Sunday, July 14, 2013

Alain Horoit: Joel Leyden's Partner in Fraud and Cyber Crime

A new article has been published about Joel Leyden's partner in crime, Alain Horoit. We urge you to read it and share widely!:

The following is a translation of an article written in Dutch by Dennis van Damme in the Belgian Gazet Van Antwerpen on July 6, 2013. We believe all the many claims of fraud against Alain Horoit are true, especially as his "Hatikvah" page has repeatedly published ridiculous lies and attacks against us, and many other Jews and Israel supporters.

They also publish many lies, in general. Just recently, they fraudulently claimed to have taken a picture in Safed (Israel), meanwhile, it was actually a photo of Greece that they stole from a professional! The page also has another known fraud and defamer of Jews behind it, Joel Leyden. We've published many articles about him that we encourage you to read, and we also encourage you to go to Joel Leyden Watch. Also note that this article does not touch upon all the many leaders in the Jewish and pro-Israel community who have been ripped off by Alain Horoit, such as Zevi Ives (head of the European Center for Jewish Students). Below is a letter written by Zevi, with regard to Horoit's fraud:
Brussels, May 9, 2012

To Whom It May Concern,

This is to verify that we lent €1550 to Alain Horoit which was not repaid as promised. He approached me as head of ECJS, European Center for Jewish Students, asking for a loan on Thursday, January 21, 2010 on behalf of his company Trendy Networkz for his party for European Jews that Saturday night. He needed to pay the band and singer. Alain promised that it would be paid back immediately following the party once he received the money from the entrance fees. Thinking it would be a small favor and possibly the beginning of a good contact for ECJS, I agreed. When the bank details in Israel did not work from our PC banking, he asked me to send it to ElAl in Belgium to pay for the tickets of the band instead.

The following week, we did not receive the promised reimbursement nor did Alain contact me to explain the delay. I e-mailed and called him over and over. He kept promising new deadlines by which he would pay ECJS back and eventually stopped returning my e-mails and calls. Despite repeated calls and e-mails, we have still not received this money back to date. This has caused us not only monetary loss, but also problems with accounting for paying for this service from ECJS bank account without a reimbursement from Trendy Networkz.


Zevi Ives
Executive Director
European Center for Jewish Students
And here is a spreadsheet documenting just some of Alain's other victims.  Now, without further ado, here's the recent article:

Fraud? Speaker with a dark past
‘Mister Never Give Up’ is planning performances in Antwerp

by Dennis van Damme, Gazet Van Antwerpen

Who is the mysterious Mister Never Give Up who is planning a show in Antwerp in December? According to him, he is a source of inspiration for everyone who has problems. But according to others he is a seasoned fraud who has swindled many people of their money.

Mister Never Give up is coming to Belgium in December. “He will do a series of shows in Antwerp,” an enthusiastic press release announces. “That these shows will be remarkable, and that a whole lot of special guests can be expected, seems all but assured.”
According to the same press release, Mister Never Give Up is “much more than a motivational speaker, he is the ‘motivational rock star’ of Facebook. A real countryman who has had an international breakthrough.”


To be clear, Mister Never Give Up is Alain Horoit. He was born in Berche

m, spent a large part of his life in Berchem, and is currently living in Spain. According to him, he was active for many years in the entertainment industry, and among other things, he managed the disco Sotto’s in Zottegem.

“I was on top”, Horoit says in a phone conversation with this paper. I had personnel, I had money, but I also had a lot to lose. A few years ago I went bankrupt. I didn’t see a way out. In those five minutes that I considered giving everything up, Mister Never Give Up was born.”

Mister Never Give Up is, according to Horoit, a sort of mentor to anyone who has fallen on hard times and does not see a way out. He wrote a book about it that was sold through the Internet. Horoit is most active on Facebook. “My page has over 310.000 followers”, he says. “And those aren’t just people who have clicked on ‘Like’. I get emails daily from people who are asking for my help and advice. Those are the people that I do this for.”

Guest speakers

The show in December will be in English. “I tell my story and try to motivate people to never give up. The guest speakers are other motivational speakers who are especially active on Facebook under names such as ‘Inspirational Positive Quotes’ and ‘Lessons Learned in Life’.”

Tickets aren’t cheap: they cost 24.95 or 29.95 euro. About this Horoit is clear: “You cannot expect to pay the price of a cinema ticket for a show that will change your life.”

But Alain Horoit does not remain someone who is not spoken about. Moreover, the more we examine his past, the more people and organizations we encounter who have a bone to pick with the man. “He is a complete swindler,” was the reaction of Michael Freilich of the magazine Joods Actueel. “In 2010 he ordered an advertisement with us, but he never paid.”

