Below is the affidavit of Hassan Almrei, followed by an expert opinion affidavit (whose author cannot be revealed by court order). Various portions of both affidavits have been expunged due to safety concerns raised by bith affiants.


IN THE MATTER OF an application by the Minister's

officials for an opinion under Section 53(1) of the

Immigration Act against Hassan Almrei




I, Hassan Almrei, of 111 Disco Road, the Toronto West Detention Centre, in the City of Toronto in the Province of Ontario, in solitary confinement for more than thirteen months, SOLEMNLY DECLARE AS FOLLOWS:

1. I am the subject of the application by the Minister's representatives to the Minister, requesting that he find me to constitute a threat to the security of Canada. As such I have knowledge of the matters set out below.

2. I provided a statutory declaration, dated February 3, 2002, in support of my request that the Minister find me not to be a danger to Canada and to conclude that I am at risk of torture if I am returned to Syria. I understand from my counsel that Immigration officials are not intending to return me to Saudi Arabia, but if this were to occur, I would be at risk of torture in that country as well.

3. I understand that immigration officials are taking the position that I would not be at risk of torture or persecution if I was returned to Syria. I would be at risk of torture if I am returned there and I am very frightened about this.

4. I wish to outline my past background so that my history is clear to the Minister, as I did not have the opportunity to do this at the hearing before the Federal Court judge into the reasonableness of the security certificate imposed on me. I understand from my counsel that this process is protected from public disclosure without my consent. xx

5. As well, I wish to clarify the facts about me. I had met with two CSIS officers on October 9, 2001 in the offices of my present counsel, Barbara Jackman. These officers asked me questions about my background and as I was afraid, I withheld information from them and from my lawyer. I withheld information principally in respect of two matters: one was the help that I provided to Nabil Al Marabh in obtaining a false passport and the other was the fact that I had been in Afghanistan. I was afraid that if I told the officers about helping Al Marabh get a passport that I could face criminal charges. Further, I was afraid that if I told the officers that I had been in Afghanistan, that they would believe that I was a member of Al Queda, which I am not and never have been. I believe that this may be one of the reasons why the security certificate was issued against me.

6. I was born on January 1, 1974 in Syria and am a citizen of that country. My parents and my siblings are all Syrian, but all, except for one brother and one sister, live in Saudi Arabia. My brothers are xxxx, born xxx x, xxxx, a sales clerk; xxxx, born xxx x, xxxx, a medical doctor; xxxx, born xxx x, xxxx, a university student; xxxx, born xxx x, xxxx, a sales clerk; xxxx, born xxx x, xxxx, an accountant; and xxxx, born xxx x, xxxx, a university student. xxxx was in Syria and is now in Saudi Arabia. The other brothers live in Saudi Arabia, although xxxx is studying in Jordan. My sisters are xxxx, born xxx x, xxxx, married and a housewife; xxxx, born xxx x, xxxx, married, a housewife and a teacher; and xxxx, born xxxx x, xxxx, a student in middle school. xxxx lives with her husband in Lebanon. She is a university graduate, I believe. My other sisters live in Saudi Arabia. My youngest siblings were born in Saudi Arabia, but are not citizens of that country. They take their citizenship from my parents, who are Syrian. My family members who are in Saudi Arabia are there on temporary residence permits.

7. My father left Syria, about 1980, because he was involved with the Muslim Brotherhood and was at risk of being detained and tortured. My dad was not involved in any military activities. He and two of his brothers had been previously detained and tortured. He was able to flee but one of his brothers and his son were detained and spent ten years in prison in Syria. My mother, who returned to Syria, in 1995 and had difficulties there, as I explain below, was told that my father had been convicted in absentia and had been sentenced to death by the Syrian authorities.

8. My father was able to obtain temporary residence in Saudi Arabia because he was able to obtain a job there as a teacher. He was able to bring my mother and the rest of us to Saudi Arabia, I believe, in 1981. My father and my siblings who are in Saudi Arabia are on temporary resident permits, as I was when I lived there, which must be renewed from time to time. I had hoped that I would be able to be landed in Canada, be able to settle here and then sponsor my parents for landing here. My father is getting older and some day will not be able to renew his temporary residence because he will be too old to maintain a teaching contract. At that point he, and those in our family dependent on him, may face removal to Syria. I very much wanted to be able to provide my parents with a secure and safe country in which to live.

