B’NAI BRITH & THE CANADIAN HUMAN RIGHTS COMMISSION – CENSORING FOR ZION

B’NAI BRITH & THE CANADIAN HUMAN RIGHTS COMMISSION – CENSORING FOR ZION

[Editor's Note: As the legal events of Canada’s latest “Hate Crimes” case involving B'nai Brith Canada and RadicalPress.com ‘creep in their petty pace from day to day’ toward another Tribunal hearing Show Trial, each new exchange between the Canadian Human Rights Commission (CHRC) and myself reveals the increasing collusion between an organization purported to be “serving the public interest rather than the interests of the complainant” and the Jewish foreign lobbyist group known as B'nai Brith Canada, a secret society of pro-Zionist zealots whose main purpose in life is to prevent any criticism in Canada of political Zionism or the racist state of Israel.

Nothing thus far in the complaint process illustrates this conspiracy better than the two recent attempts on the part of the Commission to deny its involvement in attempting to fundamentally alter the nature of the original complaint laid against myself and RadicalPress.com – first by denying the existence of crucial documents (The Protocols of the Learned Elders of Zion) and then by actually trying to change the wording of the official complaint laid against me by the League for Human Rights of B’nai Brith Canada so as to eliminate what obviously could prove to be a very embarrassing and incriminating phrase (“and/or citizens of Israel”); one which clearly exposes the true nature of B’nai Brith’s motives in laying the complaint in the first place.

The following response from the CHR Commission plus my reply to them sent via the Tribunal should illustrate, as others before me have also done, the urgent need for a drastic review of this supposedly “Canadian” Human Rights organization; one which has obviously deteriorated over time and through alien influences by anti-Canadian, foreign agencies, into a dangerous, deluded body of political sycophants beholding not to Canada and its democratic freedoms but to the Zionist agents who have infiltrated our federal government and our media over decades and are now calling the shots on crucial issues such as our coveted right to freedom of speech and expression of diverse opinion plus the maintenance of a free, open, uncensored internet.

The two Motions which the Commission responded to can be found can be found at the following urls:

http://www.radicalpress.com/?p=1001
Canadian Human Rights Commission Exhibits Extreme Bias Toward Protocols

http://www.radicalpress.com/?p=1003
Canada’s Commissars of Political Correctness Change Legal Documents to Suit B’nai Brith Canada
Friday, April 24th, 2009

What follows here is the Commission's response to them and then my response to theirs sent to the Tribunal. Please pass this information along to whomever you feel might benefit from it. Also, please remember that I can always use financial assistance in carrying on this effort to rid the country of Section 13(1). See the Donate button at the top right of my Home Page. Feel free to use it. ]

Arthur Topham
Editor
RadicalPress.com

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Tribunal : T1360/9008

CANADIAN HUMAN RIGHTS TRIBUNAL BETWEEN:

Harry ABRAMS
And
League for Human Rights of B’Nai Brith Canada
Complainants

- and -

CANADIAN HUMAN RIGHTS COMMISSION

 - and -

Arthur TOPHAM and RADICAL PRESS.COM
Respondents

SUBMISSIONS OF THE CANANDIAN HUMAN RIGHTS COMMISSION
in response to Respondent’s Motions

CANADIAN HUMAN RIGHTS COMMISSION
344 Slater Street, 9th Floor
Ottawa, ON  K1A 1E1

May 5, 2009
Daniel Poulin

Tel: (613) 947-6399
Fax: (613) 993-3089

1.   This is the Commission’s response to Mr. Topham’s two Motions, namely the Motion to amend the CHRC’s Statement of Particulars (referred to herein as the Motion to amend) and the Motion to Rescind Poulin’s Denial of Further Disclosure (referred to herein as the Motion for Further Disclosure). The Commission will address the Motion to Intervene in another set of submissions.

Motion to Amend

2.   Mr. Topham argues that the Commission should be ordered to further amend its Statement of Particulars to, he writes, truly reflect the issue before this Tribunal.

