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No.

S149646
Vancouver Registry
IN THE SUPREME COURT OF BRITISH COLUMBIA
BETWEEN:
RANDAL HELTEN,ALBERT CHIN,TERRY GLENN
MORDEN also known as TERRY GLENN MARTIN,
RICHARD J.G. NANTEL and VIRGINIA A. RICHARDS
PETITIONERS
AND:
GREGOR ROBERTSON and GEOFF MEGGS
RESPONDENTS

RESPONSE TO PETITION
FORM67(RULE 16-1(5))
Filed by:

GREGOR ROBERTSON and GEOFF MEGGS(the "petition respondents")

THIS IS A RESPONSE TO the petition filed December 12, 2014.


PART 1: ORDERS CONSENTED TO
The petition respondents consent to the granting of the orders set out in the following paragraphs
of Part 1 ofthe petition: NIL.
PART 2: ORDERS OPPOSED
The petition respondents oppose the granting of the orders set out in paragraphs 1 6 ofPart 1 of
the petition and seek dismissal of the petition with special costs.
PART 3: ORDERS ON WHICH NO POSITION IS TAKEN
The petition respondents take no position on the granting of the orders set out in paragraphs Nil
of Part 1 of the petition.

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PART 4: FACTUAL BASIS
1.

The supporting affidavits filed by the petitioners contain no reliable or admissible


evidence that could support the allegations levelled against Mayor Robertson and
Councillor Meggs. Instead, the petitioners have chosen to swear affidavits replete with
inadmissible opinion, argument and anonymous hearsay.

2.

In this regard the petition and supporting affidavits contain false and defamatory
allegations and innuendo. The gravamen of the petitioners' complaint is that Mayor
Roberson and Councillor Meggs are corrupt. More particularly, the petitioners allege that
the petition respondents, as representatives of Vision, engaged in a "pay to play" scheme
with the executive the Canadian Union of Public Employees, local 1004 (CUPE
Local 1004).
(See eg. Affidavit #1 of V.A. Richards at paragraph 6 and 7)
(See Affidavit of Geoff Meggs at paragraphs 16 24)

3.

Had the petitioners published the defamatory statements in a forum other than court
proceedings, the respondents would have commenced an action for defamation as they
did when similar allegations were published by the Civic Non-Partisan Association and
its mayoralty candidate, Kirk LaPointe, during last fall's civic election.
(See eg. Affidavit #1 of Geoff Meggs at paragraph 17)

4.

The petition is ostensibly premised on an alleged "discussions between Gregor Robertson


and Geoff Meggs on the one hand and representatives of CUPE Local 1004 on the other
hand" concerning "the terms on which CUPE Local 1004 would support Vision
candidates, including Gregor Robertson and Geoff Meggs".
(See Petition, paragraph 12)

5.

The affidavits do not contain any evidence:


(a)

of"discussions between Gregor Robertson and Geoff Meggs and representatives


of CUPE 1004". Indeed such a meeting is specifically denied by Geoff Meggs.
(See Affidavit #1 of Geoff Meggs at paragraph 10;

6.

(b)

ofthe identity of the "representatives of CUPE Local 1004";

(c)

the date, time and place ofthe alleged meeting/discussions; and

(d)

what, if anything, was agreed to at the alleged meeting/discussions.

All the petitioners offer by way of evidence is second, third or fourth-hand hearsay
evidence obtained over the internet from a link to a reporter's story about a recording he
obtained from an anonymous source. The recording is of a small portion of a meeting
that occurred on October 14, 2011 attended by Geoff Meggs.

131894/2812940.1

-3(See Affidavit #1 of Randal Helten at paragraphs 7 9)


(See Affidavit # 3 of Randal Helten at paragraph 3)
7.

Assuming that the evidence found in the various affidavits filed on behalf of the
petitioners is admissible, all that the evidence discloses is as follows:
(a)

CUPE Local 1004 Political Action Committee recommended that CUPE Local
1004 make a campaign contribution to Vision Vancouver of$34,000;
(See Affidavit #1 of Randal Helten, at paragraph 8 and Exhibit"B")

(b)

various labour unions, including CUPE Local 1004, made donations to the Vision
election campaign;
(See Affidavit #1 of Randal Helten at paragraph 6)

(c)

that Geoff Meggs spoke at the October 14 meeting of CUPE Local 1004;
(See Response #4 of Jessica Landgraffto questions
from the petitioners' counsel)

(d)

that Geoff Meggs made the following statement in the course of his remarks:
"Gregor Robertson, our mayor, has again recommitted to not
expand contracting out to make sure that wherever we can bring in
new processes that members of 1004 will be there delivering those
services in your areas ofjurisdiction, ..."
(See Affidavit #1 of Hilary Renaud,Exhibit"A"

8.

There is no evidence that the decision to contribute to the Vision campaign was tied to
what Mr. Meggs said in his remarks to those present at the October 14 meeting. Mr.
Meggs specifically denies any knowledge of the recommendation of the Political Action
Committee of CUPE Local 1004 to contribute to the Vision campaign and specifically
denies that he "met with anyone from CUPE 1004 prior to the meeting". He also denies
that he had "discussion with anyone from CUPE 1004 about promising any benefit to
CUPE 1004 or its membership in exchange for a political donation".
(See Affidavit #1 of Geoff Meggs at paragraph 10)

9.

There is no evidence to contradict the sworn evidence of Mr. Meggs at set out in the
preceding paragraph.

10.

The affidavits filed on behalf ofthe petition make no reference to Mr. Robertson at all.

11.

The evidence of Mr. Meggs is that the policy of Vision Vancouver to not support
expansion of contracting out of city services dates back to the 2008 municipal election.
Mr. Meggs did nothing more than confirm that there was no change in this policy when
he made his remarks at the October 14, 2014 meeting.

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(See Affidavit #1 of Geoff Meggs at paragraphs 3 - 13)
PART 5: LEGAL BASIS
1.

Nothing in the petition or the supporting affidavits establishes that Mayor Robertson or
Councillor Meggs acted in a conflict of interest or may have had a direct or indirect
pecuniary interest in the matter.

