Sharon Ben-Haim 6-05 Saddle Rd. #225 Fair Lawn, New Jersey 07410 Tel.

917-775-5386, Fax 201-625-6377

212CV00351@gmail.com

Plaintiff, Sharon Ben-Haim Sol Havivi, Gamliel Elmalem IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW JERSEY CIVIL ACTION NO. 2:12cv351(JLL/MAH)

SHARON BEN-HAIM, SOL HAVIVI, GAMLIEL ELMALEM Plaintiff, v. YAAKOV NEEMAN, et al., Defendant.

PLAINTIFFS DOCUMENT REQUESTS FROM DEFENDANT IFCJ

To Defendant International Fellowship of Christians and Jews (IFCJ):

Pursuant to the Order of the Hon. Judge Hammer, Plaintiffs hereby demand production of documents within the time limits prescribed by the federal rules, as follows: 1. For the period between January 1, 2008 through the present, any publication, commercial, video, youtube clips, public approaches, brochure, leaflet, web site pages addressed to donors in the United States whereby IFCJ solicits money either (a) for strengthening family unit in Israel, in different variations such as for Jewish family welfare, for the women of Israel, for the safety of women in Israel or the prevention of violence against women in Israel. 2. Any direct-mail material, videos, public education material, the read-to-donor scripts at IFCJ call centers used in the United States and Canada using the holocaust or sympathies towards women to incite donors to make donations to IFCJ by either (a) depicting the holocaust at WWII, or (b) depicting women as victims of violence by Israeli men, or (c) depicting need to strengthen the family units in Israel. 3. Any document showing public opinion or research in custody of IFCJ or its contractors as to the issues that appeal to the donors, how to attract them, the meaning and definition of family 1

unity or family stability, and the donors attitudes towards encouragement of marriage break ups, separation of children from fathers fatherlessness, militant feminism, radical feminism, parental equality, and the Israeli feminists concept of female supremacy (e.g. Hacker Daphna, Ruth Halperin Kaddari, Zipy Hotovely). 4. For the period between January 1, 2008 through the present, records of any program that gave money, paid money or sent money from IFCJ, or its dispensing services of Keren Hayesod, to any womens organization in Israel, such as WIZO, NAAMAT, Israel womens Network, Shdulat Hanashim, Isha LeIsha, Bat Melech, Haddassah, Emunah, women shelters, city without violence recipients (entities or individual contractors), including documents reflecting the amount of money spent, the nature of the program, the identities of the officials who IFCJ was dealing with, the preparatory work made before granting the donation, and if paid via Keren Hayesod, why was it not paid directly from IFCJ. 5. The Objectives and Deliverables documents and Financial Pragmatic & Impact Details as to all donations IFCJ, or its dispensing services of Keren Hayesod, to any womens organization in Israel, such as WIZO, NAAMAT, Israel womens Network, Shdulat Hanashim, Isha LeIsha, Bat Melech, Haddassah, Emunah, women shelters, city without violence recipients (entities or individual contractors). 6. As to the documents requested above, please supply documents showing due diligence, or investigation or screening procedure of the recipients prior actions, goals, compliance with standards regarding IFCJs US tax exempt status/ Public Charity Status , impact on IFCJs stated goals (e.g. promote the well being of families in Israel or children in Israel) and gender based impact assessment. 7. As to each item requested above, provide documents reflecting IFCJs monitoring of the recipients use of the monies, monitoring of the recipients officials, heads and figures public appearance regarding their statements in public. 8. As to each item requested above, provide documents reflecting IFCJs monitoring of the recipients officials, heads and figures public appearances, public statements, lobbying efforts regarding their initial solicitation for funds, at the Legislature, Parliament (Knesset), or Municipal governments, and monitoring that indeed all funds were invested solely within the dedicated project and to permissible projects internally and overseas. 9. For the period between January 1, 2008 through the present, documents reflecting IFCJ, Yechiel 2

Eckstein, Yael Eckstein or any other officer or director at IFCJs meeting with any member of the Parliament (Knesset), including but not limited to Defendant Yaakov Neeman, Defendant Moshe Kahlon, or Municipal governments, for any reason other than social or photo-op, including the purpose of the meeting, the program or project discussed, the amount of money donated by IFCJ, or Keren Hayesod, or any other intermediaries, involved, the due diligence investigation whether the donation in cooperation with Ministers, parliamentarians, and other government officials complies with IFCJs promise to its donors, its US tax exempt status /Public Charity Status, and the ban on interfering with foreign legislation, and issuance of Israeli good standing certificates from the Israeli Registrar of Charities. 10. Any documents, correspondence, exchange, programs, brochures, understandings, contracts, by and between IFCJ or its officials, agents and lawyers with any of the other Defendants (Neeman, Kahlon, Arbel, Edri, Shteinmetz, KAs and NIF) in this case or the offices they represent . 11. Any documents, correspondence, exchange, programs, brochures, understandings, contracts, by and between IFCJ or its officials, agents and lawyers in association with or in combination with the Jewish Federation, the Jewish agency, the Jewish Sochnot, Keren Hayesod or any other United states fundraisers for Israel to donate money to any women-related program in Israel, City without violence program, building or enhancing or renovating of kindergartens operated or managed by womens organizations (including Naamat, Wizo, Emunah), building or enhancing or renovating Contact Centers for the supervision of children during visits with fathers, or other facilities branded as for the family or community centers bulisrt Statre 12. Notes, hand notes, meeting memoranda correspondence with any of the other co-Defendants and or the womens organizations which IFCJ donates to, showing the persons meeting with IFCJ, the purpose the understandings and follow up. 13. Documents, correspondence, exchange, programs, brochures, understandings, contracts, by and between IFCJ or its officials, agents and lawyers in association with any State or city employed social worker who is under supervision of any of the Defendants in this case, and in particular Niva Milner, Batya Artman, Simona Shteinmetz and Yael Harmel. 14. Documents, correspondence, exchange, programs, brochures, understandings, contracts reflecting transfer of monies from IFCJ donations to the needy in Israel, which is either recommended by, or handled by or dispensed in association or a state or City social worker who 3

