21.04.16 Moving Party Motion Record Vol I - Notice of Motion To Exhibit O

Court File No.
CV-20-82717
ONTARIO
SUPERIOR COURT OF JUSTICE
B E T W E E N:
MAXIME BERNIER
Plaintiff
- and -
WARREN KINSELLA, DAISY CONSULTING GROUP INC.

and DAISY STRATEGY GROUP LTD.
Defendants
MOVING PARTIES’ MOTION RECORD
(June 21, 2021 Anti-Slapp Motion)
Volume I
April 16, 2021 SHILLERS LLP

Barristers & Solicitors
197 Spadina Avenue, Suite 402
Toronto ON M5T 2C8
David Shiller (30506Q)

Tel : (416) 363-1112
Fax: (416) 363-5557
david@shillers.com
Lawyers for the defendants

2
TO:
Andremarinlaw Professional Corporation

107 Winding Way
Ottawa, ON K2C 3Hl
Andre Marin, LSO #: 31636W
Tel: 613-799-2346
Fax: 613-383-1927
Email: andremarinlaw@gmail.com
Lawyers for the plaintiff

Court File No. CV-20-82717
ONTARIO
B E T W E E N:
MAXIME BERNIER
Plaintiff
- and -

Defendants
INDEX
Tab No. Page
Notice of Motion dated April 15, 2021 1 10
Affidavit of Warren Kinsella sworn April 15, 2021 2 13
Exhibit “A” to the Affidavit of Warren Kinsella

- Ms. Wente’s April 5, 2012 article A 58
Exhibit “B” to the Affidavit of Warren Kinsella

copy of the Elections Canada’s January 8, 2020 letter B 61
Exhibit “C” to the Affidavit of Warren Kinsella

blogpost dated January 24, 2017 and HuffPost
2
Piece dated May 16, 2017 C 63
Exhibit “D” to the Affidavit of Warren Kinsella

- copies of Mr. Bernier’s tweets in August 2018 D 71
Exhibit “E” to the Affidavit of Warren Kinsella

- copy of August 13, 2018 CBC News article E 74
Exhibit “F” to the Affidavit of Warren Kinsella

- copy of MP Adam Vaughan tweet dated August 13, 2018, F 79
Exhibit “G” to the Affidavit of Warren Kinsella

- copy of article published by the CBC News on August 17, 2018 G 83
Exhibit “H” to the Affidavit of Warren Kinsella

- article published by the CBC News on August 23, 2018 H 87
Exhibit “I” to the Affidavit of Warren Kinsella

- copy of an opinion piece published by the Washington Post on
August 28, 2018 I 91
Exhibit “J” to the Affidavit of Warren Kinsella

- copy of a story published by People’s World on October 3, 2018 J 94
Exhibit “K” to the Affidavit of Warren Kinsella

- copy of a story published by the Globe and Mail
November 12, 2018 K 99
Exhibit “L” to the Affidavit of Warren Kinsella

- copy of a tweet by Mr. Bernier referred to by Mr. Ibbitson L 102
Exhibit “M” to the Affidavit of Warren Kinsella

- copy of an opinion piece by The Conversation
November 19, 2018 M 105
Exhibit “N” to the Affidavit of Warren Kinsella

- copy of an article The Coast published on January 31, 2019 N 110
Exhibit “O” to the Affidavit of Warren Kinsella

- copy of tweet on May 26, 2018 by Mr. Bernier O 113
3
Exhibit “P” to the Affidavit of Warren Kinsella

- copy of tweet by Mr. Bernier on January 27, 2019 P 117
Exhibit “Q” to the Affidavit of Warren Kinsella

- copy of tweet by Mr. Bernier on January 31, 2019 Q 120
Exhibit “R” to the Affidavit of Warren Kinsella

- copy of tweet by Mr. Bernier on February 4, 2019 R 123
Exhibit “S” to the Affidavit of Warren Kinsella

- copy of tweet by Mr. Bernier on June 26, 2019 S 127
Exhibit “T” to the Affidavit of Warren Kinsella

- copy of the February 6, 2019 published story from
the B’nai Brith website T 132
Exhibit “U” to the Affidavit of Warren Kinsella

- copy of The National Post published story on the
B’nai Brith investigation on February 7, 2019 U 136
Exhibit “V” to the Affidavit of Warren Kinsella

- copy of The Toronto Star published story on February 8, 2019 V 139
Exhibit “W” to the Affidavit of Warren Kinsella

- copy of Al Jazeera opinion piece published on April 22, 2019 W 147
Exhibit “X” to the Affidavit of Warren Kinsella

- copy of The Globe and Mail published story on April 27, 2019 X 151
Exhibit “Y” to the Affidavit of Warren Kinsella

- copy of CBC News published story on May 21, 2019 Y 169
Exhibit “Z” to the Affidavit of Warren Kinsella

- copy of iPolitics opinion piece published on May 21, 2019 Z 173
Exhibit “AA” to the Affidavit of Warren Kinsella

- copy of results of a search done on twitter of Mr. Deng AA 177
4
Exhibit “BB” to the Affidavit of Warren Kinsella

- copy of CBC News story published January 8, 2019 BB 184
Exhibit “CC” to the Affidavit of Warren Kinsella

- copy of a column by Bob Hepburn in the Toronto Star
on September 25, 2019 CC 193
Exhibit “DD” to the Affidavit of Warren Kinsella

- copy of The Toronto Star published story on April 5, 2019 DD 196
Exhibit “EE” to the Affidavit of Warren Kinsella

- copy of CBC story on July 18, 2019 EE 201
Exhibit “FF” to the Affidavit of Warren Kinsella

- copy of Toronto Star published story on October 1, 2019 FF 205
Exhibit “GG” to the Affidavit of Warren Kinsella

- copy of Global News story on May 9, 2019 GG 209
Exhibit “HH” to the Affidavit of Warren Kinsella

- copy of CBC published story on June 5, 2019 HH 214
Exhibit “II” to the Affidavit of Warren Kinsella

- copies of CBC News published stories on September 25, 2019
and September 26, 2019 II 219
Exhibit “JJ” to the Affidavit of Warren Kinsella

- copy of CBC News published story on September 30, 2019 JJ 229
Exhibit “KK” to the Affidavit of Warren Kinsella

- copy of CBC News published story on October 3, 2019 KK 233
Exhibit “LL” to the Affidavit of Warren Kinsella

- copy of Global News published story on October 12, 2019 LL 237
Exhibit “MM” to the Affidavit of Warren Kinsella

- copy of CBC News published story on July 9, 2019 MM 240
Exhibit “NN” to the Affidavit of Warren Kinsella

- copy of CTV News published a similar story on July 10, 2019 NN 245
5
Exhibit “OO” to the Affidavit of Warren Kinsella

- copy of Global News published story on July 9, 2019 OO 248
Exhibit “PP” to the Affidavit of Warren Kinsella

- copy of an excerpt from the Ant-Defamation League website PP 252
Exhibit “QQ” to the Affidavit of Warren Kinsella

- copy of Warren Kinsella’s July 29, 2019 blog post QQ 256
Exhibit “RR” to the Affidavit of Warren Kinsella

- copy of The Hamilton Spectator story on August 1, 2019 RR 267
Exhibit “SS” to the Affidavit of Warren Kinsella

- copy of Huffington Post story on July 31, 2019 SS 271
Exhibit “TT” to the Affidavit of Warren Kinsella

- copy of Global News story on August 30, 2019 TT 274
Exhibit “UU” to the Affidavit of Warren Kinsella

- copy of Toronto.com published story on July 25, 2019 UU 279
Exhibit “VV” to the Affidavit of Warren Kinsella

- copy of CBC News published July 24, 2019 VV 282
Exhibit “WW” to the Affidavit of Warren Kinsella

- copy of National Post story published July 25, 2019 WW 287
Exhibit “XX” to the Affidavit of Warren Kinsella

- copy of Regina Leader Post story on July 31, 2019 XX 291
Exhibit “YY” to the Affidavit of Warren Kinsella

- copy of HuffPost Canada published story on August 19, 2019 YY 294
Exhibit “ZZ” to the Affidavit of Warren Kinsella

- copy of Global News published story on August 25, 2019 ZZ 299
Exhibit “AAA” to the Affidavit of Warren Kinsella

- copy of Global News published story on September 13, 2019 AAA 305
6
Exhibit “BBB” to the Affidavit of Warren Kinsella

- copy of opinion piece published in the Toronto Star
on September 14, 2019 BBB 310
Exhibit “CCC” to the Affidavit of Warren Kinsella

- copy of Mr. Bernier’s tweet about Ms Thunberg CCC 314
Exhibit “DDD” to the Affidavit of Warren Kinsella

- copy of story published by Global News on September 17, 2019 DDD 319
Exhibit “EEE” to the Affidavit of Warren Kinsella

- copy of Global News published story on October 7, 2019 EEE 322
Exhibit “FFF” to the Affidavit of Warren Kinsella

- copy of The National Observer story published
October 7, 2019 FFF 325
Exhibit “GGG” to the Affidavit of Warren Kinsella

- copy of the March 14, 2018 Atlantic article GGG 328
Exhibit “HHH” to the Affidavit of Warren Kinsella

- copy of the October 21, 2020 Haaretz article HHH 332
Exhibit “III” to the Affidavit of Warren Kinsella

- copy of the October 24, 2018 Forward article III 335
Exhibit “JJJ” to the Affidavit of Warren Kinsella

- copy of Global News story published September 23, 2019 JJJ 339
Exhibit “KKK” to the Affidavit of Warren Kinsella

- copy of an excerpt from Pegida Canada’s website KKK 344
Exhibit “LLL” to the Affidavit of Warren Kinsella

- copy of Vancouver Star story on October 10, 2019 LLL 348
Exhibit “MMM” to the Affidavit of Warren Kinsella

- copy of a story published by Narcity on October 15, 2019 MMM 352
Exhibit “NNN” to the Affidavit of Warren Kinsella

7
- copy of The Conversation published October 14, 2019 NNN 355
Exhibit “OOO” to the Affidavit of Warren Kinsella

- copy of Foreign Policy published piece by Justin Ling
October 20, 2019 OOO 361
Exhibit “PPP” to the Affidavit of Warren Kinsella

- copy of The National Observer opinion piece
published October 29, 2019 PPP 370
Exhibit “QQQ” to the Affidavit of Warren Kinsella

- copy of opinion piece published by
CBC News on November 13, 2019 QQQ 373
2. Affidavit of Matthew Conway sworn May 15, 2021 3 377

10
ONTARIO
B E T W E E N:
MAXIME BERNIER
Plaintiff
- and -

Defendants
NOTICE OF MOTION
The defendants will make a motion to a Judge on June 17, 2021 at 10:00 am. or as soon
after that time as the motion can be heard, at the Court House, 161 Elgin Street, Ottawa,
Ontario.
THE METHOD OF HEARING: The motion is to be heard orally by Zoom
videoconference.
THE MOTION IS FOR:
1. An Order dismissing this action as a proceeding arising from an expression
made by the defendants that relates to a matter of public interest;

11
2. Its costs of the motion on a full indemnity basis;
3. such other relief as to this Honourable Court seems just.
THE GROUNDS FOR THE MOTION ARE:
1. The action is a strategic lawsuit against public participation brought by an
unsuccessful Prime Ministerial candidate seeking to: (i) silence a political
commentator who commented unfavourably on the candidate’s political platform,
(ii) blame the political commentator for his unsuccessful campaign.
2. The action arises from an expression made by the defendants that relates to a
matter of public interest.
3. The action has no merit;
4. The defendants have a valid defence to the action;
5. The defendants’ expression caused no harm to the plaintiff;
6. in the alternative, any harm suffered by the plaintiff as a result of the
defendants’ expression is not sufficiently serious.
7. The public interest in protecting the defendants’ expression outweighs the
public interest in permitting this action to continue.
8. Section 137.1 of the Courts of Justice Act.

12
THE FOLLOWING DOCUMENTARY EVIDENCE WILL BE USED AT THE

HEARING OF THE MOTION:
1. The affidavit of Warren Kinsella and the exhibits thereto.
2. The affidavit of Matthew Conway.
3. Such other material as this Honourable Court may permit.
April 15, 2021 SHILLERS LLP

Barristers & Solicitors
197 Spadina Avenue, Suite 402
Toronto ON M5T 2C8

Tel : (416) 363-1112
Fax: (416) 363-5557
david@shillers.com
TO:
Andremarinlaw Professional Corporation

107 Winding Way
Ottawa, ON K2C 3Hl
Andre Marin, LSO #: 31636W
Tel: 613-799-2346
Fax: 613-383-1927
Email: andremarinlaw@gmail.com
Lawyers for the plaintiff

13
ONTARIO
B E T W E E N:
MAXIME BERNIER
Plaintiff
- and -

Defendants
AFFIDAVIT OF WARREN KINSELLA
I, Warren Kinsella, of the City of Toronto, in the Province of Ontario, MAKE OATH
AND SAY:
Background
1. I am a political commentator, newspaper columnist, author, consultant,
lawyer, adjunct law professor and president of the defendant, Daisy Consulting
Group Inc. and its related companies (“Daisy”). I am also the founder of the non-
profit anti-racism group, Standing Together Against Misogyny and Prejudice
(“STAMP”).
2. I hold a Bachelor of Journalism (Honours, 1984) from Carleton University and
an LL.B (1987) from the University of Calgary’s Faculty of Law. I was called to the
14
Bar of Ontario in 1989. I have also pursued executive education at Harvard
University’s Faculty of Law.
3. In the 1990s, I was a Special Assistant to the Right Honourable Jean Chretien
when he was leader of the opposition. At the time, I initiated and helped lead
campaigns in Parliament to expose and oppose racism and hatred including the
presence of neo-Nazis and white supremacists in the Canadian Airborne Regiment,
and the presence of neo-Nazis and white supremacists in the fledgling Reform Party
of Canada.
4. In 1993 and 2000, I was the Chairman of the Liberal Party of Canada war room.
In 2003, 2007 and 2011, I was Chairman of the Ontario Liberal Party’s election war
room. A war room is a campaign group that does opposition research, quick
response and develops communications products.
5. As a lawyer and a consultant, I have been actively involved in campaigns to
oppose racism and hate for more than three decades. I have worked on these
campaigns in every region of Canada, and have provided advice in that capacity to
the Canadian Jewish Congress, the Canada Israel Committee, the RCMP, the FBI,
CSIS and many other governmental and non-governmental agencies. I have also
lectured extensively about hate groups and hate group activity across.
6. I have authored ten books, most of which concern racism, anti-Semitism,
homophobia, Islamophobia, misogyny and other manifestations of intolerance.
These include: (i) Unholy Alliances (1992, Lester), which examined alliances between
anti-Semitic extremist organizations on the Right and Left, (ii) Web of Hate (1994, 1996
and 2001, HarperCollins), which documented neo-Nazi and white supremacist

