Canada Form 5 RCMP File: ONTARIO SUPERIOR COURT OF JUSTICE (Toronto Region) IN THE MATTER OF an application for a Search Warrant pursuant to section 487(1) of the Criminal Code. AND IN THE MATTER of an application for Assistance Orders pursuant to section 487.02 of the Criminal Code WARRANT TO SEARCH TO: Sergeant Gordon Aristotle or any Peace Officers in the Province of Ontario assisting him TO: lan Smith TO: Derek Maclsaac TO: Scott Hutchison WHEREAS it appears on oath of Sergeant Gordon Aristotle, a Peace Officer, and a member of the Royal Canadian Mounted Police in the Province of Ontario; THAT there are reasonable grounds for believing that the following offences have been committed: Section 322 Theft Criminal Code; Section 336 Criminal Breach of Trust Criminal Code; Section 380 (1) Fraud Criminal Code; Section 462.31 Laundering the Proceeds of Crime Criminal Code; and Section 341 Fraudulent Concealment Criminal Code; AND THAT there are reasonable grounds for believing that the following things for the lime period from September 1,.2013 to present will afford evidence of the said offence(s): 1. All records in paper and electronic format pertaining to: PIN Consulting Group Inc,; ji, Leximco Ltd. (operating as Leximco Travel); First Response Travel Group; and Page 1 of 7iv. An unknown offshore company which is believed to be associated with one or all of the following individuals: Karl Walsh, Jim Christie, Martin Bain, Andrew McKay, Klara Kozak or Noel Francis Chantiam; including but not limited to the following: a. All financial documents and records such as: banking records and copies thereof, bank statements, cancelled cheques, deposit slips, debit and credit memos, cheque stubs, cheque registers, credit card statements, loan accounts, investment accounts both domestic and foreign, money transfer receipts, mortgage and loan agreements, account applications, mortgage applications, credit card applications, bank correspondence, accounting records, general ledgers, journal entries, sales invoices, purchase invoices, expenses, fee schedules, correspondence files, financial statements, net worth statements, working paper files, permanent files containing information on shareholders, shareholder meetings, details of long term debt, details of capital assets, deed documents and other supporting documents; and b. Income tax documents, including but not limited to original and copies of the T2 returns of income including all ‘supporting documentation such as financial statements, correspondence and working papers; 2. All records in paper and electronic format pertaining to domestic and foreign investments which are associated with any of the following: Ontario Provincial Police Association (OPPA), Karl Walsh, Jim Christie, Martin Bain, Andrew McKay, Klara Kozak or Noel Francis Chantiam, including but not limited to the following: i, Condominiums at 1 Cable Beach, Nassau, Bahamas; ii, Investment with the New Providence Income Fund Ltd. and the Sterling Financial Group In: iii. Investment with the Caldwell Group; iv. The OPPA procurement planning, assessment and development of land for the proposed new OPPA Head office; v. Investment in Leximco Travel; vi. investment in First Response Travel Group: vii, Investment in an unknown offshore company: and vili, Investment in PIN Consulting Group inc. Page 2 of 73. All records in paper and electronic format pertaining to funds being transferred to and received from, or on behalf of Kar! Walsh, Jim Christie, Martin Bain, Klara Kozak, Noel Francis Chantiam, the OPPA, First Response Travel Group, PIN Consulting Group Inc., or Leximco Travel: 4. All records in paper and electronic format pertaining to Karl Walsh, Jim Christie, Martin Bain, Klara Kozak, Noel Francis Chantiam, Barry McKay, Elena Rabenok, the OPPA, First Response Travel Group, PIN Consulting Group Inc., or Leximco Travel, including but not limited to emails, letters and faxes; 5. All records in paper and electronic format pertaining to tax returns for ‘Andrew McKay. AND THAT there are reasonable grounds to believe that the said things or some part of them ere located in Suite 903-180 Bloor Street West, Toronto, Ontario, hereinafter called the premises. AND THAT the following independent lawyer be appointed to act as the Referee in order to protect solicitor-client privilege: fan R. Smith Law Firm: Fenton, Smith Barristers, 235 King Street East Second Floor Toronto, Ontario MSA 1J9 LSUC: #32055Q AND THAT the following independent lawyer be appointed to act as the Chief Referee in order to protect solicitor-client privilege: Scott Hutchison Henein Hutchison LLP 3rd Floor 235 King Street East Toronto, Ontario LSUC #29912) AND THAT the following Independent Certified Forensic Examiner (ICFE) be appointed to assist the police and the Referee in the search and seizure of electronic devices and Derek Maclsaac Digital Evidence International Inc. 400 Queens Ave., London, Ontario Page 3 of 7Vi The police and the Referee will ask the employees of the Law Office and any other lawyers who may be present to provide all reasonable assistance to aid with the execution of this search warrant. The Referee will assist the police in determining where the said things are located inside the premises. This may include communicating with any other lawyers or law