Court File No. :

ONTARIO

SUPERIOR COURT OF JUSTICE

BETWEEN:

Richard Warman

PLAINTIFF

- and -

William Grosvenor

DEFENDANT

STATEMENT OF CLAIM

The plaintiff states that this action is commenced under RULE 76 by way of SIMPLIFIED PROCEDURE.

TO THE DEFENDANT

A LEGAL PROCEEDING HAS BEEN COMMENCED AGAINST YOU by the plaintiffs. The claim made against you is set out in the following pages.

IF YOU WISH TO DEFEND THIS PROCEEDING, you or an Ontario lawyer acting for you must prepare a statement of defense in Form 18A prescribed by the Rules of Civil Procedure, serve it on the plaintiffs’ lawyer or, where the plaintiffs do not have a lawyer, serve it on the plaintiffs, and file it, with proof of service, in this court office, WITHIN 20 DAYS after this statement of claim is served on you, if you are served in Ontario.

If you are served in another province or territory of Canada or in the United States of America, the period for serving and filing your statement of defense is 40 days. If you are served outside Canada and the United States of America, the period is 60 days.

Instead of serving and filing a statement of defense, you may serve and file a notice of intent to defend in Form 18B prescribed by the Rules of Civil Procedure. This will entitle you to 10 more days within which to serve and file your statement of defense.

IF YOU FAIL TO DEFEND THIS PROCEEDING, JUDGMENT MAY BE GIVEN AGAINST YOU IN YOUR ABSENCE AND WITHOUT FURTHER NOTICE TO YOU. IF YOU WISH TO DEFEND THIS PROCEEDING BUT ARE UNABLE TO PAY LEGAL FEES, LEGAL AID MAY BE AVAILABLE TO YOU BY CONTACTING A LOCAL LEGAL AID OFFICE.

Date :

Issued by

Local registrar

Address of court office

161 Elgin street

Ottawa, Ontario K2P 2K1

TO:	William Grosvenor [ADDRESS REMOVED] Edmonton, Alberta T5E 1Y5

THIS ACTION IS BROUGHT AGAINST YOU UNDER THE SIMPLIFIED PROCEDURE PROVIDED IN RULE 76 OF THE ONTARIO RULES OF CIVIL PROCEDURE,

R.R.O. 1990, Reg. 194 as amended

CLAIM

1. The Plaintiff, Richard Warman, claims:

a. General damages in the amount of $50,000.00;

b. Aggravated damages in the amount of $50,000.00;

c. Punitive damages in the amount of $50,000.00;

d. A complete public retraction of the defamatory comments;

e. A permanent injunction restraining the Defendant Grosvenor and/or any other persons acting for the Defendant, from publishing, causing to be published, posting, or reposting any words which are defamatory to the Plaintiff, which invade the Plaintiff’s privacy and which threaten to harm or kill the Plaintiff and/or contain invitations and encouragements to harm or kill the Plaintiff;

f. Prejudgment and post-judgment interest pursuant to the provisions of the Courts of Justice Act, R.S.O. 1990, c. C.43, as amended;

g. Costs of this action on a substantial indemnity basis, including any G.S.T. thereupon; and

h. Such other Order as this Honourable Court deems just.

The Parties

2. The Plaintiff, Richard Warman (“the Plaintiff”), is a lawyer who works for the Government of Canada, and resides in the city of Ottawa, Ontario.

3. The defendant, William Grosvenor (“the Defendant”), is and was, at all relevant times, responsible for posting articles defamatory to the Plaintiff on different websites, and for committing the torts of assault and invasion of privacy against the Plaintiff.

Facts Relevant to Defamation, Assault and Invasion of Privacy

4. Google Inc., the US-based online search engine company also hosts thousands of free online discussion forums called ‘Google groups’ where participants can discuss topics of common interest that cover an extremely broad range of subject matter. Internet users can find discussion groups related to their interests and participate in “threaded conversations”, either through the Google Groups web interface, or by e-mail. They can also start new groups.

5. From or about August 25, 2006 to November 9, 2007, the Defendant posted messages on different Google groups websites regarding the Plaintiff (collectively referred to as the “Postings”). These Postings were defamatory to the Plaintiff, and/or threatened to harm or kill the Plaintiff, and/or invaded the Plaintiff’s privacy.

6. These Postings came to the Plaintiff’s attention at different times between January 17, 2007 to January 7, 2008.

7. The Posting entitled “Richard Warman lawsuit an indicator of what’s hot on the net” appeared on the following Google website groups:

(i) Alt.politics.libertarian, talk.politics.libertarian, can.politics, can.general, and soc.culture.canada on August 25, 2006; and

(ii) Alt.politics.libertarian, can.politics, can.general, soc.culture.canada, soc.culture.usa, and alt.politics.nationalism.white on September 20, 2006.

8. The Posting entitled “Richard Warman Address- To Get Protests- He Wants Lots of Visitors” appeared on the following Mailgate website groups :

(i) Alt.politics.nationalism.white, alt.politics.whitepower, and soc.culture.palestine on September 7, 2006.

