NOTICE OF FILING
Details of Filing
Document Lodged:
Affidavit - Form 59 - Rule 29.02(1)
Court of Filing
FEDERAL COURT OF AUSTRALIA (FCA)
Date of Lodgment:
20/02/2024 11:35:35 AM AEDT
Date Accepted for Filing:
20/02/2024 11:35:39 AM AEDT
File Number:
NSD372/2023
File Title:
MEHREEN FARUQI v PAULINE HANSON
Registry:
NEW SOUTH WALES REGISTRY - FEDERAL COURT OF AUSTRALIA
Registrar
Important Information
This Notice has been inserted as the first page of the document which has been accepted for electronic filing. It is
now taken to be part of that document for the purposes of the proceeding in the Court and contains important
information for all parties to that proceeding. It must be included in the document served on each of those
parties.
The date of the filing of the document is determined pursuant to the Court’s Rules.
CB2052
1
Filed on behalf of (name & role of party)
Mehreen Faruqi, Applicant
Prepared by (name of person/lawyer)
Andrea-Marie Farrugia
Law firm (if applicable)
Marque Lawyers
Tel
(02) 8216 3000
Fax
(02) 8216 3001
Email
michaelb@marquelawyers.com.au; laureng@marquelawyers.com.au;
andreaf@marquelawyers.com.au
Address for service
(include state and postcode)
Level 4, 343 George Street
Sydney NSW 200
.
[Version 3 form approved 02/05/2019]
Form 59
Rule 29.02(1)
Affidavit
No. NSD372 of 2023
Federal Court of Australia
District Registry: New South Wales
Division: General
MEHREEN FARUQI
Applicant
PAULINE HANSON
Respondent
Affidavit of: Andrea-Marie Farrugia
Address: Level 4, 343 George Street, Sydney, NSW 2000
Occupation: Solicitor
Date: 20 February 2024
Contents
Document
number
Details
Paragraph
Page
1
Affidavit of
Andrea-Marie Farrugia in support of Originating
Appli
cation dated 3 May 2023 affirmed on 20 February 2024.
[1
] - [39]
1
-9
2
Annexure “AF-1”, being copies of the correspondence between
Ms Stephanie Tran of Marque Lawyers and
the S
tate Library of
Queensland dated 28 September 2023 and attachments.
[22
]
10
-
13
3
Annexure “AF-2”, being a copy of the email from Fryer Library to
me
dated 18 September 2023, containing confirmation of my
request for (among other things) the Balson Documents
[27(a)
]
14
-
18
4
Annexure “AF-3”, being a copy of the email from AARNET
F
ileSender to me dated 19 September 2023, containing a link
to
the Balson Documents
[27(b)
]
19
5
Annexure “AF-4”, being a copy of the letter from Mr Michael
Bradley of Marque Lawyers to Danny Eid of Danny Eid Lawyers
dated 16 February 2024.
[39
]
20
-
21
AFarrugia
CB2053
2
I, Andrea-Marie Farrugia, solicitor, of Level 4, 343 George St, Sydney NSW 2000 affirm:
1. I am a solicitor of the firm Marque Lawyers, the solicitors for the Applicant.
2. Unless otherwise indicated, I make this affidavit on my own knowledge, information and belief.
Where I depose to matters on information and belief, I believe those matters to be true.
Notice of intention to adduce tendency evidence
3. On 3 October 2023, Marque Lawyers filed a Notice of intention to adduce tendency evidence
(Original Notice) on behalf of the Applicant. An amended copy of the Original Notice was
subsequently filed with the Court on 19 February 2024 (Amended Notice).
4. As explained at paragraphs 37-39 of this affidavit, the Original Notice and the Amended Notice are
substantively the same, other than some minor typographical errors being rectified (in
underline/strike through) in the Amended Notice. Accordingly and for ease, where I refer to the
Original Notice and the Amended Notice together, I do so by referencing the Notice.
5. In this affidavit, and unless otherwise indicated, where I refer to a particular statement attributed to
the Respondent which is referred to in the Notice, I do so by referencing the relevant line item
number for that statement, being the number which appears in the first column (labelled ‘No.’) of
the table entitled ‘Schedule of Conduct’ which is included at pages 2-49 of the Notice.
