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—_— ‘SeoRT CASE NER me ISSACHAR SHABTAY V. URIEL LEVY CIVIL CASE COVER SHEET ADDENDUM AND STATEMENT OF LOCATION (CERTIFICATE OF GROUNDS FOR ASSIGNMENT TO COURTHOUSE LOCATION) ‘This form is required pursuant to Local Rule 2.3 In all new civil case filings in the Los Angeles Superior Court. ] Item I. Check the types of hearing and fil in the estimated length of hearing expected for this case: JURYTRIALAAES CLASSACTION? YES LIMITED CASE? YES TIMEESTIMATEDFOR TRIAL 3 _HOURS/vDAYS Item Il, Indicate the correct district and courthouse location (4 steps — If you checked “Limited Case", skip to Item Ill, Pg. 4): Step 4: After frst completing the Civil Case Cover Sheet form, find the main Civil Case Cover Sheet heading for your ‘case in the left margin below, and, to the right in Column A, the Civil Case Cover Sheet case type you selected. Step 2: Check ane Superior Court type of action in Column B below which best describes the nature ofthis case. Step 3: In Column C, circle the reason for the court locaton choice that applies tothe type of action you have checked. For any excaption to the court location, see Local Rule 2.3. Applicable Reasons for Choosing Courthouse Location (eee Column Cbeow) 1 geotools em 5 RBCS ecco tenses” Sr Rah atari wy, £ EE ee A are secre, Use Usteecssnatepeataa dems abe ees SR i HE areata 11, Mandatory Fling Location (Hub Case) ‘Step 4: Fillin the information requested on page 4 in Item'Il; complete Item IV. Sign the declaration. A 8 T rire Ci ase Cove shat Typect Aeon aan Sen Sp 3 aap No Sono) ‘ore ‘io @2) © ATHO0 sor Veie-PenoalnunyPrepetyDanapeongtuDeat | 1.2.4 SE vineueamaora as) | A7110 PenonalinunyPepet Danagattonsh Death Unreueamotist [1.24 1A Ashes Propry Danae 2 ‘Asbestos (04) 1 A7221 Aatetos-Peronalibyfngt Death a z iE Peauuabay a) [El A7200 Pred by (ot anes or ioelontonmenta 12.848 £3 aR ES i BS | mmccamanecn 8) | gr Ober Prien eth Cr Mapacca 06 3 gf © ATH Prin Ly 9 a 7 a5 er Perea! : sf eee ‘gosaut,vandafiom, a) AWA. ga Deu) | A72TO Inrtonal icon of Enotonal sss 13 @ 7220 Other Personal njun/Property DamagelWronghul Death 14. eater aes ———— ecw 08 Reva) CIVIL CASE COVER SHEET ADDENDUM Tocal Rule 23 LASC Approved 03-04 AND STATEMENT OF LOCATION Page 1 of 4 nT: ISSACHAR SHABTAY V. URIEL LEVY A B C Applcabie Civ Case Cover Sheet Type of Acton Reason Soe Stop 9 (Category No. (Check only one) ‘Above Business Tort (07) D A6029 Other Commercial/Business Tort (not fraud/breach of contract) 1.3. z Civil Rights (08) (D_A6005 Civil Rights/Discrimination 1.2.3. Eg | scons enone rr & =f ‘Fraud (16) 1 A6013 Fraud (no contract) ay 2a 3. = 1D AGOI7 Legal Malpractice Professional Negligence (25) aa 1D. 8050 Other Professional Mlpacie (not medica or legal) 142.3 otter (35) 'B.A8025 Other Non-PersonalrjuryPropery Damage tort 23. | Wont Termination 26) | 0 A60S7 Wrongil Termination 1,2,8 1D S024 Other Employment Complaint Case 2.3. B | onwtnomat v8 z 1D. AS109_ Labor Commissioner Appeals 10 TD AG0D4 Broach of RenalLease Contec (ntunlawl desir orwrongtl | >. cevaton) 2 or cane! Waren | 5) qso08 ConraciWaranty Breach Sell Pan (0 faudnenigenes) oe (rotinsurance) 1B AG019.Negigent Breach of ContectWarranty (no fraud) mere 1G A6028 Other Breach of Contrac/Warranty (no fraud or negligence) oe z {1 A002 Collections Caso Salle Pint 25.611 z Cateters (2) | pgot2 otter Promisor NowColectons Case zen oi (D_ A6034 Collections Case-Purchased Debt (Charged Off Consumer Debt 5.6.11 Purchased on or ae lary 1, 2014) Insurance Coverage (18) | ABOIS Insurance Coverage ot complex) 1.2,548 1 A600 Contractual Fraud 1.2.3.8 Otter Contact(s?) | A6031.Tortousitreroncs 4.2.3.8. 1 A6027 Other Coniract Dspue(rat breechinsurencaraudnegigence) 4,2.968 = Enron Donavon 5 " fase [a AW EnintDonantondennsion — Nunberefpwon | 2 Wrong Evicion (3) | 2 6023 Wrongful Evctlon Caso 2.8. i 1 ABO18 Morgage Foreclosure 2.8 ‘otner Real Property (26) | ABIS2 Guet Tite 2.6 1B. A2060 Other Real Property (not eminent domain, landordAenant forecosure) | 2.6. |g | twetbeinarcoret | paca Unt Deane Commer ot so wnat ven) 2.8 3 Unit Deir Rene |-potz0 Un Det ser ror wort evn) 2.8 Usted Deane. Post Foreclosure [eerie ‘Uniaw Delaner Drugs (28) | C A602 Unlawful Detainer Drugs 28 ee _________ CIVIL CASE COVER SHEET ADDENDUM Local Rule 2.3 LAGIV 109 (Rev 315) LASC Approved 03-04 (AND STATEMENT OF LOCATION Page 2 of 4 Tae mai S°™E ISSACHAR SHABTAY V. URIEL LEVY ae A B Cs Case Cover Shut Donat hcton eon ee Se Category No. (Check ery oe) Asset Forfeiture (05) D_ A6108 Asset Forfeiture Case: at 3 Petition re Arbitration (11) | Q A6115_ Petition to Compel/Confirm/Vacate Arbitration 2,5. é 1D AB151 Wit- Administrative Mandamus 2.8 3 \Writof Mendate (02) | A6182 Wat- Mandamus on Limited Court Case Mattor 2 3 1D. AGtS9 Wit-OfrLinted Court Cate Reviow 2 (Other dual Review (99) [1 ASIEO Ober Wit dl Review 2.8 ‘ara Tree Repaton (3) | A009 Antrtrade Reguston 12,8 i coorsamomatey [5 AAT Grane Doe waa Cains netyra tae Tot | B00 ciara hing Mas Tot 1.208 i ‘Secures Ligation (28) | C2 ABIRS Secures Lsgaton Case 1.2.8 3 = Toxic Tort Toxic prime 1.2348. i ee ee TraranceGovorge Cans = trogaton(complexcase 4.2.5.8 E | rermezcmmageciins | sot inarance CoverpeSiroatonconplexcae on) ASIA Sater State Jogment ae 12 ABt60 Abotct of udgment i —— 12. A607 Confesion cf Jodoment nondomestcreaons) i et esament(2) |) AB140_Adminiaive Agony Ava (rt uni es) 22 1 ABA Patton Eat dgmerton UpaT 13. ASH2 Other Enreement of Jgment Case RIGO @) TD AGO5S Rackotorng (RICO) Case e? el Ae Dosa al Ory a BF | cnwcumgans | AOD ce Rte On onchamenrt 28 FS | ovaSpmctaa hoor) 2) | cs poor cer Conner Compan Cas (nr atnar compet) 12.8 23 A000 ter Ci Compa romodno-complen) 2.8 Pn O) A6113 Partnership and Corporate Governance Case 2,8. 1 ABI21 Ci Harassment 2.3.8 i O A6123 Workplace Harassment 2.3.9 a ye ‘Ab124 ElderDependent Adit Abuse Case 2.3.9 sf Specified Above) (43) | C1 A6190 Election Contest 2 23 13. ABt10 Pelion or Change of Name 27. 1D. ASI70 Pelton for Rete rom Late Cia Low 2.3.4.8 S100 Otter Cv Patton aa Tae 100 fev a6) CIVIL CASE COVER SHEET ADDENDUM Local Rule 23 LASC Approved 0-04 ‘AND STATEMENT OF LOCATION Page 3 of 0 S_cY ee L Pr ISSACHAR SHABTAY V. URIEL LEVY “AoORE SS REASON; Check the appropriate boxes for the numbers shown |2010 W AVE K LANCATER CA 93536 [11.02.83.04.05.06.07.081 80100 11 stare | zp cove: ILANCASTER ca bart ee wit ea] Item IV. Deciaration of Assignment: | deciare under ‘Penalty of perjury under the laws of the State of California that the foregoing is true and correct and that the above-entitled matter is Property filed for assignment to the ANCASTER CouRTHOUSE courthouse in the LOS ANGELES COUNTY _Djstrit of the Superior Court of California, County of Los Angeles [Code Civ. Proc., § 392 et seq, and Local Rule 2.3, subd.(a). Dated: 10/15/2015 somkruns BTFLNGPART) ——\ PLEASE HAVE THE FOLLOWING ITEMS COMPLETED AND READY TO BE FILED IN ORDER TO PROPERLY COMMENCE YOUR NEW COURT CASE: 1. Original Complaint or Petition. 2. If fling a Complaint, a completed Summons form for issuance by the Clerk. 3. Civil Case Cover Sheet, Judicial Council form CM-010, 4 Gari Sase Cover Sheet Addendum and Statement of Location form, LACIV 109, LASC Approved 03-04 (Rev. 03/15). 5. Payment in full of the filing fee, unless fees have been waived. 