As a consequence
he applicant's motions and the schedule for the delivery
Facta, the respondent hereby provides its Factum on the Application, which also serves
context for the motions and his responses to the motions.
The respondent submits four responses to this Honourable Court, each
which justifiesthe dismissal
the Application:(a) the
provisions to a breach
Conduct. The Code
Conduct is a distinct and separate statutory regime whichprovides specific penalties for any breach;(b) the
Toronto Resolution requiring the respondent to pay $3,150 todonors who had contributed to a charitable foundation;(c) in the alternative, error
the further alternative, insignificant amount that does not influence therespondent's actions.
PART II -SUMMARY OF FACTS
The Integrity Commissioner, who
mandated by the
to investigatealleged Code
Conduct violations, determined the respondent had breached the provisions
theCode in that he used his councillor letterhead to solicit funds for his charitable foundation.
important to bear in mind in determining this application that the breach was not thesolicitation
funds for charitable purposes but the use
councillor letterhead to