Jessica Barrow

Jessica Barrow spoke 522 times across 13 days of testimony.

  1. Jessica Barrow, Counsel (Ott-OPS)

    Good morning to you both. I just have a couple of questions for you, Ms. Li. You spoke earlier this morning about the injunction. Did circumstances change after the injunction in terms of the level of threats that you were receiving from the community?

    02-054-26

  2. Jessica Barrow, Counsel (Ott-OPS)

    And once that occurred, once you were receiving a higher level of threat, would you agree that you had multiple interactions with the Ottawa Police Service as a result of that?

    02-055-06

  3. Jessica Barrow, Counsel (Ott-OPS)

    You had made them aware of the threats that you were receiving?

    02-055-11

  4. Jessica Barrow, Counsel (Ott-OPS)

    And the Ottawa Police actually attended your residence a couple of occasions as well; correct?

    02-055-21

  5. Jessica Barrow, Counsel (Ott-OPS)

    I just want to bring up one document if you don't mind. It's OPS-3014460. Can you see at the top of the page that this is a document dated February 9th?

    02-055-25

  6. Jessica Barrow, Counsel (Ott-OPS)

    And can you see about halfway down the page there's a subheading Constable Islam and Constable Lemieux?

    02-056-02

  7. Jessica Barrow, Counsel (Ott-OPS)

    It appears as though there's notes under that heading in relation to the activities of those officers?

    02-056-06

  8. Jessica Barrow, Counsel (Ott-OPS)

    If we could go to the next page, bullet number three, it says, "Mo and I spoke with..." (As read) And then, of course, there's obviously a redaction. "...regarding the threats she has received from her involvement with the injunction related to the convoy protest and the warrants." (As read) Obviously, we can see that there's a redaction here, but would you agree that on February 9th you did, in fact, speak with these two officers from Ottawa Police Service?

    02-056-10

  9. Jessica Barrow, Counsel (Ott-OPS)

    Okay. Thank you. And if you could look at that second sentence, it indicates, "She feels very supported by the OPS with this." Would you agree at this time that you had received the attention in relation to the threats from Ottawa Police Service that made you feel comfortable that they were managing that situation?

    02-056-23

  10. Jessica Barrow, Counsel (Ott-OPS)

    Thank you. Those are my questions.

    02-057-02

  11. Jessica Barrow, Counsel (Ott-OPS)

    Good afternoon to you both. My name is Jessica Barrow and I represent the Ottawa Police Service. I want to start -- we had a bit of a discussion earlier, we heard a bit of a discussion earlier about what information BIAs would typically receive as we're preparing -- or as the City was preparing for a protest, or an activation as you called it, Mr. McHale. And so I want to unpackage that a little bit and I'll start with you, Mr. McHale, if that's all right. So in terms of the types of information you would expect to receive, would that typically include the nature and location of any traffic disruptions?

    02-110-20

  12. Jessica Barrow, Counsel (Ott-OPS)

    As well as any plans the police may have to mitigate any such traffic disruptions?

    02-111-06

  13. Jessica Barrow, Counsel (Ott-OPS)

    You would also presumably expect to hear about any information the police have available to them about the expected behaviour of the protesters?

    02-111-09

  14. Jessica Barrow, Counsel (Ott-OPS)

    As well as the expected number of the protesters?

    02-111-13

  15. Jessica Barrow, Counsel (Ott-OPS)

    And perhaps how disruptive the protest is likely to be to your local businesses?

    02-111-16

  16. Jessica Barrow, Counsel (Ott-OPS)

    Right. And you would expect to be advised where businesses could direct any concerns they may have, should those arise throughout the course of events; correct?

    02-111-21

  17. Jessica Barrow, Counsel (Ott-OPS)

    I take it though that you would agree with me that there may be circumstances under which there are impediments to police disclosing certain information to local businesses; is that fair?

    02-111-26

  18. Jessica Barrow, Counsel (Ott-OPS)

    Or that may impede the police's ability to consult with the public or community members or business members and jointly agree on strategies?

    02-112-03

  19. Jessica Barrow, Counsel (Ott-OPS)

    For example, there may be sensitivity or confidentiality around certain operational planning techniques that may be going on at OPS?

    02-112-07

  20. Jessica Barrow, Counsel (Ott-OPS)

    As well as in relation to any intelligence information in the possession of the Ottawa Police?

    02-112-11

  21. Jessica Barrow, Counsel (Ott-OPS)

    And I take it you would obviously agree with me that you could not expect the police to provide information to the public which is not yet known to them?

    02-112-15

  22. Jessica Barrow, Counsel (Ott-OPS)

    And you would agree that the police may need to quickly or unilaterally adopt or change strategies to address the changing circumstances of an event?

    02-112-20

  23. Jessica Barrow, Counsel (Ott-OPS)

    We spoke earlier, we heard earlier about the experience that local BIAs and in particular the downtown core have with events and demonstrations and protests in the City of Ottawa; correct?

    02-112-24

  24. Jessica Barrow, Counsel (Ott-OPS)

    And you've indicated that they're a fairly regular occurrence?

    02-113-01

  25. Jessica Barrow, Counsel (Ott-OPS)

    Would you agree with me that the convoy was unlike any of the previous demonstrations or protests the City has seen?

    02-113-04

  26. Jessica Barrow, Counsel (Ott-OPS)

    More specifically, the size of the convoy was unlike any previous protests local businesses have seen?

    02-113-08

  27. Jessica Barrow, Counsel (Ott-OPS)

    And the volatility of the convoy was unlike previous protests?

    02-113-12

  28. Jessica Barrow, Counsel (Ott-OPS)

    And in fact, you indicated that previously businesses have never been required to close?

    02-113-15

  29. Jessica Barrow, Counsel (Ott-OPS)

    And that this time they did because this protest was very different from all previous ones?

    02-113-18

  30. Jessica Barrow, Counsel (Ott-OPS)

    So I want to talk now -- we talked sort of a generalities, now I want to focus on the specific communications that were provided to BIAs in the leadup as well as during the convoy. I want to start with a document. It's an OPS- 403228. And if we could go specifically to page 6? Just maybe scroll down a little bit. Thank you. That's perfect. Can you see here that there's an email exchange between the Ottawa Police and the City of Ottawa?

    02-113-23

  31. Jessica Barrow, Counsel (Ott-OPS)

    Perhaps just scroll back up a little bit, so we can see the date. It's on January 26 at 12:09 p.m.?

    02-114-05

  32. Jessica Barrow, Counsel (Ott-OPS)

    And would you agree with me that it says that, "The community police officers are in touch with downtown BIAs and are providing them with updates to expect large crowds and traffic disruptions. We cannot tell them to stay open or to close, but some businesses may elect to close, so as not to get tied up in an anti-vax demonstration." (As read)

    02-114-09

  33. Jessica Barrow, Counsel (Ott-OPS)

    Do you recall that as of this time, which is January 26th, OPS community police officers were in fact reaching out to local BIAs to share information in advance of the convoy's arrival?

    02-114-20

  34. Jessica Barrow, Counsel (Ott-OPS)

    And this is 2 days prior to the beginning of the convoy starting to arrive on the 28th?

    02-114-26

  35. Jessica Barrow, Counsel (Ott-OPS)

    And businesses are being told that there will be large crowds as well as traffic disruptions?

    02-115-01

  36. Jessica Barrow, Counsel (Ott-OPS)

    And that there is a possibility of anti-vax demonstrations in downtown establishments by convoy participants?

    02-115-05

  37. Jessica Barrow, Counsel (Ott-OPS)

    But that ultimately, the decision has to remain with the businesses as to whether or not to close?

    02-115-09

  38. Jessica Barrow, Counsel (Ott-OPS)

    I want to take you now to OTT-00000166. There's also a .0001 on the end if that's required. And if we could just scroll down a little bit, you'll see an email to the January 25th email below. That's perfect. So you can see here it's an email from Sébastian Lemay on January 25th at 11:38 a.m. And you would agree with me that Sébastien Lemay is one of the Community Police Officers, I believe, that was testified to earlier?

    02-115-13

  39. Jessica Barrow, Counsel (Ott-OPS)

    No, but he’s -- yes.

    02-115-25

  40. Jessica Barrow, Counsel (Ott-OPS)

    And you would agree that it tells us a few details about the upcoming convoy, and this is as early as January 25th; correct?

    02-115-27

  41. Jessica Barrow, Counsel (Ott-OPS)

    “The Ottawa Police are in the process of continually monitoring the progression of the convoy.” (As read) Correct?

    02-116-03

  42. Jessica Barrow, Counsel (Ott-OPS)

    That: “They can expect significant traffic disruptions.” (As read)

    02-116-09

  43. Jessica Barrow, Counsel (Ott-OPS)

    That: “Police resources will be deployed to mitigate safety risks.” (As read)

    02-116-13

  44. Jessica Barrow, Counsel (Ott-OPS)

    And it points you to where you can go to receive regular updates?

    02-116-17

  45. Jessica Barrow, Counsel (Ott-OPS)

    Right. And then, of course, it promises to disseminate any new information as it’s being received? And would you agree that further information subsequent to this was disseminated in a similar fashion from either this Community Police Officer or others that were local to your area?

    02-116-21

  46. Jessica Barrow, Counsel (Ott-OPS)

    Great. Ms. Carrier, I want to turn to you, if you wouldn’t mind, for a minute. I’m going to take you to OPB0001257. Thank you. So this is the minutes of the Ottawa Police Services Board’s special meeting that took place at 1:00 p.m. on January 26th. If we could turn to page 2 of that document, we see an agenda item that reads: “Operational Briefing on Weekend Demonstrations” and it’s the Chief’s report. Did you watch this meeting?

    02-117-01

  47. Jessica Barrow, Counsel (Ott-OPS)

    You did.

    02-117-14

  48. Jessica Barrow, Counsel (Ott-OPS)

    So we may not need to go through all this since you obviously watched the meeting, but would you agree that the meeting informed community members on the fact that this was a fluid event that could go on for a prolonged period? And we of course saw this same sentence in another communication as well? Is that correct?

    02-117-16

  49. Jessica Barrow, Counsel (Ott-OPS)

    And that the event was unpredictable?

    02-117-24

  50. Jessica Barrow, Counsel (Ott-OPS)

    And that existing intelligence was that protestors were peaceful, but that they would update if that were to change?

    02-117-27

  51. Jessica Barrow, Counsel (Ott-OPS)

    And if we turn to page 4 of this document, the second last bullet, we can see here that there’s questions being asked by Councillor Fleury, and we see here in response some advise to business owners. Is that fair?

    02-118-03

  52. Jessica Barrow, Counsel (Ott-OPS)

    Sorry, it starts, I guess, the last bullet.

    02-118-09

  53. Jessica Barrow, Counsel (Ott-OPS)

    If you keep scrolling. Yeah, okay. So sorry, the second bullet on page 5. There’s a question raised in relation to the BIAs in particular.

    02-118-12

  54. Jessica Barrow, Counsel (Ott-OPS)

    Okay. And do you recall that there was also information at this point that the police were anticipating numbers in the one to 2,000 range, but that even within the hour, they expected that that was information that was continuing to change?

    02-118-16

  55. Jessica Barrow, Counsel (Ott-OPS)

    Right.

    02-119-01

  56. Jessica Barrow, Counsel (Ott-OPS)

    But they were indicating that they were giving you the information they had at the time, and that as that changed, they were going to update the information; correct?

    02-119-04

  57. Jessica Barrow, Counsel (Ott-OPS)

    Right. But you were permitted to attend and did in fact attend; correct?

    02-119-10

  58. Jessica Barrow, Counsel (Ott-OPS)

    Okay.

    02-119-14

  59. Jessica Barrow, Counsel (Ott-OPS)

    Sure.

    02-119-17

  60. Jessica Barrow, Counsel (Ott-OPS)

    Sure. I’m happy to wrap it up. I just want to ask a couple more questions to you, Ms. McHale. Is it true that you were a fairly frequent ---

    02-119-20

  61. Jessica Barrow, Counsel (Ott-OPS)

    Sorry, Mr. McHale, Ms. Carrier. You were in frequent communication with your Community Police Officer throughout that time?

    02-119-25

  62. Jessica Barrow, Counsel (Ott-OPS)

    So you were speaking with, I believe, Cst. Lemay; correct?

    02-120-07

  63. Jessica Barrow, Counsel (Ott-OPS)

    Right. Okay. And you would frequently ---

    02-120-10

  64. Jessica Barrow, Counsel (Ott-OPS)

    Right. But you were in communication with ---

    02-120-14

  65. Jessica Barrow, Counsel (Ott-OPS)

    --- someone from Ottawa Police; correct?

    02-120-17

  66. Jessica Barrow, Counsel (Ott-OPS)

    Yeah. And he was responsive?

    02-120-20

  67. Jessica Barrow, Counsel (Ott-OPS)

    Yes. And you had raised complaints or concerns ---

    02-120-23

  68. Jessica Barrow, Counsel (Ott-OPS)

    --- or information you had found on social media, for example?

    02-120-26

  69. Jessica Barrow, Counsel (Ott-OPS)

    Would he indicate though, in response to those emails, that he was passing the information along ---

    02-121-04

  70. Jessica Barrow, Counsel (Ott-OPS)

    --- to whomever maybe would be that senior individual?

    02-121-08

  71. Jessica Barrow, Counsel (Ott-OPS)

    Okay. Those are my questions. Thank you ---

    02-121-11

  72. Jessica Barrow, Counsel (Ott-OPS)

    --- both for your time.