6. gned order appointing the Guardian ad Litem, Judicial Couneil form CIV-010, if the plaintiff or petoneris a minor under 18 years of age will b e required by Court in order to issue a summons. 7. Additional copies of documents to be conformed by the Clerk. Copies of the cover sheet and this addendum must be served along with the summ jons and complaint, or other initiating pleading in the case. TACIV 109 (Rev 3716) CIVIL CASE COVER SHEET ADDENDUM Local Rule 2.3 LASC Approved 03.04 AND STATEMENT OF LOCATION Page 4 of 4 “ 1s 16 ” 18 19 20 a 2 n ISSACHAR SHABTAY, PLAINTIFF 4833 Morella Ave Valley Village, CA 91607 (818) 980-2628 or initial filing purposes counsel to be assigned SUPERIOR COURT OF THE STATE OF CALIFORNIA. COUNTY OF LOS ANGELES ISSACHAR SHABTAY; and Case No.: ISSACHAR SHABTAY ON BEHALF OF YOSEF CHAIM TEMPLE Phaintifs PLAINTIFF ISSACHAR SHABTAY’S - VERIFIED COMPLAINT FOR ‘URIEL LEVY; and CONVERSION, FRAUD, BREACH OF URIEL LEVY AS TRUSTEE FOR iE CONTRACT, INTENTIONAL INFLICTION Yost CHAIM SYNAGOGU SPENT Defendants FINANCIAL ELDER ABUSE [UNLIMITED CIVIL] JURY TRIAL Plaintiff Issachar Shabtay alleges as follows: PRELIMINARY ALLEGATIONS 1. Atall times mentioned herein, Plaintiff Issachar Shabtay (or “Issy”) ‘was a natural person over the age of 65 years. VERIFIED COMPLAINT 1 2 B m a 8 2. tall times mentioned herein, Plaintiff's appearance was such that it would be plainly apparent to a reasonable person that Plaintiff was over 65 years of age. 3. At all times mentioned herein, Defendant Uriel Levy (or “Levy”) was a natural person over the age of 18 years, and a resident of Los Angeles County. 4. The true names and capacities of defendants sued as Does are unknown, and plaintiff will amend this complaint to show their true names and capacities when this information is ascertained. Each Doe defendant is in some manner responsible for the damages alleged pursuant to each cause of action asserted, either through its own conduct, or vicariously through the conduct of others. All further references in this complaint to any of the named defendants, or to defendants generally, shall include such fictitiously named defendants. 5. Onor about sometime in 1980, Issy founded the Yosef Chaim ‘Synagogue, duly named in honor of his deceased brother, Yosef Chaim. 6. From the time of its inception in 1980, Issy maintained sole ownership of his synagogue, as well as the positions of sole Director of Operations for Services and Rabbinical Lead Cantor. 7. Onor about sometime in 1986, Issy purchased the property located at 11754 Riverside Drive, Valley Village, California for approximately $250,000. 8. Subsequent to the purchase of the property located at 11754 Riverside Drive, Valley Village, California, Issy converted the property into a synagogue, pursuant to its zoning at an approximate additional cost of $100,000. plus additional build out and improvement expenses. Issy then transferred all operations and most of his present synagogue contents of the Yosef Chaim ‘Synagogue that remain there to this day to the Riverside Drive location. 9. Issy a major motions pictures studio manager then paid all mortgage payments, insurances, property taxes from his personal funds for the Riverside ‘VERIFIED COMPLAINT 2 25 6 2 Drive property and the majority of all utilities, upkeep, food, festivities and incidentals for all synagogues operations. On or about sometime in 1994, due toa series of events, which included the destruction of his personal residence due to catastrophic damage from the Northridge Earthquake, the death of his father and his own major bought with cancer, Issy informed the Yosef Chaim Synagogue ‘Congregation that he would no longer be able to carry the majority entire burden of making the mortgage payments from his own personal funds. 10. On or about sometime in 1996, the Yosef Chaim Synagogue property was subject to foreclosure. The balance owed on the property at that time was. approximately$160,000. from the original $250,000. purchase price, exclusive of the approximate $400,000 Issy invested into the property itself, as well as the approximate $200,000 he invested in its contents. 11. At the time of the foreclosure sale and auction of the property located at 11754 Riverside Drive, Valley Village, California, Issy raised approximately $30,000. towards the re-purchase of the property, while congregation members and synagogue attendees had raised approximately an additional $30,000. In order to complete the purchase of the property, an approximate additional $100,000. was required by the foreclosure trustee, as the total sale price was $160,000. plus closing costs. 12. At this point in time Defendant Levy, who was an occasional synagogue attendee, stated to Issy and the congregation that he had a “friend” who might consider assisting by obtaining a loan for the necessary balance to complete the purchase until such time Issy and or synagogue congregation members would repay the loan. Levy explained that his friend Yoram Fishman (or “Fishman”), a secular businessman, would complete the loan as a “mitzvah” or charitable endeavor, and also stated they would benefit from the Potential tax write off for assisting a non-profit religious entity. Levy was then given the funds raised by Issy and the congregation to negotiate the buy back of the Synagogue land from the VERIFIED COMPLAINT 3 foreclosure trustee. Levy was personally handed funds by founding Yosef Chaim Synagogue members such as Zvika Yehuda and others (Declaration of Zvika "Yehuda is incorporated herein and attached to this complaint as Exhibit-A) and thousands more by Issy and others. 13. On May 18, 1996 Fishman agreed to provide the remaining $100,000. in funds needed to complete the re-purchase from the foreclosure trustee. As part of this agreement coordinated by Levy, Fishman would hold the note for the loan in the form of a Grant Deed, with an absolute promise to re-convey the property to Issy and the non-profit Yosef Chaim Synagogue upon repayment of the $100,000 obtained from Fishman’s bank line of credit. Fishman completed the loan for Issy and his Yosef Chaim Synagogue, and Levy saw to it that he was placed on Grant Deed to the synagogue land as a trustee. Soon after, Levy on behalf of he and Fishman requested of Izzy that both their names be added to the synagogue’s existing corporation and corporate bank accounts as officers, stating that it would make things much easier to have all monies deposited there so payments for the mortgage could should be paid from that account. 14. Onor about sometime in 1997, approximately ten-years after its Yosef Chaim's original corporate formation by Issy Shabtay ; Levy and Fishman were added as officers to the Yosef Chaim Temple Synagogue Corporation and its Accounts. All funds deposited into the account were either Issy’s personal funds and or raised by Issy from friends, donors, attendees and congregation members. Issy additionally continued to see that all payments were made for expenses, up- keep, renovations, incidentals, and taxes. 15. Subsequent to the May 18, 1996 loan from Fishman as coordinated by Levy, Issy made all monthly mortgage payments to the account from his own personal funds based on the repayment of the $100,000 loan. The same account ‘VERIFIED COMPLAINT 4 that Levy and Fishman asked to be previously added to. Issy also paid for the majority of all operations, expenses, upkeep and build out of the Yosef Chaim Synagogue from his own personal funds. Levy and would attend synagogue only one or two days a year on Yom Kippur the highest of Jewish Holidays accompanied usually by Fishman. 