9. The Posting entitled “Richard Warman Address- He Wants Lots of Visitors at his Address – To Get Protests” appeared on the following NNTP₂HTTO.com website groups :

(i) Alt.hackercan.politics, soc.culture.jewish, alt.revisionismcan.general, mail2news@remailer.org.uk, soc.culture.canada, soc.culture.palestine, mail2news@bananasplit.info, alt.politics.whitepower, and alt.politics.nationalism.white on September 30, 2006; and

(ii) Alt.hackercan.politics, soc.culture.usa, alt.revisionismcan.general, mail2news@remailer.org.uk, soc.culture.canada, soc.culture.palestine, mail2news@bananasplit.info, alt.politics.whitepower, and alt.politics.nationalism.white on October 3, 2006.

10. The Posting entitled “Richard Warman Wants Lots of Visitors, Callers- Repost” appeared on the following Google website groups :

(i) Alt.politics.nationalism.white, alt.politics.white-power, ott.general, can.general, soc.culture.canada, soc.culture.usa, and soc.culture.palestine on November 4, 2006; and

(ii) Alt.politics.nationalism.white, alt.politics.white-power, ott.general, can.general, soc.culture.canada, soc.culture.usa, and soc.culture.palestine on December 29, 2006.

11. The Posting entitled “Canada Awake! The Time To Cast Off Your Chains Is Now” appeared on the following Google website groups :

(i) Soc.culture.canada, can.general, and alt.politics.nationalism.white on May 19, 2007; and

(ii) Alt.politics.nationalism.white, soc.culture.canada and can.general on November 10, 2007.

12. The Posting entitled “Faggoty-looking lawyer crusades AGAINST free speech” appeared on the following Google website groups :

(i) Can.politics on July 11, 2007.

13. The Posting entitled “Richard Warman’s Song – Visit Him - Repost” appeared on the following Google website groups :

(i) Can.politics on July 11, 2007; and

(ii) Alt.politics.nationalism.white, alt.politics.white-power, can.general, soc.cutlture.canada, and ott.general on September 23, 2007.

14. The Posting entitled “Protests Planned for Richard Warman Address- He Wants Visitors/Callers- Repost ” appeared on the following Google website groups:

(i) Alt.politics.nationlism.white, alt.politics.white-power, can.general, ott.general, tor.general, soc.culture.palestine, can.general, and soc.culture.canada on September 19, 2007.

15. The Posting entitled “Why are ZYDs/Jews So Hated Worldwide?” appeared on the following Google website groups:

(i) soc.culture.europe, soc.culture.usa, can.general, edm.general, soc.culture.canada, uk.politics.misc, alt.politics.europe, soc.culture.australian, soc.culture.new-zealand on May 24, 2006;

(ii) soc.culture.europe, soc.culture.usa, can.general, edm.general, soc.culture.canada, uk.politics.misc, alt.politics.europe, soc.culture.australian, soc.culture.new-zealand on August 2, 2006;

(iii) soc.culture.europe, soc.culture.usa, can.general, edm.general, soc.culture.canada, uk.politics.misc, alt.politics.europe, soc.culture.australian, soc.culture.new-zealand on August 18, 2006;

(iv) soc.culture.europe, soc.culture.usa, can.general, edm.general, soc.culture.canada, uk.politics.misc, alt.politics.europe, soc.culture.australian, soc.culture.new-zealand on August 27, 2006;

(v) soc.culture.europe, soc.culture.usa, can.general, edm.general, soc.culture.canada, uk.politics.misc, alt.politics.europe, soc.culture.australian, soc.culture.new-zealand on September 24, 2006;

(vi) soc.culture.europe, soc.culture.usa, can.general, edm.general, soc.culture.canada, uk.politics.misc, alt.politics.europe, soc.culture.australian, soc.culture.new-zealand on October 2, 2006;

(vii) soc.culture.europe, soc.culture.usa, can.general, edm.general, soc.culture.canada, uk.politics.misc, alt.politics.europe, soc.culture.australian, soc.culture.new-zealand on October 13, 2006;

(viii) soc.culture.europe, soc.culture.usa, can.general, edm.general, soc.culture.canada, uk.politics.misc, alt.politics.europe, soc.culture.australian, soc.culture.new-zealand on October 22, 2006;

(ix) soc.culture.europe, soc.culture.usa, can.general, edm.general, soc.culture.canada, uk.politics.misc, alt.politics.europe, soc.culture.australian, soc.culture.new-zealand on November 18, 2006;

(x) soc.culture.europe, soc.culture.usa, can.general, edm.general, soc.culture.canada, uk.politics.misc, alt.politics.europe, soc.culture.australian, soc.culture.new-zealand on November 30, 2006;

(xi) soc.culture.europe, soc.culture.usa, can.general, edm.general, soc.culture.canada, uk.politics.misc, alt.politics.europe, soc.culture.australian, soc.culture.new-zealand on December 16, 2006;

(xii) soc.culture.europe, soc.culture.usa, can.general, edm.general, soc.culture.canada, uk.politics.misc, alt.politics.europe, soc.culture.australian, soc.culture.new-zealand on December 28, 2006;