Horoit, who is Jewish, needed the ad to promote a gala ball for the Jewish community that he had organized in the Radisson Blu hotel near the Stadspark. The ball would turn out to be a flop. Joods Actueel is one of many parties who were left with a bitter taste after the ball.

Gaining trust

Horoit also placed an ad in the Dutch Jewish magazine Benjamin without paying. Many people who were involved with organizing the party, were presented with bills afterwards for services that Horoit had ordered. Similarly with his former friend Marco Devaux:

“I suddenly received a bill for 25,000 euro for the rent of the party hall and a bunch of hotel rooms in the Hilton Hotel,” Davaux said. “I went into business with him because I knew his whole family and trusted him. We had arranged that he would organize the events and that we would sell tickets through my company, on which I would receive a three per cent commission. We hadn’t written this agreement down. This was stupid of me, but Horoit is very good at gaining people’s trust. His method is simple. He borrows money from one to close the holes at another. In total I have lent him 16,000 euro, money I have never seen again. I did have to pay 1,500 euro in legal fees only to prove that Horoit, not I, had booked the hotel rooms and party hall.”

Not all victims have pressed charges against Horoit. For some the legal fees would be higher than the loss they have suffered. The Dutchman Nathan Bouscher (29) was asked to arrange transportation for several guests from Amsterdam to the gala ball in Antwerp. Also he received a bill from the bus company, while Horoit had promised to pay. “In my case this concerns a bit more than 700 euro,” Bouscher says. “If I were to challenge him in court, I would lose more money.”

Judicial investigation

In Antwerp there is an investigation running against Horoit for suspected fraud and forgery. The man is also known with the courts in Dendermonde and Brussels. With a Dutch musician was in a legal clinch about thousands of euros of royalties. The biggest case file against Horoit is in Germany. A 37-year old woman, who wishes to remain anonymous and with whom Horoit had a relationship, bundled a number of complaints. She claims she has lent him 10,000 euro. Also she never saw her money back. Because Horoit is living in hiding in Spain, the legal proceedings in Germany are currently stuck.

It is also remarkable that the Antwerp cinema complex UGC, where the Mister Never Give Up Show is supposed to take place according to the press release, have never heard of him.

“Jealous stalker”

Horoit himself denies all allegations of fraud. He was still looking for another location for his show. “All those people are talking a lot, but they don’t have any proof. I have never been convicted. I have always been strong enough not to respond to such lies. That woman in Germany is a stalker. She is jealous of my success.”

But several victims, such as Marco Devaux and Nathan Bouscher, are convinced that he is trying swindle people out of money again. “His stage name is very well chosen,” Bouscher bitterly remarks. “He really doesn’t give up.”

Friday, July 5, 2013


Jews, Israel supporters, Israelis, soldiers in the IDF, and others are being defamed, harassed, and defrauded by the creator of the "Hatikvah" page ("Alain Horoit) and some of the other admins associated with it (such as "Joel Leyden" and "Phillip Pasmanick"). If you are a fan of the page, we urge you to unlike it and report it for spam and harassment, immediately. While the page might appear to be Kosher at first glance, if you look more closely, you can see disturbing trends, such as breaching the privacy, safety, and security of Jews and Israel supporters, and even supporting the murder of certain leaders in the Jewish and pro-Israel community!
To learn more about "Joel Leyden", please read the other information on our site.
To learn more about "Alain Horoit", please see this letter  and this list of many of his victims.

Wednesday, July 3, 2013

Fraudulent Causes: "Stop Lashon Hara - Slander and Libel" and the "Coalition Against Cyber Bullying"

These two fake causes were recently created and supported by internet frauds and cyber bullies and criminals "Joel Leyden" and "Alain Horoit." Their buddy Phillip Pasmanick may also be behind it, as he's always promoting their pages and blindly supporting these frauds with spam every opportunity he gets.

They are using these fraudulent fronts to hypocritically defame and attack the many people who rightfully call out their lies and abuse. Beware of these fake causes and the people behind them, and who support them. If you see your friends supporting them in any way, be sure to make them aware that these are fraudulent causes run by fraudulent people we believe are responsible for serious crimes online such as fraud, identity theft, posting of people's social security numbers, harassment, and abuse. 

