COURT FILE NUMBER COURT JUDICIAL CENTRE PLAINTIFF DEFENDANT DOCUMENT ADDRESS FOR SERVICE AND CONTACT INFORMATION OF PARTY FILING THIS DOCUMENT NOTICE TO DEFENDANT(S) You are being sued. You are a defendant, ForM10 (RULE3.25] 1503 - 03901 COURT OF QUEEN'S BENCH OF ALBERTA EDMONTON NARESH BHARDWAJ BALBIR SIDHU STATEMENT OF CLAIM BENNETT JONES LLP Barristers and Solicitors 3200, 10020 - 100" Street Edmonton, Alberta TJ 0N3 Attention: James Heelan, Q.C. ‘Telephone No.: 780-917-4275 Fax No.: 780-421-7951 Client File No.: 74072.1 Go to the end of this document to see what you can do and when you must do it. Note: State below only facts and not evidence (Rule 13.6) Statement of facts relied on: The Parties 1, The Plaintiff, Naresh Bhardwaj ("Mr, Bhardwaj"), is an individual residing in the City of Edmonton. Mr. Bhardwaj is currently a sitting Member of the Legislative Assembly of Alberta. 2. The Defendant, Balbir Sidhu ("Mr, Sidhu"), is an individual residing in the City of Edmonton. Wteqatorsr2qo00 1864318061The Edmonton-Ellerslie Nomination 3. On February 21, 2015, the Progressive Conservative Asso "PCAA") held a vote to determine its cant Ellerslie, the riding in which Mr. Bhardwaj is currently the incumbent MLA. 4. Prior to the vote, several individuals had filed nomination papers with the PCAA seeking to be nominated for the riding. These individuals included Mr, Bhardwaj and another individual, Balraj Manhas ("Mr. Manhas'), 5 Prior to February 21, 2015, Mr. Manhas withdrew from the nomination ballot. On February 21, 2015, Mr. Bhardwaj was successful in the nomination ballot and won the PCAA's nomination in the Edmonton-Ellerslie riding. The Defamation 6. On or about February 21, 2015, Mr. Sidhu swore a declaration alleging that Mr. Bhardwaj had attempted to induce to sign an Affidavit concerning the validity of Mr. Manhas’ nomination papers (the "Sworn Statement"), The Sworn Statement contains a number of false and defamatory statements with respect to Mr. Bhardwaj, including: (@) "I was approached by Naresh Bhardwaj who is presently MLA in our Ellerslie community along with person name [sic] Sukhjeevan Chahal, He offered me a bribe of $10,000.00 dollars. He and Mr. Chahal asked me to sign an affidavit saying that me and my three family members sign this affidavit then we will get $10,000." (b) "He told me that Mr. Chahal is a lawyer in Canada and he was a senior officer in India and he is well connected here and in India to arrange $10,000 to be paid in He further s Ini id in case if I and my family does not want cash then Mr. Chahil (sic] will buy vacation package for me and my family for a trip to India so nobody will suspect this money transfer for signing the pre drafted affidavit they brought” Wtegatorsor2 0900116318061(©) (@) ©) 3. "Iwas very surprised at his offer as he pretends in the community that he is very honest and learned politician" "I request to investigate this matter in depth as soon as possibl action can be taken against corrupt minded politicians otherwise Albertans will have corrupt leaders ruling over them." "FOR GOD SAKE JIM, PLEASE SAVE ALBERTA FROM SUCH CORRUPT. INDUCEMENT OR BRIBES TO KILL PARTY SOUL OF FAIRNESS" (collectively, the "Defamatory Statements") Publication of Defamatory Statements 7. Mr. Sidhu published the Defamatory Statements, or caused them to be published, on a number of occasions: @ (b) © @ In or around March of 2015, Mr. Sidhu provided a copy of the Sworn Statement to members of the PCAA, On or about March 10, 2015, Mr. Sidhu provided a copy of the Sworn Statement to journalists employed or engaged by the Free Daily News Group Inc. ("FDNG"), the publisher of a daily newspaper, "Metro", Mr. Sidhu also conducted an interview with FDNG journalists during which he repeated the Defamatory Statements. On March 11, 2015, FDNG published an article reproducing portions of the Defamatory Statements as well as the substance of the defamatory allegations made by Mr. Sidhu in the Sworn Statement, Print copies of Metro are widely circulated throughout Alberta. In addition, Metro articles are uploaded to the internet and widely available worldwide. On or about March 12, 2015, Mr. Sidhu provided a copy of the Sworn Statement to journalists employed or engaged by the Edmonton Journal. On March 12, 2015,the Edmonton Journal republished the Sworn Statement by uploading the Sworn. Statement to the Edmonton Journal website, which is widely available worldwide, Mr. Sidhu made or caused the publication maliciously, with an improper purpose, and with intent to harm Mr, Bhardwaj's reputation. Alternatively, Mr. Sidhu made or caused the publication with a reckless, willful indifference as to whether the publication was true or false, and he knew or ought to have known that making such a statement, if false, would undoubtedly result in harm to Mr. Bhardwaj’ reputation, Harm to Reputation 9. 10. ul 12. ‘The Defamatory Statements, which have been widely circulated to the PCAA and the media and the substance of which are now widely available on the Intemet and in print, contain false information and are defamatory of Mr, Bhardwaj as they state or imply that Mr. Bhardwaj: (a) _ Is unethical, dishonest, or corrupt; and (b) Has engaged in fraudulent or criminal acts; ‘These statements ani nplications are unequivocally false, As a Member of the Legislative Assembly of Alberta, Mr. Bhardwaj is a highly public figure with a valued reputation. That reputation has been severely, and irteparably, damaged by the actions of Mr. Sidhu. The publication of the Defamatory Statements has caused, and continues to cause, considerable loss of reputation to Mr. Bhardwaj, both within Edmonton, and elsewhere. Mr. Bhardwaj pleads and relies upon the provisions of the Defamation Act, RSA 2000, ¢ D-7, and the Judgment Interest Act, RSA 2000, ¢ J-1. Remedy sought: 13. Mr. Bhardwaj seeks as against Mr. Sidhu: (a) Damages in the amount of $1,000,000.00; WLegator4o72.00001 168318991(b) () @ (©) Special damages, in an amount to be proven at trial; Prejudgment and post judgment interest on all monies owing in accordance with the Judgment Interest Act; Cost of this action on a solicitor and own client full indemnity basis; and Such further and other relief as this Honourable Court may deem appropriate. NOTICE TO THE DEFENDANT(S) You only have a short time to do something to defend yourself against this claim: 20 days if you are served in Alberta 1 month if you are served outside Alberta but in Canada 2 months if you are served outside Canada, You can respond by filing a statement of defence or a demand for notice in the office of the clerk of the Court of Queen's Bench at Edmonton, Alberta, AND serving your statement of defence or a demand for notice on the plaintiff's address for service. WARNING If you do not file and serve a statement of defence or a demand for notice within your time petiod, you risk losing the law suit automatically. If you do not file, or do not serve, or are late in doing cither of these things, a court may give a judgment to the plaintifi(s) against you. WSLegaTo7407200001\ 164318261