UNITED STATES DISTRICT COURT DISTRICT OF NEW JERSEY _______________________________________ SHARON BEN-HAIM, SOL HAVIVI, and GAMLIEL ELMALEM,

Civil Action No: 2:12CV351(JLL) Plaintiffs, Vs. YAAKOV NEEMAN, MOSHE KACHLON, EDNA ARBEL, SIMONA SHTINMETZ, BATYA ARTMAN, NIVA MILNER, DANIEL EDRI, KONRAD ADENAUER STIFTUNG, INTERNATIONAL FELLOWSHIP OF CHRISTIANS AND JEWS, and NEW ISRAEL FUND, Defendants. ________________________________________ Plaintiffs, for their amended complaint against Defendants, do hereby set forth and allege, as follows: I. INTRODUCTION 1. This is an action filed by Plaintiff Ben-Haim as an alien under the Alien Tort
COMPLAINT JURY TRIAL DEMANDED

Claims Act, 28 U.S.C. 1350 et seq. (ATCA), and by Plaintiffs Havivi and Elmalem under TVPA. Plaintiffs seek relief and damages for gross violations of human rights and torture arising out of an institutionalized discriminatory laws and policies of gender apartheid against men, including disengaging and separating fathers from their minor children, the purposeful impoverishment of men, and the encouragement of use of the various arrest and detention techniques to jail men, and intimidate them from demanding parental equality. Plaintiffs contend that Defendants actions constitute crimes against humanity, violations of international civil and human rights, torture of Plaintiffs, their children and all other men who are similarly situated. Defendants and their agents, subordinates and functionaries, have acted

in concert with the members of the Israeli Judiciary and employees of the Israeli Ministry of Welfare in aiding, abetting, facilitating, directing, and orchestrating these practices of gender apartheid and the denial of the rights to fatherhood. Defendants actions constitute violations of the Law of Nations, international law, US laws, and the natural laws of man. II. PARTIES 2. Plaintiff, Sharon Ben-Haim, is a resident of New Jersey, since 2004 who

resides at 25-24 High Street, Fair Lawn, NJ 07410. Ben-Haim is the father of Ofir Ben-Haim, born September 10, 2009, in the United States, an American citizen who was abducted by her mother, Oshrat Ben-Haim, to Israel. 3. H1 visa. 4. Plaintiff, Sol Havivi, is a United States citizen born and raised in New York Plaintiff Ben-Haim is an alien residing in the United States who was granted a

City. He currently resides at 1 HaCarmel Street, Tel Mond 40600, Israel (Tel 011-972-54497-3652). Havivi is 47 years old and is the father of three children. The younger two children live with him after a bitter divorce, and excruciating and tormenting struggles with Court appointed social workers, but the older daughter is a victim of parental alienation syndrome and has refused to see him for 5 years. Havivi is now physically handicapped, penniless and about to become homeless. 5. Plaintiff, Gamliel Elmalem, is an American citizen and a former resident of

Lakewood, NJ with address at Chabad House, 25 Cottage Street, Jersey City, NJ 07306, USA (Tel 201-798-0056). He lived in Israel until recently, escaped to the United States during 2011, and has returned to Israel to try to unite with his children. Upon his return he

was arrested on a false domestic violence charge. He now resides at his parents home at 3 Duchifat Street, Box 4408, Yavne, Israel. 6. Defendant, Yaakov Neeman, is a resident of Israel with an official address of 4

Weitsman St., Tel Aviv 64239 Israel. Neeman is the Justice Minister for the State of Israel and is the official responsible for the implementation of international treaties, including the Treaty of Friendship, Commerce and Navigation (1950), and other multilateral conventions, pursuant to which he is the chief overseer that Israel ensure fundamental human rights including no discrimination, due process, right to family life, right to access children, right to travel, right to earn a living, the right to dignity and the right to be free from arbitrary intrusions into private and family life. 7. Upon information and belief, Defendant Neeman is a graduate of NYU, New

York University law School, who served as a visiting professor at NYU, Cardozo Law school and University of California at Los Angeles. Blvd., Forest Hills, NY 11375. 8. Upon information and belief, Defendant Neeman while serving as a minister He maintains an address at 11201 Queens

of Justice still retains his position as the head of Israels biggest law firm, and his clients include many tycoons including Americans, Daniel Abrahams, Charles Bronfman, the arms dealers Shoul Eisenberg and Marcus Katz, Robert Maxwell and Jonathan Kolber. He thus has extensive commercial interests and transactions with the United States, mainly advising clients on tax evasion. 9. Upon information and belief, Neeman served as a Minister of Justice 15 years

ago, but he resigned when charges of obstructing justice, false swearing and perjury were

launched against him in connection with dissuading a British millionaire from testifying in a corruption scandal. 10. Defendant, Moshe Kahlon, is a resident of Israel with an official address of 83 Narkisim Street, Atlit. He is the Minister of Welfare and Social Services for the State of Israel. He is the official in charge of social workers that are appointed in every divorce case in Israel to investigate the fathers, by appointing a social worker as a personal Probation officer, and determine whether, if at all, they will be allowed access to their own children. 11. Upon information and belief, Kahlon has signed certain agreements with the IFCJ and other Jewish federations to collect funds in the United States and propel them, into the industry of persecution of men in Israel, by giving social workers the power to dispense IFCJ money, and financing programs designed to portray divorced men as inherently violent, e.g. Cities without Violence a program designed to treat every man as a potential ticking bomb, and lock them up, and by hand-outs to feminist organizations such as Naamat, which use the money to incite hatred and propaganda against men. 12. Defendant, Edna Arbel, is a resident of Israel and is an Associate Justice with the Supreme Court for the State of Israel with an official address of Bet Mishpat Elyon, Sharei Mishpat St, Kiryat Memshala, Jerusalem. As part of her previous official duties, she was also responsible for drafting Attorney General Guideline 2.5 which is intended to encourage filing of false domestic violence complaints which improperly prejudice fathers custody and access claims relating to their minor children. As a Supreme Court of Justice Judge, her decisions are motivated by a radical agenda seeking to empower women at the expense of men, perpetuate gender based stereotypes, and disengage fathers from children, in total oblivion to the miseries of the fathers.

13. Upon information and belief, in her prior position as chief State Prosecutor she handed down several criminal indictments against public officials, who were eventually acquitted and as a result she was criticized that she started prosecutions despite lacking evidence or an adequate case to justify criminal charges, and that she lacks the professional judgment to continue in her senior position. Arbel prosecuted Benjamin Netanyahu, Yaakov Neeman, and Ariel Sharon, which turned out to be groundless. This is mentioned because in Ben-Haims case her legal theories also appeared groundless. Her main criticizers were Yaakov Neeman, Ehud Olmert and Avigdor Lieberman. Six members of the Parliament (Knesset) filed objections against her appointment, and the Knesset Law Committee held an emergency session on the matter of Arbels appointment. Upon information and belief, her appointment passed due to affirmative action. 14. Upon information and belief, Defendant Arbel also abused her position as Chief State Prosecutor when she asked then Communications Minister Limor Livnat to appoint her husband as a director in a State controlled telephone company, Bezeq. Livnat filed objections to Arbels appointment as a Supreme Court Judge, citing corruption. It is also believed she asked for her husband to be appointed as director in the State controlled maritime shipping company Zim. 15. Upon information and belief, during Arbels tenure as State Attorney and as Supreme Court Judge, she has manifested radical feminism agenda, and has consistently advanced appointments of radical feminists and male bashers, and has refused to acquit males on appeal in domestic violence or sexual harassment cases, even when other judges found no evidence to sustain such appeals, as she advocated the position that a female victim should always be believed on her claims alone, with no need for external evidence.

16. Upon information and belief, Arbel tailored bids for public servant positions in civil service, especially the police, to populate them with radical feminists to further develop tools for tormenting men via massive police arrests (e.g. Nurit Ziv). 17. Defendant, Simona Shteinmetz, is a resident of Israel with and address of 63 Ramat Bet haKerem, Street, Jerusalem, (Tel. 011-972-2-648-0153). She is the National Supervisor of Court Appointed Social Workers in Matrimonial Cases. She is responsible for developing policies which have artificially increased the use of supervised visitations centers in contact centers (20%-25% in Israel as opposed to 1% to 2% in the United States), as well as training social workers to appease women, and arm them with veto powers over fathers ability to see children. 18. Shteinmetz is also responsible for instructing social workers to treat any referral for investigation from a Court as an at risk/high conflict situation, and coerce interventionist measures, as well as compel therapy for men. 19. Shteinmetz is also responsible for orchestrating anti-male orientation sessions for social workers at radical feminist institutions, where the social workers are taught that men are inferior to women, men are inherently violent, Israeli men are the most violent on the world, men cannot take care of their own children, men can easily forget their own children and make new ones, and that the brains of men cannot produce neurons that pick up stress signals from young children. 20. Defendant Batya Artman is a legal advisor at the Ministry of Welfare with an official address of 6 Hasatat St, Jerusalem. Artman is actively producing opinions designed to perpetuate discrimination, and disengage children from fathers. She deliberately frustrates any

effort to align Israel with the rest of the world in the context of joint custody and equal access to children. 21. Defendant Niva Milner is the Regional Director of court-appointed social workers in Tel Aviv with an official address of 53 Haalon St. Yavne Israel. She is responsible for thousands of reports each year that deny fathers basic and/or minimal access and contact with their children, and collect and disseminate libel and fiction against those fathers. She encourages the treatment of all men as violent or aggressors, and she is responsible for execution of the contact center for everybody policy in the Tel Aviv area. 22. Upon information and belief, Milner is an employee of a municipality. She has filed thousands of false, perjuries reports against men, and coached social workers to fabricate false police complaints against men, so as to keep them away from seeing their children. 23. Defendant Daniel Edri is a Rabbi who sits in a Rabbinical Tribunal as a quasijudge (Dayan) and resides at or may be served at Regional Rabbinical Bet Din, 28 Yalag Street, Haifa 31052 Israel. 24. Edri has aided and abetted the kidnapping of Plaintiff Ben-Haims child, by trapping Ben-Haim in Israel, threatening needless arrest, and refusing to vacate a ne exeat order issued against the child to keep her in Israel. Edri is currently tormenting Ben-Haims father in retaliation. 25. Upon information and belief, Edri is not a lawyer or judge. He is trained in ancient Jewish laws, and sits in a tribunal, which lacks any characteristics of a Court, i.e. no evidence rules, no adversarial rights, active coaching of litigants during sessions what to argue. Edri has persecuted thousands of men who are compelled against their will to appear in a religious tribunal.

26. Edri has sent letters to Rabbis in New Jersey demanding that they excommunicate Plaintiff Ben-Haim, publish his name and picture anywhere possible as a criminal and approach Plaintiff to compel him to follow commands. 27. Defendant, Konrad Adenauer Stiftung (KAS), is an entity existing and organized under the laws of the nation of Germany with an address of 2005 Massachusetts Avenue, NW, Washington, D.C. 20036, U.S.A. KAS is ostensibly engaging in charitable activities with branches in Israel and in New York. KAS is funding radical feminist groups that are devoted to the destruction and annihilation of fathers or men in divorce in Israel. 28. Upon information and belief, KAS conducts commercial activities in the US and in NJ. For example, KAS sponsored trips to Germany of New Jersey and other US residents, including Muslims to Auschwitz (reported on November 15, 2010 a trip with Rabbi Jack Bemporad of Center for Interreligious Understanding (NJ) in Carlstadt, NJ followed by event at South Orange, Seton Hall auditorium at Jubilee Hall. 29. Upon information and belief, KAS publishes or sponsors books and articles with Princeton University Press, Princeton, NJ. 30. KAS also offers grants and scholarships to all US residents, including residents of NJ. 31. Defendant International Fellowship of Christians and Jews (IFCJ) is a United States charity based in Washington, D.C. with a business address of 30 North LaSalle Street, Suite 2600, Chicago, IL 60602-3356. 32. Allegedly, IFCJ was founded by Rabbi Yechiel Eckstein to promote understanding between Jews and Christians, but IFCJ collects donations from evangelical

worshippers in the United States, and sends the funds to charitable causes, and also directly to Minidtry of Welfare (I,e. to Defendants Kahlon, Shteinmetz, Milner and Artman). 33. While IFCJ donors believe in the strength of the families, IFCJ sends money to organizations such as NaAmat in Israel, which are devoted to the break-up of Jewish families, annihilation of men in divorce, and disengagement of fathers from children, and to another program City without violence headed by ultra feminist Orly Innes who advocates that all men are inherently violent. 34. Upon information and belief, IFCJ works as the alter-ego of Kahlon, Shteinmetz, Milner and Artman in the United States, collecting money in the United States and transferring it to Kahlon, Shteinmetz, Milner and Artman, so that they continue the persecution of men in Israel beyond the budget allocated by the Government of Israel for these purposes, with US money. 35. Defendant New Israel Fund (NIF) is a U.S. based nonprofit organization located in New York with an address of 330 Seventh Avenue, 11th Floor, New York, NY 10001-5010. NIF donates money to radical feminist groups, which espouse, advance and take part in the wrongful actions set forth in this complaint. 36. Upon information and belief, NIF actively solicits donations in the US and in NJ. At least two local synagogues, Congregation Shomrei Emunah, in Montclair, and the Reform Temple Ner Tamid of Bloomfield, are sponsors of NIF, where NIF events are held. 37. The events are described to the public as civil rights, religious pluralism, environmental, and poverty-fighting, but in reality a large proportion of the money is sent to organizations that advocate the alienation of fathers from children.