Tuesday, June 25, 2013

Fraudulent "Israel News Agency" Removed from Google News

As we reported earlier, "Israel News Agency" is a fraudulent enterprise run by a criminal harasser and defamer of many good people. We asked you to report it to Google, as Joel Leyden's fraudulent "Israel News Agency" follows none of Google News' guidelines for inclusion. He abused Google News, posting many fraudulent stories for personal gain. Joel Leyden and his fraudulent "Israel New Agency" exist solely to promote themselves. Leyden also abused Google News using his status in the Google News index to threaten and harass many good people.

Quite simply, if you don't do or say what Joel Leyden wants you to do or say (whether it's give him $2,000 or refrain from criticizing his fraud, defamation, and harassment), he will threaten to destroy your reputation online, and he will use his fraudulent "Israel News Agency" and whatever other tools he has, or can find, at his disposal.

Kudos to Google, for taking the proper stand in this case!

Leyden has been busy lately, continuing with his defamatory spam on Facebook. He and his buddies "Phillip Pasmanick", "Alain Horoit", and "Michael Mendelson" have created a new fraudulent effort they're spamming all over the place which claims to be against "slander."  The ironic and hypocritical thing is that they are using their fake effort to slander good people, themselves! They flat-out make up lies about people.

In other news, many people in the Jewish and pro-Israel community throughout Europe claim to have been defrauded of tens of thousands of dollars by Alain Horoit, Leyden's close buddy and apparent partner in crime. Horoit is famous for trying to sell goods that many people say they never received. He also tried to sell a book with hundreds of blank pages, for around $20. If you Google him, you can read all about it. He runs a lot of pages on Facebook such as "Hatikvah" and something called "Mr. Never Give Up."

Be wary of all these frauds and their associates. They claim to be doing work for Jews and Israel, but they're spending a lot of their time attacking good people with defamatory spam. If you Google them, just know that all the "good" stuff is stuff they've probably written about themselves, and all or most of the bad stuff, is true.

Leyden also tried to post his fraudulent, defamatory, and nonsensical "Israel News Agency"  "article" at the "Free Republic" site, but it was quickly removed, as they saw it for what it was. The people who had an opportunity to comment on Leyden's nonsense before it was taken down, were great, as they were all familiar with Leyden's fraud. They ridiculed him and his defamatory "article." It was fantastic.  You don't get to see that on Facebook because these fraudsters simply ban and remove anyone's comments who try to question or reason with them.

They are also abusing the "Causes" petition site, using a the fraudulent "article" in the fraudulent "Israel News Agency" to back their fraudulent claims against a group which dares to call out their fraud. The "article" was written by one "Karen Levy." Does she even exist? Or is it another Joel Leyden alias? We're not sure.

We have contacted "Causes" about this petition and hope to see it come down, too.

They've also put their fraudulent and defamatory "article" into a site for press releases, against that site's TOS, as well, so we hope to hear back about.

In a nutshell, anywhere they can spam defamatory and harassing information about people they don't like, or that they disagree with, they are. And most of those places have TOS against such activities.

It seems a big part of it is that these people just enjoy the attention, so we're going to try to keep our posts to a minimum. However, we will continue to privately document their fraud and attacks, and coordinate with attorneys, law enforcement, and their many victims to pursue these criminals legally.

They can spam their lies about good people all they want. Brainless fools who don't do their homework may even "support" them. But it doesn't make anything they say or do against others, true.

Again, the fraud is clear from their new effort, which claims to be against slander on one hand while simultaneously committing it on the other. These guys are the ultimate hypocrites and frauds. They are nobody in the Jewish/Israel world, and are clearly jealous of people who do excellent work.

These fraudsters can make up all they want about people, but it doesn't make it true. We'll let rational minds prevail, much like they did at Google, and at Free Republic, and like they will in courts of law, too.

If you see anyone linking to "Israel News Agency" or citing it as a source, please let them know the facts behind it.

Thursday, June 20, 2013

"Israel News Agency" = Fraudulent News Agency

From our friends at the JIDF:

Joel Leyden, and his fraudulent "Israel News Agency" were actually banned and removed from Wikipoedia.