15
activity in Canada, was a national best seller and won the Ottawa Citizen Best Book
Award and, (iii) Fight the Right (2007, Random House), which address the rise of far-
Right populist movements, and (iv) a Young Adult trilogy – Recipe For Hate (2017,
Dundurn), New Dark Ages (2018, Dundurn) and Age of Unreason (2019, Dundurn) –
which extensively discussed organized racism and hate movements.
7. As an adjunct professor, I have lectured on anti-hate legislation at the
University of Calgary’s Faculty of Law and Carleton University’s Department of
Journalism. I have also advised the Ontario Bar Association and the Canadian Bar
Association on issues of racism and bias.
8. I was an investigative reporter at the Calgary Herald, where I won the
newspaper’s excellence award for my work exposing the activities of the Aryan
Nations. I was also an investigative reporter at the Ottawa Citizen, where I received
an award for my writing about extremism. I have also written extensively about
racism and hate as an opinion columnist at newspapers owned by Southam News,
CanWest and Postmedia. I am currently a national opinion columnist with
Postmedia. My opinion pieces about these subjects have also been published by the
Wall Street Journal, The Globe and Mail and other publications.
9. I am generally known as a pundit and commentator on public affairs,
particularly Canadian political affairs. The style I employ is fairly seen as caustic
and direct. I am not a member of any political party but, through Daisy, have done
work for many of them over the last 15 years. I have been commenting on Canadian
political matters for more than 25 years. My website, warrenkinsella.com, where I
write daily about a variety of matters including political issues, debuted in 2000. I
have been active on Twitter since 2008, where I write about a variety of issues
16
including political issues and in particular, Canadian politics. I have commented on
every Canadian federal election since 1988.
10. I have been the president of Daisy since I founded it in May 2006. Daisy does
public relations, government relations and media relations. Its main activity,
however, is running public advocacy campaigns. Daisy has, since its founding, been
involved in multiple campaigns opposing racism, anti-Semitism, homophobia,
Islamophobia, misogyny and other manifestations of intolerance. At present, via our
STAMP group, we have been working for more than a year to remove the street name
“Swastika Trail” in Puslinch, Ontario.
11. My anti-racism work has resulted in some accolades, but also a number of
attacks. I have received death threats, and threats of violence, since 1986, and have
occasionally received police protection as a result. Most recently, in November 2019,
Daisy’s Toronto offices were targeted by a bomb threat. During the investigation by
Toronto Police Service Bomb Squad, the person claiming to be the bomber called
Daisy. I spoke to him and he said he was a member of the Soldiers of Odin and that
he had planted the bomb because of the work Daisy had done exposing and opposing
extremism in the People’s Party of Canada (the “PPC”). He said: “You put a smear
campaign against Maxime Bernier…we believe in the elimination of faggots, we
believe in the elimination of blacks, we believe in Nuremberg Laws.”
Genesis of this action
12. This action arises from comments I made in newspaper articles, on my website
and on other social media platforms about Maxime Bernier (“Mr. Bernier”). My
comments, all made in 2019, were made on stories in the media about Mr. Bernier
17
and the PPC during the time Mr. Bernier formed the PPC and was running for the
highest political office in Canada.
13. In the final week of the October 2019 election, stories were published in the
Globe and Mail, CBC and Canadaland that claimed Daisy was behind a social media
campaign against the PPC and Mr. Bernier which had been funded by the
Conservative Party of Canada (the “CPC”). The story was based on stolen Daisy
banking and client documents and a secret recording provided to the above noted
media organizations by a former Daisy employee who was represented by Mark
Bourrie (“Mr. Bourrie”), co-counsel to Mr. Bernier in this action. The former
employee had given Daisy a sworn statement confirming that she destroyed all the
documents she had taken. This sworn statement turned out to be false: the former
employee provided the media with documents and secret recordings she had made
while at Daisy.
14. This put Daisy in a very difficult position. Daisy owes its clients a duty of
confidentiality. Keeping confidentiality considerations in mind, I can say that Daisy
was not hired by the CPC. Rather, for a six-week period ending June 29, 2019, a
lawyer who was a member of the CPC paid Daisy to supplement work Daisy was
already doing about the PPC. Daisy did not take direction from the lawyer or submit
any work for his review or comment. We stipulated that we would continue to
expose racism and intolerance in all political parties not just the PPC; the lawyer
agreed to this position. During this period, the STAMP Twitter account made
postings about Mr. Bernier and the PPC.
15. In every war room campaign I led, and at Daisy, I would urge my staff to
energetically oppose and defeat our partisan opponents, using very direct language.
18
I also did this in respect of the PPC. I often likened this opposition to a purifying
force. My entreaties became sufficiently well-known that they were commented
upon in the media, years before the instant case, as conservative columnist Margaret
Wente did in the Globe and Mail in April 2012: “With charming candour, Mr.
Kinsella revealed that "whenever I set up a political war room … I tell the assembled
youngsters their loathing of conservatives is a purifying force. 'Let it wash over you,'
I tell them. 'Step on their necks, and don't lift your foot until the day after the
election. Hurt them.’" Annexed hereto as Exhibit “A” is a copy of Ms. Wente’s April
5, 2012 article. The statements recorded of me are simply a motivational speech I
gave as I have done on many previous occasions.
16. When Mr. Bernier lost the election in October, 2019, it was reported in the
media that he had filed a complaint against Daisy and me with the Commissioner of
Canada Elections alleging that we had been waging a “secret” campaign against him.
Daisy and I submitted a report and made representations to the Elections
Commissioner and in January 2020, the Elections Commissioner issued a judgment
dismissing Mr. Bernier’s complaint stating: “Based on the outcome of our review and the
information available, we have determined that neither you nor the Daisy Group contravened
the Act. We consider the matter closed” Annexed hereto as Exhibit “B” is a copy of
Elections Canada’s January 8, 2020 letter in this regard.
17. Over my 30 years of exposing and opposing racism, anti-Semitism,
homophobia, Islamophobia, misogyny and other manifestations of intolerance, I
have often been the target of efforts to silence me, this proceeding being the latest
example. Mr. Bernier himself tweeted on January 10, 2021 his clear opposition to
those in politics who seek to “silence dissenting voices.” and yet that is precisely
what he seeks to do with this proceeding. It is a legal action that has been initiated
19
by a national public figure – the leader of a federal political party, no less – who is
seeking to intimidate and silence dissenting voices.
18. Mr. Bernier’s lawyers in this proceeding have themselves engaged in an
extraordinary and years-long campaign of harassment and “lawfare” against me,
which is detailed below.
19. It should be noted that I bear Mr. Bernier no malice or ill will whatsoever. In
fact, when the plaintiff was seeking the leadership of the Conservative Party, I wrote
on several occasions on various media that he was the best candidate and the best
option to beat Justin Trudeau’s Liberal Party. Annexed hereto as Exhibit “C” are
copies of a blogpost I did on January 24, 2017 and a piece I wrote for HuffPost on
May 16, 2017 about Mr. Bernier’s leadership run.
20. In the following sections of this affidavit, I have set out a sample of news
reports and opinion pieces reporting and commenting on Mr. Bernier and the PPC
from October 2018 through to after the October, 2019 federal election. Daisy and I
relied on these news reports and opinion pieces in our own reporting and
commentary about Mr. Bernier and the PPC. Our objective, in the main, was to
draw attention to the critical reporting and critical commentaries of others about Mr.
Bernier and the PPC. I believe that the statements I made about Mr. Bernier and the
PPC which he complains of in this action - while sometimes caustic and direct – were
always truthful and/or fair comment on Mr. Bernier and the PPC. All my comments
on Mr. Bernier’s statements and actions were genuinely and honestly made based on
the facts.
20
A brief history of Maxime Bernier and the formation of the PPC
21. Mr. Bernier is from Beauce, Quebec. He was a member of the CPC, elected to
the House of Commons and appointed as the Minister of Industry in 2006. In
August, 2007, he became Minister of Foreign Affairs but resigned in May, 2008 after
it became public that he had left a confidential briefing book at the home of his
girlfriend who had ties to a biker gang.
22. In 2011, Mr. Bernier was appointed as Minister of State in the Harper
government. In November, 2015, he was appointed as critic for Economic
Development and Innovation. In April, 2016, he resigned to pursue the CPC
leadership. He was unsuccessful in his leadership bid and was re-appointed critic
for innovation, Science and Economic Development Canada in August 2017 then
dismissed from this position in June 2018 after he released some chapters from his
upcoming book which were critical of the CPC.
23. In August 2018, Mr. Bernier announced he was leaving the CPC to form the
PPC which was ultimately founded in September, 2018: “I have come to realize over
the past year that [the CPC] is too intellectually and morally corrupt to be reformed”.
24. Around the time Mr. Bernier left the CPC, his views and positions became
considerably more extreme. To me and many political observers, Mr. Bernier
appears to have re-branded himself as a populist as a strategy for becoming Prime
Minister. Many people have said that Mr. Bernier borrowed from the playbook of
US President Donald Trump after seeing the success of his populist campaign in the
US.
25. Much like Mr. Trump, Mr. Bernier denies that he or his policies are racist.
However, as shown in the media reports and opinion pieces listed and summarized
21
below, from August, 2018 until after the federal election in October 2019, there were
repeated incidents regarding Mr. Bernier and the PPC that could indeed fairly be
described as racist, or showing willful indifference to the presence of racists in the
ranks of the PPC. Since the party’s creation, media coverage of the PPC and Mr.
Bernier has documented dozens of examples of racist activity, policies and views
held by the PPC and Mr. Bernier.
Mr. Bernier’s “extreme multiculturalism” tweets kick off his resignation from the
Conservatives and the formation of the PPC
26. In August, 2018, just before forming the PPC, Mr. Bernier posted a series of
tweets, copies of which are annexed hereto as Exhibit “D”, about Prime Minister
Trudeau’s comment that “diversity is our strength”. Mr. Bernier was very critical of
this comment, labelling it “radical multiculturalism” stating:
(a) “Having people live among us who reject basic western

values such as freedom, equality, tolerance, and openness
doesn’t make us strong. People who refuse to integrate into
our society and want to live apart in their ghetto don’t
make our society strong”;
(b) “Trudeau’s extreme multiculturalism and cult of diversity
will divide us into little tribes that have less and less in
common, apart from their dependence on government in
Ottawa. These tribes become political clienteles to be bought
with taxpayers (money) and special privileges”; and
(c) Cultural balkanization brings distrust, social conflict, and
potentially violence, as we are seeing everywhere. It’s time
we reverse this trend before the situation gets worse. More
diversity will not be our strength, it will destroy what has
made us such a great country.
22
Press call Bernier “extreme multiculturalism” tweets racist and xenophobic
27. These comments were heavily criticized both on social media and in the press.
Mr. Bernier’s comments were, in my view, meant to be dramatic to gain publicity,
much like the comments of Donald Trump when he launched his campaign with his
“Mexico is not sending their best” speech.
28. Annexed hereto as Exhibit “E” is an August 13, 2018 CBC News article which
reports on these tweets and notes that social media commentators condemned the
sentiment of the tweets as racist and xenophobic.
29. MP Adam Vaughan responded to these tweets by tweet dated August 13, 2018,
a copy of which is annexed hereto as Exhibit “F”, stating: “Your statements are
“unacceptably” racist. @MaximeBernier criticized “diversity” and then “more
diversity” and then invented “radical multiculturalism” as something to fear. The
only thing “destroyed” is your credibility. All with “your words”.
30. Annexed hereto as Exhibit “G” is an article published by the CBC News on
August 17, 2018 about a park in Winnipeg named after a Pakistani leader that had
been vandalized. Mr. Bernier tweeted that this park dedication was an example of
“extreme liberal multiculturalism”. Mr. Bernier argued that the creation of Pakistan
killed nearly 1 million people. The article also described Mr. Bernier’s tweets the
weekend before regarding multiculturalism as having been “roundly disparaged for
stoking racist and xenophobic tensions.”
31. Annexed hereto as Exhibit “H” is an article published by the CBC News on
August 23, 2018 which describes him as causing waves on the national scene and
23
within his own party – for recent tweets regarding Canada’s diversity which had
been labelled xenophobic by some commentators…”
32. An opinion piece published by the Washington Post on August 28, 2018 a copy
of which is annexed hereto as Exhibit “I”, commented on Mr. Bernier and the PPC
as follows: (i) Mr. Bernier has a “new obsession with so-called identity politics”, (ii)
“immigration scaremongering is the populist cover for his … program”, (iii) Mr.
Bernier is “walking a path that has been laid by Canadian far-Right groups for years
now.”, (iv) there are few politicians better situated than Mr. Bernier to shamelessly
seize on the rhetoric of anti-immigrant white supremacist groups in Canada that
have succeeded in confusing facts about refugees, migrants and immigration.
33. A story published by People’s World on October 3, 2018, a copy of which is
annexed hereto as Exhibit “J”, describes Mr. Bernier’s policies as including “sharp
attacks on Muslims, immigrants, and diversity, coupled with demands for deep cuts
to immigration and foreign aid, and testing for ‘Canadian values.’”
34. In a story published by the Globe and Mail on November 12, 2018 a copy of
which is annexed hereto as Exhibit “K”, commentator John Ibbitson writes about a
speech by Mr. Bernier at a conference hosted by right-wing Rebel Media in which,
among other things, Mr. Bernier stated “our immigration policy should not aim to
forcibly change the cultural character and social fabric of our country. Immigration
levels should be reduced, and immigrants must “adopt widely shared Canadian
values, Western civilization values,”. Mr. Ibbitson commented that Mr. Bernier
promises to be the voice for those who believe the Canadian economy and social
fabric are being undermined by environmentalists, do-gooders and immigrants. Mr.
Ibbitson also referred to a tweet by Mr. Bernier, a copy of which is annexed hereto
24
as Exhibit “L”, including a video of crowds in Pakistan protesting the release of Asia
Bibi, a Christian who had been convicted of blasphemy and stating: “Radical
multiculturalism is the misguided belief that all values and cultures can coexist in
one society. They cannot. We must protect our society against this kind of
barbarism.” Mr. Ibbitson commented that this tweet removes all doubt about the
buttons Mr. Bernier intended to push in the months ahead and commented: (i) “No
credible voice in this country seeks to undermine the values and beliefs embedded
in the Charter of Rights and Freedoms, and in the fabric of Canadian society.
Immigrants and refugees come here in search of a future protected by those values
and beliefs. Mr. Bernier is simply stoking irrational fears of a threat that does not
exist. It is pure Trumpism”, and (ii) “in his attacks on multicultural diversity and
tolerance, he echoes – in a typically attenuated, Canadian way – Mr. Trump’s
rhetoric; he stokes the anger Mr. Trump seeks to stoke.”
35. The Conversation published an opinion piece on November 19, 2018, a copy
of which is annexed hereto as Exhibit “M” which comments on a speech Mr. Bernier
gave at a PPC rally in Etobicoke. The piece references the previous PPC rally in
Calgary which was hosted by Rebel Media and comments that Mr. Bernier’s speech,
which included attacks against “radical multiculturalism”, climate change science
and foreign aid prompted political commentators to compare him to Donald Trump.
The piece also comments that: (i) blended into Mr. Bernier’s libertarian rhetoric and
the PPC’s platform are “proposals that reflect the ideological tenets of a populist
radical right, defined by a commitment to xenophobia”, (ii) Faith Goldy, well-known
as an advocate for the conspiracy theory of white genocide and attacks against
Islamic culture and immigrants, attended the Etobicoke rally, something that was
not surprising since Mr. Bernier has courted far right support to publicize the PPC,
(iii) Mr. Bernier has received glowing media coverage from Rebel Media, appearing
25
at its events and being interviewed by its employees, (iv) Rebel Media is closely
associated with far right leaders and activists like Faith Goldy and Gavin McInnes,
leader of the misogynistic, pro-violence Proud Boys and that Mr. Bernier is aware
of these associations and is actively seeking to build a base for his party around
Rebel subscribers, (v) Mr. Bernier’s stance against “extreme multiculturalism”
mirrors similar rhetoric used by radical right wing populist parties in Europe who,
instead of openly calling for racial or ethnic discrimination, base their appeals to
voters on civic values of tolerance, diversity and liberal citizenship, (vi) it appears
that subscribers to far right ideas may be viewing Mr. Bernier and the PPC as a
viable pathway to mainstreaming their xenophobic and nationalistic beliefs in
Canada.
36. The Coast published an article on January 31, 2019, a copy of which is annexed
hereto as Exhibit “N” which reports on the January 18, 2019 PPC convention in
Halifax. The author states unequivocally: “Make no mistake, this event was a white
supremacist rally.” The author continued as follows: (i) Mr. Bernier started off
speaking of supply management and corporate welfare, ending federal equalization
payments and pipelines all to a mostly muted response from the crowd, (ii) when
Mr. Bernier said “I want to speak about immigration”, the room shook as the crowd
erupted into wild applause, (iii) Mr. Bernier stated that a reduction in the number of
immigrants is not only important to the Canadian economy, but also in maintaining
“Canadian values” and “Western civilization” for the next 20 to 50 years, (iv) Mr.
Bernier could not contain his glee as he watched the crowd scream in excitement, (v)
Mr. Bernier then closed his speech by borrowing Trump’s familiar phrase “Let’s
make Canada great again”. The story ends with the author stating: “The PPC
convention painted a bleak and terrifying picture for the future of the Canadian
political landscape. We live at a time in which we are continually confronted by the

26
failures of liberal capitalism and are increasingly presented with only two solutions:
egalitarian, international socialism; or fascist and barbaric white supremacism. The
latter has now found a party, a leader and is seeking candidates to run in Nova
Scotia for this year’s upcoming federal election.
Various tweets by Mr. Bernier
37. On May 26, 2018, Mr. Bernier tweeted at MP Celina Caesar-Chavannes:
“@MPCelina focuses less on policy and more on personal matters. That’s the main
difference between us. You think the world revolves around your skin colour. My
goal is to bring better policies to all Canadians. That’s an MP’s job.” Annexed hereto
as Exhibit “O” is a copy of this tweet.
38. On January 27, 2019, Mr. Bernier tweeted: “We are a diverse country with
multiple heritage and identities. But we should focus on what UNITES us. Or else
Canada will be balkanized and split into little warring tribes. Time to stop the tribal
politics. The pandering to ethnic voting blocs. We are all Canadians. Annexed hereto
as Exhibit “P” is a copy of this tweet.
39. On January 31, 2019, Mr. Bernier tweeted: “Housing costs are high in
Vancouver and Toronto because most immigrants move to these cities and zoning
regulations curtail supply. The lunatic left solution: Throw more money on the
problem! More subsidies, more tax distortion, more big government!”. Annexed
hereto as Exhibit “Q” is a copy of this tweet.
40. On February 4, 2019, Mr. Bernier tweeted: “ … Many people are fed up with
political correctness and diversity nonsense. I’m the only politician in Ottawa who
dares attacking it.” Annexed hereto as Exhibit “R” is a copy of this tweet.
27
41. On June 26, 2019, Mr. Bernier tweeted: “M-103 was only a motion, they said.
But here is the “strategy”. You’re afraid of Islamist terrorism?, Sharia law?
Traditionalist Muslim teaching about beating wives and killing gays? You’re a racist
and an Islamophobe! And Liberals will prevent you from expressing your fear”.
Annexed hereto as Exhibit “S” is a copy of this tweet. Mr. Bernier’s tweet was in
response to a new ant-racism strategy unveiled by the federal government which
included a definition of Islamophobia from the Ontario Human Rights Commission
and fulfilled recommendations from a parliamentary committee study that arose
from M-103, an anti-Islamophobia motion made by the federal government.
B’nai Brith Investigation finds Bernier right-hand man made statements that may
foment anti-Semitism, misogyny and racism
42. In February, 2019, the B’nai Brith of Canada published findings of an
investigation it did into Martin Masse. Mr. Masse is a top PPC official and
spokesperson and a top advisor and long-time friend to Mr. Bernier. The B’nai Brith
found that Mr. Masse made or supported statements that may foment anti-Semitism,
misogyny and racism. These statements include the following statements made by
Mr. Masses or by contributors to an online Libertarian news outlet Mr. Masse
published: (i) Islamist suicide attacks are not a consequence of religious extremism
but a response to western aggression and interventionism, (ii) Africa has equal
responsibility for the western slave trade, (iii) LGBTQ groups want to establish their
own tyranny, (iv) statements personally defending Jorg Haider who spoke highly of
Nazi war criminals and often trivialized the Holocaust and Jean-Marie Le Pen, a
convicted Holocaust denier who claimed former French President Jacques Chirac
was controlled by Jewish organizations, (v) referring to the B’nai Brith and other
Jewish organizations as “ethnic barons” and denouncing Zionism as “just another
fancy justification for killing and displacing Palestinians”.