    02-121-14

  73. Jessica Barrow, Counsel (Ott-OPS)

    If I might interrupt just for a second. Sorry to my friend, but I just wanted to let you know that Deputy Chief actually has a hard copy of her notes on -- in front of her, so I just wanted to let that -- let you know of that, and also in case there's a specific page you could turn her to, she could actually turn it up in her notebook.

    06-045-08

  74. Jessica Barrow, Counsel (Ott-OPS)

    I'm sorry, I wonder if I could interrupt for a second. I don't know about the witness, but I can tell you it's nearly impossible to read from where I'm sitting. It may be the case that this document exists in some other format elsewhere in the record. I don't know if we can take a minute to try to find it. I just don't want to be unfair to the witness.

    06-064-12

  75. Jessica Barrow, Counsel (Ott-OPS)

    Good afternoon, Deputy Chief Ferguson.

    06-193-04

  76. Jessica Barrow, Counsel (Ott-OPS)

    You obviously are familiar with me, but for the record, my name is Jessica Barrow, and I represent the Ottawa Police Service. I only have a few things that I would like to cover with you this afternoon. So I want to start by talking about some of the comments that were made by you in response to questions with respect to those protestors that came, the ones that stayed, and the ones that left. Is it your understanding that OPS has filed an institutional report in relation to this Commission?

    06-193-08

  77. Jessica Barrow, Counsel (Ott-OPS)

    Are you familiar with it?

    06-193-20

  78. Jessica Barrow, Counsel (Ott-OPS)

    Are you prepared to adopt the content of that report?

    06-193-22

  79. Jessica Barrow, Counsel (Ott-OPS)

    I would like to pull it up. The number is OPS.IR.00000001, and if we could turn specifically to page 13? What do you understand this chart to represent?

    06-193-26

  80. Jessica Barrow, Counsel (Ott-OPS)

    I think if you read paragraph 44 as well, it may assist in understanding what, specifically, is set out in that chart.

    06-194-08

  81. Jessica Barrow, Counsel (Ott-OPS)

    So we've heard a lot about the vehicles in particular and the fact that they had not left. What do we see as between January 31st and February 1st in terms of the number of vehicles that are listed?

    06-194-16

  82. Jessica Barrow, Counsel (Ott-OPS)

    Would you say that this chart aligns with your experience at the time in terms of the ebbs and flows of the trucks?

    06-194-23

  83. Jessica Barrow, Counsel (Ott-OPS)

    Could we now please turn to page 33? And I'm bringing this to your attention in response to some questions that we heard earlier. What do you understand this chart to be?

    06-194-28

  84. Jessica Barrow, Counsel (Ott-OPS)

    And if we scroll to the bottom of that chart, does this demonstrate how many charges in total arose out of the events of the convoy? If we could go -- I guess it's on the next page, actually.

    06-195-08

  85. Jessica Barrow, Counsel (Ott-OPS)

    As well, does it demonstrate how many charges were laid per day?

    06-195-13

  86. Jessica Barrow, Counsel (Ott-OPS)

    And if -- I'm sorry, if we could go back to the top of the chart, does it demonstrate how many charges were laid in relation to violent offences?

    06-195-16

  87. Jessica Barrow, Counsel (Ott-OPS)

    And can you see whether charges were laid during the period of at the beginning of the convoy through to when they ultimately left?

    06-195-24

  88. Jessica Barrow, Counsel (Ott-OPS)

    Great, thank you. I want to turn to another issue that has been discussed with both Commission counsel as well as counsel for former Chief Sloly, and that is the request that was made by Chief Sloly for a POU plan. Do you recall that evidence?

    06-196-04

  89. Jessica Barrow, Counsel (Ott-OPS)

    And do you recall evidence in relation to a meeting that occurred on February 1st with respect to that plan?

    06-196-10

  90. Jessica Barrow, Counsel (Ott-OPS)

    Did that POU plan materialize?

    06-196-14

  91. Jessica Barrow, Counsel (Ott-OPS)

    Right. And you spoke earlier in your testimony about a POU being one part of a larger plan.

    06-196-19

  92. Jessica Barrow, Counsel (Ott-OPS)

    Do I have that right?

    06-196-23

  93. Jessica Barrow, Counsel (Ott-OPS)

    Can you explain to the Commission a little bit more about how POU would fit into a larger operational plan?

    06-196-26

  94. Jessica Barrow, Counsel (Ott-OPS)

    Would it normally be the case that a POU plan would be created in isolation from other plans?

    06-198-07

  95. Jessica Barrow, Counsel (Ott-OPS)

    Would it normally be the case that it would be created in advance of all other aspects of the plan?

    06-198-11

  96. Jessica Barrow, Counsel (Ott-OPS)

    Can we turn please to Document OPS6085? And if we could just scroll down a little bit, there's an email there from Superintendent Dunlop to yourself, as well as a few others, right?

    06-198-16

  97. Jessica Barrow, Counsel (Ott-OPS)

    And it's dated February 2nd. And perhaps you could just take a minute to read that. And my question to you in relation that is, what did you understand the concern to be at this time from Superintendent Dunlop?

    06-198-21

  98. Jessica Barrow, Counsel (Ott-OPS)

    After this email, or perhaps before, I suppose, were the concerns in relation to the scope of the ask that was being direct to them raised with Chief Sloly?

    06-199-18

  99. Jessica Barrow, Counsel (Ott-OPS)

    Would it normally be the case that a plan such as this would be drafted by the people that were being asked to draft it?

    06-199-28

  100. Jessica Barrow, Counsel (Ott-OPS)

    Right.

    06-200-06

  101. Jessica Barrow, Counsel (Ott-OPS)

    Earlier in your testimony, in response to a question from counsel for Former Chief Sloly, you referenced the request for a POU plan as compared to other types of plans and used the word “fixated” when describing Chief Sloly’s attitude towards the POU plan. Can I ask you to explain a little bit what you meant when you used that word?

    06-200-09

  102. Jessica Barrow, Counsel (Ott-OPS)

    I’m going to move on now to the expectations of the community and City Council. And we’ve heard some evidence about that; you’ve been asked some questions about that. We heard evidence in relation to the level of communication, or perhaps the lack thereof in some people’s minds, between the police and City Council. Can you tell us about the extent to which the police and you personally were in touch with City councillors?

    06-200-18

  103. Jessica Barrow, Counsel (Ott-OPS)

    And kind of along those same line we’ve heard from multiple witnesses that there was a feeling from the community that there was insufficient presence and enforcement by police officers during this time period, and we’ve also heard some evidence about some enforcement actions that were taken. What the impact, from your perspective, of enforcement actions that were taken by police during this time?

    06-201-16

  104. Jessica Barrow, Counsel (Ott-OPS)

    Those are my questions. Thank you very much, Deputy.

    06-202-20

  105. Jessica Barrow, Counsel (Ott-OPS)

    Good afternoon.

    07-210-01

  106. Jessica Barrow, Counsel (Ott-OPS)

    My name is Jessica Barrow and I’m representing the Ottawa Police Service. We heard earlier in your evidence that the reason the integrated planning cell was created was to assist OPS; is that correct?

    07-210-03

  107. Jessica Barrow, Counsel (Ott-OPS)

    And you listed a few reasons that that was the case, but one of the ones that you listed was to restore the public’s confidence in the police; is that fair?

    07-210-09

  108. Jessica Barrow, Counsel (Ott-OPS)

    And would you agree with me that the loss of public confidence in OPS was related, at least in part, to the public’s perception of inaction by OPS?

    07-210-13

  109. Jessica Barrow, Counsel (Ott-OPS)

    And that perhaps residents felt like the unlawful behaviour of protestors was going unchecked by OPS?

    07-210-17

  110. Jessica Barrow, Counsel (Ott-OPS)

    In response to that, however, you are not a proponent of leading with enforcement; is that fair?

    07-210-21

  111. Jessica Barrow, Counsel (Ott-OPS)

    It’s not fair. Okay.

    07-210-25

  112. Jessica Barrow, Counsel (Ott-OPS)

    Right. So, I guess my point was that it’s not the place you start; is that fair?

    07-211-04

  113. Jessica Barrow, Counsel (Ott-OPS)

    Right. And your goal, I think you explained this earlier, the goal is to try to negotiate your way out prior to engaging enforcement, unless necessary?

    07-211-10

  114. Jessica Barrow, Counsel (Ott-OPS)

    Right.

    07-211-18

  115. Jessica Barrow, Counsel (Ott-OPS)

    Fair enough. But because you are a proponent of that integrated model of negotiation and, perhaps, enforcement where necessary, you are a huge proponent, and I think you’ve mentioned this earlier, of the value of PLT; is that fair?

    07-211-22

  116. Jessica Barrow, Counsel (Ott-OPS)

    And you were of the view at the time of your arrival in Ottawa that OPS was not providing a supportive environment for PLT?

    07-212-03

  117. Jessica Barrow, Counsel (Ott-OPS)

    Fair enough. And you -- earlier in the Commission hearings, we’ve heard about the National Framework. I take it you’re familiar with that?

    07-212-10

  118. Jessica Barrow, Counsel (Ott-OPS)

    And the National Framework favours the use of PLT wherever possible to negotiate, correct?

    07-212-14

  119. Jessica Barrow, Counsel (Ott-OPS)

    And so, is it fair to say that the answer in response to the loss of public confidence wasn’t necessarily to go in right away and start enforcing; is that fair?

    07-212-17

  120. Jessica Barrow, Counsel (Ott-OPS)

    Fair enough. So, you would say that at the very least, any level of enforcement that was happening or ought to happen, needed to happen in tandem with PLT?

    07-212-28

  121. Jessica Barrow, Counsel (Ott-OPS)

    And for that reason, obviously, the operational plan that ultimately was agreed upon with Superintendent Bernier as the event commander did involve a strategic deployment of PLT as part of that, correct?

    07-213-05

  122. Jessica Barrow, Counsel (Ott-OPS)

    And in fact, I believe you indicated in your witness statement that the integrated plan involved a vital PLT communication and negotiation plan; is that correct?

    07-213-10

  123. Jessica Barrow, Counsel (Ott-OPS)

    And that when you presented the cell’s proposed plan to OPS, the key role of PLT was actually specifically stressed because the cell was concerned about the lack of buy in at OPS in relation to the role of PLT; is that fair?

    07-213-15

  124. Jessica Barrow, Counsel (Ott-OPS)

    So, they weren’t being deployed in a way that you felt was appropriate; is that fair?

    07-213-26

  125. Jessica Barrow, Counsel (Ott-OPS)

    So, I think part of what you’re saying, but you can correct me if I’m wrong, obviously, is that in order for PLT to be effective, they had to have the autonomy to actually negotiate effectively; is that fair?

    07-214-15

  126. Jessica Barrow, Counsel (Ott-OPS)

    Right.

    07-214-23

  127. Jessica Barrow, Counsel (Ott-OPS)

    Fair enough. And you were of the view, obviously, again, correct me if I’m wrong, that the reason PLT wasn’t engaged in the way that you’re describing in terms of its effectiveness was because that Chief Sloly didn’t believe in the PLT program?

    07-214-28

  128. Jessica Barrow, Counsel (Ott-OPS)

    Fair.

    07-215-09

  129. Jessica Barrow, Counsel (Ott-OPS)

    Right. So, in terms of ---

    07-215-12

  130. Jessica Barrow, Counsel (Ott-OPS)

    --- you’re talking about the optics of it?

    07-215-14

  131. Jessica Barrow, Counsel (Ott-OPS)

    Right. So, it perhaps is not that he didn’t believe in it, it may be that he didn’t understand its utility?

    07-215-23

  132. Jessica Barrow, Counsel (Ott-OPS)

    I’m sorry, who were they told that by?

    07-216-06

  133. Jessica Barrow, Counsel (Ott-OPS)

    And so, ultimately, when the integrated plan was agreed upon with Superintendent Bernier, and obviously with buy-in from others at OPS, there was an agreement that PLT played an important role in the dismantling of the convoy, is that fair?

    07-216-10

  134. Jessica Barrow, Counsel (Ott-OPS)

    No, no. Yes, fair.

    07-216-18

  135. Jessica Barrow, Counsel (Ott-OPS)

    Right.

    07-216-22

  136. Jessica Barrow, Counsel (Ott-OPS)

    Okay. I want to talk very briefly about the chain of command, and have you assist those of us that don’t work in policing to understand how the chain of command works. So, you would agree with me that police services are paramilitary organizations; is that correct?

    07-216-27

  137. Jessica Barrow, Counsel (Ott-OPS)

    You wish you agreed with me?

    07-217-05

  138. Jessica Barrow, Counsel (Ott-OPS)

    Would you agree with me there is a chain of command ---

    07-217-11

  139. Jessica Barrow, Counsel (Ott-OPS)

    Yes. Okay. So, however you describe it.

    07-217-15

  140. Jessica Barrow, Counsel (Ott-OPS)

    Okay.

    07-217-19

  141. Jessica Barrow, Counsel (Ott-OPS)

    So, there is a chain of command that one expects to follow, correct ---

    07-217-22

  142. Jessica Barrow, Counsel (Ott-OPS)

    --- within a police service, so however that’s described, there is a chain of command?

    07-217-25

  143. Jessica Barrow, Counsel (Ott-OPS)

    And that chain of command requires that where an officer is directed or ordered by a senior officer to do something, they’re required to follow the command?

