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                                  AFFIDAVIT
                                     OF
                               WOLFGANG DROEGE
                                                    Court File No. T-567-96

               IN THE FEDERAL COURT OF CANADA TRIAL DIVISION

                                  BETWEEN:

                           ERNST ZÜNDEL APPLICANT

                                   -AND-

  THE MINISTER OF CITIZENSHIP AND IMMIGRATION SECURITY INTELLIGENCE REVIEW
                                 COMMITTEE

                                RESPONDENTS


                        AFFIDAVIT OF WOLFGANG DROEGE

I, WOLFGANG DROEGE, of *************, Ontario, make oath and say as follows:

1. I was born in Forchheim, Bavaria, Germany on September 25, 1949. I
immigrated to Canada in 1963 and became a Canadian citizen in the early
1970s.

2. I have been involved in the white racialist movement since 1974 being a
member of the Western Guard and later the Ku Klux Klan in Canada until about
1981.

3. In 1975 I was arrested and convicted for public mischief. The conviction
resulted from spray painting a white power slogan the night prior to an
African liberation day march in Toronto.

4. I was imprisoned in the United States from April 1981 to June of 1983 for
violation of the Neutrality Act due to my involvement in the planned
overthrow of the government of Dominica.

5. In November 1984 I was arrested in Huntsville Alabama for possession of a
weapon aboard an airplane and possesion of cocaine for the purpose of
trafficking. I received a 13 year sentence of which I served one-third in
Lompoc, California. I was released in April of 1989.

6. I returned to Canada in April of 1989 upon my release from prison in the
United States.

                    Grant Bristow and the Heritage Front

7. I first met Grant Bristow within a week of returning to Canada at a
meeting at the Nationalist Party in the house of its leader Don Andrews.
This was in April of 1989. Bristow was an investigator with a large
multinational company called Kuhne and Nagel. He was a skilled and competent
investigator. I was told that Bristow had first come onto the scene in
November of 1988 when he appeared at a meeting of the Nationalist Party in
Don Andrews' house. No one knew him but he volunteered to do investigative
work for Andrews and the party and train people.

8. Bristow took an immediate interest in me and we subsequently became close
friends. Shortly thereafter I obtained employment with Al Overfield's
company Accurate Bailiff Services repossessing automobiles and doing skip
tracing (locating people who have left no forwarding address). Bristow
helped me in locating automobiles which had been missing for quite some
time. That in turn provided me with extra bonuses which helped get me back
on my feet financially. This helped me tremendously because I had returned
to Canada from prison with $57.00 and the clothes on my back.

9. I went to Libya accompanied by Grant Bristow in August of 1989 along with
a delegation of Nationalist Party members. On the return trip, I was
detained at O'Hare Airport in Chicago for allegedly violating the United
States immigration laws. Bristow arranged a lawyer for me and contacted a
Canadian consulate official in an attempt to have me released. He provided
$1,000.00 to the lawyer. Part of the money was his and the rest was
solicited by him from other members of the Nationalist Party. With the help
he arranged, I was released within about forty-eight hours. Bristow's help
sealed our friendship as it made me feel confident in his abilities.

10. Bristow and I spent a large amount of time together tracking cars during
which time the ideas were discussed of forming an organization fighting for
white rights. Bristow was instrumental in urging me to seek an alternative
to Don Andrews' Nationalist Party. He said that Andrews wasn't even white
and never seemed to get anywhere with his white racialist message. He said
that an organization needed to be founded which would take the racialist
movement into the 1990s by using videotapes, seminars to upgrade people's
speaking skills, use of computers, and techniques that are used by major
political parties in attracting the masses to our cause.

11. The goal of the new organization was to be an advocacy group for white
rights. Bristow and I felt that present immigration was detrimental to the
interests of the country because it would eventually turn Canada into a
non-white nation. And with it, our institutions would be altered in such a
way as to become unrecognizable to the founding people. This would lower the
quality of life as we know it. We opposed equity hiring as we viewed it as
disadvantaging whites who are essentially the founding people of this
nation. (In fact, one of the chief election promises of the Ontario
Conservative Party in 1995 was the repeal of these laws and they have in
fact now been repealed. The Heritage Front may have played a part in raising
public consciousness about these issues by the large amount of publicity we
generated.)

12. I am not a white supremacist. We are racial nationalists whose eventual
goal would be the creation of an exclusively white state for those wishing
to live in an area among their own kind. Our intention was and is to lobby
legally and publicly in achieving our goals without any violence. We do not
wish to dominate or subjugate any other race but do believe that separation
of the races is our only way of preserving our race which we believe to be
the most unique on the face of the planet. Bristow appeared to be sincere in
these beliefs.