6. Between about 2 June 2023 and 3 October 2023, I sourced content to be included in the Notice.
During this period, I did the following.
(a) I conducted a number of searches to identify and source the statements attributed to the
Respondent which are referred to in the Notice. Further details in relation to the searches I
conducted, and caused to be conducted, are outlined at paragraphs 7 to 366 of this affidavit.
(b) I caused Mr Xander Schwarz, a former paralegal under the employ of Marque Lawyers, to
identify and source the statements attributed to the Respondent which are referred to in the
Notice. Mr Schwarz is no longer employed by Marque Lawyers. Accordingly, and to the
extent Mr Schwarz conducted any searches in relation to the Notice:
(i) I am unable to access Mr Schwarz’s computer or his computer profile, and as a result
I am unable to confirm the specific searches he conducted, however I believe, based
on the instructions I gave to Mr Schwarz, that his searches would have been similar to
those which I detail at paragraphs 7 to 366 of this affidavit; and
(ii) I reviewed any material identified by Mr Schwarz for the purpose of confirming
whether it should be included in the Notice.
Preliminary searches
7. Prior to undertaking searches to identify and source the statements attributed to the Respondent
which are referred to in the Notice, I conducted, and caused to be conducted, searches using
Google to identify incidents involving the Respondent which had been reported in the media, and
which in my view, showed the Respondent demonstrating the tendencies referred to at paragraphs
[1(a)]-[1(b)] of the Notice (Incidents).
8. I cannot recall the specific search terms I used to identify the Incidents, and I am unable to retrieve
this information from my search history because my Google Chrome profile includes a feature
AFarrugia
CB2054
3
which permanently deletes my search history after 90 days. I believe this feature was
automatically enabled at the time I commenced using Google Chrome because I do not recall
setting it up.
9. The purpose of undertaking the searches described in the paragraph 8 above was to familiarise
myself with the Incidents, and to identify the kinds of statements which the Respondent made in
response to, or throughout, the Incidents. I then used this information to inform the searches
(including the specific terms) I describe at paragraphs 10-36 below.
B. Social media
Hanson Twitter Account
10. Line items 21, 24, 38-44, 48-52, 57, 60, 64, 71-72, 76-77, 85 of the Notice refer to statements
made by the Respondent in Tweets which were published to the Respondent’s Twitter account
‘@PaulineHansonOz’ (Hanson Twitter Account) between 25 July 2013 and 5 July 2023 (Hanson
Tweets).
11. I identified and sourced copies of the Hanson Tweets by doing the following.
(a) I conducted searches of the tweets which have been published to the Hanson Twitter
Account using the ‘Advanced Search’ feature on Twitter which is accessible via the following
link;
https://twitter.com/search-advanced?lang=en. For the reasons explained at paragraph
8 above, I am unable to retrieve my search history through Google Chrome, and as a result I
am unable to access the specific searches I conducted using the Advanced Search feature.
However, to the best of my knowledge and recollection, I believe that the search parameters
I used to identify and source the Hanson Tweets are as follows.
(i) Typing ‘Pauline HansonOz’ into the search bar entitled ‘From these accounts’; and
(ii) Typing combinations of the following search terms into the search bar entitled ‘Any of
these words’.
(A) ‘Islam’ and ‘Islamic’;
(B) ‘Muslim’;
(C) ‘Burqa’ and ‘Burqa ban’;
(D) ‘Aboriginal’, ‘Aborigine’, ‘Aboriginals’, ‘Aborigines’, ‘Indigenous’ and ‘Mob’;
(E) ‘ISIS’ and ‘ISIL’;
(F) ‘Halal’;
(G) ‘Sharia’;
(H) ‘Pray4MuslimBan’ and ‘PrayforMuslimBan’;
(I) ‘Africa’ and ‘African’;
(J) ‘China’ and ‘Chinese’; and
(K) ‘Asia’, ‘Asian’ and ‘Asians’.
