66. On March 24, 1996, I read copies of the threatening communiqué and the press release communiqué. They contain the following statements:

(a) The press release communiqué starts out with "fur is dead" and explains that "enclosed you will find a booby trapped envelope". It does on to explain that there is no "infected blood" in this envelope but claims to have sent eighty-seven (87) across Canada to retail stores "who profit from the sale of fur." It refers specifically to the HOLT RENFREW stores. They refer to their action as "war" and that "people die". They chastise the media for "appeasing their advertisers" instead of printing "honest facts". It ends with the "JUSTICE DEPARTMENT".

(b) The threatening communiqué starts out with "fur is dead" then goes on with "And hopefully so are you". It claims that the razor blades are coated with AIDS-infected blood in hopes of "eliminating scum like yourself from the earth". It too reports that "this is war, and in war people die. Enough animals have been killed, now it's your turn". It further states that "You have 6 months to shut down your business. After that you will start receiving explosive devices which WILL kill you. This is not a joke." It ends with the "JUSTICE DEPARTMENT".

67. On March 31, 1996, I attended at the Lower Mainland Mini-Storeroom at 1396 Richards Street, Vancouver to routinely check locker 5525. I examined the locker from the outside and determined that:

(a) my "markers" which I had placed covertly to ascertain whether the locker had been opened since the last check, were missing.

(b) a gold coloured piece of plastic moulding approximately one foot in length had been placed in the crevice between the lower left had bottom of the door and the frame of the locker by a person or persons unknown.

68. On March 31, 1996, at 1006 hrs, I removed the videotape from the videotape recorder which has been recording the area in front of locker #5525 on the continuous basis for 12 hour sessions from a covert video camera since January 12, 1996. That I personally viewed this videotape and observed the following occurrences:

(a) On March 30, 1996 at approximately 0956 hours, a male known to me as Darren Todd THURSTON gained access to locker # 5525 by using a key. He arrived carrying what appeared to be a larger sealed envelope.

(b) THURSTON removed the brown file box inside the locker and placed it on the floor in front of the locker. He began examining the contents. He placed the larger sealed envelope beside the file box.

(c) THURSTON at one point held up a white envelope to the light to observe the contents. It is my belief that this is the envelope containing the nine volt battery connectors. He lowered the envelope out of sight of the camera.

(d) THURSTON examined the contents for approximately three minutes before replacing the lid on the file box and returning the box to the locker and locking it back up with the padlock.

(e) THURSTON began wiping the padlock with the sleeve of his coat to remove any fingerprints.

(f) THURSTON had placed the envelope he arrived with into the file box prior to closing the file box up. He also removed an envelope from the box as well as what appeared to be the nylon wallet containing pieces known to have contained pieces of identification in different names. He appeared to put the wallet in his right coat pocket.

(g) THURSTON examined the contents of the envelope he removed from the file box which appeared to be the plastic bag containing the gelatinous substance. He replaced the plastic bag into the envelope. He appeared to place this under his left arm or put it in his left coat pocket.

(h) THURSTON started to walk down the moveable stairs to depart but then stepped back in front of the locker. He disappeared from sight, then re-appeared with what I believe was the gold coloured piece of moulding. THURSTON inserted this moulding into the crevice between the door and the frame, then also wiped his fingerprints from the moulding. THURSTON then left the area.

69. It is my belief that THURSTON and his associates are responsible for the razor blade campaign initiated against the Guide Outfitters in January of 1996 in which the "Justice Department" claimed responsibility. It is also my belief that THURSTON and his associates are responsible for the recent razor blade campaign initiated against the fur retail outlets across Canada in March of 1996 in which the "JUSTICE DEPARTMENT" claimed responsibility.

70. It is my belief that THURSTON and his criminal associates are continually planning campaigns in support of their various causes which involve both criminal and legitimate activity. I believe that their criminal activity is escalating which may involve the sending of explosive devices. The threatening communiqués from the JUSTICE DEPARTMENT in March of 1996 state "...you will start recieving (sic) explosive devices which WILL kill you".

71. On April 2, 1996, I appeared before the Honourable Judge GODFREY, a Provincial Court Judge for the Province of British Columbia and swore an Information to Obtain a Warrant pursuant to Section 487,01 of the Criminal Code of Canada. Judge GODFREY subsequently issued a Warrant under Section 487.01 authorizing Peace Officers to enter Locker # 5525, situated at 1396 Richards Street, Vancouver, B.C. to:

(a) examine the contents of Locker # 5525, located at the premises, including the contents of the file box contained in the aforesaid Locker # 5525, to ascertain whether any other items have been placed in the box since the box was last examined by members of the Royal Canadian Mounted Police on January 12, 1996.

(b) examine the contents of Locker 5525, located at the premises, including the contents of the file box contained in the aforesaid Locker # 5525, to ascertain whether any items have been removed since the box was last examined by members of the Royal Canadian Mounted Police on January 12, 1996.