2.

Similarly, nothing in the petition or the supporting affidavits establishes that


CUPE 1004's contribution to the electoral campaign of Vision Vancouver ("Vision")_
was made on the "express understanding" that all of the Vision candidates, if elected,
including Mayor Robertson and Councillor Meggs, would "deliver their votes" not to
expand contracting out.

3.

Rule 22-2(12) and (13)sets out the nature ofthe affidavit evidence a deponent may give:
(12) Subject to subrule (13), an affidavit must state only what a
person swearing or affirming the affidavit would be permitted to
state in evidence at a trial.
(13) An affidavit may contain statements as to the information
and belief of the person swearing or affirming the affidavit, if
(a)the source ofthe information and beliefis given, and
(b)the affidavit is made
(i) in respect of an application that does not seek a
final order,or
(ii) by leave of the court under Rule 12-5 (71)(a)
or 22-1 (4)(e).

4.

The orders sought by the petitioners are final orders.

5.

In C. (KL.) v. C. (J.), Master Baker provided a useful summary of the jurisprudence on


objectionable affidavits:
Counsel for Mr. C. relies upon F.(J.K.) v. F.(J.D.)(1986), B.C.J.
No. 672; Creber v. Franklin (1993), B.C.J. No. 890; and Webber
v. Wallace (1994), B.C.J. No. 1894. All are decisions of our court.
Shortly stated, in all these cases the court directed that portions of
affidavits be expunged for various reasons. These reasons include:
hearsay upon hearsay, or irrelevance (F.(J.K.) v F.(J.D.)),
inadmissible opinion, adjectival descriptions, or subjective

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descriptions of reactions(Creber), unidentified witnesses, opinions
regarding motives, or argument(Webber).
2000 BCSC 798 [Emphasis in original]
6.

All these objectionable features are manifest in the petitioners' affidavits, and the
offending portions ought to be struck out pursuant to Rule 9-5(1).
Jones v. Industrial Wood and Allied Workers ofCanada (Local 1-3567),
2011 BCSC 926 at para. 9 to 17

7.

The first affidavit of petitioner Randal Helten is particularly noteworthy for its
noncompliance with Rule 22-2(12) and the common law rules of evidence. For example,
at paragraph 9(b)of his affidavit, Mr. Helten purports to lead evidence of a "secret" audio
recording of a CUPE 1004 membership meeting that allegedly occurred on October 12,
2014, a meeting which Councillor Meggs purportedly attended (the "Audio Recording").

8.

The Audio Recording is the only factual evidence offered by the petitioners that could
conceivably suggest impropriety by the respondents.

9.

The difficulty for the petitioners is this: In the hands of Mr. Helten, the Audio Recording
is, at best, quadruple hearsay. According to Mr. Helten, he obtained the Audio Recording
(quadruple hearsay) from the YouTube website (triple hearsay), which had obtained it
from reporter Bob Mackin (double hearsay) who obtained it from an anonymous source
(hearsay) who allegedly recorded the words spoken therein.

10.

With this many degrees of separation between Mr. Helten and the speakers of the out-ofcourt statements, Mr. Helten could never authenticate the Audio Recording at trial.
(There is no suggestion that Mr. Helten was at the meeting where the words were
spoken.) By simply attaching an electronic file of the recording to his affidavit, Mr.
Helten does not make the Audio Recording admissible as evidence.
R. v. Andalib-Goortani, 2014 ONSC 4690 at para. 28 to 34;
R. v. George Jack Giroux, 2013 NWTTC 04(and authorities cited at para.18 to 25);
Ulrich v. Ulrich, 2004 BCSC 95 at para. at 32

11.

It follows that the petition is without an evidentiary basis and an abuse of the Court's
process; it ought to be struck out pursuant to Rule 9-5(1)(d).

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Chernen v. Robertson, 2014 BCSC 1358 at para. 29 to 33.
12.

The petitioners originally brought an application to have the claim struck but adjourned
the application at the request of counsel for the petitioners in order to allow the
petitioners to adduce further evidence which they did in the form of a statement from
Jessica Landgraff, a union employee who took minutes of the meeting on her laptop. All
that the evidence of Ms. Landgraff establishes is that Mr. Meggs attended the meeting
and that the recording appended to Mr. Helten's affidavit "sounds accurate".

13.

Rather than renew the application to strike the claim the respondents elected to file this
response so that the petition would be decided on its merits. To that end, Mr. Meggs has
sworn an affidavit in which he confirmed his presence at the meeting and acknowledged
that he said the words relied on by the petitioners.

14.

Ms. Landgraffs evidence is important in one respect. She states that "the recording is
incomplete or has been edited or both".

The recording lasted approximately

9:22 minutes. The meeting lasted from 5:00 p.m. until 6:52 p.m. Ms. Landgraffs
evidence is also important in another respect. She is the only witness/affiant that was
present throughout the entire meeting. Importantly, her statement does not make any
reference to what if any motions were approved at the meeting.
15.

In summary, even with the evidence of Ms. Landgraff, the petitioners have not met the
evidentiary burden on them to prove, even on a prima facie basis, what, if anything, was
approved at the meeting.

16.

Leaving this issue aside, there is no evidence connecting what Mr. Meggs said in his
remarks to the contribution made by CUPE Local 1004 to the Vision campaign. There is
no offer and acceptance which is the essence of a binding agreement. As for CUPE
Local 1004 it is impossible to say what they decided at the meeting because there is only
a partial transcript of an unverified recording which "is incomplete or has been edited or
both".

17.

Accordingly the petition and supporting affidavits fall far short of what is required to
support a finding that the respondents had a direct or indirect pecuniary interest that gives
rise to a conflict to interest.

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18.

The petitioner's reliance on Highlands Preservation Society v. Corp. of the District of


Highlands, 2005 BCSC 1743 is misplaced. Municipal politicians should not have their
integrity called into question on such specious grounds. Legitimate donors to municipal
political parties ought not to be chilled from exercising their democratic rights to
participate in the political process.

19.

