Exhibit C

Case 1:22-cv-23661-PCH Document 28-4 Entered on FLSD Docket 02/03/2023 Page 1 of 23
[10/25/21, 10:26:08 AM] BInyamin EN Corp: Messages and calls are endto-end encrypted. No one outside of this chat, not even WhatsApp, can 

read or listen to them.

[10/25/21, 10:26:08 AM] Eliezer: Hi benjamin, this is Eliezer

[10/25/21, 10:26:17 AM] Eliezer: I’m looking forward to completing 

this transaction with you and working with you guys

[10/25/21, 10:26:50 AM] Eliezer: I have a partner his name is Asher 

berko that’s Currently visiting Israel right now and he would like to 

come see you to say hello and shake your head possibly today or 

tomorrow I’m going to pass your phone number onto him and he will be 

in touch

[10/25/21, 10:32:16 AM] BInyamin EN Corp: Hey Eliezer, good morning.

That will be my pleasure

[10/25/21, 10:44:19 AM] BInyamin EN Corp: <attached: 00000006-

AUDIO-2021-10-25-10-44-19.opus>

[10/25/21, 11:22:33 AM] Eliezer: Ok great thanks!

[10/26/21, 3:13:26 PM] BInyamin EN Corp: Hey,

Adam and I are waiting for you at the zoom

[10/26/21, 3:15:55 PM] Eliezer: On on

[10/26/21, 3:15:59 PM] Eliezer: So sorry!

[10/26/21, 3:18:28 PM] BInyamin EN Corp: Liana Foksheneanu is inviting 

you to a scheduled Zoom meeting.

Topic: Liana Foksheneanu's Zoom Meeting

Time: Oct 26, 2021 12:00 PM Pacific Time (US and Canada)

Join Zoom Meeting

https://us02web.zoom.us/j/86435281738?

pwd=UFd2eW5zSUhZNVdZOWIvSGZPQUFFUT09

Meeting ID: 864 3528 1738

Passcode: 995788

One tap mobile

+14086380968,,86435281738#,,,,*995788# US (San Jose)

+16699006833,,86435281738#,,,,*995788# US (San Jose)

Dial by your location

 +1 408 638 0968 US (San Jose)

 +1 669 900 6833 US (San Jose)

 +1 253 215 8782 US (Tacoma)

 +1 346 248 7799 US (Houston)

 +1 646 876 9923 US (New York)

 +1 301 715 8592 US (Washington DC)

 +1 312 626 6799 US (Chicago)

Meeting ID: 864 3528 1738

Passcode: 995788

Find your local number: https://us02web.zoom.us/u/k41gYRwTq

[10/26/21, 3:23:48 PM] BInyamin EN Corp: The guy like to talk

[10/26/21, 3:23:59 PM] BInyamin EN Corp: But you asked to meet him;)

[10/26/21, 3:47:15 PM] BInyamin EN Corp: <attached: 00000014-

Case 1:22-cv-23661-PCH Document 28-4 Entered on FLSD Docket 02/03/2023 Page 2 of 23
PHOTO-2021-10-26-15-47-15.jpg>

[10/27/21, 9:58:50 AM] Eliezer: Hi benjamin can u speak??

[10/27/21, 10:03:10 AM] BInyamin EN Corp: <attached: 00000016-

PHOTO-2021-10-27-10-03-10.jpg>

[10/27/21, 11:16:33 AM] Eliezer: When you get a second please call me 

I have a quick question thank you

[10/27/21, 6:15:29 PM] Eliezer: ןימינב! 

[10/27/21, 6:15:52 PM] Eliezer: Please make sure that this transaction 

goes smoothly and if it does I will bring you more business than you 

can handle bezerat hashem

[10/28/21, 12:36:30 AM] BInyamin EN Corp: Good morning.

ה״זעב

[10/28/21, 11:08:50 AM] BInyamin EN Corp: Good morning,

The office is not open yet, so I’m updating you that for now we secure 

two air freight, one for Wednesday and one for Thursday. 

Once the funds will be in the escrow we can set the booking.

[10/28/21, 11:09:21 AM] BInyamin EN Corp: In a different matter,

Do you have clients that don’t need specific the OTC?

[10/28/21, 11:12:13 AM] Eliezer: <attached: 00000023-

AUDIO-2021-10-28-11-12-12.opus>

[10/28/21, 11:14:13 AM] BInyamin EN Corp: <attached: 00000024-

AUDIO-2021-10-28-11-14-13.opus>

[10/28/21, 11:17:58 AM] Eliezer: <attached: 00000025-

AUDIO-2021-10-28-11-17-57.opus>

[10/28/21, 12:53:16 PM] BInyamin EN Corp: Did I call back?

Sorry, millions of calls

[10/28/21, 2:44:57 PM] Eliezer: It’s OK I get it we are all slab so 

I’m confirming first thing in the morning 9 AM Eastern we will send 

you the full wire I have the funds today but it’s not available for me 

to send out today since it only came in today as you know Tonight 

everything will post in first thing in the morning go fund the account 

but you can go ahead and start the order everything and get the 

airfreight set up because we are good here

[10/28/21, 2:45:19 PM] Eliezer: I meant to say we are all slammed it 

get it

[10/28/21, 2:45:47 PM] Eliezer: I appreciate everything and the 

opportunity

[10/28/21, 2:47:50 PM] BInyamin EN Corp: NP .

[10/28/21, 6:24:26 PM] Eliezer: R u awake?

[10/28/21, 6:24:31 PM] Eliezer: I know it’s very late by you

[10/29/21, 12:20:59 AM] BInyamin EN Corp: Now I’m up

[10/29/21, 1:22:54 AM] BInyamin EN Corp: You will see it when you will 

wake up. Liana spoke with me so I’ll reply 

It’s obvious that there will be a fight on antigen all over. As you 

know better than me, it’s the new “gold rush”.

From legal point of view, you are buying from Acon a US package 

products that can be sold only in the US. So no one can tell you not 

to sell it. 

I’ll will send you also LOA signed by our lawyers that guarantees the 

same.

Case 1:22-cv-23661-PCH Document 28-4 Entered on FLSD Docket 02/03/2023 Page 3 of 23
I’ll try to talk with Acon China this morning, but I’m pretty sure 

their reply will be the same as what I wrote you.

As you know, November 9 is the date the American distributor is afraid 

of so I would not take it too much serious all those threats.

With any case, I will take the “risk” and guarantee that you won’t 

have a problem.

Without connection to that, I’m updating you that I gave the approval 

to book the place for your product on Wednesday Thursday (it will be 

splitting) after your text last night (my night). So your shipment is 

also secured.

[10/29/21, 6:48:31 AM] Eliezer: Good morning. Is it possible that we 

get on a call at 8:30 Am EST this morning? You, me, david, your 

compliance guy that was on the first call and my partners Anchi and 

Lewis. I hear what your saying so believe me I see Both sides so can 

we all speak? It would be 3:30 israel time I believe.

[10/29/21, 6:50:12 AM] BInyamin EN Corp: Jonathan (compliance) won’t 

be available (middle of his night) 

David I will ask

[10/29/21, 6:51:05 AM] BInyamin EN Corp: If we would do it at 17:00 my 

time I believe everyone can join

[10/29/21, 6:54:09 AM] Eliezer: Ok great so can we do rhat then? 17 

isn’t to late for you? I don’t know what time Shabbat comes in israel.

[10/29/21, 6:54:42 AM] BInyamin EN Corp: Shabbat enter at 17:40 so 

it’s ok

[10/29/21, 6:56:07 AM] Eliezer: Ok so yes if we can all speak. Will be 

important fir Lewis my partner to hear what you are saying because I 

agree with what you’re saying but if he can hear it also direct from 

you and your compliance guy that we’re not doing anything wrong I 

think would be very helpful.

[10/29/21, 6:56:36 AM] BInyamin EN Corp: NP

[10/29/21, 8:26:24 AM] Eliezer: Will u b circulating a dial in or 

zoom? Should I message liana?

[10/29/21, 9:14:40 AM] BInyamin EN Corp: We can do zoom, I’ll send a 

link later

Already texted liana

[10/29/21, 9:53:49 AM] Eliezer: Are you guys going to circulate a 

link?

