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.