38. Upon information and belief, other NIF lectures and activities are organized in NJ in association with the Amy Adina Schulman Fund at The Jewish Center, in Princeton, New Jersey. For example, in 2011 the guest speaker was Bruce Temkin, NIF NY director. 39. Upon information and belief, one of NIFs chief directors is Peter Shapiro of South Orange, NJ. 40. Upon information and belief, NIF is registered with the Division of Consumer Affairs Charities Registration Section, under the provisions of the Charitable Registration and Investigation Act (N.J.S.A. 45:17A-18 et seq.), the "CRI Act." 41. Plaintiffs bring this complaint on their own behalf, as victims of systematic persecution, torture and denial of civil rights of men in divorce proceedings, who are subject to torture, abuse, and threats of great harm by, or as a direct and proximate result of, Defendants actions as described herein. III. JURISDICTION AND VENUE 42. The Court has subject matter jurisdiction over this case under the Alien Tort

Claims Act (ATCA) 28 U.S.C. 1350, as to Plaintiff Ben-Haims claims and pursuant to the Torture Victim Protection Act of 1991 (TVPA) 28 U.S.C. 1350 Pub. L. 102256, note 2(a), as to Plaintiffs Havivi and Elmalems claims. 43. The court also has jurisdiction pursuant to 28 U.S.C. 1331 encompassing

actions which present a federal question. 44. The Court has diversity jurisdiction between Ben-Haim and Edri pursuant to

28 U.S.C. 1332 (diversity jurisdiction) because Plaintiff Ben-Haim is a resident of this district, Defendant Edri resides in the State of Israel, and the impact of Defendants actions impact Plaintiffs in this district.

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45.

Moreover, Defendant Edri availed himself of the jurisdiction by aiding and

abetting the violation of an anti-suit order issued by a New Jersey Court, and sent letters requesting New Jersey rabbis to approach and intimidate Defendant Ben-Haim, with instructions not to bury the body of Ben-Haim. 46. Defendant Neeman derives substantial benefits from commerce with the

United States in his private practice, and upon information and belief maintains an address in New York. 47. Upon information and belief, immediately after two witnesses located in Israel

have signed declarations on June 15, 2012 to be presented to this Court, and indeed so filed, Defendant Neeman instructed Israels Administration of the Courts to crack down on dissident and recidivist fathers. One witness, Guy Shamir was arrested and kept in custody for 40 days, and the other, Amir Shipperman was interrogated by Israels elite police force, his house searched and computer seized. Shipperman was told that any activity on behalf of fathers rights will result in immediate suspension of child access and criminal indictment. Six other activists (and one mother) were also arrested or interrogated or their computers seized in a massive wave of arrest, which upon information and belief was ordered by Defendant Neeman. Thus, Neeman has tampered with potential witnesses and evidence and/or attempted to tamper with witnesses or evidence belonging to a pending New Jersey case, and subjected himself to jurisdiction. 48. Defendants Kahlon, Shteinmetz, Milner and Artman have availed themselves

of the jurisdiction of New Jersey by selecting IFCJ to solicit funds and donations in the USA and NJ to be spent in Israel on programs and buildings designed to disengage fathers from

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children, and to collect for them funds which they give to social workers for hand outs to the needy, or to satisfy payments for claims of abuse of power. 49. Defendants are subject to suit in the courts of the United States pursuant to the

Foreign Sovereign Immunities Act, 28 U.S.C. 1602 et seq., because their conduct falls within the exceptions to foreign sovereign immunity set forth in 28 U.S.C. 1605(a)(5) and 1605(a)(7). 50. Defendant committed tortuous acts with impact on the United States.

Alternatively, Defendants raising of funds within the US are commercial activities carried on in the U.S. by the foreign Defendants or by their agents, KAS, NIF and IFCJ, and/or acts which were performed outside the U.S. in connection with commercial activity outside the U.S. and which causes a direct effect in the U.S. 51. The amount in controversy, both individually and collectively, exceeds one

million U.S. Dollars. IV. FACTUAL BACKGROUND 52. Plaintiffs claims arise in conjunction with widespread discrimination against

men in Israel, especially during divorce, which results from years of radical feminist brainwashing that men are inferior, dangerous and unworthy of contact with children 1 . Against this background, Plaintiffs efforts to obtain custodian and/or access rights and/or visitation rights of their minor children in Israel are illustrative of the discrimination, since the Defendants automatically give the children to women, with veto powers to block the fathers pleas for child access.
1

For example, on January 3, 2012 Defendants Kahlon, Shteinmetz, Milner and Artman conducted an indoctrination conference for the social workers at the Rackman Center, where they learned that mens brains cannot produce neurons that pick up stress signals from children, and that fathers are unnecessary in childrens lives.

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53.

In the case of Ben-Haim, his child was illegally removed and kidnapped from

the United States to Israel, and because of the Defendants discrimination and hatred towards men, was unable to rescue his daughter from Israel. 54. In each case, Plaintiffs minor children had been used by their mothers to

alienate the children from their fathers, under the active encouragement of the Defendants, who believe that children belong with their mothers, and that children should be disengaged from their fathers to empower the mothers or to compensate for historical oppression of men against women. 55. In Ben-Haims case, following the abduction, once in Israel, the childs mother

refused to return the child to the US. Ben-Haim sought relief in Israel pursuant to the Hague Convention on the Civil Aspects of International Child Abduction. Pending disposition of the Hague Petition, he sought interim access rights to his child. Plaintiffs efforts to obtain relief were thwarted, though, by Defendants failure to take action to abolish institutionalized policies elevating the rights of women over the rights of men in Israeli child custody cases, and failing to provide due process. These policies violate Plaintiffs civil rights and basic human rights; they are discriminatory and create statutory presumptions and a prevailing atmosphere of hate against men in divorce within the Judiciary, social workers and the police. 56. Plaintiff Ben-Haims Hague Petition in Israel was ultimately denied by

Defendant Arbel who ruled in defiance of law and common sense that Plaintiff Ben-Haims participation in divorce and custody negotiations constituted acquiescence to abduction.2 He was compelled to travel to Israel to testify, where Defendant Edri waited for him as easy prey,
2 Arbels Judgment poses a risk to the International Community as the Permanent Bureau of the Hague Convention is now developing in the Malta Process a new international Guideline for international mediation in abduction. When the highest Court in Israel states that an attempt to negotiate constitutes acquiescence, it will deter spouses from mediating.

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and restricted his ability to exit Israel for 4 months to coerce him to succumb to Oshrat BenHaims demands. Ben-Haim was also interrogated at the police twice for false claims. 57. Prior to Ben-Haims case, Israel persistently refused to return children

abducted by mothers due the belief of officials in Israel that women are superior. Other men who came to testify in Hague Convention cases were also trapped in Israel by rabbinical Dayanim, and some were arrested. (One man, Noam Hupert [Dkt. No. 47] had to travel from Australia to testify in a Hague case in Israel, and upon his arrival was arrested. The same happened to a man who travelled from Spain, Dan Cohen [Dkt. No. 48]). 58. Plaintiffs inability to obtain relief is a result of, among others, discriminatory

and statutory presumptions in Israeli family law and cases, which create an atmosphere of hate against men in divorce among the Judiciary, social workers and the police. 59. In Israel, women are improperly favored in divorce proceedings and receive

preferential treatment. However, because Plaintiffs are American, they are entitled to the same level of treatment as that enjoyed by Israeli women. In other words, while Israeli men may remain inferior to women, American men in Israel are entitled to equalizing protection via the bilateral treaties. Specifically, American Plaintiffs are entitled to protections under the Treaty of Friendship, Commerce and Navigation between Israel and the United States, signed in 1951 (the Friendship Treaty). However, Defendants Arbel, Neeman and Kahlon failed to comply with such treaties between Israel and the US, which prohibit the preferential treatment of women in Israeli child custody cases where the father is a United States citizen. 60. Pursuant to the Friendship Treaty, Article 5, the Plaintiffs are entitled to a

most favored nations treatment with respect to access to the Courts of Justice in pursuit

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of and in defense of their rights. Pursuant to article VI (1) property of nationals and companies of either party shall receive the most constant protection and security. 61. In essence, Plaintiffs are entitled to treatment in Israel that is no less favorable

than the sector that receives the most preferential treatment in Israel, and in Israel the sector that receives the most preferential treatment is women in divorce or separation. 62. Contrary to the Friendship Treaty, Defendants Arbel, Neeman and Kahlon

continue to deny the benefits and protections of the Treaty to all men. 63. Examples of preferential treatment for women in divorce proceedings include

automatic interim child custody, presumptive permanent custody, exemption from producing financial records, exemptions from paying child support or from contributing to child support, and the luxury of filing false police complaints and causing the arrests of the male spouses without evidence. 64. Men in Israeli divorce proceedings are also routinely denied due process and

fair hearings because they are not allowed in many cases to cross examine wives or witnesses, family courts refuse to issue necessary subpoenas for witnesses and financial records, refuse to hear witnesses on behalf of husbands, improperly limit trials to 30 minutes or a few questions per side, and refuse to mark exhibits or admit proof into evidence. In most cases, men are not permitted by Judges to cross-examine other witnesses, including the social workers who are appointed by the Judges. 65. Upon information and belief, these tactics were developed or condoned by

Defendant Arbel, who consistently refused to allow any appeal on these issues to proceed. 66. The Judiciary, under the watch of Defendants Neeman and Arbel, also allows

women to file ex parte motions and enters immediate remedies for any relief sought by the

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women. However, the mens applications for relief are deliberately postponed for months or years, to allow women to accrue tremendous child support delinquencies, which will be recovered from the husbands half of the marital property when distributed3. 67. Most egregiously, Defendants Arbel, Neeman and Kahlon did nothing to

abolish the immunity for women from making false domestic violence complaints in support of their divorce cases. As referenced above, these false domestic violence actions are granted presumptive validity by the courts and men are precluded from substantively contesting the allegations. There is no ability to talk to potential witnesses, (otherwise a new charge of obstruction of investigation will be tacked on), no ability to access or examine evidence or the scene, and any attempt to challenge the prosecution results in further charges of tampering with evidence or testimony. 68. Conversely, men are discouraged at police stations from filing domestic

violence complaints against wives or partners, when they are attacked. In Elmalems case, despite being brutally attacked and permanently scarred by his wife, he ended up being

Some Judges, for example, Esperanza Alon of Haifa or Tova Sivan, President of the Family Court in Tel Aviv District, simply issue Judgments on the merits without proofs or even scheduling a trial. In 2005, an American from Indiana, Evan Watkins found his way to Judge Sivans courtroom in a custody case. Judge Sivan unequivocally told Watkins that anybody can raise children, except their biological fathers. Watkins family engaged senators from Indiana and California to write letters of protest to Defendant Neemans predecessor, as they were outraged by Israels systematic disengagement of fathers from children, and apparent discrimination under color of the law. The letters from the American senators fell on deaf ears. To this day, Judge Sivan continues to abuse and torment fathers, and to deny them basic familial rights. At the same time she imposes thousands of dollars in sanctions to deter further applications for contact with children. In July-August 2012, Sivan, Esperanza Alon, Esther Stein, Shifra Glick had used Israels Judiciary intra-net email to send messages to other judges to treat men harshly, and do whatever they can to quash the fathers protest in Israel. They also started filing criminal complaints against fathers who are active in protests. The letters of Evan Watkins American family, which detail five cases of abuse that occurred six years ago shows a pattern of abuse by against biological fathers in Israel. See Exhibit A; Letter of Shoshana Harper, dated October 7, 2005.

