Court File No. 02-CV-237691       SR

Ontario
Superior Court of Justice

Between

RICHARD WARMAN

Plaintiff

DAVID ICKE, BRIDGE OF LOVE PUBLICATIONS, PREFERRED NETWORK, BANYEN BOOKS, ETERNAL MOMENT BOOKSTORE, BIOSFAIRE, TOM KENNEDY, SEEKERS BOOKS, KNOWLEDGE BOOKSTORE, and BOULE DE NEIGE

Defendants

STATEMENT OF CLAIM

TO THE DEFENDANTS

A LEGAL PROCEEDING HAS BEEN COMMENCED AGAINST YOU by the Plaintiff. 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 Plaintiff's lawyer or, where the Plaintiff does not have a lawyer, serve it on the Plaintiff, and file it, with proof of service, in this court office, WITHIN TWENTY 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 forty days. If you are served outside Canada and the United States of America, the period is sixty 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 ten more days within which to serve and file your statement of defense.

IF YOU FAIL TO DEFEND THIS PROCEEDING, JUDGEMENT 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.

IF YOU PAY THE PLAINTIFF'S CLAIM, and the $1,000.00 for costs, within the time for serving and filing your statement of defense, you may move to have this proceeding dismissed by the court. If you believe the amount claimed for costs is excessive, you may pay the Plaintiff's claim and $400.00 for costs and have the costs assessed by the court.

Date:    October 17, 2002                                               Issued by    S. Gatt       
                                                                                                     Local Registrar

Address of the court office: 393 University Avenue, Toronto, Ontario, Canada

To:
David Icke
Bridge of Love Publications (United Kingdom)
Preferred Network (Salmon Arm, BC)
Banyen Books (Vancouver, B.C.)
Eternal Moment Books (Toronto, Ont.)
Biosfaire (Montreal, Quebec)
Tom Kennedy (Ottawa)
Seekers Books (Toronto, Ont.)
Knowledge Bookstore (Brampton, Ont.)
Boule de Neige (Montreal, Que.)
Earth Bound Books (Collingwood, Ont.)

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

CLAIM

1. The Plaintiff claims:

(a) General damages in the amount of $500,000;

(b) Aggravated damages in the amount of $250,000;

(c) Punitive damages in the amount of $250,000;

(d) Pre-judgment interest and post-judgment interest pursuant to the Courts of Justice Act;

(e) The costs of this action on a solicitor and client basis;

(f) Applicable taxes; and

(g) Such further and other relief as this Honourable Court may deem just.

2. The Plaintiff Richard Warman is a lawyer. The Plaintiff is a member of the Green Party, has been active in an number of human rights causes and is employed as an investigator for the Canadian Human Rights Commission. He presently lives in Ottawa, Ontario.

3. The Defendant David Icke is an author who has published a number of works. He is the author of Children of the Matrix.

4. The Defendant Bridge of Love is a publisher based in the United Kingdom and operating in the United States. Bridge of Love is the publisher of Children of the Matrix distributed the work worldwide including but not limited to the United Kingdom, Ireland, the United States, Canada, France. Germany, Japan, Denmark, Australia, New Zealand and South Africa.

5. Preferred Network operates an online bookstore from its location in Belmead, Edmonton which has distributed and distributes Children of the Matrix.

6. Banyen Books is a bookstore located in Vancouver, British Columbia which has distributed and distributes Children of the Matrix.

7. Eternal Moment Bookstore is a bookstore located in Toronto, Ontario which has distributed and distributes Children of the Matrix.

8. Biosfaire is a bookstore located in Montreal, Quebec which has distributed and distributes Children of the Matrix.

9. Tom Kennedy operates an Internet bookstore from his location in Ottawa, Ontario. he has distributed and distributes Children of the Matrix.

10. Seekers Books is a bookstore located in Toronto, Ontario which has distributed and distributes Children of the Matrix.

11. Earth Bound Books is a bookstore located in Collingwood, Ontario which has distributed and distributes Children of the Matrix.

12. Knowledge Bookstore is a bookstore located in Brampton, Ontario which has distributed and distributes Children of the Matrix.