    07-217-28

  144. Jessica Barrow, Counsel (Ott-OPS)

    And in fact, it is a misconduct offence under the Police Services Act not to follow a command ---

    07-218-05

  145. Jessica Barrow, Counsel (Ott-OPS)

    A lawful order. Correct.

    07-218-09

  146. Jessica Barrow, Counsel (Ott-OPS)

    And in addition to that, would you agree with me that it would be considered unprofessional to directly question the directions of one’s superior in front of partner agencies?

    07-218-11

  147. Jessica Barrow, Counsel (Ott-OPS)

    Fair enough. I want to talk a little bit about the integrated command. So when the Integrated Planning Cell arrived in Ottawa, its first activities -- and we’ve heard about this already -- involved meetings with OPS to get a sense of where their plans stood; is that fair?

    07-218-21

  148. Jessica Barrow, Counsel (Ott-OPS)

    And the Integrated Planning Cell brought with it a fairly significant amount of planning expertise?

    07-218-28

  149. Jessica Barrow, Counsel (Ott-OPS)

    And you indicated with the exception of you, that these were experts in their field; is that correct?

    07-219-04

  150. Jessica Barrow, Counsel (Ott-OPS)

    Okay. And the goal of the Integrated Planning Cell was to work with OPS to work towards a more robust overall plan?

    07-219-08

  151. Jessica Barrow, Counsel (Ott-OPS)

    And we’ve heard throughout your testimony -- and I’ll use the word criticism, but perhaps you had described otherwise -- but would it be fair to say that there’s some level of criticism of the level of integration OPS was allowing with your team at this point in time, when you arrived?

    07-219-12

  152. Jessica Barrow, Counsel (Ott-OPS)

    Fair enough. And we do know, however, that Superintendent Bernier was appointed as event commander on February 11th?

    07-219-27

  153. Jessica Barrow, Counsel (Ott-OPS)

    And although perhaps not the integration level that you would have liked, there was an integrated command table after he came in, correct?

    07-220-03

  154. Jessica Barrow, Counsel (Ott-OPS)

    It started.

    07-220-07

  155. Jessica Barrow, Counsel (Ott-OPS)

    Yes.

    07-220-09

  156. Jessica Barrow, Counsel (Ott-OPS)

    And ultimately that does happen, right? Superintendent Bernier moves his group over to the unit?

    07-220-17

  157. Jessica Barrow, Counsel (Ott-OPS)

    Right. And that takes time, obviously, to assemble that number ---

    07-220-26

  158. Jessica Barrow, Counsel (Ott-OPS)

    --- of people? And one of the things that Superintendent Bernier did when he was appointed as Event Commander was appoint a Deputy Event Commander; is that right?

    07-221-01

  159. Jessica Barrow, Counsel (Ott-OPS)

    And that Deputy Event Commander was Inspector Springer?

    07-221-06

  160. Jessica Barrow, Counsel (Ott-OPS)

    And he’s from the OPP?

    07-221-09

  161. Jessica Barrow, Counsel (Ott-OPS)

    Oh, a retired member of the OPP then perhaps?

    07-221-12

  162. Jessica Barrow, Counsel (Ott-OPS)

    And part of that integrated team that was assembled and evolved, I guess is what you’re saying, it was specialties from all different specialty units, as well as members from a variety of different agencies. Is that right?

    07-221-15

  163. Jessica Barrow, Counsel (Ott-OPS)

    And you felt at this time, I think you indicated, that even with Superintendent Bernier and the integrated table in place at this time, that there was at least a perceived need for Chief Sloly to approve any kind of planning. Is that fair?

    07-221-21

  164. Jessica Barrow, Counsel (Ott-OPS)

    Right. And, you know, we talked a little bit throughout this Commission here and with various witnesses about this Incident Command System. We know that there’s multiple iterations of it, but would you agree with me that irrespective of which version we’re talking about, that the Chief’s requirement to sign off on an operational plan is inconsistent with that model; is that fair?

    07-222-04

  165. Jessica Barrow, Counsel (Ott-OPS)

    Correct. You indicated that your team met with Deputy Chief Ferguson on the 11th to present the plan that your team had created; is that right?

    07-222-14

  166. Jessica Barrow, Counsel (Ott-OPS)

    Okay. So there was a meeting of some kind?

    07-222-20

  167. Jessica Barrow, Counsel (Ott-OPS)

    And am I correct in saying that the plan involved the creation of a unified command?

    07-222-23

  168. Jessica Barrow, Counsel (Ott-OPS)

    And you indicated, I think earlier in your testimony, that Deputy Chief Ferguson was very supportive of that plan?

    07-222-26

  169. Jessica Barrow, Counsel (Ott-OPS)

    And you also indicated that Ferguson was your primary contact with the OPS at this time?

    07-223-02

  170. Jessica Barrow, Counsel (Ott-OPS)

    And so would you agree with me that that support that she indicated on February 11th was generally consistent with the level of collaboration you saw from her during your interactions with her?

    07-223-05

  171. Jessica Barrow, Counsel (Ott-OPS)

    In fact, in your witness statement, you referred to Deputy Chief Ferguson as a voice of reason; is that right?

    07-223-10

  172. Jessica Barrow, Counsel (Ott-OPS)

    Okay. And you also indicated in your testimony earlier that by this time, all of the rank and file of OPS was working well with your team; is that right?

    07-223-14

  173. Jessica Barrow, Counsel (Ott-OPS)

    And on the same day of Chief Sloly’s resignation, you would agree with me that Interim Chief Bell agreed with RCMP and OPP to implement a unified command; is that correct?

    07-223-19

  174. Jessica Barrow, Counsel (Ott-OPS)

    Those are my questions. Thank you very much.

    07-223-24

  175. Jessica Barrow, Counsel (Ott-OPS)

    Good morning, Inspector.

    09-090-18

  176. Jessica Barrow, Counsel (Ott-OPS)

    For the record, my name is Jessica Barrow and I'm Counsel for the Ottawa Police Service. I just have a few areas that I want to quickly chat with you about, Inspector. So, first of all, we heard from both you and other witnesses that initially the planning for this event was primarily traffic focussed; is that right?

    09-090-20

  177. Jessica Barrow, Counsel (Ott-OPS)

    Correct. And in this respect, I want to circle back to something you said earlier in your examination. You said that the reason OPS initially focussed on traffic management was because the number of vehicles that were going to come you were not going to stop them; do I have that right?

    09-090-27

  178. Jessica Barrow, Counsel (Ott-OPS)

    Can you tell us what you meant by that?

    09-091-06

  179. Jessica Barrow, Counsel (Ott-OPS)

    If you had wanted to try to stop them, and we look at sort of the resources and the logistics that would have been involved in that, what would that have looked like from your perspective?

    09-091-18

  180. Jessica Barrow, Counsel (Ott-OPS)

    What is your perspective on what the impact could have been on other communities had you tried to stop them?

    09-092-02

  181. Jessica Barrow, Counsel (Ott-OPS)

    And why would it have been more difficult for you to contain and manage?

    09-092-11

  182. Jessica Barrow, Counsel (Ott-OPS)

    Great. I want to just get some clarity on two plans. We've seen two plans as it relates to the early period, and I just want to make sure that it's clear what the purpose of those plans were and how they relate to one another. So could we please pull up OPS4221? So this is the plan that's dated January 28th, I believe; right? If we could scroll down? It's difficult to see.

    09-092-15

  183. Jessica Barrow, Counsel (Ott-OPS)

    Right. Okay. And so I think you testified that this was the overall plan that you went into the weekend with; right?

    09-092-23

  184. Jessica Barrow, Counsel (Ott-OPS)

    Okay.

    09-092-27

  185. Jessica Barrow, Counsel (Ott-OPS)

    And one element of this plan was traffic?

    09-093-02

  186. Jessica Barrow, Counsel (Ott-OPS)

    So just to clarify, there's another plan that speaks to traffic. Is that a completely standalone plan?

    09-093-07

  187. Jessica Barrow, Counsel (Ott-OPS)

    Okay. To what extent did this January 28th plan evolve in the week leading up to January 28th?

    09-093-15

  188. Jessica Barrow, Counsel (Ott-OPS)

    And so we heard quite a bit of evidence, both through you and others, about the intelligence that was available throughout that time period. What other sources of information is your team and the Intelligence Team relying on as we get to this final plan?

    09-093-23

  189. Jessica Barrow, Counsel (Ott-OPS)

    So you would say it's sort of multi-dimensional?

    09-094-12

  190. Jessica Barrow, Counsel (Ott-OPS)

    Okay. And we heard a suggestion earlier in -- with another witness that essentially OPS dusted off a template plan that it implemented for this event. What would you say to that suggestion?

    09-094-15

  191. Jessica Barrow, Counsel (Ott-OPS)

    So did you use a SMEAC template for this plan?

    09-095-05

  192. Jessica Barrow, Counsel (Ott-OPS)

    Okay. Something you said earlier... We can move away from this document, thank you. Something you mentioned earlier is that, as it relates I believe specifically to the meeting that occurred on the 27th, that your concerns with respect to resources related to making sure OPS had the resources to restore safety if the tides were to turn from a violence perspective. Is that correct what you ---

    09-095-08

  193. Jessica Barrow, Counsel (Ott-OPS)

    Okay. And one of the subplans you indicated to this plan was a POU plan; right?

    09-095-18

  194. Jessica Barrow, Counsel (Ott-OPS)

    Okay. What's the purpose of a POU subplan in this context?

    09-095-21

  195. Jessica Barrow, Counsel (Ott-OPS)

    Well, perhaps we can just get a little clarity on the numbers that would be associated with that. And to that end I'll pull up OPS3324, please. If you could just scroll down to the email -- right there. It looks like to be an email from Chief Sloly to a number of people on the 27th that lists the POU that was obtained in relation to the event. Is that right?

    09-096-07

  196. Jessica Barrow, Counsel (Ott-OPS)

    So we see OPP, YRPS, DRPS, LPS, and then obviously OPS as well. Can you give us a sense of the number of officers that we would be talking about when we combine all of those sections together?

    09-096-16

  197. Jessica Barrow, Counsel (Ott-OPS)

    And did those officers all arrive prior to the commencement of the convoy?

    09-096-27

  198. Jessica Barrow, Counsel (Ott-OPS)

    And did we use them?

    09-097-02

  199. Jessica Barrow, Counsel (Ott-OPS)

    Did we use them for the, quote, "worst case scenario" that you were referring to earlier?

    09-097-04

  200. Jessica Barrow, Counsel (Ott-OPS)

    But in terms of the violence that you were associating with this worst case scenario, did that ever occur on that first weekend?

    09-097-13

  201. Jessica Barrow, Counsel (Ott-OPS)

    Great. So we talked earlier in your earlier testimony in relation to the level of cooperation that you had with protesters as the weekend unfolded; right? And you testified that in the early or early hours, I guess, they were cooperative and then ultimately that shifted; right?

    09-097-18

  202. Jessica Barrow, Counsel (Ott-OPS)

    And why were OPS officers not able to control the behaviours to make them comply with the traffic plan?

    09-097-25

  203. Jessica Barrow, Counsel (Ott-OPS)

    I think I'm almost at the end of my time so I'll only ask maybe one more question. You indicated earlier in your testimony in relation to the shift in the level of cooperation and the footprint that that then created as a result, sort of the unintended footprint. You indicated that there was an opportunity afterwards to shrink the footprint but that that did not occur. What did you mean by that?

    09-098-07

  204. Jessica Barrow, Counsel (Ott-OPS)

    Who did you understand that direction to have come from?

    09-098-24

  205. Jessica Barrow, Counsel (Ott-OPS)

    Okay, those are my questions. Thank you very much, Inspector.

    09-098-28

  206. Jessica Barrow, Counsel (Ott-OPS)

    Good afternoon, Superintendent.

    10-158-28

  207. Jessica Barrow, Counsel (Ott-OPS)

    For the record, my name is Jessica Barrow and I am counsel for the Ottawa Police Service. We heard evidence yesterday from you, Superintendent, about your extensive background in incident command; does that background involve planning for large-scale events?

    10-159-03

  208. Jessica Barrow, Counsel (Ott-OPS)

    Okay. And we’ve heard testimony from both, I believe, and others that gathering intelligence is an important part of that planning process; do I have that correct?

    10-159-11

  209. Jessica Barrow, Counsel (Ott-OPS)

    Is there more than one source of intelligence that would be relevant to the planning process?

    10-159-16

  210. Jessica Barrow, Counsel (Ott-OPS)

    Could you tell us a little bit about what those sources might be?

    10-159-20

  211. Jessica Barrow, Counsel (Ott-OPS)

    Great. We’ve also heard considerable evidence about the use of PLTs as well. What is your understanding with respect to their role in assisting planners leading up to an event.

    10-160-05

  212. Jessica Barrow, Counsel (Ott-OPS)

    Okay. I want to take you through a couple of the concerns that you've identified, both in your witness statement as well as during your testimony, specifically as it relates to the planning process leading up to the convoy's arrival. I believe you indicated -- and obviously, correct me if I'm incorrect -- that you developed those concerns about the scope of the event after reading the January 27th Hendon Report, attending the January 27th Hendon call, as well as the internal OPS meeting that occurred on that date as well; is that right?

    10-160-20

  213. Jessica Barrow, Counsel (Ott-OPS)

    Prior to the convoy's arrival, did you read any of the other Hendon Reports?

