JEREMY JONES
                                                         Applicant           

SECOND FURTHER AMENDED STATEMENT OF CHARGE PURSUANT TO ORDER 40 RULE 5

1. The respondent is guilty of contempt of the Court in that in wilful and/or contumacious disobedience of an order made by Her Honour Justice Branson on 17 September 2002 ("Order"), the respondent published or republished to the public, by himself or by any agent or employee:

(a) On the World Wide Web material which conveys the following imputations or any of them:

A There is serious doubt that the Holocaust occurred ("Imputation A");

B It is unlikely that there were homicidal gas chambers at Auschwitz ("Imputation B");

C Jewish people who are offended by and challenge Holocaust denial are of limited intelligence ("Imputation C");

D Some Jewish people for improper purposes including financial gain have exaggerated the number of Jews killed during World War II and the circumstances in which they were killed during World War II and the circumstances in which they were killed ("Imputation D").

(b)  On the World Wide Web the document headed "About the Adelaide Institute".

Particulars of Charge

1. The respondent did on 18 August 2006 and 11 October 2007 publish or republish to the public, by himself or by any agent or employee, on the World Wide Web at the website address specified in the third column of the Schedule annexed hereto and marked "A" ("the Schedule"), the material contained in the hypertext mark up language (htm) file named in the third column of the Schedule at the pages specified in the fourth column of the Schedule, (which material is reproduced in exhibit "JJ1" to the Affidavit of Jeremy Jones sworn 1 November 2006). The said material, contrary to the Order, conveys the imputations as follows ( row numbers are specified in column one of the Schedule):

(i) Imputation A: the material identified in rows 1-81 inclusive of the Schedule;

(ii) Imputation B: the material identified in rows 82 to 117 inclusive of the Schedule;

(iii) Imputation B: the material identified in rows 119 to 122  inclusive of the Schedule;     

(iv) Imputation B: the material identified in rows 122 to 144  inclusive of the Schedule; 

2. The respondent did publish or republish the document headed "About Adelaide Institute" to the public, by himself or by any agent or employee, on the World Wide Web during or about August 2007, and again on 31 October 2007 at the foot of the pages of the Newsletters/Archive section on the said website for Newsletters 50-80 and 93-112 respectively.

Dated 2 November 2007

Steven Lewis

Solicitor to the applicant

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Slater and Gordon                                                                                                                                              DX 1163  Sydney

Lawyers                                                                                                                                                             Tel: 8267 0600

Level 11, 51 Druitt Street                                                                                                                                   Fax: 8267 0650

Sydney NSW 2000                                                                                                                                            Ref: SL:KW:283157

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