(xiii) soc.culture.europe, soc.culture.usa, can.general, edm.general, soc.culture.canada, uk.politics.misc, alt.politics.europe, soc.culture.australian, soc.culture.new-zealand on February 1, 2007;

(xiv) soc.culture.europe, soc.culture.usa, can.general, edm.general, soc.culture.canada, uk.politics.misc, alt.politics.europe, soc.culture.australian, soc.culture.new-zealand on February 28, 2007;

(xv) soc.culture.europe, soc.culture.usa, can.general, edm.general, soc.culture.canada, uk.politics.misc, alt.politics.europe, soc.culture.australian, soc.culture.new-zealand on March 13, 2007;

(xvi) soc.culture.europe, soc.culture.usa, can.general, edm.general, soc.culture.canada, uk.politics.misc, alt.politics.europe, soc.culture.australian, soc.culture.new-zealand on April 7, 2007;

(xvii) soc.culture.europe, soc.culture.usa, can.general, edm.general, soc.culture.canada, uk.politics.misc, alt.politics.europe, soc.culture.australian, soc.culture.new-zealand on April 12, 2007;

(xviii) soc.culture.europe, soc.culture.usa, can.general, edm.general, soc.culture.canada, uk.politics.misc, alt.politics.europe, soc.culture.australian, soc.culture.new-zealand on April 21, 2007;

(xix) soc.culture.europe, soc.culture.usa, can.general, edm.general, soc.culture.canada, uk.politics.misc, alt.politics.europe, soc.culture.australian, soc.culture.new-zealand on May 29, 2007;

(xx) soc.culture.europe, soc.culture.usa, can.general, edm.general, soc.culture.canada, uk.politics.misc, alt.politics.europe, soc.culture.australian, soc.culture.new-zealand on June 19, 2007;

(xxi) soc.culture.europe, soc.culture.usa, can.general, edm.general, soc.culture.canada, uk.politics.misc, alt.politics.europe, soc.culture.australian, soc.culture.new-zealand on July 11, 2007;

(xxii) soc.culture.europe, soc.culture.usa, can.general, edm.general, soc.culture.canada, uk.politics.misc, alt.politics.europe, soc.culture.australian, soc.culture.new-zealand on July 18, 2007;

(xxiii) soc.culture.europe, soc.culture.usa, can.general, edm.general, soc.culture.canada, uk.politics.misc, alt.politics.europe, soc.culture.australian, soc.culture.new-zealand on July 31, 2007;

(xxiv) soc.culture.europe, soc.culture.usa, can.general, edm.general, soc.culture.canada, uk.politics.misc, alt.politics.europe, soc.culture.australian, soc.culture.new-zealand on September 12, 2007;

(xxv) soc.culture.europe, soc.culture.usa, can.general, edm.general, soc.culture.canada, uk.politics.misc, alt.politics.europe, soc.culture.australian, soc.culture.new-zealand on September 18, 2007;

(xxvi) soc.culture.europe, soc.culture.usa, can.general, edm.general, soc.culture.canada, uk.politics.misc, alt.politics.europe, soc.culture.australian, soc.culture.new-zealand on October 4, 2007;

(xxvii) Soc.culture.canada, soc.culture.europe, soc.culture.australian on October 12, 2007;

(xxviii) soc.culture.europe, soc.culture.usa, can.general, edm.general, soc.culture.canada, uk.politics.misc, alt.politics.europe, soc.culture.australian, soc.culture.new-zealand on October 15, 2007;

(xxix) soc.culture.europe, soc.culture.usa, can.general, edm.general, soc.culture.canada, uk.politics.misc, alt.politics.europe, soc.culture.australian, soc.culture.new-zealand on November 4, 2007;

(xxx) soc.culture.europe, soc.culture.usa, can.general, edm.general, soc.culture.canada, uk.politics.misc, alt.politics.europe, soc.culture.australian, soc.culture.new-zealand on November 5, 2007.

16. The Posting entitled “RICHARD WARMAN; HIS YID SCUMBAG AGENDA AND WHERE HE LIVES?” appeared on the following Google website groups:

(i) alt.revisionism, can.general, ont.general, alt.politics.white-power, ott.general, soc.culture.palestine, can.general on April 24, 2007;

(ii) alt.revisionism, can.general, ont.general, alt.politics.white-power, ott.general, soc.culture.palestine, can.general on May 2, 2007;

(iii) Soc.culture.canada, and alt.politics.nationalism.white on September 28, 2007; and

(iv) Soc.culture.canada, and alt.politics.nationalism.white on October 15, 2007.

17. The Posting entitled “NIZKOR & THHP STREET ADDRESSES FOR OCTOBER 2007” appeared on the following Google website groups:

(i) Alt.revisionism on October 19, 2007.

18. The Posting entitled ““Tricky Dick” Warman and His War On Dissent” appeared on the following Google website groups:

(i) Alt.politics.nationalism.white, ott.general, and tor.general on November 2, 2007; and

(ii) Alt.politics.nationalism.white, ott.general, and tor.general on November 8, 2007.

