תביעת הענק הוגשה בעיכבות היתעללות של מערכת בתי המשפט ע"י שופטים,וגורמי רווחה כולל שופט בית המשפט אביהם ברקאי שגם הוא חשוף לתביעת נזיקין בשל שיתוף פעולה לפגיעה בלוחמי זכויות אדם.
התביעה היא על סך 5,000,000 דולר ואושרה קבלתה ע"י בית המשפט .
מצ"ב אישורי התביעה והתביעה עצמה .
מדובר בתביעה יחודית נגד שופטים ,ואנשי רווחה שהחליטו לפגוע בזכויות לוחמי חופש וצדק למען זכויות ילדים ,ואבות גרושים.
מדינת ישראל תצתרך להסביר מדוע פגעה בילדה רק משום שרצונה היה לחיות עם אביה.
מדינת ישראל מנהלת הסתה,ורדיפה אשר אינם מביישות את קוריאה הצפונית,או את אירן כאשר היא מנהלת משפטי דרייפוס נגד פעיל זכויות אדם.
United States District Court
Eastern District of Pennsylvania (Philadelphia)
CIVIL DOCKET FOR CASE #: 2:14-cv-05527-CDJ
|BEN ISSASCHAR et al v. ELI AMERICAN FRIENDS OF THE ISRAEL ASSOCIATION FOR CHILD PROTECTION, INC. et al
Assigned to: HONORABLE C. DARNELL JONES, II
Cause: 18:1961 Racketeering (RICO) Act
|Date Filed: 09/25/2014
Jury Demand: Plaintiff
Nature of Suit: 440 Civil Rights: Other
|ETTI BEN ISSASCHAR||represented by||ETTI BEN ISSASCHAR
|YAAKOV BEN ISSASCHAR||represented by||YAAKOV BEN ISSASCHAR
|ELI AMERICAN FRIENDS OF THE ISRAEL ASSOCIATION FOR CHILD PROTECTION, INC.|
|DAPHNE BARAK EREZ|
|MICHAL BARAK NEVO|
|Date Filed||#||Docket Text|
|09/25/2014||1||APPLICATION TO PROCEED IN DISTRICT COURT WITHOUT PREPAYING FEES OR COSTS by ETTI BEN ISSASCHAR, YAAKOV BEN ISSASCHAR. (Attachments: # 1 Civil Cover Sheets, # 2 Complaint)(lbs, ) (Entered: 09/26/2014)|
UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF PENNSYLVANIA AT ALLENTOWN
ETTI BEN ISSASCHAR, YAAKOV BEN ) Case No.:
Plaintiff, ) COMPLAINT
ELI AMERICAN FRIENDS OF THE ISRAEL )
ASSOCIATION FOR CHILD PROTECTION, INC.)
ASHER GRUNIS, EDNA ARBEL, DAPHNE ) RICO
BARAK EREZ, MICHAL BARAK NEVO ) AND RELATED CLAIMS;
Plaintiffs, a daughter and her father hereby complain of the Defendants, alleges and sets forth as follows:
- This is a civil action for RICO remedies pursuant to 18 U.S.C. 1961 et seq.; for damages; and for all just and proper relief, See 18 U.S.C. §§ 1964(a) and (c) (“Civil RICO”), as well as relief for common law torts based on diversity.
- Plaintiff Etti Ben Issachar, a young woman, age 19, still unemancipated, for being locked up for 8 months in the facilities of Defendant ELI due to agendas of radical feminism, extreme man hating and gender apartheid against men, tantamous to a Shoah perpetrated against divorced men in Israel, and by her father Yaakov Ben Issachar, who after he released his daughter from a child shelter became a human rights defender and in retaliation, the Defendants, Asher Grunis, Edna Arbel, Daphna Bartak Erez and Michal Barak Nevo have persecuted him, concocted false and bogus criminal charges against him, initiated steps to forbid his freedom of speech, and arranged more than 100 false arrests and interrogation in the police.
- In particular, after Plaintiff Yaakov Ben Issaschar filed an action in this Court against ELI and other Israeli officials, (CIV 13-2415) the herein Defendant Grunis, Arbel, Barak Erez and Barak Nevo maliciously retributed against him by directing a Judge in Israel to sentence him for one year in prison, in retaliation for exposing the corrupt ways of the Israeli Judiciary in American courts, and for his attempts to release his daughter from the ELI Shelter.
- The primary cause of this action is a widespread criminal enterprise, by Defendant ELI engaged in a pattern of racketeering activity across State lines, and across international lines and a conspiracy to engage in racketeering activity involving numerous RICO predicate acts during the past ten (10) calendar years by ELI, which is endorsed aided and abetted by the Israeli Official Defendants.
- In addition, Plaintiffs claim compensation for illegal detainer of Etti Ben Issaschar, and malicious prosecution by Defendants Grunis, Arbel , Barak Erez and Barak Nevo.
- The predicate acts alleged here cluster around activities in soliciting funds and donations under false pretense in the United States to finance morally shocking, repugnant and horrendous activities of imprisonment of children against their parents’ will, alienation of children from parent, subjecting children to regime of terror and Dickensian discipline in facilities operated by “ELI”, administering drugs to children, physically restraining children and disciplining them, exploiting the poverty of the children’s parents to supply jobs to the staff of ELI in Israel, See 18 U.S.C. §§ 2319, 2320, 1512, 1513, 2315, 1503, 1510, 1511 and 1581–1588 respectively.
- Other RICO predicate acts, although appearing to be isolated events, were actually part of the overall conspiracy and pattern of racketeering activity alleged herein, e.g. mail fraud and bank fraud. See 18 U.S.C. §§ 1341 and 1344, respectively.
- The primary objective of the racketeering enterprise has been to inflict severe and sustained economic hardship upon Plaintiff Etti, daughter of Yaakov and other parents similarly situated whose children were kidnapped from them by ELI personnel through the assistance of co-defendants, and with the intent of impairing, obstructing, preventing and discouraging Plaintiff from writing, publishing, investigating and conducting judicial activism as a qualified reporter and public activist.
- The Defendants Grunis, Arbel, Barak Erez and Barak Nevo’s hatred to men (emanating from their manifest radical feminism) is so overwhelming that they are willing to sacrifice young children, such as Etti, languishing in child shelters for 8 months, in the name of “female empowerment”.
- Jurisdiction is pursuant to the civil RICO remedies at 18 U.S.C. 1964, and diversity for the common law claims.
- Defendant “Eli” is incorporated in Pennsylvania, and the fundraising that propels the industry of snatching children in Israel from loving parents into prisons for children is centrally orchestrated from Pennsylvania.
- In the past 5 years ELI has collected in Pennsylvania a sum of half a million dollars each year, which is $2,500,000 and sent it to Israel in order to fuel the assault on divorced men, by providing facilities to lock up “recalcitrant” children such as Etti.
