Zundelsite - RCMP Search Warrant

INFORMATION TO OBTAIN A SEARCH WARRANT CANADA:

PROVINCE OF BRITISH COLUMBIA

This is the information of Constable Warren Leigh RYAN, Officer of Royal Canadian Mounted Police, in the City of Vancouver, hereafter called the "informant", taken before me, the undersigned Justice of the Peace in and for the Province of British Columbia.

The informant says that he has reasonable grounds to believe that the offences:

Darren Todd THURSTON
David Nathan BARBARASH

Count 1

On May 16, 1995, at Toronto, Ontario did attempt to murder Ernst ZUNDEL by manufacturing and mailing an explosive device, contrary to Section 239 of the Criminal Code of Canada.

Count 2

On June 12, 1995, at Yarrow, British Columbia did attempt to murder Charles SCOTT by manufacturing and mailing an explosive device, contrary to Section 239 of the Criminal Code of Canada.

Count 3

On July 11, 1995, at or near Cochrane, Alberta did attempt to murder Terence MITENKO by manufacturing and mailing an explosive device, contrary to Section 239 of the Criminal Code of Canada.

Count 4

On July 13, 1995, at Toronto, Ontario did attempt to murder John THOMPSON by manufacturing and mailing an explosive device, contrary to Section 239 of the Criminal Code of Canada.

Count 5

Between the 29th day of December 1995 and the 31st day of January 1996, at or near the City of Vancouver, and elsewhere in the Province of British Columbia, with intent to do bodily harm to Philip Des Mazes, did send to Philip Des Mazes a dangerous thing, to wit, a three and one half inch long razor blade which was taped to a card contained in an envelope, contrary to section 81(1)(b)(ii) of the Criminal Code of Canada.

Count 6

Between the 29th day of December 1995 and the 31st day of January 1996, at or near the City of Vancouver, and elsewhere in the Province of British Columbia, with intent to do bodily harm to Gerald Geraci, did send to Gerald Geraci a dangerous thing, to wit, a three and one half inch long razor blade which was taped to a card contained in an envelope, contrary to section 81(1)(b)(ii) of the Criminal Code of Canada.

Count 7

Between the 29th day of December 1995 and the 31st day of January 1996, at or near the City of Vancouver, and elsewhere in the Province of British Columbia, with intent to do bodily harm to Kenneth Belford, did send to Kenneth Belford a dangerous thing, to wit, a three and one half inch long razor blade which was taped to a card contained in an envelope, contrary to section 81(1)(b)(ii) of the Criminal Code of Canada.

Count 8

Between the 29th day of December 1995 and the 31st day of January 1996, at or near the City of Vancouver, and elsewhere in the Province of British Columbia, with intent to do bodily harm to David Fyfe, did send to David Fyfe a dangerous thing, to wit, a three and one half inch long razor blade which was taped to a card contained in an envelope, contrary to section 81(1)(b)(ii) of the Criminal Code of Canada.

Count 9

Between the 29th day of December 1995 and the 31st day of January 1996, at or near the City of Vancouver, and elsewhere in the Province of British Columbia, with intent to do bodily harm to Jim Shockey, did send to Jim Shockey a dangerous thing, to wit, a three and one half inch long razor blade which was taped to a card contained in an envelope, contrary to section 81(1)(b)(ii) of the Criminal Code of Canada.

Count 10

Between the 29th day of December 1995 and the 31st day of January 1996, at or near the City of Vancouver, and elsewhere in the Province of British Columbia, with intent to do bodily harm to Thomas Christie, did send to Thomas Christie a dangerous thing, to wit, a three and one half inch long razor blade which was taped to a card contained in an envelope, contrary to section 81(1)(b)(ii) of the Criminal Code of Canada.

