NOTICE OF FILING

Details of Filing

Document Lodged: Statement of Claim - Form 17 - Rule 8.06(1)(a)

Court of Filing FEDERAL COURT OF AUSTRALIA (FCA)
Date of Lodgment: 5/12/2023 4:17:03 PM AEDT
Date Accepted for Filing: 5/12/2023 4:54:22 PM AEDT
File Number: VID1023/2023
File Title: MOIRA DEEMING v JOHN PESUTTO
Registry: VICTORIA 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.
Form 17
Rule 8.05(1)(a)
Statement of Claim
No. of 2023
Federal Court of Australia
District Registry: Victoria
Division: General

MOIRA DEEMING
Applicant

JOHN PESUTTO
Respondent

Parties

1. The Applicant (Deeming) is and was at relevant times:

1.1. A Member of the Victorian Parliament for the electoral district of Western
Metropolitan Region in the Legislative Council, elected on 26 November 2022;

1.2. A Member of the Victorian Liberal Party; and

1.3. From 26 November 2022, a Member of the Victorian Parliamentary Liberal Party
(Parliamentary Liberal Party) until she was purportedly expelled on 12 May 2023.

2. The Respondent (Pesutto) is and was at relevant times:

2.1. A Member of the Victorian Parliament for the electoral district of Hawthorn in the
Legislative Assembly, elected on 26 November 2022, having previously been a
Member between 2014 and 2018;

2.2. A Member of the Victorian Liberal Party; and

Filed on behalf of: Deeming

Prepared by: Patrick George
Law firm (if applicable) Company (Giles)
Tel 1300 204 602 Fax
Email [email protected]
Address for service
(include state and postcode) 111 Elizabeth Street, Sydney NSW 2000
. [Form approved 01/08/2011]
 2

2.3. The Leader of the Parliamentary Liberal Party, elected as Leader on 8 December
2022.

Publications

Media Release

3. On or about 19 March 2023, Pesutto published a media release (Media Release):

3.1. By himself or his agents in communicating the Media Release to various persons,
who are presently unknown to Deeming, including journalists, with the intention
and knowledge that it would be published to the world at large

3.2. By himself or his agents in uploading the Media Release to the John Pesutto –
Member for Hawthorn website (https://www.johnpesutto.com.au/) at URL
https://www.johnpesutto.com.au/media-releases/2023-03-19-pesutto-statement-
from-the-leader-of-the-opposition, where it:

(a) was available online for download to readers throughout Victoria, the
Australian Capital Territory, and the other States and Territories of
Australia;

(b) was downloaded and read by persons in Victoria, the Australian Capital
Territory, and the other States and Territories of Australia;

(c) is still available online for download; and

(d) the extent of publication will be sought by way of admissions and discovery
from Pesutto.

A copy of the Media Release as it was uploaded to the John Pesutto – Member for
Hawthorn website is set out in Schedule A to this Statement of Claim.

3.3. By himself or his agents in uploading the Media Release to the Victorian Liberal
Party website (https://vic.liberal.org.au/) at URL https://vic.liberal.org.au/media-
 3

releases/2023-03-19-pesutto-statement-from-the-leader-of-the-
opposition?topic=leader-of-the-liberal-party, where it:

(a) was available online for download to readers throughout Victoria, the
Australian Capital Territory, and the other States and Territories of
Australia;

(b) was downloaded and read by persons in Victoria, the Australian Capital
Territory, and the other States and Territories of Australia;

(c) is still available online for download; and

(d) the extent of publication will be sought by way of admissions and discovery
from Pesutto.

A copy of the Media Release as it was uploaded to the Victorian Liberal Party
website is set out in Schedule B to this Statement of Claim.

3.4. The sense and substance of the Media Release was republished, as intended
and/or authorised by Pesutto and/or as the natural and probable consequence of
its publication on the above websites, in the mainstream news media, on social
media, and elsewhere via the grapevine effect. The sense and substance of the
Media Release was republished, by way of example, in the following articles:

(a) Article published on 19 March 2023 by The Age, entitled “Liberals move to
expel Deeming over neo-Nazi rally links”.

(b) Article published on 19 March 2023 by The Canberra Times, entitled “Vic
Liberal MP set for expulsion over anti-trans rally”.

(c) Article published on 19 March 2023 by The Herald Sun, entitled “Liberal
MP Deeming faces expulsion after neo-Nazi rally”.
 4

(d) Article published on 20 March 2023 in The Guardian, entitled “Deeming

vows to fight expulsion push over involvement in protest attended by neo-
Nazis”.

(e) Article published on 21 March 2023 by The Herald Sun, entitled “Libs vote
as John Pesutto releases dossier on Liberal MP Deeming following anti-
trans rally”.

(f) Article published on 20 March 2023 by The Star Observer, entitled “Liberal
MP Deeming Faces Expulsion For Attending Melbourne Anti-Trans Rally”.

(g) Article published on 20 March 2023 by 7News, entitled “Liberal MP

Deeming set to be expelled over role in violent Melbourne anti-trans rally”.

3.5. Deeming relies on the republication of the Media Release pleaded in paragraph
3.4 as to damages only in relation to the extent of publication of the Media Release.

3.6 The extent of publication of the Media Release will be sought by way of admissions
and discovery from Pesutto.

4. The Media Release was of and concerning Deeming.

5. The Media Release, in its natural and ordinary meaning, was defamatory of Deeming and
carried the following defamatory imputations (or imputations that do not differ in
substance):

5.1. Deeming supports white supremacists and Neo-Nazis.

5.2. Deeming holds abhorrent white supremacist and Neo-Nazi views.

5.3. Deeming knowingly associates with white supremacists and Neo-Nazis.

5.4. Deeming sympathises with white supremacists and Neo-Nazis.

5.5. Deeming is a Neo Nazi.

 5

5.6. Deeming is a white supremacist.

5.7. Deeming is unfit to sit in the Victorian Parliament because she supports white
supremacists and Neo-Nazis.

5.8. Deeming is unfit to sit in the Victorian Parliament because she holds abhorrent
white supremacist and Neo-Nazi views.

5.9. Deeming is unfit to sit in the Victorian Parliament because she knowingly
associates with white supremacists and Neo-Nazis.

5.10. Deeming is unfit to sit in the Victorian Parliament because she sympathises with
white supremacists and Neo-Nazis.

5.11. Deeming is unfit to sit in the Victorian Parliament because she is a Neo Nazi.

5.12. Deeming is unfit to sit in the Victorian Parliament because she is a white
supremacist.

5.13. Deeming is unfit to belong to the Victorian Parliamentary Liberal Party because
she supports white supremacists and Neo-Nazis.

5.14. Deeming is unfit to belong to the Victorian Parliamentary Liberal Party because
she holds abhorrent white supremacist and Neo-Nazi views.

5.15. Deeming is unfit to belong to the Victorian Parliamentary Liberal Party because
she knowingly associates with white supremacists and Neo-Nazis.

5.16. Deeming is unfit to belong to the Victorian Parliamentary Liberal Party because
she sympathises with white supremacists and Neo-Nazis.

5.17. Deeming is unfit to belong to the Victorian Parliamentary Liberal Party because
she is a Neo-Nazi.
 6

5.18. Deeming is unfit to belong to the Victorian Parliamentary Liberal Party because
she is a white supremacist.

5.19. Deeming is unfit to belong to the Liberal Party because she supports white
supremacists and Neo-Nazis.

5.20. Deeming is unfit to belong to the Liberal Party because she holds abhorrent white
supremacist and Neo-Nazi views.

5.21. Deeming is unfit to belong to the Liberal Party because she knowingly associates
with white supremacists and Neo-Nazis.

5.22. Deeming is unfit to belong to the Liberal Party because she sympathises with white
supremacists and Neo-Nazis.

5.23. Deeming is unfit to belong to the Liberal Party because she is a Neo Nazi.

6. The imputations pleaded in the preceding paragraph, or imputations that do not differ in
substance, were carried to readers of the Press Release who also listened to an interview
of Pesutto with Neil Mitchell of 3AW Melbourne on 20 March 2023 (3AW Interview):

6.1. A transcript of the 3AW Interview is set out in Schedule C to this Statement of
Claim;

6.2. The 3AW Interview was broadcast by 3AW radio at or about 8.55am on 20 March
2023 to an audience throughout the Melbourne RA1 licence area in Victoria;

6.3. The 3AW Interview was live streamed by 3AW radio at or about 8.55am on 20
March 2023 to an audience throughout Victoria, the Australian Capital Territory,
and the other States and Territories of Australia through the 3AW website
(http://www.3aw.com.au) and other online radio streaming services and
applications;

6.4. The 3AW Interview was also uploaded on or around 20 March 2023 to the 3AW
website under the title “Liberals move to expel controversial MP over neo-Nazi rally
 7

links” at URL http://www.3aw.com.au/liberals-move-to-expel-controversial-mp-

over-neo-nazi-rally-links/, where it:

(a) was available online for download to readers throughout Victoria, the
Australian Capital Territory, and the other States and Territories of
Australia;

(b) was downloaded and listened to by persons in Victoria, the Australian

Capital Territory and the other States and Territories of Australia; and

(c) is still available online for download;

6.5. Further particulars of the extent of publication and republication of the 3AW
Interview may be provided following subpoenas to 3AW.

7. The publication of the Media Release by Pesutto has caused, or is likely to cause, serious
harm to Deeming’s reputation by reason of the following facts and matters:

7.1. The seriously defamatory nature of the Media Release and the imputations
conveyed to recipients.

7.2. Applying general community standards, the defamatory imputations as conveyed

were likely to lead the ordinary reasonable recipient to think less of Deeming and
to cause a serious, not trivial, degree of harm to her reputation.

7.3. The degree of harm to Deeming’s reputation was self-evidently caused by the
extent of publication and republication of such serious imputations to the world at
large, to persons she knows, to persons she does not know, to persons who knew
her or knew of her, and those who did not know of her beforehand.

7.4. The publication was not restricted or sought to be restricted to a limited audience
but was unrestricted to the world at large.
 8

7.5. The publication caused or was likely to cause ordinary reasonable recipients and
the actual recipients to conclude that Deeming’s position with the Parliamentary
Liberal Party was ‘untenable’ and she should be expelled.

7.6. The Media Release was published as the start of an ongoing, relentless and
persistent public campaign against Deeming by Pesutto where:

(a) The Media Release, 3AW Interview and the matters pleaded below were
published to an extensive and, at least in a significant part, distinct
audience due to the nature of the matters, the manner and timing of their
publication and the different media outlets involved, including their target
and actual audiences, such that in the circumstances each was likely to
cause and did cause serious harm to Deeming’s reputation;

(b) Each of the matters had joint, cumulative and/or continuation effects in the
circumstances to cause or be likely to cause serious harm to Deeming’s
reputation when two or more of the matters were published to the same
audience;

(c) There was extensive republication of the Media Release and Pesutto’s
other statements against Deeming which were (i) spread by mainstream
media in newspapers and online; (ii) spread online, including on various
social media platforms; (iii) spread by the grapevine effect; and (iv) spread
by word of mouth; and

(d) Pesutto published the same or similar imputations to those carried by the
Media Release repeatedly in his campaign against Deeming, to convince
the world at large, not restricted to members of the Parliamentary Liberal
Party, that the imputations were true and of such gravity that they required
her urgent expulsion from the Parliamentary Liberal Party.

7.7. The actual impact of the campaign, starting with the Media Release, to those who
listened to, watched or read about Pesutto’s statements about Deeming. This
caused hateful conduct by members of the public, including vandalism of
Deeming’s Electorate Office sign with ‘Nazi Bigot’ written across her face,
retraction of official MP invitations from community functions, social media
 9

reactions, threats, jibes, hatred, harassment, abuse, contempt and ridicule through
emails, letters and voicemails to Deeming and on social media.

7.8. Pesutto’s false allegations against Deeming have been widely discussed on a
large number of online platforms, including social media, particularly given the
political interest and notoriety of the incursion by neo-Nazis at the ‘Let Women
Speak’ rally on 18 March 2023 (Rally) and Pesutto’s subsequent publicity
campaign to expel Deeming from the Parliamentary Liberal Party, meaning that
the grapevine effect increased the harm to Deeming’s reputation.

7.9. On 21 March 2023, the Herald Sun published a two page spread (pages 8 and 9)
of articles entitled “State to outlaw Nazi Salute”, “Deeming is looking like Bernie
Finn 2.0 and be John Pesutto’s make-or-break moment” and “Risky Bid to expel
sitting MP – Opposition leadership on the line” (21 March Herald Sun Articles).

(a) A copy of the 21 March Herald Sun Articles are set out at Schedule D to this
Statement of Claim.

(b) The 21 March Herald Sun Articles featured a large image, with a photograph
of Deeming and Kellie-Jay Keen in the foreground and the neo-Nazis in salute
on the steps of Parliament House in the background. The photo conveyed
that the neo-Nazis saluted Deeming and Kellie-Jay Keen at the Rally.
Deeming complained to one of the Herald Sun journalists who said he did not
make the decision to place the photo with the Articles, he only writes stories,
but Deeming needed to talk to her leader (Pesutto) who had ‘compiled
dossiers of evidence’ to claim she had links with the neo-Nazis and that no
one was talking about her at the Rally until Pesutto did.

(c) The 21 March Herald Sun Articles included the following content:

“Mr Pesutto said the decision to expel her had nothing to do with the
transgender debate, but concerned her association with extremists.”

He said he could not accept that Ms Deeming did not know the
organisers of the Let Women Speak event had links with neo-Nazis
and white supremacists.
 10

“I just can’t satisfy [myself] that Moira didn’t know”, he said.

“It wasn’t just that Moira had escorted organisers through the precinct
of parliament. It wasn’t just that Moira stayed at the protest when
Nazis turned up. It was the celebration that you can see on social
media afterwards, which tells you perhaps all you need to know about
why it’s necessary to bring this motion”.

“It’s saying that ‘I am prepared to associate with those people and

not take the opportunity to walk away from them despite the odious
things they have shared”.

“Any question of an association, even indirectly, to Nazis, white

supremacists, ethno-fascists or whatever else, is so odious in 2023,
as it should be, that I can’t see a way back.”

7.10. The Media Release, of itself, and as part of the public campaign, caused and/or
exacerbated a tide of both public and private negativity and hatred towards
Deeming which preceded the meeting of the Parliamentary Liberal Party on 27
March 2023 (27 March Meeting), and then the further motion to expel and her
expulsion from the Parliamentary Liberal Party on 12 May 2023, and continues.

7.11. Prior to the publication of the matters complained of, Deeming had a respected
reputation within the Victorian Liberal Party, her constituency, and the community
generally, and was proud of the contribution that she had made, as an individual,
a teacher, a Councillor, as a Member of Parliament and a member of the
Parliamentary Liberal Party.

7.12. Pesutto’s role and status was as the Leader of the Victorian Liberal Party. In that
capacity, when he made the allegations about a Member of his own Parliamentary
Liberal Party that led to the attempted but withdrawn expulsion of Deeming on 27
March 2023 and then her expulsion from the Parliamentary Liberal Party on 12
May 2023, it meant that many of those to whom his statements were published
have believed, and were likely to believe, that the defamatory imputations are true,
irrespective of the actual falsity of the imputations and irrespective of contrary
information from Deeming or other sections of the public and media. This is
 11

particularly the case given the nature of the allegations because the Liberal Party
is to the right of the then, and current, Labor Party in Government. This
significantly undermined the way in which Deeming is seen and regarded not only
by constituents and members of the public or the Left or other political persuasions
who may actively disagree with Deeming and her political positions but also by
members of the Liberal Party and other persons with centre-right views that would
otherwise have supported her.

