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in a [9] On the second day of trial Ms. Amin testified that the website justice4lgbt .com was still active that very morning and all of the blog posts that are in issue in this action are still on that website.

[10] Ms. Amin testified that the first time people started to write about her in a defamatory way, was after the publication of an article in an online magazine known as Khodnevis on the day Mr. Parsi was the guest honorary editor. This was May 17, 2015. People sent the article to her and said that it was about her, even though she is not mentioned by name.

[11] Ms. Amin claimed in her evidence that justice 4lgbt.com is only about her and events in Iran and includes multiple pictures of her and her colleagues and articles about her.

[12] Counsel for Ms Amin took Ms. Amin to each of the alleged defamatory documents. He began with the document headed “BBC researcher has criminal record but no diploma”.’ It is dated November 21, 2015 and appeared on the justice4lgbt website. It contains a picture of Ms. Amin. I take one line as an example only from the article, which states “But why is it that the road has been cleared for Ms. Soheila Amintorabi to step foot into the BBC again? And this is after the recent scandals with voluminous financial files, money laundering and documented cases of verbal, physical, and sexual violations”. The author is anonymous.

[13] The plaintiff claims that the entire article is defamatory of her. Ms. Amin testified that she found this article to be extremely hurtful and that none of the allegations in the article are true.

[14] The next article is headed “Report: do you even censor Wikipedia?”.2 It is dated June 10, 2015 and appears on the website of justice4lgbt.com. The article makes reference to Ms. Amin. It contains information that is inaccurate, such as alleging Ms. Amin was married at the age of 14, but contains one sentence that is alleged to be defamatory of her. It is as follows “what financial and nonfinancial activities have you hidden under this name that you do not want to be disclosed?”. Further the plaintiff claims that the article suggests she is hiding her identity, which is untrue, and is alleged to be defamatory of her. The author is anonymous.

1 See attached as Schedule A 2 See attached as Schedule B

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a a [52] As a result, Mr. Parsi posted on his Facebook and contacted friends and asked people to send him articles. He also wrote an editorial. Mr. Parsi testified that his responsibility was just to read articles that he received from the owner and he himself sent some articles to the owner. Mr. Parsi denied that he was personally responsible for the decision to post particular articles and testified his discussions with the owner were on Facebook.

[53] Mr. Parsi received a text from the owner with a copy of what has been known during the trial as the “refugee letter”. It was the owner who made the decision to publish. As far as Mr. Parsi was concerned, the refugee letter was not about one particular group but more than one.

[54] Mr. Parsi testified about an article that Ms. Amin posted on her Facebook page titled: “Avoiding fights with the pig”.8Mr. Parsi agreed that there is no reference to him, but he believed that the article was about him. He found the article insulting and disrespectful.

[55] As a result, Mr. Parsi then posted an article entitled “The tale of stick and the thieving cat”.9Mr. Parsi later deleted the post on his web site.

[56] Mr. Parsi testified that he read the article written by Ms. Homily on July 23, 2015. He knew Ms. Homily from working on refugee issues. He wanted to know whether Ms. Homily had done due diligence before writing her article. He felt that Ms. Homily was angry at him. This is why he engaged in a Facebook chat with her.

[57] Mr. Parsi next testified about the article entitled “The room with purple cover and coloured walls”. He agreed that it was about rape, but that it was mostly emotional rape not rape as a sexual relationship without consent.

[58] With respect to the email to Amnesty International, he testified that the first time he saw this document was when it was attached to the original claim.

[59] Mr. Parsi agreed that he had posted the article entitled “The room with purple cover and coloured walls” on his Facebook page and asked people to comment about it. He denied that he meant that the article was true.

See attached as Schedule H

See attached as Schedule I

10

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he of [67] Another email was sent by Mr. Parsi in July 2017 asking justice4lgbt to identify themselves publicly. An email in response refused to provide that information and is allegedly from Dr. Emad Tabandeh.

[6$] Mr. Parsi once again wrote requesting the assistance of Dr. Tabandeh and he replied without providing any identification information.

[69] further email correspondence ensued. In one of those emails Dr. Tabandeh alleges that a volunteer was responsible for using the irqr host for setting up justice4lgbt.

[701 Mr. Parsi also introduced emails alleged to have come from other individuals being responsible for some of the articles in issue in this action and some from other individuals alleging cyber activities of security agencies in Iran.

[71] Mr. Parsi introduced what he alleged is an official affidavit of Shervin Shafirad that was supposedly sent to him by Dr. Tabandeh. Again, Mr. Wanless objected to the introduction of the statement, but again Mr. Arnouzgar confirmed that he is not claiming that I should rely on the truth of the contents of this statement. It alleges that the person making the statement was responsible for establishing justice4lgbt. Similarly, a statement was introduced from $anaz Zandi alleging that he or she was responsible for justice4lgbt.