    10-161-04

  214. Jessica Barrow, Counsel (Ott-OPS)

    As of the date of the 27th when you expressed the concerns that we noted earlier in your testimony, had you read any other Hendon Reports besides the one on the 27th?

    10-161-09

  215. Jessica Barrow, Counsel (Ott-OPS)

    Right. And had you attended any previous Hendon calls prior to the 27th?

    10-161-16

  216. Jessica Barrow, Counsel (Ott-OPS)

    Did you have any involvement in discussions with PLT at that time?

    10-161-19

  217. Jessica Barrow, Counsel (Ott-OPS)

    What is your understanding about the level of information Inspector Lucas would have had at that time as compared to the level of information you had at that time in relation to the convoy's arrival?

    10-161-22

  218. Jessica Barrow, Counsel (Ott-OPS)

    Were you privy to the information that they were discussing, specifically?

    10-162-04

  219. Jessica Barrow, Counsel (Ott-OPS)

    Okay. You indicated in your witness statement that there appeared to be a disconnect between the intelligence and the planning, and that the intelligence may have been impacted by the fact that intelligence is not usually involved in gathering intelligence on protests; is that right?

    10-162-07

  220. Jessica Barrow, Counsel (Ott-OPS)

    Right. Do you have any direct knowledge about whether that was, in fact, impacting the intelligence department's ability to connect the dots?

    10-162-22

  221. Jessica Barrow, Counsel (Ott-OPS)

    Okay. In relation to your examination with former Chief Sloly's counsel, there was an issue as it relates to whether former Chief Sloly was issuing operational directions during your time as Event Commander. Do you remember that discussion?

    10-162-26

  222. Jessica Barrow, Counsel (Ott-OPS)

    And I think the suggestion that was put to you was that you were free to voice any concerns you had around those operational directions to Chief Sloly and that he would be receptive to that. Is that a fair assessment of that exchange?

    10-163-04

  223. Jessica Barrow, Counsel (Ott-OPS)

    I just want to bring you to OPS10443. I just want to -- just to situate you, it looks at the top like there's a list of attendees, and it appears that your name is on it. Is that correct?

    10-163-10

  224. Jessica Barrow, Counsel (Ott-OPS)

    And I know it doesn’t have a date on it, so perhaps if we just scroll down a little bit and we look -- yeah, that’s great -- where you're under at NCRCC now, there's a statement, an update from you. Does that situate you in terms of around what timeframe this would have been?

    10-163-15

  225. Jessica Barrow, Counsel (Ott-OPS)

    So were you the Event Commander then at the time of this meeting?

    10-163-22

  226. Jessica Barrow, Counsel (Ott-OPS)

    Okay. Can we scroll please down to the bottom of page 2? That’s perfect, thank you. And just if we start under the first redaction, there's a question being posed by John Steinbachs about closing bridges. And then under it, you see Lucas is saying, "Not going to close it right now." Do you remember this conversation?

    10-163-27

  227. Jessica Barrow, Counsel (Ott-OPS)

    And do you remember what Lucas' plan was in relation to the closures that we're seeing being discussed here?

    10-164-08

  228. Jessica Barrow, Counsel (Ott-OPS)

    And if you look under that, we see a comment -- there's one by Bell and then under that, we have Sloly. It says, "Bridge closed, wants it done. Close everything, not debating." Do you recall that comment being made during that meeting?

    10-164-16

  229. Jessica Barrow, Counsel (Ott-OPS)

    And what did you take that comment to mean?

    10-164-23

  230. Jessica Barrow, Counsel (Ott-OPS)

    Irrespective of Lucas' plan? Okay.

    10-164-27

  231. Jessica Barrow, Counsel (Ott-OPS)

    I want to move on. Thank you, Mr. Clerk, we can take that down. We heard in your earlier examination about the steps that you took to set up an integrated command table. I wonder if you could just explain to us a little bit about how you selected each of the experts, I think you called them, at that table, in terms of the qualifications that you were looking for to select that person?

    10-165-02

  232. Jessica Barrow, Counsel (Ott-OPS)

    Perhaps you could just give us a general idea of how you decided who to put in those seats?

    10-165-12

  233. Jessica Barrow, Counsel (Ott-OPS)

    Perhaps you could just explain what KSAs are, just so ---

    10-165-25

  234. Jessica Barrow, Counsel (Ott-OPS)

    Great, thank you. Were all of the officers you selected from OPS?

    10-166-01

  235. Jessica Barrow, Counsel (Ott-OPS)

    So why did you select officers from other services as well, if at this time, there was no unified command?

    10-166-04

  236. Jessica Barrow, Counsel (Ott-OPS)

    What was your view at that time. once the integrated command table was set up, as to the quality of the integration between the various services that were present?

    10-166-15

  237. Jessica Barrow, Counsel (Ott-OPS)

    Yes.

    10-166-21

  238. Jessica Barrow, Counsel (Ott-OPS)

    Okay. Those are my questions. Thanks very much, Superintendent.

    10-166-25

  239. Jessica Barrow, Counsel (Ott-OPS)

    Good evening, Superintendent.

    10-300-27

  240. Jessica Barrow, Counsel (Ott-OPS)

    For the record, my name is Jessica Barrow, and I am counsel for the Ottawa Police Service. Mr. Commissioner, I just want to ask for permission to replay a video that played earlier today with Superintendent Bernier in cross-examination that only became relevant as a result of his cross-examination. And so though it's not on the list of materials I intended to bring Superintendent Drummond to, I'd appreciate leave to do that with this witness.

    10-301-02

  241. Jessica Barrow, Counsel (Ott-OPS)

    Thank you. The number for that is HRF1560. (VIDEO PLAYBACK)

    10-301-14

  242. Jessica Barrow, Counsel (Ott-OPS)

    Superintendent Drummond, have you seen this video before?

    10-301-17

  243. Jessica Barrow, Counsel (Ott-OPS)

    And are you able to tell us, based on what you are seeing here, where this video was taken?

    10-301-20

  244. Jessica Barrow, Counsel (Ott-OPS)

    Before I continue the video, can you give us some context as to -- we've heard already about the group of protesters that were located there, but can you give us some additional context about the type of behaviour that was seen throughout the protest at this location?

    10-301-24

  245. Jessica Barrow, Counsel (Ott-OPS)

    All right. Perhaps we can just continue the video. (VIDEO PLAYBACK)

    10-302-15

  246. Jessica Barrow, Counsel (Ott-OPS)

    Thank you. What do you observe happening there?

    10-302-18

  247. Jessica Barrow, Counsel (Ott-OPS)

    Were any reports filed in relation to this incident?

    10-303-12

  248. Jessica Barrow, Counsel (Ott-OPS)

    You said that the officer received medical attention.

    10-303-18

  249. Jessica Barrow, Counsel (Ott-OPS)

    In relation to this incident?

    10-303-22

  250. Jessica Barrow, Counsel (Ott-OPS)

    Okay, those are my questions. Thanks very much, Superintendent.

    10-303-26

  251. Jessica Barrow, Counsel (Ott-OPS)

    Thank you, Mr. Commissioner. This is Jessica Barrow for the Ottawa Police Service. Our questions have already been canvassed, so we have nothing further for this witness. Thank you.

    14-105-20

  252. Jessica Barrow, Counsel (Ott-OPS)

    Thank you, Mr. Commissioner. I wonder if I could have access to earphones for the witness just because I will be asking my questions in English.

    14-218-18

  253. Jessica Barrow, Counsel (Ott-OPS)

    If the witness could have access to earphones just because I’ll be asking questions in English.

    14-218-23

  254. Jessica Barrow, Counsel (Ott-OPS)

    Good afternoon. My name is Jessica Barrow, and I’m counsel for the Ottawa Police Service. I just have a couple of questions for you. I believe you went over this a couple of times, but just to be clear, you were not at the intersection of Rideau and Sussex at any time during the course of the events. Is that fair?

    14-219-02

  255. Jessica Barrow, Counsel (Ott-OPS)

    Are you getting the translation?

    14-219-12

  256. Jessica Barrow, Counsel (Ott-OPS)

    Apologies. There’s a bit of a delay.

    14-219-18

  257. Jessica Barrow, Counsel (Ott-OPS)

    Can you hear me?

    14-219-23

  258. Jessica Barrow, Counsel (Ott-OPS)

    There we go. Thank you. So I think I have the answer to this question now multiple times, but just to be clear since you didn’t perhaps understand my full question the previous time. You, yourself, were never at the intersection of Rideau and Sussex throughout the events of the convoy. Is that correct?

    14-219-25

  259. Jessica Barrow, Counsel (Ott-OPS)

    But you weren’t stationed there for any length of time, I think was your evidence; correct?

    14-220-11

  260. Jessica Barrow, Counsel (Ott-OPS)

    And so you wouldn’t -- you wouldn’t have any firsthand knowledge of the behaviour of the protestors that were at that intersection?

    14-220-15

  261. Jessica Barrow, Counsel (Ott-OPS)

    And you had testified that Farfadaas didn’t necessarily have control over who may have identified themselves as members of Farfadaas. Is that correct?

    14-220-19

  262. Jessica Barrow, Counsel (Ott-OPS)

    Okay. Thank you. And do I have it correct that you were not downtown Ottawa on February 18th and for the weekend that followed February 18th?

    14-220-25

  263. Jessica Barrow, Counsel (Ott-OPS)

    Okay. So you have no first- hand knowledge then as to the arrest that occurred on February 18th to 20th in Downtown Ottawa.

    14-221-08

  264. Jessica Barrow, Counsel (Ott-OPS)

    And so, more specifically, you don’t have any first-hand knowledge of the behaviour of police officers in the course of those arrests.

    14-221-12

  265. Jessica Barrow, Counsel (Ott-OPS)

    But in terms of first-hand knowledge or observations, you don’t have any of that — is that correct?

    14-221-19

  266. Jessica Barrow, Counsel (Ott-OPS)

    Okay. And you referenced violence on the part of the police. If I were to tell you that no disciplinary and/or criminal charges were filed in relation to members of the Ottawa Police Service, would you have any information to the contrary?

    14-221-23

  267. Jessica Barrow, Counsel (Ott-OPS)

    So, when you were referring to violence on the part of the police, you were referring either to conversations with friends or to things you’ve seen in the media but not any first-hand observations.

    14-222-11

  268. Jessica Barrow, Counsel (Ott-OPS)

    Okay. Thank you. Those are my questions.

    14-222-16

  269. Jessica Barrow, Counsel (Ott-OPS)

    I have no questions, sir. Thank you.

    14-307-25

  270. Jessica Barrow, Counsel (Ott-OPS)

    Good afternoon, Mr. Wilson. My name is Jessica Barrow, and I’m counsel for the Ottawa Police Service. I just have a couple of points I want to walk through with you. So, first of all, I want to make sure that the record is very clear about who you do represent and who you do not represent. So as the representative for Freedom Corp., you represent only those organizers that I believe you listed earlier in relation to Freedom Corp., and not other participants in the convoy; correct?

    15-095-22

  271. Jessica Barrow, Counsel (Ott-OPS)

    And so, specifically, you do not represent Pat King or James Bauder?

    15-096-06

  272. Jessica Barrow, Counsel (Ott-OPS)

    And you would agree with me that both Pat King and James Bauder were espousing views that your clients disagreed with; is that fair?

    15-096-09

  273. Jessica Barrow, Counsel (Ott-OPS)

    Okay.

    15-096-13

  274. Jessica Barrow, Counsel (Ott-OPS)

    And we saw specific evidence of them kind of rejecting the views of Pat King and James Bauder; is that fair?

    15-096-16

  275. Jessica Barrow, Counsel (Ott-OPS)

    Right. So speaking of violence, you indicated that at the time you sort of advertised on TikTok that people should come to this city. It was your view that -- that that was because it was a lawful and peaceful protest in Ottawa; is that fair?

    15-096-27

  276. Jessica Barrow, Counsel (Ott-OPS)

    So you were aware, however, that -- and there were multiple warning to that effect -- that arrests were going to be taking place very shortly; correct?

    15-097-17

  277. Jessica Barrow, Counsel (Ott-OPS)

    And so when you’re speaking of peacefulness and lawfulness, I take it you’re not referring to those individuals that were charged with criminal offences prior to that date in relation to violence, or threats, or weapons?

    15-097-23

  278. Jessica Barrow, Counsel (Ott-OPS)

    So I believe you’ve seen the institutional report from the Ottawa Police Service. It’s been part of -- made part of the evidence.

    15-098-02

  279. Jessica Barrow, Counsel (Ott-OPS)

    And would you disagree with me that multiple charges were laid prior to that TikTok video in relation to criminal offences that related to violence of threatening behaviour or weapons?

    15-098-07

  280. Jessica Barrow, Counsel (Ott-OPS)

    Okay, but my specific question was, when you’re referring to a “peaceful protest”, I take it you’re not referring to the people who were engaged in criminal behaviour that was obviously deemed not to be peaceful?

    15-098-22

  281. Jessica Barrow, Counsel (Ott-OPS)

    I’m going to move onto the deal with city officials. We’ve heard quite a bit of testimony about that and I think it’s clear that your understanding of the deal always was that some trucks would move onto Wellington -- and I think your evidence was around 25 percent -- and then the rest would leave the city core; is that correct?

    15-099-02

  282. Jessica Barrow, Counsel (Ott-OPS)

    Right. I want to bring you to HRF00000513 at page 52. And just for your reference, these are the text message between you and Mr. French.

