Jerusalem Letter / Viewpoints
No. 484 7 Elul 5762 / 15 August 2002
UNDERSTANDING AMERICAN CHRISTIAN ATTITUDES
Seeking Allies in the Battle for Jerusalem / U.S. Christian Views on Jerusalem / Impact of the Recent Violence / The Holiness of Jerusalem / The Influence of Holy Land Christians on U.S. Christians / U.S. Christian Political Involvement / Outreach Channels / Outreach Messages / Selected Additional Recommendations
Seeking Allies in the Battle for Jerusalem
The unity and control of Jerusalem have been among the most contentious and complex issues in Israel-Arab relations. Until recently, Israel's stance that Jerusalem would remain under its sole sovereignty as its eternal, undivided, and sole capital was not open to compromise. That position enjoyed near-unanimity among Israelis, the international Jewish community, and Congress.
Over the past few years that consensus has eroded somewhat. In late 2001, 44 percent of American Jews surveyed said that Israel "should be willing to compromise on the status of Jerusalem," up from 33 percent in 1998.1 Bill Clinton's pronouncements in the waning days of his presidency "legitimized" the idea.
However, it is unlikely that a future Israeli government will ever countenance the kinds of ideas that were tabled in 2000, particularly after the ensuing Palestinian vitriol and violence. Even before Palestinian violence erupted, 57 percent of Israelis felt that ideas floated by Prime Minister Barak were "too much of a compromise."2
Nonetheless, taking any less-forthcoming positions when negotiations with the Palestinians resume will be like trying to put the genie back into the bottle. Israel will need allies in the U.S. to help counter anti-Israel media, the Palestinian/Arab public relations onslaught (which will surely be endorsed by the European Union), softening American Jewish support for Israel,3 and an increasingly organized and vocal Arab American community. Christians who care about Jerusalem could be of critical importance to this effort.
Historically, Israel's U.S. outreach efforts have been oriented primarily toward the Jewish community and at decision-makers in Washington. Relatively little attention has been paid to the U.S. Christian community, much of which is highly empathetic to Israel's story. Until recently, there has been little effort to mobilize the community on Israel's behalf, even though Christian support for Israel is sometimes more passionate than that of many Jews.
At the same time, the Christian community is subject to anti-Israel rhetoric, and not only through the media. The head of one of the main churches in Israel, for example, reportedly has a full-time staff that sends out anti-Israel emails to his American compatriots.
Using religious affiliation as an organizing principle of a Jerusalem outreach effort makes sense. First, existing institutional structures may provide efficient and effective ways to communicate to and mobilize large numbers of people about this religiously significant subject. A recent study found that "Churches and other religious institutions have become more actively engaged in the political process, and religious people have increased the level...of their political participation."4 "Most citizens who regularly attend religious services report that their clergy discuss political issues, and most also approve of such sermons."5 One's level of religious commitment was found to be "indisputably associated with greater political participation" and, in fact, there is "increased targeting of religious voters by candidates and parties."6
Second, religion can play an important role in affecting the opinion of important political leaders. There is no question that a president's religious beliefs, for example, have affected American policy toward Israel, as when Harry Truman decided to first recognize the State of Israel.
While until recently7 there has been no specific outreach to the Christian community on Jerusalem, there have been episodic attempts to reach out to it regarding Israel. However, there has been no clear definition of objectives or a comprehensive strategy. In fact, outreach has sometimes backfired, as when Prime Minister Benjamin Netanyahu met in 1998 with Christian Coalition leaders just before meeting with President Clinton.
A key, however, is to recognize that the U.S. Christian community is large, segmented, and heterogeneous, holding diverse theological and political views generally and pertaining to Jews, Israel, and Jerusalem, particularly. Different groups need to be approached differently and with proper consideration and presentation of the relevant historical, political, humanitarian, and theological cases.
U.S. Christian Views on Jerusalem
There are approximately 150 million affiliated Christians in the United States.8 The Catholic Church accounts for almost one in five Americans. Another 60 to 70 million Americans describe themselves as Evangelical.9 The largest group of Evangelicals comes from the Southern Baptist movement, the largest Protestant body in the country. However, the Evangelical community draws members and churches from many Protestant denominations, including the Reformed, Baptist, Pentecostal, Holiness/Wesleyan, and Lutheran churches.