office support staff. The Referee will take all necessary steps to ensure the maximum protection of solicitor-client privilege and to ensure that the Order is complied with. The duties of the Referee will include: a. Assist police to locate the things sought under the search warrant; b. Identify the location from which the things were seized and document a brief description of the things seized; c. Identify and assert privilege, if applicable; 4d. Identify said things that are clearly not privileged, such as share certificates, personal material belonging to Andrew McKay, and safety deposit keys; €. Maintain the independence of the forensic process; f. After the search has been executed the Referee will maintain continuity, security and store the things seized until delivering these things to the Chief Referee or releasing to police. The police will only seize things that the Referee determines are clearly not protected by solicitor-client privilege. ‘SEARCH PROCEDURES FOR ELECTRONIC EQUIPMENT, DEVICES and MEDIA: The ICFE will make reasonable attempts to image the electronic equipment, devices and media. In the event that this is not possible, the original devices will be seized. Once the electronic devices are imaged or seized, the ICFE will document a description of the device and describe where it was located. Page 4 of 7Vil. vill. XL. OFFSITE FORENSIC EXAMINATION BY THE ICFE: The ICFE will take steps to locate the things on the devices or media, or on the images of the devices or media, including but not limited to the following: a. The ICFE will conduct key word searches on the devices or media, or the images of the devices or media. The list (s) of key words will be supplied to the ICFE by the Sergeant Gordon Aristotle or his designate, b. The ICFE will provide all things located as a result of the key word searches to the Chief Referee, The ICFE will maintain continuity, security, and store the devices or media, or the images of the devices or media, until the forensic examination is completed. Upon the completion of the forensic examination the ICFE will deliver all electronic devices and media, whether imaged, copied or seized and the images or copies thereof, to the custody of the Chief Referee. POST SEIZURE DUTIES OF THE CHIEF REFEREE: The Chief Referee will receive the said things seized by the Referee and the ICFE from the search site both in paper and electronic form. Upon receipt, the Chief Referee will maintain continuity and security, and be responsible for the storage of these things until otherwise ordered by the Court. The Chief Referee will examine all presumptively privileged things seized from the search site, whether seized in paper or electronic form, The Chief Referee will separate the things into three categories, and prepare a report that will provide the Court with rationale why this material: 1, In the opinion of the Chief Referee is not protected by solicitor-client privilege. 2. In the opinion of the Chief Referee may be protected by solicitor-client privilege. 3. In the opinion of the Chief Referee should be protected by solicitor-client privilege. The Chief Referee will be responsible for notifying olients who have been affected by the execution of the search warrant, or whose documents have been seized pursuant to the search warrant. This notification will occur as soon as reasonably practicable following the execution of the search warrant and may include advising clients of; a. The seizure of any of their documents; Page 5 of 7b. The risk to their privilege interests by the investigative or prosecutorial authorities; c. The existence of a conflict of interest if one has arisen; 4. The right to seek and obtain legal advice and legal representation; e. How solicitor-client privilege may be asserted; f. How to request a hearing to determine any issue of privilege by the Court; and 9. Any other information to assist the clients in protecting their interests as a result of the search for and seizure of their documents. Xil, The Chief Referee may notify the clients either verbally or in writing and may request the assistance of the Police in the notification process. In the event that client cannot be notified after all reasonable attempts, the Chief Referee may take steps that will afford continued protection of the clients’ solicitor-client privilege, including responding to the Crown's application to gain access to the seized material, or bringing @ motion to have the privilege issues adjudicated by the Court. THIS IS THEREFORE, to authorize and require you on the 6th day of March, 2015 between the hours of 8am and 4 pm, to enter into the said premises and to search for the said things and bring them before me or some other Judge, or submit a report in writing in respect of anything seized, DATED this_SS day of March, 2016 at the City of Toronto in the Province of Ontario. the Superior Court of Qutario JUSTICE NORDHEMER Page 6 of 7TakeONTARIO SUPERIOR COURT OF JUSTICE (Toronto Region) IN THE MATTER OF an application for a Search Warrant pursuant to section 487(1) of the Criminal Code. AND IN THE MATTER of an application for Assistance Orders pursuant to section 487.02 of the Criminal Code WARRANT TO SEARCH Sergeant Gordon Aristotle Royal Canadian Mounted Police 345 Harry Walker Parkway South Newmarket, ON Page