In a Decision – Ben-Haim v. New Israel Fund, (an "Unreported Decision") >> the Court Held:
The Appellate Division affirmed the Trial Court’s determination that a non-US Defendant could not be sued in New Jersey without minimum contacts to and with New Jersey.
Husband and Wife were married in New Jersey in 2008. They subsequently had a child. In 2010, while on a family vacation in Israeli, Wife filed for divorce in the rabbinical courts of Israel and refused to return to New Jersey and would not allow the child to return. Husband unsuccessfully sought relief from an Israeli court and returned to New Jersey, where he obtained a court order that directed the child's return. In 2013, Husband obtained a default judgment of divorce, which awarded him temporary custody of the child and again directed the child's return to New Jersey. Wife and the child have remained in Israel.
Husband filed the action against defendants claiming that they provided legal and financial assistance to Wife when she filed for divorce in Israel. Husband asserted causes of action that sounded in intentional interference with custody, defamation, intentional infliction of emotional distress, and civil conspiracy. The Appellate affirmed and found that HUSBAND had not established that any of defendants had minimum contacts with New Jersey.