7.13. This was particularly the case as Pesutto took the drastic steps toward threatening
to expel her and successfully campaigning for her eventual expulsion from the
Parliamentary Liberal Party, a most exceptional step in Australian politics, indeed
a step of ‘last resort’, and then expelling her. The fact that Deeming has been
expelled from the Parliamentary Liberal Party will reinforce, in the minds of ordinary
reasonable people to whom Pesutto’s statements were published, that the
imputations were regarded as true by those who voted to expel Deeming, that they
are true, and that they were the basis for Deeming’s suspension and expulsion.

7.14. The serious harm caused or likely to be caused to Deeming’s reputation was
evident at the meeting on 27 March Meeting, during which:

(a) Nick McGowan MP said: “If the motion is successful today you are actually
labelling someone a Nazi. Moira is going to have to live with that. It’s like
calling someone a murderer, a rapist or a paedophile. Substance is key
because there is not a penalty that is worse than this”.

(b) Deeming said:

“Your decision today - whether you like it or not - will be linked in the minds
of the public, to the specific accusations and imputations in that dossier. I
want to remind you all that being accused of Nazism - in any degree - by
the Liberal Party Parliamentary Victoria - is going to have heinous
consequences for my life, the lives of my husband and our four children. It
will have negative consequences for anybody associated with me, like my
brother, my parents, and my friends. My husband and I have already begun
to receive hate mail from people who’ve read those accusations, and now
believe that we are white supremacists. There have already been threats
 12

of violence against me, because of these accusations. A stranger has

already attempted to trespass into our backyard where our children play.
The Police have had to start doing regular patrols outside our home to help
keep us safe. We’ve already had threats to withdraw work opportunities
because of these accusations. Our children have already been excluded
from their activities and groups

These allegations against me of Nazism and hatred towards the trans

community are 100% false. But people will believe them if you support this
motion to expel me. So even if you don’t like me, or you think my focus isn’t
mainstream enough, or you worry that I’m not a team player- please by all
means deal with me, but whatever you do, please don’t deal with me via
this expulsion motion because it smears me and my family as Nazi
sympathisers when it couldn’t be further from the truth”.

7.15. The media outlets, like the Herald Sun, which republished Pesutto’s statements,
have large audiences in Victoria, and the other States and Territories throughout
Australia. Pesutto’s statements were indiscriminately published, as he knew and
intended and/or authorised, to the world at large. It is to be inferred that many of
those to whom the statements were published would believe, and did believe, the
imputations to be true. The incursion by neo-Nazis at the Rally on 18 March 2023,
and Pesutto’s subsequent steps to have Deeming expelled from the Parliamentary
Liberal Party on the basis of associations with Nazism, made the publications
particularly topical as news and made Deeming the target of vilification and hatred
online and on social media.

7.16. The Media Release, 3AW Interview and other matters pleaded below remain
available online and will cause and are likely to cause ongoing harm by their
permanence. In the absence of a public and fulsome exoneration, retraction and
apology from Pesutto or vindication by way of a judgment in Deeming’s favour in
these proceedings, the serious harm to Deeming’s reputation is likely to continue
and be ongoing indefinitely.
 13

7.17. The serious harm to Deeming’s reputation from the campaign that the Media
Release instigated continues in various and unexpected situations. For example:

(a) On 24 October 2023, she attended a meeting in Scotland with two Scottish
MPs who refused to allow photographs taken together with her to be
published until and unless her name and reputation was cleared of any
association with Nazism.

(b) On 25 November 2023, Deeming was scheduled to speak at a community

forum with a Local Government Councillor, Council Watch (AU) and local
residents at a local Church Hall in Werribee, but the Church was inundated
with threats and complaints about Deeming’s supposed ‘Nazism’ and so the
venue pulled out and the event had to be moved outdoors to a park.

7.18. The commencement of these proceedings and the defence to be filed by Pesutto
in these proceedings, as foreshadowed in correspondence from his solicitors, and
the hearing of the trial are likely to cause serious harm to Deeming’s reputation
unless or until she is vindicated by the court and there is reparation of her
reputation.

7.19. Deeming will provide further particulars of the serious harm to her reputation in the
course of the proceedings.

3AW Interview

8. On or around 20 March 2023, Pesutto published an interview with Neil Mitchell of 3AW
Melbourne (3AW Interview):

8.1. A transcript of the 3AW Interview is set out in Schedule C to this Statement of
Claim;

8.2. The 3AW Interview was broadcast by 3AW radio at or about 8.55am on 20 March
2023 to an audience throughout the Melbourne RA1 licence area in Victoria;
 14

8.3. The 3AW Interview was live streamed by 3AW radio at or about 8.55am on 20
March 2023 to an audience throughout Victoria, the Australian Capital Territory
and the other States and Territories of Australia through the 3AW website
(http://www.3aw.com.au) and other online radio streaming services and
applications;

8.4. The 3AW Interview was also uploaded on or around 20 March 2023 to the 3AW
website under the title Liberals move to expel controversial MP over neo-Nazi rally
links” at URL http://www.3aw.com.au/liberals-move-to-expel-controversial-mp-
over-neo-nazi-rally-links/, where it:

(a) was available online for download to readers throughout Victoria, the
Australian Capital Territory, and the other States and Territories of
Australia;

(b) was downloaded and listened to by persons in Victoria, the Australian

Capital Territory and the other States and Territories of Australia; and

(c) is still available online for download;

8.5. In publishing the 3AW Interview, Pesutto intended and/or authorised and/or it was
the natural and probable consequence of his publication that 3AW would publish
or republish the sense and substance of the 3AW Interview on its various media
platforms;

8.6. Further particulars of the extent of publication and republication of the 3AW
Interview may be provided following subpoenas to 3AW.

9. The 3AW Interview was of and concerning Deeming.

10. The 3AW Interview, in its natural and ordinary meaning, was defamatory of Deeming and
carried the following defamatory imputations (or imputations that do not differ in
substance):

10.1. Deeming helped organise, promote and attended a rally with Nazi activists.
 15

10.2. Deeming had so conducted herself as to warrant being expelled from the Liberal
Parliamentary Party by associating with Nazi activists.

10.3. Deeming associates with Nazis.

10.4. Deeming is a Nazi sympathiser.

11. The publication of the 3AW Interview by Pesutto has caused, or is likely to cause, serious
harm to Deeming's reputation by reason of the following facts and matters:

11.1. The seriously defamatory nature of the 3AW Interview and the imputations
conveyed to recipients.

11.2. Applying general community standards, the defamatory imputations as conveyed

were likely to lead the ordinary reasonable recipient to think less of Deeming and
to cause a serious, not trivial, degree of harm to her reputation.

11.3. The degree of harm to Deeming's reputation was self-evidently caused by the
extent of publication and republication of such serious imputations to the world at
large, to persons she knows, to persons she does not know, to persons who knew
her or knew of her, and those who did not know of her beforehand.

11.4. The publication was not restricted or sought to be restricted to a limited audience
but was unrestricted to the world at large.

11.5. The publication caused or was likely to cause ordinary reasonable recipients and
the actual recipients to conclude that Deeming's position with the Parliamentary
Liberal Party was 'untenable' and she should be expelled.

11.6. Neil Mitchell was the highest rated radio host in Melbourne and one of the most
prominent and listened to radio hosts and political commentators in Australia such
that there:

(a) was an extensive audience both by broadcast radio and online of the 3AW
Interview;
 16

(b) listeners would regard content on his show as a reliable source of news; and

(c) there was a significant grapevine effect from statement on the show such as
the 3AW Interview.

11.7. The 3AW Interview was published as part of an ongoing, relentless and persistent
public campaign against Deeming by Pesutto. Deeming otherwise repeats the
facts and matters pleaded at paragraphs 7.6-7.18 above.

11.8. Deeming will provide further particulars of the serious harm to her reputation in the
course of the proceedings.

ABC Interview

12. On or about 20 March 2023, Pesutto published an interview with the Australian
Broadcasting Corporation (ABC Interview):

12.1. A transcript of the ABC Interview is set out in Schedule E to this Statement of
Claim;

12.2. The ABC Interview was published by television broadcast on ABC Television at or
about 9.39am on 20 March 2023 to viewers in Victoria, the Australian Capital
Territory, and the other States and Territories of Australia;

12.3. The ABC Interview was published by streaming on ABC iView on 20 March 2023
to viewers in Victoria, the Australian Capital Territory, and the other States and
Territories of Australia;

12.4. In publishing the ABC Interview, Pesutto intended and/or authorised and/or it was
the natural and probable consequence of his publication that the ABC would
publish or republish the sense and substance of the ABC Interview on its various
media platforms;

12.5. The sense and substance of the ABC Interview was republished on ABC
Television, and on other affiliated ABC television stations, at times presently
 17

unknown to Deeming to viewers in Victoria and the other States and Territories of
Australia;

12.6. The ABC Interview was uploaded on or around 20 March 2023 to the ABC website
(www.abc.net.au), a mass media website read and viewed by multiple
readers/viewers, including:

(a) under the title “VIDEO: Victorian Opposition Leader moves to expel MP
over anti-trans protest attended by neo-Nazis” at URL
https://www.abc.net.au/news/2023-03-20/victorian-opposition-leader-to-
expel-mp-over-anti-trans-protest/102118582;

(b) as part of an article titled “Victorian government moves to ban Nazi salute
as Liberals move to expel MP Deeming over anti-trans rally” at URL
https://www.abc.net.au/news/2023-03-19/victorian-liberals-move-to-expel-
mp-who-attended-rally/102117788,

where it:

(i) was available online for download to viewers throughout Victoria, the
Australian Capital Territory, and the other States and Territories of
Australia;

(ii) was downloaded and viewed by persons in Victoria, the Australian

Capital Territory, and the other States and Territories of Australia;
and

(iii) is still available online for download;

12.7. Further particulars of the extent of publication and republication of the ABC
Interview may be provided following subpoenas to the ABC.

12.8. The sense and substance of the ABC Interview was republished, as intended
and/or authorised by Pesutto and/or as the natural and probable consequence of
its publication and republication as pleaded above, in other mainstream news
 18

media, on social media, and elsewhere via the grapevine effect. The sense and
substance of the ABC Interview was republished, by way of example, in the
following articles:

(a) Article published on 20 March 2023 by The Epoch Times, entitled “Victorian
MP to be Expelled For Attending Women’s Rights Rally Against
Transgender in Sports”.

(b) Article published on 21 March 2023 by Politicom, entitled “Lib MP published

for LGBTQ pushback”.

(c) Article published on 28 March 2023 by Daily Mail Australia, entitled

“EXCLUSIVE: Inside the betrayal that drove Deeming to fight for the
protection of women’s rights – and why the suspended MP will NEVER be
silenced”.

12.9. Deeming relies on any republication of the sense and substance of the ABC
Interview as pleaded in paragraph 12.8 above as to damages only in relation to
the extent of publication of the ABC Interview.

13. The ABC Interview was of and concerning Deeming.

14. The ABC Interview, in its natural and ordinary meaning, was defamatory of Deeming and
carried the following defamatory imputations (or imputations that do not differ in
substance):

14.1. Deeming supports white supremacists and Neo-Nazis.

14.2. Deeming holds abhorrent white supremacist and Neo-Nazi views.

14.3. Deeming knowingly associates with white supremacists and Neo-Nazis.

14.4. Deeming sympathises with white supremacists and Neo-Nazis.

14.5. Deeming is a Neo Nazi.

 19

14.6. Deeming is a white supremacist.

14.7. Deeming is unfit to sit in the Victorian Parliament because she supports white
supremacists and Neo-Nazis.

14.8. Deeming is unfit to sit in the Victorian Parliament because she holds abhorrent
white supremacist and Neo-Nazi views.

14.9. Deeming is unfit to sit in the Victorian Parliament because she knowingly
associates with white supremacists and Neo-Nazis.

14.10. Deeming is unfit to sit in the Victorian Parliament because she sympathises with
white supremacists and Neo-Nazis.

14.11. Deeming is unfit to sit in the Victorian Parliament because she is a Neo Nazi.

14.12. Deeming is unfit to sit in the Victorian Parliament because she is a white
supremacist.

14.13. Deeming is unfit to belong to the Victorian Parliamentary Liberal Party because
she supports white supremacists and Neo-Nazis.

14.14. Deeming is unfit to belong to the Victorian Parliamentary Liberal Party because
she holds abhorrent white supremacist and Neo-Nazi views.

14.15. Deeming is unfit to belong to the Victorian Parliamentary Liberal Party because
she knowingly associates with white supremacists and Neo-Nazis.

14.16. Deeming is unfit to belong to the Victorian Parliamentary Liberal Party because
she sympathises with white supremacists and Neo-Nazis.

14.17. Deeming is unfit to belong to the Victorian Parliamentary Liberal Party because
she is a Neo-Nazi.
 20

14.18. Deeming is unfit to belong to the Victorian Parliamentary Liberal Party because
she is a white supremacist.

14.19. Deeming is unfit to belong to the Liberal Party because she supports white
supremacists and Neo-Nazis.

14.20. Deeming is unfit to belong to the Liberal Party because she holds abhorrent white
supremacist and Neo-Nazi views.

14.21. Deeming is unfit to belong to the Liberal Party because she knowingly associates
with white supremacists and Neo-Nazis.

14.22. Deeming is unfit to belong to the Liberal Party because she sympathises with white
supremacists and Neo-Nazis.

14.23. Deeming is unfit to belong to the Liberal Party because she is a Neo Nazi.

14.24. Deeming is unfit to belong to the Liberal Party because she is a white supremacist.

15. The imputations pleaded in the preceding paragraph, or imputations that do not differ in
substance, were carried to viewers of the ABC Interview who also listened to the 3AW
Interview. Deeming repeats the matters she pleaded in paragraph 6 above.

16. The publication of the ABC Interview by Pesutto has caused, or is likely to cause, serious
harm to Deeming’s reputation by reason of the following facts and matters:

16.1. The seriously defamatory nature of the ABC Interview and the imputations
conveyed to recipients.

16.2. Applying general community standards, the defamatory imputations as conveyed

were likely to lead the ordinary reasonable recipient to think less of Deeming and
to cause a serious, not trivial, degree of harm to her reputation.

16.3. The degree of harm to Deeming’s reputation was self-evidently caused by the
extent of publication and republication of such serious imputations to the world at
 21

large, to persons she knows, to persons she does not know, to persons who knew
her or knew of her, and those who did not know of her beforehand.

16.4. The publication was not restricted or sought to be restricted to a limited audience
but was unrestricted to the world at large.

16.5. The publication caused or was likely to cause ordinary reasonable recipients and
the actual recipients to conclude that Deeming’s position with the Parliamentary
Liberal Party was ‘untenable’ and she should be expelled.

16.6. The ABC portrays itself as a respected, reliable, non-partisan and balanced news
source such that the information in the ABC Interview would be considered by the
audience to be reliable and reach an extensive number of people.

16.7. The ABC Interview was published as part of an ongoing, relentless and persistent
public campaign against Deeming by Pesutto. Deeming otherwise repeats the
facts and matters pleaded at paragraphs 7.6-7.18 above.

16.8. Deeming will provide further particulars of the serious harm to her reputation in the
course of the proceedings.

The Press Conference

17. On or about 20 March 2023, Pesutto published an interview with the media (Press
Conference):

17.1. A transcript of the Press Conference is set out in Schedule F to this Statement of
Claim;

17.2. Deeming does not presently know the journalists and other persons who were
present and comprehended the Press Conference;
 22

17.3. Pesutto published the Press Conference with the intention and knowledge that his
statements would be published or republished to the world at large and/or
authorised those persons present to publish or republish his statements to the
world at large and/or it was the natural and probable consequence of his
publication that his statements would be published or republished to the world at
large in Victoria, the Australian Capital Territory, and the other States and
Territories of Australian;

17.4. The Press Conference was republished on multiple online media platforms in
Victoria, the Australian Capital Territory and the other States and Territories of
Australia in the following publications:

(a) Article published on 20 March 2023, by the Australian Financial Review,

entitled “Liberal MP’s position ‘untenable’ after Nazi rally” which reported:

“I will never, ever accept any member of the parliamentary Liberal

Party under my leadership ever associating with anybody who
shares a platform with people who peddle hate, division and attack
people for who they are,” Mr Pesutto said.

