XXX DISTRICT COURT
___________ DISTRICT OF XXXX
XXXXX,
Plaintiff(s),
vs.
XXXX
Defendant(s)
Case No. ___________
COMPLAINT
JURY TRIAL DEMANDED
COMPLAINT
1. COMES NOW Plaintiff XXXXX, with this complaint against the
Defendants, and alleges as follows:
PARTIES
2. Plaintiff XXXX is an individual of address [ENTER ADDRESS].
3. Defendant, XXXX an individual of address XXXX,
XXXX. Said Defendant is an attorney of license number XXXX.
4. Defendant, XXXX is an individual of address [ENTER
ADDRESS]. Said Defendant is Plaintiff’s ex-wife.
5. Defendant XXX is an individual of address [ENTER ADDRESS].
6. Defendant XXXX is an individual of address [ENTER ADDRESS].
JURISDICITON AND VENUE
7. This Court has subject matter jurisdiction under 28 USC § 1331, on the basis of
there being a federal question relating to 18 USC § 1962 [d].
8. Venue is proper in this district under 28 U.S.C. § 1391 as Defendant is subject to
personal jurisdiction in this state. Defendant lives within the jurisdiction of this Court. Besides, a
COMPLAINT – 2
substantial part of the acts and omissions forming the basis of these claims occurred in the
_______ District of XXX and arose from the actions or inactions of the Defendants.
FACTS
Facts against Defendant XXX
9. Plaintiff met with XXXX on XXXX. Plaintiff went to his
office at XXXX. The purpose of the meeting was to discuss obtaining additional visitation
rights for Plaintiff’s children. They are an important part of Plaintiff’s life, and Plaintiff felt he
was not spending as much time with them as he deserved.
10. During that meeting, XXX failed to disclose that he was actually
representing the second Defendant, Plaintiff’s ex-wife (hereinafter “ex-wife” or “ex”), or
considering doing so, which Plaintiff feels was a significant breach of legal ethics. Obviously, if
Plaintiff knew he was representing his wife or potentially doing so, Plaintiff would not have
disclosed information details about Plaintiff and his ex’s custody arrangement, or disagreement,
to him.
11. Because he shielded this essential knowledge from Plaintiff, Plaintiff opened up
and spoke freely including how he felt that his children needed their father in their lives more
often as well as all essential details about his situation. Sadly, Plaintiff’s ex-wife was not willing
to allow Plaintiff to spend time with them, so Plaintiff decided to pursue the legal route. It was
not until later that he found out the lawyer Plaintiff had disclosed so much to was representing
the first Defendant, Plaintiff’s ex-wife, which was a significant conflict of interest and obvious
breach of legal ethics.
12. Shortly after meeting with XXXX, ex drove Plaintiff’s daughter to the police
station (she was rejected from the army due to her mental issues) and had the daughter file a
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complaint that she overheard Plaintiff yelling on phone with XXXX that Plaintiff will not pay
child support. At that time, there were considerable overpayments of child support and at no
point did Plaintiff ever discuss with XXXX not paying for the children. Daughter said that
Plaintiff abused her twin brother all the time. She admitted to police that she never mentioned
this to anyone including her therapist. Daughter met with therapist weekly for years and texted
between meetings. Besides, Daughter and ex had no objection with her living with Plaintiff from
XXXX. Daughter even wanted to move in with Plaintiff again shortly before
ex induced her to file complaint.
13. On XXXXX filed a lawsuit against Plaintiff on behalf of ex-
wife. Plaintiff was not served as the address he filed for Plaintiff with the court was fake. The
court ordered that secretary serve Plaintiff. Secretary could not do so, since the address was false.
14. In the lawsuit, XXXX mislead the court to believing that Plaintiff was not seeing
his children at all and that Plaintiff was not paying child support. He alleged that Plaintiff was
refusing to see the children and did not have any interest in being a father, which was not the
case.