Similarly, the facts in the other case relied on by the petitioners, Schlenker v. Torgrimson,
2013 BCCA 9 bears no relevance to the facts of this proceeding. That case involved a
situation where the involved civic councillors were also directors of the entity whose
contract with the municipality they voted in favour of. It was on that basis that the Court
of Appeal found that their conflicting fiduciary duties created a disqualifying conflict.

20.

A case on point is King v. Nanaimo, 2001 BCCA 610. In that case the Court of Appeal
held that a municipal councillor did not have a disqualifying pecuniary interest where he
received a $1000 campaign contribution by the principal of a developer, and
subsequently voted in favour of matters benefitting the developer. The Court of Appeal
held:
[12] ... What was prohibited by s.201(5) is participation in the
discussion or vote on a question in respect of"... a matter in which
the member has a direct or indirect pecuniary interest." The
"matter" (or matters) in respect of which questions arose before
Council were, in this case, the various applications by Northridge
Village and its associates. Nothing in the facts established in this
proceeding could justify the conclusion that Mr. King had a
pecuniary interest, direct or indirect, in any of those matters. The
mere fact that Northridge made campaign contributions could not,
in and of itself, establish any such interest. There could, of course,
be circumstances in which the contribution and the "matter" could
be so linked as to justify a conclusion that the contribution created
a pecuniary interest in the matter. Indeed, the learned chambers
judge took note of an example of such a situation when he said in
his reasons:
There is no evidence of a pecuniary interest in the
sense that he agreed to vote for these projects in
return for their campaign contribution of$1,000.00.
[13] It would not be useful to speculate as to what circumstances
could create an indirect pecuniary interest. It is enough to say that
the mere fact of the applicant having made a campaign

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-8contribution is not enough. In the absence of any factual basis for


finding that Mr. King had a pecuniary interest in the matter, the
finding based on s.201(5) is wrong in law and must be set aside.
21.

The obvious lack of legal merit of this proceeding, together with its apparent political
purpose, ought to attract an award of special costs. In every respect it is reprehensible
and deserving of rebuke. Not only does it make scandalous and unfounded allegations
and innuendoes, but it is an abuse ofthis Court's process for rank political ends.

22.

In Morriss v. Prism Properties Inc., 2010 BCSC 454, the Court, per Gropper J., held, in
making an award for special costs:
[83] Special costs are awarded in cases where the conduct of the
one of the parties is "reprehensible". That term was interpreted in
Garcia v. Crestbrook Forest Industries Ltd 1994 CanLII 2570
(BC CA),(1994),9 B.C.L.R.(3d)242 at para. 17, 119 D.L.R.(4th)
740(C.A.):
[17] ... it is my opinion that the single standard for
the awarding of special costs is that the conduct in
question properly be categorized as "reprehensible".
As Chief Justice Esson said in Leung v. Leung, the
word reprehensible is a word of wide meaning. It
encompasses scandalous or outrageous conduct but
it also encompasses milder forms of misconduct
deserving of reproof or rebuke. Accordingly, the
standard represented by the word reprehensible,
taken in that sense, must represent a general and all
encompassing expression of the applicable standard
for the award of special costs.
[84] Special costs can be awarded on the basis that the plaintiff's
claims lacked legal merit, or if the plaintiff fails to ascertain that
there is no evidence to support the claim before advancing it:
Crown West Steel Fabricators v. Capri Insurance Services Ltd.,
2003 BCCA 268(CanLII), 2003 BCCA 268, 227 D.L.R.(4th)574.
I am convinced that Mr. Morriss' pursuit of his claim based on the
alleged option was not so benign. It was not a mere failure to
ascertain that there was no evidence to support it; rather, it was a
premeditated attempt to harass the defendants to achieve Mr.
Morriss' ends to get the property.
[85] In Catalyst Paper Corp. v. Companhia de Navegacao Norsul,
2009 BCCA 16 (CanLII), 2009 BCCA 16, 307 D.L.R.(4th)285,
Mr. Justice Hall stated at para. 17:
[17] It seems to me that the trend of recent
authorities is to the effect that the costs rules should
be utilized to have a winnowing function in the

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litigation process. The costs rules require litigants
to make careful assessments of the strength or lack
thereof of their cases at commencement and
throughout the course of litigation. The rules
should discourage the continuance of doubtful cases
or defences. This of course imposes burdens on
counsel to carefully consider the strengths and
weaknesses of particular fact situations. Such
considerations should, among other things,
encourage reasonable settlements.
23.

Finally, a failed allegation in a civil lawsuit of corrupt conduct will more readily justify
an award ofspecial costs against the maker than will other types of unproven allegations.
Abakhan & Associates Inc. v. Golden Arch Resources Ltd, 2012 BCSC 346 at para. 7

PART 6: MATERIAL TO BE RELIED ON


1.

Affidavit #1 of Geoff Meggs, made March 19, 2015.

The petition respondents estimate that the application will take one day.

Date: 23 March 2015

xP
HARPER GREY up
(Per Bryan G. Baynham, Q.C.)
Lawyer for the petition respondents Gregor
Robertson and Geoff Meggs

The petition respondents' address for service is:


HARPER GREY LLP
Banisters & Solicitors
3200 - 650 West Georgia Street
Vancouver, BC V6B 4P7
Telephone: 604 687 0411
Fax No: 604 669 9385
Attn: Bryan G. Baynham, Q.C./sjp/#131894

131894/2812940.1

This is the 1st affidavit


of G. Meggs in this case
and was made on March 19, 2015
Court File No.: S149646
Vancouver Registry
IN THE SUPREME COURT OF BRITISH COLUMBIA
BETWEEN:
RANDAL HELTEN,ALBERT CHIN,TERRY GLENN
MORDEN also known as TERRY GLENN MARTIN,
RICHARD J.G. NANTEL and VIRGINIA A. RICHARDS
PETITIONERS
AND:
GREGOR ROBERTSON and GEOFF MEGGS
RESPONDENTS

AFFIDAVIT
FORM 109 (RULE 22-2(2)AND(7))
I, GEOFF MEGGS, Councillor, of 819 Sawcut Avenue, in the City of Vancouver, Province of
British Columbia, MAKE OATH AND SAY AS FOLLOWS:
1.