[11/1/21, 2:53:17 PM] Eliezer: We just sent the balance of 150,000

[11/1/21, 2:58:32 PM] BInyamin EN Corp: Thanks 

[11/1/21, 2:59:32 PM] Eliezer: Don’t go spending it all in one 

place ;)

[11/1/21, 2:59:45 PM] BInyamin EN Corp: 

[11/1/21, 2:59:46 PM] Eliezer: American saying not sure if you can 

relate to it lol

[11/1/21, 2:59:55 PM] BInyamin EN Corp: Actually I am

[11/1/21, 3:00:16 PM] BInyamin EN Corp: Of course, I lived two years 

in the US

[11/1/21, 3:02:02 PM] Eliezer: OK thanks so we’re good remember this 

is just an initial test phase order if all goes smoothly we can do a 

Case 1:22-cv-23661-PCH Document 28-4 Entered on FLSD Docket 02/03/2023 Page 4 of 23
heck of a lot more immediately

[11/1/21, 3:02:31 PM] BInyamin EN Corp: ה״זעב

[11/1/21, 3:03:04 PM] Eliezer: Exactly iyh

[11/1/21, 3:03:25 PM] Eliezer: I would much rather work with people 

from the tribe believe me

[11/1/21, 3:03:53 PM] BInyamin EN Corp: <attached: 00000056-

AUDIO-2021-11-01-15-03-53.opus>

[11/1/21, 4:00:49 PM] Eliezer: <attached: 00000057-

AUDIO-2021-11-01-16-00-48.opus>

[11/1/21, 4:01:05 PM] Eliezer: <attached: 00000058-

AUDIO-2021-11-01-16-01-05.opus>

[11/1/21, 4:02:24 PM] Eliezer: <attached: 00000059-

AUDIO-2021-11-01-16-02-23.opus>

[11/1/21, 4:05:14 PM] BInyamin EN Corp: <attached: 00000060-

AUDIO-2021-11-01-16-05-14.opus>

[11/3/21, 10:11:31 AM] Eliezer: <attached: 00000061-

AUDIO-2021-11-03-10-11-30.opus>

[11/3/21, 10:12:53 AM] BInyamin EN Corp: Wow, no idea,

I will ask for the packing list from the logistic company and I’ll 

send you

[11/3/21, 10:13:23 AM] Eliezer: OK perfect thank you just so I can 

prepare a know what to expect with my logistics

[11/3/21, 10:13:34 AM] Eliezer: And know what to expect

[11/3/21, 10:13:38 AM] BInyamin EN Corp: Absolutely

[11/3/21, 10:15:25 AM] BInyamin EN Corp: I’ll make sure that you have 

the paperwork (not 100% sure today cause it’s late in China, but I’ll 

try).

Anyhow, I will also check later with the distributor I’m working with 

in the UK, but I’m in meetings in the next hours, so I’ll do it a bit 

later (with him it’s never 5 minutes call)

[11/3/21, 2:49:46 PM] Eliezer: Please let me know when you’re able to 

as far as how many are going to make it on today’s flight and how many 

on tomorrow’s flight - obviously if they can all get on today that 

would be best but I understand either way

[11/3/21, 2:50:08 PM] Eliezer: Since you did tell me it would be split 

up

[11/3/21, 2:55:36 PM] BInyamin EN Corp: I won’t have the details 

before China wakes up, 

Haven’t got the AWB yet

[11/3/21, 2:59:52 PM] Eliezer: Ok

[11/4/21, 9:08:12 AM] BInyamin EN Corp: In a meeting,

I’ll call you in 45 minutes +-

[11/4/21, 9:08:55 AM] Eliezer: Good morning Benjamin I’m just 

following up to see what made it on yesterday and if you could please 

send me those documents of the airway bill and also how much is making 

it on today, thanks

[11/4/21, 9:08:58 AM] Eliezer: Ok

[11/4/21, 9:42:08 AM] BInyamin EN Corp: Missed voice call

[11/4/21, 9:47:17 AM] BInyamin EN Corp: <attached: 00000075-

PHOTO-2021-11-04-09-47-17.jpg>

Case 1:22-cv-23661-PCH Document 28-4 Entered on FLSD Docket 02/03/2023 Page 5 of 23
[11/4/21, 12:17:55 PM] Eliezer: Can me u snd Anchi talk?

[11/4/21, 12:18:04 PM] Eliezer: He has something to share with u

[11/4/21, 12:18:11 PM] Eliezer: Only us 3 speak

רקוב בוט ןימינב :Eliezer] AM 8:51:05 11/5/21,[

[11/5/21, 8:51:23 AM] Eliezer: Please call me

[11/5/21, 9:08:53 AM] BInyamin EN Corp: Good morning, I’ll call in 

about 30min

[11/7/21, 7:56:34 AM] Eliezer: Shavua Tov BInyamin. This isn’t a good 

sign still nothing. Again I wake up after Shabbat with no messages, 

airway bills or information. Even an airway bill to Mexico still 

nothing as I’ve suspected and been saying all along. Again believe me 

I would love to be wrong but as it seems I’m not.

[11/7/21, 8:02:05 AM] BInyamin EN Corp: Shavua tov and chodesh tov,

Believe me I think you will be wrong this time.

No one in the US will have the new package before you will.

I didn’t want to start calling you after Shabbat, that’s the only 

reason I haven’t sent a massage, and my apologies for Friday, I forgot 

Shabbat is entering earlier.

The Mexico solution is new, I need to reroute some of the orders , but 

I found a creative way to cross the issue.

I know I’m asking a lot, but be a little bit more patient with us and 

you won’t regret.

I’m in a factory tour in the next few hours, and I’ll call from the 

hotel with all the information.

I’ll prove you not only that you haven’t mistaken, you will gain more 

(forward you call with Nate on Friday).

I’ll call you when I’ll get back to the hotel

[11/7/21, 8:22:14 AM] Eliezer: BInyamin I hear you but timing is 

everything and if I can’t deliver ontime very soon I will have a 

problem. - call me later. (Even with the back up solution but with re 

routing through Mexico according to Liana was supposed to happen over 

the weekend and it hasn’t which is why it’s still concerning) - will 

speak Later.

[11/8/21, 7:29:18 AM] BInyamin EN Corp: <attached: 00000085-

AUDIO-2021-11-08-07-29-18.opus>

[11/8/21, 8:09:03 AM] Eliezer: <attached: 00000086-

AUDIO-2021-11-08-08-09-03.opus>

[11/8/21, 2:41:20 PM] BInyamin EN Corp: Where do you need to 200k? 

Where is your buyer warehouse, NY?

[11/8/21, 2:41:48 PM] BInyamin EN Corp: On a call

[11/8/21, 2:41:59 PM] Eliezer: Ok

[11/8/21, 2:42:01 PM] BInyamin EN Corp: One sec mate

[11/8/21, 2:42:21 PM] Eliezer: My client was n Virginia so either 

Virginia or my warehouse in NY either one works

[11/8/21, 2:42:39 PM] BInyamin EN Corp: Ok

[11/8/21, 2:42:44 PM] Eliezer: Virginia only a 5 hour drive from NY

[11/8/21, 2:42:49 PM] Eliezer: So I can send my drover

[11/8/21, 2:42:51 PM] Eliezer: Driver

[11/8/21, 2:43:08 PM] Eliezer: Actually 6-7 hours but it’s ok either 

way

Case 1:22-cv-23661-PCH Document 28-4 Entered on FLSD Docket 02/03/2023 Page 6 of 23
[11/8/21, 2:43:50 PM] BInyamin EN Corp: I use to live in Virginia for 

few months:)

But it will probably will come from San Diego so I need to check which 

one is better.

Checking

[11/8/21, 3:09:17 PM] BInyamin EN Corp: Missed voice call

[11/9/21, 2:51:46 PM] BInyamin EN Corp: Missed voice call

[11/9/21, 3:03:47 PM] Eliezer: Hi I just tried u back

[11/11/21, 9:47:37 AM] Eliezer: Hi please call thanks

[11/11/21, 9:47:41 AM] BInyamin EN Corp: Will call in an hour, in the 

airport

[11/11/21, 9:48:00 AM] Eliezer: Ok please do thanks

[11/11/21, 1:36:01 PM] Eliezer: Please call

[11/11/21, 1:36:10 PM] Eliezer: R u still on flight?

[11/11/21, 1:36:15 PM] BInyamin EN Corp: I’m on the flight, I’ll call 

in 3 hours when I’ll land

[11/11/21, 1:36:18 PM] BInyamin EN Corp: Yes

[11/11/21, 1:36:57 PM] Eliezer: OK I think I will accept your offer on 

a compromise where I withdraw only 1 million for the cash flow and I 

leave the rest in there to keep this moving forward before I call the 

lawyer to amend the escrow agreement are you sure you’re OK with this?

[11/11/21, 1:37:10 PM] Eliezer: I’m taking a leap of faith here and 

trusting that in the end everything will work out

[11/11/21, 1:37:56 PM] BInyamin EN Corp: I appreciate that more than 

anything else. The only way to do business.

[11/11/21, 1:38:26 PM] BInyamin EN Corp: I am.

You can screen shot that I approved it

[11/15/21, 9:29:37 AM] Eliezer: Good morning BInyamin can you talk?