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arrested and charged. Thus, Defendants Arbel, Neeman and Kahlon failed to protect the physical safety of Israeli and American men in Israel. 69. The nature of the unfair treatment, because it destroys the parental relationship,

is equivalent to torture and violates the most fundamental international human rights. 70. The parental relationship, particularly the relationship between parents and

their minor children, is vastly more important and deserving of protection than the material concept of property. It is the most basic of human rights. 71. Defendants Arbel, Neeman and Kahlon, Shteinmetz, Milner and Artman

engage in a systematic practice of torture, violations of human rights and egregious gender discrimination for the intentional purpose of separating fathers from their natural born children in proceedings related to the dissolution of family relations. 72. In order to perpetrate the assault and torture of men, Defendants utilize a

myriad of tools to suppress men and torture them, as follows: a. Defendants protect, condone and encourage abductions of children from foreign countries to Israel by women, where women enjoy the presumption that the best interests of the child is equal to the best interest of the abducting mothers, b. Defendants automatically disengage fathers from children either completely or by sending men to visitation centers. c. Defendants encourage women to file false domestic violence complaints against men and remove them from their homes, thereby preventing the fathers from physically being in contact with their children.

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d.

Defendants policies validate false domestic violence complaints, thereby giving women unfair advantages financially and in matters of custody, while the men are removed from the home and/or locked up in the custody of the police.

e.

Defendants policies place greater evidentiary weight on the womans testimony and evidence in family courts and criminal Courts, (i.e. a womans testimony is always considered more credible than that of a men),

f.

Defendants automatically and without Due Process grant motions against men, most times ex parte, or they aid and facilitate such practices,

g.

Defendants impose unconscionable child supports awards on men regardless of the womens income or the mens actual income (sometimes at 80% to 250% of the mens actual salary) for the improper purpose of prejudicing them, making them unable to meet court imposed obligations and coercing them into giving up their parental rights, and their share of the marital property,

h.

Defendants attribute to men fictitious imputed salaries without testimony or evidentiary support,

i.

Defendants deplete mens property and transfer it to their wives without testimony, evidentiary support or Due Process,

j.

Defendants policies cause men to be arrested without due process for inability to pay child support, be arrested on charges of anticipatory refusal to divorce, be arrested on false domestic violence charges, result in the revocation of mens passports and drivers licenses, and deny men the ability to work by issuing a constant stream of executions and levies.

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k.

Defendant Edri and his colleagues routinely support womens claims in divorce, routinely award automatic custody to women, routinely issue ex parte orders of arrest of men, even non-residents, based on spurious charges of potential to refuse to divorce, routinely issue ex parte orders restraining mens abilities to leave the State of Israel, and routinely transfer marital property to women or curtail the mens right to equitable distribution by allowing women exclusive possession until the children mature. In cases of abduction by women of minor children, because of the ancient religious policy of preference for custody with women, Defendants and Edri support and facilitate kidnapping by helping the women kidnappers trap the fathers in Israel with excessive bonds, threats of arrest and ex parte orders.

l.

In the area of child abductions, Defendants consistently violate the objectives of the Hague Convention on the Civil Aspects of Child Abduction by systematically denying left behind fathers their right to a speedy return of children abducted by mothers to Israel. The Defendants ideological adherence to the Tender Years Presumption, the statutory discrimination in favor of women and the overall preferences in favor of women and mothers inspired by radical feminism, (or in the case of Edri, the fear of violating the anti-male feminist trends for fear of losing his job), enables Defendants to prolong litigation, interpret the Convention in contrast to the rest of the world, and, in the rare case a father wins a Hague Convention case, impose drastic and draconian financial conditions that are unaffordable to ordinary men. See Exhibit B. Edri and his cohorts set up legal and jurisdictional traps for the

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men who come to Israel solely to testify on the issue of abduction by issuing ex parte orders of arrest, ex parte restraining orders on properties and bank accounts, and ne exeat orders secured by exorbitant bonds (in one case $500,000). Defendants coerce the men into divorce and to submit to a Rabbinical jurisdiction that they would otherwise not be subjected to. Edri is now issuing orders against Ben-Haims father in retaliation. 73. Fathers, or any male in matrimonial proceedings, are automatically treated as

second class citizens by family courts, rabbinical courts and the social workers that answer to anti-male policies disseminated and enforced by Shteinmetz, Artman and Milner. Defendants intentionally discriminate against such men who lose the basic protections of human rights. 74. Indeed, a man in divorce proceedings in Israel is subject to institutionalized

torture and constant denial or deprivation of civil rights. The defendants Neeman, Kahlon and colleagues of Arbel at the Supreme Court of Justice refuse to recognize any rights to fatherhood, family life and contact with children, and to achieve their goal they subject men to deprivation of life, liberty and property. They routinely divest and destroy mens rights in this area by failing to conform to the laws, practices and policies of international standards of equality and right to family life. 75. Defendants officially interpret the right to family life as dependent on the

concept of mothers consent, which the international community, European Court of Human Rights and other international tribunals discarded long ago. Similarly, Defendants fail to treat men and women equally as they officially advocate that the best interest of the child is equal to the best interests of the mother.

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76.

The mothers consent doctrine, advocated by Neeman, Kahlon, Shteinmetz,

Artman and Milner obviously offends jus cogens4 and discriminatory because its very nature is to favor one partys position over another without any evidentiary scrutiny, assessment of accuracy or actual of proof. It is completely subjective and without basis in fact.

Perpetuating these policies allows for judicial, emotional and economic tools of extortion. 77. Despite many opportunities, Defendants have done nothing within their powers

to terminate the policies of egregious and unconscionable gender-apartheid, as follows: a. The Tender Years Presumption gives automatic custody of children to mothers, pursuant to Article 25 of the Guardian and Capacity Law, which Defendants never took steps to terminate its effect. b. Under Kahlons supervision, all men are sent to court appointed social workers who act as personal criminal probation officers and cancel visitations without reason or notice. c. Due to policies promulgated by Defendants Shteinmetz, Artman and Milner, and endorsed by Defendant Kahlon, the rate of supervised visitations (2033%) in Israel is the highest anywhere in the world. The rate in the U.S. is 13%. See Exhibits C & D. d. The rate of childrens removal and outplacements is also the highest in the world.5 e. The rate of false arrests and false convictions is also extremely high; the false arrests are an institutionalized tool used to disengage fathers from children.

See the recent case Atala v. Chile at the Inter-American Court of human rights, where the judges and various amici concurred that discrimination against lesbians and gays offends international human rights. 5 See: http://www.mchp.gov.il/default/Pages/Residential%20Education_Care%20in%20Israel.aspx

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f.

Pursuant to policies endorsed by Neeman, women are exempt from paying child support in all cases, allegedly based on religious law. Child support awards do not take into account the womens income in setting the child support amount. Child support awards should be formulas based on

disposable income as in other developed countries. Instead, Israeli child support awards are based on multiplying the number of children by a certain minimum (about $450 per child), and adding additional amounts (e.g., 30%, 40% and 50% of the womans monthly rent, medical, dental, extracurricular, babysitting, and other expenses a judge feels like including). As a result,

most men are burdened with child support awards substantially exceeding their income. This rate of non-disposable income vs. award of child support is unconscionable and is the highest rate in the world. See Exhibit E. 78. Defendants also imposed and enforce discriminatory domestic violence

guidelines. Defendant Arbel herself drafted the policies that exempt women from prosecution for false reports, and thus she encouraged free and careless false reports by women at police, and perjuries at family courts. This results in automatic removal of husbands from homes, and placement of men in police custody, as well as a high rate of false convictions, and suicides. 79. Defendants have done nothing to stop the routine separation of children from

their fathers for long and intolerable periods. All fathers are subjected to compelled interventionist methods of social workers, (under supervision of Kahlon, Shteinmetz, Artman and Milner), and costly parental fitness evaluators, which increase the impoverishment of fathers. See Exhibit F, Parliamentary Report of Dan Shcnit on the futility of parental

22

fitness exam, published September 26, 2011. These practices affect about 10,000 fathers every year, and result in about 50% of the national number of suicides, 200 divorced men out of 400 total. See Exhibit G, Suicide Date from the Ministry of Health of Israel. 80. In defiance of all international standards, the Israeli family and rabbinical They systematically grant

courts do not engage in objective determinations of justice.

women interim custody and refer the men to social workers who become the true decisionmakers. The social workers are trained to assist women in denying visitations to the men, and assist women in filing false police reports. The gender training of social workers is supported by funds provided by KAS, IFCJ and NIF to radical feminist organizations, who are hired by Kahlon, Shteinmetz, Milner and Artman to train the social workers. 81. Defendants Neeman and Arbel have done nothing to clean up the family courts

from the mechanisms that turned the family courts into butcher-shops for men. There is no due process in them and hardly any evidentiary hearings. Judges capriciously issue The family courts

Judgments without trials, proper testimony or any evidentiary record.

merely schedule endless numbers of conferences. The conferences are not on full record, are dominated by the judge, and routinely deny the husbands attorneys any participation. Similarly, decisions on applications benefiting husbands, such as equitable distribution of marital assets or child access, are deliberately delayed for months or years. By contrast, applications benefitting women are decided immediately or within days based on affidavits containing ridiculous unsupported allegations not tested by cross examination. 82. If the Court must conduct a trial, judges limit the trial to 30 minutes per side to

avoid elicitation of facts adverse to the womens positions.

23

83.

It is even impossible to apply for child support reduction or visitation

enlargements because those applications are routinely denied without hearing and often result in exorbitant monetary sanctions that further impoverish the men. 84. Defendants policies also deny men due process by refusing applications to

summon witnesses or financial records, denying applications to cross examine social workers hearsay reports, and issuing judgments without trials. Family Court proceedings lack due process, fair justice and equal protection. In addition, Defendants have made it impossible to appeal from family court are intentionally expensive and unaffordable. A minimum $3,000 bond is necessary to secure an appeal, as well as court fees. 85. The policies result in ongoing damage to the father-child relationship through

the imposition of supervised visitation requirements, regardless of risk factors. The per-capita rate of supervised visitation in Contact Centers in Israel is the highest in the world (2,200 families per year, out of 6,000 divorces-with-children (but the number is higher as there are 1,000-1,500 in waiting list). See Exhibit C. Official data from the Ministry of welfare is attached as Exhibit H. Periods of State-enforced disengagement and alienation can last two to five years and in an extreme case, 12 years 6. 86. Defendants Shteinmetz, Milner, and Artman actively develop more

discriminatory policies also impose a strict, cruel and unconscionable regime of supervised father-child relationships. 87. Despite the obvious harm in constraining and limiting the father child

relationship, these decisions are imposed without any evidentiary determinations. Family
6

Since this case started, Defendants Shteinmetz, Milner, and Artman have intensified the rates of parental alienation by opening two additional Contact Centers and populating them with additional 500 children. It is believed that IFCJ and its co-partner the Jewish Federation collect funds in the US to building these centers.

24

Court judges simply delegate the authority to determine the fathers level of contact with his children to state employed social workers, as court aides. 88. In making their determinations, social workers utilize a presumption that the

mother is the parent best suitable for custody under Capacity and Guardianship Law, Section 25. As a result, women are routinely granted primary physical custody rights on application alone. Conversely, men are sent to social workers for investigation, character assessment and reports. This practice is discriminatory on its face, and it is supported and advocated by

Defendants Neeman, Kahlon and Arbel. According to Shteinmetz, social workers must apply interventionist methods even if the Court only orders an investigation. 89. The social workers routinely threaten the fathers, and collect rumors and false

statements against them, entice women to file false domestic violence complaints to expel men from their own homes, and delay proceedings pending referrals to private and costly Dangerous Propensity Tests or Parental Fitness Tests. These tests feed a booming industry of psychologist and mental evaluators at $5,000 per test, while the professionals who administer them admit that the tests have no scientific validity7. 90. More specifically, those fathers who take Parental Fitness Tests, are degraded,

punished, and subjected to non-scientific experimentation that is non-scientific, highly subjective, and non-clinical. 91. Moreover, it is simply degrading and dehumanizing for a father who devotedly

raised his children during the marriage and behaved as a fit and responsible parent to be

7 This is stated in a recent report presented to Defendant Neeman by Prof. Dan Schnit, available in Hebrew only. The Schnit Committee Report calls for the abolishment of the parental fitness testing, and abolishment of the Tender Years statutory presumption, but Defendant Neeman refused to endorse the recommendations on September 27, 2011.

