CANADA PROVINCE OF NOVA SCOTIA HALIFAX REGIONAL MUNICIPALITY

C.R. No. 388485

IN THE SUPREME COURT OF NOVA SCOTIA

HER MAJESTY THE QUEEN -versusGLEN DOUGLAS RACE IN THE MATTER OF: A HEARING TO ASSESS CRIMINAL RESPONSIBILITY FURTHER TO SECTION 16 OF THE CRIMINAL CODE OF CANADA

AGREED STATEMENT OF FACTS

Pursuant to section 655 of the Criminal Code of Canada, the Crown alleges, and the accused, Mr. Glen Douglas RACE, admits, for the purposes of dispensing with proof thereof, the following facts: Paul Michael KNOTT 1. Paul Michael KNOTT was born in Channel, Newfoundland on October 7, 1962. 2. Paul was the son of Kathleen Knott and the late Eric Knott. 3. Paul was a member of the Canadian Armed Forces, serving as a cook in the Navy until his retirement in 2003. He did two tours of duty in the Persian Gulf on the HMCS Athabaskan, including during operation Desert Storm. He further served with NATO Peace Keeping Forces on the Israel/Sinai Border. 4. Paul had two children, Andrew and Jennifer, one sister Kathy, and two brothers, Tom and Reginald.

5. Paul was a devoted family-man who loved his children. 6. Paul KNOTT had a private life which he acknowledged but preferred to keep private. Paul was a homosexual and would occasionally attend areas where other men were known to meet each other. In particular, Paul was known to attend the Citadel Hill in Halifax, Nova Scotia, during the nighttime hours.

Trevor BREWSTER 7. Trevor Charles Brewster was born in Liverpool, Nova Scotia on May 2, 1962. 8. Trevor was the son of Alfred Brewster and Theresa Brewster. He had one sister, Robenia, and one god-child. 9. He was an employee of the Steak & Stein Restaurant for 24 years. 10. He loved pets of all kinds, especially his dog Polar. 11. Trevor loved to travel. 12. He had a green thumb and loved all aspects of gardening. 13. Trevor was well-known and well-liked in the community. 14. Trevor was proud and open about his homosexuality and would occasionally attend areas where other men were known to meet each other. In particular, Trevor was known to attend Frenchman Lake in the Burnside Industrial Park, Dartmouth, Nova Scotia.

Chronology of Events 15. May 1, 2007 was the first full day Glen RACE had stayed at his new apartment on North Street in Halifax, Nova Scotia. This day marked the first time he had lived independently from his parents in years. 16. On the morning of May 1, 2007, Glen RACE attended various local businesses in Halifax, Nova Scotia. He made a small purchase at a local bicycle store, bought lunch at Sobeys, purchased a pre-paid long distance phone card, and attended the public library.

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17. While at the public library, Glen RACE paid fines that he had accumulated for overdue books, books which covered the topics of Central America, the Amazon river, Mexico, Belize, the Spanish language, the Maya world, and private investigations. After paying his fines, Glen RACE borrowed two new books from the library, one on traveling in Mexico and one on traveling in Belize and Guatemala. 18. On the afternoon of May 1, 2007, Glen RACE attended a branch of the Royal Bank of Canada (RBC) in Halifax and withdrew funds. 19. On that same afternoon of May 1, 2007, Paul KNOTT went shopping with his daughter Jennifer. Jennifer was 17 years old at the time. Together, they attended various stores including Zellers, where he and his daughter met with his ex-wife (the mother of Jennifer). 20. Later that afternoon on May 1, 2007, Paul KNOTT dropped Jennifer off at her work in the Bayers Lake Business Park, kissed her good-bye, and told her that he would see her at home later that night. 21. After finishing her shift at 9:00pm on May 1, 2007, Jennifer KNOTT returned home. She expected to see her father at their residence, but found that he was not there. 22. Between the early evening of May 1, 2007 and the early morning of May 2, 2007, Glen RACE and Paul KNOTT came into contact with one another. It is likely that they met at Citadel Hill in Halifax, Nova Scotia. Furthermore, it is likely this was a chance encounter and nothing suggests it was pre-arranged. 23. Between the early evening of May 1, 2007 and the early morning of May 2, 2007, Glen RACE attacked and killed Paul KNOTT with a knife. 24. Between the early evening of May 1, 2007 and the early morning of May 2, 2007, Glen RACE disposed of Paul KNOTTs body on an overgrown path found off a small clearing that is located off a dirt road in a remote and densely forested location near Mill Cove, Nova Scotia. His body would not be found until several days later. (a) Note: The site of where Paul KNOTTs body was disposed of is located approximately 60 kilometers southwest of Halifax, Nova Scotia. 25. On the morning of May 2, 2007, Jennifer KNOTT awoke and discovered that her father was still not home. She was concerned; it was unusual for her father to be
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out of contact with her for this length of time. On other mornings when he left their home before she awoke, he would phone her to make sure she was awake and ready for school. 26. On that same morning of May 2, 2007, and after disposing of Paul KNOTTs body, Glen RACE drove Paul Knotts blue Chevrolet Malibu to various locations around Halifax, Nova Scotia. (a) Glen RACE first attended a convenience store. While in the store it appeared to the store clerk that Glen RACE, who was unknown to her, was making deliberate attempts to avoid being captured by the stores security cameras, while at the same time, attempting to test various cards in an ATM. His suspicious behavior prompted the store clerk to record the license plate of the vehicle he was driving. (b) After leaving the convenience store, Glen RACE attended a PetroCanada gas station where he asked the store clerk if he could use a phone book. Upon being handed a phone book, he proceeded to look up and record numbers for 3 local businesses that sold firearms. (c) Glen RACE next attended a Canadian Tire store and purchased a small gasoline container. The store clerk who sold the gas can to Glen RACE recalled him as being calm and quiet. (d) Finally, on the morning of May 2, 2007, Glen RACE attended a Superstore where he purchased a bottle of laundry detergent. While at the store, he also made several unsuccessful attempts to use an ATM. 27. On the afternoon of May 2, 2007, Glen RACE attended a Sobeys store in Halifax and withdrew $40. After attending the Sobeys, he went to a Needs convenience store in Halifax where he made a purchase of $6.22. 28. As the day continued on May 2, 2007, Jennifer KNOTT continued to attempt to contact her father, all without success. 29. On the evening of May 2, 2007, Glen RACE attended an Ultramar gas station in Halifax and made a purchase of $42.82. After attending the Ultramar gas station, he went to the Walmart located on Mumford Road in Halifax where he purchased a large Buck knife for $62.25.

