Action No. _________________





















The Parties


1.         The Plaintiff ("Dr. Christensen") was at all material times retired from his position as Professor of Philosophy at the University of Alberta. He retains the title and position of Professor Emeritus and resides in the City of Edmonton in the Province of Alberta.


2.         At all material times, Dr. Christensen was an active volunteer member of a Society incorporated pursuant to the laws of the Province of Alberta and entitled "The Equitable Child Maintenance and Access Society" ("ECMAS"). That Society was founded in Edmonton in 1992 for the purpose of assisting divorcing and non-custodial parents who have suffered unfair treatment or other difficulties during their interaction with the legal system, and of attempting to get changes made in that system. Dr. Christensen has contributed money and considerable time to ECMAS, and has never at any time received material compensation of any sort, direct or indirect, from or through participation in that organization.


3.         The Defendant the National Post Company ("the Post") is a partnership registered under the laws of the Province of Alberta and is the proprietor and publisher of a daily newspaper known as The National Post.  The partners forming the Post are the Defendants NP Holdings Company and Global Communications Limited, both of which are limited companies duly registered pursuant to the laws of the Province of Alberta.


4.         The Defendant Donna Laframboise ("Laframboise") was at all material times a reporter and columnist employed by the Post.


The Publication


5.         On Tuesday, April 17, 2001, in the City of Edmonton in the Province of Alberta and elsewhere throughout Canada, The Post published an article ("the article"), written by Laframboise, in which the Defendants falsely and maliciously published the following words about the Plaintiff which, taken in the context of the article as a whole, are defamatory of the Plaintiff:


                        "The Equitable Child Maintenance and Access Society is Alberta's largest non-custodial parents' lobby group. But between an executive's conviction for sexual exploitation of a minor and an activist's views on childhood sex, the group is self-destructing" . [The word "activist" meant and was understood to mean Dr. Christensen.]


                        ECMAS is "...self-destructing amid a scandal that includes an executive convicted of sexual exploitation of a minor and an activist who holds controversial views about childhood sex." [The word "activist" meant and was understood to mean Dr. Christensen.]


                        "Louise Malenfant, a community activist in Edmonton, says published views on childhood sex by Ferrell [sic] Christensen, a second man involved in ECMAS Edmonton, further undermine the group's ability to assist those wrongly accused of sex offences. "You cannot legitimately speak on behalf of the falsely accused while holding the belief that sex in childhood is a good thing," she says, adding that these two men are among ECMAS Edmonton's most prominent activists."


                        "Ferrell [sic] Christensen, for his part, is a professor emeritus of Philosophy at the University of Alberta and the author of a 1990 book, Pornography: the Other Side. While children's sexuality has decided moral dimensions for most Canadians, in a section titled Sex and Young People, Prof. Christensen discusses these issues outside of a moral context."


                        "Even more controversially, when discussing the harm he believes society's attitudes toward childhood sex cause, he equates loving parents, who teach their children sexual restraint, with pedophiles..."


                        "Pedophiles, he believes, are able to lure children because, in our culture, "young people are prevented from having the sexual knowledge, and the sexual contact with peers, that they naturally desire." "


                        "One woman says Professor Christensen... suggested "at least, maybe eight times ...."Dump your lawyer. You don't need a lawyer, [Tim] Adams will help you."  "


                        "ECMAS Edmonton's support group meetings...begin with the disclaimer that the group is not offering legal advice. But another man says...."I remember [Dr. Christensen] saying.... '...We can't have some other support group meeting without the ability to offer legal advice', stating that [Tim] Adams, who comes to the support groups, is some kind of legal advice. Professor Christensen has often remarked,  'What you should do is call [Tim]...[Tim] is a lawyer....' But he's never said, '[Tim] is a disbarred lawyer but he can still help you.' ...Ferrell's [sic] very adamant and very sure that the only person that can really help in that group is [Tim] Adams."  "


                        "According to another man, Mr. Adams..."...kind of feels them out as to who's got money and who doesn't. We tell our story and what's happening in our situation, and both him and Ferrell [sic] kind of ask about the financial aspect." "


                        "When the Post replied with a list of 13 questions asking, among other things, whether he has ever urged anyone to hire Mr. Adams, and what he means by certain passages in his book, he declined to answer."


