16. On December 7, 1995, I was advised by Special Constable Roy GABRIEL of the Vancouver RCMP Explosive Disposal Unit, and verily believe that:

(a) He examined the parcel pipe bomb sent to Mr. Charles SCOTT.

(b) He observed the components of this pipe bomb as having a mousetrap switch, a nine volt battery, a black nine volt battery connector with red and black wires, and nails secured to the pipe bomb.

17. On November 30, 1995, I was advised by Detective Constable Dave MALCOLM of the Metro Toronto Police Force Intelligence Unit, and verily that:

(a) He was also the principal investigator on the attempted murder investigation concerning the parcel pipe bomb sent to Mr. John THOMPSON at the MACKENZIE INSTITUTE in Toronto and he has personal knowledge of this investigation.

(b) On July 13, 1995 ___________ the publication manager at the MACKENZIE institute, ________ Toronto, Ontario, picked up the mail for the Institute at the post office, included in the mail was a parcel addressed to:

"Mr. John THOMPSON - personal
Executive Director
The Mackenzie Institute
PO Box 338
Adelaide Station
Toronto, Ontario
M5C 2J4"

(c) The return address on this parcel was the "Fraser Institute, 626 Bute, Vancouver, B.C. V6E 4E8"

(d) ______ opened the parcel to realize that it contained a pipe bomb. The only reason that the device did not detonate when opened was because the power source had become disconnected.

(e) The pipe bomb was 8" galvanize pipe, 1 1/2'" diameter, a quantity of 2" inch nails secured around the pipe with clear tape, a mouse trap switch, a nine volt battery which had dislodged from the worn connector, a red and black connector which was wrapped in white packing tape.

(f) _______ brought the parcel to Mr. John THOMPSON who contacted the police.

(g) The device was detonated by the Explosives Disposal Unit of the Metro Toronto Police Force. The blast was described as significantly more powerful than the parcel pipe bomb sent to Mr. ZUNDEL.

18. On April 16, 1996, I was advised by Detective Steve IRWIN of Metro Toronto Police Intelligence Section, and I verily believe, that he has taken over conduct of the investigation, into the attempted murder of Mr. ZUNDEL and Mr. THOMPSON, from Detective MALCOLM as of March 20, 1996.

19. On December 13. 1995, I was advised by Cpl. FORESTELL of Vancouver NSIS, and verily believe it to be true, that on July 25, 1995, a meeting involving investigators from Vancouver, area enforcement agencies was held at the offices of Vancouver NSIS. It was decided that from the information presently available to them, THURSTON and BARBARASH should be the main focus of the investigation. This was based on knowledge of THURSTON and BARBARASH's previous involvement in the environment movement and their extremist activity aligned with this movement. BARBARASH and THURSTON participated in a break and enter of the University of Alberta Bio Animal Kennel in Edmonton on June 1, 1992. THURSTON was subsequently convicted in connection with this incident in 1993; BARBARASH was convicted in 1994. THURSTON was also convicted in 1993 of the offence of setting fire to the property of a fish supply company in Edmonton, the Billingsgate Fish Company Limited. BARBARASH is presently and publicly active within the Earth First and Bear Watch operations. BARBARASH is associated to Animal Liberation Front activists who are known to use mouse trap warning letters. THURSTON is a former and/or present member of the Animal Liberation Front (ALF), Skinheads against Racial Prejudice (Sharp), and the Anti Fascist League (AFL)

20. On November 29, 1995, I did computer inquiries on the Canadian Police Information Centre (CPIC) computer on Darren Todd THURSTON and acquired the following information:

(a) Darren Todd THURSTON was born on March 8, 1970. He is also know as Darren Todd McInnes.

(b) Darren Todd THURSTON has a criminal record in Canada for the following:

(i) On September 23, 1993, in Edmonton, Alberta, he was convicted of Break and Enter and Commit, Section 348(1)(b)CCC and Setting Fire to Other Substance, Section 434 CCC. He was sentenced to two years less 1 day on each charge, concurrent, on appeal on May 12, 1994.