[72] In cross-examination Mr. Parsi admitted that as executive director of IRQR he was in charge of everything that was happening in the organization including the website. He agreed that he was the one who set up and paid for the HostGator account for irqr.net.

[73] Mr. Wanless asked Mr. Parsi whether he agrees that the website justice4lgbt attacks Ms. Amin. Mr. Parsi was evasive in answering this question but finally testified that his interpretation of that website was that there were serious questions raised to Ms. Amin.

[74] Mr. Parsi agreed that when the website was first established it was established on his HostGator account. Mr. Parsi denied having anything to do with justice4lgbt. Mr. Parsi stated that he believed someone hacked into his web hosting account.

12 [75] Mr. Wanless pressed Mr. Parsi on his views on Ms. Amin and agreed that in 2015 he respected her until she wrote the post about a pig when he became angry. Mr. Parsi would not agree that he was not referred to in that article.

[76] Mr. Parsi agreed that the Iranian diaspora is worldwide and that the LGBT community is often online and that someone’s online reputation is particularly important.

[77] Mr. Parsi would not agree that being called homophobic was necessarily harmful to a person’s reputation. He did agree that being accused of money laundering would be damaging. He agreed that trust is very important when dealing with LGBT groups in Turkey and that refugees in Turkey are a vulnerable group.

[7$] Mr. Parsi first heard about the website justice4lgbt in June 2015 and that the first article he read was the bed with the purple cover article. He shared it on his Facebook. He does not believe that it is about anyone in particular. He does not believe the article is damaging to anyone.

[79] Mr. Parsi would not agree that when he read the articles on the website that they were about any person in particular. He agreed that he was not defending any of the articles.

[20] When pressed, Mr. Parsi would not agree that the article entitled “you are a homophobe and anti-male” was alleging that Ms. Amin was homophobic. Instead he suggested that it was about tension within the LGBT community.

[81] Mr. Parsi insisted that the articles do not state facts but that they raise questions. He did not think it was an issue that the website is anonymous and it did not bother him.

[82] Although in his opening statement Counsel for Mr. Parsi stated that they might be using the defence of justification, Mr. Parsi in cross-examination, after being pressed by Mr. Wanless, agreed that he did not want to do that.

[83] Mr. Wanless took Mr. Parsi to each of the articles in question but at no time did Mr. Parsi suggest that he believed the allegations against Ms. Amin were true, if they were about Ms. Amin. Mr. Parsi was particularly evasive when pressed by Mr. Wanless over the interpretation of the various articles.

‘3 [$4] When asked whether the website was possibly the work of the Iranian government, Mr. Parsi testified that he had no idea but it could be a possibility. Mr. Parsi denied that in June and July 2015 he went out of his way to promote justicelgbt.com nor did he defend it.

[$5] IVIr.Parsi admitted that twice he shared links to the website. He also shared the two articles on his Facebook, the article about the bed with purple cover and the article about Ms. Amin being homophobic.

[$6] Mr. Parsi denied contacting Samira specifically about the website. He admitted to sending her the link afier a conversation but denied that he was investigating Ms. Amin. He admitted that Ms. Amin was mentioned in the conversation.

[87] Mr. Parsi admitted that he contacted Ms. Homily because she had written an article defending Ms. Amin. He contacted her on the same day that he read her article. He stated he did this to see if Ms. Homily had done due diligence. Mr. Parsi denied that his response was about rape. He believes that the purple bed article was about conflict of interest.

[8$] Mr. Parsi admitted sending a letter to the Board of Directors of IRQR. In it he states that he was aware that the website had published a lot of information about Ms. Amin. Later he says that he was approached by some individuals who introduced themselves as victims, but in further cross-examination denied that that was a reference to be victims of Ms. Amin.

[89] Mr. Parsi admitted that he had the bed with the purple cover letter in his email account prior to it being posted onjustice4lgbt. He received it on May 18, 2015. He testified that he received it from a colleague of his in Sweden who is an Iranian LGBT activist. Justice4lgbt was created on May 21 and on May 23 he responded to the letter about the purple cover and that he would like more letters sent to him. On June 8, 2015 the same purple cover letter was posted onjustice4lgbt and on June 14 Mr. Parsi posted a Facebook link to that letter.

[90] Mr. Parsi agreed that one of the articles published onjustice4lgbt was the same article that was published in Khodnevis. This is known as the refugee letter. He denied having any control over what was published in Khodnevis. As far as he was concerned his honorary position was symbolic. He denied that the letter is about Ms. Amin.

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of or [100] Mr. Parsi agreed that he did not go back to his web hosting account to see if there was any evidence to substantiate what this anonymous person admitted to on his HostGator account.

[101] There were no attempts to have the individuals concerned testify in court. Mr. Parsi denied that he is the person writing these emails or that he knows the persons involved.

