Affidavit
[Nizkor visitors are invited to compare this sworn affidavit
with
the Respondent's own evidence, and ponder the meaning of
"perjury."]
IN THE FEDERAL COURT OF CANADA
BETWEEN ERNST ZÜNDEL APPLICANT -AND- THE ATTORNEY GENERAL OF CANADA RESPONDENT AFFIDAVIT I, DR. INGRID RIMLAND, of Carlsbad, California, United States of
America, MAKE OATH AND SAY AS FOLLOWS:
1. I am the Webmaster of the Internet website on the World Wide Web
known as the "Zundelsite" located at the electronic address
http://webcom.com/ezundel/english.
As such, I have personal knowledge of the matters hereinafter deposed
to:
2. I am the creator, designer, editor and primary electronic columnist
of the Zundelsite. All documents which appear on the Zundelsite are
prepared in HTML and Adobe Acrobat coding by me on computer equipment
owned by me and located in Carlsbad, California, United States of
America.
3. I decided on the name - "Zundelsite" - because Mr. Zundel is the
world's best-known skeptic of genocidal activities alleged to have
happened in German concentration camps. I felt the name would summarize
for many familiar with Mr. Zundel's struggle the focus and aim of this
website - namely the call to readers and scholars world-wide to
scientificall and forensically examine widely-held but here properly
eamined claims of systematic genocide of European Jews during World War
II. I do not recall consulting Mr. Zundel if I could use the word
"Zundelsite" - I unilaterally decided that I would.
4. I have sole control over the password to the Zundelsite. Mr. Zundel
does not know and has never known the password to the Zundelsite.
[page 2] 5. Through this password I access the site to make changes, additions,
deletion or graphic alterations to the Zundelsite which I do on a
regular basis.
6. The Zundelsite is located at the Web server called Web
Communications, also referred to as WebCom. The physical address is Web
Communications, 125 Water St. Suite A1, Santa Cruz, CA 95060, USA. All
Zundelsite documents are stored at this address in huge electronic
memory banks.
7. Internet customers from all over the world access Zundelsite
documents at this US-based location - not only by calling up the Home
Page of the Zundelsite but by following hundreds of links established by
other website owners who have rarely consulted me and asked for
permission to link. Such linking is a navigational device and the
mechanism that makes the Internet interactive.
8. It is a profound misconception to assume that the Zundelsite is
perceived as a "hate website" that is accessed only or even primarily by
individuals seeking to vent their frustration about real or perceived
political grievances. The Zundelsite is a very sought-after, respected
repository for information and documents not available from other
conventional sources such as libraries or mainstream publications.
These documents are studied by serious students and scholars all over
the world. Not infrequently, Ph.D. candidates will contact me via
e-mail not just for references but for personal interviews with Mr.
Zundel to learn of an alternate point of view on recent European
history. As a primary information outreach source, I work with a
volunteer researcher, also located in California, who helps to track
requests for additional books, documents, scientific papers and
reference verifications. Other volunteers, many of them students at
respected universities, have offered their assistance as translators.
We have had requests for Revisionist videos and other information used
in class projects not just by students but also their professors. I
would estimate that 80% of all correspondence sent via e-mail to the
Zundelsite is respectful, courteous and genuinely inquisitive - even
from readers who are opposed to the Revisionist point of view.
9. All of the Zundelsite e-mail goes to WebCom in Santa Cruz,
California, from where it is immediately routed to a local, San
Diego-based server called CTSNET. This company's physical address is at
4444 Convoy Street, Suite 300, San Diego, CA 92111-3761, USA. CTSNET
assigned an e-mail address called
ezundel@cts.com
for the
[page 3] Zundelsite that permits me to download all Zundelsite e-mail onto my
personal computer.
10. I open, sort, answer and file all electronic mail sent to the
Zundelsite.
11. For the past year, all documents appearing on the Zundelsite have
been linked through hyperlinks to a website called "Nizkor" opposed to
the Zundelsite point of view and offering the conventional historical
point of view. Nizkor is headed by Ken McVay of British Columbia,
Canada, and server by co-webmasters Jamie McCarthy of Michigan and
Hilary Ostrov, whose location is not known to me. Nizkor is a website
that claims to have four to five times our Internet traffic and an
estimated ten-fold number of documents opposing what we say. In a
recent e-mail to me, Jamie McCarthy wrote that Nizkor documents are now
located on 5 different servers (three in Canada) with a sixth in the
process of being finalized.
12. I have maintained an e-mail dialogue with Jamie McCarthy since
September of 1995 when he approached the Zundelsite challenging us on
disputed matters about World War II and daring us to a comparison of
evidence. With mutual consent, a linkage of the two sites resulted for
the purpose of providing readers with two opposing points of view.
