Date : 12/11/2013 1:44:41 PM
From : "דון אבישי"
To : "Marlene Mazel" , "David Atar"
Subject : Memo Regarding the Wultz Case and Updated Procedural History
Attachment : 13218_Factual Record - Wultz v. Bank of China, Ltd FINAL.xls;Memo - Main Points of Wultz v. Bank of China FINAL.doc;

Dear Marlene and David,

Please find attached my 13-page memo about the Wultz case. The memo summarizes the most important information about the case from the State of Israel's perspective. Among other things, it covers: A) What the Plaintiffs must prove to substantiate their legal claims, B) What the Plaintiffs have established with the evidence they have gathered thus far, and C) The entire procedural history of Uzi Shaya's deposition in this case, starting in July 2011. At the end of the memo, I also added my own legal analysis of how important Shaya's testimony is for the Plaintiffs' case.

Please also find attached an updated Factual Record, which corrects a number of dates and docket numbers from the previous spreadsheet.

I look forward to discussing this with you on Sunday.

Regards,

Avishai