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30. As the evening of May 2, 2007 continued, Jennifer KNOTT grew increasingly alarmed that she had not heard from her father. She contacted other family members, hoping that they knew of his whereabouts. They did not and were similarly concerned for him. 31. On the evening of May 2, 2007, Jennifer KNOTT contacted the police to report that her father was missing. 32. Between the evening of May 2nd and the early morning of May 3rd, 2007, Glen RACE drove Paul KNOTTs vehicle down the Old Guysborough Road that is located behind the Halifax International Airport. He turned off the Old Guysborough Road onto a small dirt road. He drove for approximately 500 meters until the vehicle became stuck in the mud. Glen RACE abandoned Paul KNOTTs vehicle in this location; however, prior to doing so he took various steps to conceal the identity of the vehicle. He removed the license plate. He removed some identifying decals and obscured others. He completely covered the blood-soaked back seat area with a large tarp. He wiped up the blood found in the front-seat area. He locked the doors to the vehicle. He scratched a note onto the hood which read, Waiting for friends tow-truck thx. Glen RACE kept the license plate and decals that he had taken off of the vehicle. The vehicle would not be found until days after it had been abandoned. (a) Note: The location of where Paul KNOTTs vehicle was abandoned is approximately 30 kilometers north of Halifax, Nova Scotia. 33. After abandoning Paul KNOTTs vehicle, Glen RACE rode his bicycle (which had been in the trunk of the vehicle) to the Petro-Canada gas station that is located in Fall River, Nova Scotia. At 8:30 am on May 3, 2007, Glen RACE called his father, Mark RACE, from this location and asked him to pick-him up. 34. Mark RACE arrived at the gas station on the morning of May 3, 2007 and observed his son coming down a hill located behind the gas station with a broken 18-speed bicycle. The bicycle was placed in the back of Mark RACE's Ford truck before father and son left for the family residence in Windsor, Nova Scotia. As they were driving, Mark RACE noticed that Glen RACE was holding his breath for extended periods of time. When they arrived in Windsor, Glen RACE suggested to his father that he have his truck sprayed down, and further, to keep his bicycle in the back of the truck so it too got sprayed down. 35. After their arrival in Windsor, Mark RACE found a license plate in his sons bag. Upon confronting his son about this, Mark RACE observed that his son went white as a ghost.
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36. On May 4, 2007, at approximately 6:00pm, Mark RACE drove Glen RACE back to Halifax. 37. On that same day, May 4, 2007, Trevor BREWSTER returned to Halifax after vacationing in the Dominican Republic for a week. 38. On that same day, May 4, 2007, Jennifer KNOTT, who had persistently been attempting to contact her father, sent the following two text messages to his cellphone: I love u. I really miss u please call love u daddy as well as, Dad please call me and let me no atleast ur ok im worried and so is mom and nan and aunt Kathy everyone is please c. 39. On the morning of May 5, 2007, Glen RACE attended an RBC in Halifax and made an account inquiry with one card, and then attempted to use another card without success. 40. Early in the afternoon of May 5, 2007, Glen RACE attended a Sobeys in Halifax and withdrew $120. 41. On the afternoon of May 5, 2007, Mr. Derek HARNISH, a resident of Mill Cove, Nova Scotia, was out riding his all-terrain vehicle (ATV). He went down a dirt road, known as Base Road, not far from the inactive radar station in Mill Cove. He pulled his ATV off the dirt road and onto a small clearing. On a small path leading off the clearing he saw what appeared to be a human body. He immediately contacted his uncle, asking that he contact 911 to report what he found. 42. Upon being notified, the Royal Canadian Mounted Police (RCMP) dispatched officers to the scene. There they discovered the body of Paul KNOTT. He was found with one shoe missing, his sweater pulled over his head, and his belt undone. He had been stabbed numerous times and had his throat slashed. There was no sign of Paul KNOTTs vehicle. 43. A post-mortem examination of Paul KNOTTs body revealed that he died as a result of the numerous stab wounds he sustained to his thigh, chest, neck and throat areas. This examination also revealed the presence of defensive wounds demonstrating that Paul KNOTT was conscious and attempted to defend himself from Glen RACEs attack. 44. On the late afternoon of May 5, 2007, Mark RACE returned to Halifax to pick up his son Glen RACE. He noted that his son had clothing with him and was concerned with doing laundry.
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45. Upon their arrival in Windsor, Donna RACE, Glen RACEs mother, washed his clothes. After doing his laundry, she found pieces of broken metal in the washing machine and when she put them together, they spelled MALIBU. Donna RACE confronted Glen RACE about this, thinking that he may have been destroying property in the neighborhood. Glen RACE calmly said he wanted them back without explanation. Donna RACE gave them to her son and does not know what he did with them. 46. On May 6, 2007, Mr. Kevin SEARS, Mr. Scott THERIAULT and Mr. Donald ALLEN were riding their ATVs down a small dirt road off of the Old Guysborough Road that is located behind the Halifax International Airport. They noticed what appeared to be an abandoned vehicle. They noted that the colour of the car was blue, and that it appeared to be a Chevrolet Malibu. The license plate and other identifying decals and stickers had been removed. What further piqued their curiosity was a note scratched on the hood of the vehicle which stated, Waiting for friends tow-truck thx. They attempted to open the car, but the do ors were locked. They noted the back seat of the vehicle was completely covered by a tarp. 47. On the morning of May 7, 2007, Kevin SEARS was listening to the radio and heard a news report about Paul KNOTT and how his blue Chevrolet Malibu was missing. Upon hearing the news report, and recalling the abandoned vehicle he observed the day before, he contacted the police to report what he and his friends had observed. 48. The police investigated and discovered that this abandoned vehicle was in fact Paul KNOTTs blue Chevrolet Malibu. (a) Note: When the police subsequently located Paul KNOTTs abandoned vehicle on May 7, 2007, they discovered a knife bearing Glen RACEs fingerprints lodged deep between the front drivers seat and centre console. It appears that this was the knife used by Glen RACE to kill Paul KNOTT. Furthermore, given where this knife was recovered within the vehicle, it appears that Glen RACE believed he had lost this knife, prompting the purchase of the Buck knife at Walmart on May 2, 2007. The packaging for the Buck knife was subsequently recovered in the back seat of Paul KNOTTs vehicle. 49. Forensic Examination of Paul KNOTTs vehicle revealed that Paul KNOTT was attacked by Glen RACE while he was seated in the drivers seat of his blue Chevrolet Malibu and that the attack prompted a violent struggle between the two men that occurred inside the vehicle.
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50. On the morning of Monday, May 7, 2007, Trevor BREWSTER reported for work at the Steak & Stein restaurant on Young Street in Halifax, Nova Scotia. This was his first day back to work after his vacation and was also the day that he was beginning to train as a manager. When his shift ended that day Trevor intended to visit a co-worker and friend, Ms. Stephanie BROGAL, to see her new dog. 51. At approximately 6:00 pm on May 7, 2007, Mark RACE drove Glen RACE back to Halifax. While Glen RACE had stayed with his parents between May 3 and May 7, 2007, Mark RACE did not feel nervous around his son and nothing gave him concern to the get the police or other authorities involved. 52. At 8:37 pm on May 7, 2007, Glen RACE went to the public library in Dartmouth and returned the two books he had borrowed on May 1, 2007, those being a book on traveling in Mexico and a book on travelling in Belize and Guatemala. 53. Trevor BREWSTER finished his shift at the Steak and Stein at 10:51 pm on May 7, 2007. His co-workers recalled how Trevor spoke fondly of his recent trip to the Dominican Republic; but otherwise, noted nothing remarkable about him that day. Shortly before ending his shift, Trevor spoke with his friend Stephanie and confirmed that he was still intending to visit her later that night. 54. Sometime between Trevor BREWSTER leaving the Steak and Stein restaurant on the late evening of May 7, 2007 and 1:31am on May 8, 2007, Trevor BREWSTER and Glen RACE came into contact with one another. It is likely that they met at Frenchman Lake in the Burnside industrial park in Dartmouth, Nova Scotia. Furthermore, it is likely this was a chance encounter and nothing suggests it was pre-arranged. 55. After meeting, and sometime between the late evening of May 7, 2007 and 1:31am on May 8, 2007, Glen RACE attacked and killed Trevor BREWSTER. 56. After killing Trevor BREWSTER, Glen RACE disposed of his body under a wharf at the edge of Frenchman Lake. His body would not be found until days later. 57. After disposing of Trevor BREWSTERs body, Glen RACE drove away in Trevor BREWSTERs black Honda Civic. 58. At 1:31 am on May 8, 2007, officers with the RCMP spotted a black Honda Civic at the intersection of the Cole Harbour Road and the Forest Hills Parkway in Dartmouth. The vehicle proceeded through the intersection and screeched its tires. Upon observing this, the officers began a pursuit with the intent of performing a traffic stop on the vehicle. Upon activation of their lights and
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sirens, the black Honda Civic, driven by Glen RACE, fled at a high rate of speed. Fearful of endangering public safety, the officers ceased their high speed pursuit of the vehicle. The officers proceeded to run the license plate and determine d the vehicle was registered to Trevor BREWSTER. The officers proceeded to the address of Mr. BREWSTER where they failed to locate him or his vehicle. 59. At 2:50 am on May 8, 2007, Glen RACE drove Trevor BREWSTERs black Honda Civic to the toll station on the Cobequid highway in Great Village, Nova Scotia. Glen RACE asked the employee in the toll booth if he was on the right road to the American border, and further, if he could tell him the easiest route to get there. Following a short conversation, Glen RACE, drove away, though not without some difficulty, prompting the employee to think that he was having trouble driving a car with a standard transmission. (a) Note: The toll station on the Cobequid Highway is located approximately 150 kilometers north of Halifax. 60. At 7:18 am on May 8, 2007, Glen RACE withdrew $20 from his VISA card at a gas station in Canaan, New Brunswick. Near this time, Glen RACE contacted his parents by telephone and requested money, stating that he intended to go to a monastery in New Brunswick. His father refused his sons request. (a) Note: Canaan, New Brunswick is located approximately 150 kilometers northwest of the Cobequid highway toll station. 61. At approximately 8:00am on May 8, 2007, Glen RACE attended the Our Lady of Calvary Abbey monastery in Rogersville, New Brunswick. (a) Note: The Our Lady of Calvary Abbey monastery in Rogersville, New Brunswick is located approximately 60 kilometers north of Canaan, New Brunswick. 62. Glen RACE was familiar with this monastery as he had visited there on a previous occasion. Upon his arrival, he asked Father LEBLANC if he could stay there; however, Father LEBLANC advised him that he could not as the monastery had a conference going on at the time. Glen RACE proceeded to ask Father LEBLANC if he could wash-up, but was similarly refused by Father LEBLANC. 63. Despite his conversation with Father LEBLANC, Glen RACE remained at the monastery for a couple of hours on the morning of May 8, 2007. During this time he washed himself and his clothes and cleaned and wiped the interior of Trevor BREWSTERS black Honda Civic.
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64. While at the monastery, Glen RACE spoke to Father CHAISSON. Glen RACE appeared to Father CHAISSON to be more comfortable on May 8, 2007, than he had been on other occasions while at the monastery. Glen RACE told Father CHAISSON that he was driving his fathers car. 65. Prior to leaving the monastery on May 8, 2007, Glen RACE was observed to be sitting cross-legged in the parking lot for no apparent reason. 66. After leaving the monastery, Glen RACE drove to Trois Pistoles, Quebec where, at approximately 6:30pm on May 8, 2007, he withdrew $200. (a) Note: Trois Pistoles, Quebec is located approximately 415 kilometers north of Rogersville, New Brunswick. 67. On May 8, 2007, and after Trevor BREWSTER had failed to attend her home the night before, Stephanie BROGAL attempted, without success, to contact him throughout the day. She knew that it was supposed to be a day off for him and that he had planned on doing some gardening. 68. On the morning of May 9, 2007, Glen RACE attended a TD bank machine in Lachine, Quebec, where he made two unsuccessful attempts at withdrawing $100. (a) Note: Lachine, Quebec is located approximately 493 kilometers south-west of Trois Pistoles, Quebec. 69. That same morning of May 9, 2007, Stephanie BROGAL received a call from an employee at the Steak and Stein restaurant advising her that Trevor BREWSTER had failed to show-up for work that day, something which was very uncharacteristic of him. Upon learning this, Stephanie BROGAL went to Trevors home in Dartmouth, Nova Scotia. 70. Upon arrival at Trevors home, she did not see Trevors Honda Civic or any evidence of gardening from the day before. Ms. BROGAL contacted the manager of the Steak and Stein, Mr. Shawn COVEY, and reported what she found. 71. On the morning of May 9, 2007, Shawn COVEY contacted Trevor BREWSTERs sister, Robenia to advise that her that Trevor had not shown-up for work and then contacted the police to report that Mr. BREWSTER was missing. 72. After receiving the call from Shawn COVEY, on May 9, 2007, Robenia BREWSTER and Heather DEWOLFE attended and entered Mr. BREWSTERs home. There was no sign of Mr. BREWSTER or his vehicle. They found Trevors dog in the home,
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who, uncharacteristically, had had several accidents on the floor, suggesting to Robenia that her brother had not been home for some time. After leaving the home, Robenia contacted the police and reported her brother missing. 73. On the late afternoon of May 9, 2007, Mr. Colin BROWN was collecting bottles at Frenchman Lake near the Burnside Industrial Park in Dartmouth, Nova Scotia. As he bent over to pick up a bottle, he was startled as he spotted what appeared to be a human body under a small wharf at the waters edge. Colin BROWN immediately contacted the police. 74. Upon their arrival, the police discovered the lifeless body of Trevor BREWSTER. His body was under the wharf partially covered by a garbage bag weighed down by rocks. His shoes were neatly placed beside his body. His pants were undone with his penis left partially exposed. 75. A post-mortem examination of Trevor BREWSTERs body revealed that he died from a combination of blunt force injuries to his head and numerous stab wounds to his head, neck and throat areas. This examination also revealed the presence of defensive wounds demonstrating that Trevor BREWSTER was conscious and attempted to defend himself from Glen RACEs attack. 76. Sometime between the morning of May 9, 2007 and the afternoon of May 10, 2007, Glen RACE drove Trevor BREWSTERS black Honda Civic onto the private property of Mr. Giles BOULET in Havelock, Quebec. The property of Mr. BOULET is located only a few kilometers north of the border separating Canada and the United States of America. (a) Note: Havelock, Quebec is located approximately 50 kilometers south of Lachine, Quebec. 77. Once on Mr. BOULETs property, Glen RACE drove Trevor BREWSTERS vehicle down a long wooded road, before driving down another wooded path, formerly used for logging. The Honda Civic became stuck in the mud. Glen RACE abandoned Trevor BREWSTERs vehicle in this location; however, prior to doing so took various steps to conceal the identity of vehicle. He removed the license plate. He removed identifying decals from the vehicle and obscured others. He took tree branches and draped them over the vehicle and caked mud onto the reflective lights. The vehicle would not be discovered until months later. 78. Sometime between the morning of May 9, 2007 and the afternoon of May 10, 2007, and after abandoning Trevor BREWSTERs Honda Civic, Glen RACE entered