19. The Posting entitled “Female Activist Faces ‘Thought Crime’ Charges” appeared on the following Google website groups:

(i) Alt.politics.nationalism.white, can.general, and soc.culture.canada on November 9, 2007.

20. The Posting entitled “OTTAWA RICHARD WARMAN AND NANAIMOIAN KENNETH “NIZKOR” MCVAY ARE LOVERS AND FAGS” appeared on the following Google website groups:

(ii) alt.revisionism, ab.general, ott.general, edm.general, and can.general on January 7, 2008.

Publication of Material Defamatory to Richard Warman

21. On or about the spring of 2006 until but not limited to the Winter of 2008, the Defendant published throughout Canada and worldwide on the World Wide Web written words that are defamatory and libelous of the Plaintiff as part of postings on the Google website groups, Mailgate website groups and NNTP₂HTTO.com website groups.

22. On or about the month of January 2007 until but not limited to the month of January 2008, more than two hundred (200) libelous statements published by the Defendant came to the Plaintiff’s attention.

23. The different postings (First Posting, Second Posting, Third Posting, Fourth Posting, Fifth Posting, Sixth Posting, Seventh Posting, Eighth Posting, Ninth Posting, Eleventh Posting, Twelfth Posting Thirteenth Posting and Fourteenth Posting) (the “Defamatory Postings”) defamed and libeled the Plaintiff and were defamatory to his personal reputation and his professional reputation as a lawyer.

The Defamatory Postings

First Posting

24. The Plaintiff complains of the following words posted at least eleven (11) times by the Defendant :

“Richard Warman lawsuit an indicator of what’s hot on the net”

[…]

You just create a backlash that lets people see the Zionazis for what they really are – actually, never mind, keep trying to suppress free speech so at least Canadians can see you scumbags for what you are.

(…) protests outside of the communist co-op that Richard Warman calls home.

25. This Posting in question contained serious allegations against the Plaintiff, clearly stating, in its plain and ordinary meaning or by virtue of surrounding circumstances which give the words a defamatory meaning inferentially or by innuendo that:

a) The Plaintiff is a Zionist and Nazi, a “Zionazi”;

b) The Plaintiff is “trying to suppress free speech”;

c) The Plaintiff is a “scumbag”;

d) The Plaintiff lives in a “communist co-op”; and

e) The Plaintiff’s personal and professional reputation is discredited.

Second Posting

26. The Plaintiff complains of the following words posted at least three (3) times by the Defendant :

“Richard Warman Address- To Get Protests- He Wants Lots of Visitors”

Warman, Canadians don’t need government babysitters to tell us what to think or what websites we should read. Stop your hate crimes against the Canadian people, we don’t need Zionazis thought enforcement on the internet when you bastards control most of the media. You just create a backlash that lets people see the Zionazis for what they really are – actually, never mind, keep trying to suppress free speech so at least Canadians can see you scumbags for what you are.

[…]

We got an email today from a Canadian comrade saying he is planning ARA-style protests outside of the communist co-op that Richard Warman calls home.

[…]

27. This Posting in question contained serious allegations against the Plaintiff, clearly stating, in its plain and ordinary meaning or by virtue of surrounding circumstances which give the words a defamatory meaning inferentially or by innuendo that:

a) The Plaintiff performed “hate crimes against the Canadian people”;

b) The Plaintiff is a Zionist and Nazi, a “Zionazi”;

c) The Plaintiff is “trying to suppress free speech”;

d) The Plaintiff is a “scumbag”;

e) The Plaintiff lives in a “communist co-op”; and

f) The Plaintiff’s personal and professional reputation is discredited.

Third Posting

28. The Plaintiff complains of the following words posted at least eighteen (18) times by the Defendant :

“Richard Warman- He Wants Lots of Visitors at his Address- To Get Protests”

[…]

We got an email today from a Canadian comrade saying he is planning ARA-style protests outside of the communist co-op that Richard Warman calls home.

[…]

29. This Posting in question contained serious allegations against the Plaintiff, clearly stating, in its plain and ordinary meaning or by virtue of surrounding circumstances which give the words a defamatory meaning inferentially or by innuendo that:

a) The Plaintiff performed “hate crimes against the Canadian people”;

b) The Plaintiff is a Zionist and Nazi, a “Zionazi”;

c) The Plaintiff is “trying to suppress free speech”;

d) The Plaintiff is a “scumbag”;

e) The Plaintiff lives in a “communist co-op”; and

f) The Plaintiff’s personal and professional reputation is discredited.

Fourth Posting

30. The Plaintiff complains of the following words posted at least fourteen (14) times by the Defendant :

“Richard Warman Wants Lots of Visitors, Callers- Repost”

[…]

(…) protests outside of the communist co-op that Richard Warman calls home.

[…]

31. This Posting in question contained serious allegations against the Plaintiff, clearly stating, in its plain and ordinary meaning or by virtue of surrounding circumstances which give the words a defamatory meaning inferentially or by innuendo that:

a) The Plaintiff is a Zionist and Nazi, a “Zionazi”

b) The Plaintiff is trying “to suppress free speech”;

c) The Plaintiff is a “scumbag” ;

d) The Plaintiff lives in a “communist co-op”; and

e) The Plaintiff’s personal and professional reputation is discredited..