- Defendants Grunis, Arbel, Barak Erez and Barak Nevo each have minimum contacts with the United States. All three of them have personal ties to the United States, and they have directed their actions and omissions in retaliation for Plaintiff Yaakov opening Case 13-2415 in this Court.
- Plaintiff Etti was born on November 12, 1994, age 19.5 and is a resident of Israel, living in the same house as her father, who cares for her and provides for her. She is a dependant on her father. (Therefore the statute of limitations as to her did not expire).
- Plaintiff, Yaakov was born in 1968, age 46 is a resident of Israel, whose elder daughter was declared by ELI as “at risk child”, because she did not want to live with her mother and wanted to live with Plaintiff. Etti the daughter was “kidnapped” with the help of social workers and Judges and locked up in a facility operated by ELI. Plaintiff Yaakov has devoted his life to fight corrupt entities that for personal gains inflict terror and torture upon children. Plaintiff, as a whistleblower, has exposed the nefarious activities of Defendants in print, media and in the Parliament, and ever since Defendants seek revenge by way of filing bogus police complaints, or seeking to separate him from his other children.
- Plaintiffs address is 97 Hagolan Street, Tel Aviv.
- Defendant Eli-American Friends of The Israel Associate for Child Protection Inc. (“Eli”) is a corporation registered in the State of Pennsylvania with an address at 1009 Delene Rd, Rydal, Pennsylvania 19046-3313, and EIN-Tax ID 522171745. This Defendant fundraises in the United States to finance a child prison in Israel and kidnapping of innocent children from parents into outplacement facilities.
- Defendant Asher Grunis is a resident of Israel who performs judicial activities at the Jerusalem Supreme Court, and is a sponsor of Eli. Grunis address is 1 Kiryat Hameshala, Jerusalem. Upon information and belief, Grunis is also a dual resident of New York, NY where he maintains an apartment, and a paramour in the Upper East Side of Manhattan.
- Defendant Edna Arbel is a resident of Israel, who performed judicial activities at the Jerusalem supreme Court since 2004, and is a sponsor of Eli.
- Daphna Barak Erez is a resident of Israel, who performs judicial activities at the 1 Kiryat Hamemshala, Jerusalem, and is a sponsor of Eli.
- Defendant Barak Erez is a regular publisher of hateful anti-men articles and books in praise of misandry, and women’s superiority over men at the University of Pennsylvania Press, and other US books, from which she regularly receives royalties.
- Defendant Barak Nevo is a resident of Israel, who performs judicial activities at the 1 Weitzman St., Tel Aviv and is a sponsor of Eli
- Defendant Grunis, Arbel, and Barak Erez are not sued here in and for their judicial capacities in Israel. Rather they are participants in a newly formed “Committee for the Reputation of the Courts”, (hereinafter: the Reputation Committee”) where they sit together with the Minister of Justice Tzipi Livni, and the Chiefs of Police, and the State Attorney General and Head of the Prosecution to devise special tools to suppress, prosecute and torment anybody who expresses voices of criticism against judges and the Judiciary. As such, the Reputation Committee is not “judicial”, and it is a manifest example of the fact that Israel does not adhere to the rules of separation of powers, as the Chief legislator (Tzipi Livni, Chief Judge Grunis and chiefs of the Executive, sit together and brainstorm how to torment and retaliate against the voices of criticism. Apparently the Reputation Committee considers filing a lawsuit overseas as an act of criticism, which is why they placed Yaakov Ben Issaschar on their top list of targets. BACKGROUND
- ELI is a corporation, which purportedly provides services to children at risk, including operation of a so called “safe house” where children who are removed from parental care are placed, as well as a network of therapists and public campaigns. Its services are billed to the Israeli ministry of welfare at 5 times the actual cost ($5,000 per child per month).
- Out of pure greed, and in total disregard of international human rights, ELI has established a network of fundraisers in the United States intended to fraudulently collect money from American donors under false pretenses from its center in Rydall, PA where bogus fundraising occurs.
- The chief principal of Eli, Michael Hersch does not have a fundraiser license in PA.
- Upon information and belief, the surplus collected in the USA is paid to bribe Judges and social workers who support them.
- While in the United States, “children at risk” are usually children of parents with severe neglect problems (alcoholism, violence or incapacity of the parents), in Israel ELI, and the other Defendants have stretched the definition to include children living in poverty, and children of divorce in case a child insists on custody with a father. ELI and the co-Defendants believe that no father is fit to be a parent in a divorce situation.
- ELI in the United States create the false impression that there are many at risk children in Israel whose future development depends on the donation. However, in Israel, ELI uses the United States money to launch public campaigns that poor children belong in facilities away from their parents, solely to create more business and bill the Israeli Ministry of Welfare.
- As a result, instead of assisting the parents by handouts and keeping the children in parental care, those parents are haunted, chased, ridiculed and impoverished by legal proceedings designed to take away the children and place them in ELI’s facilities.
- ELI’s facility, which is touted in the United States as a safe house for children are actually full-fledged prisons where the children are disciplined, physically restrained, administered drugs, and forbidden to be in contact with the parents.
- This massive campaign to “catch” poor children and transfer them to outplacement facilities (temporary, and then permanent), is cruel, inhuman, degrading to the parents and children and is conduct that is in gross violation of human rights.
- In order to catch more children and falsely brand them as “at risk” children, Defendants have determined that in situations of divorce, when the woman is unfit, cannot or does not want to raise the children, then fathers would be excluded from receiving custody and the children will be declared “at risk”.
- In other words, Defendants promote the idea that all fathers in divorce are unfit parents, and therefore either the children are placed with the mothers or placed in the custody of ELI.
- Such cruel and inhuman treatment of men is especially advocated by Defendants Grunis, Arbel , Barak Erez and Barak Nevo, who have declared a war on fatherhood in Israel, and expressed many times that so long as they are alive, they will destroy physically, mentally and financially any man who seeks custody of his children. As a result, of Grunis, Arbel , Barak Erez and Barak Nevo’s legal decisions (which are squarely against international ius cogens, 200 fathers every years commit suicide (out of 400 incidents statewide), tens of thousands of children lose contact with their fathers and thousands of children each year (25% of all divorce cases) see their fathers in “contact centers”. In fact, almost every divorce case in Israel starts with a false police complaint against the man, because women are exempt from prosecution for false reports. This causes a massive amount of false arrests and imprisonment, as 20% of the police resources are devoted to, and invested in incrimination of divorced fathers, and 20% of the men in jail in Israel are fathers, most of them convicted on the mere say-so of their wives. (It is not necessary in Israel for any proof of abuse or physical evidence. It is enough that a woman says that she was threatened to convict a man.
- If that is not enough, women are exempt from child support. A man has to pay child support to the woman even when he is the custodian, and the rates of child support are 3-4 times higher than the USA, while salaries are about half those of the USA. Arrests for non-payment of support are encouraged by these defendants, without any hearing on the financial ability to pay, and they are almost automatic procedures.