AFarrugia
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(b) Between about 2 June 2023 and about 3 October 2023, I reviewed the Hanson Twitter
Account on occasion to identify whether any tweets which had been posted by the
Respondent throughout this period should be included in the Notice. I do not recall how
frequently I reviewed the Hanson Twitter Account throughout this period, however to the best
of my recollection, I believe that it was approximately once to twice per month.
(c) I reviewed an article entitled ‘The Burqa Ban, Islamophobia, and the Effects of Racial
“Othering” in Australian Political Discourses’, authored by Benafsha Askarazai and published
in the Australian Journal of Politics and History, Volume 68, number 2, 2022, which I sourced
through the Wiley Online Library by conducting a search of the words “Pauline Hanson” and
“racist”. Pages 238-241 of this article contain a list of tweets which are attributed to the
Respondent and/or the Hanson Twitter Account.
(d) I also conducted various searches through the Google search engine. For the reasons
explained at paragraph 8 above, I am unable to retrieve my search history through Google
Chrome, and as a result I am unable to access the exact search terms I used to conduct
these searches. However, to the best my recollection, I believe that the searches I
conducted were combinations of some or all of the search terms referred to in paragraph
11(a)(ii) above, along with the words “Pauline Hanson Twitter”, “Pauline Hanson Tweets”
and “racist”.
Hanson Facebook
12. Line items 27-28, 31-32, 55-56, 62, 65-66, 68-70, 78-80 and 86 of the Notice refer to statements
which were published to the Facebook page ‘Pauline Hanson’s Please Explain’ (Hanson
Facebook) between about 19 April 2015 and 6 July 2023 (Hanson Facebook Posts). The
Hanson Facebook is accessible via the following link;
https://www.facebook.com/PaulineHansonAu.
13. I identified and sourced copies of the Hanson Facebook Posts by doing the following.
(a) I conducted searches of the Facebook posts which have been published to the Hanson
Facebook using the search bar entitled ‘Search’ which is accessible through the Hanson
Facebook. For the reasons explained at paragraph 8 above, I do not have access to the
exact the search terms I used to identify the Hanson Facebook Posts, however, to the best
of my recollection I believe that they were a combination of some or all of the search terms
referred to in paragraph 11(a)(ii) above.
(b) Between about 2 June 2023 and about 3 October 2023, I reviewed the Hanson Facebook on
occasion to identify whether any Facebook posts which had been published to the Hanson
Facebook throughout this period should be included in the Notice. I am unable to recall how
frequently I reviewed the Hanson Facebook, however to the best of my recollection, I believe
that it was approximately once per month.
(c) I conducted various searches through the Google search engine. For the reasons explained
at paragraph 8 above, I do not have access to the exact search terms I used to conduct
these searches, however, to the best my recollection, I believe that they were combinations
of some or all of the search terms referred to in paragraph 11(a)(ii) above, along with the
words “Pauline Hanson Facebook”, “Pauline Hanson Facebook posts” and “racist”.
AFarrugia
CB2056
5
C. YouTube videos
Hanson YouTube
14. Line items 25, 53, 58, 73-75, 83 of the Notice refer to statements made by the Respondent in
videos which have been published to the YouTube account entitled ‘Pauline Hanson’s Please
Explain’ (Hanson YouTube) between about 25 October 2014 and 4 July 2023 (Hanson YouTube
Videos). The Hanson YouTube is accessible via the following link;
https://www.youtube.com/@PaulineHansonsPleaseExplain.
15. I identified and sourced copies of the Hanson YouTube Videos by doing the following.
(a) I conducted various searches on YouTube by typing specific search terms into the search
bar. For the reasons explained at paragraph 8 above, I do not have access to the exact
search terms I used to conduct these searches, however, to the best of my recollection, I
believe that were combinations of some or all of the search terms referred to in paragraph
11(a)(ii) above, along with the words “Pauline Hanson” and “Pauline Hanson Please
Explain”.
(b) I viewed, and/or instructed Mr Schwarz to view, several videos that are available on the
‘Videos’ tab (which is accessible through the Hanson YouTube via the following link
https://www.youtube.com/@PaulineHansonsPleaseExplain/videos) for the purpose of
identifying potential videos to be included in the Notice. To the extent Mr Schwarz identified
any such videos, I then reviewed those videos to confirm whether they should be included in
the Notice.
