FILEr) zun FEB 23 Ail: 28 - Courthouse News

SHARON S BEN-HAIM BEN-HAIM SUPERIOR COURT BERGEN COUNTYOFIR

6-05 Saddle River Rd 225 FILEr) zun FEB 23 Ail 28 Fair Lawn NJ 07410

FEB 2j LUllT2012034106 F2016256377 sharonsbh ilcom ~a~)~Ben-Haim pro se DEPUTY CLERK

SUPERIOR COURT OF NEW JERSEY SHARON S BEN-HAIM individually ) LAW DIVISION BERGEN COUNTY and as guardian ad litem ofOFIR BEN-HAIM )

)

Ben-Haim

) ) )

Docket No bl ~ -I Y v )

) Civil Action NEW ISRAEL FUND a non-profit corporation ) MAVOl SATUM (DEAD END) ) an Israeli non-profit organization ) COMPLAINT AND JURY DEMAND and ) BATYA KAHANA-DROR an individual )

ORR TORAH STONE a non-profit corporation )

YAD LISHA an Israeli non-profit organization ) ZVIA MOSKOWITZ an individual )

) Defendants )

Plaintiffs SHARON S BEN-HAIM an

)~ Date Filed L i L 7 P ---~ayment ___ ___rOO

CA ~ (-

Amount ~ L ~G) payor~~~~~~~ BatchRetl- 1l~

1AIM complain

against defendants NEW ISRAEL FUND MAVOI SATUM _ (DEFJd END)00 =

1 ZVIABATYA KAHANA-DROR OHR TORAH STONE YAD

[2 11

MOSKOWITZ and do hereby set forth and allege

~) -

I ) i

I I

1

PARTIES

1 Sharon S Ben-Haim (Ben-HaimU) an individual has

been a resident of New Jersey since 2004

2 Ofir Ben-Haim (Ofir) is the minor daughter of Ben-

Haim and was born September 10 2009 in Englewood New Jersey

3 Defendant New Israel Fund (NIF) is a California nonshy

profit organization that has provided direct and indirect

financial support to Oshrat Abergel the mother of Ofir who

criminally abducted her from New Jersey to Israel NIFs

registered agent for service of process 1S Steve Rothman and

42 ndits address for service of process is 1946 Avenue San

Francisco CA 94116

4 Defendant New Israel Fund (NIFU) also has 0 ice in

39 thNew York City Located 6 East St Suit 301 New York NY

10016

5 Defendant Mavoi Saturn (DEAD END) is a self-described

Israeli non-profit organization with of ces in New York City

located at 317 Madison Ave Suite 607 New York NY 10017 and

upon information and belief 1S an unincorporated association

operating under the recognized name of Mavoi SatumU or (DEAD

END) and thus may be served by serving a copy of the summons

lSimultaneously with the filing of this Complaint Sharon Ben-Haim has filed an application to be appointed Ofir Ben-Haims guardian ad litem

2

and complaint on an officer or managing agent of Mavoi Satum

which in this case is defendant Batay Kahana Dror NJ Rule 44shy

4 (a) (5)

6 Defendant Batay Kahana-Dror ( Kahana - Dror ) is a

resident of State of Israel residing at Nes Barim 605

rusalem 9988500 Israel and is the founder and chief

executive officer of Mavoi Sum and has appeared as counsel in

courts Israel on behalf of Abergel and as a result of

residing outside of the territorial jurisdiction the United

ates she may be served pursuant to the methods s out in NJ

4 4-4 (b) (1) (B) and (C)

7 Defendant Ohr Torah Stone 1S a New York non-profit

organization located at 155 East 55th reet Suite 303

New York New York 10022 and has provided direct and indirect

finan al support to defendants Yad Lisha and Zvia Moshkowitz

who have in turn assisted Oshrat Abergel (formerly Oshrat

Ben-Baim herein Abergel) through financial support and other

means criminally abduct and kidnap Ofir Ben-Bairn in violation

of a custody order for Superior court of New Jersey

8 De ndant Yad Lisha is an Israeli non-profit

organization that supported the criminal abducted and kidnapping

a US child and citizen from New Jersey Yad Lisha is located

3

at Sheila 7 Tel Aviv - ISRAEL With conne ion to 0 lces OHR

TORAH STONE in New York City located at 155 East 55th Street

Su e 303 New York NY 10022 and upon information and

belief is an unincorporated association operating under the

recognized name of OHR TORAH STONE and thus may be served by

serving a copy of the summons and complaint an ficer or

managing agent of Yad Lisha which this case lS defendant

Ziva Moshkowitz NJ Rule 44-4 (a) (5)