(c) On September 3, 1993, in Edmonton, Alberta, a charge of Mischief Under $1000.00. Section 430(4) CCC against Darren Todd THURSTON, was dismissed.

21. On April 16, 1996, I obtained a notice of appeal and a certificate of judgment from the Alberta Court of Appeal in regard to the sentence appeal referred to in subparagraph 20(b)(i) above. These documents show that the convictions on the break and enter and the arson offences actually occurred on September 3, 1993. Further, these documents indicate that THURSTON pleaded guilty to the offences on the Court of Queen's Bench and received a suspended sentence and two years probation on each count and a compensation order in the amount of $73,725.00. The compensation order was for $26,725.00 on count #1 (the break and enter) and for $47,000.00 on count #2 (the arson). On the Crown appeal against sentence, the Court of Appeal varied THURSTON's sentence to two years less one day concurrent on each count, compensation order affirmed.

20. On April 17, 1996, I obtained a copy of an Order made by a judge of the Provincial Court of Alberta at Edmonton on October 28,1993 pursuant to section 103(6) of the Criminal Code regarding Darren Todd THURSTON. The Court prohibited THURSTON from having possession, custody or control of any firearm, other offensive weapon, ammunition or explosive substance for a period of five years from the date of the Order. The Court also revoked any Firearms Acquisition Certificates issued to THURSTON and prohibited THURSTON from applying for a Firearms Certificate for a period of five years.

23. On April 17, 1996, I obtained a copy of an information dated September 1, 1995, charging Darren Todd THURSTON with one count of being unlawfully at large within Canada on August 31, 1995, before the expiration of a term of imprisonment to which he was sentenced. On November 10, 1995, THURSTON pleaded guilty to this charge and was sentenced to one day incarceration.

24. On November 29, 1995, I did computer inquiries on the Canadian Police Information Center (CPIC) computer on David Nathan BARBARASH and acquired the following information:

(a) David Nathan BARBARASH was born on September 1, 1964. He is also known as Lawrence Troy Beyer.

(b) David Nathan BARBARASH has a criminal record in Canada for the following:

(i) On December 13, 1982, in Brampton, Ontario, he was convicted of Possession of Narcotics, Section 3(1) NCA and was sentence to a $300.00 fine, in default 15 days.

(ii) On December 22, 1988, in Toronto, Ontario, he was convicted of three charges of Mischief, Possession of Burglar tools, and Possession of Property Obtained by Crime under $1000.00. He received a Suspended sentence and probation for 1 year.

(iii) On June 9, 1992, in Vancouver, B.C., he was convicted of Theft under $1000.00, Section 334(b) CCC, and received a Suspended sentence and Probation for 1 year.

(iv) On September 8, 1994, in Edmonton, Alberta, he was convicted of Break and Enter, Commit, Section 348(1)(B) CCC and received a suspended sentence and Probation for 18 months.

(c) In my CPIC check, I further learned that other charges against David Nathan BARBARASH were disposed of as follows:

(i) On February 2, 1984, a charge of Mischief to Private Property was dismissed in Toronto, Ontario.

(ii) On October 29, 1987, a charge of Possession of Burglar tools was withdrawn in Toronto, Ontario.

(iii) On November 5, 1987, five charges of Mischief were withdrawn in Toronto, Ontario.

(iv) On November 22, 1988, five charges of Mischief, Possession of Explosives with Intent, Possession of a Prohibited Weapon were all withdrawn in Toronto, Ontario.

25. On December 13, 1995, I was advised by Cpl. FORESTELL, of Vancouver NSIS, and verily believe it to be true that:

(a) On July 25, 1995 at 1345 hrs, he attended at the Vancouver Sun newspaper office, 2250 Granville Street, Vancouver, B.C. and received a communiqué and the envelope it was contained in, from reporter Kim BOLAN. The communiqué had been sent to their office. The communiqué was from the MDATF which claimed responsibility for the ALTA GENETICS INC. parcel pipe bomb.