Count 11

Between the 29th day of December 1995 and the 31st day of January 1996, at or near the City of Vancouver, and elsewhere in the Province of British Columbia, with intent to do bodily harm to Keith Connors, did send to Keith Connors a dangerous thing, to wit, a three and one half inch long razor blade which was taped to a card contained in an envelope, contrary to section 81(1)(b)(ii) of the Criminal Code of Canada.

Count 12

Between the 29th day of December 1995 and the 31st day of January 1996, at or near the City of Vancouver, and elsewhere in the Province of British Columbia, with intent to do bodily harm to Bob Fontana, did send to Bob Fontana a dangerous thing, to wit, a three and one half inch long razor blade which was taped to a card contained in an envelope, contrary to section 81(1)(b)(ii) of the Criminal Code of Canada.

Count 13

Between the 29th day of December 1995 and the 31st day of January 1996, at or near the City of Vancouver, and elsewhere in the Province of British Columbia, with intent to do bodily harm to Eldon Hoff, did send to Eldon Hoff a dangerous thing, to wit, a three and one half inch long razor blade which was taped to a card contained in an envelope, contrary to section 81(1)(b)(ii) of the Criminal Code of Canada.

Count 14

Between the 29th day of December 1995 and the 31st day of January 1996, at or near the City of Vancouver, and elsewhere in the Province of British Columbia, with intent to do bodily harm to Graham Perry, did send to Graham Perry a dangerous thing, to wit, a three and one half inch long razor blade which was taped to a card contained in an envelope, contrary to section 81(1)(b)(ii) of the Criminal Code of Canada.

Count 15

Between the 29th day of December 1995 and the 31st day of January 1996, at or near the City of Vancouver, and elsewhere in the Province of British Columbia, with intent to do bodily harm to Stuart Maitland, did send to Stuart Maitland a dangerous thing, to wit, a three and one half inch long razor blade which was taped to a card contained in an envelope, contrary to section 81(1)(b)(ii) of the Criminal Code of Canada.

Count 16

Between the 29th day of December 1995 and the 31st day of January 1996, at or near the City of Vancouver, and elsewhere in the Province of British Columbia, with intent to do bodily harm to George Padneault, did send to George Padneault a dangerous thing, to wit, a three and one half inch long razor blade which was taped to a card contained in an envelope, contrary to section 81(1)(b)(ii) of the Criminal Code of Canada.

Count 17

Between the 29th day of December 1995 and the 31st day of January 1996, at or near the City of Vancouver, and elsewhere in the Province of British Columbia, with intent to do bodily harm to Robert Nielson, did send to Robert Nielson a dangerous thing, to wit, a three and one half inch long razor blade which was taped to a card contained in an envelope, contrary to section 81(1)(b)(ii) of the Criminal Code of Canada.

Count 18

Between the 29th day of December 1995 and the 31st day of January 1996, at or near the City of Vancouver, and elsewhere in the Province of British Columbia, with intent to do bodily harm to Volker Scherm, did send to Volker Scherm a dangerous thing, to wit, a three and one half inch long razor blade which was taped to a card contained in an envelope, contrary to section 81(1)(b)(ii) of the Criminal Code of Canada.

Count 19

Between the 29th day of December 1995 and the 31st day of January 1996, at or near the City of Vancouver, and elsewhere in the Province of British Columbia, with intent to do bodily harm to Don Caldwell, did send to Don Caldwell a dangerous thing, to wit, a three and one half inch long razor blade which was taped to a card contained in an envelope, contrary to section 81(1)(b)(ii) of the Criminal Code of Canada.

Count 20

Between the 29th day of December 1995 and the 31st day of January 1996, at or near the City of Vancouver, and elsewhere in the Province of British Columbia, with intent to do bodily harm to Doris B. and Leo Quellet, did send to Doris B. and Leo Quellet a dangerous thing, to wit, a three and one half inch long razor blade which was taped to a card contained in an envelope, contrary to section 81(1)(b)(ii) of the Criminal Code of Canada.

