IN THE FEDERAL COURT OF CANADA
THE ATTORNEY GENERAL OF CANADA
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 scientifically
and forensically examine widely-held but never properly examined 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.
5. Through this password I access the site to make changes, additions,
deletions or graphic alterations to the Zundelsite which I do on a regular
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
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 verification. 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 firstname.lastname@example.org for the 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 served 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.
15. One specific Zundelsite document, challenged by the Canadian Human
Rights Commission 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 re-posted 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 invited many
times as a guest lecturer for historical events or college level history
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 America 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
Ingrid A. Rimland, Ed.D.