13. The name "The Heritage Front" was decided upon by myself, Grant Bristow
and Gerry Lincoln. We were the three founding members of the organization.

14. The HF was officially founded in the fall of 1989 by registering the
name with the Ministry of Consumer and Commercial Affairs in Ontario. It was
registered by James Dawson.

15. I was the leader of the HF, Gerry Lincoln was the secretary and Bristow
was in charge of security and all legal matters which were to arise because
of his para-legal training. Initially, there were about twelve or fifteen
supporters. Actual memberships were not issued until the beginning of 1993.

                       Funding of the Heritage Front

16. The HF was initially financed by the three founding members who each
donated hundreds of dollars. Bristow gave more money than either myself or
Gerry Lincoln. Over the years he used his own camcorder, computer and other
electronic devices in furthering the activity of the HF. Videos made on his
camcorder and a camcorder provided by Dawson were sold to raise funds for
the HF. On his computer, Bristow networked with other organizations using
e-mail such as Tony MacAleer, Terry Long among others. Terry Long provided
Bristow with information as to who he viewed as being "enemies." Bristow
kept files of this information. Bristow used his other electronic devices
for surveillance of anti-racists.

17. Bristow obtained a flight for me to Vancouver in 1990 and also provided
on various occasions rental cars and paid for travel expenses. He also paid
for trips to Ottawa, Montreal, Windsor and Kitchener by paying for gas,
rental cars, hotel rooms and meals. Payment for the meals was a big
contribution by Bristow especially during court cases which were frequent.
He would pay for me, the lawyers and supporters, sometimes paying for up to
twelve or fifteen people for meals and drinks at restaurants. Some of these
meals were at fairly expensive places where the bill would come to about
$150 or more. Especially when the lawyers were taken out, Bristow would pay
up to $100 for the four of us for a meal. Bristow helped pay for copying and
printing expenses for business cards, stationary with letterheads, pamphlets
and later helped put up money for "Up Front," the magazine HF produced. He
contributed funds for "Up Front" until the magazine became self-financing.
As time went on, Bristow paid out more and more money for HF. When the
"Equal Rights for Whites Hotline" set up by Ken Barker needed funding,
Bristow provided hundreds of dollars for telephone bills. Many of the people
attracted to the HF were young and had little money. We met them in public
places such as restaurants and Bristow frequently picked up the tab for
these young people.

18. For the first two years, HF built infrastructure by setting up a
hotline, developing pamphlets, getting a post office box and building some
membership. At the beginning by contacting other known like-minded
individuals we were able to fill necessary positions in the organization.
Some of that was achieved by travelling to other parts of Canada and
networking with others (Ottawa, Montreal, Vancouver, Calgary) which Bristow
substantially paid for out of his own funds.

19. Bristow was a para-legal and helped in a number of cases in which HF
people were involved. This included myself, Ken Barker, the Fischer
brothers, Les Jasinski and others. Bristow would try to arrange bail, and
help the lawyers in preparing the cases. He was heavily involved in the
Canadian Human Rights Tribunal case by doing legal research and even
represented me at a Ministry of Consumer Affairs tribunal review of my
bailiff license. He would also represent some supporters in traffic cases
for free.

                         Heritage Front Activities

20. In September of 1991, the HF held its first public meeting in Toronto.
About one hundred people attended. Bristow spoke to the meeting for the
purpose of raising funds and updating the supporters on the latest
activities. I spoke and gave the reasons why we had to fight for this cause.
Paul Fromm of C-FAR (Citizens for Foreign Aid Reform) was our guest speaker
and addressed the issue of immigration.

21. Bristow spoke at all other subsequent meetings for the purpose of
raising funds for the HF. The funds were used primarily for fighting the
legal battles before the Canadian Human Rights Commission. He fired up the
crowd by denigrating our opponents and ridiculing them.

22. Later in 1991, our first issue of HF's magazine "Up Front" was
published. HF has now published nineteen issues of the magazine on an
irregular basis. The magazine deals with issues such as immigration, crime,
racial matters, ideology and the transformation of Canada. The magazine has
never faced a complaint from the authorities.

23. HF believed that the most fertile ground for members was in the schools.
The kids were facing racial problems in the schools yet the school
authorities and their parents were out of touch with issues which effected
them such as equity hiring, affirmative action and violence in the schools.
They felt alienated and disenfranchised and felt no voice spoke on their
behalf. Instead, a guilt trip was always laid on them by the schools that
whites were responsible for all the ills of the world. The schools always
tried to raise the self-esteem of non-whites but the concerns of white
students were never addressed. HF had exceptional success in attracting
these young people. They would call up the HF hotline and after listening to
several messages would leave their names and addresses. At later meetings,
HF would attract up to 200 people, mostly young people.