Natural and Ordinary Meaning


6.         The defamatory words complained of, in their natural and ordinary meaning in the context of the article as a whole, were meant and were understood to mean any or all of the following, which are defamatory of the Plaintiff:

            a.         that Dr. Christensen has published the opinion that a loving parent who teaches children sexual restraint is morally indistinguishable from a pedophile;


            b.         that Dr. Christensen's views about childhood sex created a scandal so great as to cause Alberta's largest non-custodial parents' lobby group to be self-destructing;


            c.         that Dr. Christensen knows or recklessly disregards the fact that the scandalous nature of his published views about childhood sex  undermines the ability of ECMAS to assist people who need help;


            d.         that Dr. Christensen has claimed in his book that keeping children from sexual knowledge and sexual experience with their peers does not just make possible the specific pedophile tactic of using pornography to lure children, but is the entire explanation of the success of pedophiles in luring children into sex with them;


            e.         that Dr. Christensen makes a practice of advising people who come to ECMAS for help, irrespective of their individual situations, to avoid hiring lawyers or to fire their lawyers and instead hire paralegal [Tim] Adams;


            f.          that Dr. Christensen and Adams collude to discover and exploit the financial resources of those who come for help.





The Innuendo


7.         In the alternative, the defamatory words as set out in paragraph 5, in the context of the article as a whole, contain false and defamatory innuendoes as set out above in paragraph 6.


8.         Further, the defamatory words, in the context of the article as a whole, contain false and defamatory innuendoes, particulars of which include:


            a.         that by (allegedly) discussing issues of childhood sexuality outside of a moral context in his book, Dr. Christensen expressed the view that morality is irrelevant to issues involving  children's sexuality;


            b.         that Dr. Christensen does not believe that the criminal sexual misconduct for which Mr. Adams was convicted was morally wrong;


            c.         that Dr. Christensen has some oblique motive for colluding with Mr. Adams for the latter's financial gain; 


            d.         that Dr. Christensen  hides the fact of Mr. Adams' disbarment from people who come to ECMAS for help;


            e.         that Dr. Christensen did not answer the 13 questions posed by Laframboise because he had something to hide;


            f.          that Dr. Christensen is amoral or of bad character;


            g.         that Dr. Christensen is recklessly irresponsible or dishonest or both;

            h.         that Dr. Christensen manipulates vulnerable persons to cause them to act in ways that he knows or ought to know are not in their best interests, or is recklessly unconcerned about whether his conduct harms or benefits those who come to ECMAS needing help.


9.         The words complained of were about the Plaintiff and were written with malice.


The Slander


10.       On Thursday, March 22nd at about 10:00 a.m., Laframboise called Bob Bouvier, the President of ECMAS, at his place of employment. She had not yet made any attempt to contact the Plaintiff. They spoke for approximately 75 minutes. During the course of that conversation, Laframboise said she expected to publish an article in The National Post on Saturday, March 24th. She suggested to Bouvier that ECMAS should, in its best interests, dissociate itself from [Tim] Adams and Dr. Ferrel Christensen. She recommended that ECMAS do so immediately, before her story came out, so as to minimize the damage that might be done to ECMAS as a result her article's exposure of the conduct of Adams and the Plaintiff. When Bouvier suggested that there was no time to investigate her allegations, Laframboise told him that she could delay her story, but not for long. Her editor, she said, had to have ECMAS's response, as to whether it was going to dissociate itself from Adams and the Plaintiff, before the end of the weekend.  In the course of that telephone conversation, during the whole of which Laframboise was acting in her capacity as an employee of the Defendant Post, Laframboise slandered the Plaintiff by saying the following  words or words to the following effect:


            a.         "Ferrel Christensen wrote a book,  which I have read.  In that book he condones adult-child sex".


11.       The words  set out in paragraph 10a herein slandered the Plaintiff and were calculated to lower his reputation in the community and specifically intended  to seriously discredit him within ECMAS. In their ordinary meaning, and in the context of the conversation as a whole, they were intended to mean and did mean that Dr. Christensen had published a book in which he condones sexual  activity between children and adults.


