court file number: 1503-03309 origi ii stephen...

L

ORIGI iiCOURT OF QUEEN'S BENCH OF ALBERTA

COURT FILE NUMBER: 1503-03309

COURT:

JUDICIAL CENTRE: EDMONTON

PLAINTIFFS: CLAUDE COLGAN, ERICKA CLARKE,DARLENE MACKENZIE, KURT LUCIA ANDSTEPHEN BUDDO

DEFENDANTS: CANADA'S NATIONAL FIREARMSASSOCIATION AND SHELDON CLARE

_______-__—__—.——-.-—----u-._....-.__-____________.---__.....____

QUESTIONING ON AFFIDAVITS

OF

SHELDON CLARE

SWORN THE 19TH DAY OF MARCH

AND THE 23RD DAY OF APRIL, 2015------u---------......____________-_____—---_________—_---

M. Stoyanov, Esq. &. For the P1a1nt1ffsA. Kn1se1y, Esq.

K.G. Heintz, Esq. For the Defendants

Richard D. Jacobs, CSR(A) Court Reporter/Examiner

EDMONTON, A1berta7 May, 2015

J1C£LRgmflfiy5wvka2m;L'PI'iom:: (780) 497-4223

INDEX OF UNDERTAKINGS

(Undertakings are provided for your assistance.

Counse1's records may differ. Please check to

ensure that a11 undertakings have been Tisted

according to your records.)-i***i*'k*'k‘t**i'****-ki"A-i--I-titi1****'k*'kitiiii'*'k**‘§'k'.l’**i'i'ti'*i

NO. DESCRIPTION PAGE

[UNDERTAKING NO. 1: TO DETERMINE 19

WHETHER A DEBT OBLIGATIONS REGISTER IS

APPLICABLE TO THE ASSOCIATION AND IF SO

TO ADVISE IF IT IS MAINTAINED AT THE

REGISTERED OFFICE OF THE ASSOCIATION]

[UNDERTAKING NO. 2: TO PROVIDE 34

CORRESPONDENCE BETWEEN MR. CLARE AND THE

STAFF OF THE REGISTERED OFFICE WITH

RESPECT TO ANY INSTRUCTIONS OR

DISCUSSIONS REGARDING MISS CLARK'S

REQUEST FOR THE PRODUCTION OF DOCUMENTS]

[UNDERTAKING NO. 3: TO PROVIDE A COPY 49

OF THE NOTICE TO THE DIRECTORS OF THE

JULY 218T, 2013 MEETING]

[UNDERTAKING NO. 4: TO PROVIDE THE 64

MINISTERIAL APPROVAL FROM CORPORATIONS

CANADA OF THE JULY 29, 2015 BYLAW

AMENDMENTS]

A.C.E. Reporting Services Inc.Certified Court Reporters

[UNDERTAKING N0. 5: TO LOOK FOR ANY 65

COMMUNICATION IN 2014 REGARDING THE FACT

THAT THE MEMBERSHIP HADN'T SANCTIONED

THE CHANGES TO THE BYLAWS]

[UNDERTAKING NO. 6: TO SEARCH FOR AN 68

EMAIL FROM THE NFA DATED 2014, 07-16]

[UNDERTAKING N0. 7: T0 ADVISE AS TO THE 75

DATE THE AUDITORS WERE ENGAGED IN THE

SPRING OF 2015]

[UNDERTAKING N0. 8: TO PROVIDE RECORDS 76

OF VOTING RELATING TO THE APPOINTMENT OF

THE AUDITOR]

[UNDERTAKING NO. 9: TO PROVIDE THE 75EMAIL SENT REGARDING THE VARIOUSQUOTES][UNDERTAKING N0. 10: TO PROVIDE A COPY 77OF THE ENGAGEMENT LETTER WITH THEAUDITOR][UNDERTAKING-N0ru11+——T0-PROVIDE-A-COPY ———93OF MINUTE OF THE DIRECTORS MEETINGREFERRED TO IN PARAGRAPH 26 OF MR.CLARE'S MARCH 19TH AFFIDAVIT]

UNDE TAKING Ho. 12: TO PROVIDE A COP 131OF THE LIST OF REGISTERED OFFICERS FORTHE PAST FIVE YEARS IF AND WHEN IT ISCREATED]


INDEX OF EXHIBITS

NO; DESCRIPTION PAGE

[EXHIBIT 1: LETTER DATED JULY 29, 2013] 48

[EXHIBIT 2: Draft minutes of the 48

director te1econference Ju1y 21st, 2013]

[EXHIBIT 3: By1aws received from 67

Corporations Canada]

[EXHIBIT D-4: Form 4006 changes 111

regarding directors of the association]

13

INDEX OF OBJECTIONS

(OBJECTIONS ARE PROVIDED FOR YOUR ASSISTANCE.

COUNSEL'S RECORDS MAY DIFFER. PLEASE CHECK TO

ENSURE THAT ALL OBJECTIONS HAVE BEEN LISTED

ACCORDING TO YOUR RECORDS.)it***it'k**iti'tt't***t'*********'kk*tt**ti't1'l'****i'i-*******i

OBJECTION PAGE

119


D>D>

MR.

SHELDON CLARE, AFFIRMED AT 1:06 P.H.,

QUESTIONED BY MR. STOYANOV:

MR. STOYANOV: Good afternoon. I just want

to confirm that you are the Sheidon Ciare who

swore an affidavit dated March 19th, 2015 and

a1so on Apri1 25th I beiieve, 2015?

I thought it was 23rd.

It's hard to read. Yes, maybe 23rd, indeed.

I am.

Okay. And I want to confirm aiso that you're

here in two capacities, one in your personai

capacity and an individuai named in this

appiication, and a1so as a representative of

the Canada's Nationa1 Fire Arms Association?

I am.

And your answers you're going to be giving us

on beha1f of the, on behalf of Canada's

Nationai Fire Arms Association are binding on

the association?

HEINTZ: That's correct, sir. Insofar

as the Ru1es of Court provide.

MR. STOYANOV:

background as to the NFA, the Nationai

Can you give me some

Firearms Association, when it was associated,

incorporated, what happened in the early

years?

we11 I wasn't there in the ear1y years.

A.C.E. Reporting Services Inc.

Certified Court Reporters

I understand that.

I'm a historian, I suppose I cou1d give you a

history Tesson if you have Tots of time.

Just brief1y p1ease.

Okay. The NFA was origina11y started in the

1970s by a fe11ow named Bi11 Jones, a1ong with

severa1 other individua1s who sought to make

changes in Canadian firearms Taw. They were

concerned about particu1ar1y Taws originating

from the 1960s, 1968 in particular out of the

Libera1, then Libera1 government. They were

particu1ar1y concerned with the pending Bi11

C51 which wou1d have come into force I be1ieve

in 1978, which among other things wou1d have

brought in the firearms acquisition

certificate, wou1d have created a prohibited

c1ass of firearms, restricted c1ass of

firearms and brought in a number of other

strictures. The association was unsuccessful

in preventing that 1egis1ation from moving

forward and thus it became defunct for a

period of time, after which it was reinstated

under a s1ight1y different name in 1984 by one

of those founding members, David Tom1inson.

what was that name?

The Nationa1 Phoenix Communications &

Information Association, Firearms Association,


MR.

it's not quite correct as I'm saying it but it

wouid be a —- I might actua11y be able to give

you a corrected version of that if I have a

copy of that here, kind of a minute book or

something.

HEINTZ: Like he says Mr. Stoyanov, I

think we've got it here in this binder.

The Nationai Phoenix (1984) Firearms

Information and Communication Association

(NFA).

MR. STOYANOV: And that was a non-share

capitai corporation under the Canada

Corporations Act?

I have no knowiedge of that at that time, I

was not a member.

Okay. And currentiy the name is Canada's

Nationai Firearms Association?

That's correct.

And basicaiiy it was continued under the

Canada Not For Profit Corporation Act on March

26th, 2014?

2014? I wouid have to have a iook at the

documents, but if you say so.

Fair enough. Now, the membership of the NFA,

how do you go about becoming a member of the

NFA?

How do you become a member of the NFA?


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Yes?

we11 membership in the NFA is avai1ab1e to

peopie as stipu1ated in the by1aws.

Do they have to pay a fee of some sort?

That's correct.

A membership fee?

Yes, or there are other different c1asses of

membership, for exampie there are business

members and 1ife members. Life members don't

pay a membership fee. There's, seniors pay

different membership fee. we have different

categories of membership.

How do you become a Iife member?

We11 it's genera11y an appointment based on,

there's a coup1e of ways you cou1d, you could

pay a iife membership fee or you cou1d be

granted iife membership by the board of

directors.

who appoints directors in the association?

Directors are e1ected provincia11y under our

current structure by members.

By the members, okay. what is the ro1e of the

directors?

we11, it's, the directors are under various

governance modeis and the governance modeis of

course boards of directors tend to set their

own patterns. But they do things 1ike set


MR.

MR.

genera1 po1icy, oversee those stipu1ations as

contained in the by1aws for directors, I think

they're spe11ed out fairly we11 in the byiaws

what directors do. And oversee the affairs of

the association.

And do you know who the current directors are

by heart?

Yes I do.

Okay, wou1d you please state their names for

the record?

The names of the current directors?

Yes?

we11, the current directors are myse1f,

Sheidon C1are; Jarroid Lundgard. In British

Co1umbia -- Jarroid Lundgard is in A1berta.

Ericka C1ark is in A1berta. B1air Hagen is in

British Co1umbia. There's a Kurt Luchia from

Saskatchewan, there is a Bi11 Rantz in

Ontario, Dar1ene MacKenzie in Ontario and in

the Maritimes we have Robert Bracket. Pardon

me, Quebec has Stephen Buddo, and it a1so has

C1aude Co1gan.

HEINTZ:

STOYANOV:

I think that's everyone.

That's 10.

Very good, yes.

I'm not ab1e to count on my fingers I'm

afraid.

The directors my understanding is, appoint the


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officers of the association?

The directors e1ect the officers of the

association.

So you are the president?

That's correct.

And Mr. Jarro1d?

Lundgard.

Lundgard is the secretary?

That's correct.

Then Bi11 Rantz is the treasurer?

B111 Rantz is the Ontario director and

treasurer, that's correct, and there is a

vice-president in British Co1umbia as we11,

which is B1air Hagen.

So the vice-president office was in British

Columbia on1y or was it for the entire

association?

The executive officers wou1d be e1ected for

anywhere. He's the executive, or he's the

vice-president for the entire association.

His name again is?

B1air Hagen.

So that position isn't vacant current1y, is

it?

No.

Now, a11 the directors must be voting members

of the association?


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Directors, yes.

And is there something ca11ed an executive

committee or an executive?

Yes.

Can you exp1ain what that sort of means?

Those are present1y the executive officers of

the organization.

Now, in your affidavits there's a reference to

the executive, this is paragraph 27?

In which affidavit are you referring?

The March 19th affidavit, 2015.

Paragraph?

27?

M-hm.

You speak of somebody trying to oust the du1y

appointed Executive with a capital E, I'm just

trying to understand what you mean by that

word Executive?

I think if you Iook at my affidavit that on

attachment E, I think the attachment speaks

for itseif.

HEINTZ: Just for the record the

witness is referring to Exhibit E Mr.

Stoyanov.

MR. STOYANOV: Perhaps you can help me out, I

don't see any reference to the term I guess

"Executive" with a capita1 E, I just want to


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understand what that rea11y means, the

executive?

Sure, if you Iook at paragraph F and paragraph

D as we1T as paragraph E, paragraphs D, E, and

F I think that makes it pretty c1ear.

Okay.

HEINTZ: Go ahead and exp1ain.

STOYANOV: wou1d you p1ease.

HEINTZ: Answer the question fu11y.

Certain1y. It says, and I mean I didn't write

these particu1ar minutes, but it wou1d

probab1y be best to question the person who

did. But --

Sorry?

I didn't write this, you'd probab1y best

question the person who did.

Actua11y my question was actua11y much

simpler. who is the Executive capita1 E, is

it the board, is it the officers, is it --

The executive officers and executive committee

of the association are genera11y referred to

as the executive, they're one and the same.

That's what I was trying to figure out.

Yes.

So the executive inc1udes who precise1y?

It wou1d inc1ude the president, the

vice-president, the secretary and the


MR.

MR.

13

treasurer.

But not the directors?

No.

Okay. And this is the same as the executive

committee then?

I be1ieve that's what I said.

Okay. Just c1arifying. Now, we discussed the

manner in which the members of the executive

are appointed by the directors?

Eiected.

Eiected. Can you produce the minutes or any

other record of the resolution that appointed

the current members of the executive?

Yes, it wou1d be in the minute book. It wou1d

be at the annuai genera1 meeting in Vancouver

of Iast year, at the directors meeting prior

to the annuai generai meeting. Yes, we have

it right here, nomination of the executive is

Iisted on the Iast page of the minute, wouid

you Iike me to read it to you?

May I have a copy of it?

HEINTZ: Your office has been provided

with a copy.

It was unanimous and uncontested for any

position. It's just after directors reports.

MR. STOYANOV: Does that resoiution --

HEINTZ: It's tit1ed draft executive


14

meeting 2014, Mr. Kniseiy.

That wou1d be I beiieve on May 23rd. 2014.

MR. STOYANOV: Now, I know that it says draft

executive meeting, were those documents ever

finaiized, how does that usua11y work?

We11 as you're aware, Roberts Ruies of Order

is one of our governing provisions and since

these meetings don't take p1ace on more than a

quarter1y basis these types of minutes are

genera11y approved by the secretary and the

president. They're not brought to the

directors, they don't, aren't required to be.

That's in Roberts Ruies of Order in the, where

is it here. on the 11th revised edition which

is the current proper one. I think that's at

page, I'm having troubie seeing with my

g1asses I'm afraid, I rea11y shou1d be wearing

bifocals but, yeah, it's on page 474, 475, and

it says, wou1d you Tike me to read it for you,

it's probabiy easiest?

Sure.

when the next regular business session wi11

not be he1d within a quarter1y time intervai,

it makes reference to pages 89 to 90, and the

session is not ionger than one day or in an

organization which there wi11 be a change or

repiacement of the portion of the membership,


15

the executive order or committee reported for

the purpose shou1d be authorized to approve

the minutes. The fact that the minutes are

not then read for approvai at the next meeting

does not prevent a member from having a

reievant excerpt read for information nor does

it prevent the assembly in such a case from

making additiona1 corrections, treating the

minutes as having been previous1y approved,

etc. etc. I hope that's he1pfu1. wou1d you

1ike to have a 100k at it?

That's fine, thank you. I just wanted to

confirm these draft minutes were at some point

approved.

I've approved them.

You have, okay. And when was that?

I went through a11 of the minute books just

recent1y on my visit here today, or actua11y

yesterday when I was Iooking through them.

And that's when you approved them?

That's when 1 approved them, yeah.

So the powers of the executive committee, is

that up to the directors to define or are they

set out in the by1aws?

I think the by1aws are pretty c1ear about

that.

Now, the association a1so emp1oys a genera1


16

manager; is that correct?

Yes it does.

what does that person do?

That person administers and Tooks after our

office and our office staff. That person is

responsibie for the good order of the NFA

offices, in our case that person is a1so our

privacy officer and supervises our bookkeeper

and reports to me as the representative of the

board of directors and the executive

committee.

And who ho1ds that position currently?

That is he1d by Ms. Ginger Fournier.

Now, I was under the impression that she was

supposed to report to the vice-president but I

guess in the absence of a vice-president?

In our byiaws the office of executive

vice-president was one that we actua11y used

to assign to the manager of the office, that,

in our previous manager that person he1d that

particu1ar position. However, we had some

probiems with that person and the position as

defined, so we decided not to utilize that

position any Tonger. So that genera] manager

was no Tonger, instead of having an executive

vice-president who in effect was the genera1

manager, we eiected to have a generaT manager


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who managed the office and those affairs and

reported to the executive on behaif of the

board of directors.

50 the genera1 manager has taken on some of

the responsibilities that wou1d ordinari1y be

the executive vice-president's?

That particu1ar section in the by1aw was

designed for that particu1ar person except we

decided to no 1onger use that particu1ar tit1e

for that particu1ar position.

Okay. Now, where is the association's

registered office?

It's

At 45th Avenue?

in Edmonton.

That's correct.

9683-45th Avenue?

I don't know the address off the top of my

head but if you're certain of it I'11 accept

your certainty.

Fair enough. And of course the association

maintains its officia1 records at that office?

Yes.

So I'm going to read off a bunch of types of

documents and I want to confirm that those are

in fact kept at that registered office. One,

the artic1es?

The artic1es?

A.C.E. Reporting Services Inc-Certified Court Reporters

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The artic1es?

Can you be more specific the articies,

magazine articies?

No, the articies in the sense of the artic1es

of the association?

Yes, as I understand it they're kept in the

office.

And the association's by1aws?

Yes, they're e1ectronica11y kept, they're on

our web site of course and our paper copies

wouid be at the office as we11.

A11 the amendments to the byiaws?

Yes.

The minutes of the meetings of the members?

Yes.

A debt obiigations register?

I'm sorry I don't know what a debt ob1igations

register is.

Okay. Can you undertake to confirm whether or

not --

Yes, I couid probably find that out.

HEINTZ: whether or not what?

STOYANOV: A debt ob1igations register is

maintained at the registered office of the

association.

HEINTZ: Can the first part of the

undertaking Mr. Stoyanov, be to determine if


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the debt ob1igations register is app1icab1e to

this association and if so.

STOYANOV: Certain1y.

HEINTZ: If it's maintained.

STOYANOV: Yes.

HEINTZ: Thank you.

[UNDERTAKING N0. 1: TO DETERMINE

WHETHER A DEBT OBLIGATIONS

REGISTER IS APPLICABLE TO THE

ASSOCIATION AND IF 80 TO ADVISE

IF IT IS MAINTAINED AT THE

REGISTERED OFFICE OF THE

ASSOCIATION]

HEINTZ: whi1e, and I apo1ogize whi1e

I'm interrupting your questioning, I shou1d

just qua1ify when Mr. C1are is testifying

today that the records are kept at the office,

right at the moment they're in your boardroom

on this tab1e, they're not physica11y there

today.

STOYANOV: I understand that.

A register of directors?

Yes.

A register of officers?

Yes.

A register of members?

Yes.


20

Accounting records?

Yes, and they wou1d a1so be with our

accountant.

Annuai comparative financia1 statements?

Yes.

The report of the auditor or pubiic accountant

on the annuai comparative financiai

statements?

Yes, where such is avai1ab1e that's kept at

the office.

Minutes of meetings of the directors?

Yes.

And aiso minutes of the meetings of the

executive committee?

Yes.

who is responsibiie at the association to

prepare and maintain those records?

we11 the by1aws outiine the responsibi1ities

of the various officers, of course some of

these, some of the administrative tasks are

deiegated to staff given that the organization

is spread across the country as it is, and

officers do not 1ive in Edmonton or dai1y

frequent the office. These things are heid in

the custody and maintained and iooked after by

the staff as deiegated.

So for exampie the minutes of the meetings of


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the directors and the minutes of the meetings

of the executive, who at the office wou1d be

responsib1e for maintaining those and keeping

them?

The genera1 manager.

Okay.

Under the supervision of the secretary, who is

not at the office.

Right. But that is done under the authority

that's given to that person by the directors

and the executive?

Yes.

They sort of oversee things?

Yes.

And are responsib1e for comp1ying with

whatever 1ega1 ob1igation there is in that

respect?

I'm sorry, you went a Tong way, I Tost the

train of your --

So the general manager acts on the

instructions of the executive and the

directors?

That's correct.

As far as making sure that whatever 1ega1

requirement there is to keep records that

that's being done correct1y?

Yes. They a1so take the ro1e of te11ing us


22

when we're not te11ing them what we need to

te11 them sometimes as we11, which is

something that's quite va1uab1e and important,

particuiariy in a vo1unteer organization, to

assist us in maintaining our fiduciary

responsibi1ity.

You mentioned you'd reviewed these documents

just recent1y?

I happened to be in the office so I made sure

I had a good Iook at them.

Do you often do that or do you get a chance to

review the documents on a regular basis?

In the office, no.

But as it being generated or created

throughout the years you wou1d usua11y --

I try to keep a finger on things, on the pulse

of the things. I of course try to trust my

peop1e so I'm not micro managing in any sense

of that word, it's not my management sty1e.

But you're fami1iar with the nature of those

documents and information they contain?

Of course, yes.

Now, the records that I mentioned ear1ier a11

the minutes and the registers and those types

of documents, do you have records that date

prior to January 1st? Sorry, records between

January 1st, 2009 to the present time?


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I beiieve we do.

How far back does it go?

we11 we have a gap I think from 2002 because

we had some difficu1ties with staff in the

office which were the subject of another 1ega1

matter, and I have my suspicions about where

some of those documents went and are being

he1d. And I've tried to take steps to Iocate

some of them but we have a gap during a period

of turmoi1 in the office where some of those

records are not available.

what time period is that?

It's about from 2002 to 2009.

But since then they're quite consistent and

comp1ete?

Yes. I've tried to make that my ro1e as being

president is to professionaiizing the office

and making sure we're fo11owing procedures and

making sure that we're fo11owing our duties

and responsibi1ities as required by 1aw, and

required by good duty to care and fiduciary

responsibi1ity of the directors, and a1ways

with an aim to act in good faith.

And what sort of steps did you take in order

to make this actua11y happen in practice?

we11 when I became president and we engaged.

and we had a good team of directors, we tried


24

to make sure that as a team we appointed goodpeople in roles of executive authority. Wemade some staff changes. we, one of the

people we hired was Ms. Fournier, on the

recommendation of one of our consultants atthe time, and we proceeded to move our officesfrom where they were previously, which was adismal, moldy. filthy little place with torncarpets and burgundy paint on the walls, andjust a general horrible horrible place. Ifound my nose clogging when I came into theplace. It was upstairs, it was inconvenient

for wheelchair access, it was not what was inthe vision of anyone who had been there as tothe public face of a national organization.And one of our first instructions to our newgeneral manager was to ensure that she foundus suitable lodgings commensurate with thestatus and needs of the organization, with thegoal of providing a happy, productive work

place that would be running in an efficientmanner commensurate with the needs of themembership, the directors, the executive andthe Canadian firearms public frankly.Now, are you aware of any missing documents

from that time period or afterwards?

Oh, I was not aware that earlier documents


25

were missing unti1 about a year or two iater I

had been to1d that we had some probiems with a

coupie of staff members who were iong since

departed from us, who were 1et go. And they

had been responsibie for maintaining documents

and iooking after them, doing bookkeeping and

so on, and the parting was not an amicabie one

and unfortunateiy a 1ot of documents went

missing. There was a1so an executive officer

at the time who had to be removed from the

organization who was, subsequent1y had his

accountancy designation removed due to bad

practices, not reiated to our particuiar

circumstances, but to other practices and

compiaints. It's a matter of pubiic record.

And we did get some fragments of documents

through a director from him which were reaiiy

not a11 that he1pfu1, so we did try to take

steps to reconstruct those, and we sti11 try

to find out where those went. But with the

rebranding, deveiopment of new byiaws we

estabiished a new organization and tried to

make sure we couid move forward with vigor and

with good intent to make sure that that kind

of nonsense never ever happened again.

Now, so as of recent things have been normai

as far as record keeping and --


26

we try to do the best we can. we've had avery consensus driven board for the most part,our board has not been one to engage in

negativity. Our board, whiie we've had gooddiscussions, some points of disagreement, we

usua11y come to a consensus and move forward

based on that.

Has anything changed in the past severa1

months as far as the way you keep records,

particu1ar1y since February 24th, 2015?A change in the way? we11 we've become a bitmore rigorous about ensuring our transcripts

of our meetings are proper1y documented and in

keeping with the requirements of our byTaws inthe -- I shouid point out one thing, one ofthe things that is a practice and again Irefer to Roberts Ruies of Order, is thepractice of custom, and this has to dea1 witha particu1ar, if I may indu1ge, and I refer to

page 19 of the 11th edition Roberts RuTes ofOrder new1y revised: In some organizations a

particu1ar practice may sometimes come to be

fo11owed as a matter of estab1ished custom. Imight interject, the taping of our meetings we

wanted to make sure we had good transcript

capability of our meetings if it was needed to

refer back to points. To continue: So that


27

it is treated practicaliy as if it were

prescribed by a ru1e. If is there no contrary

provision in the par1iamentary authority or

written ru1es of the organization the

estabiished custom shouid be adhered to uniess

assembiy by a majority vote agrees in a

particuiar instance to do otherwise. However,

if a customary practice is or becomes in

confiict with the par1iamentary authority or

any written ru1e, and a point of order,

referred to in 23, citing the conflict is

raised at any time, the custom falls to the

ground and the conf1icting provision in the

par1iamentary authority or written ru1e must

thereafter be comp1ied with. If it is then

decided to fo11ow the former practice a

speciai ruie of order or in appropriate

circumstances a standing ru1e or by1aw

provision can be added or amended to

incorporate it.

Now when you said you made those changes

recent1y, when did that actua11y happen?

we11 there were severai requests for

information and the requests for information

were perfect1y reasonab1e and iegitimate, and

this necessitated the need to ensure that the

taped transcripts of our directors meetings


28

were put on to paper in minute form so that

they cou1d be avai1ab1e to those who had

requested them. Now this of course does take

a bit of staff time, effort and so on but we

made efforts to ensure that we cou1d meet with

those particuiar requests.

Okay.

Acting of course in the best interests of the

organization and in good faith.

Now, does anybody take notes or minutes of the

meetings in writing during those meetings?

Yes. In some instances where there have not

been taped transcripts, and I confess that I'm

a bit of a fumb1e finger sometimes with

pushing the right buttons on some of these

e1ectronic te1econferencing materia1, then the

secretary or a staff member wou1d take the

notes and then they wou1d be transcribed into

minutes. The secretary of course retaining

responsibi1ity for an accurate transcript or

an accurate minute of the meeting.

And those minutes are, those records are kept

at the registered office?

Yes, they're provided to the registered office

when whoever has been responsibie for writing

them down has been ab1e to do so.

