ONTARIO COURT OF JUSTICE (Ottawa Region) INTHE MATTER OF an application for @ Search Warrant pursuant to section 487 of the (Criminal Code; [AND IN THE MATTER OF an application for an Order Denying Access to Information (eating Order pursuant to section 487.91) ofthe Griminal Code. |, Matthieu Boulanger, a puaco affcer and member of the Royal Canadian Mounted Police (RCMP), make ou and cay as flows: 4.1 have reasonasle grounds to believe the follwing offences have been commited: ‘2. Breach of Trust by a public officer contrary to secon 122 ofthe Criminal cose; '. Wrongful communication of nfermatin contrary to section (1a) ofthe ‘Seounty of Information Act ‘Allowing possession of document contrary to section 4(4X() of the ‘Socury Information Act.” ‘Tamora te sve ned ceo fh icy of ifort At wee Scared ncn 9 ‘ast of the sup Eourt ef Ot oO. Conary Gene. Tis eon rat bean esi and err reion ws poe yh pete ars Feet Ue vy thee ten | sm nce sem the frac oO an ete wat 2 ste be Fy trowpwen wih he Gut te apply Belg cnleed Wn eat ve he dnc be Susp to these fn re the seo ellen Bech fT anderson 22 fhe Page of 97OVERMAN n nnn AITRODUCTIOR ns DeFONS & ABEREMATONS.. SDURCESOF NFORMATIN nner WVESTIGRTIVESTEPS LEADON UPTO THSSEARCH WARRANT EG SOUGHT + 80 oer aE fader fanaa Non and ab nD {ecton tote arcade ig onscreen SE papoose ossicles pond ay pet of Seach VT a COO senunc Koen a a) a So MIPOOKTE anne jer E aaonene NO SS poreone serene oe sore a pena er a APPNOICE" n = MOOD? coe PPO on Page 20897APPEND one pePEHOIK APPERODE Pao APPENOOCU one APPEOUC NE om APPEND Wace APPIADIE nnn _PPEWOUK a cas APENOICAR — APPENDIL BB” nnn ine APPENDICC nnn . 95 PRENOK “DD eet wn 6 Pages of 97ovERVIEW This etter of Inert commited the Government of Canada fo reimburee Chanter Dave's costs upto S29M if canractwas nol awarded by Novernber 30, 2016. ‘5.1 have reasonable grounds to believe that wo government ofa independenty jeakedclassifod information surounding the interim Ausiary | Oler Replenishment (AOR) cont Fri invocation ended up in te possession BF BiTan Marsa, 2 buyist working for Hil+Knowiton Strategies Canada, [ebbing fm representing Chanter Davie, and Spencer Fraser, CEO of Project RResalve ne. (PRI, the entity exeated by Chanter Davle to manage the resupply Ship's roofing. This Informaton to Obtain focusses on tho information in the posseesion of Fraser, who used this information subject to cabinet confidence to Frflence the decision makers tough various means including the medi. 4 Throughout the investigation, various search watrants, goneral warrants end production orders have been executed. The frst warrant was executed at the tice of Kevin Macintosh, a lobbyist working at Fleishmantitard Canada Inc, 2 {obbyng fim representing Chanbar Dave atthe time ofthe leak, Detain te form fof emails Was seized at FleichmanHllard Canada Ine. which Wentiied HMacintoet’s sauces of classed information 2s John Schmit, View President, Commercial at Chanter Davie and Blan Mersereau, Chairman at Hilrnowon Strategies Canad, 5. Two addonal search warrants were then exoouted, one at the HilleKnowton Strategies Carada office in Otter, Ontario, and the other atthe Chanter Davie ‘fic I Léxis, Québec. Data inthe form of emals was seized at both locations, snd documents including a Memorandum to Cabinet (MC) bearing the “Secret” ‘esignation, vas elo seized at the Hil+Knowlton Sirategies Cancda oft. ‘These emails Hentfy te sources of the leak of cassis information. henner baer nosed prepa veer of Cand nO 26 0 bin6. reviewed the emails seized at Chanir Davie and I boiove thatthe source of the loak to Fraser was Vico-Admical Mare Norman, thon Commander of the Royal ‘Canadian Novy. Norman, | believe, provised the infrmation subject to cabinet tanfidence to Spencer Fraser, who then provided updates tothe Chanter Davie / PRI team, Some ofthis information was subsequent dstibuted to lobbyists and fventualy tothe media As sel out in detall below, 8 review of Fraser's emals \Jemonetates tre Fraser had a source of information he refered to 29 “our end? fd tat his sure, I blieve, as Norman. In alton to sending ema from the Sno! 26ers: TE wich were seized during the ‘recufon of a search warrant at Chanler Dave, Fraser also used the private onal ace: I forward lassie information. 7-Two production orders were subsequently served on Shaw Cable Systems GP. The frst was lo obtain all emal contents and contacts preserved pureuart (0 & prosorvaton demand dated sly 12, 2016, for Shaw customer email address “The second production order was to obtain the subsorber Iformaton, system notes along with the content of any other email accounts aoeocated to the Shaw Cable Systems GP. customer aooount to which is associated, ond an update of TM emai ‘contents ane eantacs, 8.A review ofthe email conlent received from Shaw Cable Systems G.P. revealed fhat some of the information subject to cabinet confidence thot Fraser was Sending. to fie Chanter Dave PRI toam was being received from | which | batove to be used by Mark Norman. The emal rev aleo idetifed what | belove to bo atid email adds used by Fraser, 19.A general warant was authorized and executed to coverty andlor remotely or ‘thorwise gain acoess tothe mobile davices, copy andor seize, by any means, {ata Including email auhenticaion deta and any electronic communication, sent roveived_or saved, between May 21, 2014, and July 3, 2016, stored within the mobile devices, copy andlor s8ize electronic communications by using Collected authentication details to remotely access emall_ accounts J. andlor any other emit ecount for viien avenicabon detais have been collected, for Mark Norman's iPad andlor eallular shone (associated to phone number ) and for ‘Spencer Frasers cellar phone (associated to phone numbe] p {0.Athough none of Norman's devices or email accounts were successfully ‘accessed, the execution of the general warrant resulted in emaits being seized ftom Fraser's email account, A review ofthese emais revealed that on March 30, Page Sf 972016, Fraser, using his wit address, sant an eral to Norman's ‘email adress, demonstrating Communication bolweon Norman and Fraser even beyond the AOR contrac boeing aired Chantior Davie PRL {1.1 am now seeing the authorzation ofa search warrant fo be exeouted at the eidonee of Mark Noman located at 825 Adencffe Drive, Ottawa, Ontario, to Soe electronic communication devices containing data demonstrating that Norman tansnited or communicated protected information to unauthorized patties Inciting Spencer Fraser. These communications contained information elated to the interim AOR project which was protected by cabinet confidence that ‘Shout! not have been disseminated tothe public, Therefore, | bellve tracing the tigi of this formation trough electronic communication devices such a Calllar phones, Pads end computers wil ford evidence to conf Nortan's oo of bis malas well as ideny the exfent ofthe leak of classi information, Furthermore, Norman's possession of these devices wil also afford ovidence into the offences being investigated. This evidence will demonstrate that Norman's conduct represenied a serious and marked departure from the standards ‘cxpected of an individual in te ofcia's positon of public ts hereby commiting {Breach of Tris pursuant to section 12 of the Criminal Cade and wil afford ‘vidonce that tloman's conduct was also a visaton ofthe Security of Information Act INTRODUCTION 421 am a Peace Officer and | have been a member ofthe RCMP since March 17, 2008.1 2m exrenty posted to the National Division based in Ottawa, Onario. At this. posting, Tam an investigator wth the Sensitive and Intemational Investigations unit whose mandate isto focus is expertise in sense, high-tsk inwestigatons info significant threats to Canada’s pica, economic and sacst Integy. Prcr to my current posting | spent nearly vee years in the Otawa Detachment Financial Crime team. 48. Dufing my career vith the RCMP, | have been an aint assigned to sn nvestigaton that targeted the online sale and dstrbuton of marhuana using Canavin Prat as a courler, Aa 9 result, | prepared several judicial authorizations Including preston orders, sealing orders and a search warrant. | was also an fafiant for ‘he financial component of an, investigation that targeted an ‘organization that operated a clandestine lab producing ecstasy. During thie Investigation | had dealings with senior bank employees from various financial Page 60097institutons olor with forensic aocountants and other business professonak, ‘Duo to my contribution, the investigative team determined that the businass ‘porated by the organzaton was Ina fact an legitimate business fanced by a nod etiminel Anoher investigation to which was assigned, focusing on prooeeds of erne, led me to work wth enlor bank offidals 9 well as business ‘mers. AS a result of having idonifies potential proceeds of cme abroad, t ‘resented the RCMP in a meeting with high ranking government ofa nthe Inteior Securty Fere in Beirut, Lebanon, 44. 1n additon to my previous investigational experience, | suecessfuly completed ‘the Seareh Warrant Drafng course in March 2012. This course ls designed to develop the Knonledge and stile of potce officers 9 draft item-speciic or technique-spedte formations to Obtain (IFO) and warrants, and included the {olloning topics: warrant types and requirements; information from Third Petes; fand grounds lo belleve and warantloss search and seizures. Adctonaly | ‘completed the Financial Investigations Techniques course in Octobor 2013. This course Is dacigned 0 provide tools to assist investigators in gathering and preserving therequred evidence to successfully prosecute indvduals involved in Financal crimes. ts topics include financial ciimes, money laundering, Investigative techniques, major case management and using the Internet for investigations. 