I am a resident of the City of Vancouver and elected member of council having first been
elected in 2008 and re-elected in 2011 and 2014. As such I have personal knowledge of
the matters and facts herein deposed to save and except where the same are stated to be
made upon information and belief and as to the latter I verily believe them to be true.

2.

I was a founding member of the municipal political party known as Vision Vancouver
and have personal knowledge concerning its policies over the years including the
longstanding commitment not to expand contracting out ofjobs performed by the City's
unionized employees including members of CUPE 1004.

3.

I recall the issue of contracting out coming up in the 2008 nomination to be the mayoralty
candidate for Vision which was contested by Raymond Louie, Gregor Robertson and

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Allan De Genova. Raymond Louie, who lost the nomination battle to Gregor Robertson,
publicly declared during the campaign that he was against contracting out as city workers
provide good value for money. Gregor Robertson, to the best of my recollection, did not
make a definitive statement that he was against further contracting out until after he won
the nomination.
4.

In the 2008 municipal election all Vision candidates including Mayor Robertson and
myself publicly stated that we opposed any expansion of contracting out of civic jobs.
This "policy" was widely publicized in the media as was the fact that Vision was
supported by the union movement, including CUPE 1004. By way of example, a
GEORGIA STRAIGHT editorial dated November 2008 stated as follows:
"Keep in mind that there are some significant differences between
Vision and the NPA. Vision is supported by many unions, so it
shouldn't surprise voters when its mayoral candidate, Gregor
Robertson, promises not to contract out civic services."
Attached and marked as Exhibit"A" to this my affidavit is a copy of the online editorial
dated November 12, 2008.

5.

There was no change in the Vision policy with respect to contracting out in the 2011 civic
election in which Mayor Robertson and I were both re-elected. Once again, the position
ofthe Mayor and of all Vision councillors was a matter of public record. One example of
the public record is the GEORGIA STRAIGHT candidate survey which all "hopefuls"
including all seven Vision councillors answered. Question 10 read as follows:
"10. Do you favour contracting out more city services to the
private sector?"
I along with the other six Vision candidates answered no to this question.
Attached and marked as Exhibit"B" to this my affidavit is a copy of the GEORGIA
STRAIGHT questionnaire.

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6.

The 2011 Vision Vancouver campaign again sought the support of the union movement
and union members. As was the case in 2008 various unions including CUPE 1004
publicly supported Vision Vancouver and donated funds to Vision's election campaign.

7.

In the lead up to the 2014 election campaign the Vancouver District Labour Council
Political Action Committee ("VDLC") sent out a candidate survey to those seeking the
office of mayor or councillor. One ofthe questions in the survey was as follows:
"3. Under what circumstances would you consider contracting out
or privatizing public services?"
My answer to that question was as follows:
"Our council has not expanded contracting out or privatization
and I do not support any change to that approach."
It is my understanding that Mayor Robertson and each ofthe Vision councillors answered
this question, if not in the identical words, in words to the same effect, that is, they
answered that they did not support any expansion of contracting out.
Attached and marked as Exhibit"C" to this my affidavit is a copy of my answers to the
VDLC candidate survey for mayor and counsel.

8.

In the lead up to the 2014 civic election Vision again sought donations from and the
support of various public sector unions. As part of Visions' fundraising efforts I assisted
in preparing a fundraising letter addressed to various unions that was ultimately approved
of and signed by Mayor Robertson. In the letter Mayor Robertson specifically confirmed
that those seeking election under the Vision Vancouver banner were committed to
encouraging no privatization or contracting out.
Attached and marked as Exhibit"D" to this my affidavit is a copy of the generic
fundraising letter sent out under the signature of Mayor Robertson.

9.

On October 14, 2014 during the civic election campaign I attended a membership
meeting of CUPE 1004 along with Councillor Raymond Louie and Parks Board

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commissioners Trevor Loke and Niki Sharma. As I understood it several civic political
parties were invited to the meeting and were given an opportunity to seek financial
support and endorsement by the membership of CUPE 1004. Having listened to a
recording of a portion of that meeting and having had the opportunity to review the
agenda (Exhibit"B" to affidavit #1 of Randal Helten), I understand that the Political
Action Committee of CUPE 1004 had met in a previous meeting and recommended that
$34,000 be donated to the Vision campaign and that the Political Action Committee's
recommendations would be put to a vote at the meeting.
10.

At the time I had no knowledge of the fact that the Political Action Committee had made
a recommendation to contribute to the campaign of Vision Vancouver. I had not met
with anyone from CUPE 1004 prior to the meeting nor did I have any discussion with
anyone from CUPE 1004 about promising any benefit to CUPE 1004 or its membership
in exchange for a political donation.

11.

The four representatives of Vision Vancouver including myself were only present for a
small portion of the meeting. I was present for and heard the oral presentation by
representatives of COPE. There was also a presentation from two school board
candidates. I made a brief presentation and listened to the presentations thereafter by
Niki Sharma, Trevor Loke and Raymond Louie. My remarks were intended to convey,
and I believe did convey, that those running under the Vision Vancouver banner had
close ties and were supportive of the union movement generally and would appreciate
their support.

12.

I knew that the issue of contracting out was important to the membership of CUPE 1004,
as well as other unions, as it had been in the campaigns of 2008 and 2011. Recognizing
this fact, I reiterated the longstanding commitment of Vision Vancouver not to support an
expansion ofcontracting out of city services.

13.

My remarks were intended to confirm that our commitment on this issue had not changed
since 2008. The same commitment had been made in past campaigns and was also
contained in the fundraising letter sent by Mayor Robertson to various unions
approximately six weeks before the meeting. The commitment not to expand contracting

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out was not in any way tied to whether or not CUPE 1004 or any other union for that
matter made a donation ofany size to the Vision Vancouver campaign.
14.