3.   In response, the Commission submits that the Tribunal may exercise the same powers as a superior court in relation to a hearing of a complaint (s.50, Canadian Human Rights Act).
This would include the ability to make rulings as to decorum, and to ensure that the parties who appear before the Tribunal are treated with respect.

4.    Consequently, the Commission submits that this would also include the ability to strike a Statement of Particulars, and/or to order the filing of a new one if, for example, the document is found to contravene the rules of the Tribunal, or if it were to be found to be vexatious. These types of orders would be in accordance with the purpose of the Rules: to ensure that the parties are treated with respect.

5.    The Tribunal’s Rules set out what a party’s Statement of Particulars is to contain. Of importance here is Rule 6(1)(b) which states that “(w)ithin the time fixed by the Panel, each party shall serve and file a Statement of Particulars setting out (…) (b) its position on the legal issues raised by the case (…).” (Emphasis added)

6.   The Commission’s Statement of Particulars sets forth the Commission’s position on the legal issues raised by the case and its formulation on these issues. It is not meant to be Mr. Topham’s views of these legal issues; those are to found in his own Statement of Particulars.

7.   In the present case, the Commission’s Statement of Particulars is not vexatious and is in conformity with the Tribunal’s Rules.

8.   Consequently, the Motion to Amend should be dismissed.

Motion for Further Disclosure

9.   Mr. Topham’s second motion is one in which he seeks to have the Commission and/or the Complainants provide him with a copy of the Protocols of the Learned Elders of Zion. He seems to suggest that this document should be presented to the Tribunal because it would be a historical document.

10.    This document was not, and is not at this time, in the file of the Commission. One of the first rules of disclosure is that a party must disclose a document that may be arguably relevant when it is in its possession. The Protocols is not in the possession of the Commission and therefore cannot be disclosed. The Tribunal cannot order a party to disclose a document it does not have.

11.    Moreover, the Commission submits that it is of public knowledge (and that the Tribunal can take judicial notice) that the Protocols is a forgery. In addition, it is of common knowledge that the Protocols is a major anti-Semitic text. The document was described by the U.S. Judiciary Committee as “vicious” and meant to “peddle the myth of Jewish Conspiracy” (“Protocols of the Elders of Zion, A Fabricated ‘Historic’ Document”, Report to the Committee of the Judiciary, United States Senate, 1964, an electronic version may be found at
http://www.ushmm.org/museum/exhibit/focus/antisemitism/pdf/senate-protocols.pdf )

Allegation of bias on the part of Counsel

12.   Mr. Topham alleges that Commission Counsel’s response to one of his initial emails constitutes a clear allegation of bias. Since Commission Counsel is It is submitted that this allegation is clearly unfounded and must be dismissed.

Motion to Intervene

13.   As to the Motion to Intervene introduced in the present hearing, the Commission has no submissions to make other than to indicate that it may adopt the Complainant’s position when it is known.

Conclusion

14.   Consequently, the Respondent’s Motions should be dismissed.

ALL OF WHICH IS RESPECTFULLY SUBMITTED

Dated at Ottawa, this 30th day of April 2009

Daniel Poulin
Legal Counsel, CHRC
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RADICALPRESS.COM’S RESPONSE TO MAY 5, 2009 SUBMISSIONS OF THE CANADIAN HUMAN RIGHTS COMMISSION

BY EMAIL

Arthur Topham
Pub/Ed
The Radical Press
Box 4633 Barkerville Hwy
Quesnel, B.C. V2J 6T8
Email: radical@radicalpress.com

May 14, 2009

Nancy Lafontant
Registry Officer
Canadian Human Rights Tribunal
Nancy.Lafontant@chrt-tcdp.gc.ca

Dear Nancy Lafontant, et al,

Re: Harry Abrams and the League for Human Rights of B’nai Brith Canada v. Arthur Topham and the RadicalPress.com
File Number: T1360/9008

1.  Please find enclosed a letter to the Tribunal outlining further my complete disagreement with the position taken by the Commission’s submission of May 5, 2009 with respect to my April 23, 2009 “Motion to Further Amend CHRC Statement of Particulars” and my April 22, 2009 “Motion to Rescind Poulin’s Denial of Further Disclosure” (referred to herein as the Motion for Further Disclosure).