9. We lived in Dammam, Saudi Arabia from then on. I attended school there and graduated from the Dammam High School in 1992. I worked as a self employed person part time while I was in high school and then full time later. After I graduated from high school, I did not work for awhile, then I was able to get a job with a charitable organization for several months before I started a full time business in the sale of honey and perfumes xx. Even when I was not working, I sold oud, an incense, from my home.

10. I told the CSIS officers who interviewed me on October 9, 2001 that I traveled to Thailand, Turkey, Bahrain, the UAE, Yemen, Pakistan and Jordan. I misled the officers because I denied that I had been in Afghanistan. My interview was on October 9, 2001 and I was very much afraid that, with the fear that had developed after the attack on the World Trade Centre on September 11, 2001, the officers would automatically believe that I had been part of Al Queda and would put me in jail. In the end I was put in jail anyway and have been held in solitary confinement for more than a year.

11. I have traveled to a number of countries. I cannot remember exactly all the dates, but have tried to be as accurate as I can in remembering the dates. 1990 was the first time I went to Pakistan, intending to go to Afghanistan. At this time the Saudi government was encouraging youth to go there. In the mosques, young men were being strongly encouraged to go to fight the 'infidels', i.e. the communist government that took over when the Soviets left. There was open fund raising in Saudi Arabia for the fight. It was my understanding that even the United States supported the fight against the Soviets and then the communist government that the Soviets left in place in Afghanistan when they departed. There were flights every Tuesday and Thursday to Islamabad, Pakistan. The Saudi government gave a 75% discount to anyone who was going to help in the fight the Soviets and then the pro-Soviet communist government in Afghanistan. I supported the fight against the Soviet regime in Afghanistan and against the communist government left in the place of the Soviets when they left. Bin Laden was not a big name, that I knew of at that time, and I did not support him. I try to be a devout Muslim, but I am not a fanatic or an extremist. I am the only person in my family who went to support the fight against the Soviets and the Afghani pro-Soviet government. xx

12. The first time I went to Pakistan, I remained for about 27 or 28 days. I stayed in Peshawar as I contracted malaria. I had wanted to go to Afghanistan, but could not because I was very ill. I returned to Saudi Arabia because of this. I had to take blood tests through the Ministry of Health in Saudi Arabia. I was given a kit to test my blood over a period of several months. I suffered the effects of malaria for years. Each time I went to Pakistan, I got ill again.

13. Several months later I returned to Pakistan, and this time I did go into Afghanistan. I met a man on the plane, named Saladin. He told me that the Arab camps had a lot of problems, eg. for every ten Arabs there were eleven chiefs. He told me that if I went to an Afghani camp, instead of an Arab camp, then I could learn another language, as they are Farsi and Pashtun speakers and there were not so many problems in the camps. He said I could help by teaching the Afghanis the Koran, which I know very well. After I landed in Islamabad, I did not board the bus which was there to pick up the Arab youth who had come to participate in the war. Instead I took a taxi with Saladin to Babhi, a small town, close to Peshawar. This town and its camp were under the control of a commander named Sayaf. I remained in this town for about two to three weeks. We were waiting for a truck to come to take us to Afghanistan. When it did arrive, we were taken to a camp in Afghanistan, on the outskirts of Jalalabad. Saladin stayed a few weeks and then went back to Saudi Arabia. He had been there many times and knew many people there.

14. There were many camps in the area. Each camp was under a different leader. The camp that I was in was one under the command of Sayaf and it was only Afghanis, but for me and Saladin. I learned Farsi as it was the language spoken. I remained there for about four or five months. I had no contact with Arabs during this trip, but for Saladin. I was sick on and off through this time. I did not go to a camp to go through training, but remained in the camp in which I had arrived, which was not a training camp. The only training which I received was basic information on how to handle an AK-47, which is something everyone there had to know because of the war. I was issued an AK-47, but never used it. I spent my time there as an imam, leading prayers and teaching the Koran. I was an imam because I had memorized the Koran. When we were young, my father taught me, my brothers, and my two sisters the Koran and had us memorize it. This was a camp of Afghani mujahadeen. Sayaf and those under his command were against the communists. It was a mixed ethnic Afghani group, but the majority were Pashtun. Later, when the Taliban formed, I was aware, as I was there in Sayaf's camp again, that they were opposed to the Taliban.