“I’m not here to say that people can’t have different views. I’m here
to say it will never be acceptable in this state of Victoria, as a
member of the Liberal Party, to associate with anyone who is
connected with or shared platforms with Nazis, white supremacists,
ethno-nationalists, or whatever other odious agenda someone
wishes to spout.”

“We need to take these strong, decisive steps to show that we will
never support and that we will always oppose anything that is
hateful or liable to incite [violence].”

(b) Article published on 20 March 2023, by The Age, entitled “Deeming vows
to fight move to expel her from party room” which reported that Pesutto
stated “Deeming has had an association with people to organise the rally
along with her assistance, who have shared platforms with viewpoints with
people who promote Nazi views or sympathies.”
 23

(c) Article published on 20 March 2023 by SBS News, entitled “Victorian MP

intends to fight expulsion as party leader ‘satisfied’ MP knew of rally’s Nazi
links”.

(d) Article published on 20 March 2023 by the Canberra Times, entitled “Vic
Lib leader ‘satisfied’ MP knew rally’s Nazi links”.

(e) Article published on 20 March 2023 by The Guardian, entitled “Deeming

vows to fight expulsion push over involvement in protest attended by neo-
Nazis” which reported that Pesutto had stated:

“There wasn’t really any alternative but to do this, the reason being
any question of an association, even indirectly, with Nazis, white
supremacists, eco-fascists [sic] or whatever else is so odious in
2023 – as it should be – that I can’t see a way back”.

(f) Article published on 20 March 2023 by the Star Observer, entitled “Liberal
MP Deeming Faces Expulsion For Attending Melbourne Anti-Trans Rally”.

(g) Article published on 20 March 2023 by Sky News, entitled “Victorian Liberal
leader moves to expel MP Deeming over alleged links to far right groups
during heated anti-trans protest”.

(h) Article published on 21 March 2023, by The Age, entitled “Dumping

Deeming to be big test for Pesutto”, which reported, amongst other things,
that Mr Pesutto had said that it was necessary for the Liberal Party to take
these steps against Ms Deeming “to show that we will never support and
that we will always oppose anything that is hateful or liable to incite
[violence]”.

(i) Article published on 21 March 2023, in the Bendigo Advertiser, entitled

“Nazi salute to be banned in Victoria”.

(j) Article published on 21 March 2023, by Warrnambool Standard, entitled

“Nazi salute to be banned in Victoria”.
 24

(k) Article published on 21 March 2023, by The Herald Sun, entitled “Risky bid
to expel sitting MP – Opposition leadership on the line”, which reported that
Pesutto had said “the decision to expel her had nothing to do with the
transgender debate, but concerned her association with extremists. He
said he could not accept that Ms Deeming “did not know the organisers of
the Let Women Speak event had links with neo-Nazis and white
supremacists”. “I just can’t satisfy that Moira didn’t know,” he said. “It wasn’t
just that Moira had escorted organisers through the precinct of parliament.
It wasn’t just that Moira stayed at the protest when Nazis turned up. It was
the celebration that you can see on social media afterwards, which tells
you perhaps all you need to know about why it’s necessary to bring this
motion. It’s saying that ‘I am prepared to associate with those people and
not take the opportunity to walk away from them despite the odious things
they have shared’. Any question of an association, even indirectly, to Nazis,
white supremacists, ethno-fascists or whatever else, is so odious in 2023,
as it should be, that I can’t see a way back.”.

(l) Article published on 25 March 2023, by The Guardian, entitled “The

Deeming question: Victorian Liberals are at war, but leader John Pesutto
knows the party must change”.

17.5. Deeming relies on the republications pleaded in paragraph 17.4 above as to

damages only in relation to the extent of publication of the Press Conference;

17.6. Further particulars of the extent of publication and republication of the Press
Conference will be provided following admissions from Pesutto, discovery,
interrogatories and/or subpoenas.

18. The Press Conference was of and concerning Deeming.

19. The Press Conference, in its natural and ordinary meaning, was defamatory of Deeming
and carried the following defamatory imputations (or imputations that do not differ in
substance):

19.1. Deeming helped Neo-Nazis by working with them to promote their hateful agenda
of vilification and hatred;
 25

19.2. Deeming had so conducted herself in assisting Neo-Nazis to promote their hateful
agenda of vilification and hate on the steps of Parliament that she should be
expelled from the Parliamentary Liberal Party;

19.3. Deeming deliberately gave Neo-Nazis a platform on the steps of Parliament;

19.4. Deeming actively participated in a rally and knowingly worked with the key
speaker, Kellie-Jay Keen, to promote her Neo-Nazi sympathies of hate and
vilification, and promote her white supremacist and ethno-fascist views of hate and
vilification;

19.5. Deeming engaged in hateful conduct while a member of the Parliamentary Liberal
Party by actively participating in and working with the organisers of a rally who she
knew were Neo-Nazi sympathisers;

19.6. Deeming knowingly associated with people who share a platform with Neo-Nazis
who peddle hate and division and attack people for who they are;

19.7. Deeming had so conducted herself in staying at a rally attended by Neo-Nazis and
then celebrating with the key speakers of the rally who had Neo-Nazi sympathies
after ugly scenes had occurred on the steps of Parliament so as to warrant her
immediate expulsion from the Parliamentary Liberal Party;

19.8. Deeming had so conducted herself before, during and after a rally at Parliament in
associating herself with the key speakers who have shared platforms and
endorsed viewpoints of Neo-Nazis so as to warrant her immediate expulsion from
the Parliamentary Liberal Party;

19.9. Deeming supports Neo-Nazi’s hateful views towards others by her association with
Neo-Nazi sympathiser, Kellie-Jay Keen, the key speaker at the Let Women Speak
Rally;

19.10. Deeming stands with Neo-Nazis and white supremacists.

 26

20. The imputations pleaded in the preceding paragraph, or imputations that do not differ in
substance, were carried to listeners or viewers or recipients of republications of the Press
Conference who also listened to the 3AW Interview. Deeming repeats the matters she
pleaded in paragraph 6 above.

21. The publication of the Press Conference by Pesutto has caused, or is likely to cause,
serious harm to Deeming’s reputation by reason of the following facts and matters:

21.1. The seriously defamatory nature of the Press Conference and the imputations
conveyed to recipients.

21.2. Applying general community standards, the defamatory imputations as conveyed

were likely to lead the ordinary reasonable recipient to think less of Deeming and
to cause a serious, not trivial, degree of harm to her reputation.

21.3. The degree of harm to Deeming’s reputation was self-evidently caused by the
extent of publication and republication of such serious imputations to the world at
large, to persons she knows, to persons she does not know, to persons who knew
her or knew of her, and those who did not know of her beforehand.

21.4. The publication was not restricted or sought to be restricted to a limited audience
but was unrestricted to the world at large.

21.5. The publication caused or was likely to cause ordinary reasonable recipients and
the actual recipients to conclude that Deeming’s position with the Parliamentary
Liberal Party was ‘untenable’ and she should be expelled.

21.6. The availability of the Press Conference to the media, attendance by the media
and the extensive publication of the Press Conference.

21.7. The Press Conference was published as part of an ongoing, relentless and
persistent public campaign against Deeming by Pesutto. Deeming repeats the
facts and matters she pleaded at paragraphs 7.6-7.18 above.
 27

21.8. Deeming will provide further particulars of the serious harm to her reputation in the
course of the proceedings.

The Expulsion Motion and Dossier

22. On or about 20 March 2023, Pesutto published an Expulsion Motion of Deeming from the
Parliamentary Liberal Party and an Annexure:

22.1. By himself or his agents, by writing, signing and sending a letter to Deeming and
Members of the Parliamentary Liberal Party and other persons unknown to
Deeming which was expressed to be a notice to Deeming, under the Parliamentary
Liberal Party Constitution, of Pesutto’s intention to call a special meeting of the
Parliamentary Liberal Party and to move a motion that she be expelled from the
Parliamentary Liberal Party and which included an Annexure (collectively,
Expulsion Motion and Dossier);

22.2. A copy of the Expulsion Motion and Dossier is set out in Schedule G to this
Statement of Claim;

22.3. By himself or his agents, by communicating a copy of the Expulsion Motion and
Dossier to unknown persons associated with the media outlets The Australian and
The Herald Sun intending and authorising those media outlets to publish the
document to the world at large in Victoria, Australian Capital Territory, and the
other States and Territories of Australia;

22.4. The Expulsion Motion and Dossier were published in each of The Australian and
The Herald Sun newspapers on 21 March 2023 and 22 March 2023 respectively
on their websites to the world at large, and were downloaded and read by readers
throughout Victoria, the Australian Capital Territory, and the other States and
Territories of Australia, such as:

(a) The Expulsion Motion and Dossier were uploaded by The Australian on its
website at the URL: http://www.theaustralian.com.au/nation/politics/the-case-
against-antitrans-liberal-mp-moira-deeming/news-
story/0d7b62c3756b48d94887367bea0baa70#&gid=null&pid=1
 28

(b) The Expulsion Motion and Dossier were uploaded by The Herald Sun on its
website at the URL: http://www.heraldsun.com.au/news/victoria/pesutto-
facing-uphill-battle-to-dump-deeming/news-
story/1894c75b4c14c9ab4330b8d2156b7883,

where it:

(i) was available online for download to viewers throughout Victoria, the
Australian Capital Territory, and the other States and Territories of
Australia;

(ii) was downloaded and viewed by persons in Victoria, the Australian

Capital Territory, and the other States and Territories of Australia;
and

(iii) is still available online for download.

22.5. The sense and substance of the Expulsion Motion and Dossier were republished,
as intended and/or authorised by Pesutto and/or as the natural and probable
consequence of their publication to and by The Australian and The Herald Sun, in
other mainstream news media, on social media, and elsewhere via the grapevine
effect. The sense and substance of the Expulsion Motion and Dossier was
republished, by way of example, in the following articles:

(a) Article published on 21 March 2023 by The Herald Sun, entitled “Libs vote as
John Pesutto releases dossier on Liberal MP Deeming following anti-trans
rally”, which published the entirety of the Expulsion Motion and Dossier.

(b) Article published on 21 March 2023 by The Guardian, entitled “Bid to expel
Deeming deepens divide in Victorian Liberal party”.

(c) Article published on 21 March 2023 by 9News, entitled “Victorian Liberals to

push forward with a motion to expel MP Deeming”.
 29

(d) Article published on 21 March 2023 by The Age, entitled “Deeming suffers
blow in fight against expulsion from Liberals’ party room” which uploaded the
entire Expulsion Motion and Dossier.

(e) Article published on 22 March 2023 by The Age, entitled “Liberals fight for
Deeming reprieve as anti-trans rights saga splits party”.

(f) Article published on 22 March 2023 by The Australian, entitled “Victorian

Liberal leader John Pesutto’s bid to expel anti-trans MP Deeming splits Libs”.

(g) Article published on 27 March 2023 by The Age, entitled “Deeming expulsion
vote looks set to pass in key test for Pesutto” which uploaded the entire
Expulsion Motion and Dossier.

22.6. Deeming relies on any republication of the sense and substance of the Expulsion
Motion and Dossier as pleaded in paragraph 22.5 above as to damages only in
relation to the extent of publication of the Expulsion Motion and Dossier;

22.7. Further particulars of the publication of the Expulsion Motion and Dossier will be
sought by way of admissions, interrogatories and discovery from Pesutto.

22.8. Further particulars of the extent of publication and republication of the Expulsion
Motion and Dossier may be provided following subpoenas.

23. The Expulsion Motion and Dossier were of and concerning Deeming.

24. The Expulsion Motion and Dossier, in their natural and ordinary meaning, were defamatory
of Deeming and carried the following defamatory imputations (or imputations that do not
differ in substance):

24.1. Deeming had so conducted herself on 18 March 2023 in relation to a public rally
that it warranted her expulsion from the Victorian Parliamentary Liberal Party.
 30

24.2. Deeming had so conducted herself in associating with Neo-Nazi activists on 18

March 2023 that it warranted her expulsion from the Victorian Parliamentary
Liberal Party.

24.3. Deeming conducted activities in a manner likely to bring discredit on the Victorian
Parliament or Parliamentary Liberal Party by organising, promoting and attending
a rally on 18 March 2023.

24.4. Deeming conducted activities in a manner likely to bring discredit on the Victorian
Parliament or Parliamentary Liberal Party by publicly associating with Neo-Nazi
activists on 18 March 2023.

24.5. Deeming organised, promoted and attended a rally on 18 March 2023 where
Kellie-Jay Keen, a known Neo-Nazi, was speaking,

24.6. Deeming met and published a video with known Neo-Nazis on 18 March 2023.

25. The imputations pleaded in the preceding paragraph, or imputations that do not differ in
substance, were carried to listeners or viewers of the Press Conference who also listened
to the 3AW Interview. Deeming repeats the matters pleaded in paragraph 6 above.

26. The publication of the Expulsion Motion and Dossier by Pesutto has caused, or is likely to
cause, serious harm to Deeming’s reputation by reason of the following facts and matters:

26.1. The seriously defamatory nature of the Expulsion Motion and Dossier and the
imputations conveyed to recipients.

26.2. Applying general community standards, the defamatory imputations as conveyed

were likely to lead the ordinary reasonable recipient to think less of Deeming and
to cause a serious, not trivial, degree of harm to her reputation.

26.3. The degree of harm to Deeming’s reputation was self-evidently caused by the
extent of publication and republication of such serious imputations to the world at
large, to persons she knows, to persons she does not know, to persons who knew
her or knew of her, and those who did not know of her beforehand.
 31

26.4. The publication was not restricted or sought to be restricted to a limited audience
but unrestricted to the world at large.

26.5. The publication caused or was likely to cause ordinary reasonable recipients and
the actual recipients to conclude that Deeming’s position with the Parliamentary
Liberal Party was ‘untenable’ and she should be expelled.

26.6. The purported evidentiary nature of the Dossier in support of such a serious Motion
advanced by members of the Liberal Party such that readers were likely and did
consider the contents reliable and accurate.

26.7. Publication to and republication by The Australian and The Herald Sun given:

(a) their broad and extensive circulation and paper and online readership
throughout Australia;

(b) their readership regards them as reliable sources of news; and

(c) as to The Australian, that it is considered amongst its readership as a national

paper of record;

26.8. The Expulsion Motion and Dossier was published as part of an ongoing, relentless
and persistent public campaign against Deeming by Pesutto. Deeming repeats
the facts and matters she pleaded at paragraphs 7.6-7.18 above.

26.9. Deeming will provide further particulars of the serious harm to her reputation in the
course of the proceedings.

Concerns Notices

27. On 11 May 2023, Deeming, through her lawyers, gave a concerns notice (First Concerns
Notice) to Pesutto in accordance with the Defamation Act 2005 (Vic) and its counterparts
in the other States and Territories (Defamation Act) in relation to the Expulsion Motion
and Dossier.
 32

28. On 8 June 2023, Pesutto, through his solicitors, responded to the First Concerns Notice.

29. On 31 May 2023, Deeming’s lawyers gave a second Concerns Notice to Pesutto (Second
Concerns Notice) in relation to the ABC Interview and the Media Release.

30. On 26 June 2023, Pesutto’s lawyers responded to the Second Concerns Notice.

31. On 14 July 2023, Deeming’s lawyers gave a third Concerns Notice to Pesutto (Third
Concerns Notice) in relation to the Press Conference.

