Guillaume Sirois

Guillaume Sirois spoke 62 times across 1 day of testimony.

  1. Guillaume Sirois, Counsel (POEC)

    Good afternoon. I’m Guillaume Sirois, Commissioner Counsel. I will be leading from the events of February 10th. In the morning of February 10th, this is when Supt. Dana Earley from the OPP arrived in Windsor?


  2. Guillaume Sirois, Counsel (POEC)

    I would like to pull up WTS.00000022. While it’s being pulled up, I’ll just summarize what’s mentioned. That’s Dana Earley’s witness summary. At page 3, the second paragraph at the top, she mentions that, upon arriving in Windsor, Dana -- or Supt. Earley engaged in discussions with the Windsor Police Command team, including Deputy Chief Bellaire, and that during those discussion, Deputy Chief Bellaire told her that WPS welcome OPP’s assistance, understood that OPP had more experience policing blockades and protests that WPS, and understood that all operational decisions needed to come through Supt. Earley. Is that -- were you present during these discussions?


  3. Guillaume Sirois, Counsel (POEC)

    And were you informed about the content of these discussions afterwards?


  4. Guillaume Sirois, Counsel (POEC)

    And was this understood prior to Supt. Earley’s arrival or once she arrived?


  5. Guillaume Sirois, Counsel (POEC)

    So it was -- just to make sure I understand correctly -- it was OPP -- sorry, WPS command's position that OPP should take over the event in Windsor?


  6. Guillaume Sirois, Counsel (POEC)

    So you would say that OPP was in charge of the POU response and PLT perhaps, and WPS maintained control of the overall operation?


  7. Guillaume Sirois, Counsel (POEC)

    Okay. So in the same paragraph, we see that Supt. Earley later called Craig Abrams and informed him that Windsor has told us -- us being OPP --this is now ours. And Supt. Earley explained that she meant that OPP was in charge and that WPS will be working alongside OPP. That’s not your understanding of how it took place?


  8. Guillaume Sirois, Counsel (POEC)

    I think we can come back to the witness summary later on, but I would like to pull up WPS00000002 at page 27, because I think I just want to understand who was taking decisions and who was giving advice and so on in their command structure, because I understand that the idea of coming forward and giving some space to the other command, but I just want to make sure I understand properly how this works in practice.


  9. Guillaume Sirois, Counsel (POEC)

    And that -- this is a document that -- the debrief. Do you recognize this?


  10. Guillaume Sirois, Counsel (POEC)

    This is something that you prepared?


  11. Guillaume Sirois, Counsel (POEC)

    Okay. But it was prepared after the Freedom Convoy events to make a debrief of the events and recommendations moving forward?


  12. Guillaume Sirois, Counsel (POEC)

    And if we can go at page 27, please? On the right table, it's the -- it's point 4. It says, under "CIC Takeaway" -- CIC, I understand, is Critical Incident Command -- we see at point 4: "Needed WPS to be more engaged with collaborating on operational plans. WPS members have best idea of the area and implications of decisions and should be embedded in decision making matrix."


  13. Guillaume Sirois, Counsel (POEC)

    Okay. Maybe we can talk a little bit about the command table that was formed by Supt. Earley. Do you recall that command table?


  14. Guillaume Sirois, Counsel (POEC)

    Can you just explain how it worked and who from the WPS was on the command table, what was their role, and so on?


  15. Guillaume Sirois, Counsel (POEC)

    So it's fair to say that your initial command table just merged with theirs?


  16. Guillaume Sirois, Counsel (POEC)

    Okay. More -- on the same topic but more narrowed on the Critical Incident Command questions -- we can remove that PowerPoint, by the way - - just specifically on the Critical Incident Command structure and how it works, we understood from previous testimony that the CIC's purpose was to give autonomy to the CICs to take decisions on the go and to have their own autonomy and so on. I'm wondering how did it work with Dana Earley, Supt. Earley being a Critical Incident Commander for the same incident that you and - - that you were?


  17. Guillaume Sirois, Counsel (POEC)

    Yes, this provides a lot of clarity. Thank you. Maybe we can jump to February 11th, about the approval of the operational plan. We can pull up the operational plan, just to refresh your memory. It's WPS1440 page 2. That’s not the operational plan itself, but it's an email that presents the operational plan. I'm wondering -- it says that it's Inspector Younan who was in the planning team under Inspector -- under Supt. Earley, and the emails were about the plan. And he says: "Please reply all with your approval of the plan so that our municipal partners have the recorded approval." I just want to understand why it was necessary to have the approval recorded for your purposes?