115. Throughout my career, Ihave paripated in various investigations ranging from ‘rug and organized crime Investigations to proceeds of cime and money faundaring Investigations. Inthe majorly of those investigations, | found neary all people have communicated by some electronic means, whether by email or tellar phone meseages. I fe my experiance that when dealing wi business Drofectionals, these fecords are kept in a meficlous manner, generaly to Protect themselves against polendal Lawsuits by dents, and 10 demonstrate bilable work, 46.1 have personal knordedge ofthe matters and facts deserbed in this Information {to Onlain, except where stated to be on information and belie. | fliove the Contents of ts Information to Obtain to be te 117.1 undeestandtat this san ex parts application and that am obligated to prove full and fair disclosure ofthe all materia facts avalabe to mo. Inthe process of itoring thie doeument, didnot inckade every single data ofthis investigation. Fotexample, | eid ot indude information that was duplicaled between the Privy Council Offee intemal investigation. and the ongoing criminal investigation. ‘ddionlly, many of the reports | have read (end have summarized below) ‘contain mest information than | have included in this document. In an efor to Page of 97prepere.a document that is concise and wrtn in plan language, {have included information thet | believe relatos to this specific investigation and that is necessary to establish the grounds for issuance and to make full and fair (Bsdlosure. Despite the fac that | have summarized some of the information | have ead, | belove there is sufient nfrmation inthis document to support the requested search warrant, am also aware of my obligation to provide ful and fait disclosure ofthe Informaton relating to the issuance ofthe requested search ‘warrant and fo dscose information known fo me that materaly undermines the precondltions fr the proposed warrant, and have done o. DEFINITIONS & ABBREVIATIONS 18. Troughout the Information to Obtain, have used acronyms and abbreviations to describe catan terme. In tis Secon, | have included the fl names fora ‘acronyms and have provided dfinions fo descrbe what | reference throughout ‘his information o Obi ‘2. Abbreviations and Dofiitons: ‘AOR — Autry Ofler Replenishment: Ship utlized by the Royal Canadian Navy which provides a spectum of operations at home ‘nd abroad, inluding responding to ratural disasters, humanitarian ‘izes, and deterrence and peace operations. PCO ~ Privy Counc Office: Hub of nonpartisan, public service supporto the Pre Minister and Cabinet and its decision-making structures, [RCN ~ Royal Canadian Navy: Canada’s naval foree, and one of ‘hee environmental commends within te Canadian Armed Forces {cary LOLLetter of Intent: A document outiring the genera plans of an agreement between two oF more partes before a log agreement ‘efnalze. Cabinet confidence? — The tenn “Confidences ofthe Queen's Privy Counc for Canada’ (commonly refered 10 3s “Cabinet The tpreme Coun of nas eck x Cae (tomey Gone 00} dc, ste "he Bash “mown whi fers the can aon hs lan oie te aay f wae io {he atin vo, aot uss paper ppv fo it sn. Theres ae ds Tose (Pepe the hen repost of tng goverment desorbed al eco the (Penton tacoma blo em ano eet al rn few atu ar ht wt hey rab yok Page $f 97‘cerfdences’ ie defined In legsaton, notably in section 29 of the {Canada Evidence Act, section 68 ofthe Access to Information Act ‘ant section 70 of the Privacy Act. Cabinet confidences inciude Invrmation contined in, but nt inte to: ‘8, Memeranda the purpose of which Is to present proposals or recommondations lo Counc 'b, Discussion papers the purposo of which i to present background explanations, analyses of problems of palcy options to Counel fr consideration by Council Jnmaking decsions ©, Agenda of Counel or records of deliberations or decisions of Counc 4. Records used for er reflecting communications or discussions between Ministers of the Crown on matters relating to the making of goverment ‘decisions or the formulation of goverment poi; Records the purpose of which isto bref Ministers of the Cronin relation to mators tat ate before, or are proposed tobe brought before, Counc or that ae the Subject of communicatons oF eiscussions referred to In paragraph (a and f. Drategistaton b, Pereont and businesses mentioned inthe Information to Obtain: ‘Chanter Davie Canada Ino. (Chanter Davie: Canada's largest and highest capacty shipyard and one of the largest sipbulers in North Ametca. Chanter Davo is located in Lexis, Québec. Project Resolve Inc. (PRI): A specal purpose ently eeated fr the AOR project by Inocea Group, the parent company of Crantor (Davie Canada Inc. PRI is now Faderal Flat Service. Irving Shipbuiling tne. (11): The second targest shipbuilder in ‘canada, Headquartered in Halil, Nova Scola, the company is & “om ine be naj oie ety LI aint meats ware ot sone, aint Imenban mi csr hr woe consi o unecnus They mip hyo fe sang ngePar pti orm mating cmon tht rp cone plncayheoret” Page9 of 97willy owned subsidiary of the Canadian industisl conglomerate 133. ving Lite |v. Ssaspan ULC (SS): Seaspan provides marne-etated services 10 the Paciic Norwest, The group of companies includes shipyards IinBriisn-Cotumbia \ Feishman-Hilard Canada inc: Lobbyist fim hired by and Tepresenting Chanter Davie to assist them vath the AOR project. Fishman lard Canada ines bbying actly for hanior Davie fended on January 11,2016. vi. bilKnowlion Strategies Canada: Lobbyist fim tired by end fnpresenting Chander Davie to assist them with the AOR project. tieKnowilon Stratogies Canada romaine Usted as active on the “robsto ofthe Office ofthe Commissioner of Lobbying of Canada. vii Catherine McKenna: Environment and Climate Change Minister vii Scott Brison: President of tho Treasury Board of Canada Secretariat (TBS) ve Melissa Burke: Anaiyet st the Foreign and Defence Policy Secretariat at POO 1 Siobhan Har: Director of Operations, Economie & Regional Development Paley (ERDP) PCO. i, fan Bumey: Assistant Secretary tothe Cabinet, ERDP PCO. vii Les Linklater: Deputy Secretary tothe Cabinot Operaions, PCO. vil Brian Mersereau: Lobbyist at HileKnowiton Strategies Canada (Ottawa office) represesing Chantir Davi. div, dohn Schmidt Vico President Commercial at Chanter Davie ‘ev. Spancor Fraser: CEO of Foderal lest Services, formety Project Resolve Inc. Joi. Kevin Macintosh: Lobbyist at Fleishmansillard Canada. Ine (Ottawa ofie). soil, James Cucmore: Reporter at the Canaan Broadcasting “Corporation (CBC) during the time of he leak of nferation. Page 100697soil, George Da Pont: Retired Depuly Minster of Public Senices and Procurement Canada (PSPC), six. Gavin Liddy: Aspociate Deputy Minister at Public Services and Procurement Canada, x. ex Viet: CEO of Ingcea, parent company of Chanter Davie. vex Marke Norman: Viee-Admiral and former Commandr of the FREN (at the time ofthe leak), recently promoted to Vice Chief ff Defence Staff of the Canadian Armed Forces. Norman is Suspected of having committed @ Criminal Code section 122 Inoach of trust offence, The search warrant sought with this Toplication is for a search of Norman's residence located at £25 Adenclife Drive, Ottawa, Ontario. sos Jon Mack: Former Doctor General of Procurement Services atthe Department of National Defence (OND). Lodi Kevin McCoy: President af ining Shipbuilding nc voiv, Ken Hensen: Foner nary ofleer and maine secuity analyst t Dalhousie University ,ow. ain Garceaur Employee of Project Resolve In. 6. Investigators Comment {. investigator's comments ~ Throughout ths Information fo Obtain | have aided comments 1 expla ook information and to stato my Dole. Where these comments are added, | have defined them with square brackets and an alc foo, fas Such 1 Verbatim quotes — In the Grounds to Believe section of this Information to Obtain | have added verbatim quotes used during ‘mall communication. Where these quotes are used, | have wien thom as they appear on the selzed data/dooament and hightghted them using a bold and an dae fort, as such. SOURCES OF INFORMATION {9. Toughoutthis Information to Obain various sources of nfmaton have been ed to forrulste my reasonable grounds of belt, These include: Pape of 97«a, Package of documents prepared by the Privy Counc! Office (PCO) and provideto the RCMP: |. A document tied “Intemal investigation Into the Unautherized Déslosute of Cabinet Corifidence Information Relating t© the Inerim Aunitary Replenishment Copabiiy" dated November, 2015, Prepared by Gory Deneautt and Louise Lacalle of Secuty ‘Oreratons at PCO. This package includes documents such as Iiemoranda fo Cabinet, emails and othor documents obtained by P50 while conducting their ttemal investigation. When sourcing ‘ny erounds using the PCO package, | wil refer to the spectic ‘document contained inthe package. b, Audio recorded interviews: |. rleriew of Minister Catherine McKenna, Mnisier of Environment ‘2nd Gimate Change, canduced by Sot Denis Beausin and Supt nis Desnoyers, both mambors of the RCMP, on January 19, a6. i Interiew of Melissa Burke, Analyst at the Foreign and Defence Folcy Secretariat at PCO conducted by Cpl. Joss Dubsime ond (pl. Benjamin Bertrand, both members of the RCMP, on January 20,2016. J hnervow of Minister Scot Brison, President of the Treasury Board, conducted by Sot. Beaudoin and Supt Desnoyers, on January 29, 2016 Iv. Inteniew of George Da, Pont, Deputy Minister (ered) of Pubic ‘Senvices and Procurement Canada conducted by Cpl. Betrand and hhep. Mike MacLean of tho RCMP on February 8, 2018, 1 nteeview of Kevin Macinlosh, Senior Vice-President at Fleishman Hillard Canada Inc's Otawa ice conducted by Cp. Bertrand on March 31,2016. interview of Spencer Fraser, CEO of Project Resolve, conducted by ‘pl Duhaime and myself on May 11, 2016, ‘yen sourcing information fam one af the above noted interviews In tho tnformaton to Obtain, | acquired the knowledge by Htering to a recording ofthe interview in question, Page 120097Documents and data seized during the execution of a search warrent at the offer of Fleishnan-ilad Canada Inc, located at 45 O'Connor Steet, ‘Suite 120, Ottawa, Ontario. 