13. Boule de Neige is a bookstore located in Montreal, Quebec which has distributed and distributes Children of the Matrix.

PUBLICATION OF MATERIAL DEFAMATORY OF RICHARD WARMAN

14. The Plaintiff pleads that in June 2001 the Defendants falsely and maliciously published in Ontario and throughout Canada, the United Kingdom, Ireland, the United States, France, Germany, Japan, Denmark, Australia, and South Africa, a book called Children of the Matrix.

15. The Plaintiff pleads that Children of the Matrix refers to the Plaintiff Richard Warman.

16. The Plaintiff pleads that Children of the Matrix contains defamatory words published of and concerning Richard Warman.

17. The Plaintiff pleads that Children of the Matrix was malicious, unfair, sensationalized and defamatory of the Plaintiff personally and in way of his calling as a lawyer.

THE DEFENDANTS WERE MOTIVATED BY ACTUAL MALICE IN DEFAMING RICHARD WARMAN

18. The Plaintiff pleads that the Defendants acted maliciously in that:

(a) Each of the Defendants was warned that the Plaintiff considered Children of the Matrix to be defamatory. These Defendants nevertheless continued to distribute the work and mocked the Plaintiff's concerns about Children of the Matrix.

(b) Children of the Matrix deliberately attempted to create fear in the minds of the readers and corresponding indignation in the minds of the readers against Richard Warman by accusing him of being a member of the "Illuminati," a disinformer, liar, hypocrite, far right-winger, Nazi, fascist and censor.

(c) David Icke deliberately omitted information known to him to create a false and unfair distortion about Richard Warman's actual opinions regarding David Icke and the source of those opinions.

(d) David Icke deliberately omitted information known to him to create a false and unfair distortion about Richard Warman's actual opinions regarding child abuse and falsely accused him of working vociferously to cover-up child abuse. He emphasized this information by setting in bold type this allegation in Children of the Matrix.

(e) The Plaintiff pleads and relies on the entirety of Children of the Matrix as the context in which the defamatory words appear and, in particular, on Chapter 19 entitled The Gatekeepers.

THE DEFENDANTS DEFAMED RICHARD WARMAN BY CALLING HIM A LIAR, HYPROCRITE, CONTROLLED BY SOMEONE ELSE AND DELIBERATELY DISHONEST IN THE VIEWS HE EXPRESSED.

19. The Plaintiff complains of the following words, which were intended to mean and were understood to mean that Richard Warman was a liar, hyprocrite, controlled by someone else and/or deliberately dishinest in expressing his views:

Page 410

"Enter stage right, far right from where I am sitting, one Richard Warman. Never heard of him? You are not alone. No one seems to have heard of him until he decided to dedicate his life to preventing me speaking and anyone having the opportunity to hear me anywhere in the world. No, you didn't misread that. This man, by the way, works for the Canadian Green Party, which condemns the censorship of freedom of speech! Just like David Taylor of the British Green Party who also sought to have my events banned. The stench of hypocrisy fills the air."

"Warman has worked closely in his campaign of vilification and censorship against me with the Canadian Jewish Congress or CJC. This was formed and funded by the very same Bronfmans. Just a coincidence, nothing to worry about."

Page 411

'This is a classic of its kind and typical of the thrust of the disinformation that has caused venues around the world to cancel my meetings. Note that he says that one venue cancelled after a "minimum inquiry" of its own. Normally it is no inquiry at all and my freedom of expression and the freedom of audiences to listen is denied purely on this guy's say-so. he says the decision to cancel by the Order of Grey Nuns was impressive. But, of course, like all disinformers, he fails to mention that they did not cancel because they said I was anti-Semitic. They did so because I was questioning the literal existence of 'Jesus.'"

"Where am I a hatemonger? Where do I condemn the Jewish people? I don't, and Warman knows that I don't, but then that's not the point is it? And what are Warman and Farber (the Bronfmans) seeking to do in this campaign of personal abuse? To get as many people as possible to hate me. So who are the real hatemongers here?" (italics in original)

"The bile circulated by Warman and Farber (the Bronfmans) led me to being stopped by both customs and immigration at Ottawa Airport and kept there until two o'clock in the morning. Every item in my luggage was searched (glad I brought those dirty socks) and every piece of paper was read in pursuit of "hate material." They found nothing and in the end the officer-pawn involved could see it was all a set-up."