Following the presentation of Raymond Louie I left the meeting with the other three
representatives. I do not know what was discussed after we left nor the outcome of the
vote, save and except for the transcript that has been produced as Exhibit"D" to
affidavit #1 of Hilary Renaud. I have read the transcription of the audio recording and
have listened to the audio recording attached as Exhibit"C" to Mr. Helten's affidavit #1.
The transcription of my remarks and those of Ms. Sharma, Mr. Loke and Mr. Louie
appear to be accurate. As I was not present for the remainder of the meeting I cannot say
whether the transcription of what was said by unnamed individuals after I left is accurate.

15.

Prior to swearing this affidavit I had the opportunity to review the response of Jessica
Landgraff to questions put to her in writing by the petitioner's counsel. I note, in
particular, her answer to paragraph 9 where she states that the recording in question is
approximately 9 minutes and 22 seconds in length and while the meeting lasted for
almost 2 hours from 5:00 p.m. until 6:52 p.m. Ms. Landgraff also states that "the
recording is incomplete or has been edited or both".
A copy of Ms. Landgraffs statement is attached and marked as Exhibit "E" to this my
affidavit.

16.

As disclosed in Mr. Helten's affidavit #1 my presentation to the membership of


CUPE 1004 at the general meeting on October 14th was disclosed in a news story
published in the VANCOUVER COURIER by Bob Mackin. Included in the online
version of Mr. Mackin's story was a link to a recording ofa small portion ofthe meeting.

17.

Based on Bob Mackin's story and a link to a recording of a portion of the October 14th
meeting, the NPA mayoralty candidate, Kirk LaPointe, in an OPED piece in the
PROVINCE newspaper, at a press conference, in paid advertisements on television and
radio stations and in postings on the Civic Non-partisan Association website accused
Mayor Robertson and me of corruption, buying votes, dishonesty and a lack of integrity.

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18.

We were not prepared to allow these defamatory statements to go unchallenged and


instructed counsel to commence an action for defamation. The action for defamation was
served and a response filed on behalf of Mr. LaPointe and the Civic Non-partisan
Association prior to election day. I value my reputation for personal integrity and
honesty very highly as does Mayor Robertson. Mayor Robertson and I intend to see the
case to trial and have instructed our counsel to obtain the earliest possible trial date.

19.

I have read Affidavits #1 and #3 of Randal Helten who ran unsuccessfully for mayor
against Mayor Robertson in 2011. In paragraphs 11 to 13 of his first affidavit and in
paragraphs 4 to 8 of his third affidavit, Mr. Helten leaves no doubt that he believes and
his fellow petitioners believe that I was party to a corrupt agreement between Vision
Vancouver and CUPE 1004. I consider this a direct attack on my integrity and honesty,
as well as a direct attack on Mayor Robertson's integrity and honesty. In effect, Mr.
Helten is using the defence of absolute privilege that applies to affidavits filed as part ofa
court proceeding to echo defamatory statements that are the subject of separate
proceedings.

20.

I find it particularly offensive that Mr. Helten purports to be the voice of "thousands of
electors in Vancouver" and that he and his fellow affiants are simply bringing this claim
"so that issues that are important to our democracy can be resolved by the Court"
notwithstanding the verdict of the voters, who re-elected Mayor Robertson and me. In
his affidavit, Mr. Helten also purports to be an advocate for "promoting transparency"
and "accountability", while at the same time he refuses to answer a question from Charlie
Smith ofthe GEORGIA STRAIGHT as to who was funding the petition. In my view this
petition is nothing more than a desperate attempt by Mr. Helten and others to use the
courts for political purposes.

21.

I have also read the Affidavit #1 of Virginia Richards. To my knowledge I have never
met Ms. Richards, nor do I know anything about her background and politics save and
except for what is contained in her affidavit. I consider the statements contained in
paragraphs 5 to 7 to be a direct attack on my integrity and honesty and an attack on the

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integrity and honesty of Mayor Robertson. This is clear from paragraph 7 of her affidavit
where she specifically states that it is her belief that we are "corrupt".
22.

I have also read the Affidavit #1 of Albert Chin. In paragraphs 6 and 7 Mr. Chin takes a
slightly different attack on my integrity and the integrity of Mayor Robertson by alleging
that as a result of accepting a donation from CUPE 1004 Mayor Robertson, Raymond
Louie and I "lack" "ethical standards". In paragraph 7 he defames the three of us by
alleging that we engaged in pay for play by offering "to exchange influence for a political
donation, even if that as not actually said on the recording". Once again I consider this to
be a direct attack on the integrity and honesty of me, Mayor Robertson and Councillor
Louie which would form the basis for an action in defamation were it not for the fact that
the defamatory allegations were made in an affidavit in support ofthe present petition.

23.

I have also read the Affidavit #1 of Terry Glenn Morden, who also ran unsuccessfully for
council in 2011 as a member of Mr. Helten's electoral organization. At paragraphs 9
to 11, after referencing the article by Bob Mackin, Mr. Morden asserts that by
"exchanging promises" I had done "a terrible thing" which "subverts our democracy".
Once again, I consider this to be a direct attack on my personal integrity and honesty.

24.

I have also read the Affidavit #1 of Richard J.G. Nantel. In paragraphs 5 to 9 of his
affidavit, Mr. Nantel makes vague references to "done deals" and then references his
concerns about my statements at the October 14th meeting and the resulting lawsuit
against the NPA and Mr. LaPointe. He concludes by stating that "That kind of money
exchange to me seems .... violation of proper conduct under the Vancouver Charter".
While Mr. Nantel's statements are more nuanced than the outright allegation of
corruption by Ms. Richards, I still consider it to be an attack on my integrity and honesty
by implying that I was a party to a pay to play scheme by accepting money for Vision in

13189412815200.1

exchange for a commitment not to permit contracting out of city services in the next
collective agreement between the City of Vancouver and CUPE 1004.

SWORN(OR AFFIRMED)BEFORE
ME at Vancouver,in British Columbia,on
March 19, 2015

)
)
)
)

A Commiss
r for taking A 'davits
within British Columbia

)
)
)
)
)
)
)

BRYAN G. BAYNHAM
BARRISTER & SOLICITOR
3200 Vancouver Centre
650 West Georgia Street

(Print narneilniiV'stin$66tro7mmissioner)

131894/2815200.1

The Straight slate for municipal elections in Vancouver and the burbs I Georgia Straight, ... Page 1 of 17

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news features

The Straight slate for municipal elections in


Vancouver and the burbs
by EDITORIAL CM NOV 12, 2008 at 3:53 PM

Lnia

Twist

3.1

STORY

VOTE&WIN &amanita WineCountry Gstaway Ls.