(c) mark the contents of Locker #5525, located at the premises, including the contents of the file box contained in the aforesaid Locker #5525, with an ultra-violet marking pen for the purposes of future identification.

(d) photograph the contents of Locker #5525, located at the premises, including the contents of the file box contained in the aforesaid Locker #5525.

72. On April 2, 1996, at 1957 hours, I along with other Peace Officers attended at Lower Mainland Mini-Storeroom situated at 1396 Richards Street, Vancouver, B.C., and executed the Warrant issued by Judge GODFREY on Locker #5525 and did the following:

(a) examined the contents of Locker #5525, located at the premises, including the contents of the file box contained in the aforesaid Locker #5525, and ascertained that a light brown sealed envelope had been placed inside the file box since the box was last examined by members of the Royal Canadian Mounted Police on January 12, 1996. Inside the envelope were eight (8) blank "National Union of Students" cards for eight (8) different universities throughout Great Britain. There were also eight (8) preprinted cards listing the goals of the "National Union of Students". These cards could be used as the reverse side of the previously mentioned Student Union cards when laminated together. The list of Universities are as follows:

(i) University of Liverpool

(ii) University of Glasgow

(iii) University of Cardiff

(iv) University of Manchester

(v) University of West London College

(vi) University of Birmingham

(vii) University of South Hampton

(viii) University of Sheffield

Also inside the envelope were two (2) military manuals described as:

(i) TM31-201-1
Department of Army
Technical Manual
Conventional Warfare and Devices and Techniques
INCENDIARIES
HQ Department of the Army
May 1966

"United States of America War Office" seal was on the front cover.

(ii) Department of the Army
Field Manual
FM5-25
EXPLOSIVES AND DEMOLITION
HQ Department of the Army
May 1967

(b) examined the contents of Locker #5525, located at the premises, including the contents of the file box contained in the aforesaid Locker #5525, and ascertained that the following items had been removed from the box since the box was least examined by members of the Royal Canadian Mounted Police on January 12, 1996.

(i) the dark green nylon wallet and pieces of identification in the names of:

Kelly John WHYTE (Date of Birth: 1966.07.15)
Andrew James MACLACHLAN (Date of Birth: 1968.05.29)
Leanne Marie GAUTHIER (Date of Birth: 1969.01.27)

The piece of ID in the name of Kelly John WHYTE is a British Columbia Identification card with a photograph of THURSTON, who members of Vancouver NSIS recognize as Darren Todd THURSTON. This was issued on May 30, 1996.

(ii) A brown envelope containing a ziplock plastic bag in which the yellow gelatinous substance.

(c) photographed the contents of Locker #5525, located at the premises, including the contents of the file box contained in the aforesaid Locker # 5525.

73. On April 29, 1996, C/M BEVERIDGE of the RCMP Forensic Laboratory in Vancouver, British Columbia, forwarded a report to myself in regards to a 9 volt battery connector used in the ZUNDEL parcel pipe bomb. I have read that report which show the following results/conclusions:

(a) The shape and dimensions of the battery connector depicted in photographs of x-ray images from the ZUNDEL parcel pipe bomb are similar to those of the battery connectors used in the ALTA Genetics, SCOTT, and MACKENZIE Institute parcel pipe bombs, as well as to the 9 volt battery connectors found in the THURSTON locker.

74. On June 7, 1996, C/M BEVERIDGE of the RCMP Forensic Laboratory forwarded a report to Cst. LABOSSIERE. The report dealt with the examination of the utility knife blades from the second campaign from the "Justice Department" to the fur retail outlets across Canada to compare them to ones purchased from Staples, a stationary store in Vancouver, British Columbia. I have read that report which show the following results/conclusions:

(a) The utility knife blade sent by the "Justice Department" were the same in overall dimensions - the width, length and thickness, as well as elemental composition. Further, the end section of each blade had the same curved configuration.

(b) the construction of both exhibits was consistent with having originated from the same manufacturer.

75. On April 23, 1996, Patricia J. DONALD, an Agent specially designated in writing by the Attorney General of British Columbia for the purposes of section 185 of the Criminal Code, and I appeared before Associate Chief Justice DOHM of the Supreme Court of British Columbia. Pursuant to section 185 of the Criminal Code, Patricia J. DONALD made an ex parte Application, supported by my Affidavit sworn on April 23, 1996, for an Authorization to intercept Private Communications. Pursuant to section 185 of the Criminal Code, Associate Chief Justice DOHM granted Authorization P.23/96.

76. During the term of Authorization P.23/96, there were approximately nine thousand and seventy three calls intercepted on telephone lines, both audio and facsimile.

