed some help.

Re: Seyed Mahmood Mousavi

September 19, 2008

Page 14

writes:

My father searched for a place to host this community, until he

came across a wedding chapel in West Covina which was for sale.

He showed this building to people in the community and everyone

was excited about it; however when it came time for the

community members to pay, they all took a step back, not wanting

to sacrifice. No one wanted to take active leadership, so again, my

father took everything in his own hand and decided to purchase the

place with his own credit line, placing himself deep in debt.

a recent graduate from Boston University with a Master’s degree in

Public Health, states:

I first met Seyed Mahmood Mousavi at Ahlul-Bayt mosque. He

was one of the few respected elders who supported the youth.

Unlike other mosques in which the youths are shunned, he

believed in us. He encouraged us to share our thoughts and give

lectures. Myself and others were able to connect with others

passionate about social issues such as racism, women’s rights, the

need for tolerance, and other issues.

Later when the Al-Nabi mosque was founded, the youth started to

go there. The atmosphere of tolerance is what drew us. The youth

were able to give regular speeches and share their concerns and

ideas with the various generations attending the mosque. Instead of

wasting our time loitering at the theaters, we were engaging in

dialogues about liberal interpretation of Islam. When some people

would complain of our “unorthodox” views, he would defend us

every time. He gave the youth a voice and I believe bridged some

of the differences between the elders and the youth. We were able

to have meaningful discussion in which we gained some of the

wisdom of our elders, and the elders were able to look at an old

concept in a new way.

, a postdoctoral fellow at Caltech, recalls in his letter:

Seyed Mahmood Mousavi was one of the first people that I met at

the Saturday evening program at Ahlul Bayt Mosque in Pomona…

As the only African-Americans at a largely Iranian event, I believe

Re: Seyed Mahmood Mousavi

September 19, 2008

Page 15

he immediately recognized me as a newcomer and took it upon

himself greet me.

… On another occasion, I attended a board meeting of Al-Nabi

Mosque in West Covina. All of the participants in the meeting

were Iranian, and they immediately began conducting the meeting

in Farsi language… Seyed Mahmood stopped the meeting and told

people to speak in English because it was disrespectful to conduct

business in Farsi when they knew I could not understand… Seyed

Mahmood showed me that day that he was a true citizen of the

United States, not some Iranian nationalist. Growing up as an

ethnic minority in the U.S., I have developed that keen ability to

sense patronizing behavior from different ethnic groups towards

people of color. However, I have never sensed this type of

behavior from Seyed Mahmood.

In 2000, Seyed also accepted a position as president of the San Bernardino United

Islamic Youth Organization, a group that managed the only Southern California Muslim

cemetery and a small mosque on the grounds. This organization was started in 1988 by

Adelanto police commissioner, Shaikh Zaid Assfy. Before he died in 2000, Shaikh Assfy asked

Seyed to take over this job for him after his death. Shaikh Assfy trusted Seyed, and wanted him

to take over this important job, which was the realization of Shaikh Assfy’s dream. Seyed

managed the small staff and the funeral services on a volunteer basis, and refused to accept a

salary. On June 3, 2005, a suspicious fire gutted the mosque. San Bernardino arson

investigators who inspected the ruins concluded that the blaze was a hate crime but have yet to

find the perpetrators. After the fire, funeral services were held under makeshift tents and the

attendees had to use rented restroom facilities. Seyed planned to rebuild the mosque. He had

plans drawn up by an architect for the new building, and had begun talking with the city council

of Adelanto regarding permits.

(Jafri) writes:

When the Cemetery was burned down three years ago, Mr. Mousavi

arranged for an architect to come up with a unique and grand design

to rebuild the cemetery, and he worked side by side to go through

permitting and approvals. His dream was not just a place to bury the

loved ones, but it would be a place for the visitors of the deceased to

enjoy the time while visiting their loved ones.

Re: Seyed Mahmood Mousavi

September 19, 2008

Page 16

Seyed Mousavi has assisted not only the Muslim community, but also the community at

large in the Los Angeles area, without regard to religion, nationality, and other such

classifications.

