Count one: Forceful indecent act and rapeThe charge was divided into three subsections:
Subsection 1 – Committing a forceful indecent act against A. of the Tourism Ministry: "The complainant was employed by the defendant as an executive assistant between 1998 and 1999. during that time, the defendant began adamantly pursuing her romantically, despite her refusing his advances.
"The defendant would attempt to engage the complainant in conversations of a sexual nature," read the indictment. "He would stroke her, hug her waist and try to kiss her against her will… On several occasions he tried touching her breasts and attempted to drive his hands under her shirt and make explicit sexual propositions.
"In April of 1998, the defendant asked if he could accompany the defendant to her Jerusalem apartment, after failing to discourage him, the complainant eventually agreed. Once in the apartment, the defendant backed the complainant (into a wall)… held her up to him and grabbed her breasts against her will. She managed to push him away and asserted her refusal to comply. The defendant then left the premises.
"(…) The complainant resisted the defendant's advance in various ways, even if somewhat subtle, as she was intimidated by his position and office" continued the brief. Nevertheless, her protest was clear to him."
Subsection 2 – The first rape of A. of the Tourism Ministry: "On April 1998, the defendant and the complainant both attended an official function in Tel Aviv. At the end of the evening, the defendant asked the complainant to accompany him to this office," read the indictment.
"Once in the office, the defendant attempted to touch the complainant's breast against her will. The defendant then attempted to remove the complainant's trousers, but she was able to resist. He then grabbed her, forced her down to the floor and proceeded to forcibly remove her trousers, despite her attempts to resist. He then unzipped his pants, laid on top of her – using his weight to restrain her – and penetrated her against her will."
A. was eventually able to fight Katsav off, added the State Prosecutor's Office, and hoping she was finally able to illustrate her disinterest in a sexual relationship with the defendant – the complainant returned to work the next day, hoping to put the incident behind her.
Subsection 3 – the second rape of A. of the Tourism Ministry: "On June of 1998, the defendant asked the complainant to meet him at the Plaza Hotel in Jerusalem under the pretext of business. though assuring her they would meet in the lobby, once the complainant arrived in the hotel, the defendant asked her to come up to his room, as he was 'still getting ready.'"
Once in Katsav's hotel room, continued the indictment, the complainant discovered the defendant half dressed. "He then proceeded to push her down onto the bed, and pull her trousers and undergarment down despite her resistance… The defendant pinned her down, laid on top of her and attempted to force sexual intercourse on her, assuring her she will 'enjoy it.' The complainant vigorously resisted the act and was eventually able to fend him off.
"Again, fearing for her job, she attempted to ignore the incident and resume normal working relations with the defendant. Over time, and once he realized she will not comply with his advances, the defendant began mistreating her and stripping her of her professional responsibilities in his office… he eventually fired her."
Count two – sexual harassment
In the case of complainant H., of the Office of the President: "The defendant was president of the State of Israel between 2000 and 2007… H. was employed in his office and his bureau chief between May and November of 2003.
"During the course of her work," continued the indictment, "The defendant would often call her into his private office and hug her for extended periods of time, despite the fact that she asserted she was not interested in his advances. He also made explicit, repeated references as to her sexuality, thereby harassing her."
Count three – sexual harassment
In the case of complainant L., of the Office of the President: "In late 2005 the complainant was tasked with organizing the defendant's formal 60th birthday party and the two had numerous meetings in that regard. During the meetings, the defendant would make intimate remarks at the complainant, comment on her appearance and pry into her personal life.
His remarks soon turned to a sexually explicit tone, argued the State Prosecutor's Office, "And he ignored all her attempts to avoid such matters. In late December of 2005, the defendant managed to solicit the complainant into giving him 'a birthday hug.' He then held her up against him tightly and attempted to caress her neck. The complainant, distraught, ran out of the office crying."
"The State alleged that in his act, the defendant sexually harassed the complainant and abused the power of his office to do so."
Count four – obstruction of justice and witness tampering
In the case of complainant L., of the Office of the President: "In September of 2006 the complainant was questioned by the police in connection with her sexual harassment charge. Later that month, the defendant called her into his office and attempted to make her divulge details of her police session.
"The defendant ignored the complainant attempt to avoid the subject and continued to recount his recollection of the events, saying that he only kissed her as 'a sign of his deep appreciation of her dedication.' The complainant remained silent.
"The defendant than asked the complaint to tell him what she said to the police, so that he 'would know what to say' should he be questioned about the incident. The complainant informed him that she was unwilling to discuss the matter. The defendant then told her to keep their conversation confidential, demonstrating intent to obstruct justice."