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the United States of America illegally and did not attend an official international border crossing. 79. At 4:30 pm (EST) on May 10, 2007, Glen RACE was walking northbound on the Drown Road in the Township of Mooers, in upstate New York, located only a few kilometers south of the border separating Canada and the United States. Ms. Marjorie RUSHFORD, a local resident, stopped in her vehicle to speak to Glen RACE who appeared to have with him a map and compass. Glen RACE advised her that he was just out for a walk. (a) Note: The direct distance between where Glen RACE abandoned Trevor BREWSTERs vehicle in Havelock, Quebec and the north -end of the Drown Road in New York is approximately 6 kilometers. The distance, if driven, is approximately 35 kilometers. 80. Mr. Darcy MANOR was born on May 29, 1971. He was a resident of Mooers, New York, and was a local mechanic, handyman, school bus-driver, husband and father of two young boys. 81. At approximately 5:00 pm (EST) on May 10, 2007, Darcy MANOR attended a hunting lodge situated on a large property located at the north-end of the Drown Road. This hunting lodge was owned by a businessman from Vermont and Darcy MANOR was the seasonal caretaker for the property. He had been asked by the owner to ready the exterior water pump for the new season. 82. Unbeknownst to Darcy MANOR, when he arrived at the property on May 10, 2007, Glen RACE was inside the hunting lodge, having entered through an unlocked window. 83. While Darcy MANOR was working on the exterior water pump, Glen RACE fired a single rifle-shot through the kitchen window of the hunting lodge, striking Darcy MANOR in the back. Darcy MANOR was approximately 33 feet from Glen RACE when he was shot. 84. Darcy MANOR likely survived for several minutes after being shot by Glen RACE. 85. Glen RACE took Darcy MANORs keys and wallet from him. 86. Glen RACE obtained a key for a shed on the property which housed an ATV. He opened the shed and found keys for the ATV. He tied Darcy MANOR up with sugar-tubing used for maple trees and proceeded to drag his body with the ATV down a trail approximately 300 meters away from the hunting lodge.
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87. Glen RACE left Darcy MANORs body tied and bound on the trail. He returned the ATV to the shed, replaced the keys for the ATV in the shed, re-locked the shed, and returned the keys to the shed to the lodge. 88. Glen RACE left the hunting lodge in Darcy MANORs Ford 250 pick-up truck. 89. Before driving away from the hunting lodge, Glen RACE locked the front gate to the property. 90. In the early evening of May 10, 2007, Darcy MANOR was noted to be missing by his friends and family. Knowing that he had intended to go to the hunting lodge that day, his friends attended the hunting lodge to look for him and found that the front gate was locked. They hopped the fence; however, they did not find Darcy MANOR or his vehicle upon a quick search. 91. On May 10, 2007 at 6:36 pm (EST), Glen RACE drove westbound through Malone, New York in Darcy MANORs vehicle. (a) Note: Malone, New York is located approximately 55 kilometers west of the Drown Road in New York. 92. On the late evening of May 10, 2007, friends and family of Darcy MANOR still had not heard from him and grew increasingly concerned. It was decided by them to return to the hunting lodge, cut the lock, and begin a more thorough search for Darcy MANOR on the various trails on the property. 93. At approximately 12:30 am (EST) on May 11, 2007, Marvin DROWN and Harold SMITH located Darcy MANORs lifeless body. Paramedics and New York State Troopers were immediately called. 94. On May 11, 2007, between 6:30 pm and 10:00 pm (EST), while in Dalton, Georgia, Glen RACE stole a South Dakota license off of a parked vehicle. He replaced the New York license plate on Darcy MANORs truck with the South Dakota license plate. (a) Note: Dalton, Georgia is located approximately 1760 kilometers south-west of Malone, New York. 95. On May 12, 2007 between 9:00 pm and 9:30 pm (EST), while in Vinton, Louisiana, Glen RACE stole a Louisiana license plate off of a parked vehicle. He replaced the South Dakota license plate on Darcy MANORs truck with the Louisiana plate.

