Written Opponent Testimony of Terry J. Lodge on HB 188 — Ohio House Development Committee, October 28, 2025
Summary
Written opponent testimony of Terry J. Lodge, Esq., dated October 28, 2025, submitted on behalf of the Northwest Ohio Peace Coalition to Chair Jim Hoops and the Ohio House Development Committee. The testimony opposes HB 188, "Creating an Ohio-Israel Trade and Innovation Partnership". It states that the coalition is a 24-year-old organization of over 100 Ohio voters in the greater Toledo area. It argues that the bill's supporters do not adequately appreciate the political and legal implications of an economic partnership with Israel, and describes the Partnership's proposed mission of promoting trade, investment and policy ties.
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“2025 10 29 Development Testimony Testimony 12214.”
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Law Office of
Terry Jonathan Lodge
316 North Michigan Street, Ste. 520 Phone (419) --------
Toledo, Ohio 43604-5627 Fax (419) 932-6625
lodgelaw@yahoo.com
October 28, 2025
Chair Jim Hoops
Ohio House Development Committee
OHRDevelopmentCommittee@ohiohouse.gov
and Zachary.Groome@ohiohouse.gov
Written Opponent Testimony of Terry J. Lodge, Esq.
On behalf of Northwest Ohio Peace Coalition:
Opposing HB 188 , “Creating an Ohio-Israel Trade and Innovation Partnership”
Before the Ohio House Development Committee
Chair Hoops, Vice Chair Lorenz, Ranking Member Brownlee, and members of the Development
Committee:
My name is Terry J. Lodge. I am a lawyer licensed to practice in Ohio and I’m testifying on
behalf of the Northwest Ohio Peace Coalition (“NWOPC”), a 24-year-old organization made up of over
100 Ohio voters and supporters of peace with justice, located in the greater Toledo, Ohio area.
NWOPC opposes HB 188, the proposed Ohio-Israel Trade and Innovation Partnership
(“Partnership”). We believe that the bill’s supporters do not adequately appreciate the negative
political and legal implications of an economic partnership with the nation of Israel at present.
The Partnership’s mission would be to study and promote trade, investment and policy ties
between Ohio and Israel, focusing on bilateral trade, business and academic exchanges, infrastructure
projects, emerging technologies (spyware), and multilateral deals involving Israel and other regions.
The public perception of many is that this new Ohio-Israel commercial relationship is meant to
rehabilitate the image of Israel, seen by the community of nations as a genocidal apartheid state and
perpetrator of a dramatic series of regional wars in the Middle East. The vortex of these wars is the
continuing genocidal massacre of thousands of Palestinians to thwart foundation of a Palestinian
nation. HB 188 would appropriate millions of taxpayer dollars annually for the partnership and would
create a commission at the Ohio end made up of pro-Israel legislators, representatives of the state-
chartered JobsOhio corporation, and the private sector.
These are not normal times where the nation of Israel is concerned; creation of the Partnership
brings along controversy. We submit that passage of HB 188 into law could place members of the
General Assembly and the Ohio state government, as well as JobsOhio staff and board and others, at
risk of criminal and civil liability for complicity with Israel in causing genocide, war crimes and crimes
against humanity under international law. Implementation of murky trade relationships that directly or
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indirectly enable Israel’s continuing war effort could subject Ohioans in government and the private
sector to investigation and even potential prosecution at the International Criminal Court or in third
states acting under the principle of universal jurisdiction.
