part,  is  described  in additional
documents (REASONS For Humanitarian and Compassionate cases,
     sub-folder CONTRIBUTION):
     a)  Introduction  for:  "Exceptional contribution,  which Gunins  could
bring to Canadian cultural heritage".
     b) Evaluation of Lev Gunin as a talented musician / musical composer.
     c) Evaluation of Lev Gunin as a poet and writer.
     d) Evaluation of Lev Gunin as  a human right activist, historian, and a
thinker.
     e) Evaluation of Ina and Marta Gunin.
     f) Evaluation of Gunins as a family.

     SECOND 7 GROUPS OF REASONS (PARTS)
     [ B) What hardship would you have if appeal from outside Canada?]


     1. An  irreversible damage could be cause to Applicants' health if they
will be forced to apply from outside Canada (see below)
     2. Applicants' lives could be under a threat (see below)
     3. Mistakes, committed by the members of the refugee  board (IRB), Mrs.
Murphy, put Applicants' health and lives under an additional threat
     (see below)
     4.  Applicants  might face ill treatment and extreme sanctions  if they
will be forced to appeal from outside Canada (see below)
     5. Both Israeli authorities  and IRB consider one of the  Applicants as
an enemy of Israel with a tendency to justify any punishment (see
     below)
     6. Direct threats to Applicants  used to come from Israel even here, to
Montreal (see below)
     7.  Because  of all  above-mentioned reasons exceptional  hardship  for
Applicants to apply from outside Canada (from Israel) seems obvious
     (see below).  A special permission (pass)  is required to leave Israel.
Lev GUNIN was always refused that "departure authorization" during
     3,5  years, when  he  lived  in Israel.  He  links Israeli authorities'
decision to give him at least that authorization with his appeal to Amnesty
     International in  1994. Authorities in  Israel  will never give  it  to
Gunins again (Israeli authorities refusal to give Gunins permission to leave
the
     state  of  Israel  during 3  years  was discussed  during their refugee
hearing; refers to CASSETTES). So, he never could do the independent
     immigration procedure from outside Canada because  Israeli  authorities
will never let him leave Israel again! The certified translation of that
     pass -  permission -  (2-pages  document)  was presented to  the IRB in
Montreal and can be found in folder SUPPLEMENTS-2.

     Humanitarian & Compassionate Cases - page 8 -
     Part 1 - (b)
     Thesis: An irreversible damage  could be caused to Applicants health if
they will be forced to apply from outside Canada

     There are 5 main reasons for that:
     1) Because one of Applicants' passports  has  been expired, and can not
be extended (see: SUPPLEMENTARY DOCUMENTS-2,
     documents  5,6,7,8,9,10,11,  etc.)  Applicants could  go outside Canada
only to Israel. In the same time Applicants have so much fear of what
     they  believe could  threat  their  freedom,  lives,  right not  to  be
persecuted, if  they  would be forced back to  Israel, that  it alone  could
damage
     their health by a psychological shock (see: APPLICANTS, Document 1).
     Three and a half  years in Israel already damaged Applicants' health so
much that now another push towards the same country may lead to
     irreversible damage  to  their  health.  This  issue was  described  or
reflected in next documents: APPLICANTS, Document #1, pages
     5,6,7,8,17,18;  NOTE  OF MOTION OF EXTENSION OF  TIME; SUPPLEMENTS; see
the list of medical documents. To evaluate this point it
     is necessary to read over all documents in this  submission. To examine
this point, please, read over the above mentioned documents.
     [Please,  also  look   over  all  medical  documents  in  SUPPLEMENTARY
DOCUMENTS-2, sub-folder MEDICAL].

     2)  What Applicants consider  as IBR  members' humiliating behavior and
partiality provoked Applicants to feel themselves completely
     unprotected,  insecure,  bad-treated  and  insulted  (see:  APPLICANTS,
Document #1, pages # 3-8, 14-18; Document #4, parts 1,2, and 3;
     Document  #5; also see: LAWYER'S  FILE,  Document #  ). This caused  an
additional damage to their health.

     Part 2 - (b)
     Thesis: Applicants' lives could be under a threat

     Applicants'  lives  might be under a threat if they will  be  forced to
appeal from outside Canada.
     Predictable inhuman treatment  and extreme  sanctions  against them  in
Israel (because this is the only country they can go: please, read
     over the  First seven reasons, this  document,  page  #2) can put  even
their lives under a threat.
     They already  faced  inhuman treatment and  extreme sanctions in Israel
(see: APPLICANTS, Document #1, pages # 10-14, 16-19), and
     there are same significant indications  (see the  same  documents) that
the both inhuman treatment and extreme


     - Humanitarian & Compassionate Cases - page 9 -
     sanctions will  be used against  them  again as soon as they will enter
the state of Israel.