25

questioned simply because he appears in Israel. Those policies subject men to an unfair and discriminatory system that doubts their ability to parent and torments them. 92. As a general rule, appointed social workers routinely send the men to see their

children in supervised visitations centers one hour a week. Even if a report initially makes certain favorable findings to men, the moment a woman is displeased with the arrangement, the visitations or even co-parenting is immediately suspended, and the father goes to a Contact Center. 93. The requirement of supervised visitation is imposed simply upon the mothers

request. Simona Shteinmetz admits this in the press by the official in charge, Defendant Simona Shteinmetz. Defendant Kahlon also admitted this at the Israeli parliament8. 94. As a result, fathers are treated like criminals, branded as dangerous, and only

get an hour or two per week with the children, for several years. 95. The supervised visitation system is also designed and operated to prejudice

fathers rights. The supervised visitations take place at the social workers convenience, and only one or two hours per week of visitation during the fathers work hours. The States policies requiring supervised visitation causes men to miss work, lose income and jeopardize their careers in order to see the children. 96. Before a father may see his child in supervised visitation, a social worker must

issue a report. These reports take six to nine months to issue and often are supplemented by additional reports before allowing the fathers to see their children. 97. The process used to prepare social worker reports is faulty and inherently

discriminatory. The social worker merely collects any piece of libel and defamation from the

See on YouTube: http://www.youtube.com/watch?v=hAs8wrhqY4M

26

woman and encourages the woman to manufacture lies. Manipulated character assassination of men is the usual practice of such Social workers. 98. These practices violate the guarantees under article 10 of the International

Covenant on Economic, Social and Cultural Rights (ICESCR), and its equivalent in other international conventions, since the right to family life becomes conditioned on satisfying the whims of a hostile and biased social worker in every case and as to each child. 99. These practices, endorsed by Defendants Kahlon, Shteinmetz, Artman and

Milner, feed an industry of prejudiced social workers at huge costs to society. The policies are driven by a philosophy of woman empowerment that destroys mens self respect, privacy and their human to be parts of their childrens lives. Defendants Kahlon and Shteinmetz are responsible for the social workers training school, at 1 Jabotinski Street, Ramat Gan, where the curriculum comprised only of women empowerment lectures, radical feministic indoctrination and interventionist theories. 100. This system was created and enjoys continued support through Defendants

policies and actions, and their financiers, KAS, NIF and IFCJ. 101. The state of Israel and the United States are signatories to international

covenants such as the International Covenant on Civil and Political Rights (ICCPR), ICESCR and the Convention on the Rights of the Child (CRC). Despite those agreements, Israels courts systematically refuse to recognize a fathers right to see his children without state intervention or interference. Instead, Neeman, Kahlon, and their subordinates require fathers to demonstrate why the childs best interest warrants such contact. Because of this failure, fathers must submit to the authority of social workers and supervised visitations, while women get automatic interim custody without a fair, evidentiary and adversarial hearing.

27

102.

These policies result in most men only seeing their children in a prison-like

setting for one or two hours per week because the Ministry of Welfare automatically refers men to supervised visitations whenever a woman voices disagreement with regular visitations. 103. Supervised visitation occurs for at least one to two years, and can be longer.

During the visits, men must yield their rights and civil liberties to the guards on duty. There is no remedy available to a father if a woman does not bring the child to the center. 104. Attorney General Guideline 2.5 immunizes women, but not men, from

prosecution for false domestic violence arrest. See Exhibit I. Women are encouraged by the authorities and the social workers to file as many domestic violence complaints as possible, in order to perpetuate the child alienation and disengagement periods. The discriminatory guideline is a tool used to cut off children from fathers. 105. Defendant Arbel, drafted said Attorney General Guideline 2.5 when she was

Attorney General of the State. A pending petition to revoke it will likely be dismissed. 106. Defendants routinely convict men merely on the unsupported and uncontested

allegations of a purported victim. No evidence is required other than the rehearsed words of the woman. This is the pattern and practice in Israel even when there were no domestic violence complaints, or complaints that the man posed a danger to the well being of the child or woman, before the divorce. Despite this questionable basis, domestic violence complaints result in the immediate removal of the husband from his home. clothing, records, personal belongings, and his children. 107. Once judgments are rendered, and often they are issued ex parte without trial, He is cut off from his

an unconscionable mechanism of usurious post judgment collections is utilized to further destroy the mans livelihood, ability to work, his morale, spirit and sanity. Courts impose a

28

constant stream of executions and levies carrying up to 50% interest and exorbitant automatic attorney fees to leverage men into giving up. 108. Defendants practices result in thousands of children being disengaged from

their fathers every year, thousands of fathers being needlessly arrested, and thousands of fathers being forced to live in fear, taunted by endless and persistent persecution. The abuse results in about 150-200 suicides of divorced men every year. 109. The institutionalized and statutory discrimination against fathers in Israel is a

violation of international treaties. A complaint based on these discriminatory policies filed on behalf of the fathers rights organizations in Israel is pending before the United Nations Committee on Economic, Social and Cultural Rights, and is scheduled to be heard on November 15-16, 2011 in Geneva. A true and correct copy of the United Nations Rights Complaint is attached as Exhibit J. Five more individual complaints were sent to the UNs Human Rights Council in August 2011, detailing torment and abuse. 110. American citizens in Israel victimized by outrageous conduct designed to

disengage them from their children and impoverish them have organized as a group called fathers 4 Justice Israel. 111. Many of them were victims of Judge Rivka Mekayes, a former attorney with

the Israel Womens Network, who published guides for women detailing how to file false and fictitious domestic violence charges against men Exhibits K, and L. After her judicial appointment, she began terrorizing men and disengaged thousands of children from their fathers, while awarding outrageous child support awards.

29

112.

Mekayes and the other Defendants have acted only to enable the American

citizens former partners physical and emotional abuse of the joint children and to increase the childrens alienation from the fathers. 113. For the past three years, many American citizens residing in Israel have been

able to meet their children only at a contact center. 114. In fact, American citizens joined a support group called "Fathers injured by

Judge Rivka Mekayes. The judge, herself, is a victim of parental alienation syndrome, reportedly having had no contact with her divorced father. 115. Rivka Mekayes is the lead author of a 1992 guide teaching women how to

fabricate domestic violence charges. See Exhibit M. The judge now lectures on false accusations in her spare time. In her courtroom she is the last to recognize child abuse, parental alienation and false accusations. 116. American citizens in Israel are also victims of the Defendants policies

requiring fathers to undergo Parental Custody Evaluation at mental health clinics that evaluates fathers without even seeing them, and depend financially on manufacturing reports that suit the discriminatory policies of Kahlon, Shteinmetz, Artman and Milner. 117. It is impossible to seek remedies for gender discrimination or exhaust remedies

in Israel based on international human rights, because Israel does not recognize any UN Convention internally. While Israel signed some UN Conventions, it did not adopt them internally, and they are meaningless in Israel. 118. Thus, for example, in March 2011, one such father who has not seen his six-

year-old child in three years, (even though the child resides within 3 city blocks), filed a Collective administrative petition against Defendant Kahlon with the High Court of Justice in

30

Jerusalem, where Defendant Arbel is a chief judge to show cause why the right of fathers to child access is unrecognized, but colleagues of Defendant Arbel, (J. Itzhak Amit) dismissed it ex parte, on September 27, 2011. In fact, Judge Amit stated that he does not even understand what the Petitioner and 29 other co-Petitioners want. 119. In 2012 a collective Petition to abolish exemption of women from child

support launched by Guy Shamir was assigned to Defendant Arbel, who refused to schedule a hearing. Several months later, Shamir was framed by his family court judge, Esperanza Alon, who filed false charges that he threatened her, and was incarcerated for 40 days since August 10, 2012. [Dkt. No. 66] 120. Shamir also signed a declaration on June 15, 2012 in support of this case, and

thus became a target for retribution. Also Amir Shipperman filed a declaration in this case. He too was called to the police and his computer was seized. 121. In fact, the witnesses who filed declarations in this case, and those who

assisted them became targets for retribution9. See, Declaration of Adi Vaxman, a New Jersey citizen, [Dkt. No. 45] Declaration of Amir Shipperman, [Dkt. No. 49] Declaration of Guy Shamir, [Dkt. No. 50] 122. In a recent Supreme Court case in Israel, Orit Goren v. Home Center, on May

17, 2012, Judges of Israel Supreme Court actually praised the values of radical feminism

See, Israel Jails Dads Protesting Family Courts (Sep 6, 2012), at http://www.fathersandfamilies.org/2012/09/06/israel-jails-dads-protesting-family-courts and Wave of Arrests of Father's Rights Activists, (Aug, 31, 2012) at http://www.israelnationalnews.com/News/News.aspx/159496

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and stated that every matter involving men versus women should be looked at through the prism of radical feminism. In a jurisdiction that actually praises radical feminism; no man has a chance to obtain any remedy whatsoever, and for men to exhaust remedies in Israel is an exercise in futility, especially so since in August 2012 family court judges who are most antagonistic to men, usurped to judges intra-net email system to request other judges assistance in quashing fathers rights, and 7 men were arrested on spurious charges launched by the judges in different parts of the country, together with tv promotions, and recruited journalists at Haaretz and Maariv, who slammed fathers rights in a concerted attack. V. PARTICULAR FACTS FOR EACH INDIVIDUAL PLAINTIFF A. 123. SHARON BEN-HAIM Plaintiff Ben-Haim, is a United States resident living in Fair Lawn, the State of

New Jersey, whose child was abducted to Israel June 20, 2010 by the childs mother. 124. Defendant Arbel disregarded the protections of the Hague Convention for the

Civil Aspects of International Child Abduction (which direct the immediate return of such children to the United States), and a New Jersey State Court order directing the return of the minor to the United States. Arbel condoned the kidnapping in deciding an appeal filed at the Supreme Court after two lower courts held the mother wrongfully abducted the child to Israel and the child should be returned to the U.S. (albeit with severe financial impositions on Mr. Ben-Haim). On May 17, 2011, Arbel ordered the minor shall not return to her home State, New Jersey, on the spurious theory that Plaintiff Ben Haim, by participating in negotiations for a divorce and custody settlement, while trapped in Israel by Rabbinical Court Orders for his arrest enjoining him from leaving Israel, somehow acquiesced to the abduction. See

32

Exhibit N, Judge Arbels decision and Exhibit O, Judge Mizdols decision refusing to grant comity to Judge Arbels decision. 125. The climate of discrimination against men is Israel so brutal, that the

Defendants have erected various procedural obstacles to deter Ben Haim from seeking to reunite with his daughter. The courts compelled him to appear in the destination country of abduction instead of allowing videoconference, forced him to pay exorbitant fees and bonds, forced him to pay the kidnappers airfare, six months of rent and six months of child support in New Jersey, (contrary to New Jersey law and in encroachment on the sovereignty of the United States), and issued ne exeat injunctions and orders of arrest against him. 126. Defendant Arbels manufactured Judgment denying the return of the minor

daughter to the United States is a heinous crime tainted with gender-based hate and discrimination. The Israeli Central Authority, responsible for implementing the Hague Convention in Israel, filed an opinion severely criticizing Defendant Arbels butchering of the law. Exhibit P. 127. As a result, Plaintiff is cut off from Ofir, an American citizen, for more than

two years, has needlessly spent $100,000 in attorney fees and related expenses, has been arrested by an ex parte order of a Rabbinical Court, has been served with a ne exeat injunction preventing his departure from Israel when he arrived to participate in the International Child Abduction proceedings, and was trapped in Israel for months during which his entire business in the United States collapsed due to inability to fulfill orders. Plaintiff Ben-Haim has suffered and continues to suffer mental anguish, loss of work and loss of self-esteem. Everyday, his daughter grows more distant despite his every effort to reunite. B. SOL HAVIVI

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128.