16. During the period of time from on or about June 1996 to sometime on or about late December 2006, and with the full knowledge of Levy, Issy contacted Fishman’s personal assistant and bookkeeper, Gladyse Trosden, (or “Trosden”) on a regular basis to obtain the current loan balance and conduct synagogue accounting business. Upon every contact and inquiry with Trosden she would state that the remaining loan balance was approximately $100,000. and everything was current. 17. Onor about sometime in late 2007, Issy first contacted Levy and then Fishman and wanted to personally pay off the then remaining balance of the loan from his own personal funds for subsequent re-conveyance to the non-profit Yosef Chaim Synagogue. They refused to accept payment from Issy or let Issy pay off the loan for subsequent reconveyance, stating that they would see to it that the small remaining balance would be taken care of, on the condition Issy not to change the way things presently stood, because it was a organized and a very convenient and advantageous tax write off and they wanted things to remain the way they are for the time being. Further stating, not to ever worry; as you are aware Issy we are much more interested and concerned with the synagogue non profit tax status advantages, then we are with the synagogue itself, it will always be yours Issy, everyone knows its Issy's Yosef Chaim Synagogue founded by you and named after your brother. You continue to keep operating at your property and synagogue as usual and let us handle the concern for the small remaining balance at the time being. It was at this time Issy's home of nearly 40 years a block away VERIMED CUMPLAINL $ 26 21 28 from his synagogue suffered a catastrophic fire and Issy was dealing with its rehabilitation and related issues that carried on for some time. 18. On or about sometime in September 2014 during the Jewish Holidays, Issy was visiting his son in Israel who had just had a new born baby. It was the first and only time since Issy found the synagogue some 35 years earlier that he had not been at his synagogue during the high holidays in order to conduct services and oversee all operations. While Issy was in Israel, Alon Elias, (or “Elias”) a self- proclaimed rabbi and Israeli citizen was on a visit to Southern California, and the Valley Village area. Levy and Fishman asked Elias to conduct services at the Yosef Chaim Synagogue during the holidays in Issy’s absence. Fishman concurred with Levy's request for Elias to conduct holiday services. All proceeds from the holiday season contributed by the congregation or received by any means in cash form or check were taken in by Levy and Fishman who then took all synagogue proceeds and did as they chose and also subsequently made undeclared large cash payment arrangements with Elias. 19. Onor about sometime in December 2014, Issy discovered that with full knowledge , encouragement and assistance from Levy, Fishman had at one point on or around December 1996 unbenounced to Issy or his congregation members that had previously given them funds and entrusted them, refinanced the property for not $100,000. but $128,000. and obtained a new loan and better interest rate. 20. Also on or about sometime in December 2014 Issy discovered that with Levy and Fishman had at one point unbenounced to Issy or the congregation, refinanced the property with a new loan of nearly $500,000. against the Yosef ‘Chaim Synagogue land on or about sometime in March 2006, and had been apparently using the loan proceeds for personal use. They had now encumbered Issy Synagogue with not a small loan remaining under $100,000 that had been entrusted to them and nearly paid off , but instead with nearly $500,000. in additional new debt for their sole personal benefit. Secretly hiding their unethical behavior and indiscretion by keeping the VERIFIED COMPLAINT 6 B Fy 2s 26 loan from Issy and the congregation. Using the funds for personal gain and simply paying its interest payments for the new loan they had discreetly taken to their sole benefit. Any and all loan transactions were completed with the full knowledge of and assistance of Levy who was still and at all times since their involvement in synagogue business saw to it that he was listed as a trustee on the Deed. Since recently discovered all requests and demands by Issy for full disclosure and accounting records for these indiscretions and unethical actions have been ignored or turned down. 21. Levy and Fishman continued their befriending of Elias and developed an ongoing relationship with him. On or about sometime in early 2015, Fishman subsequently traveled to Israel and visited with Elias, further cementing their relationship. Sometime later subsequent to Issy's return from a short trip around the same time, unbenounced to Issy until most recent, Levy and Fishman had sent communications to community members and congregation alike informing them ‘that from now on and during the upcoming holidays any and all contributions as to the synagogue were to be sent to them exclusively. 22. Onor about sometime in early 2015, Levy assisted Fishman in coordinating the purchase of a distressed single residence directly to the rear of Yosef Chaim Synagogue, located at 11751 Blix Street, Valley Village, California and subsequently without Issy permission removed the fence which divides the two properties. 23. On or about sometime in July 2015, Levy and Fishman invited Elias back to conduct services at Yosef Chaim Synagogue for the holidays despite Issy’s adamant objections. 24. Upon information and belief Alon Elias is not an ordained rabbi and there is no record of his status as a rabbi anywhere in Israel or the United States. (Declarations of Avraham Dyan and Sara Cohen are incorporated herein and VERIFIED COMPLAINT 7 attached to this complaint as Exhibits B & C respectively). Upon belief that Elias a fraud, was a conspirator in siphoning off undeclared large sums of synagogue congregation raised funds. Issy also heard thru others Elias was working with Levy and Fishman in attempt to take Issy's synagogue from him and get his hand on holiday funds on 2015 like he had done in the previous year in Issy's absence. 25. On July 22, 2015, Issy arrived at the Yosef Chaim Synagogue for morning services and observed that Elias was present at the location. Under the direction of Levy and Fishman, Elias physically pushed and attacked Issy. Elias then threatened Issy with further physical harm if he did not leave the synagogue. Issy, in fear for his physical safety and well being left the synagogue extremely emotionally distraught and shaken. 