24. Two copies of January 28, 2025 "Initial Estate Inentory" [פרטה] that were forwarded on January 30, 2025, by Adv. Rachel Ben-Ari to Heir Joseph Zernik and to the APAK's office, Haifa and the North District

Background Submitting an "Estate Inventory Report" (Parta) to the heirs and to the Administrator General (APAC) within 60 days of appointment constitutes one of three core statutory duties owed by a lawfully appointed estate administrator toward the heirs. This duty is anchored in Section 84 of the Succession Law, 5725-1965, and in the Succession Regulations, 5758-1998, which specify the required reporting forms, including the text of the verifying affidavit. The legal and financial significance of the inventory is decisive, as it serves as the baseline for evaluating all future financial reporting and monetary movements within the estate. Additional core duties of an estate administrator toward the heirs include: (a) submitting periodic financial reports in accordance with regulations, and (b) providing full responses to any request for information from the heirs concerning the estate. The Dispute at Hand In the estate file of the late Rivka Shami Zernik (Family Court Case EF 11650-06-24, Haifa), Advocates Rachel Ben-Ari and Yoav Salomon drafted an Estate Distribution Agreement, signed on August 28, 2023. In that Agreement, the two Advocates Were appointed Trustees for the execution of the Agreement. Moreover, filing court actions was prohibited, unless for enforcement of the Agreement. The 2 Advocates failed to even perform the initial actions for executing the Agreement. On June 5, 2024, they filed in court Application for Appointing Estate Administrators EF 11650-06-24. The Court process was fraught with Badges of Fraud according to Heir Joseph Zernik. Eventually, the two Advocates claimed to have been appointed Estate Administrators under a "Post-judgment Operative Order" (Psikta) dated December 1, 2024. They claimed to seize possession and control over the Estate's bank accounts and real estate assets using this instrument. However, in fact they had possession and control already earlier, based on Power of Attorney certificates that they had received from the Heirs as Trustees in the Estate Distribution Agreement. The Heir, Dr. Joseph Zernik, entirely contests these claims and clarifies that the Psikta is a legally void document and/or a forged instrument (within the meaning of Section 414(1) of the Penal Law, 5737-1977). He contends that the attorneys are acting while impersonating Estate Administrators. The heir's central argument rests, inter alia, on the fact that over a year and a half after their alleged appointment, no financial report has been filed, the submitted inventory document contains misrepresentations and material defects, and the attorneys refuse to provide information regarding the administration of the estate. Below are two copies of the "Estate Inventory Report" dated January 28, 2025. Both were transmitted on January 30, 2025, by Adv. Rachel Ben-Ari—one to heir Joseph Zernik and the second to the APAC offices in Haifa. The copy held by the APAC was forwarded on October 22, 2025, to heir Joseph Zernik accompanied by a cover letter (reproduced below). The analysis reveals prima facies evidence of deceit, forgery, and impersonation, raising serious questions regarding the conduct of the APAC's senior management and the 2 attorneys. Because the Administrator General serves by law as counsel to the Attorney General in certain proceedings, an inherent conflict of interest arises that prevents the Attorney General's apparatus from investigating the matter itself, necessitating the appointment of an independent Special Investigator.