32. On 8 August 2023, Pesutto’s lawyers responded to the Third Concerns Notice.

33. Each of the First, Second and Third Concerns Notice was given more than 28 days before
the date of this pleading.

34. On 4 December 2023, Deeming’s lawyers gave a Fourth Concerns Notice to Pesutto
(Fourth Concerns Notice) in relation to the 3AW Interview.

35. Pesutto has not, prior to the filing of this Statement of Claim, made any Offer to make
Amends in relation to the matters in question generally or in relation to the imputations
particularised in the Concerns Notices, and has disputed that the matters in question have
caused or are likely to cause serious harm to Deeming’s reputation.

36. The Fourth Concerns Notice particularises imputations of concern which are the same as,
or do not differ in substance from, the imputations of concern particularised in the previous
Concerns Notices, and it is unlikely Pesutto will make any Offer to make Amends in
response to the Fourth Concerns Notice.

Damages

37. By reason of the publication and republication of the matters complained of, Deeming has
been gravely injured in her reputation personally and professionally, and in her career,
and has suffered and will continue to suffer substantial hurt, distress and embarrassment
and fear for her safety and financial security.
 33

Aggravated damages

38. Deeming claims aggravated damages for the following conduct of Pesutto (and/or the
conduct of those under his direction and leadership), which is known to Deeming, and
which was improper, unjustifiable and lacking in bona fides and has increased the harm
suffered by Deeming so as to warrant an award of aggravated damages:

38.1. Pesutto’s knowledge of the falsity of the imputations conveyed by the matters
complained or, alternatively, his reckless indifference to the truth or falsity of those
imputations.

38.2. The conduct of Pesutto in presenting the matters complained of in an

unnecessarily urgent, excessively distributed and over-sensationalised manner.

38.3. The failure of Pesutto to apologise when called upon to do so by the Concerns
Notices, and otherwise, in circumstances where an apology is self-evidently called
for.

38.4. The response of Pesutto to the Concerns Notices, which sought to ignore or
downplay the obvious and demonstrable consequences of the publication of the
matters complained of.

38.5. The conduct of Pesutto (and those he directs or leads) before publishing the
matters complained of (the Prior Conduct):

(a) Failing to warn or direct Deeming, when he knew in advance of her

involvement, that she should not associate with the speakers or organisers of
the Rally or attend the Rally on 18 March 2023, and/or if she did, that he and
the Leadership Team would consider that she had brought discredit upon the
Parliamentary Liberal Party and herself;

(b) Summoning Deeming to attend a meeting of the Leadership Team of the

Parliamentary Liberal Party on 19 March 2023 alone, without inviting her to
bring a support person or representative, and without notice of the full
agenda;
 34

(c) At this meeting with the Leadership Team on 19 March 2023, ambushing,
attacking and bullying Deeming alleging that she had knowledge of the neo-
Nazis turning up to the Rally and alleging she had knowledge of the support
by Kellie-Jay Keen, Angela Jones and/or Katherine Deves of neo-Nazis, and
that she had celebrated with these women, who he alleged were Nazi
sympathisers, after the Rally, and that she had not condemned the neo-Nazis
and these alleged Nazi sympathisers or disassociated herself from them;

(d) Calling Members of the Parliamentary Liberal Party to say that he was moving
a motion to expel Deeming because she had arranged for the neo-Nazis to
attend the Rally and (on his behalf) that the Leadership Team had the
evidence that she was a closet Nazi.

38.6. The conduct of Pesutto in publishing the matters complained of on 19 and 20

March 2023 (the Media Campaign):

(a) Engaging in a calculated and purposeful media campaign to as wide an

audience as possible, not restricted to Members of the Parliamentary Liberal
Party who were entitled to vote on the Expulsion Motion, and briefing
journalists with the matters complained of and in particular the Expulsion
Motion and Dossier for the purpose of damaging Deeming’s reputation ahead
of the debate by the Members about the Expulsion Motion in the Party Room;

(b) Excluding Deeming’s denials of the imputations from the matters complained
of or failing to include exculpatory material in her favour which showed she
had no association or showed she had no knowledge of association with neo-
Nazis;

(c) Excluding from the matters complained of Deeming’s 18 March Twitter

statement condemning the Nazis at the Rally, Deeming’s answers during the
19 March Meeting, and Deeming’s Facebook Statement on 20 March
responding to the matters complained of published on the evening of 19
March and the morning of 20 March 2023.

38.7. The conduct of Pesutto since publishing the matters complained of (the
Subsequent Conduct):
 35

(a) in combination with the publication of the matters complained of, constituting
a calculated attack campaign against Deeming, which further exposed her to
hatred, contempt and ridicule, and caused further harm to her reputation;

(b) promoting the matters complained of more widely than to Members of the
Parliamentary Liberal Party entitled to vote on the proposed Expulsion motion
and without restriction to members of the public and members of the Liberal
Party;

(c) encouraging members of the public, members of the Liberal Party and
members of the Parliamentary Liberal Party to hate, hold contempt for and
ridicule Deeming and to express that hatred, contempt and ridicule;

(d) repeating statements about the matters complained of and the imputations,
including publishing the matters complained of on social media, to news
media journalists, and to broadcasters;

(e) attributing blame to Deeming for not making ‘concessions’ about her conduct
earlier than the Parliamentary Liberal Party Meeting on 27 March 2023, when
that was blatantly false in respect of when she did in fact condemn the neo-
Nazis who gate crashed the Rally, and blatantly false by him asserting that
she had condemned the speakers and organisers of the Rally and
condemned the Rally itself;

(f) refusing to withdraw the Expulsion Motion on 21 March 2023 or delay it until
at least after the Aston by-election on 1 April 2023, when he was told by
certain Members of the Parliamentary Liberal Party that the Dossier did not
justify Deeming’s expulsion and a motion to delay it would save face for him,
save his leadership, give everybody time to think clearly and find a better way
of handling the issue, rather than smearing a new MP with Nazism and
expelling her. Pesutto refused and continued his campaign to persuade the
other MPs and ordinary members of the Liberal Party and the wider public
that the expulsion was justified and necessary.

(g) Not honouring the agreement with Deeming to a compromise suspension

motion at the meeting of Members on 27 March 2023, by which Deeming was
 36

to be suspended for 9 months with automatic re-entry but with the loss of the
role of Whip; and in exchange, that Pesutto would withdraw the Expulsion
Motion and officially and completely exonerate Deeming from all the
accusations he had made about her, via the issuing a “joint statement”; and
that there would be a “media statement” which would “make it clear that no
one was accusing [Deeming] of being a Nazi, or Nazi sympathiser”.

(h) Attending a media conference immediately following the meeting of the

Parliamentary Liberal Party on 27 March 2023, in which he stated, falsely,
that he withdrew the Expulsion Motion because Deeming had made
“concessions” early that morning and stated falsely that he accepted
Deeming’s suspension (rather than expulsion) given “Moira had provided
what I had been seeking and recognised why it was important to do that”, and
that “the conduct that I wanted condemned has been condemned” that day
when he knew from Deeming’s statements on 20 March, 21 March and 27
March 2023 that she had condemned the neo-Nazis who gate crashed the
Rally and had refused his unreasonable demand that she condemn or
disassociate herself from the three women speakers at and organisers of the
Rally as neo-Nazis or Nazi-supporters.

(i) Not joining with Deeming in making the agreed joint public statement “that no
one was accusing [Deeming] of being a Nazi, or Nazi sympathiser” or
otherwise exonerating her for not condemning the Nazis or being a Nazi
sympathiser or for associating with Nazis or Nazi sympathisers, as agreed.

(j) Repeating the misrepresentations in an interview on the ABC 7.30 Report the
same evening where he said that Deeming had made concessions earlier that
morning condemning the conduct of persons associated with her who
organised the Rally and condemning the conduct of the Rally itself and falsely
represented that Deeming had then walked back those concessions or had
acted inconsistently with assurances she gave Members condemning the
Rally and the organiser of the Rally.

(k) Refusing to provide Deeming with the minutes of the 27 March meeting and
asking the Secretary to alter them which she refused.
 37

(l) Despite a resolution at the meeting of the Parliamentary Liberal Party meeting
on 2 May 2023 that the final version of the 27 March minutes be agreed
between certain Members, submitting his own version to the meeting on 12
May 2023 contrary to the resolution of 2 May 2023.

(m) As Leader and Chairman of the Parliamentary Liberal Party, on 6 May 2023
accepting an unconstitutional notice of motion to expel Deeming which did
not give reasons in support of the motion, in breach of Clause 57 of the
Parliamentary Liberal Party’s Constitution, and despite Deeming having
requested the reasons twice, ignoring the request and permitting the motion
to be put to the vote and passed by Members on 12 May 2023 which expelled
her from membership.

(n) Prior to the vote at the meeting on 12 May 2023, telling Members that
Deeming had sent a Concerns Notice which contained a threat to sue the
Members for defamation but refused to table the document when he knew
that the threat was made only against him.

(o) After the 12 May Meeting, deliberately misrepresenting the reasons for
Deeming’s expulsion claiming, falsely, that it was based on Deeming’s threat
to sue for defamation in a Concerns Notice, when to his knowledge the
Concerns Notice was served on Pesutto on 11 May 2023 and could not
possibly have been the basis for the motion issued on 6 May 2023.

(p) Claiming in November 2023 that Deeming’s suspension and subsequent

expulsion had ‘always’ been because she had not condemned the neo-Nazis
who had spoken at or protested at the Rally and had not disassociated herself
from them, in circumstances where Pesutto knew that those claims were
patently false in that she did condemn the neo-Nazis who gate crashed the
Rally and had no association with them and there were no neo-Nazis who
spoke at the Rally.

38.8. Deeming will provide further particulars of aggravation in the course of these
proceedings.
 38

Injunctive Relief

39. Pesutto has published and republished the matters complained of as set out above in this
pleading.

40. The matters complained of remain available for publication and are being published as at
the date of this pleading.

41. Since publishing the matters complained of, Pesutto has engaged in the Subsequent
Conduct.

42. It is to be inferred from the matter referred to in paragraphs 40 and 41 above that Pesutto
will continue to publish the defamatory imputations (or imputations that do not differ in
substance) carried by the matters complained of unless restrained by the Court.

Date: 5 December 2023

Signed by Patrick George

Lawyer for the Applicant

This pleading was prepared by Patrick George, solicitor, and settled by Sue Chrysanthou SC and
Barry Dean, counsel.
 39

Certificate of lawyer

I, Patrick George, certify to the Court that, in relation to the Statement of Claim filed on behalf of
the Applicant, the factual and legal material available to me at present provides a proper basis
for each allegation in the pleading.

Date: 5 December 2023

Signed by Patrick George

Lawyer for the Applicant
 Schedule A
John PESUTTO HOME ABOUT
MEMBER FOR HAWTHORN
VICTORIAN LIBERAL LEADER

Sunday, 19 March 2023

1 Yesterday afternoon Victorians witnessed an abomination on the steps of the Victorian Parliam ent w h en neo -Nazi
2 protesters engaged in an affront to t h e values we should all hold dear as Victorians.

3 The violence, prejudice and h ate that these p rotesters conveyed by their od iou s actions will never be acceptable in our
4 State. I condemn them and commit to opposing such hate wherever it m ay exist.

5 This afternoon I met w ith Moira Deem ing MP who attended yesterday's ra lly. I d iscussed her involvem ent in organising,
6 promoting and participating in a ral ly with speak ers and other organisers w h o themselves have been publicly associated
7 with far right-w i ng extremist grou ps in cluding neo-Nazi activists.

8 At ou r meeting I i nformed Ms Deeming t h at I will move a m otion at the next party room meeting to expel her as a m ember
9 of the parliam entary Liberal Party as her position is untenable

10 This is not an issue abou t free speech but a m em ber of the parliamentary party associating with people w h ose views are
11 abh orrent to m y values, t h e values of the Liberal Pa rty and the wider community.
12 The Liberal Party I joined and which I am now honoured to lead, must strive to represent all Victorians.
13 Regard less of religious faith , race, sexu al p reference and ident'ty, Victorians everywh ere shou ld know that the Liberal Party
14 is inclusive and can be a voice for them.
15 No m atter what our backg rou nd we all sha re the abiding bond of an essential h umanity.
16 Equ ality of opportunity, t h e benefits to each and all of an enterprising culture, t h e security that comes from the rule of law,
17 t h e strength which stem s from families and commu nities that can live together in search of happiness w hile sha ring in
18 Victoria's p rosperity, must extend to all people who reside in our land.

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2
 Schedule B

·-
IJIIEllAI.
VICTORIA
HOME NEWS OUR TEAM /\BOUT US CONTACT US Donate Join Volunteer

STATEMENT FROM
THE LEADER OF THE
OPPOSITION

Sunday, 19 M arch 2023 SHARE THIS: ~ f

John Pesutto
1 Yest erday afternoo n Vic t orians witnessed an ab ominat ion on the st ep s of the Member for Hawthorn
2 Victorian Parl iam ent w hen n eo-Nazi p ro t esters en gaged in an affront to the Lead er o f the
3 valu es we should all h old dear as Victorians. Opposition
Lead er o f the Li beral
4 Th e violence, p rejud ice and h at e that these p rotest ers conveyed by their od iou s Party
5 act ions w ill n ever b e accept able in our St at e. I condem n them and commit to Shad ow Mi n ist er for
6 opposing such h at e w h erever it m ay exist. Mu lt icult u ral Affai rs

7 Th is afternoon I m et w ith M oi ra Deem ing MP w ho attended yesterday's rally. I

8 discu ssed her involvem ent in organisi ng, promoting and particip ating in a rally
9 with speakers and o t h er orga n isers w h o t h em selves have b een p u b licly
10 associat ed with fa r rig ht-wi ng extrem ist g rou ps in cl ud ing neo-Nazi act ivists.

11 At ou r m eet ing I i nformed M s Deem ing t h at I will m ove a m otion at the n ext
12 party room m eeting t o expel her as a m em ber of t h e parliam ent ary Liberal Part y
13 as h er posit ion is u n t enable.

14 Th is is not an issue abou t free speech but a m em ber of t he p arliam entary party
15 associat ing with peopl e w h ose views are abh orrent to m y values, the va lu es of
16 t h e Liberal Part y and the w id er commu n it y.

17 Th e Li b eral Party I j oin ed and w h ich I am now honoured to lead, must strive t o
18 represent all Vic t orians.

19 Regard less o f religiou s fait h , race, sexu al p reference and id ent'ty, Vict orians
20 everywhere shou ld know that t h e Libe ral Part y is inclu sive and can b e a voice for
21 t h em .

22 No m atter w hat ou r b ackg rou nd we all sh are the ab id ing bond of an essent ial
23 h u m anity.

24 Equ ality of opportu nity, t h e benefits to each and all of an enterprising cult ure,
25 t h e secu rity that com es from the ru le o f law, t he strength which stem s from
1
26 families and com munit ies that can live together in search of happiness while
27 sharing in Victoria's prosperity, must extend to all people w ho reside in our land.

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2
 Schedule C

Transcript of 3AW Interview published on or around 20 March 2022

START: [00:00]

1 N Mitchell: Now as I said, that vote later today for Liberals to expel Moira Deeming
2 from the parliamentary party – she’s only been there five minutes – I’ll talk to the leader
3 John Pesutto in a moment. There are a lot of things that complicate this. I’d argue Moira
4 Deeming was entitled to be there, though I certainly wouldn’t have gone, but did she leave
5 when the Nazi’s turned up? The political optics are bad: a Liberal MP at a hate rally with
6 Nazis, if it’s a hate rally. That’s not entirely fair, I’m not defending Moira Deeming, she
7 stands for a lot of things I don’t like. I think she’s a [00:30] loose cannon for the Libs but
8 they’re going to throw her out. Opposition leader John Pesutto, good morning.