Wikipedia admins were spot on with the case:
Joel Leyden is a known SEO spammer and states that on his website. He is using Wikipedia, and has admitted as such, to get traffic to his blog. He is not a noted journalist. I state this unequivocally as someone who has worked for 15 years in the Israeli media, and as anyone from the Hebrew Wikipedia will tell you. In fact, he is an unknown in Israel. Here is a classic example of someone abusing Wikipedia for personal gain. What is worse, his blog (and as an examination will show, it is nothing more) is one of the tools he is using to fight a custody battle with his ex-wife over his children. As a user, now banned, he attempted to use wikipedia to fight this same custody battle, as a perusal of the history of Raanana will show. In addition, he was banned for harassing another user, both online and in person. The votes to keep included sockpuppets and personal friends, who have fewer than ten edits each, i.e., make 3 edits and vote for Joel. I am not even going to discuss his personal attacks against me or the foundation on his blog. Given the confusion of information and misinformation there, I can only wonder what kind of nonsense he is posting in his article. Nevertheless, I will state this, summarizing a lengthy email which I sent to the Arb Com about two months ago: if the Hebrew Wikipedia, based in Israel, sees fit to include a version of the article about him or his blog, I will support its inclusion in English. If not, I will continue to regard it as simple SEO spam and unverifiable drivel by someone attempting to use wikipedia to attain fame and pursue his own, selfish agenda, using false information, sock puppets, and what have you. I sincerely hope that this is not the direction that Wikipedia is taking.
As you can see, we're not the only Jews and Israel supporters speaking out against this fraud.  And it should be noted that Joel Leyden's "Israel News Agency" is not an official Israel News Agency. Anyone can take a quick look at his piece of crap website to see that. It's an SEO spam platform that Leyden uses to promote himself and to attack others. Nothing more. Leyden recently threatened to continue to spread lies about us on his site, which is somehow indexed in Google News.

However, if you actually study the guidelines and requirements to be included and indexed Google News, you can see that Leyden's fraudulent "Israel News Agency" meets few, if any, of them, and that his site is in clear violation of many, if not most, of those guidelines.

Thus, we urge you to report his site, here.

There's simply no reason a self-promotional SEO site used also to harass and defame Jews and Israel supporters, and which barely publishes any content should be included in Google News. If you don't know what to write on the form, you can click here to see some suggestions. 

Joel Leyden Continues to Criminally Harass and Defame Good People

We're continuing to receive reports with regard to Joel Leyden's harassment and defamation of good people. He most recently threatened a woman online, claiming that he was going to call the police on her if she didn't remove her criticism of him. We've also discovered many other important links concerning Joel Leyden's harassment, defamation, cybersquatting, fraud, abuse, and extortion:

Here are just some of the reviews, complaints, legal documents, criminal reports, and other reports about Joel Leyden:
The following are more aliases, DBA’s, and other entities in which he is involved or associated:

Leyden Digital” (, “Israel News Agency” (, “Israel PR” (, “Jewish PR” (, “Israel SEO PR” (, “Reputation Management PR” (, “London SEO PR” (, “israel Public Relations Institute” (, “Internet Marketing SEO PR” (, “Joel Leyden New York” (, “Joel Leyden SEO PR” (, “Joel Leden” (, “Leyden Communications Internet Marketing, SEO, Digital PR” (, “Passover” (, “Hatikvah” (, “Jerusalem - Capital of Israel” (, “Israel Humanitarian Aid” (, “Joel Leyden” (, “Jewish Business Networking” (, “Jewish Fathers” (, “Children 4 Israel (, “Israel News Agency” (, “I Support the Israel Defense Forces In Preventing Terror Attacks From Gaza” (, “Online Reputation PR” (, “Joel Leyden” (, “Joel Leyden SEO” ( , “Joel Leyden LInkedin” (, “IsraelBeach YouTube” (, “Joel Leyden Slideshare” (, “Joel Leyden” (, “Joel Leyden” (, “Phillip Pasmanick’s Israel & Stuff” (, “Fathers for Justice Israel” (, “Digital PR 4 Israel” (, "Stop Lashon Hara - Slander and Libel", "Coalition Against Cyber Bullying",, 

He often uses the same retorts or rebuttals (using fake names) against anyone criticizing him, or calling out his rampant online abuse. Some of these including:
  • He will claim whoever is making the complaint is being investigated by the FBI, CIA, Police, or other law enforcement agency
  • He will claim whoever criticizes him is in Iran
  • He will claim that who he’s “known Joel Leyden for 15 years
  • He will claim the complainant is guilty of libel and defamation
  • He will claim the complainant is a “professional con artist”
  • He will make up completely false information about people he suspects are complaining
  • He will falsely accuse people of hacking him and cyber-harassing him
  • He will falsely claim that he is a “highly respected” consultant in the Jewish community
  • He will falsely claim he served in the IDF as an officer in three wars
  • He will falsely claim he serves as a “senior advisor” for the Israel Ministry of Foreign Affairs
He claims to be in the business of “reputation management”, but as you can see, it appears the only person’s reputation he tries to manage, is his own. Most of the top results for his name are for his own spammy duplicitous and crappy websites. So I urge everyone to review this information, and to help spread it, if you agree that Joel Leyden is indeed a threat that must be called out.