(c) I conducted various searches using Google. For the reasons explained at paragraph 8
above, I do not have access to the exact search terms I used to conduct these searches,
however, to the best my recollection, I believe that they were combinations of some or all of
the search terms referred to in paragraph 11(a)(ii) above. I also recall searching for videos
which showed some of the Incidents by using search terms which described those Incidents.
16. Line items 88-92 of Notice refer to statements which have been published in episodes of the
animation series entitled ‘Pauline Hanson’s Please Explain,’ which was created by Stepmates
Studios and which is available on the Hanson YouTube (Animation Series). I instructed Mr
Schwarz to view the Animation Series for the purpose of identifying potential videos to be included
in the Notice. I then reviewed the videos identified by Mr Schwarz to confirm whether they should
be included in the Notice.
Other YouTube videos
17. Line items 18, 26, 45 and 59 of the Notice refer to statements made by the Respondent in videos
which have been published by various users to YouTube between 27 April 2010 and 6 July 2017. I
identified and sourced copies of this material by conducting the searches referred to in paragraphs
15(a) and 15(c) above.
AFarrugia
CB2057
6
D. Media articles and media appearances
18. Line items 2, 9, 13, 17, 19-20, 23, 30, 33, 34, 46, 61, 63, 84, 93 refer to statements which are
attributed to the Respondent and which were published in various media articles between 30
November 1996 and 5 July 2023 (Media Articles).
19. I identified and sourced copies of the Media Articles by conducting searches on Google. For the
reasons explained at paragraph 8 above, I do not have access to the specific searches I used to
identify the Media Articles, however, to the best of my recollection, I believe that they included the
term “Pauline Hanson”, along with combinations of some or all of:
(a) the search terms referred to in paragraph 11(a)(ii) above; and
(b) the following further search terms:
(i) “racist” and “racism”;
(ii) “true black”; and
(c) descriptions of the Incidents.
20. Line items 6, 22, 35, 47, 54, 87 of the Notice refer to statements made by the Respondent in
various media appearances that she made between about 1996 and 19 July 2023. I identified and
sourced copies of the videos referred to in those line items by conducting the searches referred to
in paragraph 19 above.
E. Other material
Material obtained through libraries
21. Using the search terms referred to at paragraph 19 above, and reviewing the material contained in
the search results which were responsive to those search terms, I identified a number of further
sources that attributed statements to the Respondent, but which I was unable to access through
the resources available on Google and the Respondent’s social media accounts. I have
summarised this material, along with the steps I took to source this material and annex it to the
Notice at paragraphs 22-322 below.
22. Line item 1 of the Notice refers to a statement which is attributed to the Respondent in an article
entitled ‘Hanson Says no to Asia’ which was authored by Simon Kelly and published by The
Queensland Times on or about 7 June 1996 (Hanson Says No Article). I obtained a copy of the
Hanson Says No Article by doing the following.
(a) I instructed Ms Stephanie Tran, a paralegal under the employ of Marque Lawyers, to source
the Hanson Says No Article from the State Library of Queensland on 28 September 2023.
(b) I am informed by Ms Tran and believe that she subsequently:
(i) submitted a webform through the website for the State Library of Queensland
requesting a copy of the Hanson Says No Article; and
(ii) received an email from the State Library of Queensland which attached (among other
things) the Hanson Says No Article.
AFarrugia
CB2058
7
Copies of Ms Tran’s correspondence with the State Library of Queensland including the
attachments are annexed to this affidavit at pages 10-13 and marked “AF-1”.
23. The article annexed at page 50 of the Notice and marked “A” is a true copy of the Hanson Says No
Article that was provided to me by Ms Tran.
24. Line items 3, 5 and 7 of the Notice refer to statements that have been published in a book entitled
‘Pauline Hanson --- the Truth: On Asian Immigration, the Aboriginal Question, the Gun Debate and
the Future of Australia,’ which was published in 1997 (The Truth Book). I obtained a copy of The
Truth Book by doing the following.
(a) I instructed Mr Schwarz to source The Truth Book from the State Library of New South
Wales on about 4 August 2023.
(b) I am informed by Mr Schwarz and believe that he subsequently attended the State Library of
New South Wales and obtained a copy of The Truth Book.