And the audio recordings, are they kept as


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we11 or are they discarded once they're

transcribed?

we keep them a11.

How far back does that go?

As 1ong as I've been president.

The audio recording?

Yes.

Again when did you become president?

In 2010. we had no such sty1e or manner of

doing things before that, not that I'm aware

of, anyway.

Okay. Now, you had mentioned there had been

some requests for information from members or

directors that sort of caused you to make

those certain changes?

Yes. we saw that a continuation of our

practice had been questioned and as that's the

case, we11 okay, if you want this stuff we're

happy to provide it.

Very good. I know that Miss Ericka Ciark had

made a request of a simiiar nature on February

27th of this year?

I think I read something to that effect in her

affidavit.

Okay.

If you cou1d refer to me where that was.

HEINTZ: Mr. Stoyanov, if it assists,


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Miss Clark's affidavit of March 6th, 2015

references the date February 27th, 2015 at

paragraph four.

Paragraph four,

MR. STOYANOV:

yes.

So if you look at that same

affidavit, Exhibit A, there's an actual

letter?

Yes, I see that, from Ericka Clark.

Do you know who may have received that letter?

It wasn't sent to me.

Okay. She swears it was sent by recorded mail

to the registered office.

well

reason to doubt that that would be the case.

if she says so and swears so I have no

Is there one particular person at the office

who is responsible for receiving

correspondence?

well our general manager generally picks up

the correspondence and distributes it

accordingly.

Alright.

HEINTZ: I'm just going to refer the

witness to Exhibit B of Miss Clark's affidavit

Mr. Stoyanov, you're questioning about

delivery and your client has testified about

delivery in her affidavit.

MR. STOYANOV: There's a signature in that


31

signature box, and there's a1so --

Picked up the 2nd month, 27th day, 2015 at

14:18 hours.

And then further down it says POD Eric?

Eric wou1d be one of our staff members at the

office.

Now have you seen this Ietter before Ms. C1ark

served her affidavit?

I don't reca11 seeing it before. I notice it

a1so says it was de1ivered on the 2nd month,

27th day, 2015 at 16:12 hours, it's by, what

is it, it has a company name, Axe Express

Inc., you have a11 this I guess.

Yes. So you don't rea11y know who received

that request, that written request by

Ms. Ciark?

You wou1d have to ask someone who received it,

I didn't receive it. I can't te11 you about

things I have no direct persona1 know1edge.

That wasn't, so nobody sent this Ietter to you

at the time?

No. I don't reca11 seeing this Ietter. But I

do get a 1ot of emai1.

Now, Ms. C1ark has stated in her affidavit

that she attended the registered office of the

association on March 2nd to inspect those

records.


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HEINTZ: Can you just refer the witnessto the paragraph you're talking about, sir.

MR. STOYANOV: That wou1d be the affidavit

sworn on March 6th, and on page two paragraph

six on Monday March 2nd.

M—hm.

On Monday, March 2nd, 2015, 9:00 a.m.: I

attended the registered office of the

association and met the association's general

manager Ginger Fournier. Did Miss Fournier

advise you of Ms. C1ark's visit?

She advised me of the visit, I don't know, I

don't reca11 if it was on that day or another

day.

was it shortiy thereafter, was it a week

1ater?

I'm not sure. That's March 2nd, that's a

coup1e months back in my life at a very busy

time.

Did Ms. Fournier ask for any guidance or

directions from you with regard to Ms. C1ark's

request?

No,

So did you at some point authorized or direct

I don't reca11 anything Tike that.

anybody to do anything with respect to the

request by Ms. Ciark?

I've a1ways instructed that everyone shou1d


MR.

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have any information that they're entitied to

have and certainiy directors of the

association are entitied to have information.

So actua11y, now, do you say this in generai

to everyone?

Yes.

Or was it you actua11y make that statement

with respect to a specific request by

Ms. Ciark?

I don't reca11 what specific statement I may

have made but I certainiy wou1d not have been

standing in the way of any of those records

being given to Ms.

entit1ed to have them.

Right.

C1ark or anyone eise

But you had discussed Ms. C1ark's

request with Miss Fournier?

I'm sure I did at some point, but I don't

reca11.

HEINTZ: Weii at what point Mr.

Stoyanov, I mean it's the subject matter of a

iawsuit, obviousiy he's taiked to her about

it.

STOYANOV: I'm just trying to figure out

at what point did you give directions to Miss

Fournier about Miss C1ark's access to the

records?

I cou1dn't say for certain.


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Now, at some point your 1awyer's office

forwarded documents to our office, was it at

that time that you authorized the re1ease?

I think I've answered the question.

You answered that you don't remember?

I don't reca11 the time or date of that,

It's not in the detaii that wou1d

no

don't.

appear important to me at any point in time.

I'm a very busy person you see.

HEINTZ: If it assists, Mr. Stoyanov,

we cou1d undertake to make inquiries of the

office.

STOYANOV: If you wouid maybe undertake

to provide correspondence between Mr. Ciare

and the staff of the registered office with

respect to any instructions or discussions

regarding Miss C1ark's request for the

production of documents.

HEINTZ: Can we do that?

Certainiy, of course, happy to cooperate.

STOYANOV: That wouid be very he1pfu1,

thank you.

[UNDERTAKING NO. 2: TO PROVIDE

CORRESPONDENCE BETWEEN MR. CLARE

AND THE STAFF OF THE REGISTERED

OFFICE WITH RESPECT TO ANY

INSTRUCTIONS OR DISCUSSIONS

I


35

REGARDING MISS CLARK'S REQUEST

FOR THE PRODUCTION OF DOCUMENTS]

MR. STOYANOV: Now Miss C1ark, that's

paragraph 7 of her affidavit, says that she

wasn't ab1e to inspect any documents on that

day. What is your understanding why that

happened, or didn't happen?

we1T I wou1d suggest that it's probab1y due to

the busy nature of our office. It's a time

when renewaTs are particu1arTy heavy, there's

a Tot of work coming in and I think it's not

that particu1ar1y easy to sudden1y be running

around gathering documents together at a

moment's notice. I think that a reasonab1e

thing to do is make an appointment and come

back at a later time when such things cou1d be

provided.

Have you got a po1icy in p1ace regarding such

things?

I don't think such a po1icy is written, I

think it's just a matter of reasonab1e

practice.

But there is no dispute as to Miss C1ark's

right to have copies of documents?

I don't dispute that, no, of course not.

Now, do you give more Tatitude to directors of

the association as far as access to records to


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members?

Of course. I wou1dn't say that I give more

access. I think that the access exists

independent of what I do.

And again you're here to testify on beha1f of

both yourse1f and the association so I guess

my question in this respect was the

association?

I wasn't c1ear as to that.

Fair enough.

Yeah.

What does a director need to do in order to

have access to those records?

we11 I think that part of the thing is to

attend at the office, is part of that. As

with many organizations it's not a very easy

thing to be shipping records around the

country. we have directors a11 over the

country and to be shipping documents in this

sort of form, which are Iike minute books and

sort of thing shou1d not be ieaving the

faciiity. I think that the opportunity is to

have them in the office. I think in our

byiaws the, and you cou1d 1ook this up and see

it, I hate to go off the cuff in such

references but the genera1 idea of hoiding the

meetings is done in Edmonton except as

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otherwise authorized by the board of directors

and the board of directors set annual general

meetings in a number of other locations some

time ago so as to provide opportunities for

members to have access to the organization.

And certainly providing that access means that

we try to do what we can to make sure people

have that information.

Okay. And you had suggested that it will make

sense to make an appointment?

Yes.

Come back later, what sort of time frame would

you say is reasonable?

I would suggest that that would depend on the

requirements of the office and staff and

everything else that happens at the time, as

well as the ability of the particular director

to be able to come by and see it. It would

kind of be a mutual discussion I would think.

when is good for you, that sort of thing, well

how about this day at this time, you know, a

little bit of back and forth might be able to

resolve such a thing quite easily. I would

think, I don't think that there should be a

need for a micro management of such a thing.

But still are we talking about a week, a

month, two months?

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I think that given the particu1ar request and

the need to have some documents transcribed ortaken from transcription, I think that there,

in some respects there wou1d be a need for

some delay for some of the records, not for

a11 of them.

Now, Miss C1ark says that Miss Fournier had

indicated she wou1d attempt to prepare the

records that afternoon or the fo11owing day,

that's paragraph 7 of Miss C1ark's March 6

affidavit?

But that wou1d be something to ask Miss C1ark

about I guess, if she says that's so I suppose

it's so.

I'm just trying to see whether --

You're questioning me on someone e1se's

affidavit.

That wasn't my question, I was just reading it

out. My question is this, do you think it's

more reasonabIe to have this sort of request

answered within the afternoon or the fo11owing

day, or to wait two months?

I think that it depends on the abi1ities of

the organization to be ab1e to produce the

documents when they have the abi1ity to do so.

If we have to take things from transcript I

think that takes a bit more time. If there's


39

a need to bring in extra staff, we have a very

sma11 office with very few peop1e, we take a

Iot of phone ca11s on a dai1y basis. we have

requirements to be responsive to our

membership and to ensure that their needs are

met, and I think as directors and officers of

the association we have to find our p1ace in

the queue sometimes.

Of course I'm just referring to documents that

are a1ready kept at the registered office.

Yes.

So they're there a1ready, I presume?

But there cou1d be some need to pu11 some out,

Iook at computer fiies, pu11 things together,

this a11 takes time.

How much room do those records take on a

she1f?

we have some of them right here. I think that

the thing, it cou1d be easiiy determined and

gotten to you, I don't have a measure of the

sheif or anything Iike this.

Is it severa1 binders, is it 20 bankers boxes?

we11 we have Iots of bankers boxes I can

assure you.

And those contain what sort of documents?

A11 sorts of records, batching, membership

data. we have, I think I was to1d we produce


40

something Iike, and I couid be incorrect about

this, but something 1ike 20 per year.

But now when I was referring to the documents

that are kept and maintained at the registered

office, the artic1es, the by1aws, the

amendments to the by1aws, the minutes, the

various registers of directors, officers and

members, the accounting records, the minutes,

those, I can't imagine they're kept in bankers

boxes?

No. No, they wouid be bound or on computer

records. The administration of those is not

my purview, the administration is with the

staff at the office. And the abiiity to

determine the staffing needs and so on with

regards to a specific request or demands is

that I think there's a discretion within the

office as to how to best a11ocate time. I

don't micro manage the time of our generai

manager nor of the staff in the office.

And I wasn't asking, so no. I'm just trying

to get at this, these documents are easi1y

identifiabie, you had reviewed them just

recent1y, so I'm just trying to figure out

whether it's not possib1e to simpiy te11

somebody go ahead have a seat and go at it,

here is the records?


MR.

41

I'm not privy to the particu1ar circumstances

in the office on that day at that time when

Miss C1ark came by. But I do understand that

it was a very busy time and there were other

things that were taking priority.

when you reviewed those documents did you have

to wait a Iong time to get access to them, do

you have to make an appointment yourse1f?

Yes, I did.

How far in advance did you make the

appointment?

we11 I think I made it Iast week. when I

found out I was coming to Edmonton.

was there a meeting on March 2nd of the

directors of the association?

March 2nd?

Yes?

HEINTZ: Are you referring to a

particu1ar part of Mr. C1are's affidavit Mr.

Stoyanov, or affidavits?

It does sound fami1iar as a date for a

meeting. I wou1d have to check our minutes to

be sure.

MR. STOYANOV: I'm referring to a document

titied draft minutes of directors

2015.te1econference March 2nd, It shou1d be

in the binder.


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HEINTZ: I just need you to reiate that

to the affidavit that you're questioning on,

sir.

STOYANOV: It relates to the production

of documents.

which paragraph?

STOYANOV: And the abiiity to inspect

documents.

I don't see anything about it in my affidavit.

we11 it's in the affidavit of Ericka Ciark on

March 6th, there's a reference to a board of

directors,

HEINTZ:

that's paragraph 19.

Right, but it's not in Mr. --

That's not in my affidavit.

HEINTZ: In Mr.

STOYANOV:

C1are's affidavit.

That is correct. What is your

objection, I don't understand?

HEINTZ: I was just asking you to refer

the witness to the part of his evidence that

you are questioning him on, that's a11. It's

questioning on affidavit, you're bound to the

four corners of the affidavit.

STOYANOV: Not the four corners.

HEINTZ: It's not a questioning at

iarge Mr. Stoyanov, certainiy you agree with

that.

STOYANOV: we11 it's re1evant because it


43

MR.

MR.

MR.

concerns the events which 1ed to Miss C1ark

trying to attempt to obtain those documents,

so it's very much re1ated to everything.

HEINTZ: It has to be founded in Mr.

C1are's affidavit,

takeoff point for that I'd be obiiged.

STOYANOV: Okay,

then.

so if you can find a

1et's take a few minutes

Off record p1ease.

(OFF RECORD DISCUSSION)

MR. STOYANOV: I just refer you back to that

draft minutes of the directors te1econference

March 2nd, 2015?

Yes.

HEINTZ: He's got it in front of him.

I have it in front of me now.

MR. STOYANOV: During that meeting Dar1ene

MacKenzie proposed and Ericka C1ark seconded a

motion, or severai motions inciuding requiring

the secretary to forward his original notes of

meetings to the board, meetings of the board

and the executive committee to the genera1

manager for distribution of copies to a11

directors?

May I correct you on your --

Yes.

The motion was to add that fo11owing 11st to

the agenda, that's the oniy motion that was


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made by Dariene MacKenzie at that point. And

the motion was defeated.

Okay. How did you vote?

I voted against.

And what was your reasoning for that?

Because I didn't think that that was going to

be productive in what was intended to be a

meeting of moving forward in a positive way.

Especia11y when the first item on the

particuiar thing was to withdraw support for

me as president. It didn't 1ook 1ike

something that was going to be very productive

or he1pfu1 to have a productive meeting. It

was aiso the agenda was set before the

meeting. And I'm not the on1y one that voted

that way, as you can see.

Now. do you aiways stick to the agenda as it

had been prepared in advance of those

meetings?

we try to.

Try to?

Sometimes things come up, sometimes peopie

want to add things to the agenda and they make

a motion to add them and they're accepted or

not. In this case it wasn't accepted.

was it your opinion that Ericka Ciark shou1d

not be permitted to inspect or take copies of


MR.

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45

those records?

I be1ieve I've a1ready answered that.

As far as this motion was concerned was it

simp1y a matter of scheduling the agenda?

that

That

The motion was adding it to the agenda,

has nothing to do with that motion.

wou1d be getting into a discussion of the

points on the motion.

So your voting against it was simp1y a

procedura1 matter?

Yes.

Are you aware that on March 25th, 2015 Ericka

C1ark attended the registered office again to

inspect the register of members?

March 25th you say?

Yes.

Is there some reference to that in my

affidavit there?

HEINTZ: Can I assist to refresh the

witness Mr. Stoyanov?

STOYANOV: P1ease.

HEINTZ: That's the date that Ericka

went to the office after Adam and I had agreed

she cou1d go.

Oh, okay, yes, I understand that that

happened, yes.

MR. STOYANOV: So you had discussions with


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Miss Fournier about Miss C1ark's visit?

I think I probab1y did.

Do you know if Miss Fournier was providing

assistance to Miss C1ark?

I'm sure she was.

Wou1d she ordinari1y be there overseeing?

If she was there at the time. Her hours are

such that she arrives ear1y in the morning and

Ieaves mid afternoon.

HEINTZ: It was arranged between

counse1, it was agreed that she be there.

Yes.

MR. STOYANOV: Now, these records are kept on

the computer I take it?

which records in specific?

The register of members?

Yes.

So how does one get access to it, does Miss

Fournier contro1 the computer?

She is the privacy officer as we11, so she has

responsibi1ity for the custody of members‘

private information. We take members‘

information privacy extreme1y serious1y. we

have an organization by its very nature who

are peopie who tend to be very protective of

their personai privacy and their records, so

we've, we wrote a privacy poiicy, I think in,


47

I'm going to, it's on our web site, the date

of it escapes me but it might have been 2010

or 2009, something 1ike that regarding our

privacy po1icy. So she has custody of that

11st in the office, yes.

So Miss Fournier as she's giving access to the

registered members wou1d be withhoiding

certain information or just providing it?

No, she wouid give her access to everything.

So she wi11 a11ow the person to sit at the

computer and have at it?

Sure, as Tong as it's not making any changes.

You can't be changing things so that's one of

the, certain1y have to supervise that. I

understand that that's what the case was, that

she provided, was ab1e to do that.

Now, we've received some records from the

association, has the association provided

copies to the app1icants of a11 of the

officiai records that it has?

Pardon me, of which specific officia1 records?

We have thousands of records.

I'm referring again to the 1ist that I

referred to ear1ier, the articies, the by1aws,

the amendment to the by1aws, the minutes of

meetings of the members, the debt ob1igations

registry if it exists?


48

MR.

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MR.

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To the best of my know1edge we've met our

requirements to provide a11 information that

was requested.

Let's ta1k about the by1aws.

Pardon me?

Let's ta1k about the by1aws of the

association. we'11 mark this as an exhibit.

HEINTZ: Can I have a Took at it first.

STOYANOV: Certain1y.

HEINTZ: Thanks.

STOYANOV: Ju1y 29, 2013 regarding

changes to the genera1 by1aws.

HEINTZ: No objections here.

[EXHIBIT 1: Letter dated JuTy

29, 2013]

MR. STOYANOV: Now, I'm Tooking aiso at a

draft minutes of the director te1econference

Ju1y 31st, 2013 which I believe refers to

those same changes in the byiaws, there's a

copy of that for your inspection.

Right, yes.

STOYANOV: Cou1d we mark this as Exhibit

2.

HEINTZ: No objection.

[EXHIBIT 2: Draft minutes of the

director teieconference Ju1y

21st, 2013]


MR. STOYANOV:

49

If you cou1d sir, review those

minutes and Iet me know whether that's a fair

representation as far as your recoiiection of

them, of the meeting?

Your question again?

Do those minutes represent a fair, are they

consistent with your reco11ection of what

happened at the meeting?

A They seem to be a fair representation of it,

yes, as best that I can reca11. It's a Iong

time ago.

0 Do they happen to exc1ude any significant

information or actions taken at the Juiy 21st

meeting, 2013?

I don't think they do.

Q Now, did you provide notice, written or

emailed of that meeting to the directors?

A Of this meeting?

0 Yes?

A Yes.

Q Can you undertake to provide that piease?

A If I sti11 have it. I cieaned out my email.

MR. HEINTZ: Best efforts.

[UNDERTAKING N0. 3: To provide a

copy of the notice to the

directors of the Ju1y 21st. 2013

meeting]


A

MR.

50

I try to keep my, 1ike I say I get 1ots of

emaii and my fi1e bui1ds up, and sometimes I

send things from work and they te11 me that I

have too much emaii and things have to be

de1eted.

MR. STOYANOV: I do have an emai1 from Ju1y

30th that re1ates to that meeting, I'm going

to show it to you and hopefu11y enter it as an

exhibit as we11.

Okay. You aiso have the ear1ier one be1ow it

iooks Iike. Or no, that's just a pasting --

oh no, that's the ear1ier thing.

Sorry what is an ear1ier thing?

It Iooks 1ike you have that here just without

the header information. It doesn't have the

date on which it was sent.

A1right.

HEINTZ:

to take a Iook at it.

Can I interrupt, I just want

I just want to know if

the undertaking has been satisfied. we've got

a Ju1y 30th emai1, which is a reminder and at

the bottom of the first page of the document

that I handed the witness it says: He11o, in

accordance with by1aws 26 and 44 I wish to

give notice of a meeting to be he1d on

Ju1y 31st at 6:00 p.m.Wednesday, and so on.

It wou1d appear Mr.


MR.

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51

Stoyanov, I'd appreciate it if you'd confirm

with the witness that that wou1d satisfy

undertaking #3.

STOYANOV: It does appear to reflect some

sort of a notice but I'd 1ike to know what

date that was sent on so if you cou1d piease

find the origina1 emai1.

I'11 do my best to find what we're iooking

for.

HEINTZ: We know what we're 1ooking

for.

MR. STOYANOV: So what brought about the need

to amend the byiaws?

Pardon me?

what brought about the need to make those

amendments?

I beiieve byiaws are a iiving document. One

of the things that came up is that it came to

my intention that we hadn't actua11y sent in

by1aw changes that had been made in 2010 and

that had been sanctioned at a subsequent

meeting of members and that

And

that had just not

been properiy sent in. when I became

aware of that I wanted to make sure that we

took the appropriate steps to make sure that

was done. As we11 we had some other changes

that we needed to do to better try to refiect


52

some of our practices because it became

apparent that some of our practices were in

conf1ict with our by1aws and I could foresee

that there cou1d be difficuities were we to

continue with the practices that wou1d appear

to be not in accordance with the byiaws. So

when that happens in an organization my

experience is that perhaps it's time to make

amendments to the byiaws, so what you do is

you see what you need to do, put it together

and propose it.

And at the time I reca11

be1ieving that there were two processes for

amending by1aws, and one of them was director

driven and the other was member driven. And

that the processes sti11 required a general

approvai of the members but that when you do

it you go through it and get it, you get it

done by going through the directors first.

That's usua11y a pretty good survey as to

whether or not things were happening. I think

the content of them speaks to the

circumstances but I think what we were trying

to do, we were trying to do in iooking at

these by1aw changes was to ref1ect the

practices we were actuaiiy fo11owing to bring

them in Tine with our byiaws.


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So you wou1d change the by1aws to match what

had been practiced?

To what actuai practice is, 1ike in keeping

with the custom issue because it's fine to

adopt a custom but if the custom is in

confiict with the by1aws something needs to

change. Either you drop the custom or you

change the byiaw at some point and that, you

know, that's when it's brought up. For

exampie at an annua1 generai meeting or a

directors meeting if someone says we11, you

know we're actua11y not doing this, we

probab1y shouid 1ook at changing this or we

shouid stop this practice and do something

eise, right, so you try to co11aborative1y

100k for the best practice and soiution.

So --

To act in good faith, to act in fiduciary

responsibiiity of the directors with regards

to the operations of the organization.

You mentioned the director driven process, is

that what you --

Yeah.-- used to get these by1aws amended?

Yeah.

So what is the, sort of the procedure that you

have to fo11ow to do that?


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we1T in our by1aws as they stand there is an

amending process, I think the by1aws are c1ear

on that, I'm sure you're fami1iar with that,

you probab1y had a glance at it. And it does

refer to them at section 44 which is

specifica11y tit1ed the amendment of by1aws,

and it ta1ks about enacting by a majority of

members and then sanctioned by an affirmative

vote.

HEINTZ: I'm just going to interrupt

you Mr. C1ark, because Mr. Stoyanov is Iooking

for the record.

Oh, I'm sorry it wou1d be at paragraph 44

a1most the penu1timate page of the by1aws.

MR. STOYANOV: So these were the by1aws which

were in effect at that time?

These were the by1aws as amended from 2010

which are the current operating by1aws.

You mentioned that you rea1ized that some

documents which had been fi1ed in 2010 or had

which had been created?

we11 they'd be created, voted on, approved by

the members, a1T of the process had been

fo11owed except they hadn't been fi1ed. It

doesn't change their va1idity or anything,

it's a process that's supposed to happen. So

we were taking steps to do that and


55

concurrentiy we thought if we're doing that we

may as we11 Iook at some other things as we11.

Aithough I beiieve we -- we11, 1'11 Iet you

continue.

So fo11owing the Ju1y 31st, 2013 meeting of

the directors?

Right.

Your understanding is that the NFA had

compieted the amendment process in respect to

the by1aws?

We11 no. I understood that we a1so had to

take the byiaws to membership for sanctioning.

They had to be sanctioned at some point. I

think I've got an answer there that Iooks on

the face of it confusing, to question by Phil,

but I think it's probab1y a very pooriy

composed response. It says no they do not.

The bylaw NFA —— it says, the question is: If

we a11 agree on these changes do these have to

go to the members for ratifications. And my

response there, or the response there is no

they do not. In NFA bylaw process we are ab1e

to make changes, we do Iet the members know,

the members have to approve the byiaws in the

generai form, they do have to go to Industry

Canada. we have some by1aws that were made a

few years ago that were never reported to

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Industry Canada and we've been negiigent in

getting those forward. So we were trying to

take corrective action here to correct a

deficiency.

Now, do you know if the 2010 byiaws had been

consented to by the membership?

Yes they were.

Or ratified, okay?

We11 sanctioned I think is the term used in

the byiaws.

Airight.

There's ratified and sanctioned, I suppose

cou1d have different meanings at different

times. I think the by1aw says sanctioned if I

remember correct1y.

HEINTZ: 44.

Is it 44? Yes, that's right, sanctioned by an

affirmative vote of at Ieast two thirds,

that's right. And it says may be enacted by a

majority of directors at the meeting of the

board of directors.

MR. STOYANOV:

1 which is the Ju1y 29th,

there's, back to Exhibit

2013 letter to

Now,

Corporations Canada regarding the amendments,

was that Ietter actua11y sent to Corporations

Canada?

I be1ieve it was. I think the date on it is


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incorrect however.

That was my next question because the meeting

was on Ju1y 31st, correct?

Yes. Si11y to have a meeting that takes piace

before.

Now, this is kind of important, do you reca11,

do you know whether you sent or whether this

1etter was signed prior to Ju1y 31st?

No it was not. It was probabiy signed in

August sometime, but the date on it is

incorrect.

Now, at the very bottom of page two of Exhibit

1.

Exhibit 1?

Yes, that 1etter to Corporations Canada?

Okay, yes.

It says: The amendment was sanctioned by the

members of the corporation in accordance with

the existing byiaws on Ju1y 31st, 2013?

M-hm.

HEINTZ: Say yes or no for the record

piease.

Pardon me, yes,

MR. STOYANOV:

that's what it says.

Did this actua11y happen?

I believe the directors are members of the

corporation. Now was it a fu11 speciai

meeting ca11ed for that purpose, yes. was it


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directors, yes. was it fu11 membership, no,

and I think there's an error in that process.