"They treated me like a criminal, as if all the propaganda by Warman and Farber (the Bronfmans) was true. In others words they were mind controlled by a preconceived idea, planted by someone else."

Page 412

"As a result of the lies directed at me, the head of the Canadian Police Hate Crimes Unit was in the audience. We shook hands afterwards and he had no problem with my talk whatsoever. Warman and Farber (the Bronfmans) never mention that."

"As a result of Warman's efforts to dub me a fascist, a schoolteacher on Vancouver Island who had hosted a meeting for me there, lost his job. Now that's freedom isn't it? The campaign continued when Warman flew across Canada (who paid?) to gather support for a campaign to have my event banned in the spring of 2000."

"And while all this was unfolding, the children went on being abused, tortured and sacrificed, and when the wars and other horrors went on being manipulated, as Mr. Warman and Mr. Farber worked so ferociously to stop it being exposed. They have made their priorities very clear." (Emphasis in original text)

"Warman sat through my talk and in those more than six hours, he saw at first hand that I do not speak about a Jewish plot at all and never even mention the word 'Jewish' because there is no need, except to emphasize what a travesty of truth Warman is seeking to purvey. This can be seen on a video called From Prison To Paradise and you can see for yourself that what I am saying here is true. If Warman had simply been stupid and mis-guided, this is where it would have ended. But it didn't. That was the point when Richard Warman's  true motives became clear in my opinion. This guy has an agenda and, given what small fry he is here in Canada, it must, I believe, be someone else's agenda.

Page 413

"All he does is check on my website where I am speaking and waits until a few days before the event to ensure that there is not enough time to find another venue. He then either rings the venue or sends them a package claiming I am anti-Semitic and will be blaming Jews for a global conspiracy, something he knows from his own experience is not true."

Page 414

"Everyone concerned with these events is a gatekeeper for the Matrix. There are so few on this planet who are not. People like Richard Warman and Bernie Farber (the Bronfmans) know that they are, that's the difference. Either that or their brain cell count must be dangerously low of their capacity for self-delusion dangerously high."

"Richard Warman. gatekeeper to the Matrix, would be a legitimate dictionary definition for the word 'hypocrisy.'"

Page 415 - 416

"You are going to see an onslaught against Internet freedom, just as Richard Warman and his string-pullers targeted my own site. Censors never admit to being so."

THE DEFENDANTS DEFAMED RICHARD WARMAN BY ACCUSING HIM OF DELIBERATELY COVERING UP CHILD ABUSE

20. The Plaintiff complains of the following words, which were intended to mean and were understood to mean that Richard Warman was deliberately covering up child abuse:

Page 412

"And while all this was unfolding, the children went on being abused, tortured and sacrificed, and the wars and other horrors went on being manipulated, as Mr. Warman and Mr. Farber worked so ferociously to stop it being exposed. They have made their priorities very clear." (Emphasis in original text)

Page 413

"Perhaps most sickening of all, he includes the fact that I am exposing famous people as abusers and sacrificers of children as a reason why venues should not let me speak."

Page 420

'At least he had the guts to change his mind and he will not be the last and he will not be the last as the evidence becomes more and more obvious. When it does, the Crowleys, Taylors, Warmans and Farbers will have those abused children to answer to. I trust they will have a good excuse prepared for looking the other way and ridiculing the evidence of this abuse while doing no research to see if it is true. or, in the case of Warman and Farber, vociferously seeking to suppress exposure of the children's plight."

THE DEFENDANTS DEFAMED RICHARD WARMAN BY CALLING HIM A HOLDER OF FAR RIGHT WING VIEWS, A NAZI

21. The Plaintiff complains of the following words which were intended to mean and were understood to mean that Richard Warman was extremely right wing in his views, a Nazi, Fascist and/or hatemonger:

Page 410

"Enter stage right, far right from where I am sitting, one Richard Warman."