I. Israel Is Committing Genocide In The Gaza Strip
Since Israel launched its military assault and siege on Gaza following the attacks of October 7,
2023, the Israeli military has killed at least 68,234 fatalities and caused another 170,373 injuries.1
Credible estimates of overall Palestinian death and injury rates range much higher.2 At least 2,605
unarmed Palestinians were murdered while seeking aid from the Gaza Humanitarian Foundation during
the summer months of 2025.3 Israel has destroyed or damaged 92% of the housing units, the majority
of hospitals and health care centers, almost 90% of schools, all universities, and most of the road
network across Gaza, as well as destroying and access to nearly all water and sanitation facilities.4
Throughout Israel’s two-year assault on Gaza, Israel has deliberately limited access to basic
necessities for life, which were already in short supply owing to Israel’s closure and occupation of
Gaza commencing in 2006. After October 7, 2023, Israel’s then-Minister of Defense Yoav Gallant set
the tone, declaring, “I have ordered a complete siege on the Gaza Strip. There will be no electricity, no
food, no fuel, everything is closed.”5 Since then, a plethora of Israeli government officials have uttered
more than 500 incitements to genocide against Palestinians,6 including demands to use nuclear
1 Humanitarian Situation Update #334 | Gaza Strip | United Nations Office for the Coordination of Humanitarian
Affairs - Occupied Palestinian Territory, https://www.ochaopt.org/content/humanitarian-situation-update-334-
gaza-strip
2 The reported death toll is widely understood to be a severe undercount. See Rasha Khatib et al., Counting the
Dead in Gaza: Difficult but Essential, 404 Lancet 237 (2024) (letter to the editor)
(doi:10.1016/S0140-6736(24)01169-3), https://www.thelancet.com/journals/lancet/article/PIIS0140-
6736(24)01169-3/fulltext (projects possibly 186,000 deaths as of July 2024).
3 Id.
4 Oxfam International, Water War Crimes: How Israel has weaponised water in its military campaign in Gaza,
(July 2024), https://oxfamilibrary.openrepository.com/bitstream/handle/10546/621609/bp-water-war-
crimes-180724-en.pdf;jsessionid=F0106B24E8CFAC29E814175755B16629?sequence=1 (Since October 7,
2023, Gazans have had only 4.74 litres of water per person per day for all uses, a 94% reduction in the amount of
water available before and well below the internationally accepted minimum standard of 15 litres of water per
person per day for basic survival in emergencies. By 26 May 2024, water production from sources within the
whole Gaza Strip had reduced by 84% due to destruction of water infrastructure and restrictions on fuel,
electricity, and water and sanitation spare parts entering Gaza. By 3 June 2024, five water and sanitation
infrastructures had been taken out of service every three days (1% per three days) by the bombardment. By 3
June 2024, Gaza City had lost nearly all its water production capacity, with 88% of its water wells, 100% of its
brackish water desalination plants and 100% of its seawater desalination plants damaged or destroyed and put
out of service. The Israeli military has destroyed the two main water quality testing laboratories. By 3 June 2024,
the Israeli military had destroyed 100% of all water and sanitation warehouses in Gaza City and Khan Younis.
By 3 June 2024, the Israeli military had destroyed 70% of all sewage pumps and by 26 June 2024, 100% of all
wastewater treatment plants in Gaza.)