In reaching out to Christians, it is important to keep in mind that, overall, church-Jewish/Israel relations are shaped by several doctrines that are adopted or rejected by different denominations to varying degrees. Some are:
Replacement theology: Jews have been replaced by the Christians in God's favor; thus, all of God's promises to the Jews, including the Land of Israel, have been inherited by Christianity. The Roman Catholic and other churches have officially renounced this doctrine, but it remains alive in many quarters.
Salvation through conversion only: Personal salvation is possible only through belief in Jesus. Thus, Jews, even if still considered people of the covenant, must convert in order to be saved.
- Witnessing/proselytizing: Christians must actively bear witness/proclaim the gospel of Jesus to all people in order for them to have the opportunity (but not be coerced) to embrace Jesus.
- Jews' centrality in Jesus' second coming: Only when the biblical Israel is fully restored to the land can the final drama of God's judgment and salvation be carried out.
Even within individual churches, it is often difficult to ascertain clear-cut policy lines regarding Jews, Israel, and Jerusalem. In addition to the evolving nature of official policy, the views of the laity or of individual clergymen often differ. Ongoing Palestinian-Israeli violence also clouds or confuses general policy. Finally, most U.S. Christians do not focus daily on Israel and Jerusalem.
There is no consensus on exactly what constitutes Evangelical beliefs. However, four ideological characteristics distinguish Evangelicals from Catholics and mainline Protestants, more "in the degree to which [they] are stressed...than in their being affirmed at all."10
The centrality of Scripture as the very word of God, contrary to those who assert that both Testaments are the words of men interpreting the things of God.
- A stress on the Trinity, especially upon Jesus who, though revered as God, is a person who is viewed in very personal terms and often spoken of as one might talk of a beloved friend. The standard of behavior is: What would Jesus do? What would Jesus say?
- The "born again" experience, a personal experience of commitment to Jesus as Lord and Savior that results in a spiritual rebirth by the regenerating and life-transforming power of the Holy Spirit.
- Emphasis on evangelism, to spread the good news that man can be reconciled with God and that the ultimate destiny of each soul hangs on one's decision to accept or reject Jesus.
The Evangelical movement can be divided into Left, Center, Right ("Fundamentalist"), and Pentecostal streams. Pentecostal denominations - which are theologically Center or Right but also believe that miracles of the early church should be normative for Christians today - represent a fast-growing segment. Typically, the Evangelical Center and Right are supportive of and often passionate about Israel, although not always uncritically.
As Ed McAteer, founder of the Memphis-based Religious Roundtable, suggests: "the best friends that Israel has are Bible-believing Christians."11 "'Christian Zionism' is characteristic of some subgroups within the evangelical community; [many] pay particular attention to events in Israel as portents of the End Times."12
Many Bible-believing Christians also endorse Jewish control of Jerusalem because they believe that God gave it to the Jewish people as part of His eternal covenant with them and that the Jewish people do not have a right to give away land covenanted to them. Others also endorse Jewish control for an additional reason that conflicts with Jewish belief. "Some Christians believe the second coming of Christ will occur only after Israel rebuilds God's temple in Jerusalem. They support Israel having full control of that land - not ceding it to the Muslims."13
Catholic Church Attitudes
Throughout his papacy, Pope John Paul II has sought to improve relations between the Church and the Jewish people. Vatican policy towards Israel, of which Pope John Paul II is a key proponent, also seeks good relations and has typically sought to be balanced and measured. So, while it condemns "occupation," it also condemns Palestinian violence; while it disapproves of Israeli military violence, it censures terrorism and condemns Palestinian refusals to acknowledge Israel's right to exist. It is deeply concerned about the dwindling number of Christians in the Holy Land, and encourages unbiased U.S. involvement in a peace process. Catholic clergy in the Holy Land often deviate sharply from official policy, however, and would want a future pope to be less balanced.
Regarding Jerusalem, the Vatican distinguishes clearly between political arrangements for the city and religious ones, where it sees sharing among Christians, Jews, and Muslims. It is highly concerned about the sacred nature of the city and calls for international guarantees for the most important religious sites, but has no "competence or ambition to intervene in the territorial" issues of the city.14 The Vatican might remain silent on Israeli claims for political sovereignty. Most U.S. Catholic clergy and laity, however, are probably not well-informed on the issues.