Fifth Posting

32. The Plaintiff complains of the following words posted at least six (6) times by the Defendant:

“Canada Awake! The Time To Cast Off Your Chains Is Now”

[…]

A gay gook named Fo Niemi recruited Jew hatemonger Richard Warman for that purpose. These are not average Canadians -- but they are officials in your government. And they are not out to preserve your human rights, but to strip you of your humanity. There is no crime against white people that the Canadian government will not protect.

[…]

In fact, the Canadian government is organizing crime. This same Jew attorney, Richard Warman, hired a bus and organized the mob that attacked Paul Fromm at his home. He has been organizing and financing vigilante mobs who attacks critics of Jewish power for years. He is a gangster and an organized crime figure -- but he is one acting under the protection of the Jews.

[…]

33. This Posting in question contained serious allegations against the Plaintiff, clearly stating, in its plain and ordinary meaning or by virtue of surrounding circumstances which give the words a defamatory meaning inferentially or by innuendo that:

a) The Plaintiff is a “hatemonger”;

b) The Plaintiff is “not out to preserve human rights”;

c) The Plaintiff is a “gangster and an organized crime figure”;

d) The Plaintiff organized and financed “mobs”;

e) The Plaintiff abused his position as a public servant pursuant to a-d above;

f) The Plaintiff’s integrity is attacked; and

g) The Plaintiff’s personal and professional reputation is discredited.

Sixth Posting

34. The Plaintiff complains of the following words posted at least one (1) time by the Defendant :

“Faggoty-looking lawyer crusades AGAINST free speech”

[…]

To find out more about this communist, scumbag menace to free expression, just do a Google search on his name. And then pay him a visit:

[…]

35. This Posting in question contained serious allegations against the Plaintiff, clearly stating, in its plain and ordinary meaning or by virtue of surrounding circumstances which give the words a defamatory meaning inferentially or by innuendo that:

a) The Plaintiff is a “faggoty-looking lawyer”;

b) The Plaintiff is “against free speech” and “a menace to free expression”;

c) The Plaintiff is a “communist” and a “scumbag”; and

d) The Plaintiff’s integrity is attacked.

Seventh Posting

36. The Plaintiff complains of the following words posted at least six (6) times by the Defendant :

“Richard Warman’s Song – Visit Him - Repost”

[…]

Now perhaps if enough people do to Warman what he does to innocent civilians, then perhaps he will mend the error of his ways?

[…]

He’s a dead Jew walkin’

[…]

It's just a dead Jew talkin'.

He had a job, he had a boyfriend,

[…]

Like a dead Jew walkin’

[…]

To find out more about this communist, scumbag menace to free expression, just do a Google search on his name. And then pay him a visit:

[…]

Employer: Bernie "Superkike" Farber, Canadian Jewish Congress. Mugshots of the white nigger can be found here:

[…]

37. This Posting in question contained serious allegations against the Plaintiff, clearly stating, in its plain and ordinary meaning or by virtue of surrounding circumstances which give the words a defamatory meaning inferentially or by innuendo that:

a) The Plaintiff attacks “innocent civilians”;

b) The Plaintiff is a “communist” and a “scumbag”;

c) The Plaintiff is a “menace to free expression”;

d) The Plaintiff is a “white nigger”; and

e) The Plaintiff is exposed to hatred, contempt and ridicule.

Eighth Posting

38. The Plaintiff complains of the following words posted at least eight (8) times by the Defendant:

“Protests Planned for Richard Warman Address- He Wants Visitors/Callers- Repost ”

[…]

(…) protests outside of the communist co-op that Richard Warman calls home.

[…]

39. This Posting in question contained serious allegations against the Plaintiff, clearly stating, in its plain and ordinary meaning or by virtue of surrounding circumstances which give the words a defamatory meaning inferentially or by innuendo that:

a) The Plaintiff is a Zionist and Nazi, a “Zionazi”;

b) The Plaintiff is “trying to suppress free speech”;

c) The Plaintiff is a “scumbag”;

d) The Plaintiff lives in a “communist co-op”; and

e) The Plaintiff’s personal and professional reputation is discredited.

Ninth Posting

40. The Plaintiff complains of the following words posted at least two hundred (200) times by the Defendant :

“Why are ZYDs/Jews So Hated Worldwide?”

When creatures such as Richard Warman use the Canadian Human Right Commission to persecute individuals for having a different political opinion, or even for being politically incorrect, the people who THINK start wondering about the truth of much that Warman and his ilk are promulgating!

[…]

41. This Posting in question contained serious allegations against the Plaintiff, clearly stating, in its plain and ordinary meaning or by virtue of surrounding circumstances which give the words a defamatory meaning inferentially or by innuendo that:

a) The Plaintiff is a “creature”;

b) The Plaintiff abuses the Canadian Human Rights Commission to persecute those who have different political opinions or are politically incorrect;

c) The Plaintiff is a liar; and

d) The Plaintiff’s integrity and reputation are attacked and discredited.