, former teacher and present Board Member of the Al-Nabi Mosque,

describes in her letter:

Our mosque is located in an area with several hotels which

homeless people use as a temporary refuge, especially victims

of domestic violence who have escaped with their children.

These people often come to our doors looking for help. Mr.

Mousavi has not let them down. A woman came into the

mosque late one night, and told us that she needed medicine

for her sick baby. She was living in the hotel next door, and

was in great need. We gave her money, and sent her with our

prayers. A few weeks later, the woman came back, happily

reporting that she had found a place to live for herself and her

children… We took up a collection and got her the deposit money,

and she and her children moved into their new home. With Mr.

Mousavi’s permission, I gave the woman many needed household

items, which we had at the mosque. This woman did not know that

we were Muslims when she came to us for help. She was surprised

when she realized … I met this woman again a few months later,

and she told me that she now has turned her life around: she felt

inspired by us to become a good Christian, and she is studying to

get a good job so that she can go off of welfare and give her

children a better life.

Board Member of Masjid Al-Nabi, relates:

Mr. Mousavi taught me good lesson. When we started renovation

projects on the building we use for our mosque, Mr. Mousavi would

hire people who needed work: he would give the jobs to people who

really needed a job and needed money. We could have gotten better

workers, but he chose people by their need more than any other criteria.

He would give them money, food, and housing, as the particular need

existed. He didn’t care about race, color, or national origin: he gave

Re: Seyed Mahmood Mousavi

September 19, 2008

Page 17

the work to Latino, Caucasians, Persians, Arabs, or whoever he needed

the work.

family friend, writes:

My memories of Seyed Mousavi are helping the poor in East L.A,

as well as South Central. Seyed Mousavi endeavored to not only

provide the poor with food and clothes, but more importantly, he

took great strides in helping to find them jobs.

, Electrical Engineer, states:

I remember the day of Eid Fetr, an Islamic holiday in which Muslims

break their fast to celebrate a whole month of fasting rituals. That

day, you could tell Mr. Mousavi was in high spirits. He had invited

all the neighbours of Al-Nabi mosque to come and join a big feast

with us. Whenever a new-comer would arrive, Mr. Mousavi would

immediately welcome them with a warm smile and show them the

way to the main hall.

, a teenage blind girl who frequents the Al-Nabi Mosque,

writes simply:

He was like a gas station that never closed; he offered his help 24

hours a day.

In 2002, Seyed Mousavi attended the three-week Hajj pilgrimage to Mecca for the first

time. He reports that he was so profoundly moved by the experience that he wanted to organize

his own caravan make the trip possible, even for those with low incomes.

A year later, he

coordinated a trip for 20 pilgrims. Seyed personally led caravans each following year until 2007,

when he was incarcerated. The Hajj is a pillar of the religion, and is required of all Muslims at

least once in their lifetimes.

3

Hajj expenses for Americans flying from the west coast this year will range from

approximately $4800 to $8000, depending on the level of accommodations.

Re: Seyed Mahmood Mousavi

September 19, 2008

Page 18

Many of the individuals who have written in support of Seyed Mousavi grew close to him

during the Hajj pilgrimage, which includes staying in tents in the desert. These people cite his

egalitarian nature, his calmness and equanimity when problems arise, and his repeatedly shown

concern for members of the caravan who were elderly, disabled, or ill.

, professor at the Georgia Institute of Technology, writes:

When Mr. Mousavi started his Hajj Pilgrim program… his main

motivation was to provide the highest quality service to the people

who usually go to Mecca and Medina. This is a very important trip

for any Muslim and it is essential to do all the tasks completely and

accurately. Since I went with his group three times, and I saw and

heard about other groups who provide the Hajj services, I can attest

that Mr. Mousavi provided an outstanding service for the pilgrims

at a very low cost. While he could have charged considerably more

for the services he provided, he tried to charge the minimum

possible to make it more affordable for people. Even those who

could not afford to pay were given the service and were asked to

pay when they could; for Mr. Mousavi the effect of this divine trip

on people was more important than money... I personally wanted

to take my wife and my mother with me in year 2006 and did not

have cash at the time of the trip; so I decided to skip it myself. He

urged me not to do so and asked me to pay him whenever I could.