12.       Laframboise's statement to Bouvier in the conversation referred to in paragraph 10 herein, to the effect that ECMAS must forthwith decide whether to dissociate itself from the Plaintiff and that, having regard to the intended content of her forthcoming article, it ought to so dissociate itself, was calculated to exacerbate the damage to Dr. Christensen's reputation and standing in the community that she intended to cause and did cause by the slanderous words as set out in paragraph 10a.




13.       The promulgation of the libellous and slanderous statements set out above were calculated to and did disparage the Plaintiff in his personal reputation and in his professional reputation. As a result, the Plaintiff has suffered public humiliation and distress, serious harm to his personal and professional reputation, and irreparable harm to his future activities as an advocate for ECMAS and for other causes in which he has been, is, or will be engaged. 


14.       The Defendants promulgated the libellous and slanderous statements set out above with express malice and in a high-handed and reckless manner, which has aggravated the harm suffered by the Plaintiff and which justifies the awarding of both aggravated damages and exemplary damages.  Particulars of that conduct include those set out in paragraphs 10 and 11 herein.


15.       Proper notice under the Defamation Act was served by the Plaintiff more than 7 days before the filing of the within action.


16.       The Plaintiff has demanded an apology and a full and fair retraction of the defamatory and slanderous statements. The Defendants have not apologized to the Plaintiff nor have they retracted any statements contained in the article.


17.       In the article, Laframboise resiled from the slanderous words spoken to Bouvier by including the comment that Dr. Christensen "... neither advocates nor condones inter-generational sex...". However, the immediate context into which Laframboise inserted that comment distorted the views of the Plaintiff in such a manner as to leave doubt in the reader's mind as to whether he does in fact condone sex between adults and children. For this reason and others, the disclaimer by Laframboise fell well short of an adequate correction.


18.       The Plaintiff proposes that the trial of the within action be held at the Law Courts in the City of Edmonton in the Province of Alberta.


19.       The Plaintiff says that the duration of the trial will be less than 25 days.





            a)         general damages, including aggravated damages, of $500,000.00;


            b)         punitive or exemplary damages of $500,000.00;


            c)         interest pursuant to the Judgment Interest Act;


            d)        costs of this action on a solicitor and client basis;


            e)         direction to the Defendants that the National Post publish, at its own expense and as prominently as the defamatory article, the Reasons for Judgement of this Honourable Court; or, in the alternative, such summary or extracts therefrom as may be directed by this Honourable Court;


            f)          such further and other relief as this Honourable Court may deem just.


DATED at the City of Edmonton in the Province of Alberta and delivered by Bradley J. Willis, Barrister and Solicitor, solicitor for the Plaintiff, whose address for service is in care of Willis & Bokenfohr, Barristers and Solicitors, at #325 Capital Place, 9707- 110th St., Edmonton, Alta, T5K-2L9, or by fax at 780- 452-3247.















You have been sued. You are the Defendants. You have only 15 days to file and serve a Statement of Defence or Demand of Notice. You or your lawyer must file your Statement of Defence or Demand of Notice in the office of the Clerk of the Court of Queen’s Bench in Edmonton, Alberta. You or your lawyer must also leave a copy of your statement of Defence or Demand of Notice at the address for service for the Plaintiff named in this Statement of Claim.


WARNING: If you do not do both things within 15 days, you may automatically lose the law suit. The Plaintiff may get a Court judgement against you if you do not file, or do not give a copy to the Plaintiff, or do either thing late.



AND IS ADDRESSED TO the Defendants



Current Partners of The National Post Company:


NP Holdings Company

Primary Attorney: John A. Cross

Miller Thompson

2700, 10155 – 102 Street

Edmonton, AB   T5J 4G8


Global Communications Limited

Primary Attorney: John H. MacFarlane

Osler, Hoskin & Harcourt LLP

1900, 333 – 7 Avenue SW

Calgary, Alberta   T2P 2Z1



Action No.
















- and -


















Bradley J. Willis

Solicitor for the Plaintiff

and whose address for service is:


c/o Willis & Bokenfohr

#325, 9707-110 Street

Edmonton Alberta  T5K 2L9


Tel: (780) 452-2751

Fax: (780) 452-3247