2.  With respect to Mr. Poulin’s comments in Para. 3 of the Commission’s “Motion to Amend” the question as to the Tribunal’s legal right to decide all questions of law and fact is not in dispute. I must assume that Mr. Poulin offered this statement to somehow corroborate his additional remarks that “This would include the ability to make rulings as to decorum, and to ensure that the parties who appear before the Tribunal are treated with respect.” What remains though in his comments concerning making rulings on “decorum” and ensuring that parties are “treated with respect” again is somewhat nebulous and confusing.

3.  In the case of my April 23, 2009 “Motion to Further Amend CHRC Statement of Particulars” the relevant question for the Commission and the Tribunal had nothing to do with the issues of “decorum” and “respect” for the parties involved. It had to do with the fact that the Commission was, in its Statement of Particulars, attempting to change the actual nature of the complaint! That, I submit, given all the documented reasons contained within the motion, should have clearly and succinctly signified what the real issue is for the Tribunal to consider, not what Mr. Poulin and the Commission in their subsequent Submission are seeking to divert the attention of the Tribunal away from recognizing as being the substance of my motion.

4.  As well, in my original motion, out of due respect for the Commission’s confusing, misleading wording, I stated the following:

“. . . in the commission’s Statement of Particulars, this aspect of the “ISSUES” has been either purposely overlooked and deliberately altered in order to deflect away from the original wording so as to comply with the subterfuge of the complainants or else it is merely an unwitting error on the part of someone who hasn’t a sufficient grasp of the English language or the legal expertise to realize the importance or import of retaining the precise original wording. In the case of Mr. Poulin, counsel for the commission, I cannot accept that he is unaware of the importance of the nature of the wording so that leaves only one of the other two options and at this point I’m not willing to speculate on which of them it might be.”

5.  Now, given the manner in which the Commission has responded to my “Motion to Amend”, I’m left to conclude that they are, in fact, deliberately attempting to alter the nature of the original complaint and can only be doing so as a result of obvious collaboration with the Complainants. There is no other reasonable or logical explanation for why the Commission would suddenly decide, midway through the complaint process, to change the wording of the original complaint other than they were influenced into doing so by the Complainants.

6.  In Para. 4 the Commission then goes on to state, again for reasons which they don’t elaborate on, that the Tribunal also has the legal right to “strike a Statement of Particulars, and/or to order the filing of a new one if, for example, the document is found to contravene the rules of the Tribunal, or if it were to be found to be vexatious.” [underlining is mine. A.T.] Again, the Commission inserts a reference to doing so in order “to ensure that the parties are treated with respect.” What this has to do with the “Motion to Amend” is left unanswered and open to conjecture, something which I will comment on further on but prior to doing so I wish to draw the attention of the Tribunal to the underlined portion of the wording in this paragraph wherein it states that the Tribunal may order the filing of a new Statement of Particulars if “the document is found to contravene the rules of the Tribunal . . . .”

7.  In the Tribunal’s Rules of Procedure, Rule 6(1) it states, “Within the time fixed by the Panel, each party shall serve and file a Statement of Particulars setting out,

“(d)  a list of all documents in the party’s possession, for which no privilege is claimed, that relate to a fact, issue, or form of relief sought in the case, including those facts, issues and forms of relief identified by other parties under this rule;” [underlining is mine. A.T.]

8.  What is clearly evident in the Commission’s submission and its position on this matter is that it is trying its utmost to deflect my argument away from the FACT of the original wording of the complaint onto extraneous, irrelevant issues of “decorum” and “respect” in order to avoid the obvious fallacy contained in its own biased attempt to intentionally manipulate the original wording of the complaint to suit the suspect interests of the Complainants. That, I submit, is showing a very high degree of disrespect toward the Tribunal itself.