    15-099-09

  283. Jessica Barrow, Counsel (Ott-OPS)

    And actually, could we go to page 59? I apologize, Mr. Clerk. And so we just heard very briefly from you in relation to the Tweet that went out -- I think if you scroll down a little bit -- and that’s the Tweet that’s being referenced, right? This is an article about the Tweet where it comes from Tamara’s account that it’s a denial of the deal; is that correct?

    15-099-13

  284. Jessica Barrow, Counsel (Ott-OPS)

    And so regardless of who ultimately authored the Tweet, it was coming from Ms. Lich’s Twitter account; correct?

    15-099-22

  285. Jessica Barrow, Counsel (Ott-OPS)

    But it -- in terms of how the public received it ---

    15-099-27

  286. Jessica Barrow, Counsel (Ott-OPS)

    --- it came from Ms. Lich’s account, right?

    15-100-02

  287. Jessica Barrow, Counsel (Ott-OPS)

    Can we just scroll down a little bit please?

    15-100-17

  288. Jessica Barrow, Counsel (Ott-OPS)

    And if you keep going down - --

    15-100-20

  289. Jessica Barrow, Counsel (Ott-OPS)

    No, I want to -- I think if we keep going down -- sorry, right there, yeah. So this is Dean French saying: "It was posted two hours ago and no correction yet." So it does take some time, right, for the Tweet to get corrected? I recognize there may have been some inner workings going on but it takes at least a few hours for that get correct; is that fair?

    15-100-23

  290. Jessica Barrow, Counsel (Ott-OPS)

    Okay. Can you ---

    15-101-05

  291. Jessica Barrow, Counsel (Ott-OPS)

    And there is -- I won’t take you through the whole exchange just to save time but there is an acknowledgement from Mr. French where he’s saying, “It would have been nice had it occurred prior to the 11 o’clock news.” So would agree that it didn’t get corrected prior to the 11 o’clock news; is that correct?

    15-101-13

  292. Jessica Barrow, Counsel (Ott-OPS)

    Would it be fair to say that through this text exchange -- and I can walk you through it if need be but to save time -- that Mr. French was expressing concerns about the impact this Tweet would have on the legitimacy of the deal, publicly?

    15-101-23

  293. Jessica Barrow, Counsel (Ott-OPS)

    Yeah, you shared those concerns?

    15-102-01

  294. Jessica Barrow, Counsel (Ott-OPS)

    And you would agree that because of that miscommunication, it would have created a lack of clarity to those following that account about whether there was or there was not a deal; is that fair?

    15-102-15

  295. Jessica Barrow, Counsel (Ott-OPS)

    But not withstanding that plan that may have been engaged, we did here from Ms. Belton yesterday that she was of the view at that time that it was fake news. In fact, she put a video out on TikTok that said it was fake news; is that correct?

    15-103-01

  296. Jessica Barrow, Counsel (Ott-OPS)

    Right.

    15-103-08

  297. Jessica Barrow, Counsel (Ott-OPS)

    And so, even at that time, there was still a lack of clarity even amongst organizers as to whether there was or was not a deal?

    15-103-10

  298. Jessica Barrow, Counsel (Ott-OPS)

    Sure, there may be emails but the TikTok video was put out to whomever Ms. Belton’s following consisted of; correct?

    15-103-17

  299. Jessica Barrow, Counsel (Ott-OPS)

    Right. And so I just want to bring up -- you mentioned that the flyer that got circulated. Could we bring that up, please? That’s HRF1259. If we could scroll down to the bottom of the notice here, we -- this is obviously the notice we saw earlier that got circulated; correct? Sorry, if we could go -- yes, right there is perfect. Is this the correct version?

    15-103-21

  300. Jessica Barrow, Counsel (Ott-OPS)

    And so we ---

    15-104-01

  301. Jessica Barrow, Counsel (Ott-OPS)

    Okay.

    15-104-04

  302. Jessica Barrow, Counsel (Ott-OPS)

    And so we see here that it says -- sorry, that’s perfect: "The truckers on the Freedom Convoy 2022 board plan to start repositioning our trucks forward on Monday to consolidate our protest to the streets in front of Parliament. There is also room for trucks to relocate to 88." That's the site off -- out of the city; correct?

    15-104-06

  303. Jessica Barrow, Counsel (Ott-OPS)

    Would you agree with me that nowhere in this letter does it say that 75 percent of the trucks are going to have to leave the city as part of this deal?

    15-104-18

  304. Jessica Barrow, Counsel (Ott-OPS)

    Right. So there may have been a lack of clarity about that issue as well?

    15-104-22

  305. Jessica Barrow, Counsel (Ott-OPS)

    Fair enough. But you would agree, and we saw evidence of that in the video at Rideau and Sussex, you would agree that where there was a lack of clarity about what the police were up to, it created challenges for the police in managing the situation; is that a fair assessment?

    15-105-08

  306. Jessica Barrow, Counsel (Ott-OPS)

    And the PLT were alongside doing that as well, correct, in terms of trying to get truckers to move in response to the deal?

    15-106-04

  307. Jessica Barrow, Counsel (Ott-OPS)

    But I think after that miscommunication was clarified, PLT did work with protesters and ultimately some trucks did move; correct?

    15-106-27

  308. Jessica Barrow, Counsel (Ott-OPS)

    No, I'm talking about in general in response to the City deal. Some trucks moved Tuesday; yes?

    15-107-03

  309. Jessica Barrow, Counsel (Ott-OPS)

    Yeah.

    15-107-07

  310. Jessica Barrow, Counsel (Ott-OPS)

    Could I just ask one more -- -

    15-107-19

  311. Jessica Barrow, Counsel (Ott-OPS)

    --- Mr. Commissioner?

    15-107-23

  312. Jessica Barrow, Counsel (Ott-OPS)

    Thank you. You were here when Superintendent Drummond testified, and he testified that there were challenges with getting some of the truckers to move in response to that deal. Do you have any reason to disbelieve that evidence from Superintendent Drummond?

    15-107-25

  313. Jessica Barrow, Counsel (Ott-OPS)

    And you testified that you were taking that on faith; is that correct?

    15-108-07

  314. Jessica Barrow, Counsel (Ott-OPS)

    Thank you. Those are my questions.

    15-108-11

  315. Jessica Barrow, Counsel (Ott-OPS)

    And thank you for the indulgence.

    15-108-14

  316. Jessica Barrow, Counsel (Ott-OPS)

    I'm sorry for interrupting, Mr. Commissioner, but you may have missed Ottawa Police on the list.

    15-191-20

  317. Jessica Barrow, Counsel (Ott-OPS)

    Sure.

    15-191-25

  318. Jessica Barrow, Counsel (Ott-OPS)

    Good afternoon. My name is Jessica Barrow, and as you've now heard, I am counsel for the Ottawa Police Service.

    15-192-07

  319. Jessica Barrow, Counsel (Ott-OPS)

    I just have a couple of questions, and I wonder if we can start with the document OPS14504. Have you seen this document before?

    15-192-11

  320. Jessica Barrow, Counsel (Ott-OPS)

    If you read through it, and obviously we can give you a minute, it's a document that was -- we've heard was circulated to the protesters and it's dated February 17th. It was circulated by the Ottawa Police Service.

    15-192-15

  321. Jessica Barrow, Counsel (Ott-OPS)

    So you testified earlier that perhaps there was a lack of clarity around whether you could be in the red zone on foot at this point, but that it was your -- it was your understanding that you could not be there with a vehicle; is that correct? Do I have that correct?

    15-192-25

  322. Jessica Barrow, Counsel (Ott-OPS)

    Okay. Well, let's take a look at this document then. If we could scroll to the top a little bit? It says we want to inform you that, "You will face severe penalties under provincial and federal legislation if you do not cease further unlawful activity and remove your vehicle and your property immediately from all unlawful protest sites." And then if we scroll down a little, it says you may be arrested, your vehicle could be seized, a few other issues. Those delivering -- you can see at the bottom, "Those delivering fuel and other supplies can be charged. Persons travelling to the unlawful protest sites to participate or support the unlawful demonstration can be charged." So does that perhaps clarify the question of whether you could be there at this point in time on February 17th?

    15-193-09

  323. Jessica Barrow, Counsel (Ott-OPS)

    Right. So you’re getting an interpretation from your lawyer ---

    15-194-07

  324. Jessica Barrow, Counsel (Ott-OPS)

    --- that the Ottawa Police are circulating information that you’re choosing not to read that is telling you, that if you continue to stay here, you may get arrested; is that fair?

    15-194-11

  325. Jessica Barrow, Counsel (Ott-OPS)

    So I respect the fact that you may have been operating on legal advice, but I guess my question to you is, it wasn’t a question of there being a lack of clarity from the Ottawa Police Service, and in fact it was just that you disagreed with the direction of the Ottawa Police Service?

    15-195-05

  326. Jessica Barrow, Counsel (Ott-OPS)

    Were you aware that there was also social media posts in relation to these warnings?

    15-195-22

  327. Jessica Barrow, Counsel (Ott-OPS)

    Were you monitoring the Ottawa Police Service’s social media?

    15-195-25

  328. Jessica Barrow, Counsel (Ott-OPS)

    Okay. You indicated -- you referred to police violence ---

    15-195-28

  329. Jessica Barrow, Counsel (Ott-OPS)

    --- starting on the –- I presume on the 18th of February; correct?

    15-196-03

  330. Jessica Barrow, Counsel (Ott-OPS)

    And you indicated that you were watching that from your hotel room?

    15-196-06

  331. Jessica Barrow, Counsel (Ott-OPS)

    So then you would have heard prior to the arrest taking place multiple verbal warnings from police officers indicating that if people didn’t depart, they risked being arrested; is that ---

    15-196-10

  332. Jessica Barrow, Counsel (Ott-OPS)

    And so if there’s evidence to suggest that there were sort of loud speakers or whatever we’re calling them, indicating that people needed to leave or they could be arrested; you just didn’t hear that?

    15-196-23

  333. Jessica Barrow, Counsel (Ott-OPS)

    And notwithstanding that the police were obviously present and ready to arrest because they weren’t leaving, they weren’t leaving, correct?

    15-197-01

  334. Jessica Barrow, Counsel (Ott-OPS)

    Okay. Thank you. Those are my questions.

    15-197-05

  335. Jessica Barrow, Counsel (Ott-OPS)

    The Ottawa Police Service has no questions. Thanks very much, Commissioner.

    15-267-19

  336. Jessica Barrow, Counsel (Ott-OPS)

    Good afternoon, Mr. MacKenzie. My name is Jessica Barrow, and I am counsel for the Ottawa Police Service. Can you see and hear me all right?

    17-207-11

  337. Jessica Barrow, Counsel (Ott-OPS)

    Excellent. I’m going to start with something that you testified to earlier, and you indicated that in the lead-up to the events in Ottawa you were of the view that this was not going to be what you referred to as an in-and-out event. But just to be clear, you were not one of the organizers of this event; correct?

    17-207-16

  338. Jessica Barrow, Counsel (Ott-OPS)

    So you really had no knowledge as to the specific intentions of the organizers, except for whatever, perhaps, you were seeing online; is that fair?

    17-208-08

  339. Jessica Barrow, Counsel (Ott-OPS)

    Right. But with respect to your comment, in terms of this not being an in-and-out event, ---

    17-208-22

  340. Jessica Barrow, Counsel (Ott-OPS)

    --- are you aware that the organizers, or some of them testified earlier this week that this event become -- became much more significant than they had really anticipated?

    17-208-26

  341. Jessica Barrow, Counsel (Ott-OPS)

    Are you aware that, similarly, that some of the organizers testified that they had not anticipated staying as long as they ultimately did?

    17-209-10

  342. Jessica Barrow, Counsel (Ott-OPS)

    Okay. I’m going to move on to the issue of social media. Obviously, we heard some testimony from you today about your particular use of social media. Would you agree with me that social media is a tool that some people use to influence the actions of others?

    17-209-14

  343. Jessica Barrow, Counsel (Ott-OPS)

    In fact, it’s actually a career now, being a social media influencer?

    17-209-21

  344. Jessica Barrow, Counsel (Ott-OPS)

    And it’s a tool that’s used to encourage people to buy things or used for social advocacy?

    17-209-25

  345. Jessica Barrow, Counsel (Ott-OPS)

    So then I take it you would agree with me that social media has the power, both unintentionally and intentionally, to influence the actions of others?

    17-210-06

  346. Jessica Barrow, Counsel (Ott-OPS)

    I was speaking specifically to social media influencers, but I'm happy to be more clear if that's required.

    17-210-23

  347. Jessica Barrow, Counsel (Ott-OPS)

    Sure.

    17-211-01

  348. Jessica Barrow, Counsel (Ott-OPS)

    Happy to. So to be clear, Mr. MacKenzie, I'm speaking obviously specifically to the users that are using social media. And in terms of influencing others, my question was would you agree with me that those using social media can both intentionally and unintentionally influence others?

    17-211-04

  349. Jessica Barrow, Counsel (Ott-OPS)

    And you indicated earlier that depending on the platform and depending on the specific post that anywhere between tens of thousands to hundreds of thousands of people have followed you.

    17-211-16

  350. Jessica Barrow, Counsel (Ott-OPS)

    I think you may have indicated that one of your YouTube videos may have garnered up to half-a-million views. Do I have that incorrect?