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(a) Note: Vinton, Louisiana is located approximately 1160 kilometers southwest of Dalton, Georgia. 96. On the morning of May 13, 2007, while in Sabine Pass, Texas, Glen RACE stole a Texas license plate off of a parked vehicle. He replaced the Louisiana license plate on Darcy MANORs truck with the Texas plate. (a) Note: Sabine Pass, Texas is located approximately 80 kilometers west of Vinton, Louisiana. 97. On the morning of May 13, 2007, while in Sabine Pass, Texas, Glen RACE drove Darcy MANORs truck to the Sportsman's Warehouse in Sabine Pass, Texas and purchased fuel. 98. On the morning of May 14, 2007, Glen RACE abandoned Darcy MANORs truck. The truck had sustained a flat tire. Mr. Glen RACE made an unsuccessful attempt at repairing the tire before abandoning the vehicle. He left the vehicle fifty feet north of Jones Road, Baytown, Texas, in a grassy area of a county right of way used for maintaining a county flood control ditch. The vehicle was left with the Texas license plate on it that Glen RACE had stolen in Sabine Pass, Texas. In the bed of the truck were the license plates stolen by Glen RACE from Louisiana and South Dakota, as well as the New York license plate belonging to Darcy MANOR. Before leaving the truck, Glen RACE removed the registration and inspection stickers from the windshield. (a) Note: Baytown, Texas is located approximately 125 kilometers west of Sabine Pass, Texas. 99. On the morning of May 14, 2007, after abandoning the stolen Ford 250 pick-up truck, Glen RACE proceeded to the Valero Truck Stop and Convenience Store in Baytown, Texas. At approximately 10:50 am (EST), he purchased a one-way bus trip from Baytown, Texas, to Brownsville, Texas, scheduled to depart at 3:30 pm (EST) that afternoon. Glen RACE remained outside the Valero Truck Stop and Convenience Store for several hours while awaiting the departure of the bus. He entered the store on several occasions to purchase small items, including a new map of Texas. At all times, Glen RACE appeared to be calm and was polite to store employees. 100. On the morning of May 15, 2007, Glen RACE got off the bus in Harlingen, Texas.