[11/15/21, 9:30:11 AM] Eliezer: I have to speak with you before I talk 

with my client and they have already tried to call me three times so 

let me know thanks thanks

[11/15/21, 9:33:49 AM] BInyamin EN Corp: Hey,

I’ll call in about an hour

[11/15/21, 9:51:53 AM] Eliezer: Are you possibly available sooner?

[11/15/21, 10:01:57 AM] BInyamin EN Corp: Yes, I’ll try in about 10-15 

minutes

[11/15/21, 10:02:26 AM] BInyamin EN Corp: <attached: 00000117-

PHOTO-2021-11-15-10-02-26.jpg>

[11/15/21, 11:41:24 AM] BInyamin EN Corp: Send me your email address 

please

[11/15/21, 11:55:38 AM] Eliezer: Eliezernerenberg@yahoo.com

[11/17/21, 10:46:30 AM] BInyamin EN Corp: Hey, good morning 

I have a client that need ready stock for POC and I don’t have at the 

moment. Can you assist with that?

[11/17/21, 10:46:45 AM] BInyamin EN Corp: He needs 5m test total

[11/17/21, 12:13:50 PM] Eliezer: I’m assuming we’re talking about only 

the FDA eua approved products correct? because I don’t deal with the 

non-approved ones

[11/17/21, 12:15:13 PM] BInyamin EN Corp: Of course

[11/17/21, 12:31:55 PM] Eliezer: Can u please set up a call so I can 

Case 1:22-cv-23661-PCH Document 28-4 Entered on FLSD Docket 02/03/2023 Page 7 of 23
vet it? U me and the buyer. Thanks

[11/17/21, 12:32:24 PM] Eliezer: From my experience BInyamin if you’re 

not speaking to the actual buyer these deals never happen

[11/17/21, 12:32:53 PM] Eliezer: That’s why I would like to set up a 

call to understand this request but just to price without any 

information I might as well buy a lottery ticket

[11/17/21, 12:33:19 PM] Eliezer: But yes there are some options

[11/17/21, 12:34:23 PM] Eliezer: Any movement on the Flow flex?

[11/17/21, 12:40:21 PM] BInyamin EN Corp: Few minutes please

[11/18/21, 3:12:20 PM] BInyamin EN Corp: Found the outline:

Diagnostic evaluation criteria

1. Full product data sheet, packaging, and IFU

2. Clinical data: white paper, assumptions, primary data sets, 

submitted methodology

3. Manufacturers history 

4. Plant certifications 

5. Additional products made at same facility 

6. All product filings linked to facility

7. Any adverse event filings made against company or facility

8. Any quality or labor shortcomings, warnings, fines, or citations

9. All current files but not awarded certifications attached to 

facility

[11/22/21, 2:20:56 PM] Eliezer: Hi BInyamin please call me thank you

[11/22/21, 2:40:06 PM] BInyamin EN Corp: Hey hey,

I’ll call you in about an hour

[11/23/21, 10:32:42 AM] Eliezer: Good morning BInyamin if you can 

please call me

[11/23/21, 10:42:51 AM] BInyamin EN Corp: 20 minutes

[11/23/21, 10:43:25 AM] Eliezer: Ok thanks

[11/23/21, 11:34:13 AM] BInyamin EN Corp: <attached: 00000136-

PHOTO-2021-11-23-11-34-13.jpg>

[11/23/21, 11:34:13 AM] BInyamin EN Corp: <attached: 00000137-

PHOTO-2021-11-23-11-34-13.jpg>

[11/23/21, 11:34:13 AM] BInyamin EN Corp: <attached: 00000138-

PHOTO-2021-11-23-11-34-13.jpg>

[11/23/21, 11:34:13 AM] BInyamin EN Corp: <attached: 00000139-

PHOTO-2021-11-23-11-34-13.jpg>

[11/23/21, 11:34:13 AM] BInyamin EN Corp: <attached: 00000140-

PHOTO-2021-11-23-11-34-13.jpg>

[11/24/21, 10:19:33 AM] BInyamin EN Corp: Missed voice call

[11/24/21, 10:19:58 AM] BInyamin EN Corp: What’s the expiration date 

on the 150k?

[11/24/21, 10:20:39 AM] BInyamin EN Corp: And which state is the 

warehouse you said?

[11/26/21, 5:52:10 AM] BInyamin EN Corp: Wanted to give you an update 

if we won’t talk before Shabbat:

The logistics company picked up the goods from the warehouse,

2 flights are scheduled for Monday and Tuesday. Don’t know the split 

yet.

My office in Switzerland has your email if they will receive the AWB 

Case 1:22-cv-23661-PCH Document 28-4 Entered on FLSD Docket 02/03/2023 Page 8 of 23
while it’s Shabbat here.

Shabbat Shalom

[11/26/21, 8:45:29 AM] Eliezer: OK thank you for the update because 

you realize that based on the timeline you gave me it was that we 

would receive it here in America by the end of this week which is 

today so you can imagine everybody’s getting very antsy at this point 

so I really hope the stuff actually gets on these flights on Monday or 

Tuesday

[11/26/21, 8:52:37 AM] Eliezer: Please can you ask the logistics 

company for proof that they picked this up please ask them for a 

packing slip signed or some thing Showing that they have this

[11/26/21, 9:02:28 AM] Eliezer: <attached: 00000147-

AUDIO-2021-11-26-09-02-27.opus>

[11/29/21, 8:27:01 AM] Eliezer: Good morning please call me

[11/29/21, 8:27:35 AM] Eliezer: The fact that we still haven’t 

received anything from the logistics company proving that they picked 

up the stuff is concerning

[11/29/21, 8:27:49 AM] Eliezer: Again over Shabbat or the weekend I 

expected to receive some stuff and nothing came in

[11/29/21, 8:29:55 AM] Eliezer: Please call when u can

[11/29/21, 8:30:31 AM] BInyamin EN Corp: Hey good morning,

I’m at the Knesset so it will take me few hours.

I have spoke with them 2 hours ago and the said there is no delay and 

the first flight is leaving tonight. They said we will have the AWB 

tonight as well.

I don’t know why we haven’t got the paperwork yet, but they have no 

reason to lie (and if they will we will know in few hours, and they 

have fine on that).

As you know, AWB/BOL are usually provided after the loading.

I’m working with the distributor, not with the logistic company.

[11/29/21, 8:30:48 AM] BInyamin EN Corp: I updated Liana and I asked 

her to update you as well.

[11/29/21, 8:31:15 AM] BInyamin EN Corp: Sorry, that will take me few 

hours, I can’t pick up the phone freely here

[11/29/21, 8:32:23 AM] Eliezer: It’s not adding up I’m sorry I don’t 

believe it there’s something wrong here

[11/29/21, 8:32:29 AM] Eliezer: I believe you but I don’t believe them

[11/29/21, 8:32:53 AM] Eliezer: She told me yesterday it was getting 

on a flight on Monday and that I would have the paperwork yesterday 

day after day it’s always tomorrow tomorrow tomorrow after the weekend 

after Shabbat tomorrow tomorrow tomorrow there’s something wrong here 

I’m telling you right now BInyamin

[11/29/21, 8:33:09 AM] Eliezer: If the logistics company picked it up 

you would have paperwork proving that it simple and the fact they 

can’t give that to you there’s an issue

[11/29/21, 8:34:03 AM] Eliezer: Now again it’s tonight you said 

yourself, you’re not listening to yourself BInyamin it’s always 

tonight or tomorrow

[11/29/21, 8:34:26 AM] Eliezer: God for bid I’m not accusing you of 

Case 1:22-cv-23661-PCH Document 28-4 Entered on FLSD Docket 02/03/2023 Page 9 of 23
lying I’m telling you they’re telling everybody what they want to hear

[11/29/21, 8:34:51 AM] Eliezer: Today is Monday tonight it’s already 

Tuesday in China it’s almost Tuesday already

[11/29/21, 8:35:21 AM] BInyamin EN Corp: Eliezer, I’m forwarding to 

you exactly how I’m getting it.

I’m not manufacturing for the first day of my life in China, and I 

know how those companies are. I *do* believe, that based on my 

relationship and connection and signed documents and deposit, they 

won’t lie. They have told me (and I was forwarding to you) the status 

on ACON from the inside the whole time.

[11/29/21, 8:36:00 AM] Eliezer: I believe you I don’t believe them

[11/29/21, 8:36:17 AM] BInyamin EN Corp: That’s already good, but not 

enough:)

[11/29/21, 8:36:58 AM] BInyamin EN Corp: Let’s see what they will come 

with. If we won’t have paperwork tonight, you and I will jump on a 

call with them and decide what to do.