    17-211-23

  351. Jessica Barrow, Counsel (Ott-OPS)

    Okay. So I'm not going to take you to this specific document, but for the record, it's OPP835, and it's a document published by the Canadian Anti-Hate Network, which I take from your earlier testimony you disagree with, but it describes: "Diagolon, also referred to as Plaid Army, as a conspiracy-based network that is increasingly evolving into a militia compromising neo-fascists who anticipate a violent revolution which they will seize power." (As read) I take it you disagree with that assessment of the organisation. Is that fair?

    17-211-28

  352. Jessica Barrow, Counsel (Ott-OPS)

    Fair enough. But I take it you would agree with me that at least some people might interpret your messaging in that way because obviously the Canadian Anti-Hate Network does?

    17-212-18

  353. Jessica Barrow, Counsel (Ott-OPS)

    Fair enough. I'll just ask one more question because I believe I'm getting the signal that I'm out of time.

    17-212-28

  354. Jessica Barrow, Counsel (Ott-OPS)

    But as a follow-up to that, there were a few veiled references to violence that we saw earlier counsel take you to, and you indicated in response to those that it certainly wasn't your intention to promote violence and that your followers would know that. Is that a fair assessment of your answer?

    17-213-04

  355. Jessica Barrow, Counsel (Ott-OPS)

    But it's true that you have not obviously spoken to all of your followers; right?

    17-213-11

  356. Jessica Barrow, Counsel (Ott-OPS)

    And so you obviously couldn't know how they're interpreting your message?

    17-213-18

  357. Jessica Barrow, Counsel (Ott-OPS)

    Okay. Thank you, those are my questions.

    17-213-21

  358. Jessica Barrow, Counsel (Ott-OPS)

    Good afternoon, Superintendent. I’m Jessica Barrow. I’m counsel for the Ottawa Police Service.

    19-142-26

  359. Jessica Barrow, Counsel (Ott-OPS)

    I just wanted to clarify one quick thing with you that came out of your conversation with Mr. Curry, and that’s the change that you made this morning to your witness statement.

    19-143-02

  360. Jessica Barrow, Counsel (Ott-OPS)

    So just to make sure I have it correct, what you indicated this morning was that you had a conversation with Commissioner Carrique as well as the Deputy Commissioner ---

    19-143-07

  361. Jessica Barrow, Counsel (Ott-OPS)

    --- in relation to whether to stand down the Windsor operation.

    19-143-12

  362. Jessica Barrow, Counsel (Ott-OPS)

    And as a result of that conversation, you ultimately decided to revert course and continue with the Windsor operation; correct?

    19-143-15

  363. Jessica Barrow, Counsel (Ott-OPS)

    And just so that I understand it, the reason for that was because you obtained new information in the course of that conversation; correct?

    19-143-19

  364. Jessica Barrow, Counsel (Ott-OPS)

    And you couldn’t otherwise have had that information previously because you were in charge of the Windsor operation.

    19-143-23

  365. Jessica Barrow, Counsel (Ott-OPS)

    And you had limited information or, I think, line of sight into that operation in Ottawa.

    19-143-27

  366. Jessica Barrow, Counsel (Ott-OPS)

    And so it was less a question of being directive and more about sharing information with you that you couldn’t otherwise have had prior to that meeting.

    19-144-03

  367. Jessica Barrow, Counsel (Ott-OPS)

    And so as a result of that meeting, you decided that the risks you initially were concerned about were not concerns after all and you could proceed with your operation.

    19-144-08

  368. Jessica Barrow, Counsel (Ott-OPS)

    Okay. Thank you. Those are my questions.

    19-144-13

  369. Jessica Barrow, Counsel (Ott-OPS)

    Good afternoon to you both. My name is Jessica Barrow and I’m one of the counsel to the Ottawa Police Service. My questions will be directed to you, Mr. Stewart. I just want to start by discussing some of the information that was known to Public Safety prior to the arrival of the convoy, and I know you went through some of that already with Commission Counsel, but I wanted to clarify a couple of things. So you indicated in your witness statement that there were challenges in obtaining information in relation to the convoy because the novelty of the events made it difficult to distinguish between things seen on social media that were credible versus not credible. Is that correct?

    22-136-17

  370. Jessica Barrow, Counsel (Ott-OPS)

    And in fact, you testified this morning that because of the organic nature of the events, it was difficult to obtain what you referred to as “good intel”? Correct?

    22-137-05

  371. Jessica Barrow, Counsel (Ott-OPS)

    And you would agree with me that these would have been challenges that all law enforcement agencies would have been facing as well; correct?

    22-137-10

  372. Jessica Barrow, Counsel (Ott-OPS)

    So Commission Counsel took you to one of the key points documents, and I want to take you toa couple as well. I’ll start with January 26. And Mr. Clerk, the number is PB.CAN.701. And if we could scroll down to page 2 towards the bottom of the page? In the third to bottom bullet, it says: “Some supporters suggested they would not leave Ottawa until vaccine mandates for public servants, Canadian travelers and cross-border truckers are lifted.” Do you recall seeing that?

    22-137-14

  373. Jessica Barrow, Counsel (Ott-OPS)

    And so this suggests that there was at least information available to you and others to the effect that some protestors may not leave Ottawa; correct?

    22-137-26

  374. Jessica Barrow, Counsel (Ott-OPS)

    But again, as you’ve indicated, with open-source information, it’s difficult to know whether that information was credible or not; correct?

    22-138-02

  375. Jessica Barrow, Counsel (Ott-OPS)

    And the RCMP was presumably privy to this same information as well?

    22-138-09

  376. Jessica Barrow, Counsel (Ott-OPS)

    And you indicated in your witness statement, at page 10, and I’m happy to turn it up if necessary, but I suspect you’ll recall saying this, that if the RCMP had intelligence that the convoy was planning on becoming entrenched in Ottawa and failed to report that information up to Public Safety, that you would have considered that to be problematic; correct?

    22-138-12

  377. Jessica Barrow, Counsel (Ott-OPS)

    And notwithstanding the fact that we see that there’s at least some information to suggest that protestors might stay, the RCMP was similarly not raising any kind of alarm bells around that; correct?

    22-138-20

  378. Jessica Barrow, Counsel (Ott-OPS)

    And if we scroll to the top of the document, if you go down a -- yes. The first sentence there: “The following relates to a planned peaceful demonstration in Ottawa on 28-29 [January].” So even with that information in mind, you’re still planning for, you know, a couple of days; correct?

    22-138-25

  379. Jessica Barrow, Counsel (Ott-OPS)

    Okay. So I want to turn back to the one on the 27th, which you did speak about briefly with Commission Counsel. That number, Mr. Clerk, is PB.CAN703. And if we could go to page 3, please? That’s perfect. Thank you. My friend took you to one of the bullets in the bolded section that we see here, but I want to turn to some of the bullets that precede that one bullet. So what we can see here is a number of directions that appear to have been provided by OPS in relation to where the trucks could park when they arrive; right?

    22-139-06

  380. Jessica Barrow, Counsel (Ott-OPS)

    And is it your understanding that this information was coming from INTERSECT?

    22-139-18

  381. Jessica Barrow, Counsel (Ott-OPS)

    Okay. And so what we see is a number of different options. The first one we see is from the west, they’re being directed to Sir John A. MacDonald Parkway; correct?

    22-139-22

  382. Jessica Barrow, Counsel (Ott-OPS)

    And then following this, Kent and Metcalfe exits can be used, the George-Étienne Parkway can be used, and then ultimately we see in the third bullet there that Wellington will be closed, but there will be three lanes dedicated to the demonstration; correct?

    22-139-27

  383. Jessica Barrow, Counsel (Ott-OPS)

    And so you were provided information prior to the convoy’s arrival that the OPS plan was to allow at least some of the truckers to park downtown; correct?

    22-140-05

  384. Jessica Barrow, Counsel (Ott-OPS)

    And I’m just going to bring you to the INTERSECT document. That one is PB.CAN1234. If you could scroll down a little bit, please? So this is presumably then the INTERSECT information that ultimately we see coming through that key points document? Is that fair?

    22-140-10

  385. Jessica Barrow, Counsel (Ott-OPS)

    and so again, we see here that there is information to suggest that OPS’ plan involved having some truckers park on Wellington; correct?

    22-140-18

  386. Jessica Barrow, Counsel (Ott-OPS)

    And so again, this didn’t raise any kind of alarm bells from your perspective, that this was the plan for OPS; right?

    22-140-22

  387. Jessica Barrow, Counsel (Ott-OPS)

    And again, this information would have been available to RCMP?

    22-140-26

  388. Jessica Barrow, Counsel (Ott-OPS)

    And similarly, RCMP didn’t raise any concerns with you in relation to the plan?

    22-141-01

  389. Jessica Barrow, Counsel (Ott-OPS)

    And you understood at this point, and I’m happy to turn back to the previous document if necessary, but I think you would agree that this was a group at this point that was cooperative, and from your perspective, was exercising their democratic right to peaceful protest; correct?

    22-141-04

  390. Jessica Barrow, Counsel (Ott-OPS)

    Mr. Clerk, could we turn to SAS12, please? So these appear to be the minutes or notes from a deputy minister's call on February 7th. Do you recall that meeting?

    22-141-10

  391. Jessica Barrow, Counsel (Ott-OPS)

    And so I just want to take you through a couple of the comments that you've made in here on February 7th. The first bullet references, "A protest of significant proportions we have not seen before." Do you recall saying that?

    22-141-16

  392. Jessica Barrow, Counsel (Ott-OPS)

    And if we can go down to the third bullet point, please? And in there, we see, "Setting a standard to worry about. Setting a standard for behaviour. How to go above the norms and laws." So I take it you agree that you made those comments?

    22-141-23

  393. Jessica Barrow, Counsel (Ott-OPS)

    And what you meant by this comment was that what Ottawa was doing was unlike any protests that any city in Canada had ever seen before; is that correct?

    22-142-02

  394. Jessica Barrow, Counsel (Ott-OPS)

    And specifically, you were saying that the behaviour of these protesters was unlike anything seen in previous protests?

    22-142-06

  395. Jessica Barrow, Counsel (Ott-OPS)

    Right, as well as the honking, some of the harassment that we saw exhibited by ---

    22-142-13

  396. Jessica Barrow, Counsel (Ott-OPS)

    The behaviours of some of the protesters ---

    22-142-17

  397. Jessica Barrow, Counsel (Ott-OPS)

    --- as well as the trucks, I take it you're saying. And so the protesters were prepared, from your perspective, to disregard the laws as well as the social norms of behaviour that we had come to expect in a city and other places as well with respect to the behaviour of protesters; is that fair?

    22-142-20

  398. Jessica Barrow, Counsel (Ott-OPS)

    And when we walked through - - I took you to two of the key points documents, and I take it you would agree with me that the specific references to this idea of honking or lawlessness or the departure from social norms, there wasn’t really any indication that the protesters were going to engage in that type of behaviour; is that fair?

    22-142-28

  399. Jessica Barrow, Counsel (Ott-OPS)

    And in fact, as far as you're aware, they weren’t engaging in that type of behaviour before they arrived in Ottawa?

    22-143-07

  400. Jessica Barrow, Counsel (Ott-OPS)

    Fair enough. And so you would agree with me then that the behaviour was unexpected?

    22-143-13

  401. Jessica Barrow, Counsel (Ott-OPS)

    And I don’t need to pull it up, I don't think, but please correct me if that’s not the case, but on page 12 of your witness statement, you indicated that the other cities that subsequently had similar events were able to learn from what was seen in Ottawa. Do you recall saying that?

    22-143-16

  402. Jessica Barrow, Counsel (Ott-OPS)

    And so you would agree with me that it's because of what happened in Ottawa that other cities may have been able to prepare in a different way?

    22-143-22

  403. Jessica Barrow, Counsel (Ott-OPS)

    I just have one last issue I want to raise, and that’s in relation to the engagement proposal that you went through with Commission counsel earlier. And so I wonder if we could pull up OPP142, Mr. Clerk? And if we could scroll down to page 2, we'll see an email between yourself and Inspector Beaudin, and that’s setting out some considerations in relation to the proposal. If we can -- I think it might be up a little bit. Yes, there. Do you recall seeing this email with all the considerations?

    22-143-26

  404. Jessica Barrow, Counsel (Ott-OPS)

    And what we see from Inspector Beaudin is that he was of the view that this could constitute a win of sorts for protesters in terms of providing an exit strategy; is that -- do you recall that?

    22-144-11

  405. Jessica Barrow, Counsel (Ott-OPS)

    And would you agree with me that the comments that come from Inspector Beaudin involve an advocacy for a measured approach consistent with the national framework rather than simply resorting first to enforcement?

    22-144-16

  406. Jessica Barrow, Counsel (Ott-OPS)

    And in your witness statement, you indicated at page 18 that there were particular difficulties, actually, to enforcement operations in Ottawa. Do you recall saying that?

    22-144-21

  407. Jessica Barrow, Counsel (Ott-OPS)

    And that was because the protesters were very entrenched and they were aggressive towards the police?

    22-144-26

  408. Jessica Barrow, Counsel (Ott-OPS)

    And so the proposal was presumably aimed at trying to change that posture; is that fair?

    22-145-02

  409. Jessica Barrow, Counsel (Ott-OPS)

    Okay. And you indicated in your witness statement that you did not share the proposal with OPS; is that right?

    22-145-05

  410. Jessica Barrow, Counsel (Ott-OPS)

    Okay. I just ---

    22-145-13

  411. Jessica Barrow, Counsel (Ott-OPS)

    You did not consult them. So maybe we'll just bring up one last document. I'm almost completed, Mr. Commissioner. OPP633, just to provide some clarity on this point.