9.  The Commission then goes on to state in Para 6: “The Commission’s Statement of Particulars sets forth the Commission’s position on the legal issues raised by the case and its formulation on these issues. It is not meant to be Mr. Topham’s views of these legal issues; those are to found in his own Statement of Particulars.”

10.  Again I must submit to the Tribunal that this position of the Commission is nothing short of subterfuge and the deliberate avoidance of the real issue here which is that of the wording of the original complaint. No one, least of all myself, is suggesting that the Commission’s Statement of Particulars should be guided by what my position is with respect to the complaint. But I must state uncategorically that whatever the Commission states in its Statement of Particulars must be in conformity with Rule 6(1)(d) and the rule of law and that means it cannot legally change the wording of the original complaint which, regardless of anything else, must remain intact in order for the process itself to retain any semblance of impartiality, fairness and, ultimately, justice.

11.  As for Para. 7 wherein the Commission concludes that its Statement of Particulars is not “vexatious” and “is in conformity with the Tribunal’s Rules” I cannot accept such a position given the explanation stated above.

12.  In my original April 23, 2009 “Motion to Further Amend CHRC Statement of Particulars” I stated, “. . . this aspect of the “ISSUES” has been either purposely overlooked and deliberately altered in order to deflect away from the original wording so as to comply with the subterfuge of the complainants or else it is merely an unwitting error on the part of someone who hasn’t a sufficient grasp of the English language . . . .”

13.  I purposely chose not to accuse Mr. Poulin and the Commission of being “vexatious” because of the unusual, incorrect (both grammatically and legally) and incongruous wording used. Rather I hoped to receive some further elucidation from the Commission which would clarify what obviously was an error on their part.

14.  Instead, the Commission is now choosing to stand by its original error and, in addition, is taking it to yet another level of disingenuousness by equating it with a completely irrelevant issue concerning the need for “decorum” and “respect” for the parties as if this somehow had anything to do with my original Motion. One is faced with having to conclude that stating “and/or citizens of Israel” is somehow insulting to or disrespectful of the other parties involved in this complaint and that is too preposterous to even entertain let concede to.

15.  At this point therefore I am forced to conclude that in fact the Commission IS being vexatious and biased and partial and its actions are showing complete disrespect for the rule of law as well as for the complaint process and the Tribunal’s own Rules as well as the alleged legal rights of the Respondents.

16.  I must therefore restate once again for the Tribunal’s consideration the original error contained in the Commission’s Amended Statement of Particulars dated April 8, 2009:

“The issue to be raised before the Tribunal in this case is as follows:

Did the Respondents communicate or cause to be communicated, in whole or in part, by means of a computer, including the internet, any matter that is likely to expose Jews and other non-white[sic] to hatred or contempt, contrary to section 13 of the Canadian Human Rights Act?” [underlining in second paragraph and bold are mine. A.T.]

A serious, unbiased look at the wording “and other non-white[sic]” leaves absolutely no room for doubt that this is a completely DIFFERENT charge than the original one contained in the initial complaint. How can the Commission, in all honesty and with regard to the facts themselves, change the words “and/or citizens of Israel” into the incomprehensible expression “and other non-white” without realizing or knowing that they are altering the very grounds upon which the Complainants have filed their complaint?

17.  Given this further explanation I would ask that the Tribunal take a very serious and impartial look at what the Commission is in fact attempting to do here with respect to the altering of basic facts of the complaint and instruct them to re-submit their Statement of Particulars with the correct wording in place. Should they, in the event of your doing so, fail to comply with your request, I would therefore suggest that the Tribunal dismiss the complaint based upon gross negligence, bias and an obvious intent to tamper with the legitimate evidence surrounding this complaint.

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Moving on now to the Commission’s response to my April 22, 2009 Motion to Rescind Daniel Poulin’s Denial of Further Disclosure (referred to herein as the Motion for Further Disclosure).