[11/29/21, 8:37:03 AM] Eliezer: OK so what day will you surrender and 

finally say that they’re lying because every day it’s always tonight 

or tomorrow so I want to know when you will finally say that they’re 

lying

[11/29/21, 8:37:11 AM] Eliezer: Will you finally agreed that if it 

doesn’t get on a plane tonight that they’re obviously lying

[11/29/21, 8:38:47 AM] BInyamin EN Corp: If we want have all 

documentation tonight, they are lying.

And tomorrow morning I have SGS inspector in their warehouse in China 

to verify 6m tests for government buyer I have. White box as well.

So double verification on them

[11/29/21, 8:39:22 AM] BInyamin EN Corp: And I really need your advice 

on the Turkish test (you have the samples and documentation).

[11/29/21, 8:43:29 AM] Eliezer: So far your inspections and logistics 

companies have not come through it’s a very simple thing if the 

logistics company picked it up from the factory then they would have 

paperwork verifying that and the fact that you can’t get this don’t 

you see how that’s a problem!?

[11/29/21, 8:43:45 AM] Eliezer: It’s very simple call your distributor 

and ask them for the paperwork from the logistics company that they 

picked it up I’m not understanding this

[11/29/21, 8:44:00 AM] Eliezer: Forget the flight and the airway bill 

that’s separate

[11/29/21, 8:44:12 AM] Eliezer: Because if that first part never 

happened then we’re dreaming to even think about a flight

[11/29/21, 8:46:17 AM] BInyamin EN Corp: That’s the most important. 

But I’ll ask them to send me something from the logistic company that 

they have taken it.

For me, I care about the AWB cause this is the part I’m paying the 

balance to them, that’s why I’m usually working with that (only real 

verification, except inspection)

[11/29/21, 8:47:02 AM] BInyamin EN Corp: And that’s the first time we 

are inspecting large quantities of the white box outside the factory, 

so it is important

Case 1:22-cv-23661-PCH Document 28-4 Entered on FLSD Docket 02/03/2023 Page 10 of 23
[11/29/21, 8:47:57 AM] Eliezer: I agree an airway bill is very 

important but you’re never gonna get it airway bill if you can’t even 

get a simple document with a signature that they picked up what they 

picked up from the factory if you can’t get this then it never 

happened hence why I’m very skeptical

[11/29/21, 8:48:08 AM] Eliezer: Please call me as soon as you’re able 

to we need to get on the phone

[11/29/21, 8:48:38 AM] Eliezer: Please get the paperwork from the 

logistics company nobody picked up a few million dollars worth of 

product without getting a signature

[11/29/21, 8:48:44 AM] BInyamin EN Corp: Ok, I’ll call you when I’ll 

have a break here

[11/29/21, 5:09:21 PM] Eliezer: Any luck on those docs from logistics?

[11/30/21, 7:43:17 AM] BInyamin EN Corp: Yes,

We were starting receiving the AWBs and bookings for tonight’s flight. 

My office preparing everything and will share with you shortly

[11/30/21, 7:44:22 AM] BInyamin EN Corp: <attached: 00000182-

PHOTO-2021-11-30-07-44-22.jpg>

[11/30/21, 7:56:35 AM] BInyamin EN Corp: 20 minutes

[11/30/21, 8:01:11 AM] Eliezer: <attached: 00000184-

PHOTO-2021-11-30-08-01-11.jpg>

[11/30/21, 8:01:17 AM] Eliezer: You agreed that if we woke up today 

and they didn’t get on the flight last night that they are lying, and 

now again your saying again tonight we agreed that they lied at this 

point why didn’t it get on the flight yesterday or why don’t we have 

the documentation from the courier that it was picked up? Anyone can 

go to dhl.com and put these stupid papers up here this is bullshit

[11/30/21, 8:01:41 AM] Eliezer: Ok yes please call thanks

[11/30/21, 8:10:00 AM] Eliezer: Nope we still never got the documents 

verifying it was picked up from the factory which is why everything 

else here is a bunch of nonsense

[12/1/21, 9:55:55 AM] Eliezer: BInyamin please call me immediately I’m 

about to shut this whole thing down

[12/1/21, 9:56:17 AM] BInyamin EN Corp: Few minutes please

[12/1/21, 9:56:29 AM] Eliezer: OK please right away in a few minutes

[12/1/21, 11:08:31 AM] Eliezer: Please call me I spoke with logistics 

company

[12/1/21, 11:08:40 AM] BInyamin EN Corp: Few minutes

[12/1/21, 11:08:48 AM] BInyamin EN Corp: Finishing a meeting

[12/1/21, 4:06:57 PM] Eliezer: I guess I was not the first one as I 

was promised to get product here locally in the USA - Acon USA has 

already successfully brought product here and are selling it locally 

and two companies I know already successfully purchased and selling. 

There is 200,000 now sitting in Tennessee at customs and two major 

distributors are selling it right now if you had such great contacts 

within acon why don’t you call them and get me that product

[12/1/21, 4:07:48 PM] Eliezer: They said it’s available for pick up in 

the beginning of next week after customs possible earlier

[12/1/21, 4:08:12 PM] Eliezer: Let your contacts at accon give us 

this

Case 1:22-cv-23661-PCH Document 28-4 Entered on FLSD Docket 02/03/2023 Page 11 of 23
[12/1/21, 4:09:13 PM] BInyamin EN Corp: I haven’t heard anything about 

that, but I’ll talk with Acon guy in the morning for explanations

[12/2/21, 12:02:37 PM] BInyamin EN Corp: <attached: 00000198-

PHOTO-2021-12-02-12-02-37.jpg>

[12/2/21, 12:03:20 PM] BInyamin EN Corp: Missed voice call

[12/2/21, 12:33:47 PM] Eliezer: Just tried u back

[12/2/21, 12:33:51 PM] Eliezer: Can u speak

[12/2/21, 12:54:02 PM] Eliezer: I have a call in seven minutes with my 

big client so can we speak before then please

[12/2/21, 12:54:08 PM] Eliezer: I just need to minutes of your time

[12/2/21, 12:54:30 PM] BInyamin EN Corp: Few minutes I’ll step outside

[12/2/21, 1:11:21 PM] Eliezer: Please send whatever you can hopefully 

it’s at least half or a few thousand pieces to

Genetworx

Attn: Ryan Forsthoff 

1000 Technology Drive

Glenn Allen, VA 23060

[12/2/21, 1:11:26 PM] Eliezer: Then please send one case to my office

[12/2/21, 1:12:01 PM] Eliezer: Eliezer Nerenberg 

5571 North University Dr. 

Suite 104 

coral Springs, FL 33067

[12/2/21, 1:26:34 PM] Eliezer: I spoke to them if we can get them at 

least the 5000 tests which is half of what you have here that will go 

along way

[12/2/21, 10:14:34 PM] Eliezer: Please make sure on that 5000 and have 

them send me tracking info as well

[12/3/21, 7:25:20 AM] BInyamin EN Corp: I have sent your details and 

the addresses to the US office, they will contact you in the morning 

and send the trucking paperwork

[12/3/21, 8:37:55 AM] Eliezer: OK can you please give me contact 

information of the US office in case I don’t hear from them and it’s 

already תבש by you

[12/3/21, 9:13:19 AM] BInyamin EN Corp: <attached: 00000212-

<vcf. הקירנה

[12/3/21, 9:13:24 AM] BInyamin EN Corp: םולש תבש

[12/8/21, 8:29:19 AM] Eliezer: Good morning BInyamin. Something is 

fishy. Call u soon.

[12/8/21, 8:30:27 AM] BInyamin EN Corp: Good morning,

I’m here.

Try in the next 30 minutes please cause after that I’m not going to be 

available for 2-3 hours

[12/8/21, 8:32:16 AM] Eliezer: I just tried

[12/9/21, 7:43:40 AM] Eliezer: All day I was promised tracking from 

Henrique spoke to him a couple times yesterday still have not received 

anything I’m done

[12/9/21, 7:43:53 AM] Eliezer: Like I said I’m being lied to Every day 

since Sunday I was promised the same thing still nothing

[12/9/21, 7:47:21 AM] BInyamin EN Corp: I don’t understand what’s 

Case 1:22-cv-23661-PCH Document 28-4 Entered on FLSD Docket 02/03/2023 Page 12 of 23
going on. I’m telling you that the first shipment already arrived to 

the first client. Let me talk with Enrique and the logistics this 

morning and call you with an answer

[12/9/21, 7:48:11 AM] Eliezer: It’s all bullshit exactly every day and 

promised the same thing I spoke to Enrique he still has not been able 

to provide me the tracking information

[12/9/21, 7:48:18 AM] Eliezer: It’s the same as always story after 

story after story

[12/9/21, 7:49:40 AM] BInyamin EN Corp: Eliezer if you won’t get the 

product this week, I’m taking a flight over there myself. Let me talk 

with Enrique to check what’s going on.

