Human Rights Alert (NGO)

Joseph Zernik, PhD "

PO Box 33407, Tel Aviv, Israel 6133301 ",33407 "
Fax: 077-3179186 Email: joseph.zernik@hra-ngo.org

[]
February 23, 2017

Tel-Aviv Mayor Ron Huldai huldai@mail.tel-aviv.gov.il, haimov_a@mail.tel-aviv.gov.il

City of Tel-Aviv CEO Menachem Liebe mancal@tel-aviv.gov.il
Deputy CEO Ruby Zluf - losthois_a@mail.tel-aviv.gov.il
Enforcement Director Aluf Sharf saraf_a@tel-aviv.gov.il
And by hand delivery in the CEO's office

RE: Repeat demand to cease unlawful City of Tel-Aviv threats against my Protest Tent
Your response within 24 hours is requested. Time is of the essence!

Dear Mayor Huldai, CEO Liebe, Assistant CEO Zluf and Enforcement Director Sharf:
Yesterday, I was told that City enforcement personnel visited my Protest Tent and threatened to
demolish it. I demand an end to such unlawful threats and extortion.
a) There is no valid legal basis for the City's threats
Previous threats were purportedly based on court process in Russov et al v City of Tel-Aviv (18790-
10-14). I was not party in that court case, I was not represented in that court case, and the court had
no jurisdiction over me. The subject matter of that litigation was the right of street dwellers to
adequate housing, pursuant to the Base Law Human Dignity and Liberty, while I have never sought
any housing assistance by any government agency. Furthermore, regardless of repeat requests, the
City has so far failed to serve on me duly signed and certified, enforceable copy of any court
decision or judgment in that case.
b) I hold a valid permit till May 31, 2017 by Deputy CEO Ruby Zluf
In late 2012, I set up my Protest Tent in the Volovelsky Garden under the November 28, 2012
agreement between the protest movement and City of Tel-Aviv, which designated the Volovelsky
Garden as the protest site, in lieu of Rothschild Avenue, for exercising the Right to Protest. In
response to my routine monthly request for extension for December 2016, I received a letter dated
December 01, by Deputy CEO Ruby Zluf, which extended my permit till May 31, 2017 (attached).
c) Attorney General Guidelines regarding protest tents and the Right to Protest
Only last week media reported new Guidelines by the Attorney General, pertaining to the right to
set up protest tents. According to such reports, the Attorney General instructed or encouraged the
Municipality of Jerusalem to permit the maintenance of protest tents.
d) Selective, arbitrary and capricious enforcement
The City of Tel-Aviv is engaging in selective enforcement: It has been clear all along that there is
no intention of taking any action against the tent of my good neighbors, non-Israeli citizens, Iraqi
family. The City's enforcement personnel have previously explained such selective, arbitrary and
capricious enforcement by the bizarre designation of my neighbors "State Persons". Such patently
unlawful discrimination previously prompted a complaint by Ministry of Justice CEO Amy Palmor
(by her own initiative) to the Ombudsman of the Judiciary.
Therefore, the City's conduct is perceived as an unlawful threat of use of force on multiple accounts.
I demand that the City of Tel-Aviv cease its unlawful threats against my Protest Tent.

Truly,

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Joseph Zernik, PhD
)Human Rights Alert (NGO
Attached: December 1, 2016 permit
CC: Wide distribution
232017 ,

haimov_a@mail.tel-aviv.gov.il ,huldai@mail.tel-aviv.gov.il
" " mancal@tel-aviv.gov.il
" " ,sade_r@mail.tel-aviv.gov.il , losthois_a@mail.tel-aviv.gov.il -
saraf_a@tel-aviv.gov.il
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