FILED: NEW YORK COUNTY CLERK 09/28/2016 07:24 PM INDEX NO.

653668/2016
NYSCEF DOC. NO. 8 RECEIVED NYSCEF: 09/28/2016

David Abrams, Attorney at Law

305 Broadway Suite 601
New York, NY 10007
Tel. 212-897-5821 dnabrams@gmail.com

Supreme Court of the State of New York

County of New York
____________________________________
)
Bibliotechnical Athenaeum, )
)
Plaintiff, )
) Index No. 653668/2016
- against - )
)
National Lawyers Guild, Inc., & )
The National Lawyers Guild )
Foundation, Inc. )
)
Defendants. )
)
____________________________________)

Affirmation of David Abrams in Opposition to Motion to Dismiss

David Abrams, an attorney duly admitted to practice before the Courts of the

State of New York, affirms the following statement to be true under penalty of perjury:

1. I am the attorney for the Plaintiff ("Bibliotechnical") in the above-referenced

matter. I respectfully submit this affirmation in opposition to Defendant's ("NLG's")

motion to dismiss. My memorandum of law is attached hereto as Exhibit A; a copy of

the Summons and Complaint is attached hereto as Exhibit B.

I. Compliance with Corporate Formalities

2. Bibliotechnical, the Plaintiff in this matter, was duly incorporated by the State of

Israel, Ministry of Justice, Corporations Authority on March 8, 2016. A true copy of

Bibliotechnical's certificate of incorporation, along with a certified English translation, is

attached hereto as Exhibit C.

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3. Subsequently, on March 11, 2016, Bibliotechnical filed an application for

authority with the New York Department of State which was duly accepted. A copy of

the filing receipt, along with a printout from the Department of State confirming the

registration, are attached hereto as Exhibit D.

4. Subsequently, on March 17, 2016 Bibliotechnical filed an Certificate of Assumed

Name with the Department of State which was duly accepted by the same Department. A

file-stamped copy of the Certificate, along with a copy of the receipt, is attached hereto as

Exhibit E.

5. Thus, at all times relevant to this matter, Bibliotechnical is and was an Israeli

corporation, duly authorized to do business in the State of New York under the name

"Bibliotechnical Athenaeum."

II. The NLG's Annual Banquet and Dinner Journal

6. Attached hereto as Exhibit F is a true copy of NLG's brochure for its annual

convention which was to be held in Manhattan in August of 2016. I downloaded Exhibit

F from the Defendant's web site.

7. Page 7 of Exhibit F is the registration form. From the registration form, which

contains a schedule of prices for members and non-members, it is clear that all aspects of

the convention, including the banquet and dinner journal, were held completely open to

members of the general public and not limited in any way. (Except of course when it

comes to Israel.)

8. This is confirmed by Exhibit G, the brochure for dinner journal ads (also

downloaded from Defendant's web site), which states "Placing an ad in the journal is a

great way to congratulate our outstanding honorees

(http://www.nlg.org/convention/2016-nlg-honorees), recognize his years keynote

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speaker, Elle Hearns, publicize your firm or organization, or just share a message of your

ownall while supporting the Guild!"

8. Attached hereto as Exhibit H is a true copy of an e-mail exchange between myself

(on behalf of my client) and an anonymous representative of NLG.

9. As the Court can see, there is and can be no dispute that (1) I attempted to place

an ad in the dinner journal on behalf of the Plaintiff in this matter; (2) to that end, I paid

NLG $200 via a credit card; (3) and the ad, which was otherwise not objectionable, was

rejected solely due to the origin and citizenship status of Bibliotechnical.

10. Further, as the Court can see, the e-mail exchange contained no

misrepresentations on my part.

III. Other Lawsuits Filed by the Defendant

11. Finally, attached hereto as Exhibit I is a true copy of a Complaint filed by the

Defendant in the United States District Court for the Western District of Virginia.

Evidently, even though it is a corporation, the NLG feels that it has standing to assert its

rights in Court.

[continued on next page]

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12. I found Exhibit I with a quick search on PACER. That search revealed that NLG

and/or its local chapters, has filed numerous lawsuits in federal courts all over the country

even though it is a corporation. Presumably there are also many lawsuits in courts not

covered by the PACER system.

Respectfully submitted,

___________________________

David Abrams, Attorney at Law

Attorney for Plaintiff
305 Broadway Suite 601
New York, NY 10007
Dated: New York, NY
September 28, 2016

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David Abrams, Attorney at Law
305 Broadway Suite 601
New York, NY 10007
Tel. 212-897-5821 dnabrams@gmail.com

Supreme Court of the State of New York

County of New York
____________________________________
)
Bibliotechnical Athenaeum, )
)
Plaintiff, )
) Index No. 653668/2016
- against - )
)
National Lawyers Guild, Inc., & )
The National Lawyers Guild )
Foundation, Inc. )
)
Defendants. )
)
____________________________________)

Memorandum of Law in Opposition to Motion to Dismiss

Plaintiff Bibliotechnical Athenaeum ("Bibliotechnical") by its attorney, David

Abrams, respectfully submits this Memorandum of Law in opposition to Defendant's

motion to dismiss; disqualify; and strike portions of the Complaint.