9 Defendant Zvia Moshkowitz (Moshkowitz) is a resident

of State Israel residing Tamar St 19 Shoham Israel and

has appeared on behalf of Abergel as counsel (Loading rabbis)

in the Rabbinical Religious Court of Haifa And as a result of

residing outside of the territorial jurisdi ion of the United

St es she may be served pursuant to the methods set out in NJ

44 4 (b) (1) (B) and (C)

Loadinq rabbis (initials Tor) or claims court is professional modern representation of clients before religious courts in family law

JURISDICITION AND VENUE

10 Venue and jurisdiction are proper in this court because

Ben-Haim is a resident of Bergen County NJ as is his daughter

Ofir and each of the defendants has su icient minimum contacts

wi New Jersey so that to subject them to jurisdiction in New

4

Jersey Superior Court does not offend due process or the

traditional notions substantial justice and fairness


the all orders issued om this court

12 The defendants intentional torts were dire ed at the

Ben-Haim in Bergen County NJ and the impa defendants

acts lured and continues to injure Ben-Haim in rgen county

NJ Moreover the defendants have availed and continue to avail

themselves of New Jersey jurisdiction by nancially and

otherwise supporting the criminal abduction and kidnapping of a

New Jersey resident and aiding and abetting the violation of an

anti-suit order issued by the Superior Court New Jersey and

in violation international law

13 NIF donates money to Mavoi Saturn defendant Kahana-

Dror both whom have espoused advanced and took part in the

wrongful actions s forth in this complaint See Exhibit 1

attached hereto

14 NIF donates money to Yad Lisha which has also

espoused advanced and took part In the wrong 1 actions set

forth in this complaint See Exhibit 2 attached hereto

15 Upon information and belief NIF actively conducts fund

raising activities in New Jersey to solicit and receive

5

donations least two NJ synagogues Congregation Shomrei

Emunah in Mont clair NJ Reform Temple Ner Tamid of

Bloomf ld NJ are sponsors of NIF and regularly host NIF

events where such fundraising has ta place Upon and

information and belief NIF and the other defenda s have used

such funds to commit the acts complained of ln t s complaint

16 Upon information and belief other NIF ctures and

a ivities are organized in New Jersey as for example those

conducted in ass ation with the Amy Adina Schulman Fund The

Jewish er in nceton NJ For example 2011 the

guest speaker at the Jewish Center was Bruce Temkin NIFs NY

dire or

17 Upon information and ief Peter Shap 0 who serves

on Fs Intern ional Council resides of South Orange New

Jersey

18 NIF is registered with the New Jersey Division of

Consumer Affa s Charities Registration Section under

provisions the Charitable Registrat and Investigation Act

NJSA 4517A-18 et S 0 regist ion number 0455800

-binchaht wwwstate

19 In 2012 Ben-Haim previously sued NIF in New Jersey

federal distri cou Civil Action No 212CV351( ) its

6

role in supporting rabbis and others in the Israel to create an

environment and system that is anti-male hostile and abusive

to fathers in divorce proceedings Therein Ben-Haim leged

NIF notwithstanding the existence the anti-suit order knew

or should have known that by continuing support to Abergel it

was aiding and abetting her in a criminal enterp se Defendant

Kahana-Dror upon information and belief travels regularly to

the US and to New Jersey to give speeches and to solicit

donations for Mavoi Saturn Because the Defendants intentional

torts were directed at New Jersey and caused an ef ct on a New

rsey resident jurisdiction exists over each of them before

the Supe or Cou New Jersey

INTRODUCTION

20 This is an action by Ben-Haim and his daughter Ofir

who was criminally abduct and kidnapped by her mother Oshrat

Abergel from her home New Jersey to Israel Courts of law

in both Israel and New Jersey have recognized the abduction

21 Abergel was charged with criminal abduction on Aug 9

2012 in State of New Jersey v Oshrat Ben-Haim (Abergel) Case

Number 10-15260 and Indictment No S-1210-12 by the criminal

7

of New rs and the County Grand Jury See

Exhibit 3 attached hereto

22 The kidnapping continues as Abergel has never returned

ir to her r in her home state of New sey Abergel

committed cr by holding in Israel and continues to

ate a dire order of the erior Court New Jersey

County which had ordered Abergel to urn Ofir to

ited States by S ember 10 2011

23 Al so a s ares u 1 t continuing c nal act

iling to return Ofir to New sey both State of New

rsey and Inte 01 have issued arrest warrants Abergel See

Exhibit 4 atta hereto

24 On Janu 28 Hon Judge Susan J eel issued an

opinion against hrat Ben-Ha in the Superior Court of New

rsey Docket No BER-L-7551 13 nding Oshrat liable to Sharon

damages from parental abduction A copy the opinion

is attached o as Exhibit 5

25 On y 30 2015 a 1 judgment was entered

aron Ben-Ha against Oshrat -Haim in the Superior Court

New Jersey for the damages s has caused in an amount of

$274616146

8

26 The fendants provided and cont to provide

financ 1 and other support to Abergel and have aided and

ab ted and continue to aid and Abergel a known

criminal her continuing abduction of Ofir trating a New

Jers anti-suit order and Interpol warrants and have tormented

and threatened and cont to torment and threaten Ben-Haim and