25. I subsequently instructed Mr Schwarz to review The Truth Book to identify any potential pages to
be included in the Notice. I then reviewed the pages identified by Mr Schwarz to confirm that they
should be included in the Notice.
26. The documents included at Annexures C, E and G of the Notice are true copies of the pages which
I extracted, and caused to be extracted, from The Truth Book.
27. Line items 8 and 10-11 of the Notice refer to statements made by the Respondent in media
releases and speeches which she made between 23 April 1997 and 1 July 1997 (Balson
Documents). From my review of website for The University of Queensland Library, I am aware
that the Balson Documents are available in a collection entitled ‘UQFL366 Scott Balson Collection’
at Fryer Library, The University of Queensland Library. I obtained copies of (among other things)
the Balson Documents by doing the following.
(a) On about 6 September 2023, I requested to obtain copies of the Balson Documents (among
other things) through the ‘Fryer item request form’ which is accessible via the following link;
https://web.library.uq.edu.au/library-services/special-collections/fryer-item-request-form. A
copy of the email I received from Fryer Library on 19 September 2023 which contains
confirmation of my request is annexed to this affidavit at pages 14-18 and marked “AF-2”.
(b) On 19 September 2023, I received an email containing a link to the file share platform
AARNET FileSender which contained (among other things) the Balson Documents. A copy
of this email is annexed to this affidavit at page 19 and marked “AF-3”.
28. The documents included at Annexures H, J and L of the Notice are true copies of the Balson
Documents which I obtained through the AARNET FileSender.
29. I subsequently instructed Mr Schwarz to review the material received from Fryer Library, including
the Balson Documents, to identify any potential documents to be included in the Notice. I then
reviewed the specific material which Mr Schwarz identified for the purpose of confirming whether it
should be included in the Notice.
30. Line item 67 of the Notice refers to statements which have been published in a book entitled
‘Pauline In Her Own Words’ which the Respondent is credited as co-authoring with Tom Ravlic,
and which was published on or about 13 April 2018 (In Her Own Words Book). I obtained a copy
of the In Her Own Words Book by doing the following.
AFarrugia
CB2059
8
(a) On 15 September 2023, I instructed Ms Georgia Lewis-Stark, a legal secretary under the
employ of Marque Lawyers, to source the In Her Own Words Book from the State Library of
New South Wales.
(b) I am informed by Ms Lewis-Stark and believe that she subsequently attended the State
Library and obtained a copy of the In Her Own Words Book.
31. I subsequently instructed Mr Schwarz to review the In Her Own Words Book to identify any
potential pages to be included in the Notice. I then reviewed the pages identified by Mr Schwarz to
confirm that they should be included in the Notice.
32. The documents included at Annexure BK of the Notice are true copies of the pages which I
extracted, and caused to be extracted, from The In Her Own Words Book.
Hanson documentary
33. Line items 4, 16, 29, 36 and 37 of the Notice refer to statements made by the Respondent in a
documentary entitled ‘Pauline Hanson: Please Explain!’ which was directed by Anna Broinowski
and initially released on or about 31 July 2016 (Documentary). I am informed by my colleague,
Ms Lauren Gasparini, and believe that she watched the Documentary on Prime Video on 1
September 2023 and identified the statements referred to in these line items.
34. On about 28 October 2023, I am instructed by Ms Gabby Lee, a legal secretary under the employ
of Marque Lawyers, and believe that she subsequently purchased the Documentary from the
Google Play Store.
Media and press releases
35. Line items 12, 14 and 15 of the Notice refer to statements made by the Respondent in press
releases which were published between about 1 October 1997 and about 31 December 1997. I
identified and sourced copies of this material by:
(a) reviewing the press releases available on Trove, and
which can be accessed via the following link;
https://webarchive.nla.gov.au/awa/1999072713
0000/http://www.onenation.com.au/press/press.html; and
(b) conducting searches of Trove using the terms “Pauline Hanson” and “press release” and
reviewing the material that is responsive to those search results.