- Defendant Arbel especially, propounded rules in 2004 while she was State Attorney General that exempts women from prosecution for making false complaints at the police against their husbands. She later used that exemption for her own benefit when she filed false claims against her own son in law, a City Judge in Rishon LeZion, Judge Eyal Baumgart (who was married to her daughter) sexually fondled and got sexually aroused by playing with her grand-children (who are his children). When the complaint turned out to be a lie, she escaped prosecution for false complaint. She then routed to herself all appeals in family cases, and Administrative Petitions in matters of welfare and family. She routinely granted almost every woman’s appeal, and denied every husband’s appeal. She routinely granted each and every Admin Petition filed by ferocious women’s rights organization and denied every Admin Petition filed by men’s rights groups.
- Plaintiffs Ben Issachar had the misfortune of being assigned to Arbel during Etti’s lock up at ELI. Arbel, of course, dismissed the appeal, and kept Etti in the shelter. COUNT 1
- Common law – detention of Etti Ben Issaschar
- Etti Ben Issachar was born in 1994. In 1999 the parents separated and Etti was placed in her mother’s custody. In December 2004 Etti moved to her father’s de facto custody and lived with him. The mother agreed and relinquished custody, however government social worker, Shifra Inbar, who just like all Israeli government social worker was trained by a radical feminist organization (WIZO), could not stand the idea that a man will be a custodian, so she used her “emergency authority” to remove Etti from her father’s home without a court order.
- In or around March 30, 2005, on orders of the social worker Shifra Inbar, working on cooperation with ELI Staff, six policemen raided Yaakov’s home, and with pointed guns demanded that he surrender Etti to be placed in an emergency shelter operated by ELI. Etti Etti was 11 years old.
- The policemen and Defendant ELI staff took Etti into a “child shelter” located at 12 Zamenhoff Street, Tel Aviv, and forbade her to see her father. Ironically one of the famous Warsaw Ghetto streets was also called Zamenhoff Str.
- ELI started a campaign to tarnish and destroy the father and the child by working with social workers to declare the child “at risk” and incarcerate her.
- Indeed, using false and bogus declarations of “at risk” Defendant ELI obtained an order placing Eti Ben Issaschar in an emergency shelter operated by ELI in Tel Aviv.
- Etti Ben Issaschar was locked up for 8 months with no access to the Plaintiff, in conditions that are physically and mentally torturous.
- ELI officials filed numerous police complaints against Etti’s father in order to coerce him to give up the battle to bring his daughter home.
- In addition, ELI officials including Hanita Zimrin and Dani Male Ron arranged for a petition to declare Plaintiff mentally unfit, and lock him up in a psychiatric facility for mental observation.
- In the end, Eti suffered 8 months of needless incarceration at ELI facility, where she suffered loss of liberty, loss of family life and family relations, violence by staff, restraints, placements in padded rooms for “tranquilization”, and severe mental traumas.
- In addition to the acts of fraud deceit, unlicensed solicitations and which Defendant ELI perpetrated , Defendant ELI (a) fabricated documents to falsely brand Plaintiff Etti as “at risk” child in order to lock her up and deter her from living with her father as custodian, (b) Defendant ELI used the police to forcefully enter Plaintiff’s home and remove the child to the temporary “safe house, where Etti was abused for 8 months, while ELI was charging the Israeli ministry of Welfare 5 times their cost, and appealing to Americans to finance these kinds of activities, (c) ELI made at least 4 false police complaints against the Plaintiff Yaakov in order to silence him and deter him from exposing the corruption and from assisting other parents, (d) Defendant ELI falsified documents to arrange for the psychiatric lock up of Plaintiff Yaakov so that he will stop his efforts to release his daughter from ELI, ( e) Defendant ELI extorted Etti emotionally that if she wants to be released from their prison (the so called “safe house”), she can agree to live with her mentally unstable mother.
- The statute of limitations did not expire because Etti Ben Issachar reached 18 on November 12, 2012 but since then she is still an unemancipated minor living at her father’s home in his custody and care.
- Plaintiff Etti Ben Issachar is therefore entitled to recover from ELI the sum of $5,000,000. MALICIOUS RETRIBUTION AGAINST YAAKOV BEN ISSASCHAR
- COUNT II
- Plaintiffs repeat and reallege all facts and circumstances described above as if fully set forth herein.
- Since the release of Etti Ben Issachar in or around October 2005 to her father’s custody, Plaintiff Yaakov started a charity intended to release children who are needlessly placed in such facilities posing to “save children”, but in reality they subject the children to life without family love, in institutions and facilities were discipline is violent, and drugs, petty crimes and sexual promiscuity are the norms.
- Yaakov Ben Issachar has appeared in countless court hearings as a recognized friend of the court, and at Parliament hearings, wrote articles, and encouraged victims to upload video clips to the internet and tell their sordid stories in front of cameras. He has participated and supported demonstrations in front of rogue judges, who rubber stamp social worker’s action, or simply cut off children from fathers’ lives.
- Yaakov Ben Issachar has thus become a “sore thumb” for the Israeli “Judiciary”, but even more so after he filed a complaint in the Federal courthouse in Allentown.
- In particular, Yaakov Ben Issachar’s charity “Movement for the Future of Our Children” has been devoted to publish the atrocities committed by people with color of law’ such as social workers and judges. The publications are uploaded by volunteers as he lacks the technical skills to do so.
- Since the release of Etti in February 2006, and the growth of the activities of Yaakov Ben Issaschar, and as more parents joined him, Israeli authorities tried to scare him and silence him in order to stop helping parents rescue their children from such child shelters, and to shut down his web site, where volunteers uploaded stories of children being kidnapped from their children.
- The District attorney, upon receiving private correspondences from Edna Arbel opened two criminal cases against Ben Issachar, one for participation in a demonstration in front of the Judge that signed the order to lock up Etti, (Nathan Nachmani) ,and another for allegedly forging a signature on a letter from a sister- charity addressed to ELI and demanding the release of Etti.
- The cases were kept open, but as soon as the federal Court in Allentown dismissed the complaint brought here against Eli and other officials, Defendants Grunis, Arbel and Daphna Barak Erez, as participants in a non-judicial “Reputation Committee” gave instructions to the city judges, such as Defendant Michal Barak Nevo, who were assigned to the two cases to speedily bring these two cases to a guilty verdict, at all costs, and without due process.
- Indeed, the two judges, Judge Itzkak Itzhak assigned to the indictment on participation in the demonstration in 2005 in front of Nachmani’s house, and Defendant Michal Barak Nevo assigned to the alleged forgeries of the letters from the charity to ELI, set up trial dates, denied Plaintiff Yaakov Ben Issaschar the right to free trial, denied him the right to bring witnesses or to cross exam the witnesses of the prosecution, harassed him repeatedly by issuing habeas corpus warrants to fetch him, and they quickly issued guilty verdicts in or around June 2014.
