In Rabinowitz v. Olewski, 100 AD2d 539 [2d Dept 1984] the intended arbitrators received an inflammatory letter linking one of the parties to the Palestine Liberation Organization and accusing him of various criminal acts against Israel (Rabinowitz, 100 AD2d at 539). The court held that the highly inflammatory nature of the letter affected the arbitrators, who were predominantly Jewish, to such an extent that they were permeated with bias and upheld the lower court's decision to select an independent arbitrator (Rabinowitz, 100 AD2d at 540).