Dan Sheppard

Dan Sheppard, Senior Counsel (POEC)

Mr. Commissioner, parties, members of the public, good morning. My name is Daniel Sheppard. I am senior Commission Counsel with the Public Order Emergency Commission. Today, we will be introducing into evidence three overview reports, and we anticipate that additional overview reports will be put into evidence in the days and weeks to follow. The first is a report on the COVID-19 pandemic and Public Health responses. Next slide, please. Because we're going to be spending some time today putting overview reports into evidence, I'd like to take a moment to discuss with members of the public what an overview report is and how it works within the Commission. You have already heard that the timelines that the Commission is working under are tight, and that not every witness that the Commission might hear from will, in fact, be called. There are large bodies of evidence that exist often in writing and entire topics that need to be explored by the Commission, but it would be impracticable to call live evidence in order to put it before the Commissioner. Previous commissions of inquiry have adopted the procedure of overview reports, documents created by Commission staff that collect, corelate and summarize large bodies of information into documents that may be more or less concise, so that they can be reviewed by the Commissioner, the parties and the public to understand a particular area of relevance to the Commission. The Public Order Emergency Commission has adopted this procedure. And for those who are interested in technical details about how overview reports work, reference can be made to Rules 41 through 45 of the Commission's Revised Rules of Practice and Procedure. I've mentioned that overview reports are created by Commission Counsel. After they are prepared, they have been circulated to the parties and we've invited their comment. And for those parties who have provided comment to the overview reports so far, I would like to express the thanks of the Commission. While not all comments have been accepted or necessarily reflected in finalized overview reports, the feedback that has been provided has been invaluable in ensuring that the Commission puts forward what it believes are high- quality documents before the Commissioner that he can rely upon. Once overview reports have been finalized and are introduced, they do become evidence before the Commission that may be relied upon by the Commissioner and the parties. However, it is important to note that simply because an overview report has been prepared by Commission Counsel does not mean that the Commissioner necessarily will accept its contents. Rather, an overview report is, like all other evidence, information before the Commissioner that he may or may not choose to rely on. This means that parties are free to disagree with the content of an overview report and are entitled to challenge its contents. Moreover, in areas where an overview report may not capture relevant information, parties and indeed Commission Counsel are free to supplement the information contained in them through the ordinary process of the factual inquiry. Next slide, please. With that general introduction out of the way, I would now like to present COM.OR.2, the COVID-19 Pandemic and Public Health Responses. This overview report summarizes publicly available information about the COVID-19 pandemic around the world and in Canada. The Commission anticipates that a great deal of evidence that it will be hearing will be made in reference to the pandemic and public health measures implemented by various Canadian authorities. This overview report attempts to provide context so that when those discussions take place and that evidence is heard, the Commissioner, the parties and the public have a factual background to understand what public health measures were in fact in place and what statements about the current public health system around the world and the pandemic were at different points in time. It therefore provides information not only about the pandemic itself and about public health measures, it also provides information about vaccine development and particular measures adopted by Canadian governments in different jurisdictions with respect to COVID vaccines. Next slide. The overview report contains essentially four components. The first, which is found at paragraphs 1 through 39 of the overview report deals specifically with the emergence of the COVID-19 pandemic. It does so in two ways. First, it provides a summary overview of international information about the spread of COVID-19 around the globe, and then second, provides background information about the emergence of COVID-19 in Canada. Next slide. On the international side of things, this overview report provides information about the original emergence of a novel coronavirus in late 2019 and its rapid spread throughout the world. It also provides background information about public health declarations and surveillance conducted by organizations, most notably, the World Health Organization. This includes the January 30, 2020 declaration of COVID-19 as a public health emergency of international concern and the March 11th, 2020 declaration by the World Health Organization of COVID-19 to be a global pandemic. Next slide, please. In Canada, this Overview Report discusses two main timelines. First it deals with when COVID-19 first emerged in different provinces across the country. With the exception of early provinces, such as Ontario and British Columbia, and the Territory of Nunavut, which was spared any infections until later in 2020, the Overview Report notes that most provinces began to be impacted with infections in later February, through mid-March. This Overview Report also outlines when each province and territory first declared a state of emergency under a variety of public health and emergency management statutes in respect of COVID-19. You’ll note from the slide that each of these jurisdictions declared some form of emergency throughout March of 2020. Next slide, please. The second part of this Overview Report, which is found at paragraphs 40 through 108, deals with what we term as the initial public health measures. Next slide, please. Spanning pages 16 through 50 of the Overview Report, this is a lengthy section, but notwithstanding its length, it’s important for Commission Counsel to emphasize this is not a comprehensive list of every public health measure that was implemented within Canada. Rather, it is limited in a couple of different ways. First, this Overview Report focuses on public health measures that were adopted from the early declarations of emergency in March 2020, up until the point in time when covid vaccines began to be approved for distribution and marketing in Canada. Secondly, this section of the Overview Report focuses almost exclusively on public health measures adopted by governments at the provincial and territorial level. Notably, it does not address public health measures adopted by other levels of government, such as municipalities or Indigenous governments. Finally, even within those confines, the Overview Report does not attempt to outline each and every public health measure adopted within the first year of the pandemic. That would be impossible and would turn the Overview Report into a largely useless document. To put this in context, in Ontario, the jurisdiction where I live, in the first year of the COVID-19 pandemic, the Provincial Government adopted over 200 orders in council specifically dealing with measures in respect to the pandemic. And while I have had the pleasure of reading each and every one of them, it would not necessarily be the best use of the Commission’s time to go over them in an Overview Report. Instead, this Overview Report focuses on six particular types of public health measures that were adopted broadly throughout Canada, and had significant impacts on the way Canadians live their lives. This includes restrictions on travel, both in terms of barriers to entering provinces and territories, or requirements to self-isolate, school closures and other types of closures impacting early childcare, limits on gatherings of persons, both in terms of public assemblies and private gatherings, both indoors and outdoors, closures of businesses and other locations, such as the shut down of indoor dining or prohibitions on use of outdoor recreational amenities, curfews and stay at home orders, measures that while adopted less frequently throughout Canada, did have significant impacts by restricting individuals’ rights to leave their home during particular periods or times of the day, and finally masking requirements, obligations imposed on individuals to wear face coverings in a variety of settings. Next slide. The third portion of this Overview Report deals with vaccine approvals in Canada. It is found in paragraphs 109 through 123 of the Overview Report. This section of the Overview Report deals with two broad issues. First, the Overview Report discusses the process whereby vaccines were considered and approved by Health Canada. Second, it deals with the actual approvals that were in fact made and the vaccines that became available at different points in time for marketing and use. Next slide, please. With respect to the drug approval process, the Overview Report discusses, in very general terms, how drug approval operates within Canada, under the Food and Drug Regulations, a regulation that is made pursuant to the Food and Drugs Act. Under the Food and Drugs Act, however, the Minister of Health has the authority, in section 30.1, to make something referred to as an interim order. And interim order can be made, this is the statutory language: “…if the Minister believes that immediate action is required to deal with a significant risk, direct or indirect, to health, safety or the environment.” The overview report discusses that on September 16th of 2020, the Minister of Health made one such interim order with respect to COVID-19 vaccines. The interim order respecting the importation, sale, and advertising of drugs for use in relation to COVID-19 contained a number of rules that were followed by Health Canada in the assessment and ultimate approval of a series of COVID-19 vaccines. Two procedural characteristics of the interim order are of particular note. The first is the rolling application process. In the ordinary drug approval process, Health Canada expects proponents to put forward all relevant clinical information at the time an application