THE WITNESS STATEMENT  which was posted here on January 25, 1999 is withheld pursuant to an Order made by Mr Justice Moses on the application of Professor Deborah Lipstadt in the Queen's Bench on January 26, 1999; the full text will be posted immediately it comes into the public domain when the trial begins. Salient points of the statement are extracted below:

Witness Statement of Warren Kinsella (and our questions)

ABSTRACT: WARREN KINSELLA of Toronto, Ontario, is a barrister and author of two books on organised racism and anti-Semitism (entitled Unholy Alliances, Lester Publishing, 1992 and Web of Hate, HarperCollins, 1996[*]). He has often appeared as a witness in Canadian court proceedings against alleged racists and anti-Semites like George Burdi, and in the on-going the Security Intelligence Review Committee investigation of Ernst Zundel.

UESTION: Provide evidence of Professor Kinsella's impartiality or otherwise in these proceedings; examples of false testimony, if any, under oath. How much if anything was he paid to testify?

ABSTRACT: For about twelve years Kinsella has interviewed racists and anti-Semitic leaders all over Canada and the United States. He has seen them nurture 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."

UESTION: What evidence is there for Mr Irving's active association with any of these bodies (other than possibly and indirectly the League of Rights, C-FAR, and the Free Speech league)?

ABSTRACT: Mr. Irving has a veneer of scholarly legitimacy and has made public expressions of doubt about the Holocaust which have been embraced by these individuals. Professor Kinsella offers the following "proof" of Mr. Irving's associations with Canadian neo-Nazis and white supremacists: In March 1989, Ian Verner Macdonald, said to be an associate of the Ku Klux Klan, and Ernst Zundel, allegedly organised a speaking engagement for Mr. Irving at the Chateau Laurier Hotel; at this function "neo--Nazi skinhead leader" Mark Bauer was hired to provide security and pass out anti-Semitic and white supremacist propaganda.

UESTION: Comments on these lurid allegations, which are typical of Kinsella's modus operandi, please! Does anybody know of Bauer?

ABSTRACT: In November 1992, Ernie Britskie, long-time associate the Aryan Nations, Ku Klux Klan, the Aryan Resistance Movement and Lyndon LaRouche, allegedly told Kinsella he had given Mr Irving support in Vancouver.

UESTION: Mr Irving has never met Britskie. Who can provide information about him, please?

ABSTRACT: Wolfgang Droege often promoted Mr. Irving's writings and statements. His Heritage Front organisation supports separation of the races and denies the Holocaust . In December 1992 the Heritage Front magazine, Up Front encouraged its readers to contribute to a "legal defence fund" for Mr. Irving.

UESTION: Mr Irving rejected any contacts and dealings with Wolfgang Droege, being fully aware of his criminal past. What has happened to the funds raised by Droege allegedly on Mr Irving's behalf?

ABSTRACT: June 1993, George Burdi, of Ontario, with various right-wing associations listed by Professor Kinsella, confirmed to him that he suported and had met Mr Irving.

UESTION: A negative is hard to prove -- Mr Irving has never met Mr Burdi -- but who can provide evidence of similar lying allegations by Kinsella?