15. I returned to Babhi several times from the camp in Afghanistan, for a change and to contact my father. It was my father who told me to come back as he said that the airports might be closed because of the war. I think that my father was worried that I was staying too long there and wanted me to come home. As well I was still sick. I had lost over forty kilograms from being ill. I returned to Saudi Arabia.

16. I returned to school and it was during the summer vacation about a year later that I returned to Islamabad. I went to Babhi again and remained there for two months during the summer months. I only went to the camp near Jalalabad for two weeks. On this trip I knew people already and was taken around to the homes of several Afghanis. I had some respect because I was an imam and read the Koran well. I visited several Arab camps, but did not stay at any of them. There were skirmishes during the time that I was there between the rebels and the government forces, but I was not involved in them.

17. It was during that trip that I bought twenty kilograms of honey and shipped it back to Saudi Arabia. It was easy to buy honey in bulk from the producers, so it was very cheap. I bought it as gifts for friends and family. I also gave people samples after I returned to Saudi Arabia.

18. At the end of the summer vacation, I returned to Saudi Arabia to complete high school. It was towards the end of that year that I opened a little perfume stall and worked at it in the evenings part time, as I was in school during the day. I rented a small room in the library and sold perfume from it. I ran it for three or four months and then sold it. I had to sell this little part time business, as I was operating it illegally. It is not possible for non-Saudi nationals to own businesses there and I knew that some Saudis, who saw that my business had the potential to be quite successful, were pressuring the landlord to report me. So I sold the business because I knew that it would be closed down, if the landlord reported me.

19. After I completed high school, I was unemployed for awhile, but was selling oud from my home. In 1992 I was able to get a job with a charitable organization, the Muslim African Agency, which was a registered charity in Saudi Arabia. I only worked there for a few months. The charity was helping orphans, digging wells and helping to build schools. I worked in the office. I left this work because I was able to xx front a business in the wholesale distribution of perfume. xx

20. By this time the war in Afghanistan was over, but there was still factional fighting going on. People were spreading the word that a new jihad was developing in Tajikistan against the Russians.

21. I traveled to Pakistan again in 1994, I think in about November of that year. I went back to Sayaf's guest house in Babhi, where I knew people. I heard while I was there that Arabs were traveling to Tajikistan under the command of Khatab, who was later a commander in Chechnya. I understand that he is dead now. I traveled to his camp, although it was dangerous to travel there through Afghanistan because of the factional fighting. I went to Khunduz and stayed there for about a month. There were many Tajiki refugees fleeing there and I became very aware of the problems that they faced. It was very difficult to get access to the Tajik front and so I decided to return to Saudi Arabia. My residence permit there was to expire soon and I had to return to renew it. When I returned to Saudi Arabia, I approached the charitable organization, Al Haramin, and asked them to help fund a girl's school. I was not aware that there was any connection between this charity and Bin Laden. If there was it was not public knowledge and I did not know of it. The charity was registered in Saudi Arabia. In Khunduz I became aware from some of the Tajikis that there was a need for a girl's school, as there was no school for them. My request was supported by some of the clergy, so I was able to get a grant of 120,000 rials which I took to the management of the refugee camp, who were Tajikis. I know the school was established, as I returned there and saw it. The man who was in charge of establishing the school was an Arab named Mansour, who was working for a charity helping refugees. It was his wife who ended up being the supervisor at the school when it was first established. After that a Tajiki woman took over.

22. I returned to the camp in Khunduz and stayed there for about five more months. This was sometimes toward the middle of 1995, as I returned again to Saudi Arabia at the end of 1995. When I was there I remained in the camp for most of the time. I did travel twice to Tajikistan. The first time I went along with a party scouting Russian positions, although it was only a scouting party and did not engage in conflict. There were about twenty of us, both Tajikis and Arabs. We went to the border, but did not go into Tajikistan. I was the only person that time who was not armed. I was not sure of the strategy of the Mujahadeen leadership at that time, as I had the impression that they were pretty disorganized. They did not really want to fight. I went another time to the border. This time we were able to cross over the river into Tajikistan and I remained there for about two weeks and helped set up a camp. I was given an AK-47 at that time, but we did not encounter any Russians. The gun was for protection, in case we were attacked trying to establish the camp. The area we were in had no villages or people around. It was empty.