         Bristow's Harassment Campaign and Other Illegal Activities

24. In early 1992, the Human Rights Commission at the behest of Rodney
Bobiwash, laid a complaint against the HF telephone hotline. These
proceedings were not resolved until 1994 when I signed an agreement with the
Canadian Human Rights Commission not to run messages on the hotline which
incited hatred or contempt against identifiable groups.

25. Proceedings against the HF Hotline led to demonstrations and
disturbances by anti-racists starting in August of 1992. Bristow felt that
it was necessary to monitor our opposition. In time, it led to harassment of
our opponents. Bristow was instrumental in orchestrating the harassment
campaign. He broke into telephone answering machines of anti-racists, had
people harass the opposition over the phone, and put people under
surveillance. The harassment was very extensive. He seemed to spend a
considerable amount of time in these activities. He probably involved over a
dozen members of HF in these activities.

26. I never stopped the harassment campaign because Bristow was a founding
member of HF who contributed substantially to the organization. He was an
indispensable member of the organization and had his own faction which
supported his actions.

27. One person he instructed in harassment techniques and providing names
and telephone numbers was HF member Elisse Hategan. Hategan was involved
extensively in the harassment campaign by telephoning people. Later,
however, Hategan told me that her voice had been recognized by an
Anti-Racist Action member Ruth MacKenzie. This frightened her and she wanted
to drop out of the harassment activities. Bristow, however, told her to
continue the harassment. This led to her attempting suicide at which time
she contacted Ruth MacKenzie and formed a friendship with her. Thereafter,
MacKenzie introduced her to Martin Theriault who wanted her to provide
information on the HF to his organization in Montreal. After meeting
Theriault, Hategan informed me what had happened. In February or March of
1993, Hategan began keeping notes on Bristow's activities and tried to
research his background. She had become suspicious of his activities.
Hategan told me that Bristow was pressuring her into continuing the
harassment activities against her will and he threatened her with a "white
van ride" in the summer of 1993. This was a reference to the Tyrone Mason
kidnapping incident where the Fisher brothers and Drew Maynard picked Mason
up in a white van, and beat him and threatened him with death.

28. I confronted Bristow with this accusation by Hategan. Bristow denied the
threat and said she was unstable. I believed Bristow at the time because he
seemed more reliable. Later, Hategan told Bristow about keeping notes on him
at which time Bristow sought me out and asked me to organize a party to
break into and ransack her residence to retrieve her notes on him. I
declined. This was the first time that Bristow was ever agitated with a
decision of mine. Bristow was a person who was frequently at odds with
people but this was the first time he had become visibly angry with me. He
said he had done a lot for the movement and individuals, and gone to a lot
of expense in doing so, but all people ever did was question his motives and
character. The second time he became upset with me was when our lawyer
pressed Hategan in cross-examination (in the Federal Court where I was
facing contempt charges) on harassment activities which led to Bristow's
role being exposed.

29. Today I am convinced that Bristow in fact threatened Hategan because she
refused further involvement in the harassment campaign.

30. In January of 1993, Hategan was charged with inciting hatred under the
Criminal Code. She had distributed a flyer comparing a black man with a
gorilla. The flyer contained the name and address of a known anti-racist as
being the person responsible for the flyer. It was Bristow who provided the
name and address of the anti-racist for the flyer. Bristow told me that the
anti-racist individual received harassment due to the flyer and was forced
to move out of her home. He was amused by these developments.

31. The harassment campaign led the HF astray from its objective of lobbying
for white rights. Instead, it caused dissension in the organization because
of constant conflicts with our extremist opposition. Some people in the HF
started to ask what the agenda of the HF really was - was it just to attack
groups on the left which were basically insignificant or was it to be a
lobby group for white rights and trying to change government policy? It
caused people with sensitive jobs to reconsider their membership and support
and to tone down public support.

32. In April of 1994, Bristow told me that the hate charges against Hategan
were going to be dropped because the anti-racists were no longer willing to
testify against her after her defection and testimony against Gary Schipper,
Ken Barker and myself. He was proven correct in this.

33. In 1991, Bristow, Sean McGuire and I were having lunch in Scarborough. I
left but within a minute of my leaving, a police swat team effected a
take-down of the car containing Bristow and McQuire. A rifle and shotgun
were found in the trunk of Bristow's car. Bristow always carried these guns
in the trunk. I had seen them there many times before. Both were taken to 41
Division Police Station. McGuire was held for possible immigration
violations but was eventually released and voluntarily returned to the
United States. Bristow was held for a short time. He telephoned me at the
bailiff's office which was located a short distance from the police station.
I met him at the police station and he told me what had transpired. He told
me the police were really pissed off at him but they couldn't "make anything
stick" so they were releasing him. Some people in the movement were
surprised he was not charged with unsafe storage of firearms.

