TORONTO: Libel Suit- First Salvo -Demand for Apology
Gregg <elrond1@home.com>
Fri, 30 Jun 2000 16:09:58 -0400

Toronto June 29, 2000

The following individuals received the letter appended below by courier on Friday June 30, 2000.

Liz Kristiansen
12 Hiawatha Rd.,
Toronto, Ontario
M4L 2X8

J.G. Layton
Layton Creations
128 Manville Rd. Unit 28
Scarborough, Ontario
M1L 4J5

Betty Misener
Reliable Promotions
725 Browns Line
Suite 201
Toronto, Ontario
M8W 3V7

Grahame F. Potter
Grahame Potter Marketing Inc.
385 Vaughan Road
Toronto, Ontario
M6C 2N8

A. Renault
XL Transcribing & Document Processing Services
1405 Lewisham Drive
Mississauga, Ontario
L5J 3R2

David Stokes
168 Lake Promenade
Etobicoke, Ontario
M8W 1A7

********************************************

William G. Hagglund C/O
Marks and Ciraco
Barristers, Solicitors
And Trademark Agents
247 North Service Rd. W.,
Suite 101
Oakville Ontario
L6M 3E6
905 844 1604

VIA COURIER

June 29, 2000.

Mx. Xxx
123 xxx.,
Toronto, Ontario
XxX xXx

Dear Mx Xxxxxx,

My wife and I have forwarded a copy of your defamatory letter of April xx, 2000 to our Solicitors.

We understand Mr. Eric Roher of Borden Ladner Gervais LLP, who represents the Toronto Board of Education, has already reprimanded you for your conduct.

*The patently false allegations or innuendoes you made were one or more of the following:*

With respect to Jennifer Hagglund:

Is too deficient in character to be a teacher.
Distributes hate literature or hate propaganda.
Is outspoken against your religion.
Assaults your religion.
Is a religious bigot.
Is involved in illegal hate crime activities.
Is involved in religious hatred in general.
Supports anti-religious or anti social activities.
Supports illegal hate crime activities.

With respect to Gregg Hagglund:

Distributes hate literature or hate propaganda.
Leads a group of hate mongers.
Is a hate monger.
Hates your religion
Assaults your religion.
Attempts to incite hatred against your church.
Is involved in illegal hate crime activities.
Is involved in anti-religious or anti social activities.
Is involved in religious hatred in general.
Yells obscenities in front of the scientology building.
Is a pedophile: Warned by the police to take down pictures of children
from his website.

Innuendo:
White Supremacist/Nazi: Is the same as Ernst Zundel.
Pedophilia: Is involved in taking children's pictures for the
Internet.

It is the obligation of those who make such accusations to have made at least some reasonable effort to establish the veracity of such statements. Failure to do so is not exculpatory in the event such statements prove false and legal action is prosecuted against those publishing the libel.

There is no evidence whatsoever to "support the serious allegations made by you. There is absolutely no evidence of professional misconduct, incapacity or incompetence on the part of Ms. Hagglund."

There is also no evidence whatsoever to support the serious allegations or innuendoes made by you about my conduct or myself.

The facts of the matter are that contrary opinion is neither harassment nor a hate crime. My activities of criticizing Scientology management, policies and 'technologies' are Charter Protected Freedom of Expression. The Toronto Hate Crimes Unit informed Mr. Al Buttnor, DSA, of that fact in late 1997 or early 1998. Detective Bone (7287) of 52 Division also informed Mr. Buttnor similarly in 1999. Detective Kijewski (5894), of the HCU was quoted in the Globe and Mail on February 24, 1999 as concurring, in particular, of my right to demonstrate and voice contrary opinion or reveal embarrassing fact.

Detective Kijewski would also confirm the police have never issued a warning nor made a request or demand for me to remove any photograph of anyone from any website I have been responsible for.

Additionally the Toronto police Department do not ignore individuals or groups who commit hate crimes. This may be confirmed with a simple phone call to the HCU.

" In all the circumstances, the statements contained in your letter are not only unfounded, but are also completely inappropriate" and recklessly inaccurate.

*Such statements, if not recanted by the author will definitely be subject to legal measures.*

Your allegations and innuendos in respect of my wife Ms. Hagglund and myself constitute a form of defamation in our opinion and in the opinion of others. "The comments that you made demonstrated either a wilful intent to bring prejudice to Ms. Hagglund or callous disregard for her professional reputation."

Equally so have you sought to bring prejudice upon my wife by association with acts by myself, which you allege or imply, are illegal. Since you either know these serious allegations or implications to be false or could easily independently determine them to be so, the burden falls upon you to be held responsible for the legal consequences of publishing such libel.

It is very apparent you have very little to gain and much to lose by participating in a malicious libel campaign orchestrated for the benefit of the Church of Scientology.

You should note the Supreme Court has upheld the Criminal Code in respect to the crime of Criminal Libel. " The Court held that "perpetrators who wilfully and knowingly publish lies deserve to be punished for their grievous misconduct." The principal object of the criminal law is the recognition of society's abhorrence of a criminal act and the punishment of criminal behaviour. Civil law has as its main goal compensation through awards of damages. Further, the Court said, a civil action will have little, if any, deterrent effect on impecunious defendants."

The recent victory by Mrs. Bonnie Woods in her libel suit against individuals and Scientology in Great Britain should clearly indicate to you how perilous your position is. The circumstances of her suit are nearly enough identical to the instant matter as to serve as a template for the course of action my wife and I are considering.

Our Solicitors, thanks in part to Mr. Minton and the LMT, will have the same access, or greater, as Ms. Woods did to internal Scientology policy documentation and expert witnesses.

We are confident any jury would look upon the unchanged and unapologized for anti-social conduct and internal policy mandates of Canada's only criminally convicted Church with little sympathy.

Therefore, your abject apology and complete recantation of all allegations made by you is required, in writing, immediately. This must be sent within the next 10 business days to all of your previous recipients. A copy may be sent to my wife and myself care of our Solicitors. In addition, you are put on notice that you, or anyone acting in concert with you, are not to have any direct contact with any member of my family. Any attempt by yourself or anyone you act in concert with, to deliver direct communications with my family, in any manner, will be considered as harassment.

Obviously any recantation by yourself will certainly serve your best interests in any civil or criminal actions, which may ensue. However, said recantation should not be construed as a release by us of yourself or others, of legal responsibility, civil or criminal, for the impact of your initial letter.

In any event, whether you choose to recant or not, and only excepting your letter of recantation, "you are hereby formally put on notice to cease and desist immediately from making or circulating, in any manner whatsoever, any comments, commentary or other information with respect to" my wife, myself, any member of our family or those we associate with, especially within our community.

Our current Solicitors address is above.

Sincerely Yours,

William G Hagglund.

*********************************************

Gregg Hagglund SP7

Toronto and Canadian National Picket Reports now at: < http://www.geocities.com/HotSprings/Spa/8412/toronto/index.html>

"It's interesting that Scientologists cannot seem to differentiate between: ----individuals: picketing an organization to voice their opinion on its behavior, and -----an organization: picketing individuals for voicing their opinion." - M.C.DiPietra

"Give'em hell son." the late M.G.Hagglund