MOTION TO RESCIND DANIEL POULIN’S DENIAL OF FURTHER

DISCLOSURE OF DOCUMENTS PERTAINING TO ABRAMS/B’NAI BRITH V

RADICALPRESS.COM COMPLAINT

BY EMAIL

Arthur Topham
Pub/Ed
The Radical Press
Box 4633 Barkerville Hwy
Quesnel, B.C. V2J 6T8
Email: radical@radicalpress.com

April 22, 2009

Nancy Lafontant
Registry Officer
Canadian Human Rights Tribunal
Nancy.Lafontant@chrt-tcdp.gc.ca

Dear Nancy Lafontant,

RE: Harry Abrams and the League for Human Rights of B’nai Brith Canada v. Arthur
Topham and the RadicalPress.com
File Number: T1360/9008

The motion contained herein follows upon the letter from Mr. Daniel Poulin, Counsel,
Canadian Human Rights Commission received on Wednesday, April 22, 2009 respecting
the request contained in my email to Mr. Poulin on April 20, 2009 for further disclosure
of missing documents, to wit, the “Protocols of the Learned Elders of Zion”.

I found Mr. Poulin’s reasons for declining my request for inclusion of this document to
be totally unacceptable. This motion will therefore contain my reasons for making this
assertion.

Firstly, this document, as stated in my request, is part of the initial complaint and to
contend otherwise is, in my opinion both disingenuous and false on the part of the
commission.

Having been submitted as part of the complaint it MUST be included in the list of articles
otherwise the whole complaint itself can only be construed as being a farcical act of
premeditated, vexatious persecution of myself for blatant political reasons.

Harry Abrams, in his own written statements and in his complaint to the commission, has
declared this document to have been a major influence motivating him to make his
decision to file the complaint against myself and RadicalPress.com. As such, for the
commission to now try and side-step the controversial document in question by stating
that it is not part of their file and therefore they do not have to include it in their
disclosure is both absurd and false.

When I received notification from the CHRC that I was being charged with having
committed a “hate” crime the evidence sent me included the urls to all of the articles
which Mr. Abrams complaining of. It DID NOT include the full text to ANY of the
articles themselves. This is clear proof that the article known as the “Protocols of the
Learned Elders of Zion” was INCLUDED in the package of articles. I cannot therefore
accept Mr. Poulin’s current assertion that somehow it was not a part of the original
complaint to the commission and therefore the commission is not obligated to include it
in their disclosure to the parties. It doesn’t take either a lawyer or a rocket scientist to see
that what Mr. Poulin is doing is incorrect, inappropriate, misleading and highly suspect.

My final description of Mr. Poulin’s line of reasoning contained in the last two words of
the above paragraph, “highly suspect”, is not without basis and is stated because of Mr.
Poulin’s own personal, biased, prejudicial remarks made in his letter of April 20, 2009
with respect to this historic document.

What legal, or even ethical right for that matter, does Mr. Poulin have, as counsel for the
commission, to be making such erroneous, biased statements as, “the notorious anti-
semitic forgery” when making reference to this document? It behooves the commission to
justify itself on this question for the obvious reason that Mr. Poulin is, in fact and in
essence, merely mouthing the traditional and historic propaganda which the Zionist Jew
media has used since the document first appeared in the British press in 1920 to discredit
the contents of the work. As such, his transparent attempt to continue this deception, as
exhibited by his choice of language, can only be construed as a further example of
attempting to impose the law of les majesty with respect to this controversial document
when it is not called for or warranted on the part of a supposed “impartial” commission.

Further to Mr. Poulin’s initial faux pas regarding this matter is his final remark wherein
he states, “In addition, it is submitted that because of its very nature as one of the
most notorious anti-semitic piece of litterature[sic] ever created; there should be no
need to have a party disclose it.” [emphasis added. AT]

This remark, on the part of an impartial counsel, I submit, shows extreme and overt bias.