his family both physically and nancially The defendants

have worked closely with rgel in to de at the New

Jersey or Court order and to successfully separate

Haim his daughter

27 As a result of the defendants action Haim has

lost 1 connection with his daughter As a result -Haim

has suffered reme emotional distress from the loss of his

father-daughter relationship with rand r inabil y to

have any cont with one another Ben-Haim s been

emotionally devastated by this forced separation from Ofir and

Ofir s missed ting to know her and having him

sent during her childhood

28 To stop to s seemingly unending nightmare Ben im

obtained an 1 Suit order from the Superior Court of New

rsey o ing Abergel from aking any further court

proceedings outs of the New sey courts and then obtained

9

an order granting Ben-Haim custody of Ofir See Exhibi t 6

attached hereto

29 Despite knowledge of the orders of the court the

defendants through their financial backing of Abergel and

through Kahana-Drors assistance of Abergel in Israeli courts

have blatantly disregarded the anti-suit order the custody

order and have continued on Abergels behalf to defame Benshy

Haim and psychologically torture he and his family before the

Israeli rabbis and the Israeli courts

30 As a result Ben-Haim has brought the instant action to

hold defendants to account for their misdeeds and for the

damages to Ben-Haim and to his reputation Ben-Haim also

reserves the right to add other individuals and entities as

defendants whose identities are currently unknown to Ben-Haim

but who on information and belief continue to financially

support Abergel either indirect ly through the defendants or

directly to Abergel in continuing her criminal abduction of

Ofir

10

FACTUAL BACKGROUND AND PRIOR RELEVANT

LEGAL PROCEEDINGS

31 During a Passover vacation in Israel while of Ben-Haim

and Abergel vacationed In Israel Abergel hired attorney Tal

Itkin to file a summons for divorce and equitable jurisdiction

in the Rabbinical Court in Israel on April 7 2010 To

Abergel it had not been a vacation at all but rather a

premeditated act of forum shopping to lure Ben-Haim into a more

favorable jurisdiction for her one in which men are routinely

discriminated against

32 On April 8 2010 Abergel also filed a request to

obtain a ne-exeat warrant against Ben-Haim to prevent him from

leaving Israel and falsely alleged Ben-Haim intended to kidnap

Ofir and run away with her to the United States when in fact

it was Abergel who had been preparing to kidnap Ofir Abergel

and her counsel also intentionally omitted from the documents

used to support the ne-exeat warrant the fact that she and Ben-

Haim were residents of the State of New Jersey Abergels

request for the warrants was argued before rabbinical judges

(known as the Dayanim) an Israeli religious tribunal of

rabbis to have Ben-Haim arrested and to issue ne-exeat

restraining orders to prevent him from leaving Israel While

11

ese forums a referred to as so-called a Rabbi cal Courts II

New Jersey courts do not recognize rulings issued by such

entities

33 rthermore e Dayanim have been found to misuse

their religious authority ra udicially in Israel and in

US to emotionally physically harass men l 0 granting

religious divorces Indeed c nal charges have been filed by

t US Attorney in New Jersey federal court against rabbis for

their abduction and physical abuse of Jewish men to forcibly

obtain religious divorces

34 On June 20 2010 Abergel refused to to New

Jersey with Ofir as previously agreed and planned by aim

and Abergel and she remained in Israel The New Jersey

Superior Court and Israeli Supreme Court 1 er ruled

Abergels refusal to return ir amounted to child abduction

35 rgel with the bac ng and support of

defendants waged war in Israel ainst Ben- lm and his ly

fighting un irly and re sing to acknowledge the primacy of

the New rsey courts on custody and divorce

36 On January 28 2011 upon his return to the Un ed

States Haim commenced an action in the Superior Court of

New sey Chance Division ly Part Case No FD-02 906shy

12

II seeking an order demanding gel return r to New

sey

37 Meanwhile on May 17 2011 while the Supreme Court in

Israel agreed t Ofir had been abdu ed it deni Ben-Haims

i tion on the technical theory that Ben-Haim consented to

abduction when in fact he was being coerced by Abergel to

negotiate terms r release of the ne-exeat warrants

38 Irnrnedi ely thereafter -Haim sought relief in the

or Court of New Jersey which on August 25 2011 found

e actions of Dayanim in Israel did not warrant comity and

the Israeli courts judgment was irrational and contrary

to the facts Spe fically the held

New Jersey has previously addressed the issue of ecclesiastical court rulings in other jurisdictions and I particularly note Innes v Carrascosa which is 391 N J Supr 453 And in that case the defendant had argued that the religious annulment that she had filed for in Spain first should be recognized

In this case the defendant Abergel filed for ecclesiastical court That court granted her temporary custody And this Court finds that ruling is not to be recognized by the State of New Jersey As in Innes v Carrascltsa the rabbinical court is a religious court whose is ruling not given any civil effect New Jersey case law provides that such rulings should not be recognized and as a result that ruling has no bearing on the decision to be made by this Court