Plaintiff Havivi was born and raised in New York City. He is 47 years old. In

1984 he moved to Israel and later married an Israeli woman. He is now the custodian of two children, ages 17 and 12, after a long and excruciating custody battle. He has another daughter who he has not seen in five years. 129. When his wife filed for divorce, Judge Yaakov Cohen told him that in his

Court fathers do not see children. Havivi suffered humiliating treatment by hostile social workers, who despised him solely on account of his gender. For 8 months, he was forced to see his children in a supervised contact center, for no valid reason who ATCA over. His oldest child was a victim of parental alienation and Havivi has not seen her in 5 years. The social workers and Judge Cohen ridiculed Havivi, made his life unbearable and tormented him for more than 4 years. 130. In Havivis case, social workers deliberately procrastinated any order to

arrange for visitations, and had incited all three children against their father. In private, low level social workers admitted that they were forced by their supervisors to lie and to take a womans side in every dispute. Moreover, the low level social workers were forced to ignore any request by the children to live with their father, and to offer foster care rather than paternal custody, should the children insist on moving away from their mothers. When the children themselves told the social workers they were abused by their mother, the social workers rationalized and ignored every act of the mother, and offered outplacement instead of custody with the father. 131. The social workers convinced the Police in Petach Tikva to close an assault

charge against the mother, who smashed Havivis head into a table, because prosecution would disrupt her life.

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132.

Judge Cohen imposed an outrageous child support award that exceeded the

entire salary of a person who is 100% handicapped, thereby living Plaintiff Havivi no resources for daily life, and subjecting him to arrests without any proof of financial ability to pay. C. 133. GAMLIEL ELMALEM Plaintiff Elmalem is an American citizen who resided in Lakewood, in the

State of New Jersey and now returned to Israel. He is a former Israeli police officer, and after becoming religious, he became a kosher food inspector. He escaped Israel and left four minor children in Israel (ages 11, 10, 7 and 3). Prior to his departure, Elmalems wife attacked him with sharp glass and ripped his arm apart. He called the police, but the police arrested him and removed him from his home. He had nowhere to go, so he went to a domestic violence shelter, but the shelters only accepted women. His salary was 2,500 shekels (about $714) per month, but he was ordered to pay 3,000 Shekels ($857) per month. Because of the order of removal/protection he did not see his children for many months, until a social worker determined that he must see his children in a contact center, "so as not to traumatize the children. 134. In Elmalems case, the police did not register him as a victim and arrested him

instead of his wife. He was also ordered to pay child support exceeding his income and was only permitted to see his children in a supervised contact system. These injustices resulted because Defendants Kahlon, Shteinmetz, Artman and Milner believe that children will be traumatized if they see their own fathers unsupervised. 135. Because child support was so unconscionably excessive, unaffordable and un-

payable, orders for Elmalems arrest were issued. He fled to the United States in June 2010

35

and has no ability to exercise his parental rights. Elmalem returned to Israel in November 2011 because he could not bear the separation from his children. The complete elimination of Elmalems rights through discrimination and criminalization demonstrates the pervasive and systematic injustice experienced by fathers in Israeli child custody cases. COUNT ONE AIDING AND ABETTING, INTENTIONALLY FACILITATING, AND/OR RECKLESSLY DISREGARDING TORTURE AND CRIMES AGAINST HUMANITY IN VIOLATION OF INTERNATIONAL LAW (By Plaintiff Ben-Haim Against Defendants Neeman, Kahlon, Arbel, Edri, Shteinmetz, Milner and Artman) 136. Plaintiffs repeat and reallege all previous allegations with the same force and effect, as if fully set forth herein. 137. The rights to non-discrimination, equal protection, due process and family life

(in the sense of right to parental access to children) are universally agreed upon as the law of nations and international law, except Israel, the only dissenter in the international community. 138. For example, the rights are enshrined in ICESCR Article 10(1) The right to

family life: "The widest possible protection and assistance should be accorded to the family, which is the natural and fundamental group unit of society, particularly for its establishment and while it is responsible for the care and education of dependent children." See also, Art. 8 European Convention on Human Rights, and Karen Atala v. Chile. 139. Crimes against humanity are likewise defined with a specificity sufficiently

comparable to international law violations that were familiar when the ATCA, 28 U.S.C. 1350, was enacted. 140. The core elements of a crime against humanity in violation of international

law, as codified in the above sources and recognized in international law generally, include

36

various forms of heinous acts against human life, physical welfare, and dignity that are undertaken as part of a widespread or systematic attack against the male population in Israel. 141. war. 142. Aiding and abetting and/or reckless disregard of crimes against humanity are Crimes against humanity are punishable whether committed in time of peace or

actionable claims under the law of nations and this court has jurisdiction over claims related to such actions pursuant to the ATCA as to Sharon Ben-Haim, an alien. 143. When the Defendants violate all such universal rights, utilize threats of arrest,

injunctions on right to travel, unconscionable child support, gender based anti-male social workers interventionist methods, lack of due process and equality in both family courts and rabbinical courts, it is an act of systematic torture and terror applied against innocent citizens, and especially Americans who are entitled to a most favored nations treatment. 144. Defendants intentionally, knowingly and willfully facilitated, encouraged

and/or condoned, or at minimum failed to take steps to protect the Plaintiffs using the following tools10, and failing to take steps within their powers to (a) abolish the Tender Years Presumption which discriminates against men in favor of women and results in separation and alienation of fathers from children, (b) abolish Israeli Attorney General Guideline 2.5 which immunizes women from prosecution or liability due to false police reports of domestic violence, (c) abolish the Israeli Police patrol guidelines mandating orders of removal from the home based on mere allegations of violence without evidence, (d) Policies disengaging children from fathers, (e) Policies allowing fathers access to children only at supervised visitation contact centers, or no visitation if the woman does not cooperate,

10

See Exhibit Q, Discrimination Against Divorced Fathers in Justice and Welfare.

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(f) Policies compelling fathers to prove their fitness to see children and beg to be granted visitations despite that fathers are entitled to the same presumption as mothers that they are good and loving parent; (g) Policies postponing property distribution and awarding most of, if not all, the marital property and the husbands personal property to the women; (h) Policies of issuing ex parte decisions in Family Court and in post Judgment Enforcement Offices (i) Family Court policies inflicting excessive attorneys fees on husbands in almost every case; and (j) Policies undermining and ignoring the Hague Convention on Child Abduction by discriminating in favor of women abductors and falsely interpreting the Convention to the detriment of disabused fathers. 145. Defendants Neeman, Kahlon, Arbel, Edri, Shteinmetz, Milner and Artman

wrongful conduct jointly and severally, as hereinabove alleged, and the crimes and torts committed by them, as hereinabove alleged, have caused Plaintiffs and other similarly situated men, emotional and psychological harm including stress, detachment from family, pecuniary and economic damages, loss of support, loss of nurture care and guidance, grief, anguish and other mental and physical injuries. 146. In Ben-Haims case, Defendants Neeman, Kahlon Arbel, Edri, Shteinmetz,

Milner and Artman created the circumstances and/or did nothing to prevent the circumstances that enabled the wife, Oshrat, to kidnap his daughter, and get away with it. 147. The kidnapping of Ben-Haims daughter has caused a loss of family life in NJ,

a financial loss in NJ to the Plaintiff, continued persecution while ongoing litigation in Israel resulted in orders from Edri to rabbis in NJ to intimidate, harass him, excommunicate him, as well as instructions not to bury his body in NJ, which is an implicit death threat.

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148.

In fact, in Plaintiff Ben-Haims efforts to return his abducted child to the

United States, Arbel herself abetted the abduction, motivated by her belief that women in all situations should enjoy custody of children, even at the expense of the fathers rights. 149. In order to achieve her goal, Arbel manipulated facts, intentionally misapplied

principles of law, and sabotaged the goals of the Hague Convention on the Civil aspects of Child Abduction. Her ruling makes Israel a safe haven for female child kidnappers, and is a violation of the rights to non-discrimination, equal protection and due process. 150. As Defendant Neeman is in charge of the justice system, he did nothing to

protect Ben Haim from false complaints, police interrogation, the fear of being arrested and the creation of an automatic criminal record. 151. Ben-Haim also suffered from false complaints launched in Israel by his wifes

mother and sister, who falsely claimed on December 23, 2010 and again on January 5, 2011 that he threatened them. Ben-Haim was interrogated for hours, humiliated, removed from his home town, and left with a stain on his rap sheet. 152. At the rabbinical Court, Defendant Edri caused Ben Haim to be trapped in

Israel for four months, and actively coached the wife what to say and do in order to issue various restraining orders against Plaintiff Ben Haim and prevent him from returning to the US for 4 months. 153. Edri then started a campaign to torment Ben-Haims family members by

issuing subpoenas to banks, allowing the wife to sue Ben-Haims father for $25,000, and after this case was initially filed, aided and abetted a violation of an anti-suit order and issued written demands to the Israeli Consulates in the US and to rabbis in NJ to limit and curtail the liberties of Ben Haim and make his life miserable.

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154.

The remaining Defendants of the Welfare office, Kahlon, Shteinmetz, Milner

and Artman supported the wifes claims that interim visitations while the Hague case was pending be allowed only in a contact center. 155. WHEREFORE, Plaintiff Ben-Haim, based on the ATCA, requests judgment in

his favor and against Defendants Neeman, Kahlon, Arbel, Edri, Shteinmetz, Milner and Artman, jointly and severally, in an amount in excess of $75,000 plus interest, costs, punitive damages, attorneys fees and such other relief as the Court may determine.

COUNT TWO AIDING AND ABETTING, INTENTIONALLY FACILITATING, AND/OR RECKLESSLY DISREGARDING TORTURE AND CRIMES AGAINST HUMANITY IN VIOLATION OF INTERNATIONAL LAW AND THE TVPA (By Plaintiff Havivi and Elmalem Against Defendants Neeman, Kahlon, Arbel, Edri, Shteinmetz, Milner and Artman) 156. Plaintiffs repeat and reallege all previous allegations with the same force and

effect, as if fully set forth herein. 157. Crimes of torture within the meaning of TVPA, 28 USC 1350 are subject to

jurisdiction in this Court as to Havivi and Elmalem, who are American citizens. 158. Before his divorce, Havivi was in good health, a sportive person and a police

sniper. The divorce has turned him crippled, 100% incapacitated, and totally impoverished. 159. Havivi has suffered all of the above plagues. Social workers under command

of Kahlon, Shteinmetz, Milner and Artman have deliberately harassed, intimidated and tormented him with intentions to destroy him physically and mentally, so he would give up the fight for his children. They have written libelous and horrendous lies about him to court, branded him as violent and dangerous and compelled him to see his children in contact centers where he was was forced to sign a confidentiality agreement as well as an agreement

40

to obey all orders of the guards and placed in the custody of the guards and treated like a dangerous criminal while he was permitted to only see his children one hour a week, and . When Havivis children expressed desire to live with him, the social workers told Havivi that children who refuse to live with mothers belong in outplacement institutions. 160. At family court, the Judge issued a child support order that was unconscionable

child support of 7,500 Shekels or $2,200, when his salary was only 5,000 Shekels. He was then hounded by child support execution which garnished all his salary and issued levies, restraining orders, and other measures that completely stripped him of any citizens rights. 161. At the hands of police, Havivi has endured 28 baseless false complaints, and

when his ex wife intruded his new home and brutally attacked him, with intentions to kill, the police refused to investigate, and failed to protect him in the same way women are protected when they file domestic violence complaints. 162. As a result of the continued terrorization by the Defendants, Havivi developed

fibromyalgia and degenerative disk disease. He is in the most severe life-threatening pain the human body can endure. He is prescribed morphine. Without pain management, he is at risk of dying from the pain itself. The fibromyalgia pain racks the entire body while the degenerative disk disease is localized to the spine. 163. Given the above, defendants knew, or should have known, that they were

physically torturing Havivi in this serious condition, when they forced him into a Contact Center one hour a week for 8 months to see his son11.

11

A new petition was filed on September 13, 2012 with the Supreme Court where Arbel sits to close the contact Centers, and related remedies. It will surely be dismissed, like all others before. Guy Shamir v. Simona Shteinmetz, Bagatz Docket # 6819/12.

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164.