Some of Leyden's close associates, who aid and abet his criminal behavior are "Philip Pasmanick" and "Michael Mendelson." We're not sure if those are their real names. If you encounter these people online, or elsewhere, please be wary.

Wednesday, May 22, 2013


A new document entitled "Joel Leyden HARASSMENT, MALICIOUS FALSEHOOD AND LIBEL" has surfaced from one of Joel Leyden's many victims, here's just an excerpt, but we urge you to read all of it:
This document concerns and contains information about Joel Leyden and his malicious internet activity that has resulted a multitude of domain hijackings, harassment, defamation, libel and slander allegations to many people on the internet.....The information gathered was discovered through the use of Open Source Intelligence which has resulted in a substantial amount of information gathered on Joel Leyden. Our initial goal was to have certain web sites and defamatory statements removed however companies such as and require that subpoenas and injunctions be sent to them in order to remove this information.Further,through phone calls the Los Angeles Police Department and the FBI pointed us in the directionof with little or no help from the authorities we were left with no other choice than to investigate Joel Leyden on our own. After numerous attempts to negotiate with Joel to remove this content we have been unsuccessful. While emotionally and monetarily draining we found ourselves with information that not only pointed to more internet victims, but also victims in Israel and the United kingdom with the same charges, but in addition to the numerous victims on the internet we have uncovered that Joel was also has outstanding charges for Rape, Sexual Misconduct with a child with multiple allegations of these same offenses.

On October 25th 2010 Joel fled Israel on an American passport to escape these charges and being brought to justice. Other possible reasons for Joel fleeing Israel were to escape Debtors Prison for child support money that was owed to his Ex-Wife, Julie Portner. What will be presented in this document will be evidence toward behavior of Joel Leyden’s internet etiquette and method of operation and then, as the leads were followed, point you into the new issues that were uncovered on Joel Leyden and his criminal background.

Our primary objective is to establish and ultimately prove our case against Joel Leyden and have ALL defamatory, harassing, libelous web properties removed permanently and to have criminal chargesbrought against Joel Leyden for his continuous use of these tactics to extort money from not only Richard Maize and Michael Martinez, but all of the other victims who suffer from the demands to remove the content for money. We also seek to repair our online reputations by obtaining 1) a restraining order from any future ma licious conduct by Joel Leyden or any Alias used in such act & 2) to obtain a multi-party injunction for any and all use to remove this malicious content by serving it to the appropriate web properties that contain such content.

Our secondary objective is to see to it that, through the information that has been uncovered, he is broughtto justice and is accountable for any other criminal allegations and charges that he has escaped from.

While there is a massive amount of relevant findings to prove our case against Joel Leyden as a predator on the internet, we do not want this to over shadow the fact that he also has a physical presence as a criminal unaccounted for hard crimes in other nations. We feel that this compounds and over shadows the fact that he is a predator on the internet intent on finding new victims for whatever use he finds necessary. Whether it be to emotionally disturb individuals or companies to submit into extortion practices or to simply menace the internet community the evidence, as well as the internet, shows that there is a large amount of evidence either from his own mouth or from others that have been harassed or stalked over time. As of recent there has been as escalation of events taking place to defame others of shady business practices and claiming, himself a victim of what he actually commits. For the sake of brevity, we will show screen shots in the main document and provide an appendix of full documents.....
From the Jewish Internet Defense Force's Google Plus page
PLEASE SHARE WIDELY!: Please very careful with whom you associate. Not everyone who appears to be "pro-Israel" is a good person. If you or anyone else  you know have been harassed, defamed, impersonated, threatened and/or spammed by the Joel Leyden (as we, and many other friends, Jews, and Israel supporters have been), there is now a legal precedent which may help you. - And here's the result of the complaint:

Since we went public with this, many of his victims have come forward. Please see this 66 page PDF: which documents his harassment of Jews and Israel supporters, even further.

Please be aware of this jerk. Neither he nor any of his associates can be trusted. As documented in the aforementioned case, he attempts to cybersquat, defame, threaten, harass, and endanger various Jews and Israelis, as well as Jewish and pro-Israel organizations.

Thursday, May 16, 2013

The Cybersquating, Fraud, Abuse, Extortion, Threats, Defamation, Bullying, Harassment of Joel Leyden

joel leyden, fraud, extortion, cybersquatter, bullying, harassment
Joel Leyden, Fraud
Have you been attacked, harassed, threatened, or defamed by Joel Leyden, or any of his many aliases, or companies, such as "New York Digital PR" or "Leyden Communications" or "Israel News Agency?" You are not alone. Please see just one of many official complaints against Leyden, and the settlement thereof, where he was forced, legally, to reverse a lot of his disgusting behavior. We will be documenting it all here, and will be creating a forum where people who have been harassed, threatened, bullied, abused, and defamed by Leyden can come together, unite, and try to heal.