28
43. When the B’nai Brith approached Mr. Bernier with a lengthy dossier detailing
Masse’s embarrassing statements, Mr. Bernier responding “there is nothing in what
I read that can be described as anti-Semitic or racist views”. Annexed hereto as
Exhibit “T” is a copy of the February 6, 2019 story from the B’nai Brith website
regarding its investigation of Mr. Masse and Mr. Bernier’s response to it.
44. The National Post ran a story on the B’nai Brith investigation on February 7,
2019. Annexed hereto as Exhibit “U” is a copy of the story which states: “Maxime
Bernier, leader of the nascent People’s Party of Canada, is defending his right-hand
man Martin Masse amid accusations the top party official fomented anti-Semitism,
misogyny and racism’…”. The story quotes Mr. Bernier saying the B’nai Brith had
political motivations for its report, suggesting they support another party and also
quotes former conservative cabinet minister Peter Kent saying: “I think Max is
pandering to the wrong people by defending the exposed hateful prejudices of his
policy advisor”. The story also quotes the people by defending the exposed hateful
prejudices of his policy advisor”. The story also quotes the CEO of B’nai Brith
saying: “One would expect that the leader of a federal party would immediately
expunge senior staff members who have expressed such radical and repulsive views
when it is called to their attention. We were shocked that, upon presenting this
information to Mr. Bernier, he defended his top advisor, Mr. Masse.”
Press about Mr. Bernier’s association with the alt-right
45. The Toronto Star published a story on February 8, 2019, a copy of which is
annexed hereto as Exhibit “V” entitled “Maxime Bernier’s alt-right problem”. The
article discusses: (i) how Canada’s “tiny cadre of neo-Nazis and the broader alt-right
movement” needed a politician who could bridge the gap between the mainstream
and the far-right fringe, someone who was an unabashed supporter of “western
29
values” who would clamp down on immigration and multiculturalism and that they
decided that Mr. Bernier could be that politician, (ii) Mr. Bernier’s denouncing
Prime Minister Trudeau’s “extreme multiculturalism and cult of diversity” and
states that when Mr. Bernier declared the death of political correctness in Canada on
Twitter, it was heard as a dog whistle, (iii) quotes from “Cracker Jack” (who later
identified himself as Tyler Hall-Kuch), one of the hosts of the podcast “The Ensign
Hour”, stating about Mr. Bernier and the PPC: “This sets a precedent. This is a huge
step forward. This opens the conversation for our people – the Europeans, the
settler class – to give us permission to speak our minds”, (iv) a quote from Daniel
Béland, director of the McGill Institute for the Study of Canada saying “[Bernier]
would be aware that this kind of rhetoric could attract people who listen to some
of the Hitler rhetoric [and] who are associated with the far right. It’s hard to
imagine that he would be unaware of the ramifications of these comments. Simply
saying he’s against racism while at the same time attracting these people is ...
problematic and might turn against him over the next few months if it gets out of
control.” Lastly, the article references 3 PPC riding officials and a PPC provincial
organizer who posted the following on social media: (i) “Islam is not Canadian.
Canada was founded by Christianity. They do not assimilate because they don’t
want to. They want to take Canada and every non Muslim and kill non converters”,
(ii) “When I have kids, they will not play with n*****s”, (iii) a tweet referring to
Islam as an “insane radical religion”, and (iv) a caricature of Andrew Scheer being
manipulated like a puppet by Jewish philanthropist George Soros. The article
mentions that 3 of the 4 PPC officials were no longer in their positions as a result of
their social media posts .
46. Al Jazeera published an opinion piece on April 22, 2019, a copy of which is
annexed hereto as Exhibit “W” entitled “Canada’s political compass is veering far
30
right”. The writer, after commentating on the UCP in Alberta, refers to the following
tweet by Mr. Bernier scolding Prime Minister Trudeau for warning about the
dangers of white supremacy: "Trudeau has been warning us for weeks about dangers
of ‘white supremacy’, equating an entire ethnicity with terrorism. Hypocrite! It’s all
about pandering to votes”. The author comments that Mr. Bernier is the definition
of a pandering hypocrite as he created a party explicitly opposed to “extreme
multiculturalism and cult of diversity”, a party described as having an insular,
xenophobic message that appears to be resonating with Canadians.
47. The Globe and Mail ran a story on April 27, 2019, a copy of which is annexed
hereto as Exhibit “X” entitled “Canada’s new far right; a trove of private chat room
messages reveals an extremist subculture”. The story recounts: (i) a Globe and Mail
investigation into online chat room exchanges between “a loosely aligned node of
Canadian right-wing extremists” described as “anti-Semitic, anti-immigrant,
Islamophobic, sexist and racist” seeking pathways into mainstream politics, (ii) the
overarching goal of many of the extremists was the eventual creation of a white
ethnostate by slowly gaining a foothold in a range of institutions and professions,
(iii) members of the chat room set out to make their mark on mainstream politics in
2017 by participating in the CPC leadership race, (iv) the group first rallied behind
Kellie Leitch who proposed screening immigrants for cultural values, but when her
leadership bid stalled, they moved en masse to support Mr. Bernier, (v) one person
in the chat room…said he attended a Bernier event in March 2017 and described the
politician as “dog-whistling pretty hard. He mentioned western values and western
civilization a lot”, and (vi) neither the PPC nor Mr. Bernier responded to requests
for comments on the story.

31
48. CBC News ran a story on May 21, 2019, a copy of which is annexed hereto as
Exhibit “Y” entitled “Ken Pereira, union whistleblower turned conspiracy theorist,
joins forces with Maxime Bernier”. The story recounts that: (i) the PPC confirmed
that Mr. Pereira will run for the PPC in a Quebec City riding, (ii) on a YouTube
channel he co-hosts, Mr. Pereira speaks about a purported international ring of
pedophiles that performs occult rituals and claims that the September 11, 2001
attacks on the US were a false flag operation to justify new wars, (iii) in a video
published earlier that year, Mr. Pereira said that pedophilia is part of the daily life
of politicians, celebrities and other powerful people.
49. iPolitics published an opinion piece on May 21, 2019, a copy of which is
annexed hereto as Exhibit “Z” entitled “’Crazies now completely in control of PPC,
says former executive”. The piece recounts how: (i) Alain Deng, a person with a
history of guttural anti-Muslim rhetoric on social media (he posted “Muslim is
terrible and trouble maker in any where of this planet” among other posts), was
listed as a member of the PPC’s Burnaby South riding association, (ii) when the
author emailed PPC’s Martin Masse to inquire, he was assured that Mr. Deng was
not a member of the riding association, (iii) the author was subsequently told by
Angelo Isidorou, a former PPC executive who became an outspoken critic of the
party, that Mr. Deng was indeed a member of the riding association, (iv) Mr. Isidorou
became disillusioned with the PPC for failing to disavow what he called “the crazies”
who had attached themselves to the PPC, (v) Mr. Deng tweeted that Federal
Immigration Minister Ahmed Hussen should “swim” and/or otherwise go ‘back to
Somalia, (vi) Mr. Deng subsequently became the PPC’s candidate for the riding of
South Vancouver, (vii) Mr. Isidorou said the PPC had a policy vacuum that had been
filled with equal parts white nationalists and social conservatives, and (viii) Mr.
Isidorou said the PPC has become “a gong show of racial politics, embarrassing
32
diatribes and social conservative castoffs”. Annexed hereto and marked as Exhibit
“AA” is the results of a search done on Twitter of Mr. Deng on May 15, 2019 which
shows a number of racist tweets posted by Mr. Deng.
50. CBC News ran a story on January 8, 2019, a copy of which is annexed hereto
as Exhibit “BB” reporting that Laura Lynn Tyler Thompson would be running for
the PPC in the Burnaby South riding. The story describes Ms Thompson as a devout
Christian and ardent abortion foe who has dedicated a portion of her life to fighting
what she calls “a global initiative to make the ideology of the LGBTQ well accepted
and taught even in pre-school,”. The story recounts that Thompson ran for a trustee
position on Burnaby's school board on a platform opposing British Columbia's
sexual orientation and gender identity policy, known as SOGI.
51. A column by Bob Hepburn published in the Toronto Star on September 25, 2019,
a copy of which is annexed hereto as Exhibit “CC”, addressed the reaction of some
angry Star readers to learning that the Star editorial board was meeting with Mr.
Bernier. The writer’s view was that the public should know of Mr. Bernier’s views. In
stating that opinion, the writer describes Mr. Bernier as someone who “spreads
discredited lies about climate change”, wants to slash immigration by 50%, erect fences
in places along the US border to block refugee seekers, and wants to impose a
“Canadian values” test on overseas immigration applicants. The writer says that these
positions are what make people brand Mr. Bernier as a racist and that it is important
for voters to understand why and how Mr. Bernier is appealing to “far-right
nationalists and neo-Nazis in our midst”.

33
Former PPC officials allege racism and xenophobia within the PPC
52. The Toronto Star did a story on April 5, 2019, a copy of which is annexed
hereto as Exhibit “DD”. The story recounts that the Star learned of an exodus of PPC
organizers and followers in BC. Daniel Joseph, the a PPC official for a BC district
association, who resigned claiming the PPC had taken on “hateful overtones” and
that he wanted to call out racist, homophobic, xenophobic and “hateful influences”
within the PPC is quoted as follows: (i) “Racists and bigots that spew hatred and
play divisive, political games…need to be called out”, (ii) “the message from party
officials was clear – they were going to embrace this hateful far-right rhetoric -and I
felt like not only was there no longer a place for me in the party but that Canadian
politics doesn’t need a party that strays so far from our democratic institutions”.
53. The CBC published a story on July 18, 2019, a copy of which is annexed hereto
as Exhibit “EE”, which recounts how the entire PPC board in a Winnipeg riding
resigned in disgust, claiming the party was being taken over by racists, anti-Semites
and conspiracy theorists. A resignation letter from the former riding executive says
the board could not sit by as bigoted views hold prominence in public discussions
about the party and that the PPC is attracting supporters who would deny freedoms
to Canadians, close borders and spread false information online. The letter to Mr.
Bernier says: (i) “None of these are things we would have expected you stand beside
during the leadership campaign” (ii) “We are appalled to see it encouraged with a
wink and a nod now”. The story also quotes riding association president Shaun
Martin as saying people believed in Mr. Bernier’s stances against corporate welfare,
supply management and government intervention but that “before long, the party
latched onto racist and anti-immigrant sentiment…” and “We kind of held out hope
that Max would stop just saying that he’s denouncing this stuff and actually take
some action against the people who are doing these things, but we didn’t see any
34
evidence of that, and we just couldn’t stay any longer.”. The story notes that the
PPC did not respond to the CBC’s request for comments.
54. The Toronto Star published a story on October 1, 2019, a copy of which is
annexed hereto as Exhibit “FF”, which recounts how Chad Hudson, a PPC candidate in
Nova Scotia, pulled out of the race and was then subjected to “abuse and hatred” from
the far-right fringe. Mr. Hudson is quoted as saying he resigned due the PPC’s “values
and the choices its leadership have made”, that he had deep concerns about the PPC’s “
Say NO to mass immigration” billboard campaign, and that Mr. Bernier’s attacks on 16
year old climate activist Greta Thunberg were “extremely poor judgment”. Mr. Hudson
is also quoted as saying what Mr. Bernier has tapped into has “awakened something
very dark and dangerous in this country and I don’t want to be a part of it” and that he
would never run as a PPC candidate because he is “sickened” with the style of divisive
politics he believes they are espousing.” The story recounts how the PPC did not
immediately respond to a request for comment and later said it would answer no
questions on the topic.
PPC candidate Jordan Kent alleges homophobia within PPC
55. Global News ran a story on May 9, 2019, a copy of which is annexed hereto as
Exhibit “GG” which recounts that (i) Jordan Kent, who had been running to
represent the PPC in the Oxford riding, alleged that his candidacy was disqualified
in part due to his sexual orientation, (ii) Mr. Kent told Global News that he was
disqualified because: “number 1, I’m LGBT and the second ground is that I brought
forward allegations of homophobia, of election tampering and of meddling in the …
nomination”, (iii) Mr. Kent called Mr. Bernier personally and said “Look, the riding
association has a bias against me because I’m an LGBT activist. They are working
actively to try to spin this election… can you step in?” (iv) Mr. Kent said Mr. Bernier
35
agreed get some help getting an investigation open and would have answers for Mr.
Kent by 7 p.m. the next day, but the deadline passed with no action, following which
his candidacy status was revoked by the PPC on the basis that Mr. Kent had
contravened both a conduct pledge and a non-disclosure agreement.
56. Mr. Kent approached Daisy in May 2019 concerning intolerance associated
with Mr. Bernier and the PPC. Mr. Kent approached us because of our record in
opposing hatred and bigotry. We communicated extensively with Mr. Kent because
the allegations were: (a) a matter of great public interest, given the fact that Mr.
Bernier was seeking the Office of the Prime Minister, and (b) because we wanted to
ensure that we had taken additional responsible steps to validate what had been
written by others about Mr. Bernier and the PPC. Mr. Kent told us that many of the
criticisms of Mr. Bernier and the PPC’s intolerance were true. As Mr. Kent stated to
me in an email dated May 1, 2019: "I even spoke to Maxime Bernier on the phone
and he isn’t addressing this issue as he promised he would.” The issue Mr. Kent
referred to was the illegitimate disqualification of an openly gay PPC candidate.
PPC officials post racist tweets
57. The CBC published a story on June 5, 2019, a copy of which is annexed hereto
as Exhibit “HH”, entitled “People’s Party of Canada slammed for racist tweet from
Burlington account”. In response to a tweet from someone saying they don’t
understand racism because “we only have one race living on this planet, the human
one”, the official Burlington PPC twitter account responded: “not all [people] are
homo-sapien, some are homo erectus”. The tweet also included a series of three
pictures showing people of different racial backgrounds next to images of skulls,
with outdated and offensive labels like ‘caucasoid,’ ‘mongoloid’ and ‘negroid’. The
story quotes PPC spokesman Martin Masse stated that the tweet has nothing to do
36
with the views of the PPC and that the person running the account was removed
from the PPC riding association, but Mr. Masse refused to respond to questions
seeking more information about the person responsible for the tweet or whether the
PPC is concerned about people holding racist views seemingly finding a place in the
party. The story also quotes Kojo Damptey, manager of programs at the Hamilton
Centre for Civic Inclusion as follows: “(i) it is disheartening the tweet came from a
PPC-branded account as that could lend legitimacy to the messages it shares, (ii)
messages like that can act as “dog whistles” for racism by making people feel
comfortable sharing prejudiced views, and (iii) Making comments like that are “code
words for racist ideology, xenophobia and bigotry.”
58. CBC News published stories on September 25, 2019 and September 26, 2019,
copies of which are annexed hereto as Exhibit “II” entitled “Ontario PPC candidate
published racist transphobic tweets” and “Maxime Bernier stands by Ontario PPC candidate
who published racist, transphobic tweets”. The stories recount how: (i) PPC candidate Bill
Capes published tweets earlier in the year which included the following stereotypes
about people of Asian, African and Caribbean descent: “yellow people been working since 5
am, black people up at noon. Lol.” and “… I can’t wrap my head around the whole gender thing.
Either stand or sit where I come from. Hey! Maybe its ME gender confused, cause I don’t get it?
Binary, nonbinary, ah jeez. Mother nature will rule on its eventually, be sure of that.”, (ii) Mr.
Capes at first denied he wrote the tweets but then later admitted he did and apologised
for them, (iii) Mr. Bernier accepted the apology and allowed Mr. Capes to continue to
run for the PPC stating: “After he apologised and after a discussion with him, he is a
full member of our party, because he shares our values and that is the most important
[thing]”. The September 26 story also quotes University of Windsor political science
professor Lydia Miljan referring to Mr. Capes as follows: “ He’s been outed as
37
somebody who has said racist and intolerant things in the past…and they’re not that
long ago”.
59. CBC News published a story on September 30, 2019, a copy of which is annexed
hereto as Exhibit “JJ” which recounts how Brian Everaert, a PPC candidate from Sarnia-
Lambton, tweeted: “Islam is the wart on the ass of the world. People need to either unite
against it or lose all we stand for and believe in. Enough is enough” and how Mr. Everaert
defended the tweet on the basis that it was taken out of context and he is against radical
Islam not Muslims. The story also recounts how Mr. Bernier defended Mr. Everaert
stating that the PPC is not a culturally insensitive party and “Our candidates have the
right to their opinion” and “What’s important is that they [PPC candidates] fight for what
we believe, individual freedom, personal responsibility, respect and fairness”.
60. CBC News published a story on October 3, 2019, a copy of which is annexed
hereto as Exhibit “KK” which recounts how: (i) PPC candidate Mark Friesen shared a
cartoon on Twitter depicting Mr. Singh with a bomb in his turban, (ii) Mr. Friesen said
he didn’t notice the bomb when he shared the cartoon but did not remove the tweet
after it was brought to his attention, (iii) PPC candidate Rob Lussier retweeted the
cartoon 2 weeks before but didn’t recall doing so, and (iv) Mr. Bernier’s campaign office
did not respond to requests for comments about the tweet. The story also quotes Evan
Balgord, the executive director of the Canadian Anti-hate Network on the cartoon: “Of
course its racist”.
61. Global News published a story on October 12, 2019, a copy of which is
annexed hereto as Exhibit “LL” which recounts that Sybil Hogg, a then Nova Scotia
PPC candidate tweeted that Islam was “pure evil” and called for the religion to be
banned in Canada, saying it was not compatible with Canadian values of democracy.
38
The piece states that Mr. Bernier said the tweets were in fact racist, but that Ms Hogg
would not face any consequences for her statements. Mr. Bernier is quoted as stating
“She did a mistake. She’s not against Islam, she’s not against Muslims, she’s with
us. She was speaking about radical Islam and political Islam and she’s still part of
our party. I appreciate her explanation on that”.
Mr. Bernier poses for a picture with Northern Guard member
62. The CBC published a story on July 9, 2019, a copy of which is annexed hereto
as Exhibit “MM” which recounts how Mr. Bernier posed for a picture at a PPC event
with men wearing patches depicting the emblem of the Northern Guard, with one of
the men flashing a hand gesture that the American Anti-Defamation League says has
been used by white supremacists to symbolize white power. The story quotes
Barbara Perry, director of the Centre on Hate, Bias and Extremism at Ontario Tech
University describing the Northern Guard as a hate group that has “crawled out
from under the shadows” and stating about Mr. Bernier: “it’s disturbing. From the
very beginning when he created the party … there was a flood of far-right
nationalists, you know, sort of coming to the party, and he was not very vociferous
in turning them away”. The story quotes Evan Balgord, executive director of the
Canadian Anti-Hate Network, saying he doesn't believe that Mr. Bernier was
ignorant of the group's identity as an offshoot of the neo-Nazi group the Soldiers of
Odin, and also quotes Duane Bratt, a political scientist at Mount Royal University
stating: “This isn't, you know, a mistake or ... an inadvertent gaffe. I think this was
deliberate. [Mr.] Bernier’s been in the public eye a long time, you know, as a cabinet
minister. And he was always viewed as a straight-shooter libertarian and now he’s
just gone full identity politics. And is that just a transformation or is that something
he hid? Or is it a political strategy?”