& titbitsto IATIihniconvior Food +Cooking Fest

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Your horoscope from 3anuary 15 to 21, 2015

Michael J. Fox treated Parkinson's with brain drilling


procedure, reveals neurologist xa

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and more let

Variety's values-based banking brings CEO Tamara


Vrooman in contact with global Icons is

5 Scott McLean enters race for HOP nomination in


Vancouver East RP
Vision Vancouver's Gregor Robertson (left) Isn't tarnished by city council's secret decision to lend up to
$100 million to a developer; incumbents Raymond Louie, Suzanne Anton, and David Cadman hope voters
focus on their accomplishments.

'referred to In the

WITH THE HELP of clever marketing consultants,political parties can sometimes mislead the
public. In the last federal election,the NDP pretended that Jack Layton had a chance of
becoming prime minister in order to boost the party's chance of taking seatsfrom the Liberals.
The Conservatives put Stephen Harper in front ofchildren on numerous occasions to show he
cared about families,even though his party had eliminated daycare agreements with the
piroviqces.
-711'd the federal Liberals presented themselves as a united team behind St6phane Dion
en,i)rivately,some MPs were deeply disenchanted with their leader.

We've seen a similar spinning in advance of the Saturday


(November is)Vancouver municipal election. Vision Vancouver
presents itself as the caring alternative to the Non-Partisan
Association,even though Vision wants to invest far more new
money in beefing up the police force than in local libraries or new
community centres for youth. Vision is also calling for more
transparency regarding the city's financial dealings over the billiondollar Olympic Village. But four Vision councillors attended an incamera meeting last month that, we've been told,authorized a Stoo
-million loan with zero transparency.

Meanwhile,the Non-Partisan Association is presenting itselfas the


party for addressing street disorder in Vancouver. But no NPA

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1/15/2015

The Straight slate for municipal elections in Vancouver and the burbs I Georgia Straight, ... Page 2 of 17

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candidate,asfar as we can tell, has uttered a peep about the


provincial government's punitive social-welfare and taxation
policies, which are at the root oframpant homelessness.No NPA
candidate,asfar as we can tell, has voiced any concerns about the
provincial government's refusal to do anything for ttrban aboriginal
youth in Vancouver,who are sometimes the most at risk of
becoming drug addicts.
It's tempting to recommend a pox on both major parties and urge
the public to vote fora slate ofindependents. But that wouldn't
result in the best city councilfor Vancouver,because the
independents have no experience.That's why we favour a balanced
slate that mixes experience with idealism.
Keep in mind that there are some significant differences between
Vision and the NPA.Vision is supported by many unions,so it
shouldn't surprise voters when its mayoral candidate,Gregor
Robertson,promises not to contract out civic services. NPA mayoral
candidate Peter Ladner has said he is open to the idea of
contracting out services ifthis provides a better deal for taxpayers.
The NPA has already supported an $Boo,000 expansion ofthe
Downtown Ambassadors program;this is, in effect,contracting out
security to business-improvement associations. Many property
owners on the boards ofthese associations are also contributors to
the NPA.

SEE FULL LIST OF BEST OF VANCOUVER WINNERS r

LATEST STORIES

Video: How to behave as a Fernen activist


(warning: nudity)
ET CETERA s 24 MINUTES AGO

Fourteen things to do in Metro Vancouver on


Friday, January 16
LIFE 37 MINUTES AGO

Pot activist Marc Emery talks shop at UBC


LIFE 39 MINUTES AGO

During council's last term,Vision,and not the NPA,was the loudest


proponent for increasing the number of police officers in
Vancouver.
The police union is a contributor to Vision, which opposes
expanding the Downtown Ambassadors program.
Ifyou think Vancouver has too many police alreadyanother96
officers and 22civilians were slated this year and nextthen you
probably shouldn't votefor either Robertson or Ladnerfor mayor.
At a November9candidates meeting,independent mayoral
candidate Marc Emery advocated freezing the police budget forever
and taking away officers'Tasers if he becomes chair of the
Vancouver police board.You won't hear that from Robertson or
Ladner.
Vision and the NPA also have distinctly different positions
regarding the six-lane Burrard Bridge. Vision and its ally, the
Coalition ofProgressive Electors,favour a trial converting one lane
of traffic for cyclists,a half-lane each in either direction. During the
trial, there would be signals installed that would change the
direction ofthe carlanes(similar to the signals on the Lions Gate
Bridge)so there would always be three lanes open for rush-hour
vehicles.The other two car lanes would always travel in the
opposite direction.
The NPA now opposes its earlier plan to widen the bridge, which
would have cost up to $63 million. During the recent campaign,
Ladner proposed that a barrier be installed separating cyclists and
pedestrians and traffic. According to the NPA,this would cost $33
million and retain all six lanesfor motorized vehicles.
The pesky left-wing gnat in this election,the Work Less Party,
supports dedicated bike-lane corridors linking all parts ofthe city,
as well as dedicated bike and bus lanes on all roads and bridges.
The Work Less Party,whose mayoral candidate is antilogging
activist Betty Krawayk,also favours reducing reliance on private
cars by introducing road tolls. COPE has called forafree bus loop
between the downtown core and the Broadway condor and will
push for a single transit fare for the whole region.
On development issues, Vision and the NPA have voted in favour of
freezing the rate ofchange in certain neighbourhoods,which has
slowed the number ofevictions. As a result,it's harderfor
developers to convert rental buildings into strata-title
condominiums.

http://www.straight.com/news/straight-slate-municipal-elections-vancouver-and-burbs

1/15/2015

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Here's an easy guide to where Vancouver citycouncil candidates stand on some key issues.
(N/R= no response)
(N/A= not applicable)

Candidate
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ident and phone number