34. In May of 1993, the computer of the Church of the Creator, a group
affiliated with HF, was stolen when the house was left unguarded on a night
an HF concert took place. Bristow was not at the concert which was extremely
unusual as he always attended all HF events in the city of Toronto as
security chief. This was the first event he had missed.

35. The day after the theft, Bristow made accusations against Tyrone Mason
who had left the concert early that evening. Bristow claimed that Mason had
a record for computer theft and had previously been charged with possession
of stolen goods. The Fisher brothers informed me that Bristow suggested to
them that they had to retrieve the computer. Bristow agitated what was
already a very volatile situation at the time.

36. The Fischer brothers and Drew Mason were later charged with kidnapping,
forcible confinement, assault causing bodily harm, threatening death after
picking Mason up in a white van and beating him to obtain information about
the computer. They told me that they concluded that Mason had not stolen the
computer. After release on bail, Eric Fischer told me that Bristow suggested
that it must be George Burdi who was responsible for the theft. Bristow went
as far as suggesting that Burdi should be killed.

37. The computer contained the names of members and supporters of the Church
of the Creator and some HF members who were members of the Canadian military
forces. A controversy had erupted in the House of Commons just weeks prior
to the theft about racism in the military.

38. Bristow was accused of witness tampering by the police. The lawyers for
the Fischer brothers told me that in a chambers hearing the police made
accusations that Bristow, along with two other individuals, might be witness
tampering. The police had attempted to wiretap Mason in an effort to obtain
evidence against Bristow but Bristow refused to meet with Mason and sent
someone in his place.

39. At trial, Drew Maynard's charges were dismissed for delay. The lawyers
for the Fischer brothers (Harry Doan and George Wootten) informed me that
they were called to a meeting with the prosecutors in the chambers of *****
**** ***** who was not the presiding judge in the case. Nevertheless, *****
offered a deal to the lawyers - if the Fischer brothers pleaded guilty they
would receive a 30 day sentence, if they did not plead guilty they would be
put away for a long time. The Fisher brothers accepted the deal.

40. Tyrone Mason expressed to me his shock at the light sentence the Fischer
brothers received. He told me he had not been consulted about the plea
bargain. The police detective in the matter, Det. McPherson expressed to me
outside the courtroom his outrage at the outcome.

41. On the evening that Gary Schipper's house was trashed by the Anti-Racist
Action, Bristow urged HF supporters who had gathered at Allen Gardens to
send a message to the ARA. He urged them to go to Sneaky Dees, a bar
frequented by the ARA, to let them know that the HF was not going to be
intimidated by their actions. As a result, about forty supporters went to
the bar and had drinks. After most of them had left, a fight broke out
outside between a large group of ARA supporters and a few remaining HF
supporters. As I was leaving Sneaky Dees in my car, I saw a lone HF member
being attacked by about twelve to fifteen ARA supporters. I jumped out of my
car and ran to the defence of the HF member. The fight turned into a huge
brawl involving up to seventy people. I was later charged and convicted of
aggravated assault and acquitted of weapons dangerous. The aggravated
assault charge was reduced to assault on appeal.

42. Bristow's actions contributed to a climate in Toronto which a Toronto
Sun editorial expressed as the city being held hostage by these warring
factions. Violent clashes occurred between the HF and extremist anti-racist
groups fuelled by Bristow's harassment campaign.

43. I believed we had to have dialogue with our opposition. At one time at
Toronto City Hall I was speaking to Marvin Kurz of B'nai Brith when Bristow
came up to us and started to confront him and be extremely rude and
threatening. Kurz fled in fear and sought protection.

                                Ernst Zündel

44. SIRC found on page 5.2 of the "Heritage Front Affair" that I requested
Zündel to provide information to be forwarded to Terry Long on various
"enemies." This is completely untrue. I never made any such request to
Zündel.

45. To my knowledge, Zündel works with all races in his day to day business
affairs. Zündel's printer for many years is Chinese and I have had dinner
with him and Zündel. Zündel allowed a black woman who needed a temporary
place to stay after losing her home to stay in his Toronto home for seven
months. I have met two East Indians at Zündel's house who work closely with
him on research projects. I met a Jewish man named David Cole from
California who has worked closely with Zündel on historical revisionist
matters. Ernst Zündel cannot be defined as a "white supremacist" or a
"racist." His preoccupation is undoing wrongs which he perceives have been
committed against the German nation.

