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residency have been failed, too. (By then practically everybody could easily get such a visa). Israelis did not want to allow him and his

brother to immigrate to Israel.

1991. After his brother's death, Lev started to cancel all steps of immigrating to Israel. He did not want to go there by then. Soon he

received an order from KGB to leave his native country for Israel. Soviet authorities sent us (family Gunin) all previously suspended visas.

We could not say "no" to KGB, but pla

L.Gunin's Polish friends, Israelis captured us, and took us to Israel by force. In Israel, Mossad (Shabbak) officers verbally accused Lev in an

attempt to sabotage the whole operation of bringing the Soviet Jews to Israel. Mossad approached him several times.

In Israel we faced next persecutions:

1) Israeli citizenship was thrust on us

2) Alla, Lev's wife, was abused, attacked, beaten, assaulted, and systematically discriminated against

3) Elisabeth, his mother, was abused, attacked, and assaulted

4) Children became victims of systematic humiliations and mockery

5) Lev himself was deprived in his rights. Israeli authorities denied him:

a) valid diploma equivalent

b) professional courses

c) rights to enter other courses or university

d) full and valid employment authorization

e) registration with the State labor exchange

f) tax exemption as all fresh immigrants were receiving

g) welfare when he was unemployed

h) proper and equal medical service

i) legal, and police defense

j) reduction of municipal taxes

k) authorization of departure, which is required in Israel to leave the country

l) etc.

He was beaten, abused, discriminated against. Israeli state radio called him an enemy. One of the leading Israeli newspapers suggested

that his works (essays, articles, etc.) must be destroyed. I

and his (his family) financial situation.

During his life in Israel L. Gunin published a number of articles books in Israel, Lithuania, Poland, Moscow, and Germany, criticizing Israeli

government for human rights violations and fascist tendencies in Israel.

1994-1996. With an indirect Amnesty International's involvement we could come to Canada, and claimed a refugee status. To support our

claim we presented next types of documentary proof:

A. Legal documents

B. Documents, issued by Israeli government

C. Documents, issued by all kinds of Israeli institutions

D. Affidavits

E. Letters

F. Post receipts

G. Medical documents

H. Newspapers

I. Researches made by International committees and human rights organizations

J. Proof that in Israel we turned to i





K. Our lawyer's documents

L. Etc.

Practically each statement, described in our refugee claim, was supported by the documentary proof. Only the list of documents' description

consisted of six pages.

1994-1997. In her translations, our lawyer's secretary/translator distorted all documents in our refugee claim. One of our two lawyers

submitted several messages to IRB in protest of some outraged events. He claimed that the IRB members took advantage of the distorted

translations, using them as a tool against us. IRB members used offensive, illegal methods against Lev. They interrogated only him. No

questions were given to other family members. IRB commissioners demonstrated their opinion that Lev GUNIN must be punished for his

ideological (political) views. Two members of IRB, immigration judges, gave the whole initiative to the third member, an immigration officer, a

Jew and - probably - Israeli, who only spoke. During our refugee hearings she manifested an outraged malicious hatred towards us, and

maintained close contacts with the Israeli embassy in writing, in our case. IRB members maintained the atmosphere of hostility and

arbitrary attitude towards us.

Denying our refugee claim, the IRB members not just acted unfair. Their negative decision was not just a refusal to recognize us as

refugees, but a declaration-manifest, which rejected the basic human rights in principle. In form of declaration, they denied in principle rights

to have an independent opinion, practice or not to practice religion, be protected by the state. IRB members claimed that if government

paid for immigrants' transportation, immigrants became the property of that government (a kind of commodity). IRB members also claimed

that police' and other institutions' refusal to give protection was justified if people had an alternative political /ideological opinion (even if that

opinion was not expressed to police). They claimed that we alienated Israelis by keeping controversial opinions, and refusing to change our

views. And so on...

The IRB's negative decision became not just a matter of our personal fate, but also a matter of human rights in general.

1998. In her speech in the Federal Court, Mrs. Murphy, the Minister's of Immigration representative, confirmed the IRB members' negative

attitude towards human rights, and also widened personal accusations against Lev Gunin, turning the question of our refugee status into

the question of his "inadmissible" (by whom?) ideological views. As IRB did before, Mrs. Murphy refused even to mention Alla Gunin,

Elisabeth Epstein (Gunin), and the children.

The Federal Judge, Mr. Dube, just copied Mrs. Murphy's and the IRB statements, refusing to evaluate arguments of the TWO sides. He

claimed that - because in their refusal to recognize us as refugees IRB members used the formula "no minimal credibility", - such cases are

automatically denied by the Federal Court. In reality, his decision was made in contradiction to another Federal Court judge's decision in our

case, and also contradicted the IRB's final (conclusive) decision. In that decision IRB agreed that some persecutions against us (they

called them "difficulties") could take place because we abused the Israelis by refusing to obey their demands to change our views. Mr.

Dube also revealed his partiality by distorting some important events and attacking our lawyer in personal. A person, whose name was also

Dube, was involved into negotiations between the immigration officer, Mrs. Malka, and the General Consul of Israel, in our case. We could

not find that person among the IRB headquarters' staff, or among other immigration divisions. All faxes were submitted to Israeli consulate

from Mrs. Malka, without mentioning any other name (s). However, the responses from the consulate were submitted to Mr. Dube. We feel

that this mysterious Mr. Dube has something what to do with the Federal Judge Mr. Dube.

IRB and Mrs. Murphy's accusations against us were such, which are the prerogative of the criminal court. They accused us so sharp as if

we were killers or terrorists. In reality we are i

might be easily considered as a criminal offence.

We are appealing not just because of incredible injustice, but because the removal back to Israel means DEATH for us. If nobody in the

whole world could prevent it, it would mean that if people are deprived and i

by force. It would mean that demonstrative humiliations over human rights, such as the IRB members and Mrs. Murphy expressed, are