On January 21, 2004, charges were brought against businessman and Likud activist David Appel, for alleged bribery of public officials. Among those mentioned as a recipient of an alleged bribe was Prime Minister Ariel Sharon.

The following is an extensive translation of the indictment, as filed at the Tel Aviv Magistrate's Court by prosecutors Rahel Shiber and Ella Rubinek. The original indictment is 33 pages long, including 7 pages listing 209 witnesses. The prime minister's son, Gilad Sharon, is listed as witness 207.

Amended Indictment

General Section

1. Over the course of the years, Accused #1 [David Appel] accumulated much power and influence over people in government at the national and municipal level. His stature gave him access to and direct contact with government officials at all levels.

2. Starting in the 1990s, Accused #1 began to be active part in various party affairs, including those relating to appointments to political and public positions and became known as someone with power and influence in this regard.

3. Starting in the 1990s, Accused #1, by himself and via companies he controlled, started to work in real estate development in the central region, primarily in Lod and Givat Shmuel.

4. In order to promote Accused #1’s interests and those of the companies he controlled, it was important to have the support of the local authority heads in the places mentioned, senior officials in the Israel Lands Administration (hereafter: the ILA) and other public servants who were or might be connected to his business interests.

5. As will be detailed in this indictment, Accused #1 attempted to gain the support of the above-mentioned public servants for his business affairs in one or more of the following ways: a. by providing financial benefits, which he granted with the aim of ensuring their continued tenure as public officials or in payment for their activity on his behalf; b. by using his position, power and connections to promote their interests. c. By creating expectations among public officials, inter alia through promises or creating the impression that Accused #1’s status and contacts would be available to them to advance their affairs.

6. Accused #2 [Migdal Hazohar Construction, Ltd.] is a real estate development company established in 1991.

7. Accused #1 is one of the two beneficiaries of Accused #2. This fact was concealed by Accused #1 and Accused #2. In the relationship between Accused #1 and Accused #3 [Benjamin Ben Jacob Tabin] served as the front man for Accused #1 and carried out financial transactions at his behest and for him.

Charge one: against Appel alone

A. General section

1. During the periods relevant to this charge sheet, Ariel Sharon served as an MK as well as in the following public positions: from July 8, 1996 to July 6, 1999 he was minister of national infrastructure and responsible for the ILA; foreign minister, acting chairman of the Likud Party, chairman of the Likud Party and a candidate for prime minister. On February 7, 2001, he was elected prime minister and on March 7, 2001, he was sworn into office. Therefore, while serving in all of the above positions, Ariel Sharon was a public servant as defined by law.

2. During the periods relevant to this charge sheet, the following public servants served in the following positions: a. Ehud Olmert was the mayor of Jerusalem (and therefore a public servant). b. Shula Zaken was the senior adviser to the mayor of Jerusalem and his office director. c. Amos Radian was the political adviser of the mayor of Jerusalem, on loan to the Jerusalem municipality from the Foreign Ministry. d. Ruchama Avraham was employed on the project as the material coordinator.

The Tourism Project in Greece

3. In 1998, as part of his business enterprises, Accused #1 began planning the construction of leisure and tourism centers in several locations around the world (hereafter: the project). He sought to build the first vacations resort on the Greek island of Patroklos, southeast of Athens (hereafter: the Island Project).

4. During 1998, Accused #1 began negotiating with the island’s owners to purchase it. Some time before December 1998, Accused #1 was in contact with Norman Skolnik, a former Israel and resident of Greece with numerous connections in Greece. Skolnik oversaw the contacts with the island’s owners and attempted to promote the enterprise via key figures in the Greek government.

5. The success of the Island Project, which was classified as an archeological site, entailed, among other things, legislative amendments in Greece and a change in the land use designation and planning and construction procedures, the granting of a franchise and tax breaks. Accused #1 felt that closer ties with Greek public figures would help him achieve this objective and worked with Skolnik to attain them. As part of this effort, Accused #1 sought to invite them to visit Israel on the pretext of an official or state visit, and arrange for them meetings with senior Israeli figures. In this way, Accused #1 sought to impress the Greek public figures and obtain their support for the Island Project.

6. During 1998, Skolnik found out that the Israeli Labor Party and the Greek ruling party, Pasok, were in contact to arrange a visit to Israel of a Pasok delegation as the guests of the Labor Party.

7. In 1998, Skolnik, in agreement with Accused #1, worked on getting the Labor Party to finalize the visit, by offering to pay for part of it and even approached the Israeli Foreign Ministry which was headed at the time by Ariel Sharon, asking for it to approve Skolnik’s participation in the meetings with the delegation, which was to be led by the Greek deputy foreign minister, Iannos Kranidiotis (hereafter: the deputy foreign minister’s delegation). Eventually, a meeting was arranged for January 10, 1999.

8. Shortly before the delegation’s arrival in Israel, Accused #1 and Skolnik arranged the schedule for the visit, with Accused #1, directly or indirectly, even funding a substantial share of the costs and working with his acquaintances to coordinate a visit to the Palestinian Authority by the delegation, to coordinate a visit to the Knesset and to coordinate its meetings with Labor Party officials.

9. On January 11, 1999, Accused #1 contacted Sarah Elman, the foreign minister’s bureau chief, in order to arrange Skolnik’s inclusion in the deputy foreign minister’s delegation’s meetings with the [Israeli] foreign minister and with the Foreign Ministry Director General Eitan Ben Tzur. Elman had trouble permitting this given the opposition of various Foreign Ministry officials to Skolnik’s inclusion in meetings of a diplomatic nature. However, in the afternoon of January 12, 1999, when the two above-mentioned meetings took place, Skolnik was present at them.

10. Before January 12, 1999, Accused #1 had invited Foreign Minister Ariel Sharon and his son, Gilad, to a dinner at his home on the evening of January 12, 1999 in honor of the Greek deputy foreign minister. He also invited other Israeli guests. Ariel Sharon and Gilad Sharon accepted the invitation.

11. The following day, January 13, 1999, at the Sheraton Hotel in Tel Aviv, Accused #1 and his associates presented the project to the leaders of the deputy foreign minister’s delegation.

12. In mid-1999, or thereabouts, as part of the plan described in section three above, Skolnik told Accused #1 that Dimitris Avramopoulos, the then-mayor of Athens, is a key figure in Greek politics and might possibly lead the country in the future. Consequently, Accused #1 decided to try and arrange for the invitation of the mayor of Athens to Israel, present the project to him and attempt to obtain his support and advocacy.

13. Later on, as will be detailed below in the second charge, Accused #1 asked Olmert to invite the mayor of Athens to Jerusalem. Olmert agreed to the request. The Athens mayoral delegation arrived in Israel on July 25, 1999.

14. On July 28, 1999, Accused # 1 hosted a dinner in his home in honor of the mayor of Athens. Accused #1 invited Ariel Sharon, who was at the time the acting chairman of the Likud Party, to this dinner and Sharon accepted the invitation. Gilad Sharon and other guests also attended the dinner.

15. In late October 1999, or sometime around then, when negotiations over the purchase of the island collapsed, Skolnik, after coordinating with Accused #1, began to search for alternate land in Greece. Skolnik found land in a gulf located southeast of Athens, but purchasing it also entailed numerous difficulties. At the same time, Accused #1 began searching in Spain for alternate locations for the project.

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