46. Don Andrews, leader of the Nationalist Party, has expressed dislike of
Zündel and criticized him. He stated often to people that Zündel was nothing
but a German chauvinist who was only on the periphery of the right wing
until he was charged with spreading false news, lost his business and was
forced to fight. Only then out of necessity, did Andrews believe Zündel had
become a full-time activist. Andrews believed Zündel was concerned only with
the German issue of the Holocaust and not with the issues that concerned the
right wing - immigration, loss of culture, equity hiring and so on. Andrews
said that Germans should never be leaders in the movement because they were
arrogant, snobbish and had little understanding of anyone else. Andrews said
Zündel was strictly out for himself and provided little or no help to any
like-minded organization. This made Andrews angry because he felt Zündel had
the resources to provide help to organizations such as his own but did not.
Andrews said that if Zündel could reverse course he would gladly do so.

47. Bristow initially thought Zündel was a kook and a nut as did most
members of the Nationalist Party due to Andrews' influence. Andrews poisoned
a number of other people against Zündel. I introduced Bristow to Zündel in
1989 and thereafter he changed his opinion of Zündel. Bristow later spoke of
Zündel in an admiring fashion. The Holocaust was not an issue for Bristow.
He always expressed very anti-Jewish sentiments and went so far as to say
that the Holocaust wouldn't have been a bad idea.

48. I have known Ernst Zündel since 1975 and I have never heard him promote
or suggest violent means to attain his goals. He in fact has admonished me
on a number of occasions over the years for involving myself in activity
which he deemed improper. On the night Gary Schipper's house was trashed by
the Anti-Racist Action, Zündel urged me not to take retaliatory measures. He
said, "Don't do something stupid you are going to regret." In the last few
years I have tried to stay away from radical activities because of Zündel's
influence.

                SIRC and the "Heritage Front Affair Report"

49. SIRC investigators called me about the Heritage Front Affair in early
November of 1994. I met with them in Toronto for a period of about three or
four hours. The interview was extensive.

50. I was then asked later in the month to travel to Ottawa to be
interviewed by SIRC. On the trip I was accompanied by Al Overfield, the
attorneys Harry Doan and George Wootten. Overfield was interviewed in the
morning and I was heard in the afternoon for about two and a half hours.
Near five o'clock, the Chairman asked me if there was anything else. I
pointed out to the tribunal that I could go for quite some time to which
Eddie Goodman of SIRC replied, "Please don't."

51. I feel serious issues were never adequately addressed in SIRC's report
on the Heritage Front Affair such as the theft of the computer or the
possible witness tampering by Bristow in the Fischer brothers trial.

52. I believe the report is an utter sham. I recognize nothing of what I or
any of the people I spoke to about their testimony told SIRC. SIRC accepted
Bristow's version of events completely. Bristow is not in any way held
accountable for the harassment activity which he orchestrated. In fact, the
blame is shifted to me. For example, SIRC wrote "The Heritage Front then
became more militant as Droege wished to increase the confrontations with
his opponents...Bristow, in his position with the Heritage Front, carried
out Droege's instructions in regard to a harassment campaign and also
informed the anti-racists that a Heritage Front event was planned." (4.4 at
page 9) This is false. I never participated in, ordered or instructed any
harassment of our opponents.

53. SIRC claims at page 7 of "Methodology" that "We also held five full days
of formal hearings under oath, during which we questioned the principal
players in the affair." This is simply not the case. Only one of the
principal players in the HF, namely myself, was ever called to Ottawa to
testify. Yet others who worked closely with Bristow were never called.
People such as Ken Barker, Peter Mitrevski, Eric Fisher, Elkar Fisher,
George Burdi, Marc Lemire, Les Jasinski, Gary O'Neil, Becky Primrose and
many others never were called to Ottawa by SIRC. Nor did any one of them
ever indicate to me that they were interviewed by SIRC investigators. Each
one, I believe, could have provided vital evidence about Bristow's
activities.

54. The report is incomplete in the sense that many people who should have
been interviewed were not. Some like Gary Schipper, Gerry Lincoln, Max
French and others were interviewed only days prior to the release of the
report. These individuals informed me of this themselves. Al Overfield also
testified but he is not a member of HF.

55. The anti-racists refused to testify before SIRC because they wanted
legal representation and SIRC refused to pay. Because of this, SIRC failed
to get vital testimony about the harassment campaign and Bristow's role in
it. Therefore, the only sources viewed as being credible were Bristow and
CSIS. In my opinion, the report is biased and unbalanced and does not
present the truth.