39
63. CTV News published a similar story on July 10, 2019, a copy of which is
annexed hereto as Exhibit “NN” which quotes the statement from Public Safety
Minister Ralph Goodale’s office in response to the picture of M. Bernier with the
Northern Guard “White supremacy and white nationalism undermine the fabric of
our society. For political leaders to court these views is a terrible mistake; we
condemn Mr. Bernier’s attempt to legitimize this type of hatred.” Martin Masse, the
PPC spokesperson is quoted as saying: “Mr. Bernier does not known the people in
this picture. Mr. Bernier takes hundreds of pictures with everyone who asks at
rallies and wherever he goes. He goes not inquire about people’s views before taking
pictures”. Global News published a story on July 9, 2019 which also reported on the
picture of Mr. Bernier with the Northern Guard, a copy of which is annexed hereto
as Exhibit “OO”.
64. The Northern Guard is a Soldiers of Odin splinter group. The Soldiers of Odin
is neo-Nazi group. They were founded by a neo-Nazi, Mika Rinta, in Finland in
2015. The Soldiers of Odin are one of the biggest neo-Nazi groups in the world.
They are global and are found in the U.S., the U.K., Germany and Canada. They
oppose immigrants and refugees who aren't white. Formed by a number of former
members of Soldiers of Odin, this men-only group state that they want to "defend
the country against its internal enemies."
Mr. Bernier photographed with Paul Fromm
65. Paul Fromm (“Fromm”) is a well-known white supremacist. Indeed Mr.
Bernier concedes Fromm is a white supremacist in in paragraph 26 (g)(a) of his Fresh
as Amended Statement of Claim. Fromm has been described by the Anti-Defamation
League as “a Canadian white supremacist with long ties to his counterparts in the
US”. He has spoken at events hosted by white supremacist group. Fromm has also
40
appeared frequently at annual conferences held by the head of an Arkansas-based
Klan group called the Knights party and has also spoken at Holocaust denial
conferences held by the Institute for Historical Review. Fromm attended David
Duke’s European-American Conference in 2005. Fromm was dismissed as a teacher
in Canada due to his extremist activities, runs a group in Canada called Canadian
Association for Free Expression, which defends racists, anti-Semites and Holocaust
deniers.” Annexed hereto and marked as Exhibit “PP” is an excerpt from the Ant-
Defamation League website describing Fromm.
66. Mr. Bernier posed for a photograph with Fromm in July, 2019. I posted this
picture under the headline “Bernier and his infamous Neo-Nazi Friend” in my July
29, 2019 blog post, a copy of which is annexed hereto as Exhibit “QQ”. In the blog
post, I describe Fromm as perhaps the leading Canadian far Right leader with
decades of involvement with the Canadian organized hate movement including the
Western Guard and the Heritage Front and a myriad of white supremacist and neo-
Nazi groups. My blog also cites the following statement from the Southern Poverty
Law Centre about Fromm:
From 1974 until 1997, Fromm served as a public school teacher with
the Peel Region Board of Education. He was fired from his position
after speaking at several Heritage Front events, one of which fell on
Hitler’s birthday. A video of the December 9, 1990, event captured
Fromm, in front of a Nazi flag, speaking to a crowd shouting “Sieg
Heil!,” “white power,” “Hail the Order!,” and “nigger, nigger, nigger,
out out out,” while performing the Nazi salute.
67. I was not the only person who commented on the photograph. The Hamilton
Spectator ran a story on August 1, 2019, a copy of which is annexed hereto as Exhibit
“RR” which recounts that: (i) Fromm embraces views and beliefs contrary to
41
multiculturalism and tolerance and participates in white supremacist groups and
events, (ii) Fromm was a supporter of Holocaust denier Ernst Zundel, and (iii) PPC
executive director Johanne Mennie did not respond to a request for comment.
68. Huffington Post also ran a story on July 31, 2019 reporting on the Mr. Bernier-
Fromm picture, a copy of which is annexed hereto as Exhibit “SS”. The piece
recounts that Fromm lost his teaching license in Ontario over a decade ago over his
affiliation with white supremacists including former Ku Klux Klan grand wizard
David Duke and is a self-described “white nationalist, a populist, a traditionalist
with libertarian leanings”. The piece also recounts how Ontario Progressive
Conservatives distanced themselves from Fromm after he supported then-leadership
contender Tanya Granic.
69. Following this encounter, Fromm endorsed Mr. Bernier on Facebook and
Twitter as “a federal leader with both the charisma and determination to put
CANADA FIRST” and praised Mr. Bernier’s immigration policies as steps towards
‘regaining control’ of Canada’s border.” (See HuffPost July 31, 2019 cited above).
70. Mr. Bernier never disavowed Fromm’s support or condemned Fromm and his
neo-Nazi views. Instead, he claimed that he did not know who Fromm was when
the picture was taken.
Shaun Walker removed from PPC party after it was reported he was convicted for his
role in attacks by the racist National Alliance
71. A story published by Global News on August 30, 2019, a copy of which is
annexed hereto as Exhibit “TT”, reported that Shaun Walker was removed from the
PPC party after it was reported that Walker had been convicted in Utah in 2007 for
his role in attacks by the National Alliance racist group meant to intimidate
42
minorities. Walker had helped organize a PPC electoral district association in St.
Catharines, Ontario. The story cites tweets by Walker stating the armed forces
systematically discriminates against white males and that immigration is out of
control in Canada and “balkanizing our big cities, lowering our wages and swelling
our welfare class”.
Bernier July 2019 speech: extreme multiculturalism is a very dangerous type of social
engineering and a lie based on the idea that all cultures are equal
72. Toronto.com published a story on July 25, 2019, a copy of which is annexed
hereto as Exhibit “UU”, which reports on a speech Mr. Bernier gave in which he
stated: (i) [in denouncing “mass immigration” and “extreme multiculturalism”]
“these policies would lead to social conflicts and potentially violence. These ideas
have nothing to do with freedom, but rather a very dangerous type of social
engineering”, (ii) official multiculturalism is “a lie based on the idea that all
cultures are equal. A lie destructive of our Western liberal democratic heritage,
traditions and values…”, and (iii) on immigration, a PPC government would focus
on religious minorities in majority-Muslim countries and members of “sexual
minorities” instead of refugees identified by the UN.
73. CBC News published a story on the same speech on July 24, 2019, a copy of
which is annexed hereto as Exhibit “VV” which recounts that (i) Mr. Bernier took
aim at what he called a policy of “extreme multiculturalism” and accused the
Liberals of “putting Canada on a road to destruction” through Prime Minister Justin
Trudeau’s “globalist vision”, (ii) Mr. Bernier said he wants to submit every person
hoping to immigrate to Canada to an in-person interview to answer questions to
determine whether their values and ideas correspond to Canada’s “societal norms”.
43
74. The National Post ran a story on the same speech on July 25, 2019, a copy of
which is annexed hereto as Exhibit “WW”.
Bernier defends PPC candidate calling for “more hate speech”
75. The Regina Leader Post ran a story on July 31, 2019, entitled “Bernier Defends
Sask. Candidate who urged ‘more hate speech’”, a copy of which is annexed hereto
as Exhibit “XX” which recounts how PPC candidate Cody Payant posted on social
media calling for “more hate speech” to stave off a violent backlash to “leftist
authoritarianism” and that Mr. Bernier defended Mr. Payant stating “That candidate
did nothing reprehensible” and that he was satisfied with Mr. Payant’s explanation
that Mr. Payant was taken out of context.
Bernier claims ‘Islamist Extremists’ have infiltrated Canadian Politics
76. HuffPost Canada published a story on August 19, 2019, a copy of which is
annexed hereto as Exhibit “YY”, entitled “Bernier claims ‘Islamist Extremists’ have
infiltrated Canadian Politics”. The story recounts how: (i) Mr. Bernier was responding
to questions about whether he shares the views of Benjamin Dichter, a guest speaker
at the PPC’s inaugural conference, (ii) Mr. Dichter said in his speech that the Liberal
Party of Canada is “infested with Islamiscists”, that Canada is suffering from “the
stench of cultural relativeness and political Islam” and that “Despite what our corporate
media and political leaders want to admit, Islamist entryism, and that is the adaptation
of political Islam, is rotting away at our society like syphilis”, (iii) Mr. Bernier responded
to reporters that Andrew Scheer went out of his way to meet an Islamist extremist
“who tells people how it is good to beat your wife and how to beat them”, to get
their votes. The story then recounts that (i) the PPC delegates gave Mr. Dichter
one standing ovation after another, (ii) Mr. Bernier in his speech noted the PPC is
the only party willing to talk openly about the “Islamist menace”, (iii) Mr. Bernier
44
called the NDP “a zombie party” after its leader, Jagmeet Singh wrote to the head of
the Leaders’ Debates Commission asking that the PPC be excluded from the leader’s
debate because Mr. Bernier’s conduct would risk bringing the debates “into
disrepute” because the PPC “had courted outright racists and promoted far-right
conspiracy theories and that including Mr. Bernier in the debates would give him a
platform to promote his “ideology of hatred and intolerance”.
PPC anti-immigration billboard taken down after public outcry
77. Global News published a story on August 25, 2019, a copy of which is annexed
hereto as Exhibit “ZZ” about a billboard advertisement featuring a photo of Mr.
Bernier and the slogan “Say NO to mass immigration”. The story describes the PPC’s
stance on immigration as controversial and recounts how the billboard company
decided to take it down in response to overwhelming criticism. The story recounts
that Mr. Bernier said he agreed with the billboard’s message, though noted it was
placed by an outside group.
PPC expels a candidate after he asks Mr. Bernier to denounce racism
78. Global News published a story on September 13, 2019, a copy of which is
annexed hereto as Exhibit “AAA” which addresses how the PPC expelled one of its
candidates, Brian Misera, from running in the election after he sent Mr. Bernier an
email asking him to denounce racism and white supremacy. Mr. Misera is quoted
as saying: “I wanted [Mr. Bernier] to do more to make it very very clear that we don’t
represent them, we don’t want their support”. Mr. Misera is also quoted as saying
he supported Mr. Bernier’s platforms and ideas but that he was regularly called a
‘Nazi” and “racist” when campaigning when people found out he was a PPC
candidate and that he became further troubled after seeing people with ties to far-
right groups and ideologies either express support for the PPC or become members
45
themselves. Mr. Misera is also quoted as saying: “I mean, like, we’ve had a couple
of people being outed for being legitimate Nazis, and I just don’t know what to say.
It really smears the whole group”. The story also reports that the PPC claims to have
revoked the candidacy because Mr. Misera admitting to acting as his own financial
agent, a charge Mr. Misera denied.
Mr. Bernier calls 16 year old Greta Thunberg “clearly mentally unstable”
79. In an opinion piece published in the Toronto Star on September 14, 2019 a
copy of which is annexed hereto as Exhibit “BBB”, writer Naomi Klein describes Mr.
Bernier as the leader of the “extremist” PPC and addresses Mr. Bernier’s recent tweet
calling 16 year old climate activist Greta Thunberg “clearly mentally unstable. Not only
autistic, but obsessive compulsive, eating disorder, depression and lethargy, and she lives in
a state of constant fear. She wants us to feel the same”. Ms Klein writes that Mr. Bernier
backpedaled after a ferocious backlash, calling Ms Thunberg “a brave young woman
who unfortunately is a pawn of the climate movement”. Annexed hereto as Exhibit
“CCC” is a copy of Mr. Bernier’s tweet about Ms Thunberg.
Statements by Justin Trudeau and Jagmeet Singh before and at the October 2019
leadership debates
80. In a story published by Global News on September 17, 2019, a copy of which
is annexed hereto as Exhibit “DDD”, in response to learning that Mr. Bernier would
participate in the leader’s debate, Jagmeet Singh is quoted as stating: “‘I think it’s
wrong to give someone like Mr. Bernier the platform to spread hateful and divisive
messages” and Justin Trudeau is quoted as stating: “I look forward to holding [Mr.
Bernier] to account publicly for his intolerant views”.

46
81. Global News published a story on October 7, 2019, a copy of which is annexed
hereto as Exhibit “EEE” entitled “Your ideas are hurtful to Canada: Singh tells
Bernier …”. The story reports on the October 2019 leadership debate and a back and
forth between Mr. Bernier and Jagmeet Singh during which Mr. Singh said that its
one thing for someone to say things that you disagree with “But when you incite
hatred, when you incite division…you don’t deserve a platform and I’m happy to
challenge you on that, because your ideas are harmful to Canada”.
82. The National Observer also published a story on October 7, 2019, a copy of which
is annexed hereto as Exhibit “FFF” reporting on the leadership debate. The story states
how Mr. Bernier wasted little time putting his new exposure to use, tossing out an
incendiary anti-Semitic slur when he declared “the other leaders on this stage are
globalists”.
83. The term “globalist” is an anti-Semitic slur. The Anti-Defamation League’s
Jonathan Goldblatt, for example, told The Atlantic in March 2018 that “the term
originates from a reference to Jewish people who are seen as having allegiances not
to their countries of origin, but to some global conspiracy.” and that its disturbing
when public officials “literally parrot this term which is rooted in prejudice”.
Annexed hereto as Exhibit “GGG” is a copy of the March 14, 2018 Atlantic article
quoting Rabbi Barenblat.
84. In October 2020, Halie Soifer – executive director of the Jewish Democratic
Council of America – told the Israeli newspaper Haaretz that the term was “a code
word used by anti-Semites to describe Jews.” Annexed hereto as Exhibit “HHH” is
a copy of the October 21, 2020 Haaretz article.

47
85. In October 2018, Rabbi Rachel Barenblat wrote in Forward : “ ’globalist’ is a
term with an anti-Semitic history, and it’s often understood as code for ‘Jews’, so this
language is activating and traumatizing for a lot of Jews.” For politicians to use the
“globalist” slur “is both chilling and horrifying,” Barenblat wrote. Annexed hereto
as Exhibit “III” is a copy of the October 24, 2018 Forward article quoting Rabbi
Barenblat.
Press discovers that the leader of a US neo-Nazi group, a former Soldiers of Odin
member and a Pegida Canada official were among the people who officially
registered for the PPC when it was formed
86. A story published by Global News on September 23, 2019, a copy of which is
annexed hereto as Exhibit “JJJ”, reported that the leader of a US neo-Nazi group, a
former Soldiers of Odin member and a Pegida Canada official were among the
people who officially registered for the PPC when it was formed. The story contains
a quote from Evan Balgord the executive director of the Canadian Anti-hate
Network: “These people speak to who is really excited about the [PPC] … It’s become
impossible to separate the PPC from this kind of white supremacist ideology.” The
story recounts that: (i) Shaun Walker, Janice Bultje and Justin L. Smith were among
the names officially registered by the PPC when it applied to register as a party, (ii)
Walker was a member of the National Alliance who was removed from the party a
month earlier, (iii) Ms Bultje is an active member of Pegida Canada, and (iv) Evan
Balgord the executive director of the Canadian Anti-hate Network describes Pegida
as an anti-Muslim group. Annexed hereto as Exhibit “KKK” is an excerpt from
Pegida Canada’s website which explains that PEGIDA is an acronym from the
German which, translated into English, means “Patriotic Europeans against the
Islamization of the West.”, most chapters have kept this name to show solidarity,
and PEGIDA was founded in Dresden, Germany in October 2014 by citizens

48
concerned about “the increasing Islamization/Globalization of our western
cultures”. The story also recounts that: (i) Justin L. Smith confirmed that he was
formerly active in the Soldiers of Odin, (ii) the Sudbury Star reported M. Smith was
president of the Soldiers of Odin in Sudbury as recently as September, 2017, the
Soldiers of Odin appeared in 2015 as a Finnish anti-immigration group closely tied
to the racist far right, and (iv) a 2017 Canada Border Services Agency intelligence
report said it had members that “adhere to extreme right-wing ideology and are not
afraid to use violence”.
Press reports founding member of Canadian Nationalist Party works security for Mr.
Bernier
87. The Vancouver Star ran a story on October 10, 2019, a copy of which is annexed
hereto as Exhibit “LLL” which recounts that: (i) Darik Horn, who works personal
security for Mr. Bernier, is a founding member of the Canadian Nationalist Party
(“CNP”) – a newly minted political party that advocates for white nationalism, (ii) Mr.
Horn began supporting the PPC after volunteering for white nationalist Faith Goldy’s
failed 2018 mayoral bid in Toronto, (iii) the CNP specifically advocates to maintain a
demographic majority of European heritage in Canada and wants to re-write the
constitution to replace multiculturalism with “ethnic nationalism (iv) Edwin Hodge, a
University of Victoria professor specializing in right-wing extremist movements and
white supremacist activism in North America, said the CNP’s stance on a European-
descent majority is a “dogwhistle” that allows the party to espouse a message to a
particular group without treading into hate speech. “It’s a politically correct way of
saying he wants to maintain a white ethnostate,” Hodge said of … the CNP, and (v) Mr.
Bernier did not respond to multiple requests for comment.