5 Defense minister announces 'complete siege' of Gaza: No power, food or fuel , Times of Israel, (October 9,
2023) https://www.timesofisrael.com/liveblog_entry/defense-minister-announces-complete-siege-of-gaza-no-
power-food-or-fuel/
6 https://law4palestine.org/law-for-palestine-releases-database-with-500-instances-of-israeli-incitem
ent-to-genocide-continuously-updated/
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weapons on the Palestinians.7
The Israel Defense Force has determined that 83% of the Gazan casualties are civilians, an
unusually high rate since Israel has waged the genocide with advanced technological surveillance and
stupendous artificial intelligence methodologies.8 The high proportion of civilian deaths bolsters the
perception that civilian deaths have been a priority military objective, and not merely a collateral effect
of combat.9
From these grisly statistics, it’s no wonder that there are dozens of authoritative findings and
rulings that an active genocide is being conducted in Gaza while ethnic cleansing proceeds apace in the
West Bank.10
7 Commentary: Nuclear weapons, Israel, and Gaza,
https://www.icanw.org/commentary_nuclearweapons_israel_gaza
8 Israeli army database suggests at least 83% of Gaza dead were civilians, https://www.972mag.com/israeli-
intelligence-database-83-percent-civilians-militants
9 Report of the Independent International Commission of Inquiry on the Occupied Palestinian Territory,
including East Jerusalem, and Israel - Britain Palestine Project (June 25, 2025)
https://britainpalestineproject.org/report-of-the-independent-international-commission-of-inquiry-on-the-
occupied-palestinian-territory-including-east-jerusalem-and-israel/ (Israeli security forces directed air strikes
against scores of educational facilities, with no or inadequate advance warning, despite the presence of civilians
inside some of the facilities at the time of attacks.. . . many resulted in disproportionate harm to civilians. . . the
Commission finds that Israeli security forces committed the war crimes of: (a) directing attacks against civilians;
(b) willful killing (where civilians were killed due to the attacks); and (c) intentionally launching an attack in the
knowledge that such attack would cause incidental loss of life or injury to civilians which would be clearly
excessive in relation to the concrete and direct overall military advantage anticipated. Furthermore, the
Commission finds that, in killing civilians sheltering in schools, Israeli security forces committed the crime
against humanity of extermination.)
10 13 October 2023, Raz Segal, https://jewishcurrents.org/a-textbook-case-of-genocide…;15 October
2023: Public Statement: Over 800 Scholars Warn of Potential Genocide in Gaza
https://twailr.com/public-statement-scholars-warn-of-potential-genocide-in-gaza/…; 2 November: UN
experts call to prevent genocide: https://un.org/unispal/document/gaza-is-running-out-of-time-un-exp
erts-warn-demanding-a-ceasefire-to-prevent-genocide/… ; 16 November: UN experts call to prevent genocide:
https://ohchr.org/en/press-releases/2023/11/gaza-un-experts-call-international-communit
y-prevent-genocide-against… ; 16 November, William Schabas: https://ccrjustice.org/sites/default/file
s/attach/2023/11/Declaration%20Expert%20William%20Schabas_w.pdf…; 16 November: Holocaust and
genocide scholars John Cox, Victoria Sanford, and Barry Trachtenberg declaration, https://ccrjustic
e.org/sites/default/files/attach/2023/11/Historians%20Declaration_w.pdf…; 29 December, South Africa
submission to ICJ: https://icj-cij.org/sites/default/files/case-related/192/192-20231228-app-01-00-en.pdf…; 29
May, South Africa's dossier of evidence of Israel's genocidal intent, the UN Security Council:
https://tinyurl.com/nb6ua4a5; Martin Shaw, https://x.com/martinshawx/status/18203890088
80361676…; UN Expert Francesca Albanese, first report on the Genocide (March 2024): https://ohchr.