I see.

Yeah.

Now, back to this Tetter and the question of

when and how it was sent to Corporations

Canada, is there any sort of interna1 record

of when correspondence goes out?

I once tried to create a correspondence 10g

and successive managers have to1d me that has

been prob1ematic for them. I remember when I

was a B.C. director I asked about creating

such a thing, in fact I gave an examp1e that

was back in the '90s and my suggestion was

rejected. But I am not aware that we keep a

correspondence 10g 1ike that.

Do you know how --

Particu1ar1y in the age of emai1 when we have

thousands of emai1s, it just wou1d be an

unwieldy project.

Did you draft the Ietter itse1f?

Pardon me?

Did you draft this 1etter yourse1f?

No. I didn't draft it myse1f, it was, it

wou1d have been drafted for me in the office

and then I wou1d have signed it.

Did anybody e1se review the Tetter before it


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was signed and sent?

It wou1d have just been reviewed in the staff,

I don't be1ieve it was given to anyone e1se to

review. I don't reca11.

Any of the executive or the directors?

No, I don't reca11 that being done.

After it was sent did anybody eise review it

or Iook at it?

Not to my know1edge.

But as far as you were concerned this Ietter

was to inform, Exhibit 1 was to inform

Corporations Canada that the NFA had approved

the amendments?

Yes.

was there a notification to the membership at

Iarge regarding the Ju1y 31st proposed by1aw

amendments?

No, not that I'm aware of. I didn't put one

out myseif.

was the membership notified after?

I'm sorry?

was the, were members notified after the Ju1y

31st, 2013 byiaw amendments?

Notified about them?

Yes, about the change?

They were posted, yes.

On your web site?


60

Yes.

How do you ordinariiy contact your membership

regarding important matters such as --

we have a number of ways. The membership

cou1d be contacted in various ways, not every

one of course has e1ectronic mai1. we have a

varied demographic, some peop1e are on

computer some are not. We do mai1 out, mai1

peop1e for such things, we put notices in the

Canadian Firearms Journa1 which is the

pub1ication of the organization. That's a

coupie of ways in which that can be done. But

it's, you know, we have a fairiy Targe

membership.

Now, back to Exhibit 2, the minutes of the

directors te1econference on Ju1y 31st, the

question by Phi1 regarding the need to have

the members ratify the changes, what were you

basing your sort of opinion on that they do

not need to approve it?

we11 I had an understanding, I didn't have the

by1aws in front of me ironica11y enough when I

was at that meeting, because I was trying to

chair and sitting in front of my, if I reca11

the meeting I was at my home computer at the

time, and it was basica11y a very quick

meeting to dea1 with the one thing, and it


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61

ended up going into a coupie of other points

as we11 that peopie wanted to add. And I was

asked the question, I thought we11 there's

these two processes and I think I was wrong in

my, in part of my answer when I gave the

answer.

which part was the wrong one, sorry?

The initiai thing, no they are not. But I'm

a1so cognizant of the word sanctioned and

ratification are different and I think that

probably threw me off when I gave my answer,

if that's a fu11 response to it. I think

there was a nuance there about it. My

understanding of the by1aws at the time was

that the directors cou1d make changes to the

by1aws without having them ratified because

ratifying isn't in the by1aw, it says

sanctioning.

Sometime iater when I guess you wrote to

Corporations Canada, and again I'm referring

to the 1ast page of your Ju1y 29th, 2013

letter, which may have been sent at a iater

date, it says the minutes was sanctioned by

the members of the corporation. I just want

to confirm that by that you meant the members

meaning a11 of the members of the corporation?

I think part of the confusion is that some of


62

these were sanctioned and some of these were

not. Because not a11 of these were made in

2013. The thing is the one about members

meetings at the top was done at a much ear1ier

meeting, I think back in 2010 at the annua1

genera1 meeting and it was sanctioned by the

members.

Now, did you at some point rea1ize or

understand that the 2013 amendments hadn't

been sanctioned or --

Yes, and this is where I be1ieve I was in

error.

when did you come to that rea1ization?

Quite some time after actua11y. I think this

year in Iooking in it, reviewing the by1aws

and rea1izing that change when peop1e started

ta1king about amending by1aws and such. One

of the things about by1aws is nobody rea11y

Iooks at them very much un1ess there appears

to be some kind of a prob1em.

But sometime after that meeting when exact1y?

I'm not sure exact1y when. I came to the

rea1ization probab1y ear1ier this year.

Did you take any steps to address a potentia1

issue or prob1em?

We11 I think --

Arising from that?


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63

You know what, I'm wrong, I came to that

reaiization before the Iast annuai, or the

annuai genera1 meeting I think the year after.

that which wou1d be 2014, and we intended to

at the

that didn't happen

have that raised as an item on the,

members meeting. However,

and I think,

for that,

you know, I take responsibiiity

and a11 the directors take

ofresponsibiiity for that. we had a number

very busy things happening at the meeting and

I remember my whip, the generai manager

te11ing me we don't have time, we need to keep

moving, get moving. And that particuiar

important matter didn't get brought up to be

corrected at that point.

Now, did you actua11y get approval from the

minister of the changes?

I beiieve we did.

Did you get a notice of any sort?

I beiieve we did. I think I was notified of

that, I'm not sure.

Couid I get a copy?

HEINTZ: I beiieve it's in here.

Then again we were trying to correct our

fiawed process in the best interests of moving

things forward in good faith, with the

interests of the organization, and without


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64

causing any harm.

HEINTZ: Are we off?

STOYANOV: Sure.


STOYANOV: P1ease provide an undertaking

to provide the ministeria1 approva1 from

Corporations Canada of the July 29th, 2015

by1aw amendments.

HEINTZ: Yes, if it exists we'11 find

it.

[UNDERTAKING N0. 4: To provide

the ministeria1 approva1 from

Corporations Canada of the Ju1y

29, 2015 by1aw amendments]

MR. STOYANOV: Alright. Now, you had

mentioned ear1ier, you sort of tried to

correct yourse1f that you actua11y had

rea1ized that there may have been an issue in

2014?

Yes, because I wanted to make sure we

corrected ourse1ves and put ourse1ves back

into good order, because we weren't in good

order prior, so that it cou1d be done at the

annua1 genera1 meeting. But there were a very

fu11 agenda, very fu11 p1ate. This was an

important thing, it shou1d have been done and

I as the presiding officer certain1y shouTd


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have been driving that process. But I was

being pu11ed in many directions and

unfortunateiy it just s1ipped my mind.

were there any communications among you and

directors or the executive regarding that

deficiency?

I'm sure there must have been but I can't

reca11 anything specific.

Anything in writing, emaiis, ietters?

Probab1y phone ca11s.

So no ietters, no emaiis?

I can have a 100k and see if I have anything.

Can you piease undertake to 100k for any

communication in 2014 regarding the fact that

the membership hadn't sanctioned the changes

to the byiaws?

HEINTZ: Yes, sir.

[UNDERTAKING N0. 5: To 100k for

any communication in 2014

regarding the fact that the

membership hadn't sanctioned the

changes to the byiaws]

MR. STOYANOV: Now, according to the records

of Corporation Canada this here is the current

version of the byiaws of the association. Can

you confirm that?

I wou1d say that that is not correct. Or hang


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66

on. Hang on a second, 1et me review this

before I --

Oh piease.

Right, That's

I wou1d say that this wouid not

I was reading the wrong thing.

correct. No,

be the correct version at present.

HEINTZ: That wasn't the question.

Sorry, what was the question again?

COURT REPORTER:

uQ_

of Corporation Canada this here

(By reading)

Now, according to the records

is the current version of the

by1aws of the association. Can

you confirm that?"

I wou1d say no.

MR. STOYANOV: And what makes you say that?

Weii given the need for sanctioning some byiaw

changes this ref1ects a11 of these changes as

having been made, and if, in terms of if

they're not made then this is not the correct

version.

HEINTZ: But the preamble to the

question was according to the records.

I'm sure, we11 I don't have responsibiiity for

the records of Industry Canada but this is,

this wou1d need to be updated to the 2010

I believe,status, in my opinion.


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67

STOYANOV: Can we enter as an exhibit

piease.

HEINTZ: Is that the same document that

I just put in front of him, sir?

STOYANOV: Yes it is, the by1aws.

HEINTZ: No objection.

[EXHIBIT 3: By1aws received from

Corporations Canada]

MR. STOYANOV: There's a time stamp at the

bottom of the document on the first page of

Exhibit 3.

M-hm.

Do you know what that refers to?

I have no idea. I suspect that's an Industry

Canada time stamp.

would you agree that's when it was received by

Industry Canada?

I have no idea when Industry Canada received

it.

when did you send this document to Industry

Canada or Corporations Canada?

Ne11

change but I don't know when this particuiar

It's,

it wou1d have been sent subsequent to the

one was sent. I wou1d suspect it was

sent after our directors meeting in Ju1y that

we were referring to ear1ier.

Wouid you be ab1e to undertake to 100k for the


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68

emai1 dated Ju1y 16th, 2014 sending this

document to Corporations Canada?

Sure.

I'm quite certain that that time stamp refersto when it was received by Corporations

Canada?

HEINTZ: Can we 1ay a 1itt1e more

foundation to the undertaking? It's based on

the assumption that there was an emaii from

the NFA, right?

STOYANOV: Indeed.

HEINTZ: So we'd be iooking for an

emaii from the NFA dated 2014. 07-16, right

Mr. Stoyanov?

STOYANOV: That's correct.

HEINTZ: That's what you're thinking is

the way it worked?

STOYANOV:

HEINTZ:

Yes.

Sure, we'11 make an

undertaking to 1ook for that.

STOYANOV: Thank you.

[UNDERTAKING N0. 6: To search

for an emaii from the NFA dated

2014, 07-16]

MR. STOYANOV: Now, the association prepares

comparative financiai statements on an annuai

basis; is that correct?


69

Yes. we do more than that, I mean we have

month1y financia1 statements, the treasurer

communicates regu1ar1y with the bookkeeper and

with the rest of the directors about the

status of our finances.

And those statements shouid ref1ect fair1y the

financia1 position of the association during

the particu1ar fiscai period in question?

Yes.

And the cash f1ows for the year that ended in

accordance with accepted Canadian accounting

standards?

General accepted Canadian accounting

practices, yes.

Are there any gaps in the records as far as

those financia1 statements are concerned, that

you're aware of?

No, not as Iong as I've been president.

Prior to that?

I a1ready discussed that with you or pointed

out that we do have some records missing from

years previous which we be1ieve were removed

from our possession by disgrunt1ed emp1oyees.

Now, when accountants prepare these documents

they go through certain procedures to ensure

that everything is correct I wou1d imagine,

there's three 1eve1s of assurance 1et's ca11


70

it, notice to reader, compiiation of

statements and a review engagement?

Yes. I understand that to be the case.

Right, and then aiso an audit engagement as

weii?

Yes.

which of these provides the most assurance as

to the correctness of the finances statements?

We11 I'm not an accountant so I don't have

expertise in that particuiar fieid. So I'm

not sure I'm best quaiified to answer that

question.

Do you agree that audit is probabiy the Iatest

and best step to ensure correctness?

I think there are different gradations of

audit but yes I think auditing is a good way

to ensure good practices, yes.

Now, who are the individuais in charge of

preparing these financiai statements?

The treasurer and the bookkeeper put them

together and they become owned by the

directors and the members at the annua1

generai meeting.

And you have a chartered accountant firm that

you retain to assist with that as we11?

Yes, we have an annuai financiai review done

or have had an annuai financiai review done of


71

a1] of our records since 2010.

who is that?

The name of the firm that we presentiy use or

have used for that purpose is Davidow and

Neison LLP.

Now, were they invoived in performing a1so an

audit?

The direction of the membership in 2010, the

direction of the directors from that period

forward has aiways been to do a financia1

review rather than a fu11 audit. This is

primariiy because of the high cost. One of

the things with adopting new by1aws is

sometimes peopie don't Took at the financiai

status of the organization and see if you

cou1d actua11y afford to do what you say

you're going to do.

was there any Tegai obligation to get an

actuai audit done?

The byiaws require an audit. The practice or

custom that was deve1oped was as approved by

the members at every annua1 genera1 meeting

since was to accept the unaudited financiai

review. I be1ieve this has been expiained

quite abiy by our treasurer at every AGM.

So it's just a matter of custom then that you

didn't fo11ow the byiaw requirements to get an


72

audit?

when you say you, do you mean the Nationai

Firearms Association or do you mean Sheidon

C1are?

Yes, the association?

It became a matter of importance for the

association to ensure that we were putting acheck upon our staff by having an accountant

go over our figures to see that we were

fo11owing genera11y accepted accounting

princip1es. And at a time as accepted by

membership and endorsed by the directors the

idea was that when we cou1d afford to do anaudit, and when that, or if we had an ink1ing

that there was any kind of probiem as raised

by our accountant then that wou1d be what we

wouid do. This became our custom.

Did any of the members or directors or the

executive express concern or a desire to

actua11y have a fu11 b1own audit?

when the practice was started we had a very,

we had discussions about that but everyone has

been perfectiy fine with the process as we

fo11owed up unti1 this year.

To your knowiedge did any members, officers ordirectors request or demand that the NFA

appoint an auditor or pub1ic accountant?


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Not unti1 this year.

And when was that?

That wou1d have been at the time when the

some of the directors

I think

directors requested,

were requesting that information,

that's in some of the documents before us. It

wou1d be around, after Mr. Bevens was

terminated.

I understand that you did take steps to

actua11y engage an auditor?

Right away. I we1come audits.

Sorry?

I we1come audits.

when did that actua11y happen, what date?

I cou1d find you the date.

Wou1d you p1ease?

I suppose, but I don't know off the top of my

head.

would you undertake to --

Because it was, I reca11 directing our genera1

manager to find some quotations and I did

distribute an email to directors when she had

provided me with some quotations about

auditors. And from my perspective, given the

nature of the current dispute between

directors and given some of the accusations

that have been f1ying around I wanted to


74

ensure that this was done properiy with a

reputab1e firm, and to go back as far as the

accountant was wi11ing to do to make sure that

we were fo11owing due process in a11 of our

accounting procedures, that we were acting

within our fiduciary responsibiiities, that

there was no maifeasance, no impropriety, and

that we were engaged in the best interests of

the organization, directors, the executive,

staff, and everyone e1se ensuring that we were

providing fu11 and open records.

You mentioned you emai1ed the directors or the

executive with different quotes from a variety

of firms?

Yes, and has been the practice for some

pressing issues, I soiicited votes on the

matter from them.

So there was an actua1 meeting that authorized

the appointment of the auditor?

The, there was not a meeting, there was an

emaii request for voting on the matter. The

proposition was put forward as a motion.

We've frequentiy done votes 1ike that. For

examp1e when we were proposing that a

biathiete be accepted as sponsored by the NFA,

which is I think a $2,500 a year provision we

put out a request to the directors whether or


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75

not they supported that or not. And that was

unanimousiy supported by the directors in the

same sort of voting pattern.

Can you provide us with some record of that

voting by emaii or whatever other means it

took?

Sure, I think that's pretty easy to do. I

think some of the directors responded by

te1ephone ca11 so I may not have a written

response from them, but others responded by

emai1.

Your best efforts?

HEINTZ: Sure. Can we just go back

over the 1ast two, I don't think the iast

undertaking was c1ear, it was to advise of the

date the auditors were engaged in the spring

of 2015, right?

STOYANOV:

[UNDERTAKING N0. 7:

Yes.

To advise as

to the date the auditors were

engaged in the spring of 2015]

HEINTZ: And then this 1ast one,

provide.

Evidence of voting.

STOYANOV: Record of voting regarding the

appointment of the auditor.

HEINTZ: Thanks.


MR.

76


records of voting reiating to the

appointment of the auditor]

There were no response from five directors,

probabiy on the advice of counse1 I wouid

conjecture.

MR. STOYANOV:

Okay.

The appointment was authorized by the

I won't ask which five.

directors then?

We11 yes, given when one asks for a vote and

you receive positive votes from a11 of the

executive and one director and you ask, and

the other directors don't respond, that's

taken in that sort of voting as an abstention.

An abstention doesn't defeat a motion.

To go back to the undertaking regarding the

votes, I wou1d a1so 1ike to have the initia1

emaii to which they responded, the one

mentioning the various quotes?

Yes, I'm sure we have that.

HEINTZ: Okay.


the emai1 sent regarding the

various quotes]

Certain1y you wou1d have some directors who

wou1d have that as we11.


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MR. STOYANOV: when you retain an accountant

or an auditor there's ordinari1y a retainer or

an engagement ietter of some sort?

Yes.

Did you get one in this case as we11?

Yes.

May I have a copy of that please, as an

undertaking?

Certainiy.

HEINTZ: Yes.



a copy of the engagement Ietter

with the auditor]

MR. STOYANOV: I'm going to refer you to your

affidavit of March 19th, 2015.

I have it in front of me.

Just to get some c1arification regarding some

of the things to which you deposed, has this

been fi1ed with the court yet?

HEINTZ: Yes it has, March 31st. My

apoiogies if I haven't provided you with a

fiied copy.

STOYANOV: Same question regarding the

affidavit of Apri1 23rd, has it been fi1ed?

HEINTZ: I don't think that one has

yet, Martin.


MR.

MR.

MR.

MR.

MR.

78

STOYANOV: would you undertake to do

that?

HEINTZ: I already have.

STOYANOV: Okay.

HEINTZ: And I previously agreed that

it could be used during our application on my

undertaking to provide you with a filed copy.MR. STOYANOV: So back to the March 19thaffidavit, paragraph 33, it says: I make this

my affidavit in opposition to the withinapplication. I'm just trying to figure out

whether in this case you were speaking on yourown behalf or on behalf of the association?

On behalf of the association.

Do you personally believe that this, did youpersonally oppose this application as well?

which application?

HEINTZ: Well we have to clarify

because there's part of the application that

deals with the compliance with section 21 ofthe Canada Not For Profit Corporations Act and

another part of the application that requestsa restraining order against Mr. Clare

personally, and then another part of theapplication that requires a clarification of

Butthe bylaw issue, if I can use that term.

the bylaw issue has already been addressed as


MR.

0

A

THE COURT REPORTER:

79

between Mr. Knise1y and I, so that Teaves the

comp1iance with section 21 which we take the

position has been comp1ied with, and the

restraining order against Mr. C1are which is

objected to.

Yes.

STOYANOV: Okay.

And on what basis does the association object

to this app1ication?

Cou1d you --

what is the basis of the opposition to this

app1ication?

The, may I see the app1ication?

Certainiy.

Okay, give me a moment.

this.

I just want to review

Certainiy.

wou1d you read the question back again p1ease.

(By reading)

"0. And on what basis does the

association object to this

app1ication?"

We11 there are a number of basis for the

opposition to this app1ication, I beiieve I

referred to them in my affidavit, you're I

I think there arethink aware of those bases.

a number of them and 1et's_go through a short


80

Iist, notwithstanding that there may be other

matters that wou1d raise opposition to this

appiication business that I may not consider

fu11y in my answer, it may have reasons to

oppose. But certainiy the registry of members

does contain the information required by law.

This is referred to in 9.2, I dispute that.

The number 14, the association does keep

minutes of meetings of members, directors of

it's committees, the fact that these minutes

may not be, we11 I dispute this. The absent

rectification, I dispute that the appiicants

are significant1y hindered in their abiiity todischarge their responsibiiities associated

with their office, at 15. I dispute that wehave fai1ed to notify the director of

Corporations Canada about our composition of

our board of directors, we've certainly done

that. I dispute that I have disseminated

among the officers, Teadership, and members

faise and misieading statements. there was,

that's addressed in my affidavit, the intent

of that, I think this particu1ar

characterization of mine is not the same as myresponse. I dispute that the app1icants have

not committed any unethica1 behavior, I

be1ieve they have. The hoiding of a by


81

eiection is dependent on suitab1e candidates

coming forward, we have not had that

circumstance happen. One of the probiems with

our organization genera11y has been finding

good peopie to run, and often seats have been

vacant for 1ong period of time. So

occasionaiiy we have peop1e express interest

but they don't come up with the necessary

requirements, nomination papers, so on and

that does preclude peop1e from running. The

byiaws are c1ear on that particuiar

circumstance.

I dispute that the

appiicants have attempted to address the

foregoing matters of the board of directors of

the association and we faiied to act. I think

that what I saw was an attempt at a coup in

fact, rather than any attempt to engage in

diaiogue in a responsib1e way showing duty to

care or a concern about the ro1es of

governance or fiduciary responsibiiity. I

dispute that there's been any interest in that

by the app1icants, despite some of their

c1aims to the contrary.

I beiieve we've met the

remedies that are required in here. Some of

these points about the auditor of the


82

association, we attempted to have auditing

done for the fu11 period of time, however, the

auditors would on1y do the previous two yearsand insisted that that wou1d be more thansufficient to meet any of our needs. Theorder restraining me, I find that to be rea11y

just an offensive idea that it wouid be

I think that has been addressed,

About

continued,

that particuiar issue. disseminating

faise statements, I don't think I've made any

faise statements. I had particu1ar

impressions, I refer to them in my affidavit,

you have that before you. But I think that'ssufficient grounds to oppose this appiication.

Now, just to go back to --

Notwithstanding that there may be others.

Just to go back to what you just said about

the auditors te11ing you that on1y two years

worth of audits are necessary in this case?we11 the --

HEINTZ: Let Mr. Stoyanov finish his

question, Mr. Reporter can't get you both at

the same time.

I'm sorry,

MR. STOYANOVI

piease continue.

So the audits are on1y going

to take piace for the years ending 2014 and

2013, is that what you're trying to te11 me?


83

That's my understanding, yes. In my

discussions with regards to that is that the

audit, they didn't see any need to go back any

further than that to meet the requirements of

having a thorough examination done of our

records. I understand actua11y that they have

gone back further into our records than that

but I'm not an auditor so I'm not sure what

they actua11y did.

Wi11 that be refiected in the engagement

Ietter which we had referred to ear1ier?

I think so, yes. I beiieve that wou1d be the

case. My understanding is that the audit is

in its very fina1 stages and we're awaiting a

report.

What were your instructions initia11y to the

auditors, what did you request them to provide

you a quote for?

I wanted them to go back as far back as they

couid and to try to do three years I be1ieve

is what I had indicated to them. Given the

point that we wanted to make sure that we

were, this audit is out of synch as it were

with the byiaws, it's not one that's been

directed by the membership or assigned by the

membership at an annuai genera1 meeting, the

auditor was not named there but it's within


MR.

MR.

84

the fiduciary responsibility of the executive

given the current division of the board of

directors to get this done, to make sure that

everything can be seen to be transparent,

above board and operating in good faith within

the interests of the organization and its

membership.

Alright.

March 19th by you,

Now back to the affidavit sworn

paragraph two refers to

certain purported or supposed directors

meetings on February 24th, 2015. Can you give

me some background as to your use of these

adjectives to describe those meetings?

Adjectives to describe the meetings?

Purported and supposed?

HEINTZ: Just to be fair to the witness

I think there's an a11egation that there was

one meeting Mr. Stoyanov.

STOYANOV: Yes, the February 24th

meeting.

HEINTZ: Thanks, 2015.

We11 I don't be1ieve that there was a du1y

constituted meeting at that time, despite the

best efforts of that group which decided to

and as I characterized it ear1ier,

But I think that that's been --

convene,

ho1d a coup.

there's, if you read my statement it's right


85

there in the affidavit, in my opinion it's

dishonest and mis1eading due to its fai1ure to

disciose the fact that the app1icants herein

purported to ho1d a directors meeting on

February 24th, 2015 at which inter a1ia they

purported to depose the current duiy appointed

executive, shouid be du1y e1ected frankiy, and

that they then primariiy via socia1 media

mis1ed the membership of the National Firearms

Association by propounding the Iegitimacy of

the supposed board meet ing. I be1ieve that

to have been a high1y inappropriate response,

highiy emotiona11y based, high1y irregu1ar and

far beyond any interests of the organization.

In fact I be1ieve it to have been

reprehensibIe.

Emotions and motives aside, what in particu1ar

about the manner of this meeting was ca11ed,

was not Iegitimate?

We11 there had been a meeting origina11y

ca11ed and the meeting had been cance11ed.

By whom?

By me as the presiding officer and the person

who set the meeting initia11y. It's a common

practice for us to change meetings when some

peop1e indicate they aren't avai1ab1e. And

again, the agenda and the need to discuss the


MR.

86

circumstances with Mr. Bevens with everyone I

fe1t it was important to make sure that everydirector was present. And that was made

apparent to me it was not the case that

everyone cou1d be present, or at Teast fu11yparticipate.

Is there a requirement that there's a fu11quorum, that a11 the directors are present for

a meeting to be du1y constituted?

The importance of the meeting I beiieved to

have been of such importance that I thought itwas necessary that a11 be there. And since

a11 cou1d not be there I decided to change themeeting to a time when they couid be, which

was way1aid by the fact that some fo1ks

decided to get together and have a chatoutside of the due process.

And the decision to cancei that meeting wasyours and yours aione?

Yes.

How did you communicate it to the --

By e1ectronic mai1 as has been the practice.HEINTZ: It's Exhibit C to the

affidavit you're examining him on right now,sir.

Yes. You have it before you?

MR. STOYANOV: Yes.


87

MR.

MR.

Do you want me to read it out?

No, that's okay, thank you. Turning to

paragraph D of the same affidavit.

Paragraph?

D as in David, the March 19th affidavit.

Okay, Exhibit D, yes. Not a document I

produced.

Okay --

Ciaude Colgan, who was purporting to be the

president of the Nationai Firearms Association

produced that document, based on the coup

attempt of the meeting the day before.

Okay.

is that

And so your opinion of this memorandum

it is --

Of no force and effect, and void, u1tra vires.

HEINTZ:

STOYANOV:

Just answer the question.

Thank you. You in essence

finished my question for me and I appreciate

that.

I'11 try not to do it again.

Now,

March 19th you state that:

in paragraph 11 of your affidavit of

Ericka Clark has

attached my emai1 ca11ing the meeting but she

has not attached my emai1 cance11ing the

meeting. I consider these antics to be artfui

and mis1eading on the part of Miss C1ark. Can

you e1aborate on that?