49
Mr. Bernier tweets that all cultures and values are not equal
88. On October 15, 2019, Mr. Bernier tweeted: “There is no place for radical Islam
in Canada. We need a values test to screen out potential immigrants who share this
barbarian ideology. The multiculturalist left refuses to recognize it, but all cultures
and values are NOT equal”. Annexed hereto as Exhibit “MMM” is a story published
by Narcity on October 15, 2019 reporting on the tweet.
PPC loses the election and Election Commentary
89. The federal election took place on October 21, 2019. The PPC was resoundly
defeated. It did not win a single seat in Canada with no other PPC candidate other
than Mr. Bernier winning more than 4% of the vote in his or her riding. Mr. Bernier
was defeated in his own riding.
90. The Conversation published a story by Arvind Magesan, an Associate
Professor of Economics at the University of Calgary on October 14, 2019, a copy of
which is annexed hereto as Exhibit “NNN” in which Professor Magesan analysed
the PPC’s immigration platform which includes the notion “immigrants should not
put excessive financial burden on the shoulders of Canadians”, describing it as a
commonly used justification for tightening immigration. Professor Magesan showed
how based on available data, immigrants do not put a financial burden on
Canadians. Professor Magesan concluded that the PPC case for immigration reform
cannot be an economic one and that ”as such, Bernier and his PPC should not be so
surprised when they are accused of xenophobia and racism by the media and other
political parties”.
91. Foreign Policy published a piece by Justin Ling on October 20, 2019, a copy of
which is annexed hereto as Exhibit “OOO”. The story states “As head of the [PPC],
50
Bernier is singing from the hymnal of modern populism – illiberal, anti-
immigrant…His movement is buoyed by white supremacists and conspiracy
theorists. He is campaigning against the very idea of Canada’s multicultural state,
vowing to obliterate its immigration levels and roll back the clock on transgender
rights …”. The story recounts how Mr. Bernier narrowly lost the CPC leadership
race in 2017, released a preview chapter of a book he was writing on his time in
politics and got swiftly demoted and then states “That’s when Bernier suddenly
discovered two things: Twitter, and his hatred for multiculturalism…While Bernier
spent some time talking about race and religion before, suddenly they appeared to
be his only concerns.” The story recounts that: (i) Far-right groups, such as the
Canadian chapter of the Finnish group Soldiers of Odin and the Quebec-based La
Meute, have generally gravitated toward Mr. Bernier, (ii) Mr. Bernier was slated to
show up at a far-right rally on Parliament Hill where anti-immigrant groups and
self-styled militias such as La Meute and Soldiers of Odin came together to protest
their conspiratorial understanding of a United Nations migration compact and how
had Mr. Bernier showed up, he would have spoken after the leader of Stram Kurs, a
far-right Danish party committed to banning the Quran, (iii) the right-wing Rebel
Media produced friendly coverage of Mr. Bernier – the outlet having become
notorious internationally by giving a platform to homegrown racists such as Faith
Goldy, Gavin McInnes and Laura Southern, as well as imported ones, such as
Tommy Robinson and Kate Hopkins.
92. The National Observer published an opinion piece on October 29, 2019, a copy
of which is annexed hereto as Exhibit “PPP”. The piece addresses how despite the
PPC’s rout in the election, it would be foolish to see Mr. Bernier’s loss as a victory
over the far-right. In the piece, Nora Loreto comments: (i) “Bernier successfully
51
transformed fringe, extreme or otherwise insignificant groups into a cohesive
national group that has mainstream expression”, (ii) “The PPC gave organized
racists a vessel through which to reach average Canadians. The PPC attracted social
media ranters and ravers who spew Islamophobia, racism, transphobia and sexism”,
(iii) “The far-right in Canada, organized through the Yellow Vests, the Proud Boys,
the Soldiers of Odin and others, found their political expression in Bernier’s party.
They finally had a party that would lie about illegal immigration on the national
airwaves of the public broadcaster”, and (iv) “his interview on CBC Radio’s The
House allowed Bernier to argue that housing prices in Toronto and Vancouver are
so high due to immigration, a claim that is a total lie”.
93. In an opinion piece published by CBC News on November 13, 2019, a copy of
which is annexed hereto as Exhibit “QQQ”, Messrs. Stanger Ross and Schmidtke
comment that the PPC has an ideology “of exclusionary, anti-immigrant
nationalism” and “contends that immigrants threaten to forcibly change the cultural
character and fabric of our country” and that the Multiculturalism Act should be
repealed to “ensure social cohesion”. The writers also comment that: “ This mash-
up of anti-globalism, hostility to immigrants, and cultural nationalism draws from
an international populist Right.” and “The ideology of the PPC, and not recent
immigration, constitutes a threat to the social cohesion and unity of Canada.”
ACTIONS BY MARK BOURRIE
94. Mr. Bourrie is co-counsel to Mr. Bernier. I met Mr. Bourrie in 2000, during the
federal election campaign, when he was working as a journalist. Mr. Bourrie later
became a lawyer. For more than two decades, as a writer and a lawyer, Mr. Bourrie
has targeted me with an extraordinary campaign of harassment and abuse – ranging
from defamatory statements, to vandalizing my Wikipedia entry, to actually

52
circulating online the pleadings in my divorce proceeding. I believe his involvement
in this action is part of his ongoing effort to silence and punish me for my views, and
for my public participation in Canadian politics. Below I have detailed some, but by
no means all, of the various attacks Mr. Bourrie has made on me over the years.
95. In 2006, Mr. Bourrie stated on a website he controlled that I had committed
crimes as part of the sponsorship scandal. I sued for a retraction, apology and
damages, all of which I obtained. Mr. Bourrie thereafter posted the following on his
web site: “The manner in which my January 14, 2006 blog entry was worded made it seem
that Mr. Kinsella had been a party to illegal conduct when this was clearly not the case. I
apologize without reservation to Mr. Kinsella for that error on my part.”
96. In January 2007, Bourrie sent me an email that stated: “Kinsella, By the way,
I’m shopping myself around to Earnscliffe, Reid, Navigator, et al as a free witness in
their libel actions against you. I will get up in front of a jury and tell them about all
the evil shit you've done to me, going back ten years now, how you've tried to
‘ratfuck’ me, tried to ruin my life, etc. It will show what an evil, obsessive
psychopath you are. I'll stand there, with my cute little kids watching, and tell about
how you tried to paint their dad as an anti-semite, and they'll cry, I'm sure, when I
remind the court that their great-grandfather was murdered in a Nazi camp. And I'll
do all that to you before my case gets to court. You've been warned. Mark”
97. In late 2012, I worked as a volunteer for the Ontario Liberal leadership
campaign of Sandra Pupatello. Pupatello lost to Kathleen Wynne, as is well known.
Thereafter, in January 2013, I was sent flowers to my office with an unsigned card
that stated: “Sorry to see your career die at such a young age. Hopefully interesting new
challenges await in the used car sales profession.” I was advised by a journalists who
53
worked in the Parliamentary Press Gallery with Mr. Bourrie around that time, and
believe, that Mr. Bourrie sent the card and flowers.
98. In June 2013, an individual in my firm received the following comment by Mr.
Bourrie on her Facebook page: “Maybe Warren’s ex-wives and children could form
a choir and sing at various churches and social events. In all seriousness, if some
band had named Warren in a song about his rat-fucking [sic], he would have sicked
his drummer/lawyer on them. Warren is a classic bully and renowned fool.” Mr.
Bourrie was obliged to apologize for the comment.
99. In August 2013, Mr. Bourrie posted comments on Twitter, and added the
Twitter handles of national journalists: “kinsella lies about McG expense question,
Deflower ad, police protection nonsense” and “kinsella lies.” He was obliged to delete
these postings.
100. Furthermore, in August 2013, Bourrie made postings on his
“warrenkinsellasux” website about Daisy clients, in a manner designed to cause
them and Daisy embarrassment.
101. In October 2013, Mr. Bourrie offered copies of the pleadings in my divorce
action on a website he then owned, called “WarrenKinsellaSux”[sic]. At that time,
he maintained what he called “Warren Kinsella archives.” The relevant post,
offering my ex-wife’s pleadings, stated that it was posted by Mr. Bourrie. When I
wrote that Mr. Bourrie was doing so, he changed the post to thank me for sending
him “traffic” and that the pleadings were “flying out of here.”
102. In October 2013, Mr. Bourrie threatened Media Temple with multiple libel
notices because they then hosted my personal website. In the same month, Mr.
54
Bourrie made a written criminal complaint against me in Ottawa with the Ontario
Court of Justice. He stated thereon that “ACCUSED HAS ENGAGED IN LIBEL
UNDER SEC 301 CRIMINAL CODE OF CANADA.”
103. Also in October, 2013, Mr. Bourrie sent me an email stating: If you do not
remove the defamatory material about me from your web page, I will attend at a
Justice of the Peace Tuesday and swear out a complaint of criminal libel against you
under the Criminal Code of Canada.
104. In December 2013, I received a letter from the Law Society of Upper Canada,
as it then was, to advise me that Mr. Bourrie had made a complaint against me in
October 2013 but that it did not even require me to respond to the complaint and it
did not intend to pursue the matter further at this time.
105. In July 2019, Bourrie wrote on his “Fair Press” blog that the 2019 federal
election campaign and my involvement with the Green Party meant that “the election
is going to be one of the ugliest ever.” A few weeks later, in October 2019 and in relation
to this action, Mr. Bourrie wrote on his personal Twitter account: “Warren Kinsella
says his ratfuck of Bernier's party is protected by solicitor-client privilege. I hope the Law
Society of Ontario picks up on that and asks just what kind of law was Kinsella doing.”
106. As the foregoing perhaps makes clear, Mr. Bourrie has been engaged in an
aggressive and over-the-top campaign of harassment against me for several years.
His involvement as counsel in this action is yet another step in his campaign to
silence and punish me.

55
ACTIONS BY ANDRE MARIN
107. Mr. Marin is co-counsel to Mr. Bernier. Previously, he was an Assistant
Crown Attorney in the Ottawa courthouse. At that time, I was a legal reporter for
the Ottawa Citizen. Later, Mr. Marin became the Ombudsman of Ontario, based in
Toronto. For much of his tenure, I was a newspaper columnist and media
commentator, also based in Toronto. As such, I started to receive information about
Mr. Marin’s conduct from all three political parties in the Ontario legislature, and
also the Office of the Speaker and I would occasionally write about that on my
various media platforms.
108. Most often, I posted articles from the Toronto Star, National Post and Globe and
Mail and other media about Mr. Marin’s extravagant use of public funds, giving a
friend a $250,000 contract without competition; using public resources to hire
detectives to follow employees and forcing the departure of some 70 Ombudsman’s
Office employees during his tenure.
109. Occasionally, I would offer commentary on Mr. Marin’s performance, but
most often would simply quote what media had published about him.
110. In May 2015, Mr. Marin – again making use of public resources, and while still
Ombudsman of Ontario – made a formal complaint against me to the Law Society of
Upper Canada. I responded, at length, arguing inter alia that – as in this action –
Marin was using the force of the law and public resources to silence a critic. In
August 2016, after Mr. Marin had lost his Ombudsman position, his complaint
against me was dismissed by the Law Society.

56
44
111. Mr. Marin's involvement as counsel in this action is

yet another step in h1f.
campaign to silence and punish me.
SWORN REMOTELY at the )

City of Toronto, in the )
Province of Ontario (the affiant )
being in Hillier, Ontario) )
this 15th dav of Aoril, 2021
,' L )
in accordance with 0. Reg )
431/20 Administering Oath )
or Declaration Remotely )
�
)
A Commissioner for Taking Affidavits Warren Kinsella

David Shiller
57
EXHIBIT “A” to the Affidavit

of Warren Kinsella,
sworn April 15, 2021
Type text here

A Commissioner for taking affidavits, etc.
58
Justin Trudeau for leader! Okay, maybe not

MARGARET WENTE
PUBLISHED APRIL 5, 2012
Justin Trudeau is no girlie-man. And everyone who thought he was is eating crow. On
Saturday, he knocked out a Conservative. In the history of politics in Canada, it was a
epic moment.
Take that, Ezra Levant! The irritating host of Fox (oops, Sun) TV predicted that the
charity boxing match between Justin Trudeau and Patrick Brazeau would be a rout. The
slimmer, lighter Justin would wind up on the mat – and henceforth be known as Justine.
But the pretty boy surprised them all. Mr. Brazeau, the beefy senator with the military
training and a black belt, turned out to have a glass jaw and the wind of a two-pack-a-
day man. By the end, his nose was gushing blood. If the referee hadn't stopped the
match, Justin would have turned him into hamburger.
And now, male pundits with a liberal bent can't stop gushing over Justin.
"It is not just Patrick Brazeau thinking today that he seriously underestimated this guy,"
marvelled one scribe. Justin is no lightweight mamma's boy. He's his father's son after
all! He can cold-cock his opponents without breathing hard. At last, the Liberal Party's
salvation is at hand.
"It may come to be seen as Justin Trudeau's defining career moment," wrote Lawrence
Martin, who linked Justin's determination in the ring to Pierre's steely courage when he
faced down a pack of rampaging separatists. The Toronto Star's Thomas Walkom also
conjured up a heroic image. "Like his father, Justin left little to chance. While exuding
insouciance, he trained hard for the match. And, as with his father, that training and
discipline paid off."
Of course, the separatists were trying to break up the country. Mr. Brazeau, who is a
rare combination of Conservative and aboriginal, is a patronage appointment to the
Senate with an ego bigger than his biceps. Personally, I wasn't sorry to see him lose.
But the stakes weren't quite as high.
Before this week, I confess I'd never thought of pugilistic prowess as proof of leadership
potential. Then again, I'm not a guy. Guys regard politics as combat by other means
(which may explain why so many women don't want to play). As Warren Kinsella, a
sometime Liberal strategist, wrote after the match: "Politics, stripped down to its
essence, is like boxing. Get in a ring, beat each other to a bloody pulp as people sit on
the sidelines and cheer."
With charming candour, Mr. Kinsella revealed that "whenever I set up a political war
room … I tell the assembled youngsters their loathing of conservatives is a purifying
59
force. 'Let it wash over you,' I tell them. 'Step on their necks, and don't lift your foot until
the day after the election. Hurt them.' "
Justin can hurt them. It feels soooo good! Or can he?
Personally, I'm not convinced that the daunting Trudeau name and spirit would be quite
the asset that aging eastern Liberals seem to hope. The Trudeau name makes them
nostalgic for the glory days of their long lost youth. But it reminds Westerners of why
they hate the East. Justin's dad did more than anyone else to stoke the fire of western
alienation, which led to where we are today. Millions of westerners would cast their vote
for the Great Satan before they'd vote for anyone named Trudeau.
I feel sorry for Justin. Like most sons of powerful and successful men, he's doomed to
dwell in the shadow of his famous father. He should have gone into another line of work.
But all his life, people have been telling him he has the stuff.
Justin strikes me as a decent enough guy – expressive, warm and good-looking, like his
mother, but also completely innocent of the qualities necessary to revive the fortunes of
a party that doesn't have a clue what it should stand for any more. He's also from
Quebec, which is a fatal liability. The economic and political power of the country have
all gone west.
What the Liberals really need is not a handsome fellow with a famous name. They need
a manly-girl from Alberta. Those gals can outpunch them all.
60
EXHIBIT “B” to the Affidavit

of Warren Kinsella,

61
COMMISSAIRE AUX ELECTIONS FEDERALES
Protected A
January 8, 2020 Our file# 2019-1445
Mr. Warren Kinsella

Daisy Consulting Group
89 Bloor Street West, Suite 300
Toronto, Ontario
M5S lMl
Dear Mr. Kinsella:
I am writing in relation to allegations concerning the Daisy Group's activities related to the
43rd federal general election. These allegations were reported in the media and resulted in
complaints to our Office. All complaints received by the Office of the Commissioner of
Canada Elections are reviewed to determine whether they raise issues under the Canada
Elections Act (the Act). Based on the outcome of our review and the information available,
we have determined that neither you nor the Daisy Group contravened the Act. We now
consider the matter closed.
-operation during our review process.
Mylene Gigou
Director of Investigations
30, rue Victoria, Gatineau (Quebec) K1A 0M6 30 Victoria Street, Gatineau, Quebec K1A 0M6
rsr. 1-855-759-6740 Telec.: 819-939-1801 I www.cef-cce.ca I Tel: -1-855-759-6740 Fax: 819-939-1801
62
EXHIBIT “C” to the Affidavit

of Warren Kinsella,

63
(http://warrenkinsella.com)

ABOUT (/ABOUT) WRITINGS (/WRITINGS) DONATE (HTTP://WWW.FACEBOOK.COM/PAGES/WARREN-KINSELLA/301372599878283)
(HTTPS://TWITTER.COM/KINSELLAWARREN)
I’m sorry, but this (https://www.thestar.com/news/canada/2017/01/24/oleary-leads-as-tories-gain-ground-on-liberals-new-poll-shows.html)is

awesome:
Kevin O’Leary is the far-and-away front-runner for the Conservative leadership as the Opposition party gains slightly on the Liberals in
overall voter preference, according to a new poll.
O’Leary, the celebrity businessman who entered the Tory leadership race last week a ter months of signalling a potential campaign, is the
top choice to lead the party for 27 per cent of poll respondents. e survey found he had more than twice the support of runner-up
Maxime Bernier, the Quebec MP and former minister who scored 11 per cent.
Here’s why:
• Conservatives grew in only one province in 2015 – Quebec – but they prefer a guy who doesn’t speak a word of French
• Conservatives prefer a far-Right reality TV show moron at the precise moment that far-Right reality TV show morons are spurring protests around
the globe involving millions
• Conservatives prefer a Boston resident who, like that other Boston resident they spent untold millions to demonize, is “just visiting”
If they had any intelligence, they’d pick Raitt, Chong or a Bernier.
ey don’t have any intelligence. ey’re O’Losers.
Like 10
CuJoYYC says:
If O’Leary wins the leadership of the CPC, who will resign their seat in Boston so he can run in a by-election?
Just asking for a friend.
Reply (http://warrenkinsella.com/2017/01/olaughable/?replytocom=287614#respond)
Matt says:
Dude……………
It’s a Forum poll.