15. In actuality, Plaintiff’s ex-wife was refusing to comply with the child custody
arrangement as stated in the legally binding child custody agreement. Because the ex-wife was
not allowing Plaintiff to see the children on his assigned weekdays, as stated in the custody
agreement, Plaintiff was not seeing his children as much as he wanted. XXX attempted
to use this as a basis of a lawsuit, and was asking the court to sanction Plaintiff despite the fact
that his client was illegally registering children for XXXX on Plaintiff’s days, making it
impossible for Plaintiff to see them. She also lied about their bedtime, insisting that they need to
be home by 7:30. In reality, they were taking XXXX three nights a week (without Plaintiff’s
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permission) that ended at 8:30 so they were home by 845. As it took Plaintiff 1.5 hours each
way, her attempts made it impossible to see children as much as Plaintiff wanted but she was
unable to prevent Plaintiff from at least visiting children on weekends (she refused to cooperate
with children staying over by Plaintiff. Insisting that Plaintiff’s place was not suitable and then
when Plaintiff rented hotels or Airbnb canceling without notice so that Plaintiff would lose some
or all of the money paid for reservations and Airbnb hosts would refuse to rent to him.
16. This goes in direct violation of the court-ordered custody agreement .XXXX refused to acknowledge that a prior custody agreement was in place, that his client was
not complying with the custody agreement, and would not communicate with Plaintiff’s current
legal representation in an honest effort to modify the child custody agreement in a manner that
was appropriate or all parties.
17. Despite being the opposing counsel in this significant case, XXXX refused
to communicate with Plaintiff or Plaintiff’s attorney, and his intransigence made it virtually
impossible to reach an amicable resolution in this manner. He continually refused contact to
discuss the trial custody arrangement, which had a significant impact on the quality of life of
Plaintiff’s children. Inappropriately, he kept stating that we needed to contact the ex-wife
directly, but she had no interest in speaking with Plaintiff about the issue and just used any
contact to claim harassment. Because there was no communication from the other party, the
parties were not able to get anywhere in the dispute.
18. As one specific example, Plaintiff had to miss Plaintiff’s son’s bar mitzvah, which
was a major milestone in his life. The ex-wife stated that Plaintiff was not allowed to attend the
event, but then XXXX filed a lawsuit a few days before the bar mitzvah saying that
Plaintiff was refusing to be involved in the son’s life, which was obviously not the case. He even
COMPLAINT – 5
testified at the Rabbinical Court on January 10 th that Plaintiff was invited to the son’s bar
mitzvah, which Plaintiff was not. Plaintiff did not even know where it was because no one would
tell him. It was Plaintiff’s belief that he filed a lawsuit solely to falsely claim that Plaintiff had
abandoned his children in an effort to expedite Plaintiff’s wife’s move to the United States. The
ex has attempted to kidnap the children during Channukah to the Unites States but due to the
significant publicity of the kidnapping, she was forced to return.
19. Despite the overwhelming evidence and his personal knowledge (from his
consultation with Plaintiff) that Plaintiff have an interest in participating in the children’s lives,
he filed a frivolous, baseless, and spurious lawsuit based on nonexistent evidence and a
convenient manipulation of the facts without appropriate context. Through his meeting Plaintiff,
he had all of the context and direct knowledge that the lawsuit was fraudulent.
20. In any event, XXXXX contacted Plaintiff on June 8, 2022 complaining that
he was not able to serve Plaintiff. Plaintiff agreed to accept the service of the papers via
WhatsApp and told him that he wanted to discuss the matter with him and resolve the issue
amicably.
21. During this conversation, he openly stated that the relationship between a father
and his children was treasured and that any trip made abroad was only temporary and would not
have a significant impact on Plaintiff’s relationship with his children. He even stated that he
thought it was important for a father to speak with his children every day to ensure he was a
presence in their lives.
22. Even though Plaintiff tried to call and speak with the children repeatedly over the
next few days, the children refused to speak to Plaintiff. That was when Plaintiff realized that ex-
wife was poisoning the children against them. There are a number of lies ex-wife had told the
COMPLAINT – 6
children to poison them against Plaintiff, and one of them was a vaccination issue that was only a
red herring and had been twisted out of context by ex-wife. Plaintiff simply wants the children to
receive the best medical care they can, and all of the decisions made in concert with the best
practices and standards set by the medical profession.
23. Because Plaintiff was not able to speak to the children, and because ex-wife does
not speak to him, Plaintiff was not sure if the children are okay. Therefore, Plaintiff decided to
reach out to XXXX once again to let him know that Plaintiff do not want to traumatize the
children by calling the police. Plaintiff simply wanted to make sure they were okay. Without any
communication from the children or ex-wife, Plaintiff found himself staying awake at night
worrying, wondering if something bad has happened to them. It was having an adverse impact on
his overall quality of life.