A true and correct copy of Transcript courts is tached hereto as Exhibit 7

true and corre copy of the courts order is attached reto as Exhibit 8

13

39 court then orde ir be returned to w sey

by S 10 2011

40 However Abergel s re sed and unable to attack

Ben im In Israel directly has pressured Ben-Haims f ly in

to r har as sand inj ure -Haim and to force h into

ng up his fight for his er On January 6 2012 on

Ben- petitioned for and t court enj oined 1 from

fil or pursuing any action or complaint for divorce child

support or alimony in any including Rabbinical Cou sand

the lian courts of e of Israel other the

Superior Court of New Jersey en County Family The

full is attached as Exhib 6 attached he o

41 On January 7 2013 t court granted a

and awarded Ben-Haim 1 custody of Ofir true and

corre copy of the order is att hereto as Exhibit 9

42 spite these orders as detailed below the s

have provided direct and indi support to Abergel in aid of

her a ions against Ben Haim and his family In harassing

infli ing extreme emotional abuse and defamation and In

support and perpetuation of Aber ls kidnapping of Ofir

43 er the January 2012 anti-suit order s

supported Abergels efforts to pursue actions for divorce child

14

support or alimony Israel esently there are three

actions pending the Rabbinical Court in 1 one r

divorce one for alimony and one for a motion for a warrant

There is also an action child support pending in the ly

Court in Nazareth

44 On or before about October 2 2013 Zvia Moshkowitz

(Moshkowitz) of the Yad Lisha aid organization fil a

request a hearing the i Rabbinical Religious Court

regarding mar property on behalf of Abergel On information

and belief NIF provided the funding for Moshkowitzs

resentation of Aber 1 and NIFs own documents rep that

Yad Lisha is a direct rec ient of aid from Defendant NIF as

set forth in Exhibit 2 attached hereto

45 NIF was aware the time t Ofir had been kidnapped

and that Haim had obtained the Janu 2012 anti-suit order

because Ben aim had alleged similar facts in a federal suit

pending against NIF and other defendants

46 Haim sent a cease and desi letter to Moshkowitz

and Yad Lisha s cifically referenc the anti-suit order See


47 Ben- im also sent a cease and desist letter to Rabbi

Shlomo Riskin Ohr Torah Organization specifically

15

re rencing anti-suit r and demanded that the request

hearing terminated Ohr Torah Orga zation supp s the

Yad Lisha Or nization with donations is collected all

over US See Exhibit 11 tached hereto

48 Defendants Moshkowitz Yad Lisha and NIF iled to

rminate these proceedings and Moshkowtiz made additional

lings and arances on b If of Abergel in defiance the

New Jersey s January 6 2012 1 anti-suit order Kahanashy

has defamed Ben-Haim and caused extreme emotional stress

to Ben-Haims ly by inuing to Isely state on the

record before the Dayanim and Ben-Haim l s family (who had been

summoned to ar) that -Haim was a criminal that he

wrongfully from Israel and that Haims family should

be put in prison and sanctioned monetarily

49 More recently on June 7 2015 Batay Kahana Dror of

Mavoi Saturn obtained authorization to resent Abergel in the

yanim of Hai Case No 5897991 On formation and belief1

F provided e funding Kahana- s representation of

Abergel and NIFs own documents report that defenda Mavoi

Saturn lS a dire recipi of aid from fendant NIF as set

rth In See Exhibit 12 ached hereto

16

50 Since fendants have aided Ab I to continue

using the Rabbinical Cou to put additional pressure on

Haim by threatening to jail his mother er and sister

unless he drops his efforts to rain his daughter and provided

the religious divorce (a get) to Abe el in Israel

51 As a result of these statements Ben-Haims mother