Tenth Posting

42. The Plaintiff complains of the following words posted at least eight (8) times by the Defendant :

“RICHARD WARMAN; HIS YID SCUMBAG AGENDA AND WHERE HE LIVES”

RICHARD WARMAN; HIS YID SCUMBAG AGENDA AND WHERE HE LIVES – Repost

[…]

He’s a dead Jew walkin’

[…]

It's just a dead Jew talkin'.

He had a job, he had a boyfriend,

[…]

Like a dead Jew walkin’

[…]

To find out more about this communist, scumbag menace to free expression, just do a Google search on his name. And then pay him a visit:

[…]

Employer: Bernie "Superkike" Farber, Canadian Jewish Congress. Mugshots of the white nigger can be found here:

[…]

43. This Posting in question contained serious allegations against the Plaintiff, clearly stating, in its plain and ordinary meaning or by virtue of surrounding circumstances which give the words a defamatory meaning inferentially or by innuendo that:

a) The Plaintiff has a “scumbag agenda”;

b) The Plaintiff is a “communist” and a “scumbag”;

c) The Plaintiff is a “menace to free expression”;

d) The Plaintiff is a “white nigger”; and

e) The Plaintiff is exposed to hatred, contempt and ridicule.

Eleventh Posting

44. The Plaintiff complains of the following words posted at least one (1) time by the Defendant :

“NIZKOR & THHP STREET ADDRESSES FOR OCTOBER 2007”

[…]

Mamzer Warman likes litigating people whom the jews have targeted in Canada. He derives pleasure in hurting people financially for mere words are not libelous but not friendly to the kike agenda Warman serves. He’s a disgusting maggot.

[…]

45. This Posting in question contained serious allegations against the Plaintiff, clearly stating, in its plain and ordinary meaning or by virtue of surrounding circumstances which give the words a defamatory meaning inferentially or by innuendo that:

a) The Plaintiff “likes litigating people who the jews have targeted”;

b) The Plaintiff “derives pleasure in hurting people financially”;

c) The Plaintiff serves a “kike agenda”;

d) The Plaintiff is a “disgusting maggot”;

e) The Plaintiff is exposed to hatred, contempt and ridicule; and

f) The Plaintiff’s integrity and reputation are attacked and discredited.

Twelfth Posting

46. The Plaintiff complains of the following words posted at least six (6) times by the Defendant :

““Tricky Dick” Warman and His War On Dissent”

No Wonder people consider this creature almost sub-human.

[…]

This man holds between his ears the prototypical Jewish extremist mind with its paranoia, its almost inbred disgust for the Gentile and his culture, its power-mad delusion of god-like control over the masses, its "inalienable right" not to be offended, its reflexive and intractable totalitarianism (the Bolshevik brain) and the borderline personality disorder of so many Jewish power-players in the zealous Zionist crime syndicate.

[…]

How does Dick Warman, either crypto-Jew or Shoddy Goy, play the pimp for Big Jewry so effectively? Simple. He is part of the Government/Jewry Complex.

[…]

To find out more about this communist, scumbag menace to free expression, just do a Google search on his name. And then pay him a visit:

[…]

47. This Posting in question contained serious allegations against the Plaintiff, clearly stating, in its plain and ordinary meaning or by virtue of surrounding circumstances which give the words a defamatory meaning inferentially or by innuendo that:

a) The Plaintiff is an almost sub-human creature;

b) The Plaintiff is a paranoid extremist;

c) The Plaintiff has an almost inbred disgust for non-Jews and non-Jewish culture;

d) The Plaintiff has a “power-mad delusion of god-like control over the masses”;

e) The Plaintiff is associated with political ideologies such as totalitarism and communism;

f) The Plaintiff has a “borderline personality”;

g) The Plaintiff is part of a Zionist crime syndicate;

h) The Plaintiff “play[s] the pimp”;

i) The Plaintiff is part of a Jewish-government conspiracy;

j) The Plaintiff is a “scumbag”;

k) The Plaintiff is a “menace to free expression”; and

l) The Plaintiff’s integrity and reputation are attacked and discredited.

Thirteenth Posting

48. The Plaintiff complains of the following words posted at least three (3) times by the Defendant :

“Female Activist Faces ‘Thought Crime’ Charges”

Female Activist Faces ‘Thought Crime’ Charges – Another Victim of Warman”

[…]

49. This Posting in question contained serious allegations against the Plaintiff, clearly stating, in its plain and ordinary meaning or by virtue of surrounding circumstances which give the words a defamatory meaning inferentially or by innuendo that:

a) The Plaintiff abuses Canadian human rights law to wrongfully attack others who are, in fact, his “victims”;

b) The Plaintiff’s integrity, honesty and reputation are attacked and discredited.