He even did not ask me to sign agreements and commitments, etc;

something that I found very generous and gentlemanly. I paid him

back after about 9 months and offered to compensate any charges

he paid for this (e.g., interest on credit card, etc.), but he refused to

accept even a penny more than my original charges. I am positive

that no other Hajj group offers or accepts this kind of arrangement

with the pilgrims.

, senior electrical engineer at JPL writes:

...during the Hajj ceremony, up to four million people from all over

the world pour into the city of Mecca and Medina.... I almost get

in tears when I recall all those instants that I personally noticed

how Mr. Mousavi and his family put themselves in danger and

risks to help someone lost or sick or in any sort of trouble peculiar

to Hajj...

Re: Seyed Mahmood Mousavi

September 19, 2008

Page 19

remembers:

On the last day of Hajj, one of the pilgrims, a very close friend of

mine, fell off the top of Jabal Al-Noor mountain in Saudi Arabia.

He sustained life threatening injuries... Doctors at the hospital

requested that someone stay back with our injured colleague, and

Seyed immediately volunteered. We were nearing the end of our

trip, and Seyed sacrificed his comfort and his schedule to stay back

with our fellow traveler…

, medical student at Michigan State University, writes:

We were given first class accommodations throughout the trip:

staying in 5-star hotels that were literally minutes away by foot

from the mosques, air conditioned buses, complete food

accommodations even when we were away from the hotel that we

stayed, and 24/7 accessibilities to any all amenities that we needed.

Such an operation does not come easy in a foreign country

especially at such a busy time as the Haj period but the Hejrat

organization through Mr. Mousavi ensured that we had nothing but

the best accommodations. This was in stark contrast to other

groups that were far away from the mosques, had difficulties with

food, and numerous other problems. Such organization comes with

exceptional ability to provide the best accommodations and I am

sure that Mr. Mousavi spared no expense in getting these things

done for us and he did not compromise price or convenience for

the people he was taking on this trip.

UCLA undergraduate student, states:

Recently, I went to Hajj with the group led by Mr. Mousavi. It

was the best experience of my life. The only reason the youth

were able to go on this trip was because he gave us a huge

discount…

lecturer in Ancient and Islamic Art and Culture at

comments:

The incredible spiritual experience can be marred by the frustrating

lack of organization... Mr. Mousavi... had anticipated all of this...

Re: Seyed Mahmood Mousavi

September 19, 2008

Page 20

spent many months ahead... speaking with hotels, bus companies,

etc., to make sure everything went smoothly... We were extremely

fortunate he took such good care of us.

Over one hundred character reference letters have been received, which vouch for Seyed

Mousavi. All are attached.

a U.S. military veteran and network administrator for the Aerospace

Corporation, writes:

Mr. Mousavi particularly helped some of the youth. These few

individuals were experiencing a lot of problems and were getting

into trouble, and they needed this special help and attention to save

them from themselves. I also had my share of troubled teenage

years. If I had had someone like Mr. Mousavi in my life, perhaps I

wouldn’t have gone astray in those years.

In the time that I have known him, whether it was from seeing him

at the mosque or from the two Hajj trips in which I joined him, I

have found Mr. Mousavi to be someone who cares about others

and particularly strives to give back to the American society. He is

a true Muslim, and a peace-loving person. He has helped many

American Muslim youth to be able to integrate within our society

and learn to work toward enriching the American society. In

addition, he has worked on instilling in the older generation,

American values of tolerance and acceptance. In fact, I later

realized that some members of the mosque were apprehensive of

my continued presence in the programs, because they didn’t know

me. It was Mr. Mousavi who kept telling them not only that they

should not be apprehensive of me, but they should respect me for I

had voluntarily chosen to serve my country in the U.S. military.

I am confounded and shocked by the idea that some believe Mr.