9 J Pesutto: Good morning, Neil.

10 N Mitchell: What did Moira Deeming do wrong?

11 J Pesutto: She’s had associations, Neil, with organisations – organisers of Saturday’s

12 protest to have known links with Nazis, Nazi sympathisers, far right extremists, white
13 supremacists and can I just make a couple of things very clear –

14 N Mitchell: – Just before you do, just before you do, who are you referring to there?
15 Are you –

16 J Pesutto: – Kellie, uh, uh, uh [01:00] Kellie-Jay Keen.

17 N Mitchell: And she’s had associations with, she’s got associations with Nazis? Who?

18 J Pesutto: Well, well people – okay, so um Jean-François Gariépy. She’s done videos
19 with Richard Spencer, Mark Collett, Klu [sic] Klux Klan leader David Duke. There’s a long
20 rap sheet –

21 N Mitchell: – Were they videos or interviews?

22 J Pesutto: Videos, interviews, she’s shared platforms with – this person, can I offer
23 you a different perspective on this person, Neil. This person is not somebody that comes
24 to this with a clean skin, she has known associations with [01:30] uh, I really just want to
25 be able to set a few things straight, Neil.

1
26 N Mitchell: But she does say, she does say she’ll be interviewed – willing to be
27 interviewed by anybody.

28 J Pesutto: Uh no, that, that’s not right.

29 N Mitchell: Okay.

30 J Pesutto: Her history of activism actually has taken her into league with people, with
31 views I cannot accept –

32 N Mitchell: – Okay –

33 J Pesutto: – as consistent with Victorian values. Can I just say a couple of things at
34 the top, Neil?

35 N Mitchell: Yep.

36 J Pesutto: First of all, this is not about free speech I am perfectly comfortable with
37 people debating issues [02:00] they feel passionately about, even Moira. Absolutely
38 people can have that. I’ve always said debate must be reasonable, respectful, inclusive,
39 you can do that even in a robust setting. The problem here is that Moira just didn’t turn up
40 to this rally, she had helped organise and promote it with people who had known
41 associations. It’s not about free speech, it’s about people whose values are not consistent
42 with mine –

43 N Mitchell: – Okay –

44 J Pesutto: – not consistent with the Liberal Party or Victoria’s values in my view.

45 N Mitchell: Well did you tell her not to go?

[02:30]
46 J Pesutto: Uh no, but I don’t expect any member of the Liberal team to be associating
47 with long rap sheets of association with these people –

48 N Mitchell: – But why didn’t you tell her not to go? Why didn’t you say this is wrong,
49 don’t do it?

50 J Pesutto: Well, Neil, I don’t have a problem with people airing their views and the
51 neo-Nazis that turned up to the rally had made it clear that they were there to support this,
52 as we later found out. And we later found out that one of the organisers, Angie Jones, who

2
53 did a video with Moira and [03:00] two other people including Kelly-Jay Keen later on, on
54 Saturday actually posted this Neil, and I quote the tweet: “Nazis and women want to get
55 rid of pedo filth, why don’t you?”

56 N Mitchell: Oh, that’s garbage. That’s garbage.

57 J Pesutto: Is that acceptable in 2023?

58 N Mitchell: No, of course not.

59 J Pesutto: Is that acceptable?

60 N Mitchell: Of course not.

61 J Pesutto: And that’s what it’s about –

62 N Mitchell: – But I get back to the point, why didn’t you avoid all this and just tell her
63 not to be part of it?

64 J Pesutto: Well Neil, I have that expectation of all members –

65 N Mitchell: – But did you know she was – she even raised it in the [03:30] Parliament
66 last week.

67 J Pesutto: I – yeah, I’m aware of these values that she’s had and as I said –

68 N Mitchell: – Yeah, but did – were you aware that she was – were you aware that she
69 was promoting this rally in the Parliament and on Twitter and intending to go? Were you
70 aware of it?

71 J Pesutto: I was aware that she’s active in this space, right? I don’t –

72 N Mitchell: Were you aware she was going to this rally and promoting this rally?

73 J Pesutto: Well, I wasn’t aware that she was going to be going to a rally at which Nazi
74 activists would turn up, at which videos being posted –

75 N Mitchell: – No, no, but that’s not her fault. That’s not –

3
76 J Pesutto: – Well, well she’s [04:00] associated with it and as you say, when the neo-
77 Nazis turned, up did she leave?
78 N Mitchell: Well, actually you could ask Matthew Guy the same thing about certain
79 dinners he’s been to. But it’s a fair point she should have left.

80 J Pesutto: Well, those are different. So –

81 N Mitchell: Did she?

82 J Pesutto: – So, I just want to emphasise this –

83 N Mitchell: – Did she?

84 J Pesutto: Sorry?

85 N Mitchell: Did she leave?

86 J Pesutto: I don’t understand her to have left. I don’t believe she left.

87 N Mitchell: Okay, but I won’t leave this point about she, five or six days ago, was telling
88 the world she was going, she was promoting the rally. Why didn’t you sit her down and say
89 this is wrong, don’t do it or else? Did you know? Did you know she was promoting it and
90 raised it in Parliament?

[04:30]

91 J Pesutto: Neil, I know she’s passionate about these issues.

92 N Mitchell: No, but did you know she raised it in Parliament?

93 J Pesutto: I didn’t know she had raised the rally in Parliament, no.

94 N Mitchell: Were you aware she was tweeting urging people to go?

95 J Pesutto: No, I didn’t see her tweet.

96 N Mitchell: Well, you know you could have avoided it all if you knew that.

97 J Pesutto: Well, but – but, nevertheless Neil, we’re left with a situation actually where
98 you have a member of the Liberal team associating with people with these associations.
99 Know public associations with these – and I just can’t – I can’ let it stand. [05:00] I’m a

4
100 party – I’m the leader of a party that wants to govern all Victorians and the values that I’m
101 espousing as Liberal leader are not consistent with those Nazi activists. I know Moira’s not
102 a Nazi, but my point is that she’s associating with people who are. And that brings them
103 into a place where it’s unacceptable for me as a leader and I believe unacceptable for the
104 party.

105 N Mitchell: Well, a member of the Greens who was Jewish went ahead and didn’t
106 have any problems.

107 J Pesutto: Well that that’s a matter for them. I think in terms of the overall issues
108 about what Nazism means [05:30] and what white supremacy means, it is odious. And I’m
109 not prepared as leader of the party to abide by any of it.

110 N Mitchell: Alright so your saying –

111 J Pesutto: We want to govern in four years.

112 N Mitchell: So, you’re saying Kellie-Jay Keen is a sympathiser with Nazis, correct?

113 J Pesutto: Yes.

114 N Mitchell: And others are there as well?

115 J Pesutto: Well certainly her, Angie Jones with whom Moira posted on social media
116 about, after the rally on Friday, posted about what I said before, I won’t repeat it. So, it’s
117 not as [06:00] if any of this is in doubt it’s on the public record. They’re not Moira’s posts,
118 granted, but we’ve got a Liberal member having done that and I just don’t think that’s
119 acceptable.

120 N Mitchell: Did she object to what you told her?

121 J Pesutto: Oh, look I won’t go into the details of the discussion. You can imagine how
122 someone would react to the news that I’m going to bring this application but I believe it’s
123 the right thing to do, Neil, right? We’ve got a government in Victoria which is corrupt,
124 incompetent, and clearly exhausted. I want to be able to present an alternative.

[06:30]

125 And as alternative Premier I want to make it clear to Victorians that my values, the values
126 of the party I lead are not consistent with Kellie-Jay Keen, never will be. Not consistent
127 with Thomas Sewell or the Nazis who turned up on the steps of Parliament, never will be.

5
128 I will fight hate speech like that wherever I see it. And the party wants to govern in 2026
129 and beyond because our state needs it.

130 N Mitchell: Did you –

131 J Pesutto: – This is not going to help us get to that goal.

132 N Mitchell: Do you, you know, do you accept that the organisers of this rally and Moira
133 Deeming had no idea the Nazis were turning up?

[07:00]

134 J Pesutto: I’m not in a position to say that I can accept that because – and the reason
135 I say that is because I’m not saying Moira necessarily knew, is that these people have
136 known associations with Nazi sympathisers and white supremacists given their history and
137 Thomas Sewell posted on social media that they were there to support that rally. So, my
138 point is, I’m not saying Moira necessarily knew that, but I find it hard to believe that the
139 other organisers didn’t.

140 N Mitchell: Okay. Um It says something about your preselection processes doesn’t if
141 Moira Deeming [07:30] got preselection?

142 J Pesutto: Look Neil, as talented as I like to think that I am I can’t change the past, I
143 can only assure all of our listeners of a couple of things. I do support free speech but I
144 believe this – this position that I am taking is consistent with that. I can’t support, and never
145 will, hate speech. As to preselection processes, I am committed to making sure the party
146 has better processes in place going forward. But again, free speech is an important part of
147 what the Liberal party advocates. But hate speech is not and never will be.

[08:00]

148 N Mitchell: Under your leadership would you hope to avoid the uh preselection of a
149 Moira Deeming?

150 J Pesutto: Well, again I just want to indicate, people are entitled to have a broad
151 range of views across any political organisation, that is going to happen. I don’t have any
152 objection to that at all. I have an objection and will act where anybody’s activities take them
153 to an association with either right-wing extremists or left-wing extremists. Either way, it’s
154 not what Victoria is about –

155 N Mitchell: – Okay –

156 J Pesutto: – and it’s not the Victoria that I want to lead.

6
 [08:30]

157 N Mitchell: Do you want her out of the party?

158 J Pesutto: Uh I think it’s consistent with the position I’m taking that the party will need
159 to consider what it does if the motion gets up. I expect it will, but the party and its members
160 will need to make a decision about that. Look, I really need to be careful of the processes
161 as they are for the members of parties to decide.

162 N Mitchell: Are you –

163 J Pesutto: – I think they’ll see – they’ll see obvious conclusions uh if the motion
164 succeeds.

165 N Mitchell: When’s the parliamentary party meeting?

166 J Pesutto: I have to give a period of notice so I would expect that that would be very
167 early next week.

[09:00]

168 N Mitchell: Look a bit silly if you don’t win it, won’t it?

169 J Pesutto: Well, I can only do what is right, Neil.

170 N Mitchell: Okay.

171 J Pesutto: I think this is the right thing to do.

172 N Mitchell: Just quickly, the other thing, the Nazi salute, ban it or not?

173 J Pesutto: I’m certainly open to it. I do understand the free speech arguments which
174 are compelling and which I normally advocate myself and would, but I also have always
175 understood that there needs to be reasonable limitations on free speech. And anything,
176 whether it’s a salute or symbol [09:30] that has the potential to incite violence and, you
177 know, injury I think then engages a serious question – I’m very open to it and will work
178 constructive with the government I think most sensible decent people are on the same
179 page here.

180 N Mitchell: But that’s interesting, you’re open to it, do you want it or not?

181 J Pesutto: I do.

7
 182 N Mitchell: Good.

183 J Pesutto: But I’m conscious that there’ll need to be – there’ll need to be a discussion,
184 you know the normal careful drafting processes, to get that balance right. But I do think the
185 potential and what we saw, I mean you talked about it at the top, [10:00] about you know
186 what those salutes mean and what they have the potential to incite is a very serious thing
187 and I believe it’s justified as a limitation on free speech.

188 N Mitchell: Do you want to ban the hammer and sickle too? The hammer and sickle’s
189 killed a few million people over the years.

190 J Pesutto: Well – well true and I think this discussion always has to be a mature
191 discussion about does it have the potential to insight or cause such disorder in our
192 community that the public interest must prevail to the point of placing reasonable limitations
193 so that’s [10:30] always the question. It’s not the same to every issue. Some issues might
194 be offensive without being inciteful and so that for me is the crux of the question you have
195 to answer.

196 N Mitchell: Okay, by the way, Angie Jones we’ve spoken to she says that tweet you
197 referred to is right out of context and she had a history with the person tweeting it.

198 J Pesutto: Hmm do you – do buy that?

199 N Mitchell: I don’t know, I’ll have a speak, have a speak to her.

200 J Pesutto: You know, please do but I can’t interpret it any other way.

201 N Mitchell: Thank you very much for your time.

[11:00]

202 J Pesutto: Pleasure now.

203 N Mitchell: John Pesutto, state opposition leader.

END: [11:02]

8
08 STATE POLITICS heraldsun.com.au
Schedule D

State to
outlaw
Nazi Neo-Nazis deliver their

salute
offensive salute at
Saturday’s anti-trans Let
Women Speak rally on
the steps of state
parliament; (below)
British activist Kellie-Jay
Keen about to speak
MITCH CLARKE government. “We need to take alongside Liberal MP
this very seriously,” he said. Moira Deeming (left);
THE Nazi salute will be Anti-Defamation Commis- and (inset) a “post event
banned in Victoria as a result sion chairman Dvir Abramov- chat” between (from
of neo-Nazis storming the ich said the proposed law was a left) Moira Deeming,
steps of state parliament over good step towards curbing the Kellie-Jay Keen,
the weekend to perform the “disease of extremism”. Katherine Deves and
offensive gesture. “The passing of this law will Angie Jones.
Jewish organisations have be a resounding triumph for
welcomed the move, but justice and a thunderous blow
warned a “broader approach” to the solar plexus of an angry
is needed to combat threats neo-Nazi movement that will
from the far right movement. now realise that the law is no
Attorney-General Jaclyn longer on its side,” he said.
Symes revealed the Andrews “Performing the Hitler sal-
government would fast-track ute is a call for murder, and for
plans to outlaw the public dis- a Holocaust survivor, seeing it
play of the salute. tears a hole in their heart and is
On Saturday, a large group as threatening as being held up
of masked men in black cloth- with a gun.”
ing gatecrashed an anti-trans- Australian Centre for Jew-
gender rally where they ish Civilisation director David
performed the gesture, which Slucki said a “broader ap-
was used in Nazi Germany to proach” was required to com-
signal obedience to and sup- bat the rise of the far right.
port for Adolf Hitler. “Banning the Nazi salute will
Last year, Victoria became help to reduce the presence of
the first Australian jurisdiction Nazi symbolism in public pla-
to outlaw the Nazi swastika. ces, but it will do little to erad-
Ms Symes said the Andrews icate Nazism, which thrives in
government would expand online spaces,” he said.
that legislation to include the “These Nazis will continue
Nazi salute because “everyone to target vulnerable groups and
deserves to feel safe, welcome it is incumbent on political and
and included in Victoria”. community leaders not to use
“The behaviour we saw on those groups as political
the weekend was disgraceful pawns, which only empowers
and cowardly,” she said. them.”
“It’s clear this symbol is Jewish Community Council
being used to incite hatred not of Victoria president Daniel
just towards Jewish people but Aghion welcomed the move to
our LGBTIQ community and ban the salute but also called
other minority groups. for a “broader discussion about
“Victorians have zero toler- vilification of all minorities”.
ance of this behaviour and so “It should not be lost in the
do we. debate that, on this occasion,
“We’ll look at how this can the proximate target of this
be done carefully, with consid- hateful conduct was transgen-
ered consultation with a var- der people and not Jews,” he
iety of groups, and will have said.
more to say on the details of [email protected]
this legislation as we undertake
that.”
The laws are likely to pass FOR THE
parliament, with Opposition
Leader John Pesutto declaring
LATEST NEWS
HERALDSUN.COM.AU
he is open to working with the