[102] The re-examination of Mr. Parsi referenced a conversation with someone who called him after the Khodnevis article. She complained about Ms. Amin. He also testified that he heard from others and so wrote and posted an article entitled Stop the Intimidation. Mr. Parsi denied that he was upset with Ms. Amin at this time but felt that it was unprofessional for Ms. Amin to interrogate LGBT refugees as alleged by complainants.

[103] It was shortly after that that Ms. Amin posted on her Facebook and called Mr. Parsi a pig and insulted his family. Mr. Parsi admitted that his response was still on his Facebook page but he had deleted it the day before giving this evidence.

[104] Mr. Parsi agreed that his article was about Ms. Amin because she called him a pig.

[105] Mr. Parsi confirmed that the editor of Khodnevis was the one who had the authority on publishing and approving the material that was published on that website.

[106] Mr. Parsi also referenced some articles onjustice4lgbt.com that he says do not refer to Ms. Amin.

[107] For the defence, the expert report of Navid Mohaghegh was filed as an exhibit. In his report he confirmed justice4lgbt.com was a sub-domain of irqr.net being created on May 21, 2015 and hosted there for some time in May but was gone in early June 2015.

[108] Also introduced for the defence was a witness statement of Au Hamedani. He was involved in the production of a BBC documentary featuring both Ms. Amin and Mr. Parsi. The documentary explored the issue of gender reassignment in Iran. The

16 witness alleges that after the documentary aired Ms. Amin engaged in a vindictive campaign to defame Mr. Parsi. Ms. Amin made complaints to the BBC and the BBC launched an investigation. The BBC concluded that the complaints were without bases and facts.

The law and my conclusions

[109] It is trite law that in a libel action the plaintiff must prove on a balance of probabilities: (a) The words about which the plaintiff complains are defamatory; (b) The words refer to the plaintiff; (c) The words were published to someone other than the plaintiff, and particularly in this case, by the defendant.

[110] Assuming these elements are established, falsity and damage are presumed and the onus shifts to the defendant to establish on a balance of probabilities, in this case, fair comment and responsible communication on a matter of public interest.’0

[111] To determine whether the words complained of bear a defamatory meaning, the question is whether the words in their ordinary signification are capable of being defamatory. The words do not have to be understood in a defamatory sense by everybody who reads or hears them. The question is whether a reasonable person to whom the words were published would understand them in a defamatory sense.

[112] In determining the meaning of the impugned statements, all of the circumstances of the case may be considered, including; (a) any reasonable implications the words may bear; (b) the context in which the words were used; (c) the audience to whom the words were published; (d) the manner in which the words were presented.”

[113] A defamatory meaning is one that injuriously affects a person’s fame, reputation or good name, or diminishes her respectability.

‘° Grant v. Torstar 2009 5CC61 ‘ The Law of Defamation in Canada, R.E.Brown Chapter 6

17 [114] Applying this test, I have no hesitation in finding that the article titled “BBC researcher has criminal background but no secondary School diploma” is defamatory and it is clearly about Ms. Amin. It references her by name and alleges that she was involved in recent scandals and major money -related lawsuits, money laundry [sic] and documented cases of verbal, physical and sexual harassment.

[115] Applying this test, I have no hesitation in finding that the article titled “You are a homophobe and anti male, Ms. Amin” is defamatory and is clearly about Ms. Amin. It references her by name and alleges that Ms. Amin hates men and bisexual people, that she is homophobic and aggressively promotes these views and has misrepresented her sexual orientation in order to gain fame, wealth and sexual relationships.

[116] Applying this test, I have no hesitation in finding that one sentence in the article titled “Report: do you even censor Wikipedia?” is defamatory and is about Ms. Amin. The sentence is referred to in paragraph 14 above. It mentions Ms. Amin and alleges that she is involved in hiding financial improprieties and other wrongdoings.

[117] Applying this test, I have no hesitation in finding that the email sent to Amnesty International is defamatory and is about Ms. Amin. It mentions her by her full name and alleges that she has engaged in widespread wrongdoing and abuses including rape, bullying and money laundering.

[11$] Apart from the Facebook messages to Ms. Homily, this leaves for determination the articles known as the refugee letter and the bed with the purple cover. Neither of these articles refer to Ms. Amin directly. Thus, I have to apply the legal test with respect to whether the words are such as would reasonably lead persons acquainted with the plaintiff to believe that she was the person referred to.