[12/9/21, 7:53:51 AM] Eliezer: Don’t bother because I’m not waiting 

any longer I’m gonna have to call it off I’m sorry

[12/9/21, 7:55:56 AM] BInyamin EN Corp: Eliezer it was already 

shipped. You have trusted me that long please keep trusting. You will 

have the 5,000 this week, and by Judy we are also ok with the 

logistics in China. We were entering this venture together, for not 

only this transaction.

[12/9/21, 7:56:30 AM] BInyamin EN Corp: I’m available to talk if you 

are able

[12/9/21, 7:57:04 AM] Eliezer: It’s a simple request if it was already 

shipped where is the tracking information

[12/9/21, 7:57:40 AM] BInyamin EN Corp: I agree, and I will get you 

the answer and the information of the logistics company

[12/9/21, 11:45:33 AM] Eliezer: It’s OK I’m speaking with judy she’s 

the only one that tells me the truth and give me a straight story and 

answers

[12/9/21, 11:45:39 AM] Eliezer: Henrique is a liar I don’t want to 

ever speak to him again

[12/9/21, 11:46:04 AM] Eliezer: It’s not even manipulation it’s a 

straight up lies from him

[12/9/21, 11:48:23 AM] BInyamin EN Corp: Judy updated me already. 

Already told Enrique to step back

[12/9/21, 10:28:27 PM] Eliezer: BInyamin I wasn’t going to text you I 

was just gonna let it be but I have to share with you that I’m very 

upset at you because regardless of what you say and the excuses you 

lied to me I know you have no control over China but you lied to me 

about the samples that were here in the US and then Enrique continued 

the lie and there’s no point in even telling you why but if you think 

about the things that you told me regarding this you flat out lied to 

me.

[12/10/21, 6:57:36 AM] BInyamin EN Corp: I apologise that I wasn’t 

involved enough. I never lied in my life, I was forwarding to massage 

I got. That’s just not who I am.

I do apologize that this is the service you got and I hope with Judy 

you will get the right service.

I do apologise and hopefully we will get it right.

[12/12/21, 5:39:16 PM] Eliezer: <attached: 00000234-

AUDIO-2021-12-12-17-39-15.opus>

[12/12/21, 5:43:00 PM] Eliezer: <attached: 00000235-

Case 1:22-cv-23661-PCH Document 28-4 Entered on FLSD Docket 02/03/2023 Page 13 of 23
AUDIO-2021-12-12-17-42-59.opus>

[12/12/21, 6:01:15 PM] Eliezer: Also we were not the first ones in the 

US as you promised to get these tests now again that I’m not accusing 

you of lying about because that you cannot control I’m just letting 

you know there’s much more going on than you r aware of and I have two 

groups that I work with that already have product in hand and they 

sent me pictures.

[12/12/21, 6:02:22 PM] Eliezer: <attached: 00000237-

PHOTO-2021-12-12-18-02-22.jpg>

[12/13/21, 5:30:27 AM] BInyamin EN Corp: I explained you how and who.

[12/13/21, 5:31:06 AM] BInyamin EN Corp: Don’t know what else to tell 

you Eliezer, you can decide if to continue with Judy or not.

[12/20/21, 12:27:48 PM] BInyamin EN Corp: <attached: 00000240-

PHOTO-2021-12-20-12-27-48.jpg>

[12/20/21, 12:28:37 PM] Eliezer: I’m sorry I just hit reply all did 

not even realize I’ll make sure next time not to do that!

[12/20/21, 12:28:50 PM] Eliezer: I apologize Yes I stand corrected you 

did mention on your email this morning not to do that and I did not 

even realize

[12/20/21, 12:28:51 PM] BInyamin EN Corp: Thank you very much

[12/20/21, 12:29:00 PM] Eliezer: Next email will only be to you and 

David

[12/20/21, 12:29:14 PM] BInyamin EN Corp: Thanks

[12/22/21, 9:52:18 AM] BInyamin EN Corp: <attached: 00000246-

AUDIO-2021-12-22-09-52-18.opus>

[12/22/21, 11:00:32 AM] Eliezer: No problem thanks for the update

[12/22/21, 11:00:53 AM] Eliezer: When u r ready please send it to the 

first account that I emailed u

[12/22/21, 11:26:38 AM] BInyamin EN Corp: 

[12/23/21, 11:08:38 PM] Eliezer: Hi BInyamin. Please let me know when 

u can send back the deposit. Can u send us this tomorrow on Friday? 

Would be today when u wake up and see this by you.

[12/23/21, 11:10:17 PM] Eliezer: Also please make sure to send it back 

to us (Zeflon) from the original email that I sent and not the 2nd 

email.

[12/27/21, 9:59:48 AM] Eliezer: Hi BInyamin it’s been a full week can 

you please advise?

[12/27/21, 10:00:51 AM] BInyamin EN Corp: Sure, I’m waiting for the 

guys in the US to wake up so we can finalised. Probably tomorrow will 

be wired from Switzerland to your account

[12/29/21, 9:37:01 AM] Eliezer: Good morning Benjamin we still haven’t 

received anything

[12/29/21, 10:04:20 AM] BInyamin EN Corp: <attached: 00000255-

AUDIO-2021-12-29-10-04-20.opus>

[12/29/21, 10:09:32 AM] Eliezer: Ok thank u

[12/30/21, 11:43:33 AM] Eliezer: Please call thanks

[12/30/21, 11:43:31 AM] BInyamin EN Corp: Calling back in a few

[1/2/22, 2:02:01 PM] Eliezer: BInyamin it’s really not right that you 

have not sent back that money yet

[1/2/22, 2:02:13 PM] Eliezer: And I have not emailed the whole group 

Case 1:22-cv-23661-PCH Document 28-4 Entered on FLSD Docket 02/03/2023 Page 14 of 23
like you asked me not to do

[1/2/22, 2:02:21 PM] Eliezer: Please there should be no reason it’s 

been a couple weeks now

[1/2/22, 2:03:23 PM] Eliezer: I’ve been very patient since the 

beginning

[1/2/22, 2:06:25 PM] BInyamin EN Corp: Eliezer I have no idea why it 

haven’t been approved yet, I will send you the copy mail the date I 

gave an order to sent. Tomorrow I’ll check with the banker and update 

in your morning. My apologies

[1/2/22, 2:12:35 PM] Eliezer: OK BInyamin but I thought you’re in 

charge

[1/2/22, 2:13:03 PM] BInyamin EN Corp: I am responsible, indeed.

[1/3/22, 10:25:48 AM] Eliezer: Hi BInyamin. Please advise. Thanks

[1/3/22, 10:27:32 AM] BInyamin EN Corp: <attached: 00000267-

AUDIO-2022-01-03-10-27-32.opus>

[1/4/22, 9:02:11 AM] BInyamin EN Corp: <attached: 00000268-

AUDIO-2022-01-04-09-02-11.opus>

[2/1/22, 7:51:04 AM] Eliezer: Hi BInyamin. I already told judy in the 

weekend and I’m making sure she told you. Today is Tuesday and I 

requested the refund already for Monday and nothing came through yet. 

Can you please make sure to refund the $217,000 today?

[2/1/22, 7:51:59 AM] Eliezer: It’s been months now and nothing has 

worked and if you guys somehow do come through I’ll be happy to pay 

and proceed accordingly but until then I need the refund. Thanks

[2/1/22, 8:57:25 AM] BInyamin EN Corp: <attached: 00000271-

AUDIO-2022-02-01-08-57-25.opus>

[2/1/22, 9:04:39 AM] Eliezer: <attached: 00000272-

AUDIO-2022-02-01-09-04-38.opus>

[2/3/22, 9:52:44 AM] Eliezer: Hi BInyamin I still haven’t received the 

refund and it’s already Thursday can you please advise

[2/7/22, 9:51:59 AM] Eliezer: Please call me

[2/7/22, 10:09:46 AM] BInyamin EN Corp: Hey, will call you back in few 

hours, I’m on reserve

[2/7/22, 1:39:10 PM] BInyamin EN Corp: Missed voice call

[2/9/22, 9:52:34 AM] Eliezer: Hi BInyamin, so what’s the story? 2 days 

ago we spoke and you said that you were going to be talking to Ana 

yesterday and then based on that let me know. Thanks

[2/10/22, 7:03:54 AM] BInyamin EN Corp: <attached: 00000278-

AUDIO-2022-02-10-07-03-54.opus>

[2/14/22, 11:48:53 AM] BInyamin EN Corp: Calling back in an hour

[2/14/22, 11:48:54 AM] Eliezer: Still no refund BInyamin

[2/14/22, 11:49:43 AM] BInyamin EN Corp: I already approve to wire 

after no clear response from Ana. You will have it in your account 

this week no worries.