  18. Guillaume Sirois, Counsel (POEC)

    And that’s why you had to have her approval for your records?


  19. Guillaume Sirois, Counsel (POEC)

    Excellent. Can we pull up OPP00004557? I understand this is the Overall Ambassador Bridge Operational Plan. I just have a few questions on it. I’m wondering, it took only two days, in fact, to come up with that plan. Do you have any insight to why it was so quick?


  20. Guillaume Sirois, Counsel (POEC)

    And on February 11th as well, not only the plans were approved, but the Province declared a State of Emergency under the MCPA and there was a civil injunction that went into effect?


  21. Guillaume Sirois, Counsel (POEC)

    That’s quite a busy day.


  22. Guillaume Sirois, Counsel (POEC)

    Did either of those, either the Declaration of Emergency, or the injunction, have any effect on the plan or the operation itself?


  23. Guillaume Sirois, Counsel (POEC)

    So I understand that charges were laid under the breaking of court order criminal offence ---


  24. Guillaume Sirois, Counsel (POEC)

    --- under the Criminal Code. Do you know if there were -- these charges were laid during the operation or afterwards?


  25. Guillaume Sirois, Counsel (POEC)

    And I would like to move to the operation itself. I think we can remove that -- the plan. You explained in your witness summary that there was, perhaps, around 730 officers that participated in the operation and approximately 500 OPP officers that were present? Is that ---


  26. Guillaume Sirois, Counsel (POEC)

    And do you have any understanding or insight about why so many officers were sent in the end, despite the fact that only 100 officers were asked at the beginning?


  27. Guillaume Sirois, Counsel (POEC)

    And what was WPS’ role during the operation itself? You mentioned a bomb threat. Was there any other things?


  28. Guillaume Sirois, Counsel (POEC)

    Okay. And the operation lasted from the February 12th to the 13th?


  29. Guillaume Sirois, Counsel (POEC)

    And would you consider the operation a success?


  30. Guillaume Sirois, Counsel (POEC)

    And now moving on from the operation, on February 13th, I understand that WPS, the Windsor Police, and the OPP both adopted a Joint Traffic Plan?


  31. Guillaume Sirois, Counsel (POEC)

    We can pull up the plan, if possible. It’s WPS0000711 at page 2. So the goal of that plan was to prevent a further blockade?


  32. Guillaume Sirois, Counsel (POEC)

    And if we go at page 2, there’s that mission statement, which is basically the same of the February 9th operational plan, about maintaining -- establishing and maintaining a safe flow of traffic respecting individuals’ Charter Rights. If we move -- yeah, it’s here as well. The Immediate Action Plan, it says what you mentioned, that: “If members observe an imminent highway blockade and form reasonable grounds an offence is about to be committed, officers will intervene to prevent a blockade if it is safe to do so.” I’m just curious as to how both interact, preventing a blockade and respecting individual's Charter rights and freedom?


  33. Guillaume Sirois, Counsel (POEC)

    So the limits of a stay, sort to say, is blocking infrastructure or a highway, that was a no-go, but as long as it's off the highways ---


  34. Guillaume Sirois, Counsel (POEC)

    Understood. So you briefly mentioned the plan itself on the ground consisted of establishing jersey barriers all along Huron Church Road. I think Mayor Dilkens explained as a -- this morning as a pipeline to allow the trucks to go directly from the 401 to the Ambassador Bridge. Is that correct?


  35. Guillaume Sirois, Counsel (POEC)

    And members of the public were not allowed to just go on the highway without a lawful reason or justification on Huron Church Road?


  36. Guillaume Sirois, Counsel (POEC)

    Okay, but they had to move forward and go towards Ambassador Bridge or else they could not just hang on on Huron Church Road.


  37. Guillaume Sirois, Counsel (POEC)

    So there were -- were there any situations where the traffic management plan was helpful in preventing any blockades?


  38. Guillaume Sirois, Counsel (POEC)



  39. Guillaume Sirois, Counsel (POEC)

    And just moving on to February 14th, the day the -- there was a declaration of emergencies by the Federal Government.


  40. Guillaume Sirois, Counsel (POEC)

    I'm wondering if you had any -- because of the injunction was enforced the EMCPA was in place, you had a traffic management plan, is there anything that the Emergencies Act added to the situation or helped you in any way in preventing further blockades?