Introduction

The undisputed facts in this matter show that the Defendants ("NLG")

discriminated against the Plaintiff ("Bibliotechnical") by refusing to run a dinner journal

advertisement on the basis of Plaintiff's Israeli citizenship and national origin. This is a

clear violation of the New York City and State Human Rights Laws so it is unsurprising

that NLG now challenges the Constitutionality of those laws. Unfortunately for NLG, its

Constitutional challenge is 30 years too late: the Court of Appeals considered and

rejected a similar Constitutional challenge to the Human Rights law back in the 1980s

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and the United States Supreme Court affirmed the decision. Moreover, as set forth in

more detail below, NLGs argument misses the critical difference between (1) rejecting

an advertisement based on content and (2) rejecting an advertisement based on the race,

religion, national origin, citizenship, etc. of the advertiser.

Perhaps realizing that its Constitutional argument is weak, NLG offers a slew of

additional arguments: That it is a private organization and therefore exempt from the

Human Rights laws; that Bibliotechnical lacks standing to bring this action; that

Bibliotechnical has failed to comply with corporate formalities; and finally that

Bibliotechnical's counsel should be disqualified from representation. As set forth in

detail below, none of these arguments has any merit: NLG is well within the definition

of "provider of public accommodation" under the Human Rights laws; Bibliotechnical

has explicitly granted standing under the law; Bibliotechnical has complied with the

corporate formalities and all of the relevant documents have been a matter of public

record with the Department of State since March; and under applicable law there is no

basis for disqualification of counsel. Accordingly NLG's motion should be denied in its

entirety.

Facts and Procedural History

By way of background, this matter is a discrimination claim brought by the

Plaintiff ("Bibliotechnical" or "Plaintiff") against the Defendants ("NLG" or

"Defendant") for refusing to run a dinner journal ad and permit participation in NLG's

annual banquet on account of Bibliotechnical's Israeli citizenship and national origin.

(Abrams Aff. Exh. B)

An Israeli organization, Bibliotechnical was duly incorporated by the State of

Israel, Ministry of Justice, Corporations Authority on March 8, 2016 as "Bibliotechnical

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Blue & White Ltd." (Abrams Aff. Para. 2; Exhibit C) Subsequently, on March 11, 2016,

Bibliotechnical filed an application for authority with the New York Department of State

which was duly accepted. (Abrams Aff. Para. 3; Exhibit D) Subsequently, on March 17,

2016 Bibliotechnical filed an Certificate of Assumed Name with the Department of State

to use the name "Bibliotechnical Athenaeum," which Certificate was duly accepted by the

same Department. (Abrams Aff. Para. 4; Exhibit E) Thus, at all times relevant to this

matter, Bibliotechnical has been in full compliance with corporate formalities. (Abrams

Aff. Para. 5)

In advance of NLG's annual convention which was held in New York in August

of 2016, NLG placed solicitations on its internet web site for participation in the

Convention. (Abrams Aff. Para. 6-8). Among other things, the solicitation offered

tickets to an annual banquet and advertisements in its dinner journal to be distributed at

the banquet. (Id.) Significantly, these services were all held open to the general public

and not limited to members in any way. (Abrams Aff. Para. 7) The solicitation for

advertisements stated as follows:

Placing an ad in the journal is a great way to congratulate our outstanding

honorees (http://www.nlg.org/convention/2016-nlg-honorees), recognize his
years keynote speaker, Elle Hearns, publicize your firm or organization, or just
share a message of your ownall while supporting the Guild!"

(Abrams Aff. Para. 8)

On or about June 26, 2016, Plaintiff -- through counsel -- attempted to place a

$200 advertisement in the dinner journal. (Abrams Aff. Para. 8-9; Exhibit H) The

advertisement was simple and consistent with other advertisements placed in the dinner

journal over the years. (Id.) It simply stated "Congratulations to the Honorees" and

included Bibliotechnical's name and address. (Id.) Although Bibliotechnical's $200 was

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initially accepted, the money was later refunded and Bibliotechnicals advertisement

rejected solely because of Bibliotechnicals Israeli citizenship and national origin. (Id.)

NLG's e-mail specifically stated that "we have a resolution barring us from accepting

funds from Israeli organizations. Your refund to your credit card will be processed

tomorrow . . . ." (Id.)

Subsequently, Bibliotechnical brought suit in this Court seeking damages and

injunctive relief and NLG has now moved to dismiss.