1.  In Para. 9 of the Commission’s response Mr. Poulin states, with respect to the document known as “The Protocols of the Learned Elders of Zion” (hereafter referred to as the “Protocols”), “He [the Respondent, Arthur Topham] seems to suggest that this document should be presented to the Tribunal because it would be a historical document.” I would only add here that it must be an intentional understatement on the part of the Commission to state that I “seem” to be suggesting that this document should be presented to the Tribunal.

2.  In Para. 10 we come to the crux, once more, of the Commission’s controversial attempt to change the rules of the game insofar as trying to blatantly deny the existence of particular documents relevant to the complaint by stating that they are not in possession of them, to wit, the Protocols. As Mr. Poulin says in this paragraph, “One of the first rules of disclosure is that a party must disclose a document that may be arguably relevant when it is in its possession. The Protocols is not in the possession of the Commission and therefore cannot be disclosed. The Tribunal cannot order a party to disclose a document it does not have.” This is not only an inaccurate assessment of the facts but one obviously designed to circumvent having to acknowledge the obvious. The Complainants disclosed this document in their initial complaint to the Commission. This is a FACT as the original complaint document in my possession clearly shows. Were the Commission being honest here it would have stated that it received this document in the form of a set of urls, just as it received the other 17 articles in the form of urls, all of which were purloined without permission from my website www.RadicalPress.com but that it then decided, for whatever unexplained reasons, to not include this document in its file of evidence. Judging from all the roundabout inferences and skirting of the subject as contained in Mr. Poulin’s constant denial evident in his anomalous references to “decorum” and “respect” one can only conclude that the Commission’s refusal to accept this document was based upon the erroneous and spurious notion that somehow its very existence posed an imminent threat to the parties concerned in this process. Such a conclusion on the part of the Commission can only be comparable in effect to a police department not admitting the murder weapon into an investigation because it might offend those connected to the crime. That said, for the Commission to then further state that “The Tribunal cannot order a party to disclose a document it does not have.” is but an absurdity coupled with an already irrational proposition and should not be given any credence by the Tribunal in its decision on this matter.

3.  With respect to Para. 11 the Respondent finds additional evidence of a confused and disjointed position being taken by the Commission with respect to the document known as the Protocols. In his response Mr. Poulin states, “. . . the Commission submits that it is of public knowledge (and that the Tribunal can take judicial notice) that the Protocols is a forgery. In addition, it is of common knowledge that the Protocols is a major anti-Semitic text.” With all due consideration to the fact that the Commission does not have this document in its files and therefore the Hate Crime Investigator, Ms. Sandy Kozak, who theoretically did the investigation into this complaint could not therefore have read the document in question (because she didn’t have it ), it appears rather presumptuous on the part of the Commission to make the sorts of judgments being given here by Mr. Poulin on a document which no one within the Commission appears to have read. Whether the document in question is a “forgery” or is “anti-Semitic” is irrelevant to the Commission’s argument for not having it in its possession. I won’t, for obvious reasons of length of this letter, go into the details of the document and counter these two longstanding false arguments which the Zionist Jews themselves have been complaining loudly of for the past 89 years. It will suffice for now to state that they are a ruse designed to perpetuate the very myth to which the current Commission obviously has succumbed in its present denial of the validity of the document.

4.  I would though like to comment on Mr. Poulin’s further statement to the effect that, “The document was described by the U.S. Judiciary Committee as “vicious” and meant to “peddle the myth of Jewish Conspiracy” (“Protocols of the Elders of Zion, A Fabricated ‘Historic’ Document”, Report to the Committee of the Judiciary, United States Senate, 1964, an electronic version may be found at http://www.ushmm.org/museum/exhibit/focus/antisemitism/pdf/senate-protocols.pdf )”

5.  Having read the document submitted by Mr. Poulin as some type of proof to back up the Commission’s position it’s quite obvious that Mr. Poulin is relying upon a document riddled with bias, misconceptions and prejudice and in all likelihood is one of a countless number of fabrications by the very same Zionist sources who have been doing their utmost since the publication in English first appeared to disparage the reading of it and influence the general public from actually studying its contents and ramifications contained within it.

