harmed in the united states by certain acts in israel in conjunction with certain fund raising acts by other defendants in the united states the action is brought against talking about divorce proceedings in israel well specifically as part the first part divorce proceedings do play a role in it but the issue is primarily debt debts and debt collection not judges for x beyond their authority what we've alleged is that among other things they've created fictitious debts and to create their drift stiction you claim that those debts are fictitious because the divorce decree pain through fraud or other improper me what we're what we're claiming is among other things that these debts are not part of the forced craze i'm showing israeli john and israeli officials what's the claim against them the claim against them is they're falsely charging the plaintiffs in this case with not paying debts and having them arrested harassing their families in the course of legal proceedings you know in the course of that collection season not a legal proceeding per se did that collections this is a debt collection office it's not a judge it's not a drug i'm asking about the israeli officials that complain their debt collectors they're not judges the only person we've named that is not and what we're saying basically is that fund raising is being done in the united states by certain defendants and that fund raising is being used to assist the debt collectors from we meant in remaining in office and then creating a scenario where they can fund raiser wall of the charge the false charges of of the plaintiffs being deadbeat dads per se even in cases where the fathers were able to demonstrate their fully paid up new debts were created out of whole cloth by these people were alleging and that that gave them the jurisdiction to arrest them to take their passports away in some cases they harassed the parents especially if if the plaintiff was in the united states at the time to collect funds that were not due to them and in at least one case they force the parent to put their trial in a school of one of the fund raising defense defendants now ma for the purpose and then and pay that school so so when the plane the plaintiffs are alleging this is a rico claim because we have an association in fact of various individuals and the fund raising defendants and they're all playing their part in the rico scheme which is to get money out of the plaintiffs in essence and i have nothing further at this time thank you  good morning your honour's i'm reaves anderson from arnold and porter i'm here today on behalf of the government of israel to represent the thirteen israeli government officials who were named in the suit a former justice minister a judge and eleven other public servants in the clear up one factual question that was raised a moment ago when he says that collectors these are all officials of the israeli government they are registrars of the israeli collection and foresman agency they are government officers the three points i'd like to address today the first district court properly dismissed this case on numerous dispositive independent grounds all deriving from the fact that israeli citizens have sued israeli officials for their official acts in israel pursu israel its officials and numerous charities those are listed in footnote one of the read brief on page three third the district court's pre filing order was a reasonable and proportionate response to that  fear versus us lines you set forth five factors the first of which is a history of vexatious litigation with mr elliott who did but they never set forth sort of a numerical threshold if other factors counterbalance that and so with respect to mr  he sued the state of israel on the exact same facts casts not as a rico claim then but while that appeal was pending in the ninth circuit after being dismissed as implausible and borderline frivolous he joined this campaign he joined this suit three thousand miles away raising the exact same complaints we have a case that imposes such an injunction based on only one prior loss and we're not aware of any case with that numerical but there are a couple other factors that i think  counterbalance that the district court recognized below both the motive and the burden prong so the motive here is whether there's an objective good faith expectation of prevailing there is not when my friend said that this is the first rico case it's not there were three other prior rico are the complaints and those are the three cases yes your honor we actually in our read brief we show where the complaint listed verbatim a laundry list of predicate acts that have no connection whatsoever to this case those were from that complaint into this one that case was that case went nowhere they knew objective leave this case would go nowhere either is your point then that these prior cases although who's not plaintive in any of those prior cases other than his own that the frivolous nature of them and the prior rulings knowledge that is imputed are you suggesting that i think it goes to whether there's an objective good faith basis that they expect to prevail and recognizing the landscape upon which this case is brought both for foreign immunity the lack of personal jurisdiction to claim in those eleven prior cases this built upon that and the burden is the other point in this is i think the district court really glued into below that one different quality of this case as it involves foreign sovereign immunity and the attendant so foreign to opportunity is intended to protect against the attendant burdens of litigation not just of protection against liability the entire purpose of these suits i submit is to impose the attendant burdens of litigation the costs here are being borne by the israeli taxpayers you have israeli judges israeli officials with a lawsuit an ocean away hanging over their heads for years mr eliyah case although it had no chance of prevailing in california went on for more than three years this case been pending for two and a half years and so the restrained injunction here is to balance all of those factors but the junction is on the name plaintiffs in this action on two of the name plaintiffs yes around and so nothing would prevent them from finding new plaintiffs who is willing to adopt all the prior pleadings and just do this all over again right you're right you honor this is a game of whack a mole and we are trying to be measured in our response to the two that have filed duplicative and numerous suits so there are five other plaintiffs that join the suit the injunction does not extend to them this was their first suit and it may be that more escalating sanctions may be necessary down the road but israel's objective here is not retribution it's judicial peace and so if the ringleaders and again they're not prevented from filing in u s courts they're required to to submit a proposed new point to judge paul your judge paul the designee and submit that it's not frivolous this this new suit is not designed to harass if they have sued some of the defendants their name to the next complaint they must say so they must identify are they suing israeli officials i get that but that difference between who and the other plaintive who are not who are not subject to this injunction is that he filed another suit once right that's correct or is no other differen there is that correct and that there is the numerosity that you know he has he has done this once before i am hopeful that the plaintiffs who have seen their case dismissed here and see no no potential for recovery and they shouldn't be suing israel officials in the united states won't do it again the ones who do i think there needs to be measured repr cautions and again the options here are to impose monetary sanctions on plaintiffs who already complain that they can't pay alimony and child support and other debts that are incurred in israel or do you take a more measured approach and say if you're going to continue this campaign you just need to clear it through a federal judge represent that you're not here to harass to get that so you did you ask for a filing injunction with respect discourage the repeated vexatious ness again as a first step and if if this scheme if i'm back here two or three years from now it may be a different injunction that i'm asking this court to uphold but we see that's you're saying it's whacko so the way to defeat the injunction that's been imposed here or in the future given the standards is to just every time add a new plant and they'll be an injunction against the ones who filed before with the new plaintiff want to get the file again bring in a couple more charities that support israel's child welfare and family law programs and to impose costs on israeli taxpayers as retribution for what points it's perceived as flights in israel and we think that this is a measured good first step  i am handling this argument i didn't i had played no role in traffic in the complaint and i was not aware of the other cases that apparently had different plaintiffs than the ones here and i would submit that and as i said i don't see how if a plaintiff has substantially similar circumstances they can take allegations from a complaint they didn't draft and put it in the specially a pro se one out of thirteen and held to be frivolous in a file or comes in and takes over the case i would think it would be a comment upon the lawyer to check it out i was not aware of the pennsylvania actions in any event  they were and actions of my of my clients so i can't speak to them at all and i would also just like to point out yes the yes the debt collectors may be israeli officials in a debt collection office but they're not judges which