ABOUDI & BROUNSTEIN
LAW OFFICES
3 GAVISH ST., POB 2432
KFAR SABA IND. ZONE 44641 ISRAEL
Tel. 972- 9-764-4833 Fax. 972-9-764-4834
E-Mail: david@a-blaw.com
David Aboudi, 1D.*
Gerald Brounstein, LL.B.**
Jeffiey Moskowitz LLB.
* Monier of thera d& New York Bars
* Member ofthe lal & Ontario Bars
Ostober 21, 2009
By E-mail Without Prejudice
Bronte Capital
Suite 2101B
520 Oxford Street
Bondi Junction 2022 NSW
Australia
Attention: John Hempton
‘Simon Maher
This response to John Hempton's e-mail below should be deemed as responding to
Simon Maher's separate e-mail of the same date.
We do not accept your contention that the blog is only a personal effort of John
Hempton and not also an effort of Bronte Capital. The full e-mail address of John Hempton is
‘brontecapital@gmail.com', which is also one of the e-mail addresses on Bronte's website and
is referenced for third parties wishing to communicate with Bronte. Simon Maher's full e-mail
address is 'simon@brontecapital.com', Additionally, John Hempton and Simon Maher have
signed Bronte Capital’s Client Letter for 2009. In fact, from what we have uncovered, it
appears that Bronte Capital has two employees, John Hempton and Simon Maher. Accordingly,
your contention that the blog is a personal effort of John Hempton is completely without merit
and will not be convincing to any regulatory agency or court of law.
Zion Oil & Gas, Inc. holds Bronte Capital, John Hempton and Simon Maher fully
responsible for the consequences of their actions, both individually and collectively.
In his e-mail, John Hempton acknowledges that he has "nor had detailed access to the
Jogs of said well” and further admits that that he "represented the well as dry". John Hempton
claims that the basis of his representation that the well is dry is based on reports on Zion Oil's
website. Disingenuously, John Hempton then requests that Zion violate federal law by
selectively sharing with him material non-public information
John Hempton's response to my letter is without merit, as Zion Oil does not post the
logs on its website. Had John Hempton or Bronte Capital carefully reviewed Zion's publicz
filings before making their spurious statements, they would have learned that Zion is in the
process of commencing completion tests for the recently drilled well.
We note that, neither John Hempton nor Bronte Capital, address the issue of the
libelous statement made respecting Zion Oil's management,
Zion Oil & Gas stands by its demand, in my letter to John Hempton and Bronte Capital
yesterday, that Bronte Capital and John Hempton immediately issue an express and
‘unequivocal retraction of the patently false and libelous statements made on the blog. Posting
my letter and/or any other communication from me on the blog will not qualify as an
appropriate retraction.
Uniess the appropriate retraction is immediately forthcoming, but in no event later
than the open of business on October 22, 2009 (United States Eastern Standard Time), we
have been instructed to commence vigorous action in both Australia and the United States
against John Hempton, Simon Maher and Bronte Capital,
This matter is viewed with the utmost seriousness. John Hempton, Simon Maher and
Bronte Capital have maligned Zion Oil & Gas and its management and may have also
committed serious violations of law. Needless to say Zion reserves and intends to avail itself of.
all rights, privileges and defenses available to it under law in pursuing this matter.
PLO
ce: Richard Rinberg, Chief Executive Officer
Irwin Weltz (Ellenoff Grossman & Schole LLP, New York, NY)