Argument

I. The Human Rights Laws Are Not Unconstitutional

NLG's prime argument is that it has a Constitutional right to discriminate against

Bibliotechnical even if such discrimination is otherwise prohibited by the Human Rights

Laws. As set forth in more detail below, the Court of Appeals already rejected this type

of Constitutional challenge to the Human Rights Laws some 30 years ago in a case

affirmed by the United States Supreme Court. Moreover, NLG's argument disregards the

critical distinction between (1) rejecting an advertisement based on the contents of the

advertisement; and (2) rejecting an advertisement based on the race, religion, national

origin, etc. of the advertiser. Thus, there is a difference between, for example, rejecting

an advertisement because it supports Donald Trump for president and rejecting an

advertisement because the advertiser belongs to a particular race, religion, or national

origin. The former practice may very well be Constitutionally protected but is not

prohibited by the Human Rights Laws. The latter practice is of course prohibited by the

Human Rights Laws but is not Constitutionally protected. Significantly, NLG has failed

to cite even one case authority from anywhere in the United States which gives any

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provider of public accommodation the Constitutional right to reject an advertisement or

allow participation in an event in violation of anti-discrimination laws.

At the outset, it should be noted that the Human Rights Laws, like all statutes,

enjoy a presumption of Constitutionality. See, e.g. Asian Americans for Equality v. Koch,

72 N.Y.2d 121, 131 (1988). Further, that the NLG has no supporting authority is hardly

a surprise; back in the 1980s there was a similar Constitutional challenge to the New

York City Human Rights Law. New York State Club Association v. City of New York, 69

N.Y.2d 211 (1987), aff'd 487 U.S. 1 (1988). The Plaintiffs in New York State Club

Association argued, among other things, that New York's anti-discrimination laws were

an impermissible infringement on their rights of free speech and association. Id. at 222-

223. The Court of Appeals rejected this argument, noting the distinction between the

general activities of the plaintiff associations and the specific practice of discrimination

by those same associations. Id. at 223 ("The law evinces an intent not to dictate the

selection policies or activities of the private clubs except to the extent necessary to ensure

that they do not automatically exclude persons from membership or use of the facilities

on account of invidious discrimination").

Of course the same is true here: The Human Rights Laws do not require the NLG

to support a particular political candidate; to refrain from criticizing Israel; or even to

publish pro-Israel advertisements. They do require the NLG to offer facilities and

accommodations without discrimination on the basis of race, religion, national origin,

citizenship, and so forth. And as held in New York State Club Association, this mild

restriction is completely consistent with the Constitution.

Indeed, Plaintiff's position is stronger here than the situation in New York State

Club Association since (1) it is not seeking membership in any kind of private club; as set

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forth in more detail below, it simply sought to take part in accommodations which have

clearly been held out to the general public; and (2) New York has a strong policy against

anti-Israel boycott activities just as it has a strong policy against more general types of

discrimination. See Executive Order Number 157 (June 5, 2016) (State will not invest in

or do business with businesses that boycott Israel).

The authorities relied on by the NLG do not contradict any of the above analysis.

Thus, for example, the case of Miami Herald Publishing Co. v. Tornillo, 418 U.S. 241

(1974) invalidated a "right of reply" law which required newspapers to publish responses

to criticism. Accordingly, at issue in Miami Herald Publishing was the actual substance

of what was to be published. If the law had simply stated that newspapers had to accept

advertisements without discriminating on the basis of race, sex, religion, or national

origin, the results would of course have been different.

In this case, NLG did not object to the contents of the advertisement at issue. The

advertisement simply said "Congratulations to the honorees," which is typical of NLG's

dinner journal advertisements. NLG had no problem with the contents of the

advertisement, its problem was and is the citizenship and national origin of the advertiser.

NLG also relies on the case of Camp-of-the-Pines, Inc. v. New York Times Co.,

184 Misc. 389) (Sup. Ct. 1945), in which a provider of public accommodation sued over

the Defendant's refusal, in June of 1943, to run advertising which included racially

discriminatory language. As with the other cases relied on by NLG, there is an important

difference between refusing to run an advertisement because of the contents of the

advertisement and refusing to run an advertisement based on protected characteristics of

the advertiser. The advertisement in Camp-of-the-Pines was rejected because it

contained code words indicating that Jews and non-Whites were not welcome at the

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Plaintiffs facilities. If the advertisement had been rejected because the Plaintiff was

itself a Jewish-owned facility, then it would have been the Defendant not the Plaintiff

who was guilty of discrimination and the results would likely have been literally the

opposite.

Moreover, the Court in Camp-of-the-Pines noted that "A newspaper in the

absence of regulatory legislation is not in the same category as common carriers or

innkeepers. The newspaper business, in the absence of statutes to the contrary, is a

business essentially private, just as much as that of the baker, the grocer or the milkman."

Id. at 401-402 (emphasis supplied).

Needless to say, the law has changed considerably since 1943 and now there do

exist statutes which clearly prohibit the conduct engaged in by NLG -- the New York

City Human Rights Law and the New York State Human Rights Law. It would appear

that no Court has ever struck down these laws as unconstitutional and NLG has not

offered any argument -- let alone a compelling argument -- why it should have a

Constitutional right to discriminate on the basis of race, sex, national origin, citizenship,

etc. Indeed, as noted above, the Courts have affirmatively held that the Human Rights

laws are Constitutional. For this reason, NLG's argument should be rejected.