[119] The test is discussed in detail in S. G. v. I C. 12 a decision of the Ontario Court of Appeal. The court refers to Professor Brown’s text on Defamation as follows; “It is not necessary that the plaintiff be identified by his or her proper name, or even mentioned at all, if it is otherwise shown that the words would be reasonably understood to refer to the plaintiff. He or she may be referred to in the guise of some fictional or historical character or by a play on words. It may be clear from other evidence that he or she was the one alluded to, but he or she must satisfy the court in that regard. This may be done by introducing evidence, apart from the publication, connecting the plaintiff with the defamatory publication. The question in such a case is whether or not the words used are such as to lead an ordinary sensible person, or reasonable persons, who pay reasonable attention to the contents of the communication,to understand that it was the plaintiff to whom the defendant referred.

12 2001 CanLil3041

18

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a is It [124] I heard evidence from Ms. Homily that, although at first, she did not recognize the article as being about Ms. Amin, she did come to that conclusion eventually and thus published the article defending Ms. Amin.

[1251Applying the test of whether the words are capable of being defamatory, I conclude that they are indeed defamatory. The author alleges that she was raped by Ms. Amin and that Ms. Amin committed emotional rape. The article also says that Ms. Amin has exploited intimate and sexual relationships with clients and that she hates gays and bisexual people. Finally, the article alleges that Ms. Amin has a hidden camera in her bedroom used to record visitors without their knowledge or consent.

[126] I turn to the Facebook messages between Ms. Homily and Mr. Parsi. The context of these messages is important. Ms. Homily had published an article defending Ms. Amin which Mr. Parsi had just read. In the first message Mr. Parsi refers to Ms. Amin. Ms. Homily responds that she wrote her article in defence of Shadi Amin’s dignity and nameless libels. Mr. Parsi replies in part “Letters regarding rape cases are true...” thereby implying that Ms. Amin was the rapist. Later he states “I stand by the rape letter and I have posted it in my Facebook”, implying the same thing.

[127] Thus I find the words refer to Ms. Amin and are defamatory of her, but of course, were only published to Ms. Homily.

[12$] Before turning to the issue of whether Mr. Parsi is responsible for publication, I turn to the defences raised in the amended amended amended defence and to the written closing submissions of the defendant. I will specifically reference the submissions as they appeared to me to go way beyond what is set out in the defence. Nowhere in the pleading is there a claim that the articles on justice4lgbt.com or the email to Amnesty International were not defamatory or malicious, or were covered by the defence of fair comment.

[129] The defence repeatedly denies that Mr. Parsi had any involvement in the impugned web site or was the author of the articles or email. However, the written submissions contain 50 pages essentially defending the articles and the email. I have reviewed these submissions but give them no credence as the defences were not pleaded and submit, for example, that to accuse Ms. Amin of being involved in rape or fmancial scandals does not lower Ms. Amin’s reputation. That is simply preposterous. The submissions also purport to claim the allegations are based on facts, which facts were not proven at trial.

20 [130] The only reference to fair comment and responsible communication as defences in the defence is with respect to the actions of Mr. Parsi. With respect to the alleged defamatory publications, these were the messages with Ms. Homily and the reposting of the article the bed with the purple cover on his Facebook page.

[131] The test for the defence of fair comment is set out in WIC Radio Ltd v. Simpson’3as follows: a. The comment must be on a mailer of public interest; b. The comment must be based on fact; c. The comment, though it can include inferences of fact, must be recognizable as comment; d. The comment must satisfy the following objective test: could any person honestly express that opinion on the approved facts; e. Even though the comment satisfies the objective tests, the defence can be defeated if the plaintiff proves that the defendant was subjectively actuated by express malice.

[132] The test for the defence of responsible communication on a matter of public interest is set out in Grant v. Torstar’4 as follows: a. The publication is on a mailer of public interest, and b. The publisher was diligent in trying to verify the allegation, having regard to: (1) the seriousness of the allegation; (2) the public importance of the mailer; (3) the urgency of the mailer; (4) the status and reliability of the source; (5) whether the plaintiff’s side of the story was sought and accurately reported; (6) whether the inclusion of this defamatory statement was justifiable; (7) whether the defamatory statement’s public interest lay in the fact that it was made rather than its truth; and (8) any other relevant circumstances.

[133] It is trite law that the defence of fair comment applies to comment only and not to statements of fact. If the defendant fails to prove the truth of the underlying facts at trial, the defence of fair comment will fail. See Awan v. Levant’5.

[134] In his message to Ms. Homily Mr. Parsi states that “letters regarding rape cases are true.”. This is a statement of fact not a comment. Similarly, in the bed with the purple cover the author writes “she hated gay people and loathed bisexual people”. Then the author writes “she is raping me emotionally every single day. I think to myself that she only cares about her bank account, and the long list of names with whom she has shared a bed. She hates men, but her behaviour and clichés are revolting, chauvinistic and lumpen attitudes.” These too are statements of fact and

2320085CC40 ‘ 20095CC61 ‘ 2014 ONSC6890 upheld 2016 ONCA970

21

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to in [139] Mr. Parsi points out his efforts to obtain a Norwich order which was used to try and determine the identity of the individuals responsible for the website, but Ms. Amin refused to cooperate in that effort.

