M.Y.C.S. (the mother) and C.M.S. (the father) married in 2015, following a brief courtship. Life was complicated for this family. The father was employed as an Israeli diplomat. His 12-year-old daughter by a prior relationship made an outcry to her counselor that he had allegedly spanked her with a belt. This outcry occurred while M.Y.C.S. was pregnant with twins—the pregnancy being achieved through technology using donor eggs and father’s sperm. Following the outcry, the father returned to Israel in February 2016. After his return to Israel, he advised M.Y.C.S. that he had done a background check on her, no longer believed she was Jewish, and declared that under Jewish law, they were no longer married. M.Y.C.S., by then 32 weeks pregnant, traveled to Israel on a three-month tourist visa. C.M.S. rejected her, even denying her access to his home. In light of the fact that she did not have a residence, she tried to return to the United States, but the airline would not allow her to travel due to her advanced state of pregnancy. The twins were therefore born in Israel on June 20, 2016, around two weeks after the mother arrived. The father was not present for the birth of the children, nor did he support the twins or their mother. In fact, he insisted on a paternity test.

On Nov. 8, 2017, the parties signed an agreement for a Jewish divorce. That document mandated that the children be educated and reside in Israel. The document was written in Hebrew. Around three months later, the father sought and was granted “stay of exit” orders from the Israeli Court. M.Y.C.S. left Israel with the twins in April 2018. She had been ordered to do so by the Israeli government, as her visa had expired. She later claimed she received no notice of the “stay of exit.” She obtained passports for the twins through the U.S. Embassy, marking the requisite form by indicating there were no court orders impacting the twins’ custody. Meanwhile, back in Israel, the father filed a police report in May 2018 after learning that the mother left Israel with the twins. C.M.S. represented that he worked with the State Department, the Middle Eastern Affairs Department and a private investigator to locate the mother and their twins. However, he failed to mention that he had a copy of mother’s Texas driver’s license, listing her residence in Wood County, Texas, where she resided with her parents.