36. Line items 81-82 refer to statements made by the Respondent in media releases which have been
published to the website located at
https://www.senatorhanson.com.au/ (Hanson Website). I
identified and sourced copies of this material by:
(a) navigating to the webpage entitled “News” on the Hanson Website, and selecting the option
entitled “Media Release’; and
(b) reviewing the media releases available on this webpage.
AFarrugia
CB2060
9
F. Revised notice
37. Subsequent to the Original Notice being filed with the Court, I identified that:
(a) electronic links contained in the sealed copy of the Original Notice did not work in that they
either could not be clicked, or redirected to incorrect webpages;
(b) the annexure markings on pages 50 to 263 of the sealed copy of the Original Notice had
been removed; and
(c) some of the descriptions of the statements and particulars referred to in the table included at
pages 2-49 of the Original Notice contained typographical errors.
38. I believe that the issues referred to in paragraph 37(a)-(b) above occurred at the time at which the
Original Notice was electronically filed with the Court. I have based this belief on the fact that these
issues do not appear in the unsealed copy of the Original Notice which was contained in a Dropbox
folder that I emailed to Mr Danny Eid, the solicitor for the Respondent, on 3 October 2023.
39. On 16 February 2024, I emailed Mr Eid a letter from Mr Michael Bradley which identified the issues
and typographical errors referred to paragraph 37 above, and enclosed an unsealed copy of the
Amended Notice, which rectifies the issues and typographical errors referred to in paragraph 37
above. A copy for Mr Bradley’s letter to Mr Eid is annexed to this affidavit at pages 20-21 and
marked “AF-4.”
Affirmed by the deponent
at Sydney
in New South Wales
on 20 February 2024
Before me:
)
)
)
)
)
Signature of deponent
Signature of witness
Lauren Gasparini
Solicitor
Marque Lawyers
Level 4, 343 George Street
Sydney NSW 2000
This affidavit was affirmed and witnessed via audio visual link in accordance with Part 2B of the
Electronic Transactions Act 2000 (NSW).
AFarrugia
CB2061
1
Andrea Farrugia
From:!SLQ!Ask!Us!<slqas[email protected]nfo>!!
Sent:!Thursday,!September!28,!2023!3:45!PM!
To:!Stephanie!Tran!<stephaniet@marquelawyers.com.au>!
Subject:!ASK101346!Response!to!your!request!
!
State Library of Queensland - Response to your question: ASK101346
Your question number: ASK101346
Our response to your question:
Dear Stephanie,
Thank you for your enquiry requesting the article "Hanson says no to Asia" from the Queensland Times
of 8 June 1996.
I have attached a scan from our microfilm of the page 1 article, as well as the full interview article that
was on page 13.
I trust this information will be useful. If you have another question please submit a new enquiry.
Your feedback in relation to this enquiry will help us to improve our service. Please share your
feedback with us, using the feedback options below.
Kind regards,
Fiona Dixon, Librarian
State Library of Queensland
Number of documents attached to this message:2
Attached documents may be listed at the beginning or end of this email
!
!
You!don't!often!get!email!from![email protected].!Learn!why!this!is!important!
!
10
Annexure AF-1
CB2062
2
Your original question:
Your Question:
Hi,
I'm writing on behalf of Marque Lawyers, we're a law firm based in Sydney. We're after a copy of an
article titled 'Hanson says no to Asia' which was published by the Queensland Times on 8 June 1996.
We urgently need this article for evidence and would really appreciate it if we could get a copy of it by
this Friday (29th September).
Please don't hesitate to reach out if you need any additional information.
Thanks,
Stephanie
List any resources you have already searched:
-
NSW State Library (not available)
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The information provided in this response has been provided to you by our service in good faith. However the information should not
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Please note that information goes out of date and, in particular, URLs that we might provide you may not continue to be available.
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copyright laws.
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11
CB2063
12
CB2064
13
CB2065
1
Andrea Farrugia
From: Fryer Library <[email protected]>
Sent:
Monday, 18 September 2023 12:00 PM
To: Andrea Farrugia
Subject: Application for copies of Fryer Library manuscript material form submission
[Enquiry: 230906-003848]
Subject!
Application for copies of Fryer Library manuscript material form submission
18/09/2023!11:59!AM
Dear Andrea
Thank you for your request for copies. The total cost for digitizing these items will be $156
($20 administration fee plus $1 per page).