Worse yet, it’s a Forum poll done for the Conservative Party of Canada hating Toronto Star.
64
Mike says:
e honourable member from Beacon Hill
Matt says:
It should also be noted that this poll includes Canadians in general, not just Conservative Party members. ey did however break it down further to respondents who
claimed they were Conservative supporters
doconnor, a slave to pompous scientism (https://doconnor.transsee.ca/) says:
is poll doesn’t mean much. e real question is how many party members have him as a second or thrid choice.
BlueGritr (http://warrenkinsella.com) says:
Wondering how it’s possible that unilingual O’Leary wins the federal Conservative leadership? He’s a non-factor in 110 ridings, where 50 per cent or more of the voters speak
French. Secondly, O’Leary is late to the dance, which means he has to play big time catch-up in selling party memberships. His only other course of action is to poach from
other candidates. A few may let him. But I bet front runners like Leitch, Chong, Scheer, O’Toole and Bernier are going to ght hard to hold onto their base of support. O’Leary’s going to
be embarrassed by how badly this plays out for him, and he’s going to head back to Boston with his tail between his legs. And deservedly so.
Ridiculosity says:
O’Leary can run. But he can’t hide…
“Oesterlund later testi ed that their marriage was a “rocky ride ever since the start,” but Pursglove blamed their new lifestyle. Somewhere along the way, she told me, Oesterlund had
fallen in with a tribe of wealthy globe-trotting nomads and minor celebrities. He befriended Kevin O’Leary, a judge from “Shark Tank,” she says, and partied at the Maya-themed Lyford
Cay estate of Peter Nygard, the Finnish-Canadian retail mogul. Oesterlund’s money and his boat attracted hangers-on and women, Pursglove says.
By his wife’s account, some of Oesterlund’s new friends also began tutoring him in how to minimize his taxes. He traveled constantly, Pursglove says, in part to reduce the amount of
taxes he would be required to pay to any of the countries where he owned a home…” – How to Hide $400 Million, New York Times Magazine http://nyti.ms/2j11Sel
(http://nyti.ms/2j11Sel)
Richard says:
You have to feel for Kellie Leitch and her 22 letters in all of this. She entered this race hoping to be Canada’s Donald Trump; turns out she’s Ben Carson.
Jason Inness says:
I took out a CPC membership to vote in the leadership election. I won’t be voting for Kevin O’Leary. I don’t hate the man, but Bernier seems to have the most new ideas,
whether they become platform items or not. And Bernier, at least from out here in the Canadian colony of New Brunswick, seems to have the best ground organization,
which counts in these things. I predict it will be Bernier that wins, but I don’t have the political experience that Warren Kinsella has.
Warren (http://warrenkinsella.com) says:
I don’t have the political experience that Warren Kinsella has. at means you are smart!
bluegreenblogger says:
I do not watch TV. I do not think that someone who has never held o ce, or even worked in any form of community service, is quali ed to be a dog catcher. I certainly do not
think that reality TV is a strong background for the reality of politics. I am surprised that anybody would think otherwise.
Ronald O'Dowd says:
Kevin,
So you’re scally and economically conservative and socially liberal. So let’s see how you play the game. Maybe you might have a good swing and maybe not.
65
The Doctor says:
A not-very-meaningful poll. Completely ignores the mechanics and rules of the race, which are extremely important. Furthermore, O’Leary’s numbers are goosed by name
recognition. Anyway, I’m Tory-sympathetic and would never vote for the guy. Would personally favour Bernier, Chong, Raitt or O’Toole.
Miles Lunn says:
at is more a case of name recognition. Amongst actual paid up party members, his path to victory while not impossible won’t be easy. ose who have signed up to support
an existing candidate aren’t likely to switch and there isn’t a whole lot of time to sign up new members. Add to the fact he is likely to get destroyed in Quebec as he doesn’t
speak the language. I suspect that one of the following will be the next leader: Bernier, Chong, O’Toole, Raitt, or Scheer, but we shall see.
Leave a Reply
Your email address will not be published. Required elds are marked *
Comment
Name *
Email *
Website
CAPTCHA Code *
Post Comment
BREAKING
66
© 2021 Copyright Warren Kinsella

4/13/2021 Trudeau Can't Coast On Youth And Charisma Alone In Next Election | HuffPost Canada Politics
67
Legal Disclaimer
THE BLOG
Trudeau Can't Coast On Youth And Charisma Alone In

Next Election
05/ 16 /2017 12:10pm EDT | Updated May 16 , 2017
ADVERTISING
https://www.hufﬁngtonpost.ca/warren-kinsella/trudeau-bernier-signh-federal-election_b_16638952.html 1/6
68
02:11
NDP leadership candidate Jagmeet Singh

takes aim at Trudeau
69
Trudeau better get going on all three fronts.
Follow HuffPost Canada Blogs on Facebook
70
EXHIBIT “D” to the Affidavit

of Warren Kinsella,

4/12/2021 Maxime Bernier on Twitter: "1/ Trudeau keeps pushing his “diversity is our strength” slogan. Yes, Canada is a huge and diverse country. This diversity …
71
https://twitter.com/MaximeBernier/status/1028800406535716864 1/4
4/12/2021 Maxime Bernier on Twitter: "1/ Trudeau keeps pushing his “diversity is our strength” slogan. Yes, Canada is a huge and diverse country. This diversity …
72
https://twitter.com/MaximeBernier/status/1028800406535716864 2/4
73
EXHIBIT “E” to the Affidavit

of Warren Kinsella,

74
Maxime Bernier criticizes Liberals for

'extreme multiculturalism'
'Trudeau's ... cult of diversity will divide us into little tribes,' Quebec MP says
John Paul Tasker · CBC News · Posted: Aug 13, 2018 1:39 PM ET | Last Updated: August 13, 2018
The man who nearly bested Andrew Scheer in the last Conservative leadership race is
condemning the Liberal approach to multiculturalism, warning "ever more" diversity is
leading to the ghettoization of minorities and fostering a culture of government
dependence.
Quebec Conservative MP Maxime Bernier sent a series of tweets Sunday taking aim at
Prime Minister Justin Trudeau for what he says is dangerous sloganeering about
"diversity" that threatens to undermine Canada's social cohesion.
"Trudeau's extreme multiculturalism and cult of diversity will divide us into little tribes
that have less and less in common, apart from their dependence on government in
Ottawa. These tribes become political clienteles to be bought with taxpayers $ and
special privileges," Bernier tweeted.
"Having people live among us who reject basic Western values such as freedom,
equality, tolerance and openness doesn't make us strong. People who refuse to
integrate into our society and want to live apart in their ghetto don't make our society
strong."
Some social media commentators condemned the sentiment of his tweets as racist and
xenophobic.
A spokesperson for Scheer told CBC News that Conservatives celebrate the
contributions of all Canadians regardless of their racial or ethnic origins — and issued a
statement that did not address Bernier's criticism of "more diversity" specifically.
75
"Canada has been built by people from all over the world coming here to enjoy the
freedom, prosperity and equality that our country offers. Conservatives will continue to
recognize and celebrate the contributions made to Canada from people from diverse
backgrounds that have enriched our history and our society," said Brock Harrison,
Scheer's director of communications.
Harrison said Bernier is still a member of the Conservative caucus.
In a followup tweet sent Monday, Bernier said he was not criticizing diversity per se but
rather "more diversity" in Canada.
"Canada has always been a diverse country and this is part of who we are. I love this
Canada. But there is a difference between recognizing diversity and pushing for ever
more of it. Something infinitely diverse has no core identity and ceases to exist," he
tweeted.
Some of Trudeau's comments on diversity have been a lightning rod for criticism from
some on the right wing of Canadian politics.
Notably, in an interview with the New York Times Magazine in 2015, Trudeau said
Canada has "no core identity" and "no mainstream" adding he sees Canada as the "first
post-national state."
His critics pounced, branding these comments as political correctness gone awry.
'Canada is successful because we respect diversity'

Trudeau has long been a vocal promoter of Canada's cultural diversity as a source
of strength, something that differentiates the country from other Western nations that
have grappled with anti-immigrant political movements.
"Canadians understand that diversity is our strength. We know that Canada has
succeeded — culturally, politically, economically — because of our diversity, not in spite
76
of it," Trudeau said shortly after his election in 2015, a message that he has frequently
repeated.
It is not the first time Bernier has taken to Twitter to voice his opposition to the Liberal
approach to diversity. He sparred with Liberal Ontario MP Celine Caesar-Chavannes,
who is black, for thinking "the world revolves around your skin colour" as opposed to
pushing policies that help all Canadians.
Conservative Ontario MP Erin O'Toole, another caucus member who vied for the party's
leadership last year, took issue with Bernier's approach to diversity saying the
Conservative Party has a strong tradition of tackling racial and ethnic barriers. The
Multiculturalism Act was passed in 1988 by the government of former PC prime minister
Brian Mulroney and the party had the first Chinese, Greek, Ukrainian and Japanese MPs.
"Today our country faces challenges, but to suggest the challenges are because of
"diversity" — either too much or too little — is simplistic & shows a disconnect with our
past and present," O'Toole tweeted.
"Canada is a successful country because we respect diversity and have had, by and large,
a rules-based system that treats individuals fairly, regardless of their personal
backgrounds. Conservatives have always understood this and will continue to fight to
protect it."
Lisa MacLeod, Ontario's minister in charge of immigration, said Monday she does not
agree with Bernier's take on diversity saying she's proud to represent a multiethnic
riding in Ottawa.
"I am not sympathetic to Maxime Bernier, never have been," she said.
MacLeod first backed Ontario MP Lisa Raitt, and then ultimately Scheer, for her party's
leadership over Bernier.
77
"Ontario is a welcoming society, it has been built by its diversity, I personally represent a
riding in the nation's capital which is one of the most diverse in the province, that I
believe brings in rich cultural experiences for all of us," she told reporters in Ottawa.
Bernier has also butted heads with Scheer on the issue of supply management. Bernier
has vocally condemned the policy that uses quotas to control the amount of some
products produced by farmers to ensure national supply matches expected demand.
In June, Bernier released a chapter of his new book on supply management, in which he
accuses Scheer of winning the party's leadership due to the support of "fake
Conservatives" who were only interested in voting against Bernier's candidacy because
of his opposition to supply management in the dairy sector.
He was later removed from Scheer's shadow cabinet where he had served as the party's
industry critic.
Bernier maintains a following among Conservative activists — paying off his leadership
campaign debts in August after a series of successful email fundraising campaigns.
78
EXHIBIT “F” to the Affidavit

of Warren Kinsella,

4/11/2021 Adam Vaughan MP on Twitter: "@MaximeBernier @CTVNews Your statements are "unacceptably" racist. @MaximeBernier criticized "diversity", and then "more diversity" and then invented "radical multic…
Tweet Search Twitter 79

Explore Maxime Bernier @MaximeBernier · Aug 13, 2018
1/ This title is unacceptably misleading, @CTVNews. I did not criticize
Settings “diversity” but rather “more diversity,” and “ever more diversity” as
Trudeau is proposing with his radical multiculturalism.
CTV News @CTVNews · Aug 13, 2018
Diversity will 'destroy' what makes Canada great: Conservative MP
@MaximeBernier ctv.news/O1tnj2l #cdnpoli
619 1K 2.3K
Adam Vaughan MP
@TOAdamVaughan New to Twitter?
Replying to @MaximeBernier and @CTVNews Sign up now to get your own personalized timeline!
Your statements are "unacceptably" racist. Sign up
@MaximeBernier criticized "diversity", and then "more
diversity" and then invented "radical multiculturalism" as
something to fear. The only thing "destroyed" is your Relevant people
credibility. All with "your words" Adam Vaughan MP Follow
11 02 AM · Aug 13, 2018 · Twitter Web Client @TOAdamVaughan
Member of Parliament / Spadina—
34 Retweets 4 Quote Tweets 237 Likes Fort York / Toronto / Parliamentary
Secretary for Housing / #SpaFY
(pronouns -he/him/his)
Maxime Bernier Follow
@MaximeBernier
This Tweet was deleted by the Tweet author. Learn more Chef du @ppopulaireca / Leader of
the @peoplespca
This Tweet was deleted by the Tweet author. Learn more CTV News Follow
@CTVNews
Show replies Tweeting breaking news from
CTVNews.ca in the CTV National
Ian Troop @IanTroop_ · Aug 13, 2018 newsroom. RTs do not constitute
Donʼt miss whatʼs happening
Replying to @TOAdamVaughan @MaximeBernier and @CTVNews
People on Twitter
endorsement ofLog
views.
in Sign up
Adam -arewellthestated.
first toThis
know.
attitude is deplorable, but shared by too many.
F
https://twitter.com/TOAdamVaughan/status/1029020295363997697
i th ti t I th ht C di b d th "T i " 1/7
Fear is the motivator. I thought Canadians were beyond the "Trumpian" Whatʼs happening
dog whistles - I thought wrong. Search Twitter 80
2 3 Premier League · 2 hours ago
Explore Show replies Tottenham Hotspur vs
Manchester United
Settings Mouthy Gurl @mouthygurl · Aug 13, 2018 Trending with #TOTMUN, McTominay
Replying to @TOAdamVaughan @MaximeBernier and @CTVNews Politics · Trending
You should force him to apologize publicly #Ramadan
48.4K Tweets
Mr Marco Critelli @MarcoCritelli7 · Aug 13, 2018 Politics · Trending
Replying to @TOAdamVaughan @MaximeBernier and @CTVNews Taiwan
Spoken by a true liberal....they know whats good for us....we all know 42.7K Tweets
that...right! Premier League · 26 minutes ago
1 1 8 Sheffield United vs Arsenal
Trending with Ceballos
Adam Vaughan MP @TOAdamVaughan · Aug 13, 2018
it's not a question of good vs bad. We are a diverse nation. Fighting it, is Golf · LIVE
like arguing with the wind The Masters Tournament 2021
4 1 4 Trending with #themasters ,
Zalatoris
Show replies
Stephen Harris @Brokerstephen · Aug 13, 2018 Show more
Replying to @TOAdamVaughan @MaximeBernier and @CTVNews Terms of Service Privacy Policy Cookie Policy
Not sure criticizing diversity is of itself racist but I do know what "virtue Ads info More © 2021 Twitter, Inc.
signalling" means Adam. How about you?
7
This Tweet was deleted by the Tweet author. Learn more

David Robert @bigbobby53 · Aug 13, 2018
So how many brown people is too many for you?
10 5 53
Show replies
Lynne Hooker @lynnemorvirat · Aug 13, 2018
Replyingaretothe@TOAdamVaughan
People on Twitter first to know. @MaximeBernier and @CTVNews Log in Sign up
So
https://twitter.com/TOAdamVaughan/status/1029020295363997697
says the dyed in the wool NDP to the core now Liberal Considering 2/7
So says the dyed in the wool NDP to the core now Liberal. Considering
you betrayed everything you stood for as an NDP to run to the Liberals Search Twitter 81
when JU$tin beckoned, how can anyone believe you have any credibility
??
Explore 7
Settings Geoppetto Hosseltoff @Geoppetto · Aug 13, 2018
You used to have a voice that I respected, Adam. Then you decided to sell
yourself to Trudeau and Liberal group think.
Now your voice is just part of the noise.
Muted.
2
BeyondOldfashioned @Karen22912 · Aug 13, 2018
Ohhhhh Adam!
GIF

People on Twitter are the first to know. Log in Sign up
https://twitter.com/TOAdamVaughan/status/1029020295363997697 3/7
82
EXHIBIT “G” to the Affidavit

of Warren Kinsella,

83
Sign vandalized after MP Maxime Bernier

calls out Winnipeg park for 'extreme
multiculturalism'
Pakistani group wants to send message to Bernier and his supporters after
'hurtful, saddening' act
Ian Froese · CBC News · Posted: Aug 17, 2018 6:29 PM CT | Last Updated: August 18, 2018
Days after Conservative MP Maxime Bernier singled out a Winnipeg park named after a
Pakistani leader in an attempt to demonstrate that multiculturalism has gone too far, the
park's new sign was vandalized.
Masroor Khan, who campaigned to give the new park its name, was told Friday that the
sign bearing that name — Jinnah Park — was knocked off its perch and left lying against
a tree.
The discarded wooden stumps suggest the sign's poles were sawed off.
"It's very hurtful and saddening to see," said Khan, standing metres from where the sign
once stood in Winnipeg's South Pointe community.
He wants to send a message to Bernier, his supporters and everyone else in Canada that
hatred has no place in this country. The city's Pakistani community will host a
celebration of diversity at the park on Sunday.
"We should be giving a message of peace and love as a revenge, as an answer," said
Khan.
In a tweet posted Tuesday, Bernier suggested it was an odd dichotomy that