4. Documents and data seized during the exzcution of a search verant at the offic: of HisKnawiton Stratagies Canada, located at 55 Metcalfe Street, Suite 1100, Ottawa, Ontario «Data seed during the executon of ¢ search warrant at the office of ‘Chantior Davie Canada Ine, located at 22 rue Geome-D. Dave, Lévis, ‘Québec {Data sozed ae a recut of production orders served on Shaw Cable Systems —G.P._for the email contents of the email address 9. Data seized a2 a reaull of the execution of the goneral warrant from Fraser's oral address INVESTIGATIVESTEPS LEADING UP TO THIS SEARCH WARRANT BEING ‘SOUGHT 20. Asa result of fre documents received frm PCO tied “intemal Investigation nto the Unauthorised Disclosure of Cabinet Confidence Information Relating to the Intesim Auilary Replenishment Capabilty’, along with inerisws of officals Invelved in the AOR contract. was determined that Kevin Macintosh lobbyist ‘working for Fhishman-Hilard Canada ine. and representing Chanter Davie at the time of the leak, was in possession of information protcted by cabinet confidence 21.0n Merch 28 2016, Ontario Court of Justice Judge D. Lahsie authorizes a ‘search warrant (eluding an assistance order and a sealing order) to be fecuted at Flshman-Hillad Canada Inc's offi located at 45 O'Connor Street, Sule 1200, Olav, Ontario, The search warrant was executed on March 31, 2016, ani various documents and data pertaining 10 the unauthorized ‘lsciosute of te formation pean to tre AOR project were actzod, caer rrnetn etered by cabin canferce lo Yona Woe’ acs, Tea akon The Page 3 of 9722, During an interview, Macintosh was asked wat he knew regarding the Ad Hoo CConmitse and answered: “All know is what Iwas told, that there was 2,1 quess| fp meng, That's what someone, 1 guess they [Charlier Davie} knew, but ‘ersinly noone tld me about it, except them [Chanter Davie}” Macintosh also Stated he reseed a bing note from someone al Dave, most ket fom Jot Smidt® 23, Resulting rom the analysis of the emails seized at Flelshman-Hitard Canada Ine, twas delerined that Macintosh recelved te information subject o cabinet confidence a emails sent by Schidl® ‘24. On ay 9, 2018, Oniero Court of Justice Judge J. Brunet authorized wo search warrants (nchding assistance orders and sealing orders), the fist to be fxecuted af HilsKnowton Strategies Canada's office located at 65 Metcalfe ‘Sreot, Silo 1100, Ctiave, Ontario, and the other at Chantior Davie Canada Inc's office located at 22 tue George-D. Davie, Lévs, Québec. On Nay 11.2016, the two searc warrants were exccued, during which various documents and fata pertaining to the unauthorized dielosure ofthe Information related to the [AOR project ware solzed. 126. As a result of he analysis of tha data seized at Chanter Dave, twas discovered that Spencer Fraser was suppjing information subject to cabinet confidence to Schmid, to Asx Viceield, CEO of Inocea, parent company of Chantor Dave, ‘and to variouslabbysts working on behalf of Chanter Davie. Fraser sont multplo mail to the above menoned group, in ful orn pat in which Fraser sources the information contained in his emalls toa person he refered to as “our frond” [Adsiionaly, ene of the emails vont by Fraser contained the subject heading arco fo “our fiend” nchded, “rod i ying warring of Maso’, codes by Sean om ch «era in vending see ard tc Seni sent Ma co Novis 1, 2015, sao. meen ad wacker are sncedin padi of is eration tn + vnared is by ceding al ae sn Sih asl on over 1,205, 9:02 om hit ‘sched Append nfm Page M0897FATT information was sfomaton subject fo cabinet eonence 26.Athough Froser most wed 1S TT ost ‘address to communicate withthe Chaner Dawa /PRI team, some emals were cont rom his LE orl adress. 27.0n July 26, 2046, Ontario Court of Justice Judge M. Hoffman authorized production order (hekiding @ non-disclosure order and a sealing order) 1o be Served on Shaw Cable Systems G.P. fo obtain the data preserved subsequent to f preservation demend dated duly 12, 206, including the email contents and contacts for emal address 28.0n July 27, 246, Ontario Court of Justice Judge M. Hofman authorized 3 production onder, non-dieciosure order and a sealing order tobe served on Shaw Cable Systeme GP. to obiain the subscriber Information, system notes along vith the content of any other email accounts associated to the Shaw Cable ‘Systems GP. customer account to which TM's 2socoted. 29. Pursuant to these production orders, email content and contacts were solzed ‘fom Shaw Caple Systems G.P. Through the analysis of tee emails, i was determined te Fraser was receiving information subject to cabinet contnce fom the onci odes: ET wich 1 lieve to be (sed by Mark Horan, Aire emai address befeved fo be used by Fraser was alto discovered, 30, Alco included withthe content of he TTI eras, was 3 contact Crested for "Mork Noman’, which cde a fame phone number, 2 cal phone umber and th amit address ‘no af the two phone numbers under Noman’ contacts ited as | 1.1 conducted an interet search on the wonnvhitenanes.ca mebste, wich idee tat he I phone ruber is associated to 1, Noman at £25 Adeeb, rears, ON. Teed sb rardg ea Fis ent Shi snd edo ve 5 2015, 42 pT ‘inl er sce Brite sactin of x each war t Che De on Ma 2, 26. The em ‘ate sept" ths nomen te Oban * eed i by realness Ves on Move 8,208,243 mT ena was tc sine enctin of ech wart Choe Ds on My 31,201. Tee stad Page of 97'92.0n October 14, 2018, Ontario Court of Justice Judge A. Aldor authorized ‘seneral wartant and sealing order to coverly andor remoaly or ethers gain ‘access to the mobile devices, copy andlor seize, by any means, data incuding email authentiction details and any electronic communication, sen, received, ‘saved, betwoen May 21, 2014, and July 31, 2016, stored within the mobite devices, copy andlor seize electronic ommuricatons by using collected authentication dota to remotely socass—omall accounts andlor any other emt faccount for whieh auontcation detais have been coleced, foc Mark Norman's 'Pad andior celular phone (assodated to phone number ) ana ‘Spencer Frasers caliar phone (aseociated fo phone number] p. 288. As result of he exzcuon of the geneal warrant, email authentication details ‘were obtsinee from Fraser's cellar phone’ for the email address ‘No data, including omall authentication details, was ‘plained from any of Nowman's devices. 34, 0n November 6, 2016, Ontarlo Court of Justice Judge A. Alder authorized a ‘general warrant and sealing order allowing for continuation of the technique ‘authorized with the October 11, 2018, ganeral warrant. This November 5, 2016, ‘general warran provided greater deal nt the technique being lized. 25, Asa resull ofthe execution of this latest goneral warren, emails from the email, address NIL were seized. One email in paricutar was sent ‘om Fraser to Norman on March 30, 2016, demonstrating thatthe two were stl in communicaton despite the AGR contract being awarded to Davie / PRI on November 30,2018. GROUNDS FOR BELIEF Background on| [EERE 27 tho Aucttary Oller Repl ishment contract 38, The Royal Cenadian Navy (RCN) operated two Auxiliary Oler Replenishment (AOR) ships om the 19902 unl 2014, at which point both were ‘decommissioned earlor than anticipated. The RCN ordered two new AOR ‘vessels fo replice he retired ship, but these are only scheduled to ba delivered age 60697to the RN in 2020 and 2021. Tis resulted inthe RCN having an AOR capably gap of 45 year.” ‘57. On duly 51, 2015, the Government of Canada" signed a Lotter of Inent with Chantier Davie and Project Ralve nc. (Chartier Davie) to start negotiations for the procurement of senvioes agreement for an itarim AOR shi.” The relevant ‘lauses ofthe Loto of Intent are set out as follows: L The Goverment of Canada il enter Into a non-competitive Cnitact with Chanller Davie to reiroft an AOR for anproximatly ‘67M. i. Should the Government of Canada decde to aot award the contract to Chanlier Davie by November 30, 2015, the Goverment of ‘Canadas to reimburse Charlier Davi'e costs up to $090, 138. On October 7, 2015, the commercial ship "Aste arrived at Chanter Davie in Love, Québec. Upon the ship's aval at the shipyard, work began to refurbish it according othe Letior of Intnt® 2, — "th eth ater fet wa ene he aan vere as Made by in Mie eon pera concent ——E—_—_—_ ———_e Page 17 f97“41 the early morning of November 20, 2018, a news aricie written by James ‘Cudmore was publahod on CBC's website. The article stated “CBC News has Jeamed thet on Thureday [November 19, 2015), the commit has delayed doing on the dea! [wih Chanier Davie] for atleast two months" "* 42 [1he content of the Commitige meeting wos protected by confiencs of the ‘Queen's Privy Gouna (cabinet confidence) and should not have ben public fnowiedge. Codmore'’s article clearly demonstrates 9 source privy to the Clscussions held daring the Commitee masting disclosed the confilential Information to an unauthorized person afer the Commitee meeting] ‘Frrarred ws by megan ao eight lise Br rst th ost an ‘une ely Seta t PX cence by EDs LB Rrra Lh marr the RMP, ‘non 28 206 ———>S— == ened i een rt igen ned, cont ye. nan ‘idsip moyen bah nthe RESP enor 206 earned ty ad Cure: ne tie aes “Ove arin suey sip SOM del dey ssa de Hownbe 29 205, ced on iste nella hie rs he {Sinn thea tached in Append tO Page 1809748, As government procurement is part of the mandate of Public Sarvloss arel Procurement Canada, tis ministy’s then Deputy Minister George Da Pont layed a signifeant role in the orchestration of the