Mainline Protestant Attitudes
Mainline Protestant churches are typically highly negative towards Israel. On Jerusalem, too, mainline Protestant churches strike a strident anti-Israel tone. As the positions of three major umbrella organizations show,15 they believe that Jerusalem should be shared politically and suggest international intervention in the entire city. Individual mainline Protestant churches take similar stances.
In a recent development, however, on April 12, 2002, clergy and theologians disenchanted with official church policy formed the Episcopal-Jewish Alliance for Israel. They issued a statement to "protest the unbalanced condemnations of the Jewish state issuing from the headquarters of the Episcopal Diocese of Massachusetts, and from other parts of our church hierarchy." By April 25, the statement had over 100 signatories. Such disenchantment and willingness to act likely exist among other denominations as well and represent an opening worth exploring.
While lacking specific research, our sense is that, with clear exceptions, Black Protestant churches generally are sympathetic to the Palestinian cause, but the laity is more focused on domestic issues.
Impact of the Recent Violence
The recent violence seems to have reinforced pre-existing stances. Mainline Protestants appear more hostile to Israel. Eugene Korn, ADL Director of Interfaith Affairs, writes:
On Feb. 19, [2002,] the Episcopal Church [in New York] sponsored "Waging Reconciliation in the Holy Land" at St. Bartholomew's Church in Manhattan. Promoted as a quest for justice and truth, it aimed to help end the conflict in the Middle East. Yet the agenda for the daylong conference focused almost exclusively on Israeli occupation of the West Bank and Gaza Strip....With twisted logic, speakers invoked the apostles of nonviolence, Mahatma Gandhi and Martin Luther King, as advocates of Palestinian violence antiseptically described as "resistance." Instead of promoting justice and truth, the conference served to propagate bias and moral confusion.16
At the same time, the Evangelical community remains firmly behind Israel. Michael D. Little, president of the Christian Broadcasting Network (with over one million daily viewers across the U.S.), declared: "Israel is an important country to the United States and to Bible-believing Christians. This is the time to support Israel like never before."17 The Christian Coalition of America plans to hold a massive solidarity rally for Israel on October 11, 2002.
The Vatican seeks to remain balanced. But on April 14, 2002, Archbishop Jean-Louis Tauran, the Vatican's top foreign-policy official, admitted that the "status quo of the holy place of the Basilica of the Nativity has been violated by the Palestinians, who have sought refuge in its interior with arms."18
The Holiness of Jerusalem
Jewish and Christian notions of the holiness of Jerusalem differ significantly. Zwi Werblowsky describes the historical relationship of Christians to Jerusalem:
The true home of the Christian...is the heavenly Jerusalem....Terrestrial Jerusalem which is "united to the [Jerusalem] in heaven" is wherever the perfect Christian life is lived....It is not the Holy City or Land that constitute the "area" of holiness, but the new community, the body of Christ.
Yet for...generations of Christians, the land in general and Jerusalem in particular were the scene on which the most uniquely momentous events of history had been enacted. All these took place on definite spots in this particular city and land...[thus] Christians have always cherished Palestine as a "holy land," and Jerusalem as a "holy city," and...pilgrims have at all times come to visit the [historic] sites. Yet…the heavenly Jerusalem…is the real and essential one…earthly Jerusalem is but a pale terrestrial reflection.19
In Jewish tradition, "Liturgical devotion, popular piety, religious symbolism, and messianic hope are directed first and foremost to the earthly Jerusalem as a symbol of the ingathering, on this earth, of the people to their promised land....Earthly Jerusalem does not...derive its significance from the fact that it mirrors a celestial reality. It is a value in itself....Jerusalem is not a city containing holy places or commemorating holy events. The city as such is holy."20
Over the past 50 years, the theological connection to physical Jerusalem has grown in some Christian circles, as Jerusalem is being rebuilt (by the Jewish people) and attaining modern-day glory. Some argue that the link was never actually severed and that it was only due to the practical difficulties of visiting that theologians turned believers' attention to heavenly Jerusalem. "[Physical] Jerusalem is an integral part of the Christian faith...where God meets with man."21
Nonetheless, others retain different perceptions of physical Jerusalem. "To suggest that Jerusalem is central and necessary for Christian worship" is not correct. "Jesus was clear that the place of worship for the Christian is within, no matter where he lives in the world. The significance of Jerusalem for Christians…is most directly related to God's purposes and plans for Israel and the Jewish people in the redemption of the world."22
The Influence of Holy Land Christians on U.S. Christians
The Christian community in the Holy Land is relatively small and dwindling. But its connections to and influence on the positions of U.S. churches, particularly mainline Protestants ones, are significant.