is made. Under the interim order, Health Canada allowed for rolling applications, permitting drug companies to provide initial clinical information at the time of an application, but to continue to provide additional information as the application was assessed, and prior to final approval. The second procedural alteration was pre- positioning, a measure that permitted the importation of drugs and its positioning throughout Canada so that in the event a vaccine were approved, doses would already be located at several locations throughout the country. At this point, I’d like to pause to note that on March 17th of 2021, the interim order expired. At that time, the Government of Canada made amendments to the Food and Drug Regulations to incorporate some aspects of the interim order into the ordinary regulatory regime. Next slide, please. The interim order also set out the approval standard for the Minister of Health to apply when approving drugs for use with COVID-19. The standard and relevant part was that the Minister had to have sufficient evidence to support the conclusion that the benefits associated with the drug outweigh the risks, having regard to the uncertainties relating to the benefits and risks and the necessity of addressing the urgent public health need related to COVID-19. Applying this standard, Health Canada approved a series of drugs for use within Canada. By today, there are currently six drugs that have gone through the approval process that began December 9th of 2020 and most recently occurred on February 24th, 2022 with a drug put forward by the company, Medicago. Next slide, please. The fourth and final section of this Overview Report deals with public health measures specifically related to vaccines and it can be found at paragraphs 124 through 180 of the Overview Report. Next slide. Once again, the Overview Report does not need to be entirely exhaustive. The purpose of this section of the Overview Report is to identify certain key public health measures that were specifically tied to individuals’ vaccination status. The focus of this section of the Overview Report is on rules imposed by governments, rules imposed by other types of actors, such as employers of their own accord, are not specifically dealt with in the overview report. Much like the section dealing with early public health measures, the Commission has also focused on a particular subset of public health measures connected to vaccine status. It is focussed on access to places, requirements for work, and limits on travel and movement. Next slide. With respect to access to places, this overview report discusses a range of rules implemented by government that tied an individual's ability to access a particular place, venue or service to their vaccine status or their willingness to provide proof of their vaccine status. Within this section, the Commission notes that there were a range of different types of public health measures adopted by different governments. So to simply provide an example to show some of the ranges of options adopted by governments, Alberta implemented something called the Restrictions Exemption Program in September of 2021. At this point in time, many types of businesses in Alberta were subject to particular forms of public health measures, such as masking requirements, limits on the number of people who could be physically present in a venue, or social distancing obligations. Under the Restrictions Exemption Program, certain types of businesses had an option. They could continue to operate under the pre-existing public health orders, or they could opt into this system, which would relieve them of the obligation to comply with several of them. However, in order to participate in the Restrictions Exemption Program, qualified businesses were required to check vaccine status of those attempting to access their venues, and to confirm that individuals were fully vaccinated. A different type of approach was adopted in Ontario pursuant to originally Regulation 645/21, though amended several times thereafter. Under this approach, the Government of Ontario imposed mandatory obligations on businesses to require that anyone accessing their premises show proof of full vaccination. There were no opt-outs that were provided. Next slide, please. The overview report also deals with a number of measures related to employment and work. In this area, governments adopted a range of different rules and measures that linked individual's ability to engage in certain types of work to their vaccine status. These measures were adopted in a variety of different ways. Some were applicable solely to the public sector, others captured private sector employers as well. Some measures applied directly to workers, other measures applied to employers and required them to implement particular policies. And the requirements under different programs varied dramatically. Some were simple obligations on workers to become vaccinated to access workplaces and others provided a variety of alternatives. Again, solely by way of example, we've provided two on this slide. The Saskatchewan Government adopted a pair of regulations. The Public Employer's COVID-19 Emergency Regulations and the Employer's COVID-19 Emergency Regulations. The former imposed an obligation on all public sector employers to implement policies. These policies required their employees to either become fully vaccinated by a particular point in time, or else to undergo weekly testing in order to access the workplace. The latter regulation applied to the private sector. It imposed no specific obligation on employers, but did give employers the legal authority to impose this type of policy on their workforce. As a contrast, the Commission has put on this slide Newfoundland's approach in its mandatory vaccination policy. This policy, which was applicable to public servants as well as contractors and vendors with the government required workers to become fully vaccinated by December 17th of 2021. Those individuals who chose not to become vaccinated by that date were told pursuant to the policy that they could be placed on a leave of absence without pay. Next slide. Thank you. The third and final area of focus in the overview report in this section deals with travel and movement. While some provinces and other jurisdictions imposed rules with respect to travel and movement that were connected to individual's vaccine status, the bulk of rules in this area were implemented by the federal government under a range of statutes, including transportation legislation, such as the Railway Safety Act and the Aeronautics Act, and also, and of particular significance to the evidence that we anticipate hearing in this inquiry, pursuant to the Quarantine Act. As many may remember, for much of the early days of the COVID-19 pandemic in Canada, Canada's borders were largely closed to foreign nationals who were attempting to enter for optional or discretionary purposes. However, starting between August 9th and September 7th of 2021, Canada began to implement rules permitting individuals to enter the country for optional or discretionary purposes, as long as they were able to show proof of being fully vaccinated. However, these were rules that were targeting optional and discretionary entry into Canada. A different set of rules were applicable to individuals seeking to enter Canada for what might be termed as essential purposes. The rules were contained in a variety of orders under the Quarantine Act and were often applicable in a somewhat complicated fashion. However, taken together, the effect was that for much of the pandemic, commercial truckers were able to cross the U.S./Canada border without regard to their vaccine status. Indeed, for much of the time they did so, there were no vaccines available. Those individuals crossing the border could be exempted from a variety of otherwise applicable measures under the Quarantine Act such as the obligation to quarantine as well as certain rules with respect to testing. Next slide, please. The Commission anticipates, however, that a series of changes that began to become announced in October and November of 2021 played a significant role in the circumstances that led to the proclamation of a public order emergency. First, starting in October of 2021, the Government of the United States of America made an announcement that starting in January of 2020, all inbound foreign nationals entering the United States via land or ferry crossings would be barred from entry if they were not fully vaccinated, even if they were entering for an essential purpose. A little over a month later, on November 19th of 2021, the Government of Canada announced that starting January 15th, 2022, new rules would apply at the border under orders made under the Quarantine Act. The effect of the announced changes was that essential service providers, including truck drivers, would have to be vaccinated to enter Canada in many circumstances. Unvaccinated foreign nationals would be barred from entry. Canadians and others that had a special legal entitlement to enter the country would still be allowed entry; however, they would no longer be exempted from particular public health measures such as the requirement to quarantine. On January 12th of 2022, a spokesperson with the Canadian Border Services Agency announced that, in fact, unvaccinated Canadian commercial truckers would be allowed to enter Canada across international borders without the obligation to quarantine. However, the next day on January 13th, the Government of Canada indicated that that statement was made in error. The Government reiterated that the previously announced new measures at the border that would apply, including to commercial truckers, though not exclusively, would come into effect on January 15th. And that is essentially where the overview report ends. As the Commission anticipates that a great deal of the evidence that it will hear will deal with events taking place in early and mid-January of 2022, influenced in part by some of the measures outlined in this overview report. Next slide. For parties with standing at the Commission, this overview report is available for review in the participant database. For members of the public who wish to learn more about the topic covered in this overview report, it will shortly be made available on the website for the Commission at www.publicorderemergencycommission.ca. Mr. Commissioner, parties, members of the public, I thank you for my time. That is the presentation on this overview report.