Page 411

'Where am I a hatemonger? Where do I condemn the Jewish people? I don't, and Warman knows that I don't, but then that's not the point it is? And what are Warman and Farber (the Bronfmans) seeking to do in this campaign of personal abuse? To get as many people as possible to hate me. So who are the real hatemongers here? (italics in original)

'Warman summed up his attitude to freedom when he told a journalist of equal intelligence in the British Independent on Sunday:

'He has taken all the conspiracy theoris that ever existed and melded them together to create an even bigger conspiracy of his own. His writings may be the work of a madman, or of a genuine racist. Either way they are very dangerous. There is an unpleasant ant-Semitic undertone in his work [I thought I was a 'hatemonger' openly condemning Jewish people] that must be brought to public attention. If he's unstable than so are his followers, who hang on his every word. What benefit can there be in allowing him to speak?'

"If someone had spoken those words in the middle of the last century while wearing a Nazi uniform, no one would have been surprised. If the speaker in Warman's opinion is unstable, so, by definition, must be everyone who listens."

Page 426

"But do you really want to have the experience of living in a fascist global state with your freedom of expression and choice denied in its most basic form? If you do then just sit on your arse and watch it happen because it will. It is happening. What Richard Warman and Bernie Farber (the Bronfmans) are trying to do to me will be written into the law of the land. Such laws are already being introduced."

THE DEFENDANTS DEFAMED THE PLAINTIFF BY CALLING HIM A CENSOR

22. The Plaintiff complains of the following words which were intended to mean and were understood to mean that Richard Warman was censoring David Icke:

Page 408

"Censorship is the life force of the Matrix. if you can stop the free flow of information you are already well on the way to global control."

"I can speak from experience because there have been endless attempts to censor my work. The closer I have gotten to the truth the more determined those attempts have become, especially since I began to speak and write about reptilian hybrid bloodlines."

Page 410

"Once in print, even if the sources themselves may no longer believe it, the articles can be used to further censor what people can hear. Enter stage right, far right from where I am sitting, one Richard Warman. Never heard of him? You are not alone. No one seems to have heard of him until he decided to dedicate his life to preventing me speaking and anyone haveing the opportunity to hear me anywhere in the world. No, you didn't misread that. This man, by the way, works for the Canadian Green Party, which condemns the censorship of freedom of speech! Just like David Taylor of the British Green Party who also sought to have my events banned. The stench of hypocrisy fills the air."

"Warman has worked closely in his campaign of vilification and censorship against me with the Canadian Jewsih Congress or CJC. This was formed and funded by the very same Bronfmans. Just a coincidence, nothing to worry about."

Page 411

'The bile circulated by Warman and Farber (the Bronfmans) led to me being stopped by both customs and immigration at  Ottawa Airport and kep there until two o'clock in the morning. Every item in my luggage was searched (glad I brought those dirty socks) and every piece of paper was read in pursuit of "hate material." They found nothing and in the end the officer-pawn involved could see it was all a set-up. But I still could not leave because some immigration technicality was then found to hold me still longer. I was brought back the following lunchtime, the day of my talk. They kept me there for hours and then asked me what time my talk was due to end that day. I said four o'clock. They let me go at four o'clock. More men and women in uniform, more gatekeepers of their own freedoms. They treated me like a criminal, as if all the propaganda by Warman and Farber (the Bronfmans) was true. In other words they were mind controlled by a precobceived idea because once that is implanted all you see is evidence to support your preconception."

Page 411 - 412

"Richard Warman's abuse of my character devastated my meeting in Ottawa, where the venue had to be changed again and again in the last 48 hours, and the one at Windsor was cancelled. Together with the Bronfmans' Canadian Jewsih Congress and its vitriolic spokesman, Bernie Farber, and others, Warman orgainzed a demonstration outside my talk at the Hart House THeatre at Toronto University, which they failed to miserably stop."

Page 412

'The only reason the Toronto talk went ahead was because the head of the university refused to bow to pressure from Warman and Farber to block my freedom of speech."