- These two guilty verdicts were intended to make Yaakov Ben Issaschar a scapegoat, to signal to all activists for fathers’ rights in Israel that they will be severely punished for trying to change the laws.
- The two guilty verdicts which were obtained without Due process, and without ability to bring defense witnesses, or to develop a defense strategy, are products of the work of the Reputation Committee’s pressures, and in retribution against Ben Issaschar to teach him a lesson for daring to sue Israeli Judges in the United States.
- Upon information and belief the three Judges of Israeli Supreme Court, Grunis, Arbel and Barak Erez are known for their ultra radical feminist and anti-male ideology. This is manifested by the judgments they write. Just as an example, as late as on April 3, 2014 Barak Erez wrote that Israel must continue to discriminate against men, and that all women must get automatic sole custody over young children. The Judgment reeked of derogatory hate words towards men. (Case 1854/14). This comes after a string of Administrative Petitions asking these judges to equalize the rights and obligations of women to men, but all such cases are pulled by Arbel they all fail, many times with sanctions.
- In or around August 2012, Grunis and Arbel had formed the “Reputation Committee” to combat fathers’ rights in combination with the Minister of Justice and the heads of the police and law enforcement.
- The existence of this non-judicial committee was revealed in Haaretz newspaper first on October 3, 2012. Reporter Revital Hovel published that the two judges (Barak Erez joined later) are meeting regularly with police, law enforcement chiefs and the Department of Justice to examine tools: to prevent and deter demonstrations in front of judge’s homes, to seize computers from activists, to launch police complaints against activists without live complainants for expression of speech and reports in blogs, all with the purpose of oppressing the activists in Israel from seeking to change the laws that discriminate against men.
In the article entitled: “Grunis seeking protection for family court judges under threat”, (10/3/2012), reporter Hovel wrote:
Following threats against judges handling divorce and custody cases, Supreme Court President Asher Grunis and the head of the courts administration, Judge Michael Spitzer, have taken steps to ban demonstrations around the private homes of judges. In their attempt to obtain such a ban, Grunis and Spitzer have held meetings recently with Attorney General Yehuda Weinstein, State Prosecutor Moshe Lador, police commissioner Yohanan Danino and head of the police investigations unit Yoav Segalovich….Officials at the Justice Ministry refused to comment on meetings involving Grunis and Spitzer. Spokesmen for the courts administration confirmed that there has been such discussions, adding that "recently there have been instances of inappropriate gatherings around the private homes of judges. It bears mention that demonstrations around courthouses are not prohibited, so long as they are undertaken in line with procedure."
The courts administration spokesman added that an order has been issued by Weinstein regarding the freedom to demonstrate, with the order saying "a demonstration or protest vigil near the private home of a public service worker, who is not an elected official, is a grave phenomenon that constitutes an attempt to intimidate and deter the worker from carrying out his task, and such a demonstration is therefore banned."
- Later on August 28, 2013, same reporter published more from the Reputation committee: “Courts Administration seeks to block online criticism of judges”, with sub heading: “Agency asks prosecutors to examine legal measures for closing down websites devoted to slamming judges”.
- According to the article, “The Courts Administration has asked the state prosecution to examine what legal steps can be taken against websites that malign judges, including whether they can be shut down. …The Justice Ministry said: “Consultations have been held with various parties in the prosecution regarding speech crimes over the Internet that harm judges… Methods of enforcing [the law] and dealing with this issue are being examined by the law enforcement system as a whole.”
- On August 8, 2014 Revital Hovel published another article stating that the Reputation committee instructed the police to summon up activists to interrogations, seize computers, launch cyber sniffing tools, and file indictments against anybody “defaming” a judge. (“defaming” is a laundered word for criticizing).
- Indeed the impact of this Reputation Committee is clearly visible. Defendants Grunis, Arbel , Barak Erez were extremely annoyed that Plaintiff Yaakov has sued Israeli Judges in Pennsylvania, so as soon as the case was dismissed they have given instructions via intra-mail passed to the Judges in Israel to treat Yaakov Ben Issachar and any parent receiving assistance in the harshest way possible.
- In retaliation Plaintiff has been harassed and haunted by several judges, including Michal Barak Nevo, was called by the police for interrogations, his house was raided, and was under constant surveillance, and an illegal seize of his computer was executed, all under the pretext of the charge of “insulting an officer”.
- Some of the Judges who filed complained against Yaakov Ben Issachar as a result of this are: Judge Galit Mor Vigotzki, complained that someone overheard allegedly talking in the Court kiosk that Yaakov wants to hurt this Judge. Yoram Shaked, complained about negative reviews about decisions he made written in a web site devoted to exposing inhumane court decisions, and allegedly attributed to Ben Issasschar. Tova Sivan complained about a cartoon that appeared in one of the Hebrew web pages. Judge Tamar Snunit Forer, (formerly head of the radical feminist network of Israel) complained that she was insulted by an article that called her a “vampire sucking men’s blood”. Even Judges who Plaintiff Ben Issachar never heard of, and never knew that they existed, such as Sigalit Ofek, filed a complaint about something that was not even related to her.
- In addition, during a demonstration in front of the residence of the minister of Welfare, Mr. Meir Cohen, in Dimona in June 2013, police was dispatched with instructions to physically attack, injure and maim Mr. Ben Issaschar in order to scare him not to demonstrate. Ben Issaschar was severely beaten up.
- The acts or omissions described above constitute a string of torts, including assault and battery, libel, false imprisonment, false arrests and intentional infliction of emotional distress.
- The acts or omissions described above were inflicted upon Plaintiff Yaakov Ben Issaschar in retaliation for opening a lawsuit on April 30, 2013 in this District, and for the purpose of deterring and scaring Plaintiff, and others similarly situated from access to American Courts.
- The acts or omissions described above were maliciously inflicted with purpose, intent and desire to cause Plaintiff further physical and emotional harm, including false detainers, violent raids of the home’ surveillance, malicious seizure of computer as well libel way of disseminating mails from the reputation committee to 650 Judges, with intent to ridicule him and prevent him from helping others to salvage their children and what’s left of their civil rights.
- Plaintiff is therefore entitled to recover from defendants Asher Grunis, Edna Arbel, Daphna Barak Erez and Michal Nevo the sum of $5,000,000.
Acquisition and Maintenance of an Interest in and Control of
an Enterprise Engaged in a Pattern of Racketeering Activity:
18 U.S.C. §§ 1961(5), 1962(b)
- Plaintiffs now re-allege each and every allegation as set forth above, and hereby incorporates same by reference, as if all were set forth fully herein.
- At various times and places, ELI acquired and/or maintained, directly or indirectly, an interest in or control of a RICO enterprise of individuals who were associated in fact and who did engage in, and whose activities did affect, interstate and foreign commerce, all in violation of 18 U.S.C. §§ 1961(4), (5), (9), and 1962(b).