26. Onor about July 22, 2015, Issy, after leaving the synagogue telephoned Levy and Fishman to discuss the physical assault committed upon him by Elias. During Issy’s conversations with Levy and Fishman, he was dismayed that they were completely supportive of Alon's actions and indifferent to him and indeed were attempting to take from him the Yosef Chaim Synagogue that he (Issy) founded and operated for 35 years, stating he was no longer needed at his synagogue. Issy then spoke to Yosi Kachlon and other synagogue attendees who informed him that Levy and Fishman had been conspiring for some time now, and furthermore more certain and decisively since September 2014 with Elias, while Issy had been away in Israel to attempt to take his synagogue from him. 27. Shortly after the July 22, 2015 incident, Levy and Fishman arranged for Elias and other individuals to physically start residing at the synagogue to provide and ensure for them that Issy would be denied all access. 28. Asa result of the physical assault by Elias and subsequent actions supported by Levy in moving Elias into the synagogue, learning of Levy's and Fishman's indestrections, Issy suffered extreme emotional distress and was ‘VERIFIED COMPLAINT 8 Prescribed that he need relax and rest, perhaps take a trip, travel, so Issy opted to visit relatives in Israel for a few weeks on or about sometime in late July 2015 under prescribed orders. 29. On or about sometime in August 2015, while in Israel, Issy and his family were the subject of continued stalking and harassment by individuals associated with Levy and Fishman, who further relayed to Issy through various forms that he is no longer allowed to enter his synagogue. (Israeli Police Report is incorporated herein and attached to this complaint as Exhibit D) As a result of these aforementioned unrelenting continued actions Issy suffered a very severe and near fatal heart attack. (Declaration of Doctor Victor Rosenfield is incorporated herein and attached to this complaint as and Israel Medical Center & Hospital Reports Exhibit-E). Shabtay's son stated Doctor Rosenberg cardiologist ICU, came out of ICU stating, "I am sorry it doesn’t look good, I don’t think he is going to make ites 30. On or about sometime in August 2015, while Issy was hospitalized on a respirator after suffering a heart attack, Issy continued to be stalked and harassed, while hospitalized in the Intensive Care Unit (ICU). While in ICU Levy and Fishman informed Issy that they decided to change the name of Issy's synagogue of 35 years and that he was no longer welcome at the location. Issy was then further informed by Fishman and other individuals that Elias and two other individuals were now residing at the synagogue and that under threat of physical harm, Issy ‘VERIFIED COMPLAINT could no longer enter the location to retrieve even his belongings or the contents of his synagogue. Levy and Fishman then removed the sign bearing the name of the Yosef Chaim Synagogue which had been at the location for the previous thirty- years. When Issy was informed of this he went into cardiac arrest 31. On or about sometime in August 2015 Issy found that he could not enter or go near the synagogue due to the enormous amount of emotional stress and physical harm that could and would be exerted on him by Fishman, Levy and or individuals operating on their behalf . They would not even let Issy get his smaller very personal belongs out of the synagogue. Not to mention Issy had just most recently on or about May 2015 put on temporary display his model of The Great Temple of Jerusalem made of real Jerusalem Stone that took him over seven years to construct by hand and tens of thousands of dollars. Levy and Fishman had now decided to hold it as leverage with all of Issy's other synagogue contents in the hopes of knowing how valuable it is to Issy, that they would let him get it, if he promised to give-up and release to them all interest in his synagogue. 32. Levy and Fishman had never in over the previous decade spent a cent of their personal money buying or doing anything for the synagogue; no contents of any sort and not paying or doing improvements of any sort to the benefit of the synagogue. Most recently they purchased the distressed house to the immediate rear of Issy's Riverside Synagogue Property. This other property which is 11751 Blix Street Valley Village on or about mid 2015 and they then tore down the fence separating the two properties without Issy's approval then did some inexpensive interior painting at Issy's 11754 Riverside Synagogue. All and anything they are doing is unnecessary and simply being done in attempt to hide or cloud their previous indiscretions in attempt to show a new found sudden interest or concern for the synagogue when it had never previously been there before. 33. Onor about sometime in August 2015, Levy and Fishman sent Issy a “No Trespassing Letter” stating that he, Issy, was no longer allowed at the synagogue which he had founded and operated for a period over thirty-five years. 10 ‘They also changed all the locks interior and exterior to the entire synagogue grounds and refused to provide Issy keys. It was relayed to Issy by a synagogue attendee contractor that works with Levy and Fishman that they have been planning to demolish the synagogue property at 11754 Riverside and attempt to develop it in commercial use, condo or apartment use. This had never been Previously relayed to Issy by Levy or Fishman who had previously unethically secretly refinanced $500,000 out of the synagogue land without authorization 34. On or about August 2015 Issy still not fully recooperated from his recent near fatal heart attack, Issy had his son communicate with Fishman and copied to Levy a formal Cease and Desist that nothing at the synagogue is to be touched by them, fore Issy's fears of their conversion of destruction of his personal property and his synagogue contents. It was relayed to Issy that if he attempts to come near the synagogue they will destroy his personal belongings and or parts of the synagogue in attempts to emotionally cause Issy further intentional emotional distress. The contents that are all nearly ; ninety-nine percent (99.0%)personally owned by Issy and anything in the interior or surrounding exterior structure of the synagogue itself. Fishman with full approval and support of Levy ‘on or about mid September 2015; had Rudy , Fishman's contractor weld the front gate entrance to the Riverside Synagogue Property shut to further hinder accessibility for Issy and they simply ignored the Cease and Desist , leaving the only access from the rear property at Fishman's newly purchased distressed property that sits to the rear of the synagogue, 11751 Blix Street. 