MR.

88

Neil I think it's in effect misieading by not

providing a11 the information, not engaging in

fu11 disciosure.

Paragraph 12 of the March 19th affidavit:

Miss C1ark to my personai know1edge pubiished

the minutes referred to above on socia1 media

including the NFA Facebook page. What do you

base this know1edge on?

The Ietter Exhibit D indicates that, pardon

me, that's not the correct exhibit, the

minutes.

HEINTZ: Probabiy E.

Yes, the minutes of the meeting at Exhibit E

contain a number of directions and votes and

so on, again which I regard to not be of any

force or effect, but were acted upon by these

individuais. To, where is it here, towards

the end.

Oh yes.

At H: Be it resoived that the president,

meaning at that point C1aude Coigan. is

instructed by the board of directors to

immediate1y take steps to secure the property

of the association inc1uding without

Iimitation the association's financia1

records andaccounts, social media accounts.

data. And at the time of the meeting I reca11


89

doing some maintenance on the social media

pages and I was engaged in a conversation by

Miss C1ark on a Facebook chat, which was quite

unusua1, because it hadn't happened, before

and concurrent with my conversation I was

removed as an administrator from the socia1

media pages and the said minutes and so on

were put up very, you know, short1y after I

was removed from administrative capabi1ity, as

were a11 of the du1y constituted

administrators, or most of them, and in effect

that directive was acted upon. So I regard

that Miss C1ark and others associated with her

enab1ed that to happen.

Alright. Turning to paragraph 13 of that same

affidavit, March 19th, 2015, you had made a

statement or you began disseminating the

statement that Miss C1ark and Dar1ene

MacKenzie had been removed as directors for

unethica1 behavior. what steps did you take

to inform anyone that Ericka C1ark and Dar1ene

MacKenzie were not directors of the

association or that they had committed

unethica1 behavior?

I think the on1y thing I did is I sent them

each a message that in my opinion they had

removed themse1ves by their unethica1


90

behavior. I think you have a copy of that

particuiar screen shot. And whi1e I was sti11

a member, or was a member of one of the

administrative pages I posted a copy of that

there, and I don't reca11 doing very much

eise. These wouid have been highiy Iimited.

Now, as far as the association is concerned at

the present time are Ericka Ciark and Darlene

MacKenzie directors?

Yes.

They are. So they were so to speak

reinstated?

I sought -- no, I don't think they were ever

removed. I think that I reacted in a very,

we11 I reacted based on what had happened with

some anger and emotion and I think I was

probabiy mistaken at that point in time as to

my interpretation of the byiaws. But I sought

1ega1 advice to make sure that I couid be seen

to be acting in a11 due care and fiduciary

responsibility, in good faith and in the best

interests of the organization.

were any steps taken or any consuitations done

with the executive and the board regarding the

remova1 of Ericka C1ark or Dariene MacKenzie?

No. I don't think we've had any discussions,

or had any discussions at that time about


91

that. There was certainiy some discussion

about unethicai behavior and that effect upon

their status.

And was there any confirmation issued

foiiowing your eariier statement that they

have removed themseives, in essence was there

any confirmation that they were in fact

directors regardiess of that prior statement?

Yes there was. we posted and distributed

fairiy wide1y I think, much more wideiy than

anything e1se was posted, a copy of our iegai

opinion of our so1icitor in the matter which

was accepted by the executive and so on as

being the case. I presume it was a1so

accepted by the concerned directors.

In paragraph 15 you say that the theme of Miss

C1ark's affidavit is that the NFA is being

mismanaged?

Yes. we11 in particuiar, we11 sorry, do you

want to finish your question?

That's okay. where in her affidavit does she

say that, or what in her affidavits are you

referring to when you make that statement?

we11 1et‘s have a 100k at it here and I think

this is the affidavit of March 6th, and I

think what it is is the generai fiavor of the

affidavit goes after 1ots of minutia of


92

process and procedure. demands for documents,

demands for information, status of directors.

The attachments ta1k about the status of the

executive, the status, my status as president,

in particu1ar the comments made, if you wish Ican go through a number of paragraphs here.

we11 the who1e f1avor of the affidavit is

resp1endent with such tone that imp1y that

there's a beTief that the executive and the

president are not managing the organization

we11. I mean the efforts of the group to ho1d

a coup is I think se1f-evident, the minutes of

that are attached to her affidavit.

You have acknow1edged today that there are

some significant issues with respect to the

bylaws being amended proper1y?

Oh, I free1y acknow1edge that there's a

concern with this. I don't think that that

represents significant mismanagement.

And that a1though the by1aws require that

audits be conducted on an annua1 basis those

hadn't been done for probab1y decades?

we11 the by1aws that are in p1ace from 2010

are not the same by1aws that were in piace

before that.

Fair enough.

I think that the byiaws that were in p1ace


93

before that did not have the same

requirements.

Okay.

But I'm not, we're not here to discuss that

but your characterization of it being decades

I don't think is quite accurate.

So the requisite audits for the past severa1

years hadn't been conducted?

No. And again I referred you to the issue of

custom, even in conf1ict with a particu1ar

aspect Roberts Ru1es is referred to in our

by1aws and it does discuss custom and its

ro1e, and when custom is cha11enged how it

dies and fades away unti1 it's corrected.

Does custom trump the written by1aws?

we11 no, that's the point. What does trump

though, it's things Iike suspension of ru1es

and so on, is the fact that the membership was

apprise of this and supported the practice by

accepting these unaudited statements at each

annua1 genera1 meeting. And if you Iook,

again I read out the practice of custom and I

don't need to read it again I don't be1ieve,

but when the custom becomes something that's

cha11enged certain1y then one must take steps

to put things in order, and I be1ieve that

we've acted in the best interests of the


94

organization to make sure that that practice,

the practice of having audits is put back in

piace. And by having an audit immediateiy

upon the raising of the concern, trying to

correct that, I think we've acted in good

faith with the best interests of the

organization and in keeping with the fiduciary

responsibiiities of the directors. The simpie

fact of the matter is whether there is any

harm, and I don't think there is any harm to

the organization by this particu1ar faiiure.

The situation doesn't change the effect of any

decisions made or anything that's been done.

There's no harm. The harm is happened by the

inabiiity of some to work coiiaborativeiy to

come to a common resoiution of common

prob1ems.

How wouid you know if no harm was done if

there was no audits to the finances of the

organization?

when I have the fu11 record from the auditors

1'11 be happy to discuss that with you

further.

That wi11 be in the future. right?

Yes. I am, if I was aware of any harm then I

wou1d be certain to be bringing it up, but I

am not.


DID-03>

D?-*D>

95

Now, turning to paragraphs 24, 28 of your

affidavit deaiing with the termination of Sean

Bevens?

Yes.

Is there any reiationship between the

termination and the duty of the NFA to for

exampie prepare and maintain officiai records

at its registered office?

No.

Anything to do with the abiiity of the

directors to inspect its records at its

registered office?

No.

To permit them to take copies of those

records?

No.

To e1ect or appoint a pubiic accountant?

No.

Or to cause a financiai statement to be

audited?

No.

To disciose that audit to the members?

No.

Prior to being terminated Sean Bevens was the

executive vice president of the association?

Not in the same status as imp1ied in the

byiaws, aithough the byiaws were intended to



96

try to address his particuiar circumstances.

He was basica11y an empioyee engaged to iobby

and to provide business advice. I think I

discussed that in my materiais.

Now, wouid his appointment and termination be

ref1ected within the register of officers of

the association?

No. Given that he, aithough tit1ed as an

officer and having certain trappings thereof,

I think I've discussed this in here as we11,

he in effect is an emp1oyee with a tit1e to

he1p open some doors, or was an empioyee.

You wou1d agree that after he was terminated

there was a controversy among the membership

as to whether or not a resoTution of two

thirds of the NFA's directors was required to

remove him as an officer?

Oh, I'm aware of a controversy that's been

generated by some directors who were unhappy

with this decision, yes.

And your position in generai terms, your

persona1 position is that the director

approva1 was not required in this case?

The position of the Nationai Firearms

Association, and my position is that the board

of directors gave me, as president and chief

executive officer, they assigned me this


97

particu1ar ro1e, the authority to hire and

discip1ine and supervise Mr. Bevens a1ong with

Ms. Fournier who have an administrative ro1e

and supervision. That is very very c1ear1y

intended to inc1ude a11 aspects of discip1ine

which inc1udes everything that was done and

reported to the board of directors on severa1

occasions. That inc1udes the various, the

written Tetters of reprimand, one of them

based on his participation in a directors

meeting whi1e he was drunk in which the board

of directors were present and heard it. Now

some of the directors who are current1y

directors were not directors at that time and

operationa1 matters such as cautions and

warnings are not necessari1y things that are

in the governance role of a board of

directors. They don't need to know about that

except perhaps in genera1 terms. But when

there are, it's basica11y what it is is you

engage in the discip1ine, then you report the

discipline to the directors is how I see it.

That has been the practice that we fo11owed in

keeping with the ro1e that I was assigned in

supervising Mr. Bevens when he was hired.

I'm sti11 a 1itt1e confused about his

appointment and why it wasn't done in the


MR.

MR.

MR.

MR.

98

ordinary manner where the board has to approve

it or the directors have to vote or e1ect him?

He wasn't e1ected, he's not that kind of an

officer. The on1y ones that get to be eiected

are people who are directors. The by1aws arec1ear about this. His particu1ar ro1e was an

emp1oyee, he was a saTaried emp1oyee. He wasgiven a tit1e to enab1e him to do a particu1ar

job. The supervision of that empToyee was

assigned to me, at a11 phases of that.

was that part of the by1aw amendments?

No.

I think I refer to that,

That was done at a directors meeting and

on May 8th, 2013,

that's at point 26 in my affidavit.

KNISELY: Can we go off the record.


(BRIEF ADJOURNMENT)

MR. STOYANOV: So would you undertake to

provide to us a copy of the?

HEINTZ: Minute of the directors

meeting referred to in paragraph 26 of Mr.

C1are's March 19th affidavit?

STOYANOV: Right.

HEINTZ: Yes,

[UNDERTAKING N0.

sir.

11: To provide

a copy of minute of the directors

meeting referred to in paragraph


99

26 of Mr. C1are's March 19th

affidavit]

MR. STOYANOV: Now, wou1d you agree that

without the abi1ity to inspect the

association's officiai documents and minutes

there wouid be no way for the appiicants to

know why -- sorry, there wou1d be no way for

the appiicants to know who the executive of

the association was and whether or not they

were appointed?

Eiected.

Eiected, and whether or not that eiection was

Iawfui?

No, I wou1d not agree with that. I think that

they had fu11 access to that information, it's

pub1ished and we11 known and I beiieve that

that information was of common knowledge.

What information are you referring to

specifica11y?

The director, the members of the executive,

who they were and it's pubiished in our

journai, comes out every coup1e of months, I

think that it's common know1edge.

But are the under1ying motions and meetings,

are those avai1ab1e pub1ica11y as we11?

The motions, pub1ic1y, no. But they are

avai1ab1e to the directors.


MR.

100

For inspection?

Yes. As I discussed.

The way Miss Ciark tried to go and 100k at

those in ear1y March?

Ne11 I think we've ta1ked about how Miss Ciark

did that and I pointed out and you've got my

response to that on, in my affidavit on page

two at paragraph, we11 section A paragraphs

three through to seven.

HEINTZ: Here's your opportunity

opportunity to actuaiiy give that evidence Mr.

Ciare.

Okay. we11 I think that it's pretty ciear

that that information is avaiiabie, it was

we11 known. They have participated in

meetings with the members of the board of

we're we11 aware of who was

If they had a

directors,

presiding at the meeting.

question about that they're more than weicome

to ask, if there's some sort of concern or

probiem that couid have been easiiy raised but

instead what we saw were these ambush type

events, attending at the office at times when

other things are underway, rushing in, making

demands. And this is not good business

practice to be engaging in, this is not the

kind of behavior one expects of a director who


101

MR.

MR.

MR.

HR.

is concerned with fiduciary responsibi1ity,

it's the kind of thing one expects that's

consistent with the peop1e who engaged in this

coup.

Now the question was how wou1d Miss C1ark know

whether or not the members of the executive

were eiected proper1y?

She cou1d ask.

without reviewing the documents that she was

seeking in March?

we11 I think as I said that information is

genera11y avai1ab1e to Miss C1ark shou1d she

have chosen to ask for it before causing a big

probiem.

A big probiem meaning what?

HEINTZ: To be fair to the witness Mr.

Stoyanov, I think in essence your question is

how wou1d she know if these corporate actions

had taken piace if she cou1dn't review the

minutes.

STOYANOV: Correct.

HEINTZ: Is that being fair to you?

Oh, I see.

HEINTZ: And he's obviousiy. the answer

wou1d be she couldn't. But the second part of

the answer wou1d be so then she cou1d go 1ook

at the minutes.


MR.

102

which she endeavored to do and which we

a11owed her to do, and to1d her that we were

happy to provide minutes, they were going to

have to get typed up.

MR. STOYANOV: what about the other records,

it took quite awhiie for her to get access to

them, correct?

Weii --

HEINTZ: That's not correct Mr.

Stoyanov. You know a 1ot of this has gone

between Mr. Knise1y and I and we got the first

batch of documents and it's set out in Mr.

C1are's affidavit, within a few days after

being served with the originating app1ication.

And as soon as Miss Fournier was abie to get

the rest put together she brought it to my

office and I phoned your office and said it

That didn'twas there, come and 100k at it.

happen for a week. The witness, and I'm sorry

to be in essence giving evidence, but the

witness has repeated1y testified that they

have never, your c1ients have never been

denied access and that every effort has been

made to accommodate them, but you keep

repeating the question apparentiy in an effort

to have him admit that that hasn't been the

C888.


103

MR. STOYANOV: Now, you had mentioned that

no one has stepped forward to become, to want

to be a director from Manitoba association?

I'm not aware of anyone who has fu1fi11ed any

requirements as iaid out in the byiaws to put

themseives forward as a director. we've tried

finding peopie. I know other members of the

association have iooked. I've ta1ked to our

former director from Manitoba in that regard,

but persons who had initia11y expressed

interest faded away or 10st interest. Some

stepped away because of heaith issues, some on

being interviewed were frankiy rea11y not

interested or what they, you know, they were

concerned about what their ro1e was, what they

wouid do, when they found out there was

certain expectations and they stepped away

from it. There's been nobody come forward as

a candidate.

Nobody quaiified or nobody whatsoever?

Nobody's come forward, not that I'm aware of,

that's for sure.

Okay. Let's go to your affidavit of Aprii

23rd, 2015?

M-hm.

Turning to paragraph five?

Yes.


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And paragraph six you state that this issue

has been resoived. meaning the issue

surrounding the amendment of the byiaws?

I beiieve it has, yes.

Okay. How has it been resoived, in what

sense?

we11 we've become aware of the probiem with

sanctioning of the various, the bylaws and in

looking at the byiaws it wou1d seem that the

amendments

the others

to 2010 are in force and effect and

at present are not. Though they

wou1d have been in effect for the time period

up unti1 which they shou1d have been

sanctioned.

HEINTZ: we11 again in fairness to the

witness, he's taiking about the remedies

sought in your originating appiication and

your originating appiication seeks, quote: "A

deciaration as to the by1aws of the

association

29th, 2013".

that have been in force since Ju1y

And then as you know, Mr.

Kniseiy and I have discussed this matter anumber of times and I've toid Mr. Kniseiy that

I've given my opinion to the NFA and that it

accepts the opinion that it's what we refer,

what we've been referring to as the 2009

by1aws that are actua11y the current byiaws


105

with the 2010 amendment.

MR. STOYANOV: Has Corporations Canada been

informed of this?

They, we11 they received the, that amendment

aiong with those other amendments but they

have not been informed, to my knowiedge, of

the probiem with the bylaws to this point.

One of the possibi1ities that I think is

worthwhiie is to see, iike one of the things

we did is we tried to strike a byiaw committee

to review byiaws, to try to sort everything

out, to make sure it's c1ear, transparent and

in the interests of the organization.

But in the interim what has been done to

ensure that as far as Corporations Canada is

concerned they have the iatest and va1id

byiaws in their records?

we11 given the particuiar situation as it

exists right now, I think that we haven't done

anything to contact Industry Canada about

doing anything like changing this or changing

that to make, because we want to make sure

that whatever is put forward is correct,

accurate, and in keeping with the byiaws as

they are, the requirements of the byiaws,

which are unaffected by any of the amendment

changes.


106

Right, so your position is that the 2009

by1aws are the currentiy va1id by1aws of the

association?

The 2009 byiaws as amended to 2010 are the

current and accurate byiaws is my

understanding and position.

Okay. So knowing that, why haven't you

written to Corporations Canada to iet them

know that this is the case?

It's an exce11ent idea and probabiy something

we shou1d do quite soon.

Might I suggest this may be a 1ega1

requirement to do so?

we11 thank you for the suggestion. I

appreciate the 1ega1 advice, I hope I'm not

going to get a bill for it.

I'm not giving 1ega1 advice I'm just thinking

out 1oud. Your 1awyer is very we11 quaiified

to do that on your behaif.

Paragraph eight of the same

affidavit refers to the discretionary powers

or the Iack thereof of Ms. Ginger Fournier.

what directions if any have been given to her

and by whom concerning any of the matters

raised in this app1ication?

we11, the primary contact, the point of

contact for Miss Fournier for supervision is


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from me as the representative of the board of

directors and the executive. And my

directions to her have been to give everything

to the directors that they're entit1ed to have

under the by1aws and to cooperate fu11y,

that's what we're trying to do.

Paragraph nine of the same affidavit you say

that she does not have any information that

wou1d further the end of the app1icants. But

she's aware of these matters, correct?

Of which matters?

Of the matters arising out of this

appiication?

I be1ieve so, yes.

She's got, she's had to communicate with you

and the officers and directors?

Yes.

Regarding these matters; yes?

Yes.

And she has personaiiy observed events in the

office, in the registered office of the

association that reiates to those matters?

Wei] I'm not sure what you mean by events in

the office that relate to those matters, cou1d

you be more specific?

we11 for example, the creation and keeping of

records and documents?


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Yes.

And you wou1d agree that she is primari1y

responsib1e for preparing and maintaining the

officia1 records of the association?

I'm sorry?

Do you agree that she's primari1y responsib1e

for preparing and maintaining the officiai

records of the association?

The responsibi1ity for minutes is that of the

secretary and the presiding officer, but

certain1y the staff have ro1es which have been

directed to them from the board of directors

through me.

who maintains the actua1 officia1 records of

the association?

In the office?

Yes?

The staff.

The staff being?

The peop1e emp1oyed in the office to do things

Tike maintain the register of members, take

membership information in, give peop1e

memberships or remove peop1e or are no Tonger

members and so on under the direction of the

manager as assigned within the parameters

given her through her authority by the

managers and the board of director and the


109

executive.

30 Ms. Fournier wou1d be the one overseeing

the staff or the emp1oyees in that regard?

Yes.

And as far as dea1ing with requests for copies

or inspection, is she the point person, the

contact person for that as we11?

For, I'm sorry, for copies of?

As far as requests to inspect documents or to

get copies of documents?

Provided that she's been given authority to

reiease such information yes, which she has

been.

Thank you. Does she have a genera1

responsibiiity to attend the meetings of the

directors?

Yes.

Committees, and to tape those meetings as

we11?

There are two peopie who are capab1e of taping

those meetings, one of these is Miss Fournier

and the other is myseif.

Now when you are talking about 1ooking for

different quotes from accounting firms for the

audits did you do a11 the research yourse1f or

did you deiegate some of that to her?

I de1egated that to Miss Fournier. As you're


110

aware I'm a vo1unteer and I receive no

compensation for anything I do as the e1ected

director for British Coiumbia who has been

e1ected to be the nationa1 president and chief

executive officer of the NFA.

How Iong has she been with the association?

She's been there since, to about 2010 and she

rep1aced a previous emp1oyee.

Is she assigned with a task to send

correspondence to Corporations Canada and

other governmenta1 offices?

In terms of the administration of those

things, yes. when we're aware of that and in

keeping with a11 the other many things that

have to happen. As was made ciear there are a

Iot of different things going on in that

office at different times and I mean some of

them take more priorities at particuTar points

in time than others. Many of them have Iegai

requirements around them.

Now, there was a change of directors after the

December 1st, 2014 e1ection?

There's, December 2014, the eiection, the

e1ections usua11y take p1ace in the fa11 and

usua11y ha1f the board of directors is e1ected

in particu1ar, rough1y ha1f, not a1ways, but I

don't know how fami1iar you are with our


MR.

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processes, but the directors have been pretty

stab1e for a good bit of time. we have had a

few changes. The main change, the Targest

change has been this recent one. Now, some

directors were acc1aimed in which case they

are in pretty much right away. The others

where there were e1ections, and those

e1ections went through their processes, and

then the association carries on with a11 of

that in p1ace.

Now, was Corporations Canada advised of the

change of directors after this?

I be1ieve it was.

Most recent e1ection? Is there some record of

it?

I'm sure we can find that for you.

Perhaps you can undertake to provide a copy of

that correspondence?

HEINTZ: May I just have a moment.

STOYANOV: Sure.

HEINTZ: I think it's the first

document in the binder, Adam.

(BRIEF ADJOURNMENT)

MR. STOYANOV: Now, can I enter this as an

exhibit.

HEINTZ: No objection, sir.

[EXHIBIT D-4: Form 4006 changes


112

regarding directors of the

association]

MR. STOYANOV: when reviewing the originai Isort of noted that your signature appears

somewhat pixiiated in a different co1or than

anything eise, I'm just trying to figure out

what the procedure usually is for you piacing

your signature on these documents?

It's an exceiient question. As you are aware

it's, I am not in Edmonton on a reguiar basis,

I iive in Prince George, British Coiumbia.

And from time to time there are documents that

need to have my signature affixed such as

certificates and so on, as in my ro1e as

president of the association, and with that inmind I had a stamp created to a11ow the

genera1 manager with my permission, and

checked every time, to affix my signature with

authorization. So she wou1d in practice send

me an emaii and I wouid authorize yes okay,

you know, yes piease sign this or I wouid

direct her to affix my signature on something

that needed to be sent in. And it's been apretty workabie process. It seems to be,

seems to meet our needs, the kind of practice

that's common in many organizations for

stamping cheques and other 1ega1 documents,


MR.

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113

that sort of thing. My father is a bookkeeper

and I've observed him use a stamp to run

cheques for payro11 for many many years. It

seemed to me to be a workab1e soiution rather

than going to the expense of priority posting

documents back and forth.

So this was signed with a stamp?

Yes, in effect it's a signed --

when was this documentation created and

signed?

I don't reca11 exactiy when this was. I guess

we can Iook into it. we haven't received, as

far as I'm aware, a receipt from Industry

Canada yet regarding it's been fiied.

So do you have any record of it being sent to

Industry Canada?

HEINTZ: If it assists Mr. Stoyanov, in

the documents that we provided to you, I think

right underneath that one Mr. Kniseiy, it

appears that Miss Fournier sent it just on

Apri1 23rd, I think that's the fax copy. Can

we just go off for a second.

STOYANOV: Sure.


MR. STOYANOV: So just to confirm this

document Exhibit 4, which is the form 4006

changes regarding directors, that was


114

initia11y sent to Corporations Canada in March

of 2015 and then again in Aprii, Aprii 23rd,

2015?

That appears to be the case from the

documents, yes.

And you don't have yet any registration of

that?

I'm not aware of one being received yet.

That's not surprising though.

Now, paragraphs 10 and 11 of your Apri1 23rd

affidavit dea1 with Miss Ciark being suppiied

with the association's membership count at

your instruction?

It says association's registered member and

membership count, yes.

Sorry, come again?

I'm just reading it here, I'm sorry, I'm

thinking out Toud a bit.

That's okay. So what had she been actua11y

provided, just the count or was she given

access to the register as we11?

She was given fu11 access to the register. As

I understand it she sat at Miss Fournier's

computer and was aliowed to peruse the fu11

membership Tist.

So she cou1d see it but she cou1dn't take a

record of it with her?


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115

HEINTZ: That was the agreement made

between Mr. Knise1y and I.

MR. STOYANOV: Wou1d you agree that the

agreement, that this agreement between counse1

concerning Miss C1ark‘s inspection of the

membership Iist was without prejudice as to

any of the app1icants' entit1ement to inspect

or obtain copies of this register of members

at a future time?

HEINTZ: To be fair to him sir, that's

probab1y a 1ega1 question and I think it's

fair of me to answer in the affirmative to

your question, these were without prejudice

discussions.

STOYANOV: Okay, thank you.

Paragraph 13 deals with, we11 my question is

did you or anyone e1se give any instructions

to Miss Fournier about how the inspection was

to take p1ace?

No.

Did she provide a report back to you after the

inspection took piace?

She, I believe we ta1ked on the te1ephone and

she informed me that she had been there and

she Iooked at it, she didn't stay very Iong,

and had a 100k at it and Ieft.

Did you discuss any detai1s as to what


116

transpired?

She said there was not much conversation and

that was that.

Alright. Now, paragraph 17, Miss C1ark, you

write that Miss C1ark states that: I admit I,

that I impetuous1y sent fa1se messages with

respect to Miss C1ark and Dar1ene MacKenzie.

Now the word impetuous, as far as I

understand, means acting quick1y or without

thought or care. Isn't that how you actua11y

described your initia1 reaction was sort of a

hasty reaction to the situation?

I didn't characterize it as impetuousiy, I

think I've discussed this with you a1ready.

So how does the word impetuous conf1ict with

your eariier evidence?

we11 I don't think I acted without thought or

care. I may have acted in a bit of haste.

Paragraph 27 dea1s with the executive again,

capita1 E, having instructed its solicitor to

object to the production of Miss Fournier.

was there an actuai vote of some type that 1ed

to this, who decided to object to her being

produced as a witness?