became so straught and panicked th she came ill and had to

be hospitaliz

FIRST CAUSE OF ACTION

Intentional Interference with Custody

Ben im adopts and realleges all pr ous allegations

with same force and feet as if fully set h here

53 The defendants have been on notice of and are aware of

the New Jersey courts January 6 2012 order oining Abergel

proceeding th any claims divorce alimony or ild

support in Rabbinical Courts or any other courts of Israel

(see exhibit 6) That notice is on file with Rabbinical Court of

Hai Case No 5897991I

54 Thus I Defendants have been on direct notice the

existence of the courts order since its inception

defendants gave substantial nancial and other assistance and

17

encouragement to Abergel as she refus to abide by the custody

orders of the New Jers Superior Court and return ir to

fathers custody Thus endants actions have aided and

abetted Abergels kidnapping Ofir thereby causing injury to

Benshy

55 a proximate result of one or more of se

intentional a s Ben has s red damages in an amount to

be proven at trial Moreover the a ions by defendants have

injured Ben im by cing him having to respond and oppose

improper and invalid proceedings in the Rabbinical Court of

ifa and Nazareth Family Court Consequently Ben-Haim has

suf damages in an amount to be proven at trial and has

incurred necessary attorney fees in an amount to be proven at

trial Moreover cause these acts were int ional and

malicious punitive damages are warranted

SECOND CAUSE OF ACTION

Defamation and Libel Against All Defendants

56 Ben- 1m adopts and real leges all previous allegations

with the same and ef ct as if lly set rth here

18

57 On or about June 2015 Kahana-Dror with the support of

NIF and Mavoi Satum gan a malicious campaign of character

assassination against Ben- im and his family members

58 Beginning W1 statements ma to e Dayan Kahanashy

Dror falsely accus Ben im of criminal condu cla ng that

he fl from Israel and that he V1 ed court 0 rs However

inasmuch as the Rabbinical Courts are religious tribunals on or

about August 25 2011 NJ Sup Court had decla the

Rabbini Cou s actions and judgments were not recognizable

or enforceable in the State of New Jersey Because rabbinical

courts are not recognized under NJ law traditional immunities

would apply to defamatory atements made in US judicial

pro ngs are not applicable

59 In or around September 2016 Kahana-Dror continued her

malicious character assassination campaign against Ben- 1m and

his ly members On September 13 2016 Kahana-Dror

published Ben-Haims name on Channel I and on Radio B 1n

Israel and Isely accused him of criminal condu that he fled

from Israel and violated court orders

60 On October 7 2016 Ben- im filed a complaint against

Kahana Dror W1 the Israel Bar Association Jerusalem District

Ethics committee Case No 16321 publishing -Haims

19

name on Channell and on Radio B in Israel and sely

accusing him of criminal conduct and that he fled from Israel

Ben-Haim compl ned that she vi ated pr leged court Sup Ct Of

Israel orders that the case was not for publishing until the

court g a final judgment

61 On Jan 8 2017 the Israel Bar Association- rusalem

strict Ethics Committee smissed the case but gave to Kahana-

Dror the following on her

However the Commdttee notified attorney Batya Kahana-Dror that in view of the fact that the proceedings in the Supreme Court are conducted behind closed doors there is something violation about the fact that in an interview given on the radio program Waves of Israel the names of parties whose names are confidential were mentioned thereby collaborating with however indirectly a breach of a judicial order with regard to confidentiality