01-073-19

Dan Sheppard, Senior Counsel (POEC)

We would ask that to be done.

01-088-03

Dan Sheppard, Senior Counsel (POEC)

Hello, everyone, long time, no see. My name is Dan Sheppard, and I’m Senior Commission Counsel with the Public Order Emergency Commission, this time to present an Overview Report entitled, “Timeline of Certain Key Events”. Next slide, please. This is COMMOR00000004. The purpose of this Overview Report is somewhat different than the other ones that have been produced by the Commission. Whereas other Overview Reports are being put forward primarily as a means by which individuals can understand background information that’s relevant to the evidence that’s going to be heard, this Overview Report is intended to just serve more as a tool. It’ll become fairly clear, as evidence gets heard in these proceedings, that events were taking place across the country, often within compressed rapid timeframes, often in different parts of the country, in parallel. As individuals hear evidence about particular events, it may be useful to be able to step back and take a broader view about what was happening Canada-wide. This Overview Report is intended to therefore serve as something of a reference tool to help put the evidence that will be heard in its chronological and spatial context. You’ve heard me say, with respect to the last Overview Report that I presented, these are not exhaustive. This is very true for this Overview Report. If this Overview Report were to recount every relevant event that took place throughout the events leading up to the proclamation of a public Order of Emergency, then the bulk of the Commission’s report would already be written. This is necessarily a highly reduced timeline that deals with only some events that may be useful for participants and members of the public to have in mind when they hear the evidence that will be put before the Commissioner. I want to emphasize, therefore, that the absence of any particular event from this timeline is not a signal that the information is in any way less relevant or irrelevant. Rather, these are only some of the events that the Commission thought would be useful to be contained in a single document before all the parties, and available to the public. Next slide. So as a timeline, it is unsurprisingly organized chronologically. Within that chronological organization, the events are also subdivided by either location, when we’re dealing with an event that took place in a particular space; or by jurisdiction, when we’re dealing decisions that are more appropriately tied to a particular type of authority, like a level of government. The idea is that this will permit the reader to get a rapid sense of where different events were taking place simultaneously in different locations. It’s also important to note, as you read the Overview Report, that the actual events that are being identified are set out in very succinct and neutral terms. The purpose of the Overview Report is not to provide detailed information about any particular event; but rather to flag the existence of an event. The Commission anticipates that evidence will be heard on most, if not all, of the events identified in this Overview Report. In terms of the report’s scope, it captures the period beginning November of 2021 ,and ending in April of 2022. However, the focus of the timeline really are events that take place between January 13th and February 24th of 2022. While the time periods before and after are covered to a certain degree, it is within that narrower timeframe where the Overview Report provides something of a day-by-day account of events that were taking place throughout Canada. Next slide. Now, we are a little bit ahead of schedule, and so I’m tempted to simply read the Overview Report into evidence, but, again, I’m not sure parties would necessarily enjoy that. And so instead I’m going to take what I’ve already told you is a already non-exhaustive list of events and make it a little bit less exhaustive by just pointing out some of the events that are actually covered, divided into some rough timeframes. I mentioned that the Overview Report does begin in 2021 with some things we could style, “Pre-convoy events”; this would include, for example, what Mr. Armstrong had already discussed in terms of posts on social media that attracted particular attention with respect to public health measures and border crossings; what I had previously discussed with respect to the last Overview Report, in terms of government announcements relating to border measures and public health measures; as well as, to some predecessor protests and events that may be relevant to the circumstances leading to the proclamation of a Public Order Emergency, such as the Operation Bear Hug Convoy that took place in Ottawa in early December of 2021. Next slide. The Overview Report goes on to discuss what could be styled as convoy preparation, both in terms of those individuals involved in the convoy itself, but also preparation taking place by other actors throughout Canada. This includes the events that Mr. Armstrong has already referred to, in terms of meetings taken online between different organizers. We also see, on January 13th, 2022, the first time that the phrase, “Freedom Convoy” is mentioned in a Project Hendon Report. The Commission anticipates that it will hear a fair bit of evidence with respect to Project Hendon; what it was, what these reports were, what they contained, and how they were shared and acted upon. Many parties have made reference to crowdfunding, and the funding of protest activities. The Overview Report also talks about certain actions taken with respect to efforts by organizers to raise funds in support of the Freedom Convoy, such as the January 14th creation of the Freedom Convoy 2022 crowdfunding campaign on the GoFundMe platform. The Overview Report also then discusses the actual departure of convoy participants from locations across Canada, and what different individuals were doing in terms of responding to that, including communications within governments and police services. Next slide. The next portion of this Overview Report deals with the early protests taking place in Ottawa, and a series of events occurring simultaneously in other parts of the country. On January 28th of 2022, convoy participants began to arrive in the City of Ottawa, and at the same time, levels of government began to respond, including the Government of Ontario making requests for federal assistance, for access to certain spaces to be used for police station. It's during this period of time in which the overview report also identifies the emergence of protests at various locations along the Canada/U.S. border and in other major jurisdictions within the country, including provincial capitals. It covers early protests taking place in the City of Windsor that were styled as slow-roll protests designed to impede, although not block, traffic; a blockade that took place near Coutts, Alberta; and other protests in provincial capitals where individuals and vehicles protested a variety of public health measures. These events were largely public. The overview report also captures certain events that, while significant to the circumstances leading to the proclamation of a public order emergency, were not taking place in the public eye. Events such as the January 30th creation of the Freedom 2022 Human Rights and Freedoms non-profit corporation and briefings taking place within municipal government, discussing the possibility of seeking injunctions in response to protest activities. Next slide, please. Moving into February, this overview report deals with what we can style the protest continue and spread, as the Ottawa protests continue, to the surprise of some, and protests taking place in other parts of the country expand and become more frequent. Events that are summarized in this part of the overview report include highly notorious events such as the release of $1 million by GoFundMe, comments made by the Ottawa Chief of Police with respect to policing solutions for the Ottawa protests, and changes in the Coutts border blockade. It also deals with an increasing number of protests taking place now in locations such as Toronto, Winnipeg and Regina. Also canvassed during this period of time are continued interactions between federal, municipal and provincial governments, such as the Government of Alberta's request for federal assistance to gain access to military tow trucks to be used in the context of the Coutts' protests. And finally, with respect to Windsor, it captures the February 7th blockage of the Ambassador Bridge. Next slide, please. Moving into mid-February, this timeline deals with how protests continued and the emergence of new responses from a variety of actors. Examples of this were the February 7th injunction obtained by class action litigants in the City of Ottawa designed to prevent the honking of horns by truckers, the arrival of an integrated planning team that brought OPP and RCMP planners to the City of Ottawa. It dealt with requests for federal assistance by governments such as the Government of Windsor. And responding to some of the previous events with respect to online crowd funding, it also reviews steps taken by the Government of Ontario to restrain access to those funds as proceeds of crime. Notably in this period, this overview report also notes the first meeting of the Incident Response Group, or the IRG. The Commission anticipates that the Commissioner will hear a great deal of evidence on what the IRG is and the particular role it played in federal decision making with respect to the declaration of a public order emergency. Next slide, please. The overview report then moves to February 13th and 14th being the immediate period of time before the declaration of a public order emergency and the actual decision itself to invoke the Emergencies Act. It covers events taking place in Windsor and in Coutts, and also deals with both key meetings that took place at the federal level and between different levels of government. Next slide, please. The overview report then goes on to recount events that take place during the proclaimed public order emergency and the events leading up to the revocation of that proclamation. This includes changes in the senior leadership at the Ottawa Police Service, the creation of the Emergency Measures Regulations, the EMRs, and the Emergency Economic Measures Order, or the EEMO, pursuant to the Emergencies Act, the clearance of blockades at Emerson, and the influence of further injunctive activity before the courts. Finally, this section of the overview report chronicles parliamentary debates and the ultimate decision to revoke states of emergency that existed at the federal, provincial and municipal levels. Next slide, please. Again, for the parties, this overview report is available within the participant database, and for members of the public who wish to have this before them as a tool as they listen to the evidence throughout these hearings, this overview report will soon be available on the Commission's website. And, Mr. Commissioner, I would ask that this overview report be marked as the next exhibit.

