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ONTARIO SUPERIOR
COURT OF JUSTICE
IN THE MATTER OF an
intended action
BETWEEN
RICHARD WARMAN
Plaintiff
and
CANADIAN ASSOCIATION
FOR FREE EXPRESSION INC.
and
PAUL FROMM
Defendant
NOTICE
Pursuant to section 5(1) of the
Libel and Slander Act, R.S.O. 1990, c.L. 12,
PLEASE BE ADVISED that you have
spoke words and/or written words and/or published words which are
defamatory and libelous t Richard Warman appearing on the website
"FREEDOMSITE" (http://www.freedomsite.org/pipermail/fs_announce/2003/001228.html)
entitled 'RICHARD WARMAN, HIGH PRIEST OF CENSORSHIP, ON RAMPAGE IN
LONDON[sic]", this same article sent out via the website
'FREEDOMSITE" e-mail announcement list, same article also
appearing on the website 'CANADIAN HERITAGE ALLIANCE" UNDER
THE TITLE "We're Coming for You". On the website
FREEDOMSITE and article entitled "Jewish Lobby Being
Re-Organized". On the website "CANADIAN HERITAGE
ALLIANCE", again, (www.
candianheritagealliance.com/channels/news/2003/September/la.html),
article entitled "White Supremacists Sued". These
articles first came to the knowledge of Richard Warman during the
months of September and October 2003, as being defamatory and
libelous. The matters complained of are as follows:
The web-page article entitled,
Richard Warman, High Priest of Censorship, on Rampage in
London", and the web-page article entitled, "We're
Coming For You":
1. Accuses Richard Warman of
abusing tax payers' money.
2. Accuses Richard Warman of being
a "fanatically anti-free speech cabal of the politically
correct".
3. Accuses Richard Warman of
victimizing immigrants because their first languages are not
English.
4. Describes Richard Warman as a
"Human Rights persecutor".
5. States that Richard Warman IS an
"enemy of free speech".
6. Accuses Richard Warman of being
the political thought police.
7. Accuses Richard Warman of
participating in a "war on free speech".
Stated on the web-page article
entitled, "Jewish Lobby Being Re-Organized"
1. Accuses Richard Warman of
contributing to turning over the control of the Internet to the
censors of the Canadian Human Rights Commission.
2. Accuses Richard Warman of being
the Canadian Human Rights Commission's "hatchetman".
Stated on the web-page article
entitled, "White Supremacists Sued"
1. That Richard Warman's
professional career as a lawyer involves him in the repression of
free speech and thought and in the actions of the "political
thought police" through his employer, the Canadian Human
Rights Commission.
2. Accuses Richard Warman of "mak[ing]
a career of throttling the expression of those whose views he
doesn't like".
3. Accuses Richard Warman of using
scare tactics to censor free speech.
4. Accuses Richard Warman of being
an oppressor and a member of "Big Brothers' thought
police".
PLEASE BE ADVISED THAT you have
spoken words and/or written words and/or published words which
contain serious allegations against Richard Warman, clearly
stating to the readers of the website, "Canadian Heritage
Alliance," and "Freedomsite" in their plain and
ordinary meaning or by virtue of the surrounding circumstances
which give the words a defamatory meaning inferentially or by
innuendo, that you are questioning Richard Warman's morality,
integrity and professionalism: that Richard Warman commits
disreputable and unconstitutional acts such as the suppression of
free speech; that Richard Warman works for the thought police and
is the Canadian Human Rights Commission's "hachetman",
that Richard Warman is an oppressor and a member of the "Big
Brother's thought police", and that Richard Warman victimizes
immigrants. You have defamed and libeled Richard Warman in his
skill, judgment, and/or capacity in his profession.
PLEASE BE ADVISED THAT the words
spoken and/or written and/or published, in their plain and
ordinary meaning or by virtue of the surrounding circumstances
which give the words a defamatory meaning inferentially or by
innuendo, are completely and absolutely false, defamatory and
libelous.
PLEASE BE ADVISED THAT we request a
complete retraction to be published on the websites "Canadian
Heritage Alliance" and "Freedomsite", as well as
via the freedomsite email announcement list with as much clarity
and prominence as the defamatory and libelous words spoken and/or
written and/or published.
PLEASE BE ADVISED THAT It is our
intention to commence an action for libel against you.
THIS NOTICE is served upon you
pursuant to the paragraph 5(1) of the Libel and Slander Act, R.S.O.
1990, ch. L-12.
Date: October 22, 2003
Richard Warman
by his solicitors:
- Nelligan O'Brien Payne LLP
- Barristers & Solicitors
- 1900–66 Slater Street
- Ottawa ON K1P 5H1
- Sophie Theriault, Student at Law
- 613-231-8227
- 613-238-2098 (fax)
- Solicitors for Richard Warman
TO:
- CANADIAN ASSOCIATION FOR FREE
EXPRESSION
- Box 332, Station B
- Rexdale, Ontario M9W 5L3
and
PAUL FROMM
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