35. On or about September 2015 just prior to The High Holidays, Fishman with full knowledge and support of Levy saw to it then to go as far as to even weld the gates (the gates Issy initially installed with his own funds) to the front entrance of the synagogue courtyard to ensure Issy or anyone "unapproved by them" could not enter and to ensure Issy could not get any of his contents. Leaving the only access from the newly purchased house of to the rear of the synagogue 11751 Blix Street , where they have the Israeli individuals living that are there to keep Issy away. Los Angeles Police Dept had been informed of this behavior and tried to assist Issy, but the welded gates also kept them out. 36. Fishman with support of Levy further suddenly on or about September 2015 just prior to the holidays starting installed a new sign with a new synagogue name without any concern for the fact that it is still Issy's VERIFIED COMPLAINT n 1 || Synagogue that he owned, funded, built and operated for 35 years and all his 2 ||SYBagogue contents were still there. Then Fishman informed synagogue and 3 || Community attendees and congregation whoever had not left or been scared off by « ||them yet. That if anyone is in support of Issy or supportively discussing or brings up Issy's name in a positive fashion or light they will no longer be able to access 5 ||the synagogue. (Rev Grimberg ) 7 37. On or about September 2015 The Jewish High Holidays Issy an orthodox Jew, who does not drive on the holidays or sabbaths, for the first time in 35 years since the founding of his synagogue had to do the high holidays at home alone without even the benefit of his own prayer books or belongings. While Levy and Fishman and those on their behalf sat and enjoyed the holidays in Issy's Synagogue, that Issy solely worked so hard to build and develop over three decades 4 38. On or about sometime in July 2015 thru September 2015, Yehudah 15 || Anconina, (or “Aconina”) an individual with violent tendencies who mercilessly 16 || beat his wife, and thus recently divorced; Levy and Fishman housed at 17 || the synagogue, sent a series of emails and text messages to Issy stating that “They 18 |] will burn down Issy’s house.” Subsequently Aconina and other individuals at the 19 || direction of Levy and Fishman threatened Issy’s family members in Los Angeles 29 [and Israel. (Police Report, Emails and texts are incorporated herein and attached to this complaint as Exhibit-F) 39. _ Issy was granted a temporary restraining order against Aconina on September 18, 2015. (Copy of TRO is incorporated herein and attached to this complaint as Exhibit-G). 40. On or about mid September 2015 , Rudy the contractor of Levy and 2 || Fishman , under Levy and Fishman's orders and in complete opposition to Issy's 2s || wishes and Cease and Desist, demolished the beautiful custom marble and granite $25,000. driveway Issy previously designed, paid for and installed at his Riverside Synagogue Property and they had the granite and marble replaced with cheap 2B ™ a 28 ‘VERIFIED COMPLAINT R a te compressed sand. When Issy heard this he had a breathing attack and fainted at his ome FIRST CAUSE OF ACTION-CONVERSION 41. Plaintiff realleges and incorporates by reference each and every allegation of paragraphs 1-40 inclusive. 42. _Issy owned and possessed numerous items of valuable property which comprise the total contents of Yosef Chaim Synagogue. (Itemized list of property incorporated herein and attached to this complaint as Exhibit H). 43. Levy intentionally interfered with Issy’s property by taking possession] of the property as noted in Exhibit “H” incorporated herein and attached to this complaint, and; by preventing Issy from having access to the property as noted in Exhibit “H” incorporated herein and attached to this complaint, and; by refusing to return the property as noted in Exhibit “HH” incorporated herein and attached to this complaint despite Issy’s repeated demands to do so. 44, _ Issy did not consent to Levy taking possession of, or preventing access to his property as noted in Exhibit “H” incorporated herein and attached to this complaint; 45. _Issy was harmed by Levy’s actions; and 46. _Levy’s conduct was a substantial factor in causing Issy’s harm. SECOND CAUSE OF ACTION-FINANCIAL ELDER ABUSE Welfare and Institutions Code section 15610.30 et seq VERIFIED COMPLAINT B 2 2 2 25 6 n 28 47. _ Plaintiff realleges and incorporates by reference each and every allegation of paragraphs 1-23, 33-40 inclusive. 48. Defendant Levy assisted in appropriating and retaining Plaintiff Izzy’s property. 49. Plaintiff Issy was 65 years of age or older at the time of Defendant Levy’s conduct. 50. Defendant Levy assisted in appropriating and retaining Plaintiff Izzy’s| property with the intent to defraud. 51. Plaintiff Issy was harmed; and. 52. Defendant Levy’s conduct was a substantial factor in causing Plaintiff} Izzy’s harm. 53. Plaintiff Issy had the right to have the property made readily available to him; and 54. Defendant Levy knew or should have known that Plaintiff Issy has this right. THIRD CAUSE OF ACTION-FRAUD Civil Code Sections 1572, 1709 et seq. 55. Plaintiff realleges and incorporates by reference each and every allegation of paragraphs 1-23, 33-40, and 39-46 inclusive. 56. Defendant Levy represented to Plaintiff Issy that the loan obtained from Fishman for the purpose of re-purchase of the Yosef Chaim Synagogue from the foreclosure trustee was in fact a “mitzvah” or good deed, and that the Grant Deed issued to Fishman as security for the loan naming Defendant Levy as VERIFIED COMPLAINT “4 27 28 trustee would be immediately re-conveyed to the Yosef Chaim Synagogue, owned by Plaintiff Issy, upon repayment. 57. Defendant Levy’s representation was false. 58. Defendant Levy knew that the representation was false when he made it to Plaintiff Issy. 59. Defendant Issy intended that Plaintiff Issy rely on the representation. 60. Plaintiff Izzy reasonably relied on Defendant Levy’s representation. 61. Plaintiff Issy was harmed; and 62. Plaintiff Issy’s reliance on Defendant Levy’s representation was a substantial factor in causing his harm. FOURTH CAUSE OF ACTION-BREACH OF CONTRACT Civil Code Section 1549 et seq. 63. Plaintiff realleges and incorporates by reference each and every allegation of paragraphs 1-23, 33-38, 39-46, and 47-62 inclusive. 64, Plaintiff Izzy and Defendant Levy entered into a contract for the negotiation of re-purchase terms of the Yosef Chaim Synagogue from the foreclosure trustee and coordination of a loan from Fishman for the balance owed, with re-conveyance to Yosef Chaim Synagogue and Plaintiff Issy as owner upon repayment; 65, Plaintiff Issy did all of the things that contract required him to do; 66. All conditions required by the contract for Levy’s performance had occurred; ‘VERIFIED COMPLAINT 1 67. Defendant Levy, named on Grant Deed as land trustee for Fishman, 2 || failed to facilitate the re-conveyance of the Grant Deed to Yosef ‘Chaim Synagogue| 3 ||and Plaintiff Issy as owner upon successful repayment of the loan. 4 68. Plaintiff Issy was harmed by Defendant Levy’s failure to act. s FIFTH CAUSE OF ACTION- 6 INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS 69. Defendant Levy’s conduct was outrageous in preventing Plaintiff Issy from; entering, remaining on the property, or attending worship services in the synagogue he founded 35-years ago and informing Plaintiff Issy while in a hospital Intensive Care Unit recovering from a heart attack, that Defendant Levy had changed the name of the Yosef Chaim Synagogue. 0 70. Defendant Levy intended to cause Plaintiff Issy emotional distress; 1“ 71. Plaintiff Issy suffered severe emotional distress; and 1s 72. Defendant Levy’s conduct was a substantial factor in causing Plaintiff| Issy’s severe emotional distress. WHEREFORE, Plaintiff prays for damages against defendant as follows: ee 1. Conversion: FA a. Compensatory damages according to proof; 2 b. Punitive damages according to proof; 23 . c. Reasonable attomney’s fees and costs according to proof; 25 2. Financial Elder Abuse: 26 a. Compensatory damages according to proof; a fa b. Punitive damages according to proof, VERIFIED COMPLAINT 16 2 2 2 25 26 a 28 c. Reasonable attorney’s fees and costs according to proof. 