[140] Mr. Parsi, upon receiving the plaintiffs expert’s report, retained his own expert who confirmed the plaintiffs expert’s findings.

[141] On May 21, 2015, the day the website was registered, Mr. Parsi was calling for unity and seeking to engage with Ms. Amin to build bridges and he sent her a message congratulating her on the publication of her book.

[142] Mr. Parsi submits he only responded with the article entitled “the tale of stick and the thieving cat” as a response to a personal attack by Ms. Amin on Mr. Parsi in her article. Shortly after posting his article it was removed by him but he forgot that it was still on his Facebook page and he removed that when it was pointed out to him.

[143] Mr. Parsi submits that he took all reasonable steps to identify the parties responsible for the website. The plaintiffs expert’s report was not delivered until July 2017 and until he read that report he had no reason to believe there was any connection between himself, his organization and the parties responsible for setting up the website.

[144] Mr. Parsi does not wish to provide the names of the volunteers who work with his organization as he has promised confidentiality as to their identities, particularly as they are vulnerable persons many of whom continue to live or have family who live in Iran.

[145] Mr. Parsi has shared his efforts to contact HostGator during his investigation, including the recording of one of his phone calls.

[146] Mr. Parsi has received several emails from people assuming responsibility for the creation of the website.

[147] The fact that Mr. Parsi had access to copies of the articles before they were published on the website, results from his being a guest editor of Khodnevis and the people were sending him articles for possible publication.

[14$] On a balance of probabilities, I am persuaded that Mr. Parsi was involved in the creation and publication of the articles on justice4lgbt.com and for the email. I

24 come to this conclusion for the cumulative reasons submitted by the plaintiff set out above. Most persuasive is the following. It would have been the simplest of tasks to obtain from HostGator information to show who created the sub-domain of the website owned and paid for by Mr. Parsi. Instead, Mr. Parsi created obstacles in the way of obtaining this information. Similarly, when faced with the evidence that the impugned website was a sub-domain of Mr. Parsi’s website, IVfr.Parsi alleged that the account must have been hacked, but again took no steps to request from HostGator evidence or information confirming this allegation.

[149] Rather Mr. Parsi brought an application for a Norwich order which he knew or ought to have known would have no effect outside of Ontario. Then he provided information from anonymous sources in an effort to exonerate himself but provided this information in a manner that was impossible to independently verify.

[150] The second basis for finding Mr. Parsi responsible, is the disingenuous way he testified about the articles that defame Ms. Amin. I use one example only. For the article entitled “you are a homophobe and anti male Ms. Amin”, Mr. Parsi testified that the article was really about tension between various groups within the LGBT community and not about attacking Ms. Amin. This, in spite of the very headline that does just that.

[151] This position was then compounded by attempting to defend the various defamatory articles in the closing submissions of the defendant.

[152] Thus I find Mr. Parsi liable for the defamatory articles published on justice4lgbt.com and for the email sent to Amnesty International. I do not find him liable for the refugee letter published on Khodnevis, as I have not found that article refers to Ms. Amin. He is also liable for the email messages to Ms. Homily, but the publication was only to her.

[153] The final issue is to determine damages. Damages in a libel action are at large. The principles guiding the court in the assessment of damages are set out in Minar Mar Group v. Divine16. The factors to consider are [a] the plaintiffs position and standing; [b] the nature and seriousness of the defamatory statements; [c] the mode and extent of the publication; [d] the absence or refusal to retract the libel or to apologize; [e] the conduct and motive of the defendant; [f] the presence of aggravating or mitigating circumstances.

16 2011 ONSC1172

25 [154] As the Court of Appeal recently held inRutman v. Rabinowitz’7, the pernicious effect of defamation on the Internet, or cyber libel, distinguishes it, for the purposes of damages, from defamation in another medium. An analysis of the damages occasioned by the extensive Internet defamation campaign must be evaluated in the context of the unique and somewhat insidious nature of Internet defamation and in light of the fact that the defamatory statements were instantly available to an unknown number of recipients.

[155] In my opinion, the general damages for libel amount to the maximum claimed of $25,000, thus I need not deal with the claims for other damages. The plaintiff, although a resident of Germany, is well known throughout the international LGBT community. The defamatory statements accuse her of rape, money laundering and other serious charges. The defamatory statements were broadcast on the Internet and there has been a complete absence of any retraction or apology. The defendant appears to have been motivated by his anger at the plaintiff. For these reasons I believe the maximum amount is appropriate.

[156] Thus, there will be judgment for the plaintiff against the defendant for $25,000 plus pre-and post judgment interest pursuant to the Courts of Justice Act from September 29th 2015. The parties may make submissions as to costs through the court office and this may now be done electronically to [email protected]. The subject line of the email must indicate my name, the file number and style of cause and must, of course, be served on the other party. The plaintiffs submissions are to be filed by no later than April 30 and the defendant submissions by May 18.

APR772078

17 2018 ONCA80

26 40 SCHEDULE 1

Dorostkar Translation Services

lO27lYonge St., Unit 224, Richmond Hill,Ontario, t.4C385, Canada Tel:f647) 965-3867, Toll Free! Fax: 1-877-778-8562 Email: [email protected]

CERTIFIEDTRANSLATION

(Persian/ Fats! into English)

Letter: BBCResearcher has Criminal Background but No Secondary School Diploma

July 10, 2015

It was months since Soheila Amintorabi (Shadi Amin) had been absent from mainstream Parsi media when we found her reappearing on Farsi BBCTelevision as a researcher and a human rights activist.

But how is it that LadySoheila has found her way into BBConce again? Especially after the recent scandals and major money related lawsuits, money laundry, and documented cases of verbal, physical and sexual harassments, how is it that the BBCdirectors have not bothered to question themselves whether they can call someone a researcher simply because she wishes to be called so when they label such a notorious person as a researcher fin the case of Shadi Amin, she has not even completed grade S and dropped out of school at the age of 14, as she has written herself). Can she be called a human rights activist simply because she is opposed to the Islamic Republic of Iran regime? Can she be decorated with a string of titles and labels thanks to some weblog posts, self-made awards, and the organizations that are mostly one-person operations and baseless according to Deeds Registration Company of Britain? What is the story?

For some time, there has been some news of Soheila Amintorabi’s (Shadi Amin) efforts to establish networks of friends and bribe certain Parsi media officialsto buy time and impose herself on them, They talk about her leaving home in California and moving to Farnkfurt and livingwith Shadi SaUr,who has

different

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age 60 SCHEDULE 9 61

What has Soheila Amintorabi, born in Dey 1343 (Iranian Solar Calendar), January 1961 (translator’s note: the conversion of the year in the original text is wrong and it must be 1965), done that she is so worried? What financial and non-financial activities have you hidden under this name that you do not want to be disclosed? Which part of your past are you hiding? How can you, who cannot tolerate seeing your real name and the date of birth revealed, proclaim exposing and disclosing this fact and that fact and clarity?

Don’t hide behind the concept of “privacy”. Privacy has a different meaning for people like you. It is our right to know who our activists are and what goals lie behind their activities. Name change has a legal definition. Ifyou had registered you human rights companies under the name Shadi Amin, then you would be completely tight; however, you have registered all your companies such as “6Rang” (6 colours) in pubic references under the name of Soheila Amintorabi. In all registered cases, it is Soheila Amintorabi who is responsible not the name Shadi Amin.

Is Wikipedia good enough only when you line up your unseen and unheard films and books in it? Then does ft becomes bad when only one sentence of truth is written in it about the truth of your life and then it must be stifled?

Iwill send a copy of the Wikipedia page, which you tried to change with your virtual military campaign,

to Justice for LGBT;also, I willask Wikipedia to remove the lock of censorship and feed the folks with true information. Stop censorship, distortion and inducement of facts.

Wikipedia User haghighatl23 (translator’s note: haghighat means truth)

Name and identity of sender is protected with Justice far LGBT

Ms. Shadi Amin can refute this claim by sending a copy of her IDcard/ passport or send her explanation for adopting an alias to Justice for LGBT Source: http://iustice4lgbt.com/?p=361

Certified Translation of Article in Farsi in 2 Pages.

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THAI BEDWITH PURPLE SEARCH COVER AND Co LOURED Search the site WALLS

November23, 2015 j English No Comments ARCHIVES I November 2015 August 2015 july2015 June 2015

META

Log in

I was hesitant whether or not to write what was bothering me for a long time. Awound was about to open up. The infection was intolerable, yet I did not dare to let the putrefied infection out. I was so hateful toward this infection that I was carrying within me. Similarly, I was terrified of letting the wound open and the pus come out. Perhaps she herself is an embodiment of homophobia, inasmuch as there are many lesbians who have deeply hurt by her

Who have believed if I had spoken out? Every hour of every day I carry a chronic infected wound like a hunch on my back. Everyday I am more worn out than the last. I think to myself, how many have seen that bed with a purple cover and colourful walls? For how many, after making love, has she made cafe latte, and has entered to the bedroom from the kitchen with one eye half open singing . U?” Evan though she has never known love, to how many has she said “we are the only good ones, none other”? To SCHDULE”- 99 how many has she said “1am number one”? To how many and in how many ways has she implied that others are no good? She is not a good comedian, She brings tear to people’s eyes

Myhead becomes heavy when I think of all the contradictions in her. Truly, how many faces and facades does she have? ha