AOR. project. During fis Trteriew, Deputy Minister George Da Pont elated he believes the information included in Cudmore's November 20, 205, arte originated from someone wh ‘wae presont| ‘oF from ‘omeone to whom the infrmatio had been relayed by someone presont ding ‘he mesing. ‘ccorting to Miser Pema Towever, nat rust and caidence in ofclals was cleary put into (doreputa Ninieler Brison, on the other hand, slated: "On the twentieth [November 2 2015] when that aril (Cudiore's CBC nows are ted Davie [htonm supply ship $700M deal delayed by Liveals] came ou it made our jobs Tmuch more dealt” Ministor zon further ctatod he cannot remember a breach Cf cabinet confidence euch as this [feteng to the information published in Cudmore's Noveribor 20, 2015, nen arte, and the unauthorized disclosure of Gassted infammation denied mambers of the Commities the opportunity #2 thought eb their jobs. Addionaly, Minster Brison said: “It fhe teak of Classified inermafion) impacted ur abilty to do our work. We have cabinet ‘confidence [2] that we can speak openly and honestly with each other, and ‘Giscuss Infomation and that wae blown aut ofthe water by this [leak of classified Information”, Miniter BHeon went on to say: "The rendering ofthis (caesied Information! into the public domain di sn cl lott iit our abity to relly do ined sy aig oo rg spt ite Paneer cnn 8 aaa an nk mnizn on fer 2015, ad corowing i cots Clare’ Hove 20, 215 neo eat sent an ioe of Miter Messner, sedated by et Rin feds ena oronar 32 238. Page 9 £97wnat we'd (the Commitee intended to do, and that is more due diligence on ths. Excrango of emails betweon Norman and Frasor 45: {The following grounds wil itustrate the relationship between Spencer Fraser A Vice Ada! Mork Norman, and demonstrate why I belle Fraser received Infomation subject fo cabinet confidence trom Norman. These grounds wil also ‘demonstrate why | belove data that wil provi evidence into the comission of the offences under investigation exists In Norman's (Pad, cotular phone and computer} 48. [Whon {rele fo the onat ace | tte his emal adsoss fo bo used by ViceAdmwral Mar A. Ravan as We name and file would suggest in the emai ariess. As mentoned in paragraph 20, email Content ascoccted (IMEI wos seized from Shaw Cable Systems GP meting a contact car fer Mork Norman which fisted is phone number a ‘Aesordeg to an October 28, 2010, record in the Ottawa Pole ‘Ber recor’ management stom. this same phone number is Hnked to Mark A Merman (orn EE) resicing et 825 Adoncife Drive, Otlawa, Ontaria® 47,0n October 8, 2015, at 9:13 pm, Fraser, using his email eddress tient an ema to Norman's eral address wh the subject: “Status otis ema Fraser Tine! fo Noman various fuewatons and challnges Ne was having along wh Tous cooie associated to the AOR contact. The folowing maring, Noman Tonlod to Frser and wots: “Aok. hang in there. Feedback at my end is near: Cancistenly supportive. lots of hurdles but nobody is throwing stones oF Tony to wal avroy..sfoady as she goes. Arrival of ship fsa great, visible ‘Hep forwara pickup inthe media fs posifive..my sense is that we continue hyamed wy eng mai rc Miri’, onde yt. needs by eng Ona Pole Seer re co age of97{fo be on the curve...n0 doubt painful and unnecessarily dificult, but tracking in the right alrection.™ 48, [Since the new government wasn't voted-in uni October 19, 2015, | beleve that "Norman and Fraser had bon communicating since baforo tho irroduton of the now governmeit | also befiove that due f0 the content of the email sont by Noman to Fraser on October 8, 2016, Norman was providing Fraser wih tupdefes rlsed to the prevaing sentiments within govorament regarding the ‘AOR contact} 49,0n October 22. 2015, at 9:30 am, Fraser, using his mall adress sent an oma 12 Norman's email address once again wh the subject “Status” nhs femal Fraser hole "Mark, -Good news fe that the contract terms and conditions 22 well as pricing are agreed. We are told LOY expansion is being staffed or ealy next week ~Bad new Is that there are more delays Sent from my iPhone, Less han two hours iter, Noman rete: ‘Agree with your assozemont. 1 think hinge ae prety solkd and IAOR rs unquestionably a priority in forms ‘of nearterms agenda. Good news is that te nancial rsk'o tho crown as in essence bee” capped. that there 1s file risk of the contract not belng supportedisigned...the {esuo will be what potential baggage there might be with a decision f0 90 forward. Any further delays and everyane agrees it stats 10 look less “appealing... need to avold a selffulliling “told you so” scenario. Mt Sent from my Pad" 50.1 ative thatonce again, Norman was sharing with Fraser information relating io the governments concerns and issues regaraing tho AOR contact. Norman provided Fraser wih intricate deta ralated to issues and concerns surounding {Veal is vn the east btieen aera Noman om tebe 8 05, 98m res sthredon nb 2°02, 208 The cere altace n pnd“ os omsin*sOtsn, 2 era ny rexng th eas sn tween Fase a Neon fom taba 22,205, 8 ato Ceter 22 20, me 13 so Tse svat re ek om Shaw Cae Ses GP. pss to the produ retort ona 26 927, 208 The eal rea i epesi Paget of 7the AOR contract within government. By doing s0, Norman gave Fraser and Chanter Davie PRI ar insight on how to tigate potential cancems expressed by the government. This exchange of emails also demonstrates that tho lationship bewean Norman and Fraser was more than simply professional "The way in which Fraser bogan hie email fo the than Commander ofthe RON, "Mar," and the way in wich Norman signed his reply *M, demonstrates an ‘established and personal relationship rater than a rank-riented professional tne. The sknaure ending Normen’s email demonstrates that was Sent rom Wis ‘Pad ‘51.On November 92015, at 6:23 am, Norman, using hie email adkreos sent an emai to Fraser's omall adcress wih tie subject “Vimy. In this emall Norman wrote: “Great fo see you ou the other night. Werit looking for afterward ~ wanted to chat ref RESOLVE, Paseed the message fo Al G. Wit advice. Holly would lke fo sond you an (Email refs fundraiser she's Involved with next month ~ that of with you? Mare ‘52. beliove this email father demonstrates the extent of the relationship botwoon Norman and Fraser. Thay not any commanicatod through emai but also met or ‘attemped to meetin person. Also, Nonmsn advised Fraser that Hoty, whom 1 bafiove, fr the reasons eat out af footnote 25, to be Mark Norman's daughter, would be geting in contact with him regarding a fundraiser she's invotved with, reiniarcing the personal relationship betweon Norman and Fraser! behove when Norman wrote Passed the message to AIG." hei referring to Alain Garcoad, an ompoyeo of Project ResoWve Ine. Once again, Norman advised Fraser on the ‘Salus of tho Memorandum to Cabinet (MC), and stated he would advise him ‘once the naw ister of National Dofence (MND) received i 153.0n November 10, 2015, at 951 am, Norman using his email address sen an emal to Frasers email address ‘with the subject: "See articlo In GEM This ofall Norman woe: "Did you guys fssue/stimulate regarding Regina See moral Dee fon Holy Noon ag he ena i TT 1 Cer canny dn ynrarsput eta usec owison ese hey sending el se rom Homan ean vee 215, 2 623 a Tens Tete ram sno ce Stem GP. psu oth reducton oder outer on My 2 3427, 206. The age 20897that story about Humanitarian assistance & RESOLVE? Mf, One minute later, Fraser replied. "Kept getting aggressive questions from media. Decided to put outa media refoase Hos it backfired? S Sent from my iPhone". At 10:08 Finn the same day, Noman answered: ‘Nope.its perfect, but eis will see ii as 4 ploy.-its was appropriate and accurate..keeps the heat on. ust ‘don't overplay your hare" 654. bolove the rews arte to which Norman refers is the Newswire artisle dates November 9, 2015, and tod "ResoWve-Class AOR'* / believe this emai ‘domansrafes hat Norman, in response fo 4 modo erile generated by the ‘Chanter Davie 7 PRI team, instructed Fraser on the appropriate amount of pressure 10 to oppled using the media. | believe Fraser, in response to Norman's inquy, was seeking input from Norman, who apposred to be giving ‘advice © Fraser} 56.0n November 16, 2015, st 3:96 pm, Fraser, using his email address Pvvect an email” to Norma's email address withthe subject: “Some minor nonsense... Iii eral Paser wrole about vaious people belleving that Project Resolve Is ina precaious poston, and there are chances that the AOR contact won't be ‘approved bythe new government. Approximately two haut later, Norman replied that "CEN are rapidly becoming irelevant fo the Ottawa batiespace" and “Everything Ym hearing ts that that although there afl is risk (most capacity and schedule ~ both of which folks like fo overstate) there are no ‘glaring alarms or red lights. fire y no fonger have PeP ete, so al goes fo everyone...makes scheduling and choreography bit of challenge. Unless something has chenged, they will be ‘surprised...don’t want to sound foo confident, but! think we are ok." “Tearnd'r y ennte als snt wn Frss a Homan om Never 30, 205, at 953 am ceeete tea noe am Thee erate wee sabe from St cable Stems OF pursuant othe +n om tiie Reh Gas OR” cated at den esa iat snd ard fs tne OH aed hist en them sont ese rus eran om Novrer 35,20, at 36 aan resis at f20 pm These eras ware eed fom Sha Cable Stes GP. pra the seve rds eter on i 26 na, 208 Te ama oe tached pend of bs onan feo, Page 28 of 9756, allve the shove noted CFN refers fo CEN Consuitants Inc, a consultancy frm specializing in defence and secusty issues, and PEP refers tothe Prories and Planning Secretariat™. | bolove Fraser sent this email fo Norman to Keep him abreast of what Fraser is hearing regarding the AOR projec, and fo sock ‘reassurance fom Norman 10 ensure the contract remsine on track Norman ‘dressed Frasers concerns i doa and advised itn tat infomation that was. not publ: and should not have bean ‘ssomnated. Norman concludes his email by writing “but J think wo are ok” 1 olive tho use of Wwe" demenstrates that Norman considared himself in-line with Fraser's plans of esd outcomes] 57.On November 15, 2016, at 6:42 pm, Fraser, using his email address sent an email to John Schmidt and Alex \Viceteld (CEO of inocea, parent company of Chanter Davi) withthe subject “Fram our friend. tn his eal, Frasor provided an update to Vieefeld and ‘Schmit: CAN are new irefevant inthe ‘Ottawa Batlaspace’ Not to worry ‘about thelr eflorts fo support SS. 2. Our fiend says the support is cold. Only ‘schedule and capacity’ seem to concern folks. 