3. Fraud: a. Compensatory damages according to proof; b. Punitive damages according to proof. 4. Breach of Contract: a. Compensatory damages according to proof. 5. Intentional Infliction of Emotional Distress: a. Compensatory damages according to proof; b. Punitive damages according to proof. 6. As to all causes of action: a. Treble damages pursuant to California Civil Code Section 3345; b. Interest pursuant to California Civil Code Section 3287; c. Costs pursuant to California Civil Code Section 1032; and 7. For other relief as follows: a. The synagogue to be placed in non-profit Yosef Chaim Temple; b. With new named trustees; c. Issy Shabtay, and unrelated trust attorney, an unrelated CPA, and three or four _personally named trustees to be decided 8. For such further relief as the court may deem just. ‘VERIFIED COMPLAINT "7 10 u 20 2 2B m4 2s 6 8 Dated: October_(_,2015 Issachar Shabtay, Plaintiff Pro Per (fr initial filing purposes co ‘VERIFIED COMPLAINT 18 10 2 ” 18 19 20 2 2B 4 6 a 8 VERIFICATION am the Plaintiff in this proceeding and have read this Complaint. I declare under penalty| of perjury under the laws of the State of California that this Complaint is true and correct. ‘VERIFIED COMPLAINT 19 'ssachar Shabtay Synagogue Contents Initial List Plaintiff Reserves Right to Amend Shabtay Contents Presently Located at His Synagogue; 11754 Riverside Drive Valley Village CA 91607 QRON = o 1 8. OF 10. i 12. - Model of Old Temple of Jerusalem (Built at Shabtay Personal Home and recently put on display at Synagogue)photograph Ex 1.1 . Plexi Glass Chair of Elijah The Prophet Bris Milah Chair . Plexi Glass Personal Podium Issy Shabtay . Shoffar - Rams Horn Large . Various Books Numbered and Volumes aprox 200 in quantity see photograph 1 . Various Books Numbered and Volumes aprox 251 in quantity prayer books see photograph 2.0 Torah Scroll housed in wood light bamboo with dark Star of David see photograph 5.0 Marble Tables see Photograph 2.4 Cantors Podium with Blue Star of David see photograph 2.1 Dolphin WaterFall Large Marble Menorah 1 Wood Menorah 2 ****Plaintiff will seek to amend this list as needed 16 "7 19 20 a 2 2 25 2 ‘VERIFIED COMPLAINT 20 EXHIBITS ‘VERIFIED COMPLAINT a EXHIBIT A EXHIBIT A awn Koncept anon 10 12 13 4 15 16 7 18 19 20 21 22 23 24 25 26 27 28 30 31 32 be 1Zvi Yehuda, declare as follows: = My name is Zvi Yehuda. Lam over the age of 18 and a reside curently reside in Israel . I now retired previously ‘owned a gas and service station in Beverly Hills and service stations throughout The San Femando Valley in California. If called to testify I will and could testify to the following, Tam one of the founding members of Issachar Shabtay’s Yosef Chaim Temple located at 11754 Riverside Drive Valley Village CA 91607. The Synagogue, its land and all its contents are owned by Issy Shabtay “Yosef Chaim ‘Temple or Synagogue founded 1980 by Issy and solely operated ever since by him. was an intricate part in assisting Issy and can say without a doubt he is one of the finest of character indivi uals ‘One can ever pray to meet or know. Issy found the synagogue on the sole purpose of bettering our community and Seeing to it we all had a place for services and our families for services, Sabbaths and Holidays. ‘When Issy got sick in 1996 he asked for the first and only time if possible we assist in contributing to save his ‘Synagogue from foreclosure. I and my partner Eddie and many others felt enriched to do so, because Issy had done ‘so much for us all over the previous 15 years. Even buying, carrying ,and founding the synagogue himself and never] asking anyone for anything in return as attendees of the synagogue. Issy is a very modest, humble and good man. and my partner Eddie Heskia personally handed Uriel Levy nearly $5,000 dollars in mid 1996 . Levy was to be our] synagogue land trustee and I believe the Treasurer or secretary of Issy Shabtay’s Yosef Chaim Temple. We along ‘ith Issy and others handed this money to Uriel Levy in order to negotiate for Issy’s Yosef Chaim Synagogue ate $100,000 needed after the money we supplied was a loan taken out by Uriel Levy and Fishman at the time one behalf of the «a negotiated buy back at time of foreclosure of the synagogue land. The balance of appro. synagogue. Once this amount was paid back they swore they would transfer it back to Issy and Yosef Chaim Synagogue. Uriel said they were doing this as a mitzvah to help Issy and his synagogue. I do not recall if Uriel Levy] hhimself put in any personal funds, but I am most certain he was in god faith handed tens of thousands from Issy and us. At 1 of saving the property from foreclosure I am most certain that this Fishman gentleman from what I recall just was facilitating the approximate $100,000 remaining balance needed. 1 Zvi Yehudah declare under the laws of the United States that the foregoing is all true and correct and when called to testify and would and could testify to all the above under penalty of perjury. I executed this Declaration in The US Embassy in Tel Aviv, Israel this 8 of October 2015, Zvi Yehudah EXHIBIT B EXHIBIT B DECLARATION OF SARA COHEN T'Sara Cohen, declare as follows: My name is Sara Cohen. I am over the age of 18 and a resident of Los Angeles County, CA. I am{ very fluent in both Hebrew and English and am employed as a personal assistant. I was asked to call and contact all governing branches of The Rabbinate in Jerusalem, Israel in order to verify The Rabbinical Certification of one Mr. Alon Elias. Who states in Declarations that he was ordained. by no less than The Head Rabbi of Israel and apparently has also showed some sort of copy to others here, but has yet to leave a copy with anyone or provide a copy to the courts or Shabtay. None of the branches of The Rabbinate had record of an Alon Elias. Neither did the Office’s of the current Head Rabbi of Israel T called and found there are four ranches in Jerusalem of The Rabbinate; Ones that perform weddings, one that are moils, o2s ‘hit certify kosher foods, and general scholars and teachers. © The lists forwarded consist of ev.1 ‘pages and literally nearly 1,000 names. I have attached ‘one samples page of each of the hui pages forwarded and can forward a PDF copy to whomever is interested to review them in their entirety. Nowhere on the lists can one find the name Alon Elias of even a close variation of said name. I declare under penalty of perjury that the forgoing is true and correct and I executed this Declaration in Los Angeles, CA on September 24, 2015. hte Cbd Sara Cohen EXHIBIT C EXHIBIT C 71D) PF DW THAW PPT — AW Moshe - Dayan Law Office &Notary Tamar Dayan Moshe, Adv LL.M ,Notary Pow 7/9 AWA pT ON Jan Office Avraham Dayan, Adv LL.B Guys vmy nove ox po) VY POT BATIN Guy Keidar, Adv LLB cwrper rane) VAY , VAY NOD Tali Shitrit, Adv LL.B ny IBY 90 ‘September 9, 2015 Shabtay Issachar ~ 22¥> xnav To whom it may concern, 1. To the request of my client, I hereby verify that my office has been retained by Mr. [ssachar Shabtay to inquire with the Ministry of Religious Services in Israel on whether or not Alon Elias, date of birth, 02/08/1980 is a certified Rabbi in Israel. XN . According io r name and birth here is no Certified Rabbi matching that 3. In addition, our client has been harassed and photographed and stalked while in the hospital and upon his release during the month of August, 2015, according to our client, by Mr Alias or someone of his behalf. 