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(a) Note: Harlingen, Texas is located approximately 560 kilometers southwest of Baytown, Texas. 101. After getting off the bus, Glen RACE requested a cab at the Stripes Convenience Store located at F Street and Frontage Street in Harlingen, Texas. Mr. Lorenzo HERNANDEZ, a local taxi driver, arrived. Glen RACE dropped his bags in the trunk of the cab and they sounded hard and heavy. He entered the back seat of the cab and told Lorenzo HERNANDEZ that he wanted to go to the "University" in Brownsville. Glen RACE pointed to an area on a small map that appeared to be cut from a larger map. The driver told Glen RACE that the total fare would be $53.00. Glen RACE advised that he did not "have that kind of money" and exited the cab and retrieved his bags from the trunk. Lorenzo HERNANDEZ noted that Glen RACE appeared calm and collected and spoke in a normal voice that was neither loud nor nervous. 102. Later that morning, on May 15, 2007, Glen RACE attended a different Stripes Convenience Store in Harlingen, Texas, located at Harrison and Frontage streets. Once there he asked the store clerk, Mr. Ramero RAMIREZ, for a phonebook to call another taxi and change to use the pay phone. Ramero RAMIREZ provided a phonebook as well as change. After calling a taxi, GLEN RACE returned the phonebook. Ramero RAMIREZ noted that Glen RACE's demeanour was "normal, calm, nothing out of the ordinary" and "very polite." 103. In response to Glen RACE's call for a taxi at the Stripes Convenience Store located at Harrison and Frontage Streets, in Harlingen, Texas, Mr. Jose MORALES, a local taxi driver arrived and picked up Glen RACE. Glen RACE put his bags in the trunk and advised Jose MORALES that he would like to go to the border in Los Indios, Texas. During the drive, Glen RACE told Jose MORALES that he was from "up north" and that he was going to "Mexico." When asked where in Mexico he was going, Glen RACE replied by saying he wasn't quite sure. Jose MORALES told him to be careful as they "make their own laws in Mexico". Jose MORALES dropped Glen RACE off at the corner of Rangerville Road and Hwy 281 in Los Indios, Texas, next to the Casa de Cambio, currency exchange business. Jose MORALES lifted the duffel bag of Mr. Glen RACE out of the trunk for him, and thought that it weighed between 35 and 40 lbs. The ride from Harlingen to Los Indios was approximately 20 to 25 minutes. Jose MORALES noted that Glen RACE's demeanour was "calm and normal", "very quiet" and that he was "very polite". 104. After exiting the taxi of Jose Morales on the morning of May 15, 2007, Glen RACE went to the Casa de Cambio currency exchange in Los Indios, Texas,
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where he spoke with Ms. Aurelia ZUNIGA, an employee of the business. He attempted to convert Canadian currency for Mexican pesos, but was advised by Ms. ZUNIGA that she would be unable to do so as she did not know the conversion rate. Glen RACE responded, "No exceptions?" to which Aurelia ZUNIGA said, "No." Glen RACE appeared annoyed, and then provided $35 USD. He received 371 Mexican pesos and then left on foot towards the Rio Grande River. Aurelia ZUNIGA noted that Glen RACE's demeanour was "quiet", "tired looking", "normal acting" and that he "kept to himself." 105. On the morning of May 15, 2007, Mr. Raymond VARGAS, who was senior patrol agent with the Texas Border Patrol, was dispatched to investigate a border sensor activation at the edge of the Rio Grande River, in Los Indios. The Rio Grande River separates the United States of America from Mexico. 106. As Agent VARGAS was approaching the location of the border sensor activation, he spotted a white male walking approximately a mile from the Rio Grande River. The male was carrying a large duffle bag and small backpack. Agent VARGAS approached the male and asked him what he was doing, to which he replied, just walking around. Agent VARGAS asked the male if he had any ID, to which the male replied, I have this and handed him a Nova Scotia drivers license bearing the name, Glen RACE. 107. Agent VARGAS asked Glen RACE if he had a passport. Glen RACE said he did and began to reach in his duffle bag. (a) Note: Glen RACE did not have his passport with him, as it was still at his apartment in Halifax. 108. As Glen RACE began to reach into his duffle bag, Agent VARGAS saw the stock of a weapon. Agent VARGAS quickly stepped back, and asked Glen RACE to place his hands on his vehicle. Glen RACE immediately attacked Agent VARGAS and tried to go for his service weapon. He bit Agent VARGAS on the cheek and thumb. Following a violent struggle, Agent VARGAS managed to gain control of his service weapon and told Glen RACE, Freeze or I will kill you. Glen RACE ceased struggling and lay still. Back-up arrived and Glen RACE was taken into custody. 109. Shortly after being placed under arrest, Glen RACE was noted to be repeating the phrase, walking in circles, walking in circles. 110. Upon his arrest, Glen RACE was found to be in possession of various items including, the rifle that was used to kill Darcy MANOR, ammunition, knives,
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camouflage make-up, a balaclava, pliers, balloons to float his duffle bag, and garbage bags. Additionally, within the wallet of Glen RACE was found to be a VISA card belonging to Trevor Brewster, the Nova Scotia drivers license of Trevor BREWSTER, and a VISA card belonging to Darcy MANOR. 111. On September 15, 2007, Darcy MANORs abandoned truck was discovered in Baytown, Texas. Numerous items were recovered from the truck including, the various license plates stolen by Glen RACE as well as a white Steak and Stein shirt that belonged to Trevor BREWSTER. 112. On September 30, 2007, the adult daughter of Mr. Giles BOULET discovered the black Honda Civic belonging to Trevor BREWSTER concealed down a small wooded path on the property in Havelock, Quebec.