56. In "I. Overview of the Extreme Right" SIRC writes that right wing
extremist groups "fundamental agreement is the conviction that whites
(aryans) are an endangered species. These beliefs lead, in turn, to their
attitudes which are: anti-Semitic; anti-non whites;
anti-immigration/refugee; anti-democratic; pro-free speech for racist or
anti-Semitic ideas; anti-human rights; and anti-gay." This is an inaccurate
description of the HF's goals and beliefs. HF believes in democracy and the
right of the majority to determine policy; it is pro-free speech for
everyone and has never suggested that free speech should be limited for
anyone; HF is not anti-human rights but believes the human rights laws are
applied selectively against whites; HF does not agree with the open
promotion of the homosexual lifestyle but does not believe in the creation
of laws to outlaw it; HF believes the public should have input into
immigration policy through referendums; it believes that the present
immigration policy will change the character of Canada and that these
policies were enacted without the consent of the public; HF believes many
Jewish organizations are working against the best interests of Canada and
therefore HF objects to their constant undermining of majority opinion on
issues such as equity hiring and immigration. The HF is open to Jews who
support its viewpoint. Even though I gave testimony before SIRC about HF's
policies and goals, SIRC seems adamant in believing biased media reports
about the HF and relies on information from people such as Stanley Barrett
and Warren Kinsella who are self-admitted opponents of the white racialist
movement and whose books are full of inaccuracies. For example, SIRC writes
at 1.2 at page 3 that "Andrews had the dubious distinction of being the
first person in Canada charged with wilfully promoting hatred", citing
Kinsella as its authority. This is not true. The first person charged under
the hate law was Armand Siksna.

57. SIRC writes at page 4 of 1.2 that I was "instrumental in increasing the
membership in the group [Ku Klux Klan] to an estimated 2,500 in 1980" citing
Kinsella again as its source. This figure is ludicrous. The real figure was
about 150 at its highest level.

58. SIRC writes at 1.3 that "Other neo-Nazi skinhead groups such as the
Aryan Resistance Movement and the Alberta-based Final Solution Skinheads are
organizing and finding a place in the extreme-right network in Canada,"
citing Kinsella as its source. This information is false. Both organizations
had been defunct since about 1990 or 1991.

59. SIRC writes at 3.2.4 at page 5 that "Don Andrews conducted a special
meeting. His 'Androids' were invited to his mansion." Andrews did not call
his supporters "androids". Andrews does not live in a "mansion" but in a
small, east-end working class Toronto semi-detached house. This is typical
of the hyperbole used by SIRC throughout the report.

60. SIRC describes at 3.2.4 at page 5 how the HF was allegedly formed and
what its goals were. This is full of falsehoods. The name "White Heritage
Foundation" was never considered. There was no covert side to the proposed
organization. I had no intention of targetting a specific country or area
and using "whatever persuasive methods or inducements necessary to convince
non-whites to leave the area" as alleged by SIRC quoting Bristow. There was
no such thing as "the Brethren" as described by SIRC. This fabrication is
repeated at 3.3.5 at page 12. I did not "consider" Gerry Lincoln and Bristow
for positions in the organization. Both in fact were co-founders of the HF.

61. SIRC writes at 3.3.1 at page 7 that I told Max French to "shut your
mouth." I never made this statement to Max French.

62. SIRC writes at 3.3.2 that on the trip to Libya we were "allowed to
reside in Camp Kadhafi some miles from Tripoli." We stayed at a camp with a
number of self-contained units. We referred to it humorously as "Camp
Kadhafi" but that was not its real name. Bristow's reports were obviously
spiced up with references like "Camp Kadhafi" to make the situation more
exotic than it really was. Bristow embellished his reports as if he were
writing a novel.

63. SIRC writes at 3.3.3 at page 9 that "Droege wanted to stay on the plane
and fly back to Rome, but the aircraft Captain told him either to get off or
be charged with piracy...They were strip-searched and had their body
cavities probed for contraband." The Captain never threatened me with
charges of piracy. He stated that if I did not get off the plane the police
would be called to have me forcibly removed. Again, the use of the word
"piracy" by Bristow is an embellishment on what really occurred. No one had
their body cavities probed for contraband. I was strip-searched but no other
person in the group told me that they were strip-searched. The falsehood
about body searches is repeated at 3.3.4 by SIRC.

64. SIRC writes at 3.3.4 that "Droege was released and driven to Niagara
Falls by the American authorities at night." This is not true. I was flown
from Chicago to Detroit and driven from the airport to Windsor. From there I
took a bus to Toronto. This indicates Bristow's information to CSIS was
inaccurate.

65. SIRC writes at 3.3.5 at page 12 that "Droege...said the HF...will use
the group to 'clandestinely forward the white supremacist movement.'" I
never made this statement and do not use the phrase "white supremacist" to
describe the HF. I do not subscribe to a "white supremacist" philosophy but
to a white nationalist philosophy.