Nothing seems to be beneath this jerk, who goes out of his way to even harass his own family. As the original complaint states:

HERZFELD & RUBIN, P.C., the Plaintiff herein by its attorney, Edward L. Birnbaum, complaining of defendant, Joel Leyden ("Joel"), alleges as follows:

1. Upon information and belief, Plaintiff is a well-respected law firm with
offices at 125 Broad Street, New York, N.Y., which with its predecessor firms, has been
engaged in the practice of law in New York for over sixty years. It is well lmown in the
legal community, anaong lawyers and judges for its professionalism, responsibility,
integrity, and dedication to the interests of its clients.
2. On December 12, 2005, Plaintiff prepaxed a Will for its longtime client,
Bernard Leyden ("Bernard"), the father of defendant. The Will was reviewed and
republished when a Codicil was prepared and executed on December 3, 2007 after the
initial execution of the Will. Bernard died on January 22, 2009.
3. Bernard’s Will provided, among other things, for a Trust which became
effective on Bernard’s death. It designated as Trustee, Brian Leyden ("Brian"), the other
son of Bernard, and the brother of Joel Leyden ("Joel"), the defendant in this action.
4.The Will was probated in New York County and the Trust is, therefore,
subject to oversight by the New York County Stm’ogate’s Court.
INDEX NO. 154004/2012
5.The Trust was established because Bernard did not have confidence in
Joel’s ability to manage funds and because of the frequency and severity of the physical, economic and including legal conflicts with women with whom he was not married and his ex-wives over arrears in alimony and non-support, and their potential and actual penal consequences. Bernard desired to create a mechanism with Brian as Trustee, which would safeguard the funds he was allocating for Joel from Joel’~ behavioral difficulties.
Accordingly, he entrusted them to Brian to be available to Joel as Brian’s "sole and absolute discretion, deems necessary or advisable."
6.For many years, Joel had been residing in Israel where he had engaged in
a variety of failing enterprises and relationships which required repeated support and
rescue by Bernard.

7. Joel, in his computer published biography, portrays himself as an Israeli
war hero, and a seasoned, respected and responsible international public relations
practitioner, In fact, as Joel also admits in published documents, he describes himself as evicted from his home, and separated from his children and work opportunities in Israel. He claims to b~e subject to arrest if he returns to Israel. He also claims to own hundreds of computer domains, which he buys and sells. As described below, he perverts and abuses his computer domain registrations, not merely by nuisance attacks on persons he seeks to damage, but by deliberate defamation, coercion and other violation of law.

8. Brian, as Trustee, after Bernard’s demise, has acted with prudence to
administer the Trust assets to prolong their availability over Joel’s anticipated life span,
to carry out Bernard’s intent to avoid their being squandered by Joel and to protect them
from Joel’s creditors.
9.Plaintiff has acted as attorney for Brian, in his capacity as Executor of the
Estate, and as Trustee. At no time has Plaintiff acted as attorney, or in may other fiduciary
capacity for Joel.
10. Approximately two years ago, Joel left or was caused to leave Israel in the
context of failure to support and other charges in respect to his relations with his children.

11. Arriving in the United States, he contacted Brian ~and requested payments
from the Trust which Brian determined were unwarranted. Negotiations with Joel
successive attorneys failed to resolve Joel’s advanced and irrational demands.
12. Thereafter, Joel commenced his campaign of harassment, threats and
to force Brian to make payments from the Trust which, in Brian’s judgment, were
inappropriate and contrary to his obligation under the Trust.
13. Joel’s response to Brian’s rejection of Joel’s demands was to cause his
attorneys successively to press his demands through judicial action. He sued in three
separate proceedings, in the New York County Surrogate’s Court, through one or more of
such attorneys, or pro se. The Surrogate’s Court dismissed each of Joel’s proceedings,
finding that each claim was meritless.

14. The Surrogate, in dismissing the most recent proceeding brought by Joel,
directed him to stop his unsupported claims, in deference to the resources of the Court, as well as to avoid the depletion of the assets of the Trust by his irrational and frivolous applications.

15. Finally, the Surrogate, in August, 2011, issued an order prohibiting Joel
from commencing any new proceeding without making a prior application to the Court and receiving the Court’s permission.