01-094-11

Dan Sheppard, Senior Counsel (POEC)

Yes. Good morning, Mr. Commissioner. It’s Daniel Sheppard for the Commission. If Mr. Clerk could bring up the PowerPoint presentation.

16-007-10

Dan Sheppard, Senior Counsel (POEC)

Mr. Commissioner, today the Commission is presenting its next overview report dealing with fundraising in support of protesters. Next slide, please. COMOR00000005 describes the major fundraising activities that took place to provide money to support protestors in Ottawa. This overview report describes a variety of entities that were involved in this process including crowdfunding platforms, financial institutions, payment processors, as well as cryptocurrencies. The report provides a narrative of meetings and decision-making that took place with respect to how these fundraisers would be organized and constructed, and how money would be distributed, and it provides information available to the Commission about the ultimate sources and disposition of approximately $24M in donations. Next slide. Before getting into the results of the investigation, a few words about the process that the Commission used. It began by reviewing information provided by the parties to the proceeding, however, a great deal of the information necessary to complete this investigation was not in the hands of the parties. The Commission, using its powers of summons, as well as negotiations, obtained additional documents from six non-parties to this proceeding as well as engaging in a open- source investigation for further information. Commission counsel also interviewed 10 witnesses who provided statements that then were used to complete this report. Next slide, please. There were certainly a number of fundraisers that were in play during the Ottawa protests. This overview report focuses, however, on four main sources of funding, the GoFundMe and email money transfer campaigns associated with the Freedom Convoy, the Adopt a Trucker crowdfunding and email money transfer campaign, the second Freedom Convoy fundraiser posted on the GiveSendGo platform, and a subset of cryptocurrency campaigns that raised virtual currencies in support of protestors. Next slide. This represents the results of the investigation. Each line depicts a different source of funds and tracks how those funds were distributed and how they were dealt with at various points by a number of different intermediaries. The thickness of each line represents the amount of funding in question. I’ll return to this slide towards the end of my presentation to review exactly what the Commission learned about the sources and final destinations of funds. Next slide, please. Before turning to that, however, it’s useful to review some of the individuals and entities that played significant roles in the fundraising associated with the Freedom Convoy. Some of those individuals include Tamara Lich, who was the creator of the original GoFundMe and email money transfer campaigns for the Freedom Convoy; Chris Garrah, the organizer of the Adopt a Trucker Campaign and its associated funraisers; Chad Eros, an accountant who provided advice to the Freedom Convoy organizer, created the Convoy Corporation and played a significant role in the creation of the GiveSendGo campaign; and Jacob Wells, the co-founder of GiveSendGo who was also involved in the move of the Freedom Convoy crowdfunding campaign to his platform. Next slide, please. There are also a number of companies that were involved in the various forms of fundraising. You’ve already heard me refer to GoFundMe and GiveSendgo which are two crowdfunding platforms that take in donations in support of causes. There are also Canadian financial institutions that had important roles, such as the Toronto Dominion Bank and the Royal Bank of Canada. These were two financial institutions that received some of the funds. And finally, payment processors like Stripe and it’s Canadian subsidiary, Stripe Payment Canada Limited, played an important role in the background to these fundraisers, as I’ll discuss later in my presentation and is set out in more detail in the overview report. Next slide, please. One thing that will become apparent as one reviews the overview report is that frequently there were events that were taking place in parallel. It is not a strictly linear story that can be told, but rather one has to understand that different actors were engaged in different forms of fundraising conduct at the same time. The first part of the story that the overview report details has to do with the period January 14 to February 2nd of 2022 associated with the creation of the Freedom Convoy GoFundMe campaign and its associated e-transfer campaign. Next slide, please. The story begins with Tamara Lich and the creation of a crowd funding campaign on the GoFundMe platform on January 14th of 2022. At the same time, or rather four days later, Ms. Lich also made a post to Facebook that put forward an email address that solicited direct email money transfer donations in support of the Freedom Convoy. Both the GiveSendGo campaign and the email money transfer campaign were associated with a bank account at the Toronto Dominion Bank in Ms. Lich’s name. And both campaigns began to receive funds on the days that they were created. Nest slide, please. In its interview with Commission counsel, representatives from GoFundMe indicated that they became aware of the crowd funding campaign on their platform within hours of its creation. This was because it was flagged through its algorithms due to the very high rate of donations that were made very early in its creation. This flagging caused individuals within GoFundMe to review the campaign and relatively early on those individuals began to be concerned about the ability of this fundraiser to comply with the GoFundMe terms of service. In particular, the concern related to the GoFundMe terms related to campaigns distributing money in accordance with their description. When an individual creates a crowd funding campaign they have to describe what it is that they’re going to do with the money that’s raised. GoFundMe requires people who organize campaigns on their platform to actually distribute money in accordance with what they tell the public they will do with it. In the case of the Freedom Convoy fundraiser the description said that it would do certain things with the money such as: “We are asking for donations to help with the costs of fuel, food, and lodgings. Funds will be spent to help cover the costs of fuel for our truckers first and foremost will be used to assist with food if needed, and contribute to shelter if needed. Any leftover donations will be donated to a credible veteran’s organization which will be chosen by the donors.” GoFundMe reported that it had concerns with these statements. They indicated that, for example, they were uncertain how it would be possible for what was now thousands of donors to all agree on a credible veteran’s organization that could receive leftover funds. Because of these initial concerns they tasked what they called their VIP team to reach out to Ms. Lich. This is a group of GoFundMe employees who are responsible for