24. Sadly, this was another issue that Yogev Haimi refused to discuss with Plaintiff.
He would not let Plaintiff know if the children were okay, and he told Plaintiff that he needed to
hire a lawyer who could take the issue to court. He also said that Plaintiff was not able to contact
him again.
25. Plaintiff accepted service from him via WhatsApp under the pretense that they
would work together, in concert to resolve the issue quickly and amicably. Now, he was refusing
to discuss anything with Plaintiff at all, and it has significantly slowed down the case. He would
not let Plaintiff speak to the children and he would not let Plaintiff know if they are okay. Even
though he opened a promise that Plaintiff would be able to speak to the children, he has refused
to do so even after Plaintiff fulfilled his part of the agreement. Ex-wife has poisoned the children
against Plaintiff, and he feels that he has played a major part in alienating his children and
COMPLAINT – 7
damaging his relationship with them. He has taken advantage of the traumatic experience he has
caused, and he was refusing to do his part to reach an amicable agreement.
26. Eventually, Plaintiff’s ex-wife did contact Plaintiff, saying that they should work
with XXXXX to resolve the disagreement. After the phone call as over, she sent Plaintiff
another message claiming that Plaintiff was harassing her, and she claimed that Plaintiff was
being belligerent, despite any of that being true. Plaintiff simply wanted to work together to try
to resolve this complicated issue. She demanded that she take the children to the United States
for three weeks, and then stay with her in Israel for three weeks, and then split the remaining two
weeks. This would only leave Plaintiff with one week that Plaintiff can spend with the children,
which was unfair and does not allow Plaintiff to play a significant role in their lives. This was
not a serious offer and was just a manipulation.
27. In addition to that, he falsely represented to the court system that Plaintiff was not
paying Plaintiff’s child support, not seeing Plaintiff’s children, and did not have any interest in
seeing the children. He also claimed that Plaintiff was refusing to negotiate with them, but that
was not at all the case. In addition, he knew that his claims were outrageously false, not based in
fact, and absurd obfuscations of the truth. He also knew that his client, ex-wife, was committing
XXXX.
28. On top of all of this, he has filed additional paperwork with court system claiming
that Plaintiff’s attempts to discuss Plaintiff’s children and resolve the issue before the court
somehow constituted harassment. He even went so far as to ask the court to impose an order that
blocks Plaintiff from contacting ex-wife despite the fact that neither he nor ex-wife are willing to
discuss the issue with Plaintiff. This was done at end of November as ex-wife had plans to
kidnap the children in December. A no contact order from police or court would help prevent her
COMPLAINT – 8
from being prosecuted for kidnapping. As she could use the order to claim that she was unable to
notify Plaintiff of her plans.
29. In addition, ex-wife falsely told the police that the court had granted an order that
blocks Plaintiff from contacting her (the complaint was filed online with a false police order
written by XXXX and likely filed by XXXX as ex does not speak Hebrew). That was not the case,
and it constitutes making a false statement to law enforcement. Of course, his request that
Plaintiff be blocked from communicating with him and ex-wife was blocked as the parties
needed to discuss the issue with each other to resolve it. One of the reasons why he had been so
successful so far was that he was a former police officer and maintained strong connections with
the police department.
30. The only reason why he was not able to get the police to arrest Plaintiff was that
Plaintiff’s lawyer was able to prevent the police from arresting Plaintiff after explaining the
situation to them. The police believed that they were going to arrest Plaintiff for violating a court
order, but it was only after Plaintiff’s lawyer spoke to them at the police realized that no court
order actually exists. This was just another example of how XXXX has been abusing his
position of authority and been going against his oath and legal ethics as a lawyer. XXX has
significant police connections. Obviously, police do not typically take unwanted texts seriously.
31. In addition to the obvious conflict of interest and betrayal on the part of XXX
, he has written that Plaintiff’s daughter heard Plaintiff telling XXX that Plaintiff was not
going to pay child support, which was false. Plaintiff has never once refused to pay child
support, and Plaintiff has not discussed anything that specific with him on the phone ever. While
ex-wife has continued to claim that Plaintiff was not paying child support, as written in her
WhatsApp, that was untrue. Even though Plaintiff’s daughter has spoken to the police before,
COMPLAINT – 9
Plaintiff’s daughter has never heard Plaintiff saying that Plaintiff does not want to pay child
support, as Plaintiff does want to be involved in the lives of the children and support them.