When I read the article in Khodnevis Website, even though I could

heat her breathing and was disgusted by and fearful of it, I asked myself with what price did BBCPersian invite her to their programs, and how could those watching inside the country find out the truth? One’s true face cannot be seen on the television screen. I remembered someone who said she was a refugee in Turkey and she had started an intimate relationship with her, and after sleeping with her, she put her aside like a dildo. How many have told me about her bedroom and its details, and must keep their painful silence forever. How many has she fooled with her showmanship on the internet camera and lured into a two way, but temporary, relationship? and who is aware of that hidden camera

To how many has she promised a position, and when their expiration date came about they were tossed onto the forgotten land. Even so, how many moderators are needed for a closed Facebook page

She was supposed to give me consultation, but she slept with me, just like she slept with all of them, She hated gay people and loathed bisexual people. The hero Ofher bed was always herself

Everything began with trust. Everything begins with trust. Then you realize you were a mere object to her.., then denial.,. then... then threats.., then silence... then isolation

The relationship she started with me as a human rights activist for LGBTpeople was rape. She is raping me emotionally every single day. I think to myself that she only cares about her bank account, and the long list of names with whom she has shared a bed. She hates men but her behaviour and cliches are revolting, chauvinistic and lumpen attitudes. How many people did she belittle and SCHEDULE”-’ 100 destroy. One day I will speak out. I will stand strong and I will reveal this. I will force her to look at herself

Name and particulars of the sender are kept in confidence with justice4LGBT

Picture is for display

Given that we do not have independent verification of this statement, we have withheld the name of the sender

Justice4LGBTis willing to provide documentation to relevant organizations

This document is translated by 6Rang volunteers and ]ustice4LGBl received it by email

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.jUSTICE4 LGBTL, j1yl1 COPYRIGHT© 20] 5 ALLRIGHTSRESERVED jL ENGLISH 33 SCHEDULE

Original Message Subject: Ms. Raha Bahreini s Conflict of Interest: Dat.e: 2015—08—11 16:25

From: •Justce4LCBi To: Cc: Dahreh. ia liSamnef-v.

To Amnesty International Director of Middle East and North Africa

Dear Mr. Luther, I am writing this emaIl in regards of Ms. Raha Babreini who is working at Iran’s desk at the Al and her relationship with Ms. Soheila Amintorabi (Thadi Amin) and Ms. Shacli SaUr and her conflict of interest which is very important for us.

As you might know, Ms. Bahreini has a close relationshig with Ms. Amintorabi and Sadr and their companies Justice for Iran and 6rang. She wrote their paper in English name Jensiyac—e X which we have received a lot of complain from Iranian LOST community and those who have participated at those interviews. They claim that their interview responses were doctorate and it is not what exactly they told. Ms. Bahreini is their key lobby at the Amnesty International in order to promote their agenda.

We have recently publ;shed a lot oi reports and letters that we received from Iranian LOST community members on the wrono doing of Ms. Amintorebi and SaUr, their abuses, rape, bullying and money laundering and etc. in Farsi chat you can check them out at our websire (www. jiia1u,4l bL. c :m)

Me would like to bring this Into your attention and reoueso you to advise Ms. Eabreini to follow the Al and other international organization ‘s policy to remain non—partisan and neutral and avoiding any kind of favouritism while she is part of the Amnesty International.

We believe Al is playing a significant role to support victims of human rights violation and it is our responsibility to report these wrong doings to you otherwise, Al and those victims of violation will pay the cost of mistrust if Ms. Bahreini and other people in her posit.ion does not follow the policies. We informed that she is going to speak at a panel on .;ugust 13th which organized liv Ms. Sadr and Aipintorabi in order to clean their mess and claim that everything is fine by using (abusing) other organization and individual names such as Al to show that they have a large supporters and they are legitimate.

Thank you so much for your consideration in advance and looking forward to the day chat Ms. Sahreini cots her relationship with them and remain as one of the valued member of Al. 427

Minoo Homily On Mobile

Arsham Parsi July 23, 2015

HI I Minoojan, read your article on Akhbar Rooz. Iwant you to review my latest blog post about personality destruction and why I am against it including my last Facebook chat with Ms. Shadi Amin. http://www.arshamparsi.net/?p=1804

Our Current Pain Arsham parsi.net

Arsham Parsi:

I always had special respect for you and still do. I do not like it when people use others and their credits to exonerate themselves. Ms. Amin must have responded to the folks in that manner only in your presence, while at all other times she has been bad-mouthing them and proof of this is on her Facebook in the posts made by her which can be seen in the post.

Minoo Homily:

Mr. Parsi, I am not an idiot to allow anyone to use me. I am the one who introduced you to the UNwhile [you] a refugee. Bythe way, my article was in defence of Shadi Amin’s reputation and the anonymous accusations against her. One would expect that you too should stand up against defamation of other activists. I have continued to remain silent with respect to the complaints by the refugees against you. I hope that you can prove their falsehood by changing your ways.