    22-145-15

  412. Jessica Barrow, Counsel (Ott-OPS)

    If you wouldn't mind.

    22-145-22

  413. Jessica Barrow, Counsel (Ott-OPS)

    Thank you very much. And so it's just that first email we see from Inspector Beaudin, and he's indicating that it's the opinion of Deputy Chief Ferguson that the letter go to her and she will ensure the letter is disseminated to the proper people. So you would agree with me that Deputy Chief Ferguson was both aware and approved this, correct?

    22-145-25

  414. Jessica Barrow, Counsel (Ott-OPS)

    Yes. Okay, thank you. Those are my questions, and thank you, Mr. Commissioner.

    22-146-05

  415. Jessica Barrow, Counsel (Ott-OPS)

    Good afternoon to you both. My name is Jessica Barrow, and I’m counsel to OPS. My questions are for you, Deputy, as well. I want to focus primarily on the enforcement strategy and how it impacted or didn’t impact operations on the ground in Ottawa, but I want to touch base on a statement you made in your witness statement, before we get into that. First of all, obviously the enforcement strategy was created after the occupation in Ottawa had been entrenched for some time; is that correct?

    24-223-12

  416. Jessica Barrow, Counsel (Ott-OPS)

    Right. And in your witness statement, you commented on the fact that both Toronto and Quebec City were successfully able to deter occupations from their downtown cores, and that some of the tools they were implemented were similar to what you suggested in the enforcement strategy; is that fair?

    24-223-23

  417. Jessica Barrow, Counsel (Ott-OPS)

    The events in Toronto and Quebec City, however, both occurred after the event in Ottawa was well underway, is that right?

    24-224-02

  418. Jessica Barrow, Counsel (Ott-OPS)

    And so we’ve heard testimony from various other witnesses to the effect that other jurisdictions were able to take lessons from what occurred in Ottawa and apply those lessons to their own planning. I take it you would have no reason to disagree with that.

    24-224-06

  419. Jessica Barrow, Counsel (Ott-OPS)

    And many of the witnesses we have heard from also testified that the tactics used by protesters in Ottawa were unprecedented at the time of the convoy’s arrival in Ottawa, and I take it you similarly would not have any reason to disagree with that evidence?

    24-224-12

  420. Jessica Barrow, Counsel (Ott-OPS)

    Fair enough.

    24-224-21

  421. Jessica Barrow, Counsel (Ott-OPS)

    Right.

    24-224-24

  422. Jessica Barrow, Counsel (Ott-OPS)

    And cities like Toronto and Quebec City enjoyed a benefit that Ottawa did not, and that’s sort of a fuller appreciation of what the group was capable of, what their intentions were, and what police tactics were and were not going to be effective in respect of that; would you agree with that?

    24-224-27

  423. Jessica Barrow, Counsel (Ott-OPS)

    Fair enough. And I think you would also agree with me that the convoys and blockades in the various jurisdictions were all quite different from one another, in terms of their scope; is that fair?

    24-225-08

  424. Jessica Barrow, Counsel (Ott-OPS)

    Of course. And if we look specifically at Ottawa, I think you would agree with me that the size of it, we can agree that there perhaps were similar behaviours but if you look just at sort of the footprint of the protest, it was much larger than any of the others; is that fair?

    24-225-17

  425. Jessica Barrow, Counsel (Ott-OPS)

    Okay, thank you. And so it wouldn’t necessarily be fair to compare the successful use of the strategies from the enforcement strategy by some jurisdictions with what was occurring in Ottawa, given the significant differences; is that fair?

    24-225-26

  426. Jessica Barrow, Counsel (Ott-OPS)

    Sure.

    24-226-06

  427. Jessica Barrow, Counsel (Ott-OPS)

    Of course. So your strategy was intended to address the challenges that OPS was already experiencing, and which others had not yet experienced. Is that fair?

    24-226-13

  428. Jessica Barrow, Counsel (Ott-OPS)

    Right. And so if we look at the specifics of the enforcement strategy, and I don't think we need to turn it up, but I'm happy to if you think that's necessary. It had the messaging component as well as the enforcement component; correct?

    24-226-26

  429. Jessica Barrow, Counsel (Ott-OPS)

    And I think you've testified with respect to the messaging component that the purpose of that component was to communicate the illegality of the actions of the protesters; right?

    24-227-04

  430. Jessica Barrow, Counsel (Ott-OPS)

    Right. And just so that we clear this up in terms of the purpose of that messaging, we've heard a lot of evidence about PLTs. I don't know if you're familiar with the work of PLTs.

    24-227-12

  431. Jessica Barrow, Counsel (Ott-OPS)

    Fair enough. And so we heard a lot of evidence about the purpose of the PLT Program and the need for a measured response and consistent communication as between sort of like corporate communications and what PLT are engaging with on the ground. Do you have any reason to dispute that evidence?

    24-227-18

  432. Jessica Barrow, Counsel (Ott-OPS)

    And so I take it that you wouldn't necessarily say that the communication strategy that you were proposing as part of this -- the strategy that we're talking about here, that it was intended to overshadow the work of PLTs?

    24-227-25

  433. Jessica Barrow, Counsel (Ott-OPS)

    That's correct.

    24-228-05

  434. Jessica Barrow, Counsel (Ott-OPS)

    And so you're talking sort of a global strategy to all protesters and blockaders from coast to coast that may be thinking of engaging in that activity or already are engaging that activity. Is that fair?

    24-228-17

  435. Jessica Barrow, Counsel (Ott-OPS)

    Right.

    24-228-23

  436. Jessica Barrow, Counsel (Ott-OPS)

    But I think you would agree with me that given what we have heard about the importance of PLT work, to the extent that PLT messaging needed to be prioritised over the messaging that you're referencing, those on the ground from an operational perspective would be the best equipped to make that kind of decision?

    24-228-27

  437. Jessica Barrow, Counsel (Ott-OPS)

    So I think we're agreeing, and perhaps just coming at it from slightly different perspectives, but I think ---

    24-229-12

  438. Jessica Barrow, Counsel (Ott-OPS)

    Yeah. So basically what you're saying, if I understand it, is this was a strategic direction. Those that were operationally engaged on the ground would the ones making decisions about how and when to implement the strategies that you were proposing?

    24-229-16

  439. Jessica Barrow, Counsel (Ott-OPS)

    And of course, there's a multitude of reasons for that, but one of those reasons may be that those on the ground obviously would have far more information about what's going on operationally than you would?

    24-230-01

  440. Jessica Barrow, Counsel (Ott-OPS)

    Right. And I think as it relates specifically to enforcement, and you've already addressed this to some extent, there were specific challenges in Ottawa around enforcement due to the sort of hostility of the situation. You would agree with that I take it?

    24-230-18

  441. Jessica Barrow, Counsel (Ott-OPS)

    Right. And if we -- I think you indicated that one of the main goals of the strategy was to identify sort of harsher penalties or identify those that existed, and you thought or hoped that that would disincentivize those from participating or encourage those who were participating to leave. Is that right?

    24-230-27

  442. Jessica Barrow, Counsel (Ott-OPS)

    And obviously, we do know that harsher penalties and more significant enforcement tools do come into place, both through the Ontario legislation and the federal legislation; right?

    24-231-06

  443. Jessica Barrow, Counsel (Ott-OPS)

    Right.

    24-231-14

  444. Jessica Barrow, Counsel (Ott-OPS)

    Right. And so the goal was to either highlight those existing tools, or ultimately, once there were new ones, to highlight those and hopefully there would be a change of behaviour as a result. I'm wrapping up.

    24-231-20

  445. Jessica Barrow, Counsel (Ott-OPS)

    But ultimately, I think you would agree that although that may have had some impact on the numbers in Ottawa, what we saw ultimately was a massive POU operation that was required to remove the majority of the protesters. Is that fair?

    24-231-26

  446. Jessica Barrow, Counsel (Ott-OPS)

    And so even though there were more significant penalties available, the choices that were being made by protesters were primarily not to leave the area.

    24-232-04

  447. Jessica Barrow, Counsel (Ott-OPS)

    Fair enough. I think all I was getting at is that ultimately, I think other witnesses have referred to it as the largest POU operation in Canadian history was required to dismantle the protest notwithstanding that there may have been some impact of the previous measures and that ultimately hundreds of arrests had to occur to clear the area. I take it you wouldn’t disagree with that?

    24-232-22

  448. Jessica Barrow, Counsel (Ott-OPS)

    Thank you. Those are my questions.

    24-233-06

  449. Jessica Barrow, Counsel (Ott-OPS)

    Good afternoon, Minister. My name is Jessica Barrow, and I’m one of the counsel to Ottawa Police Service.

    28-104-27

  450. Jessica Barrow, Counsel (Ott-OPS)

    Prior to the arrival of the convoy, would you agree with me that there was conflicting information about how many protestors may participate in Ottawa as well as how long they may stay?

    28-105-03

  451. Jessica Barrow, Counsel (Ott-OPS)

    Right.

    28-105-09

  452. Jessica Barrow, Counsel (Ott-OPS)

    And so that was a real difficulty from a planning perspective at all levels of government and law enforcement. Is that fair?

    28-105-14

  453. Jessica Barrow, Counsel (Ott-OPS)

    And in fact, you testified earlier that you were concerned that even the intelligence you were receiving from your team maybe didn’t fully capture all of what you were seeing in terms of public narrative. Is that fair?

    28-105-18

  454. Jessica Barrow, Counsel (Ott-OPS)

    And Deputy Minister Stewart testified last week that there was a difficulty amongst the intelligence community at that time in assessing the information that was being received because much of that evidence was open source and there was difficulty ascertaining the credibility of that information. Would you agree with that?

    28-105-24

  455. Jessica Barrow, Counsel (Ott-OPS)

    And so again, that’s something that all levels of law enforcement would have been grappling with at that time.

    28-106-04

  456. Jessica Barrow, Counsel (Ott-OPS)

    And so ultimately, no one really had a very clear picture in advance of the scope of the event as well as the behaviour of the protestors before it arrived. Is that fair?

    28-106-08

  457. Jessica Barrow, Counsel (Ott-OPS)

    And ultimately, what we did see here in Ottawa as well as elsewhere in the country was entirely unprecedented, both in terms of the scope as well as the behaviour we ultimately saw from protestors. Is that correct?

    28-106-21

  458. Jessica Barrow, Counsel (Ott-OPS)

    I want to move on to the police response once the protestors arrived here in Ottawa. And we’ve heard considerable evidence to the effect that when OPS and its partners engaged in ad hoc enforcement actions or ticketing, by-law enforcement, things like that, it could create dangerous situations for officers. We heard about swarming, harassment I think you spoke to earlier. So you would agree that that type of thing was occurring in Ottawa; correct?

    28-106-27

  459. Jessica Barrow, Counsel (Ott-OPS)

    Right. And so that was a real difficulty for law enforcement on the ground, particularly OPS, since that was the bulk of the officers, obviously, at that time, that to be able to engage in any real enforcement was a real challenge as a result of what they were facing in response.

    28-107-21

  460. Jessica Barrow, Counsel (Ott-OPS)

    And that remained the case until they had sufficient resources; correct?

    28-107-27

  461. Jessica Barrow, Counsel (Ott-OPS)

    And at that time, they did not have sufficient resources to really engage in meaningful enforcement in a way that people could maybe see it as meaningful. Is that fair?

    28-108-02

  462. Jessica Barrow, Counsel (Ott-OPS)

    So specifically with respect to the resources, you had obviously agreed that that messaging coming from both OPS and Chief Sloly was from the very beginning, essentially. Once it became apparent that these protestors were not leaving, it became equally apparent that there was insufficient resources. Is that fair?

    28-108-13

  463. Jessica Barrow, Counsel (Ott-OPS)

    And would it be fair to say that any concerns in relation to operational plans or the level of enforcement should not be taken as some kind of suggestion that OPS should have engaged in enforcement action without the resources they needed?

    28-108-21

  464. Jessica Barrow, Counsel (Ott-OPS)

    Right. And so none of the sort of if we could call it criticisms about the lack of enforcement or the lack of a plan should be perceived as a suggestion that there was -- that OPS should have been engaging in enforcement notwithstanding the fact that they didn’t have the resources to do that safely.

    28-109-06

  465. Jessica Barrow, Counsel (Ott-OPS)

    Right.

    28-109-15

  466. Jessica Barrow, Counsel (Ott-OPS)

    And something you said earlier, and I just want to expand on it, if I can, you indicated that it was essentially impossible to police those on Wellington Street. Do you recall making a statement to that effect?

    28-109-20

  467. Jessica Barrow, Counsel (Ott-OPS)

    And that’s because if you compare the sort of lawlessness of the behaviour of the protestors as compared to the resources that were there to deal with that situation, there was a disconnect. Is that fair?

    28-109-28

  468. Jessica Barrow, Counsel (Ott-OPS)

    And so when we talk about the operational plans, and you’ve touched on it a couple of times, would it be fair to say that the reason the plans were required was to ensure that if the resources were provided, there was an understanding by those agencies about how they would be used to safely and productively contribute to an end of the event?

    28-110-11

  469. Jessica Barrow, Counsel (Ott-OPS)

    And so it wasn’t a question of undermining the actions of OPS. It was about ensuring collaboration. Is that fair?