Defendants knew, or should have known, they physically torture Havivi in this

serious condition when they used his medical condition against him in documented falsified reports and evaluations. 165. Defendants knew, or should have known, they physically torture Havivi in this

serious condition when they repeatedly punished him for being the victim of domestic violence, (and failed to protect him in the same way women are protected), including at least one attempt on his life. 166. Defendants knew, or should have known, they physically torture Havivi in this

serious condition when they obstruct access for him to the same welfare benefits freely given to women with the same medical condition, such as a assisting caretaker, timely renewal of prescriptions, protection from domestic violence, etc. 167. Defendant Kahlon, Shteinmetz, Milner and Artman have abused and mentally

tortured Havivi by subjecting his children to psychiatric treatment and medications intended to teach the children that they do not need a father in their lives. 168. Defendants knew, or should have known, they mentally tortured Havivi in this

serious condition when they forced psychiatric treatment on at least 2 of his children without his consent and against his will. 169. Defendants knew, or should have known, they mentally tortured Havivi in this

serious condition when their psychiatrists hired by Shteinmetz social workers told his children on record that Havivi is a lousy father (due to his handicap), and they were better off suffering life-threatening abuse from their mother, locked in an orphanage or put up for adoption to complete strangers.

42

170.

Defendants knew, or should have known, they mentally tortured Havivi in this

serious condition when they forced mind-altering drugs on his son under threat of cutting him off completely from Havivi if the son refused to comply. 171. Defendants, via their agents, knew, or should have known, that they mentally

tortured Havivi in this serious condition when they forced his daughter into a lock-down psychiatric hospital, where they forced her to take mind-altering drugs and forcibly tied her down to a bed in their radical attempt to "cure" her of needing a father. 172. Defendants knew, or should have known, they mentally tortured Havivi in this

serious condition when they eventually broke his daughter down mentally, causing her to become suicidal, self-mutilating and even homeless. 173. The actions and, or, omissions committed by defendants constitute crimes

against humanity in violation of the law of nations, and crimes of torture within the meaning of TVPA, 28 USC 1350. 174. Plaintiff Elmalem had become homeless and destitute because of the torture he

endured in Israel. Due to the circumstances of annihiliation and destruction of men in divorce situations, his wife, encouraged by the exemption from prosecution promulgated by Defendant Arbel, and inspired by Neemans encouragement of the family courts to brutally treat all men as violent and dangerous, picked up a sharp glass and assaulted him causing his severe bodily injury and permanent physical and emotional pains. Instead of being protected by the police, he was charged with assault against his wife, and ordered to leave the home immediately. Thus, Elmalem lost his children and his home. 175. After a long period of disengagement from the children, social workers who

take orders from Kahlon, Shteinmetz, Milner and Artman compelled him to see his children in

43

a contact center one hour a week.

In order to crush him, completely, child support

exceeding his income was awarded to the wife, therefore eliminating the ability to work, and causing him, starvation, and the need to beg for food and shelter from strangers. 176. Elmalem knew that many men in his situation simply commit suicide, and he

would have committed suicide as well, but for his American citizenship, which gave him, hope. However, in the US Elmalem was so traumatized; he could not keep a job, or a steady place to live. Missing his children, he returned top Israel where he was arrested again on a new domestic violence charge, intended to keep him away from seeing his children. 177. Under the circumstances described above, Defendants Neeman, Kahlon, Arbel,

Edri, Shteinmetz, Milner and Artman, each acted under actual or apparent authority or color of law of the nation of Israel, and subjected Plaintiffs Havivi and Elmalem to torture. 178. Defendants Neeman, Kahlon, Arbel, Edri, Shteinmetz, Milner and Artman,

jointly and severally, committed acts directed at Plaintiffs Havivi and Elmalem while Havivi and Elmalem were under their custody or physical control, either at the Contact Centers, the police stations where their wives filed false complaints, the offices of the social workers Shteinmetz, Milner and Artman, or any office of an employee who receives instructions from Defendant Kahlon, or inside the rabbinical courts, where defendant Edri exercises his control, or the family courts where defendant Arbel exercises her control, or the family courts and offices of child support enforcement where Neeman is exercising his control12. 179. Defendants Neeman, Kahlon, Arbel, Edri, Shteinmetz, Milner and Artman,

jointly and severally, subjected Plaintiff Havivi and Elmalem and/or failed to take action to

12

For that matter, the entire State of Israel can be considered the locus of custody or physical control, because of the issuance of ne exeat orders.

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prevent severe pain or suffering, both physical and mental, which was intentionally inflicted upon them because of their gender. 180. Defendants Neeman, Kahlon, Arbel, Edri, Shteinmetz, Milner and Artman,

jointly and severally intended to punish Plaintiff Havivi and Elmalem for the act of separating from his wife and/or the act of seeking child access, and or seeking reversal of custody of the children. 181. Defendants Neeman, Kahlon, Arbel, Edri, Shteinmetz, Milner and Artman,

jointly and severally, intimidated and/or coerced Plaintiffs Havivi and Elmalem, to give up their parental rights, to refrain from seeking custody of their children and to give up all their assets and transfer them to his wife in the form of unconscionable child support, and all that was based on discrimination attributed to their gender as males. 182. Defendants' conduct was the sole proximate cause of the severe and continuing

emotional distress suffered by Plaintiffs and other similarly situated individuals, who have experienced similar human rights violations, torture, mayhem, and false arrests. 183. As a direct and proximate result of Defendants intentional, reckless,

outrageous and intolerable conduct, Plaintiffs, as well as similarly situated men, have suffered, and continue to suffer, substantial damages and discrimination. 184. Plaintiffs are therefore entitled to judgment in their favor against Defendants

and demand damages in an amount to be determined by a jury, not less than the statutory minimum amount of $75,000, for damages arising out of severe emotional distress, mental anguish, intense fear and anxiety, and manifestations of physical and emotional distress, such as loss of sleep, loss of appetite, back pains, migraine headaches, heart ailments, depression loss of self esteem, nervousness and anxiety. loss of consortium, loss of solatium, and/or loss

45

of services, plus interest, costs, and such other monetary and equitable relief as this Court deems appropriate to compensate the Plaintiffs, and prevent Defendants from ever again supporting crimes against humanity in violation of the law of nations. 185. Defendants actions towards Plaintiffs and other similarly situated individuals

were undertaken with the specific intent to harm and discriminate. WHEREFORE, Plaintiffs Havivi and Elmalem, based on TVPA request judgment in his favor and against Defendants Neeman, Kahlon, Arbel, Edri, Shteinmetz, Milner and Artman, jointly and severally, in an amount in excess of $75,000 plus interest, costs, punitive damages, attorneys fees and such other relief as the Court may determine. COUNT THREE RECKLESS DISREGARD FOR HUMAN AND PARENTAL RIGHTS (Plaintiff Ben-Haim against Defendants Neeman, Arbel and Kahlon) 186. Plaintiffs repeat and reallege all previous allegations with the same force and

effect, as if fully set forth herein. 187. Defendants Neeman, Kahlon, and Arbel, jointly and severally, recklessly

disregarded the Plaintiffs right to most favored nations treatment in Israeli Courts and other tribunals to be treated no less favorable than the treatment enjoyed by women in divorce. 188. Plaintiffs application to the US Department of State to invoke remedies in

that Convention (i.e. sue Israel in Hague) resulted in issuance of a travel warning as follows: Court Jurisdiction :Civil courts in Israel actively exercise their authority to bar certain individuals ,including nonresidents, from leaving the country until monetary and other legal claims against them are resolved. Israels religious courts exercise jurisdiction over all citizens and residents of Israel in cases of marriage ,divorce, child custody and child support. In some cases, U.S. citizens who entered Israel as tourists have become defendants in divorce or custody cases filed by their spouses in Israeli religious courts. These U.S. citizens have been detained in Israel for prolonged periods while the Israeli courts consider whether the individuals have sufficient ties to Israel to establish jurisdiction. Such visitors should be aware that they might be subject to

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involuntary and prolonged stays in Israel if a case is filed against them in a religious court, even if their marriage took place in the United States and regardless of whether their spouse is present in Israel13. 189. Defendants knew, or should have known, their encouragement of, disregard of

and/or negligence regarding the atrocities men suffer in Israel during divorce proceedings would result in the harm, pain and suffering, as described above. 190. Defendants knew, or should have known, they were and are disregarding the

rights of the American Defendants to treatment in Israel at a most favored nations basis equal to the treatment women in Israel are entitled to. 191. Defendants knew, or should have known, their disregard of the rights of

Plaintiffs, and others similarly situated men causes 200 suicides each year. 192. Defendants knew, or should have known, their disregard of the rights of

Plaintiffs, and others similarly situated causes 3,500 children to be sent to Contact Centers due to the almost automatic supervised visitation policies promulgated by Defendant Shteinmetz. 193. Defendants knew, or should have known, their disregard of the rights of

Plaintiffs, and others similarly situated, causes at least the same amount of disengagements of children from fathers every year. 194. Defendants knew, or should have known, their disregard of the rights of

Plaintiffs, and others similarly situated, causes the impoverishment and false arrests of thousands of men each year.

13

http://travel.state.gov/travel/cis_pa_tw/cis/cis_1064.html#special_circumstance

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195.

Defendants knew, or should have known, their disregard of the rights of

Plaintiffs, and others similarly situated, causes the massive transfer of millions of dollars in properties lawfully belonging to men to be taken without due process and given to women. 196. In spite of this knowledge, or in spite of the fact they did not take reasonable

steps to know what a reasonable person should know, Defendants Neeman, Arbel and Kahlon have intentionally turned a blind eye and failed to investigate or evaluate Plaintiffs assertions of improper conduct, Plaintiffs specific suffering and the impacts on others similarly situated. 197. Defendants appointed various commissions to investigate the perpetration of

such heinous crimes against men, including the Slonim-Nevo Commission on social workers, Exhibit R, Schnit commission on joint parenting Exhibit S, and Shifman Commission on fair child support amounts. Defendants have taken no action on the findings of the Slonim-Nevo Commission (which finalized its report two years ago). 198. Beyond appointing the Schnit and Shifman Commissions, Defendants have let

those bodies languish for more than six years without taking any action suggested by the reports. Defendants have paid only lip service to the well-known calls for reform

demonstrating Defendants intent to continue their systematic discrimination against men. 199. As a result, Neeman, Arbel and Kahlon were aware or should have been aware

of a risk so great that it was highly probable, and thus foreseeable, that serious harm and/or death could result to Plaintiffs from their acts or omissions. 200. Neeman, Arbel and Kahlon recklessly disregarded this known and substantial

risk thereby facilitating, assisting, aiding, abetting and incentivizing the torture and abuse that were foreseeable to Neeman, Arbel and Kahlon, and which were the direct and proximate cause of the injuries Plaintiffs and their children.

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201.

As a direct and proximate cause of the acts and omissions of Defendants

Neeman, Arbel and Kahlon foreseeable physical and emotional injuries were inflicted upon the Plaintiffs. 202. As a result of the foregoing Plaintiffs have been damaged in an amount not less

than $26,000,000. WHEREFORE, Plaintiff Ben-Heim requests judgment in his favor, under the ATCA for violation of treaties with the United States, and against Defendants Neeman, Arbel and Kahlon in an amount in excess of $75,000 plus interest, costs, punitive damages, attorneys fees and such other relief as the Court may determine. COUNT FOUR AIDING AND ABETTING AN ANTI-SUIT INJUNCTION AND INTENTIONAL OR NEGLIGENT INFLICTION OF EMOTIONAL DISTRESS (Plaintiff Ben-Haim against Defendant Edri) 203. Plaintiff Ben-Haim repeat and reallege all previous allegations with the same

force and effect, as if fully set forth herein. 204. 205. Plaintiff Ben-Haim brings this claim against Defendant Edri. Following the abduction of Plaintiff Ben-Haims daughter to Israel, and the

family Courts refusal to hear testimony by video, Ben-Haim had to travel to Israel to testify in November 2010. 206. Defendant Edri knew that Ben-Haims center of life is in New Jersey and that

he was only coming to Israel to testify. Despite this, and out of pure malice, Defendant Edri issued a ne exeat order against Ben-Haim, thus trapping him in Israel for four months. 207. collapsed. Ben-Haims private business in NJ as an Italian kitchens importer and installer

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208.