II. Defendant Operates A Public Accommodation

NLG next argues that it is exempt from the requirements of the Human Rights

Laws because it is "distinctly private." In making this argument NLG confuses the

distinction between (1) membership in NLG as an organization; and (2) participation in

public events put on by the NLG. To illustrate, the very first case relied on by NLG

noted that "the facilities of a fraternal organization became a 'place of public

accommodation' for the one night that they were used to stage a fashion show to which

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the general public was invited." Ness v. Pan Am World Airways, 142 A.D.2d 233, 240

(2d Dept. 1988) (citation omitted).

NLG's confusion is especially ironic here: The primary reason the NLG was

founded in 1937 was due to the American Bar Association's discriminatory membership

practices at the time, including discrimination against Jews. No doubt the ABA felt that

it was morally justified in these practices just as the NLG feels morally justified in

engaging in discrimination 80 years later.

In any event, the issue of membership is a red herring and is not before the Court.

Plaintiff is not seeking to join the NLG; it simply sought to participate in NLG's annual

banquet and dinner journal, both of which are clearly and unequivocally open to the

public. (Even if membership were the issue, it is unlikely that NLG's argument would

hold any water since it is a national organization with minimal membership criteria.) In

any event, the New York City Human Rights Law defines a "place or provider of public

accommodation" as follows:

The term "place or provider of public accommodation" shall include providers,

whether licensed or unlicensed, of goods, services, facilities, accommodations,
advantages or privileges of any kind, and places, whether licensed or unlicensed,
where goods, services, facilities, accommodations, advantages or privileges of
any kind are extended, offered, sold or otherwise made available.

New York City Human Rights Law Section 8-102(9). Thus, regardless of whether NLG

is a private organization, its activities in offering services to the general public place it

squarely within the definition of a "provider" of "public accommodation."

Unsurprisingly, the cases relied upon by NLG do not support its position. For

example, in Ness v. Pan Am World Airways, 142 A.D.2d 233 (2d Dept. 1988), the issue

was whether the Pan American WorldClub -- a travel rewards program exclusively for

travel agents -- was a "public accommodation" within the meaning of the Human Rights

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Laws. In holding that WorldClub did not qualify, the Court emphasized that WorldClub

was not open to the public:

Membership in WorldClub is limited solely to professional travel counselors and

travel agents who are actually engaged in selling travel to the public and who are
employed by selected travel agencies which are accredited by the International
Air Transport Association (hereinafter IATA) or the Airline Reporting
Corporation (hereinafter ARC). This limitation is prominently disclosed on the
WorldClub membership application which is disseminated only to eligible travel
agents.

Id. at 234. It was for this reason, and this reason only, that WorldClub did not qualify:

It becomes readily apparent, therefore, that WorldClub does not fall within either
the statutory definition or the traditional concept of a place of public
accommodation. WorldClub does not provide any goods, conveniences or
services to the general public, nor does it offer to provide any goods,
conveniences or services to the general public. WorldClub was not designed to be
used by the general public, nor was the general public solicited to use it.
WorldClub is, plain and simple, an incentive program for travel agents, a
marketing program, and not a place of public accommodation. It is not a place
opened to serve the public.

Id. at 241.

Indeed, as noted above, the Second Department in the Ness case was careful to

distinguish WorldClub from the situation where "the facilities of a fraternal organization

became a 'place of public accommodation' for the one night that they were used to stage a

fashion show to which the general public was invited." Id. at 240.

Thus, even assuming for the sake of argument that the NLG has become a

"distinctively private" organization just like the ABA was in 1937, today's Human Rights

laws would still apply to the annual banquet and dinner journal which were clearly held

open to the general public.

Finally, it should be noted that "distinctively private" is affirmative defense on

which the NLG bears the burden of proof. See New York City Human Rights Law

Section 8-102(9) ("Such term [public accommodation] shall not include any club, which

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proves that it is in its nature distinctly private.") Thus, even if the public accommodation

at issue here were "distinctively private," the NLG would have to offer actual evidence

beyond the self-serving unsworn assertions of its attorney in support of a motion to

dismiss. See Wilcox v. Newark Valley Central School District, 74 A.D.3d 1558, 1562 (3d

Dept. 2010) (holding affirmative defense to be raised in Defendant's answer "does not

lend itself to a preanswer motion to dismiss") (citation omitted).

For the foregoing reasons, NLG's argument that it is not a provider of public

accommodation should be rejected.

III. Plaintiff Has Standing to Pursue this Matter

Notwithstanding the fact that Defendant itself has asserted its own standing in

numerous public interest lawsuits throughout the country, it argues that Plaintiff lacks

standing as an organization to pursue this matter. Defendant's argument ignores the clear,

specific, and unequivocal grant of standing to Plaintiff under the New York City and

State Human Rights Laws; this is clear even looking at the authorities relied upon by

Defendant.