Victoria would take down a statue of Canada's first prime minister, Sir John A.
Macdonald, as Winnipeg recently dedicated a park to Muhammad Ali Jinnah, the
founder of the modern state of Pakistan.
84
Bernier described it as an example of "extreme Liberal multiculturalism."
The former Conservative leadership contender also argued that the partition of India,
which led to the creation of Pakistan in 1947, killed nearly one million people. Bernier's
remarks, made on Pakistan Independence Day, came after a series of his tweets last
weekend was roundly disparaged for stoking racist and xenophobic tensions.
He has since defended himself by tweeting he did not intend to criticize diversity
itself, but rather "ever more of it."
Members of his own party have tried to distance themselves from the controversial MP,
including Ontario Conservative Sen. Salma Ataullahjan, who is Pakistani-Canadian.
She said she's received hateful comments after suggesting her colleague's remarks were
not merely offensive, but an attempt to divide Canadians of Pakistani origin from other
Canadians.
Some detractors told her to leave the country and, in the worst comment, a newspaper
columnist insisted she betrayed her great-grandfather, who fought for India's
independence from British rule prior to the creation of Pakistan.
"People who follow Maxime, who have other agendas, are taking it to the next level and
this needs to stop," she told CBC News on Friday.
"If a small corner in a park is named after somebody, how is that offensive? How does
that lead to abuse? This has to stop somewhere."
After receiving pictures of the sign's damaged foundation on Friday, she blamed
"divisive rhetoric" for prompting the vandalism.
Ataullahjan also said the untoward attention clearly inflamed some people who are
critical of the country's diversity.
Inciting hatred
85
"There's a lot of people who will just get incited by this kind of stuff and that's exactly
what happened," she said. "What I was afraid of has happened."
Bernier did not respond Friday to a request for comment.
Conservative Leader Andrew Scheer walked back from Bernier's comments earlier this
week when he said the Quebec MP does not speak for the party on any issue.
Although Khan feels attacked by the targeted vandalism, he said is not threatened
because he knows the act embodies the opinions of only a few people.
He says his neighbours are welcoming. Only days ago, Khan said he and other
Pakistanis attended the inauguration of Shaheed Bhagat Singh Park in Bridgwater Trails,
named after a revolutionary who fought for India's independence. Indian-Canadians
who supported that naming bid attended the grand opening of Jinnah Park this May, he
said.
"We're building in harmony for a better Canada."
Winnipeg police said as of late Friday afternoon, it has not received a police report
about the vandalized sign, which has been cleaned up by city staff.
In response to Bernier's remarks, people of all cultural backgrounds have been invited to
Jinnah Park, south of Tim Sale Drive at Northern Lights Drive, beginning at 4 p.m. local
time on Sunday for a show of Canada's diversity, hosted by the Pakistani Students'
Association and the Pakistani Association. The event will include live music, bouncy
castles and ethnic foods.
Khan expects hundreds of people to attend. He said the formal ceremony will start at 6
p.m.
86
EXHIBIT “H” to the Affidavit

of Warren Kinsella,

87
MP Maxime Bernier quits 'morally corrupt'

Conservatives, plans to start new party
Conservative leader says Bernier was more occupied with advancing his own
profile than the needs of the party
Catharine Tunney · CBC News · Posted: Aug 23, 2018 11:05 AM ET | Last Updated: August 23, 2018
Divisive Quebec MP Maxime Bernier made a scorched-earth exit from the Conservatives
today, while announcing plans to start his own federal party.
Bernier, who represents the riding of Beauce, made the announcement Thursday in
Ottawa as the party's policy convention kicks off in Halifax.
"I have come to realize over the past year that this party is too intellectually and morally
corrupt to be reformed," he said, on the heels of controversial tweets he
posted regarding diversity.
"I know for a fact that many in the caucus privately oppose supply management, but
buying votes in a few key ridings is more important than defending the interests of
Canadians."
Bernier said he plans to talk to Elections Canada on Friday and his goal is to head a
party that runs candidates in all of Canada's 338 federal ridings.
"We'll have a lot of Canadians, and that new party will win the next election."
Canada's dairy supply management system has been a consistent sticking point
for Bernier, but in his takedown of the party, he also attacked Conservative Leader
Andrew Scheer for supporting retaliatory tariffs against the United States.
"I'm the only one in the House who is against a trade war and the only one in the House
who is for Canadian consumers," he said.
88
Bernier has caused waves on the national scene — and within his own
party — for recent tweets regarding Canada's diversity. They have been labelled
xenophobic by some commentators, while others view them as the start of a much-
needed debate over Canadian identity and the role of immigration.
Bernier said he spoke to Scheer nine days ago and made his decision to leave the party,
adding the leader is consumed with "polls and focus groups."
Scheer, who narrowly beat Bernier at last year's leadership convention, said the
former cabinet minister was more occupied with advancing his own profile than the
needs of the party.0:49
"Today Maxime made a choice," he told reporters in Halifax. "He decided today to help
Justin Trudeau."
"I always challenged him to put personal ambition aside and to concentrate on common
ground that all Conservatives can rally around.… Not once did he come to me or my
team with ideas for the issues he's raising."
Harper: Bernier 'seeks only to divide Conservatives'

Leading up to Bernier's announcement, some prominent Conservatives rallied
around Scheer.
Former prime minister Stephen Harper, who helped secure the historic merger of
the Canadian Alliance and the Progressive Conservatives that formed the modern-day
Conservative Party, says the party needs to move forward.
"It is clear that Max never accepted the result of the leadership vote and seeks only to
divide Conservatives. His decision today allows the Conservative Party of Canada to
move forward united behind our leader," he tweeted.
89
Ontario Premier Doug Ford tweeted support for Scheer, while Kory Teneycke, the former
director of communications for Harper and a Bernier supporter in the leadership
race, penned an op-ed for the Toronto Sun backing Scheer for prime minister.
Rachel Curran, Harper's former director of policy, put it more bluntly.
"I hope Justin Trudeau and his cabinet colleagues are breaking out the champagne in
Nanaimo this morning," she tweeted, saying that the Prime Minister's Office
has "secured an easy win in 2019 despite a mostly terrible summer."
Speaking in Nanaimo, B.C., after the conclusion of his federal cabinet retreat, Trudeau
refused to be drawn into the Conservative infighting.
"Our government is focused on giving answers to the questions that Canadians have,
and on demonstrating that we're entirely focused on them," Trudeau told reporters. "I'm
going to let Conservatives focus on themselves, as they are right now. We're going to
remain focused on Canadians."
Earlier this summer, Bernier was banished from the Tories' front bench and stripped of
his role as innovation critic.
At the time, a Conservative MP who spoke to CBC News on the condition he not be
identified said Bernier was removed because of his decision to post a chapter from his
book on his website. The MP wrote that Scheer's victory as party leader was owed to
"fake Conservatives" who only joined the party to defend supply management in the
dairy industry.
Peter d'Entremont, who sits on the board of directors of the Libertarian Party of Canada,
said it tried to court Bernier to leave the Conservative Party and join its cause, but he
wasn't interested.
90
EXHIBIT “I” to the Affidavit

of Warren Kinsella,

91
In Maxime Bernier, Canada’s far-

right finds a mouthpiece
August 28, 2018 at 3:18 p.m. EDT
Nora Loreto is a Canadian freelance writer and author of “From Demonized to

Organized: Building the New Union Movement.”
On the evening of Oct. 3, 2016, Maxime Bernier posted a classic black and white photo
from the 1979 movie “Mad Max.” Bernier’s head was photoshopped over Mel Gibson’s.
“Some people like to call me Mad Max …” wrote Bernier, in French. “They may think
that it’s an insult. But let me tell you something: it’s true. I’m furious.”
He was well into his leadership bid for Canada’s Conservative Party, and the Mad Max
moniker stuck. It has been resurrected in the past few days, as Bernier announced his
resignation from the Conservative Party to found a new, far-right political party.
The reaction to his decision from his fellow caucus members was unanimously negative.
Conservative MP Michelle Rempel told Canada’s national public affairs channel CPAC:
“Well, if he works as hard as he has in the Conservative Party, we don’t have a lot to
worry about.” Erin O’Toole, also an MP, who came in third in the Conservative
leadership race, told CBC Radio’s the Current, Bernier is “consistent in being
inconsistent.”
It’s unlikely that Bernier’s new party will have much electoral success, outside of
reelecting Bernier. But Bernier isn’t seeking electoral success alone.
Bernier was the runner-up in the Conservative Party leadership race in 2017, and his
second-place finish was decided by a handful of points. His new obsession with so-called
identity politics was not a hallmark of his campaign then. Instead, he ran on his deep
libertarian ideals, such as eliminating taxes and Canada’s milk management system.
Bernier’s beliefs are extreme, even for the Conservative Party. With not many supporters
and few plans, it looks as if his party’s primary goal will be to create a team to support
his libertarian economic views. Immigration scaremongering is the populist cover for
his overall program.
On Twitter, he has called immigration a burden. He declared that the era of “political
correctness” was over, a tweet that was written in both English and French (a gesture
that is arguably the most politically correct way in which to engage in politics in
Canada). He has picked fights with Liberal MP Celina Caesar-Chavannes, at one
point saying, “You think the world revolves around your skin colour.” Caesar-Chavannes
is one of Canada’s few black lawmakers.
It was perhaps easy to miss Bernier’s anti-immigrant rhetoric during the 2017
Conservative Leadership race. The sixth-place finisher, Kellie Leitch, made her
campaign almost entirely about demonizing immigrants. But Bernier’s recent Twitter
rants are identical to the policy platform that he issued during the race.
92
Bernier’s gamble is whether anti-immigrant sentiment will be enough to woo people to

his new party and then support his other priorities. He is walking a path that has been
laid by Canadian far-right groups for years now. Since the Liberal Party victory in 2015,
there has been a surge of anti-immigrant, white supremacist organization and activity
across Canada. These groups have successfully been able to torque numbers and confuse
facts about refugees, migrants and immigration.
There are few politicians better situated than Bernier to shamelessly seize on this
rhetoric. Bernier wins elections with consistently high margins. Like Justin Trudeau and
Ontario Premier Doug Ford, Bernier has leveraged the popularity of his father, a
longtime politician from the same riding he has represented since 2006. The riding of
Beauce is extremely monocultural: Only 1.45 percent of residents are immigrants, and of
the 107,180 residents captured in the latest census, only 70 people reported that their
mother tongue is not English or French (and only 785 reported it was English).
All members of the Beauce Conservative riding association except one resigned in
support of Bernier. “They say that they vote for Maxime in the same way they voted for
his father,” reported CBC News’s Catou MacKinnon from Beauce. With an airtight lock
on his seat, Bernier is free to do what he thinks will make the biggest impact on the
Conservative Party.
Even though he has been in office for 12 years, most English-speaking Canadians know
Bernier as the guy who left sensitive government documents at his then-girlfriend’s
apartment in 2008. She had been formerly involved with organized crime. Most French
Canadians know Bernier as the son of his father. In both languages, Bernier isn’t famous
for being a capable and sophisticated operator.
There’s no compelling proof that his prowess as a politician will get his new far-right
party off the ground. But in an age when the far right is becoming more and more
mainstream, it would take very little for Bernier’s plan influence and shift rhetoric even
further to the right. An untethered mouthpiece who is using the rhetoric of the far right
to score political points is bad news, if you care about the quality of Canada’s national
political debates.
93
EXHIBIT “J” to the Affidavit

of Warren Kinsella,

94
Canada gets its own right-wing populist

party
October 3, 2018 12:04 PM CST BY ELIZABETH ROWLEY
TORONTO—Maxime Bernier, a recently defeated Conservative Party

leadership candidate, and a former Foreign Affairs Minister under
Stephen Harper who left his top secret files with a girlfriend who
consorted with the Hells Angels, has left the federal Tories to form the
“People’s Party of Canada.”
Already christened the “anti-people’s party” by progressives, Bernier’s

policies are consistent with the hard-right policies advocated by most of
the candidates in last year’s Tory leadership race. These include sharp
attacks on Muslims, immigrants, and diversity coupled with demands for
deep cuts to immigration and foreign aid, and testing for “Canadian
values.”
Bernier also wants to cut the corporate tax rate from 15 percent to 10
percent, eliminate the capital gains tax which mainly benefits the
wealthy, while slashing income taxes on the wealthiest. He wants
balanced budgets—on the backs of working people.
With this in mind, Bernier advocates privatizing healthcare, airports, and

Canada Post, for starters. He also wants to get rid of the supply
management system which has kept family farms afloat in Canada’s dairy
and poultry industries, instead of bankrupt as is happening to many
family dairy farms in the U.S. northwest. He opposes equalization
payments that are intended to address uneven development across
Canada and guarantee equal access to universal social programs and
Medicare.
Bernier wants more free trade deals like NAFTA and CETA that destroy
jobs and drive down wages while undermining sovereignty and
democracy. He also wants to eliminate inter-provincial trade barriers
95
which have protected workers’ wages and working conditions to some

degree against the power and greed of the biggest national and
transnational corporations.
Bernier opposes action on climate change and the Liberal government’s

carbon tax in the first place; never mind that it has done nothing more
than put a price on carbon emissions.
He has a special place in his heart for gun owners, who he says have been
harassed and should be reimbursed for property loss from previous
government ‘gun grabs’. Bernier’s government will “respect the rights of
firearms owners”—but not women’s right to choose. Bernier proposes a
free vote on abortion rights in Parliament.
One of the first to praise the new party is the leader of the Libertarians,
who wants a merger of the two parties. But Bernier’s interests lie
elsewhere for the present, as he works to shear off Tory MPs, members,
and donors to support his fledgling party and re-form the political right
in Canada on a more populist and right-wing base.
True to form, Bernier has launched his party with a sharp attack on his
former colleagues, calling the Conservative Party “morally
corrupt.” Possibly the only thing Bernier has said that has a ring of truth
to it, the criticism was not about the past, but about the future. Bernier’s
criticism is that the Tory caucus is unwilling to adopt the stance and
policies of far-right parties like the Republicans to the south, or even
more right-wing parties in Europe.
His new political party is evidently willing and anxious to provide just
such an alternative in Canada. Whether it will wither away or—like the
Reform Party or Wild Rose in Alberta—re-invent the Conservative Party
in an even more reactionary direction, remains to be seen.
But what is concerning for progressives is this public call to action by

one of the most right-wing politicians in the country. Coupled with the
election of the Doug Ford government in Ontario, the victory of the right-
wing CAQ in Quebec’s October 1 election, and the likely win for Jason
96
Kenney’s Tories in Alberta next spring, the outlook for the federal
election next fall is anything but, to use Prime Minister Trudeau’s word,
“sunny.”
Working people across Canada are struggling with widespread

unemployment and precarious work, stagnant wages, and declining
purchasing power, unable to afford either post-secondary education or
housing, carrying massive debts while falling further and further behind.
Anger is growing at a political system and Parliament that are unable or
unwilling to address these massive problems. These are the people who
are most vulnerable to the siren call of the Doug Fords, the Donald
Trumps, and the Francois Legaults, who declare themselves against “the
elites” and “for the people,” but who neglect to mention that it’s the rich
and the corporations they actually represent.
Exposing these reactionary political forces for what they really represent
is half of what’s required today. The other half is to mount a real fight for
policies that will meet people’s needs for jobs and rising wages and living
standards; for peace, and for a progressive majority in Ottawa that will
fight to deliver those policies.
That’s the job for the next 12 months leading up to the federal election.
What we get on election day will depend on what the labor and
democratic movements do in the months before October 2019.
We can be absolutely certain that the corporations and reaction will use
every minute of this time to consolidate and strengthen their positions
and their favored parties in the months ahead.
The Canadian Labour Congress must take up the challenge, working with
its social and political allies, to make the issues and the solutions visible,
and to mobilize public support for policies and a parliamentary majority
that puts people’s needs before corporate greed, for peace, for
environmental action, and for curbs on corporate power.
97
That’s the best answer to Bernier, and to the Tory Party he came from
which continues to represent the most powerful and reactionary forces
in Canada today.
98
EXHIBIT “K” to the Affidavit

of Warren Kinsella,

99
Maxime Bernier goes to a dark place

JOHN IBBITSON
PUBLISHED NOVEMBER 12, 2018
Maxime Bernier wants to win the Canadian Trump vote.
In a speech on Saturday at a conference hosted by the right-wing Rebel Media in

