Court File No. T-567-96
IN THE FEDERAL COURT OF CANADA TRIAL DIVISION
ERNST ZÜNDEL APPLICANT
THE MINISTER OF CITIZENSHIP AND IMMIGRATION SECURITY INTELLIGENCE REVIEW
AFFIDAVIT OF ERNST ZÜNDEL - APPLICANT
THE MINISTER OF CITIZENSHIP AND IMMIGRATION; and SECURITY INTELLIGENCE REVIEW
I, Ernst Zündel, of 206 Carlton St., City of Toronto, Province of Ontario,
MAKE OATH AND SAY AS FOLLOWS:
1. I am the applicant in this matter. The Minister of Citizenship and Immigration
seeks to deny me Canadian citizenship on the grounds that I am a risk to
the national security of Canada under the Citizenship Act and the Canadian
Security Intelligence Act on the grounds that I will commit serious violence
in the furtherance of my political beliefs.
2. I have been convicted of no criminal offense during the 38 years I have
lived as a permanent resident of Canada. I have never been convicted of
counselling, aiding, or abetting any crime,
3. (n)otwithstanding the near-riot which occurred outside of my home by
Jewish organizations in 1981, the pipe bombing of my home in 1984, beatings
of me and my supporters on the steps of Toronto courthouses in 1984 and
1985, violent threats and telephone harassment over the years (for which
at least 3 people have been convicted), a devastating arson attack in 1995,
which almost destroyed my home, and the attempted murder by sending me a
pipe bomb in 1995. I have never threatened, intimidated, bombed, attacked,
beaten or harassed any person in Canada or counselled anyone else to do
so, or broken the laws of Canada in any way to the best of my knowledge.
4. I am a pacifist. I renounce violence as a means of political change,
and I am disgusted by the use of violence by political groups, the more
so since I have been the victim of so much left-wing and Jewish violence.
5. No person, to my knowledge, has ever accused me, either directly or indirectly,
of using violence, advocating violence or planning the use of violence in
the furtherance of my political beliefs. The sole exceptions to this are
the respondents in this application, the Minister of Citizenship and Immigration
and the Canadian Intelligence Review Committee (SIRC).
6. The respondent SIRC found in its report on the Heritage Front Affair
(The Heritage Front Affair Report) that I had asked for names of Jewish
individuals for the purpose of doing them serious physical violence. At
4.4, page 10, of the Report, the respondent SIRC wrote:
"In late October 1993, the CSIS Source learned about a
threat of serious physical violence against leaders in the Jewish community
by a Heritage Front member. The threat was evaluated by CSIS, and the police
were notified. Ernst Zündel wanted information on the Jewish community's
leaders during this time and was provided with publicly available information
(see chapter V, 5.10.6((22) Footnote 22, SIRC interview with Source.
And further at 5.10.6 at page 36, the respondent SIRC wrote:
"We asked the Source about the kinds of information collected
on Jewish groups and their leaders. The Source stated that Zündel tasked
Bristow to obtain specific information about the names, work places, home
addresses, telephone numbers and profiles of prominent Jewish individuals
and groups. (135)
The foregoing statements are utterly false allegations.
Zündel said that he needed the addresses of members of the Jewish community
so that he could serve subpoenas, but the Source said that Bristow did not
believe this. Footnote 135 - Zündel denies this allegation.
7. SIRC's source for this false information was Grant Bristow, co-founder
and Security Chief of the Heritage Front and alleged CSIS agent.
8. In fact, I asked Bristow for the addresses of the Jewish leaders who
had been harassing me relentlessly with threats of prosecution and deportation
as a "hate monger" both before and after I won my appeal in the
Supreme Court of Canada in August of 1992. The orchestrated harassment against
me by these Jewish leaders generated a climate of violence against me that
was palpable. Ultimately this hysteria resulted in violent demonstrations
outside my home and posters with my head in the cross-hairs of a rifle sight,
a devastating arson attack in 1995, and an attempted murder by pipe bomb
the same year. I believed and still believe that these leaders of the Jewish
organizations were and are guilty under the Criminal Code of intimidation,
watching, besetting, stalking and harassment. I wished to charge them with
these offenses and believed that I required the addresses of the leaders
involved before the police would act on my complaint.
9. I also wrote to my lawyer, Barbara Kulaszka, asking for names and newspaper
clippings of those Jews who were continually calling for my arrest and re-charging
under the hate laws and deportation, and asked for legal advice on the feasibility
of such charges being laid. I also had correspondence with the Attorney
General, the Crown Attorney in Toronto and attended at the local police
division office and Crown offices in order to try to bring criminal charges
against the Jewish leaders harassing me. Attached to this my affidavit and
marked Exhibit A is a copy of such correspondence.