Medical History of Glen Douglas RACE Background 113. Glen Douglas RACE was born on March 5, 1981. His father, Mark, worked as a Chemical Supervisor in a power plant. He is now retired. Glen RACEs mother, Donna worked as a cashier. Glen RACE has a brother Douglas who is three years younger. 114. The RACE Family lived in Mt. Uniacke for several years until moving to Dartmouth in 1990. In 2005 the family moved to Windsor, Nova Scotia. 115. There is no history of violence or abuse in the RACE family. The family remains intact and Glen RACEs father, mother and brother maintain contact, and are supportive of him. 116. Glen RACEs formative years are unremarkable. There is no history of hyperactivity, attention deficit, substance abuse, conduct disorder or criminality. 117. Glen RACE has some history of depression in Junior High School where he lacked friends and was somewhat isolated. These issues were resolved in high school when Glen RACE became more involved in sports and music. At one point he was co-captain of the football team. Glen RACE did well academically and excelled at math. 118. After graduating from High School, Glen RACE began first year at Dalhousie
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University in the fall of 1999. He was studying Mechanical Engineering. 119. In the spring of 2000 Glen RACE joined a fraternity and later that same year he went to Tai Pei for eleven weeks with friends to teach English. 120. While in Tai Pei Glen RACE began to experiment more heavily with drugs including marijuana and ecstasy. 121. Following his return from Tai Pei Glen RACE began to use marijuana on a daily basis. That lasted for a year. 122. Glen RACEs mental deterioration began in the fall of 2000 after he returned to university for his second year. He began skipping classes and eventually withdrew from all his first semester classes. He did return in the second semester and managed to complete some courses. He may have suffered a depressive episode during this time. 123. In August 2001 Glen RACE went to Montreal with friends from his fraternity. He consumed multiple drugs including marijuana, ecstasy, mushrooms, alcohol and cocaine. 124. When he returned home from Montreal, Glen RACE reported to his family that he felt paranoid. He stated an intention to stop using drugs. 125. In the fall of 2001, Glen RACE was supposed to begin his third year at Dalhousie University. He dropped out of school shortly after the fall semester began. 126. In September 2001 Glen RACE returned to live with his parents but he nevertheless attempted to isolate himself. He locked himself in the basement for five days and nights. He cut off the telephone, lights, television, and radio. He would only consume small amounts of food and water. He reported a need to cleanse himself and a desire to examine or overcome the concept of what is need and what is want. Between August and October 2001 Glen RACE lost forty pounds. 127. In early October 2001 Glen RACE was referred by his family doctor for a psychiatric assessment on an urgent basis for depression. 128. Glen RACE was seen several times in October 2001 by a social worker,
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Lorraine Gavin and a psychiatrist, Dr. Alec Hipwell. Glen RACE was described as illogical, and tangential. His thought processes were vague with pseudo philosophical ruminations. Glen RACE described his behavior as trying to find himself and discover the meaning of his need to eat. 129. Glen RACE was diagnosed with major depression with psychotic features. He was prescribed antidepressant and antipsychotic medication but refused to take them. Admission to the Nova Scotia Hospital: November 2001 January 2002 130. On November 1, 2001 Glen RACEs mother contacted Dr. Hipwell to advise her son was gorging himself to the point of physical pain. Glen RACE had expressed a desire to retreat to the woods to solve his problems. His parents were preventing him from leaving the house. 131. On November 2, 2001 Dr. Hipwell and Lorraine Gavin met with Glen RACEs parents who reluctantly agreed to contact the police and to have their son taken to the hospital. 132. On November 2, 2001 Glen RACE was formally admitted to the Nova Scotia Hospital. The certification forms indicated Glen RACE suffered from a psychiatric disorder and required inpatient treatment for his own safety. Dr. Feltham noted that Glen RACE had poverty of speech, his answers were guarded, his thought content was perplexedly philosophical and his affect was flat. He also noted This may be a mood disorder with psychotic features, but I fear this is a schizophreniform illness. 133. Glen RACE lacked any insight into his condition. His judgment was noted to be poor. His family had difficulty accepting the diagnosis and was uncomfortable with him being treated against his will. 134. On November 5, 2001 Glen RACE eloped from the hospital despite being under close observation. He went home and his parents were able to persuade him to return to the hospital. On November 6, 2001 he eloped again. 135. On November 13, 2001 the police brought Glen RACE back to the hospital. His hygiene had deteriorated and he had spent time living in a dumpster. He was angry, belligerent and refused any physical examination or treatment. He had no insight into his illness or concern for his own safety. He was deemed to be
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incapable of consenting to treatment. He was given antipsychotic medication by injection as he refused to take it orally. 136. Glen RACE appealed his involuntary status to the Review Board. On December 5, 2001 the Board concluded Glen RACE remained a danger to himself. 137. During Glen RACEs time at the Nova Scotia Hospital in 2001 it was noted that his mental status was difficult to assess. He either refused to answer questions or was vague. He was suspicious and paranoid. He would mutter under his breath, talk to the walls and have darting gazes. He had disorganization of thought and loose associations. He was guarded. He would scan the room and look spaced out. He had difficulties with insight and compliance with medication. 138. With treatment Glen RACE began to demonstrate some improvement. He had greater organization and took better care of himself and his hygiene. His spaced out appearance disappeared and he no longer appeared to be responding to internal stimuli. While he eventually agreed to take his medication orally he continued to have no insight into his illness or the need for treatment. 139. As a result of agreeing to take his medication orally, Glen RACE was granted additional privileges. On January 14, 2002 he went for a walk on hospital grounds and did not return. 140. Glen RACEs mother contacted the hospital to advise he would not be returning. She would not reveal his whereabouts. 141. Glen RACE purchased a bus ticket to go to Vancouver. He went as far as Winnipeg when he contacted his family and arranged to return home. 142. On January 28, 2002 Glen RACE was discharged in absentia from the Nova Scotia Hospital. His diagnosis at the time was: Psychosis Not Otherwise Specified (NOS) with a differential diagnosis of paranoid schizophrenia. Glen RACEs parents declined follow-up in the community but requested Glen RACEs record be forwarded to his family physician.

2002-2005 143. Between March 2002 and September 2003 Glen RACE continued to isolate
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himself and deteriorate. He became a recluse. He did not leave the family home. He did not attend to his daily hygiene including not showering or brushing his teeth for over a year. He ate excessively and gained sixty pounds. He claimed to have telepathic experiences and that he was influenced by other peoples thoughts. He was angry and blamed the hospital for ruining his life and spirituality. 144. In October 2003 Glen RACE started leaving the family home again. He went for increasingly long walks. He developed a belief in vampires and demons. He believed he was being attacked through the astral plane. He believed eating garlic and holding his breath would protect him from these attacks. He claimed to have reached a high consciousness. He claimed he walked the streets as if he was a God. At one point he emerged from his bedr oom having painted all its contents and himself white for the purpose of purification. 145. Glen RACE was angry with his parents and blamed them for his admission to the hospital. He punched holes in the walls. He threw objects at his father. He spit at his parents. He smashed stereo equipment. He tried to intimidate his mother. He slept with a knife. In January 2004 he struck his father and smashed his computer when his parents refused to allow him to drive their car. In 2005 he struck his father with a rake because he was angry his father had hurt the grass by mowing the lawn. 146. In July 2004 Glen RACE wanted to go to Mexico or Belize. He boarded the ferry but was refused entry into the United States because he had no money.

Admission to the East Coast Forensic Hospital: April 2005 147. In April 2005 Glen RACE left his home intending to walk to Vancouver and then south into the U.S. and Mexico. He walked towards Antigonish to say Goodbye to his younger brother who was at university there. He left the highway near Mt. Thom in favor of Glen Road because it had my name. He slept in a tree. He broke in to a cabin for the purpose of drying his clothes and his sleeping bag. 148. The owner of the cabin was alerted to Glen RACEs presence. He confronted Glen RACE and the police were called. Glen RACE resisted arrest. Glen RACE was sent for an assessment to determine fitness and criminal responsibility.
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149. On April 18, 2005 Glen RACE was admitted to the East Coast Forensic Hospital. He was noted to be paranoid. He stated Im a traveler I dont want to be in society. I dont want to have a job or a house. This is all frivolous. I intend to go to the West Coast down to the U.S. and Caribbean to live on the land and grow my own food. 150. Dr. Kronfli assessed Glen RACE. He found clear evidence of a psychotic illness. He noted: Presentation today is that of extreme psychosis however he is not an imminent risk to himself or others. There are extreme and extensive delusions with regard to himself and others. He carries extreme thoughts with regard to the illegality of personal property and the extreme concrete notion of personal freedom. 151. Glen RACE was diagnosed with Schizophrenia Disorganized Type. He was noted to be non-compliant with medication and had absolutely no insight into the need for medication or the nature of his illness. 152. Dr. Kronfli concluded that Glen RACE was fit and his psychosis did not rise to the level of allowing him to rely on a defence of NCR. He also noted the potential for exacerbation of his symptoms, deterioration and increased risk for violence is there despite the lack of past charges.