We11 1et me see. I don't reca11 exact1y who

we discussed this with. As you understand

when you have a fragmented board of directors


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you're not discussing that with everyone, but

I certain1y didn't see that Miss Fournier's

attendance was necessary or required given

that she acts on1y under the authority of the

I think

I may have said that but I do beiieve I did

executive and the board of directors.

discuss it with other members of the

executive. I don't think we had a meeting

about it and voted on it.

But the decision was yours then?

we11 --

As the president?

I think so, yes. I think that's a fair

characterization. I am the spokesperson for

the executive and that's the tenor of things,

you know. I did reca11 discussing this with

the other executive members but I don't think

we had a meeting, a forma1 meeting about it.

I get a 1itt1e meeting'd out after awhiie

frankiy.

Turning to paragraph 28 you a11ege that

questioning Miss Fournier is evidence of bad

faith and abuse of process on the part of the

appiicants. Doesn't your own evidence support

the fact that she is the best witness as to

the officia1 records, the auditor and the

audited financiai statements?


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No. I disagree.

Okay.

She is an empioyee acting under direction.

who among the empioyees or the officers of the

association has the most compiete knowiedge of

the records being kept at the registered

office?

The most compiete knowiedge?

Yes?

I think that that information is, in what

terms of that do you mean?

In other words --

where they are on the she1f?

where they are on the sheif, when they were

generated, fiied, indexed, when correspondence

to various government offices was sent, who is

in charge of a11 these minutia?

The minutia, the administrative work, well

that couid be in terms of the staffing of

that, and the staff doing it, Ginger does that

on our direction, yes, informing me as to what

she's doing.

Of course. Turning to paragraph 29, is it

your evidence that if Ginger Fournier was to

be questioned on her knowiedge of the matters

raised in the appiication her evidence wou1d

not support any of the aiieged facts?


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Excuse me?

Is it your contention that her evidence

wouldn't support any of the allegations in the

application?

HEINTZ: That's asking him to assess

evidence Mr. Stoyanov, evidence that hasn't

been given.

OBJECTION:

MR. STOYANOV: Okay. Now, at some point

documents were sent to our office through your

lawyer's office, once in March, I think March

12th, 2015 and then again on April 27th I

believe, of 2015. Did you personally review

those records before they were being sent to

us?

Pardon me?

Did you personally review those record before

they were sent over to us?

I would have discussed all of the records with

my counsel prior to sending any of that

forward, yes.

Did you actually review them physically?

well not --

Electronically?

Electronically if at all, yes, and I would

suggest that I would have reviewed all of them

at some point, yes.


120

MR. STOYANOV: Let's take a 1itt1e break,

I'11 review my questions and I think we're

aimost done here.

(BRIEF ADJOURNMENT)

Q MR. STOYANOV: Now, how many members are

there in the association?

we11, I can't give you an exact number.

Piease, average, roughiy?

And I want to preface this by saying we have a

number of categories in membership inc1uding

members of c1ubs who are what we term

associate members who are primari1y there for

the insurance. At our current membership is

approximate1y 71,000 members.

0 when you first started how many were there,

when you became president?

I think about 45,000.

So it's grown steadiiy ever since?

Yes, thank you.

I just rea1ized that I probabiy took a 1itt1e£3

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Ionger than I expected so just a coupie of

quick questions but I'm afraid I'm going to

have to adjourn ti11 the next time we meet to

comp1ete this questioning.

MR. HEINTZ: we11 I'm not sure I'd be

comfortab1e with that. He's been produced

here today for an examination, we're here for


MR.

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121

the duration.

I'm here ti11 midnight if you want me, my

piane doesn't 1eave ti11 tomorrow morning.

HEINTZ: Subject to Mr. Reporter's

requirements, he's a1ready to1d me that he's

got some time.

STOYANOV: Airight. We11 now, you had

mentioned ear1ier that you had contacted and

emai1ed Ericka C1ark and Dariene MacKenzie,

again that's regarding their ceasing to be

directors because of their conduct.

I be1ieve it was a Facebook chat message but I

cou1d be wrong about that.

Okay. Did you communicate that to anyone e1se

other than Ericka C1ark and Dar1ene MacKenzie?

At that point no. I do beiieve that I may

have posted a screen shot of that or someone

did on our administration page, which had I

think at the time 12 administrators for one of

our sites.

Okay. But it wasn't you who posted that?

I don't think I did but I can't reca11

exactiy. I wasn't very interested in

disseminating it very wide1y, I wanted to make

sure that they knew I was very disappointed in

their conduct.

Do you have any sense as to who may have


122

posted it then?

I think they did, on that site, that wou1d

have been one of the administrators, but that

page has undergone a 1ot of turmoii and changebecause there have been a 1ot of peop1e who

have been taking sides in these issues and

some of those sides taken have ied them to dorather unfortunate things.

were Ericka C1ark and Dar1ene, or Dar1ene

MacKenzie administrators at that point in

time?

There was some back and forth unti1 the page

was, contro1 of the page was regained to its

rightfu1 authority.

But at the time --

I was kicked off for awhi1e and then --

I just want to confirm that you hadn't sent

this to anybody e1se persona11y that you

hadn't sent it or posted it?

I may have mentioned this to some of the

executive members but it wasn't my intention

to be f1ashing this a11 over the internet.

I'm not a dirty Iaundry in pub1ic person.

I want to refer you back to the necessity toamend the by1aws back in 2013, at some point

you had rea1ized that the practices as they

were at the time didn't quite confirm to the


123

by1aws?

M-hm.

Can you give me a precise date or time when

that reaiization arose in your mind?

I cou1dn't do that, no. I mean this, byiaws

are an ongoing thing, I think about them

frequentiy. I mean I p1ayed a fairiy major

roie in writing these bylaws a1ong with a

committee, who I vetted them, I think I went

through 17 different drafts before we put

something forward to the members and had it

voted on which was done universa11y, it was

done as a vote of the entire membership.

Sorry, the members voted, what are you

referring to exact1y?

when we adopted new by1aws it was in the 2009,

2010, I was basica11y chairing the byiaws

committee to make sure that that was done.

Okay. And regarding the 2013 amendments, when

did you reaiize that you had to a1so address

these issues as we11?

We11 it was before the Vancouver AGM 1ast

year. It was apparent to me that, you know, I

think maybe I had been reading them for

something e1se, I can't say when or when it

was, and it became apparent to me that

contrary to my opinion at the time, the


124

directors cannot uni1atera11y change the

byiaws, you know. they had to go to the

membership for sanctioning. And what sanction

meant and what ratification meant, the

differences between those terms I was pretty

fuzzy on frankiy. And I mean when we were

preparing the byiaws we had a number of peopie

who had input into them, we were raising some

tempiate, boiierpiate ianguage in some aspects

of them, some of the Industry Canada materiais

we used, some of them we didn't. we had input

from former members of the executive and so onand, you know, it became apparent to me that

this was a probiem, I rea1ized, okay, we've

got to get this dea1t with. But I think I

discussed the rest of that with you aiready.

Actua11y what I was referring to was prior to

that Ju1y meeting of the directors to vote on

these new byiaws, when did you sort of reaiize

that they needed to be changed yet again?

Oh, I think that had to do with our practice

changes when we hired Mr. Bevens and the need

to ciarify the ro1e of the president. Because

we've been operating on the need to have a

boss, right, because in the absence of a boss

who is the boss, and there needs to be a

sing1e report for peop1e, otherwise you have,


125

I wou1d say unwieldy and difficu1t

circumstances of having emp1oyees reporting to

mu1tip1e bosses which I think any of us wouid

find very very unpa1atab1e. And we had this

meeting that we referred to that we've

undertaken to provide you the minutes of,

which appointed me to be the supervisor CEO

and on so on to make sure that there was a

boss, because there had to be a boss.

So there was some stream1ining or

conso1idation of power?

we11 it's not conso1idation of power, I think

streamlining is a better way of characterizing

it. The power's in the board of directors, it

a1ways has been and remains so. I think the

byiaws are very c1ear about that. And I want

to add, for many years we operated under a set

of by1aws that were very centra1 contro11ed in

we had a mode1 of governance that invo1ved an

extremeiy strong president and a11 authority

was vested in the president. And I think I

reca11 by1aw three if, you know, if there's

any question about any interpretation of the

by1aws the president's interpretation is the

correct interpretation and wi11 be deemed

fina1. And I hated that. I found it anti

democratic, I found it destructive to the best


126

interests of the association and I 1ong tried

to propose changes to that, those by1aws to

bring them in 1ine with 21st century ways of

doing things and proper governance poiicies.

I'm a great beiiever in governance, I've been

on many boards and I beiieve that due process

is rea11y important. And when I looked at

creating a new set of byiaws as part of the

process to re-brand and rebuiid and invigorate

the organization and buiid it from what it was

to what it is today. Part of that was to have

a much more invo1ved governance system, so

that's what that's about. So it's not about

consoiidating power in the hands of the

president, in fact it's exactiy the opposite.

Now, I think my question was when did you

decide to amend those by1aws, or when did you

come to the rea1ization that 1et's do this?

I think there were others who were iooking at

how we were doing things. I mean we had

conversations with the teiephone. You've got

to understand that my time in doing this

voiunteer job invo1ves me doing this 20 to 30

hours a week on top of my famiiy, my job, and

everything eise I do as voiunteers. I

voiunteer in other organizations and quite

frankiy it invoives not sieeping sometimes I


127

think some of you might be fami1iar with that

from your own activities. So the idea that,

this has been something that's been discussed

with peopie and, you know, we need to be

making changes so it wasn't a surprise to the

directors at the time that there would be

something brought forward to make changes in

byiaws because we knew that our by1aws were

not refiecting our actuai operating practices.

And the idea is do you change the practice to

fit the byiaw or do you change the by1aw to

fit the practice, and usuaiiy you try to

change the practice to fit the bylaw because

byiaws by their nature shou1d not be easy to

change, and if you did that you wou1d be

fiipping around back and forth. But given

these are in effect re1ative1y new byiaws

there's bound to be some growing pains, there

are bound to be some structurai issues that

need to be deait with on an ongoing basis.

And this has a11 been about trying to make

that process work to the best interests of the

organization and in keeping with the fiduciary

responsibiiity of the directors acting in good

faith for the benefit of the organization.

But then again the know1edge that the practice

was inconsistent with the byiaws. was that


128

always there throughout your tenure as

president?

Probably. Probably there was, well I mean for

example the nature of requiring an audit, we

realized very quickly after adopting the

bylaws we couldn't afford an audit. we looked

at this and we said what do we do, well we'll

take it to the members at the AGM. Guys,

we're supposed to have an audit, what we've

got is a financial review, is everybody okay

with that and, you know, there had been,

you've got to understand that the

organization's records in previous years had

been very poorly regarded, there had been no

annual general meetings for a long time in a

number of respects, and all kind of gross

travesties. And I think that the membership

was pleased to see the executive, the

directors and officers all taking action to

try to take something that would be getting

off the rails and putting it back on the

rails, cleaning it up, and making it run like

a well oiled machine. So when? Ongoing. I

look at bylaws all the time. I think about

them all the time. You know, I think in this

particular room there are actually people who

would understand that.

A-C.E. Reporting Services Inc.Certified Court Reporters

129

So you were invo1ved in drafting those initia1

amendments?

The initiai by1aws, yes, for the then

president B1air Hagen.

what made it necessary to have yet another

round of amendments in 2013?

Ne11 the idea was that we were changing our

structure, we had this new emp1oyee, we had a

need to ciarify processes to make it c1ear

since we had gotten rid of assigning the

manager the tit1e of executive vice-president,

.that was rea11y a dead kind of position. we

didn't have anybody doing that title with that

job. The genera1 manager was kind of, was

doing the supervision of staff on beha1f of

the board of directors but it became kind of

confusing as to who was the boss because we

were re1ying on this directive that okay, we11

Sheldon, you're the boss, right, you're

supervising these key empioyees. And that is

fine as far as it goes, but it isn't very

c1ear and I think that's possib1y some of the

issue with some of these directors that

there's, they're not c1ear about that. And

having changes to the by1aws to get some

c1arity is important. The by1aws shou1d be

ciear.


MR.

MR.

MR.

MR.

MR.

130

Okay. Just one 1ast request, I'd 1ike to see

a copy of the registered officers if you wouid

undertake to provide that, I don't think we

have it produced just yet?

HEINTZ:

that comp1ies to the 1etter with the

I don't think there is one

regu1ations Mr. Stoyanov.

STOYANOV: That's okay, whatever you

have.

HEINTZ: Miss Fournier has been

instructed to prepare one when she gets a

chance but notwithstanding that as I've

advised your office a iist of the officers

appears in every Canadian Firearms Journa1 and

those are avai1ab1e in hard copy and

e1ectronica11y.

STOYANOV: Okay. Can we just have a copy

of what was current1y, you know, what had been

kept at the registered office.

we'11 endeavor to meet

HEINTZ:

your request.

we11 we wi11 but we might be

ab1e to meet it right now. You know, we've

got the May 14 minutes where the executive are

appointed.

E1ected.

HEINTZ:

That's true,

E1ected,

that's there.

thank you. So --


MR.

MR.

MR.

MR.

MR.

MR.

MR.

MR.

MR.

MR.

MR.

131

HEINTZ: Te11 me, beyond that I don't

know what, there is nothing I can give you at

the moment.

STOYANOV: Right, what I'm trying to get

is in essence the registered officers for the

past say five years.

HEINTZ: Right, it wi11 have to be

created.

STOYANOV: A1right.

HEINTZ: And I can't give you an

undertaking to give you something that hasn't

been created yet, but I can te11 you that the

process has been instructed, the staff have

been instructed to engage in the process and

at the moment at ieast your ciients are

entitied to see those records.

STOYANOV: Alright. Can you undertake to

provide it once it's created?

HEINTZ: Sure.


HEINTZ: If it's created.

STOYANOV: Okay.

HEINTZ: I'm not trying to be cute.

[UNDERTAKING NO. 12: To provide

a copy of the 1ist of registered

officers for the past five years

if and when it is created]


132

MR. KNISELY: Let's go off the record for a

second.


MR. STOYANOV: Mr. C1are, thank you for

attending, and subject to any undertakings,

subject to any answers to undertakings this

conc1udes my examination today.

(WHICH WAS ALL THE EVIDENCE TAKEN AT THIS EXAMINATION)

(5:06 p.m.)


133

CERTIFICATE OF TRANSCRIPT

I, the undersigned, hereby

certify that the foregoing pages are a comp1ete and

accurate transcript of the proceedings taken down by me

in shorthand and transcribed from my shorthand notes

to the best of my ski11 and abi1ity.

Dated at the City of Edmonton.

Province of A1berta, this 14th day of May, 2015.

/6é<%»%Richard D. Jacobs CSR(A)

0fficia1 Court Reporter


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26:14, 36:24, 49:9,40:6, 47:24, 47:25,48:4, 48:5, 48:12,48:19, 50:24, 91:13,91 :17, 52:3, 52:6,52:9, 92:14, 52:27,5 :1 3:6 5 :2454:1, 54:2, 91:6,54:14, 54215, 54:17,54:18, 55:10, 95:12,55:24 55:26 56:55621 7:19 :2261:14, 61:16, 9915,92:17, 62:19, 65:16,65:22, 65:25, @213,97:5. 67:7, 71:13,71:20, 81:11, 83:24,99:19, 92:16, 92,'20,92:23, 92:24, 92:27,93:12, 99:15, 95:27,99:5, 103:5, 195:3,104:8, 104:9,104:19 104:27195:7, 105211,105217, 19924,105225, 106:2,106:4, 109:5, 107:5,122:25 123:1,123:9, 123:8,123:16,12,3:17124:2, 124:7124:19,125:1§,125219, 125:24,129:2, 126:8,126:17, 127:9,127214, 127:17,127:27, 128:6,128:24, 129:9,129:2§, 129226

CC51 - :13Canada L3] - 4:19,

7:12, 7:29, 55:26,56:1, 56:24, 59:26,57:15 58:7 59:1261:20, fi:7 64:19,65:24 66:11 66:2567:8, 97:19, 67:17,67:18, §7:21, 68:268:6 78:21 80:1710522, 105:15,105:20, 106:8,110:10,111:11,113:14,113:1§,

Cert 7' fied Court Reporters

114:1 124:10CANADA [1] - 2:26CANADA'S [1] - 1:15Canada‘s1§]- 5:14,

Canadian [5] - 6:8,24:24, 60:10, 69:11,

9:13 1 :14cancel [1] - 86:18cancelled [11 - 85:21cancelling [1] — 57:24candidate [1] - 103219candidates [1] - 81 :1canno;[;|1- 124:1cagabili_t_1u2] - 25:25,

Ecagble [1] - 109:20cagclties [1] — 5:11cagciym - 5:12cagital [5] - 7:12,

11:16,11:27,12:18,11 :20

care [5] - 23:21, 81:20,90:20, 116:10,3

cagts [1] - 24:9carries 111- 111:9case [15] - 15:7, 16:7,

25:18, 30:14, 44:25,

Wiflfli.78:12 82:19 83:13@1_.§L1_4.i2’~'5..102:2? 1 :9111: 1 14:4

cash [1] - 69:10categories [2] - 8:12,

1 :10caused [11 - 29:14causing [1] - 64:1,

6cautions [1] - 97:15ceasing [1] - 121210centml [1] - 125:18CENTRE [1] - 1:5century [1] - 126:5CEO[11- 125:7certain [19] - 17:18,

25:15, 33:27, 47:8,68:4, 69:25, 84:15,54:25, 96:9, 155:1?

L0.19:3, 35:2, 33:1134:29, 37:5, 42:25,47:14, 48:9, 64:27,76:25, 77:9, 79:14,75:17, 80:5, 85:18,91:1, 95:25 108:11,IE

certaingm - 17:19certificate [1] - 6:16

CERTIFICATE [1] -

E lJ.l;

112:14certi - 1 3:4chalr[1|- 50:24chairing [1] - 123:1?challenged [2] -

93:13, 93:25chance [2] - 22:11,

1 0:12change [22] - 14:26,

26:11, 53:1, 53:7,55:8, fi',25, 55:25,62:16, 67:23, 55:25,86:13 94:12

111:4 1 11:12122:4, 124:1,127210, 127:11,127:13 127215

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changs la] - 4:11,6:8, 24:3, 27:21,29:15 47:12 :1248:19, 51:20, 51 :25,52:25 55:19 55:2360:18, 61:15, 65:17,65:15, 65:22, 66:18,

111227 113:2?124:22 126:2127:5 127:7 129:25

CHANGES - :4changing [5] - 47:15,

53:13 105:21, 129:7characterization 1;] -

80:24, 95:5, 117:14 J;5

characterized [1] -

£125characterizing [1] -

5charge [21 - 70:18,

Echartered [11 - 70:24cha - 861 89'BL2.

check [3] - 2:4, 41:22,E

CHEC - 4:17checked [1] - 112:18chegues [2] - 112227,

11 :3chief [21 - 96:26, 110:4chosen [1] - 101:13circumstance 12] -

81:3 81:12

4circumstances [1] -

25:14, 27:18, 41‘,1,52:25, 55:1, 96:1,

Eciting [1] - 27:11Ciy [J] - 133:8claims [1] - 81:24Clare [9] — 5:4, 9:14,

19:16 34:14 72:478:25, 75:4, 100:12,

129224 12 :27clea - 7:4clien§[1]- 30:25clienm [2] - 102:22,

131 :15clggging [11 - 24:11clubs [1] - 120111cognizant [1] - 61 :9COLGAN13]- 1:7Colgan la] - 9:22,

120:24, 133:4comgleted 11] - 55:9comg|iance[z1-

78:20 79:2comglied [23 - 27:15,

7943comglies [3] - 130:6comglying [1] - 21:15comgosed [1] - 55:17comgosition [1] -

1 57:5, 88:21 flflflCLARE |5] - 1210, collaboralivebg [3] - comguter [5] - 39:14,

1115,2115, 5:1 53:15, 94:15 40:11, 55:14, 46219,

3&4 color[1]- 112:5 47:11 60:8 60:25Clare's - 41:1 commbia - :15 114224

42215. 4325, 98222 9:17, 10:13, 10:16, concern [5] - 72:19.

99:1,1Q2:13 110:3 112111 §1:2Q, 92:18, 94:4,CLARE'S |‘_|| - 3223 comfortable [1] - 100220clarification [2] — 12 :26 concerned 1191- 6:9,

77:15, 78:25 coming[3_1 - 35:11 6:12 45:3 59:10clarify [3] - 78:18, 41 :13, 81 :2 59216, 9017. 91215.

12423. 1231.9 commensurate 121-clan‘ in - 13:7 24:1 24:22 6clari - 129: 6 commons [1] - 52:5 n-

Clark um — 9:16, committed 121- 80:26, £5__..__§1324 115129:20, 30:8, 51:7, §_g;_2_3_ concerns - 4 :131:15, 31:24, 32:25,33:9, 33:13, 55:5,58:7, 38:12, 41:3,42:10, 45:1, 43:17,44:26, 45:13, §:4,54:11 87:22 87:2688:5, 59:3, 85:13,85:18, 89:21, 90:8,90:25, 1m:5, 100:5,101:5,101:12,1 14:11 116:4116:5,115:7, 121:9,121:15 122:9

CLARK‘S [21 - 2:19,E

Clark's [12] - 30:1,30:23, 52:11, 32:21,33:15, 53:25, fi:17,35:23, 38:10, Q11,91:17, 115:5

CLARKE [1] - 1:7class [2] - 6:17classes [3] - 5:7Claude [:1 - 9:22,

87:9 88:21CLAUDE [1] - 1:7cleaned - 4 :22cleaningm - 128:22clear [15] - 12:5,

75:15, 81:11, 9826,100113 105:12110:15,125:16,129:9, 125:22,

committeem] - 11:3,12:20 13:5 15:115:22, 16:11, 20:14,43:21, 1Q5:10,123:5, 123:18

committees [2] -80:10, 1@:18

common [a] - 55:2494:16 99:17 99:23112:25

communicate 1;] -86:21, 1Q7:15,121:14

communicates [1] -

35%Communication [1] -

7;‘-3communication [2] -

65:14, 55:15COMMUNICATION [1]fi1_2.

Communications [1] -

Ecommunications [1] -

§§I_4_camgny [1] - 31:12comgrative |_a_] -

2 :4 20:7 68:26comgnsation [11 -

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concludes [1] - 132:7concun-en; [1] - 89:5concurrenm [1] -I?conducnz]-121',11,

1.2.11.5conducted - 2: 1

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5:10, 15:13, 17:24,18:19, 51',1, 61:25,

§§2§.fi;fl..113:25 122:1?1.LNI ‘HI1::

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5J1_14._£conflict [5] - 27:9,

27:11, 52:3, 55:5,93:10 1 16:15

confllcting [1] - 27:13confused [1] - 97:26confusing [2] - 55:15,5

confusion [1] - 61:27coniecture [1] - 76:6consensus - 2 :2

Econsented [1] - 56:6consider [2] - 80:3,E

consistent n] - 23:14,49:7, 101:3

consolidating [1] -


126214consolidation [2] -

125211 125212constituted [31 -

84:23 86:9 89:10consultants [11 - 24:5consultations [1] -

2222contact [5] - 60:2,

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contacted [2] - 60:5,

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39:25 60:6 88:14contained [1] - 9:2content [1] - 52:22contention [1] — 119:2continuation [1] -

2222continue [5] - 26:27,

52:5, 55:4, 82:24continued [21 - 7:19,222

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89:2 89: 11 :2conversations [1] -

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cogies [19] -19:19,35:24 43:22 44:2747:19 95:14 109:5109:8 109:10 115:8

COPY[_I,[ - 2:21, 3:17,3:20 :24

cogy [21] - 7:4, 13:21,13:23 48:20 49:2563:22, 77:7, 77:19,77:23, 78:7, 90:1,90:4, 91:11, 98:19,99:26, 111:17,113:21, 130:2,130:15, 1:10:17,131125

comers [2] - 42:22,1222

corporate [1] - 101:18coggoration [5] - 7:12,

57:18 57:26 61:24

2322Corporation [:1 —

7:20, 65:24, 66:11Coggcrations [221 —

4:10, 7:13, 56:24,56:25 57:15 58:659:12 61:20 64:764:19, 97:8, 67:21,68:2 68:5 78:21

221LJ222.105:1 106:8110:10 111:11

1161CORPORATIONS [1[ -

222correc§[31[- 5:20,

7:1, 7:18, 8:5, 19:5,10:9 10:12 16:117:15, 21:23, 42:16,43:24, 56:3, 57:3,63:24 64:17 65:27

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corrected [5] - 7:9,63:15 64:21 93:14

corrections [1[ - 15:8correctlve [;[[ - 56:3correctly [2] - 21:26,2232

correctness [21 - 70:8,2215

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30:17 30:18 34:1458:8, 58:9, §9:16,110:10 111:18118115

CORRESPONDENCEm - 2:16, 34:24

cos§[1[- 71:12counsel [5] - 46:11,

76:9, 115:4, 119220Counsel's [1] - 2:4COUNSEL'S [11 - 4:17count [5] - 9:25,

114:12 114:15114:20

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223222212couQ[§[ — 81 :17,

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595:25 36:2, 39:9,60:6, 118223

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12232create - 5 :9created [11] - 6:16,

22:14 54:21 54:22

1122221222.11: 131:12131218 1:31:21l2L2Z

CREATED [1] - 9:27creating [2] - 58:12,

1222creation [1] - 107:26Q§Efla;l2§.

133:15cuff [1[ - 36:2522Esnyfl1;E21.