10. An investigator for the respondent SIRC identifying himself as John
Smith interviewed me over the telephone only days before the "Heritage
Front Affair Report" was issued in December of 1994. On the basis of
this telephone interview, with no further checking with my lawyers, the
respondent SIRC saw fit to make these accusations against me. It did not
accept my version of events as to why I wanted the addresses of the Jewish
leaders and instead found that my request was tied to threats against the
Jewish community leaders.
11. The respondent SIRC's own report "The Heritage Front Affair"
is entered against me by the Minister of Citizenship in the hearings now
going on before SIRC. The evidence of Grant Bristow contained in that report
is the only evidence disclosed to me by the respondent Minister of Citizenship
that forms a basis for alleging that I will use violence in the future in
furtherance of my political beliefs. It is utterly false information which
has proved extremely damaging to me, as these proceedings show.
12. I am unable to subpoena Bristow as I do not know his whereabouts.
13. The respondent SIRC has already proven that they accept the credibility
of Bristow over the evidence of myself and other persons and based the whole
of the Heritage Front Affair Report, in which it defends and praises CSIS's
actions, on his version of events. They have accepted his testimony that
my request for information is tied to threats against the Jewish community
leaders. This finding was an important justification for the respondent
SIRC's exoneration of Bristow and CSIS activities because in its words
(quote accidentally omitted from affidavit filed)
14. The oral testimony I wish to call is as follows:
(a) Wolfgang Droege - Droege was and is the leader of the
Heritage Front and will testify as to the goals and strategies of the organization;
the role of Grant Bristow in founding and supporting the Heritage Front
financially; the actions of Grant Bristow with respect to the harassment
campaign against anti-racists, the carrying of guns in the back of his car,
the threats of coercion and bodily harm against members of the Heritage
Front who did not want to participate in the harassment campaign; and his
tampering with a witness in the criminal trial of Eric Fischer and his brother.
Droege will also give evidence on the failure of the respondent SIRC to
elicit crucial evidence to check what Bristow was saying.
(b) Tyrone Mason - Mason is a former member of the Heritage
Front who was kidnapped, forcibly confined and beaten in 1993 by three other
members of the Heritage Front, Eric and Elkar Fischer and Drew Maynard.
Mason will testify that Bristow counselled Mason to commit perjury after
Mason laid charges against the Fischers and Maynard. Mason will testify
that the charges against Maynard were dropped because of Crown delay and
that under a Crown deal the Fischers pleaded guilty to assault and received
a sentence of 30 days. Mason had to be put into the witness protection programme.
(c) Elisse Hategan - Hategan is a former member of the
Heritage Front who took part extensively in the harassment campaigns against
anti-racists and has knowledge of Bristow's leading role in organizing and
conducting the harassment campaign against anti-racists.
(d) Val Meredith, Derek Lee and Tom Wappel
- These three persons are all members of the House of Commons Sub-Committee
on National Security which investigated the Heritage Front Affair in 1995
and wrote a draft report which media accounts reported found that CSIS had
broken the law in spying on the Heritage Front and covered up evidence in
its report on the affair. This report was never released.
(e) Grant Bristow - Grant Bristow is the source of the
information that I planned future violence against Jewish leaders. I should
be entitled to cross-examine Bristow in open court to show that Bristow
lied about me in the version accepted by the respondent SIRC in its report
"The Heritage Front Affair." This is a matter of credibility which
should take place in open court and for the public to see that justice is
(f) Ernst Zündel - My own testimony would show that
the "Heritage Front Affair" report by the respondent SIRC falsely
accuses me of eliciting the names of prominent Jews for some illicit purpose,
that SIRC is biased against the Right wing and its ideas; that it falsely
portrays the Right wing as a monolithic entity bent on political violence
and destabilization; that the evidence of Grant Bristow regarding my requests
for information was false; that the other findings of SIRC in its report
concerning me were false and show an overwhelming political prejudice and
hostility to me and to what it terms the "extreme right wing"
of which it alleges I am a leading part.
15. This evidence should be open to public scrutiny and cross-examination
in open court.
16. I believe this evidence will show reasonable apprehension of bias and
conflict of interest by the respondent SIRC.
DATED this 9th day of May, 1996.
_________ Ernst Zündel
Sworn before me at
the City of Toronto in the
Province of Ontario
this 9th day of May 1996.
___________ Commissioner for Taking Affidavits, etc.
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