6.  After reading the pdf of Mr. Poulin’s I then re-read Harry Abrams’ January 27, 2008 letter to the Quesnel Cariboo Observer wherein he stated, “One very specific item complained of is the re-publication of aspects of the notorious Czarist-era forgery: The Protocols of the Learned Elders of Zion.

7.  This vicious screed, debunked both as fraudulent and hateful many times, was a substantial propaganda component in Hitler’s Nazi-era propaganda, and sadly, remains in circulation, mainly in Arab countries today.”

8.  Mr. Abrams’ words are practically word for word a parroting of this document which Mr. Poulin has submitted in his defense of the indefensible and as such ought to be taken with very large grains of salt. It would indicate that the Commission is merely relying upon “evidence” furnished by the Complainants rather than having done any serious investigation of the matter on their own impetus.

9.  I would also like to remind the Tribunal of certain statements made by the Commission’s senior “hate crimes” investigator Dean Steacy regarding the concept of “freedom of speech” contained in the transcripts of the Warman v Lemire case and found in the  May 10, 2007 transcript, at page 4793 http://richardwarman.com/transcripts/2007-01-Marc_Lemire/May_10_2007.pdf . In that document Dean Steacy testified that, “freedom of speech is an American concept, so I don’t give it any value… It’s not my job to give value to an American concept.”

10.  Given this assertion that the Commission’s senior investigator places no value whatsoever on anything connected to “American” concepts it now appears rather incongruous for Mr. Poulin to be enlisting the support of “American” concepts contained in a U.S. Judiciary Committee’s reports to support his argument for not including the Protocols in the Commission’s file. Rather, one would think that Mr. Poulin would rely upon Canadian documents and Canadian jurisprudence and/or government authorities to back any arguments in favour of the Commission’s position in this matter. Bearing this in mind I would therefore propose to both the Commission and to the Tribunal specifically the following “Canadian” concept which should be considered over and above those suspect “American concept[s]” to which Dean Steacy alluded in his testimony.

11.  In Canada, Member of Parliament Norman Jaques declared in the House of Commons on July 9, 1943: “Those who feel libeled by the Protocols have the most obvious remedy in the world; all they have to do is rise and denounce the policy of them, instead of denying the authorship… But when you come to read them how can any reasonable man deny the truth of what is contained in them?”

12.  That said I would now like to share with the Tribunal, by way of analogy, the following analysis of what I feel is the Commission’s mistaken position on the subject of the Protocols and why it needs to remedy its error in order to maintain its appearance of impartiality. For the purposes of this letter I’m referring to this analysis as Poulin’s Principle of Non-existent Evidence.

Poulin’s Principle of Non-existent Evidence

13.  What we have in fact is a complaint laid against myself, Arthur Topham and my website www.RadicalPress.com by a political lobby group whose primary agenda is to garner and maintain support for a foreign nation with a foreign policy that is both undemocratic and racist by definition.

14.  When this complaint was laid the complainants, Harry Abrams and the League for Human Rights of B’nai Brith Canada, handed over to the Commission what they felt to be the smoking gun or murder weapon assuming that having done so it would then simply be a matter of taking the finger prints off the alleged weapon, identifying the accused and reaching the logical conclusion of guilt.

15.  That “smoking gun,” I contend, is the document known as “The Protocols of the Learned Elders of Zion” (hereafter referred to as the “Protocols”). As I have already explicitly shown Mr. Poulin and the Commission and the Tribunal in my Motions of April 20, 2009 and April 22, 2009 this one document, above all the 18 documents originally complained of, was the primary one in terms of importance for the Complainants in establishing the validity of their alleged complaint against myself and www.RadicalPress.com. This is a known fact, revealed in the unequivocable words of the complainant Harry Abrams and clearly outlined to Mr. Poulin and the Tribunal in my previous motions noted above as well as in my current letter regarding the Commissions submission of May 5, 2009.