dealing with high profile fundraisers and they reached out to Ms. Lich starting on January 16th of 2022 to discuss the fundraiser and how the funds might be spent. Next slide, please. These communications continued between the 16th and January 27th, initially with Ms. Lich abut very quickly turned over to a group of other individuals who were working with her to manage the campaign and to deal with GoFundMe. Over the course of this period, GoFundMe representatives posted questions and received answers. And by January 27th they had reached the part where they felt comfortable releasing at least some of the money that had been raised. Up until this point, donations remained in the control of GoFundMe. On January 27th, in order to formalize the assurances that Ms. Lich and her associates had provided GoFundMe, they provided something that they referred to as the attestation letter. The attestation letter was a document that they asked Ms. Lich to sign that set out a number of obligations on her part that she would have to agree to in exchange for access to the first $1 million of funds. This included pledges that she would act as a fiduciary for the beneficiaries of the fundraiser -- that is to say the truckers involved in the Ottawa protests; that she would deliver funds in a manner that was consistent with what she had set out in the fundraiser itself; a series of accountability mechanisms such as requiring truckers to sign registration forms and to provide receipts in order to receive reimbursement; and to make reimbursements through email money transfers to create a form of a digital paper trail that could be tracked. Finally, there was a requirement for the group of advisors that had surrounded her on these matters to form a formal finance committee that would be involved in overseeing the distribution of funds. Ms. Lich signed the attestation letter on January 27th and returned it to GoFundMe. Next slide. It is at this point that GoFundMe decided to release $1 million Canadian to Ms. Lich’s bank account. However, the money did not actually get transmitted on January 27th and this led to some confusion amongst the various actors. As the Commission discovered, while GoFundMe had reached the decision to release the funds on January 27th it wasn’t until February 1st that an actual transaction was initiated. In the time between January 27th and February 1st, Chad Eros, the accountant who had by this point had been brought in by the organizers to assist them in their dealing with GoFundMe, began to express concerns about the idea that funds would be sent directly to Ms. Lich’s personal bank account. In his view it would be more appropriate for there to be a non- profit corporation that would received donated funds and would manage their distribution. To that end, on January 30th, again after the money was agreed to be released but before any release of funds took place, Mr. Eros incorporated the Freedom 2022 Human Rights and Freedoms non-profit corporation which is referred to in the overview report as the Convoy Corporation. As I've mentioned, February 1st was the date which the actual fun fund transfer from GoFundMe was initiated. Records obtained from Toronto Dominion Bank indicate that on that date Chris Barber was added as a second signatory to Mms. Lich’s account that was receiving the funds. Records also showed that second account at TD Bank was opened jointly between Ms. Lich and Mr. Barber on that date. The overview report refers to these as the first and the second TD accounts, respectively. February 2nd, in the early morning hours was when the $1 million was in fact deposited into the first TD account. However, for reasons that I'm going to get into later in my presentation, very little of that money was ever accessed. And on February 3rd, TD Bank itself placed holds on both the first and the second TD account. Next slide, please. Before continuing the story of the GoFundMe fundraiser I'm going to speak a little bit about a second fundraiser that was taking place during the same period of time, the Adopt-A-Trucker fundraiser on the GiveSendGo platform. Next slide, please. Chris Garrah articulated the concept of Adopt-A- Trucker on Facebook. The idea was to pair Ottawa area residents with incoming truckers so that the truckers could receive support like showers, food, and billets. In order to support this concept, Mr. Garrah created a crowd funding campaign on January 18th on GiveSendGo. This campaign was attached to a bank account in his name located at the Royal Bank of Canada. Sometime after the creation of that crowd funding campaign he also, with the assistance of a man known to the Commission as Serge created a website. The website did a number of different things including soliciting email money transfer donations. Those donations were associated with an email address that was also connected to the same RBC account. And again, on January 18th, these campaigns began to raise funds. Next slide, please. So I'm going to return now to the GoFundMe campaign and discuss the events that took place that eventually led to that campaign being shut down. Next slide. Now, I've already indicated that on January 27th, GoFundMe had authorised the release of $1 million in funds. We'll recall that January 28th was the first day on which protesters, as part of the Freedom Convoy, began to arrive in Ottawa. GoFundMe representatives told the Commission that on January 28th they began to receive conflicting media reports about the nature of the protests that were taking place. They were aware of some media reports that described the protests as peaceful, and other reports that described it as involving harassment or unlawful activities. This led GoFundMe to have concerns about term service compliance, not only with respect to whether the funds would be distributed in accordance with the description, but also their requirement that funds not be used to fund unlawful conduct. A series of further communications between GoFundMe and convoy organisers then took place. On January 31st, GoFundMe sent emails to organisers asking a series of questions, and in particular, asking them to confirm that no funds would be given to protesters that were engaged in a range of unlawful activities. One of the activities specifically mentioned by GoFundMe in their communications was blockades of roads. Subsequently, on February 1st, the day in which the $1 million transition was actually initiated, GoFundMe emailed organisers asking a further series of questions, including whether or not they would agree to publicly disavow unlawful conduct that GoFundMe was concerned may be taking place in Ottawa. GoFundMe asked the organisers to respond to their questions within 24 hours. A response was not received within that timeframe, and on February 2nd, the same day that $1 million was received into the First TD account, GoFundMe decided to suspend the fundraiser pending further investigation. Over the course of the next two days, a series of important meetings took place. On February 2nd, representatives of GoFundMe met with Deputy Chief Bell, of the Ottawa Police Service, and on February 3rd, with Mayor Watson, of