62 On Jan 22 2017 -Haim appealed to the National

Ethics Commit about not taking dis inary a lon against

Batya Kahana-Dror and has still has not been provided a

decision

63 Kahana-Dror and Mavoi Saturn organization knowingly and

maliciously disseminated to the Rabbinical Dayanim in Haifa

Isra that Ben-Haim was a criminal however said statement was

false misleading and injurious to the Ben-Haim

20

64 Kahana by publishing statements accusing Ben- im

of criminal conduct committed libel per se

65 Kahana Dror acted will ly mali ously and wantonly

reckless disregard of -Haims rights liberties and with

intent to injure the Ben-Haim

66 Kahana-Dror by publishing other statements about

Haim with knowledge of their lsity has entionally caus

Ben-Haim to su damages here in New sey including but not

limited to loss reputation in community and the refusal

of others to age with him in business

67 a proximate result of these int ional acts and the

infliction of emotional distress Ben- im has suffered damages

in an amount to be proven at trial and has incurred necessary

attorney fees in an amount to be proven at tal

68 cause these a s were intentional punitive

dama s are warranted

THIRD CAUSE OF ACTION

Intentional Infliotion of Emotional Distress Against All Defendants

69 Ben-Haim repeats and realleges all previous aIle ions

with the same force and effe as if lly s forth reinf

21

70 Abergel engaged defendants Kahana and Mavoi Saturn

to maliciously torment and financially t -Bairn and to

threaten Ben-Bairn and cause him grief and agony through improper

and illegal means while defendant NIF p the necessary

funding for Kahana-Drors and Mavoi Saturns condu

71 NIF Kahana-Dror and Mavoi knew or should have

known there existed a high probability continuing

abduction of Ofir in Isra and t compl e s ng of the

paternal relationship between and r prevention

of Ben-Bairn from returning horne to New and the repeated

assaults on Ben-Bairn and his character and ity ln the

Rabbinical Court and the Family wou resu in severe

emotional distress to Ben-Raim

72 Defendants intentional a ions consti ed extreme and

outrageous conduct designed to termi n- ims relationship

with Ofir his child

73 Defendants actions alienat n 1 bond and

affection that should exist between and s daughter

and caused Ben-Bairn severe and extreme ional distress Ben-

Raim suffered depression anxi y sl tion and other

emotional and psychological damage as a resu his alienation

from Ofir

22

74 Defendants conduct was so outrageous in character and

so extreme in degree as to go beyond all possible bounds of

decency and to be regarded as atrocious and utterly

intolerable in a civilized community

75 As a proximate result of these intentional acts Benshy

Haim and Ofir have been completely alienated from each other

since June 20 2011 Ben-Haim has been prevented from sharing

in his daughters life in any meaningful way He has suffered

countless sleepless nights and his mental and physical state has

deteriorated as he has tried in vain to have Ofir returned

despite Abergels efforts

76 Ben-Haim has been prevented from having any contact

with Ofir since September 1 2011 and has had absolutely no

role in her life her upbringing or her education

77 As a result of losing his business due to the extreme

emotional distress caused by his alienation from Ofir Ben-Haim

now works for minimal wage

78 Defendants knew or should have known that there existed

a high probability that the continuing abduction of Ofir In

Israel and the complete severance of his paternal relationship

