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MOTION TO RESCIND DANIEL POULIN’S DENIAL OF FURTHERDISCLOSURE OF DOCUMENTS PERTAINING TO ABRAMS/B’NAI BRITH VRADICALPRESS.COM COMPLAINTBY EMAIL
 Arthur TophamPub/EdThe Radical PressBox 4633 Barkerville HwyQuesnel, B.C. V2J 6T8Email: radical@radicalpress.comApril 22, 2009Nancy LafontantRegistry OfficerCanadian Human Rights TribunalNancy.Lafontant@chrt-tcdp.gc.caDear Nancy Lafontant,
 RE: Harry Abrams and the League for Human Rights of B’nai Brith Canada v. ArthurTopham 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 respectingthe request contained in my email to Mr. Poulin on April 20, 2009 for further disclosureof 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 tobe totally unacceptable. This motion will therefore contain my reasons for making thisassertion.Firstly, this document, as stated in my request, is part of the initial complaint and tocontend otherwise is, in my opinion both disingenuous and false on the part of thecommission.Having been submitted as part of the complaint it MUST be included in the list of articlesotherwise 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, hasdeclared this document to have been a major influence motivating him to make hisdecision 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 statingthat it is not part of their file and therefore they do not have to include it in theirdisclosure is both absurd and false.When I received notification from the CHRC that I was being charged with havingcommitted a “hate” crime the evidence sent me included the urls to all of the articleswhich Mr. Abrams complaining of. It DID NOT include the full text to ANY of thearticles themselves. This is clear proof that the article known as the “Protocols of theLearned Elders of Zion” was INCLUDED in the package of articles. I cannot thereforeaccept Mr. Poulin’s current assertion that somehow it was not a part of the originalcomplaint to the commission and therefore the commission is not obligated to include itin their disclosure to the parties. It doesn’t take either a lawyer or a rocket scientist to seethat 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, 2009with respect to this historic document.What legal, or even ethical right for that matter, does Mr. Poulin have, as counsel for thecommission, 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 inessence, merely mouthing the traditional and historic propaganda which the Zionist Jewmedia has used since the document first appeared in the British press in 1920 to discreditthe contents of the work. As such, his transparent attempt to continue this deception, asexhibited 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 documentwhen 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 whereinhe states, “
In addition, it is submitted that because of its very nature as one of themost notorious anti-semitic piece of litterature[sic] ever created; there should be noneed 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 sinceit dived into the deep, murky pool of attempting to police people’s thoughts and ideas forthe benefit of special interest groups via the use of Section 13(1) of the CHR Act, hasbeen its utter lack of historic knowledge with respect to the complaints that have beenfurnished to it by lobbyists such as B’nai Brith Canada. This fact is no where moreexemplified than in Mr. Poulin’s response to my request for inclusion of this document inthe commission’s disclosure wherein he blatantly regurgitates proven slander, bias andprejudice 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 toback up what he so carelessly and spuriously presents as known fact, “there should be noneed to have a party disclose it.” [underlining is mine. AT]Being a credentialed lawyer, I must conclude that Mr. Poulin is most cognizant of theterm “bias” and how, in addition, the Canadian Human Rights Commission is presentedto the public eye as an “impartial”, quasi-judicial government body and how important itis that all Canadians perceive the commission’s behaviour as being exemplary in thismanner.As such, Mr. Poulin’s actions in this instance, as betrayed by the form and intent of hisdescriptive language used here to isolate and denigrate what should be simply one of 18objectively-viewed documents submitted by the complainants, does not lend credence tothe 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 alarge portion of my defense in this vexatious complaint is unworthy of being included inthe commission’s file because, based upon his obvious ignorance of historic reality andhis personal bias, one which I can fully understand as all Canadians have been affectedwith this bias over their lifetime of incessant Zionist propaganda, he has erroneously andpartially concluded that one of the documents included in Harry Abram’s complaintagainst 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 thecomplainants be instructed to share this document with the rest of the parties involved inthis case. That, I suggest, is not only bias and prejudice but in effect also a graphicillustration of possible overt collusion with the complainants and their false allegationsand as such grounds for having Mr. Poulin’s participation in this case dismissedforthwith.With respect to the aforesaid and to the theoretical “impartiality” of the commission, Iwould also remind Tribunal members of their own Code of Conduct, as contained in thePreamble to it and Sec. 18:
WHEREAS the Canadian Human Rights Act provides for the establishment of aCanadian Human Rights Tribunal made up of a Chairperson, a Vice-chairperson and anadditional number of appointed members, and WHEREAS such members of the Tribunalrecognize 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 PROCESS18. Independence and Impartiality
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