Calgary, the leader of the new People’s Party of Canada questioned the science of climate
change, pilloried the United Nations and insisted immigrants to Canada must embrace
“Western civilization values.”
His language was not as extreme as Donald Trump’s – this is Canada, after all – but he
made it perfectly clear, at least to this listener, that the implicit motto of the People’s
Party is: Canada First. For however many believe that the Canadian economy and social
fabric are being undermined by environmentalists, do-gooders and immigrants, Mr.
Bernier promises he will be their voice.
The party, which the Beauce, Que., MP founded in September after deciding Andrew
Scheer’s Conservatives had become too centrist, is making good progress. Its leader has
laid to rest accusations that he lacked the discipline or public support to craft a working
political party with national reach. Mr. Bernier claims to already have signed up 33,000
supporters with PPC riding associations organizing across the country.
In some ways, Mr. Bernier is simply a Conservative in a hurry, with his proposals to
lower taxes, eliminate corporate subsidies, deregulate the telecom sector, cut funding to
the CBC and privatize Canada Post.
But in front of a friendly crowd, his vision grows darker.
First, he pledged, “I am the only politician in Ottawa who promises to take Canada out
of the Paris accord” to fight global warming. He acknowledges that most scientists
believe human activity is responsible for climate change, but "there are also scientists
saying other factors, like the sun, have more impact.” Regardless, “we are not going to
destroy our economy on that subject.” Climate-change deniers will feel very much at
home in the People’s Party.
Second, Mr. Bernier is committed to “abolishing foreign aid and saving the $5-billion
that we spend every year to help Canadians instead.” Canada under the People’s Party
would have “a foreign policy that focuses on security and prosperity of Canadians, not
on pleasing a dysfunctional United Nations.” Even Mr. Trump hasn’t proposed
completely eliminating foreign aid, although he would doubtless warm to the idea if he
thought he could get away with it.
Third, and darkest, “our immigration policy should not aim to forcibly change the
cultural character and social fabric of our country,” he told the audience. Immigration
100
levels should be reduced, and immigrants must “adopt widely shared Canadian values,
Western civilization values,” he maintained.
“On issues such as immigration, multiculturalism, diversity, [the Conservatives] are

simply not willing to push back against the dominant left-wing narrative,” Mr. Bernier
declared, “and they are afraid to create controversies. I’m not afraid.”
The day before, at a party rally in Calgary, Mr. Bernier was asked how he would stem the
tide of migrants crossing the Quebec border illegally. He replied, that if he were prime
minister, “it will be easier for me and for us to sit with Donald Trump to have a
discussion about that.” That’s probably true.
And if there were any doubt about the buttons Mr. Bernier intends to push in the
months ahead, on Sunday, he tweeted a video of crowds in Pakistan protesting the
release of Asia Bibi, a Christian who had been convicted of blasphemy. “Radical
multiculturalism is the misguided belief that all values and cultures can coexist in one
society,” he tweeted. “They cannot. We must protect our society against this kind of
barbarism.”
No credible voice in this country seeks to undermine the values and beliefs embedded in
the Charter of Rights and Freedoms, and in the fabric of Canadian society. Immigrants
and refugees come here in search of a future protected by those values and beliefs. Mr.
Bernier is simply stoking irrational fears of a threat that does not exist. It is pure
Trumpism.
Not everything Mr. Bernier advocates would please the President. The People’s Party
Leader is, for one thing, an ardent free-trader.
But in his attacks on multicultural diversity and tolerance, he echoes – in a typically

attenuated, Canadian way – Mr. Trump’s rhetoric; he stokes the anger Mr. Trump seeks
to stoke.
In terms of splitting the vote, Mr. Bernier’s insurrection may be a problem for the
Conservative Party. But in terms of what he believes and who he represents, they’re well
rid of him.
101
EXHIBIT “L” to the Affidavit

of Warren Kinsella,

4/11/2021 "We must protect our society against this kind of barbarism" (from:maximebernier) - Twitter Search / Twitter
"We must protect our society against this kind of barbar New to Twitter? 102
Explore Top Latest People Photos Videos Sign up now to get your own personalized timeline!
Sign up
Settings Maxime Bernier @MaximeBernier · Nov 11, 2018
Radical multiculturalism is the misguided belief that all values and
cultures can coexist in one society.
Search filters
They cannot.
We must protect our society against this kind of barbarism. People
From anyone
AFP News Agency @AFP · Nov 9, 2018 People you follow
VIDEO: Thousands of supporters of Islamist parties take to the streets Location
of Karachi to protest Asia Bibi's acquittal and call for her beheading.
Bibi, a Pakistani Christian woman who spent eight years on death row Anywhere
for blasphemy was freed from jail Near you
Advanced search
Whatʼs happening
Premier League · 3 hours ago
Tottenham Hotspur vs
Manchester United
Trending with #TOTMUN, McTominay
0 44 2.6M views Politics · Trending
Whistler
564 2.1K 4K 2,657 Tweets
Politics · Trending
CERB
2,528 Tweets
Science Insider · 5 hours ago
How NASA captured this
breathtaking image of a sea of
People on Twitter are the first to know.
dunes on Mars
Log in Sign up
Premier League · 58 minutes ago
https://twitter.com/search?q="We must protect our society against this kind of barbarism" (from%3Amaximebernier)&src=typed_query 1/2
4/11/2021 "We must protect our society against this kind of barbarism" (from:maximebernier) - Twitter Search / Twitter
Sheffield United vs Arsenal 103

Trending with #COYG, #SHUARS
Explore Show more
Settings Terms of Service Privacy Policy Cookie Policy
Ads info More © 2021 Twitter, Inc.

People on Twitter are the first to know. Log in Sign up
https://twitter.com/search?q="We must protect our society against this kind of barbarism" (from%3Amaximebernier)&src=typed_query 2/2
104
EXHIBIT “M” to the Affidavit

of Warren Kinsella,

105
What I learned at a People’s Party

of Canada rally
November 19, 2018 5.58pm EST; Brian Budd
On a brisk November evening at a golf course in the Toronto suburb of

Etobicoke, supporters of Canada’s newest federal political party, the People’s
Party of Canada (PPC), met for a rally hosted by its leader, Maxime Bernier.
Bernier has been embarking on a cross-country tour to publicize his newly
founded right-wing party and to share his political message with voters ahead
of the 2019 federal election.
The previous Calgary stop of Bernier’s tour included a speaking engagement at

an event hosted by The Rebel Media. In his speech, Bernier outlined his plan
to limit the number of immigrants accepted to Canada, reform policies aimed
at addressing climate change and eliminate government interventions
impinging on free markets.
Bernier’s speech, which included targeted attacks against “radical

multiculturalism,” climate change science and foreign aid, prompted political
commentators to compare Bernier to Donald Trump.
The Etobicoke rally, held in the heart of what’s known as Ford Nation,
represented one of Bernier’s first attempts to sell his brand of right-wing
populism in Ontario.
More importantly, the rally provided an opportunity to gather first-hand

insight into how Bernier is crafting his populist message to appeal to
Canadians and the intersections between the People’s Party and far-right
political movements.
Unique ideological blend of populism

Bernier’s self-reinvention into a populist is a recent development for the
corporate lawyer-turned-politician from Québec. For the majority of his
political career, Bernier has served as one of Canada’s most vocal and
prominent libertarians, championing free-market economics and personal
responsibility within the ranks of the Conservative Party of Canada.
This principled commitment to libertarianism is part of his new party’s

ideology. During his speech in Etobicoke, Bernier made clear to his supporters
106
that he does not believe in “big fat government” restricting their individual
liberty and economic prosperity.
His libertarian ideology is clearly reflected in the People’s Party platform that
includes scrapping Canada’s supply management system, ending all corporate
subsidies, reducing the overall size of government and liberalizing both
international and interprovincial trade.
However, the People’s Party is not a purely libertarian party. Blended into
Bernier’s rhetoric and the party’s platform are proposals that reflect the
ideological tenets of a populist radical right, defined by a commitment to
xenophobia.
Bernier has woven xenophobia and nativism into his appeals to Canadians by
denouncing “extreme multiculturalism” and stating a desire to institute a
“Canada first” foreign policy that would see Canada reduce its commitments to
humanitarian organizations and causes.
Courting the support of the far right

Bernier’s blending of his libertarian beliefs with an embrace of radical right-
wing populism is aimed at Canada’s far right groups and supporters.
Among those in attendance at Bernier’s rally was controversial media figure

and failed Toronto mayoral candidate, Faith Goldy. Goldy is well-known on
the far right as an advocate for the conspiracy theory of white genocide and
her attacks against Islamic culture and immigrants.
Goldy’s attendance should come as no surprise. Bernier has courted the

support of the far right as a way to generate initial public support and
publicize his party in the lead-up to the 2019 election.
Bernier has received glowing coverage from The Rebel Media, appearing at its
events and being interviewed by its employees. The Rebel is closely associated
with far right leaders and activists like Goldy and Gavin McInnes, leader of the
misogynistic, pro-violence Proud Boys.
There’s no doubt Bernier is aware of these associations and is actively seeking

to build a base for his party around The Rebel’s subscribers.
Part of a global movement

107
Bernier’s stance against “extreme multiculturalism” mirrors similar rhetoric

used by radical right-wing populist parties in Europe.
These parties have found support by couching their opposition to

multiculturalism and immigration within the language of liberalism and civic
values. In other words, instead of openly calling for racial or ethnic
discrimination, these movements base their appeals to voters on civic values
of tolerance, diversity and liberal citizenship as a way to justify excluding
supposedly intolerant and reactionary immigrant populations and cultures.
This closely resembles the strategy currently being used by Bernier and his
new party. The party explains its opposition to multiculturalism on the
grounds that immigrants should be forced to adopt “Canadian values”,
including a respect for the equality of men and women, tolerance for diversity
and a respect for Canadian law.
Bernier appears to be gathering support around other issues championed by

the global far-right political movement. At the rally in Toronto, mentions of
mainstream Canadian media outlets and journalists produced spontaneous
chants of “fake news” among those in attendance.
The crowd was similarly enthused by condemnations of political correctness in

Bernier’s speech.
What does it mean?
Firstly, it shows the far right movement does not stop at political borders and
is very much alive and well in Canada.
Second, it appears that subscribers to far right ideas and beliefs may be
viewing Bernier and the People’s Party of Canada as a viable pathway to
mainstreaming their xenophobic and nationalistic beliefs in Canada.
Crafting a narrative
The final takeaway from Bernier’s rally is that he and his new party are
attempting to suggest they represent an organic movement spreading across
the country.
While the People’s Party of Canada is not the first Canadian political party to
brand itself as a movement, projecting this narrative of grassroots growth will
play an important role in certifying the populist credentials of the party and
attracting more supporters.
108
The party appears to be on track to run candidates in all federal ridings in

2019, and says it’s already established riding associations in 101 of 338
electoral districts. It also says it’s recruited more than 30,000 founding
members from across the country.
The creation of riding associations shows Bernier is building the electoral

infrastructure to run as a mainstream political party in the next federal
election.
But no one should conflate the creation of riding associations and well-
attended rallies as indicative of growing national support.
Polling data collected by the CBC indicates that the People’s Party currently
has the support of 1.7 per cent of Canadians, and that if the election were held
today, it could win one seat.
These low polling numbers suggest that Bernier may be headed toward
the same fate as other recent right-wing politicians, like Kellie Leitch, who
have attempted to integrate xenophobic and nationalist rhetoric into their
appeals to Canadians.
Bernier will likely have to distance himself from the cultural and racially
tinged components of his platform to generate the necessary support to win
seats under Canada’s first-past-the-post electoral system.
Interestingly, unlike his appearance in Calgary, Bernier’s speech in Etobicoke

did not include any discussion of “extreme” or “radical” multiculturalism, and
the issue of immigration received only passing mention.
Time will tell if this omission is a shift away from xenophobic rhetoric for
Bernier. Regardless, the People’s Party of Canada’s dual commitment to
libertarianism and radical right-wing populism provides no straightforward
path to electoral success.
Perhaps the party will be able to shave off votes from the Conservatives. But if
Bernier allows it to be a conduit for xenophobia, nativism and white
supremacy, his support will remain confined to the fringes of Canadian
society.
109
EXHIBIT “N” to the Affidavit

of Warren Kinsella,

110
White Supremacy in Halifax
Maxime Bernier and the People's Party of Canada come to town.

By Alex Macnab
To understand the growing right-wing movements in this province, I subjected myself to

the convention for Maxime Bernier’s People’s Party of Canada at the Atlantica Hotel in
Halifax on Friday, January 18. Fully aware of the United States’ MAGA movement and
the disgusting politics of the alt-right, I was still not prepared for what I was about to
see.
Make no mistake, this event was a white supremacy rally.
The former Conservative Party member kicked things off as expected, declaring war on
“supply management” and “corporate welfare,” talking about ending federal
equalization payments, expressing a deep desire to cover Canada from coast to coast in
pipelines, all to a mostly muted response from the crowd. Taking advantage of the
silence, Bernier introduced his next topic.
“I want to speak about immigration.” The room shook as the crowd erupted into wild
applause, hooting and hollering with rabid enthusiasm. Bernier didn’t stop at
denouncing illegal border crossings, going further to attack legal immigration and
describe a nightmare policy proposal that sounded like an incredibly difficult and
exploitative path to citizenship. He implored that a reduction in the number of
immigrants is not only important to the Canadian economy, but also in maintaining
“Canadian values” and “Western civilization” for the next 20 to 50 years.
It was around this time that I could overhear hateful comments from the crowd. An
older man a few feet away indiscreetly whispered something about “learning the
language” to a nearby onlooker.
Bernier could not contain his own glee as he watched the crowd scream in
excitement. He closed out by borrowing Trump’s familiar phrase, “Let’s make Canada
great again!” But before he could finish saying “make” the entire audience joined in
unison and it led to the second-biggest applause of the night. A few other moments
gained traction during the 60-minute dog whistle: defunding CBC, privatizing Canada
Post and ending foreign aid. Climate change wasn’t up for debate—it wasn’t mentioned
once.
This was not just a handful of internet trolls or NCA members either. I caught glimpses
of the security guard’s fire-safety compliance app and saw the room reach 300 people;
many were forced to stand. This was echoed by Bernier’s shocking enrolment stats—
34,000 new PPC party members in four months compared to the 20,000 members
currently registered with the 35-year old Green Party of Canada.
If the number of people was overwhelming, the diversity was not. The room was around
111
97 percent white and 94 percent male. There were the expected 80-plus, silver-haired,
white men with their crested blazers, but there was a staggering number of young
Canadians who emerged from their parents’ basements to attend as well. Halifax’s most
famous Faith Goldy supporter, Matt Whitman, was also there. While Bernier thanked
each person for coming out, the controversial city councillor was elated during his turn
at shaking hands with the new party leader.
Describing some of the people in attendance sounds like a joke, but right-wing hate
groups also appeared to be well represented. The combination of faux-motorcyclists
with a cash bar made me wonder if the hotel would even have been safe for a counter
demonstration. To be clear, these people were not joking.
The PPC convention painted a bleak and terrifying picture for the future of the Canadian
political landscape. We live at a time in which we are continually confronted by the
failures of liberal capitalism and are increasingly presented with only two solutions:
egalitarian, international socialism; or fascist and barbaric white supremacism. The
latter has now found a party, a leader and is seeking candidates to run in Nova Scotia for
this year’s upcoming federal election.
112
EXHIBIT “O” to the Affidavit

of Warren Kinsella,

113
114
115
116
BERNIER - and - KINSELLA et. al.
Plaintiff Defendants
Court File No.: CV-20-82717
ONTARIO
Proceedings Commenced at OTTAWA
MOVING PARTIES' MOTION RECORD
Volume I
SHILLERS LLP
Barristers and Solicitors
Suite 402
197 Spadina Avenue
Toronto ON M5V 1K4
Phone: (416) 363-1112
Fax: (416) 363-5557

21.04.16 Moving Party Motion Record Vol I - Notice of Motion To Exhibit O

Uploaded by

Document Information

Original Title

Copyright

Available Formats

Share this document

Share or Embed Document

Sharing Options

Did you find this document useful?

Is this content inappropriate?

Copyright:

Available Formats

21.04.16 Moving Party Motion Record Vol I - Notice of Motion To Exhibit O

Uploaded by

Copyright:

Available Formats

Court File No.

WARREN KINSELLA, DAISY CONSULTING GROUP INC.

MOVING PARTIES’ MOTION RECORD

(June 21, 2021 Anti-Slapp Motion)

April 16, 2021 SHILLERS LLP

David Shiller (30506Q)

Lawyers for the defendants

Andremarinlaw Professional Corporation

Andre Marin, LSO #: 31636W

Lawyers for the plaintiff

WARREN KINSELLA, DAISY CONSULTING GROUP INC.

Tab No. Page

Notice of Motion dated April 15, 2021 1 10

Affidavit of Warren Kinsella sworn April 15, 2021 2 13

Exhibit “A” to the Affidavit of Warren Kinsella

Exhibit “B” to the Affidavit of Warren Kinsella

Exhibit “C” to the Affidavit of Warren Kinsella

Piece dated May 16, 2017 C 63

Exhibit “D” to the Affidavit of Warren Kinsella

Exhibit “E” to the Affidavit of Warren Kinsella

Exhibit “F” to the Affidavit of Warren Kinsella

Exhibit “G” to the Affidavit of Warren Kinsella

Exhibit “H” to the Affidavit of Warren Kinsella

Exhibit “I” to the Affidavit of Warren Kinsella

Exhibit “J” to the Affidavit of Warren Kinsella

Exhibit “K” to the Affidavit of Warren Kinsella

Exhibit “L” to the Affidavit of Warren Kinsella

Exhibit “M” to the Affidavit of Warren Kinsella

Exhibit “N” to the Affidavit of Warren Kinsella

Exhibit “O” to the Affidavit of Warren Kinsella

Exhibit “P” to the Affidavit of Warren Kinsella

Exhibit “Q” to the Affidavit of Warren Kinsella

Exhibit “R” to the Affidavit of Warren Kinsella

Exhibit “S” to the Affidavit of Warren Kinsella

Exhibit “T” to the Affidavit of Warren Kinsella

Exhibit “U” to the Affidavit of Warren Kinsella

Exhibit “V” to the Affidavit of Warren Kinsella

Exhibit “W” to the Affidavit of Warren Kinsella

Exhibit “X” to the Affidavit of Warren Kinsella

Exhibit “Y” to the Affidavit of Warren Kinsella

Exhibit “Z” to the Affidavit of Warren Kinsella

Exhibit “AA” to the Affidavit of Warren Kinsella

Exhibit “BB” to the Affidavit of Warren Kinsella

Exhibit “CC” to the Affidavit of Warren Kinsella

Exhibit “DD” to the Affidavit of Warren Kinsella

Exhibit “EE” to the Affidavit of Warren Kinsella

Exhibit “FF” to the Affidavit of Warren Kinsella

Exhibit “GG” to the Affidavit of Warren Kinsella

Exhibit “HH” to the Affidavit of Warren Kinsella

Exhibit “II” to the Affidavit of Warren Kinsella

Exhibit “JJ” to the Affidavit of Warren Kinsella

Exhibit “KK” to the Affidavit of Warren Kinsella

Exhibit “LL” to the Affidavit of Warren Kinsella

Exhibit “MM” to the Affidavit of Warren Kinsella

Exhibit “NN” to the Affidavit of Warren Kinsella

Exhibit “OO” to the Affidavit of Warren Kinsella

Exhibit “PP” to the Affidavit of Warren Kinsella

Exhibit “QQ” to the Affidavit of Warren Kinsella

Exhibit “RR” to the Affidavit of Warren Kinsella

Exhibit “SS” to the Affidavit of Warren Kinsella

Exhibit “TT” to the Affidavit of Warren Kinsella

Exhibit “UU” to the Affidavit of Warren Kinsella

Exhibit “VV” to the Affidavit of Warren Kinsella