3 ‘nly challenge our fiend soes is geting a full PAP as the ‘new PH gallivants around intomationaly! S 58. boleve SS refers fo Seaspan, a shisbuiling company in Buiish Columbia. As vil be explained bolow, a frieing with the Commitee chait and vco-chalt ‘occured on November 17, 2015, Pri to this briefing, no concems existed relating to a patent delay, and support was solid as was slated by “our fond in Fraser's above menioncd email. bolave when Fraser references “our Wend’, he en fact rofering to Mark Norman] 58, [This (s an example of Frasor reposting fo others informstion he had received {hom Norman. Specie pases and ferminalogy sent by Norman to Fraser was used by Fraser In his email fo Schmidt and Vicefiold, Whan comparing the Content and tsig of both November 45, 2015, emai, it i evident tha, even if ‘he language used not ira, the information in Fraser's email to Schmidt res ude ernst "Hare ed ts a sn rom er oS and Vl on Novenkr 38, 285 8 62 pm, ‘is ema ws sed ye eon ofa snc want Caner Dao My 205 Te Pige 240197and Vicefield originated from Norman, whose poston within goverment bas allowed hin access (0 information regarding th status of the Memorandum to Cabinet. along with concerns and opinions of ofcials involved with tie AOR project The manner in which Norman raceived this Information Is unkown at this tine.) ©, "These PCO offeais were Sioohan Harty, Dresor of ‘Operations, Ecanomle 8 Regional Development Policy (RDP) PCO, lan Bumey, ‘Assistant Secrtary 10 the Cabinet, ERDP PCO end Les Linklater, Deputy Secretary toe Cabinet Operations, PCO, 162.0n November 18, 2018, at 412 pm, Jon Mack, then Director General of Procurement Servcas atthe Department of National Defence sent an eral to ‘Vicodmiral Mark Norn, along with various other oficial n this ermal, Mack provided an update on 2 teleconference i which he partbated a few houre cater. ened hey ee tesa a rom ko Honan on November 18, 20, at 12 pis emt wasnddedin th PDpacage Te rl each feeds he Wetman et Page 5 0f9764.0n November 18, 2015, at 6:49. pm, Fraser, using Wis ema address sent an email witout fext in the body to Norman's emai ‘cross ‘withthe subject: “Wl eall ce soir. ‘Almost tee tours later, Norman replied “Just back from a visit to focal ‘NavRes unit—in Saint John NB. M Sent from my Pact. 65, [Due tothe praia inthe tine botween Mack's November 18 email at 4:12pm In which he brefe Norman onthe Committee's poston onthe AOR, and Fraser's [November 18 email at 6:49 pm in which Fraser slated he would call Norman, 1 believe Norman had attempted to contact Fraser, elter though an aerate ‘emai addres or phone messagfeal fo advise hin ofthe update Norman had received fom Vac foss than three hours sare. believe Norman's reply £0 Fraser was fo advise him that he wae availble for tho cal. As wll be highlighted Jn tho paregraph bolow, Frasor forwarded infarmation I ballovehe had recived fom Norman regarding tbe Commitee’ postion on the AOR. Therefore! bolove Fraser and Nirman were in contact at somo polnt between the evening of Movember 18, 2018, and the moming of November 19, 2076, 0 discuss the Update Norman had received from Mack} 66, The next maming, on Nevomnber 19, 2015, at 9:02 am, Fraser, using his ‘emai address, sent an emal to Viosield and Senmigt in whieh Fraser sent few ines contained yithin quotation marks. The subject ofthe ell was “From Mark” and the body fead:*“..could be bad or ‘could bo helpful Most postive interpretation ‘could bo govt Just unsure and asking questions; cynical view could be folks manjpulting nov govt to try and kill it, Not sure what truth Is. James (Cudmore from CBC has rumours from inside somewhore, so this could get Interesting... * 67. [The content ofthe email demonstrates that despite boing protected by cabinet ‘confidence, Narman shared information subjct fo cabinet confidence, ‘with Fraser. 1 ere i by aig eal nan Fzer an Nera a Nova 1, 205, 4 pmo twembe i205, at 935 fn These eas yar ed fm Shaw Cable Spars GP. puro othe rection er uta on hy 26 997,206 Theale sacha oped" ois iemiion 1, at 022, ‘Much oped" fh frmation oO Page 26 of 97belive the subjtct ine Fram Mark” is usod by Fraser to demonsirato to Vcefotd ‘and Sehmiat tal the quote in the body of the email is @ quote tom Mark ‘Norman. I bokore Fraser used the quotation marks in his ermal to demonstrate the tort be rocsived was forwarded verbatim Tat Cuimore fed rumors “rom inside somewhere’, ar who the sources of Cudmoro's rurars were] oa, (69, On the same afternoon | Frans, using | wall adores sont Sr ema to Vewold with the subject "From our frlene™ In his emit. Frasor wrote: ean tel (you that Iviig did sch the nose Into this and sent.a etter to mult ministers (ine! Brison) a couple of days ago that no doubt contibuted to ‘the problem. .1% “named sb tong oa a recor of Bc’ ier conduct by Cp shame anc > ene sty ening cna ofr prone AO ng ta wr vee, are hb etn the vg hig lar ted Hower 7,205, Sol Soe reba ls rren Regen aga arta PED psa. Th ere ‘ated nope’ is nlermaon On earned by eg te oma et Facer nile Hebe 8,205 a 43 ph at vealed dry the est os src arr ter Don 0 3, 286 The em aoe in Page 27 09771.0n November 19, at approximately 7:00 pm, Deputy Minister Da Pont and ‘Associate Depty Minister Liddy called Vicefod to eound out te company. This fat had to be pre-approved by senior offcils at PCO, ard had for intent fo infor Veefile that “Ministers were new and therefore had legate concerns, ‘wanted more info to make a decision and whether the company could extend & “couple of maths! 1 accommodate’. 72. [At the fime when Deputy Minister Da Pont and Associato Depuly Minister Lida ‘called Vieefilé to inform him of tho ministers’ concerns, Vioefeld had abwody ‘been madd avare ofthis information almost three hours earfer. According fo the Information contained inthe PCO package, soniar PCO offal had fo approve the above mertoned phone eal fo ensue no information subject to cabinet confidence would be given to Viesfield and Chantior Davie, but rather a broad utine ofthe Government’ postion. Due 2 information provided by Neaman to Fraser, the process in place fo advise nvohad partes on he oulcame of eabinet comes meetings ‘without volathg cabinet confidence was complotely undermined and rendered useless) 78.0n_November_20, at _ 4:50 am, Norman, using his email aderess |, sent an erst to Fraser's email address Twi ihe subject: “Classic day’ In this email Norman wrote “Cudmore fs letter from Irving which shows they have been Intertering. Proponents will argue that it shows there was available ‘cued yong Oe Coney af et onesie PO pha ‘utente th se ie Sling ter ated November 17,25, ied RS ace Sccon Mec ured tf Rtv 2 en Ces, whe seated I A" of the Inomstanto in age 28 0897‘competition (that was never fully leveraged by last government..kind of fold you so sort of approach..."bad Idea from tho start" Equally however It helps makes the case that this has not realy been about the capability and more about the politics. Could go either way... Irving could trace letter to ime..aeshole..they couldn't just leave It alone. Graody and set-serving. M Sent from my Pad’. 7A. [irl | belovs thie email demonstrates that Norman was aware that Cudmore ‘had the ving biter prior to Cucrmore's November 20, 2016, CBC news ato. ‘As wil bo bighighted below, Cudmore published an exclusive story related fo ‘Davi's interim supply ship contract. Although 1 do not know why a this tin, 1 bafiove Norman concluded living could trace Cudimore's possession of the fetter referenced in Cucmare'sartcle to him, which would put him in 2 precarious poston. | futher belave tha, according fo Norman, Cucmore having 2 copy oF the Irving letter would alow Cudmore fo influence the public perception thet the ‘government's gecision to delay to award the contact to Davie was polical, a8 posed to rasing concerns of capably. At this time, I am unaware how CCudmaro cameo possess the Invng eter} 75. As stated in he "Background o and the Auxiiany Oler Replenishment contrac! section, on November 20,2015, at 5:34 am, approximately fry five minutes after Norman's ‘email to Frasey, James Cudmore published an artcle on the CBC webste tied “Davie Interim supply ship $700M deal delayed by Liberals. The article states “The new Liberal government is delaying approval ofa deal to carver civian cargo ship into a badly needed miliary supply vessel, loading to concems the plan wil soon be sculled and the navy wil be left unable to propery defend Canada or depay ts free abroad” and “Liberal ministers were wamed Thursday that without guaranteed access to a eupply ship, Canada will have ‘dramatically timinished capabliies to defend Canada”. ‘Cucmore asp sole: There are leo allegations from deren hghevel sources in those same comers that Ining Shipbulding Inc. a longline competitor of Davie, meddle in tho decision by sending leer to several cabinet ministers Sasser ho Cae sane gua to he ration ers autor on 25 7,206 Thecnalisatchodn ores of is nfomation Ob age29 of 7‘bout the desl an event hatin the words of one dafence sours tipped over the apple cart 76. [Cudmore's arte, in alton fo containing information that was protected by ‘cabinet conics | ‘appears caleulated