Thus, in Society of the Plastics Industry, Inc. v. Suffolk County, 77 N.Y.2d 761 --

the primary case relied upon by Defendants -- the Court of Appeals stated that "[t]he

question of standing to challenge particular governmental action may, of course, be

answered by the statute at issue, which may identify the class of persons entitled to seek

review." Id. at 769 (emphasis added).

Here, the statutes at issue clearly permit organizations and corporations such as

the Plaintiff here to pursue claims. Thus, the New York City Human Rights Law

provides that "any person claiming to be aggrieved by an unlawful discriminatory

practice . . . shall have a cause of action in any court of competent jurisdiction for

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damages, including punitive damages, and for injunctive relief . . . ." New York City

Human Rights Law Section 8-502 (emphasis added). The law goes on to say that "[t]he

term 'person' includes one or more, natural persons, proprietorships partnerships,

associations, group associations, organizations, governmental bodies or agencies,

corporations, legal representatives, trustees, trustees in bankruptcy, or receivers." New

York City Human Rights Law Section 8-102(1) (emphasis added).

Similarly, the New York State Human Rights Law provides that "[a]ny person

claiming to be aggrieved by an unlawful discriminatory practice shall have a cause of

action in any court of appropriate jurisdiction for damages . . . and such other remedies as

may be appropriate . . . ." New York Executive Law Section 297(9) (emphasis added).

The term "person" includes one or more individuals, partnerships, associations,

corporations, legal representatives, trustees, trustees in bankruptcy, or receivers. New

York State Human Rights Law Section 292(1) (emphasis added).

Indeed, the Second Circuit Court of Appeals has made this point clear: "An

organization may have standing in either of two ways. It may file suit on its own behalf

'to seek judicial relief from injury to itself and to vindicate whatever rights and

immunities the association itself may enjoy.' Irish Lesbian and Gay Organization v.

Giuliani, 143 F.3d 638, 649 (2d Cir. 1998). Here, the Plaintiff was a direct victim of

discrimination (it was denied the opportunity to place an advertisement) and filed suit

against the Defendant pursuant to specific and clear statutory authorization. See also

Irish Lesbian and Gay Organization at 649-650 ("The denial of a particular opportunity

to express one's views can give rise to a compensable injury. . . . An organization, as

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well as an individual, may suffer from the lost opportunity to express its message.")

(citations omitted) (emphasis added).

Accordingly, there is no question about Plaintiff's standing.

Finally, it is worth noting Defendant's utter hypocrisy in making its standing

argument. A search of the dockets reveals that Defendant has been a Plaintiff in

numerous lawsuits throughout the country. For example, in the case of National Lawyers

Guild v. Johnson, No. 10 cv 40 (W. D. Va.), Defendant argued that the Virginia

Department of Corrections had violated its rights by failing to disseminate its "Jailhouse

Lawyers Handbook" to inmates. (Id. Docket No. 1 July 21, 2010). In that case, as here,

the Plaintiff had standing; accordingly Defendant's argument should be rejected.

IV. Plaintiff is Qualified in New York

There is one legal issue in this matter which Defendant has gotten right: Foreign

corporations must be authorized in New York in order to maintain suit here.

Unfortunately for Defendant, it is factually incorrect on this issue. The Plaintiff,

Bibliotechnical Athenaeum, was qualified in New York on March 11, 2016 under its

Israeli name - Bibliotechnical Blue & White Ltd. Subsequently, on March 17, 2016,

Plaintiff received formal permission from the New York Secretary of State to use the

name "Bibliotechnical Athenaeum" in New York County and has been using that name

ever since in New York. The necessary filings are all a matter of public record and

Defendant is and has been perfectly free to inspect them. Additionally, Bibliotechnical

has submitted copies of the relevant filings for the Courts convenience.

Presumably Defendant will next argue that Plaintiff somehow miscaptioned the

Complaint in this matter by including only its d/b/a name and not its formal Israeli name.

However there does not appear to be any authorities holding that there is such a

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requirement and even if there were, the Court would be required to ignore such a lapse or

deem the paper amended. See CPLR 2101(f). ("A defect in the form of a paper, if a

substantial right of a party is not prejudiced, shall be disregarded by the court . . . .") Of

course it goes without saying that Bibliotechnical is ready to amend the Complaint to

include its full Israeli name if the Court prefers.

Despite NLG's attempt to divert attention from the central issues in this matter,

the fact is that Plaintiff has complied with the necessary corporate formalities.