- During the ten (10) calendar years preceding today all Defendants did cooperate jointly and severally in the commission of two (2) or more of the RICO predicate acts that are itemized in the RICO laws at 18 U.S.C. §§ 1961(1)(A) and (B), and did so in violation of the RICO law at 18 U.S.C. 1962(b) (Prohibited activities).
- ELI created a network of website to collect funds within the State of Pennsylvania. Indeed, in the past 5 years ELI collected $500,000 each year in donations for a total of $2,500,000. Out of that 40% was collected from the Jewish Federation of Pennsylvania.
- In ELI’s web sites repeat the following text, all of them containing complete and utter falsehoods: ELI demonstrates awareness and commitment by translating its services with cultural sensitivity so we can help all of Israel's children, from native Israelis to immigrants from The Former Soviet Union, Ethiopia and the Far East, from Ultra Orthodox children to those that live on Kibbutzim, regardless of their religion, ethnicity, or social strata. ELI's aim is to broaden awareness among all Israeli's as to what constitutes abuse, and how it can be stopped. And ELI can only do this with you help. Please make a tax deductible contribution to American Friends of ELI today.
- Standing the test of time, ELI has helped tens of thousands of children who were victims of abuse to heal. ELI's team of 90 clinicians works tirelessly to ensure that whenever and wherever in Israel a new case of abuse is discovered, ELI responds. Last year ELI offered therapy to nearly 4,000 children and their families. Together, ELI's team of social workers and psychologists delivered nearly 1,000 hours of therapy per week. ELI's toll free hotline fielded calls from nearly 7,000 children, and concerned friends and family members. More than 90,000 of Israel's school children participated in one or more of ELI's Outreach and Abuse Prevention programs, and thousands more teachers, parents, principals and school counselors. After 30 years on the front line in the battle against child abuse in Israel, ELI was granted the authority by Israel's National Ministry of Social Welfare to handle every case of sexual abuse in Central Israel, an area comprised of over 1,000,000 people !
- On or about June 12, 2012, Defendants created the web site: http://www.eli-usa.org. The website is registered to Emmanuel Werthenschlag,300 E85th Street, Apt 501, New York, NY 10028. The web site calls for people to send money to Michael Hersch at American Friends of ELI 1009 Delene Road Rydal PA – 19046.
- A search of Pennsylvania’s DOS Charities Online Database revealed that Hersch does not maintain a license pursuant to The Solicitation of Funds for Charitable Purposes Act, 10 P. S. § 162.1 et seq ., which requires fundraising counsels to register with the Bureau of Charitable Organizations prior to providing services related to solicitations in Pennsylvania.
- Defendants also created a sub-page under http://www.just-tzedakah.org, a corporation in marylans, Tzedaka, Inc., PO Box 34841, Bethesda MD, 20827. The fundraisers listed there are Jeffrey Hamberger, Ira Kaminow, Daniel Rothner, Alan Weitzner, Kalman Yelowitz. They admit to deducting a 3.5% service fee from donors.
- The following are predicate RICO acts committed in the nefarious plot to trick American donors into making donations to lock up children in the facilities of ELI:
- In general and this is common to all predicate acts, ELI’s President Hanita Zimrin targets Jewish federations in the United States. She then books a trip to the US paid from the funds ELI-USA in PA is maintaining, and then using mail and wires, she arranges speeches in the Jewish Communities urging the Jews to open wallets in philanthropy. For each visit on her tour, she tailors a special story. For example if a US community has a sister state in Israel, she says that ELI Israel needs to expand to that town. Usually, she passes off an already existing child treatment center, which is paid for and run by the Government of Israel, as if it was a “satellite” ELI Center. Otherwise, she invents bogus stories about renovations that never happen, or mobile treatment vans that don’t exist. Upon information and belief, the Jewish federation of Philadelphia and PA accounts for 40%-50% of the donations (about a quarter million dollars a year). In general each approach to a Jewish federation embellishes on false or misleading statistics, such as “Eli treats children in a metropolitan area of $1.5 Million inhabitants (and compare: only 15 children are housed at the shelter). Other false or embellished “statistics are “ELI’s therapists treated 3,540 abused children and their family members” . (Here again, it is Government therapist paid by the Government who “treat” the children, not ELI). In order to bamboozle the audience, she says things like: “Seventy percent of the cases in therapy are those of sexual abuse while only 41% of the calls to the hotline referred to sexual abuse. This is due to the fact that whenever sex crimes occur, there is more sensitivity and pressure to seek assistance than in cases of physical abuse (as a result, more physical abuse victims go untreated)”. In reality, the audience does not know what that treatment is. It is coercive tactics to find children and elicit information that their parents are “abusing” them in order to take them into the shelters and from then on into foster care and adoptions.
- On several occasions within the past 10 years, and each year on a continuing basis, Defendants Eli, Zimrin and Malé Ron approached by mails and wires the Edli family in Los Angeles and Louise Paktor in Holland and fraudulently represented to them that ELI needs money for a “Mobile Therapy Unit”, “which allows ELI to respond immediately to emergency situations. In addition, the mobile therapy unit allows us access to remote regions where other services are not available”. It was further fraudulently represented that “the MTU served clients on a regular basis in the Jordan Valley, Yehuda Plains, the towns around the Galilee, and Moshavim in the Negev and near Eilat”. In fact, this was a fraud as there is no mobile therapy unit, and it is illegal to interview children for possible abuse without parental knowledge, under the guise of “therapy”.
- On several occasions within the past 10 years, and each year on a continuing basis, Defendants Eli, Zimrin and Malé Ron approached by mails and wires Harry and Jeanette Weinberg Foundation 7 Park Center Court in Baltimore at Owings Mills, Maryland 21117), and the Edli Foundation and represented to them that ElI needs to start a “Satellite Therapists Project”, allegedly “in order to provide easy and friendly access to therapy in localities such as Golan Heights, Lod, Yavne or Bat Yam in office spaces which are donated by local municipalities”. In reality this was another marketing scam, to defraud the donors out of funds for a non existing project. Further, what Zimrin, Malé Ron and the naïve American co-directors call satellite offices is a passing off of Israeli Government, Ministry of Welfare, child care centers and other municipal places that are unrelated to ELI, as if they were ELI satellite centers.
- On several occasions within the past 10 years, and each year on a continuing basis, Defendants Eli, Zimrin and Malé Ron approached by mails and wires the The Bonim Atid Group of UJA New York, The Jewish Federation of Greater Philadelphia at 2100 Arch Street, Philadelphia, PA 1910, The East Bay Jewish Community Teen Foundation at 300 Grand Avenue, Oakland, CA 94610, and the Harry Kramer Memorial Fund of 1525 W W T Harris Boulevard, Charlotte, NC 28262 and falsely represented to them that ELI needed funds for a “New Immigrant Help Center for Abused Children” was designed to provide counseling, education, and therapy for children and families who have recently immigrated to Israel. In fact this was fraudulent since these immigrant children are already taken care of by the Ministry of welfare or the municipalities. It was merely a marketing ploy that sounds good to American ears.