Mousavi is a danger to the country that I love, the country I

defended. I know better than to question a jury verdict, but it seems

confusing to think that this good man is in prison. Mr. Mousavi

Re: Seyed Mahmood Mousavi

September 19, 2008

Page 21

worked so hard to serve others that I cannot imagine him but

behaving in a wholesome and kind manner.

a young man who is pursuing his MBA degree, states:

He taught me to help, but help humbly. Mr. Mousavi was the

founder of the mosque, the main organizer, the most generous

contributor; however, many a night I would find him mopping the

floors and cleaning the toilets of the very mosque he established...

Mr. Mousavi’s actions show that he never considered himself

better than anyone, and that he helped others only for the sake of

helping.

high school student, wrote:

When I was younger I always viewed Mr. Mousavi as "the boss",

but there was one experience that changed my perspective of

Mr. Mousavi forever. It was a Saturday night at Masjid Al-Nabi

during the Holy month of Ramadan. It was crowded as usual, the

elders were listening to a lecture in the main hall, and the youth

were in the youth class. I came out of the class to go get a cup of

water and I saw Mr. Mousavi in the hall all by himself. He was

clutching his back, but I did not know why. When I was walking

back to the class I saw him bending down and picking up people's

shoes from the ground and placing them on the shoe racks. I asked

him if he needed any help. Although I saw pain in his eyes, from

having to bend down and pick up approximately 75 pairs of shoes,

he said no. He told me to go back into class and enjoy my youthful

years while they lasted. I no longer saw him as "the boss"; I saw him

as man who dedicated his entire life to helping his community.

undergraduate student at California State University, Northridge says:

On one occasion at the mosque … I was feeling extremely sick.

I … went to lie down on the couch … my mom came in and tried

to make me eat something but I refused… After some time, Mr.

Mousavi walked in, a bowl of soup and orange juice in hand, and

told my mom that he would take care of it. He sat with me on that

couch for close to an hour and spoon-fed me that soup because I

was refusing to eat it. He missed the whole program but he sat there

Re: Seyed Mahmood Mousavi

September 19, 2008

Page 22

until I had eaten all the soup and was feeling better… There are not

that many people who could run a center so efficiently yet have

enough time to greet every newcomer, notice the people who were

missing and to call them, or to stick with a stubborn sick girl to

make sure she finished her soup.

Dr.

writes:

In every encounter I have had with Mr. Mousavi, from his late

night administering of religious programs to his tireless work as a

Hajj-caravan leader, he has been to me like a compassionate father.

As someone who lost his father when he was 17, I cannot tell you

how much his warmth, kindness and sincerity have affected me… I

beseech you, your honor, with all my heart, to take Mr. Mousavi’s

life as a whole into account when you pass your sentence.

Seyed’s

son relates:

If my father wanted to just care about himself and make everything

for himself, he would have been good at it. If he had decided to

build a big business, I have no doubt that he would have been

tremendously successful… However, because of his caring about

everyone and everything around him, he didn’t take that route. It

could have been different for our family. We could have been

quite rich and quite comfortable. But, as a family, we are

accepting of the path he chose. In fact, I feel that we are stronger

because of the life he chose for himself and us, a life of

selflessness.

I don’t always agree with my father, but I do respect him. Not

every choice he has made in his life is the choice that I would

make. Not every action or every word is what I would agree with.

But I appreciate what he gave me, and the role model that he was

for me. He taught me to care, and to look beyond myself. He

taught me to care about others, not just myself and my family. He

taught me how to take others into consideration.

In my view, we never get to a point where we don’t need our

parents any more, and I certainly need my father. But, beyond my

own need, I see that the community needs him. For this reason,

Re: Seyed Mahmood Mousavi

September 19, 2008

Page 23

Your Honor, I respectfully ask that you set my father free again,

giving him the shortest sentence possible.

Seyed’s

daughter, writes:

In Iran, we used to live in a big apartment complex…The people

who lived in the floor below us were Iranian-Armenian Christians,

a minority in Iran. I remember for Christmas, although we did

not celebrate it ourselves, my father would make the time to stop

by their house for a cup of tea and wish them a Merry Christmas.