23. I returned to Saudi Arabia at the end of 1995. I went to Yemen on my way back and stayed there about nine days. I bought honey while I was there, again because I could buy it from the producers, however it is more expensive than honey bought in Pakistan. I bought about twenty kilos of it. I was a tourist in Yemen. I visited the sights and bought the honey. I went there because I had not been there before.

24. I went back once more to Pakistan. This was in 1996 or 1997. I went to buy honey and to bring another grant from Al Haramin of 10,000 rials for repairs to the school. My main purpose was business. I met Mansour in Peshawar. He gave me a video of the school, which I passed on to the charity when I returned to Saudi Arabia. This was my last visit to Pakistan.

25. I returned to Saudi Arabia and continued my business. I was with a different partner. xx The business was sold in about the middle of 1997. I traveled to the U.A.E. for a short time to buy oud and then returned to Saudi Arabia.

26. I thought that I was under surveillance by the Saudi security. Although the Saudi government had encouraged and financially supported young Arabs to go to Afghanistan to support and participate in the fight against the Russians and then the communist government that they left in power there when they pulled out of Afghanistan, it changed its views of those who had gone there. They later arrested many young men who had gone to Afghanistan. I was never jailed.

27. I do not know if the Saudi government gave information to CSIS about me. They know that I went to Pakistan and Afghanistan because they were encouraging young people to go and from the questions they asked of my business partner, I know that they are aware that I went. As well, I got the 75% discount, so they had my name. As well, they are aware that I helped pilgrims from Chechnya in Mecca when they came there. I had nothing to do with Chechnya. I had received news updates from Khatab by fax. I had kept in touch with Khatab, a couple of times, but not after I left the Middle East. I had always understood that Khatab did not get along with Bin Laden. He did not like religious extremists. The Saudi security service knows of my activities, I am sure. If the Saudi security officials did provide information to CSIS, I would not expect it to be accurate. They never talked to me and never questioned me about my beliefs or my activities. I think that they assume that the young people whom they encouraged to support the fight against the Soviets, are extremists. This is just not true. I am not an extremist and many of the others who went are not extremists either. At the time that I went, people were not going to support Bin Laden. He was not to me, in any event, a big figure or even seen as a big leader. I went and many others went because we were opposed to the Soviet occupation of Afghanistan and later were against the pro-Soviet government which took over. I did not know that the Taliban would end up being in control of Afghanistan or that it would be so restrictive in its views of Islam. I was not even in a Taliban camp; there was no Taliban then. I was in Sayaf's camp and later he fought the Taliban. I do not even believe in the restrictions that the Taliban imposed on women in Afghanistan. My father treated me, my brothers and my sisters the same. We all got an education. He taught us all the Koran. My Islam does not exclude women. Further, my beliefs in Islam do not include killing innocent people.

28. I left Saudi Arabia in April, 1998 for Jordan. Our family have relatives there. I had some difficulties in Jordan, because they investigated me, I think because I had a Pakistan visa in my passport. I was looking for a place to go, as I was afraid to return to Saudi Arabia and was afraid to be sent back to Syria. While I was in Jordan, I traveled to Thailand and purchased oud, an incense, which I carried back with me to Jordan. I think that this was in the late summer of 1998. I stayed less than two weeks, at the Marriott Hotel, while there. My purpose was to have a short time to relax and to buy the incense in order to be able to sell it and have some money to travel. I sent the incense to my brother. Thailand is a popular spot for vacations for persons from the Gulf countries. I did make one friend, a Palestinian man, who lives in Thailand. I kept in touch with him afterwards.

29. I came to Canada on January 2, 1999. I entered as a visitor as I did not know to claim protection as a refugee at the airport. I had stayed at a hotel then found a basement apartment. I asked about how to make a refugee claim from other Arabs at the mosque. I claimed protection as a Convention refugee on January 13, 1999.