Fourteenth Posting

50. The Plaintiff complains of the following words posted at least five (5) times by the Defendant :

“OTTAWAN RICHARD WARMAN AND NANAIMOIAN KENNETH "NIZKOR" MCVAY ARE LOVERS & FAGS”

RICHARD WARMAN AND HIS COMMUNIST AGENDA, WHERE HE LIVES AND HIS CRIMINAL CHILD MOLESTING CONVICTION

To find out more about this communist, scumbag menace to free expression, just do a Google search on
his name. And then pay him a visit:
[…]

http://www.hiddenmysteries.org/news/america/canada/102502a.html
Richard Warman, Ottawa Lawyer Charged With Three Indictable Offenses
Against The Criminal Code of Canada
http://www.cyberclass.net/warman.htm
http://www.cyberclass.net/pressreleasenov182002.htm

[…]

RICHARD WARMAN (WAS) JAILED FOR SEXUALLY ASSAULTING 13 YEAR OLD
[…]

Richard Warman Jailed for sexually assaulting 13 year old
B08518 / Thu, 1 Sep 2005 15:28:13 / Human Rights
Richard Warman jailed for underage affair

Richard Warman, who booked a hotel room to have sex with a 13-year-old schoolgirl
was jailed for 18 months.

The love frolic occured mainly at the Comfort Inn, the relationship lasted ten
months between the couple.

Jailing Richard Warman Judge Richard Rundell told him: “You are a danger to young
girls. You corrupted this vulnerable victim and took advantage of her for your own
sexual gratification.”

The hotel booking showed a degree of planning, he added, and unprotected sex on
most occasions illustrated “highly irresponsible” behaviour.

“She said no at first but he (Richard Warman) worked his charm on her and she found
him good looking,” he said.

Mr Shakoor said Richard Warman lacked intelligence.

---

I AM GOD AND I HAVE A RUGER P-90 AND IT'S BULLETS HAVE YOUR NAME ON THEM FAGBOY WARMAN.

51. This Posting in question contained serious allegations against the Plaintiff, clearly stating, in its plain and ordinary meaning or by virtue of surrounding circumstances which give the words a defamatory meaning inferentially or by innuendo that:

a) The Plaintiff is a “fag”;

b) The Plaintiff has a “communist agenda”;

c) The Plaintiff is a “communist” and a “scumbag”;

d) The Plaintiff is a “menace to free expression”;

e) The Plaintiff was charged with three indictable offenses under the Criminal Code of Canada;

f) The Plaintiff was “convicted of child molesting”;

g) The Plaintiff was “jailed for sexually assaulting a 13 year old”;

h) The Plaintiff had an underage affair for ten months;

i) The Plaintiff is a “danger to young girls”;

j) The Plaintiff corrupts young victims;

k) The Plaintiff takes “advantage of your girls for his own sexual gratification”;

l) The Plaintiff illustrates “highly irresponsible” behaviour;

m) The Plaintiff lacks intelligence;

n) The Plaintiff is a “Fagboy”; and

o) The Plaintiff’s integrity, honesty and reputation are attacked and discredited.

Defamation

52. The Plaintiff complains of the words set out in the paragraphs 24 through 51 and that contain serious allegations against the Plaintiff, in their plain and ordinary meaning or by virtue of the surrounding circumstances which give the words a defamatory meaning or by innuendo as follows:

a) They attack the Plaintiff’s professionalism, honesty and integrity;

b) They attack the Plaintiff’s credibility as a lawyer;

c) They discredit the Plaintiff’s personal and professional reputation;

d) They portray the Plaintiff as a dishonest man and a liar;

e) They attack the Plaintiff’s personality and credibility by referring to him as a “scumbag”, “pimp”, “disgusting maggot”, etc.;

f) They falsely associate the Plaintiff with political ideologies such as communism and totalitarianism;

g) They falsely characterize the Plaintiff’s intentions as a human rights advocate;

h) They characterize the Plaintiff as a persecutor of free thought;

i) They falsely allege that the Plaintiff is part of organized crime by referring to him as a gangster or an organized crime figure;

j) They falsely state that the Plaintiff organized and financed “mobs”;

k) They state that the Plaintiff is a cruel human being;

l) They falsely allege that the Plaintiff was convicted of child molestation;

m) They tend to lower the Plaintiff in the estimation of right thinking members of society; and,

n) They expose the Plaintiff to hatred, contempt and ridicule.

Assault

53. The Plaintiff pleads that the Defendant had the intention of harming the Plaintiff by posting death threats on the Internet. The Plaintiff pleads that he believed himself to be in imminent danger because the Defendant also posted, together with the threats, the Plaintiff’s home address, together with an aerial photograph and an aerial map on how to get to his home.

54. More particularly, on or about the fall of 2006 until but not limited to the winter of 2008, the Defendant published a total of at least 72 postings containing threats to harm or kill the Plaintiff and/or containing invitations and encouragements to harm or kill the Plaintiff. These threats were made purposefully by the Defendant in the First Posting, the Second Posting, the Third Posting, the Fourth posting, the Sixth Posting, the Seventh Posting, the Eighth Posting, the Tenth Posting, the Twelfth Posting and the Fourteenth Posting.

55. On or about the fall of 2006 until but not limited to the winter of 2008, the Defendant posted at least 70 times the Plaintiff’s home address in the same Posting containing threats to harm or kill the Plaintiff and/or containing invitations and encouragements to harm or kill the Plaintiff. The Plaintiff’s home address was published purposely by the Defendant in the Second Posting, the Third Posting, the Fourth Posting, the Sixth Posting, the Seventh Posting, the Eighth Posting, the Tenth Posting, the Eleventh Posting, the Twelfth Posting and the Fourteenth Posting.