32. As evidence of that, Plaintiff was clearly stating that Plaintiff was not against an
increase in child support. If Plaintiff was allowed to be a presence in the lives of the children, he
would be happy to pay anything that was required to support them and ensure they are able to
live full lives. If Plaintiff needed to pay more XXXX to be involved in the lives of children,
Plaintiff would gladly pay more. What Plaintiff wanted was 50 % custody to ensure he could be
a fixture in the lives of the children. XXXX knows that Plaintiff was interested in being a
supportive father, despite the numerous times he has claimed to the contrary.
33. Through all of this, XXXX has continued to insist that Plaintiff should not
contact him directly, negotiate with him directly, and insistent that Plaintiff speak to Plaintiff’s
ex-wife directly while helping Plaintiff’s wife file spurious and baseless police complaints,
claiming that Plaintiff was harassing her, which Plaintiff was not. He continued to abuse his
connections with the police department and court system to make Plaintiff’s life miserable.
Plaintiff has evidence from social media that shows that XXXX has been extremely active
on divorce groups and sending messages to people that he has connections in Rabbinical Court,
that he knows all the Rabbis, and that they love him, so he can influence the outcomes of cases.
His representatives state in their messages that, “In Israel, it’s all about who you know.”
34. Eventually, Plaintiff began publishing articles showing just how much XXX was
abusing the system. Magically, the social media messages that supported Plaintiff’s allegations
were deleted. Plaintiff was originally referred to XXXX. After XXXX saw Plaintiff’s
articles online about his illegal activity, she deleted her messages. This was evidence of a crime,
as there was no conceivable reason to delete these messages over a year after sending them.
COMPLAINT – 10
35. Plaintiff tried to confront XXX about the deletions, but he simply pretended to
not know me, despite the numerous interactions we have already had by this point. Plaintiff told
him that he was not allowed to delete evidence, but he instead responded by threatening to get
police after Plaintiff. Police are extremely aggressive in handling any complaints he has.
36. Throughout all of this, it was obvious that XXX had nothing but contempt for
the judicial process, and he would use all of the connections at his disposal to get whatever he
wanted. This was having a negative impact on the lives of the children, and he had become a
significant obstacle in achieving a favorable and amicable resolution in this matter. His
outrageous conduct facilitated the kidnapping of the children by ex-wife and their transportation
to the XXX. For several weeks Plaintiff did not know if they were okay, and XXX had
refused to be transparent with Plaintiff about the well-being of the children. There was nothing to
be gained by traumatizing Plaintiff or weaponizing the children.
37. It was obvious that XXXX was just doing this out of spite, and he refused to
respond to Plaintiff or the courts while ex was illegally in America with the children. Plaintiff’s
messages were not being returned, and Plaintiff’s only option was to reach out to the police
department to do a welfare check and raise awareness on social media and newspapers. Given his
abuse of the police system, it took weeks to get the police to act. Once the children were
returned, he refused to respond to the court, Plaintiff or Plaintiff’s lawyer to let Plaintiff know
that children were fine. Despite the shared custody arrangement he refused to even let Plaintiff
be aware of anything with the children even after they returned. Plaintiff had to go down to the
police station and keep calling for days until police eventually did a welfare check on the
children.
COMPLAINT – 11
38. Not allowing Plaintiff to know if children are fine was a reckless disregard for the
court ordered shared custody arrangements and does not benefit anyone except for his need to
spite Plaintiff.
39. Because there was a significant conflict of interest in this case, Plaintiff’s
conversations with XXX should not be used against Plaintiff, and it was a significant violation
of legal ethics and his oath to not disclose to Plaintiff that he had such a conflict of interest by
representing ex-wife. Plaintiff was also deeply concerned that if he continued to represent ex-
wife, Plaintiff’s children would be irreparably harmed and damaged by his presence.
Facts against Defendant Carol Grinberg and Defendant XXXX
40. In XXX Plaintiff told ex she can keep the XXX child credits. The
divorce agreement states that Plaintiff gets the XXX credits and that she gives her back 25%,
while she gets the Israel child credits.
41. After Covid hit, ex-wife illegally claimed close to $10,000 USD of Covid credits
belonging to Plaintiff. The XXX and XXX credits were in real money.
42. When Plaintiff asked her about the foregoing on XXX via whatsapp, she
threatened to weaponize the kids. She said if Plaintiff sues her for the money, she would get the
children to testify that Plaintiff is a lousy father.