9:9, 9:11, 9:13,13:13 14:15 54:1895:24, 96:12, 73:25,84:2 85:6 104:2?106:5 120:13

2!§H!8um;2E22.46:21, 47:4

custom [11] - 26:18,26:23, 27:5, 27:12,53:4, 53:5, 53:7,71:21, 71:26, 72:17,93:10 93:12 93:1393:15 93:22 93:24

customam [1] - 27:8cute11[- 131:23

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DARLENE[1[ - 1:7data [2] - 39:27, 88:27DATE[;[[-3:9date - 2:2 :2

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Dated -13 :8dated [§| - 5:5, 48:14,

68:1 68:13 68:23DATED [2] - 3:7, 4:6

David [21 — 6:24, 87:5Davidow [1] ~ 71 :4DAY[g[-1:17, 1:18days [1] - 102213dead [1] - 129212deal [:1 - 26:18, 60:27,11211

dealing [2] - 95:2,1222

deals [:1 - 78:20,119116, 116:19

deal; [21 - 1g4:15,127220

2§2ufl;J2fl§218:17 18:23 19:15122

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17:9 27:16 84:2486:13 :1 116:23

decision [:1 - 99:18,96:20 117:10

decisions [11 - 94:13declaration [1] -

104219deemed [1] - 125:25defeat [11 - 76:16defeated [1[ - 44:2DEFENDANTS [1] -

122Defendants [1] - 1:23deficiency [2] - gm

222define [1] - 15:23defined [1[ - 16:23defunct [1] - 6:21delay [1] - 38:5delegte [1] - 109:26deleggted [:1 - 20:21,

20:2 1 9: 7deleted [1] — 99:5deIivered[1]- 31 :10delivey [:1 - 30:25,2222

demand [1] - 72:26demands [5] - 40:16,

92:1, 92:2, 100:25democratic [1[ -

12 :27demggraghic [1] -

221denied [1] - 102123degarted [1] - 25:4degndent [1] - 81 :1


de se - 8 :6deposed [11 - 77:19describe [2] - 84:19,2132

described [1] - 116:11DESCRIPTION [2] -

2:8, 4:4designation [1] -

2212designed [1] — 17:9desire [11 - 72:19desQite[2] - 81:23,2222

destmctive [1] -125:27

delzailm - 94:7detailsm-115:27DETERMINE [2] -

2:10, 1927detennine [2] - 18:27,1212

detennined [1[ - 39:19develogd [1] - 71 :21develo9n1en§[1[-

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directive [2] — 89:12,129:18

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10 :27 110:3 Tdischarge[1|-80:14DIRECTORS [11 -

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dim [1] - 122:23disa ree -11 :1disagreemen;|1]-

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disclose [2] - 85:3,E

disclosure [1] - 88:3discretion [1] - 40:17discretionagg [1] -

"Bidiscuss [5] - 99:27,

93:4 93:12 94:22115:27,117:7

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discussion 1;; -37:19 45:7 91:1

DISCUSSION [5] -43:9 64:4 98:16

_1.1_3;2A._1_§2I.§discussions [9] —

26:5 34:16 45:2711£90:27 115:14

DISCUSSIONS [2] -2:19 34:27

disgruntled [11 -

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35: 7 :2 :780:11, 80:12, 89:19,80:19, 80:25, 81 :13,E

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documentation [1] -

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2 :13DOCUMENTS [21 -

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documents [55] -

7:23 14:4 17:2422:7, 29:12, 22:21,22:25, 23:7, 24:29,24:27 25:5 25:825:16, 34:2, 34:19,35:5 35:13 35:2436:19 38:2 38:2539:9 39:25 40:340:22 41:6 42:542:8, 43:2, 54:20,69:24 73:6 92:199:9,101:9, 102:12,107127, 109:9,109:10, 112:8,112:12,112:27,113:6,113:18.114:5 119:10

done [32] - 21:9,21 :26, 36:27, §1:29,52:19, 59:6, 60:12,,62:4 64:23. fi:26,70:26, 70:27, 71:19,74:1 74:23 80:1882:2, 83:5. 84:3,90:23, 92:22, 94:13,94:19, 97:9, 97:27,98:12 105:14musgfl.123:12, 123:13,12 :18

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E90:29, 1g9:6

dumgj - 11:15, 84:22,69:9, 85:7, 86:9,89:10

duration 111- 121:1durin - 2 '

28:11, 43:16, 69:7,E

duties [1] - 23:19dug [a] - 23:21, 81:19,

9546 37:24 112:2oemailedi:-.1 - 49:17.

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10:18 13:10 13:111 :27 :798:4 99:11 99:12191:7,110:2,110:4,110:25 130:25JEZQ

election [5] - 61 :1,99:12, 119122,110:23,111:14

elections [3] - 110:24,1 1 1:7 1 11:8TAT.

electronic [9] - 28:16,

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18:9 119:24119:25, 130:19

ill-311.1email [21] - 31:23,i5B350,'6, 90:21, 91:7,58:16, 68:1, 68:9,

79:19, 76:24, 87:23,


emgloyee [§_| - 99:2,96,11, 96:12, 98:7,98:9, 110:8, 119:3,1_2.E§

emgloyees L51 - 69:23,1(i.L3;1._12i2,.1 :20

emgloys [1] - 15:27enablem - 98:8enabled [1] — 89:14enacted 111 - QI19enacting [1] - 54:7end [2] - 88:18,107:9endeavorm - 130220endeavored [11 -

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ENGAGED '11- 3:9engagement [5] -

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L326ENSURE [1] - 4;19ensure [111 - 2:5,

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105;ensuring [2] - 29:12,

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entire [3] - 10:16,10:20 1 :13

entitled [5] - 33',1,33:3, 33:14, 197:4,131:16

entitlement [11 - 119:7


Eric]z] - 31 :4, 31 :5Erickanfij - 9:16,

29:29, 30:8, 42:10,43:17 44:26 45:1245:22 87:22 89:2199:8, 90:29, 121:3,121 :15 122:9

ERlCKA[11- 1:7errorlgj - 58:2, 62:12escags [11 - 47:2es clal - 44:9Esgm-1:21, 1:22,

123essence [5] - 97:17,

91:6 101 :17102129, 131:9

established [3] —

25:22 26:23 27:5etc1z]- 15:10events 91- 43:1,

100223, 197220,107223

EVIDENCE [1] - 132:8evidence 1121- 42:19,

75:24 100:11102:20, 119:19,117:22, 117:24,118:24,118:29,119:2 11 :5

evident [11 - 32:12exacg[1]- 120:7exac - 62:21

62:22, 113:11,116225, 121:23,123:15,126:15

examination [3] -

83:5 120:2? 132:7EXAMINATION 11] -

1328examining [1] - 86,'24examgle [5] - 8:8,

20:27 :10 :1374:24, 95:7, 107:26,12;:

excel|en_t,|21- 106:10,

H23exceg [:1] - 17:8,

36:27, 54:24, 97:13exceI_'g§111- 15:6exclude 1:] - 43:12,excuse - 11 '1executive [92] - 10:18,

19:19,11:2,11:3,11: 11:9 12:212:20 12:22 12:2513:4, 13:8, 13:13,13:18, 13:27, 14:4,15:1,15:22,16:10,16:17, 16:25, 17:2,17:6, 20:14 2112,

21:11, 21:21, 24:2,24:23, 25:9, 43:21,59:5, 65:5, 72:19,74:9, 74:13, 76:13,84:1 85:7 90:2491:13, 92:4, 92:9,95:29, 36:27, 99:8,39:20, 101:6, 107:2,109:1,110:5,11 :1 117:5117:8, 117:1§,117:17,12g:21,124:12 128:18129:11, 1323

Executive [5] - 11:16,11:19,11:27,12:18

exhibigra - 48:7,50:9, 6721, 89:10,111225

Exhibit [15] - 11:23,30:6, 30:23, 48:22,56222, 37:12, 57:14,59:11 0:15 67:1186:23, 87:6, 88:3,8821 113:26

EXHIBIT [5] - 4:6, 4:7,4:9, 4:11, 48:14,48:25 67:7 111:2?

EXHIBITS [1] - 4:2existing [1] - 57:19exiss [A] - 36:3,

47:27, 54:9, 105:19exgtations [1] -

103:1?exgcted [1] - 129:21exgecs [2] - 190:27,

1922exgnse [1] - 113:5exgrlence [1] - 93:8exgrtise [1] - 70:10exglainrz] - 11:5, 12:7exglained [1] - 71 :24Exgress m - 31:12ex ress -72:1

QLZexgressed 11] -

10 :10extra [1] - 33:1extrernel\r_[z1- 46:23,

125120

Eface - 24:1 5:15Facebook ['31- 88:7,

89:3 121:12faciIig|1]- 36:22fac - 15: 17:25

58:13 65:14 65:2080:10, 81:18, 85:3,

785:15 86:15 91:793:18 94:9 117225126:15

FACT [1] - 3:2facts m - 118227faded 11} - 103:11fades m - 93:14failed [2] - 80:16,8219

failure [2] - 85:2,

9521fair [13] - 7:24, 17:20,

39:10, 49:2, 49:6,49:9 84:16 92:26101 :16 101122115:10 115:12117213

faim [5] - 9:3, 60:13,69:6 91:1 12 :7

faimessm-104:19faith [3] - 23:23. 28:9

53:18 63:26 84:599:21, 94:6, 117223127225

fall [1] - 110224falls [1] - 27:12false [51 - 99:21,

82:10 82:11 116:6familiarljl - 22:20,

41:21 :3 110:27127:1

fami - 126:24far1z1]- 21:24, 23:2,

25:27 26:9 29:435:27 41:10 45:349:3, 53:10, 69:1574:2, 83:19, 85:14,90:7 1 :15 109:5193:9,113:13,116:8 129:21

fatheru] - 113:1fa:_t[11— 113:21Februag [9] - 26:19,

29:21 30:2 84:1184:19, 85:5

fee [51 - 8:4, 8:6, 8:10,8:11, 8:16

fellow [11 - 6:6feign] - 86:2few [51 - 39:2, 43:7,

55:27 102:13 111:3fiduciag [19] - 22:5,

23:21 53:18 74:681:21 84:1 90:2094:7 101:1 127:23field 111- 70:10fi ure -12:2

33:23 40:24 78:11

llgfifigures [1] - 72:3

FILE [1] - 1:2file [1] - 50:2filed [51 - 54:29, 54:24,

77:20, 77:23, 77:25,78:7, 113:14,118:15

files [11- 39:14filthy [1] - 24:8final [g] - 83:14

125:26finalized [1]- 14:5finances - 6 :5

79:8, 94:19financlal|1§1- 20:4,

20:7, 68:26, 93:2,69:7, 63:16, 70:19,70:26. 70:27. 71 :10.71 :14, 71:23, E25,95:1 117:2?128:10

fine [5] - 15:12, 53:4,72:23, 129:21

fingeng] - 22:16,2915fingers [11 - 9:25finlsh [2] - 82:21,8329finished [1] - 87:18Flre [:1 - 5:14, 5:18FIREARMS [1] - 1:10Firearms [191 - 5:24,

6:27 7:8 7:1790:10, 72:3, 85:9,97:10, 96:24, 130:14

firearms [5] - 6:8,9:15, 6:17, 6:18,Zflzéfirm E] - 70:24, 71:3,Z$2firms [2] - 74:14

109124firstugj - 18:26,

24:1 44:9 48:850:22, 52:19, 67:10,102:11,111',21,120:15

fiscal [1] - 69:8fig[g]- 127:11 127:12,

127:13five [5] - 79:4, 79:7

103:26 131:6131:29

FIVE [1] - 3:29flashing [1] - 122:22flavorm - 91:26, 93:7flawed [1] - 63:25flig9ingm- 127:19fiows [1] - 69:19flying [1] - 73:27folks [1] - 86:15followlal - 27fi,_


53:27, 71 :27followed [5] - 29:23.

54:24 72:24 97:23following [191 - 23:18,

23:19, 38:9, 38:21,43:26 52:26 55:572:10, 74:4, 31:5

FOR [5] - 2:20, 3:1,3:6, 3:25, 4:16, 35:2

force - :13 87:1588:16, 194:10,104:29

foregoing1z]- 81:15,1 3:4

foresee [1] - 52:3for-mtal - 4:11. 26:1.

36:29, 55:25,111:27,113226

formal [1] - 117:18fonnerm - 27:19,

103:9 124:12forth [5] - 37:22,

113:9, 122',12,127216

forward [gm - 6:21,25:23, 26:6, 43:19,44:8, 59:2, 63:26,71:10, 74:22, 91:2,103:2 103:6103216, 103:21,105223, 119:21,123211, 127:7

forwarded [11 - 34:2foundation [1] - 68:8founded [11 - 43:4founding [1] - 6:24

Fournier[2§] - 16:13,24:4 32:10 32:2033:16 33:25 38:746:1 46:3 46:1947:9, 97:3, 102:15,196222, 106227,10922 109:21109:27, 113:20,115:18,116:21,117:22, 118:24,

0:1Foumier's [21-

114:23 117:2fragmented [11-

11 :27fragments [11 - 25:16frame - 7:12franku [§] - 24:24

8527, 103213,117220, 124:6,12 :27

free

—L

I:

-92:17


Z-_ 8

fregueng [1] - 20:24 glance [1] - 54:4 29:27, 30:22, §2:1, hope [21 - 1§:1Q, 1fre Lien - 74:23 glasses 111- 14:17 33:19 34:10 34:19 106:15 indexed [11 - 116:1§

1_23:_7 goa|m-24;2o 41:18 42:1 42:13 ho ful -50:6 indicate [11-85:26FROM[z] - 2:25, 3:7 ovemance - 6:2 42215 42218 42224 horrible 12] - 24:10 indicated 12] - 36:6fron;[§]-43:14, 61:21, 97:17, 43:4 43:14 45:19 hours (51-31 :3, 0

43:15. 50:22. 50:24. 12519. 125:4. 4592 46110 4013 31:11 45:7 125:24 indicates 01-33:057:4,77:17 125:5,125:12 48:10 4 :1 :24 individual 0.-5:12

fulfilledul - 103:4 governing [1] - 14:7 49:23 50118 51210 | individuals [Q] - 6:7,full 051 - 57:25, 53:1, government[2] - 5:11, 54110. 55116. 5721-

'70:13, 33:17

51:12 54:25 71:11 11321572:20 74:11 32:2 goven1menta|m- 65:17 55:7 53:22 67:18 72:13 3217 Industmm-55:25,35:7 33:3 94:21, 11 :11 671 71 17 105110 12712 55:1,55:25, 57:149gn5,11422, gradayons01—7m15 5&1?-53”5-50191 12700-1297 57n7,57n3,3720,114:24 grantedm-6:17

fulhz 151 — 12:9. 80:4. greagm - 125:5E55 1075

gross N] _ 12a:16 77:25. 7823. 7825. 3:26. 19:10. 19:11 info;-mm _ §g-11fumble m - 23:14 9,0000 0, - 27:13 EflJ£4lJ1‘fl- m1_q1_ns121L>:SI._ 35$flllllfe - 941 4 grounds [1] - 62,214159. groug[2]-84:24, 33312 93320 95324 m 15:5 22:21 27:24

fuggyu]-12¢6 9201 19Qfl9»1QEl§- §§2§29$3 29n3 331 333gEfiE00.-12z1a ‘°‘22 ‘°“2‘ Hnm9y22§L3;11E§2 37m,4322,4g23

G grown [1]- 12o;13 102:9 104315 6 47:6, 4_B_:2, 49:13,_ guess [11-11:25, “ma 11”‘ u 50:15, 73:5 30:5gagm-23:3 23:9 15,15 31:13 35:5 111125 113117 115:5, 115-,13 33:2 92:2 -15gagsu]-6915 3afl3 6“19 1,3”, 1uLLJ1§d9. inifled - :25 99n7,ga13gathering 01-35:13 g,,,da,,c,,m_32,20 1&5» im -92:3 100:14 1g1:11,general 001-31 g,,_,,s,,,_,25,0 Lzfiflu impgnancem-72:5 107:3 103:22

13:15.13:17.15:27. 130=_1Q¢39&_ 35:10 35:11 109:12 115:1015:24, 13:25, 15:27, H 51- irnwrtan; 131 - 22:3, Information 1;: - 5227,17:4 21:5 21:20 - ‘—3“—7-J3-14°» $23 §7:5,3g:3, 7_:a24:10, 24:17, 30:13, HA0"-T -3; 131519 131321 53:14 54:25 35:2 infonnedm-105:3,32:9, 33:4, 35:25, Hage,,u,_9;1037:2,, 40:19, 43:21, 1014 1022 1204 “+11-D-1:1—=2§ imgressionm-16:14 infon11ing[1]-118;2143:12, 52:15, §3:10, 030,2, _ 110,25 hL“‘-1 imgre5sions[1]- ing11]— 35:1155:25 52:5 53:3 11020 15:20 20324 2355 _6_2:_12_ initial[51-61:8, 75:13,63:11, 64:24 §g:13,70:23 71:22 73206§:26, 91:26, 93:2196:21, 97:19,1Q9:14,112:17,12 :1 1 :14

generaly m - 8:1412:21 14:10 30:1672:10. 61:4, 101212,

generated [:1 - 22:14,

.9_E.i15George [1] - 112:11Gin er - 1 :13 .116220 116124

given [23] - 20:21,21:10, 33:13, 36:1,59:§, 66:17, 73:24,73:26 76:11 :2164:2 96:6 96:6104224 10521616623, 106:2§,109:11 114:20‘l14:22, 117:3.119:7, 127:16

handed [1] - 50:23hands - 1 :14hang [21 - 65:27, 66:1haggy; [5] - 24:20,

29:19 34:20 94:22

1hard 121- 5:6 1:50:15hann Ln - fi:1, 94:10,

94:14 94:16 94:25haste [1] - 116:16hasy|1]- 116:12hate [1] - 36:25hated 111- 125:2§HAVE [1] - 4:16head [2] - 17:18, 73:16headeru] - 50:15health [11 - 1Q3:12heard - 97111017heau [1] - £210flilimfili.Eiflllc12:7 1 : 13:2213:27, 16:22, 10:26,19:4, 19:§ 1914

flfihello - :23hel - 11:25 96:1helgfui [5] - 15:10,

25:16, 34:21, 44',1§hereh - 133:herein [1] — 85:3high [1] - 71:12highly 151- 65:12,

65:13, 90:6hindered - 60:1hire 1:} - 97:1hired [3] - 24:4, 97:25,

124122historian [1] — 6:2histom [1] - 6:3hm [§] - 11:14, 32:6,

57:20, 67:12,1 : 123:2

hold [3] - §,1_1:25, 85:4,

.92_I11_holding [2] - 36:26,

$7holds [11- 16:12home [1] - 60:25

imgrogriegm] - 74:7

Inability [1] - 94:15inaggrogriate [1] -

§_i1_2.lnc[1]- §1:13include [3 - 12:26,%

includes [,3] - 12:25,

Elincluding [5] - 43:16,

68:7, 86:24, 120:10lnconsisteng [1] -

J

Eincoggorate [1] -

Eincoggoratedm -

%lncorrec;[:1- 40:1,

57:1, 57:11Indeed [21 - 5:6, 66:11lndegendengm - 36:4INDE - 2:1 4:2


116:11,12§',1,12§:§inkllng [1] - 72:14inguyz] - 124:6,

124:11inguiries [1] - 34:11insisted [1] - 82:4insofarm - 5:20insgcg [5] - 31 :26,

35:5, 42:7, 44:27,45:14 95:11 99:4109:9, 115:7

Insgction [§] - 4§-,2g,10Q',1, 109:6, 115:5,115:18,11§:22

instance [1] - 27:7Instances [1] - 26:13instead [1] - 16:25,“Iii

instructed [Q] - 32:37,B§:22, 116220,130:11,1§1:13,1 1:14

instruction [1] -114213

INSTRUCTIONS [2] -


2:18 34:27instructions [5] -

21:21, 24:16, 34:16,83:16 115:17

insurance11]- 120:13intended 15] - 44:7,

63:4, 95:27, 97:5intent 12] - 25:24,

8 :22intention [2] - 51:19,

122:21inter[1]- 89:5interestm] - 81:7,

81:22 1D3:11interested [2] -

193114, 121:23interests 11;] - 28:8,

63:25 :27 74:884:6 85:14 90:2293:27, 94:6, 195:13,126:1 127:22

interim [1] - 105214intetiect [1] - 26:24internal [1] - 58:7internet [1] - 122:2;intet,grgtation15]-

90:18 125:2312524, 125125

interrugtlg] - 50:18,

Einterrugting [1] —

fifiinterval [11 - 14:23interviewed [11 -

1 3:13invigoratem - 126:9involved 151- 71 :6,

125:1 126212L291

involves 12] — 126:23,126227

ironical - 60:2irreguIar[1]- 85:13Is 151- 2:11, 2:13,

3:26 19: 1 :11issue [19] - 59:4,

62:25 64:18 78:2678:27 82:9 93:9104:1 104:2 129:23

issued [1] - 91 :4issues 15] - 74:16,

92:15 103:12122:6, 123:21,127219

lT[:1- 2:13, 3:26,mu

item [2] - 44:9, 63:5itself [2] - 11:21, 58:21

2Jacobs [2] - 1:25,

133:15Januag 121- 22:26

L221Jarrold [:1 - 9:14,

9:15, 10:6iob [4] - 98:9, 126:23,

126:24, 129:14Jones [1] - 6:6Journal [2] - 99:10

1 :14ioumaI[11- 99:22JUDICIAL [1] - 1:5JULY [3] - 2:23, 2:26,Q

July [25] - 4:8, 48:11,48:14, 48:18, 48:29,49:13 49:26 50:650:21, 50:26, 55:5,

931:19, 49:1, 59:9,72:25 88:5 88:899:17, 99:23, 199:9,118:5,119:9,119:25, 127:26

known [2] - 99:16,100:15

Kug [11 - 9:17KURT111 - 1:7

Llack [1] - 106:22laid [1] - 103:5language [1] - 124:9large [91 — 42:25,

59:16, 60:13lamest[11- 111:3lastnm - 13:19,

13:1 41:12 61:2163:2 75:14 75:22

56:23 57:3 57:3 :.JL123=221 1157:19 59:16 59:22 _60:16 61:21,fi:7, 4511654;13 5735 53:1 latitudem-35:261:14:20 124:1a |:ILi1.u.Ifi§.

Iaw[:1- 6:8, 29:20,

K fl"" Iawfulm-99:13K.G up - 1:23 laws [11 - 6:9keeg [s] - 21 :25 Iawsuit[1]- 33:21

22:16 26:9 29:350:1, 58:15, 93:12,80:8, 102:24

keeging [jg] - 21 :3,25:27, 29:14, 53:3,94:7, 97:24, 105:24,107:26, 110:14,127:2;

kegt[1§]- 17:25, 18:6,18:9,19:17,29:9,28:22, 29:27, 39:10,40:4, 40:9, 46:19,118:6 130:19

key [1] - 129:20kicked [1] - 122216kind [15] - 7:4, 25:24,

37:19 57:6,62:29,72:19, 98:3, 190227,191:2,112:25,128216, 129112,129:14 12 :16

KNISELY [2] - 98:15,E

Knise - 1:2214:1 79:1 10221110422 104:23113:19 115:2

knowing [11 - 106:7knowledge [15] - 7:14,

Iaggeru] - 106:18layers ['21- 34:1,

1 1 9: 11la1[1[- 68:7leadershig [1] - 80:20least [:1 - 56:18, 89:5,

1 1:15leave [1] - 121:3leaves [:1 - 46:9, 79:1leaving [1] - 36:21IedJ3J - 43:1. 116:22.

