ריכטער: שאנסן פאר די זאלי סטעי......נול, זעראו

Second, for a variety of reasons, Movants are in danger of suffering immediate irreparable
injury if a stay does not issue. It is no exaggeration to say that at this moment the
stability of the Congregation and its numerous charitable, religious, educational and
social functions around which the lives tens of thousands of devoted and loyal Satmar
followers revolve. The stability is more precarious than it has ever been in the
Congregation's fifty-seven year history.

• There is a clear and present danger that the Friedman Dissidents will spark
another violent riot in the Congregations main synagogue by seeking once again to forcibly
seize the premises. Physical violence, threats, vandalism and intimidation and disruption
of religious services accompanied the last such effort. They did it before and they will
do it again, if given the opportunity.

• The Friedman Dissidents are likely to seize control over the Grand Rebbe's
personal residence, the revered leader of the Congregation since 1979 whom they have
denigrated as a mere employee thereof.

• A takeover over the Satmar school system by Berl Friedman could have severe
impact on tens of thousands of school children whose teachers are at risk of being
summarily replaced, merely because of their allegiance to Rabbi Zalmen Leib Teitelbaum.
Likewise, children from families who are loyal to Rabbi Zalmen Leib Teitelbaum are at risk
of being expelled.

• As the transfer of the Cemetery Property shows, Berl Friedman has no hesitancy to
transfer extremely valuable property of the Congregation without Supreme Court approval or
notice to the Attorney General. The value of the real estate at risk is conservatively
estimated at over $100 million. Similarly, there will be nothing to prevent Berl
Friedman from looting the Congregation's multiple bank accounts, with considerable liquid
assets.

• Unless stayed. the assets of the Congregation will fall into the hands of not
only Berl Friedman, but also federal convict Isack Rosenberg, who has pled guilty to
bankruptcy fraud, submitting false financial in*ation under penalty of perjury, and who
was reported to having engaged in money laundering. One can only shudder at the thought
that such a scoundrel would be unilaterally installed at the apex of the Congregation's
lay leadership.

• Approximately 6,000 members of the Congregation have intentionally paid dues to
the Congregation and specifically not Berl Friedman's shadow congregation are on the verge
of watching Berl Friedman seize and divert their contributions.

• The famed Satmar Matzah factory which has recently entered its period of peak
activity in the months leading up to the Passover holiday is at risk of being overtaken by
Berl Friedman, who might hire his friends and supports without regard to the fact that
this would interrupt the operations of the Matzah factory.

The preceding list is merely illustrative but by no means exhaustive.