Witness Statement of Warren Kinsella I, WARREN KINSELLA of Suite 3800, 200 Bay Street, South Tower, Royal Bank Plaza, Toronto, Ontario, Canada, M5J 2J7, WILL SAY as follows: 1. I am a barrister and solicitor called to the Law Society of Upper Canada in 1989. I am also an author, having published two books on the subject of organised racism and anti-Semitism (entitled Unholy Alliances, Lester Publishing, 1992 and Web of Hate, Harper Collins. 1996). I have acted as a witness in Canadian court proceedings related to individuals involved in organised racism and anti-Semitism, for example: the prosecution of George Burdi for assault causing bodily harm, Ottawa, April 1995 and the Security Intelligence Review Committee investigation of Ernst Zundel, in 1996 and 1998. 2. For approximately twelve years, as a newspaper journalist, a sessional professor in law, a lawyer and a commentator on public affairs, I have closely followed the activities of Canada's racist right wing. In this regard, I have interviewed the majority of the leaders active in this racist and anti-Semitic movement. I have also interviewed many of their followers, all over Canada and the United States. 3. For approximately a decade, I have been aware that Canada's organised racism movements have developed and nurtured significant links with the British author David Irving. Societies which fall within this network include: the Aryan Nations, the Ku Klux Klan, the Canadian League of Rights, the Aryan Resistance Movement, the Nationalist Party, the Heritage Front, the Northern Hammerskins, the Canadians for Foreign Aid Reform, the Resistance Records, the Western Guard, the Order and the Canadian Free Speech League. These societies are active in disseminating racist, neo-Nazi, hate propaganda in Canada and the United States. The individuals who lead these organisations have been very eager to promote Mr. Irving's writings and statements, and to publicly associate themselves with him and his work. For the most part, the enthusiasm Canadian neo-Nazis and white supremacists feel towards Mr. Irving is attributable to the veneer of scholarly legitimacy they feel his writings and statements give to their hateful ideology. In particular, his public expressions of doubt about the Holocaust have been embraced by these individuals as they seek to contrive for themselves a better public image. 4. Examples of Mr. Irving's associations with Canadian neo-Nazis and white supremacists are as follows, and are taken from interviews with leaders and members of these groups, as well as from publicly available documents: a) In March 1989, Ian Verner Macdonald, a resident of Ottawa, Ontario, who has many year's association with/membership of such groups as the Canadian Knights of the Ku Klux Klan, the Aryan Resistance Movement, the Nationalist Party, the Canadian League of Rights and the pro-Nazi movement led by Toronto publisher Ernst Zundel, confirmed to me that he had organised a speaking engagement for Mr. Irving at the Chateau Laurier Hotel, where neo--Nazi skinhead leader Mark Bauer was hired to provide security and pass out virulently anti-Semitic and white supremacist propaganda. Mark Bauer acted in this capacity on at least one occasion in the presence of Mr. Irving and myself. b) In November 1992, Ernie Britskie a resident of Vancouver, who has many year's association with groups such as the Aryan Nations, Ku Klux Klan, the Aryan Resistance Movement and the anti-Semitic organizations led by Lyndon LaRouche, confirmed to me that he had given Mr Irving support and administrative backup on Mr Irving's visits to Vancouver and the surrounding area, Mr LaRouche is primarily known for his belief in the existence of an international Zionist conspiracy to undermine Western civilisation, c) Throughout 1992, Wolfgang Droege and the neo-Nazi organisation he led at that time, the Heritage Front, actively promoted Mr. Irving's writings and statements on multiple occasions. The Heritage Front is a neo-Nazi organisation that supports separation of the races, denies the Holocaust and opposes efforts to counter criminal expressions of hatred. In December 1992 the Heritage Front placed Mr. Irving on the cover of its magazine, Up Front and encouraged its readers to contribute to a "legal defence fund" for Mr. Irving, which was then being run out of the Heritage Front's Toronto post office box. Mr. Droege has had many years' association with/membership of other racist, anti-Semitic, hate organisations in both Canada and the United States, including the Ku Klux Klan. d) In his dealings with the Canadian government in 1992, Mr. Irving's lawyer was Douglas H. Christie, who in the past has represented notorious neo-Nazi and white supremacist leaders and organisations such as Jim Keegstra, Ernst Zundel, John Ross Taylor, the Grand Wizard of the Manitoba Knights of the Ku Klux Klan, the Canadian Free Speech League, Malcolm Ross, the Canadian Liberty Net, Canadian Aryan Nations leader Terry Long. In February 1993, the discipline committee of the Law Society of Upper Canada stated in a report that Mr. Christie had "made common cause" with anti-Semitic "lunatics" (please see Appendix, pages 1 to 37). e) In June 1993, George Burdi, a resident of Windsor, Ontario, and the former leader of the Church of the Creator in Canada, an individual with many year's association with/membership of the Heritage Front, the Northern Hammerskins, Canadians for Foreign Aid Reform and, most recently, Resistance Records, expressed support for Mr Irving and confirmed to me that he had met Mr Irving, following the intervention of Ernst Zundel. f) When I interviewed Mr Irving, I brought up Mr MacdonaId's involvement with the Ku Klux Klan. Mr Irving did not regard this as an impediment to their relationship in any way. On the contrary, Mr Irving explicitly welcomed Mr Macdonald's support, and that of other associates mentioned above. 5. Mr Irving has formed many significant links with racist, anti-Semitic and homophobic extremists in Canada. It was as a result of these links, and of Mr Irving's activities in support of these extremist elements, that Mr Irving wars deported from Canada in 1992. The contents of this statement are accurate and true to the best of my knowledge and belief. Dated January 21, 1999 Warren Kinsella