16. Nevertheless, Joel has brought action in the Supreme Court, Bronx County
repeating the same issues which were rejected in the New York County Surrogate Court.
17. Having failed in his judicial applications, he intensified his campaign of
non-judicial tactics to try by false, malicious, distorted, and defamatory attacks on
Plaintiff, and his brother Brian, the Trustee of the Trust, to gain, by harassment and
denigration of Plaintiff and the Trustee, the results denied to him in the judicial
proceedings. Aware that Plaintiff has registered its firm name on the internet as
"Herzfeld-, as in numerous other instances of his harassment of others, he illegally appropriated that name by registering the name, and variants of the name, as computer domain names controlled by him. In furtherance of his illegal conduct, he posts or causes to be posted what he claims to be news articles, written by him under fictitious names, which are false and defamatory statements about Plaintiff. These articles are posted on an illicit, domain name as well as the domain names of,,,, and

18. In consequence, persons seeking authentic information about Herzfeld &
Rubin, are diverted to Joel’s defamatory, false and denigrating materials posted or caused to be posted by him on his illicit and other domain names.

19. In his campaign, he has deliberately made maliciously invented purported
news services and fictitious newspaper writers to send his malicious, defamatory and
distorted purported news releases to be posted under the aforesaid domain names. His objective is to pressure Plaintiff to advise Brian to pay him moneys from the Trust, and to extort and extract moneys from Plaintiff by forcing a coerced sale if his demands are not