[2/14/22, 11:50:56 AM] Eliezer: This week isn’t ok BInyamin every week 

it becomes this week that’s not ok, please send it immediatelyas as i 

was promised. I’ve been so patient with you guys it’s not right that 

you keep putting me off

[2/16/22, 10:02:55 AM] Eliezer: Why haven’t I been refunded yet?

[2/16/22, 10:47:34 AM] BInyamin EN Corp: Eliezer you will.

Case 1:22-cv-23661-PCH Document 28-4 Entered on FLSD Docket 02/03/2023 Page 15 of 23
And if you think that you are going to threat though David or talk 

shit on us, that’s going to fast things you are wrong.

Yes. You have been patient.

Yes. You will have your refund.

But for all that time you were speaking to Ana directly and agreed to 

wait to see if she can fulfill. I have been completely transparent 

with you the all way. And I also said that it will take few days for 

the refund cause we need to pay it from our own funds (we haven’t got 

the refund yet as well).

[2/16/22, 10:51:53 AM] Eliezer: How did I threaten anybody I will 

screenshot you exactly what I sent to david when I sent him is very 

very normal look here I didn’t threaten anybody

[2/16/22, 10:52:53 AM] Eliezer: <attached: 00000286-

AUDIO-2022-02-16-10-52-52.opus>

[2/16/22, 10:53:32 AM] Eliezer: <attached: 00000287-

AUDIO-2022-02-16-10-53-31.opus>

[2/16/22, 10:53:56 AM] Eliezer: <attached: 00000288-

PHOTO-2022-02-16-10-53-56.jpg>

[2/16/22, 10:54:15 AM] Eliezer: Here is the screenshot of the messages 

full disclosure that I sent David today how exactly is this a threat 

please tell me!?

[2/17/22, 4:50:48 PM] Eliezer: Still haven’t received the wire

[2/17/22, 4:50:53 PM] Eliezer: And it’s Thursday

[2/18/22, 7:59:35 AM] Eliezer: <attached: 00000292-

PHOTO-2022-02-18-07-59-35.jpg>

[2/18/22, 8:00:04 AM] Eliezer: Benjamin this refund has nothing to do 

with my refund you promised me you promised me you promised me what is 

going on then even in the beginning of this week you said definitely 

this week

[2/18/22, 8:57:59 AM] BInyamin EN Corp: Missed voice call

[2/18/22, 9:02:37 AM] BInyamin EN Corp: One sec on the line

[2/22/22, 7:03:19 PM] Eliezer: Hi BInyamin I still don’t have the 

refund

[2/23/22, 8:22:47 AM] BInyamin EN Corp: On a meeting, will call back

[2/23/22, 8:22:50 AM] Eliezer: Good morning BInyamin please call me 

with an update I still have not gotten refunded

[2/23/22, 8:22:54 AM] Eliezer: Ok

[2/24/22, 6:45:17 AM] BInyamin EN Corp: Eliezer, Nate will call you 

this morning with updates. I’m sorry for not being available, 

something personal in the family. Will call you Friday anyhow.

Good morning

[3/7/22, 11:20:22 PM] Eliezer: Still no refund

[3/22/22, 11:07:56 AM] Eliezer: Hi BInyamin please call me

[3/22/22, 11:23:07 AM] BInyamin EN Corp: Good morning, will call in 

couple of hours, I’m in reserve without good signal

[3/22/22, 11:23:47 AM] Eliezer: Can you please advise when I will 

receive the refund? please it’s been months and I’ve been so patient 

with you guys

[3/22/22, 11:24:15 AM] Eliezer: I have some thing that I have to put 

the money into so I need it right away

Case 1:22-cv-23661-PCH Document 28-4 Entered on FLSD Docket 02/03/2023 Page 16 of 23
[3/22/22, 11:28:13 AM] BInyamin EN Corp: The board already approved 

the refund though different company. I’m waiting for Nate to call me 

tonight if they solved the tax issue.

In addition, without related to the refund from the other company, we 

put lawsuit against GTS with very good Chinese law firm that will make 

sure we will refund you not only the amount you paid, but also losses 

that was created to you and us.

[3/22/22, 11:41:18 AM] BInyamin EN Corp: This refund is closing. We 

are doing everything in our power, even to take from another company 

of us, in order to finish it without waiting to the Chinese.

We are taking it on our back, even though you know it’s not our fault 

and we payed to the factory.

[3/22/22, 11:45:20 AM] Eliezer: The arrangement was all along between 

us and that you will refund us even in the beginning when I was very 

hesitant of this whole deal you assured me that regardless of what 

your dealings was that you were going to get me back the money because 

my deal was with your company and then even Netanel said the same 

thing so whatever happens between you and Chinah that’s your business 

but if you guys can please as per arrangement get the money to me 

right away, thanks

[3/22/22, 11:45:26 AM] Eliezer: I really need it now

[3/22/22, 11:45:35 AM] Eliezer: I’ve been extremely patient until now 

but now we really need it

[3/22/22, 1:44:39 PM] BInyamin EN Corp: Understood. 

I’ll call Nate shortly and I’ll check how can I push immediately with 

the tax advisor

[3/22/22, 2:07:12 PM] Eliezer: Thank u

[3/23/22, 7:16:01 AM] BInyamin EN Corp: Good morning,

Let me know when you can talk

(I’ll be available in about an hour)

[3/23/22, 9:59:40 AM] Eliezer: Now is good

[3/23/22, 10:00:18 AM] BInyamin EN Corp: Will call back

[3/28/22, 1:37:21 PM] Eliezer: Hi BInyamin. It’s Monday already can 

you please let me know what the status is what we talked about Friday. 

Thanks

[3/28/22, 4:26:11 PM] Eliezer: <attached: 00000317-

PHOTO-2022-03-28-16-26-11.jpg>

[3/28/22, 4:26:25 PM] Eliezer: <attached: 00000318-

PHOTO-2022-03-28-16-26-25.jpg>

[3/28/22, 4:27:28 PM] BInyamin EN Corp: Eliezer I’m on reserve because 

what’s going on in Israel, I’ll call Nate first thing in the morning

[3/28/22, 4:27:29 PM] Eliezer: <attached: 00000320-

AUDIO-2022-03-28-16-27-29.opus>

[3/28/22, 5:33:55 PM] Eliezer: <attached: 00000321-

PHOTO-2022-03-28-17-33-55.jpg>

[3/28/22, 5:34:12 PM] Eliezer: He’s not keeping his word and u guys r 

not

[3/28/22, 5:52:01 PM] Eliezer: Good luck

[3/29/22, 7:51:45 AM] BInyamin EN Corp: Taking care of it

Case 1:22-cv-23661-PCH Document 28-4 Entered on FLSD Docket 02/03/2023 Page 17 of 23
[3/30/22, 11:40:55 AM] Eliezer: Please Binyamin

[3/31/22, 9:42:16 AM] BInyamin EN Corp: <attached: 00000326-

AUDIO-2022-03-31-09-42-16.opus>

[3/31/22, 9:42:56 AM] Eliezer: Ok thanks yes please do

[3/31/22, 11:31:51 AM] Eliezer: Mazal Tov. Beautiful baby girl just 

born 11:03 am weighing 6 lbs. 13 oz. both mom and baby are doing 

great.

[3/31/22, 11:35:22 AM] BInyamin EN Corp: BH!!!

Mazal tov 

[4/1/22, 11:47:45 AM] Eliezer: <attached: 00000330-

AUDIO-2022-04-01-11-47-44.opus>

[4/1/22, 12:24:23 PM] Eliezer: <attached: 00000331-

AUDIO-2022-04-01-12-24-22.opus>

[4/1/22, 12:24:23 PM] Eliezer: <attached: 00000332-

AUDIO-2022-04-01-12-24-22.opus>

[4/1/22, 12:24:31 PM] Eliezer: These last two voicenotes I just left 

for Netanel

[4/1/22, 12:24:57 PM] Eliezer: And I’m asking you the same question 

please get this resolved as you promised because if you don’t you guys 

believe me no other option and trust me I don’t want to take that 

route this is not a threat that’s why am asking what should I do to 

protect myself because I need this money back BInyamin I’ve been 

begging you

[4/3/22, 6:25:39 AM] BInyamin EN Corp: I’m on top of it. Promise.

[4/3/22, 11:18:43 AM] Eliezer: Ok thank u

[4/4/22, 11:44:28 AM] Eliezer: Good morning BInyamin. I just tried 

calling. Can u please call me back today? Thanks

[4/6/22, 1:20:52 PM] BInyamin EN Corp: Eliezer please watch the news 

on Israel, 

Im a commander of 270 soldiers that are participating this actions.