org/sites/default/files/documents/hrbodies/hrcouncil/sessions-regular/session55/advance-versions/a-hr
c-55-73-auv .pdf… UN Expert Francesca Albanese, second report on the Genocide (October 2024):
https://documents.un.org/doc/undoc/gen/n24/279/68/pdf/n2427968.pdf……; John Quigley, “Legal
Standard for Genocide Intent: An Uphill Climb for Israel in Gaza Suit”, 14 March 2024, EJIL:
https://ejiltalk.org/legal-standard-for-genocide-intent-an-uphill-climb-for-israel-in-gaza-suit/…; UK
Judges’ and Lawyers’ Open Letter Concerning Gaza, 3 April 2024: https://lawyersletter.uk; Jinan Bastaki,
“Gaza, Forced Displacement, and Genocide”, EJIL, April 2024, https://ejiltalk.org/gaza-forced-displacement-
and-genocide/… Nimer Sultany, “A Threshold Crossed: On Genocidal Intent and the Duty to Prevent Genocide
3/6
II. Ohio’s Current Investments Of Israel Bonds Exemplify Moral And Legal Hazards Of
Investment in Israel
Consider the Ohio Treasurer’s official investments of at least $262,500,000 in Israel Bonds.11
Israel’s government uses sales proceeds from Israel Bonds to perpetrate the commission of mass
murder via purchases of weapons of war and conduct of the ongoing genocide in the Gaza strip via
bullets and bombs and famine.12 Bond proceeds also pay for the development and operation of illegal
Israeli settlements in the West Bank of Palestine.13 The Development Corporation for Israel promotes
bond sales in the U.S. to finance Israel’s illegal war against Iran.14 15 Israel Bonds finance seizures of
land from Palestinian owners without cause, compensation or due process, and home demolitions in the
in Palestine”, May 2024: https://tandfonline.com/doi/full/10.1080/14623528.2024.2351261…; University
Network for Human Rights report, May 2024: https://humanrightsnetwork.org/publications/genocide-in-gaza…;
Aryeh Neier, NYRB, 6 June 2024:https://nybooks.com/articles/2024/06/06/is-israel-committing-genocide-aryeh-
neier/?srsltid=AfmBOopOf1xbf1Ucx3Bvo11nN7VEEL-J7IA6jCNd9mhgWGeSUcLgQ9Y7…; UN Commission
of Inquiry, 10 June: Detailed findings on the military operations and attacks carried out in the Occupied
Palestinian Territory from 7 October to 31 December 2023:
https://ohchr.org/sites/default/files/documents/hrbodies/hrcouncil/sessions-regular/session56/a-hrc-56-
crp-4.pdf…; Oxfam, Water War Crimes report, July 2024: https://oxfam.org/en/pre
ss-releases/israel-using-water-weapon-war-gaza-supply-plummets-94-creating-deadly-health…; Omer Bartov, 13
August 2024: https://theguardian.com/world/article/2024/aug/13/israel-gaza-historian-omer-bartov…; Haaretz,
“The Numbers Show: Gaza War Is One of the Bloodiest in the 21st Century”, 14 August 2024:
https://haaretz.com/middle-east-news/palestinians/2024-08-14/ty-article-magazine/.premium/the-death-toll-in-
gaza-is-bad-even-compared-to-the-wars-in-ukraine-iraq-and-myanmar/00000191-50c6-d6a2-a7dd-
d1decf340000…; Maryam Jamshidi, On Genocidal Intent, August 2024:https://opiniojuris.org/2024/08/02/re
flecting-on-genocidal-intent-in-the-icj-case/… Forensic Architecture:cartographic analysis of the genocide in
support of South Africa’s case in the ICJ: https://forensic-architecture.org/investigation/a-cartography-of-
genocide……; AOAV analysis that shows vast majority of killed in Gaza are civilians: https://aoav.org.uk/
2024/casualties-in-gaza-israels-claims-of-50-combatant-deaths-dont-add-up-at-least-74-of-the-dead-are-
civilians/…; 10 October 2024: UN Commission of Inquiry: Israel’s destruction of the health system in Gaza,
https://ohchr.org/en/press-releases/2024/10/un-commission-finds-war-crimes-and-crimes-against-humanity-
israeli-attacks…; 8 November 2024: UN Commission of Inquiry: 70 percent of verified victims (October - 30
April) were children and women: https://ohchr.org/en/documents/reports/six-month-update-report-human-rights-
situation-gaza-1-november-2023-30-april-2024…; 12 November 2024: 8 aid organizations of the systematic
violation of ICJ orders on humanitarian assistance, thereby establishing genocidal intent,
https://oxfam.org/en/press-releases/joint-release-israel-receives-failing-grade-us-demands-gaza…; 14
November 2024: UN Special Committee Report https://ohchr.org/en/press-releases/2024/11/un-special-
committee-finds-israels-warfare-methods-gaza-consistent-genocide…; North Gaza: 9 October 2024: 18 Aid
organizations warn of dramatic escalation of humanitarian catastrophe in northern Gaza.