Moira Deeming is looking like Bernie Finn 2.0, and it could also
OPINION Liberal HQ when the week should have been on Oversight Committee. Mr alleged corruption within our from the broader party.
SHANNON DEERY statement announcing moves prosecuting government Redlich has explicitly accused governing bodies”. That leaves Whatever you think of her
to expel Deeming was issued corruption. On Wednesday, the government of launching just two more votes. It views, Deeming enjoys a vast
WILL they ever learn? at 8.42pm on Sunday. the upper house will vote to revenge attacks on IBAC in shouldn’t be hard. amount of grassroots support.
The Victorian Liberals Until then there had been establish a select committee to retaliation for a series of It will be the first major test Booting her from the party
should have spent this week much discussion and media investigate concerns of investigations into its dealings. of the new upper house that won’t eradicate that support,
challenging the Andrews coverage of Saturday’s Let government corruption raised The opposition needs seven has lost government-friendly or the views of those inclined
government on a range of Women Speak rally that was by former IBAC chief Robert votes to get the motion over MPs in Fiona Patten and Andy to offer that support. This is a
corruption issues. gatecrashed by a group of neo- Redlich. the line. It is confident it has Meddick. broader Liberal brand issue
Instead, they will spend it Nazis. Almost none of it Under the proposal, the support of the four Greens, Pesutto’s problem is that that Pesutto is taking on.
talking about Moira Deeming mentioned Deeming. But this witnesses would be called in meaning there are just three even if Deeming is booted Having won the party
and themselves. is a party that has made an art an attempt to prove claims of more needed. One Nation’s from the parliamentary wing leadership by a single vote in
Who knows what was going form of focusing on itself. government interference in Ricki-Lee Tyrrell has said she of the party, sources say December, he has now set a
through the minds of those in The party’s attention this the parliament’s Integrity and will support “any inquiry into there’s no appetite to expel her huge test of his own

1 MHSE01Z01MA - V1
TUESDAY, MARCH 21, 2023 heraldsun.com.au STATE POLITICS 09

Risky bid
to expel
sitting MP
NOT TAKING A BACK SEAT Opposition leadership on the line
SHANNON DEERY
MITCH CLARKE
OPPOSITION Leader
John Pesutto could face
calls to resign himself if he
loses a bid to expel contro-
versial MP Moira Deeming
from the Liberal partyroom.
In his boldest move since
taking over the leadership in
December, Mr Pesutto will
bring on a vote to have Ms
Deeming expelled from the
party room after she attend-
ed a rally on the steps of par-
liament on Saturday that was Opposition Leader John Pesutto during Question Time.
crashed by neo-Nazis.
Mr Pesutto said the deci- party, with some sources confi- ers did not realise who they
sion to expel her had nothing dent the motion to expel Ms were until they were being
to do with the transgender de- Deeming could be defeated in escorted out by Victoria Police
bate, but concerned her as- a move that would be a huge when they did the despicable
sociation with extremists. blow to Mr Pesutto’s authority. Nazi salute.
He said he could not accept Some party figures backing “I completely reject the
that Ms Deeming did not the move also fear it may not beliefs of National Socialists
know the organisers of the Let have enough support. “It’s (Nazis) and I have seen first-
Women Speak event had links close, but there are unexpected hand the impact that the Holo-
with neo-Nazis and white opposers,” one source said. caust had on a family member.
supremacists. Several party sources said if “None of those organising
conservative views on “I just can’t satisfy that the motion was defeated, Mr the event had any involvement
Moira Kellie-Jay transgender people. Ms Moira didn’t know,” he said. Pesutto’s position would be with these men.”
Deeming Keen-Minshull Deves has previously “It wasn’t just that Moira untenable. The move to expel Ms
described trans teenagers as had escorted organisers It is understood Liberal Deeming cannot be put to the
The anti-abortion aka Posie Parker “surgically mutilated”. through the precinct of parlia- Party members spent Monday partyroom before Friday,
crusader replaced
controversial MP Bernie Prominent British anti- ment. It wasn’t just that Moira lobbying Mr Pesutto to aban- because five days’ notice must
Finn in the upper house seat transgender activist who Angie Jones stayed at the protest when don the move. be given.
of the Western founded the organisation Nazis turned up. It was the cel- However, others threw their It is expected the vote could
Self-proclaimed women’s
Metropolitan Region at last Standing for Women. Ms ebration that you can see on full support behind the leader, be held early next week.
rights activist. Organiser of
year’s election after he was Parker has appeared in a social media afterwards, which saying it was a clear sign he Mr Pesutto said he was con-
the Let Women Speak rally
expelled from the party. The video with French Canadian tells you perhaps all you need was serious about reforming fident he would have the sup-
on March 18. Ms Jones
former Melton City white nationalist Jean- to know about why it’s necess- the party. port of his party room, but
recently posted on Twitter
councillor and teacher was François Gariépy, who has ary to bring this motion. A dossier of evidence has added that “every day is a test
that “Nazis and women
at the centre of another previously had former Ku “It’s saying that ‘I am pre- been compiled by party of leadership”.
want to get rid of paedo
controversy after explosive Klux Klan leader David Duke pared to associate with those officials. “I would consider it a great
filth. Why don’t you?” in
emails she sent between appear on his YouTube people and not take the oppor- “I don’t think the opposers failure of leadership if I didn’t
response to a social media
2020 and 2022 were channel. It’s understood tunity to walk away from them have understood the severity take this action,” he said.
user who suggested that
released under Freedom of Parker claimed she didn’t despite the odious things they of this,” one source said. “It will be for the partyroom
neo-Nazis attended the
Information. In them, she know they were members have shared’. Ms Deeming has vowed to alone, and each member of the
rally because they agreed
expressed a fervent of the far-right movement. “Any question of an associ- fight the move. partyroom, to make a decision.
with anti-transgender
opposition to the LGQBTQ+ activists. Ms Jones later ation, even indirectly, to Nazis, “I condemn of the actions of “I’m confident it will pass
community, in particular the Katherine Deves said her tweet had been white supremacists, ethno-fas- the masked men in black who but I’m also respectful of the
transgender rights Failed federal Liberal taken out of context and cists or whatever else, is so odi- were later identified as neo- fact that they will decide the
movement. candidate who has that she did not support ous in 2023, as it should be, that Nazis, who gatecrashed the Let answer to that.”
harboured ultra Nazis. I can’t see a way back.” Women Speak event,” she said. [email protected]
But the move has split the “Most of the LWS support- MARK KNIGHT, PAGE 21

be John Pesutto’s make-or-break moment

leadership. Just a month ago flitting nonchalantly between ranks to call for a winding can’t do that by saying it, you
Pesutto was throwing his controversies. back of abortion laws last May, need to live it.
support behind Deeming. Both former leaders – Guy bit the bullet. After giving More moderate Liberals
The party knew what it was Matthew Guy and Michael Finn an ultimatum to fall into firmly believe Pesutto had no
getting with Deeming, O’Brien – had been eager on line or leave the party, Guy choice but to act in an attempt
complete with ultra- more than one occasion to ultimately backed a push to to appeal to mainstream
conservative views on topics boot him from the party. expel him from the party. Victorians who oppose
such as abortion and trans But they knew it came with Pesutto has bitten the bullet Deeming’s views.
rights. Some Liberals dubbed grave political risk. The last early, keen to avoid a Bernie It could hurt him. It might
her “Bernie without a penis” – thing any leader wants to do is 2.0 situation. It’s also clear he’s even kill him. But Pesutto has
a crude reference to the man to take a stance and then be keen to send a strong message picked the hill he’s willing to
she replaced in the upper seen to be weak when they he’s reforming the Liberal die on.
house. Finn was a thorn in the can’t follow through. Party, and able to make the SHANNON DEERY IS STATE POLITICS
side of the Liberals for years, When Finn broke party tough decisions to do it. You EDITOR Bernie Finn caused headaches for former leader Matt Guy.

2
V1 - MHSE01Z01MA
 Schedule E

Transcript of the ABC Interview published on or around 20 March 2023

START: [00:00]

1 J Pesutto: It was very concerning, Michael, and the reason I’ve taken this step is
2 because I believe it’s important as Victoria’s alternative Premier to set out the values I
3 stand for and the values my party stands for. The reason I’m bringing this motion, which
4 will go to the party room hopefully next week, is because Moira Deeming not only attended
5 the protest on the steps of parliament but was actively involved in different ways in the
6 organisation and promotion of this protest at which there were speakers who have [00:30]
7 known links with neo-Nazis and white-supremacists, and I won't have any of it. My party
8 wants to govern because we live in a state where the government is corrupt, incompetent
9 and tired and Victorians will need a new government and I want a government that uh –
10 provide a government that will focus on the needs of Victorians, and these values that we
11 saw displayed on the steps of parliament are not consistent with the values I and the Liberal
12 Party stand for.

13 M Rowland: How confident are you you’ll get the support on Friday within your party
14 room to kick Moira Deeming [01:00] out?

15 J Pesutto: Well, I’m not sure it will go there on Friday. We need to observe some
16 notice provisions in the Constitution of the Parliamentary Party, but I am confident because
17 I believe in the Liberal Party, I’ve been a member of the Liberal Party for 30 years, the
18 values that I possess and the values that the party stands for like free enterprise, free
19 speech, uh the rule of law, uh support for communities and families, are all rights we stand
20 for, but we don’t stand with [01:30] neo-Nazis, we don’t stand with white- supremacists.
21 And I want to make that clear to all of our viewers that the team I lead will be focused on
22 them and Victorians more generally.

23 M Rowland: Would you like to see Moira Deeming kicked out from the broader Liberal
24 Party as well as the Parliamentary wing?

25 J Pesutto: Well, I’m going to focus, Michael, on the vote of the Parliamentary Party
26 uh next week. There will be then a discussion presumably in the broader party. That’s not
27 for me to determine, [02:00] because – I am one member of the –

28 M Rowland: – But you are the leader though, John Pesutto. You are the leader of the
29 Victorian Liberal Party –

30 J Pesutto: – Yeah. Yeah, and –

1
31 M Rowland: – do you have a view on whether this woman whose views you hold – you
32 find abhorrent, or her appearance at the rally yesterday abhorrent, kicked out from the
33 Liberal Party you lead?

34 J Pesutto: Uh, Michael, I think all of our viewers are very reasonable and sensible
35 and they will understand that by me moving this motion for the reasons I have outlined,
36 that there are certain unmistakable presumptions that they can draw about what I want
37 [02:30] to happen in the broader party. The party I lead is a party that’s there for all
38 Victorians, we are inclusive, we want to engage with everybody, and I promise everybody
39 watching that the party I lead can be a voice for all of you, for all Victorians. And what I'm
40 doing is a statement that we will not tolerate or ever accept any association with neo-Nazis
41 and white-supremacists or anybody who sympathises with them.

[03:00]

42 M Rowland: Didn’t the Liberal Party pretty much know, John Pesutto, what it was
43 getting when Moira Deeming was pre-selected? She holds some pretty, as you’d well
44 know, out-there views. She is against not just vaccine mandates, she’s against Covid
45 vaccines full stop. So, wasn’t there – shouldn’t it have been a bit – a bit of a case “of buyer
46 beware” for the Liberal Party before they pre-selected Moira Deeming in the first place?

47 J Pesutto: Well, look Michael, can I make a broader point, that I think it is important
48 for me to emphasise? I support free speech and [03:30] there are people who have
49 different views, and what I’ve always said, on the ABC and everywhere else for that matter,
50 is that debates should always be civil, uh courteous, robust, sure, but the debates must be
51 respectful. Now, the reason I’m taking this step is because Nazis and white-supremacists
52 don’t make debates respectful and civil, that’s the first thing I would say. The other thing I
53 would say, Michael, is that whilst I’d like to think I am a man of enormous talent I can’t
54 change the past. [04:00] And I’m dealing with things fourteen weeks into my leadership to
55 show Victorians that every step that I have taken since becoming leader in December, that
56 I am determined to be the best possible alternative government that Victorians are crying
57 out for. And that’s why I am taking this step.

58 M Rowland: And finally, John Pesutto, calls now for the Victorian Government to move
59 to ban, outlaw, the Nazi salute. Would the Liberal Party support that if it were to happen?

60 J Pesutto: Yeah, we're very open to this. We'll work with the government very
61 constructively, as we have in the past, as with the banning [04:30] of the swastika. We’ll
62 continue to work constructively. I want to make it clear we support free speech but every
63 sensible and reasonable person will know, that there have to be some limits on free

2
 64 speech. And people who engage in actions and gestures which incite hate and violence
65 will never be acceptable in our state.

END: [04:52]

3
 Schedule F

Transcript of the Press Conference on or around 20 March 2023

START: [00:00]

1 J Pesutto: We all good to go?

2 Unknown: Yeah.

3 J Pesutto: Alright. Uh you’ve seen my statement from last night uh, regarding Moira
4 Deeming. I have not taken this decision lightly but the events which were drawn to my
5 attention over the weekend when not far from where we stand there was a protest which
6 attracted Nazis on the steps of this magnificent Parliament. It will never be acceptable in
7 Victoria for Nazis to get a platform [00:30] or anyone who shares their views or anyone
8 who works with them to help them promote their odious agenda. This House stands for the
9 people and the values I possess and the values that my party supports and advocates will
10 always be to include all Victorians, no matter what their background, that’s why I’ve taken
11 this action today. What came to light on the weekend when seeing the awful circumstances
12 on the steps of this Parliament [01:00] were that Moira Deeming, a member of the
13 Parliamentary Liberal Party, had actively participated with and worked with the organisers
14 of the rally. That rally was organised by people who have known and established links with
15 people who have Nazi sympathies, promote white supremacist views and ethno-fascist
16 views. That is odious. It is unacceptable.

[01:30]

17 I will never, ever accept any member of the Parliamentary Liberal Party under my
18 leadership ever associating with anybody who shares a platform with people who peddle
19 hate, division and attack people for who they are. As leader of the Victorian Liberal Party,
20 as the alternative premier of Victoria, as somebody who leads a team, who wants to be an
21 effective opposition focused on the priorities of the Victorian people and somebody who
22 wants to lead [02:00] a government from 2026, I want to assure all Victorians that the party
23 that I lead along with my colleagues, David Southwick, Georgie Crozier, and Matt Bach,
24 and all of our other colleagues that we are totally committed to leading an inclusive Liberal
25 Party in Victoria that is there for all people, no matter what your background. The Liberal
26 Party I lead will always be a voice for you. I understand the significance of this matter and
27 I want to assure all Victorians [02:30] I am a strong supporter of free speech, but free
28 speech doesn’t include hate speech. And the Nazis who turned up on Saturday and who
29 said they had turned up to support the rally, peddle hate and I will never accept that. As
30 leader I will be moving the motion uh to expel Moira Deeming from the Parliamentary
31 Liberal Party. The processes of that are dealt in the Parliamentary Party’s constitution
32 [03:00] and they will take place over the coming days, so they will be observed, and the
33 party room will make a decision, but this is a necessary step, I believe, to making sure that

1
34 we are not only an effective opposition but ready to govern in a way that Victorians will
35 embrace wholeheartedly in 2026. Uh I‘ll take some questions.

36 Question: Why haven’t you done this earlier? Moira Deeming had expressed her
37 views against the trans community well before the weekend.

38 J Pesutto: I’ve taken this step now [03:30] because the events of the weekend
39 showed uh upon further investigation that the association between Moira Deeming and the
40 organisers of the rally were that those organisers have shared platforms with fascists,
41 ethno-nationalists, white supremacists and Nazis and it became clear to me on further
42 investigation following the rally and the ugly scenes that were seen on the streets of this
43 Parliament, but just before it, on the steps of this Parliament were totally unacceptable
44 [04:00] and that’s why I’ve taken this action now.

45 Question: [inaudible] So, can we just clarity, would’ve – if she attended the event but
46 the Nazis sympathizers didn’t come, sorry about my voice, um would’ve that been
47 acceptable? Was it the fact that she went and then came? If she had have [sic] left at that
48 point – like, when did it cross the line exactly?

49 J Pesutto: Okay, so let me – let me go through a few of the facts here. Uh, it’s clear
50 that Ms Deeming, from social media, escorted uh, at least one of the organisers through
51 this very Parliament, Kellie-Jay Keen uh through this Parliament.