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needed Where possible, ple
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pag
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Please complete and return Mall: VDLC #020-1880 Triumph Street, Van
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te
1cm Vetting Commit

-13
onses Questions 2.
Geoff Mew resp
ur community?
ical issues facing yo
it
cr
e
st of
th
e
ar
at
2. Wh
the skyrocketing co s
ly
al
ci
pe
es
,
ty
li
dian income
nges of inequa
ese earning above me
ecedented challe
Vancouver faces unpr of reach for most families, even th poverty next to great.afftuenCet. The
.
to
out
housing. which is homelessness, as well as extremes oftransit. The council has to find ways
in
in
d
nt
nt
se
ce
me
es
de
st
pr
t,
we
is
ex
big ir
This
ronmen
y, andwe need a
using, a dean envi
city is growing quickls the needs of all Its citizens for ho .these problems, so ensuring proper
le
et
ensure the city me . The city has limited toots to tack lt.
re
we
mo
as
ty
ch
ri
be a prio
jobs and mu
al inclusion has to
services?
consultation and re
privatizing puolic
or
t
ou
g
in
ct
ra
nt
you consider co
umstances would
rc
ci
at
t any change
wh
er
nd
ti
.1.
d I do not suppor
an
n
io
at
iz
at
iv
pr
cting out or
expanded contra
Our council has not
.
IP3s)?
to that approach
rivate partnerships
-p
ic
bl
pu
er
id
ns
u co
umstances would yo
only
4 Under what circ
ve engaged in that
ha
d
an
ps
hi
rs
ne
rt
rnment.
ic,private pa
senior levels of gove
ok to mate publ
Again, we do not to sees a condition of funding from
do
nicipality?
where required to
t options for your mu
en
em
ur
oc
pr
l
ca
ct lo
pect CETA to Impa
ll public
5. Haw do you ex
me, without the fu
is
ti
th
At
M.
e
FC
th
at
our right to
es to oppose CETA we expect further efforts to curtail
ur
as
me
r
he
ug
to
d
We urge
ct, but
t to gaup the impa
text, it is difficul nesses and jobs.
support local busi
e environment?
consideration to th
th
wi
y
om
on
ec
t
an
support a vibr
one of
6. How would you
e goal of becomingon the
th
g
in
tt
se
e
il
wh
y
rt, working
en the econom
new
nership with the po
steps to strength
We've taken many cities. We have improved our part so supported jobs in the arts, with
al
st
e
ne
ee
'v
gr
we
ss. but
d television
the world's
improve rail acce
s a hub for film an
Powell St, overpass to . by ensuring Vancouver remain
In film
.
creative spaces; th the emerging green tech seeto?
wi
d
an
;
on
ti
produc
community?
r green jobs in your
fo
fy
ti
en
id
u
yo
s do
strategy that Is
7. What opportunitie
r. has a green jobsproduction and
yo
ma
e
th
by
d
re
food
on, chai
ese include local
onomic Commissi
Our Vancouver Ec s of new jobs in a host of areas. Thre.
producing thousand chnology, recycling and much mo
l te
processing, digita
ge" Initiative?
ort far a "living wa
pp
su
of
l
ve
le
d
derstanding an
ration of
a. what Is your un
with the 8C Fede lity. At
s
wa
I
en
wh
ys
da
y
s earl
le inequa
wage" campaign in it
understand and tack
I worked on the "living ovides a really wait/able toot to nized, the vast majority of our
unio
that
e it pr
Labour and believ ver, where we are overwhelmingly. I believe the living wage Is an issueas the,
id
ou
15
sa
nc
ge That
s expire in 20
the City of Va
above the living wa
when their contract
employees are at orbargaining table with our unions
e
on this Issue.
should come to thng
-term engagement
to
a
of
se
ia
ot
t
rs
fi

policy?
of support for a "fair wage"
el
lev
d
an
g
din
tan
ers
und
0. What is your
not compete
tractors far city services do lcome the
con
re
su
en
to
t
too
t
an
rt
po
4 fair wage policy is an im
union wage I would we
ges to the prevailing, usually ent process. This is different from a
oy wage-cutting. It links wa
em
measures through our procur
development of fair wage two approaches would have to be aligned.
e
living wage program and th
ernentsr
t for 0 "project labour agre
or
pp
Su
of
el
lev
d
an
g
din
10. What is your understan
They
41 the municipal Wye(
t they are seldom relevant
se
bu
sen
ts
en
em
re
ag
e
our
vid
on
lab
pro
t
a comm
I believe Ow
d
I support projec
an
ts
jec
pro
re
ctu
tru
ras
may be for certain regional inf ion by qualified trades under union agreements.
uct
str
con
y
lit
qua
re
su
en
way to
r community!
r improving malt in you
11, What Ideas dp you have fo
wider frequent bus network,
course. but also a much
of
,
ay
bw
measures are
su
ay
dw
oa
Br
abus service.. all of these
Where do I stop?
Se
sed
rea
Inc
t.
ar
yD
nd
re Ha
nk deserves full support.
mare night bus.servIcei mo
l iD.year plan, which I thi
nci
Cou
s
or'
May
e
th
in
ed
includ
ity?
e housing in your municipal
abl
ord
aff
far
ve
ha
u
yo
12. What ideas do
vate ane not
ency to partner with the pri on to our
Ag
g
sin
Hou
e
abl
ord
Aff
r
iti
We have created a Vancouvere affordable housing across the city. This is In add units and
tal
ma
forproflt sector to build has triggered the creation of thousands of nev ren ke homelessness
h
ma
ic
wh
We
m,
ts like Taylor Manor.
Rental 100 progra
rs. Ilan provide
social hoising with projec
direct city Investment in believe It must be a key focus for the next four yea
and housing a priority and d like.)
ul
as much detail as you wo
?
poverty In your municipality
13. How would you address
e made
eet homelessness and we'v number of
str
ate
min
eli
to
it
mm
co
.a
We are the only council to ALSO cracked down on slumlords. implemented
have
nts. The two key things
significant progress. We
broad program of social gra d light to expand
ers
hav
we
d
an
es
ur
y
as
ordabilit an
tenant protection me
netessness and housing aff
hoi
s
res
add
to
ue
tin
we can do: con
e tiatives.
portant social Justic Ini
public transit. Both are im
h affordable child caret
pport to assist families wit
su
u
yo
do
ns
pla
at
Wh
14.
to add hundreds
es and will set firm targets
ac
sp
re
ca
ld
chi
w
ne
for
ms.
goals
We have exceeded our mpaigns for provincial and national child care progra
ca
g
tin
por
sup
le
whi
more,
d how would
ms In your community an
le
ob
pr
as
fy
nti
ide
u
yo
lity do
15. What forms of inequa
?
em
th
you address
g costs are rising much
but here in Vancouver housin the median family
be,
glo
e
th
nd
ou
ar
ing
ce is earning below
Inequality is worsen
gest part of the work for
me with any
faster than Income. The larbut it is impossible to live in the city an such an inco
s find R difficult
income of about 570,000.ges are falling behind so that even unionized workert the fundamental
address them. bu
security. Increasingly, wa oken above about how we
sp
el
lev
al
to make ends meet, eve
e provincial and nation
change has to come at th
y card?
16. Oo you have a librar
Yes,