We expect that the scanning of these items should be completed by the end of the week.
The delay is due to a number of item being faxes on thermal paper. This can't be scanned
and need to be photographed.
Do you wish to proceed with this request?
Kind regards
Belinda
Fryer Library
06/09/2023!05:17!PM
Submission ID: 108758
Submitted by Anonymous (not verified) on Wed, 09/06/2023 - 17:11
Select your service:
I wish to order copies
Full name:
You don't often get email from [email protected]. Learn why this is important
14
Annexure AF-2
CB2066
2
Andrea Farrugia
Organisation:
Marque Lawyers
Mailing address:
Level 4, 343 George Street, Sydney NSW 200
Phone:
0458757913
Email:
Declaration (order copies service):
I DECLARE that I require the copy(s) for research and study purposes
only,
and that I will not use the material for any other purpose.
Declaration (copyright clearance service):
I DECLARE that I will not use the material for any other purpose.
Additional information:
As per my email of 6 September 2023, the documents may be used in
connection with Federal Court of Australia proceedings no. NSD372/2023 which
were commenced by Senator Mehreen Faruqi against Senator Pauli
ne Hanson on 3
May 2023.
Fryer Call Number:
(02) 82163029
Item details:
UQFL366 Scott Balson Collection
Box 1, Folder 1
Poster for ATSIC elections, 9 Oct 1999, 1 p
UQFL366 Scott Balson Collection
Box 1, Folder 2
Program, notes and speeches relating to ‘Prosper Australia!’, Brisbane, 4
Oct 1997, 14
UQFL366 Scott Balson Collection
Box 2, Folder 1:
o Fax from Pauline Hanson to Scott Balson, 4 June 1998, 1 p
o Fax from Pauline Hanson to Scott Balson, 19 June 1998, 1 p
15
CB2067
3
o Questions and answers for an interview with Heather Hill, 25 Oct 1998, 2 p
o Letter from Pauline Hanson to Scott Balson, 29 Apr 1999, 1 p
UQFL366 Scott Balson Collection
Box 2, Folder 4:
o Text of Pauline Hanson’s speech at Gold Coast Launch, 1 July 1997, 14 p
o Text of Pauline Hanson’s speech in Adelaide, 11 Jun 1997, 13 p
o Papers re: Hanson’s visit to Western Australia and a website posting
linking her to Hitler, 2 May 1997, 2 p
o Fax of Pauline Hanson press release, 14 Jun 1996, 21 p
o Fax of letter from Pauline Hanson to Scott Balson, re: establishment of the
official Pauline Hanson Home Page, 18 Apr 1997, 1
UQFL366 Scott Balson Collection
Box 2, Folder 5:
John Woodley, Senator for Queensland, ‘Why Pauline is Wrong: Fact file on
Aboriginal and Multi
cultural Issues’ with covering letter, 30 Jul 1997, 9 p
UQFL366 Scott Balson Collection
Box 2, Folder 7:
o Notes comparing Pauline Hanson’s statements with those of John Howard at
Longreach headed ‘Howard Longreach’, nd, 1 p
o Notes headed ‘Singaporean Soldiers—Racist Attacks’, nd, 1 p
o Notes headed ‘Hanson Effecting Asian Tourism’, 13 Jul 1997, 1 p
o Notes headed ‘Boswell and Strategy’, 19 Jun 1997, 1 p
o Notes headed ‘Ma Letter’, nd, 1 p
o Notes headed ‘Triads’, nd, 1 p
UQFL366 Scott Balson Collection
Box 2, Folder 8:
•
o Pauline Hanson, ‘So-called anit-racists are nothing but socialist
thugs’, 30 Sep 1997, 1 p
o Pauline Hanson, ‘Australia cannot afford a loan to Thailand’, 12 Aug
1997, 1 p
o Pauline Hanson, ‘McNamara having a slow day’, 22 Jul 1997, 1 p
o Pauline Hanson, ‘’So-Called’ Anti-Racism Committee plots personal
assault on Hanson’, 16 Jul 1997, 1 p
o Pauline Hanson, Statement issued at press conference in Adelaide, 11 Jun
1997, 3 pp
Pauline Hanson, ‘Howard has Amnesia!’, 8 May 1997, 1 p
o Pauline Hanson, ‘Howard a hypocrite!’, 7 May 1997, 1 p
o Pauline Hanson, ‘Send them back!’, 6 May 1997, 1 p
o Pauline Hanson, ‘Big Australian slams little Aussie’, 2 May 1997, 1 p
