To the Honorable Nablus Deputy Prosecutor

by Dr. Abdul-Sattar Kassem

The Accused:

Dr. Husam Abdel Halim, in his personal capacity and as head of the board of the Workers’ Union at An-Najah National University;

Dr. Yousef Ghoneim, in his personal capacity and as a member of the board of the Workers’ Union at An-Najah National University;

Dr. Basel Mansour, in his personal capacity and as a member of the board of the Workers’ Union at An-Najah National University;

Mrs. Sarab al-Sayeh, in her personal capacity and as a member of the board of the Workers’ Union at An-Najah National University;

Mr. Nidal Jaradat, in his personal capacity and as a member of the board of the Workers’ Union at An-Najah National University;

Mr. Maher Fattash, in his personal capacity and as a member of the board of the Workers’ Union at An-Najah National University;

Mr. Sabri Nasser, in his personal capacity and as a member of the board of the Workers’ Union at An-Najah National University;

Mr. Iyad al-Bibishawi, in his personal capacity and as a member of the board of the Workers’ Union at An-Najah National University;

Mr. Suheil Saliha, in his personal capacity and as a member of the board of the Workers’ Union at An-Najah National University;

Mohammad Daqqa, in his personal capacity and as head of the Student Union Council at An-Najah National University;

Mr. Musa Abu Diyeh, in his personal capacity and as head of the movement’s office at An-Najah National University.

Subject of the complaint: Defamation, slander, denigration, incitement, and threats, together with a civil claim in the amount of one million Jordanian dinars.

Facts of the Complaint

On August 23, 2011, the accused issued a statement against the complainant and distributed it publicly, in print and electronically over the internet. The statement contained expressions of slander, defamation, fabrication, and abuse, of which I mention the following:

…of An-Najah National University, by unleashing the fire of his black hatred against everything connected to it and belonging to it."

Fabricating baseless claims and exposing the complainant to danger, as the statement says: “And he deliberately portrayed the university’s students as a fifth column working in the service of collaborationist agencies….” Such statements are liable to incite students and the security services against the complainant, and may lead to physical assault against him.

Leveling security accusations that expose the complainant to danger with the Zionist enemy, such as the claim that he moved from one organization to another.

Slander in claiming that the complainant fought only with insults and accusations of treason.

Slander and defamation concerning the complainant’s performance in the classroom, and conspiratorial insinuations about the students.

Abuse and threats through violent language such as: “The silence of the union and student institutions at An-Najah National University over Dr. Abdul-Sattar Kassem’s excesses has reached its limit on its own. His branding as traitors and cursing of the university community, in service of the exchange of his financial and political gains, must be brought to an end. And his attempt to tamper with the fate and future of the most important scientific and educational institution in Palestine must stop immediately and forever.”

The language of the statement is more like a declaration of war, and the steps it announces it will take, stipulated at the end of the statement, place the complainant’s life in danger.

The actions of the accused constitute the crime of defamation, slander, and denigration in violation of the Penal Code, as well as an explicit threat to cause the complainant harm. Their actions have caused the complainant great moral and material damage, and have affected his academic future, his work, and his private life.

Request: For all the foregoing, the complainant requests that Your Honor summon the accused and take the necessary legal action.

Attachments: A copy of the above-mentioned statement is attached.

With utmost respect,

Abdul-Sattar Kassem, Prof.

Source: Translated from the original Arabic, “لدى معزة وكيل نيابة نابلس المحترم” by Dr. Abdul-Sattar Kassem.