with Ofir the prevention of Ben-Haim from returning home to New

Jersey and the repeated assaults on Ben-Haim and his character

23

and integrity in the Rabbinical Court and Family Court would

result in severe emotional distress to Ben-H

79 The emotional distress has fered has

been severe and no reasonable person could be ected to endure

it

80 Because these acts were malicious and intentional

punitive damages are warranted

FOURTH CAUSE OF ACTION

Civil Conspiracy Against All Defendants

81 Ben-Haim repeats and realleges all p ous al gations

with the same force and effect as if lly s herein

82 The defendants engaged er planned and

collaborated in devising a scheme and campaign to aid and abet

Abergel in breaking the law by abdu ing and kidnapping Ofir

Ben-Haim and refusing to return her to -Ha

rance of the83 The defendants took acts in

scheme by providing direct and indire financial support to

Abergel and illegally uSlng judicial ocess in Israel to

frustrate Ben-Haims efforts to have r ret to NJ as

ordered by the courts

24

84 The defendants acts in furtherance of their scheme

were independent wrongful acts that gave se to counts 1 4 of

Ben-Haims complaint and the damages asse ed therewith

Consequently the defendants are liable to Ben-Haim for civil

conspiracy and for compensatory and punitive damages in an

amount to be proven at t al

PRAYER FOR RELIEF

WHEREFORE Ben-Haim requests judgment against Defendants

for at least $26000000 in compensatory damages and $1000000

for every year that Ben-Haim and 0 r his daughter have been

separated from each other plus punitive damages plus

attorneys fees costs of suit and any other relief the Cou

may deem just and proper

Dated February 23 2017

~ tn-HasqA Plaintiff Pro se

25

PARTIES

1 Sharon S Ben-Haim (Ben-HaimU) an individual has

been a resident of New Jersey since 2004

2 Ofir Ben-Haim (Ofir) is the minor daughter of Ben-

Haim and was born September 10 2009 in Englewood New Jersey

3 Defendant New Israel Fund (NIF) is a California nonshy

profit organization that has provided direct and indirect

financial support to Oshrat Abergel the mother of Ofir who

criminally abducted her from New Jersey to Israel NIFs

registered agent for service of process 1S Steve Rothman and

42 ndits address for service of process is 1946 Avenue San

Francisco CA 94116

4 Defendant New Israel Fund (NIFU) also has 0 ice in

39 thNew York City Located 6 East St Suit 301 New York NY

10016

5 Defendant Mavoi Saturn (DEAD END) is a self-described

Israeli non-profit organization with of ces in New York City

located at 317 Madison Ave Suite 607 New York NY 10017 and

upon information and belief 1S an unincorporated association

operating under the recognized name of Mavoi SatumU or (DEAD

END) and thus may be served by serving a copy of the summons

lSimultaneously with the filing of this Complaint Sharon Ben-Haim has filed an application to be appointed Ofir Ben-Haims guardian ad litem

2



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LEGAL PROCEEDINGS





















11



entities




















12


sey















13


by S 10 2011





















14





Court in Nazareth


















15






















16








be hospitaliz














17





Benshy















18























19













decision





20





















21
















with Ofir his child






from Ofir

22























23





it
















24







PRAYER FOR RELIEF









25















44 4 (b) (1) (B) and (C)