[04:30]

52 Then attended the rally, stayed at the rally when Nazis attended and then celebrated with
53 organisers of the rally, after the rally and ugly scenes had occurred on the steps of this
54 Parliament and the street before it. One of the people with whom Ms Deeming was
55 celebrating is Angie Jones and she tweeted on Saturday night, after the ugly scenes that
56 we saw on the steps of this Parliament, as follows, quote [05:00] ‘Nazis and women want
57 to get rid of pedos, why don’t you?’ That is totally unacceptable and I don’t think any
58 reasonable, decent minded person would think that that is okay. That is all material on
59 social media, it’s publicly available. I should say this, free speech in a brilliant democracy,
60 like Victoria’s, must be able to accommodate different views. I strongly believe, and have
61 always said, [05:30] that debate in our society must be civil, it must be respectful, it must
62 be inclusive but never hateful, never speech that vilifies other people for who they are. And,
63 that is possible in a democracy like ours. So, I’m not here to say that people can’t have
64 different views, I’m here to say it will never be acceptable in this state, Victoria, as a
65 member of the Liberal Party [06:00] to associate with anybody who is connected with or
66 shares platforms with Nazis, white supremacist, ethno-nationalists or whatever other
67 odious agenda someone wishes to peddle.

2
68 Question: So, just to be clear, is it her actions after the um gentleman that did the
69 Nazi salute on the steps, is it Moira Deeming’s actions after that that have prompted your
70 actions to try and expel?

71 J Pesutto: Um, thanks Simon.

[06:30]

72 It’s more than that. What Moira Deeming’s actions both before, during and after the rally
73 demonstrate is that she’s had an association, upon further investigation it’s clear, Moira
74 Deeming has had an association with people who organised the rally, along with her
75 assistance, who have shared platforms with and viewpoints with people who promote Nazi
76 views or sympathies. That’s the first thing. Secondly, Ms Deeming stayed at the rally
77 [07:00] when the Nazis arrived. Thirdly, having seen the ugly scenes and having had an
78 opportunity to disown and disassociate from those very people, Ms Deeming chose to
79 celebrate as evidenced on social media. Now, as the leader, a responsible leader, of a
80 major political party that wants to govern for all Victorians from 2026 and in the meantime
81 be an effective, mature, responsible opposition [07:30] that can’t and is not acceptable.
82 We are a party for all Victorians and when I talk about opportunity, I want opportunity for
83 all Victorians no matter what your background, no matter what your preferences or
84 orientation. We all share an underlying humanity and in that alone our commitment as a
85 major political party that wants to govern and govern well and responsibly for Victorians
86 must be that we are there for everyone.

[08:00]

87 Question: What responsibility does –

88 [inaudible questions]
89 – the Liberal Party take for preselecting Moira Deeming, even after someone such as
90 Bernie Finn was booted out in the same fashion you’re trying to boot her out now?

91 J Pesutto: As talented as I would like to think I am, I can’t change the past. I can only
92 say that along with my colleagues, David, Georgie and Matt, we are new leadership team.
93 We’ve been in our position for around about fourteen weeks and we’re making changes to
94 demonstrate to all Victorians that we will lead a – an effective [08:30] and responsible
95 opposition and we want to be able to present in 2026 as the alternative government and
96 to win government. To govern well for Victoria. That’s what we want to do.

97 Question: [inaudible – journalists speaking over each other]

98 But were you not aware –

3
99 J Pesutto: – Uh, one at a – sorry – I – I’ll get to all of your questions.

100 Question: Is what’s you’re saying though, just so I can get it straight, is that it’s okay
101 for a member of the Liberal Party to be anti-trans as long as they express that view in a
102 civilised way um that’s not hate speech?

103 J Pesutto: We have to be careful to make sure that in our [09:00] advanced
104 democracy there is the capacity for people to disagree. That is going to happen. There are
105 debates in this Parliament, in all major political parties, on these issues and what I urge,
106 as one of our state’s political leaders, is that all of us, all Victorians, owe it to ourselves and
107 particularly to each other to be respectful in the way we conduct debates. Now, what has
108 promoted my action over night is that a member of the Parliamentary Party of the Liberal
109 Party was working [09:30] with people who have shared platforms and promoted people
110 who have Nazi views and white supremacist views. So, my point, Chanelle, is that in our
111 democracy we have to accommodate different views. People are going to have different
112 viewpoints. We have to respect that part of our democracy even though sometimes we
113 may not like the views that other people have but we have to be respectful and that’s just
114 not [sic] lip service to being civil and respectful, it conditions the debate, [10:00] so that we
115 avoid incitement, we avoid actions that cause harm to other people. If we are true to that,
116 faithful to the idea that we can live in a democracy where we respect each other, then we
117 will find those debates won’t veer off so that Nazis can come and participate in protests
118 like we saw on Saturday.

119 Question: So, were you not aware of the event, because she sent flyers to a number
120 of MPs, she sent a flyer to me uh over a week ago and [10:30] if you didn’t know, I guess,
121 is that something your disappointed that even other Liberal MPs or staff didn’t tell you?
122 Because you seem to say that it’s not just her attendance, it that she also helped organise
123 it. So, you know, she’s been organising this for a long time now, and at what point were
124 you made aware and why didn’t you know?

125 J Pesutto: Well, the events on Saturday drew my attention to the seriousness of the
126 issue but let me say this, every person who is elected to the Victorian Parliament has to
127 take responsibility for their actions. I’m not there and nor is Daniel Andrews [11:00] for his
128 members or Samantha Ratnam for her members. We’re not there to babysit the activities
129 for every MP. I have a lot of responsibilities with David, Georgie and Matt as the leadership
130 team of the Liberal Party. I can’t babysit every MP. Every MP has a responsibility, not just
131 to this Parliament but to the people they represent to – to conduct themselves in a way
132 with which respects our democracy and doesn’t provide an opening for Nazis or whomever
133 else [11:30] who peddles odious and hateful views to jump into activities whether they’re

4
134 protests or public meetings each member of Parliament must take responsibility for their
135 actions.

136 Question: Who else was there, from the Liberal Party?

137 J Pesutto: On the advice I have, I – I understand Moira Deeming was the only person
138 who participated in the rally, I’m not aware of any other MP who was there, from the Liberal
139 Party, but that’s the advice I have at the moment.

140 Question: Moira Deeming says in the video posted after that there [12:00] were other
141 members of the Liberal Party there, they didn’t join her on the steps but that they were
142 there in the crowd have you actively spoken to your entire party to make sure no one else
143 was there?

144 J Pesutto: Look, I will continue to look into the matter but my main concern and what
145 has prompted my action over night to submit this motion to the party room is that it’s clear
146 on the evidence we’ve been able to gather overnight that Moira Deeming has worked with
147 these organisers and that these organisers, [12:30] not talking about Moira, but these
148 organisers have shared platforms, done videos with, worked with people who have Nazis
149 views, white supremacist views, totally unacceptable in our state.

150 Question: Are you comfortable the motion will pass? Um, and is it a test of your
151 leadership? You only won that by one vote um, there is one person that’s now leaving the
152 party, potentially. Um, you know, do you see it in that sort of context?

153 J Pesutto: I’m confident that I’ll have the support of the party room but you’re all
154 seasoned journalists, [13:00] every day is a test of leadership and I would consider it a
155 great failure of leadership if I didn’t take this action. I’m taking this action because it’s
156 necessary, it’s right, it will tell Victorians that as new Liberal leader along with David,
157 Georgie and Matt we are committed to providing Victorians with an alternative vison and a
158 party that is ready to govern in 2026.

159 Question: There’re MPs that are quite miffed by this action and haven’t heard from
160 you at all [13:30] – much at all in that the last 12 hours, and frustrated that you’re
161 prosecuting this through the media before speaking with them, what is your message to
162 them, especially trying to get them on s – on your side to vote for this motion?

163 J Pesutto: Well, between my leadership colleagues and I we have contracted every
164 member of the Parliamentary Party. I spoke to many as I could uh overnight. Time didn’t

5
165 permit me to reach everybody in the party room but that’s why we shared that responsibility
166 between us as members of the leadership team.

[14:00]

167 Can I say this? I have been speaking to the Victorian people through media this morning
168 because I think the Victorian people need to know why I have put this motion forward. It
169 will be for the party room and the party room alone, each member of that party room, to
170 make a decision next week on this matter. It won’t be my decision. I’m putting the proposal
171 to the party room and I respect the fact that it will be every member of that party room
172 voting as a group to decide [14:30] the outcome on that motion. I’m confident it will pass
173 but I’m also respectful of the fact that they will decide the answer to that. But, I hope you’ll
174 all understand as members of the media, it’s important for me to explain to the Victorian
175 people why I’m taking this action. I do respect that the party room itself will make the
176 decision.

177 Question: What if –

178 – If it doesn’t pass?

179 Yeah.

180 Yeah, if it doesn’t pass what happens?

181 J Pesutto: I think, you all know me, I have a tendency to bounce back from anything
182 but that’s not a scenario [15:00] I’m particularly worried about. I’m confident the motion will
183 pass. Politics carries with it great responsibilities and those responsibilities often involve
184 tough decisions, but this is the right decision. It’s a necessary decision and it will tell
185 Victorians that we are serious about being a viable opposition and serious about forming
186 government in 2026.

187 Question: Is it a simple majority that the motion needs to pass? And if it does just
188 pass by one vote um, is it something, you know, do you think that’s the [15:30]
189 endorsement of your party room that they agree? What is the benchmark do you think you
190 need?

191 J Pesutto: Oh, come on Annika. I won the leadership by one vote.

192 Question: [unintelligible]

6
193 J Pesutto: Uh, I’m not concerned about uh, the majority, I’m just concerned about the
194 uh, process being respected and every member of the party room having an opportunity
195 to consider my reasons, to hear in response from Moira, who obviously will have a chance
196 to put her side of the argument to the party room as well. They’ll decide it.

[16:00]

197 Um, and if a majority emerges, as I’m confident it will, we’ll move forward to achieve the
198 things I’ve outlined before: providing a viable opposition, forming government in 2026.

199 Question: Is this a big distraction for you in this parliamentary sitting?

200 J Pesutto: This will not be a distraction at all for my colleagues and I who will continue
201 to pursue the Andrews Labor Government; it’s corrupt, it’s incompetent, it’s exhausted.
202 We’re going to pursue the Robert Redlich Letter and we hope to establish a select
203 committee in the upper house, if we can attract the necessary majority [16:30] in the upper
204 house, as we are working hard to do that. We will also pursue the Minster for fiascos:
205 Danny Pearson. Danny is in the media yet again giving Victorians yet another reason why
206 he should be sacked from the Ministry. Let me just put this in context, in any other
207 jurisdiction in this country if a minster sat around a cabinet table with a direct pecuniary
208 interest in the matters he was helping decide upon, they would be sacked, in seconds flat.

[17:00]

209 That’s happened in other states. Why is it that Victoria has become a state where you can
210 be racked by a blatant pecuniary conflict of interest and keep your job? That is wrong, it’s
211 unethical, it’s corruption. I say that deliberately. In my view the reason we have conflict of
212 interest provisions is to guard against minsters of the Crown [17:30] and other public
213 servants from every profiting or being seen to profit from their positions. You will all know
214 that for weeks now, we have been peppering Minster Pearson with questions asking for
215 basic information, even information about whether he ever recused himself from cabinet
216 when decisions came up.

217 Question: When do you –

218 J Pesutto: – He’s refused – He’s refused to answer. If you look at his answers in the
219 Hansard and I invite you, look at the Hansard.

[18:00]

220 See the questions I have been asking Minster Pearson, ask yourself first, “are they
221 reasonable questions?” Then ask yourself second “is Danny Pearson hiding something?”
222 I think you’ll find the answer to both questions is “yes.”
223 Question: When do you anticipate the vote will happen, to expel Moira Deeming?

7
224 J Pesutto: Well – well, the vote will occur early next week, I’ll set a time I have to
225 advise with notice so that will mean that the meeting will have to take place next week. I’m
226 conscious [18:30] that MPs have other work to do with their communities as well so I will
227 do my best to bring this on quickly subject to the being enough time for people to observe
228 there notice period and prepare accordingly uh but it’s an important meeting and it will
229 occur early next week.

230 Question: And is there a path back for her? There’s been other cases where MPs
231 have left the party and, you know, made amends or whatever – is there a way that, I guess,
232 this could be reversed down the track, before the next election? Has she made any
233 indication to you that it’s not something she wants and that he still wants to be a Liberal
234 MP?

[19:00]

235 J Pesutto: Um, we thought as a leadership group, and myself particularly as leader,
236 about whether there were alternatives to the course I’ve taken. I thought about that
237 deliberately at length considering all sides of the question. It became clear to me that there
238 wasn’t really any alternative but to do this. The reason being, any question of an
239 association, even indirectly, with Nazis, white supremacist, [19:30] ethno-fascists or
240 whatever else is so odious in 2023, as it should be, that I can’t see a way back and
241 Victorians need to know we will just call it out. We will have nothing to do with it. Under my
242 leadership we will never have anything to do with that and more to the point we will oppose
243 it wherever we see it and that’s why, albeit early in our leadership, we’ve taken a strong
244 decisive step to say to Victorians and to say [20:00] to those mobsters, those Nazis on the
245 steps of this magnificent Parliament on Saturday “you are not going to get a foothold in this
246 state. We will oppose you wherever we can and we will stop you wherever we must.”

247 Question: Some party members are threatening to walk out when you spoke
248 [inaudible] is it a price you are willing to pay?

249 J Pesutto: I hope and trust that party members will see that the step I’ve taken is not
250 about freedom of speech, it’s about whether we will ever abide [20:30] by the odious tactics
251 and measures taken by Nazis and white supremacist. We saw that on the steps of this
252 Parliament, and I say to all Liberal Party members, understand why I have put this motion
253 forward. We are a responsible party that seeks to govern for all Victorians in their best
254 interests. We cannot and will never be able to do so if we are prepared to stand there with
255 those people on the steps who peddle violence and hate.

[21:00]

8
256 The party I lead, the values we share as a party, the values and principles the party stands
257 for mean that this action is necessary to tell Victorians we want to be a strong, effective,
258 principled, ethical opposition that is ready to govern in 2026.

259 Question: Will you accept her uh if she is expelled from the party, Moira Deeming,
260 will you accept her vote that – on matters the coalition is trying to get up in the upper house.
261 For instance, her vote on Robert Redlich [21:30] – oh sorry, the select committee to which
262 you’re trying to get Robert Redlich?

263 J Pesutto: I – I don’t want to get into those matters, only because I don’t want to pre-
264 empt the outcome of next week’s vote, but we will endeavour at all times in the conduct of
265 our strategy in the upper house to put issues on their merits and if people consider those
266 on their merits, we hope that they will support us. We will always be considered and mature
267 in the way we approach these things, with the Redlich Letter, we have worked
268 constructively uh – uh and cooperatively [22:00] with the crossbench and we’re confident
269 that something may eventuate from that. That’s an example of us working constructively in
270 the upper house in the interests of all Victorians to make sure the truth about that scandal
271 comes out and that Robert Redlich and personnel from Callida, the independent auditor,
272 can appear before Parliament and under privilege, give evidence about what went on. They
273 need to be given that opportunity.

274 Question: To clarify an earlier point, you were aware of the rally and her promotion
275 of the rally prior to Saturday but you weren’t aware of links [22:30] between some of the
276 organisers and white nationalists?

277 J Pesutto: Uh no, I wasn’t aware of those links and I uh didn’t see her material on
278 social media or the comments she – I – I understand she made in the Parliament. What
279 drew my attention on the weekend were the ugly scenes at the protest and we immediately
280 started investigating the matter, had a very lengthy meeting with Moira Deeming yesterday
281 where we exhausted inquiries into all manner of relevant matters arising from that and then
282 I made the decision following that [23:00] to bring on this motion.