43. On XXX, Defendant ex-wife supposedly sent an email that Plaintiff should
not come to her house. Plaintiff never got that email. Both Plaintiff and Defendant ex-wife
always communicated via WhatsApp as per the agreement and she knew she was blocked from
sending via email. The email was excessively long discussing what a great mother she is and
what a lousy father Plaintiff is.
COMPLAINT – 12
44. In XXXX, Plaintiff was routinely allowed at the house without issue
and she knew Plaintiff did not get the email. She then proceeded to send a WhatsApp to Plaintiff
complaining that Plaintiff was blocking her.
45. Prior to Defendant ex-wife suing Plaintiff, the parties had mediation in family
court about the $10,000 she stole. Social services also attempted to mediate over the stolen
funds.
46. Defendant ex-wife then set Plaintiff up. Defendant XXX, a neighbor, told
Plaintif in a text that Plaintiff’s abuse and control ended at that point. Said Defendant made
various baseless and unnecessary claims. Defendant XXX husband, XXX, kept
recording the goings on aggressively. When Plaintiff blocked with a hat, he pushed Plaintiff’s
hand presumably out of instinct so that the show could go on. The video clearly shows it being
blocked before cutting out. Consequently, a complaint was filed by XXX that Plaintiff
knocked his phone out of hand. It is notable that he is bigger than Plaintiff and a professional
video guy. No one can hold camera as well as him. It is all he does. He told the police that there
was no damage to phone or case. And nothing on video supports his story. No shaking or
anything. He was there because Plaintiff got into argument with his wife.
47. Defendant XXX also said she was taking over and Plaintiff could only see
the children if Plaintiff could bring them home by 7:30. In reality the children had tae kwon do
and other activities several times a week and were rarely home before 8:45 pm. This was
purposefully kept from Plaintiff. Due to her nasty tone and various accusations the conversation
did not end in a positive note. She kept accusing Plaintiff of cursing her and disrespecting her
but Plaintiff did no such thing.
COMPLAINT – 13
48. The lie about the bedtime was designed to prevent Plaintiff from seeing the
children as Plaintiff’s commute is about 1:30 hours each way, occasionally longer. It follows;
Emma and Plaintiff’s ex forced Plaintiff to only come weekends and school holidays.
49. On the day Plaintiff was to pick them up for vacation, the children were texting
and calling from 7:30 am to 10:30. They were excited. Besides, they are always anxious to go
but they were extra anxious because Plaintiff rented a nice place by beach.
50. When Plaintiff came to pick them up at around 10:45, they suddenly were not in a
rush and were waiting somewhere in house. This was the only time the children were in no
particular rush. Defendant Emma’s husband, a professional videographer, was waiting there with
his camera in a perfect spot to record ex recite her script. Plaintiff was trying to talk but the ex-
wife kept repeating from the script. “Stop yelling. Stop cursing. Not in front of kids.” No one
was yelling but her. No one was cursing. It is therefore evident that she weaponised all the
children over money.
CLAIMS FOR RELIEF
COUNT 1
CONSPIRACY TO PARTICIPATE IN RACKETEERING; VIOLATION OF RICO ACT
under 18 USC § 1962 [d]
(Against Defendant Carol Grinberg)
51. Plaintiff re-alleges and incorporates by reference every allegation contained in the
preceding paragraphs of this Complaint as though set forth herein.
52. Said Defendant stole tax refund that Plaintiff was entitled to. The divorce
agreement gave Plaintiff the USA tax credits for the children, while she was given the Israeli tax
credits.
COMPLAINT – 14
53. Normally, with regards to tax credits, Israel is generous. However, considering
the 2020 and 2021 tax years and the effects of Covid, the credit in the USA was a fortune.
Plaintiff was entitled to 75%.
54. On August 20, she threatened to use the children against Plaintiff if he did not let
her keep the Covid tax money.
55. As a result of Defendant’s conduct, Plaintiff lost his USA tax credits.
COUNT 2
FRAUD
(Against Defendant XXXX)
56. Plaintiff re-alleges and incorporates by reference every allegation contained in the
preceding paragraphs of this Complaint as though set forth herein.
57. Said Defendant made a representation, which made Plaintiff disclose pertinent
facts to him. Said representation permitted the occurrence of a conflict of interest, to the
detriment of Plaintiff.
