Jack B.

Siegel
D: 416-593-2958 F: 416-596-2043
jsiegel@blaney.com

September 13, 2017

DELIVERED VIA EMAIL

Mr. Patrick Brown, MPP

Room 381, Main Legislative Building
Queen's Park
Toronto, ON M7A 1A8

Dear Mr. Brown:

Re: Statements to members of the media regarding the Premier of Ontario

Our File No: 090364-0032

We represent Premier Kathleen Wynne. We are contacting you with respect to comments you made
during a media scrum on September 12, 2017, that were subsequently repeated by way of broadcast on
CHCH Television on its 6:00 pm newscast on Tuesday, September 12, 2017. These offending comments
were also uttered by you in the presence of the following members of the Queens Park media, as well as
others from Global, Fairchild and CP24:

Robert Benzie Toronto Star

Shawn Jeffords Toronto Sun
Mike Crawley CBC News
Rob Ferguson Toronto Star
Martin Regg Cohn Toronto Star
Colin DMello CTV News
Hayley Cooper Newstalk 1010
Pascal Morrissette TFO
Chris Reynolds QP Briefing
Randy Rath CHCH
Allison Smith Queens Park Today
Justin Giovannetti Globe and Mail
Julie-Anne Lamoureaux Radio Canada

Defamatory Statements

You have made a statement about the Premier of Ontario that is false and defamatory. Contrary to your
statement, Premier Wynne is not standing trial. Your statement is false and misleading and appears to
have been made with the intention to harm the reputation of Ms. Wynne.
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A transcript of the media scrum during which these objectionable remarks were made is enclosed
herewith. We direct your attention to your comments at the bottom of page 3.

As you should well know by now, especially in light of the Notice Letter sent to your colleague Bill Walker
just last week, the Premier is not subject to any charges and will not stand trial for anything. The Premier
has cooperated as a witness in this matter from the outset. She has gone so far as to waive her
parliamentary privilege and will voluntarily appear as a witness at the trial. There is a world of difference
between this high level of cooperation and your defamatory reference to when she stands trial; she is not
on trial, and will continue to take all necessary measures to defend her reputation.

The statement you have made is untrue and it is self-evident that you can have no evidence to support
this. The statements could be the subject of a defamation action.

Despite the inaccuracy of your statements, your status as leader of your party increases the likelihood that
these falsehoods will be repeated by others, increasing the potential harm to the Premiers reputation.

Accordingly, you will be held accountable for any damages arising from your defamatory statement and its
repetition by others, including but not limited to the September 12 broadcast on CHCH television referred
to above.

Demand

This letter is intended to provide you with an opportunity to partially mitigate the damage you have done.
Accordingly, we request that:

You publish a full retraction of the defamatory statements, to be published by every media outlet that
has republished them, and distributed to every media outlet that had a representative in attendance,
as listed above.

You provide a full apology for the defamatory statements, to be published along with each retraction,
and provided in writing to Premier Wynne.

You refrain from making any further defamatory statements whatsoever about Premier Wynne.

Please be advised that if our demand is not satisfactorily met by 5:00 p.m. EDT on Thursday, September
14, 2017, our client will take whatever steps are necessary and appropriate to vindicate her reputation and
to enforce her legal rights to the full extent of the law. You are likely aware of the action previously taken
against your predecessor as leader of your party, and the arduous and expensive road that this took
toward resolution. There is no doubt that you are aware of the recent similar episode involving your caucus
member, Mr. Walker. It is disappointing yet again, that in the year leading up to an election, you, as the
current Conservative leader, have chosen to degrade the political discourse within our province to such a
deplorable level.

Regardless of your compliance or non-compliance with the above demands, our client reserves her rights
to take whatever further steps are deemed necessary. However, should you fail to comply with the above
demands, your inaction and/or actions will give rise to aggravated and punitive damages in any lawsuit
commenced against you. Please be advised that any further defamatory statements will constitute new
causes of action against you.

This is the second such letter we have had to send out this month. I would suggest to you that it would be
in the best interest of all concerned if it were to be the last.
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If you or your legal counsel have any questions, please contact me directly. We look forward to the
satisfactory resolution of this matter.

Yours very truly,

Blaney McMurtry LLP

Jack B. Siegel

JBS/aa

c. Hon. Kathleen Wynne

encl.