the City of Ottawa. On February 3rd, the Freedom Convoy organisers also had a series of communications with GoFundMe. A letter drafted by Keith Wilson, acting as counsel for the Convoy Corporation, was sent responding to the questions posed in GoFundMe's February 1st email. Subsequently, a telephone conversation took place involving Mr. Wilson, Mr. Eros, other associates of the fundraisers, and the GoFundMe platform. In their interview with Commission Counsel, GoFundMe representatives indicated that they left that meeting unsatisfied with the responses that they had received, and they continued to have concerns about the lawfulness of the protests and the role that the funds might play in those protests. On February 4th, GoFundMe had a second meeting with Deputy Chief Bell. It was also on that date that representatives of GoFundMe reported that they believed that individuals associated with the Freedom Convoy leadership were using social media to encourage harassment of GoFundMe employees. GoFundMe reported that its employees had received a number of threats after the decision was made to suspend the fundraising campaign, and those threats increased in frequency on February 4th. In the evening of February 4th, GoFundMe made the decision to cancel the fundraiser, and over the course of the next 24 hours arrived at the conclusion that they ought to refund all donations made to the platform. Next slide, please. The Overview Report also describes the events that took place surrounding the move of the Freedom Convoy fundraiser from the GoFundMe platform to the GiveSendGo platform. But as I mentioned before, often events were taking place in parallel, and as it turned out there were critical events involved in that move to GiveSendGo that were taking place as early as January 26th, even before Ms. Lich had signed the attestation letter, let alone the GoFundMe campaign being shut down. Next slide please. In order to understand this part of the story, there is some additional individuals who have to be introduced. On January 26th, a man named John Ballard reached out to Jacob Wells, the co-founder of GiveSendGo. Mr. Ballard is understood by the Commission to be associated with an American-based social media platform called CloutHub. In the January 26th meeting, Mr. Ballard spoke to Mr. Wells about the possibility of the two men working together to convince the Freedom Convoy organisers to move their crowdfunding campaign off of GoFundMe and onto GiveSendGo. In furtherance of this discussion, on January 27th, Mr. Wells created what he described to the Commission as a mock-up of a campaign on his platform, showing what a Freedom Convoy fundraiser would look like on GiveSendGo. Although to be clear, this was not active campaign; it was not capable of receiving funds. On January 28th, Mr. Ballard obtained Mr. Eros's contact information by way of Mr. Garrah. Mr. Ballard contacted Mr. Eros and asked him to join a phone conversation to discuss the possibility of the Freedom Convoy raising funds on GiveSendGo. Mr. Eros agreed to join that conversation. However, before that phone call took place, Mr. Eros reports receiving a phone call from another man named James Peloso, who is associated with the organisation Taking Back Our Freedoms. Mr. Eros and Mr. Peloso had not previously had interactions with each other. Mr. Peloso indicated that he should be involved in any phone call involving GiveSendGo because Taking Back Our Freedoms had funders who would not agree to fund the Freedom Convoy unless one of their individuals was on the inside for discussions related to fundraising activities. On January 31st, a meeting took place between Mr. Eros, Mr. Wells, Mr. Peloso, Mr. Ballard, and another individual named Jeff Brain, who is the founder of CloutHub. During that meeting, Mr. Ballard described a plan to move the Freedom Convoy off of GoFundMe and onto GiveSendGo. As part of this plan, he also suggested that Freedom Convoy organisers should use CloutHub as their main web presence to advertise their campaign, and indeed, their movement as a whole. Mr. Ballard also described how CloutHub would provide a secure means of communication between organisers of the Freedom Convoy. Mr. Brain, again the founder of CloutHub, also offered to provide Freedom Convoy organisers a quarter-million dollar loan to finance their operations, pending the ability for them to access donated funds. At the end of this meeting, no decision was made with respect to taking CloutHub up on its offer to use its services, or indeed to accept a loan from them. Indeed, Mr. Wells and Mr. Eros, in their interviews with the Commission, found it confusing that CloutHub was involved in these meetings at all. However, as a result of this meeting, Mr. Eros and Mr. Wells did form a connection, and as a result of that connection, an agreement was made to create a crowdfunding campaign on GiveSendGo connected to the Convoy Corporation. That campaign was created and went live on January 31st, again prior to the release of funds the next day from the GoFundMe campaign. Ultimately, when the GoFundMe campaign was shut down, Ms. Lich advertised the fact that the GiveSendGo campaign was in existence, and funders then moved and made donations there. Next slide, please. I mentioned before that payment processors played an important role in the story of the fundraising of the Freedom Convoy. This was a role that was played largely behind the scenes, and it had the most significance when it came to the GiveSendGo campaign. To the public, there was only ever one campaign on GiveSendGo associated with the Freedom Convoy fundraiser. However, for reasons connected with how Stripe operates there were in fact, in effect, two campaigns associated with the Freedom Convoy fundraiser on GiveSendGo. And in order to understand why that came to be, one has to understand a little bit about what payment processors are and how they operate. Most crowdfunding platforms don't actually accept and distribute funds themselves. They are, in effect, kind of a social network shell that provides a platform to attract donors. The actual work of receiving electronic donations and distributing those donations to bank accounts are done by payment processors like Stripe. On the GiveSendGo campaign, in order to set up a campaign at all, one needs to have a Stripe account. However, in order to create a Stripe account, an individual has to have a bank account to associate with it. This presented a unique difficulty for Mr. Eros because, at this point, the Convoy Corporation did not have a bank account. Recall that the Convoy Corporation was only created the day before on January 30th. He therefore could not create a Stripe account, and he therefore could not attach it to the GiveSendGo campaign. As a temporary solution to this problem, Mr. Wells suggested that he use his Stripe account, attach it to the campaign on GiveSendGo, and that is what happened. And so between January 31st when the campaign first went live and February 7th, the GiveSendGo campaign was actually attached to Mr. Wells' Stripe account, and through that, his personal bank account. On February 7th, Mr. Eros