V. No Parts of the Complaint Should be Stricken

As a fallback position to its motion to dismiss, NLG has sought to strike portions

of the Complaint describing the background of anti-Israel boycotts and emphasizing that

Bibliotechnical does not challenge NLG's right to hold anti-Israel or anti-Semitic

positions. In order to succeed in having parts of the Complaint stricken, NLG must show

(1) that the objectionable allegations are scandalous or prejudicial; and (2) that they are

irrelevant. Cassissi v. Yee, 46 Misc.3d 552, 557 (Sup Ct. 2014). If the material

included in the pleading is relevant to a cause of action, it will not be struck from the

pleading even though it is scandalous or prejudicial. Id.

In this case, Bibliotechnical's complaint contains background information

regarding the history of Israel boycotts and the goal of at least some boycott proponents

to destroy Israel. While this may be scandalous in the sense of "causing general public

outrage by a perceived offense against morality or law," (the dictionary definition of

scandalous) the only prejudice to Defendant NLG arises from its participation in anti-

Israel boycotts, which is the precise subject matter of the instant lawsuit. Put another

way, Bibliotechnical's allegations are scandalous only to the extent that they are relevant.

And if they are relevant, then they are proper contents of the Complaint.

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 The First Department has confirmed that background evidence is admissible. See,

e.g., People v. Frankline, 123 A.D.3d 504 (2014), aff'd, No. 89 (NY June 9, 2016).

(background evidence admissible to "complete the narrative"). Of course the same is true

here: NLG's decision to boycott Israel does not exist in a vacuum; it is not as though one

day NLG's president threw a dart at the world map and decided as a result to boycott the

Earth's only Jewish state. Nor does have NLG have any stated business reason for

boycotting Israel. Instead, NLG has unfortunately joined a movement with a long and

sordid history.

Further, the U.S. State Department has defined anti-Semitism as including

"Applying double standards by requiring of [Israel] a behavior not expected or demanded

of any other democratic nation." State Department Fact Sheet, June 8, 2010, available

online at: http://www.state.gov/j/drl/rls/fs/2010/122352.htm

Regardless of whether NLG agrees with the BDS movement's ultimate goals,

Bibliotechnical is entitled to submit narrative evidence and even evidence of the anti-

Semitism of the BDS movement both for sake of background and to show that NLG's

conduct is sufficiently reprehensible to justify an award of punitive damages. See BMW

of North America v. Gore, 517 U.S. 559, 575 (1996) (reprehensibility of Defendant's

conduct is relevant to punitive damages).

For these reasons, NLG's motion to strike should be denied.

VI. Defendant Has Not Demonstrated that Plaintiff's Attorney

Should be Disqualified

Courts in New York have consistently held that motions to disqualify counsel

should be held to a strict standard. As one Court observed, "when a lawyer invokes the

need to call an opposing attorney as witness and then acts to disqualify the witness as

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counsel, such motions are subject to strict scrutiny because of the likelihood for abuse

and use as a tactical device." Uribe Brothers Corp. v. 1840 Washington Avenue Corp.,

26 Misc.3d 1235(A) (Sup. Ct. 2010)

In this case, there is essentially no dispute over the transaction which underlies this

lawsuit. The entire transaction is set forth in an exchange of e-mails and excerpts from

NLGs web site, all of which have been submitted for the Courts convenience.

Therefore it is difficult to interpret Defendant's conduct as anything other than an abusive

attempt to retaliate for bringing Defendant's conduct to light.

Given this strong possibility of abuse, "[t]he movant, therefore, `bears the burden

of demonstrating specifically how and as to what issues in the case the prejudice may

occur and that the likelihood of prejudice occurring [to the witness-advocate's] client is

substantial." Interpharm, Inc. v. Wells Fargo National Bank, 2010 U.S. Dist. LEXIS

28802, No. 08 cv 11365, at *9-10 (S.D.N.Y. Mar. 25, 2010) (citation omitted). The party

seeking disqualification must bear a heavy burden of proof in order to prevail and mere

speculation will not suffice. Id. (citation omitted).

Here of course, the Defendant has offered nothing more than vague speculation

that Plaintiff's counsel is a necessary witness and has not specified what disputed issues

are at stake. This is hardly a surprise, since the Defendant admitted clearly and

unequivocally in writing that it was rejecting Plaintiff's advertisement on account of

Plaintiff's status as Israeli. Having been caught red-handed, what facts are left for

Defendant to dispute? See Disciplinary Rule 3.7(a)(1) (permitting lawyer to act as

witness if "the testimony relates solely to an uncontested issue.") Accordingly,

Defendant's motion should be denied.

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 It is also worth noting that Defendant's insinuation of unethical conduct on the

part of Plaintiff's counsel are ridiculous. By analogy, every Court and ethics opinion to

consider the issue has held that persons testing for violation of the anti-discrimination

laws have no affirmative legal or ethical obligation to warn anyone that they are testing.

See, e.g., NYCLA Ethics Opinion #737 (May 23, 2007) (Attorney may hire investigator

who uses dissemblance to test for violations of the civil rights laws).