https://oxfam.org.uk/media/press-releases/aid-organisations-warn-of-dramatic-escalation-of-humanitarian
-catastrophe-following-further-mass-forced-displacement-of-civilians-in-northern-gaza/…; 15 October 2024, 38
organizations: “Northern Gaza is being wiped off the map”: https://oxfam.org/en/press-releases/urgent-joint-
statement-northern-gaza-being-erased-global-leaders-must-act-now-end…;1 November 2024: statement by 15
UN and humanitarian organizations: http://bit.ly/40pLGqx ; ‘You Feel Like You Are Subhuman:’ Israel’s
Genocide Against Palestinians in Gaza, Amnesty International, 4 December 2024,
file:///C:/Users/tjlod/Downloads/MDE1586682024ENGLISH.pdf
11 Treasurer Robert Sprague Announces $35 Million Israel Bond Purchase,
https://tos.ohio.gov/newsroom/article/treasurer-robert-sprague-announces-35-million-israel-bond-purchase/
12 “Israel’s Ever-Expanding War Machine Is Financed Through International Bond Sales,” Truthout (July 26,
2025), https://truthout.org/articles/israels-ever-expanding-war-machine-is-financed-through-international-bond-
sales/
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West Bank ordered by the Israel government.16
But all Israeli settlements constructed outside of Israel’s 1967 borders have been ruled by the
International Court of Justice to be illegal acts of Israeli occupation of Palestine. In 2024 the
International Court ordered all Israeli settlements in Palestine to be vacated immediately and for
reparations to be paid to the victims of Israel’s 58-year-long occupation.17 Israel has demonstrated zero
compliance with the International Court’s ruling. Investments funneled to Israel from, say, JobsOhio
liquor tax revenues to promote businesses in the West Bank could generate profits that could be
deemed ill-gotten gains made from stolen Palestinian lands. Profits from business activity under illegal
auspices might be prosecutable as the crime of money laundering under federal or Ohio law, see 18
U.S.C. § 1956, 26 U.S.C. § 60501 and O.R.C. § 1315.53.
Ohio voters may legitimately question whether the HB 188 trade mechanism, with its open-
ended wording, is meant to become a conduit for secretly investing, such as through JobsOhio, even
more Ohio taxpayer funds in dubious economic ventures that are possibly illegal under international,
federal or Ohio law.
III. HB 188 Contains No Means To Avoid Ohio Investments In Complicit Criminal Acts
HB 188 contains no terms that would screen supported economic projects to ensure there would
be no direct or indirect support for Israel’s war crimes, genocide and human rights violations. The
world which Israel has reshaped at such a cost compels those who might associate to exercise serious
13 United Nations: Include ‘Israel Bonds’ in Settlement Businesses Blacklist and Corporate Crimes Report -
DAWN (January 10, 2025), https://dawnmena.org/united-nations-include-israel-bonds-in-settlement-businesses-
blacklist-an-corporate-crimes-report/
14 Israel Bonds Supports Israel Amid Fight With Iran, a televised interview titled, Israel Bonds and Israel’s
Economic Resilience. Video, https://www.youtube.com/watch?v=g0zOP2vFWII&t=324s (DCI President & CEO
Dani Naveh explains how Israel Bonds support Israel amid its fight with Iran, highlights how Israel's economy
continues to show resilience in the face of ongoing security threats, and emphasizes the essential role of
investing in Israel Bonds); Also see, Building Tomorrow, Together, Israel Bonds promotional video,
https://www.youtube.com/watch?v=IFDaYSc4ksw&t=51s
15 F. Albanese, “From economy of occupation to economy of genocide Report of the Special Rapporteur on the
situation of human rights in the Palestinian territories occupied since 1967,” UN Special Rapporteur (July 2.