to epply pressure on the government. Dua fo Norman's ema! to Frassr at 4:50 am an November 20, 2015, in which he advised Fraser of Gusmore's possession ofthe Ivng fetter, and Cudmore's news aie pubished ‘at 5:34 am the same day in which he refers (0 te Irving fete, 1 boteve that "Norman was ekher provided with an advanced copy af Cudmare's arte prior to puis, or advised of Cudmore's intent to speak about itis unknown at this time how Cuore ‘came fo possess the mfermaton publahed in his article] 77.On_Noverbe-_20, at 10:53 am, Fraser, using hie email address sent an email to Noman at his email addese Jn Fraser's email, ha stated that theo was a meeing planned wilh Qusdecs Premier, ding which the intended message wil be “that the yard wil be closed, 1200 tay offs before xmas, we will suo the Crown... No st... Norman's reply to Fraser, sent the same day at 5:21 pm, ‘was: “Adk. 1S apologized to me tod... played nice but knew they were [BS'ing mo..it= porsonal and vindictive. Ack your plan. Makes sense, ‘you've been through this before [..] BTW, PMO-PCO having kittens over ‘references (0 explicit cabinet discussions in Cusdmore article. Launching an investigation..UFB. They'l all be distracted from the actual eapability gap 2s they execu a which hunt for who quoted who...8i.. M Sent from my ira 78. below that in his emal, Fraser shared with Norman his plan to pressure ‘government by advising Québec’s Premier the consequences and repercussions Of Davie not teing awerded the contract by the LOFs November 30, 2016, eodtne. In Nerman's reply 10 Fraser, Norman fsty acknowledged Fraser's plan. When Narman advises Frasor that ISI apologized fo hin, 1 believe 1S1 "Thame i by vedng Onmords noes ake ad “Oe nr spl hp $90 del dled by er ted Hovonber 2, 2515, posed onion nena aber 10038 Tear estan Append of his hdomatin te hin “teams is by easing ts es et betwen Fea rman am Nove 2, 205, 1958 ato vember 20,2015, ot 521 on. Thess amar wre sed or Saw Cale Stone GP. pono be ‘roion eter atharzden hy 25nd 27, 208 Teena ae ace open Wohnen Page 30 of 97apologized for faving sent the let to the Ministers, which created a dele i the «preva process and put the Chanter Davo contact a sk, Norman procended {fo inform Fraser thatthe Prime Minister's fice are the Privy Counel Office aro Jaunching an iavostigation ito the fact that expt cabinet discussions ore ‘referenced in Cadmore’s arte} 72. 0n November 22, 2015, at 8:56 am, Fraser sont an email to Vicofekd and ‘Schmidt which contained the subject Header “From our fiend. Fraser wot: “Nite commentre SS “So Peter McKay told Brison to get his head out of his 45s..n0t sure It helped, but af loast he did it. Am fold Seespan are golng coffer their two cents as wel so this Is going to get even more interesting, Fucking ridicubus..."°® 80.1 betove the quotation marks aro used to demanstate tho exact woeds sent fo ‘Fraser by Norman. Fraser began his ama ith "Nite comment | botove Fraser wrote this fo adrise Viefeld and Schmitt that he recelvad this information lato ‘on November 21, 2016. This reinforces that communication between Fraser and ‘Norman often tates place oust regular work hours.) ‘1. On November 23,2016, a naws acl, publshed on the Nova Scotia-bated The Chronicle Horak’ website, ted “Uso tankers to fue ships at sea, expert saya” ‘was released. i this afte, Ken Hansen, former navy officer and mattis ‘secunty analyst at Oslhousie University, Is quoted sting that Chanter Davia! PRI's interim supply ship is ‘needlessly complex. expensive and. tmo- Consuming’ Also i tis artic, Hanon offae a cheaper and quicker allematve to Astorb’s conversion. 82, On November 23, 2016, at &:41 pm, Fraser sent an emall to Vicefild and ‘Schmidt with the subject “Our fiend haz made an ask’. The omit stated: “Ne wants us to discredit Hansen and he will go after the Knight of No re TKS. Lae evo hy rent mal sot om fae Vet Shmi n Horie 2,205 08:36 0 ‘ser wa see ng te cone ath rat Chater Coon ey 1,26 Teas Mase in Appoint Oa, “es Wis eg te cle wit by Aden Gn ede tera ful sie steps? fect‘ tiebechnkstl fons 1239224 thr tlio aaa Te Vesna rege allt Fam eet esl Sit on November, 2085, 4 gm. ‘sc wr eld ing ncn sare wat Chat Oa ony He Te ss tached in ope" ration a Paget of 7163.1 bateve this ome was in drect response fo the news article published on The Chronicle Herat's website earor on November 23, 2015. } belive the ermal Indleated that Norman orchestrated a plan to infuence putt opinion and for Davie to regain favoetve ground withthe decision-makers within te governmont ‘and ultimately Infvence the decision fakon by ministers. 1 belove Norman equestod that Fraser disredit Hansen because, as a government official, Be ‘Could not publidy vseredt Hansen hime. Norman assumed an active robe Croumnvanting te eslablhed procedures in place fr decsln-makers fo follow: “he meaning of te Koight of Nore THOS” unknown at his time] 4. On November 23, 2015, a 9:08 pm, Fraser sent an emalto the various lobbylets “porting withthe Chanter Davo / PRI team, afong wit Vieofeld and Schmidt “uth the subject “Letter from Seaspan". Fraser urols: “Team, J have just Jearned a few momonts ago that SS has submitted a fetter fodey to the ‘Same 4 ministors as ving. am {old itis basically the same messaging and 2 tow pages of glossies. {| Here is what I am thinking we do: alert Cudmore andlpolities, they do follow up pleces. (..1"* 05.11 boieve Frasor followed trough with his plan fo alert Cudmore tothe situation, ‘ince Cudmore later published an articio on the CBC website ted “Soagpan joins fight against $700M Davie supply ship deal” on November 28, 2045. The ‘article will be highlighted baton 186.0n November 23, 2015, at 908 pm, Fraser sont an email to Vicfitd and ‘Schmidt with the stbject ‘From our friend”. The emal read: * “Fucking SeaSpan jst sont a fetfer to the same folks as Irving (they co'd me so J cart do anyhing with it.take the Irviag text..add a 1 page glossy and tore you have it. UFB." 87. [1 boleve, do fo the content ofthe Noveinber 23, 2019, 08 pm email above, Fraser lowed ofthe Seaspan letter fom Norman} 10. betove thal Fraser, once again, uses quolatian marks to report a cract quote from “our tex, Mark Norman. As described earfior, on November 22, 2016, Norman had veperted that Soaspan wae going fo show an interest in the AOR: “Tie sy vn th oats fn et ay ered is reading ems rt i fv Ves oS on Hoe 2, 205 a 38 aoc en cd darn ecu a wseach ware 2 Croton May 33,206 The ewe ‘nici pen -W" of i nerton to OA Page 32 0 97procurement. I Sellove Norman wrote that he couldnt Jeak the fete to Fraser because as seen inthe next parearaph, Norman was the only non-minser 10 whom the ltterwas addressed, and consoquenty i could bo traced back to hin 1 beleve the dcrepancy in the times of the above mentioned emalls can be explained in the folowing manner. Inthe emai sent at 8:03 pm on November 2, 20186, Fraser advised his team that he Just leamed a few moments ago ofthe ‘Seaspan leer. bolove Norman advised Frasor of the letter shortly prior fo the 9203 pm email, ter which Fraser sent hie ama o tie the team. | boiove tho five mirutos batwoen the 9:03 pm ems and the 8:08 pm emall was usad by Fraser to type out or transfor the verbatim message ho had rovelved from "Norman prior 9:08 pm on November 23, 2018.) £0. On November 24, 2015, at 8:04 am, Fraser recalved an emai containing a copy of the Seaspan leter, which was addressed to Minister Hayjt Sajan and 2d fo Minster Judy Foote, Minster Naweop Bains, Minister Scott Brison and Viee-Adnirel Mark Nomen. The letter, signed by Jonatian Wiworth, CEO of ‘Seaspan ULC and dated November 2, 2015, highlights Seaspar'sabilyf uli the AOR contact at a significantly lower cost than the Davie option, and f= requesting to share tha detals of ther proposal with Minster Sajan and his oficial" 90. 1 belovs the fehion in which the Soaspan fttor was sent irom a high ranking ‘naval offcer, Richard Jean, to an employee of PRI, Alain Garceau, and “subsoquenty fo Frasor is indicative of Norman's ettemot fo stance hiss rom the letter, all the while ensuring Fraser receives it. | further bolove this demonstrates Norman's bia forthe PRI/ Chanter Davie project] 91.0n_Novoniber 24, 2016, at 6:14 pm, Fraser, using his email address ‘sont _an_emal to Norman st his omall address In his email, Fraser vrata: “Lots of mecta eer ood he era rom anther Pl aloes, Gorcet The i bjt was "a Season leer PS and en Rac reat andor ced Par th ter mena Ath Gir elo sor wa stocked Semper to Mine Seon. ga Gwen’ eal was frat rater eal he ecitid Wom Retard i, 9 clan the ACH wong Te ema es seroma warty mies ere cot Ne Sup et ced by {angele foe Gens oan oa Noa 242015 a 808 2m iol need ng the ‘ess eae wre st hater Dave oe May 1,206. The en tad pan" xed brennan Sopa ter tna stchenar ac en wFsr on Nove, M6 Temas atacuals Apna of bi oman oan Page 33 of 97attention over next 24 hours... The Wolf told us that ISI {ook the MIND into a ‘conference rosin during a tour where Brison wes on the phone and they ‘Spoke extonsively about iAOR. This story is going to likely hit the pepers.. Wit not push to have it released if not true or you were there. Wolf has also told us that thare fs an IS! management team in town trying a “disruption” ‘move [..