did create a Stripe account. However, that account was not connected to the Convoy Corporation directly. By February 7th, the Corporation still did not have a bank account. In order for Mr. Eros to create a Stripe account, he reached an agreement with Keith Wilson to have the Stripe account attached to Mr. Wilson's trust account at his law firm. Once this took place on February 7th, the fundraiser was switched over from Mr. Wells' Stripe account to Mr. Eros' Stripe account. And from February 7th until February 10th or 11th, the evidence on that point is conflicting, donations made to the GiveSendGo campaign went into Mr. Eros' Stripe account. On either February 10th or 11th, the Stripe account was switched back to Mr. Wells' Stripe account and all further donations made to the GiveSendGo campaign went there. Next slide, please. I'll return to the crowdfunding campaigns in a moment, but before I do, a few words about some of the activities involving cryptocurrencies that were taking place. The majority of these activities occurred between January 27th and February 17th of 2022. Next slide. There were a number of cryptocurrency campaigns and fundraisers taking place during the Freedom Convoy. This overview report focuses on three main ones. The first was a cryptocurrency campaign associated with Mr. Garrah's Adopt A Trucker campaign. I'd mentioned before that an individual named Serge created a website for Adopt A Trucker. In addition to soliciting email money transfers, that website also provided information that would allow individuals to donate any of six different types of cryptocurrencies to the Adopt A Trucker campaign. However, it appears that those cryptocurrencies were not in the control of Mr. Garrah directly but were rather controlled by Serge. A second different type of cryptocurrency campaign took place in association with Pat King. This was the Freedom Convoy token campaign, a new cryptocurrency that was created and marketed in association with the Freedom Convoy. The idea behind this campaign was that individuals would exchange pre-existing cryptocurrencies for this new cryptocurrency called Freedom Convoy token. Built into Freedom Convoy token was the process by which four percent of every transaction involving it would be diverted to an entity called the Freedom Convoy Foundation, the idea being that this would provide a long-term source of funds for convoy protesters. However, the Commission was unable to determine whether or not such an entity even exists, and it appears that there is not an active market today for Freedom Convoy token, and therefore, funds are not flowing to any such entity. The most significant cryptocurrency campaign addressed in the overview report was the HonkHonk Hodl campaign. Next slide, please. This campaign was started by an Ottawa area resident named Nicholas St. Louis on or about January 27th. While Mr. St. Louis was the creator of the campaign, there were a number of individuals that were associated with it at different stages, including Benjamin Dichter. Using a cryptocurrency crowdfunding platform called Tallycoin, this campaign ultimately raised approximately 22 bitcoin in donations. The value of those 22 bitcoin at the time was approximately $1.2 million Canadian, although today, the value would be significantly lower. Of that money, approximately 800,000 was distributed to protesters involved in the Ottawa protests. This was done by splitting $800,000 worth of bitcoin into 100 individual electronic wallets and then handing out in sealed envelopes 100 sets of instructions on how to access 1 of those unique online wallets. These were distributed to truckers in Ottawa over a 24-hour period on February 16th and 17th of 2022. Next slide, please. We get to the part of the narrative contained in the overview report that deals with how all of the funds we've just been discussed were eventually blocked from arriving in the hands of fundraisers. In order to understand this, it's useful to understand two types of court orders that were involved in the process that led to these funds being blocked. The first is something called a restraint order. This is a type of order that can only be obtained by the Attorney General of a province or of Canada, and it exists within the Criminal Code's proceeds of crime provisions. In essence, a restraint order is obtained by the Attorney General when they're able to show that there are reasonable grounds to believe that some property meets the definition of offence-related property. Offence-related property is defined to mean any property that is used in any manner in connection with an indictable offence or is intended to be so used. The effect of a restraint order is to prohibit anyone from dealing in any way with the property in question unless in accordance with the terms of the order. The second type of order to understand is called a Mareva injunction. A Mareva injunction is a civil court order. It is ordinarily obtained by plaintiffs in civil proceedings against defendants. It is used to freeze and preserve a defendant's assets and funds where there is a risk that they may be dissipated. Its purpose is to freeze those funds in place, so that if plaintiffs are successful in their lawsuit, there will be assets that they are able to execute judgment against. Both of these types of orders, restraint orders and Mareva injunctions, played a significant role in how funds that were raised were ultimately disposed of. Next slide. On February 10th, the Attorney General of Ontario applied ex parte to the Ontario Superior Court of Justice and obtained a restraint order against the funds that had been raised on the GiveSendGo platform, those being the Freedom Convoy campaign, as well as the Adopt-a-Trucker campaign. As a result of the restraint order, Stripe froze the accounts of Mr. Garrah and Mr. Eros. It did not, however, freeze the account of Mr. Wells, as it was held not by Stripe Payment Canada Ltd., but by the American payment company Stripe, which Stripe felt was beyond the reach of the Ontario restraint order. I’ve mentioned before that it is either February 10th or 11th that Mr. Wells changed over the Stripe account associated with the Freedom Convoy fundraiser from Mr. Eros’ frozen strip account to his own active Stripe account. Mr. Wells also took action with respect to the Adopt-a-Trucker campaign. While Mr. Garrah’s stripe account was frozen by the restraint order, Mr. Wells switched that campaign over to a backup payment processor based in the United States called RallyPay. Thus, while both of the fundraising campaigns remained attached to active payment processors and could continue to receive funds, it would be difficult for those funds to arrive in the hands of the organizers. By this point in time, both TD Bank and RBC had been put on notice of the restraint order and they too were prevented, by its terms, from dealing in any way with the funds raised on GiveSendGo. On February 17th, Zexi Li, in her role as the representative Plaintiff of a proposed class action of Ottawa residents, obtained a Mareva injunction. This order applied to a broader set of categories -- assets. It included those