Count 21

Between the 29th day of December 1995 and the 31st day of January 1996, at or near the City of Vancouver, and elsewhere in the Province of British Columbia, with intent to do bodily harm to Kenneth Pickering, did send to Kenneth Pickering a dangerous thing, to wit, a three and one half inch long razor blade which was taped to a card contained in an envelope, contrary to section 81(1)(b)(ii) of the Criminal Code of Canada.

Count 22

Between the 29th day of December 1995 and the 31st day of January 1996, at or near the City of Vancouver, and elsewhere in the Province of British Columbia, with intent to do bodily harm to Wayne Raymond Mueller, did send to Wayne Raymond Mueller a dangerous thing, to wit, a three and one half inch long razor blade which was taped to a card contained in an envelope, contrary to section 81(1)(b)(ii) of the Criminal Code of Canada.

Count 23

Between the 29th day of December 1995 and the 31st day of January 1996, at or near the City of Vancouver, and elsewhere in the Province of British Columbia, with intent to do bodily harm to Catherine Solmonson, did send to Catherine Solmonson a dangerous thing, to wit, a three and one half inch long razor blade which was taped to a card contained in an envelope, contrary to section 81(1)(b)(ii) of the Criminal Code of Canada.

Count 24

Between the 29th day of December 1995 and the 31st day of January 1996, at or near the City of Vancouver, and elsewhere in the Province of British Columbia, with intent to do bodily harm to David Hooper, did send to David Hooper a dangerous thing, to wit, a three and one half inch long razor blade which was taped to a card contained in an envelope, contrary to section 81(1)(b)(ii) of the Criminal Code of Canada.

Count 25

Between the 29th day of December 1995 and the 31st day of January 1996, at or near the City of Vancouver, and elsewhere in the Province of British Columbia, with intent to do bodily harm to Robert Milligan, did send to Robert Milligan a dangerous thing, to wit, a three and one half inch long razor blade which was taped to a card contained in an envelope, contrary to section 81(1)(b)(ii) of the Criminal Code of Canada

and recovery of the following things, namely:

1. All computer systems of unknown make or model, and all their peripherals including but not limited to: Hard Drives, Central Processing Unit, Cables, Connectors, Monitor, Computer disks and diskettes, external hard drives, Optical disks, Mouse, keyboard, and/or any other electronic, electro-magnetic, acoustic, mechanical or other storage or communication device capable of storing, retrieving, transmitting and receiving computer data.

2. Modulator / Demodulator device or Modulator / Demodulator devices, known as a modem or modems, of unknown make or model, and all peripherals including but not limited to: cables and connectors.

3. Any computer software and manuals including but not limited to: programs and/or computer instructions which causes a computer to automatically dial telephone numbers and/or to automatically generate numeric sequences or other functions which directly relate to accessing other computer systems.

4. Computer printer and/or photocopier and peripherals including but not limited to: cables and connectors.

5. Hard copies of data, in the form of text or otherwise, belonging to, or relating to Darren Todd THURSTON and or David Nathan BARBARASH.

6. Any documentation and/or files that belong to, or relate to Darren Todd THURSTON and David Nathan BARBARASH including, but not limited to, letters and correspondence, telephone bills, diaries, address books and lists, notes, receipts, records of purchase, postage stamps, bomb building manuals and other literature relating to the building of bombs, and other papers including communiqués, files and books relating to the offences described below including newspaper clippings, scrap book collections, diagrams, drawings, notes, and texts.

7. Any and all hardware used to create and connect one of the following bomb components: timer or trigger, power source, batteries, explosive material, including single based smokeless powder, casings, container, wires, connectors, anything that can be projected to cause injury, or can be used for Conveyance and/or concealment including but not limited to mousetraps, seven strand copper "speaker" wire, single strand copper wire, seven strand silver "speaker" wire, glue, plastic nine volt battery connectors, two inch common nails, two point five inch finishing nails, alligator clips, two point two five inches outside diameter pipe, one point five inches outside diameter pipe, three inches outside diameter pipe, and caps for the afore mentioned pipes, clear tape, dark tape, rubber bands.