(b) On July 25, 1995 at 1554 hrs, he attended at the Pacific Press Building, 2250 Granville Street, Vancouver, B.C. and met with the Province newspaper reporter, Paul CHAPMAN. CHAPMAN turned over a communiqué and the envelope it was contained in to Cpl. FORESTELL.

26. On November 30, 1995, I read copies of the two MDATF communiqués that had been received by the Vancouver Sun and Vancouver Province newspapers on July 25, 1995. A comparison of the logo on these two communiqués to that of the first communiqué received by the Montreal Gazette on June 26, 1995 showed that they were the same. The two communiqués claimed responsibility for the ALTA GENETICS INC. parcel pipe bomb and the MACKENZIE INSTITUTE in Toronto. In reference to the ALTA GENETICS INC. parcel pipe bomb communiqué (#2), it blames the company's role in genetic tampering and reproductive technology with cattle as being the reason for having been the recipient of the bomb. The communiqué goes on to compare the company's work with animal genetics to that of the Nazis and their experimentation on humans. The communiqué goes on to advise that the MDATF is against all human/animal/plant genetic and reproduction technology. The first MDATF communiqué sent on June 26, 1995 not only took responsibility for the sending of the SCOTT and ZUNDEL bombs, but further it advised that their actions would not be limited to fascists. The communiqué warns Imperialists, Fascists, Military Weapons Producers, Eco Destroyers and all other oppressors that they may be targets of Armed Resistance. At the top of this communiqué is a logo depicting a silenced version of an assault weapon with a star containing an "A" in same as part of the initials displayed MDATF.

27. On December 5, 1995, I was advised by Cpl. Bill SIMPSON ("Cpl. SIMPSON") of Calgary RCMP General Investigation Section, whom I verily believe, that:

(a) He obtained the same communiqués from the Calgary Herald newspaper on July 27, 1995, that had been received by the Vancouver Province newspaper on July 25, 1995.

(b) Both communiqués came in envelopes with the cancelled postmark being Vancouver, British Columbia.

28. On November 30, 1995, March 8, 1996 and April 19, 1996, I was advised by Cst. Robert POWERS, ("Cst. POWERS") of Edmonton Police Service Crime Analysis Section, and verily believe that:

(a) He had been with the Edmonton Police Service for eighteen years. He has been a Criminal Analyst for seven years and that he is the senior analyst on the section. He has received Intelligence Analysis training at the Canadian Police College, Ottawa, Ontario in 1990. He completed the Advanced Analytical Workshop hosted by the Canadian Security Intelligence Canada held in Regina, Saskatchewan in 1992. He is a member of the International Association of Law Enforcement Intelligence Analysts (IALEIA). He has received certification as a criminal analyst from the Society of Certified Criminal Analyst (SCCA) in 1993, one of 45 members worldwide. He has completed instructors training in Strategic Intelligence Analysis and has instructed basic and strategic analysis training for various police agencies. He was assigned as the co-analyst for the investigation into the "Cold Buster Bar" incident in Edmonton, Alberta in January, 1993. This was an investigation involving Animal Rights groups who claimed to have poisoned food energy bar products. He has continued to provide analytical support for investigators looking into animal rights extremist activities in Edmonton. He completed an analysis of the Animal Liberation Front and Darren THURSTON after his arrest in 1993.

(b) He compiled an assessment on Darren Todd THURSTON, which was dated August 15, 1995 in relation to his possible involvement in the MDATF campaign involving animal rights. That this assessment is based on documentary evidence received from THURSTON's own files which were seized during the investigation of the Break and Enter in 1992 of which THURSTON was convicted in 1993. That Cst. POWERS was personally involved in that investigation of THURSTON for that offence and THURSTON's involvement in the Animal Liberation Front and other animal rights organizations.

(c) Cst. POWERS concluded in the assessment that it is probable that THURSTON is linked to this current wave of terrorist type activity.

(d) THURSTON's activist background includes animal rights and anti-fascist groups such as COAL - Coalition for Animal Liberation, ALF - Animal Liberation Front, SHARP - Skinheads against Racial Prejudice, and AFL - Anti-Fascist League.