    28-110-19

  470. Jessica Barrow, Counsel (Ott-OPS)

    And there was never any suggestion that OPS should have engaged in an overall operation to end the event before it had the resources to do that safely.

    28-110-23

  471. Jessica Barrow, Counsel (Ott-OPS)

    Okay. I want to move on and quickly discuss a couple of points referenced in your witness statement in relation to the engagement proposal. I don’t think I need to bring up your witness statement, but I’m happy to if that’s necessary. Deputy Minister Stewart testified that the purpose of the draft engagement proposal was to give protestors in Ottawa a potential exit strategy. Do you agree with that statement?

    28-110-28

  472. Jessica Barrow, Counsel (Ott-OPS)

    And that view came from Deputy Minister Stewart’s conversations with Inspector Beaudin, who you may or may not know is an expert from OPP on protestor engagement through his PLT work. Are you aware of that?

    28-111-11

  473. Jessica Barrow, Counsel (Ott-OPS)

    And he also testified, he being Deputy Minister Stewart, that the proposal had buy-in from both OPP and OPS. Were you aware of that?

    28-111-17

  474. Jessica Barrow, Counsel (Ott-OPS)

    And you testified earlier that you saw it to be your job during this time, or perhaps the job of your department, to ensure that law enforcement had both the resources and the tools they required?

    28-111-21

  475. Jessica Barrow, Counsel (Ott-OPS)

    And so in your witness statement, you indicated that there were two issues with respect to why the enforcement, or sorry, the engagement proposal didn’t come to fruition. The first was questions that were left unanswered about the convoy organizers, who they are and who was in charge. And the second related to safety concerns about the person engaged in the proposal. Do you recall saying that?

    28-111-26

  476. Jessica Barrow, Counsel (Ott-OPS)

    Okay. So I just want to pull up a couple documents in relation to that. The first is OTT00005318. If we could scroll to the bottom? So this is an email -- sorry, up a little so we can see who it’s to. Yeah. Sorry, the email at the bottom of the first page. Yes, there. So this is an email from someone at Ottawa Police, Vicky Nelson, to a number of people, including Deputy Minister Stewart. And as you can see, it says: “Good morning, On behalf of General Counsel […] please find attached the list of the convoy leaders and their affiliates.” That’s on February 7th. And then if you scroll to the top, it’s an email back from Mr. Stewart saying, “Thank you”. And so you would agree with me that there is some level of engagement with OPS to get the information your department needs about those convoy organizers and their affiliates to assist with this proposal?

    28-112-07

  477. Jessica Barrow, Counsel (Ott-OPS)

    Thank you. I’m just going to bring up one last document. This one’s PB.NSC.CAN2963. If we go to the second page? Right there. We see the first bullet. “Would the signatory of the letter or the person who goes to the meeting be putting themselves at risk? Is that a big concern?” And this is an email change between yourself and Mr. Stewart, amongst various other people. Does this reflect the concern that you’re referencing in relation to whether there would be a risk to the person engaging with this proposal?

    28-113-08

  478. Jessica Barrow, Counsel (Ott-OPS)

    Right. So if we scroll then -- back up to the first page of the document, it looks like we have the answers to those questions. And if we look at the last -- the second bullet, we see: “The risk to the signatory and government rep at a later [date --] meeting is low, assuming the meeting is virtual.” So again, would you agree that the concern that you’ve raised has been addressed as a result of a conversation between Deputy Minister Stewart and his OPP expert?

    28-113-26

  479. Jessica Barrow, Counsel (Ott-OPS)

    So you said, “I would have,” as though it were hypothetical. Did you ultimately continue that conversation or was a decision made at this point to kind of stop the process?

    28-114-25

  480. Jessica Barrow, Counsel (Ott-OPS)

    So you would say sort of events overtook and the proposal fell by the wayside?

    28-115-10

  481. Jessica Barrow, Counsel (Ott-OPS)

    Okay. Thank you. Those are my questions.

    28-115-21

  482. Jessica Barrow, Counsel (Ott-OPS)

    Good afternoon, Prime Minister. My name is Jessica Barrow, and I am Counsel for the Ottawa Police Service. Prime Minister, we've heard evidence from you about your understanding of intelligence information as well as operational planning at various points throughout the events in Ottawa, and I just want to clarify your role as it relates to that information. And I take it it's not your role as Prime Minister to collect intelligence information; is that correct?

    31-116-27

  483. Jessica Barrow, Counsel (Ott-OPS)

    Similarly, it's not your role to review the details of an operational plan?

    31-117-09

  484. Jessica Barrow, Counsel (Ott-OPS)

    And that's because you rely on highly trained police officers to perform the work that they're best at, which is performing those functions and then it gets briefed up to you; is that fair?

    31-117-13

  485. Jessica Barrow, Counsel (Ott-OPS)

    And I assume that you regularly rely in particular on the intelligence and operational planning expertise of the RCMP as they are the National Police Service; correct?

    31-117-18

  486. Jessica Barrow, Counsel (Ott-OPS)

    And of course, you trust them to perform those functions effectively?

    31-117-23

  487. Jessica Barrow, Counsel (Ott-OPS)

    Okay. So we've heard considerable evidence to date from the Commission that an Integrated Planning Cell arrived in Ottawa on February 8th. Were you aware of that?

    31-117-26

  488. Jessica Barrow, Counsel (Ott-OPS)

    And we also heard that Superintendent Bernier from Ottawa Police Service took over as Event Commander on February 10th and established what he referred to as an Integrated Command Structure, which we heard described from him as including experts from subject matter areas, such as negotiations, public order, intelligence, et cetera. Were you aware of that?

    31-118-04

  489. Jessica Barrow, Counsel (Ott-OPS)

    Okay. And the experts involved in both the Integrated Planning Cell and the ultimate Integrated Command Structure included senior and specially trained officers from OPS, RCMP, OPP and other municipal police services. Would you agree with that?

    31-118-13

  490. Jessica Barrow, Counsel (Ott-OPS)

    And as you indicated, you would, of course, leave it up to those experts to draft, review, and approve Operational Plans. Is that fair?

    31-118-20

  491. Jessica Barrow, Counsel (Ott-OPS)

    Okay. And you certainly wouldn't have had the capacity in your role to engage in any kind of line-by-line review or assessment of the viability of those Operational Plans?

    31-118-24

  492. Jessica Barrow, Counsel (Ott-OPS)

    Okay. And so I want to focus because we've heard a fair bit of evidence about this this morning, in relation to the timeframe of February 12th onwards, and the Operational Plans that existed at that time. You participated in an IRG meeting on February 12th; is that correct?

    31-119-01

  493. Jessica Barrow, Counsel (Ott-OPS)

    And so I'd like to pull up the minutes from that meeting, if we can, it's SSM.NSC.CAN214, please. And in particular, I'm looking for page 6, Mr. Clerk. And so we see in the second paragraph that this is a update from the Minister of Public Safety, and we see at the last sentence of that: "During the discussion, confirmation was obtained that the OPS Chief of police accepted the plan and the Commissioner of the RCMP agreed to be able to provide additional details of that plan at the next call." Do you recall that?

    31-119-08

  494. Jessica Barrow, Counsel (Ott-OPS)

    Right, and then subsequent to that we see that in the middle of the meeting there is confirmation that the OPS Chief has agreed to the plan and that Commissioner Lucki agrees to provide additional details to this group subsequently in relation to the details. Is that fair?

    31-119-28

  495. Jessica Barrow, Counsel (Ott-OPS)

    Okay. And so this was put to Commissioner Lucki in her testimony, and my understanding of her evidence is that she never did subsequently provide the details of that plan to this group on the 13th or otherwise. Would you disagree with that evidence?

    31-120-06

  496. Jessica Barrow, Counsel (Ott-OPS)

    Okay But you didn't ever hear the details of the plan, and she certainly doesn't say in this meeting that from her perspective it was not an adequate plan, she's just saying "I'll provide you an update later."

    31-120-14

  497. Jessica Barrow, Counsel (Ott-OPS)

    Okay. So your understanding of what occurred on the 13th was that you were provided some level of information that led you to believe that there was no complete Operational Plan. Is that fair?

    31-120-23

  498. Jessica Barrow, Counsel (Ott-OPS)

    Right. So -- and I understand that there are various planning timeframes, but I'm specifically talking about the 13th and whether you were provided details of a complete Operational Plan to end the protests in Ottawa?

    31-121-03

  499. Jessica Barrow, Counsel (Ott-OPS)

    Okay. I'd like to bring up OPP1851, please. Okay. So let's just start with the title page. This is called Integrated Mobilization Operational Plan. And if we could scroll down to page 2. You can see at the top that the plan was written by the Integrated Planning Cell that has multiple services listed there, it's dated the 13th. And we see that there is sign-off here from Superintendent Phil Lue of the RCMP, Chief Superintendent Carson Pardy of the OPP, and Acting Superintendent Rob Bernier of the Ottawa Police Service. You see that?

    31-121-11

  500. Jessica Barrow, Counsel (Ott-OPS)

    Okay. And so I just want to -- if you look at the bottom of the screenshot here, you can see that this is a 73-page document. You see that?

    31-121-25

  501. Jessica Barrow, Counsel (Ott-OPS)

    Okay. And so obviously, we don't have time, unfortunately, to fully digest this entire document, but is it fair to say that prior to the police operation on February 18th to 20tgh, as well as prior to the invocation of the Emergencies Act, you had never seen this document?

    31-122-01

  502. Jessica Barrow, Counsel (Ott-OPS)

    Okay.

    31-122-08

  503. Jessica Barrow, Counsel (Ott-OPS)

    Okay.

    31-122-11

  504. Jessica Barrow, Counsel (Ott-OPS)

    Thank you for that clarification. And so you suggested multiple times in your evidence this morning that to your knowledge the Operational Plan that existed at the time of February 13th was by no means an actual plan to actually end the protests in Ottawa. Is that a fair representation of your evidence?

    31-122-14

  505. Jessica Barrow, Counsel (Ott-OPS)

    Okay. And you also testified that it was not a plan that you or the RCMP had confidence in. Is that correct? At least that was your understanding.

    31-122-22

  506. Jessica Barrow, Counsel (Ott-OPS)

    Okay.

    31-122-28

  507. Jessica Barrow, Counsel (Ott-OPS)

    Fair enough. But as you can see here, there is a 73-page document, dated February 13th, that a senior member of the RCMP has signed off on.

    31-123-03

  508. Jessica Barrow, Counsel (Ott-OPS)

    Okay. So if we just scroll down. As I said, we don't have time to review the entire document, but we do have the table of contents here. And so I just want to go through a few components of the parts -- or component parts of the overall plan so that you understand kind of the general scope of it. And so if we scroll down a little bit we see there's a Deployment Plan, right, a reference to the Deployment Plan?

    31-123-07

  509. Jessica Barrow, Counsel (Ott-OPS)

    Yes. So I'm just trying to understand the scope of the plan. Since I only have 10 minutes we can't actually digest the entirety of the plan. So you can see that there is some content in relation to Deployment Plan?

    31-123-19

  510. Jessica Barrow, Counsel (Ott-OPS)

    Yes.

    31-123-25

  511. Jessica Barrow, Counsel (Ott-OPS)

    Well, a description of the Deployment Plan is on it.

    31-123-28

  512. Jessica Barrow, Counsel (Ott-OPS)

    Okay. And then we see a reference to Investigative Plan; correct?

    31-124-03

  513. Jessica Barrow, Counsel (Ott-OPS)

    Right. And so you hadn't read it, obviously, then ---

    31-124-08

  514. Jessica Barrow, Counsel (Ott-OPS)

    Okay. So let's turn to page 8, and we see the Objectives listed. If you could scroll down. And it says: "To facilitate a resolution through de-escalation, graduated measurable and multi-phased response while ensuring the safety of participants, citizen and members of participating agencies and return the City of Ottawa to a state of normality." And so you referenced earlier in relation to the plan that from your understanding all it was was to continue the negotiations essentially that were already taking place; correct?

    31-124-13

  515. Jessica Barrow, Counsel (Ott-OPS)

    Okay. Well, I can tell you ---

    31-125-04

  516. Jessica Barrow, Counsel (Ott-OPS)

    Fair enough.

    31-125-12

  517. Jessica Barrow, Counsel (Ott-OPS)

    Fair enough. Well, I can tell you that the experts on the plan have testified, and they have testified that this was the plan that they were acting on on the weekend of February 18th when they completed the POU operation. Would you have any reason to disagree with that?

    31-125-15

  518. Jessica Barrow, Counsel (Ott-OPS)

    Fair enough. Okay. And I just want to pull ---

    31-125-22

  519. Jessica Barrow, Counsel (Ott-OPS)

    Thank you. And so to circle back to the comments you provided in relation to the readiness of police plans as of the 13th, I take it you would agree with me that perhaps there was a little bit more substance to the plans than you were aware of on the 13th?

    31-125-27

  520. Jessica Barrow, Counsel (Ott-OPS)

    Okay. And we’ve heard evidence that the Ottawa Police were required to acquire approximately 2,200 additional police officers from across the country to support this plan and to successfully complete the POU operation that occurred on the weekend of February 18th. Would you have any reason to disagree with that?

    31-126-06

  521. Jessica Barrow, Counsel (Ott-OPS)

    Fair enough. And you may have heard, or not, this was the largest POU operation in Canadian history? Were you aware?

    31-126-15

  522. Jessica Barrow, Counsel (Ott-OPS)

    Okay. Thank you very much for your time. Those are my questions.

    31-126-20