4, Therefore, My office has been retained to take any legal actions necessary against Alon Elias or anyone on his behalf in order to make him cease and desist immediately from such actions, including filing an appropriate complaint with the Israeli authorities. Sincerely, 5126237 pra%23,,5.N229 39,27 AAYP 3.9.0.2) B.S.R 3, 27" floor, Kineret 5, Bnei-Brak 5126237 Md@Md-adv.com 03-7522588 : vp - 03-7522544:: novo EXHIBIT D EXHIBIT D Ant nwaa TATa WE"k aes een (R55) ay ern wee a4 soe Se Sen =f event Cag. ate: fw mases nn movEN ATS 242K 70872055 “rH | O7TOk2TT sno tenaw Hen na MeN > = mo me man yo pma ew tno ane pans Ce Ce ree Co ees Co) # = * pd a 00:00 17/08/2015 nw AnD Yen rors gm? Youn 126m 3a TAIN Ao BRAC I NP “own IAT OE YAR SwaL mown nen nan sya pafma yeas anya se we AE Wer _ldute ELiAs Sew PEOPLE NS 3. tTweteal- cha ane Bar Le —— aNIN Nyaa ya73 WINX ar oD 5B 0 epee “ ee ——— Pra ynon'en [Sai].[ see) -[(207g]-[ 9] wom Pm'on O3-836za69] ope es 12 WHE ID PAD RODYA yan MUNA AWA 21:24 17/09/2016 yrwNA 077304277 sf'n‘on «wna ‘moo nn adyrtin 1] 3 faa cme oan yr OD BPE OF ae 00.00 17/09/2015 yrom m>nn awn ses neatay Toma 126 19 39a 7 aI oar nw ORD awn awn nwena nn: any 7AM aBHMA pIvA OANA Na wa AF We, AANA vrD, “01 ow anoun ow oy [ Ea 70687304] rpon . En EXHIBIT E EXHIBIT E SouthCoast HEALTH Total Wellness for Life™ Re: Shabtay, Issachar D.0.B. 09/14/1945 ‘To Whom It May Concern, My name is Victor Rosenfeld, M.D. | am a Board Certified Neurologist. | am readily familiar with Mr. Shabtay, who | treated while in Los Angeles and Santa Barbara and continuously monitor since relocating my offices. Shabtay is now 70 years of age, a retired major motion picture studio facility ‘manager, and an observant Orthdox Jew, with a medical history which includes cancer, Mr. Shabtay recently suffered an epise:!» of acute heart failure which in my professional opinion was the ramification of continued exposur te str and relentless personal attacks and emotional barrages by an individual or group involved in keeping him from his synagogue he founded. ! recommend that Mr. Shabtay be afforded every courtesy and assistance possible under the law to allow him the necessary time to relax and heal from his near fatal recent hospitalization. If these highly ‘emotional and troubling matters continue, resulting in further stress, anxiety, depression and h ospitalization they can have devastating irreversible consequences, alas even fatal. Sincerely, Aa al¥¢/205 Victor Rosenfeld, M.D. Ph: 912.691.4100 www.victorrosenfeldmd.com EXHIBIT F EXHIBIT F — Pe ow ge Sen CE ee, Los Angeles Police Department cr cove coManED E40 aon € ed 930100 (oun) INVESTIGATIVE REPORT MATPLE ORS on" ppm __ CASE SCREENING FacToR(S) | ‘GluwuivaL THREATS [areas *e* pe 3 serena nrson aaa Arcee 3 rset m [w [s0 [i [70° Josnatbas 2 sonorooncr = sae se al one oe as marie (ey acu Dy woscmova mus omen 5 } |z Zon one vorm mice > a a een Caw | meee joanna eee a Reice | [Raseeres ["aetwes ENTRY cou POINT OF ENTRY POINT OF ExT ‘LOCATION OF OCCURRENCE as VS" [res [yous] a Gre as a ‘irre imme Hel conmans r onan ae Oe aoa ERE PERSIE TMNT SG Comer | Ls is s VIE TS VER WS NE CT RETR RESTO STERIL MO LORE EDR eT ONGUE AcToOns. © SIORTFORN DESGNRE SUSPECTS GT Gna WORST [PHRASES NELUDING WEAPON USED DO NOT REPEAT ABOVE FOOT CARAT j Sights text to he vet stating ne will "End his existence” if viet went tothe Police oF to court Vict se ear of he We and 4 ~ WANORTORY MRRSTS RIGHTS —— ATED BY ——sowesne ——] CARD PROVED TOTHE VET |__waTReoWAEUOe |_| GENCE REPORTING Hernandez 36r21_Nnwo_|_Reormmc a EMPLOYEE;S) Des. ore RT ERR TROT TRESS EE BE RT 0.0 Seton Sue THIS REPORT DOES NOT CONSTITUTE VALID IDENTIFICATION KEEP THIS REPORT FOR REFERENCE. INSTRUCCIONES EN ESPANOL AL REVERSO. Seats ell be assigned to @ detective for follow-up vestigation based upon specfc fats obtained during the inal vestigation Studies have shown thatthe presence of thase facts can predict whether a detaled follow-up investigation would liely result neha rest dnd prosecution ofthe suspeei(s) or the recovery af property, i. a manner that is costeffetive to you, the taxpayer, Sigmficam dscreceee | in porzonmekteme-mace + inppossiel: for deseo! ally discuss each and evacy ace with all crime Vietms, +e roulinely contact you. unless the detective requires additional information, || TOREPORT ADDITIONAL INFORMATION: If you have specific facts to provide which might assist inthe investigation of your case please Gontact the detective Monday through Friday, between 8.00 A.M. and 9:30 A Mor between 2°30 PM. and 4:00 PM. at wephone nanier ~ Hfthe detective is not available when you call, please leave @ message and include the telephone number where you an be reached COPY OF REPORT: If you wish to purchase a copy of the complete report, phone (213) 486-8130 to obtain the purchase price Send a ‘heck or money order payable to the Los Angeles Police Department to Records and Identification Division, Box 30158, Los Angeles. CA, 20030. Include a copy ofthis report or the following information with your request 1) Name and address of victims, 2) Type of report and DR number (if listed above): 3) Date and location of occurrence. NOTE: Requests not accompanied by proper payment will not be processed. DR NUMBER: [If not entered on ths form, the DR number may be obtained by writing o Records and Identification Division and giving the information needed to obtain a copy of the report (see above paragraph). Specity that you only want the DR number twill be forwardes without delay. There is no charge for this service. F CREDIT CARDSCHECKS: Immediately notify concerned credit corporation or banks to avoid possibility of bejag {ety Woomayyec abe using your stolen or lost creditcard or check HOW YOU CAN HELP THE INVESTIGATION OF YOUR CASE: * Keep this memo for reference * Ifstolen items have serial numbers not available at time of report, attempt 1 locate them and phone them tothe detectNRATIN listed number * Ify0u diseover addtional losses, complete and mail in the Supplemental Property Loss form given o you by the report employee * Promptly report recovery of property * Promptly report additional information such as a neighbor informing you of suspicious activity at time erime occurred VICTIM-WITNESS ASSISTANCE PROGRAM: The Los Angeles City and County Victim-Witness Assistance Program (VWAP) can help to dgermine if you qualify for Vietim of Violent Crime compensation. Ifyou qualify, they will assist with filling your claim application Ii'vou are 4 vietim or a witness to a crime and will be going to court, they will explain the court procedures to you. Ther staff may aso assist you with ‘ther problems created by the crime. ‘To find the program location nearest ‘0 you, call the Vietim-Witness Assistance Program atthe Los Angeles City Attomey’s Office (213) 485-6976, or the Los Angeles County District Attorney's Office (800) 380-3811 VICTIMS OF VIOLENT CRIME COMPENSATION: Refer to paragraph at bottom of reverse side. ee OTST INVESTIGATIVE REPORT Cc: ___ CASE SCREENING FACTOR(S) O susrectwencienor seen PRIETS OR OTHER EVIDENCE NOT PRESENT Mo nor istic PROPERTY LOSS Less THAN 36,000 No SemcuS auuRY TO vicTaa muy one icra mvouireD PREMISES (srecre req i I é ; £ — : eos noon aRIS RS Tete neal ils ee ee a oo = Trey at fear ast Bim bas a ususaeeet: 2S piesa hare i aa VST PE an RTE TESTER SST cmaieiooaT am Ra ene vo RAGBLFOER, OSCRDE SUSPECTS ROTO W ORET PETS ROLUOWG WENN ERD” TOTOT REPEAT REGVE ESB GORY EFORT AS MECESSAMY KAY OF TE MGSO TEMS ARE POTENTIALLY ENTIMABLE TEMZE WO DeSemne it Meas unser res ee SE ST RENTS ze @E ALL TEMS MISSING THs REDENT M THE NamravG bowen arpoate es Se = Arion) Pease + ‘STS WAROATORY MARY'S RIGHTS MOTIVATED BY DON CAND PROMOTE [RTE ar roma aa Semache enna] peg OUR camanse hae TT REPORTING eis ead: REPORTING MPLOYEE(S * ves 5 TF Sor PoE RR PA FRAT EMPLOVEE(S)[ sina) Se 13 aera Re Lie aCe | THIS REPORT DOES NOT CONSTITUTE VALID IDENTIFICATION KEEP THIS REPORT FOR REFERENCE. INSTRICCIONES EN ESPANOL AL REVERSO. Your case will be assigned to a detective for fo investigation based upon specific facts obtained during the initial investigation. Studies have shown that the presence of these redict whether a detailed follow-up investigation would likely result in the arrest and prosecution of the suspect(s) or the recove ry, in a manner that is cost-effective to you, the taxpayer. Significant decreases in personnel have made it impossible for de s pe-sonally discuss each and every case with all crime victims, A detective will not routinely contact you, unless the detective requ tional information, TO REPORT ADDITIONAL INFORMATION: | I: you have specific facts to provide which might assist in the investigation of your case, please contact the detective Monday through Friday, between 8:00 A.M. and 9:30 A.M, or between 2:30 P.M. and 4:00 P.M. at telephone number + Ifthe detective is not available when you call, please leave a message and include the telephone number where you ‘can be reached. COPY OF REPORT: If you wish to purchase a copy of the complete report, phone (213) 486-8130 to obtain the purchase price, Send a check or money order payable to the Los Angeles Police Department to Records and Identification Division, Box 30158, Los Angeles, CA 90030. Include a copy of this report or the following information with your request: 1) Name and address of victims; 2) Type of report and DR number (if listed above); 3) Date and location of occurrence. NOTE: Requests not accompanied by proper payment will not be processed. ) 7 Burbank Police Department Wl eo Vi Aon EL AcCITIZEN INFORMATION Date: 8-26-16 DR#: 15-2380 Crime Classification: 15-7285 A police report has bee: assigned to your case. telephone number indic: n through Friday 8:00am to 5:00pm. Eligible crime reports may be purchased through the Record Bureau at (818) 238-3140. Please allow 48-72 hours for Daa Processing. us 238-3210 t "oa 238-3100 EXHIBIT G EXHIBIT G co stank date oro win fo. Notice of Court Hearing @ Person Seeking Protection a. Your Full Name: lscnawe “Issy" SHaastbal ‘Your Lawyer (if you have oke for this case): ‘Nam peal State Bar No.; Firm Name: — b. Your Address (Ifyou have a lawyer, give your lawyer's information. ‘Ayou do not have a lawyer and want to keep your home address Private, you may give a different mailing address instead. You do not ‘have to give telephone, fax, or e-mail.): Fil court name and strootaderess: [Superior Court of California, County of .TH CENTRAL DISTRICT stds: A895 Meter TASTURBANK COURTHOUSE City: Nia seg NUWULKGCE State: CA zip: SILO SOQHAST OLIVE AVENUE Telephone: O18 48 7267% _ Fox: Lt E-Mail Address: Court filis in case number when form is filed. @ Person From Whom Protection Is Sought ES019829 rulNime: AN @oNINAL, Yenudé The court will complete the rest of this form. ® Notice of Hearing A court hearing is scheduled on the request for restraining orders against the person in(@) ‘Name and address of court if different from above: BOT 13 2015 ac cay eee net ie fem, (a) Se Nes oe eee ———— ‘PASADENA, CA 91101 Temporary Restraining Orders (Any orders granted are on Form CH-110, served with this notice.) a, Temporary Restraining Orders for personal conduct and stay-away orders as requested in Form CH-100, Request for Civil Harassment Restraining Orders, are (check only one béx below): (LAM GRANTED until the court hearing (2) O All DENIED until the court hearing. (Specify reasons for denial in b, below.) ©) O Partly GRANTED and partly DENTED until the court hearing. (Specify reasons for denial in b, below.) &) Case Number: ES019829 », Reasons for denial of some or all of those personal conduct and stay-away orders as requested in Form CH-100, Request for Civil Harassment Restraining Orders, are: () Ci The facts as stated in Form CH-100 do not sufficiently show acts of violence, threats of violence, or a course of conduct that seriously alarmed, annoyed, or harassed the person in (1) and caused substantial emotional distress, 2) C Other (specify): C] As set forth on Attachment 4b, © Service of Documents by The Person in @ At teasnyh five a days before the hearing, someone age 18 or older—not you or anyone to be Protected —must personally give (serve) a court file-stamped copy of this Form CH-109, to the person in @) along with a copy of all the forms indicated below: Notice of Court. ‘Hearing, ac -100, Request for Civil Harassment Restraining Orders (file-stamped) (CH-110, Temporary Restraiting Order (fle-stamped) IF GRANTED ©. CH-120, Response to Request for Civil Harassment Restraining Orders (blank form) 4. CH-120-INFO, How Can I Respond to a Request for Civil Harassment Restraining Orders? ©. CH-250, Proof of Service of Response by Mail (blank form) £ C] Other (specify): Date: __ SEP 1.8 2015 > Pisa edie Judiqgthiteaé FIELDS GOLDSTEIN * The court cannot make the restraining orders after the court hearing unless the person in @)has been perspnally given (served) a copy of your request and any temporary orders. To show that the person in(2)has been served, the person. who served the forms must fill out a proof of service form. Form CH-200, Proof of Personal Service, may be used, * For information about service, read Form CH-200-INFO, What Is "Proof of Personal Service"? + Ifyou are unable to serve the person in(@)in time, you may ask for more time to serve the documents. Use Form CH-115, Request to Continue Court Hearing and to Reissue Temporary Restraining Order. evans, 204 Notice of Court Hearing-~---~-- CH-109, Page 2019 (Civil Harassment Prevention) 2 EXHIBIT H EXHIBIT H Issachar Shabtay Synagogue Contents Initial List Plaintiff Reserves Right to Amend Shabtay Contents Presently Located at His Synagogue; 11754 Riverside Drive Valley Village CA 91607 - Model of Old Temple of Jerusalem (Built at Shabtay Personal Home and recently put on display at Synagogue)photograph Ex 1.1 - Plexi Glass Chair of Elijah The Prophet Bris Milah Chair Plexi Glass Personal Podium Issy Shabtay . Shoffar - Rams Horn Large . Various Books Numbered and Volumes aprox 200 in quantity see photograph 1 . Various Books Numbered and Volumes aprox 251 in quantity prayer books see photograph 2.0 7. Torah Scroll housed in wood light bamboo with dark Star of David see photograph 5.0 8. Marble Tables see Photograph 2.4 9. Cantors Podium with Blue Star of David see photograph 2.1 10. Dolphin WaterFall 11. Large Marble Menorah 1 12. Wood Menorah 2 ****Plaintiff will seek to amend this list as needed ARON a

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