Page 413

"Warman, from his home in eastern Canada, now seeks to prevent me speaking anywhere on the planet and if anyone wants to know how easy it is to control the world, they should look at how easy it is to stop freedom of speech without moving from your desk. All he does is check on my website where I am speaking and waits until a few days before the event to ensure that there is not enough time to find another venue. he then either rings the venue or sends them a package claiming I am an anti-Semitic and will be blaming Jews for a global conspiracy, something he knows from his own experience is not true."

"Perhaps most sickening of all, he includes the fact that I am exposing famous people as abusers and sacrificers of children as a reason why venues should not let me speak."

"Just by doing this, in the course of writing this book, Warman has, from eastern Canada, caused my events at London's Blackheath Concert Rooms, Stourbridge Town Hall, and the Burlington Hotel in central Birmingham to be cancelled because the venues banned my talk. That's how easy it is."

"When the Burlington Hotel in Birmingham hasd the Warman treatment three weeks later they pulled the meeting and refused to even speak to me to explain."

Page 414

"But it was all for nothing because the combination of one phone call or package from Richard Warman thousands of miles away and pathetic venue managers in the UK is all it takes to deny this most basic of freedoms."

"That's why Warman can use it to front his attempts to have me silenced, including his bid to have my Internet site taken down. This caused us to move quickly to another server to keep the information available. It was yet more time and effort used to overcome his attempts at censorship that could have been exposing what is happening to so many people, not the least to children. Apparently, Mr. Warman was outraged that his activities were being exposed on the website and that his official Green Party office numbers and e-mail addresses were published so that people whose freedom he had denied could not let him know what they thought."

Page 415

"But in one way, Richard Warman, this misguided holographic image, provides a service to those who care about freedoms. His behaviour has shown how fragile those freedoms are and, indeed, what an illusion they are."

"Censorship of the Internet is next on the Illuminati agenda."

Page 415 - 416

"You are going to see an onslaught against Internet freedom, just a Richard Warman and his srting-pullers targeted my own site. Censors never admit to being so. It's not good for the image, especially if you publish articles calling for freedom of speech like the Green party. They will always find a way of justifying why they are defending freedom rather than destroying it. But when the same criteria are applied to them, they scream like a three-year-old. Self-delusion is the very mind-state of the Matrix. Welcome to the Matrix, Mr. Warman."

"But do you really want to have the experience of living in a fascist global state with your freedom of expression and choice denied in its most basic form.? If you do then just sit on your arse and watch it happen because it will. It is happening. What Richard Warman and Bernie Farber (the Bronfmans) are trying to do to me will be written into the law of the land. Such laws are already being introduced."

23. The Plaintiff pleads that as a result of Children of the Matrix, the Plaintiff has been brought into ridicule, scandal and contempt both personally and by way of his calling as a lawyer and has suffered damages.

24. The Plaintiff pleads that the Defendants deliberately, intentionally or recklessly harmed and damaged the Plaintiff by publishing and distributing the defamatory words.

25. The Plaintiff states that the conduct of the Defendants towards him has been malicious, reckless, callous 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.

26. The Plaintiff states that he has demanded that the Defendants cease all distribution of the work, Children of the Matrix, due to its defamatory content. All of the Defendants have continued to distribute Children of the Matrix.

27. The Plaintiff resides in Ontario. He pleads and relies upon Rule 17.02 (h) and states that he has suffered damage to his reputation in Ontario. The Plaintiff pleads and relies on Rule 17.02 (g) and states that the tort of defamation has been committed in Ontario. The Plaintiff pleads and relies upon Rule 17.02 (o) and states that parties residing outside of Ontario are necessary and proper parties.

28. The Plaintiff proposes that this action be tried in Toronto, Ontario under the Simplified Rules Procedures.

October 17, 2002

McCarthy Tétrault LLP
Suite 4700, Toronto Dominion Bank Tower
Toronto, Ontario K5K 1E6

Christine L. Lalonde
Tel: 1.416.601.8019
Fax: 1.416.601.8246
LSUC no. 44787S

Solicitors for the Plaintiff