'

1_2_2I_7leg [1] - 11§:26legal [12] - 21:16,

21:24, 29:9, 71 :18,99:19. 91:11,106:12, 106:19,106:17,119:19,112127 115:11

legislation [1] - 6:20legitimacy [11 - 85:10legitimatelz] - 27:25,

§5L1§lesson [11 - 6:3LEl'I'ER [2] - 3:18, 4:6letterm] - 30:7, 30:9,

91:7, 91:20, 31:22,56:23, 56:25, 97:8,57:15 58:5 58:21

58:23, 99:27, 59:10, M61:22. 77:3. 77:13. —

83:11 88:9, 139:6 m.hm [5]- 11:1461116 32:6, 57:20, 67:12,letters L31 - 65:9, 109:25 123:2

55211 9719 machinem - 128:23levels [11 - 69:27 MACKENZIE [11 - 1:7

life1§_1 — 8:9, 8:13,8:16 8:17 32:18

limitation 111 - 88:25limitedm - 90:6line [2] - 52:27, 129:9LIST [1] - 3:25list [3] - 43:26, 47:5,

47:29, 80:1, 114:2§,115:6, 130:19,131 :29

LISTED [1] - 4:18listed [2] - 2:5, 13:19live [21 - 20:23, 112111living [1] - 51:17LLP [1] - 71:5lobby [1] - 96:2locate - 2 :8locations [1] - 37:9lodgings [1] — 24:18|og[z1- 5829, 58:16LOO - :1look [ag] - 7:22, 11:19,

12:3 15:11 22:1099:9, 36:24, 39:14,44:11 48:8, 59:19,53:13, 53:19, 55:2,59:8 65:12 65:135%

65:18, 67:27, @220,71:14 1:24 93:21100:3, 101 :26,102:18,11§:12,11529, 128:24

looked [9] - 20:25,103:8. 115:25.129:7, 128:6

looking [121 - 15:19,25:6, 48:16, 91:851:10, 52:24, 54:11,62:15, 68:12, 194:9,109123 126:19

looks [5,] - 19:4, 50:11,90:14, 55:14 62:19

lost[z1- 21:18,103:11loud [2] - 106218,

114118Luchia[J1- 9:17LUCIA [1] - 1:7Lundgard [=1] — 9:14,

9:15 1 :7 10:8


43:17 44:1 89:1989:22 90:9 90:25116:7,121:9,121:15, 122110

magazine|1]- 18:3mail 15] - 30:11, 60:6,

60:8, 86:22mainm-111:3maintain 1;] - 20:17,

95:7, 108:21MAINTAINED [2] -

2:19, 19:11maintained [5] -

18:24 19:4 20:25fl

maintainingts] - 21:3,22:9, 25:5, 108:9,

1i?maintains 21- 17:21,

198:14maintenance [1] -

Emaior[;|1- 123:7maiorig 151- 27:6,

54:7, 59:29malfeasance [1] - 74:7manage [1] - 40:19managed [1] - 17:1management [2] -

22:19, 37:25manager mt - 16:1,

16:19, 19:29, 16:24,16:27, 17:4, 21:5,21:20, 24:17, @:18,32:10, 49:29, 43:22,63:11, 79:21108:25,112:17,129:11,129:14

mana ers - :101 8:27

managing [2] - 22:19,

EManitoba [g] - 103:3,

ELLEmannerfi] - 13:8,

24:22, 29:9, 85:19,$1

MARCH [2] - 1:173:23

March [:9] - 5:5, 7:20,11:11, 30:1, §1:26,32:4 32:5 32:7

A32:17, 98:10, 41:14,41:16 41:26 42:1143:12, 45:12, 49:15,77:16 77:21, 78:9,84:9 87:5 87:2288:4, 89:16, 91:25,99:22, 99:1, 190:4,101210 114:1119111

Maritimes[11- 9:29ma -4 :7 48:22Mattin 111 - 77:27match [1] - 53:1fL1¢fl|.IJ.li15materials [2] ~ 96:4,

124:10matter [15 - 23:6,

25:15, 29:29, 99:29,35:21 45:4 45:1069:14, 71:26, 72:6,74:17, 74:21, 91:12,94: 104:22

matters [12] - 60:3,80:2 81:15 97:15106:24 107110107:11 107:12107:18 1072221 7:24 118125

MAY [1] - 4:17mean [15] - 11:17,

12:1 33:20 9:172:2, 72:3, 92:1],107:23, 110:17,118:11,12§:5.123:7, 124:6,126220, 12929

meaning [4] - 61:26,88:21, 101:15, 104:2

meanings [1] - 56:13

37:6, 75:5, 116:9mean; [:1 - 61 :25,llii

measure - :20media [9] - 95:9, 99:9,

.&flmeeym - 28:5, 82:5,

83:4 85:11 112:2512 :23 1 :20130222

MEHING [21- 2:29,

iflmeeting [13] - 13:15,

13:16 13:17 14:114:4, 15:4, 28:21,41:14 41:22 43:1644:8, 44:13, 44:15,49:4, 49:8, 49:1449:17, 49:18, 49:2750:7, 50:25, 51:22,

56:20, 57:2, 57:4,57:27, 60:23, 60:25,.&E62:21 63:3 63:663:10, fi:24, 67:25,79:23 71:22, 74:18,74:20 83:26 84:1884:20. 84:23. 85:4.85:18. 85:20 85:21.85:24 86:9 86:10.8§.=_1A._§§=_1_|3.87I_12_._87:23. 87:25. 88:13.88:27, 99:21, 97:11,98:12. 98:21, 98:27,100218, 117:8,117:18, 124218,3.2.5.15

meeting'd [1] - 117:19meeting ml - 14:8,

19:14, 20:11, 20:13,20:27 21:1 26:1329:24, 26:26, 27:27,28:11, 96:27, 37:9,43:20 44:19 47:26

%._flJ_I§&;1_1...84:13 84:14 85:2599:24 100:16109:15 109:18109:21 128:15

rnemberum - 7:15,7:25, 7:27, 8:13.15:5 28:17 52:1590:3 114:14

members mg - (5:24,8:9 8:21 8:2210:29, 19:8, 19:19,18:14 19:26 25:329:19, 31:9, 99:1,37:5 40:8 45:1446:1 47:7 47:2651:22 52:17 54:854:23 55:20 55:2355:24 57:18 57:2559:22 60:18 61:2461:25 61:26 62:362:7, 63:6, 70:22,71:22 72:18 72:25flifim.95:22 99:20100:16 101:6 2108:24 115:8117:7 117217120:5 120:11120:12,120:14,122:21,123',11,123:14 124:121&8

members‘ [21 - 46:21,

1046:22

membershig my -

E1.._fl.fl.8_I3-8:10 8:11 8:128:16 8:17 14:2724:23 :5 39:2655:12. 56:6. 58:1.59:15, 59:20, 60:2,60:4. 60:14. 65:15L65:21. 71:8. 72:12.83:25, 93:26, 8427,85:9, 99:19, 9_6_:14,108:22. 114212.114:15,114:25,115:6, 120;19,120:13, 123:13,124:3, 129:17

MEMBERSHIP [11 —

M ;

1D8:23memorandum [1] -

3_7£mentioned no} - 22:7,

22:23 29:12 53:2154:19, fi:16, 74:12,103:1, 121:§,122:29

mentioning [3] - 79:29message [2] - 89:26.

121 :12messages [11 - 116:6me; [5] - 32:9, 39:6.

48:1, 81:29micro [9] - 22:18,

37:25 40:19mid [1] - 46:9midnight[1]- 121:2mighgm - 7:2, 29:24,

37:22 47:2 106212127:1 130221

mind [3] - 65:3,112:16 123:4

mine [1] - 80:24minister [1] - §3:17MINISTERIAL [1] -

Eministerial [2] - 6426,

.51minute [9,] - 7:4,

13:14 13:19,15:17,28:1 28:21 36:2098:20, 99:29

MINUTE [1] - 9:21minutes L45] - 4:7,

12:11,13:11,14:9,15:3, 15:9,1§,'1§,18:14, 20:11, 20:13.20:27 21:1 22:2428:10, 28:19, 28:22,40:5 40:8 41:22

41:25. 43:7. 43:11.47:25. 48:17. 48:25.49:2, 49:6, 60:15,91:23, 89:9, 80:10.88:6, 88:11, 88:13,

fl101 :20. 101 :27.102:3. 108:9. 125:6.13 :23

minutia[;11- 91:27,118217 118:18

misleading [5] -

80:21, 85:2, 87:29,

Emlsled [1] - 85:9mismanaged [1] -

Emismanagement [1] -

92$ME§

30:23 32:10 33:1633:24 33:25 34:1735: 35:2 8738:10 38:12 41:343:1 46:1 46:346:4 46:18 47:687:26 88:5 89:3

§fl5.._100:3. 100:5. 101:5.191:12, 102115,106:27, 109121,109127, 113:20,

fl1_L1_1.fl4_=2.§..

3j:11.111:14.118:5. 118:8

motion [11] - 43:19,49:26, 43:27, 44:2,44:24, 45:9, 4§:5,45:5, 45:8, 74:22,E

motiongm - 43:18.99:24, 99:26

motives [1] - 85:17move |g]- 24:6 25:23,

Emoving [5] - 9:29,

44:8 63:13 63:25MR [131] - 2:16, 3:22,

5:2, 5:3, 5:29, 5:22,7:6 7:11 9:23 9:2411:22, 1129, 12:7,12:8 12' 13:2213:26, 13:27, 14:3,18:22, 18:29, 19:29,19: 1 :4 19:519:6 19:14,19:21,29:27, 39:5, 30',22,99:27, 92:1, 32:3,

34:13 34:19 34:2134:24 35:3 41:1841 :24. 42:1 . 42:4.42:7 42:13 42:1542:16, 42:18, 42:29,42:24 42:27 43:443:7, 43:19, 49:14,

115:5,115:18, 43:1 4 :19 4522111624, 11525211627. 45:22. 45:27. 45:10.116221, 117:2, 46:13, 48:9, 4§:9,117122 48:10 48:11 48:13

miss [:1 - 130:10 48:16, 49:22, £224,MISS [2] - 2:19, 9521 49:1 49:23 50:6missing [5] - 24:25 §0:1§, 5124, 51210,

2 :1 25:9 69:21 51:12 :10 54:15mistaken [1] - 90:17 56:16. 56222. 57321.mode| ,3, . 125;1g 57:24 63:23 64:2models 121- 8:25 *.i.:..545315 5439mo] _ 2413 64215 55217 65:23moment [5] - 19:18,

79:15 111219 L-.§_.—..7=173 57151:113 131115 5726 57:9 68:7

moment's [1] - 35:14Monday [2] - 32:5,

L7month [31 - 31:2,

31 :10, §7',27monthly [1] - 69:2months [5] - 26:9,

2:18 37:27 :22

£2momin - 46:

1_21_=3.mos§[§] - 2§:2, 70:7,


68:11, 68:12, 69:15,§8:16, 68:18, 68:19,68:21, 68:25, 79:19,75:18, 79:22, 75:2575:27, 76:7, 76:22,77:1, 77:10, 77:1177:15, 77:21, 77:24,77:26, 79:1, 78:3,78:4 78:5 78:878:18 79:7 82:218225, 84:16 84:19,84:21 86:23 86:27

87:16, 87:17, 88:12,98:15, 98:18, 98:20.98:23, 98:24 99:3,100110, 101216,1D1:21 101122101224 102:5102:9 103:1104:15 105:2111:1 111:20111221 11124111:26, 112:9,11§:17,113:23,113:25, 115:1115:9,115:10115:15, 119:5,119:9,120:1,120:§,120:25 121:4121:7 130:5 130:8130:10 130:17130:21 130:26131:1 131:4 131:7131:9,131:10,131:17,131:19,131:20,131:21,131:22,1§1:2§,132:1, 132:4

multigle [11 - 125:3musyg] - 10:26,

27:14 65:7 93:25mutual [11- 37:19

8name [5] - 6:23, §:2§,

7:16 10:21 31:12

73named [91 - 5:12, 6:6,LN

names [2] - 9:9, 9:11National [19] - 5:14

5:18 5:23 6:26 7:87:17 72:2 85:987:10, 96:24

NATlONALm - 1:10national lg] - 24:15,1

nature [1] - 22:20,29:21 35:9 46:2473:25 127:14 128:4

necessari ~ 97:16necessag [9] - 81 :9,

82:19 86:12 117:3

1&5necessitated [1] -

fl2_5necessiym - 122:24need [21] - 22:1,2729, 36:12, 37:25,38:2 38:4 39:139:1 3, 42:1, 51 ',12,

51:15, 52:19, 69:17,60:29, 63:12, 66:17,§6:26, 83:3, 85:27,93:23 97:18112:13,124:22,124:24 127:4,127:20, 129:9

needed [5] - 26:26,51:27, 112223,124120

needs La] — 24:19,24:22, 39:5 40:15,

11131:2

NOTICE [1] - 2:22notice [9] — 31 :9

35:14 49:16 49:2550:25 51 :5 63:19E

notices 111- 60:9notification [1] - 59:15notified [5] - 59:20,§9:22. 59:24. 63:20

notifl [1] - 80:16notwithstanding [3] -

93:16 113224 132:3offensive [1] - 82:7office Lgg] - 10:15,

13:22 16:5 16:1716:19. 17:1. 17:12.17:21 17:25 18:718:11,18:24,19:17,20:10, 20:24, 21 :2,21:8, 22:9, 22:13,23:5. 23:10. 23:17.29:22, 28:24 30:12,30:15 31:6 31:25

30:15, 31:5, 44:15,46:18, 47:19, @:10,51:17, §2:14, 59:18,60:6, §9:27, 61:7,62:3. 62:17. 67:24.71:12, 7§:22, 76:11,76:13, 76:19, 77:5,77:26, 81 :9, 83:24,84:18, 99:3, 93:25,97:9, 199:27, 101:2,103:2, 195:9, 105:9,109:2, 109:21,

§_3:6, 8225, 112:25, 30:1 32:11 130312 3228. 34:1. 34:2. 111:4. 113119.12429 nuance - 1:13 34:12, 34:15. 35:9. 114:s.121:19.

rIegatiVil_:[[]]-26:4 NUMBER 111-132 36:15 35:23 37:15negligengn]-56:1 ,1umbem._11-5;13 39:2 39:10 40:5 ll

__.1J1:Ne|s0n-7115 37:3, 50:4, 59:9 _ °"eS - 554neverm]-25:25 79:29, 79:27 80:8 & m_9mu;1fl:_62

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25:22 71313 12417 123115 102:1? 107:21 fl_1__1_123216. 124:19. 1o7:24. 1oa:1e_ o|:_u_:n 121 - 74:11129:9, 127:17 129:3 0 10820 110217 96:12

new|1!J_11- 26:21 — 118:7. mm. ogragd [11 - 125:17neg[51- 14:22 15:4 obiecm]-79:8, 11£;.L30_:1;*4.. ograting 111-54:13,

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6:5 7:24, 7:26,7:27 ob'|ected|1|-79:59:2 1s:s.55:a, 0BJECTlON|gj-55:13, 55:22, 59:12, 4:21 119:3 . §o:19, 66:27, 35:1,68:10, 68:19, 68:23,72:26, 74:25, 89:7,91:17, 95:6, 1g:24

ENFA's [11 - 99:16NFA - 7:10nine]1]- 107:7NO |2§j — 2:8, 2:10,215, 2:21, 2:24, 3:1,3:6, 3:8, 3:11, 3:14,3:17. 3:20. 3:24. 4:4.19:7 34:23 49:2464:11 65:18 68:2275:19 76:1 76:2377:12, 98:25, 191224

nobody [5] - 31 :29,62:18 1 :18103:20

nobo ‘s - 103:21nomination [2] -

13:18, 91:9non [1] - 7:11non-share[J1- 7:11nonsense [1] - 25:29normal [1] - 25:26nose [1] - 24:11noted [1] - 112:4notes [5] - 28:10,

28:18, 49:19, 133:6nothing 121- 45:6,

obiection [5] - 42:17,48:24, 67:6, 111:26

OBJECTIONS [3] -4:15 4:16 4:18

obiections [1] - 48:13obligation [21 - 21 :16,£1!

OBLIGATIONS [21 -2:11, 19:9

obligations L51 -

18:16. 18:17. 18:23.19:1, 4729

obliged [1] - 43:5observed [2] - 107:20,flfl

obtain 121- 43:2,

Hiohviousm |2] - 33:21

191224occasional - 81:7occasions [11 ~ 97:90F[2z|-1:3,1:15,

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OFF [§_| - 43:9, 64:4,

85:23, 96:9, 96:1796:27 98:4 108210E

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OFFICERS [1] - 9:25offices [5] - 19:7,

2426 110211 118116Official [1] - 133216officia|[s] - 17:21,

47:29, 47:21, 9527,99:5 108:4 108:71 8:14 117:26

often[z] - 22:11, 81:5oiled [1] - 128123ON [1] - 1:14once - 29:1 8:9

119111 131:18one1;g_]- 5:11, 6:23,

12:22, 14:7, 14:15,14:25, 19:18, 17:25,24:3, 24:5, 24:16,25:7, 29:3, 29:15,


87:19, 89:26, 91 :12,19¢_l:24, 104:2§,123:2?

oggrtunities [11 -

§L4oggrtuniy [:1-

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oggose [3] — 78:19,80:5 82:14:.___

oggite [1] - 126:15oggosition 151- 78:19,

79:11, 79:24, §0:2OR [2] - 2:18, 34:27Order [5] - 14:6,

14:19, 26:17, 26:21order112]- 15:1, 19:9,

23224 27:10 27:1729:12, 64:22, §g:23,78:23, 79:4, §2:6,

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46:6 60:2 77:2ordinam [1] - 98:1oI_'ganization[y1 -

11:7 14:26 20:2122:4, 24:15, 24:19,25:11, 25:22, 27:4,29:9, 37:5, 38:24,46:24, 52:7, 53:20,


I60:11, 63:27, 71:15, 78:9, 84:6, 87:3,74:9 81:4 84:6 87:4 87:21 88:485:14 90:22 92:10 69:15 91:16 98:2194:1 94:7 94:11 98:27 1 :894:26,105:13, 1D3:26 104:1126'10 127223 106220 107:7127:25 115:16 116:4

organl2ation‘s [1] - 116219 117:21128216 118223

organitions[5_1 - Qaraglaghs [5] - 12:4,26:21, 36:16, 92:6, 95:1, 106:8,112:26,126:26 114210

original [11 - 43:19, gram:-zters [1] -51:7,112:3 106225

originalfl |21- 6:5, garden m] - 9:20,ggg 47:21 48:5 51:14

originating [5] - 6:9, 7:2 122 29102214 104217 119',1§1D4;1a grliamentag lg] -

otherwise [3] - 27:7, 272 7' 27:1437:1 124227

ourselves [:1-64:21 36:14 36:15 41:19ousyn—11n5 52fl§.§L§.§L1.out|inem-2g;1a 61: 7 78:1 7 :22ougsidem-3§;17 78:24 87:26 98:11

ovelseem]-9:1, 6:4, 1 132 11732_2_1_;_1_§ 12528 126211

ovelseeing [2] - 46:6, 1°11-3 ' 357510:2 228629992;

own [5] - 3:27, 73:13, 10%117:24 127:2

owned [1] - 70:21 9_7.2flgarticular mg] - 6:10,

P 12:11.16:21.17:7.‘ 17:8. 17:9. 172102

.m ~ 0:2 132:9 25:13 26:19 26:22P.Mm-5:1 27:7 28:6 30:15PAGE-21:1 - 2:8, 4:4,i

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ages 5] - 14:24,89:2, 89:7, 66:4,1

gins [1|- 127:16gin; [1] - 24:9Egrm - 18:10, 28:1ggers [1] - 81:9PARAGRAPH [1] -

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37:17 38:1 41:141:19 44:10 63:1367:23 69:8 70:1080:23 81:11 82:982:11 85:17 90:291:19, 92:5, 93:10,94:11,96:1,97:1,

§§fi._9_fl.flfl._110218 110:26

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124:7 124227127:4, 128226

gr [1] - 40:2Qerfectly [2] - 27:25,E

gerforming m - 71 :6Qerhag [5] - 11;25,

52:8.67:19,111:17geriod [9] — 6:22, 23:9,

26:12, 24:26, 69:8,7'1_I9.£1_I.§L.Q1_2._104:12

Qermission [J] -

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12:16, 16:3, 16:4,16:5 16:7 16:2016:22,17:6, 21:10,30:15. 34:9. 47:10.85:23 109:6 109:7Hi

Qersonal [5] - 6:11,

§fl§£22

grsonaly [1] - 78:16,78:16, 78:24,107220 119:13,119:17,122:18

gersons [1] - 103210grsgective [1] -

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65:10ghoned [1] - 162:17Qhysicalym-19:16,

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24:10 24:12 24:21

35:15, 39:7, 67:4,62:26, 92:23, 92:24,92:27, 34:3, 101213,110224 111210115:19, 115122

glacing [1] - 112:7_FflNTIFFSJJJ - 1:7Plaintiffs [1] - 1:21glane [1] - 121 :6

1>tLteu1fl:2§Qlayed [1] - 123:7PLEASE|1] - 4:17gleased [1] - 128218POD [1] - 31:4goln;[z§1- 15,13,2fli233:17 33:19 33:24 .44:1, 66:6, 65:16,62:8 63:15 83:2268:21, 90:17, 93:16,98:14, 165:7,106:26, 109:6,11 : 11 :27121116, 122210,£2.25

6ointed1z1— 69:20,E

Qoinls [5] - 26:5,26:27, 45:8, 61:1,81:27 110:18

Qollcies [1] - 126:4Qolicy [51 - 9:1, 35:18,

35:20 46:27 47:4oo - :16128:14

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Qositlve [21 - 44:8,

E12gossession [1] -

EQossibilities [1] -

Epossible [1] - 46:26

ossib - 129:22Esfimli.

90:4, 91:_9_, 61:11,121:1? 121:21122:1,122:16

gosting [11 - 113:5Qotentlal [1] - 62:24gowernj - 125111,

125212 126214Qowefs [1] - 125214


Qowets [2] ~ 15:22,106:21

gracticalm [1] - 27:1

26:16 26:18 26:2227:8 27:16 29:1735:22. 53:3. 53:14.53:16 71:20 72:2174:15 85:25 86:2266:16, 63:22, 94:194:2 97:23 100226112:19,112:26,124:21, 127:10,127:12,127:13,6

gracticed[1]- 66:2gractices [16] - 25:13,

25:14 52:1 52:262:5, 52:26, 69:14,70:17 122:26 127:9

6r'eamb|e[11- 66:22

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minigregring 15] - 70:19,

108:3 108:7 124:7

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gresidenfs [2] — 17:6,125:24

gresiding [51 - 64:27,86:23, 100:18,108:10


gressing [1] — 74:16gresume [21- 39:12,

8114gram [3] - 12:5,

15:25, 52:20, 75:710D:13,111:1,111:6, 112:24, 124:5

|:_nreveng[z] - 19:5,15:7

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previously [:1 - 15:9,24:7, 78:5

gn‘marim|§1 - 71:12,85:9, 108:2, 108:6,120212

grimagg [1] - 106:26Prince1]]- 112211grincigles [1] - 72:11griorities [1] - 110218griorig [21- 41 :51125

grivacy [5] - 16:8,46:20 46:23 46:2646:27 47:4

grivate [1] - 46:22grigy 11] - 41 :1groblem [3] - 62:20,

62:25 72:15190:21,101:14101115 104:7105:7 124114

groblematic [11 -

£211groblerns [51 - 16:22,

2 :2 81:3 94:17grocedural [1] - 45:10grocedure[;1]- 53:26,

92:1 1 12:73.14.

grocedures [,1] -

23:18, 69:25, 74:5groceeded [1] - 24:6groceedingg [1] -

13 :5grocess [29,] - 53:21,

54:2 54:23 54:2655:9, 55:22, 58:2,63:25 65:1 72:2374:4 86:17 92:1112:24, 117123,126:6, 126:9,127:22, 131:13,131214

Qrocesses [5] - 52:13,52:19, 61:4, 111:1,111:8, 129:9

produce 51- 13:11,38:24, 39:27

groduced [5] - 87:787:11 1 16:24120:26 130:4

PRODUCTION L2] -2:20 35:2

groduction [9] -34:18 42:4 116:21

groductive [5] - 24:20,44:7 44:12 44:13

grofessionalizing 11]- 23:17

Profigizj - 7:20, 78:21grohibited [1] - 6:16groiect [J] - 58:20groggrlg] - 14:15,

12 :4grogem La - 26:13,

51:29, 74:1, 92:16,101:7ro - 88:23

grogose [2] - 52:11,1262

grogosed [2] - 43:17,

5226grogosing [1] - 74:24grogosition [1] -

Z522grogunding [1] -

fiéflflgrotective [1] - 46:25grovide [39] - 5:21,

29:1 34:14 37:448:2 49:16 49:2149:24, 64:5, 64:9,64:11 75:4 75:2376:1 76:23 77:1278:7 83:17 96:398:19. 98:25, 102:3,111217 115:21125: 1 0:3131:18 131:24

PROVIDE [3] - 2:15,2:21, 2:24, 3:11,9:14 3:17, 3:20,3:24 34:23

grovided|_11]- 2:9,19:22. 28:24 35:17,47:16 47:18 73:2377:22 109:11113:1B 114:20

PROVIDED [1] - 4:16grovides [1] - 70:7groviding [5] - 24:29,

37:6, 46:9 47:8,74:11, 68:2

Province [1] - 133:9rovincial - 8:20

grovision [5] - 27:3,27:13, 27:19, 74:26

grovisions [1] - 14:7A.C.E. Reporting Services Inc.

13Qublic 111- 20:6,

24:15, 24:24, 29:1572:27 95:17 122:23ublical -9 :25

gublication1;1]- 60:11ublic - 99:26

gublished |;1- 88:5,99:16 9 :21

gull [2] - 39:13, 39:14gulled [1] - 65:2guise [1] — 22:16guggorted [51 - 84:10,

95:19, 85:4, 85:6gumorting I1! - 87:9gu;Qose1:]- 15:2,

57:27, 71 :4gurviewm - 40:13gushing [1] - 28:15915 um - 28:1, 52:10,

59:18 :9 64:2197:4, 70:20, 74:22,74:27 89:8 93:2694:2 102116 103:5105223 123:10

gutting [1] - 72:7,128121

guotations [2] - 73:21,1:23

guote [2] - 83:18,104:19

guotes 31- 74:13,76:20 76:25 109:24

QUOTES [1] ~ 3:16

B

Q.gualified E] - 70:11,

103:2 106218uali - 19:16uarte - 14:9

152;uebec ~ 9:21UEEN'S - 1:3

QUESTlONED11] -

E2guestioned Q1-

29:17, 118125guestioning[a1-

19:15, 90:24, 38:1642:2, 42:20, 42:21,42:24 117:22120:24

QUESTIONING [1] -

11$guestions [2] - 120:2,

120:22gueue [1] - 39:8guick [2] - 60:26,

120:22guicky [2] - 116:9,12¢;

guite [13] - 7:1, 22:3,23:14, 37:23, 62:14,68:4 71:25 89:393:6, 102:9, 106:11,122:2? 126226

guorum [1] - 86:8

rails [21 - 128:21,128:22

raise [11 - 80:2raised [§] - 27:12

63:5, 72:15, 100:21106:25, 118:26

raising ['21- 94:4,

12$§Rant: [:1 - 9:18,

10:10, 10:1 1ralheng] - 71:11

81:18,113:4,122:8ratification [2] - 61 :10,

126iratifications [1] -

QEZQratified [:1 - 56:8,

59:12, 61 :16ratify [1] - 60:18rati in - 61:17re [11 - 126:9re-brand [11 - 126:9reacted 91- 90:14,

8925reaction [gj ~ 116:11,

116:12read [12] - 5:8, 13:20.