And here, there was not even any dishonesty -- Plaintiff placed an advertisement

with the Defendant; paid two hundred dollars for it; and would have been happy to have

the advertisement run as submitted. Thus, this is not a situation like that of a typical civil

rights tester who has no actual intention to sign an apartment lease or accept a job if

offered. Here, the Plaintiff fully intended to place an advertisement if accepted and paid

the $200 fee.

Further, there has been no claim that the Defendant was represented by counsel at

the time the advertisement was placed. See also New York City Bar Association Formal

Opinion 2010-02 (Oct. 19 2010) ("[W]e conclude that an attorney or her agent may use

her real name and profile to send a friend request to obtain information from an

unrepresented person's social networking website without also disclosing the reasons for

making the request. While there are ethical boundaries to such 'friending,' in our view

they are not crossed when an attorney or investigator uses only truthful information to

obtain access to a website, subject to compliance with all other ethical requirements.").

Of course the same principle applies here: Plaintiff's counsel contacted an unrepresented

party using entirely truthful information. There was simply no ethical or legal obligation

to warn the Defendant that it was being contacted by a pro-Israel attorney.

Thus, Defendant's motion should be denied.

16

21 of 70
 Conclusion

For the foregoing reasons, the Defendant's motion to dismiss should be denied.

However, if the Court deems Plaintiff's pleadings to be deficient, Plaintiff respectfully

requests the opportunity to further amend them. Further, should the Court decide to

convert Defendant's motion into one for summary judgment, Plaintiff respectfully

requests the opportunity to submit further affidavits and/or take discovery.

Respectfully submitted,

___________________________

David Abrams, Attorney at Law

Attorney for Plaintiff

305 Broadway Suite 601

New York, NY 10007
Dated: New York, NY
September 28, 2016

17

22 of 70

 

23 of 70
FILED: NEW YORK COUNTY CLERK 07/13/2016 10:21 AM INDEX NO. 653668/2016
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 07/13/2016

1 of 7
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33 of 70
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35 of 70
36 of 70
Entity Information https://appext20.dos.ny.gov/corp_public/CORPSEARCH.ENTITY_IN...

NYS Department of State

Division of Corporations

Entity Information

The information contained in this database is current through September 23, 2016.

Selected Entity Name: BIBLIOTECHNICAL BLUE & WHITE LTD.

Selected Entity Status Information
Current Entity Name: BIBLIOTECHNICAL BLUE & WHITE LTD.
DOS ID #: 4911194
Initial DOS Filing Date: MARCH 11, 2016
County: NEW YORK
Jurisdiction: ISRAEL
Entity Type: FOREIGN BUSINESS CORPORATION
Current Entity Status: ACTIVE

Selected Entity Address Information

DOS Process (Address to which DOS will mail process if accepted on behalf of the entity)
C/O DAVID ABRAMS
PO BOX 3353 CHURCH STREET STN.
NEW YORK, NEW YORK, 10008
Registered Agent
NONE

This office does not record information regarding the names

and addresses of officers, shareholders or directors of
nonprofessional corporations except the chief executive
officer, if provided, which would be listed above.
Professional corporations must include the name(s) and
address(es) of the initial officers, directors, and shareholders
in the initial certificate of incorporation, however this
information is not recorded and only available by viewing
the certificate.

*Stock Information

1 of 2 9/26/2016 12:39 PM

37 of 70
Entity Information https://appext20.dos.ny.gov/corp_public/CORPSEARCH.ENTITY_IN...

# of Shares Type of Stock $ Value per Share

No Information Available

*Stock information is applicable to domestic business corporations.

Name History

Filing Date Name Type Entity Name

MAR 11, 2016 Actual BIBLIOTECHNICAL BLUE & WHITE LTD.

A Fictitious name must be used when the Actual name of a foreign entity is unavailable for use in New York State. The
entity must use the fictitious name when conducting its activities or business in New York State.

NOTE: New York State does not issue organizational identification numbers.

Search Results New Search

Services/Programs | Privacy Policy | Accessibility Policy | Disclaimer | Return to DOS Homepage | Contact
Us

2 of 2 9/26/2016 12:39 PM

38 of 70



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53 of 70
Dinner Journal | National Lawyers Guild https://www.nlg.org/dinnerjournal

Show Your Solidarity With A Tribute To The 2016 Honorees

(https://www.nlg.org/convention/2016-nlg-honorees)

Please join us in congratulating this year's NLG honorees (http://www.nlg.org/convention/2016-

nlg-honorees) by placing an ad in the 2016 #Law4thePeople Convention Dinner Journal!

Every year (http://www.nlg.org/dinner-journal-archives), the NLG National Office publishes a keepsake

booklet in honor of the NLG awardees. The Dinner Journal is distributed at the Convention's Banquet
Dinner and cherished by Guild members for years to come. Placing an ad in the journal is a great way to
congratulate our outstanding honorees (http://www.nlg.org/convention/2016-nlg-honorees), recognize

1 of 2 6/26/2016 11:54 AM

54 of 70
Dinner Journal | National Lawyers Guild https://www.nlg.org/dinnerjournal

this years keynote speaker, Elle Hearns, publicize your firm or organization, or just share a message
of your ownall while supporting the Guild!

