I should note that Haim Toledano's immediate response (which is part of Appendix 15 to Michal's affidavit) from that day onwards was:
"Alon, she can't do that, and no settlement has been agreed. They also can't force us to close the accounts, they can ask for documents regarding any receipts." In response, Michal replies that he has scheduled a meeting at the branch that day and that Mr. Toledano must attend it.
I find it necessary to note and emphasize, already at this stage, that the Bank did not bring any evidence in support of the claim embodied in this announcement, as well as in Ms. Sigal Sadi Mantin's announcement dated November 23, 2016, in the internal correspondence between the Bank's employees, which was quoted above in paragraph 49, and in accordance with it - Mr. Toledano agreed that no more dividend funds would be transferred to the account after July 2016, and also that Mr. Toledano agreed to the closure of the Group's accounts - including in particular - did not testify to Ms. Sigal Sadi Mantin or Mr. Gabbay Chen. They are the ones who supposedly heard from "Makor Rishon" the words of Toledano as stated. Moreover, even though Toledano categorically denied the claim that such an agreement had been reached [see paragraph 24 of his affidavit], the bank did not question Mr. Toledano in this context as part of its cross-examination.
- Following the meeting, which apparently took place on December 6, 2016, Mr. Michal conveyed to Sigal Sadi Mantin, on December 13, 2016, information and documents that were requested in the framework of that meeting, and the latter confirmed and announced that she had forwarded them to Chen.
These include: a corporate declaration in the plaintiffs' accounts; a declaration regarding residency; a waiver of confidentiality form, and an Israeli corporation's declaration regarding FATCA.
- In addition, further to Chen Gabbay's request of December 7, 2016 to receive: separately with respect to each of the plaintiffs - a detailed description of the activity of each company in Israel and abroad, which will include a list of customers, a list of suppliers, controlling shareholders (where the controlling shareholders will have a name breakdown including identification numbers as individuals and not as companies) approved by an attorney; Details of the companies' customers, including: field of activity, whether it is an end or intermediate customer, in which country the customer is located and a valid license to work in that country - was transferred on 13/12/16:
As for each of the companies, Twiga Media and Twiga Online, a description of its activities, according to which: