WITH PREJUDICE

BY EMAIL ON 22 FEBRUARY 2019 TO:

Jean-Francois Lalonde
Partner
Vice & Hunter LLP
101-85 Plymouth Street
Ottawa ON K1S 3E2

Email: jflalonde@viceandhunter.ca

Re Michele Di Franco v. Michael Bueckert

Dear Mr. Lalonde:

We have been retained to represent Mr. Bueckert with respect to your client’s claim of
defamation. Kindly directly all future correspondence in this matter to my attention.

I have had an opportunity to review your client’s claims. It appears as though there has been a
misunderstanding. My client formulated his opinion that your client’s politics and the political
values of his organization are fairly described as ‘alt-right’ or sympathetic to the alt-right on the
basis of your client’s repeated promotion and endorsement of various public commentators,
politicians and other personalities that openly espouse either far-right or alt-right views and are
generally regarded as representing or associated with the alt-right, despite their personal
rejection of that label. These individuals include Gavin McInnes, Janice Fiamengo, Jordan
Peterson, Tim Moan, Joseph Watson, Steven Crowder, Jack Posobiec, Mike Cernovich, Milo
Yiannopoulos, Lauren Southern, James Damore, and Maxime Bernier, among others.

Your client has never made any public attempt to disassociate himself with the discriminatory
views espoused by these commentators. The only information available has led my client to
fairly infer that your client endorses the express and implicitly discriminatory views of these
individuals.

My client’s opinion is reinforced by numerous public comments and endorsements made by

your client that are consistent with alt-right political ideology. These representations include:

i. The intro to his Facebook page that states that he is “Milo [Yiannopoulos] on Facebook:
James Damore in real life.”

ii. A tweet alleging that communists get “George Soros money” (antisemitic trope and
conspiracy theory consistent with the alt-right’s preoccupation with Soros);
 iii. A tweet celebrating George Zimmerman’s verdict of not guilty; (a common theme
amongst proponents and members of the alt-right and generally consistent with the alt-
right’s antipathy towards the Black Lives Matter movement)

iv. A tweet expressing disagreement with reparations for black Americans and attributing
support for reparations to “leftists” (bizarre preoccupation with reparations that is
consistent with alt-right ideology);

v. A tweet promoting “cultural appropriation month” (self-explanatory);

vi. A tweet endorsing a defence of Lauren Southern, who handed out flyers in London
containing the statement “Allah is a gay god”. The tweet defended her stating that she is
not “alt-right,” just “right” and asserted that “The west is the best.”

vii. Tweets illustrating a preoccupation with ‘illegal’ immigration in a manner consistent with
alt-right political ideology;

viii. A tweet purportedly defending free speech and endorsing Gavin McInnes’s notion of the
“war on fun” – ‘fun’ referring to McInnes’s and others’ discriminatory vitriol, and the ‘war’
referring to the protests against him and other alt-right commentators; and

ix. Tweets illustrating a general preoccupation with ‘free speech’, but only as it relates to
the right of far right and alt-right pundits to express their discriminatory and other right-
wing views. These representations do not illustrate a general commitment to free
speech per se, and they are consistent with the alt-right’s preoccupation with ‘free
speech’ as a means to defend their dissemination of discriminatory views.

That your client does not himself identify with the alt-right is also consistent with the alt-right’s
general though not universal rejection of that label. The term ‘alt-right’ finds currency primarily
amongst the left and centre-left, which use the term to describe the emergence of an
amorphous right-wing political movement that is distinct from preceding right-wing movements,
such as neoconservatives, paleocons, white supremacists, neo-Nazis, neo-Fascists and their
ilk. Though there is overlap in the political philosophy of these groups, they are distinct
conservative political movements. At no time has my client asserted that your client is a
member of or is affiliated to these other movements and political ideologies.

As for your client’s organization, its activities suggest that it is not so much an organization
concerned with promoting free speech per se as it is an organization that offers a platform for
the exercising of free speech by far right and alt-right theorists and commentators. Its only
guest speaker to date has been Janice Fiamengo, who harbours and openly expresses anti-
feminist and Islamophobic views, and who has publicly endorsed the Proud Boys. Though the
Proud Boys deny affiliation with the alt-right, they and their former leader, Gavin McInnes,
have a record of endorsing alt-right views and engaging in activities typical of the alt-right as it
is commonly understood.

In addition, your client’s organization has either invited or expressed an intention to invite
Jordan Peterson (popular amongst the alt-right), Libertarian Tim Moan, and Gavin McInnes.
Neither Peterson nor McInnes are advocates of free speech per se except to the extent that
they invoke it as a shield against criticism of their overtly or implicitly discriminatory views. To
our knowledge, there have not been any invitees from any other end of the political spectrum.

On the basis of the publicly available information described above and other evidence, the
inferences drawn by my client about your client’s political affinities are fair. They lead
ineluctably to the conclusion that your client is fairly described as a proponent of the alt-right.

However, my client is open to retracting his statements provided your client furnishes evidence
that he does not endorse the discriminatory viewpoints of the individuals he has repeatedly
endorsed and promoted. My client’s retraction is contingent on your client’s making the
following public statement on his Twitter and Facebook accounts:
“I unequivocally and without reservation of any kind denounce any and all of the explicit and implicitly
racist, misogynist, transphobic, homophobic, Islamophobic, anti-semitic, and anti-immigrant statements
and other representations made by Gavin McInnes, Janice Fiamengo, Jordan Peterson, Tim Moan,
Joseph Watson, Steven Crowder, Jack Posobiec, Mike Cernovich, Milo Yiannopoulos, Lauren Southern,
and James Damore. I believe and accept that the alt-right is a fundamentally discriminatory political
ideology that I do not endorse. I acknowledge that my previous endorsement of these individuals
inadvertently gave a platform to and promoted their discriminatory views, and I apologize for that.”

Alternatively, your client may furnish a sworn statement containing the text above so that it
may be published by my client. Provided your client complies, then my client will
simultaneously publish the following retraction on his social media:
“In my letter of January 18th, 2019 on Medium.com, and in my interview of January 19th, 2019 with Rob
Rousseau, and in my posts on my Twitter account between January 7, 2019 and February 6 th, 2019, I
opined that Mr. Di Franco was a member of the “alt-right”. I formulated this opinion on the basis of his
public endorsement and promotion on social media of Gavin McInnes, Janice Fiamengo, Jordan
Peterson, Tim Moan, Joseph Watson, Steven Crowder, Jack Posobiec, Mike Cernovich, Milo
Yiannopoulos, Lauren Southern, and James Damore, as well as on the basis of Mr. Di Franco’s
participation in the organization, University of Ottawa Students for Free Speech. In light of Mr. Di Franco’s
recent denunciation of the discriminatory views expressed by these individuals, I recognize that my
opinion was based on incomplete information about Mr. Di Franco’s personal political ideology. I therefore
retract my comments and apologize to Mr. Di Franco for any harm done to his reputation.”

I look forward to hearing your client’s positive response to my client’s proposal for restoring
your client’s reputation to the extent that it has been unfairly damaged by his association with
alt-right pundits and by my client’s public comments.

Please advise your client to preserve all relevant records and documents, including but not
limited to, relevant Twitter and Facebook posts and comments containing references to the
topics and individuals noted above.

Sincerely,

Daniel Tucker-Simmons