(e) That he has provided the following conclusions regarding Darren THURSTON's involvement with the group claiming responsibility for the pipe parcel bombs:

(i) THURSTON is familiar with anti-fascist groups world wide through personal correspondence and information gathering. THURSTON organized local chapters of SHARP - Skinheads Against Racial Prejudice, and the AFL - Anti-Fascist League in Edmonton.

(ii) Comprehensive intelligence files were maintained by THURSTON on fascist organizations and their members which, when reviewed, showed the names and addresses of eight of the ten targets identified in the Anti-Fascist Militia communiqué to Reuters News Service in April 1995. These files were seized in 1992 at the time of THURSTON's arrest for the Breaking and Entering and Arson offenses that he committed and, as such, the information on those files is now dated. This could account for the outdated addresses used on some of the mousetrap letters sent to the listed White Supremacists.

(iii) There is a close link between the animal rights and anarchist anti-fascist causes. This would explain the connection between the seemingly unrelated targets of the four parcel bombs. THURSTON is closely involved in both causes and has been involved in extremist acts with the Animal Liberation Front and is strongly suspected of carrying out actions as part of the Animal Rights Militia.

(iv) THURSTON was on probation as a result of his temporary absence permit from Fort Saskatchewan Correctional Centre. This period of probation expired on September 19, 1995. During the period of probation, THURSTON was not allowed to leave the city of Edmonton. THURSTON maintained his association with other activists in British Columbia, through his employment with Victoria Alternative Literature and Information Distributors in Victoria, British Columbia. His work is done by telephone, or through a computer modem from his mother's residence, which would allow him the opportunity to collaborate with associates in Vancouver where the parcel bombs are being sent from.

(v) THURSTON has the interest, knowledge and experience to make explosives. Documents seized from THURSTON's residence in 1992 included a manual complete with diagrams, on how to construct a pipe bomb utilizing a mouse trap as the triggering device, and a battery source which is the same construction and set up of the four parcel bombs that have been received to date. Also from the Crime Analysis Section Intelligence files, THURSTON further earned the nickname the "Mad Bomber" while attending Harry Ainlay High School in Edmonton in the early 1980s. He was suspected, along with another youth from the school, of setting off a pipe bomb under an old bridge on the south side of Edmonton. Several of the intelligence files THURSTON maintained involved bombing incidents by terrorist groups worldwide.

(vi) THURSTON would be aware of altering group names to carry out extremist acts. A group or organization's name which utilizes passive protest methods would be changed slightly with the changing of words within the name or adding a last name. An example of this would be his use of the Animal Liberation Front "Support Group" to carry on certain group actions such as fund raising and public awareness campaigns, the Animal Liberation Front for carrying out minor extremist actions and finally the Animal Rights Militia for the serious actions. Involvement in the Anti-Fascist League may require a variation of the group name to the Anti-Fascist Militia to carry out the pipe bombing campaign. Also seized from THURSTON in 1992 were newsletters from other terrorist groups. In one of these newsletters, reference was made to "The Militant Direct Action" groups in West Germany etc. which may have been used to derive the MDATF which is claiming responsibility for these parcel bombs.

(vii) The MDATF logo has strong similarities to that used by the Red Army Faction in Germany, a group that THURSTON collected information about.

(viii) Seized computer files from THURSTON revealed references that THURSTON would like to send Terry LONG (an Aryan Nations member and white supremacist) a mail bomb. This information had been double encrypted in a computer disk of THURSTON'S and deciphered during the investigation. Terry LONG was one of the named recipients of the mousetrap warning letters sent by the Anti-Fascist Militia.

(ix) THURSTON maintains a close association with David Nathan BARBARASH, another known animal rights extremist and anti-fascist who resides in Vancouver, British Columbia, from where the mail bombs appear to have been sent. Their history of militant actions in support of their causes is well documented. That BARBARASH is also fully capable of using these parcel pipe bombs as a means to fight for his cause.