77. Following the granting of Authorization P.23/96, a monitor room was established at RCMP Headquarters situated at 5255 Heather Street, Vancouver for the purpose of monitoring the communications intercepted pursuant to Authorization P.23/96. RCMP personnel monitored the intercepted private communications and compiled a log of each individual conversation, which is an overview of the entire conversation. The logs were read by investigators from Vancouver NSIS and from these logs, reports were made of the content of these logs which were deemed possibly relevant to the investigation. These reports are a combination of intercepted information as well as information from other investigative techniques being utilized by NSIS investigators. I have personally read some of these logs from various intercepted conversations as well as facsimile interceptions. I also listened to selected conversations from the interceptions. A briefing was held virtually on a daily basis by Vancouver NSIS investigators and the information from the daily interceptions was presented and discussed by investigators. From all the sources of information described above, the following information was compiled:

(a) THURSTON had been in frequent contact with persons who identified themselves as Todd Divain FERGUSON, Ajith ALUTHWATTA, and Mark McALPINE; all of whom are actively involved in the Anti-Racist Action ("ARA").

(b) On April 30, 1996, at approximately 1323 hours, THURSTON called FERGUSON and they discussed an incident believed to be a pipe bomb that exploded in Calgary prior to this date. FERGUSON made reference that he doesn't have any idea who would have done it. THURSTON asked if "what's his name" was in town making reference to George BURDI. On May 15, 1996 THURSTON advised Todd FERGUSON that some people are moving. He refers to Charles SCOTT as an example and states he has found out where Charles SCOTT is living and that he was living on the border out in Yahk, B.C. They continued a conversation at the Youth Centre that has done some work into organizing against racists.

(c) On May 20, 1996 at approximately 1656 hours, THURSTON advised McALPINE that he has been working for the past year and one half compiling intelligence on White Supremacist members. THURSTON advised that other people from Edmonton, Calgary, Toronto, and other cities are adding information to his database. It is described as containing information about a range of people from "Ernst ZUNDEL to your local bonehead"; a name utilized by THURSTON to describe skinheads. During the conversation, THURSTON appeared to look up ZUNDEL's name in his database and to recite information that he has compiled on his intelligence file. He made reference to ZUNDEL as being part of the Heritage Front, Liberty Net, C.R.T.C. and having an address at 206 Carlton Street, Toronto, Ontario. He included the information that ZUNDEL had immigrated from Germany to Canada in 1958 and still holds a German citizenship. He was a commercial artist in 1951. THURSTON made a comment that his data base is really detailed. McALPINE stated that he would like a copy of that information. THURSTON went on to explain that his database has everything including people, racist publications and organizations and any information he knows as to who belongs to those groups and affiliations. Other information provided by THURSTON included talk about SHARP. THURSTON discussed the possibility of him attending an upcoming ARA conference which is being held in Toronto, Ontario.

(d) There were an extensive number of calls involving references to the constant use of computers and, specifically, the Internet and E-mail. THURSTON made numerous references to sending and receiving E-mail. THURSTON and his associates appear to utilize the Internet and E-mail for the majority of their communications. There was also a conversation in which FERGUSON talked about encrypting information on a disk and forwarding it to THURSTON. FERGUSON then stated he would E-mail the passcode to THURSTON once he received the disk.

(e) THURSTON was given a lap top computer financed by BLOOM. THURSTON stated to BLOOM that he required it as he was leaving for approximately 2 months on a holiday and he would require the lap top to enable him to have constant access to the Internet. THURSTON had also purchased accessories for upgrading his lap top. He provided BLOOM's MasterCard number __________ to purchase these items.

78. On June 19, 1996, Patricia J. DONALD, an Agent specially designated in writing by the Attorney General of British Columbia for the purposes of Section 185 of the Criminal Code, and I appeared before Associate Chief Justice DOHM of the Supreme Court of British Columbia. Pursuant to Section 185 of the Criminal Code, Patricia J. Donald made an ex parte Application, supported by my Affidavit sworn on June 19, 1996, for the Authorization to Intercept Private Communications. Pursuant to Section 186 of the Criminal Code, Associate Chief Justice DOHM granted Authorization P.29/96

79. Following the granting of Authorization P.29/96, a monitor room was established at RCMP Headquarters situated at 5255 Heather Street, Vancouver for the purpose of monitoring the communications intercepted pursuing to Authorization P.29/96. RCMP personnel monitored the intercepted private communications and compiled a log of each individual conversation which is an overview of the entire conversation. The logs were read by investigators from Vancouver NSIS and from these logs, reports were made of the content of these logs which were deemed possibly relevant to the investigation. These reports were a combination of intercepted information as well as information from other investigative techniques being utilized by NSIS investigators. I personally read some of these logs from various intercepted conversations as well as facsimile interceptions. A briefing was held virtually on a daily basis by Vancouver NSIS investigators and the information from the daily interceptions was presented and discussed by investigators. From all the sources of information described above, the following information was compiled:

(a) On June 20, 1996, Greg MIDDLETON {a reporter from the Vancouver Province newspaper} called Jane THOMAS and he asked her if she was aware that BARBARASH had convictions in Alberta and Toronto for vandalism and mischief and that THURSTON had convictions for fire-bombing. THOMAS replied that it has nothing to do with Bear Watch's mandate and they had never done any violent actions as a part of Bear Watch. MIDDLETON asked THOMAS if she had any concerns that they (BARBARASH and THURSTON) were suspects in a number of violent actions here and she replied that she didn't. MIDDLETON said that it appeared that Bear Watch was using Animal Rights mercenaries, people on the front lines who have a history of dangerous, violent actions. MIDDLETON went on to say that BARBARASH had a history of using the resources of groups he was involved in during these activities. THOMAS said that their protesters did not have links to the ALF and MIDDLETON replied that BARBARASH and THURSTON certainly did. MIDDLETON told THOMAS to watch the next installment he was doing and it was interesting stuff. He said that several members of Bear Watch were under investigation by police here for violent activities.

(b) During the term of Authorization P.29/96, there were approximately three thousand nine hundred interceptions, which included numerous facsimile transmissions.

(c) During the term of Authorization P.29/96, there were telephone conversations between Susan BLOOM and other Bear Watch employees who expressed concern about THURSTON's and BARBARASH'S criminal past. BLOOM had suggested that it may be necessary for Bear Watch to dissociate itself from THURSTON and BARBARASH.

80. On August 16, 1996, Patricia J. DONALD, an Agent specially designated in writing by the Attorney General of British Columbia for the purposes of Section 185 of the Criminal Code, and I appeared before Associate Chief Justice DOHM of the Supreme Court of British Columbia. Pursuant to Section 185 of the Criminal Code, Patricia J. DONALD made an ex parte Application, supported by my Affidavit sworn on August 15, 1996, for an Authorization to Intercept Private Communications. Pursuant to Section 186 of the Criminal Code, Associate Chief Justice DOHM granted Authorization P.38/96.

81. Following the granting of Authorization P.38/96, a monitor room was established at RCMP Headquarters situated at 5255 Heather Street, Vancouver for the purpose of monitoring the communications intercepted pursuing to Authorization P.38/96. RCMP personnel monitored the intercepted private communications and compiled a log of each individual conversation which is an overview of the entire conversation. The logs were read by investigators from Vancouver NSIS and from these logs, reports were made of the content of these logs which were deemed possibly relevant to the investigation. These reports were a combination of intercepted information as well as information from other investigative techniques being utilized by NSIS investigators. I personally read some of these logs from various intercepted conversations as well as facsimile interceptions and incoming E-mails. A briefing was held virtually on a daily basis by Vancouver NSIS investigators and the information from the daily interceptions was presented and discussed by investigators. From all the sources of information described above, the following information was compiled:

(a) During one conversation on August 21, 1996, between THURSTON and BARBARASH, they discussed the fact that Susan BLOOM had concerns about what might be in THURSTON's files in his file cabinet. THURSTON then made a comment to BARBARASH about how they {believed to refer to the police} if they want to, come into anyone's house and say "hey, this person's been making whatever". They could take something from your kitchen or bathroom and make something. Big deal. What are you going to do, run and hide.

(b) On August 29, 1996, THURSTON sent a facsimile of an interview that he gave, entitled "Doing time with the Animal Liberation Front - An Interview with Darren THURSTON". In the interview, THURSTON explained how he got involved with the Animal Rights Movement, how he learned ALF Actions, his role in the attack on the University of Alberta, and how he got caught. THURSTON went on to instruct what not to do, how to protect oneself, and how to maintain security while doing direct actions.

82. On September 27, 1996, I, along with Cpl. POLLOCK of NSIS attended at Maple Leaf Self Storage Inc., 3001 Wall, Vancouver, B. C., and reviewed their records. A locker, number 3-2663, was located as being rented by David BARBARASH.

83. On March 18, 1997, I was advised by Cpl. POLLOCK of NSIS that David BARBARASH attended at Maple Leaf Self Storage Inc., 3001 Wall, Vancouver, B. C. at locker number 3-2663 and spent approximately thirty minutes at that location.

84. On October 11, 1996, Patricia J. DONALD, an Agent specially designated in writing by the Attorney General of British Columbia for the purposes of Section 185 of the Criminal Code, and I appeared before Associate Chief Justice DOHM of the Supreme Court of British Columbia. Pursuant to Section 185 of the Criminal Code, Patricia J. DONALD made an ex parte Application, supported by my Affidavit sworn on October 11, 1996, for an Authorization to Intercept Private Communications. Pursuant to Section 186 of the Criminal Code, Associate Chief Justice DOHM granted Authorization P.55/96.

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