In practice, after Kotler and Adv. Meyuhas agreed on the division of labor and fees, Kotler worked to locate potential beneficiaries, market the idea, and form a group that would work to realize it. (paragraphs 9, 10 of the affidavit; paragraph 3 of the supplementary affidavit; Kotler's testimony, p. 107, lines 9-10, 27, p. 108, lines 22-24).
As Kotler explained, in order to form a group, he worked to locate property lessees who were facing the renewal of the lease for an additional period. To this end, with the assistance of Adv. Shemesh and Adv. Eidelman, he drafted a uniform version of an affidavit to various potential clients as well as a letter of authorization on their behalf, together with the profile of Adv. Meyuhas' office (paragraph 2 of the supplementary affidavit). This is the content of the request:
"From an examination we conducted, it became clear to us that the lease period with the municipality of a civil file of the property in your possession is about to expire according to the agreement with the municipality (municipal land).
The renewal of the lease requires active action on your part, in order to exercise your rights to continue using the property in your possession.
Failure to do so on time creates a contractual problem for you, which may prevent you from exercising your rights, or alternatively, obligate you to make significant and unnecessary financial payments.
From a legal examination we conducted with the law firm of Yitzhak Meyuhas & Co., it became clear that it is possible and desirable to take legal and appraisal action in order to reduce the amounts due to the Tel Aviv-Jaffa Municipality. The examination also shows that it is possible to make a number of legal claims, some of which are very unique, that will enable you to reduce your financial liability to the municipality." (Emphasis in the original - D.W.).
As mentioned, this inquiry was sent to many potential customers.
On November 8, 2009, Kotler sent the aforementioned request to Fischer by email (Appendix 3 to the supplementary affidavit, p. 357). This request was also sent to Adv. Rotem (paragraph 4 of Rotem's affidavit, Appendix 1 to the affidavit).