Professional Documents
Culture Documents
SUPERIOR
C O U R TO F J U S T I C E
BETWEEN:
KHURRUM
AWAN
lntendedPlaintiff
and
EZRA LEVANT
Intendeddefendant
NOTICE OFLIBEL
(pursuantto section5 of the Liberand sranderAct,R.s.o.1990,c. L.12.1
Awantheliar,part8" - http://ezralevant.com/2009/06/khurrum-awan-the-liar-part-
"Khurrum
8.html
of Posting:June 4, 200g
lve been bloggingfor abouta year and a hall and by far the most enjoyable
daysof it werethe ones I spentlive-blogging
MarkSteyn'sshowtrialat the B.C.
HumanRightsTribunatlastJune.
DefamatoryStatements:
1. You havefalselystatedby innuendoin the above-quoted blog entrythat
Mr. Awan is an anti-Semite. Mr. Awan has never made any inti-semitic
statements in publicor private;nordoeshe harboursuchviews.
2. You havefalselystate in the above-quoted blog entrythat Mr. Awan was
testifyingin orderto preventMr. Elmasryfrom answeringtoughquestions.
Mr. Awan testifiedat the hearingof a human rights comflaint against
Maclean'sbeforethe BC HumanRightsTribunalbecausehe was partof a
studentgroupthat met with Maclean'seditors,priorto the filingof human
rightscomplaintsagainstMacrean'swith the ontario, BC, and Federal
HRCs,to ask that Maclean'spublisha responseto one of a seriesof anti-
Muslimarticles.Mr. Awan was testifyingbeforethe BC Tribunalprimarily
!o complete the narrativeabout why comptaintswere filed against
Maclean's. Mr. Awan would have testified regardlessof whether Mr.
Elmasry testified before the Tribunal. Mr. Awan took no part in the
decisionas to whether Mr. Elmasrywould testify. The innuendoof
describingMr. Awan as a "proxy",a "pR frack","a stunt double",or .an
actor" is that he was providingfafse and misleadingtestimonyto the
tribunaland assistingto preventMr. Elmasryfromtestifling.
-3-
DefamatoryStatements:
1. By innuendo,and throughyour distortionof Mr. Awan's testimony,you
haveimpliedthat he was attemptingto obtain"thousandsof dollars;'from
Maclean'sfor his personalbenefit.In fact, and as stated before the
Tribunal,duringboth his examinationand cross-examination, the student
groupwhichmet Maclean'seditors,askedthat Maclean'sconsidermaking
a donationto an organizationworkingon race-relations in canada.
2. You falselystate that Mr. Awan admittedto lying in his testimonybefore
the BC Tribunal and that he admittedthat he tried to shake down
Maclean'sfor thousandsof dollars. Mr. Awan did not lie beforethe
tribunalin any manner and your accusationthat he did is false and
defamatory. Further,your statementthat Mr. Awan was attemptingto
shakedownMaclean'sis falseand impliesimpropriety on his part.
DefamatoryStatements:
1. You haverepublisheda totalof sevenblogsthatyou authoredtifled
"KhurrumAwanthe liar",all containing
numerousfalsestatements about
Mr.Awan.Thoseblogentriesare set out below.
Defamatory
Statements:
1. You againallegethat Mr. Awan lied to the mediadue to a phenomenon
known as "taqqiya'',which again is linked to the website of a far-right
commentator,DanielPipes, and where this term is definedas indicaied
abovein this Noticeof Libel. The innuendoof four wordsis that Mr.Awan
is an lslamic/ Muslimextremistor terroristwho thinksthat it is permissible
to lie in order to attain some kind of lslamic/ lslamistobjectives.This
statementis false. You had no basisfor ailegingthat Mr. Awan is (a)
familiarwiththisconcept;or (b)that he is an extremistof any kind.
DefamatoryStatements:
1. You havespecifically
calledMr.Awana liarand impliedthat he committed
perjury.
2. Mr. Awan did had no difficultyobtainingemploymentfoilowinghis
clerkship.He obtainedemployment whileclerkingwith the SuperiorCourt.
By innuendo,you statedthat Mr.Awanis incompetent.
3. By innuendo,you statedthat Mr. Awan is a racistMusrimwho believes
thatthe pressare "gentiles"or infidels.You had no basisin factfor making
this statement.During Mr. Awan's media appearancesreratedto the
Maclean'scase,he waSvery courteousand respectfulwith all the media
that interviewedme.
4. You specificallyassociatedMr. Awan with yasser Arafat and stated by
innuendothat he preachesterrorismto Muslims.Mr. Awan has never
preachedviolencein any formto anybody.
5. You have misrepresentedthe contentof letterswhich were exchanged
between Rogers lnc. and a student group to which Mr. Awan is
associated. In particular:
a. Mr. Awan neverstatedthat Maclean'shad to submitto CIC'schoice
of editors.
-5-
DefamatoryStatements:
1. The innuendoof your above-quoted blog entry is that in the letterMr.
Awansentto Briansegalfollowingtheirmletingwith Maclean's,he asked
for money.That statementis false. The letterJent to Mr. segai ooei not
ask for money.By innuendo,you statedthat Mr. Awan was jftemptingto
profitfinancially.