}. On the same dey, at 845 pm, Norman replied to Fraser wih the following message: “Can confirm KM, SJ, and RI (3 of tho 4 horsemen of the ‘apocalypse) are in fown for a monthly senior mgmnt migs; no doubt they wll use that opportunity fo push thelr agenda. {see thom tomorrow. As for the “telephone” story below, | have no doa. There was no obvious mement ‘on Fri when IIND could have boon taken aside for such a thing ~! was with ‘ims from startto finish. (1 92, [The idenly of tho person refered to as “The Wolf” is unknown af this tne. 1 believe the “harsemen of the apocalypse" referred fo above are th following ‘executives of ving Shiobullalng: Kevin McCoy (Present), Scott Jamieson (Vice President Programs), Rese Langley (Vico Chairman) and Jamas irving (Ct (CEO), n his email, Fraser sted that he wi not push to get an arte pushed FF Norman was preseet during the above mentioned meeting between Minstor ‘Sajen and Mister Bison. I bebave by slang this, racer was demonstrating Norman that Norman's ideally 02 Fraser's source of information is to be protscted. In Norman's reply to Fraser, Norman confined the information Togarding the wving management tear boing in town for @ senior management ‘meeting. Norman also advised Frasar that he was wilh Miniter Sayan on Friday, | believe to be November 20, 2015, the frst day of the Hatfax Intemational Securly Forur, attended by both Minister Sajan and Norman.) 198.0n November 25, 2015, at 401 pm, Fraser, using his email adéross sent. on emia to Nonman at his email addcess In hi ema, Fraser wrote: “Here fs the slam also contained analtachment ted *NT-2505-15- ‘against Ken #[...-™e {2has at E45 pe, Thee ema were sted from Shae Cale Systems GP purse 19 the (hotuton rr stor on dy 2a, 316-The eas ae tach in Aopen os araeion sth pps the 2 Hac Sct Fon nb funda ilar foc Page 34 097LLEOOSA-E-INFO} pd, A ttle over half an hour later, Noman replied “LMFAO! IM Sent trom any iPhone’ * 94. J bofeve Fraser's email fo Norman with tho attached POF document to bo tho response 10 Narman's November 23, 2018, email to Fraser requesting to (lscrdit Ken Hanson, Tho aitached POF however hss not been located within the exhibits soied to date. | bellove that sue 10 Norman's reply of Laugh My Fucking Ass Cf, abtreviated 2s "LMFAO, he is satisfied with the contont provided by Fraser {also bofleve these emails demonstrate that Fraser reported fo Norman, and provided Merman with rosuits subsequent fo his arbor “ak The signature ending Nozman's ema demonstrates that the email was sent from is Phone.) 95. Aso on November 25, 2015, at 7:44 pm, Fraser, using his email address Sent an omall 19 Norman’ at his email address In is emai, Fraser wroto: “See Cudmore article fonight Jeox do over approciata my staff college training. CODA Toop, Commanders estimate... Shock and awe babyll Aoproximataly fifteen minutes later, Norman replied: “Yeah, saw it...'s going to draw some really aggressive’ attention. The source of that document will be investigated by the RCMP and anyone associated with him will bo part of their search, This i serious shit. M Sent from my iPad. 96, bellove the arto refered to by Fraser was an artile Cuximore putished on the CBC webste ted “Shipbuilding strategy needs work to get bafooning costs tnder contol, ministre tots" on November 25, 2015. In his arte, Cusimore ‘sourced somo of his information tom “brofing melerals prepared for some Liberal ministers’, Cudore wrote: “The briefing material, obtained by CBC "News, was presented 0 Sajan and Foote earlier this. month. It was dated November 2015 and was classlied secret" | belive Norman's reply ddemonsiatod hat he knew the Information and the material sourced by Cuore Was protected by cabinet conidenoa and should not have ended up in @ news “Tanna sy coding ea st been Fra arma os Homa 28, 205, 8 8 tuvanber 2,215, 489 gn hen aise wre sed om shaw Cal Stans GP. paver 10 the frotton ero nutaied on My 26 and 27, 216 The ems oe mache in open AA” of hs + ened hsb veingthe ie writen by me Core ed Sing tty nds werk 8 ato ast aaron ims oe ated iifinnwcalnendoic ena: urna 333304 The retain gpa" of nlonnatonts Cse. Page 8 0697ace, and tat serous repercussions can ensue, such as an ROMP jtwestigation.] 97. On Janwary 12,2016, David Puglose of the Ottawa Citizen published an aricte lted “CBC delence reporter joins Defence Minister's office". In his art, Pugtose wrote that James Cudmore slated his fst doy as a seni policy ‘advo for Defence Minstr Sain. "” 98, On January 20 2046, Cpl. Duhaime and Cpl. Bertrand conducted an interview with Motssa Burko, Analyst at the Forcign and Defence Policy Secretariat at PCO. During thé inteniow, Burke stated: “know thatthe Navy has contacts with Davi. There was a referance in negotiations to Spencer, who isthe head of Project Resolve which is Davi, playing golf wit Admiral Norman’ 99, On March 30,2016, Fraser, using his email address sent an emal to Noman at his email address in hie ‘email withthe subject ‘Lisa Campbell Fraser role: "Mark, Heard froma very _good source that Lisa wouid love fo have a day at sea on the West Coast (na frigate (does not want her fog humped on the East Coast). She wants fo see a ship wn action. Not Modding, but bringing to your attention as It ‘may build a bridgetgoodwill. Sponce"® 4100.1 boliave the contnt ofthis mail not necessonly relevant other than to once ‘again domenstito, due to the informal address and solution of Mark and ‘Spence, the relationship botween Norman and Fraser extends beyond business ‘The March 20, 2016, date tbo demonstrates that Fraser and Norman continue to bo in communietion wit each other beyond the AOR contract being awarded to Davie/ PRI 101. On May 11, 2916, while search warrants were simuilancously being executed ‘at Hil+Knowiton Strategies Canada and Chartier Davie Canada Inc, Spencer Fraser was intsrdewed by Cpl. Duhaime and myself. During this inlariow, Fraser never mentonod he received information from Norman, but rather that t = eed yen th orice wtb ade Page lcd tupdlaanaiiearoniten lana dee een fete isc “Vfeenes hey lining an 2h recreate at ste oy erat sO conducted J Busine nH bth enero he res hy tng eal cat on rt Noman March 2,201 324m Tema wt sszstom thee ane tot acon Ear wiot etd on Movers, 206 The smalls stated Append“ of horn to Oban Page 36 097come th hog Poe Tea, cing of Dpuy Mit, Asta tape in 2 fanoste Dept nin Mypromatl wo fare eer Yesuon ol see’ irdon, Tos, angel ares sts na we! txt the bay fo Nomar eal = feeble ts porate crear a ee utr, Non ee a oe 2000 ** 102. botov bo prpoee of Faas ena fo Noman and phar ot ely ‘dlwod wa thorn othe RCMP tga undovay Fas wat Fade" avare fe ssurch nora happen a Chorfer Davi ard wae Treentd wit vrous spat dosnt hg his eno, Aeorng tr itt search sonauced pentared in paraaph 3 08 wot os Be Fenatoncstaned nthe Gora Pole Sie mononed i page 48, te phono number provided to Fraser to cal, LINE is associoted 10 Atoart doral seas bested a 825 haat pme lor, Ona, Thor Tov th ober pone nunbe| in rovers contac FaeNonen fos cla hone uber] 108. fn summary, | believe that Norman, contrary to his obigaton as an oficial of the Governmort of Canada, used his postion as the Viee-Admial ofthe Royal CCanaolan Navy to wilfuly provide, an an angoing basis, information subject to Cabinet confidence to Fraser in an efor fo circumvent the estabfshed processes {and procedures put in place by the government to ensure the secrecy and ‘confdentalty 2 cabinet discussions. I bofeve Norman did this fo influence {ecison-makere within government fo adopt his preferred outcome. To tls en [Norman not ony provided Frasor with continuous updates of information subject to cabinet cankdence regarding developments In the AOR file, bu also directed Fraser pubis dlserelt an industry expert and advised Fraser onthe amount of pressure fo apply toward government through the media] "rene yea ew et betwen rt Norman om Moy 3, 2016, 63 pnt MoV, dose 723 pm Tae ane wr eed on Sh Cable Sens GP putt he pedcton orders Petron tion 3 205 The oratarestacedin Appni "2" eis ration to Oa ages ofLocation to be searched and itoms being sought 404, On November 1, 2016, at 6:07 am, while conducting physical survetance, | ‘observed the garage door of the garage altached to 825 Adencifle Drive, Ottawa, Ona, open. observed an unideatifed male wearing white pants ent the divers so of a dark colored BMW sedan, Moments later, the vehicle ‘departed the residence. Te licence plate ofthe vehicle was not observed. 105.0n the same day, | resived fom Sg. D. Beaudoin information associated to ark Norman's diver’ licence. According to information In the database frked to the Ministry of Transportation of Ontario, on November 16, 2016, the address listed on Mark torman’s deve’ cence Is 825 Adenclife Dive, Orleans. Various vehicles are aso inked to Norman's ctver' licence including a black 2012 BAW 320 serios and a ever 2014 Kla Sportage 106. Also on Noveniber 18, 2016, Sat.D. Beaudoin provided me witha land reisty ‘document for Geowarehouse" dated November 16, 2018. The document Identifies that Mark Norman and Bevery Norman purchased 825 Adenclife Drive, Ottawa, KAA 3E2 in 2010 and aro curenty listed at partes to the property 4107. On Noverbe" 17, 2016, at 7:22 am, while conducting physical surveilance, | cbserved the garage door of tho garage altached to 825 Adoni Drive, Ottawa, Ontarc, open. | observed a sver Kia Sportage with Ontario cence plato reve'se out of the garage and depart the residence. The driver ofthe vohiole could nat De dened, 108. Also on November 17,2016, Sol.D. Beaudoin proved me wih the infomation lting vehicle Sconce plates associated to Norman's drive's cance, The 2012 BUY Is plated with the prsonalzed Ontario eeneo plate TAREE | baove this to bo a representation of Norman's previous dues as the 34" Commander ofthe Royal Canadian Navy. The 2014 Kia Sportage is plated withthe Ontario Hence plate KIER This lcence plate matchas the one obsorved en tho ver Ki Sportage on November 17,2016, at 7:2 am, 100. As a result ofthe grounds fisted above, along with the query conducted on the ‘wi hlteoaoes.co website which identified that the LETTE oon umber is assecated to M. Norman at 825 Adenekffe Or, Oeans, ON, | baore ‘zara fo Mlnoacounithostclsa aowerehouse is» webs, cenalted propery ‘rman sucha rode Sate haart pean ren ok as wea pteontepr. Page 38.097that Vice-Admil Mark Norman curently resides at 825 Adenctife Drive, Ottawa (Orleans secon, Ontario, ‘110. Fraser's uso of quotation marks when sending infmition subject to cabinet ‘confidence tothe Chanter Davie PRI team, alongwith email subject nes "From cur fend”, sgafes that he is quoting information that ie received verbatim from NNornan. Furthermore, one of these emai included the statement of being CCed (on the Seaspan ltr. Norman was the only nor-instr to wham the ator was addressed. Freser's emall was not sent in the thd pereen, but rather used Norman's tet. owover, aftr reviewing Frasers emails eeiced from Shaw Catto Systoms GP. and fom the exccuton of the general warrant, only & portion of the emails ser: by Fraser contsining information subject ta cabinet confidence can be traced to Norman's email address. NNownans ‘mal address vas not successfully accessed while execuing He general wanant. | beleve there are other communications between Nomen and Fraser that we have not yet discovered ‘hich wore use to convey information subject to cabinet confidence to Fraser. 