56. On or around July 2007 until but not limited to January 2008, the Defendant posted at least 21 times an aerial photograph of the Plaintiff’s home and an aerial map on how to get to the Plaintiff’s home in the same Postings in which he threatened to harm or kill the Plaintiff and/or containing invitations and encouragements to harm or kill the Plaintiff, and that he published the Plaintiff’s home address. The aerial photograph and aerial map of how to get to the Plaintiff’s home was published purposely by the Defendant in the Sixth Posting, the Tenth Posting, the Eleventh Posting, the Twelve Posting and the Fourteenth Posting.

57. As a result of these threats to harm or kill the Plaintiff and/or containing invitations and encouragements to harm or kill the Plaintiff, and of the fact that the Defendant posted at least 70 times the Plaintiff’s address, and of the fact that the Defendant posted at least 21 times an aerial photograph and an aerial map on how to get to the Plaintiff’s home, upon becoming aware of these postings on or about August of 2006, the Plaintiff believed he was in imminent danger.

58. The Plaintiff suffered emotional distress and suffered damages because of the threats posted on the internet.

59. Towards the end of October 2007, the Plaintiff moved to a different address.

Invasion of privacy

60. The Plaintiff pleads that the Defendant has invaded his privacy by publishing, without his consent, his home address at least 70 times, an aerial photograph of his home and an aerial map of how to get to his home at least 21 times on the Internet.

61. Since 2004, the Plaintiff has, to the best of his ability, attempted to keep his home address private. To this end, since 2004 he has had his address removed from his telephone listing. Further, since 2007 he has maintained an unlisted telephone number.

62. The Plaintiff’s home address, as well as aerial photographs of his home and aerial maps of how to get to his home are information that are private and should not be advertised together on the World Wide Web unless consent is given.

63. The sole reason the Defendant published this information is to harass the Plaintiff and to make it possible to harm or kill the Plaintiff.

64. The Defendant specifically invited the readers to “pay him a visit”. By virtue of the surrounding circumstances or by innuendo, these terms used by the defendant are inherently violent in nature. The Plaintiff believed he was in danger.

65. As a result, the Plaintiff suffered emotional distress and suffered damages.

66. Towards the end of October 2007, the Plaintiff moved to a different address.

Malice and Damages

67. The Plaintiff pleads that the Defendant acted maliciously in that:

a) After a notice of libel was sent to the Defendant, he continued to post defamatory materials on the Google website groups;

b) The Defendant has not, as of this date, removed all the Defamatory Postings;

c) The Defendant has not, as of this date, retracted the Defamatory Postings and/or apologized to the Plaintiff for having defamed him.

68. The Plaintiff pleads that as a result of the Postings, his personal and professional reputation have suffered, the Plaintiff has been brought into ridicule, scandal and contempt both personally and by way of his profession as a lawyer, the Plaintiff’s livelihood and safety have been threatened, the Plaintiff’s privacy has been invaded and the Plaintiff has suffered damages.

69. The Plaintiff states that the conduct of the Defendant towards him by posting defamatory statements, threats to harm or kill him, seeking to facilitate the carrying out of those threats by publishing the Plaintiff’s home address and an aerial photograph and map of his home, and invading the Plaintiff’s privacy was malicious, reckless and reprehensible and in complete and total disregard for his personal and professional reputation and that such conduct warrants the imposition of aggravated and punitive damages.

70. The Plaintiff pleads and relies upon the provisions of the Libel and Slander Act, R.S.O. 1990, c. L.12, as amended.

71. The Plaintiff pleads and relies on the Courts of Justice Act, R.S.O. 1992, c C-43, as amended, and more specifically on Rule 1.05 of the Ontario Rules of Civil Procedure R.R.O. 1990, Reg. 194 as amended, to obtain an order from this Honorable Court forcing the Defendant to have the Postings removed from the websites and to post a full retraction with as much clarity and prominence as the defamatory words spoken and/or written and/or published.

72. The Plaintiff agrees to reduce his claim to $50,000.00 to bring this action within the Simplified Procedure found under rule 76 of the Rules of Civil Procedure R.R.O. 1990, Reg. 194 as amended.

73. The Plaintiff brings this proceeding against the Defendant in Ontario in accordance with Rule 17.02 (h) since the subject matter of this action concerns: damage sustained in Ontario arising from a tort.

74. The Plaintiff proposes that this action be tried at Ottawa, Ontario.

Date: January 14, 2008.

HEENAN BLAIKIE LLP

Lawyers|Patent and Trade-mark Agents

300–55, Metcalfe Street

Ottawa (ON) K1P 6L5

Judith Parisien/ Mélanie Chenier

LSUC : 49095H/53370T

Tel: 613-236-1668

Fax: 613-236-9632

Lawyers for the Plaintiff

Richard Warman v. William Grosvenor: Statement of Claim

ONTARIO

SUPERIOR COURT OF JUSTICE