30. I had a hearing before the Refugee Division on May 25, 2000. The transcript of my hearing and a copy of my Personal Information Form has been provided by Immigration officials as part of the package which is to be given to the Minister. I outlined my claim, but as can be seen from the PIF and the transcript, I omitted information. I did not disclose the details which I have outlined above about my travels to Afghanistan and indicated that I had gone to Pakistan to buy honey. As well, I told the Refugee Division that I had destroyed the U.A.E. passport with which I traveled to Canada. I had not destroyed it, but it had expired. Immigration officials came to my place and told me that they were looking for a Saudi man. They searched my place and found the passport. They did not show me a warrant to search, but I did not know that I could tell them not to search my place without a warrant, so they just went ahead and searched. I did not stop them, rather I cooperated with them. They asked me about the passport and I said that it was mine. I had not destroyed it because I was afraid that if my refugee claim was rejected I might need to use it to travel and find another country in which to live. After I was recognized as a refugee, I forgot about the passport. I was not detained at that time, even though the immigration officers found the passport.

31. I was recognized as a Convention refugee on June 2, 2000 and applied for landing in November, 2000.

32. I was aware that CSIS officers were talking to people in my community about me. Then after September 11, 2001, I became aware that they were asking questions again about me, as a friend told me this. This friend told me that the CSIS officers had told him that I was a dangerous person, even though they had not talked to me at all at that point. I became very scared because I had been in Afghanistan, and as I indicated above, I was afraid that if I told the CSIS officers about my travels there, they would believe that I was part of Bin Laden's network. I never met Bin Laden. Further, the CSIS report against me indicates that I was preoccupied with security. Certainly after September 11, 2001 I was paranoid because of the fact that it was being reported that the destruction of the Trade Centre was done by Muslims and I am a Muslim and I had been to Afghanistan. I became more worried after Nabil Al Marabh was arrested because I knew him. As well, I learned CSIS officers were asking questions about me. I do not believe that I was preoccupied with security before, but then I am not sure what the CSIS officers think is a preoccupation with security. I came from Syria during very difficult times for my father and grew up in Saudi Arabia, which is not like Canada. I think that anyone who lived with my experiences would be concerned; it like a second nature to be cautious. In any event, I don't think that I was secretive.

33. The CSIS report against me indicates that I told the officers that I had no other name but my own. I did not tell the officers that I have a 'respect name', Abu Al Hareth, given to me as a child, which is common in the Muslim culture. I do use this name, and afterwards realized that I was given it and should have told the CSIS officers about it. I did tell the RCMP about this name. It is not a secret name. My friends use it.

34. The CSIS officers asked me about Nabil Al Marabh and I was honest in my answers about my knowledge of him. He is the man who was detained by the American authorities after September 11, 2001 in Chicago. From what I understand, although he was detained on the grounds that he was suspected of having some involvement in Al Queda, no charges were ever laid against him and no removal proceedings were brought against him on this basis, only on the basis that he had remained illegally in the United States. I knew him in Canada. I believe I met him at his uncle's shop. I cannot say that I was a really close friend of his, but I saw him from time to time and when he was detained by immigration officials in the Niagara Falls area, I went with his uncle to see him there. I became aware that he was not a Canadian citizen, as I had originally assumed. He came to my apartment sometimes and he did use my computer and phone. I met him in Khunduz, but he was not a friend. We did not even talk then.

35. CSIS has asserted that I was part of a forgery ring. The passports which I received from the Muslim Brotherhood are given by that organization to Syrians who cannot get passports from Syria because of a connection to the Muslim Brotherhood. I was not involved with them at all, I only got the passports from them. I purchased a false UAE passport to come to Canada. I was given a Kuwaiti driver's licence and later obtained a Bahrain bank card with this passport all in the same name. This was to make my false identity appear more authentic. Passports are fairly easy to purchase in the Middle East, and I only bought the passport to travel to Canada. I did not use it again. I know that many other refugees from many countries have come to Canada on false passports, as this is often the only way to be able to get to a safe country. I was refused a visitor's visa to come to Canada. One other passport which I had obtained was a Yemeni passport. I had obtained it in 1995 because I wanted to avoid having to get a passport from the Muslim Brotherhood. I did not use it, because it was not in my name, as I had thought it would be. Instead I got the Muslim Brotherhood passport. I did help Nabil Al Marabh in obtaining a false Canadian passport. Nabil told me that he really wanted to see his mother, as she was ill. He said that he had not seen her for twelve years. I said that I would help him. An Arab man that I know gave me the number of a man in Montreal. I got Nabil the passport from the man in Montreal. I was not working with the man that made the passport for Nabil. I paid for it only with the money that Nabil gave me for it and I kept a share. This was the only false passport that I helped someone get. There were a couple of other times when I was going to help some others in getting false documents, but I did not follow through on this. I did talk to people who wanted to get false documents, but I did not help them. I am not part of a forgery network.