About 50,000 Christians live in Jerusalem, the West Bank, and the Gaza Strip, representing about 1.3 percent of the Palestinian population of the West Bank (excluding eastern Jerusalem) and Gaza. About 35,000 live in the West Bank, 3,000 in Gaza (mostly in Gaza City),23 and 12,500, of at least fourteen denominations, in eastern Jerusalem. Three patriarchs and the representative bishoprics of major Western churches reside there.
In 1994, the heads of Christian communities in Jerusalem issued a declaration that has served as the basis for the positions on Jerusalem of many U.S. churches and church organizations. Specifically, they called for:
Many Holy Land Christian clergy - the Palestinians in particular - are outspoken against Israel. Some, like those at the Sabeel Center in Jerusalem, are actually developing an entirely new "Palestinian Liberation Theology" which interweaves Christian theology with Palestinian politics and reinterprets the gospels in a way that derogates Israel.
By learning from Jesus - his life under occupation and his response to injustice - this theology hopes to connect the true meaning of Christian faith with the daily lives of all those who suffer under occupation, violence, discrimination, and human rights violations. Additionally, this blossoming theological effort promotes a more accurate international awareness of the current political situation and encourages Christians from around the world to work for justice and to stand in solidarity with the Palestinian people.25
While representing only about 5 percent of the total, the Protestant Christian community in the Holy Land has close ties with the U.S. mainline Protestant community. Its anti-Israel stance seems to have significant sway on U.S. churches.
The close link between the Sabeel Center and the U.S. Episcopal Church is an example. An Episcopal theologian and an outspoken critic of Israel, Naim Ateek, is Sabeel's president. The Anglican Bishop in Jerusalem, Riah Abu Al-Assal, is a board member. Episcopal Bishop Thomas Shaw, head of the Massachusetts Diocese, lauded the Sabeel Center in an April 2002 speech, in which he also asserted that, "If true peace is to be brought to the region, the injustice done to the Palestinian community for the past 100 years [sic] must be brought into the light and addressed."26 (Ateek is influential in Britain, too, where he "is claimed by bishop after bishop as a good friend who, they say, is hugely influential throughout the Anglican communion.")27
U.S. Christian Political Involvement
Politically, 67 percent of American Jews identify themselves as Democrat or leaning Democrat.28 Demographically, the Jewish population is heavily weighted to the Northeastern states. The most-needed allies for a Jerusalem outreach may be Republican-leaning Christians who live in the Midwest and South.
In fact, "religion has a clear influence on citizens'...choice of party identification. This influence not only shows no sign of waning but may even have increased in recent times....In recent elections, this influence has rivaled that of factors that have historically been more important, such as income, education, region, and union membership."29
As it also turns out, "committed evangelicals were the most likely to vote for Republican House candidates, followed by committed mainline Protestants, other mainline Protestants and other evangelicals."30 "Committed evangelical Protestants and other religious conservatives are well integrated into the GOP electoral coalition and unlikely to defect in the near future."31 President George W. Bush and many Republican senators and congressmen consider themselves Evangelical Protestants. Also, after a marked shift in party identification to Republican over the past 30 years by committed Catholics, Catholics are now evenly split.
In terms of political activism by religious groups, "Catholics and committed mainline Protestants are the most active." Committed Evangelicals are above-average. However, "because political participation is still strongly influenced by socioeconomic status [such as income and education], evangelical and black Protestants are generally less involved in politics than mainline Protestants and Catholics."32
It is clear, however, that committed Evangelicals can be mobilized effectively. For example, "in the 1989 Citizen Participation Study, committed evangelicals and mainline Protestants were much more likely than members of other groups to report having contacted a public official (45 percent and 46 percent, respectively, compared with an average of 33 percent)."33
Finally, there are strong indications that Evangelical Christians are becoming increasingly engaged on various international issues, such as religious persecution and support for Israel. New international efforts are "going gangbusters," according to Richard Cizik, Washington director of the National Association of Evangelicals.34
Two key ways to reach Evangelical Christians are through the mass Christian communications media and by allying with political organizations that already have channels into the community.