13. This e-mail dialogue between Jamie McCarthy and me was sometimes
amiable and often hostile. Both Jamie McCarthy and I tried to find
technical solutions to advance cooperative and mutually beneficial ways
to bring us nearer to historical truth - wherever this search may lead.
Right now, Jamie McCarthy has offered to write a tailor-made program
that would facilitate the linking process. I have agreed to change the
document footer accordingly.
14. In general, however, Nizkor people have routinely been abusive about
both Ernst Zundel's motives and my own by stating or implying in various
newsgroups that we are "liars" who promote hatred and racism for
self-serving ends. A recent e-mail from Ken McVay accused me of having
posted "some claptrap about truth" and having promoted "forgeries for
blatant profit" on Ernst Zundel's behalf. Such posts are very common in
newsgroups. I, in turn, have criticized Nizkor in my ZGrams in defense
of the Zundelsite point of view, since I believe such labeling serves no
constructive purpose.
[page 4] 15. One specific Zundelsite document, challenged by the Canadian Human
Rights Commision as inappropriate for the Internet, called 66
Questions and Answers on the Holocaust, was specifically challenged
by Nizkor in an extensive rebuttal document prepared by them as a first
step to get a dialog between Nizkor and the Zundelsite going. This
document is available on the Zundelsite, and we are now rebutting the
Nizkor rebuttals, expanding and amplifying on the content. This
document is well-organized and has specific links to Nizkor. It is a
popular sub-part of the Zundelsite and often the focus of vigorous
newsgroup debates.
16. I have recently added a link to the Los Angeles based Simon
Wiesenthal Center as well. Internet visitors to the Zundelsite are
offered a convenient, direct path only a mouse click away to
quantitatively vast material attempting to refute the Zundelsite point
of view.
17. I am the author of the well-known ZGrams - daily electronic
editorials, columns and news releases on which I carry a copyright. If
Mr. Zundel wants to use these columns for hard-copy distribution, he
notifies me and asks my permission. My ZGrams are reposted on the
Internet in newsgroups by friends as well as opposition websites such as
Nizkor, and selected ZGrams are reprinted in various hard copy
publications.
18. I am the author of three books, 5 separate columns (which appeared
either weekly or monthly for years and which were reprinted and
distributed repeatedly in dozens of educational and historical
publications nation-wide) many articles in mainstream publications, and
contributions to several anthologies, two of them on World War II
history. I have won prestigious awards for my writing. One such award
was given to me for an historical essay in an international, 24-country
competition sponsored by an association of German-language newspapers
and electronic media and later published in an historical anthology.
19. I won the highest award on the West Coast for 1977, the
California Literature Medal Award, for an ethnic First Novel,
titled "The Wanderers" illustrating the experiences of German
people during World War II trapped behind the Iron Curtain. This book
is a fictitious account of my German ancestry and the experiences of
close members of my family, Pacifist Mennonites, during World War II.
It deals with themes and topics from a German point of view. It has
been and is still being used as a supplementary text in several United
States and Canadian colleges, and I have been
[page 5] invited many times as a guest lecturer for historical events or
college level history classes.
20. As a small child, I personally experienced World War II. I have
strong feelings about the German side of World War II never having been
presented fairly and honestly as I remember it. There have been many
times in my own life when I have felt defamed by a one-sided, hateful
interpretation of Germans as genocidal maniacs, when nothing in my
background and experience speaks to that. The Zundelsite presents facts
and views, not widely known and disseminated, reflecting the background
and experience of many Germans the world over. The Zundelsite
facilitates a more balanced perspective in that the documents and
articles I have posted and continue to post help to exonerate the
Germans in the public mind of many atrocities and crimes they have been
accused of but did not commit, according to Revisionist research.
Revisionist scholars and writers are given an opportunity to add to a
more balanced and healing point of view of events alleged to have
happened more than half a century ago.
21. All documents on the Zundelsite are protected by the First Amendment
of the Constitution of the United States of American which guarantees
freedom of expression. I am an American citizen who counts on this
protection from interference coming from another country, Canada.
DATED on this 13th day of December, 1996
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This site is intended for educational purposes to teach about the Holocaust and
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Any statements or excerpts found on this site are for educational purposes only.
As part of these educational purposes, Nizkor may
include on this website materials, such as excerpts from the writings of racists and antisemites. Far from approving these writings, Nizkor condemns them and
provides them so that its readers can learn the nature and extent of hate and antisemitic discourse. Nizkor urges the readers of these pages to condemn racist
and hate speech in all of its forms and manifestations.
filed by Ingrid Rimland
on December 13, 1996
TRIAL DIVISION