The Summer of 2005 153. Despite being found fit and responsible criminal charges did not proceed.

154. In July 2005 Glen RACE and his family moved to Windsor, N.S. He was still using marijuana. He would often isolate himself behind the garage, claiming he was communicating with the stars.

Admission to the Abbie Lane Hospital, QEII Acute Care Unit and the Nova Scotia Hospital: November 2005 to June 2006 155. On November 4, 2005 Glen RACE was admitted to the Queen Elizabeth II Health Sciences Centre suffering from second degree burns to his chest and back.
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He claimed he had been trying to burn some clothes in his backyard with gasoline and was accidently caught in the flames. His parents believed he was psychotic and suspected he had intentionally tried to set himself on fire. Glen RACE was referred for a psychiatric consultation. No delusional thought or perceptual disturbances were detected. Glen RACE was diagnosed with unspecified psychosis and cannabis abuse. He discharged himself from the hospital against medical advice. 156. Glen RACE returned to his parents home. They noted during his recovery that he would pick at his scabs, peel the dead skin and eat it. 157. During the month of November 2005 Glen RACE became increasingly more agitated and paranoid. He began to carry a knife with him at all times. He saw a car outside his house and believed one of its occupants was an enemy from my past who was a rapist, torturer and murderer. Glen RACE fled from his house and hitchhiked to Montreal. 158. Glen RACE contacted his parents from Montreal and arranged to return home. While en route he felt an overwhelming intuition that his mother was going to be raped and his parents murdered. He made a series of bizarre phone calls to the RCMP and his parents. At one point he told his mother she and his father should arm themselves with knives, lock themselves in their bedroom and kill themselves if necessary to avoid rape and torture. 159. Glen RACE was admitted to the short stay unit of the Abbie Lane Hospital on December 5, 2005. His attending psychiatrist noted there was clear evidence of psychotic disorder (schizophrenia) possibly untreated since 2002. When urged to get treatment Glen RACE reacted with anger and destructive behavior (e.g. throwing things around his room). Due to a shortage of beds Glen RACE was transferred to the Valley Regional Hospital on December 14, 2005. His discharge summary states: Glen has been extremely challenging, provocative and confrontational. Thought disorder with pseudo philosophical viewpoints consistently noted. Poor insight, has refused physical examination, has refused systematic examination of mental state. Noted to be talking to self, posturing, praying. 160. Glen RACE stayed at the Valley Regional Hospital for only a few days. During that time he was noted to be polite but disorganized in speech and
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somewhat grandiose. Glen RACE did not believe he had an illness or that he required medication. He wanted to disown his parents. He was hyper vigilant and suspicious. He continued to refuse any physical examinations or other investigations. He was diagnosed with schizophrenia, disorganized type. 161. On December 19, 2005 Glen RACE was transferred to the Acute Care Unit at the QEII Health Science Centre. Over the next several weeks the following observations of Glen RACE were made: a. b. c. d. e. f. g. h. i. j. k. l. m. n. o. Agitated mood; Perseverance on theme of unjust treatment; Persecutory delusions; Poor insight; Poor judgment; Reluctance to be interviewed; Suspicious of interviewers (accused them of being cursed); Refused to allow blood to be taken based on his religious beliefs; Disorganized thoughts; Disorganized behavior; Quite significant derailment with tangentially and loosening of association; Very guarded; Difficult to assess his thought content; Quite intimidating; Agitated and abusive, demanding to have the decision to have him hospitalized overturned; and, p. Refused lab tests, physical examination, vital sign checks. 162. Glen RACE was treated with antipsychotic medication which failed to produce any significant improvement. 163. On January 6, 2006 Glen RACE escaped from the hospital. He was returned by the police and escaped again on January 9, 2006. He went to Montreal and stayed at a fraternity house. He was discharged in absentia on January 13, 2006. 164. At the time of discharge it was noted that Glen RACE had not shown any significant symptomatic change. 165. On January 27, 2006 Glen RACE was brought to the Nova Scotia Hospital by the police. He was observed to be disorganized with severe aggressive
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behavior and agitation and increasingly bizarre behavior. He was paranoid and had auditory hallucinations. A note found in Glen RACEs pocket read that he felt the suffering of the world and that all evil should be killed. Glen RACE and his parents continued to lack insight into his illness. 166. Glen RACE was treated with antipsychotic medication but continued to show active psychotic symptoms and bizarre behavior. 167. Over the next several months the following observations of Glen RACE were noted: a. He used garlic to absorb negative energy (he consumed it, placed it around his room and was suspected of leaving it in room of another patient); b. He drew pentagrams and hung them in his room; c. He spoke about being spiritually raped by the hospital daily; d. He believed hospital staff were spiritual vampires who sucked the life from him; e. He believed all nature was sacred and that the trees talked to him; f. He was disdainful and dismissive of staff; g. He had persecutory and possibly religious delusions; h. He believed there could be dual realities; i. He believed he had the power to curse people and make them suffer; and, j. He almost equated himself to Christ. 168. In April 2006 Glen RACE was noted to still be delusional and lacking insight. His attending psychiatrist Dr. Wadhwa was of the view Glen RACEs illness had become treatment resistant. 169. Glen RACE was seen by Dr. Teehan, a specialist in psychotic disorders, who recommended Clozapine up to 350 mg/day. Treatment with Clozapine requires routine blood tests. Dr. Wadhwa noted on April 25, 2006 that Glen RACE did not want to give DNA to doctors or nurses based on his spirituality. However, on April 28, 2006 it was noted that Glen RACE agreed to have his blood drawn. 170. On May 7, 2006 Dr. Wadhwa prepared a report on Glen RACE in anticipation of a Review Board Hearing scheduled for May 9, 2006. He made the following observations about Glen RACE: a. Until recently he kept garlic in his room to keep demons and vampires away;
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b. He generally presented as quite agitated with verbal aggression and body posturing and staring intently to intimidate others especially the nursing and medical staff; c. On many occasions he gestured to curse the staff; d. He still has no insight into his illness and remains quite delusional; e. His illness has become treatment refractory; and, f. Glen is going to decompensate very quickly should he become a voluntary patient and left [sic] AMA (i.e. against medical advice) as he does not have enough insight to remain medication compliant. Once he is in the community his parents will have no authority to enforce medication compliance on him. 171. On May 17, 2006 Glen RACE was advised the Review Board had ruled he should remain an involuntary patient but that he had the capacity to consent to treatment. He referred to Dr. Wadhwa as corrupt. 172. On May 24, 2006 Glen RACE continued to hold religious and grandiose delusions. By May 29, 2006 however it was noted Glen RACE no longer believed the hospital was threatening his spirituality. His thought process was linear and free of delusional material and there were no perceptual abnormalities present. 173. Glen RACEs dosage of the antipsychotic drug Risperidone was lowered as his dosage of Clozapine was increased. 174. Dr. Wadhwa was transferred and Glen RACE came under the care of a new attending psychiatrist. 175. By mid-June, 2006 Glen RACE had begun to show signs of improvement. He denied paranoia or concerns about vampires. However his insight and judgment were still considered to be very superficial. 176. On June 30, 2006 Glen RACE was discharged from the Nova Scotia Hospital. At that time he showed no evidence of active psychosis. His insight was good and his judgment was fair. His diagnosis was: Schizophrenia, Undifferentiated Type. It was recommended that Glen RACE be followed up in the community by a psychiatrist at Hants Community Hospital. 177. While Dr. Teehan had recommended Glen RACE be prescribed Clozapine up to 350 mg/day it should be noted his treatment in the hospital and subsequent prescription in the community did not exceed 200 mg/day.
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Summer of 2006 Spring of 2007 178. Ms. Carol White RN was Glen RACEs case worker once he was released into the community. Glen RACE saw a psychiatrist twice. He met Dr. Acquino on August 16, 2006 and Dr. Morgan on September 14, 2006 both at the Hants Community Hospital in Windsor. Glen RACE was noted to be uncommunicative on both occasions. 179. In early January 2007 Glen RACEs father contacted Carol White RN to express concern over his sons behaviours including: a. b. c. d. e. He had stopped going out with his brother; He was staying in bed for extended periods; He appeared to be meditating; He was frequently downloading religious material from the internet; and He seemed to be fasting again.

