Our reference AJ

Sally Hunt
General Secretary
Association of University Teachers
Egmont House
25-31 Tavistock Place
London
WC1H 9UT

10 May 2005

BY FAX & BY POST

Dear Madam

The University of Haifa

We act for the University of Haifa. Our client has been defamed by a
resolution passed at your annual Council Meeting. This resolution now
appears on your website. The defamation is therefore a continuing one.

At its annual Council Meeting held on 20-22 April 2005, the AUT passed a
number of boycott resolutions aimed at Israeli academics and institutions.
Among those was a resolution calling upon AUT members to boycott our client.
The resolution received the most perfunctory debate, it was held at a time
that made it impossible for most Jews to attend, requests for the
rescheduling of the debate were refused, and no delegates were allowed to
speak against the resolution.

The allegations made against the University of Haifa in the resolution are
damaging to its reputation. These allegations, which are false, were not put
to the university prior to the debate on the resolution.

This letter has two purposes: first, to give you the information that you
would have received had you consulted with the university prior to the
resolution being put; and secondly, to communicate to you the university's
position in relation to the AUT's role in assisting the resolution's
sponsors and thereafter disseminating its defamatory allegations.

The resolution

In summary, the resolution alleges that:

1. On 15 May 2002, Dr Ilan Pappe received a letter notifying him that he
faced trial and possible dismissal from his position on the grounds that he
had violated "the duties of an academic member of staff" and that he had
"slandered departments and members in the humanities faculty, damaged their
professional reputation and endangered the possible promotion of some of
them."

2. "These accusations related to Dr Pappe's efforts to defend a . graduate
student, Teddy Katz, whose Master's thesis was under attack by an Israeli
veteran's organisation because it documented a massacre of 200 unarmed
civilians by the Haganah (the pre-state army of Israel) at a village called
Tantura, near Haifa."

3. "The recriminations are still continuing and Dr Pappe's job is still
being threatened."

4. The university has failed in its duty to uphold academic freedom and in
particular, it victimises staff and students who undertake research in
respect of events immediately prior to the founding of the State of Israel.

5. The university has subordinated its obligations in respect of academic
freedom to the support of Israel's colonial and racist policies (an
extrapolation from the "Palestinian Call" referred to at (ii) of the
resolution).

The defamations of the university, though multiple and serious, amount to
the proposition that it is not, at any rate in respect of research into the
character and origins of the State of Israel, an institution that places the
values of academic freedom above its corporate commitment to the State, to
the present Government of the State, and to the Government's policies.
Indeed the university, the resolution insists, persecutes those of its
members who dare to dissent from those policies even when their dissent is
founded in unimpeachable research.

The truth

Had the council agenda committee contacted the University of Haifa before
allowing the resolution to be put it would have discovered the following:

1. Dr Pappe has never been subject to disciplinary proceedings in relation
to his support of Mr Katz's thesis.

In March 2002, a complaint was made by the then Dean of Humanities against
Dr. Pappe. The Dean claimed that Dr Pappe had slandered departments and
staff members of the Faculty of Humanities, thereby damaging their
professional reputation, and endangering the possible promotion of his
colleagues. The complaint was copied to Dr Pappe, among others, on 5 May.

The Academic Disciplinary Court of its own volition dismissed the complaint
on 19 May. Dr Pappe was not called upon to offer any defence. He was
promptly notified of the decision on the 21 May.

2. When Mr Katz first presented his thesis - which alleged that members of
the Alexandroni Brigade had massacred some 200-250 unarmed Arab citizens -
he was awarded 97%.

However, following legal action by members of the Brigade, Mr Katz admitted
in court that there was no basis to the claim that a massacre in

3 Tantura took place. He added that he believed the Alexandroni veterans
(who denied the massacre), and offered his sincere apology to the soldiers
and their families. He retracted his claim concerning a "massacre." This
retraction was accepted by the Tel Aviv District Court and was given effect
as a judgment of the Court.

Mr Katz later made attempts to withdraw his retraction and appealed to both
the District and Supreme Courts. The appeals were dismissed.

The university thereupon established an academic committee of enquiry
composed of faculty members unconnected with the preparation of the thesis.

The committee was instructed to examine the adequacy of Mr Katz's
transcripts of interview tapes in his thesis. The committee found that in
some places there were significant discrepancies between the tapes, Mr
Katz's own notes, and the text of his thesis.

The Graduate Studies Authority (GSA) gave Mr Katz the opportunity to correct
the thesis. Upon revision and resubmission, it was sent to five reviewers.
Their reports were highly critical of its research quality. Based upon these
reports, the GSA decided that the MA degree based on research should be
withdrawn and that an ordinary MA degree be awarded in its place.

3. Dr Pappe holds tenure at the university, and his job is therefore secure
for life.

There have never been any recriminations from the university itself against
Dr Pappe, whether due to his support of Teddy Katz or his calls to boycott
Israeli academic institutions. Indeed, the university has shown great
tolerance towards Dr Pappe despite his own obvious contempt for it.

Nevertheless, and in this regard, no action of any kind has been taken
against Dr Pappe by the university, nor has any action against him been
threatened.

4+5. The University of Haifa is committed to the principles of equality, due
process and freedom of expression. The latter includes, without limitation,
the expression of religious and political opinion. The university is not, as
the resolution suggests, an institution that demands conformity to a
particular view. On the contrary, it prides itself on its encouragement of
diversity of opinion among its students and faculty members. In consequence,
approximately 20% of its current student population comprises Arab-Israelis.

Dr Pappe's own department, the School of Political Science, reflects the
diversity of the university at large. Between them, Dr Pappe's colleagues
have espoused views that reflect the entire political spectrum in relation
to the Israel-Palestinian conflict. None has been reprimanded.

The University of Haifa's position

The AUT has, both by the assistance it gave to the resolution's sponsors and
by its publication of the resolution on its website, defamed the University
of Haifa. Our client is entitled to seek damages, a retraction, and an
undertaking against further publication of the defamations. It reserves its
position in this regard.

In the meantime, it awaits the outcome of the Special Meeting to be held on
26 May 2005. It trusts that, once equipped with the truth, the delegates
will vote to overturn the boycott.

Please confirm that a copy of this letter will be made available forthwith
to all AUT members.

Yours faithfully

Mishcon de Reya
Mishcon de Reya Solicitors
Direct Tel: +44 20 7440 7025
Direct Fax: +44 20 8203 0981