y
ease services!
to maintain or incr
ed
ne
ey
th
ng
li
ir
ies get the tw
t7. Now could librar
nt from taxes.
e civic governme
th
om
fr
me
co
ld
The money shou
pality?
ate In your munici
im
cl
s
on
ti
la
re
ur
scribe the tabo
last round of
PA, How would you de
ey were and the have to work
th
an
th
er
tt
be
ch
we
e mu
e, but relations ar ke to see that continue, but know
li
We can always improv
d
ul
wo
We
.
ry smooth
bargaining was ve
ad increases.
morale as worklo
e
ov
pr
harder to im

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9 What Is your understandin

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FOR EiliMSH COLUMBIA

September 18, 2014


Dear
As Mayor, I believe much of our city's success is due to the strong relationship we've
built with the labour movement. As we prepare for a tough re-election fight in
November, I'm writing to request a renewal of this important partnership.
Vancouver is a truly world-class city no question. Because of top-quality services
provided by public and private sector unions with our City, School and Parks officials,
our city is well run, clean and safe. On behalf of all Vancouver residents, I'd like to thank
your membership for everything they do.
When Vision was first elected, one of our top priorities was to foster a new level of
respect and fairness at City Hall. I think you'll agree Vancouver has come a long way
since the bitter strike under the NPA in 2007.
On the budget side, we've protected public services while keeping taxes low. We also
reached a new collective agreement that brought in fair increases for City workers and
ensured no privatization or contracting out.
We've also backed unions in the private sector. We spoke out against the lockout at
Rocky Mountaineer and we supported collective bargaining for hospitality workers.
We're also proud to stand with unionized workers in the film industry.
Beyond City Hall, our commitment to labour also extends to the School Board. Thanks
to Board Chair Patti Bacchus, we stood with teachers to defend public education and
free collective bargaining across the education sector.
We're also supporting working families with significant investments to make Vancouver
more affordable. We expanded access to childcare with more than 900 new spaces a
City record. On transit, we're fighting to advance the Mayors' Council Plan to expand
bus service region-wide and build the Broadway Subway.
www.votevision.ca
604.568.6913 PO Box 4635 Station Main Vancouver BC V6B 4A1

.i...

/2-

On housing, we approved 1,100 new rental units in 2013 renting at prices working
families can manage -- and will open 600 new social housing units in the next six
months. In addition, the recently founded Affordable Housing Agency will build 500
new units of rental housing in the next three years.
We're also fighting hard to reduce street homelessness and are determined to keep
fighting until it's eliminated completely.
But all this progress is at risk if we don't win on November 15th.
We all remember the mess the NPA left in 2007,so I'm asking for your support to keep
Vancouver moving forward. We can't afford to get dragged backwards by the NPA, Mr.
LaPointe and NPA president Peter Armstrong, the architect of the Rocky Mountaineer
lock out.
I'm proud of the constructive relationship we've built together, and I am anxious to
renew it as my colleagues and I seek another term.
In the next few days, I, or one of my fellow Council candidates will be in touch to
discuss the renewal of our partnership.
Thank you for your consideration. I look forward to working with you and your members
to make Vancouver an even better place to live.

Gregor Robertson

P.S. I am also proud to inform you that all Vision Vancouver candidates are being
endorsed by the VDLC

www.votevision.ca
604.568.6913 PO Box 4635 Station Main Vancouver BC V6B 4A1

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A CON
NER FOR TAKIN3
AFFIDAVITS FOR BRUSH COLUMBIA

Action No.S-149646
Vancouver Registry
J

IN THE SUPREME COURT OF BRITISH COLUMBIA


BETWEEN:
RANDAL HELTEN,ALBERT CHIN,TERRY GLENN
MORDEN also known as TERRY GLENN MARTIN,
RICHARD J.G. NANTEL and VIRGINIA A. RICHARDS
PETITIONERS
AND:
GEORGE ROBERTSON and GEOFF MEGGS
RESPONDENTS

Responses of Jessica Landgraff to Questions from Petitioners' Counsel


1. Did Ms. Landgraff attend the CUPE 1004 meeting held on October 14, 2014 [the
"Meeting"] referred to in the agenda attached as Exhibit B to Randy Helton's first
affidavit [attached]?
Answer yes
2. Did Ms Landgraff record the events at the Meeting as indicated in the agenda?
Answer yes
3. If so, in what form did she record the Meeting, that is via audiotape, videotape, written
notes, or otherwise?
Answer I took the minutes on my laptop.
4. Does the agenda at Exhibit B accurately reflect the business conducted at the Meeting,
and if not, how does it differ?
Answer There was one amendment made to move the speakers up on the agenda from
the bottom to the top ofthe agenda. Additional business was added under the sections of
"New Business" and "Good of the Union"from members from the floor. Members are
allowed to make motions from the floor under these sections. Otherwise that agenda is
accurate.
5. Was Geoff Meggs present and did he speak at the Meeting?

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