To submit your ad, complete the order form below and send the text of your message or camera-ready
ad (as PDF or JPEG, at least 150 dpi) to dinnerjournal@nlg.org (mailto:dinnerjournal@nlg.org) by June
15, 2016. (NOW MONDAY, JUNE 27). If you are submitting a group ad, please be advised that we can
only process one payment per order. All fees and materials must be received by the deadline to ensure
inclusion in the journal.

Every dollar raised through ads goes to make the Guild a stronger and more effective force for justice.
Your support means a lot to us. Thank you!

DINNER JOURNAL AD SIZES AND RATES

All dimensions are width x height in inches

Dinner Journal A) Back Cover - 6 x 9 (Only one available!) - $ 3,000.00

Ad *
B) Inside Front or Inside Back Cover - 6 x 9 - $ 1,000.00
C) Page Spread - 6 x 9 (two) - $ 1,500.00
D) One Full Page - 6 x 9 - $ 850.00
E) Half Page - 6 x 4.5 - $ 500.00
F) 1/4 Page - 3 x 4.5 or 6 x 2.25 - $ 350.00
G) 1/8 Page - 3 x 2.25 - $ 200.00
H) Your name/organization included on a list of NLG supporters - $ 100.00

Total Amount $ 0.00

Email Address *

Confirm Payment

To register for the 2016 #Law4thePeople Convention and learn more, visit nlg.org/convention
(http://nlg.org/convention).

(http://civicrm.
empowered by )

2 of 2 6/26/2016 11:54 AM

55 of 70

 

56 of 70
Bibliotechnical Mail - Ad for Dinner Journal https://mail.google.com/mail/u/0/?ui=2&ik=e588c9d79e&view=pt&sear...

David Abrams <dnabrams@bibliotechnical.com>

Ad for Dinner Journal

3 messages

David Abrams <dnabrams@bibliotechnical.com> Sun, Jun 26, 2016 at 12:08 PM

To: dinnerjournal@nlg.org

Hi, I am interested in placing the attached advertisement in the upcoming dinner journal.

Is it a problem that the organization is Israeli? I realize that this is a sensitive issue.

If everything is okay, shall I pay the $200 online with a credit card?

Thanks, Dave

Dave Abrams

2 attachments

dinner journal ad 062616.jpg

22K

dinner journal ad 062616.pdf

20K

David Abrams <dnabrams@bibliotechnical.com> Mon, Jun 27, 2016 at 1:53 PM

To: dinnerjournal@nlg.org

Hi, further to my last e-mail, I have made the $200 payment.

I am re-submitting the ad in jpg and pdf form; Please let me know if there are any issues. Thanks, Dave

Dave Abrams

[Quoted text hidden]

--
David Abrams
Principal Officer
Bibliotechnical B & W Ltd.
305 Broadway Ste. 601
New York, NY 10007
646-801-3456

2 attachments

1 of 2 9/26/2016 12:44 PM

57 of 70
Bibliotechnical Mail - Ad for Dinner Journal https://mail.google.com/mail/u/0/?ui=2&ik=e588c9d79e&view=pt&sear...

dinner journal ad 062616.jpg

22K

dinner journal ad 062616.pdf

20K

NLG Dinner Journal (Law for the People Convention) <dinnerjournal@nlg.org> Mon, Jun 27, 2016 at 2:03 PM
To: David Abrams <dnabrams@bibliotechnical.com>

Hi David,

Thank you for reaching out. Unfortunately, we have a resolution barring us from accepting funds from Israeli organizations. Your
refund to your credit card will be processed tomorrow (there is a 24 hour waiting period before we're able to process any refunds).

Best,
NLG National Office
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Bibliotechnical Mail - Transaction Refund from National Lawyers Guild ... https://mail.google.com/mail/u/0/?ui=2&ik=e588c9d79e&view=pt&sear...

David Abrams <dnabrams@bibliotechnical.com>

Transaction Refund from National Lawyers Guild for $200.00 (USD)

1 message

Auto-Receipt <noreply@mail.authorize.net> Tue, Jun 28, 2016 at 10:54 AM

Reply-To: Pooja Gehi <director@nlg.org>
To: David Abrams <dnabrams@bibliotechnical.com>

REFUND CONFIRMATION
Order Information
Description: Online Contribution: Dinner Journal
Invoice Number f4d1cec83cc25e4a4c3b

Billing Information Shipping Information

David Abrams
PO Box 3353 Church Street Station
New York, NY 10008
US
dnabrams@bibliotechnical.com

Total: $200.00 (USD)

Payment Information
Date/Time: 28-Jun-2016 7:54:06 PDT
Transaction ID: 8524820617
Payment Method: Visa xxxx8941
Transaction Type: Refund
Auth Code:

Merchant Contact Information

National Lawyers Guild
New York, NY 10038
US
director@nlg.org

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