36. I was asked by the CSIS officers about Hashim Al Taha. I do not know this person, but when I applied for a visitor's visa I put the name down as it was given to me by the man that helped me with filling out the form. He called someone on a cell phone and then gave me that man's name and an address for him.

37. The RCMP seized my computer and other things from my place when they searched it. I understand that they did have a warrant, but I have not seen the affidavit which they used to support the request for the warrant. At my security hearing, the lawyer for CSIS and Immigration provided the Court with a book of pictures taken from my computer. The only thing in the book was pictures. I believe that the pictures were selected from news articles which I had read on the Internet. I used to check Arab new sources, as well as English ones, like the BBC. The articles often had pictures of people. I believe that the book of pictures was meant to be misleading as I was not collecting pictures of people like Bin Laden, but was reading the news. There is one picture which I was keeping and that is a picture of my father which was sent to me using the Internet. I went to Chechnyan and Palestinian web sites on occasion as well and the pictures of Khatab may be taken from the Chechnyan web site.

38. I wish to explain as well my circumstances at the time that I was detained. I had claimed that I was earning, I think, over $50,000 on my tax return. I did this because I really wanted to sponsor my parents to come to Canada once I was landed, as they are not secure in Saudi Arabia. However, I did not earn a lot of money, nor have a lot of money and in fact owed money to my friends, as I had borrowed from them. In January, 2000, I purchased a little restaurant business, Eata Pita. It cost $22,000. I paid down $15,000 and I borrowed money from a friend and from my brother in Saudi Arabia. It was not successful I sold it for $18,500 in August, 2000. I lost money because there was also about $10,000 outstanding in debts from the business. When I sold the business, I still had not completely paid off the purchase price, nor the debt I incurred when I borrowed to buy it. I was very depressed after I had to sell the business and for awhile I did not work. I worked for a friend for two months at the end of 2000, when he traveled abroad because of his father's death. He gave me an old van for working for him, and so I was able to work doing deliveries to restaurants three or four days a week. I did not make a lot of money, only $200 to $250 a week, but I was hoping that when I got my landing, I would be able to get a loan and start a small business again. I borrowed money from friends as I was always behind in covering my expenses. I could not even afford car insurance. I drove at times without insurance, running the risk that I could be charged with driving without insurance. My cell phone was cut off because I was behind on the payments. I was late on payments on my friend's credit card, and since I have been detained have not been able to make any payments on it. Just before I was detained I got a car and was looking for work as a delivery person that would pay me more money.

39. I understand fully the contents of my declaration. I have read it and have had my lawyer read it to me. I have been reading in English over the last year, as I am permitted to read the newspapers.

40. I make this declaration, for no improper purpose, in support of my request not to be deported to Syria, or to Saudi Arabia, believing it to be true and to be of the same force and effect as if given under oath.


City of Toronto, in the Province of

Ontario, this 10th day of November, 2002.






IN THE MATTER OF an application by the Minister's

officials for an opinion under Section 53(1) of the

Immigration Act against Hassan Almrei




I, xxxx, in the xxxx, in the Province of Ontario, SOLEMNLY DECLARE AS FOLLOWS:


1. I am a Canadian citizen. I have been asked to provide a declaration outlining the risks that Mr. Almrei would face if returned to Syria. I do not know Mr. Almrei. I have been advised of the basic the facts about his case.

2. xx

3. xx I have remained aware of the situation in Syria, the country of my birth. xx

4. xx students at the university were arrested, and tortured and some of them were executed. There was no reason for this, but for these students expressing their criticisms of government actions. Non-governmental organizations, such as student associations, professional associations and other such groups, were all canceled and the government created their own bodies. Some students criticized this and were detained and killed for this. Other students supported the Muslim Brotherhood and were detained merely for praying on Fridays. Yet other students did not even support the Muslim Brotherhood, but were detained, tortured and killed for being suspected of supporting the Muslim Brotherhood. The Syrian government had informers in the community, including in the university. Even students who were not public in their criticisms could face detention because informers might overhear private conversation critical of the government. xx It is hard to describe the atrocities that occurred in Syria. xx tanks pulling the bodies of students along the street and many young people left for dead. xx young people who were released. They were not allowed to talk about their experiences as they would be detained again. Many of them were physically maimed and many were mentally damaged. Some never recovered. Some were delivered home dead. xx Parents did not know what had happened to their children, until they were returned maimed or dead or mentally destroyed. xx the terror that the Syrian government inflicts on people in order to maintain itself in power. This terror continues to the present time.