o Pauline Hanson, ‘Cannibalism is not the issue…the truth is’, 22 Apr
16
CB2068
4
1997, 1 p
o Pauline Hanson, ‘Aboriginal call for trade sanctions treasonous’, 21
Apr 1997, 1 p
UQFL366 Scott Balson Collection
Box 2, Folder 9
Fax of newspaper cutting: George Lamont, ‘What Asia’s top business
leaders think of Hanson’,The Sydney Morning Herald, 21 Jul 1997, 3 p
UQFL366 Scott Balson Collection
Box 3, Folder 3:
Margo Kingston, ‘Party ‘s ‘gone Fischering’ as Pauline baits race
hook’, The Sydney Morning Herald, 12 Sep 1998, p 9
UQFL366 Scott Balson Collection
Box 4, Folder 3
o Letter from Pauline Hanson to One Nation supporters, 10 Oct 1997, 1 p
o Pauline Hanson, ‘An Independent Speaks’, Australian Shooters Journal
(Sep 1996), pp10-11
o Extracts from Hansard with speeches by Pauline Hanson, various dates, 10 p
o Pauline Hanson, letter to all One Nation branches, 30 Sep 1997, 1 p
o News release: Pauline Hanson, ‘So called anti-racists are nothing but
socialist thugs’, 30 Sep 1997, 1 p
UQFL366 Scott Balson Collection
Box 9, Folder 1:
Rutherford, Jennifer, ‘One love too many: the undoing of Pauline Hanson’,
Australian Journal of Politics and History, Vol. 47, No. 2 (2001), pp 192
-208
[with handwritten comments by Scott Balson].
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Question Reference # 230906-003848
17
CB2069
5
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18
CB2070
1
Andrea Farrugia
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19
Annexure AF-3
CB2071
Our reference MB/14217
Phone (02) 8216 3000
Email michaelb@marquelawyers.com.au; laureng@marquelawyers.com.au
16 February 2024
Danny Eid
Danny Eid Lawyers
522 Marrickville Road
Dulwich Hill NSW 2203
By email: danny@dannyeidlawyers.com.au
Dear Danny
Federal Court of Australia proceedings 372/2023 - Faruqi v Hanson
1. We refer to the Notice of intention to adduce tendency evidence, which was filed on behalf of
our client on 3 October 2023 (Notice).
2. Having conducted a further review of the Notice, we have identified that:
(a) many of the links contained in the sealed copy of the Notice do not work in that they
either cannot be clicked, or they redirect to incorrect webpages; and
(b) the annexure markings on pages 50 to 263 of the sealed copy of the Notice have been
removed.
3. We suspect that these issues occurred at the time at which we electronically filed the Notice
with the Court, as they do not appear in the unsealed copy of the Notice that was served on
your client on 3 October 2023. In any event, we apologise for any inconvenience that these
issues may have caused in respect of the sealed copy.
4. In addition to the matters outlined above, we have identified some minor typographical errors in
the descriptions of the statements and particulars which are referred to in the table included at
pages 2-49 of the Notice. These typographical errors are administrative in nature, and largely
relate to the dates.
5. In light of the matters outlined above, and in the interest of assisting both your client and the
Court in navigating the Notice, we have enclosed with this letter an amended copy of the Notice
20
Annexure AF-4
CB2072
2
which rectifies the issues identified in this letter, and amends the typographical errors (in
underline/strike through). We confirm that no substantive changes have been made to this
document.
6. We intend to file the amended copy of the Notice with the Court, and confirm that we will provide
a sealed copy upon receipt from the Registry.
7. If you have any questions in relation to the above, please do not hesitate to contact me.
Yours sincerely
Michael Bradley
Managing Partner
21
CB2073