  41. Guillaume Sirois, Counsel (POEC)

    So you would say it may have had a dissuasive effect but it was not used on the ground?


  42. Guillaume Sirois, Counsel (POEC)

    And moving further down the timeline, just to wrap up the Windsor story, we -- the WPS and OPP adopted the mobilisation plan as well, which it lasted until March 13 to fully mobilise I think OPP. It seems a bit long. Do you -- would you agree?


  43. Guillaume Sirois, Counsel (POEC)

    Was there any threats, any Intelligence about a possible blockade happening further down ---


  44. Guillaume Sirois, Counsel (POEC)

    Now, that the Windsor story is complete, I just want to go to lessons learned, concluding questions for just a few questions. Would it be possible to pull up WPS000002? It's the same document that we viewed earlier about the debriefing by WPS about the Freedom Convoy event. If we can go on page 19, please. There's a mention about -- it's areas to improve about the initial patrolled response, which I understand is before the blockade happened or before OPP arrived?


  45. Guillaume Sirois, Counsel (POEC)

    It mentions areas to improve, issues with the Operational Plan. Is that in reference to the February 4th plan?


  46. Guillaume Sirois, Counsel (POEC)

    In your witness summary you mentioned that if WPS had a Public Order Unit at the time, it would have been able to come up with a better plan in responding to the initial stages of the blockade.


  47. Guillaume Sirois, Counsel (POEC)

    And it says also on that same slide on the second point on the left side, "Extremely resource intensive; only a fraction of patrol officers remained to take calls [...]; patrol personnel were totally burned out" So it was not just a POU issue. It was a resource issue as well.


  48. Guillaume Sirois, Counsel (POEC)

    I would like to pull up COM0000822. It's the Adequacy and Effectiveness of Police Services Regulation, which I assume you're familiar with?


  49. Guillaume Sirois, Counsel (POEC)

    Sorry, it's the Adequacy and Effectiveness of Police Services Regulation. It's under the Police Services Act. It's ---


  50. Guillaume Sirois, Counsel (POEC)

    Okay. And under Section 18, it mentions that, "Police forces shall have a public order unit. [...] Despite subsection..." Subsection 2 says, "Despite subsection (1), [...] a board may enter into an agreement [...] to provide the services [...] through another police force..." Are you aware of any agreement with another police force to have a Public Order Unit dispatched in case of a public order event?


  51. Guillaume Sirois, Counsel (POEC)

    I think I have the policy you're mentioning. Can we pull up WPS00001877? I think that's the policy about Public Order Units deployment and the possibility of entering into an agreement.


  52. Guillaume Sirois, Counsel (POEC)

    Do you recognize - --


  53. Guillaume Sirois, Counsel (POEC)

    Is that the one you were mentioning?


  54. Guillaume Sirois, Counsel (POEC)

    Okay. And is this the version that was enforced during the Freedom Convoy events?


  55. Guillaume Sirois, Counsel (POEC)

    Okay. Can we go at point D on page 2, please? As you mentioned, it says that, "The Service shall provide [a] service[...] of a Public Order Unit through the provisions of an agreement with the [...] (OPP)."


  56. Guillaume Sirois, Counsel (POEC)

    I'm just not sure I understand why such an agreement was not entered upon prior to the Freedom Convoy events and ---


  57. Guillaume Sirois, Counsel (POEC)

    But this offer from the Commissioner never came to ---


  58. Guillaume Sirois, Counsel (POEC)

    And you mentioned formal versus informal request for assistance. I just want to make sure I understand what's the difference between the two, especially as it relates to Public Order Units or assistance at large to a public order event. In your view, what's the difference between a formal or informal request?


  59. Guillaume Sirois, Counsel (POEC)

    And on February 4th, we know that Chief Mizuno had a call with Commissioner Carrique asking for assistance. Would that -- but I think you mentioned, it was not a formal request process since -- do you know why?


  60. Guillaume Sirois, Counsel (POEC)

    And however, your -- when you reach out through Dwight Thib on the same day, would that be considered a formal request under the Police Services Act?


  61. Guillaume Sirois, Counsel (POEC)

    And under the Police Services Act, I'm sure you're familiar. It's not necessary to pull it up, but the Commissioner of OPP has to provide the resources it deems -- he deems, or she deems necessary in response to a formal request for assistance. I'm wondering, there was no request provided on February 4th. I'm wondering, do you have any idea why is that?


  62. Guillaume Sirois, Counsel (POEC)

    Perfect. I have no further questions. Thank you. Thank you, Commissioner.