DefamatoryStatements:
1. You failedto publishin your blog entrythat Mr. Awan testifiedthat there
was no needfor him to discussa mutuallyacceptableauthorbecause,at
the time,Maclean'seditorswere unwillingto publishany responseat all. lt
was only approximatelyfour days after this press conference,that
Maclean'schief editor,Ken Whyte,falselyclaimedthat he had always
beenpreparedto publisha responseto the article.Therefore,as a result
of your failureto ascertainthe completefacts beforeyou publishedthe
above-quoted blogentry,you falselyaccusedMr.Awanof perjury.
DefamatoryStatements:
1. You have falsely stated that Mr. Awan is a "serial,malicious,money-
grubbingliar," By innuendo,you have statedthat Mr. Awan committed
perjUry.The BC TribunalacceptedMr. Awan'stestimonyin its entirety,
and substantiallyrejectedthe versionof eventsthat Maclean'seditorshad
putin the publicdomainthrougha publicstatement'
2. You falselystatethat Mr. Awan is a "damnfool" and calledhimselfas a
witness.
3. You falsely state by innuendothat Mr. Awan was attemptingto elicit
moneyfrom Mclean'sfor himselfwhenthe requestwas for a donationto
a worthycause.
-7^
DefamatoryStatements:
1. lt is falseto statethat Mr.Awanis a "sockpuppet"for anybody.In fact,Mr.
Awanhad independent involvementin the humanrightscomplaints
againstMaclean's.He was an individual beforethe Ontario
complainant
HumanRightsCommission and had puttogethera groupof lawstudents
who had alreadymadethe decisionto meetwithMaclean'seditorsabout
the article,well beforethe CanadianlslamicCongressor Mr. Elmasrygot
involvedin this mdtter.
2. Thereis no writtendemandby Mr,Awanor any of the complainants for
"substantial"
moniesfrom Maclean's. The onlyrequestswerefor a
donationas indicatedabovein this Noticeof Libel. This statementis
completelyfalse.
Well, I'd like to add an eighthinstalmentto my series.I missedit when I first read
it in the Star'sletterto thq editorssection(scrolldown),but Mark Stevnpointsit
out Awan impliesthat he was the complainant againstme and the Western
Standardmagazinefor publishingthe Danishcartoonsof Mohammed.Awan
writes:
Ezra Levant accuses Canada's human rights commisslonsof censorshipfor
investigating our hate-speechcomplaints about his publishing of cartoons
depictingMuslims...
Jew-hatern?med
againstme werefiledby a Pakistani
Uh,nope.The complaints
fellowcensorsat the EdmontonCouncilof
and Soharwardy's
Sved Soharwardv,
Awanand the CanadianlslamicCongresshad nothingto
MuslimCommunities.
do with it.
Who cares,really.
But it's so curious:what is it about Awan that just makes him say or write
anything- anythingat all - no matterif it'strue or not?
I can understandif he has an urge to lie. lt's calledtaoiyyq.But surelyany
liarwouldchoosea lie that is not so easilycheck-able.
intelligent Why lie about
something thatcan be so easilydisproven?
DefamatoryStatements:
1. Mr. Awan co-authoreda letterto the Editorthat was publishedin the
TorontoStar in responseto a TorontoStar op-edpieceby you, in which
-8-
What'sgeingen?Otherthanbeingan'rnimBressi@
DefamatoryStatements:
1. Mr. Awan was not testifyingon behalfof Mr. Elmasryor Dr. Habibbefore
the BC Tribunaland therewas nothingout of the ordinaryfor himto testify
beforethe Tribunaleven though he was not one of the parties. By
innuendo,you have stated that Mr. Awan acted inappropriately by
testifying.
2 . Mr. Awan WaSnot co-counselin the case against Maclean'Sand the
innuendoof yourstatementwas thathe was actingin a conflictof interest.
3 . Mr. Awan never testifiedthat he was going to work for FaisalJoseph.
Beforethe Tribunal,he testifiedthat he was goingto articlefor Lerners,
not FaisalJoseph.FaisalJosephworksfor the Lernersofficein London'
Mr. Awan interviewedand articledwith the Lernersoffice in Toronto.The
two officeshave separatehiringprocessand Mr. Awan went throughthe
standard interviewingprocess,for articlingstudents,with the firm's
Torontooffice and was offereda job by LernersLLP, in Toronto.Faisal
Josephdid nof offerhim any positionat Lernersand he has neverworked
on a single assignmentfor FaisalJosephthroughhis employmentwith
Lerners.The innuendoof your above-quoted blog entry is that Mr. Awan
securedhis positionat Lernersbecauseof FaisalJoseph'sinfluenceand
that Mr.Awan is incompetent.Bothof thesestatementsare false.
4 . You falselystate that Mr. Awan did not work for Lernersand that there
was a job offer that was terminatedby Lernersbecauseof Mr. Awan's
"lies" beforethe BC Tribunal.The truth is that Mr. Awan just recently
completedhis articlingterm at Lerners,whichstretchedbetweenJuly28,
2008and May 29, 2009.Lernershiredbackonly 1 of 6 students.Although
Mr.Awanwas not offereda positionto return,the firm was happywiththe
work he did, as reflectedby the referencelettersprovidedto him by four
senior padners at the firm, three of whom he assistedwith trials. ln
particular,he workedon two separatetrialswiththreevery seniorlitigators
at Lerners,all of whom were very happy with his work and provided
referencelettersto that effect.
Date:July14,2009
RUBY& SHILLER
Barristers
Arthur
11Prince
ONMsR182
Toronto
Phone: (416)964-9664
Fax: (416)964-8305
TO:
EZRALEVANT
c/o 1600,300 5thAvenueSW
Calgary,Alberta
T2P 3C4