66. SIRC writes at 3.3.5 at page 12 that "...Droege also formed the October
2nd Committee, 'an active measures commando unit to be run by him and to use
selected skinheads." This is an outright fabrication. No such "commando
unit" was ever contemplated or formed. There was no "military or direct
action wing" as alleged by SIRC in this same paragraph. These loaded terms
are suggestive of violence and terror.

67. SIRC writes at 3.3.5 at page 12 that "Droege intended to unite under the
Heritage Front those persons in Canada who were associated with The Order,
the Ku Klux Klan and the Aryan Nations.. The Front would be the primary
vehicle for 'furthering the white supremacist movement in Canada.'" This is
untrue as we were trying to seek out new people in a new organization that
average Canadians could identify with. Again, I do not use the term "white
supremacist" and the HF was not a "white supremacist" organization.

68. SIRC writes at 3.3.5 at page 12 that I wanted to buy land in
Peterborough area, control the town council and try to legislate racist
by-laws. This is a total fabrication.

69. At 3.3.5 at page 13, SIRC noted that I denied all that was stated in the
first full paragraph. However, SIRC did not accept my statements.

70. SIRC repeats the allegation about a "commando cell" at 3.3.5 at page 13.
No such "commando cell" existed or was even contemplated. These ideas only
existed in Bristow's imagination.

71. SIRC accepted Bristow's allegations at 3.3.5 that I wanted to fund the
HF with money from robbing drug dealers. I never promoted these ideas for
the HF.

72. SIRC writes at 4.1 that "We learned that...Droege...and others were
responsible for disrupting a television broadcast . The program was aired on
TV Ontario and dealt with racism issues. During the telephone-in portion of
the program, the Heritage Front group was able to partially tie up the
telephone lines, and they 'were also able to start a number of arguments
with the guest panel and state their white supremacist views.'" SIRC thus
describes as "disrupting" a TV program, the actions of HF members in calling
a phone-in TV show. It is not illegal to express legal opinions on a
phone-in show. SIRC repeats the falsehood that HF's policies were "white
supremacist."

73. SIRC writes at 4.1 that "Droege told Bristow about plans to distribute
leaflets at schools. They also discussed 'spray painting (anti-white
slogans) and vandalism operations' to discredit anti-racists..." I never
advocated these activities.

74. SIRC writes at 4.2 at page 2 that "Droege established a 'computer link'
with Terry Long, although this means of communication was short-lived." I
never owned a computer and therefore I did not establish a computer link
with Long. Bristow owned a computer and he communicated with Long using it.
He maintained this link until Long went into hiding.

75. SIRC writes at 4.2 at page 3 that "In May 1991, Terry Long, Wolfgang
Droege and Grant Bristow met to discuss, among other issues, the
establishment of a bulletin board (BBS) hate line similar to one in the
United States." I never met Terry Long in the company of Grant Bristow. HF
did not set up a "hate line." Of literally several hundreds of messages on
HF's telephone hotline, no message has ever been adjudicated to be hate. No
HF member has ever been convicted of inciting hatred under the Criminal
Code.

76. SIRC writes at 4.2 that "During the June Mississauga rally, Grant
Bristow served as an escort/bodyguard for Preston Manning, at the direction
of Al Overfield and Wolfgang Droege." This is untrue. Bristow suggested and
insisted that he should be Manning's bodyguard due to his experience in that
field.

77. SIRC writes at 4.2 at page 3 that "On June 19, 1991, Droege's racist
agenda was profiled...In that month, violent United States white
supremacist, Tom Metzger came to Canada at the invitation of Droege to
attend a Heritage Front rally." Metzger did not come to Canada in 1991. He
came in June of 1992.

78. SIRC writes at 4.2 at page 4 that "Droege wanted Bristow to make contact
with other white supremacists" in the United States. This is false. It was
Bristow who wanted to make contact with other white nationalist groups and
leaders. He used my name in making contact. SIRC uses the false description
"white supremacist" again. I do not use the term "white supremacist" and do
not subscribe to "white supremacist" philosophy.

79. SIRC writes at 4.2 at page 4 that "The Heritage Front's telephone Hate
Line was established by the Fall of 1991." HF's telephone hot line was and
is not a "Hate Line." This is a loaded propaganda term used by SIRC to
vilify HF. No member of HF has ever been convicted of inciting hatred which
is an indictable offence.

80. SIRC writes at 4.2 at page 5 that "In December 1991, American racist
Dennis Mahon entered Canada to speak to a Heritage Front meeting." Dennis
Mahon did not come to Canada until February 1992 to address a HF meeting.