283 Question: Do you think this will have any impact on the Aston by-elections, some
284 MPs are saying that it will um, I just wondered if you think it’s a distraction and unfortunate,
285 I guess, in its timing?

286 J Pesutto: I don’t think this will have any impact on the Aston by-election.

287 Question: Is it plausible that Ms Deeming was unaware of the extremist links of the
288 organisers and if she was unaware do you think it’s fair to kick her out?

9
289 J Pesutto: I don’t think it’s open to me to be satisfied that Moira didn’t know about
290 their history.

[23:30]

291 Uh it took us all of about twenty minutes or so after the rally on Saturday to investigate the
292 histories of these people uh Kellie-Jay Keen has a rap sheet of associations on the public
293 record with people known to be fascist, including people like David Duke, former head of
294 the Klu [sic] Klux Clan, took us only a few minutes. I – I just can’t be satisfied that Moira
295 didn’t know [24:00] but can I make this other point? When we conducted our investigations
296 in-into how the events of Saturday unfolded, it wasn’t just that Moira had escorted uh
297 organisers through the precinct of the Parliament. It wasn’t just that Moira stayed at the
298 protest when Nazis turned up, it was the celebration you can see on social media
299 afterwards, which tells you perhaps all you need to know about why it’s necessary to bring
300 this motion. Its saying, [24:30] “I am prepared to associate with these people” and not take
301 the opportunity to walk away from them and disown the odious things that they have shared
302 with people I’ve described before.

303 Question: Once you’ve spoken to the entire party to work out if any other MPs were
304 there, can you guarantee that you will publicly announce who those MPs were?

305 J Pesutto: Uh – I – uh of course, if information comes my way that suggests there

306 are other people who had similar associations, then I would but I don’t believe that to be
307 the case on the advice I have at the moment.

[25:00]

308 Question: Do you believe it could just be members though, not MPs that were there,
309 Liberal Party members?

310 J Pesutto: I – I don’t have that information, Simon, uh – uh if there are Liberal Party
311 members, I – I’m not in a position to know whether they went, my inquiries to date have
312 been about whether MPs were there.

313 Question: And – was, when you did question Moira Deeming about the association,
314 did she imply to you that she didn’t know the links to Nazis and – and things like this and
315 she was purely just organising it? What did she say when the claim was put to her that she
316 should have known?

[25:30]

10
317 J Pesutto: Look, I hope you’ll understand, I’m not going to go into the details of the
318 meeting we had. I’m prepared to say it was a lengthy meeting, we went through a whole
319 range of issues uh, and I was satisfied on reflection and consideration of all the matters
320 we discussed, that this was the appropriate action to take and I think you can draw the
321 relevant inferences from that.

322 Question: Moira Deeming boasted that she could secure a $100,000 donation to the
323 party if she was pre-selected. Did the party ever receive that donation and if it did will it
324 pay it back if she is successfully expelled?

[26:00]

325 J Pesutto: I’m not in a position to know the details around that donation. I – I’m not
326 aware of any uh anything other than compliance with the electoral rules around that but if
327 information comes to light I will look at it uh, Mitch, but I have nothing to hand at the
328 moment.

329 Question: If the government moved urgent legislation to ban the Nazi salute, would
330 the Coalition support that?

331 J Pesutto: Uh yes. Yes. Can I acknowledge David Southwick behind me who was so
332 instrumental uh in the last Parliament to ban the Swastika and given our position on the
333 Swastika, [26:30] I can’t see how you could rationally distinguish uh the salute, the Nazi
334 salute. It is as much an incitement of hate and violence as the Swastika itself, maybe even
335 worse because it is a gesture performed by a person and so we would not take a different
336 view having led that process and then worked with the government on that. So, we are
337 open to working with the government on this measure uh [27:00] we need to take this very
338 seriously this threat as evidenced most recently on Saturday afternoon on the steps of this
339 Parliament. And we will do so.

340 Question: I know you’re not a fan of hypotheticals but if you were Opposition Leader
341 and Moira Deeming was pre-selected and her views were made public would you
342 [inaudible] that to go ahead?

343 J Pesutto: I can’t change the past, uh Benita uh but what I can say, to reiterate, as a
344 new leadership team, myself, David Southwick, Georgie Crozier and Matt Bach, we’re new
345 to these roles [27:30] and you will have seen over recent weeks decisive steps that we’ve
346 taken to build an effective, strong, responsible Opposition that Victorians will embrace and
347 hopefully in 2026, doing all the work we need to, to form a government in 2026.

348 Question: To be fair, David –

11
349 – You spoke about looking at the candidates better in the future, wha– what has been done
350 in that space so far?

351 J Pesutto: Given uh, the result in the State election last year, I think it’s fair to say that
352 we need to review a whole range of things in our process.

[28:00]

353 We know that. And vetting candidates uh making sure we have the best possible
354 candidates who can connect with their communities and who can actually focus and do the
355 work that their communities want them to focus on, cost of living, poor roads, lack of access
356 to hospitals. Doing the work to focus on those issues everyday of every week, I’ll be looking
357 to support candidates who can commit to focusing on the issues that actually matter to the
358 people on the ground.

[28:30]

359 Question: You say you have a new leadership team, David and Georgie were part of
360 the leadership team that ultimately booted Bernie Finn out which then allowed Moira
361 Deeming to be pre-selected so how can you use that argument that you have a new
362 leadership team that is [inaudible]

363 J Pesutto: We’re a new team uh we’re a group of four, we work very closely together
364 and people go through different phases of their career Simon. And uh I’ve been through
365 that as you all know and all I can say is that there is an energy between the four of us
366 [29:00] and we’re working really well together and I’m just really proud of the processes
367 we’ve gone through, particularly overnight, which is not easy, Simon. And we’ve made a
368 decision which I think is responsible and which will connect with Victorians right across our
369 state.

370 Question: Just on the Nazi salute um, when the Swastika debate was happening um
371 the IPA was one of the groups that um recommended to the Liberal Party to oppose the
372 bans, as it was against free speech um there are Liberal members who are members of
373 the IPA, [29:30] a lot of you have connections to the IPA, Evan Mulholland was there at
374 the time, and was one of the people that –

375 J Pesutto: – Sorry. Sorry Anika was it –

376 Question: – Evan Mulholland –

377 J Pesutto: – Oh, yep. Yep –

12
378 Question: – who’s now an MP, was one of the people in the IPA at the time um, when
379 they opposed that ban. Are you confident that everyone in the party room is on board with
380 a – um the – the government’s proposal to ban the salute given some of the links towards
381 um, the last debate when there was support of the free speech argument, essentially?

382 J Pesutto: Yeah. Evan Mulholland is a young up-and-comer, a rising star in the party
383 and [30:00] I’m really excited that he’s a member of the team. He’s proving himself as
384 Shadow Cabinet Secretary to be effective and responsible and he’s part of a team now.
385 And we will go through robust debates internally, that’s a part of being in the Liberal Party.
386 Uh we do have robust debates about issues, but we took a strong position on the banning
387 of the Swastika, and as a party we made it clear, we were never going to countenance
388 hateful uh gestures or symbols like that and having supported and led [30:30] the debate
389 on the banning of the Swastika it is only consistent and it follows that of course we would
390 ban anything else that had a similar effect and I think if you look at the effect and the
391 potential ramifications of the Nazi salute it is perhaps even more prone to incite violence
392 than anything else. So, there would be a consistency in our position, and I think Evan would
393 get that, but we will have a debate and Evan, like everybody else, will have a chance to air
394 their views inside the party room but once we have made a decision that’s what [31:00]
395 we will prosecute outside the party room.

396 Question: Across 2020 and 2021 there were anti-lockdown protests organised by
397 people with extremist links and some of those events were attended by Liberal MPs, I’m
398 aware you weren’t in Parliament at the time but if you were leader and you were in
399 Parliament would you have supported those Liberal MPs being kicked out of the party, as
400 well?

401 J Pesutto: I’m not going to go into uh, what I would have done in the past. I think you
402 can draw conclusions about what this new leadership team is trying to achieve [31:30] in
403 the way we are going about this. We are making it clear to the broader Liberal Party that
404 to be an effective opposition, to be able to govern from 2026, we need to take these strong
405 and decisive steps to show that we will never support and that we will always oppose
406 anything that is hateful or liable to incite violence. So that’s the approach we are taking
407 now. I can’t change the past, but we can determine our future and that’s what we are going
408 to do. Thank you everybody. Oh sorry.

409 Question: Sorry just –

410 J Pesutto: – One more? Yep.

13
 [32:00]

411 Question: Uh, shouldn’t someone in the leadership team have known that Moira was
412 promoting the rally, she spoke about it in Parliament, two people in the leadership team
413 are in that House, why didn’t anyone warn her about her attendance?

414 J Pesutto: As I said before, we are the leadership team with a lot of responsibilities
415 and we’re not there to babysit every MPs [sic] – every MP. And we’ve got to be clear about
416 this, every person, Liberal or otherwise, has a responsibility. And they can’t shirk that
417 responsibility by someone – by someone else saying [32:30] ‘you shouldn’t have done
418 XYZ’. It was incumbent upon Moira as a member of Parliament to understand the
419 dangerous consequences that can come when you are associated with people who share
420 platforms with Nazis and white supremacists. Everybody must be responsible for their
421 actions.

422 Question: Did she offer to do a blatant condemnation of Nazism and everything else
423 associated with the salute and what went on that you didn’t approve of and why wasn’t that
424 enough?

[33:00]

425 J Pesutto: I’m not going to go into the details of the discussion, suffice it to say, we
426 explored all sides of the question and as party leader, having reflected on that discussion
427 and considered everything that came out of that discussion, this was, I am completely
428 satisfied, the appropriate action to take. Thank you very much.

END: [33:19]

14
 Schedule G

20 March 2023

Dear Ms Deeming,

1. I write to give you notice of my intention to call a special meeting of the Victorian
Parliamentary Party on 27 March 2023 and that — for the reasons in the motion set
out herein — I will move a motion, pursuant to clauses 58 to 60 of the Victorian
Parliamentary Liberal Party Constitution, dated 30 August 2022, that you be expelled
from the Victorian Parliamentary Party.

2. The wording of the motion is that:

“Pursuant to the Victorian Parliamentary Liberal Party Constitution, dated 30

August 2022, (the Constitution), that the Victorian Parliamentary Liberal
party expel Ms Moira Deeming from the Parliamentary Party.

Pursuant to clauses 57 and 59 of the Constitution, the reasons for such

expulsion being, on the evidence contained in the attached Annexure hereto,
that Ms Deeming, on 19 March 2023 and in days preceding that day,
conducted activities in a manner likely to bring discredit on the Parliament or
the Parliamentary Party, such conduct by:

(a) on 19 March 2023 and on days prior organising, promoting and

attending a rally where Kellie-Jay Keen (also known as Posie
Parker), was the principal speaker in circumstances where Ms
Keen was known to be publicly associated with far right-wing
extremist groups including neo-Nazi activists; and

(b) on 19 March 2023, meeting with and publishing a video with Kellie-
Jay Keen, Katherine Deeves, and Angie Jones and that Angie
Jones, on that day posted on Twitter words that, in the mind of any
reasonable and lay observer, made association with Nazis
including on 4:41pm by posting the words “Nazis and women want
to get rid of paedo filth. Why don’t you”, that quote being set out in
the Annexure hereto, which Annexure also contains a hyperlink to
the video referred to in this reason.”
3. At the meeting on 27 March 2023, you will be given an opportunity to explain your
conduct before a vote of the Parliamentary Party.

4. If the motion is passed at that meeting by absolute majority of the Parliamentary

Party, pursuant to cl 58 of the Constitution, you will be expelled from the
Parliamentary Party.

John Pesutto David Southwick

Georgie Crozier Dr Matt Bach

2
 ANNEXURE

A. Promotion of and Participation in the 18 March 2023 “Let Women

Speak” Rally

5. On 18 March 2023, Moira Deeming organised, attended and participated in an event

held on the steps of Parliament House entitled “Let Women Speak”, which was
hosted by Kellie-Jay Keen’s (also known as “Posie Parker”’s) organisation called
“Standing for Women”. Ms Deeming’s involvement in the rally is documented,
including by reference to the following material:

3
4
6. On 18 March 2023, Ms Deeming was photographed and videotaped with Keen, who
was the key speaker at the rally, in the secured carpark of Parliament House, and
Parliament grounds, which is documented, including by reference to the following
material:

See hyperlink: https://www.youtube.com/watch?v=9o47VZvDgAA&t=754s

5
6
 B. Kellie-Jay Keen’s Association with Far-Right Extremists

7. In October 2019, Keen appeared in a video interview with Jean-François Gariépy, a

far-right YouTuber who advocates for a "white ethno-state" and who has made videos
with neo-Nazis Richard B. Spencer and Mark Collett as well as former Ku Klux Klan
leader David Duke. 1 The interview with Jean-François Gariépy is documented by the
following material:

1
Parsons, Vic (15 October 2019). "Gender-critical feminist Posie Parker in video with white
nationalist YouTuber – and a lot of Mumsnet users are fine with it". Pink News. Retrieved 19
October 2022.

7
8
8. In 2019, Keen gave an interview to Soldiers of Christ Online, a far-right network: see
Elliards, Xander (4 February 2023). "Who is Posie Parker? The controversial anti-
trans activist heading to Scotland". The National (Scotland), see also:

9. In 2019, Keen posted a photograph on the internet with Hans Jørgen Lysglimt
Johansen, a Norwegian neo-Nazi who was probed by police after his comments
against Jews and denial of the Holocaust: 2 see Elliards, Xander (4 February
2023). "Who is Posie Parker? The controversial anti-trans activist heading to
Scotland". The National (Scotland).

9
10. Keen was accused of using a Barbie doll wearing a Nazi uniform as her profile picture
on the social media site Spinster: see Elliards, Xander (4 February 2023). "Who is
Posie Parker? The controversial anti-trans activist heading to Scotland". The National
(Scotland). The following image was retrieved from an internet archive:

10
11
11. On 16 January 2023, at an event for Keen’s Standing for Women’s group in
Newcastle, United Kingdom, one of the speakers, Lisa Morgan, quoted Adolf Hitler

12
 as follows “Do you know the big lie? The big lie was first described by Adolf Hitler in
Mein Kampf … The big lie is that trans women are women”. 3

12. See the following hyperlinks:

Let Women Speak - Newcastle - 15/01/23 - Lisa Morgan - YouTube

Let Women Speak - Newcastle - Part 2 #letwomenspeak

#letwomenspeaknewcastle - YouTube

13. On 18 March 2023, a group of neo-Nazis, organized by the National Socialist

Network, performed the Nazi salute on the steps of Parliament House and displayed
a banner which read "DESTROY PAEDO FREAKS". 4

3
Elliards, Xander (4 February 2023). "Who is Posie Parker? The controversial anti-trans activist
heading to Scotland". The National (Scotland).
4
Anderson, Anthony (18 March 2023). "Anti-trans speaker's fans throw Nazi salute amid
counter-protest". News.com.au.

13
14
14. The following image was retrieved from an internet archive:

15
 C. Meeting, Video and Twitter Posts Following the 18 March 2023 Rally

15. On 18 March 2023, Ms Deeming met with and appeared in a video following the rally,
drinking champagne with Kellie-Jay Keen, Katherine Deves and Angie Jones.

16. See the following hyperlink:

https://www.youtube.com/watch?v=M4lZ5u8uws4

17. In the video, Ms Deeming and Keen did not roundly condemn the men who made the
Nazi salute and dissembled by seeking to question whether those men were
organised by the trans-rally participants or were assisted police.

18. At 4.41pm on 18 March 2023, Angie Jones posted to Twitter the words “Nazis and
women want to get rid of paedo filth. Why don’t you?.”

16
17