Larry Klayman, the former Justice Department lawyer and founder of Judicial Watch and Freedom Watch, has filed a civil complaint accusing President Obama and other officials of “facilitating terrorism” by refusing to cut off travel from Africa’s Ebola zones to the U.S.

The complaint filed in federal court in Washington charges Obama and his administration are “knowingly and willfully providing material support and aid to international terrorism and facilitating terrorism by allowing unrestricted entry of persons from countries experiencing outbreaks of the Ebola virus and adamantly opposing efforts, including calls from the U.S. Congress, to restrict travel from outbreak countries.”

The complaint from Klayman, who recently filed legal paperwork to try to get Obama deported, names Obama; Anthony Fauci, director of the National Institute of Allergy and Infectious Disease; Tom Frieden, director of the Centers for Disease Control; Health and Human Services Secretary Sylvia Burwell; and Jeh Johnson, director of the Department of Homeland Security.

Klayman, a longtime foe of the Washington establishment, says the defendants “know or should know … that the probable consequences of their actions are to facilitate the spread of the disease and to provide opportunities for germ warfare terrorism.”

He cites Obama’s criticism from the Senate floor in 2005 of President Bush for his handling of the avian flu.

Obama said the “failure to prepare for emergencies can have devastating consequences.”

“We learned that lesson the hard way after Hurricane Katrina,” the then-senator told his colleagues. “This nation must not be caught off-guard when faced with the prospect of an avian flu pandemic. The consequences are too high. … The question is will we be ready when that happens? Let’s make sure that answer is yes. I urge my colleagues in the Senate and the House to push this administration to take the action needed to prevent a catastrophe that we have not seen during our lifetimes.”

The complaint asks for a jury trial and compensatory and actual damages of at least $75,000, fees and other compensation, as well as an injunction banning travel to the U.S. from infected “African, Muslim and other nations.”

Klayman charges the Obama administration has enacted “ineffective so-called screening” procedures at a handful of American airports.

He calls it “a reckless plan to open the door not just to defendant Obama’s infected fellow Africans, but also American Muslim ISIS suicide terrorists who would intentionally infect themselves with the deadly disease and thus spread it widely in the United States.”

A Liberian infected with Ebola who traveled from his home country to Texas last month died Oct. 8, and a nurse at a Dallas hospital who attended him now has been diagnosed with the disease.

Klayman would have standing to sue, the complaint argues, because he recently traveled through Newark, a major entry point to the U.S., and was in a position to have been exposed to Ebola from travelers.

The highly contagious and deadly disease has killed more than 4,000 in West Africa. However, Obama has refused to impose travel restrictions. Instead, travelers are being questioned and checked for fever and other symptoms at five major international airports in the U.S.

Klayman blames Obama and the others “for in effect furthering acts of terrorism.”

His complaint says it is not questioned that Ebola “presents a severe risk,” but “defendants’ actions are an open invitation for terrorists to acquire infections of Ebola and travel to the United States to intentionally spread the disease inside ‘the Great Satan,’ including in ‘soft targets’ such as restaurants, shopping malls, and other public and private places.”

Rep. Duncan Hunter, R-Calif., claimed in a Fox News interview last week the U.S. Border Patrol caught 10 ISIS fighters coming into the U.S. from Mexico, suggesting it’s possible for Ebola infections to enter the country through that route.

Also, a U.S. outbreak would lead to “severe disruption” in America’s economy and society, he says.

The causes of action cited include aiding and abetting the murder of U.S. citizens, conspiracy to commit murder, provision of material support to terrorists, a Fifth Amendment violation, assault and infliction of emotional distress.

A week ago, Klayman, who has sued the National Security Agency, Barack Obama over his birth certificate, Hugo Chavez on behalf of torture victims, journalists, Taliban and al-Qaida and more, launched legal action to get Obama deported.

The deportation petition, Klayman explained, is based “on the grounds that [Obama] has falsified various birth and other documents with regard to obtaining a U.S. passport and other privileges as an alleged American citizen.”

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