All my life are on hold, I haven’t seen my family for two weeks, and 

all our business activities is falling on Nate.

I’ll try to find some time tomorrow so the three of us can talk and 

check what we can do.

My apologies

[4/6/22, 1:22:41 PM] Eliezer: Hi BInyamin I’m sorry about what you’re 

dealing with but it takes a second for Nate to send a wire and he 

keeps promising and promising are not delivering and I don’t know what 

else to do you guys are leaving me no other options, It’s very simple 

all has to do is send money we don’t even need to speak we beat us up 

already you know

[4/6/22, 1:22:52 PM] Eliezer: Nothing to do on a personal matter 

BInyamin I appreciate what you’re doing and I wish you lots of luck 

this is strictly business

[4/6/22, 1:23:46 PM] Eliezer: When we did this transaction you 

promised me that $200,000 that you guys were in a good position that 

if something went wrong it’s small money and you could refunded 

immediately I’ve been getting the runaround and promise after promise 

and nobody’s keeping there word , and you know that I don’t need to 

convince you I don’t know what Nate‘s deal is but he not a man of his 

Case 1:22-cv-23661-PCH Document 28-4 Entered on FLSD Docket 02/03/2023 Page 18 of 23
word and nobody here has been

[4/6/22, 1:29:29 PM] Eliezer: Again BInyamin I’m not minimizing 

anything that you’re doing for the sake of our country that’s amazing 

and I give you lots of credit this is nothing to do with that this is 

business and all I’m saying is there’s no need for us to speak all he 

has to do is send money

[4/14/22, 6:10:12 PM] Eliezer: I still have received not a dime

[4/20/22, 11:50:34 AM] Eliezer: Still no refund

[4/20/22, 11:50:47 AM] Eliezer: It’s a real chutzpah

[4/28/22, 6:18:26 PM] Eliezer: 2022-04-28 Demand Ltr to En Corp USA, 

et al - Signed.pdf • 2 pages <attached: 00000346-2022-04-28 Demand Ltr 

to En Corp USA, et al - Signed.pdf>

[5/15/22, 11:43:31 AM] BInyamin EN Corp: Hey, I’ll call you back in 

couple of hours

[5/16/22, 9:04:34 AM] Eliezer: Good morning please call me

[5/16/22, 9:18:53 AM] BInyamin EN Corp: Good morning, few minutes

[5/16/22, 9:19:45 AM] BInyamin EN Corp: Missed voice call

[5/16/22, 9:26:03 AM] BInyamin EN Corp: I called you back. I will soon 

enter a meeting and be available again around 21:00 IL time

[5/16/22, 11:57:58 AM] Eliezer: Call me important

[5/16/22, 12:06:17 PM] BInyamin EN Corp: One minute please

[5/18/22, 10:21:28 AM] Eliezer: What’s the best way to have that call 

this evening like in which format should we use? If I circulate a dial 

in number I’m not sure that will work from Israel what do you suggest?

[5/18/22, 10:27:21 AM] BInyamin EN Corp: What’s up, simply to call the 

group

[5/18/22, 10:50:56 AM] Eliezer: Ok 

[5/26/22, 3:16:55 PM] BInyamin EN Corp: Didn’t forget our agreement,

David is extremely sick, so I hope the paperwork will be ready by 

Monday.

Shabbat shalom

[5/26/22, 3:23:32 PM] Eliezer: David it’s simple please post the 

payment plan today than the formal agreement and paperwork David can 

do on Monday but today’s a seven days and it’s important for him to do 

it today because by Monday will already be past the 30 days from our 

original demand letter so please do it now so we have no issues OK!? 

Just the simple payment plan propose and we can formalize it in a 

document on Monday that don’t worry about it just please propose with 

a payment plan is and we will formalize it in a document on Monday OK

[5/26/22, 3:23:42 PM] Eliezer: I’m mena BInyamin sorry

[5/26/22, 3:23:49 PM] Eliezer: On the group chat

[5/31/22, 10:30:51 AM] Eliezer: Please call me

[5/31/22, 10:30:55 AM] BInyamin EN Corp: I’m boarding a flight, I’ll 

be available in 5 hours +-

[5/31/22, 10:34:18 AM] Eliezer: Benjamin it’s not right that you 

should not make a payment for another 6 weeks from now!? After all 

the patients that I’ve given towards this and working with you and I’m 

even now OK accepting the 50,000 a month that’s no problem and where I 

give in but I need you to please move that initial payment back a 

little bit. There’s no excuse or reason why the first payment should 

Case 1:22-cv-23661-PCH Document 28-4 Entered on FLSD Docket 02/03/2023 Page 19 of 23
not come for another six weeks!? Please propose to me a better date 

for the first payment!?

[5/31/22, 10:45:11 AM] Eliezer: And if u can’t make an earlier payment 

then I propose making the initial payment a bit larger like for 67k 

then the next 3 for 50 this way the last payment will be oct 15.

[5/31/22, 10:46:42 AM] Eliezer: <attached: 00000365-

AUDIO-2022-05-31-10-46-41.opus>

[5/31/22, 10:47:12 AM] Eliezer: Please when you get a chance listen to 

the voice not let me know what you decide and we could have the 

lawyers formalize it as planned

[6/2/22, 11:58:45 AM] Eliezer: Hi please call when u get a second , 

thanks

[6/2/22, 12:15:15 PM] BInyamin EN Corp: 

[6/7/22, 9:40:22 AM] BInyamin EN Corp: Can call you back in an hour

[6/7/22, 9:41:18 AM] Eliezer: Shavua Tov BInyamin. Please call

[6/7/22, 9:41:24 AM] Eliezer: Ok thanks

[6/29/22, 10:01:40 AM] Eliezer: Good morning BInyamin, David told Ari 

that you want to speak with me today, let me know what time is good 

for u. I will be tied up for only the next hour but I’ll be free after 

11 AM Eastern anytime

[6/29/22, 1:25:08 PM] BInyamin EN Corp: I’m on a zoom, will call you 

after

[6/29/22, 1:25:18 PM] Eliezer: Ok 

[6/29/22, 3:40:04 PM] Eliezer: Don’t forget

[6/29/22, 3:55:50 PM] BInyamin EN Corp: If I’m not gonna call today, 

I’ll call first thing in the morning. Some important calls I must 

finish today

[7/14/22, 12:58:53 PM] BInyamin EN Corp: Coal

[7/14/22, 12:59:08 PM] Eliezer: Cooking coal?

[7/14/22, 12:59:34 PM] BInyamin EN Corp: <attached: 00000379-

PHOTO-2022-07-14-12-59-34.jpg>

[7/14/22, 12:59:39 PM] Eliezer: $110 per metric ton before war and now 

it’s $450

[7/14/22, 1:02:16 PM] BInyamin EN Corp: Yes

[7/15/22, 10:25:48 AM] BInyamin EN Corp: <attached: 00000382-

AUDIO-2022-07-15-10-25-48.opus>

[7/15/22, 10:27:52 AM] Eliezer: <attached: 00000383-

AUDIO-2022-07-15-10-27-52.opus>

[7/15/22, 10:34:36 AM] BInyamin EN Corp: 

[7/18/22, 12:42:37 PM] BInyamin EN Corp: AltecoG_Dar Al Ryiadh_v.6.pdf 

• 26 pages <attached: 00000385-AltecoG_Dar Al Ryiadh_v.6.pdf>

[7/18/22, 12:42:50 PM] BInyamin EN Corp: 22781134 _JAM72S30 530-555 MR 

Global_EN_20210910A(2278).pdf • 2 pages <attached: 00000386-22781134 

_JAM72S30 530-555 MR Global_EN_20210910A(2278).pdf>

[7/18/22, 12:42:50 PM] BInyamin EN Corp: 

EN_Datasheet_Vertex_DE19_202102 web.pdf • 2 pages <attached: 00000387-

EN_Datasheet_Vertex_DE19_202102 web.pdf>

[7/18/22, 12:42:51 PM] BInyamin EN Corp: 

EN_Ultra_V_STP550S_C72_Pmh+.pdf • 2 pages <attached: 00000388-

Case 1:22-cv-23661-PCH Document 28-4 Entered on FLSD Docket 02/03/2023 Page 20 of 23
EN_Ultra_V_STP550S_C72_Pmh+.pdf>

[7/18/22, 12:42:51 PM] BInyamin EN Corp: BISTAR_TP7F72M & 

TP7F72M(H)_10BB_20220301.pdf • 2 pages <attached: 00000389-

BISTAR_TP7F72M & TP7F72M(H)_10BB_20220301.pdf>

[7/18/22, 12:42:51 PM] BInyamin EN Corp: 腾晖光伏画册双语20220101.pdf • 

16 pages <attached: 00000390-腾晖光伏画册双语20220101.pdf>

[7/18/22, 12:43:02 PM] BInyamin EN Corp: Will call in about an hour

[7/18/22, 2:06:17 PM] Eliezer: OK please do don’t forget! 