20. Plaintiff repeats and realleges the allegations of paragraphs 1 through 19
as though in full set forth.
21. Similar to his pattern of illegal coercion with num~erous other targets, on or
about May 5, 2012, acting, among others, under the fictitious name of "Jonathan Ariel,"
’°Israel Beach" and a pretended "Israel News Agency," operated by him, Joel issued for
posting in the public press, his illicit domain names, and other domain resources, a false
and malicious news article written l~eaded "Herzfeld & Rubin Accused of Malpractice,
Breach of Trust." The writing falsely recites that "the case will be heard in the New York
Supreme Court" and that "Herzfeld & Rubin has refused to answer or respond to emails
or telephone calls by "Israel News Agency" The article also recites accusations of Joel
"that Herzfeld & Rubin are depleting my Trust to fund the brutal and unnecessary legal
battles," that it has °’taken over $80,000 in legal fees from my Trust", "that they march
off to Court where they can find blank checks from my Trust" and "bully, intimidate and
coerce in ways one could expect from Tony Soprano, not Law and Order."
22. In a posted purported "Update," dated May 7, 2012, Joel issued a false
purported news release that "The court decided that Daniel (Joel) was suffering from
several emergencies for which the Trust is responsible for addressing and has accepted
the case." This is followed by a purported news release asserting that Plaintiff was acting
as "thugs in suits to mislead both the court and legal counsel." All of the above are false,
misleading and defamatory.
23. In an email under the email address of Joel Leyden
under date of May 17, 2012, Joel accused Plaintiff of
stealing $80,000 from the Trust, stating "My father, who retained HR, never intended for
Herzfeld & Rubin to steal 80,000 USD of his money, my money." He also refers to
Plaintiff and its personnel as "crooks." The email which he published, and caused to be
posted on another illicit Herzfeld & Rubin domain name, is addressed to his attorney and
various third parties, to give it an imprimatur of dignity and reasoned discourse. It
includes the direction to his attorney to "Please send the news story that editor/writer
Jonathan Ariel wrote to the Supreme Court." The news story, the purported writer,
Jonathan Ariel, and its contents, are the fictitious inventions of Joel. In another posting,
he accuses Herzfeld & Rubin of"committing pmjury in court."
24. All of the foregoing recitals are false. There is no malpractice and no case
of malpractice which will be heard in the New York Supreme Court. It is not Plaintiff
but Joel who is depleting the Trust by his repeated frivolous proceedings. Herzfeld &
Rubin have not taken over $80,000 from the Trust. They do not march off to Court. It is
Joel who files the frivolous claims and marches to Court. They do not bully, intimate or
coerce or act like Tony Soprano. No Court has decided that Joel was suffering from
several emergencies. Plaintiffs are not acting like "thugs in suits." They are not stealing
Joel’s money. The claim of perjury in court is simply more fiction.
25. , Plaintiff sustained damages for such defamation in the amount of in excess
of $500,000 together with punitive damages of $500,000 damage in a total of
26. Plaintiff repeats and realleges the allegations of paragraphs 1 through 24
as though in fall set forth.
27. Plalntiffhas conducted its law practice under the name Herzfeld & Rubin
for over fifty years. In the course of its operating, it maintains a computer website of
www.Herzfeld-Rubin.col~n in which it posts relevant informatiqn to be disseminated to
clients, prospective clients and other interested parties regarding its personnel, the
practice areas in which it operates, and other facts which describe the practice.
28. Plaintiff was the attorney for Bernard Leyden. It had warm personal and
professional relations with him for over fifty years until his demise.
29. Plaintiff has served clients throughout the United States, and many other
areas in the world including Europe, Asia and the Americas. It has succeeded in
achieving respect and a highly favorable reputation with its clients, its colleagues of the
bar, and the judiciary, for its integrity, compassion, judgment, and professionalism. It is
widely regarded by clients, bench and bar as anaong the most top law firms in the
30. In about 2010, with intent to appropriate Plaintiff’s good will, and to
damage, denigrate and destroy the reputation of Plaintiff among members of the bar,
bench, clients, potential clients, and the general public, Joel appropriated the name
"" and similar forms of the na111e Herzfeld & Rubin for domain
names including ",, He used the
illicit domain naanes to post or cause to be posted, false, derogatory and malicious
materials about Plaintiff. He also caused to be published, circulated and posted articles on
other websites, such as,,,,, and
ostensibly constituting bona fide news information being released by bona fide news
sources for bona fide news outlets. He intended to cause persons seeking by computer to
contact Herzfeld & Rubin, P.C., which is registered as ", to be
diverted to such illicit websites from which Joel directly and inqlirectly disseminated his
false, derogatory, distorted and damaging statements regarding Plaintiff.
31. The registry by Joel of the Herzfeld & Rubin domain names controlled by
him violated 15 USC Section 1125(d), New York General Business Law Section
and Plaintiff’s common law rights.
32. Plaintiff has demanded that Joel desist from posting false and derogatory
information, and either discontinue the illicit domain names or transfer same to Plaintiff.
33. In response, Joel demanded a payment of $100,000 for Plaintiff to
purchase the domain name "" and that Plaintiff cause its client, Brian,
to make the payments from the Trust which Brian had refused.
34. In addition, Joel advertised to the public offers to sell the illicit domain
name for $100,000. See Exhibit "A" armexed.
35. Joel rejected Plaintiff’s demand that the illicit domain name and postings
be discontinued. He continues to maintain the domain names and to post, or causes to be
posted, further false and derogatory materials regarding plaintiff.
36. By reason of the foregoing, Plaintiff is entitled to damages of at least
$500,000 together with punitive damages of $500,000.
37. Plaintiff repeats and realleges the allegations of paragraphs 1 through 35
as though in full set forth.
38. By reason of the unlawful conduct described before, clients, prospective
clients and persons doing business with or desiring to do business with Plaintiff have
been diverted from Plaintiff’s website which recites the true information regarding
Plaintiff to the illicit domain names, have become confused and uncertain about the
recitals in Plaintiff’s website, and have been deterred, from entertaining into {elations
with Plaintiff, and Plaintiff’ s professional reputation and status has been damaged.
39. Plaintiff has been caused to expend extensive time and energy, at
significant costs, to investigate and determine the illicit activities and to seek counter
action thereto.
of in excess of $500,000 and is entitled, in addition, to punitive damages of $500,000.
By reason of the foregoing, Plaintiff had sustained damages in the amount
41. Plaintiff repeats and realleges the allegations of paragraphs 1 through 24,
26 through 34, 37 through 39 as though in full set forth.
42. By reason of the damage recited herein, Plaintiff has no adequate remedy
at law and is entitled to preliminary and permanent injunction of the maintenance of the
illicit domain names and such other relief as the Court may deem proper.
996977 1
WHEREFORE, Plaintiff demands damages of $500,000 together with punitive
damages of an additional $500,000, and interest on each of Counts 1, 2 and 3 of the
Complaint, and a preliminary and permanent injunction as to Count 4, barring and
precluding the direct and indirect issuance and posting on any domain name of materials
containing or referring to Herzfeld & Rubin, P.C. and requiring the turnover of the illicit
domain names to Plaintiff, together such other relief as the Coul:t may deep proper, with
the costs of the action.
New York, New York
June 26, 2012
Edward L. Bil~aum, FA~q~F
A[ttorney for Plaintiff
~25 Broad Street,
~qew York, New York 10004
(212) 471-8500
EDWARD BIRNBAUM, being duly sworn deposes and says:
That he is a Senior Member of the firm of HERZFELD & RUBIN, P.C., a defendant in
the above-entitled action; that he has read the foregoing Verified Complaint and knows the
contents thereof; and that the same is true to the best of his knowledge except as to matters
therein stated to be alleged upon information and belief, and as to those matters he believes
them to be true