8. Dark items of clothing, threads and fibres from dark items of clothing, dark threads and fibres from other items of clothing.

9. Razor blades, utility knives, utility knife blades, envelopes of various sizes, scotch tape, masking tape, electrical tape, file cards, index cards, labels, paper, and personal keys.

10. In order to completely and accurately retrieve data maintained in a computer system or on computer software, all computer equipment, peripherals, related instructions in the form of manuals and notes, as well as the software utilized to operate such a computer system should be seized in order to be subsequently processed by a qualified computer specialist in a laboratory setting.

11. Audio transmission devices which include 63´0262 audio transmitter; 63E0258 pager switch; and 61EQ147 audio transmitter

will afford evidence with respect to the commission of the above offences, and that the things above mentioned or some part of them are in

Storage Locker #3-2663 located at Maple Leaf Self Storage at 3001 Wall Street, Vancouver, in the Province of British Columbia (the "premises")

GROUNDS FOR BELIEF

1, Warren Lee Ryan, of the City of Vancouver, in the Province of British Columbia, a member of the Royal Canadian Mounted Police, MAKE OATH AND SAY THAT:

1. I am the informant herein and have personal knowledge of the matters and facts to which I hereinafter depose, save and except where such matters and facts are stated to be based upon information and belief, and where so stated, I verily believe them to be true.

2. I am a Peace Officer, and have been a member of the Royal Canadian Mounted Police ("RCMP") since 1977. I am a Constable stationed with the Vancouver RCMP National Security Investigations Section ("Vancouver NSIS"), and have been attached to this section since October 1995.

3. Since April 25, 1995, members of Vancouver NSIS, members of the Edmonton National Security Investigations Section, members of the Ontario Security Investigations Section, members of the RCMP General Investigations Section in Calgary and Edmonton, Alberta and Chilliwack, British Columbia, members of the Metropolitan Toronto Police Service Intelligence Services, Edmonton Police Service and members of the Vancouver Police Department have been involved in the investigation of criminal activity involving:

(a) Persons identified as:

(i) Darren Todd THURSTON, also known as Steve REYNOLDS, Kelly John WHYTE, and Darren Todd McINNES, also known as Darren TURNER,
Basement #2, 130 West 10th Avenue
Vancover, B.C.
Occupation: Unemployed

(ii) David Nathan BARBARASH, also known as David BAKER and Lawrence Troy BEYER
4516 Gladstone St.
Vancouver, B.C.
Occupation: Unemployed

(b) Unknown person or persons who describe themselves as:

(i) The "Anti-Fascist Militia" ("AFM")

(ii) The "Militant Direct Action Task Force ("MDATF")

(iii) The "Justice Department"

4. The offences being investigated by Vancouver NSIS are the following:

(a) Attempted murder, contrary to section 239 of the Criminal Code of Canada.

(b) Sending or delivering to a person an explosive substance or any other dangerous substance or thing, contrary to Section 81(1)(b)(ii) of the Criminal Code of Canada.

(c) Conspiracy to commit murder, contrary to section 465(1)(a) of the Criminal Code of Canada, and

(d) Conspiracy to send or deliver to a person an explosive substance or any other dangerous substance or thing, contrary to section 465(1)(c) of the Criminal Code of Canada.

5. All the locations referred to in this information to obtain are in the Province of British Columbia ("B.C."), unless otherwise indicated. When reference is made to Cochrane, Calgary, and Edmonton, these locations refer to the Province of Alberta. When reference is made to Toronto and Guelph, these locations refer to the Province of Ontario.

6. This investigation commenced when an envelope was received by Mr. Ernst ZUNDEL, in Toronto, on April 13, 1995, which contained a mouse trap to which a razor blade was affixed.

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