Response to Indictment 1
- The defendant denied the aforementioned in the first charge. According to the defendant, Reuven initially inadvertently priced the project between NIS 10,000-12,000, and after it became clear that the scope of work on the project was greater than his initial estimate, Reuven changed the pricing to NIS 15,000. Later, when it became clear once again that the scope of work on the project in question was much larger than planned, Reuven priced the project at a cost of NIS 71,000, but the defendant managed to reduce the project's pricing significantly in relation to the price demanded by Reuven.
Charge 1 - Evidence
The Prosecution Case
Reuven's testimony
Main Investigation (Transcript of July 19, 2021)
General Regarding Charges 1-3
- An indictment was filed against Reuven for his part in charges 1-3. His case ended with a plea bargain and a sentence, and his case is final (p. 296). Reuven refused to come to the State Attorney's Office for preparation for testimony (p. 297). At an advanced stage in his initial interrogation, at the request of the prosecutor, Reuven was declared a hostile witness and was cross-examined by the prosecutor. His statements to the police were submitted to the court file (P/67 - P/75B). During his interrogation with the police, he was initially silent when asked if he had given favors or money to the defendant, but after the first interrogation by the police, he began to cooperate with his interrogators (p. 302).
- The witness has been doing work for the IPS for two decades. He knew the defendant at the beginning of this period. Reuven received some of the IPS jobs after they were referred to him through the defendant, about 10-15 jobs (p. 298). The two used to talk on the phone and sometimes met. Reuven visited the defendant's home several times, when he installed bars for him, and participated in the circumcision of the defendant's son (pp. 302-303).
- Reuven used to transfer an account to the defendant and the defendant asked him to issue an invoice for a higher amount. Reuven received checks from contractors, and after receiving a check, he transferred a certain amount of cash to the defendant. When Reuven asked the defendant why he needed the sums of money in cash, he explained that he was required to carry out additional work on the project through other parties (pp. 311-312). At this point, Reuven was referred to his police interrogation, where he was asked if he preferred to close his eyes instead of asking the defendant what the cash was for, and he replied that if he had asked the defendant, it was impossible to know whether the defendant would have told him the truth and if he would have continued to work with him (P/70 of November 2, 2018). In relation to these words, Reuven stated in his testimony that "it is just" and that he is not obligated to ask anything, and that it is not his money (p. 313).
- Reuven was asked to address the defendant's claim in the confrontation between the two on November 4, 2018, according to which Reuven had been dealt with false accusations regarding the increase in invoice amounts because he (the defendant) claimed that Reuven was working negligently. Reuven replied that the defendant had the right to think so, and that he did not remember what he said to the police in relation to the defendant's words (p. 314). However, at the police, Reuven said that he was not negligent, that the defendant did not make such an accusation in real time, and that there were additional work that the defendant asked him to do for him. Thus, for example, the defendant spoke with him about projects at the Abu Kabir facility, a few days before Reuven's arrest (P/72 of November 4, 2018).
- In the framework of Reuven's testimony, an issue was raised that was not included in the indictment, but according to the accuser, it is important for understanding the "bribery method," and it is even one of the events that led to the opening of the criminal investigation.
This is a construction project in Neve Tirza Prison – the renovation of the "Savyon Courtyard" and the construction of a theater. In this project, a price quote was received from the defendant, with the estimate given by the defendant being NIS 230,000 (N/3, testimony of Lt. Col. (retired) Mark Alfasi, who served at the time as the Logistics Support Officer of the Central District (transcript of October 27, 2022, p. 464 ff.). The offer seemed exaggerated to Alfasi and Eli Yifrach, the Lt. Col. officer of Neve Tirza Prison, and they received another offer from Reuven, which did not include air conditioners and fire extinguishers, in the amount of approximately NIS 100,000 (see P/51 invoice dated January 10, 2018; P/93 - Work order by the IPS; P/89 - Price Quote for Execution).