     Such  a  sensitive  towards some specific items state  as  Israel might
retaliate against Lev Gunin even for his request to terminate his Israeli
     citizenship.

     Both  adults -  both  husband  and wife - already suffering from: she -
chronically fatigue and depression, he - from hyper tension and other
     blood  vessel disorders, as well as neurological disorders in result of
what - they believe - happened to them in Israel. Their heath disorders
     were  jeopardized because of extremely  painful and  dramatically tenth
immigration collisions. Now the state of their health is not a direct
     threat to their lives.  But if removed to Israel, Applicants could face
any father damage to their health, and then it could become irreversible.

     Besides, Applicants' lives might be under a threat in Israel: sooner or
later. The latest documents enclosed by Applicants in this submission
     present some further explanations.

     Part 3 - (b)
     Thesis: Actions, committed  by the members of the refugee board  (IRB),
put Applicants' health and lives under an additional threat. In her
     speech in the Federal  Court Immigration  representative,  Mrs. Murphy,
repeated IRB's mistakes, and even enforced them

     Non-compatible with the status of  IRB actions, which were committed by
the IRB members, assigned to Applicants' file, directly increased
     an eventual danger for Applicants if they would be forced to go back to
Israel:
     1.  IRB  members contacted  Israeli  embassy and denounced  (disclosed)
Applicants' refugee claim (see next documents: APPLICANTS,
     Group of Documents #4, document #3 (p.p.1,2,3); APPLICANTS, document #1
(page 1, paragraph 3, points 2,3,5,8, 11); APPLICANTS,
     document #1, INTRODUCTION,  and pages  7, 8, 9, 10, 14, 15, 16, 17, 18;
SUPPLEMENTS, documents #6, 7). IRB members had no
     reasonable  grounds  to  do  that  (APPLICANTS, document #1,  page  13,
paragraph "D"). The disclosure of Applicants' refugee claim to Israeli
     officials from one side shows the total ambivalence of  the IRB members
towards refugee claimants' security, and from another side caused
     an additional severe threat to their freedoms and lives if they will be
moved to Israel.
     2.  IRB  members  presented  Applicants  as exaggerators, who committed
themselves to spread slander against "their" state (see next
     documents:

     - Humanitarian & Compassionate Cases - p.10 -
     APPLICANTS, Group of Documents # 4, Document #3 (p.3, paragraph 4; p.4,
3 last paragraphs; p.5); APPLICANTS, Document #5, p.2,
     paragraph P.4).
     3.  IRB members  pretended  that  the Applicants appealed to  dozens of
institutions and organizations in Israel (with complains) not for
     protection  but  to  spread  slander  against  "their"   country  (see:
APPLICANTS, document #5, p.2, paragraph P.4). IRB members recognised
     that Applicants started  to  complain  to  dozens of  organizations and
institutions when they lived in Israel, and were denied protection. But
     the  IRB  concluded  that  the police  and other Israeli  institutions'
refusal to give family Gunin protection was justified because of the views,
     expressed by  family members (folder  APPLICANTS, document 5, page  3).
The IRB also invented a speculative suggestion that Gunins
     turned to all these organisations not for protection but for propaganda
against Israel (APPLICANTS, document 5, page 3). They also called
     Gunins aggressive
     "exaggerators", dangerous to their country (they did not  use the  word
"dangerous", but this is what they mean). The Immigration Board
     (IRB) also indirectly called  Gunins "property of  Israel" just because
the state of Israel paid for Gunins' transportation from Warsaw to
     Tel-Aviv. IRB  denied  the right for all Russian speaking refugees from
Israel to claim a status of refugees in principle: just because they
     came to  Tel-Aviv  for Israel's cost and because they  were allowed  to
come to Israel according to "the law of return" (see APPLICANTS,
     document 5, page 2, paragraph P.3).
     4. IRB members  expressed almost direct  insinuations  that  Applicants
came to Canada to defame against "their" country, just camouflaging
     it by the refugee claim (see APPLICANTS, document 5, page 2,  paragraph
P.3).
     5. Therefore the general ideologically-motivated line in IRB statements
and in their questions during interrogations put the equal sign
     between peaceful protests against  human rights violations, Applicants'
attempts to defend themselves, their human dignity in Israel, - and
     revolutionary activity, defamation and/or mutiny.
     6. Everything, starting from  IRB members' replicas during the hearing,
to their negative decision's text, is a direct encouragement for Israelis
     to continue persecutions of Applicants. Or a direct order...