Arsham Parsi:

Dear Minoo, Idid not say that you are an idiot and did not deny that we went to the UN together. Ijust wanted to mention that what you say is true but Ms. Amin has engaged in these unconventional behaviours and I have shared the screenshots her offensive and defamatory writings against me.

If any refugee has any complaints against an organization they are dealing with, of course there are formal avenues for launching the complaint and dealing with same by the board of directors of the organization; they indeed exist in our organization.

These allegations that you referred to as anonymous all have names attributed to them and I have had opportunity to verify some of those accounts as they contacted me and Ilooked into them and some of them of course remain unverified. Definitely, Itoo will stand up against defamation of activists and my intention from my message was to convey that it is not right for someone to condemn an action that he or she engages in. Ms. Amin should not defame either.

For example she has written that I have involved my family members in my fake organizations. You are in Toronto and can easily access the list of the board of directors of our organization, 428

which is publicly available and can be accessed through the CRA,and note that none of them have a family relationship with me.

Mino Homily: Mr. Parsi, ifyou have investigated and verified any of the articles prior to publication, please let me know which of the articles have been verified. It remains a question for me why after the investigations and verifications the articles are still published anonymously. The refugees in Turkey do not know about the formal complaint avenues and ‘discusstheir concerns with those whom they trust and Iwas the one they trusted. Also, Ididn’t write that Iwent to UNwith you.

I introduced you to the UN. I hope these days end.

Arsham Parsi:

I Dear Minoo, Idid not investigate or verify [the articles] before their publication as have no connections with Justice4LGBT.I looked into them after they had already been published and because of the trust [in me] that exists for many. After a campaign was launched that those articles are baseless, some of those victims contacted me personally and asked me to confirm their stories. Letters about the breach are true. The story of putting pressure for getting “Likes” is true, and so are many other stories related to the refugees. Those financial reports and company registrations have links to the UKofficial organizations and are outside of my area of expertise and they are not very important any way. I am surprized that as someone who has worked with vulnerable people for many years, why you would question the reason they publish anonymously. Ifthey had written their names, by now a lot of pages had been created to destroy them. Now that they are anonymous, a group of people are being interrogated every day to find out for example who Sh. Kh.is. It is obvious what would have happened to them if they had written their names. Yes, it is possible that some refugees in Turkey may not be aware of formal complaint avenues but those who are in contact with us and participate at our regular meetings in Turkey ate told about these complaint mechanism at the end of every session. Also, you should know that many refugees, because the psychological traumas they have experienced, are hard to satisfy sand have very high expectations and often complain about everyone including yourself, but those complaints aren’t necessarily true. For example those refugees that you met with and posted their picture, not only all of them received services from us but they also received financial aid on a monthly basis but always said things to implythat they are not receiving any aid from anyone.

Arsham Parsi: In relation to the UN, if by correcting me you are implyingthat for the first time that we went to you have been the reason UNtogether Iwas a refugee, then that is correct but ii you mean that for my relationship with the UN and social credit and success, then you are only being too kind

I refugees which were as Iwas in contact with the UNeven before left Iran and was helping much fewer than now.

Australia. Yes,for the first time Iwent to the UNwith you and a gentleman who came from several After that I had numerous meetings with UNand other organizations and received international awards for my successful activism. When you were in Turkey and were telling the same front honestly reason hard always the difficult Why not the Minoo victim.

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someone says that an activist woman was violated in prison while many are defending the prison guards and the regime that she is lying and is tryin to taint the regime’s reputation.

Arsham Parsi:

With respect to your 15 years of working as a volunteer, I personally thank you, kiss your hands

as a sign of appreciation and say kudos to you. Iam officiallythe employee of my organization

but I am not getting paid because we spend all money for projects and you may see our

financial reports on our website. For example last year Ionly received a $5,000 salary because

we did not have money and I do not have any other job and I have a difficult life but helping

others is more important to me. Otherwise Icould go to work at Super Khorak and get at least

$2000/month. Ido not drop the ball in your court because Inever liked to play ball. AllI’m saying is that if you have heard, we have heard too but professionalism requires what is heard to be investigated and verified and not be repeated otherwise.

Minoo Homily:

Thank you for your explanation. I prefer to end this subject.

Arsham Parsi: lam happythat you understand. Have a good day and looking forward to see you

Minoo Homily:

Ending the subject does not mean that I accepted your points.

Arsham Parsi:

Ok.Just as a joke, Dear Minoo, there is nothing else for you to say since Iknow you took sides without looking into it. Kiss

Minoo Homily: Mr. Arsham do not use any polemic with me. Knowyour limits and drop your sexist tone. The truth is clear to me and please respect your and my time and consider this conversation finished.

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