- On several occasions within the past 10 years, and each year on a continuing basis, Defendants Eli, Zimrin and Malé Ron approached by mails and wires Sue Schwartzman, Director of Youth Philanthropy for the Jewish Community Endowment Fund at 121 Steuart Street, San Francisco, CA 94105, and solicited donations under false pretenses, as set out above. On One occasion ELI obtained “$3,444 to be used be used to underwrite the cost of delivering a proven, successful child abuse prevention program to ten schools in Israel that would be seen by those schools’ 2,750 children and adolescent attendees”.
- On several occasions within the past 10 years, and each year on a continuing basis, Defendants Eli, Zimrin and Malé Ron approached by mails and wires Zanvyl and Isabelle Krieger Foundation from Baltimore, MD., the Naomi and Nehemiah Cohen Foundation, PO Box 30100 Bethesda, Maryland 20824, and the Hilda and Jacob Blaustein Foundation 10 East Baltimore Street, Suite 1111, Baltimore MD 21202, and falsely represented to them that ELI needed to expand services to the Arab sector. Defendant ELI falsely represented that it needs to “address cultural nuances”, and “confront child abuse among Arabs”, and an office will open in Nazareth with hot line in Arabic “staffed by nine trained Arabic-speaking volunteers”. Defendants stated that “following interviews with the Arab press including the newspaper Alsonara and the Agil TV station in Ramalla, which are read and watched in the entire Arab world, the hot line has started to receive calls from all over the Middle East including Bahrein and Syria. May this be the corner stone for peace”. This was all falsely tailored to suit the donor’s philanthropic interests.
- On several occasions within the past 10 years, and each year on a continuing basis, Defendants Eli, Zimrin and Malé Ron approached by mails and wires the United Jewish Endowment Fund of the Jewish Federation of Greater Washington D.C. and Steven Spielberg's Righteous Person's Foundation and falsely represented to them that a new “Outreach and Prevention Program in schools in Beit Shemesh and Yehuda Plains” was planned. This was all falsely tailored to suit the donor’s philanthropic interests.
- On several occasions within the past 10 years, and each year on a continuing basis, Defendants Eli, Zimrin and Malé Ron approached by mails and wires the Jewish Federation of Greater Pittsburgh and fraudulently asked it to donate towards a “School Outreach” “program in Carmiel and Misgav”. This was all falsely tailored to suit the donor’s philanthropic interests.
- On several occasions within the past 10 years, and each year on a continuing basis, Defendants Eli, Zimrin and Malé Ron approached by mails and wires the Steven Spielberg's Righteous Person's Foundation and falsely represented to them that it needs money “to reach traumatized children in the schools in the North of Israel”. This was all falsely tailored to suit the donor’s philanthropic interests.
- On several occasions within the past 10 years, and each year on a continuing basis, Defendants Eli, Zimrin and Malé Ron approached by mails and wires the “Save the children Norway” and asked them to pay for a trip to Ethiopia, so that ELI can embellish its repertoire with international credentials so as to be able to claim that “ELI's staff is regularly invited to train professionals in other countries”.
- On several occasions within the past 10 years, and each year on a continuing basis, Defendants Eli, Zimrin and Malé Ron approached by mails and wires The Jewish Federation of Somerset, Hunterdon and Warren Counties at 1011 U.S. 22, Bridgewater, NJ 08807, and fraudulently represented that the shelter needs renovation: “ELI's emergency shelter, located in the heart of Tel Aviv, is the place where children are admitted by court order under extreme circumstances when their lives are in danger. This is an extraordinary facility which offers safety and protection, crisis intervention and diagnosis, and gives ELI's therapists the opportunity to develop a long term treatment plan for the children. 100 children received services in the shelter. In particular, the Jewish Federation of Somerset, Hunterdon & Warren Women’s Philanthropy “Imagine” luncheon was held on October 16, 2008 at the Fox Hollow Golf Club with a special program benefiting ELI, Israel Association for Child Protection, honored by Adele Blumberg, Goldie Taub and Margit Feldman. During the luncheon, a glimpse of Zimrin’s modus operandi was offered: “Dr. Zimrin showed and explained the meaning of a number of very heartbreaking and disturbing drawings made by the children in their care. The drawings indicated extreme fear, anxiety, sadness, depression, and feelings of being imprisoned and out of control. She spent the second half of her remarks explaining how our community’s assistance in creating a transitional safe house would impact the work that they do. Many children can still not go home following the period of acute treatment and stabilization in the emergency shelter, either because the parents are not fit, or the children need longer term therapy and assistance. A transitional safe house would meet this need”. Later during that luncheon, parallels were between being a survivor of the Holocaust, and the survivor of parental imposed child abuse.
- On several occasions within the past 10 years, and each year on a continuing basis, Defendants Eli, Zimrin and Malé Ron approached
- On several occasions within the past 10 years, Defendants Eli, Zimrin and Malé Ron approached, using mails and wires, Caryn Viterbi at the Viterbi Family Foundation in San Diego, CA, The Jewish Federation of Somerset, Hunterdon and Warren Counties, and Robert Satter at the Gimprich Family Foundation, 1 West 4th Street, New York, NY and fraudulently solicited funds for a “Safe House – Bridge to Home” marketing slogan. Defendants stated that “When diagnosis in the shelter indicates that there is no hope for rehabilitating a family, and parents lack appropriate parental skills, ELI directs its efforts toward termination of parental rights and adoption. There are cases however, where there is hope for rehabilitating a family, but only with appropriate treatment and sufficient time. Through this new program ELI is investing in parents and their parenting skills. This program has two major elements; one is inviting the parents to stay in the shelter with their children for several hours, several times per week for supervised visits. The visits might take place in the mornings, when the parent (usually a mother) is not working, or during the afternoon and evening, after work hours. The second element is done in the family's home. An ELI therapist accompanies the child on a home visit, spends time with the family and monitors and coaches during various “real life” situations. The visit is recorded on video and then analyzed together with the parent(s). The two methods are used in order to treat the parents, train them, empower, reinforce teach and supervise them. The goal of the Safe House program is to create a bridge between the shelter and home and allow for the child to go back home to a safe environment and mend the broken bonds”. In fact, none of this is true, and it is all fiction intended to rob the donors and enrich ELI, Zimrin and Malé Ron.
- On several occasions within the past 10 years, and each year on a continuing basis, Defendants Eli, Zimrin and Malé Ron approached by mails and wires Kent Newton and Bill Slaton, both residents of Northern California and asked them to donate and to maintain a tax free fund for ELI for a rainy day under auspices of the Jewish Endowment Fund of the West” in Sacramento.