180. Glen RACE did not attend his meeting with his case worker on January 11, 2007. Instead he left his home and went to a monastery in New Brunswick. Glen RACE left the monastery and went to Montreal for a short time. When he came home he was without any possessions having left them all in a Cathedral in Montreal. 181. After his return, Glen RACEs father again contacted case worker Carol White RN to advise his son was now admitting that he had never taken any of his medication and that he did not intend to take any in the future. 182. Between January and May 2007 Glen RACEs parents observed their son engage in the following behaviour: a. Spreading salt on the driveway and around the house (apparently to ward off demons and vampires); b. He bathed in salt; c. He would not allow anyone to be in the kitchen while he prepared his food; d. He cooked rice and left it outside to feed the spirits; e. He frequently meditated while holding a knife; f. He frequently held his breath which he stated was his way of fighting
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g. h. i. j.

demons; He took apples back to the trees because they were hungry; He claimed he could talk to the trees; He was in and out of the house at all hours of the day and night, carrying a knife; and, He told his mother he had the power to forgive sin but he would never forgive sin.

183. In early May 2007 Glen RACE killed Paul Knott and Trevor Brewster. He fled Nova Scotia, eventually crossing the border into New York State where he killed Darcy Manor. He was arrested in Texas very near the border with Mexico on May 15, 2007.

Incarceration in New York State: June 2007 October 2010 184. Glen RACE was returned to New York State where he was incarcerated in the Clinton County Jail. He was convicted of murdering Darcy Manor and in January 2009 he was transferred to the Downstate Correctional Facility. He remained there for six months until he was transferred to the Central New York Psychiatric Center (CNYPC) in July 2009. 185. During this period of incarceration, Glen RACE refused all treatment or medication. Officers observed the following behaviors: a. b. c. d. e. f. He sleeps minimally; Paranoid; Demonstrates strange mannerisms in his speech and movement; He is often fighting imaginary people in his cell, particularly at night; Eye contact is poor and threatening; and, Takes all meals in his cell so he can spend all his time meditating.

186. Glen RACE was seen in the Downstate Correctional Facility in June 2009 by Dr. Olden, psychologist, to determine if he should be transferred as an inpatient to the forensic hospital, Central New York Psychiatric Centre. 187. Dr. Olden reached numerous conclusions in relation to Glen RACE including: a. It is likely that he is unable to think clearly and concentrate effectively due
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b.

c.

d.

e.

f.

g.

to intrusive ideation; He has a serious impairment in his ability to think logically and coherently. He often has trouble drawing reasonable conclusions about relationships between events. This impairment leads to circumstantial reasoning and moments where his loose ideation is confusing to others and possibly himself; Glen RACE exhibits a serious impairment in his reality testing abilities, often misinterpreting events and forming inaccurate impressions of people. This often leads to him frequently failing to anticipate the consequences of his actions and his inability to determine the boundaries of appropriate behavior; His inability to effectively and consistently separate reality from fantasy and the inappropriate behaviours that may follow lead to persistent adjustment difficulties in his life; His thought process contains magical thinking and/or delusional beliefs. He shows a tendency to subjugate reality to fantasy when facing any situation he me feel is challenging; His reality testing is so impaired that most people with this degree of disturbance often have severe difficulty managing basic psychological aspects of everyday life; and, He is the type of individual that makes decisions based on what he thinks rather than how he feels.

188. Dr. Olden recommended Glen RACE be transferred to the forensic hospital and that consideration be given to obtaining an order to permit administering medication despite his objections. 189. From July 2009 to August 2010 Glen RACE was incarcerated as an inpatient at the Central New York Psychiatric Center. Upon arrival he was delusional, and paranoid. He had a very dangerous gaze and was religiously preoccupied. He slept minimally and displayed odd mannerisms. He spoke extensively about Buddhism, demons and guardian angels. He believed medication would dampen his spiritual progress. 190. During his time at the CNYPC some of Glen RACEs observed behavior included: a. He attempted to pour sugar into a peers ear; b. He voiced discomfort when staff stood too close; c. He was guarded and suspicious with blunted affect;
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d. He was grandiose; e. He was hyper vigilant; and, f. Other patients complained of feeling unsafe at night. Glen RACE would take a crane like stance on his bed and sometimes would stand over them while they slept. 191. The New York State Court found that Glen RACE was incapable of consenting to treatment and in April 2010 he was started on Resperidone. There was a noticeable response. By August 2010 Glen RACE was observed to be logical and coherent. He was discharged back to Attica Correctional Facility. His discharge diagnosis was Schizophrenia of the Paranoid Type with no Axis II Personality disorder diagnosis.

Incarceration at the East Coast Forensic Hospital: October 2010 to Present 192. In October 2010 Glen RACE was extradited to Canada. He has been incarcerated at the East Coast Forensic Hospital since his return. 193. During his time in the East Coast Forensic Hospital Glen RACE has cooperated with taking his antipsychotic medication. He has been polite. His affect is flat and he is not very motivated. He has engaged in few activities and spends much of the day in his room.

ALL OF WHICH IS ADMITTED this ___ day of November, 2013 at the Halifax Regional Municipality, Nova Scotia.

_______________________ Mr. Glen Douglas Race

__________________________ Mr. Paul Carver Counsel for Her Majesty the Queen

_______________________ Joel Pink Q.C., counsel for Mr. Glen Douglas Race

___________________________ Mr. Mark Heerema Counsel for Her Majesty the Queen

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