     Part 4 - (b)
     Thesis: Applicants might face  ill  treatment  and extreme sanctions if
they will be forced to appeal from outside Canada

     It is  clear from the  above placed information that Applicants can  go
outside Canada only to Israel. But in Israel Applicants would face ill
     treatment and extreme sanctions.

     - Humanitarian & Compassionate Cases - p.11 -
     This part correspond to all above mentioned reasons.

     To learn  more,  please, read over next  documents: folder  APPLICANTS,
document#1, page 16, INHUMAN TREATMENT; folder
     APPLICANTS, document#1, page  10;  APPLICANTS,  GROUP OF DOCUMENTS  #4,
document#1.

     Part 5 - (b)
     Thesis:  Both  Israeli  authorities  and  IRB  considered  one  of  the
Applicants (L. Gunin) as an enemy of Israel with a tendency to justify any
     punishment.

     This consideration  goes in contradiction  with the clear evidence that
the only thing he wants is to be away from the state of Israel, and the
     only method he's using to achieve it is the peaceful, legal approach.

     The  Refugee   Board's  treatment   of  Mr.   Gunin  is  evidently  not
independent. During their evaluation of GUNINS' claim they were in close
     contacts with Israeli embassy. They clearly demonstrated a tendency  to
represent the attitude from the Israeli point of view before the
     objective evaluation of the dangers  for  the refugee claimants in case
of their removal. Instead of defining whether or not the removal of the
     refugee claimants from Canada is dangerous for them, they made attempts
to define their "guilt". Instead, the Refugee Board turned itself
     into a kind  of a criminal (or,  rather,  a political) court,  accusing
Applicants in exaggerations, propaganda against Israel, and other "crimes".
     The very tone of the negative conclusive decision is not a neutral, but
accusational. The same tone was used by all Israeli official
     documents, which concern Applicants.

     Part 6 - (b)
     Thesis: Direct  threats to Applicants used  to  come from  Israel  even
here, to Montreal

     Israeli state  radio  and newspapers used  to make  direct  provocation
against Lev Gunin trying to cause violence against him, playing on
     sensitive issues. Applicants also used to get  mails from Israel, which
reflected some actual threats to them. There also were malicious
     telephone  threats,  e-mails, and  other  forms of  threats. Applicants
believe that an official status in Canada given to them could put an
     immediate end  to such threats.  In  the same time these threats proved
that if removed to Israel Applicants would face malicious anger of
     Israeli authorities  as  well as of ordinary  Israelis [see APPLICANTS,
SUPPLEMENTS, documents #30 ("A" and "B")].

     - Humanitarian & Compassionate Cases - p.12 -
     Part 7 - (b)
     Thesis: Because of all above mentioned reasons the extreme hardship for
Applicants to apply from outside Canada (from Israel) seems
     obvious.

     Applicants can never apply  from  Israel (the only country they can go)
for Canadian permanent residency because of: 1) predictable
     persecutions; 2) impossibility of accommodation in  Israel; 3) eventual
confiscation of Applicants' passports; 4) a special permission, which is
     required in Israel to leave the country; Israeli authorities will never
give it to Lev Gunin again (the permission issue was already discussed
     during the refugee hearings).

     Resume:  Family Gunin  suffered  a  lot.  They  went  through dramatic,
drastic, and tragic events. It is absolutely clear that they can not apply
     for  permanent residency  in  Canada from  outside Canada. A refusal to
give them a possibility to apply from within Canada will bring their lives
     to a tragic  end. If humanity and compassion is not for them - for whom
then?

IMPORTANT  NOTICE:  PLEASE,  TAKE  INTO CONSIDERATION THAT SOME  OF THE
DOCUMENTS, MENTIONED HERE AND IN
     OTHER DECLARATIONS, WITH REFERRAL  TRACES, MIGHT BE SUBMITTED 1-2 WEEKS
AFTER










PART 2
     Lev Gunin - Humanitarian & Compassionate Cases
     IMM Second Additional Document [refers to the form 5283 (02-98) E]


     Exceptional contribution, which Gunins could bring to Canadian cultural
heritage

REFERS TO
     REASONS
     ADJUSTMENT  TO SUPPLEMENTARY INFORMATION  HUMANITARIAN &  COMPASSIONATE
CASES
     Grounds for Exemption - Adjustment to Paragraphs A and B


     Three  members  of   Applicants'   family   can  bring  an  exceptional
contribution into Canadian cultural heritage.