- On several occasions within the past 10 years and each year on a continuing basis, and in particular on or about March 29, 2009 Zimrin on behalf of ELI visited the Jewish Communities in Delaware. Because Wilmington Delaware has a sister city in Arad Israel, Zimrin fraudulently represented that she wanted to “expand ELI services” to the town of Arad. Once again, she was passing off already existing Government of Municipality facility as if it was an ELI facility. Using personal connections with one of the directors, Karen Venezky, Zimrin obtained press coverage at the “Shalom Delaware” paper and an “appeal for donations was made”. Once again she fraudulently depicted ELI as a place where “families receive therapy and legal counseling”.
- For each year during the past 10 years, and each year on a continuing basis, using mails and wires, Zimrin on behalf of ELI made contact with Tzedakah, Inc., PO Box 34841 Bethesda MD 20827 to be featured on their web site which enables private donors to make donations by credit card on the internet.
- For each year during the past 10 years, and each year on a continuing basis, and in particular on or about March 12, 2009, Zimrin made solicitations in Philadelphia via her connections with Renée G. Sackey, chair of Federation's Women of Vision Foundation to address “Women of Vision”, a permanent Jewish Women's Foundation of the Jewish Federation of Greater Philadelphia. Zimrin spoke to members about the outreach project that the WOV grant of $10,000 supports for 25 to 30 girls who are victims of abuse. “Zimrin explained that the project combines individual and group therapy to reduce the psychological impact of the trauma”. "During the 2009-10 funding cycle, ELI will get $250,000 to create a Jewish Federation of Greater Philadelphia Safe House for Abused Children.". An article in the Jewish Exponent later appeared featuring Zimrin, and praising the continuing donations.
- For each year during the past 10 years, and each year on a continuing basis, Zimrin on behalf of ELI alone or with other Board members sent mails or wires to arrange appearance sat the Durham-Chappel Hill Jewish federation in order to solicit funds under false pretenses.
- For each year during the past 10 years, and each year on a continuing basis, and in particular on or about July 7, 2009 Zimrin visited Seattle and addressed the “Jewish Federation’s Lion of Judah” luncheon. Upon information and belief, “a check from WEF for $10,000 launch[ed] a new project in Seattle’s partnership community Kiryat Malachi, one of the country’s most underserved development towns”.
- For each year during the past 10 years, and each year on a continuing basis, Defendants Eli, Zimrin and Male Ron by mails and wires and obtained obtained from them under false pretenses funds which were used to harm and emotionally brutalize children in Israel: Amcha for Tsedakah, Auerbach Family Foundation, Azrael Food Dynasty, Inc., June Baumgardner Gelbart Foundation, Gerry & Burt Belzer Fund, Jack Chester Foundation Congregation B'nai Brith, Durham-Chapel Hill Jewish Federation, Fox Family Foundation, William Greenfield & Joan Rockower Greenfield Foundation, Phoebe & Herman Kappel Foundation, Esther Sherman Mc Donald Fund, Harvey M. & Lyn P. Meyerhoff Fund, Irvin Saltzman Family Foundation, Ben N.Teitel Charitable Trust, Temple Shir Ami Religious School, Nancy Wagman Foundation, Jewish Federation of Greater Washington, The Harry & Jeanette Weinberg Foundation, M.B & Edna Zale Foundation, Anne & Lionel Bercovitch, David Cohen/Janine Marlowe, Scott Davis, Albert Dreyfuss, Murray Foss, Jenifer Friedman, Bruce Goldberger, Del Rene Goldsmith, Alice & Jacob Klein, Kenneth & Maralyn Lakin, Paul & Kathleen Rosenberg, Stephanie Seltzer, Arthur & Barbara Sheer, Ilse Stamm, Arnold Stanley, and Roselyne Swig.
- Some of the donors to ELI who were solicited under false statements: Amcha for Tsedakah, Auerbach Family Foundation, Azrael Food Dynasty, Inc., June Baumgardner, Gelbart Foundation, Gerry & Burt Belzer Fund, Jack Chester Foundation, Congregation B'nai Brith, Durham-Chapel Hill Jewish Federation, Fox Family Foundation, William Greenfield & Joan Rockower, Greenfield Foundation, Phoebe & Herman Kappel Foundation, Esther Sherman Mc Donald Fund, Harvey M. & Lyn P. Meyerhoff Fund, Irvin Saltzman Family Foundation, Jewish Federation of Somerset, Hunterdon & Warren Counties, Ben N.Teitel Charitable Trust, Temple Shir Ami Religious School, NancyWagman Foundation, Jewish Federation of Greater Washington, The Harry & Jeanette Weinberg Foundation, M.B & Edna Zale Foundation, Anne & Lionel Bercovitch, David Cohen/Janine Marlowe Scott Davis Albert Dreyfuss, Murray Foss, Jenifer Friedman, Bruce Goldberger, Del Rene Goldsmith, Alice & Jacob Klein, Kenneth & Maralyn LakinPaul & Kathleen Rosenberg, Stephanie Seltzer, Arthur & Barbara Sheer, Ilse Stamm, Arnold Stanley, Roselyne Swig.
- On or about October 19-21 Zimrin toured the United States and appeared at dinners and brunches at the home of Kent Newton and Bill Slatoin in California under auspices of Bnai Brith and the Jewish Community Foundation of the West, where she made the same appeals to Americans to donate money to her organization so that she can allegedly improve the lives of thousands of children.
- Around the same time Zimrin appeared in New York at “A Networking Event Made in Heaven” in an event sponsored by Jennifer and Alan Zweibel.
- Defendants intentionally deceived the above listed donors into giving her money so that she and co-defendants can increase their salaries, distribute it in clandestine channels, and torment and molest more and more children under the false guise that the children are victims of “nefglect and abuse” that never happened.
- According to Defendant ELI’s own reports, $800,000 a year was donated from the United States. This amounts to $8,000,000 in 10 years.
- Upon information and belief,. This money was spent in israel to kidnap children from parents, to incarcerate children in facilities and to launch a war against the whistleblowers and activists who started protests against this organization.
- In order to disguise the nefarious Defendants disseminate the following false and misleading information to the public in the United States:
- The web site which Michael Hersch prepared for Defendants presents to the public claims that the money donated in the US goes to a “safe House” for children. This is utterly false. ELI charges the Israeli Government the full cost of operating the safe house, and in fact inflates the bill five times. Whereas it costs ELI 3,000 NIS, $750 per month to accommodate a child, it charges the Government 17,000 NIS per child per month ($4,250). Clearly the safe house not only funds itself in Israel, it yields a 500% profit. The American donors are clearly misled.
- Defendants do not tell Americans that the safe house accommodates only 15 children, and no more. It gives the false impression that it is a huge operation, by making vague assertions such as “Eli caters to an area where 1,000,000 people reside”. Still Eli’s house is only allowed to accommodate 15 people.