assets covered by the restraint order, but also applied to several other individuals and other assets. For example, it applied to assets that were raised by Mr. King and it applied to a range of crypto currencies that were not the subject of the restraint order. On the same day, the Toronto Dominion Bank applied to court to pay in, through an interpleader, approximately $1.4 million that were in the first and second TD accounts in the joint control of Ms. Lich and Mr. Barber. They did so on the basis that the true owners of those funds were unknown and that the funds should be held by the Court until such time as the proper recipients of that money could be determined. The money then stayed in these various bank accounts in various locations, frozen by both the restraint and the Mareva orders. This changed on March 9th, when the Mareva injunction was varied to allowed these funds essentially to be pooled in the hands of an escrow agent, who would hold them all, pending the outcome of the Ottawa litigation. And in the days and weeks that followed, the funds that we have been discussing so far were transferred to the escrow agent, where the Commission understands they remain. Next slide, please. This then takes us, then, to what the Commission understands about the sources of the various funds and their ultimate destinations. Next slide. During the events in question, there were many public statements and questions raised about the issue of foreign versus domestic funding. And in the Order in Council creating this Commission, this issue is also flagged for the Commission’s consideration. As a result of this, the Commission made inquiries with various entities about the sources of funds, both in terms of number of donors and in terms of the value of donations. The result of these inquiries show different patterns for different fundraisers. The simplest are the email money transfer campaigns associated with the Freedom Convoy and Adopt-a-Trucker. Those campaigns were 100 percent Canadian, in that they relied on the email money transfer system that exists within Canada. All donations to those fundraisers originated, at least immediately, from a Canadian domiciled financial institution. The Freedom Convoy GoFundMe campaign was also largely Canadian in its origin. GoFundMe reported that 86 percent of donors were based in Canada, and that by value, 89 percent of donations originated in Canada. The two campaigns on GiveSendGo, however, show a different pattern. Both of those campaigns were largely American based, in terms of where donors were located. Freedom Convoy, 59 percent of donations originated from the United States, 51 percent for Adopt-a-Trucker. However, when measured in terms of the value of donations, the values are slightly different. Fifty-five (55) percent in terms of the actual dollars donated through Adopt-a- Trucker originated in Canada. And in terms of the Freedom Convoy campaign, and equal amount of money originated from Canada and the United States at 47 percent each. The remainder, from other countries around the world. Next slide, please. So we’ll return then to this chart that describes the value of money flowing into and out of a number of different entities. I’ll begin with the GoFundMe campaign. The GoFundMe campaign raised in excess of $10 million Canadian. One million dollars of that was released to Ms. Lich’s Toronto Dominion bank account. However, the full amount was also refunded to donors. In other words, while GoFundMe released a million dollars, it also refunded all donors the full amount of their donations, making up the $1 million shortfall themselves. In addition to the $1 million that was deposited into Ms. Lich’s TD account from the GoFundMe fundraiser, she also received $419,416.63 in email money transfer donations. Out of this approximately $1.4 million put into the first and second TD account, only $26,000 was accessed. The remaining $1,393,000 and change was placed ultimately into escrow as part of the Mareva injunction. With respect to Adopt-a-Trucker, Mr. Garrah raised around $800,000 Canadian on GiveSendGo. Of that amount, approximately $330,000 was released by Stripe into Mr. Garrah’s RBC account. The remaining money contained in Mr. Garrah’s Stripe account was either ultimately paid into escrow, or was the subject of a variety of credit card disputes, charge backs, or fees by various financial institutions. In addition to the $330,000 that Mr. Garrah received into his RBC account, he also received approximately $31,000 in email money transfer donations. Of this amount, approximately $220,000 was released from Mr. Garrah’s RBC account and spent on a variety of things. Approximately $141,000 was paid by RBC from that account into escrow. With respect to the Freedom Convoy campaign on GiveSendGo, it begins to become a little bit difficult to provide precise figures. This is because GiveSendGo was reporting donations in U.S. funds, but that those donations were made over a period of time, subject to a number of different exchange rates. What we can say is that GiveSendGo reported receiving approximately $9.8 million U.S. in donations and that using the February 10th Bank of Canada exchange rate, that would be equal to roughly $12.4M Canadian. Of this, around $3.75M was put into Mr. Eros’ Stripe account and the remaining approximately $8.6M went into Mr. Wells’ Stripe account. The money in Mr. Eros’s Stripe account was sent into escrow; it was not provided to Mr. Eros or into the trust account of Mr. Wilson. There is a bit of a discrepancy there which was explained by Stripe being taken up again by credit card chargebacks and a variety of fees. In terms of Mr. Wells’ Stripe account, while we - - the Commission did not have access to any banking records associated with this, in communications between Mr. Wells and Stripe that the Commission did review, it appears that all donations made and put into his Stripe account were refunded to donors with the exception of certain fees that were subtracted as well as components of those donations that donors had indicated should go directly to GiveSendGo. With respect to the HonkHonk Hodl Campaign, as I mentioned before, out of approximately $1.2M of Bitcoin that was raised, $800,000 of that was distributed to protesters. Paid into escrow was 7.57 Bitcoin which at the time was worth approximately $413,000. Finally, there was a $10,000 bank draft that was also paid into escrow. This money originated from a very brief period of time when the Convoy Corporation did have a bank account at the Steinbach Credit Union. Next slide, please. The overview report contains substantially more detail about these transactions and the events surrounding them. For the parties, the overview report is available in the participant database. And for members of the public, this overview report will soon be published in both English and French on the Commission’s website along with over 100 source documents that provide further detail on the things that I’ve discussed in my presentation. With that, Mr. Commissioner, I’d ask that COMOR00000005 be entered into evidence.

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