58. Notably, Plaintiff met with XXXX on XXXX at 15:00. Plaintiff
went to his office at XXXX. The purpose of the meeting was to discuss obtaining
additional visitation rights for Plaintiff’s children. Defendant failed to disclose that he was
representing the second Defendant, Plaintiff’s ex-wife or considering doing so. Plaintiff opened
up and spoke freely including how he felt that his children needed their father in their lives more
often as well as all essential details about his situation.
59. If Plaintiff knew he was representing his wife or potentially doing so, Plaintiff
would not have disclosed information about Plaintiff and his ex’s custody arrangement, or
disagreement, to him.
COMPLAINT – 15
COUNT 3
LEGAL MALPRACTICE
(Against XXXX)
60. Plaintiff re-alleges and incorporates by reference every allegation contained in the
preceding paragraphs of this Complaint as though set forth herein.
61. First, Defendant failed to disclose that he was representing Plaintiff’s ex-wife,
thus permitting a conflict of interest. Plaintiff therefore opened up and spoke freely including
how he felt that his children needed their father in their lives more often as well as all essential
details about his situation, which information was confidential and Plaintiff would not have
disclosed if he knew of Defendant’s representation of ex-wife.
62. Next, on XXXX filed a lawsuit against Plaintiff on behalf of
ex-wife. In the lawsuit, XXX mislead the court to believing that Plaintiff was not seeing his
children at all and that Plaintiff was not paying child support. He alleged that Plaintiff was
refusing to see the children and did not have any interest in being a father, which was not the
case. In actuality, Plaintiff’s ex-wife was refusing to comply with the child custody arrangement
as stated in the legally binding child custody agreement. Because the ex-wife was not allowing
Plaintiff to see the children on his assigned weekdays, as stated in the custody agreement,
Plaintiff was not seeing his children as much as he wanted
63. Defendant refused to acknowledge that a prior custody agreement was in place,
that his client was not complying with the custody agreement, and would not communicate with
COMPLAINT – 16
Plaintiff’s current legal representation in an honest effort to modify the child custody agreement
in a manner that was appropriate or all parties.
64. Despite being the opposing counsel in this significant case, Defendant refused to
communicate with Plaintiff or Plaintiff’s attorney, and his intransigence made it virtually
impossible to reach an amicable resolution in this manner. He continually refused contact to
discuss the trial custody arrangement, which had a significant impact on the quality of life of
Plaintiff’s children. Inappropriately, he kept stating that we needed to contact the ex-wife
directly, but she had no interest in speaking with Plaintiff about the issue and just used any
contact to claim harassment. Because there was no communication from the other party, the
parties were not able to get anywhere in the dispute.
65. Defendant would not let Plaintiff know if the children were okay, and he told
Plaintiff that he needed to hire a lawyer who could take the issue to court. He also lied that
Plaintiff was not able to contact him again. On the contrary, Plaintiff had accepted service from
him via WhatsApp under the pretense that they would work together, in concert to resolve the
issue quickly and amicably. Now, he was refusing to discuss anything with Plaintiff at all, and it
has significantly slowed down the case.
66. Defendant falsely represented to the court system that Plaintiff was not paying
Plaintiff’s child support, not seeing Plaintiff’s children, and did not have any interest in seeing
the children. He also claimed that Plaintiff was refusing to negotiate with them, but that was not
at all the case. In addition, he knew that his claims were outrageously false, not based in fact, and
absurd obfuscations of the truth. He also knew that his client, ex-wife, was committing XXXX.
COMPLAINT – 17
67. Defendant filed additional paperwork with court system claiming that Plaintiff’s
attempts to discuss Plaintiff’s children and resolve the issue before the court somehow
constituted harassment. He even went so far as to ask the court to impose an order that blocks
Plaintiff from contacting ex-wife despite the fact that neither he nor ex-wife are willing to
discuss the issue with Plaintiff.
68. Defendant lied that Plaintiff’s daughter heard Plaintiff telling XXX that Plaintiff
was not going to pay child support, which was false. Plaintiff has never once refused to pay child
support, and Plaintiff has not discussed anything that specific with him on the phone ever. While
ex-wife has continued to claim that Plaintiff was not paying child support, as written in her
WhatsApp, that was untrue. Even though Plaintiff’s daughter has spoken to the police before,
Plaintiff’s daughter has never heard Plaintiff saying that Plaintiff does not want to pay child
support, as Plaintiff does want to be involved in the lives of the children and support them.