2025), https://docs.un.org/en/A/HRC/59/23
16 Breaking the Bonds Between U.S. Local and State Public Funds and the Occupation of Palestine,
Internationalist Law Center (April 16, 2025), https://www.palestinepolicy.org/news/breaking-the-bonds-
between-u-s-local-and-state-public-funds-and-the-occupation-of-palestine (proceeds from Israel Bonds are
utilized to reimburse U.S. exports of weapons to Israel, which weapons are used to commit serious violations of
international humanitarian law and international human rights law); also, see United Nations: Include ‘Israel
Bonds’ in Settlement Businesses Blacklist and Corporate Crimes Report, Democracy for the Arab World Now
(January 2025), https://dawnmena.org/united-nations-include-israel-bonds-in-settlement-businesses-blacklist-
and-corporate-crimes-report
17 The International Court of Justice determined, among other things, that Israel’s occupation of the oPt
(Occupied Palestinian Territory) is unlawful and must end, and that all nations of the world are under an
obligation to not recognize the legality of Israel’s presence in the oPt, and to cooperate in bringing an end to
Israel’s violations. See Legal Consequences Arising from the Policies and Practices of Israel in the Occupied
Palestinian Territory, Including East Jerusalem, Advisory Opinion, 2024 I.C.J 186, paras. 88-94, 267, 274-79
(19 July 2024), https://www.icj-cij.org/sites/default/files/case-related/186/186-20240719-adv-01-00-en.pdf.
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caution. The pitfalls of joint economic ventures within Israel require an ongoing assessment of the legal
and political implications of every joint project. This is because complicity to genocide, a war crime, or
ethnic cleansing might be rather easily shown; complicity does not require that the accomplice share
the same intent as the perpetrator.18 “[I]t is sufficient that in providing logistical, financial or
operational support, [that the accomplice] had actual or constructive knowledge that the principal
perpetrators were engaged in a given crime. . . .”19
Israel’s genocide in Gaza is ongoing. At least 95 Palestinians have been killed by the Israeli
military since October 10, 2025.20 “The war is not yet over; we must complete our sacred mission of
bringing the fallen hostages home and continue the campaign against Hamas,” IDF Chief of Staff Lt.
Gen. Eyal Zamir said recently at a military conference.21 Only 15% of the 600 truckloads per day Israel
promised to allow entry into Gaza under the current ceasefire deal are being allowed into Gaza.22 The
conditions for renewed fighting and additional Israeli massacres of Palestinians remain.
Should Ohio officials be gambling Ohio taxpayer resources on dubious economic ventures with
an international pariah state, given the associated open-ended security, legal and political demands? We
submit that this is no time for an Ohio-Israel Partnership, and we respectfully urge that HB 188 be
rejected and tabled by the Development Committee.
Sincerely,
/s/ Terry J. Lodge
Terry J. Lodge
Counsel for Northwest Ohio Peace Coalition
18 Id. at 181 (“[A]n accomplice to genocide need not necessarily possess the dolus specialis of genocide,
namely the specific intent to destroy, in whole or in part, a national, ethnic, racial or religious group, as such.”).
19 F. Albanese, “From economy of occupation to economy of genocide Report of the Special Rapporteur on the
situation of human rights in the Palestinian territories occupied since 1967,” UN Special Rapporteur (July 2.
2025), https://docs.un.org/en/A/HRC/59/23 p. 33.
20 “Israeli Drone Attack in Southern Gaza Kills Two Palestinians,”Antiwar.com
https://news.antiwar.com/2025/10/27/israeli-drone-attack-in-southern-gaza-kills-two-palestinians/
21 IDF chief Zamir: Gaza war not over until last of the deceased hostages is returned | The Times of Israel
https://www.timesofisrael.com/liveblog_entry/idf-chief-zamir-gaza-war-not-over-until-last-of-the-deceased-
hostages-is-returned/
22 Only about 15 percent of promised aid trucks have entered Gaza since ceasefire: Media Office - TRT World
https://www.trtworld.com/article/08e9358c8637
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