4

















attached hereto






5












dire or



Jersey





-binchaht wwwstate



6













INTRODUCTION








7





















$274616146

8










Haim his daughter













9


attached hereto
















Ofir

10


LEGAL PROCEEDINGS





















11



entities




















12


sey















13


by S 10 2011





















14





Court in Nazareth


















15






















16








be hospitaliz














17





Benshy















18























19













decision





20





















21
















with Ofir his child






from Ofir

22























23





it
















24







PRAYER FOR RELIEF









25

















attached hereto






5












dire or



Jersey





-binchaht wwwstate



6













INTRODUCTION








7





















$274616146

8










Haim his daughter













9


attached hereto
















Ofir

10


LEGAL PROCEEDINGS





















11



entities




















12


sey















13


by S 10 2011





















14





Court in Nazareth


















15






















16








be hospitaliz














17





Benshy















18























19













decision





20





















21
















with Ofir his child






from Ofir

22























23





it
















24







PRAYER FOR RELIEF









25












dire or



Jersey





-binchaht wwwstate



6













INTRODUCTION








7





















$274616146

8










Haim his daughter













9


attached hereto
















Ofir

10


LEGAL PROCEEDINGS





















11



entities




















12


sey















13


by S 10 2011





















14





Court in Nazareth


















15






















16








be hospitaliz














17





Benshy















18























19













decision





20





















21
















with Ofir his child






from Ofir

22























23





it
















24







PRAYER FOR RELIEF









25













INTRODUCTION








7





















$274616146

8










Haim his daughter













9


attached hereto
















Ofir

10


LEGAL PROCEEDINGS





















11



entities




















12


sey















13


by S 10 2011





















14





Court in Nazareth


















15






















16








be hospitaliz














17





Benshy















18























19













decision





20





















21
















with Ofir his child






from Ofir

22























23





it
















24







PRAYER FOR RELIEF









25





















$274616146

8










Haim his daughter













9


attached hereto
















Ofir

10


LEGAL PROCEEDINGS





















11



entities




















12


sey















13


by S 10 2011





















14





Court in Nazareth


















15






















16








be hospitaliz














17





Benshy















18























19













decision





20





















21
















with Ofir his child






from Ofir

22























23





it
















24







PRAYER FOR RELIEF









25










Haim his daughter













9


attached hereto
















Ofir

10


LEGAL PROCEEDINGS





















11



entities




















12


sey















13


by S 10 2011





















14





Court in Nazareth


















15






















16








be hospitaliz














17





Benshy















18























19













decision





20





















21
















with Ofir his child






from Ofir

22























23





it
















24







PRAYER FOR RELIEF









25


attached hereto
















Ofir

10


LEGAL PROCEEDINGS





















11



entities




















12


sey















13


by S 10 2011





















14





Court in Nazareth


















15






















16








be hospitaliz














17





Benshy















18























19













decision





20





















21
















with Ofir his child






from Ofir

22























23





it
















24







PRAYER FOR RELIEF









25


LEGAL PROCEEDINGS





















11



entities




















12


sey















13


by S 10 2011





















14





Court in Nazareth


















15






















16








be hospitaliz














17





Benshy















18























19













decision





20





















21
















with Ofir his child






from Ofir

22























23





it
















24







PRAYER FOR RELIEF









25



entities




















12


sey















13


by S 10 2011





















14





Court in Nazareth


















15






















16








be hospitaliz














17





Benshy















18























19













decision





20





















21
















with Ofir his child






from Ofir

22























23





it
















24







PRAYER FOR RELIEF









25


sey















13


by S 10 2011





















14





Court in Nazareth


















15






















16








be hospitaliz














17





Benshy















18























19













decision





20





















21
















with Ofir his child






from Ofir

22























23





it
















24







PRAYER FOR RELIEF









25


by S 10 2011





















14





Court in Nazareth


















15






















16








be hospitaliz














17





Benshy















18























19













decision





20





















21
















with Ofir his child






from Ofir

22























23





it
















24







PRAYER FOR RELIEF









25





Court in Nazareth


















15






















16








be hospitaliz














17





Benshy















18























19













decision





20





















21
















with Ofir his child






from Ofir

22























23





it
















24







PRAYER FOR RELIEF









25






















16








be hospitaliz














17





Benshy















18























19













decision





20





















21
















with Ofir his child






from Ofir

22























23





it
















24







PRAYER FOR RELIEF









25








be hospitaliz














17





Benshy















18























19













decision





20





















21
















with Ofir his child






from Ofir

22























23





it
















24







PRAYER FOR RELIEF









25





Benshy















18























19













decision





20





















21
















with Ofir his child






from Ofir

22























23





it
















24







PRAYER FOR RELIEF









25























19













decision





20





















21
















with Ofir his child






from Ofir

22























23





it
















24







PRAYER FOR RELIEF









25













decision





20





















21
















with Ofir his child






from Ofir

22























23





it
















24







PRAYER FOR RELIEF









25





















21
















with Ofir his child






from Ofir

22























23





it
















24







PRAYER FOR RELIEF









25
















with Ofir his child






from Ofir

22























23





it
















24







PRAYER FOR RELIEF









25























23





it
















24







PRAYER FOR RELIEF









25





it
















24







PRAYER FOR RELIEF









25







PRAYER FOR RELIEF









25

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FILEr) zun FEB 23 Ail: 28 - Courthouse News