…. [He] said it is important for us to live together and let our

differences aside and be as one.

adds in her letter:

Because of the values I have learned from my father, I have done

many volunteer jobs. I have done clinical work; previously at a

dental office, and currently in a hospital. I have worked in the

Radio Lollipop for a children’s hospital, volunteered in the

Children’s Spine Foundation, and I go camping with cancer kids

for Camp Good Times for Ronald McDonald. I have helped

elderly people to paint their houses, and I have gone to food drives

to give out food to the poor. And I know that only this has

happened because I always had a perfect role model: my father.

states:

My father has taught me so much, by word and deed. I

remember one day in Michigan, my father had come to visit

me when I was away at the university. We were walking

together through the campus when we saw a commemorative

plaque on the ground in front of one of the buildings. My

father pointed it out to me and said, “This is what one should

do for life. It is not about gathering money, it is about the

legacy we leave behind.” The legacy that my father has

sought to leave is a better world through the help he has

provided to people.

Re: Seyed Mahmood Mousavi

September 19, 2008

Page 24

But sadly, unlike all the fortunate people who had my dad to

help them, I don't have my dad to help me in these difficult

days. My support is gone.

I feel regret for the years I lost. I remember once he told me

about a project that he was very excited about. I rolled my

eyes at him, and felt it a useless project. I feel horrible about

it. I want him to come back to tell me about his projects, and

this time I won't roll my eyes or mock him.

, Seyed’s wife, states:

In the past twenty-nine years, we rarely fought. We would

disagree sometimes, of course, but we always tried to work out our

differences through peaceful discussion, rather than damaging

arguments. We built a good life together. I feel his absence

terribly; I feel that half of myself isn’t here. Without him, running

the home and caring for the mosque is difficult. I am used to

having him at my side to help me. Without him, I have no

emotional support, and my children and I are without any financial

resources.

I constantly pray that he will return home, and the children and I

will be brought out of this terrible loneliness and insecurity. Your

Honor, please return my husband, the father of my children, back

home where we need him.

In arriving at a just and appropriate sentence for Seyed Mousavi, his lifetime of caring for

others bears consideration. His friends describe a man with a passion for religious tolerance and

the performance of tangible good works. As letters written on his behalf indicate, the

contributions Seyed Mousavi has made to the American Muslim community are manifold. His

most lasting accomplishment may be the founding of a mosque that accepts the English language

and a more liberal view of Islam. In so doing, he created a bridge between traditional Iranian

parents and their American-raised children. Many of these young people who have gone on to

universities are only now realizing how rich this gift was.

Re: Seyed Mahmood Mousavi

September 19, 2008

Page 25

Seyed Mousavi has personally helped young individuals to stop making destructive

choices and find a positive direction in their lives. He has willingly spent countless hours

counseling people, trying to reunite families and husbands and wives. He has expected his

family to make these same sacrifices just as willingly, which has been tough on them at times.

He is a man who has always answered phone calls in the middle of the night. He lives the role of

a clergyman, available at all hours.

There is no sign that Seyed Mousavi has ever been motivated by personal material gain.

The house his family lives in is simply furnished and in need of repair. His children have all

required scholarships and financial aid in order to get their degrees. Seyed Mousavi has

dedicated the greatest portion of his time, energy, and vision into building the Al-Nabi mosque.

His union with this religious place is the chief legacy or inheritance his children stand to receive

from him.

Seyed Mousavi has been convicted of tax offenses and violations of the IEEP A which

seem technical and regulatory in nature. The Government conducted a thorough vetting of this

man's life, and it seems safe to say that their investigation did not

turn

up illegality of a geme or

degree they were originally expecting to find. Whatever else can be said about Seyed Mousavi,

it is clear that he is singularly devoted to his family and community, that he has enriched the

lives of nearly everyone who has had the opportunity to interact with him, and that he is not a

bigot or a zealot. It is hoped that the cumulation of his many good deeds and personal acts of

kindness may weigh in his favor, and that the Court may factor the above mitigating

circumstances into the complex human equation of sentencing.

If there are any questions regarding the information in this report, please do not hesitate

to contact us.

Respectfully submitted,

Foongy Lee

John Brown

enclosures