Far and away, the Christian communications medium with the broadest reach is the Electronic Church. Already in 1992, it comprised 1,500 religious radio stations, 25 television stations devoted to religious programming, and over 700 religious programs distributed to secular stations.35 The Pew Religion Survey in 1996 indicated that 45 percent of adult Americans watch religious television or listen to religious radio programs.36 Evangelicals are the most loyal viewers, 79 percent of whom watch occasionally and about half who watch weekly.
A number of organizations have formed over the past several years to mobilize Christians to political action. Most well-known is the Christian Coalition, which mobilized conservative Christians in the elections of the 1990s.
Non-sectarian conservative political organizations also appeal and have access to the Evangelical community. One is Gary Bauer's American Values, which "often presses Israel's case in a daily email message that makes its way to about 100,000 Christian conservatives."37 Another is Empower America, whose co-directors are stalwart supporters of Israel, including Jack Kemp, Bill Bennett, Jeanne Kirkpatrick, and William Cohen.
In addition, Christian Zionist organizations, many with offices in Israel, can certainly mobilize their networks and infrastructure to enhance support for Jerusalem. These include the International Federation of Christians and Jews, Bridges for Peace, the Christian Embassy, and Christian Friends for Israel.
Outreach at the national clerical and community church levels, direct email, appearances at conventions, articles, and advertisements in denominational publications can work too.
For mainline Protestants and Catholics, a more personal approach to clergy, theologians, and key lay leaders who take public positions sympathetic to Israel and want to help promote such positions may be best at first. These might then use their influence on both church hierarchies and the laity to seek a more informed and balanced stance.
Church services might be an effective way to reach the laity. A significant number of Christians attend church weekly at least, and most attendees say that world trouble spots are discussed in the sermon. Mainline Protestants rank world trouble spots as the second most discussed issue.
Speaking to local church groups can also be a highly effective approach, as it provides a superb opportunity to put a needed human face on the Israeli case and respond to rampant misconceptions.
Presenting the factual case about Jerusalem - its history, its ties to the Jewish people, and its diplomatic status - is always critical.
Particularly to groups critical of Israel's treatment of Palestinians, however, it is essential to take a proactive approach. One theme that may resonate is that treatment of Christians and Christian interests by Israel is far superior, as it can be argued that:
- Christians have suffered under Islamic regimes in the Middle East.
- Palestinian Muslims have harassed Palestinian Christians.
- The Palestinian Authority (PA) has harassed Christians.
- The PA has shown contempt for Christian holy sites.
- The PA has reduced the political power of Christians.
- Palestinian behavior in Jerusalem is likely to be no different.
- Christians have sought to escape Palestinian Authority control.
- Christians would likely flee Jerusalem if control is given to the Palestinian Authority.
- In contrast, Israel is deeply committed to ensuring Christian religious freedom.
A number of theological appeals can be made, as well:
- Palestinians deny Christian historical connections to Jerusalem.
- To sever Jewish ties to the heart of Jerusalem is to deny Jews their biblical rights, fulfillment, and destiny.
- To change Jerusalem's status is to deny Jews religious freedom in their holy city.
- To sever Jewish ties to the heart of Jerusalem is to impede fulfillment of Christian destiny.
Selected Additional Recommendations
Outreach should take a proactive posture. Israel's past reactive approach has often put it on the defensive. Particularly regarding Jerusalem, where the effort is preventative, outreach needs to take the offensive. There needs to be a constant outflow of information that puts the burden of explaining on others, rather than on Israel.
- Outreach needs to be undertaken with great sensitivity to each particular audience, with references, as appropriate, to God, Scriptures (e.g., "From Zion shall go forth the Torah, and the Word of the Lord from Jerusalem"), and Jesus' own Jewish roots and presence in Jerusalem.
- Outreach on Jerusalem should be nonpartisan. Support for Jerusalem among U.S. Christians should not be linked to a particular party in power or particular policies being espoused, either in Israel or the U.S. Rather, outreach should focus on enhancing support based on facts and religious beliefs that transcend momentary political constellations.