- The pictures which Defendants show to American donors are false and misleading. In the web site there is a picture of a bright white neat building with flowers. In reality, that is not the safe house. The safe house is a dilapidated, horrendous conditions, infested with rodents, bunk beds, and prison type security. The web site says that the children get contact with parents three times a week. In fact, it is a secluded closely guarded children prison, with no parent access. Even members of Knesset were denied access.
- Hersch and the Defendants herein publish pictures of children with full face to gain sympathy. It is illegal in Israel to take outplaced children’s photos.
- Hersch and the Defendants herein touts a picture of a bus as a “mobile clinic”. In fact, no such bus exists and it is a dangerous activity to randomly interview children without the parents’ agreement, with the sole purpose of removing them, from parental care to the safe house or additional coercive treatment.
- ELI, Zimrin and Male Ron also operate a therapy clinic for sexually molested children. They use the money collected in the United States to encourage women in divorce to fabricate false charges of sexual molestation by the father of the children to yield two goals: Defendants are enriched and supplied with jobs, while the women in divorce are able to get automatic custody, and take over all of the husbands’ money.
- The problem with that is that ELI, Zimrin and Male Ron are instilling in young children false memories of false sexual episodes which will torment these children forever.
- The co-Defendants, and especially Edna Arbel give ELI and its cohorts full support by failing to investigate, supervise or cross examine, and encouraging women to fabricate sexual molestation charges.
- Upon information and belief, Edna Arbel, via her husband Yechezkel took bribes from Hanita Zimrin, President of ELI.
- Defendants conspired to file false complaints to arrange false detentions of the Plaintiff on numerous occasions.
- The persecution of Defendants of the Plaintiff led to another conspiracy to silence the Plaintiff by way of launching civil libel case against him in September 10, 2008.
- On numerous occasions in 2012-2013, because plaintiff became a whistleblower and a civil rights activist against corruption in the Judiciary, when another child, Ruby Ben Issaschar, was born to Plaintiff from another woman, ands the matter came before Grunis, Grunis started tormenting Plaintiff and denying him the right to fatherhood.
- Plaintiff further alleges that all Defendants did commit two (2) or more of the offenses itemized above in a manner which they calculated and premeditated intentionally to threaten continuity, i.e. a continuing threat of their respective racketeering activities, also in violation of the RICO law at 18 U.S.C. 1962(b) supra.
- Pursuant to the original Statutes at Large, the RICO laws itemized above are to be liberally construed by this honorable Court. Said construction rule was never codified in Title 18 of the United States Code, however. See 84 Stat. 947, Sec. 904, Oct. 15, 1970.
Conduct and Participation in a RICO Enterprise
through a Pattern of Racketeering Activity:
18 U.S.C. §§ 1961(5), 1962(c)
- Plaintiff now re-alleges each and every allegation as set forth above, and hereby incorporates same by reference, as if all were set forth fully herein. Substance prevails over form.
- At various times and places partially enumerated in Plaintiff’s documentary material, all Defendants did associate with a RICO enterprise of individuals who were associated in fact and who engaged in, and whose activities did affect, interstate and foreign commerce.
- Likewise, all Defendants did conduct and/or participate, either directly or indirectly, in the conduct of the affairs of said RICO enterprise through a pattern of racketeering activity, all in violation of 18 U.S.C. §§ 1961(4), (5), (9), and 1962(c).
- During the past ten (10) calendar years, all Defendants did cooperate jointly and severally in the commission of two (2) or more of the RICO predicate acts that are itemized in the RICO laws at 18 U.S.C. §§ 1961(1)(A) and (B), and did so in violation of the RICO law at 18 U.S.C. 1962(c) (Prohibited activities).
- Plaintiff further alleges that all Defendants did commit two (2) or more of the offenses itemized above in a manner which they calculated and premeditated intentionally to threaten continuity, i.e. a continuing threat of their respective racketeering activities, also in violation of the RICO law at 18 U.S.C. 1962(c) supra.
- The RICO enterprise complained of begins in the United States by way of false or unlicensed fundraising, the fruits of which then sent to Israel to start campaigns that inflate the severity of the problem, so as to put pressure on the ministry of Welfare to give ELI monopoly in certain territory so that when the public calls the hotline to complain of any minor behavioral problem with a child, ELI then is recommended to Arbel, Grunis and Daphne Barak Erez, who rubber stamp Welfare documents. Then police is used to kidnap the children, without due process, and place them in prisons for what is supposed to be three years but can last much longer. The money from the US is then spent for salaries, trips overseas and payments to confidants who work closely with Arbel, Grunis and Daphne Barak Erez.
Conspiracy to Engage in a
Pattern of Racketeering Activity:
18 U.S.C. §§ 1961(5), 1962(d)
- Plaintiff now re-alleges each and every allegation as set forth above, and hereby incorporates same by reference, as if all were set forth fully herein. Substance prevails over form.
- At various times and places partially enumerated in Plaintiff’s documentary material, all Defendants did conspire to acquire and maintain an interest in a RICO enterprise engaged in a pattern of racketeering activity, in violation of 18 U.S.C. §§ 1962(b) and (d).
- At various times and places partially enumerated in Plaintiff’s documentary material, all Defendants did also conspire to conduct and participate in said RICO enterprise through a pattern of racketeering activity, in violation of 18 U.S.C. §§ 1962(c) and (d).
- See also 18 U.S.C. §§ 1961(4), (5) and (9).
- During the ten (10) calendar years preceding March 1, 2003 A.D., all Defendants did cooperate jointly and severally in the commission of two (2) or more of the predicate acts that are itemized at 18 U.S.C. §§ 1961(1)(A) and (B), in violation of 18 U.S.C. 1962(d).
- Plaintiff further alleges that all Defendants did commit two (2) or more of the offenses itemized above in a manner which they calculated and premeditated intentionally to threaten continuity, i.e. a continuing threat of their respective racketeering activities, also in violation of 18 U.S.C. 1962(d) (Prohibited activities supra).
- Pursuant to 84 Stat. 947, Sec. 904, Oct. 15, 1970, the RICO laws itemized above are to be liberally construed by this honorable Court.
- Wherefore, Plaintiff Etti Ben Issachar demands Judgment against Defendant ELI and co-Defendants in the amount of $5,000,000 and Yaakov Ben Issachar demands judgment against Defendants Asher Grunis, Edna Arbel, Daphna Barak Erez and Michal Barak Nevo in the amount of $5,000,000, and an injunction enjoining the fundraising of ELI in the United States.
Plaintiff hereby demands trial by jury.
Dated: September 17, 2014
Yaakov Ben Issaschar
Plaintiff Pro Se
, Tel Aviv
 In fact, Yaakov Ben Issaschar wrote a letter to the UN commissioner in charge of freedom fighters, Ms. Margaret Sekkagya, on August 24, 2013, which best described the situation, Exhibit “1”.