Moreover, as can be seen from the chronological description above, in some cases, in the framework of the electronic messages, material was transferred by the plaintiffs for review by the bank's authorized employees. However, in some cases, the bank did not present notices indicating that this material was transferred to the relevant parties for the purpose of examining the material and its suitability - i.e., to the employees of the Compliance Department. With regard to this - one is - either the bank's employees did not transfer the material to the compliance department at all, a failure that may support the claim that the bank did not want to examine the material that was transferred at all, since its decision was made and all of its activity was a "cover" in order to justify it. Or the material was transferred but the bank - contrary to a judicial order - did not present these documents. In the context of the bank's failure to present documents - which are not only relevant but are at the core of the dispute - it is even possible to refer to its failure by attaching a closure letter that is indisputably drafted in January 2017 and is even mentioned in correspondence.
Moreover, in the course of the testimonies, it became clear that the bank documents all of its conduct vis-à-vis its customers in two additional systems - one is the CRM system and the other is the "Atlas" system, and despite the aforesaid, the court was presented with only one single document from one of these systems [Appendix 3 to Lotem's affidavit. As to the existence of the systems, see Mr. Lotem's testimony dated May 15, 2018 regarding the existence of a CRM system on page 12 and regarding the existence of the Atlas system on pages 31-32; see also the testimony of Mr. Shaulson regarding the existence of a CRM system on pages 83-86 and regarding the Atlas system on pages 86-88; Moreover, the existence of these systems also emerges from the correspondence, in which there is mention of real-time documentation in the CRM system- This is how we can refer to a letter dated November 21, 2016 from Mr. Chen Gabbay, which was mentioned in paragraph 49 above, a letter dated November 22, 2016 from Mr. Gabbay, and a letter from Ms. Sigal Mantin Sadi, which is mentioned in paragraph 56].