69. As a lawyer, XXXX conduct has been completely unethical, possibly criminal,
and not in the best interests of his client, the children, or the justice system. The children should
not have had to go through everything they have gone through thus far, and his misconduct has
had a detrimental impact on Plaintiff’s physical and mental health. Plaintiff asserts that he was
entitled to a different attorney because Plaintiff need to be allowed to speak openly with
Plaintiff’s lawyer about the facts and circumstances surrounding Plaintiff’s case. His conduct has
been reprehensible and he needs to be held accountable.
70. XXX has repeatedly used his connections within the police department and
justice system to facilitate ex-wife’s kidnapping of the children, their transportation to the United
States, and the obstruction of an important judicial proceeding every step of the way. If he was
not held accountable for his actions, he may continue to harm not only Plaintiff’s family but
COMPLAINT – 18
other clients as well. Based on the custody agreement Plaintiff has with ex-wife, ex-wife was
legally obligated to share custody of the children, but XXX was standing in the way of that, and
the children are being harmed.
71. As a result of Defendant’s actions and/or inactions as alleged herein, Plaintiff
prays for damages against Defendant in an amount to be determined by the Court.
COUNT 4
INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS
(Against all Defendants)
72. Plaintiff re-alleges and incorporates by reference every allegation contained in the
preceding paragraphs of this Complaint as though set forth herein.
73. Plaintiff’s ex-wife was not willing to allow Plaintiff to spend time with the
children.
74. Defendant ex-wife drove Plaintiff’s daughter to the police station and had the
daughter file a complaint that she overheard Plaintiff yelling on phone with Defendant XXX
that Plaintiff will not pay child support. At that time, there were considerable overpayments of
child support and at no point did Plaintiff ever discuss with XXXX not paying for the children.
Daughter said that Plaintiff abused her twin brother all the time. She admitted to police that she
never mentioned this to anyone including her therapist.
75. On XXX filed a lawsuit against Plaintiff on behalf of ex-
wife. In the lawsuit,XXX mislead the court to believing that Plaintiff was not seeing his
children at all and that Plaintiff was not paying child support. He alleged that Plaintiff was
refusing to see the children and did not have any interest in being a father, which was not the
case. In actuality, Plaintiff’s ex-wife was refusing to comply with the child custody arrangement
COMPLAINT – 19
as stated in the legally binding child custody agreement. Because the ex-wife was not allowing
Plaintiff to see the children on his assigned weekdays, as stated in the custody agreement,
Plaintiff was not seeing his children as much as he wanted.
76. Defendant ex-wife also illegally registered the children for XXX on Plaintiff’s
days, making it impossible for Plaintiff to see them. She also lied about their bedtime, insisting
that they need to be home by 7:30. In reality, they were taking XXX three nights a week
(without Plaintiff’s permission) that ended at 8:30 so they were home by 845. As it took Plaintiff
1.5 hours each way, her attempts made it impossible to see children as much as Plaintiff wanted
but she was unable to prevent Plaintiff from at least visiting children on weekends (she refused to
cooperate with children staying over by Plaintiff.
77. Defendant ex-wife poisoned the children against Plaintiff. Even though Plaintiff
tried to call and speak with the children repeatedly over the next few days, the children refused to
speak to Plaintiff. That was when Plaintiff realized that ex-wife was poisoning the children
against them. There are a number of lies ex-wife had told the children to poison them against
Plaintiff, and one of them was a vaccination issue that was only a red herring and had been
twisted out of context by ex-wife. Plaintiff simply wants the children to receive the best medical
care they can, and all of the decisions made in concert with the best practices and standards set
by the medical profession. Because Plaintiff was not able to speak to the children, and because
ex-wife does not speak to him, Plaintiff was not sure if the children were okay. Without any
communication from the children or ex-wife, Plaintiff found himself staying awake at night
worrying, wondering if something bad has happened to them. It was having an adverse impact on
his overall quality of life.
COMPLAINT – 20
78. Defendant ex-wife sent Plaintiff a message claiming that Plaintiff was harassing
her, and she claimed that Plaintiff was being belligerent, despite any of that being true. On the
contrary, Plaintiff simply wanted to work together to try to resolve this complicated issue.
Defendant ex-wife demanded that she take the children to the United States for three weeks, and
then stay with her in Israel for three weeks, and then split the remaining two weeks. This would
only leave Plaintiff with one week that Plaintiff can spend with the children, which was unfair
and does not allow Plaintiff to play a significant role in their lives. This was not a serious offer
and was just a manipulation.
79. Defendant ex-wife falsely told the police that the court had granted an order that
blocks Plaintiff from contacting her (the complaint was filed online with a false police order
written by XXX and likely filed by XXX as ex does not speak Hebrew). That was not the case.
80. Defendant XXX and her husband also caused Plaintiff emotional distress.
Defendant XXX, a neighbor, told Plaintif in a text that Plaintiff’s abuse and control ended
at that point. Said Defendant made various baseless and unnecessary claims. Defendant XXX husband, XXX kept recording the goings on aggressively. When Plaintiff blocked with
a hat, he pushed Plaintiff’s hand presumably out of instinct so that the show could go on. The
video clearly shows it being blocked before cutting out. Consequently, a complaint was filed by
XXX that Plaintiff knocked his phone out of hand. It is notable that he is bigger than Plaintiff
and a professional video guy. No one can hold camera as well as him. It is all he does. He told
the police that there was no damage to phone or case. And nothing on video supports his story.
No shaking or anything. He was there because Plaintiff got into argument with his wife.
81. Defendant XXX also said she was taking over and Plaintiff could only see
the children if Plaintiff could bring them home by 7:30. In reality the children had tae kwon do
COMPLAINT – 21
and other activities several times a week and were rarely home before 8:45 pm. This was
purposefully kept from Plaintiff. Due to her nasty tone and various accusations the conversation
did not end in a positive note. She kept accusing Plaintiff of cursing her and disrespecting her
but Plaintiff did no such thing.
82. The lie about the bedtime was designed to prevent Plaintiff from seeing the
children as Plaintiff’s commute is about 1:30 hours each way, occasionally longer. It follows;
Emma and Plaintiff’s ex forced Plaintiff to only come weekends and school holidays.
83. On the day Plaintiff was to pick them up for vacation, the children were texting
and calling from 7:30 am to 10:30. They were excited. Besides, they are always anxious to go
but they were extra anxious because Plaintiff rented a nice place by beach.
84. When Plaintiff came to pick them up at around 10:45, they suddenly were not in a
rush and were waiting somewhere in house. This was the only time the children were in no
particular rush. Defendant Emma’s husband, a professional videographer, was waiting there with
his camera in a perfect spot to record ex recite her script. Plaintiff was trying to talk but the ex-
wife kept repeating from the script. “Stop yelling. Stop cursing. Not in front of kids.” No one
was yelling but her. No one was cursing. It is therefore evident that she weaponized all the
children over money.
85. As a result of Defendants’ actions and/or inactions as alleged herein, Plaintiff
prays for damages against Defendants in an amount to be determined by the Court.
COUNT 5
VIOLATION OF THE HAGUE CONVENTION ON THE CIVIL ASPECTS
OF INTERNATIONAL CHILD ABDUCTION
(Against Defendant XXX and Defendant Carol Grinberg)
COMPLAINT – 22
86. Plaintiff re-alleges and incorporates by reference every allegation contained in the
preceding paragraphs of this Complaint as though set forth herein.
87. Defendant Carol Grinberg kidnapped the children and took them to the United
States without Plaintiff’s knowledge or consent. This was in violation of the custody agreement
that was in effect between Plaintiff and said Defendant.
88. Defendant’s attorney, XXX was aware of Defendant Carol’s action, and
failed to disclose to Plaintiff the whereabouts of the children.
89. The Defendants’ actions amount to child abduction under the Hague Convention
on the Civil Aspects of International Child Abduction. Accordingly, Plaintiff is entitled to
judgment.
PRAYER FOR RELIEF
WHEREFORE, the Plaintiff, Jacob Maslow, prays for relief as follows:
a. For judgment ordering the Defendant(s) to pay damages in an amount sufficient to
compensate the Plaintiff for any harm caused by the Defendants’ actions and/inactions
alleged herein.
b. For punitive damages.
c. For any other judgment this Court deems just.
Respectfully submitted:
Dated: __________
______________________
XXX
COMPLAINT – 23
CERTIFICATE OF MAILING
I, XXX, certified on this ______day of ________ XXX, in the
FEDERAL DISTRICT COURT, upon each party through Defendants’ representative counsel on
every person required to be served, by [ENTER METHOD OF SERVICE] to the addresses listed
below:
[ENTER DEFENDANTS’ ADDRESSES]
______________________
XXX
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