81. SIRC writes at 4.3 at page 5 that "In 1992, the Front branched out. In
January of that year, Bristow was sent to Montreal by Droege 'for the
purpose of feeling out the White Supremacist movement there.'" I never sent
Bristow to Montreal. He travelled there on his own accord. SIRC again uses
the false description "white supremacist." I do not use the term "white
supremacist" and do not subscribe to "white supremacist" philosophy.

82. SIRC writes at 4.3 at page 7 that "In 1992, the Heritage Front members,
on the instructions of Droege, were using the telephone numbers they had
acquired to make increasingly violent threats against anti-racists." This is
false. I did not instruct HF members to make telephone or any other kind of
threat against anti-racists. Bristow was the person responsible for the
harassment campaign.

83. SIRC writes at 4.4 at page 8 that "Bristow provided some names to Alan
Overfield, under instruction from Droege." This is false. I never asked
Bristow to provide names to Overfield. If Bristow did, he did so on his own
initiative.

84. SIRC writes at 4.4 at page 9 that "The Heritage Front then became more
militant as Droege wished to increase the confrontations with his
opponents." This is false. I never wished to increase the confrontations. I
did not want any confrontations because it was counter-productive to the
HF's goals.

85. SIRC writes at 4.4 at page 9 that "Bristow, in his position with the
Heritage Front, carried out Droege's instructions in regard to a harassment
campaign...." This is false. I did not instruct Bristow on the harassment
campaign. The harassment was Bristow's own idea and doing.

86. SIRC writes at 5.2 that "Droege established a computer link with Long,
and the first successful test message took place..." I did not own a
computer and therefore made no electronic link with Long. Bristow owned a
computer and was in constant contact with Long.

87. SIRC writes at 5.2 at page 2 that "Ernst Zündel sometimes provided
information, at Droege's request, to be forwarded to Long. The information
concerned various 'enemies.'" This is false. I never asked Zündel to provide
information on "enemies."

88. SIRC writes at 5.2 at page 2 that "In July 1991, the Source obtained and
provided to CSIS a listing of personal information which Droege received
from Terry Long." This is false. I never received any such list from Long.

89. SIRC writes at 5.3 at page 3 that the HF set up a "Hate Line." This term
is used by SIRC to vilify HF and discredit it as a "hate" group. No member
of HF has ever been convicted of inciting hatred.

90. SIRC writes at 5.5 at page 5 that I "talked about 'spray painting and
vandalism operations'..." This is false. I opposed spray painting and
vandalism.

91. SIRC writes at 5.7 at page 9 that ..."Droege wanted all the
participating HF members to pbone ARA people and actually threaten them with
bodily harm." This is false. I did not participate in or instruct anyone to
harass HF opponents.

92. SIRC writes at 5.9.6 at page 22 that "Later, said the Source, they all
went to Zündel's house. Droege wanted a beer, but Zündel did not approve and
said that everyone should go home. Droege was upset, but Zündel was not; it
was not his house that had been trashed." This is false. Bristow knew very
well that I do not drink. We did not go to Sneaky Dees "for a beer" as
alleged by SIRC. Sneaky Dees was the hang out of the anti-racists. We went
there for the purpose of showing we were not intimidated by their trashing
of Gary Schipper's house. It is not true that "Bristow told the HF people to
settle down." In fact, Bristow agitated supporters to go to Sneaky Dees
although he did not advocate violence.

93. SIRC writes at 5.9.9 at page 25 that I might have slashed a woman's
tires although they have no evidence for this allegation. I never slashed
anyone's tires. This is another example of defamatory statements against me
by SIRC.

94. SIRC writes at 5.10.4 that at an anti-hate symposium in 1993 "Droege and
Burdi asked some abusive questions implying that Jews were racist. Wolfgang
Droege asked most of the questions." I did not ask "abusive" questions but
politely asked questions of Karen Mock of B'nai Brith. To ask questions is
part of public discourse and democracy. To use the word "abusive" implies
rudeness and hostility. I was neither. I believe this again shows SIRC's
bias against HF and the right wing.

95. This is not a complete list of errors, omissions and misrepresentations
in the SIRC report. There are many others but are too numerous to list in an
affidavit.

                                                         (Signed)
                                             ___________________________________
                                                     Wolfgang Droege

Sworn before me in the City of Toronto
this 26th day of April, 1996.
                                  (Signed)
                      ________________________________
                            A Commissioner, etc.

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                              SIRC Exposed page

Or go directly to these other affidavits

     [Wayne Elliott][Fischer][June French][Marc Lemire][Lincoln][Image]
                       [Tyrone Mason][Donna Elliott]
                   --------------------------------------
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[Image]

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