14:19,1§:4,15:6,17:23, 29:23, 79:18,84:27 87:1 3:222223

reader[1]- 70:1reading [5] - 38:19,

66:4, 69:9, 79:19,114:1? 123224

realization [,5] - 62:13,62:23 63:2 123:4126118

realize [91 - 62:8,123:20 124:19

realized [5] - 54:19,64:18 120:20122126 124114llié

realizing [1] - 62:16reaIIy|g1- 12‘,1, 14:17

25:17, 31:14, 62:18,82:6 103:13 126:7129112

reason [11 - 30:14

reasonable |§_1 -27:29, 35:14, 35:21,37:13, 38:29

reasoning [11 - 44:5reasons [1] — 99:4rebmnding [1] - 25:21rebuild [1] - 126:9receig; [1] - 11§:13receive [:1 - 31:19,

76:12 110:1received [12] - 4:9,

30:9, 31:14, 91',1747:17, 97:7, 67:16,67:1 68:5 1 :411 :12 114:

receiving [1] - 99:16recen - :26

111:4,111:14recen - 15:18

22:8, 27:22, 40:24recollection 1;] - 49:3,

522recommendation [1] -Z$§

reconstruct [11 -

2 :19RECORD [5] - 43:9,

64:4, 98:16, 113:24,12$;

record [13,] - 9:19,11:22, 13:12, 25:15,29:27, 43:8, fi:12,57:21, 58:7, 75:4,75:25, 94:21, 98:19,111:14, 113215,114:2? 119:1?1:21

recorded [3] - 30:11recording [1] - 29:6recordings [1] - 28:27RECORDS [31 - 3:11,

4:17 4:19records my - 2:4, 2:6,

17:21, 19:17, 20:1,20:17, 21:25, 22:23,22:25, 22:26, 23:11,26:9, 29:22, 31:27,33:12, 33:26, Q27,36:13, @117, 38:5,38:9, 99:16, 39:29,49:8, 40:12, 49:27,45:1, 49:13, 46:15,46:29, 47:17, 47:2047:21, 47:22, 55:23,66:19, 66:23, 99:25,99:15, 69:21, 71:1,74:11, 76:2, 83:6,89:7, 88:26, 99:7,95:11, 95:15 102:5,105217, 197:27,


108:4, 108:8,108214, 117126,118:6 119:14119:19,128:1§,131215

rectilication [1] -

9932refer|1g]- 26:17,

26:19 26:27 29:2639:22, 32:1, 42:19,43:10 54:5 77:15923229932210425 122:24

reference [51 - 11:9,11:26. 14:24. 42:11.1931

references - 0:2

3929referred [121 — 12:21,

27:11, 47:24, 79:25,80:7 83:11 88:693:9 93:11 98:2198:27, 125:5

REFERRED [1] - 3:22referring [15] - 11:10,

11:23 39:9 40:341:1 41:24 47:2361:20 67:26 91:23

9219391292123:1 124:17

refers [5] - 48:19,67:13 68:4 84:9106:21

reflecg u] - 51:451:27 52:2 69:6

reflected [2] - 83:10

999rel1ecting[1]- 127:9reflecls|1]- 66:18refreshm - 45:19regainedm - 122:13Emmi.

88:15, 99:12, 195:9,

1922ggarded [11 - 128214regarding [a] - 4:12,

34:17, 55:18, 47:3,48:11 56:24 59:1660: :17 65:565:14 65:20 75:2575:17, 76:24, 77:18,77:g4, 90:24,107:18 112:1.51.

115:14,11§:27,121:10 123:19

REGARDING [5] -

2:1 :2 '1 :1regardless [1] - 91:8regards Lg - 49:16.

53:19 :2

Fregister[15]- 18:16,

18:18 18:25,19:1,19:22, 19:24, 19:26,45:14 45:16, 96:6,108:21, 114:21,114:22 115:8

REGISTE - 2:11129

registered [22] -

17:12 17:25 18:2428:23, 25:24, 30:12,31:25 32:8 34:1559:19, 49:4, 45:13,47:7, 95:3, 95:12,107:21. 114:14.11 : 1 :2130:19,1§1:5,12229

REGISTERED [51 -2:14 2:17 3:2519:12 34:25

registers 12] - 22:24,$91

registration [1] —

1199regisgg [2] - 47:27,

329regularm - 14:22,

22:12 112:10regulafiy [1] - 59:;re ulations - 1 0:7reinstated L2] - 6:22,9932

reiected m - 58:15relate [2] - 42:1,

107:24related [2] - 25:13,

122relates 1;] - 42:4,

50:7 107:22relating [1] - 76:2RELATING [1] - 3:12relationshig [11 - 95:5relativel1[11- 127:17release [21 - 34:3.

10 :12relevant [2] - 15:6,

42:27re in - 129:18remains [1] - 125215remedies [21 - 81:26,

19139remernberm - 34:5,

56:15 58:11 6 :11reminder - :21removal [11 - 90:25remove [21 - 96:17,

108:25removed_[§_| - 25:10,

25:12 69:22 89:6

1489:9 89:19 89:27

99352999renewals [1] - 35:10regeatedly [1] -

19221regatingup 102:25reglaced [1] - 110:8reglacement [1] —

1$2Zre 0 - 16:1

20:6, 83:15, 97:21,115:21 124:2?

regortedu] - 15:1,17:2 :27 7:7

Regrterug — 133:16REPORTER [2] - 66:9,

2939£9223sLflL;9222regrtefs [1] - 121:4ReQrterIExaminer

111- 1:25rewrting [1] — 125:2regorts[z1- 13:25,199

regrehensible [1] -

9239regreseng m - 49:6regresentatlon [2] -

49:3, 49:9regresentative |§_] -

5:13 16:9 107:1regresents [1] - 92:19regrimand [1] — 97:9regutable [1] - 74:2reguesguz] - 29:21,

31 :15, §g:22, 52:26,33:8 33:16 34:1738:1, 39:20, 40:16,72:26 74:21 74:2785:17, 130:1, 1:10:20

REQUEST 121- 2:20,291

reguested [:1 ~ 28:3,48:3, 75:4

reguesting [1] - 73:5reguests [1] - 27:23,

27:24 28:6 29:1378:22 1 :5 109:9

reguire [g1- 71 :20,

9229reguiredm-14:12,

23:20, 23:21, 52:15,

9932922929939296:23 117:3

reguiremeng [31 -

21-,g§, 86:7, 106:13

|fl.mu26:14, 37:15, 39:4,48:2. 71:27. 81:9.83:4, 933, 103:5,

105125, 110120,12L§

reguires [1] - 78:25reguiring [2] - 43:18,

1221reguisite [1] - 93:7research [1] - 109:25resolution 151- 13:12,

13:26 94:16 :15resolve 11] - 37:23resolved 131- 88:20,

104:2, 104:5RESPECT - 2:12$2§

resgec; [g] - 21:17,32:25 33:8 34:162913231923921191

resgcts[21— 38:4,

12939resglgndent [1] — 92:8resgondm - 76:14resgnded Lg] - 75:5,

75:10, 76:19resgnse [:1 - 55:17,

55:21, 61:12, 75:10,76:4, 80:25, 85:12,1993

resgonsibile [1] —

2939resgonsibilities [51 -

17:5, 20:18, 23:20,74: 80:14 94:8

responsibility [151 -22:6, 23:22, 28220,5933292392931263:9. 66:24. 81 :21.§1329E2LJ9132108:9, 199:15,12221

resggnsible [:1 - 16:6,21:3, 21:15, 25:5,28:25, 30:16, 81:19,108:3, 1m:5

resgonsiveu] - 39:4res - :4 102:1612136

restraining [:1 -

78:23, 79:4, §g:§restricted - :17retain [21 - 70:25, 77:1retainer[1]- 77:2retaining [1] - 28:19review|1g]- 22:12,

49:1, 58:27, 59:4,59:7, 66:1, 70:2,70:26, 70:27, 71:11,ZL2$J93§2101219 105:11119:15,119:17,


119222, 120:2,12939

reviewed 1;] - 22:7,40:23, 41:6, 59:2,119:26

reviewing la] - 62:15,191 :9, 112:3

revised [3] - 14:14,

2921Rlchard [2] ~ 1:25,

133:15rld [1|- 129110rightfu|[;|1- 122:14rlgorous[11- 26:1_2_Robemj] - 9:29Roberts [5] - 14:6,

14:13, 26:17, 25:29,9211

role [15] - 5:22, 21 :27,2239292322913297:3, 97:17, 97:24,98:6, 103:15,112114, 123:8,1 4:23

roles [3] - 24:2, 81:20,19931

roorn - :1128:26

rou h -110:26

1228round [1] - 129:6rule 1§_1 - 27:2, 27:10,2ELL2Z3LJE39

Rules [51 - 5:21 14:6,

11322293l22§2929231

mlesjz‘. - 27:4. 93:17run 511 - 81:5,113:2,

12 :22running [31 - 24:21,

35:12 81:10rushing [1] - 100:24

Ssalaried [1] - 98:7sanction [1] - 124:3sanctioned [15] -

1:21 '8 '1356:9, 56',12, 56:14,

§9312§L1LJfl3L61 :33 62:1, 62:6,92392993529921.19132

SANCTIONED [1] -

E2sanctioning [51 ~

55:12 61:18 66:1719£232$9

Saskatchewan [1] -


E8sat[1]- 114223satisfied [1] - 50:20satis - 51:2saw[§] - 29:16, 81:17,

100:22scheduling [1] - 45:4screemg] - 90:2,

121 :17Sean [2] - 95:2 95:24search [1] - 68:22SEARCH [11 - 3:6sea - 40:26seats [1] - 81:5second [4] - 6621,

101 :25 11322

1_3Qseconded [1] - 43:17secretagm] - 10:8,

12:27, 14:10, 21:728:17 28:19 43:19108210

section [§_[ - 17:7,54:5 78:20 79:2

LEEsecure [11 - 88:23see [251- 11:26, 30:8,

34:9 36:24 37:1838:15, 42:9, 44:1 §,52:10, 58:3, 65:12,71 :15, 72:9, 79:13,83:3, 97:22, 101223.195:5, 114226,116225, 117:2128218, 130:1,131216

seeing [3] - 14:16,31:9 31:22

seeking [11 - 101:10seeks [1] - 104218seem [2] - 49:9, 104:9self[1[- 92:12self-evident [11 -

i”send [5] - 50:3, 67:20,

110:9, 112119sending [2] - 68:1,

119:2Oseniors [11 - 8:10sense [:1 - 18:4,

22:18 37:10 104:6121227

sen - 30:130:11 31:20 50:1651:6, 51:19, 51:23,56:25, 57:7, 58:6,59:1, 59:7, 61:22,67:22, 67:24, 67:25,76:24, 89:25,112:23,11§:1§,

113220, 114:1,116:6,118:16.119110, 119214,11g~,1a.122:17,122:19

SENT[1[ - 3:15serious - 46:23served ['21- 31 :8.

102:14session [21 - 14:22,

14425set, [a] - 8:26, 8:27,

15:24, 37:2,, 44:14,85:24, 1Q2:12,12 :17 126:8

seven [1] - 100:9several [1] - 6:7, 26:8,

27:23, §§:22, 43:18,93:7, 97:7

share [11 - 7:11Sheldon [5] — {$24,

9214, 72:3, 129119SHELDON lg] - 1:10,

1:16 5:1shelf[5[ - 39217,

39',21, 118213,118:14

shigging [2] - 36:17,

Eshog[11- 79:27shorthand [:1 - 133:6shofl 121 - 32:15,£9

shot [2] - 90:2, 121:17show [1] - 50:8showing [1] - §1:1gsides [2] - 122:6,

Esign[1[- 112:21signature [1] - 30:27

31:1. 112:4.112:8.

1 5sites [11 - 121:2Ositting [1] - 60:24situation [3] - 94212,

105:18 116:12six [31 - 32:5, 104:1skill [11 - 133:7sleeging [11 - 126227sli ht - 6:23sliggd [1] - 6523small [11 - 39:250 [21- 2:12,19:10social [5] ~ 85:8, 88:6,

88:26 89:1 89:6solicited [1] - 74:16solicitor[2] - 91:12,

11 :20solution [2] - 53216

113:4someone [5]-31:17,

38:16, 53:11, 121:17sometime La] - 57:10,

61:19 62:21sometimes [2] - 22:2,

2§:22, 28:14, 39:8,44:22 50:2 71:14126127

somewhat [1] - 112:5soon [gj - 102:15,

106:11sum [19] - 12:14,

18:17 21218 22:2659:1}, 54:13, 59:21,61:7 66:8 73:1282:24 91:19 9927192219, 108:5,10926 114:16,114117, 123:14

somzv,-1] - 8:4, 11:5,21:13. 23:24. 29:14.36:20 36:21 37:1237:20. 38:20 39:25,

sgecifically [2] - 54:6

2sglled [1] - 9:3sggkesgrson [11 -

117214sgonsored [1] - 74:25sgread [1] - 20:22SPRING [1] - 3210sgring [3] - 75:16,

75istable[;[1- 111:2 ;fIA..

20:26, 23:4, 24:3,25:3, 28:4, 28:17,

39:1, 40:14, 40:20,5922, 72:8, 74:10,108111, 108218,108219 109:3118220, 129215,131113

STAFF [2] — 2:17,34:25

staffing [2] - 40:15,118:19

stages [1] - 83:14stamg [51 - 67:9,

67:15. 68:4. 112216.113:2 113:7

stamging [3] - 112:2?stand [1] - 54:1standards [11 - 69:12standing lzl - 27:18,E

started [51 - 6:5,62:16 72:21 120215

state [:1 - 9:9, 87:22,flfil

gaftemennm - 33:7,33:10 84:27 89:1783:18, 91:5, 91:8,

112:13, 112:18, 51:5 53:26 58:7 91:23 95:1911222 60:19, 63:19. 64:16. statement§,[_[51 - 20:4.

signed an - 57:3, 75:3 76:15 77:3 m&g_rs,_6_$;,_57:9, 58:26, 53:1, 100:20 105211 69: 21 70:2113:7.113:8.113:10 112:4.113:1. 70:8 70:19 80:21

significant[a[ - 49:12, 116211, 124:19 82:1 82:11 3:2092:15, 92:19 sors [1] — 39:26 12

significanty [11 - 5OI.lgh§|5]- 6:7, states - 11 :5gfl 90:1 9 -1a 1o4:17 status um - 24:19,

sily [1] - 57:4 sound 111- 41 :21 66:27, 69:5, 71:15,similar[1[- 29:21 sgaking [11 - 78:12 91:3, 92:2, 92:3,simple [1] - 94:8 sgaks [2] - 11:20, 9214 95225sirng|er[1]- 12:18 52$ $11116simgm [3] - 40:25, sgcial [2] - 27:17 steadily [11 - 12Q:18

45:4 45:9 E §_t1_I1JjsinIe - 124227sit[1]~ 47:10 33:8 33:10 40:16 STEPHEN [1] - 1:8site [51 - 13;1o 47:1 46:15, 47:21, 65:8, steggd [:1 - 103:2,

59:27 1222 107:25 103212 103:1?A.C.E. Reporting Services Inc.

stag [11] - 23:8,23:24 25:19 51 :2554:27 62:24 73:988:23 89:20 90:23£25

stick [1] - 44:17still [51 - 25219, 37:26,

49:22, 52:16, 90:2,as

stigulated [11 - 8:3stigulatlons [J] - 9:1sto ~ 214stoganov [5] - 11:24,

18:27 33:29, 42:25Stoyanovnzl - 1:21,

7:6, 29:27, 30:24,34:10, 41 :29, 45:20,51:1, an 1, 68:14,82:21 84:18101:17, 102110.113217 119:6 130:7

STOYANOV [31] - 5:2,5:§, 5222, 7:11, 9:2411:25, 12:8, 13:26,14:3, 18:23, 19:3,19:5, 19:21, §g:5.30:27, 322;, 33:23,34:13. 34:21. 35:3.41:24 42:4 42:742:16, 42:23, 42:27,43:7, 43:10, 4§:16,45:21, 4§:g7. 46:13,48:9, 48:11, 48:16,48:22 49:1 50:651:4 51:12 54:1556:22, §7:24, 64:3,64:5 64:15 65:236 :1 7:1 67:57:9, 68:11, 68:15,68:18 :21 68:2575:18, 75:25, 76:7,77:1 77:11 77:1577:24 78:1 78:478:8, 79:7, 82:2§,84:19 86:27 87:1798:18 98:23 99:3101:21 102:5103:1, 10522,111:20,111:24,11223,113:23,113225, 11§:§,115:15, 119:9,120:1, 120:5, 121 :7,130:8, 130117,131:4 131 :9131:17, 1:11:20,131:22, 132:4

streamlining [21 -

125:10, 125:13strictures [1] - 6:19


strike[1[- 105210strong [1] - 125229structural [1] - 127219structure ['21- 8:21,

1&1stuff - 2 :18syle [:1 - 22:19, 29:9subiecg L5] - 23:5,

39:20, 121:4, 132:5,L21

subseguent1z1-51 :21 67:22

subseguently [1] -

£91successive [1] - 56:10suddenly [1] - 35:12sufficient [2] - ag:-§,

9211.smimLIAILEv-f3..

37:14, 106:12,119226

suggested [1] - 37:9suggestion [2] -

58:14 105:14suit:-1bIe[z[ - 24:18,

991sugrvise [11 - 47:14,

922sugrvises [1] - 16:8sugervising [23 -

7:2 12 :20sugervision [51 - 21 :7,

97:4, 96:9, 106:27,

12919sugervisor|1]- 125:7suggliecl [1] - 114:11suggog 91- 44:10,

117:24, 118:27,1199

suggorted [3] - 75:1,75: 3:19

sugge [5], - 6:2,38:13 55:12 73:17

suQ[:_iosed1§1 - 16:15,54:26 64:10 84:1585:11 128:9

suggrise [1] - 127:5sumrising [1] — 114:9surrounding [1] ~

1999s_u&v.m%susgt [2] - 67:14,9221

susgnsion [1] -

9911susgicions [1] - 23:5sweals [2] - 30:11,9919

swore - :5sworn [2] - 32:4, 64:8

SWORN [1] - 1:17synch [1[ - 83:23system [11 - 126:12

Ttable[1]- 19:19TAKEN [1] — 132:8takeoff[1]- 43:9talks [11 - 54:7tagu]-109:189u99a;2Z2Z.

2913taging [2] - 26:24,

10 :20task - 11 :tasks [1] - 20:20team - 2 :27 24:1teleconferencelfi] -

11L1L2§.1211.48:17 48:25 60:16

teleconferencing [1] -

2919teleghone [33 - 7§:9,

115123 12621ten1[:_>|ate [11 - 124:9tend [2] - 9:29, 49:25tenor[1]- 117215tenure [1] - 128:1term [5] - 11:26, 56:9,

78:26 120211terminated [:1 - 73:8,

95:24, 96:1;termination - 5:

951L999ten11s[z] - 66:19,

96:21 97:19110:12 118:11118219, 124:5

testified [2] - 30:25,19221

testify [1[ - 3§:§testi in - 19:1THAT|z| - 32;, 4:19THE[39J -1:17, 1:18,

2:12 2:1 :142:16 2:17 2:20

22222211229122.3:9, 3:4 §:7, 3:8,3:9 3:12 3:1 3:13:15 3:1 : 13:25, 3:26, 19:9,1911.19121292§235:2, 66:9, 79:19,1229

theme11]- 91:16themselves [:1-

89:27, 91:6, 103:§thereafter - 27:1

2215

16thereof[z[ - 96:9,

106222,thinking [:1 ~ 68:16,

106:17, 114118thirds [2] - 56:18,9919

THIS [1] - 192:8thorough [1] - 83:5thousands [2] - 47:225919

three - 6 :2783:20, 1@:9, 125222

threw[1[- 61:11throughou_t,[2[ -

22:15, 128:1title [5] - 17:9, 96:11,

98:8.129:11.129:13titled [51 - 13:27,

41 :2 54: 96:8T0 [an ~ 2:10, 2:12,

2:13 2:15 2:182:21 2:22 2:24 3:13:4, 3:6, 3:8, 3:11,3:12, 3:14, 3',17,3:2 :22 3:244:17 4:19 19:71 : 19:1 :232129

today [1] - 15:18,19:17 19:20 92:14120227 1262111221

together [5] - 35:13,39:14 52:10 70:21991919219

Tomlinson [J] - 6:24tomorrow [1] - 121 :3tone - .took 51 - 51:25, 75:6,

102:9, 115:22,12929

tog[41- 17:17, 62:473:17, 126124

tom [1] - 24:8towards [J] - 88:17traln|:|] - 21:19Hanssfihsehu;

28:18, 29:2, 38:2,1 3:6

transcrigt, [51 - 26:25,28:20, 38:26, 139:9

TRANSCRIPT [11 -

1321transcrigtion [1] -

999transcrigts [1] - 26:12,

27:27, 29:13transgrengm - 84:4,

105:1;transgired [1] - 116:1

tra in s - 6:9travesties [11 - 128:1?treasurer[§_1 - 10:19,

19:12,1§:1,69:2,70:20 71:25

treated - 7:1treating [11 - 15:8tried [J9] - 23:8, 23:16,

23:27 25:22 58:964:16, 100:3, 103:9,105210, 126:1

trouble [1] - 14:16true [1] - 139127trurng 121 - 93:15,

9219trust [1] - 22:17tI'V_l.1Il - 22:16. 22:17.

2§:18, 25:19, 26:1,37:7 44:20 44:2150:1, 51:27, 53:1§,

92292922929912105211 127:1212929

tying [21] - 11:15,11:17. 12:23. 33:23.

2919199111921.43:2 52:23 52:2456:2 60:23 63:2478:11, 82:27. 94:4.107:6 112:6127:21, 131:4,131223

turmoil [2 - 23:10,

1221turning |§] - 87:2,

89:15, 95:1, 103129,117:21,118:2;i_

two [15] - 5:11, 2§:1,32:4 37:27 38:2252:13, 56:18, §7:12,61:4 75:14 82:382:18 84:9 96:15100:8 109:20

Q3 91- 100:22,116:22

ggd [1] - 102:4gg [31- 14:9, 17:23,

22:24

U-1ultra - 7:15unaffected [1] -

19229unanimous [1] - 13:24unanimousy [1] -

Z22unaudited [2] — 71:23,9229

uncontested [1] -


13:24under[13_1- 6:23, 7:12,

7:19, 8:20, a:g4,19:14, 21:7, 21:9,107:5, 198124,117:4, 118:§, 125:1?

undergone|31- 122:4undeming [1] - 99:24underneath [1] -

11919undersigned [9 -

1 3:3understood [1] -

5511undertake [12] -

18:19, fi:11, 34:19,49:21. 65:13. 67:27.73:19 78:1 98:18111:17,1§9:§,19911

undertaken [1] - 125:6UNDERTAKING [25] -

21922191221.2:24 3:1 3:6 3:63:11. 3:14. 3:17.9:20, 3:24, 19:7,34:23 49:24 64:1165:18 68:22 75:1976:1. 76:23. 77:12.98:25 131:24

undertaking [111 -18:27, 50:20, 51 :9,64:5, 98:8, §§:2Q.76:15, 76:17, 77:8,78:7 131:11

UNDERTAKlNGSm -

21undertakings [:1 -

2: 1 :5 132:6Undertakings [1] - 2:3underway [11 - 100124unethical [5] - 89:29,

89:20, 99:24, 89:27,992

unfortunate [11 -

1229unfortunatebg [21 -

25:8 65:3unhaggy[1]- 95:19unilaterally [1] — 124:1universaly [1] -

123:12unless12[ - 27:5,

9219ungalatable [1] -

1221unsuccessful [1] -

919unusual [1] - 89:4unwieldy [2] - 58:20


1.2muguz]-15:23 30:18,

31:2 36:24,44:22,50:2 51:18 53:961:1 63:14 72:2481:8, 89:8, 34:26,102:4 10413128222

ugated [1] - 66:26ugstairs [1] - 24:12

123213. 124:18voted [51 - 44:4,

44:15, 54:22, 117:9,123212 123:14

votes [5] - 74:16,74:23, 76:12, 76:18,

33$VOTING [1] - 3:12voting :3] - 10:26,

45:9, 74:21, 75:3,

17 T

wordsm-118:12workable [2] - 112224,E

Wojfflifllimilworthwhile [11 — 105:9write [:1 -12:10

12:15, 116:5writing [3] - 28:11,

28:25, 65:9 123:8written 1191- 27:4,

V 93:15 97:9 105:9—W 5&2.

Wllzlié.—

51:19Q waiuz1- 39:22. 41 :7

:

valid [2] - 105:16, walls [1] - 24:9 YE waminqsm - 97:16 ‘

validigg [1] — 54:25 WAS [11 - 132:8 1ear[12]— 13:16, 25:1valuable [1] - 22:3 waylaid [1] - 86:15, 29:22 40:2 62:15Vancouvergg] — 13:15,

123:22varied [1] - 60:7variey [1] - 74:1;various [9] - 8:24

20:19. 40:7. 60:5.76:20 76:25 97:8104:8 118:16

VARIOUS [11 - 3:15version [:1 - 7:3,

65:25 66:6 66:12£21

vested - 12 :21vetted [11 - 123:9via [1] - 85:8vicem] - 10:13

10:15 10:20 12:2716:15,16:16,16:18,16:26, 17:6. 95:25,129211

vice-gresideng [5] -

10:13,10:15,10:20,12:27, 16:15 16:16,16:18,16:26,129:11

vice-[:_Iresident's 11] -

flvigor [1] - 25:23vires[11- 87:15vision [1] - 24:14visit[§1- 15:18, 32:11,

32:12 46:1void [1] - 87:15volunteerm - 22:4,

110:1, 126223,L21

volunteers [1] -126:25

vote [9] - 27:6 44:3,54:9, 56:18, 76:11,98:2, 116:22,

wa1s|§]- 8:15, 60:4,60:5 60:12 126:3

wearing [1] - 14:17

EWednesdavJJJ -

E _

37:26, 41:12,102:19 126:24

welcome [3] - 73:11,73:13 100219

WERE [1] - 3:9whasoeveru] -

103:20wheeIchair[11- 24:13WHEN [1] — 3:26WHETHER [2] - 2:11,

l!i=_8WHICH [1] - 132:8wh'g [1] - 63:11whole [1] — 92:7wide - 91:10

12124willing [1] - 74:3wish [2] - 50:24 92:5WIT E] - 2:17, 3:16,

§$£3§withdraw [1] - 44:10withholding [1] - 47:7Wi:t"¢§JJAJiZ.3_._

30:23 32:1 42:1945:20 50:23 51 :264:16 101116102:19 10222110-1:16 116:24117225

word|§] - 11:18,22:19, 61:9, 11§:B116115


62:23, 63:3, 69:10,72:24 73:1 74:26123:23

J&22:15 §5:27, 69:22.82:3, 82:18, 82:26,93:29, 93:8, 113:3,125:1? 12821313126 131:26

YEARS [11 - 3:261esterda1[J]- 15:19YOUR[z]-4:16, 4:19yourself [51 - 36:6,

41:8 58:23 64:17109:25


court file number: 1503-03309 origi ii stephen...

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