(x) In the first communiqué to the media, (the one received by the Montreal Gazette on June 26, 1995), the MDATF stated they were "fighting in solidarity with 'several other extremist groups.' Many of the groups listed were not well known in Canada and only someone deeply involved in the cause would know of their existence. THURSTON had files of information on five of the eight named solidarity groups including, RED ARMY FACTION, MACHETOROS, RARA, ROTE ZORA, and FALN.

(xi) A similarity can be seen in the communiqué (#3) concerning the MACKENZIE INSTITUTE parcel pipe bomb and an Animal Rights Movement (ARM) communiqué sent to the press in 1990. Both state their solidarity with the native rights groups.

29. On April 17, 1996, I was advised by Cst. POWERS, and I verily believe it to be true, that the prohibition order pursuant to section 103(6) of the Criminal Code made against Darren Todd THURSTON on October 28, 1993, referred to in paragraph 22 of this information to obtain, arises as a result of the execution of a search warrant on June 19, 1992, at the residence of THURSTON following his arrest on the charges of breaking and entering and arson, referred to in paragraph 21 of this information to obtain. In THURSTON's residence, the police found a Chinese AK-47 assault rifle, 7.62 ca., that had a loaded clip in the gun. They found a fully loaded 9 mm. semi-automatic handgun, as well as ammunition for each of the weapons - 128 rounds of 7.62, and 150 rounds of 9 mm. ammunition. THURSTON was also found to have two "training" hand grenades. He also had police scanners.

30. On March 11, 1996, I was advised by Wendy NICOL, of the RCMP Criminal Analysis Branch, in Ottawa, Ontario, whom I verily believe, that:

(a) She is a strategic analyst in the Criminal Extremism Analysis Section of the RCMP Criminal Analysis Branch and has been for approximately five years.

(b) It is her responsibility as a strategic analyst to monitor large numbers of international factors and to analyze how they may impact in criminal activity in Canada.

(c) The following terrorist groups are described as follows:

(i) The RED ARMY FACTION is a left wing, highly structured group with the aim of overthrowing the German government regardless of the loss of human life. It claims to be Marxist-Leninist. Other targets include businessmen and military bases and officials from Germany and the U.S.A. Tactics include bombing, fire bombing and murder.

(ii) The MACHETOROS is a Puerto Rican separatist group believed to be linked to the Cuban government. It is considered to be the most violent group in Puerto Rico. They target certain kinds of establishments in the U.S.A. with improvised bombs and military weapons, particularly police and the military. court houses and electric power stations

(iii) The ROTE ZORA is the name used by Revolutionary Cells when claiming responsibility for attacks linked to feminist issues. Revolutionary Cells's ideology is left-wing populist and anti-imperialist. It is loosely structured and has been active only in Germany.

(iv) RARA is known as the Revolutionary Anti-Racist Action and is known only to be active in the Netherlands. It has targeted companies with links to South Africa using firebombing and vandalism. It is based in the Dutch anarchist community.

(v) The FALN, the Armed Forces of National Liberation, is a Spanish-speaking Puerto Rican separatist group with the goal of the full independence of Puerto Rico. Their targets were chosen to ensure maximum publicity. A campaign in the mid 1970s escalated with the use of high explosive devices, often incorporating propane tanks, electronically detonated using clockwork delay systems. Bombs were hidden in non-descript containers, i.e. handbags, boxes, gym bags.

(vi) The JUSTICE DEPARTMENT, formed in England in 1993, is a militant offshoot of the Animal Liberation Front, which was formed in England in 1976. The ALF has a policy of non-violent direct action and liberation, while the more violent actions are carried out by the Justice Department or the Animal Rights Militia, another militant ALF offshoot. In England, the Justice Department has claimed responsibility for a large number of letters containing armed mousetraps and for parcel bombs. Targets include hunters, farmers, animal researchers, breeders and meat producers. The JUSTICE DEPARTMENT in North America, specifically in Canada, is believed to have its roots in the ALF and to have similar goals and ideology.

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