     1.  Mr.  L.   Gunin  is  a  productive  musical  composer,  journalist,
historian, poet, writer, and amateur photographer. He is also an advance
     computer designer and HTML programmer.

     Mr.  Lev  GUNIN  is  an  editor  of  two non-commercial  Montreal-based
newspapers: in Polish and in Russian languages. He is an owner and
     editor of  11  web  sited  on  Internet; 7  of  them are  E-Zines.  His
newspapers and E-Zines became wide known among International Internet
     community.  People  submitted  him  tenth  of mails  and  thousands  of
E-mails. They expressed their interest and approval. His creative works
     in Russian  (poetry  and prose) became known on  faculties  of  Russian
Literature in a number of universities, for example, in Gomel University
     (Belarus)  or Moscow  State  University  (Russia). A  number of  famous
personalities like a famous Russian writer Vladimir Batchev or poet
     Andrei Voznesensky spoke with warmth about  L.Gunin's poetry. Mr. Josef
Brodsky, Noble Prize-winner, has marked his poetry as unusual
     and  sophisticated. Mr. Gunin's essays were published in huge number in
Belarus, Russia, Israel, Germany, France, Poland, and Canada.
     Interviews with  him were published by  the  leading Russian  newspaper
"Vesti" in Israel (1994) and by the Radio "Russian Aliance" in
     Montreal,  Canada  (1998).  World-famous  writer and  scenario creator,
author of the famous American movie "Hostages", Mr. Grigory Svirski,
     citizen of Canada, gave the highest approval to L. Gunin's creative and
social activity. Gunin's prose and poetry were added to the most
     complete and famous electronic Russian libraries (Alex  Farber &  Maxim
Moshkov's library, for example).

     Mr. Gunin is an author of numerous contemporary compositions for piano,
orchestra, choral, instrumental duets, trios, etc., and also
     electronic music and songs in jazz, pop and rock styles. In Montreal he
took part in a number of music festivals, concerts, and other types
     of musical  activity.  During  his  Montreal's life  period he released
several musical albums with other musicians and poets - both immigrants
     and  Canadian  citizens.  He  created  several  songs  with  relatively
well-known Montreal poet Miguel Lamiel. His music was placed on Internet.
     He  participated in  so many musical  events that they hardly could  be
listed. Mr. Gunin is a member of Montreal-based Saint-Lawrence choral
     (the leading in Quebec) and Union Des Artist.

     Mr. Gunin is a known human rights activist, recognised by many informal
human rights groups all over the world. He maintains contacts with
     the leading human rights organisations.

     Mr.  Gunin's works  about the history of  Belarus  were approved by all
leading professional historians in Belarus, including A. Gritzkievich, A.
     Tarasov,  O.Dadiomova,  V. Posse, etc. His work "BOBRUYSK"  is a unique
monograph of that kind among the books about Belorusian
     cities.

     He is also an author of works in music  history,  musicology, theory of
music, counterpoint, art, and culture. He is an author of a number of
     philosophical essays and works in political science.

     As  an  amateur  photographer he  has a fresh,  colourful and  original
style.

     Mr Gunin is an advanced amateur computer technician,  designer and HTML
programmer.

     He is also an amateur architect.

     All  about  mentioned information is supported by documents, referrals,
photos, diplomas, certificates, etc. This supplementary information
     evaluates each sphere  of Mr. Gunin's activity separately, and could be
divided on next parts:
     1) Music plus works in musicology
     2) Poetry
     3) Prose
     4) Journalism
     5) Works in history
     6) Computer skills + HTML programming
     This 6 groups of documents will be submitted 1-2 days later or could be
presented on your request.

     One can ask: Why - if he is so talented - we never heard about him?
     This is because  in the former USSR  Lev was seriously persecuted (read
over folder Applicants, document 2), his creative works were not
     compatible with  the  communist ideology - and therefore could  not  be
officially presented for publications or awards. All doors were closed
     before him, and his carrier was broken in advance.

     Could he make his carrier in Israel - country, where he never wished to
go and where he was taken by force; country, which he criticised
     long before  he  was taken  there? (See:  Applicants,  Documents 1,  2,
etc.). Of course, not!

     In Israel  he  was also widely persecuted. He was not permitted to work
in his profession; even an employment authorisation was refused
     him: formally  an Israeli  citizen! Newspapers in Israel called him "an
enemy"; Israeli State radio called him "an enemy"! (See other
     documents). He could not  advance  in  his  attempts to be treated like
other people (see attached documents)...

     Now, in  Canada... In spite of the  pressure of  his tragic immig