is answerable to any of the co-Defendants. 15. Since January 1, 2010, documents reflecting assistance to politicians including co-Defendants (especially Kahlon) to promote themselves, including any contact between IFCJ, its presidents officers and employees motivated by enhancement of political aspirations of any of the Defendants to be promoted to a more prestigious job, including but not limited to IFCJs campaign to assist Defendant Moshe Kahlon in his bid to become Minister of Treasury and later the prime minister of Israel, including the documents showing the rationale for IFCJs donation of money to the Ministry of Welfare, and for distribution by Ministry of Welfare social workers, at a time when Defendant Kahlon announces his bid to be appointed Minister of Treasury. 16. Documents reflecting any spending of American and Canadian donors money to relocate Jews to immigrate to Israel via relocation, training, for and medical needs, and what steps were taken to warn such male immigrants, that in case of divorce, they will lose custody, be separated from their children, at risk of being falsely accused of domestic violence or sexual molestation of their own children, be assessed unconscionable child support, while their wives are exempt, and a ne exeat order will prevent them from leaving Israel. 17. Documents circulated among the charities, agencies and organizations involved with relocating men to Israel, after men who were lured by the Jewish agency to emigrate from France, managed to escape Israel and sued the Jewish Agency in France for failing to warn or alert immigrants to Israel of the rampant discrimination against men in Israel. (Reference: case at le Tribunal de Grande Instance de PARIS.1re Chambre, 1re Section, R.G. n 2010/14939, Association Paix et Justice Pour les Juifs Sfarades en Isral v. Agence Juive Pour Isral). 18. The documents, videos, information and training given to immigrants to Israel before they are persuaded to immigrate and after they immigrate regarding the unique perils of relocating to Israel, including the perils of loss of family life, liberty, and family in case of divorce, separation or sperm theft either by IFCF, Wings of Eagles " or any of its partners to the efforts to relocate Jews to Israel. 19. Documents reflecting suicide committed by immigrants to Israel who were brought via one of IFCJs immigration projects, alone or in combination with others, (for example Ethiopians who are not advised about Israeli female clinics where the Ethiopian women receive advise to break up marriages and divorce, eventually commit suicide. 20. Documents that reflect preparatory work before bringing immigrants to Israel from less feminist 4

countries such as Ethiopia and Russia has been made to adjust and acclimate the new immigrants to the ultra feministic laws and policies of the State of Israel, its Courts, police officers, and rabbinical judges. 21. Documents regarding any donation to combat parental alienation syndrome, combat the disintegration of the family units in Israel, combat the break up of marriages, combat suicide by divorced or divorcing men 22. Documents regarding any donation to support fathers rights organizations, victims of militant feminism, victims of state paid Social worker, men who lose homes, men who lose contact with children or child access, men who lose families, men who become homeless, and men who are at risk of committing suicide because of contact with any of the offices which any of the coDefendants is associated with (Ministry of justice, Ministry of Welfare, Rabbinical court, Israel Court administration including family courts and Supreme Court). 23. Any and all complaints received from immigrants brought to Israel, whose marriage broke up or was charged with domestic violence or thrown out of the house for inability to pay exorbitant child support. 24. Agreements IFCJ, or through its servicing arm, the Keren Hayesod or any of the donees, such as Cities Without Violence, signed with the done, or individuals known as feminists or womens rights champions, e.g. Orly Innes, Ruth Halperin Kaddari, Daphna Hacker, Irit Gazit, and Gali Etzyon, including all confidentiality agreements signed in Israel. 25. Documents concerning donation to any clinic offering legal services, where more than 80% of the clients are female including the material being distributed to women seeking divorce, the guidelines to advise women seeking to break up marriage the encouragement of false domestic violence complaints, and the financing of divorces and parental alienation. 26. Video footage, tv footage of officers of IFCJ, including the President Yechiel Eckstein in Israel to self promote IFCJ or Eckstein in the Israeli public eye, such as Orly Vilnai, and A Star is Born, including the payments for Israeli television to feature Eckstein personally. 27. Donations transferred by Tzvi shur or Devorah Ganani as IFCJ representative to radical feminists groups in Israel or to fund projects that are incompatible with the evangelical donors lifestyles, attitudes or beliefs.

Dated: Fair Lawn, NJ May 2, 2012 /S/ Sharon Ben Haim Sharon Ben Haim 6-05 Saddle Rd. #225 Fair Lawn, New Jersey 07410 Tel. 917-775-5386, Fax 201-625-6377 212CV00351@gmail.com cc: All counsel [Via e-mail]