111, According to "Sent form my [Pad and "Sent trom my APhone" tne often concluding the emails, | believe Norman communicated most often by use of his call phone and iPad, and that communications containing information eubject ‘cabinet confidence ara located within ar accessible fom these dovices. 112,0n November 21, 2016, | spoke to Sgt. Patick Beauchamp, Electronic Suneilance Specials atthe Covert Access and Intercept Team, who advied ‘me that during the execution of the general warrant authorized on Ociober 1 2016, ‘Altough unsuccessful in an attempt to seize ala including eval! authertfcaton details from Norman's devices, i was. dscoveted thatthe website had been accessed using an Apple system utlzing ‘he OSX operating system. This operating system is exclusively used by Macintosh lagtops and deskiop systems, ‘was subsequenly sccessed from 3 {eplop or deskiop, and tnat not al of Norman's cent emails contained the signature "Sent from my Pad” or “Sen fom my iPhone", | beiove Norman also used 8 computer fo communicate information subject to cabinet confdience. | further btleve that thi computers located at Norman's residence. | 118.1 bolleve Norman's electronic commuication devices Induting ad, IPhone ‘and__computor_ contain mails that were sent from. to Fraser which contained information subject {e cabinet conttance age 38 of 974114, Norman communicated vith Fraser, most often outside of nocmal werking hours, using a private, personal email address ‘and did not use his Department of National Defence ema to do 80. Therefore | have reasonatie grounds to balieve thatthe items listed below are in Marc Norman's residence locatad at 625 Adenclife Drive, Ottawa, Ontario, and wil ‘afford evidence of he offences under investigation, The follwing ilems are sought during the execution ofthe search warrant ‘a. Electronic communication devioes uch as Pads, caller phones {Ine Phones), computes andor ofr electronic storage devices. Proposed torms and conditions of data searches 4145.70 ensuro tht any search or seizure autrorzed by the search warrent for ‘Which this appieaton is being cought fe reasonable in the creumstances, the following tems.and conditions are proposed: ‘2. The calblar phones, iPad and other electronic devices wil be searched for data demonetrating that Mark Norman transmitied or communicatod protected information to unauthorized parts induding Spencer Fraser. b. The dat willbe examined and analyzed by members ofthe RCMP trained in the forensic analysis of computer systems andor involved in the investigation of the offences dene inthis order. «. The examination and analysis may require the imaging andlor miroing of ‘the device, computer system and/or computer data to ensure preservation of the ciginal data. The examination and analysis wil further requre the tse of computer forensle analysis software that has the ably to restore fs predousy deleted on the system 4. The Items may be examined and analyzed by persons other than ‘members of the ROMP as necessary to further the investigallon, ©. The examination and analysle of the computer systems, components, ‘lecrone devices and peripheral wil be based on the offenca(s) “dentifed inthis order and vil be limited to the purpose of locating and blaning the folowing pes of data: |. Cata that relates to or pertains to ofonce(s) identified inthis order. Page of 97IL Data that relates to ownership, access and use. |i, Data tat relates to conguration ofthe system. Ihe Any emai, andlor any electronic communication reiting 10 the ‘onauhorizedeclsute of information regarding the interim ‘Aiiary Oler Replnishment project. | When the content of the data cought Ia being reviewed, if someone reasonanly boloves that a solilior is 3 pasty to @ communication, this fommuricaion shal be sealed and no person shall access that ‘conmurication except as authorized bylaw 9. tn accorance with the terms and conditions ofthis order, any peace aifcer, and any person acting under the destin thereat, s autorized to fonductan advanced search using techniques that can render the device ‘or media under examination Inoperable h. To iderity such computer data, all ofthe data stored within any of the lems may be examined and analyzed, regardless af he form in which the datas toro. Proposed validity period of Search Warrant 116. As cal phones and tablets euch ae [Pads are portable electronic devices, 4 ‘belive these devices may be in Norman's possession when he leaves his residonce. Furthermore, due to his poston in goverment, | belleve Norman is omatines required io work out of town, Therefore, to Increase the probabity of successful sizing he electronic devices efaved to contain iformaton subject to cabinet conidence, | ptopose tha he saarch warrant be vali for execution for ‘a period of ore week as spected onthe warant This wil increase the Hkainood ‘Of the search warrant eng executed when Norman is confirmed to be at his Fesidence, located at 625 Adencltfe Drive, Ottawa, Onlaio. Once the search Ceowrant is epecutod, regarlaes at which point within the vality period itis ‘executed, ts execution will be final once the search fs completed. gett of 7‘CONCLUSION 117. Government officals are subject io a duly of loyalty to the goverment. A reach of that duly may be a breach of trust pursuant to section 122 of the ‘Criminal Cod where an offal, Vie-Admiral Mark Norman, in connection vith Fis office, broached the standads expected of him by the nature of his ofa in ‘way which constivies a serious and marked departure fom the standards which {Would be expeded of him and did 9 for purpose oer than the pubic good ** 118. Additonal, tne Securty of Information Act focuses on conduct related to ‘information secure? A breach of this conduct may be = wrongful ‘communication of information offence pursuant to section 4(3Y) ofthe Securty of Information Act where aay person, Norman, having in his possession or toniol any document or information that he has obtained owing his positon a3 ' person who holds office under Her Majesty, communicates the document or information fo any person, ether than @ person to whom he fs authorized to ‘communicate wth. The wrongiul possession of Information i tkewise a viesion Lnder section 4(4)(b) of tha Security ofintermaton Ac. +19. Acoonfing tothe Patiament of Canada webste, the Cabinet is tho execusive of ‘goverment and fs responsibe for the administration of goverment and the tstabishment of Is palicy. Cabinet members coflectively debate and decide how the government ls to proveed with icsues of national importance. Their {felberations end accessory documents to those deliberations sre conden i the Bich dencratctreiton * 120, Based on the information aet out in the above paragraphs, Ihave reasonable ‘nd probable grounds o believe that: ‘a, Vice-Aiiral Mark Norman isa high ranking goverment ofa who has a duty conform to goverment processes and procedures. Norman Was ‘opposed to the delay in the AOR process proposed by cabinet and leaked informetion subject to cabinet confidence in order to echlove the result that the warkod personaly. Norman's acons resulted in a creumventon of the stabthed processes and procedures in place to ensure confidence In = coment can Bosaner, |] £3 9200036632 ered aby tio te omen fC Hert Cones Conse wee Nidan gecftoweratletnsPbleten aspPOnd 06525879036 each Cad noray Gol DONIC, 3.208557 Page 2.0097the cabicet, which goes againet the public good and constitutes @ Breach ‘of Trust eairary to section 122 o he Gominat Cod, b. The person to whom the informaton subject to cabinet confidence was zclosed, Spencer Fraser, the CEO of Project Resolve Inc, held a postion sth the capacty to publ pressure the government 10 make a ‘ession uiizng lobbyists such a9 Moccoroauf™ and Macintosh, and reporters such as Cudmore. Fraser did in fect use this information to Sttomptn publily pressure the government. «. As dewonstrated by the multiple emails that he sent to his ecleaaues, Frazer was in possession of information subject to cabinet confidence ‘long with other government information, such as the Seaspan letior ‘addressbd o ministers. Fraser recelved this information from Viee-Admial ‘Mark Norman. The eral updates that Fraser sent inde information subject 0 cabinet confidence on the AOR's Memorandum to Cabinet's Stal, an the concems volzed by Minisior Bxson about the Chanior Davie contact, and on the existence ofthe possibilty of a delay followed by 2 cxnfimation of the sbdy day delay resulting fom the Commitee meeting on November 19, 2018. 4. Traclng the tigi of thie information wil afford evidence 9 confirm [Nownat's uso of his ermal and dentiy the extent and purpose ofthe leak of nformaton subject to eabinet confidence suounding the AOR project. SEALING ORDER 4121.1 am requestig, pursuant to section 487.9(4) of the Criminal Code, that

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