16.  Now that this issue of the missing Protocols has been questioned by the Respondent, Mr. Poulin and the Commission are stating, emphatically, that no such murder weapon exists in their files and that because they are not in possession of this document they cannot and do not have to address the issue of its contents or its absence from the official records surrounding this complaint. This, I most humbly suggest to the Tribunal and to the Commission, has to be the penultimate in both sophistry and subterfuge on the part of a quasi-judicial government body that purports to be acting in both a legal and impartial manner.

17.  When the complaint was originally filed with the Commission, at the top of the list of documents was the Protocols. That, in itself, ought to be sufficient a priori proof that such a document was both included in the original complaint and submitted to the Commission. In fact, the very first notice the Respondent received from the Commission on November 20, 2009 contained this very reference to the Protocols at the top of the list. Based upon this actual reality it therefore behooves Mr. Poulin and the Commission to acknowledge the existence of the document submitted to it by the Complainants and to recognize and admit it as evidence in order to corroborate their own conclusions which they somehow reached in the course of their investigation of said allegations.

18.  To state, as Mr. Poulin is now obviously and blatantly doing, that he and the Commission do not have to address this contentious issue of the Protocols because they are not in possession of the document is an outright attempt to evade their own irresponsibility for not having looked at all the evidence submitted to the Commission prior to making their decision to recommend this complaint be handed over to the Tribunal for a hearing and eventual resolution.

19.  Again, let me reiterate what I have already clearly pointed out to Mr. Poulin and the Commission in my previous motions noted above. The complainants, Harry Abrams and the League for Human Rights of B’nai Brith Canada, registered a complaint with the Commission that I was publishing articles which they contended promoted “hatred toward Jews and/or citizens of Israel.” First and foremost among the list of articles complained of was the Protocols. The original urls to the articles on my website (and the subsequent new urls which were later added after my original forum containing the first set of urls was lost due to the machinations of the Complainants) were included in the original complaint as were the urls to the remaining other 17 articles submitted by the Complainants.

20.  This clearly establishes the fact that the Protocols are a vital and relevant component of the overall complaint; in fact, the most relevant of all the evidence if we are to judge the relative merits of the articles in question by the standard which Harry Abrams the BBC themselves have set.

21.  So the obvious question still remains: how can the Commission now state that they do not have the document in their files? Up to this point I have given Mr. Poulin the benefit of the doubt but his and the Commission’s response to these motions leaves me with no alternative but to state in the most emphatic manner possible that both he and the Commission are committing a grave miscarriage of justice in their now transparent attempt to block having to deal with what amounts to their own ineptitude regarding this matter by resorting to such inane reactions as suggesting that my request for inclusion of this principal document is somehow an arbitrary or personal preference on my part, and not, as it rightfully is, a vital, crucial part of the original complaint.

22.  If, as Mr. Poulin is suggesting, the Commission has no legal duty to produce this document and introduce it into the evidence in the Commission’s argument in favour of having accepted the original complaint by Harry Abrams and the League for Human Rights of B’nai Brith Canada, then this whole quasi-judicial process becomes in fact nothing more than a farsical, mendacious travesty of justice equivalent only to the infamous “Show Trials” of the former Bolshevik Soviet Union.

23.  Therefore, based upon all that I have written in this letter to the Tribunal regarding this matter, I request that the Tribunal dismiss the Commission’s responses to my initial Motions and instruct them to either re-issue a correct and proper Statement of Particulars or else give the Commission notice to dismiss the complaint made against myself and www.RadicalPress.com.

24.  Concerning Para. 12 of the Commission’s submission, that of  “Allegation of bias on the part of Counsel” I would ask the Tribunal to instruct Mr. Poulin to supply the Respondent with the precise email to which he alludes so that I might respond to this submission properly.

If there is any further formality or motion that you require, please let me know as soon as possible.

Sincerely,

Arthur Topham pro se
Publisher/Editor
The RadicalPress.com

Cc:
Daniel Poulin, Legal Counsel, CHRC
Marvin Kurz,  Counsel, B’nai Brith Canada
Anita Bromberg, Co-complainant
Harry Abrams, Complainant

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