One of the major stumbling blocks that the commission has repeatedly tripped over since
it dived into the deep, murky pool of attempting to police people’s thoughts and ideas for
the benefit of special interest groups via the use of Section 13(1) of the CHR Act, has
been its utter lack of historic knowledge with respect to the complaints that have been
furnished to it by lobbyists such as B’nai Brith Canada. This fact is no where more
exemplified than in Mr. Poulin’s response to my request for inclusion of this document in
the commission’s disclosure wherein he blatantly regurgitates proven slander, bias and
prejudice as if it were established historic FACT.
“Because of its very nature” Mr. Poulin goes on to state, as if he were a professor of
history or a forensic expert on the subject of the Protocols who could provide evidence to
back up what he so carelessly and spuriously presents as known fact, “there should be no
need to have a party disclose it.” [underlining is mine. AT]

Being a credentialed lawyer, I must conclude that Mr. Poulin is most cognizant of the
term “bias” and how, in addition, the Canadian Human Rights Commission is presented
to the public eye as an “impartial”, quasi-judicial government body and how important it
is that all Canadians perceive the commission’s behaviour as being exemplary in this
manner.

As such, Mr. Poulin’s actions in this instance, as betrayed by the form and intent of his
descriptive language used here to isolate and denigrate what should be simply one of 18
objectively-viewed documents submitted by the complainants, does not lend credence to
the commission’s professed principles nor to his own obvious, albeit possibly ignorant,
statements.

What in essence Mr. Poulin is saying is that the cornerstone or lynch pin that upholds a
large portion of my defense in this vexatious complaint is unworthy of being included in
the commission’s file because, based upon his obvious ignorance of historic reality and
his personal bias, one which I can fully understand as all Canadians have been affected
with this bias over their lifetime of incessant Zionist propaganda, he has erroneously and
partially concluded that one of the documents included in Harry Abram’s complaint
against myself and my website RadicalPress.com, the “Protocols of the Learned Elders of
Zion” is therefore invalid and should not be permitted as evidence, nor should the
complainants be instructed to share this document with the rest of the parties involved in
this case. That, I suggest, is not only bias and prejudice but in effect also a graphic
illustration of possible overt collusion with the complainants and their false allegations
and as such grounds for having Mr. Poulin’s participation in this case dismissed
forthwith.

With respect to the aforesaid and to the theoretical “impartiality” of the commission, I
would also remind Tribunal members of their own Code of Conduct, as contained in the
Preamble to it and Sec. 18:

WHEREAS the Canadian Human Rights Act provides for the establishment of a
Canadian Human Rights Tribunal made up of a Chairperson, a Vice-chairperson and an
additional number of appointed members, and WHEREAS such members of the Tribunal
recognize both the importance of the protection of human rights and the importance of
the integrity, impartiality and independence of the Canadian Human Rights Tribunal,
a Code of Conduct governing Tribunal Members is hereby established to ensure that the
following principles are respected. [emphasis added. AT]

RESPONSIBILITIES TO THE PROCESS

18. Independence and Impartiality

A Member:

a) shall be independent and impartial, shall act in a fair manner and shall avoid
creating an appearance or an apprehension of bias; [emphasis and underlining mine.
AT]

Based upon the information contained in this letter and that of comments contained in
Mr. Poulin’s letter of April 22, 2009, I therefore move that the Tribunal instruct Mr.
Poulin to retract the biased statements contained in his letter and also that the Tribunal
instruct him to include the aforementioned document in the CHRC’s disclosure. In the
event that Mr. Poulin and the commission refuse to comply with such a request I would
ask that the Tribunal give serious consideration to having Mr. Poulin’s participation in
this complaint suspended on the basis of personal bias in favour of the complainants and
their politically motivated complaint made against myself, Arthur Topham and
RadicalPress.com. Should the commission refuse to honor its commitment to impariality
I would then move that this complaint be dismissed on such grounds.

If there is any further formality or motion that you require, please let me know as soon as
possible.

Sincerely,

Arthur Topham pro se

Publisher/Editor
The RadicalPress.com

Cc:
Daniel Poulin, counsel, Canadian Human Rights Commission
Marvin Kurz, Counsel, B’nai Brith Canada
Harry Abrams, Complainant
Anita Bromberg, Co-complainant
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