Date : 2/15/2017 9:53:13 PM
From : "Richard D. Heideman"
To : "Tal Werner Kling"
Cc : "Noa Bar Shalev" , "Sharon Gefen" , "Roy Schondorf" , "Richard D. Heideman" , "Noel J. Nudelman" , "Tracy R. Kalik"
Subject : RE: Request for Assistance


Dear Tal,

 

Thank you for your email and for providing this information, which is much appreciated.

 

Sincerely,

 

Richard

 

Richard D. Heideman

Heideman Nudelman & Kalik, P.C.

1146 19th Street, NW

Fifth Floor

Washington, DC 20036

(p) 202.463.1818

(f)  202.463.2999

(c) 202.255.5700

From: Tal Werner Kling [mailto:TalW@justice.gov.il]
Sent: Wednesday, February 15, 2017 7:30 AM
To: Richard D. Heideman <rdheideman@hnklaw.com>
Cc: Noa Bar Shalev <NoaBS@justice.gov.il>; Sharon Gefen <SharonG@justice.gov.il>; Roy Schondorf <RoySc@justice.gov.il>
Subject: FW: Request for Assistance

 

Dear Richard,

 

My Name is Tal Werner Kling and I am the Director of Strategic Affairs at the Department of special International Affairs at the Ministry of Justice. Dr. Roy Schondorf relayed your email to me. I apologize for the delay in our response.

 

In general, a resident or a citizen of Israel has the right to receive information from a public register, in accordance with Israel's Freedom of Information Law 5758-1998.

If you are interested in receiving specific information, your clients can submit an application to the Office of the Freedom of Information Commissioner, as detailed here.

 

However, in light of the urgency of your request, we were able to identify several additional public sources of information that may be helpful:

 

1.       Atzmona attack

a.   According to a media report, indictments were filed against two perpetrators of the attack that were members of Hamas (See a media report here which names the Hamas activists).

b.     The following media report states that "according to the IDF", Saleh Shehada was behind the planning of the Atzmona attack (here).

c.      A third article states that "according to the ISA", a group of Hamas activists is responsible for the Atzmona attack (here). According to the same article, the group was exposed and investigated by the ISA.  

d.     Additional media sources: a report that the IDF destroyed the house of the perpetrator of the attack, Muhammad Farhat (here); that the IDF confirmed that Wa'el Nassar, a senior Hamas activist was killed (here); and that the same activist was involved in the Atzmona attack (here, and on Hamas's website here).

 

2.       Neve Dkalim

a.      Information regarding the death of the victim in this case death can be found on an official website here, stating that she was killed "in the morning" by a "mortar." Additional information regarding her death can be found at the official website of the MFA, here.

b.      There is a news report from 11:13 from the same day reporting the attack (here), and another news report revealing the name of the woman killed. The name was announced a short time after 12 (noon)(here).

 

Please let me know if you have any questions.

 

Best regards,

 

Tal

 

Tal Werner Kling

Department of Special International Affairs

Office of the State Attorney

Ministry of Justice

State of Israel

Office: + 972 (0)3 763 4278 | Cell: +972 (0)50 621 6203

Fax: +972 (0)2 646 7799    

TalW@justice.gov.il

 


This email is confidential and for the exclusive use of its addressee. If you are not the intended recipient, please delete this message.

 

 

 

From: Richard D. Heideman [mailto:rdheideman@hnklaw.com]
Sent: Sunday, January 15, 2017 5:29 PM
To: Roy Schondorf; Richard D. Heideman
Subject: Request for Assistance

 

Dear Roy,

 

I hope this email finds you doing well.

 

As you know, our law firm has been working to prosecute claims for victims of Hamas terrorism during the Second Intifada.  While we already have a lot of evidence of Hamas publicly taking credit for certain attacks, we are looking for additional "official" government sources which we need to present to the Court and which will help us argue Hamas responsibilty and therefore assist us in pursuing those who provide material support to Hamas.  

 

We are focused on and in need of additional information regarding two particular attacks:

 

1.  The March 7, 2002 attack in Atmona

 

We are looking for an official Israeli government announcement or report that attributes the Atzmona attack to Hamas.  

 

In addition, we are also looking for Israeli government reports that would help us establish certain facts that are contained in the video will of the perpetrator of the attack.

 

We have a translation of the video will of Muhammad Farhat, perpetrator of the Atzmona attack who takes credit for the attack as well as Hamas' public statements about the attack but we are looking for additional information that will support our position.  

 

In the will, Farhat says he is taking revenge for Prime Minister Sharon’s “massacres against our people, the last of which was the assassination of the family of the martyr hero, the warrior of Jihad, Hussein Abu Kweik, of the warrior Jihad, brother Muhannad Abu Halawah, and of their brothers in the Al-Aqsa Martrys’ Bridages.”

 

There are news reports that Kweik’s wife and 3 kids were killed in the family car on March 4, 2002.  Kweik was not in the car.  He was arrested much later, in 2011, we believe  He was senior Hamas.  Although Halawah was not Hamas, news reports say he was killed on March 5, 2002 at 7:15 p.m.  Do you know of any official government report of some kind dating Kweik's family's death and the death of Halawah that you could provide and could be used in a United States court proceeding?  The report would have to be authenticated as having come from an official government source.

 

 

2. The September 24, 2004 attack in Neve Dekalim

 

We are also looking for a government source that confirms the details in the Hamas claims of responsibility for the Neve Dekalim mortar attack which was launched from Gaza.  The details in the Hamas statement of responsibilty indicate among other things that the mortar attack occurred at exactly 10:30 a.m. on September 24, 2004 and involved the firing of three 100-mm mortar shells.  If there was an Israeli government annoucement that also confirmed these details it would be very helpful.  Again the report would have to be authenticated as having come from government records so that it could be used as evidence in our case.

 

Any assistance you could provide with locating documentation about these two attacks would be greatly appreciated.  We are in need of this information as soon as possible as we have a late January court deadline for filing same; otherwise the victims of those attacks are likely to have their claims dismissed.

 

Thanks, and

 

Best regards,

 

Richard

 

 

Richard D. Heideman

Heideman Nudelman & Kalik, PC

1146 19th Street, NW

Washington, DC 20036

Telephone: 202-463-1818

Telefax:     202-463-2999

Cell:          202-255-5700

 

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