also please message David since we spoke Ari my lawyer has been trying 

to get with him but he hasn’t responded

[7/18/22, 2:30:55 PM] BInyamin EN Corp: NP

[7/18/22, 2:32:16 PM] Eliezer: Can you speak now

[7/18/22, 2:33:21 PM] BInyamin EN Corp: Few minutes I’ll call you from 

the car

[7/18/22, 2:39:27 PM] Eliezer: OK please do thanks because soon after 

that I won’t be able to speak but I have time now

[7/18/22, 2:46:00 PM] Eliezer: Give me a sec I’ll call you back

[7/18/22, 2:46:17 PM] BInyamin EN Corp: Ok

[7/18/22, 3:03:37 PM] Eliezer: Give me two minutes I’ll be back in WiFi hold on

[7/19/22, 4:17:58 PM] Eliezer: <attached: 00000400-

AUDIO-2022-07-19-16-17-58.opus>

[7/19/22, 4:27:49 PM] BInyamin EN Corp: I spoke with him this morning, 

don’t know why he is dragging his feet. I’ll call him again in the 

morning

[7/20/22, 12:06:50 PM] Eliezer: Hi Binyamin Still nothing I’m not sure 

what’s going on

[7/20/22, 12:07:20 PM] BInyamin EN Corp: On a meeting, will check with 

David

[7/20/22, 12:10:19 PM] Eliezer: This isn’t right

[7/20/22, 12:11:21 PM] Eliezer: Aboudi not responding and I’m starting 

to loose faith

[7/21/22, 3:02:13 AM] BInyamin EN Corp: Let me know if he sent or not,

I’ll be in his office at 18:00 my time.

[7/25/22, 10:55:50 AM] Eliezer: BInyamin I already signed the document 

can you guys please sign it Ari sent it to David on Friday after I 

signed it

[7/25/22, 11:11:07 AM] BInyamin EN Corp: I haven’t got, can you send 

it to me please?

[7/25/22, 11:11:16 AM] BInyamin EN Corp: Bz@encorpgroup.ch

[7/25/22, 11:35:19 AM] Eliezer: Settlement Agreement July 21 

22.docx.pdf • 5 pages <attached: 00000410-Settlement Agreement July 

21 22.docx.pdf>

[7/25/22, 11:35:43 AM] Eliezer: Please send to Enrique as well

[7/27/22, 11:31:24 AM] Eliezer: BInyamin please get me back the signed 

agreement

[7/27/22, 3:21:41 PM] Eliezer: BInyamin can you please send me the 

signed agreement?

[7/27/22, 3:53:11 PM] BInyamin EN Corp: I’m not home. I’ll do it from 

the office in the morning

Case 1:22-cv-23661-PCH Document 28-4 Entered on FLSD Docket 02/03/2023 Page 21 of 23
[7/27/22, 10:23:30 PM] Eliezer: OK so when I wake up I should have it 

here

[7/28/22, 7:45:41 AM] BInyamin EN Corp: Settlement Agreement July 21 

22.docx.pdf • 5 pages <attached: 00000416-Settlement Agreement July 

21 22.docx.pdf>

[7/28/22, 7:45:57 AM] BInyamin EN Corp: Have been sent to your email 

as wel

[7/28/22, 12:57:15 PM] Eliezer: Thanks

[7/28/22, 1:28:25 PM] Eliezer: Please arrange for the 1st payment as 

we discussed. Thanks

[7/29/22, 2:17:13 PM] Eliezer: <attached: 00000420-

PHOTO-2022-07-29-14-17-13.jpg>

[8/1/22, 11:14:45 AM] Eliezer: Hi BInyamin good morning what’s the 

status of your first payment? I thought we were past this already 

this was already supposed to be done on July 15 I understand we signed 

the agreement later that’s why we put the later date in there of 

yesterday but you did say it would be done immediately after we signed 

so please let me know what the status is!?

[8/1/22, 11:15:58 AM] BInyamin EN Corp: Hey,

Sorry on a meeting.

Should go out tomorrow so you will see it probably Wednesday

[8/1/22, 11:16:26 AM] BInyamin EN Corp: I have sent the agreement only 

on friday, that’s why

[8/2/22, 3:10:31 PM] BInyamin EN Corp: Missed voice call

[8/2/22, 3:10:38 PM] Eliezer: 5 min

[8/2/22, 3:10:41 PM] Eliezer: On a call

[8/2/22, 3:10:44 PM] BInyamin EN Corp: Ok

[8/4/22, 6:23:56 AM] BInyamin EN Corp: We got approved that the wire 

will leave tomorrow from our Swiss account. It’s 50k franks which a 

little over 54usd.

I apologize for the delay, but one of our clients delayed in his 

payment and I wanted to sign last week so we can put this behind us.

In other topic,

I had a meeting today with the solar guys I sent you . They want to 

start operations in the US, so it’s a good timing to check if you want 

to take a part or not.

Will be available in my late night if you want to discuss that.

[8/8/22, 10:40:48 AM] BInyamin EN Corp: I’m trying to understand 

what’s going on, no one is answering me yet

Sorry I was asleep , and I haven’t spoke with them for few days 

(reserve )

[8/8/22, 10:41:00 AM] BInyamin EN Corp: Will call once someone is 

answering

[8/8/22, 11:50:42 AM] Eliezer: There’s always different excuses it’s 

not right how you guys have been treating me I’m given everybody so 

much rope and now you guys are in violation again

[8/8/22, 11:51:02 AM] Eliezer: I’m the fool according to everyone

[8/8/22, 11:51:26 AM] Eliezer: There is another payment due in a week 

and I’m still chasing the first one

Case 1:22-cv-23661-PCH Document 28-4 Entered on FLSD Docket 02/03/2023 Page 22 of 23
[8/9/22, 7:00:57 AM] Eliezer: Please advise ASAP

[8/9/22, 7:01:23 AM] BInyamin EN Corp: I will.

[8/9/22, 7:01:54 AM] Eliezer: Ok I will isnt enough I need some 

answers immediately

[8/9/22, 6:58:19 PM] Eliezer: What’s the story still nothing

[8/9/22, 6:58:27 PM] Eliezer: How dare u guys treat me like this

[8/10/22, 1:56:13 AM] BInyamin EN Corp: Eliezer, we are fighting on it 

not less than you are fighting with us.

I’m trying to figure it out with Encorp USA that don’t respect our 

agreement of refunding you.

I’ll call you in your morning

[8/10/22, 7:53:38 AM] BInyamin EN Corp: Good morning, will you be 

available in 15 minutes?

[8/10/22, 7:55:31 AM] Eliezer: I’m at minyan just started

[8/10/22, 7:55:40 AM] Eliezer: 40 min

[8/10/22, 7:56:27 AM] BInyamin EN Corp: 

[8/10/22, 9:41:28 AM] Eliezer: I’m available driving in my car for the 

next 25 minutes

[8/10/22, 9:42:00 AM] BInyamin EN Corp: Finishing up a meeting, I’ll 

call in 15 minutes 

[8/15/22, 2:12:47 PM] Eliezer: Please call me ASAP

[8/15/22, 2:15:55 PM] BInyamin EN Corp: Will call you back in few 

minutes

[8/19/22, 10:58:26 AM] Eliezer: Please call me

[8/21/22, 6:28:58 AM] BInyamin EN Corp: Hey,

I’ll call you after 21:00

[8/22/22, 11:31:35 AM] BInyamin EN Corp: I can talk only after 21:00 

Eliezer

[8/23/22, 11:28:19 AM] Eliezer: <attached: 00000451-

AUDIO-2022-08-23-11-28-19.opus>

[8/23/22, 11:46:31 AM] BInyamin EN Corp: <attached: 00000452-

AUDIO-2022-08-23-11-46-31.opus>

[8/23/22, 11:47:36 AM] Eliezer: Ok

[11/17/22, 3:49:21 PM] Eliezer: I did exactly what you asked me to do 

and sued your company please let me know when I should expect payment

[11/17/22, 3:49:38 PM] Eliezer: You told me to sue because that was 

the only way to get your companies attention and that would work

[11/17/22, 3:49:44 PM] Eliezer: So please let me know

[1/9/23, 4:09:23 PM] Eliezer: Please call me

[1/9/23, 4:15:57 PM] BInyamin EN Corp: Will call you back in your 

morning

Case 1:22-cv-23661-PCH Document 28-4 Entered on FLSD Docket 02/03/2023 Page 23 of 23