1 Court File No. CV-18-00610489-0000 ONTARIO SUPERIOR COURT OF JUSTICE B E T W E E N: ELISA ROMERO HATEGAN Plaintiff/Defendant by Counterclaim and ELIZABETH MOORE FREDERIKSEN and BERNIE FARBER Defendants/Plaintiff by Counterclaim AFFIDAVIT OF ELISA ROMERO HATEGAN I, Elisa Romero Hategan, of the City of Toronto in the Province of Ontario, MAKE OATH AND SAY: 1. I am the Plaintiff/Defendant by Counterclaim in this action. As such I have personal knowledge of the matters to which I testify in this Affidavit, except where my testimony is expressly stated to be on information and belief, in which case I state the source of my information and belief, and I believe the testimony to be true. 2. This affidavit in sworn in response to Elizabeth Moore aka Elizabeth Frederiksen’s affidavit and the Defendants Elizabeth Moore and Bernie Farber’s Motion to dismiss my action. Herein I will reply to those matters I see as relevant to the subject matter of the Statement of Claim I filed in Ontario Superior Court on December 10, 2018 and revised as Fresh as Amended on February 11, 2019, and to Elizabeth’s countersuit and allegations of defamation. Where I do not specifically address an allegation made in Elizabeth’s affidavit, I deny that allegation, put her to strict proof thereof, and reserve the right to respond with more particularity at a later date should it become necessary to do so. 2 My Recruitment and Role in The Heritage Front 3. I was born in Bucharest, then-communist Romania in December 1974, and lived there until age 11. My parents were both deaf, and suffered enormous abuse in their childhoods due largely to the then- commonly held perception that people with disabilities were not valuable members of society. My father, Iosif Hategan, clawed his way from being called the village idiot in his Transylvanian village to becoming the president of the Romanian Deaf Association. My mother, Lucia Hategan, was assaulted at age 12 or 13 by village boys, which led to her being sent to a state-run facility for deaf girls, where she met my father (who was an art teacher). My parents’ experiences hardened them and made them frequently lash out at each other. Physical and emotional violence was a common occurrence in our family. 4. When I was 9, my mother defected from Romania while on a trip to a deaf conference in Italy, where she asked for political asylum. She made her way to Canada and applied to sponsor my father and me under the Red Cross family reunification program. My father and I joined her in Toronto in September 1986, when I was 11 years old. At that time, I was known by my birthname of Elisse Charlene Hategan; I legally changed my name in 2009. 5. While living in Bucharest in the care of my father (between ages 9-11), my father made it clear he didn’t want a child. As a result, I was frequently locked out of our apartment and left to fend for myself on the streets. I was able to overcome the neglect thanks to the generosity of a neighbour across the street, Eugenia Ganciu, who fed me and gave me shelter after dark. She was my best friend’s grandmother, and the first person in my life to teach me about compassion and kindness. 6. After we arrived in Canada, my father disliked his new life here and had problems understanding and learning a new language. In 1988 he decided to return to communist Romania, where he died 3 shortly after. I was 13 years old. My mother and I were allocated a subsidized apartment at 285 Shuter Street, a community housing building in Regent Park. While living there, she was violent and physically abusive toward me. I recall the Children’s Aid Society first becoming involved with us after Mr. Godlewsky, my 5th grade teacher at Park Public School, called the police when I showed up in class after lunch crying and with bruises. I was assigned a CAS social worker, Ms. Shanti Persad, but I was not removed from the home at that time. 7. At age 14, I ran away from home and ended up in the care of the Children’s Aid Society, spending the next 1.5 years in a couple of group homes and foster care. At one point, while living in a group home on Browning Avenue in the city’s east end, I was the only white girl there. I felt isolated and bullied by the other resident kids, who teased me because I didn’t fit in. At the time, I felt they were picking on me because of my race, although in retrospect I now believe that the bullying was more related to the fact that I didn’t know much about pop culture or rap music, often still wore my hair in braids, and came across as a stereotypical “nerd”. 8. After running away from a foster home I was transferred to, I decided to return to my mother’s apartment. I dropped out of school near the end of grade 9 – that year I had transferred schools twice, due to moving from my Browning Avenue group home to the foster home in Pickering, and I didn’t want to enroll in a new high school for the third time in one semester. 9. Back at my mother’s apartment at 285 Shuter street I was lonely, had no friends and no hope that things could get better. My mother, who worked full-time as a data input clerk at CIBC, did not enroll me in any extracurricular programs since she couldn’t afford the extra fees. I missed Romania and didn’t feel I belonged in this country. I had come from a rigid communist dictatorship that enforced conformity and punished those who stood out. To me, Canada seemed to demand the 4 opposite – individuality and multiculturalism – and I was lost. I had no self-esteem, no confidence, and didn’t feel like I belonged anywhere. 10. At age 16, in the fall of 1991, I watched an American television program that was interviewing a young man from Toronto who was speaking about taking pride in his European heritage. He argued that other races and cultures were able to freely celebrate pride in their ethnicity, but that there was a double standard against white people. His words resonated with me – he didn’t “look” like what I had imagined a neo-Nazi would be like; he wore a suit and appeared clean-cut and non-threatening. When the television show flashed the address of a US nationalist group’s PO Box, I wrote it down and sent them a letter asking for more information. Within weeks, they replied by sending me the address and telephone number of a nationalist group in my area – the Heritage Front. 11. In 1991, the Heritage Front was just starting to establish themselves as a “white rights lobby group” that would eventually become Canada's largest neo-Nazi white supremacist group to date. They operated primarily by disseminating their racist messages via a telephone hotline in Toronto. People calling their number would hear messages that were rotated every few days. From what I recall, the messages consisted of such themes as calling for an end to immigration, to affirmative action, to welfare handouts, and support for the “boys in blue” – at that time, the Toronto Police Services were being accused by community activists such as Dudley Laws of the Black Action Defense Committee of racial profiling and illegal strip-searches of innocent black women. 12. After a few days of listening to the hotline messages, I worked up the nerve to leave a message on the hotline. That same day, a man named Wolfgang Droege called me back – he represented himself as the Heritage Front’s public leader, and one of three men who ran the organization. The other two were Grant Bristow, a co-founder of the Front who in 1992 also appointed himself the “Intelligence 5 Chief/Director”, and Gerry Lincoln, who was primarily in charge of the hotline and “Up Front”, the HF’s upcoming magazine publication, which would have its inaugural release that December. 13. Wolfgang and I arranged to meet that week, on a Tuesday evening in front of the Eaton’s Centre. His friendly demeanour put me at ease, despite the fact that he was an adult and I was a fairly naïve teenager who had never even gone on a date. He assured me that the Heritage Front was a political lobby group gaining in strength, and that one day he would replace Preston Manning as the leader of the Reform Party. As someone who didn’t know much about the politics at the time, I had no reason to doubt him. Almost overnight, Wolfgang became my father figure and mentor for the length of my stay in the Heritage Front. I didn’t know it at the time, but soon learned that he was a former Klansman and member of the US terrorist group The Order, who had an extensive criminal record for drug offences and for attempting to overthrow the Caribbean island of Dominica in a failed coup attempt, known as Operation Red Dog, intended to turn the island into a white ethnostate. 14. My trajectory in the white supremacist movement was rapid – a month after joining the group, I started to record messages for the official hotline; three months after, I was speaking at my first Heritage Front rally, held on December 7, 1991.