5. xx

6. Although there was some lessening of restrictions in Syria in about 2000 after the president died and his son took over, these have largely been withdrawn. The changes were cosmetic in nature. When the government realized that there was strong popular dissent, which was being expressed, the government cracked down again. I can see little or no change between the present government and the past government. I am aware that some members of the Muslim Brotherhood that had been jailed for many years, have been released in recent times. However, some of these people were again detained and certainly none of them are permitted to express their beliefs without again running the risk of being detained again.

7. I understand that Hassan Almrei's father was a member of the Muslim Brotherhood. I understand that his mother and brother returned to Syria in 1995 and were detained, that his brother, who was quite young at the time, was released, and his mother was released several months later, that his mother was able to leave Syria to join his father in Saudi Arabia, and that his brother remains in Syria and is not permitted to leave.

8. I do not believe that the fact that Mr. Almrei's brother was not kept in detention means that Mr. Almrei will face none or few problems in Syria. First he is an adult now, not a young child. Secondly, it is clear from his past activities in Pakistan and Afghanistan, that he has been an Islamist and this would be viewed by the Syrian government as an indication that he is even worse than the Muslim Brotherhood. The Syrian government backed the Soviet Union during the war with Afghanistan. Thirdly, he has been publicly alleged to be a supporter of Al Qaeda. Syria purports to be a secular state. It has become, I believe, an anti-religious state in its zealousness not to be a religious state. It has a long history of persecuting those who are very religious, such as the Muslim Brotherhood, and Islamists. Syria does not support Al Qaeda and I believe sees it as much of a threat as the Muslim Brotherhood has been seen in the past. Fourthly, Mr. Almrei never completed his military service in Syria. He can face imprisonment for this alone, even though he did not live in Syria. I believe that it could be used as an excuse to detain and torture him. Mr. Almrei faces certain detention in Syria, certain torture and likely execution, if he is returned there. I cannot emphasize how strongly I believe that this is his fate in Syria. The Syrian secret service is brutal and vicious. It tortures and kills without compunction. I do not believe that it matters to the Syrian government that it kills and tortures innocent people, because its system can be characterized as the reverse of the democratic principles existing in Canada. Here we believe that it is better to have safeguards to protect the innocent, so that it is better that a guilty person be set free than that an innocent one be convicted. In Syria, the rule is that it is better to kill the innocent in the hopes of catching a guilty person.

9. Mr. Almrei cannot expect to have a fair trial in Syria. Syria does not have fair trials. People are tortured to extract confessions and many are murdered without trial.

10. xx I understand that Mr. Almrei traveled to Pakistan and Afghanistan during this time. I can confirm his statements about the Saudi government as well as several other Middle Eastern governments, although not Syria, fully supported the fight against the Soviets and did actively encourage young men to go there to fight. There was public fund raising for the war effort and the mosques were encouraging young men to go. I was aware that the United States did support the war against the Soviets and later against the pro-Soviet communist regime in Afghanistan. I understood from that time that many young men went to the front in Afghanistan, many of them because of the active government and religious encouragement and just as many out of a feeling of guilt for not helping when it was so clearly put that they should help. Further many young people contributed financially because they were embarrassed not to provide support.

11. Further, I can confirm that Mr. Almrei's ability to obtain passports through the Muslim Brotherhood is plausible. The Muslim Brotherhood is a large organization and has branches in a number of countries. I understand that they do have the means to obtain passports for individuals and do this for people who are not able to obtain them from the Syrian government because of their association with the Muslim Brotherhood. The Muslim Brotherhood is very popular because they are seen as an organization that provides social services to people and because they are seen as clean and not corrupted.

12. I am providing this declaration to outline the concerns about Mr. Almrei being returned to Syria. I understand that this proceeding is confidential and not publicly available. I do not want my identity made public or any of the information which I have provided that would identify me. xx

13. I make this declaration in support of Mr. Almrei's request that he not be removed to Syria and for no improper purpose.


City of Toronto, in the Province of

Ontario, this 8th day of November,


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