When the ne exeat order expired, Ben-Haim left Israel on March 7, 2011, and

immediately thereafter Edri issued a new ne exeat order. 209. In the United States, Ben-Haim started matrimonial proceedings, in which his

wife participated by phone. When the NJ Judge learned that Ben-Haims wife was pursuing actions of divorce, child support, and equitable distribution in Israel, the Judge issued an antisuit injunction against Ben-Haims wife. 210. On or about January 6, 2012, the Honorable Judge Bonnie Mizdol of New

Jersey State Superior Court issued an anti-suit order enjoining Ben-Haims wife from prosecuting any action in family court or the rabbinical courts of Israel. 211. Said order was brought to the attention of Defendant Edri on January 10, 2012

in the form of a Notice of Anti-suit Injunction in the case of Ben-Haim v. Ben-Haim, Docket Haifa 589799 212. The anti-suit order was served upon Oshrat Ben-Haim, her lawyers and the

United States Department of State for official forwarding to Israels Central Authority and administration of the Courts. 213. The order was issued following Oshrat Ben-Haim failure to comply with

previous NJ Court order to return the daughter, Ofir, by Sup 10, 2011, and on December 7, 2011 a habeas corpus order was issued against Oshrat Ben-Haim, followed by an enforcement order via the FBI dated December 21, 2011. 214. Despite knowledge of the anti-suit injunction, Defendant Edri decided to

ignore it, and instead actively aided and abetted Oshrat in tormenting the Plaintiff Ben-Haim and his family in Israel.

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215.

In retaliation, Defendant Edri issued an order without a hearing on January 29,

2012 restricting certain liberties of Ben Haim including a ne exeat order valid until February 11, 2017. 216. Continuing the retaliation, Edri issued another order on ex parte basis on

February 8, 2012 addressed to the Consulate at Fair Lawn NJ and any other consulate in the US to cease any consular services until Ben Haim agrees to appear before Edri in Haifa. He further commanded the Israeli ministry of Foreign Affairs to summon Ben-Haim to a Consulate and seize his passport. He further issued a domestic arrest warrant without bail to be effective upon entry into Israel. 217. On February 8, 2012 Edri issued an order directed to the Israeli consulates in

the United States ordering them to stop providing any consular services to the Plaintiff Ben Haim, and another local order of arrest without termination date and without a bond. 218. On or about July 22, 2012, Defendant Edri sent an envelope by mail Addressed

to Rabbi, Sephardic Center of Fair Lawn, 40-34 Terhune Place, Fair Lawn, NJ 07410. 219. In the letter which was addressed to Rabbi Avidan Elkin in Fair Lawn,

Defendant Edri called the Plaintiff a criminal, a crook, and asked everyone with the Jewish community in NJ not to talk to Plaintiff, not to do any favors to plaintiff, not to pray with him, or converse with him, and not to bury Plaintiffs body should he die. 220. In addition, Edri instructed the rabbis in New Jersey to publish the name and

picture of Plaintiff, in any place without limitation with a notice that anybody who knows the whereabouts of Plaintiff must assist in approaching Plaintiff to coerce him to give a Get.

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221.

Upon information and belief, Edri and the rabbinical courts of Israel maintain

contacts with Agunot Squads, a team of bandit rabbis, who search men overseas, outside Israel and intimidate them into doing what the rabbis of Israel dictate. 222. The Agunot Squads have used force, intimidation and terror outside Israel, to

compel men to surrender to the demands of the wives financially, and as to custody of children. 223. Upon information and belief, the Agunot Squada are financially supported by

the International Coalition for Agunah Rights (ICAR), which is financed by NIF. 224. Defendant Edri subjected himself to the jurisdiction of New Jersey by issuing

said orders directed at the Israeli Consulates in the US, and by sending the letters addressed to the rabbis of Fair Lawn14. 225. Defendant Edris conduct of threatening the Plaintiff with retribution,

retaliation, and invasion of his privacy, as well as orders not to bury him constitute a breach of the sovereignty of the United States. 226. Edri intended, knew, or should have known the commission of acts designed to

violate the rights of men, deny him due process and equal protection under law, impoverish him, arrest him, and disengage him from their daughter would create grief, devastation and emotional injuries.

14

See Jaoudi v. Cigna Worldwide Ins. Co. (3rd Cir., 2010). In the context of FSIA, a Liberian official and his attorney, both non-USA residents acted to enforce a Liberian judgment which was issued against a US anti-suit order. Citing Abi Jaoudi & Azar Trading Corp. v. CIGNA Worldwide Ins. Co., No. 91-6785, slip op. at 2 (E.D. Pa. Jan. 12, 2009), the Court rejected the appellants' jurisdictional challenge. other Courts of Appeals have "held that minimum contacts exist where one has actively aided and abetted a party in violating a court order." Id. (citations omitted). With this in mind, the District Court explained that "[t]here is evidence that Mr. Senesie, the Receiver, is acting to enforce, in part, the Liberian judgment that was the express object of Judge O'Neill's injunction." Id. Therefore, "[f]or purposes of jurisdiction only," it found "that Mr. Senesie may be considered an aider and abettor of AJA."

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227.

Upon information and belief, Edri himself called reporters from Maariv

newspaper, a paper distributed and sold in NJs Jewish and Israeli communities to publish the issuance of his orders along with defamatory information. On July 25, 2012 an article appeared in Maariv, in print and on the internet, which Edri himself sent to the press. 228. Edri infringed on the sovereignty of the United States, and perpetrated crimes

of intimidation and infliction of terror and threats upon Ben Haim on NJ soil, a territory where he is not immune from prosecution, while aiding and abetting a NJ anti-suit order. 229. The actions of Defendants Edri are unconscionable and done with an

intentional, malicious, willful, and/or reckless disregard for the rights and lives of those tortured and abused, and the extended family members, especially children. 230. As a direct and proximate cause of Defendant Edris intentional misconduct

and/or reckless disregard for human life, Plaintiff Ben-Haim suffered and will continue to suffer severe financial losses, the collapse of his business, tens of thousands of attorney fees, loss of at least work after the return to NJ, loss of 120 days of work while being trapped in Israel, debilitating, permanent emotional, physical disorder, ongoing emotional distress and anxiety, physical and mental distress, and significant mental injury and impairment causing ongoing and long-term expenses for medical treatment, services, and counseling and longterm care, particularly for all minor Plaintiffs. 231. Upon information and belief, Edri had previous contacts with the rabbis of the

communities of New Jersey, and had acted similarly with respect to other men residents in New Jersey.

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232.

Defendant Edri, by engaging in this intentional, unlawful conduct,

intentionally, grossly negligently, or negligently also inflicted financial harm and emotional distress upon Ben-Haim. WHEREFORE, Plaintiff Ben-Haim requests judgment against Defendant Edri, personally, in an amount in excess of $26,000,000. COUNT FIVE FINANCING, AIDING AND ABETTING ACTS OF PERSECUTION, UNIVERSALLY CONDEMNED AS VIOLATIONS OF THE LAW OF NATIONS (Plaintiff Ben-Haim against Defendant KAS) 233. Plaintiff Ben-Haim repeats and realleges all previous allegations with the same

force and effect, as if fully set forth herein, and sues here Defendant KAS under ATCA. 234. Defendant Konrad Adenauer Stiftung (KAS) finances radical and fanatical

groups in Israel such as the Israel Womens Network (IWN), which support, promote, and lobby for oppressive treatment of men. 235. IWN fights to curtail fathers rights, spread propaganda that all men are violent

offenders or potential aggressors, to increase the minimum statutory child support award, and to impose unconscionable and usurious child support awards that are unaffordable, ab initio. 236. KAS and IWN intensify the persecution of men. They lobby for the adoption

and preservation of institutionalized polices of discrimination and systematic opposition to joint custody and equality in duties of child support. 237. The financing of such inherently discriminatory activities and other attacks

committed by KAS and IWN is a violation of the law of nations. 238. KAS funds IWN, which is indoctrinating women with extreme anti-male

policies and preparing those women, such as Rivka Mekayes and Tamar Snunit Forer, to

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become family court judges. These funds are used to systematically configure and control the family court process in order to perpetuate anti-male case law from the bench according to their ideological hateful agenda. See Exhibit L, The Matter of the Vengeful Judge, and Exhibit K, The Vengeful Judge A Monologue of a Despondent Father. 239. The prohibition against financing activities that are in contravention of

international human rights rests on a clear and definite norm of customary international law universally accepted by the civilized world. 240. KAS officials in Israel knew well that the advocacy of child-father alienation

which they promote in Israel is against the law back home in Germany. Germany itself was been hailed several times to the European Court of Human Rights in Strasbourg for separating between men and children in violation of the European Convention of Human Rights, Article 8 (right to private life and family life), and Article 14 (non-discrimination), as well as CRC Article 3 (best interests of the child), and Article 9 (separation from parents). See Sarin v.

Germany, (30943/96) [2003] ECHR 340 (Judgment July 8, 2003) in that case Germany differentiated between fathers in marriage and fathers of children out of wedlock. The latter got no child access rights unless the woman consent. This is similar to the situation in Israel today, except that in Israel it applies to both children of marriage and children out of wedlock. 241. See also, another case against Germany, Sommerfelfd v. Germany, (31871/96), This did not propel Germany to change its laws. See

[2003] ECHR 341, affirmed Sarin.

Zaunegger v Germany [2009] ECHR 22028/04 (Judgment December 3, 2009)15: the ECHR held that the denial of a fathers right to custody of a child born out of wedlock violated his right to respect for family life under art 8, in conjunction with discriminatory treatment under

15

Judgment found here: http://www.bailii.org/eu/cases/ECHR/2009/1982.html

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art 14 of the European Convention. The Court examined the German Civil Code and determined it amounted to unjustified discrimination against unmarried fathers on the grounds of sex in comparison with divorced fathers. While the situation of men in Germany was limited to fathers of children out of wedlock, it is not comparable to the situation of all men in Israel, whose persecution covers every aspect of their life, combined with relentless hate propaganda, fueled by money from KAS. 242. While KAS activities around the world, Israel and the US are portrayed as

cultural activities, in fact, KAS has been actually aiding and abetting crimes against humanity, torture, degradation, dehumanization and systematic persecution. KAS received several demands to cease and desist, but refused to do so. Plaintiffs agree that diplomatic and cultural activities are immune, and for that purpose the US government does qualify KAS officials for special governmental visas. But some of KAS activities are beyond promoting ideas (an activity that is exchanged without monetary value), such as actually giving money to certain organizations that incite hate and stereotypes, and it is not clear from Lars Haensel Declaration how KAS can do business in the US without any connection to NJ at all. 243. Consistent with its condemnation of gender hate financing, the world

community has also joined in defining who can be held liable. 244. ATCA provides liability for financing violations of crimes against humanity

reach those that directly or indirectly provide or collect funds with the knowledge and purpose that the funds will be used to carry out defined human rights offenses, regardless of whether the funds were actually used. Specifically, the financing liability reaches accomplices and every person who organizes or directs others in the scheme.

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245.

Defendant KAS knowingly, intentionally, and purposefully, directly and

indirectly, aided and abetted, intentionally facilitated, and/or recklessly disregarded crimes against humanity in violation of the law of nations. 246. Defendant KAS aided and abetted crimes against humanity by knowingly

giving money to IWN and other radical feminist organizations, for purposes of establishing and perpetuating a discriminatory system of justice resulting in unfair determinations, denial of due process and equal justice under law, false arrest, impoverishment, emotional distress and suicide. It is estimated that upwards of 200 divorced men commit suicide in Israel every year. 247. Defendant KAS knowingly provided millions of dollars to the IWN and other

radical feminist organizations through private and charitable contributions with the purpose of supporting IWN and other radical feminist organizations, including the support of widespread intentionally discriminatory practices, gender discrimination, direct and indirect child abuse, economic discrimination, institutionalization of gender discrimination and other heinous acts against human and parental rights. 248. At all times, KAS knew that the receipt, transfer, and disbursement of

charitable funds were being paid to members of IWN and other radical feminist organizations who carried out ferocious libelous attacks against Plaintiffs and other male Israelis. 249. Defendant KAS aided and abetted, intentionally facilitated and/or recklessly

disregarded the planning, preparation or execution of these crimes against humanity by providing organized and systematic financial support and other practical assistance, encouragement or moral support which had a substantial effect on the perpetration of crimes

57

against humanity, with the knowledge and purpose that such actions would assist IWN and other radical feminist organizations in the commission of crimes against humanity. 250. Defendant KAS aided and abetted, intentionally facilitated, and/or recklessly

disregarded a violation of customary international law, to wit, terrorist financing, by knowingly providing funds to IWN and other radical feminist organizations for the purpose of assisting the IWN and other radical feminist organizations in carrying out offenses as defined by the Financing Convention and customary international law: 251. Defendant KAS regularly provided substantial funding, totaling millions of

dollars in private contributions and charitable donations, with actual knowledge and awareness that these same funds were raised and deposited for the purpose of supporting IWN and other radical feminist organizations torture activities against Plaintiffs and other innocent males in Israel. 252. KASs actions directly and materially contributed to the institutionalized

discrimination Plaintiffs and other similarly situated individuals suffer in divorce and child custody proceedings in Israel. WHEREFORE, Plaintiff Ben-Haim request judgment in their favor and against Defendant, Konrad Adenauer Stiftung, in an amount in excess of $26,000,000 plus interest, costs, punitive damages, attorneys fees and such other relief as the Court may determine and further request an Order preventing Defendant Konrad Adenauer Stiftung from ever again engaging in the financing of terrorism in violation of the law of nations, or financing organizations that advocate gender apartheid against men.

