Kotler claimed that the defendant knew very well from the outset that his work was done at the preliminary stage and upon the signing of the agreement with her, and in parallel with the signing of the agreement with the chosen attorney, the plaintiff's role had ended and she was awaiting the results of the proceeding (paragraph 31 of the affidavit). According to him, it was not his job to clarify to the defendant at what stage his role ended and the role of Adv. Meyuhas began, and this should not be written in the agreement, since it is a continuum of treatment, where the agreement constitutes a "sequence of agreements" made one after the other (p. 108, lines 2-4, 7-8, 12-13, 26-29, p. 109, lines 10-13, p. 110, lines 15-16, 23-26, p. 111, lines 22-23, p. 126, lines 26-27, p. 127, line 1, p. 128, line 25, p. 132, line 3). Kotler's claim regarding the defendant's knowledge that his position ended upon the signing of the agreement was in fact left unchecked, without any objective evidence to verify it.
On the other hand, he claimed that he had performed treatment over the years. In his supplementary affidavit dated September 22, 2024, he claimed that after the formation of the group and even after legal proceedings were taken on its behalf, he acted in cooperation with the Meyuhas law firm and followed the proceedings. Kotler attached to his affidavit various documents which, according to him, refute the defendant's claims, as if he had not carried out "treatment" over the years (paragraphs 5, 8 of the supplementary affidavit). In doing so, in effect, he contradicted his version that his work ended with the defendant signing the agreement.
In her summary, the plaintiff claimed that these documents attest to the enormous scope of the work she performed, including mapping and concentrating the assets, compiling lists of tenants identified by her, convening meetings and conversations with those tenants, and litigating with the Meyuhas law firm, so to speak, for more than a year (section 7). However, all of the actions described were carried out by the plaintiff at the preliminary stage, during which Kotler worked to form a group, andthey do not provide a response to the plaintiff's explicit obligations to the defendant.