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* With appreciation to Dr. Eugene Korn, Director of Interfaith Relations at the ADL, for his insights and collegiality; to the ADL for the extensive source material on Catholic and mainstream Protestant positions; and to Rabbi Yechiel Eckstein and Reverend Petra Heldt for their invaluable input.
1. AJCommittee, 2001 Annual Survey of American Jewish Opinion (November 19-December 4, 2001).
2. Truman Institute for the Advancement of Peace, Hebrew University of Jerusalem, and Palestinian Center for Policy and Survey Research (PSR), Ramallah, August 4, 2000.
3. Steven Cohen, as reported by Steven Rosenthal, Irreconcilable Differences? The Waning of the American Jewish Love Affair with Israel (Hanover: Brandeis University Press, 2001): "For every ten-year drop in age, there is a 5% decline in support for Israel."
4. Andrew Kohut, John C. Green, Scott Keeter, and Robert Toth, eds., The Diminishing Divide: Religion's Changing Role in American Politics (Washington, D.C.: Brookings Institution, 2000), p. 10.
5. Ibid., pp. 112-121.
7. In April 2002, Jerusalem Mayor Ehud Olmert appointed a public committee to enhance Jerusalem's status in the Jewish and non-Jewish world, Haaretz, April 30, 2002.
8. Eileen W. Lindner, ed., Yearbook of American and Canadian Churches, 2001 (Nashville: Abingdon Press, 2001).
9. Yechiel Eckstein, Understanding Evangelicals: A Guide for the Jewish Community (Chicago: International Fellowship of Christians and Jews, 1992).
11. Abraham McLaughlin and Gail Russell Chaddon, "Christian Right Steps In On Mideast," Christian Science Monitor, April 16, 2002.
12. Kohut, pp. 50-51.
13. McLaughlin and Chaddon.
14. Most Reverend Jean-Louis Tauran, The Holy See and the Middle East, Washington, D.C., March 10, 1999.
15. See for example, "City of Holiness and Hope: A Message on Jerusalem," National Council of Churches, November 12, 1996; "Mideast Peace: New Strategies for a New Era," Churches for Middle East Peace, December 2001; and "Statement on the Status of Jerusalem," Eighth Assembly, World Council of Churches, Harare, Zimbabwe, December 1998.
16. Eugene Korn, "Bearing False Witness," Religion News Service, March 6, 2002.
17. Michael Freund, "Christian Broadcaster Urges Americans to Visit Israel," Jerusalem Post, March 22, 2002.
18. Worldwide Faith News website, http://www.wfn. org/2002/04/msg00201.html, April 15, 2002.
19. R.J. Zwi Werblowsky, The Meaning of Jerusalem to Jews, Christians and Muslims (Jerusalem: Intratypset, 1977).
21. Petra Heldt, "Christian Links With Jerusalem," Christians for Israel website, www.c4israel.org.
22. Clarence Wagner, "Jerusalem, Sacred to Whom?" Dispatch from Jerusalem, Bridges for Peace, Jerusalem, November-December 1996.
23. Daphne Tsimhoni, "The Christians in Israel, the West Bank and the Gaza Strip," Middle East Quarterly, Winter 2001.
24. "The Significance of Jerusalem for Christians: Memorandum of their Beatitudes the Patriarchs and of the Heads of Christian Communities in Jerusalem," November 14, 1994.
26. Rt. Rev. M. Thomas Shaw, Remarks of April 12-13, 2002, at the conference "Ending the Occupation," sponsored by Friends of Sabeel-North America, Boston, MA, posted April 21, 2002.
27. Melanie Phillips, presentation at an online seminar on replacement theology of the Centre for Jewish-Christian Relations, May 14, 2002, http://www.cjcr.cam.ac.uk/tfstuff/phillips.html.
28. Kohut, p. 148.
29. Kohut, p. 95.
30. Kohut, pp. 90-91.
31. Kohut, p. 127.
32. Kohut, pp. 109-125.
33. Kohut, pp. 110-111.
34. Nicholas D. Kristof, "Following God Abroad," New York Times, May 21, 2002.
36. Kohut, p. 24.
37. Allison Mitchell, "U.S. Conservative Groups Unite to Support Israel," International Herald Tribune, April 22, 2002.
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David Raab is CEO of a strategy consulting firm with offices in the United States and Israel. Over the last decade he has been actively engaged, through a number of American Jewish organizations, in presenting Israel's case in the United States.
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