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COUNT SIX FINANCING, AIDING AND ABETTING ACTS OF PERSECUTION, UNIVERSALLY CONDEMNED AS VIOLATIONS OF THE LAW OF NATIONS (Plaintiff Ben-Haim against Defendant IFCJ) 253. Plaintiff Ben-Haim repeats and realleges all previous allegations with the same

force and effect, as if fully set forth herein, and sues here IFCJ under ATCA. 254. Defendant International Fellowship of Christians and Jews (IFCJ) finances

radical and fanatical groups in Israel, such as NaAmat, which support, promote, and lobby for biased and torturous treatment of men such as the Plaintiffs. 255. IFCJ also supports the Ministry of Welfare directly, by giving monies to

supplement the state budget of the welfare programs, thus giving social workers powers tro dispense monies collected in the US. 256. Thus for example, around Passover 2012, IFCJ gave $2,000,000 directly to

Kahlon for distribution of $125 food stamps to the needy. Instead of dispensing the money directly to the needy, IFCJ gives it to Kahlon and his employees. 257. IFCJ also funds the Cities without violence program in association with the

welfare Defendants (Kahlon, Shteinmetz, Milner and Artman), which advocates male bashing and removals of men from home without evidence, as well as extended and enhanced sentences to men, even when no evidence exists. 258. IFCJ is based in Chicago, with a donation center in Washington DC and it

collects donations from evangelical Christians, who themselves believe in the sanctity of marriage, family life and the importance of fathers in the lives of their children. 259. IFCJ does not tell its donors that part of their monies go to organizations in

Israel that encourage divorce, believe that women are oppressed when they create family

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units, and are prevented from self fulfillment, and that their donations are channeled to radical feminist groups that are determined to disengage fathers from their children, assist women in divorce proceedings file frivolous domestic violence claims against fathers, contest fathers rights to see children, preserve Defendants supervised visitation policies and contribute to the growing number of loss of Jewish lives by suicide. 260. NaAmat is dedicated to curtailing fathers rights, spreading propaganda that

all men are violent offenders or potential aggressors, preventing joint custody, encouraging women to file for divorce to obtain Single Family governmental benefits, and collecting unconscionable and usurious child support awards that were never affordable, ab initio. 261. NaAmat is also the Welfare licensee to conduct family violence training to

same social workers that decide the fate of fathers contact with their children. These are training focus on seeing fathers as unfit and inherently dangerous. 262. IFCJ and NaAmat are devoted to intensifying the persecution of men, fighting

to preserve discrimination, and opposing joint custody and equality in duties of child support. 263. The financing of such anti-male activities and other attacks committed by IFCJ

and NaAmat constitutes a violation of the law of nations. 264. The prohibition against financing activities that are in contravention of

international human rights rests on a clear and definite norm of customary international law universally accepted by the civilized world. 265. Consistent with its condemnation of gender hate financing, the world

community has also joined in defining who can be held liable. 266. ATCA establishes that liability for financing or facilitating torture applies to

those who directly or indirectly provide or collect funds with the knowledge and purpose the

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funds will be used to carry out a defined terrorist offense, regardless of whether the funds were actually used. Specifically, the ATCA reaches every accomplice and every person who organizes or directs others in the financing effort. 267. Defendant IFCJ knowingly, intentionally, and purposefully, directly and

indirectly, aided and abetted, intentionally facilitated, and/or recklessly disregarded crimes against humanity in violation of the law of nations. 268. Defendant IFCJ aided and abetted crimes against humanity by knowingly

giving money to IWN and other radical feminist organizations, for purposes of annihilating the ability of men in divorce in Israel to stay alive. 269. Defendant IFCJ knowingly provided millions of dollars to NaAmat and other

radical feminist organizations through private and charitable contributions with the purpose of supporting NaAmat and other radical feminist organizations, including the support of widespread intentionally discriminatory practices, gender discrimination, direct and indirect child abuse, economic discrimination, institutionalized gender discrimination and other heinous acts against human and parental rights. 270. At all times, IFCJ knew the receipt, transfer, and disbursement of charitable

funds were being paid to members of NaAmat and other radical feminist organizations who carried out ferocious libelous attacks against Plaintiffs and other male Israeli civilians, contrary to the beliefs of the donors themselves. 271. Defendant IFCJ aided and abetted, intentionally facilitated and/or recklessly

disregarded the planning, preparation or execution of these crimes against humanity by providing organized and systematic financial support and other practical assistance, encouragement or moral support which had a substantial effect on the perpetration of crimes

61

against humanity, with the knowledge and purpose that such actions would assist NaAmat and other radical feminist organizations in the commission of crimes against humanity. 272. Defendant IFCJ aided and abetted, intentionally facilitated, and/or recklessly

disregarded a violation of customary international law, to wit, terrorist financing, by directly or indirectly knowingly providing funds to NaAmat and other radical feminist organizations for the purpose of assisting NaAmat and other radical feminist organizations in carrying out offenses against humanity and customary international law. 273. Defendant IFCJ regularly provided substantial funding, totaling millions of

dollars in private contributions and charitable donations, with actual knowledge and awareness that these same funds were raised and deposited for the purpose of supporting NaAmat and other radical feminist organizations terrorist activities against Plaintiffs and other innocent male Israeli citizens. 274. IFCJs actions directly and materially contributed to the institutionalized

discrimination which Plaintiffs and other similarly situated individuals suffered in divorce and child custody proceedings in Israel. WHEREFORE, Plaintiff Ben-Haim request judgment against Defendant, IFCJ, in an amount in excess of $26,000,000, and further request an Order preventing Defendant IFCJ from engaging in the financing of violations against humanity and torture in violation of the law of nations, or financing organizations that advocate gender apartheid against men.

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COUNT SEVEN FINANCING, AIDING AND ABETTING ACTS OF PERSECUTION, UNIVERSALLY CONDEMNED AS VIOLATIONS OF THE LAW OF NATIONS (Plaintiff Ben-Haim against Defendant NIF) 275. Plaintiff Ben-Haim repeats and realleges all previous allegations with the same

force and effect, as if fully set forth herein, and sues here Defendant NIF under ATCA. 276. NIF is a U.S. based non-profit organization established in 1979 located at 330

Seventh Avenue, 11th Floor, New York, NY 10001-5010. Upon information and belief, in 2008 it contributed about $30 million (USD) to human rights and civil society groups in Israel. NIF describes its objective as social justice and equality for all Israelis. However, the opposite is true. 277. Defendant NIF finances radical and fanatical groups in Israel, such as Center

for Woman Justice, Al Anwar, Adva Center, Awareness For You, Mavoi Satum, Sisters for Women, Arous Elbahr, Women Against Violence, Women & Horizon, Woman Lawyers For social Justice, and Womans Fund For Human Rights, which support, promote, and lobby for oppressive treatment of men such as Plaintiffs. 278. One of NIFs grantees is ICAR - The International Coalition for Agunah

Rights. This Coalition was approached by Defendant Edri to harass and intimidate Plaintiff so as to surrender to his wifes demands by way of demonstrations, publications, contacting employers, telephoning and faxing, speaking to neighbors and other stalking activity. 279. While Defendant NIF advertises equality for all, in reality it supports radical

feminists in their fight to perpetuate old stereotypes and invent more legislation designed to specifically target men, hurt them, and strip men of any fundamental human right that is left.

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280.

Indeed, a test case request to fund activities benefitting men, especially to fund

shelters for men thrown out of their house by orders of removal or orders of protection, was declined. 281. NIF does not tell its donors that part of their monies go to organizations in

Israel that encourage divorce and believe women are oppressed when they create family units, NIF does not the donors the donations are channeled to radical feminist groups determined to disengage fathers from their children, assist women in divorce file frivolous domestic violence claims against fathers, contest fathers rights to see children, preserve Defendants supervised contact visitations policies and contribute to the growing number of loss of Jewish lives by suicide. 282. NIF through its funding, curtails fathers rights, spreads propaganda that all

men are violent offenders or potential aggressors, prevents joint custody, encourages women to file for divorce to obtain Single Family governmental benefits, and promotes unconscionable and usurious child support awards that were never affordable, ab initio. 283. NIF and its beneficiaries are devoted to intensify the persecution of men,

increase discrimination, and oppose joint custody and equality in duties of child support. 284. The financing of such anti-male activities and other attacks committed by NIF

and its beneficiaries against Plaintiffs, constitutes a violation of the law of nations. 285. The prohibition against financing activities which are in contravention of

international human rights rest on a clear and definite norm of customary international law universally accepted by the civilized world. 286. Consistent with its condemnation of gender hate financing, the world

community has also joined in defining who can be held liable.

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287.

NIF provides that liability for financing to facilitate torture includes those that

directly or indirectly provide or collect funds with the knowledge and purpose that the funds will be used to carry out a defined terrorist offense, regardless of whether the funds were actually used. Specifically, the ATCA reaches every accomplice and every person who organizes or directs others in the financing effort. 288. Defendant NIF knowingly, intentionally, and purposefully, directly and

indirectly, aided and abetted, intentionally facilitated, and/or recklessly disregarded crimes against humanity in violation of the law of nations. 289. Defendant NIF aided and abetted crimes against humanity by knowingly

giving money to a multitude of women only organizations and other radical feminist organizations, for purposes of annihilating the ability of men in divorce in Israel to stay alive. 290. Defendant NIF knowingly provided millions of dollars to a multitude of

radically feminist groups and organizations through private and charitable contributions with the purpose of supporting them, including the support of widespread intentionally discriminatory practices, gender discrimination, direct and indirect child abuse, economic discrimination, institutionalized gender discrimination and other heinous acts against human and parental rights. 291. At all times, NIF knew that the receipt, transfer, and disbursement of charitable

funds were being paid to members of radical feminist organizations who carried out ferocious libelous attacks against Plaintiffs and other male Israeli civilians, contrary to the beliefs of the donors themselves. 292. Defendant NIF aided and abetted, intentionally facilitated and/or recklessly

disregarded the planning, preparation or execution of these crimes against humanity by

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providing organized financial support, practical assistance, encouragement, and, or moral support that substantially effected the perpetration of crimes against humanity, with the knowledge and purpose that such actions would assist radical feminist organizations in the commission of crimes against humanity. 293. Defendant NIF aided and abetted, intentionally facilitated, and/or recklessly

disregarded a violation of customary international law, to wit, terrorist financing, by directly or indirectly knowingly providing funds to radical feminist organizations for the purpose of assisting radical feminist organizations in carrying out offenses against humanity and customary international law. 294. Defendant NIF regularly provided substantial funding, totaling millions of

dollars in private contributions and charitable donations, with actual knowledge and awareness that these same funds were raised and deposited for the purpose of supporting radical feminist organizations terrorist activities against Plaintiffs and other innocent male Israeli citizens. 295. NIFs actions directly and materially contributed to the institutionalized

discrimination which Plaintiffs and other similarly situated individuals suffered in divorce and child custody proceedings in Israel. WHEREFORE, Plaintiff Ben-Haim requests judgment against Defendant, NIF, in an amount in excess of $26,000,000 and such other relief as the Court may determine and further request an Order preventing Defendant NIF from engaging in the financing of violations against humanity and torture in violation of the law of nations, or financing organizations that advocate gender apartheid against men.

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JURY DEMAND Plaintiffs hereby demands a trial by jury of any and all issues herein triable of right by a jury. Respectfully Submitted,

_________________________ Sharon Ben-Haim, Pro se 6-05 Saddle River Road #225 Fair Lawn, NJ 07410 T: 917.285.8530 F: 201.625.6377 212CV00351@gmail.com

__________________________ Sol Havivi, Pro se 1 HaCarmel Street Tel Mond, Israel 40600

___________________________ Gamliel Elmalem, Pro se 3 Duchifat Street Box 4408 Yavne, Israel Date: September 28, 2012 Newark, NJ

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