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July 09, 2015

South District Girls Soccer Association
16911 618 Ave
Surrey, BC V3S-1C8

Attn: Bruce McCallum, Chair
Surrey Metro Soccer Association
P.O. Box 311,#151-10090 152nd Street
Surrey, BC V3R-8XB
Shaheem AIi, Chair

Re:

The Abuse of Authority by the Gentral City Football Club ("GGFC" or
the "Club") Executive Committee & Board of Directors

Please accept this letter as an official letter of complaint against the Executive
Committee & Board of Directors of CCFC ('CCFC Management"). As a member of
CCFC and former VP of Equipment / Equipment Manager, I am asking that both the
South District Girls Soccer Association (SDGSA) and the Surrey Metro Soccer
Association (SMSA) hold account the CCFC Management for its abuse of authority.
Firstly, the CCFC Management have changed the Constitution and Bylaws of the
CCFC without approval of the membership of the Club at an Annual General
Meeting. Please see documents, attached. As the Club is governed by the Society
Act, any change of the Constitution or Bylaws must be approved by the membership
of the Club. This is a huge violation of their duties as the Management of the CCFC.
CENTRAL C|TY FOOTBALL CLUB
BYLAWS

- BREACH

OF THE CONSTTTUTTON AND

Violation of Bylaw 6
Bylaw 6 of the Club's Constitution provides:

Central City Football Club shall be atfiliated with BC

Soccer Association and

its

affiliated

district

association's primary established for the purpose of
organizing and administrating soccer in the district
in which Central City Football Club belongs and is
subject to the rules and regulations of these bodies.

This Clause shall not be altered
Despite Article 6, CCFC Management has been supporting a non-affiliated BC
Soccer Association/District(s) Association soccer club, namely, the Canadian Eagles
FC. Seven board members of CCFC are actually also Board Members of Canadian
Eagles FC. Monies have been paid from CCFC to Canadian Eagles FC, despite
being a non-affiliated BC Soccer Association/District(s) Association soccer club.
Lastly, CCFC Management has been misleading CCFC members, and the public, by
stating that CCFC is running a Spring/Summer League.

Violation of Bylaw 3
Bylaw 3(a) of the Club's Bylaws provides:

Central City Football Club's ANNUAL GENERAL
MEETING shall be held on or before the thirtieth
(30th) day of June each year at a place somewhere
in the City of Surrey as the directors may determine
and on a day to be fixed by the directors and thirty
(30) days written notice of such meeting shall be
given to the members by posting it on the club's
officialwebsite; and
Bylaw 3(b) of the Club's Bylaws provides:

ANNUAL GENERAL MEETING of the Central City
Football Club shall be held at least once in every
calendar year and not more than fifteen (15) months

after the holding of the last preceding

annual

general meeting

The CCFC Management applied for an extension of the Club's AGM in February of
2015. The reason given was that the Club's audited statements were not prepared,
despite the Club having a fiscal year end of March 30.
The Society Registry first accepted the request and granted an extension. The
Registry, however, realizing the Club's Bylaw requirement, revoked the extension.
The notice for the AGM is listed as June 1"1, 2015, which is in fact back dated from
the actual posting date of June 25, 2015. See relevant documents, attached. The
2014 AGM of the Club was held on April 23,2014. The 2015 AGM should have
been held by no later than July 23,2015.lnstead, the Club is holding its AGM on
July 29, 2015, in clear violation of the Club's Bylaws.
The Bylaws of the Club defines a "voting member" as, "a designated parent or legal
guardian who is delegated to represent a family of registered youth player(s) in good
standing, or a coach, or a volunteer or an adult player who is in good standing".
Further, it defines a "Registered played' means a youth and adult player whose
application for membership has been validated by the District Registrar and by the
Provincial Registrar for the current soccer season.
The CCFC Management has set July 24,2015 as the date to determine
membership. This means that all members who have paid their registration fee for
(2015-2016 season) prior to July 24th, 2015 will be entitled to attend and vote at the
meeting.
How does the CCFC Management team plan to have the members registered for
201512016 season, validated by the District Registrar and by the Provincial Registrar
for the 201512016 season by July 24, 2015. The lists are not due until October 1st.

First, the July 24,2015 date was set arbitrarily by the CCFC Management, without
the approval of the membership at an Annual General Meeting. More significantly,
the AGM should have taken place no later than June 30, 2015. This means that
members who signed up in 2014 should be voting at the 2015 AGM (as their
membership expires on July 31, 2015). CCFC Management has artificially delayed
the AGM to have next seasons' mernbers voted at the 2015 AGM. Further, CCFC
Management is excluding all CCFC members from the 2014 soccer season who are
from participating and voting at the 2015 Annual General Meeting. lnstead, next
seasons' players will be able to participate, contrary to the spirit of the Club's
Bylaws.

Violation of Bylaw 4
Bylaw 4,A (6) of the Club's Bylaws provides:
The order of business at the ANNUAL
GENERAL MEETING shall be as Follows: Roll
Call; Credentials, Minutes; Business Arising,
Correspondence; Officer's Reports;
Constiiutional Amendments; Bylaws; Settinq
the*Annu_al Memberqhip Fee; Approval of a
Budget; Election of Board of Directors; New
Business, Adjournment.
ln violation of Bylaw 44 (6), CCFC Management has been set the membership fees
in December 2014 for the zA1ilrc soccer season. They did so without first
approving the membership fees at an Annual General Meeting for the 2015116
soccer season.

Violation of Bylaw 5
Bylaw 5 of the Club's Bylaws provides:

Any Board Member who has a personal
interest in a matter before the Board shall
before a vote on the matter declare their
interest and shall not be entitled to vote on the
matter in which they have a personal interest.
The Board may by resolution disqualify a Board
member if the Board is of the opinion that the
Board member has a personal interest in the
matter;
As stated, above, seven members of CCFC Management sit on the board for
Canadian Eagles FC. More significantly, SpringlSummer fields are rented from the
City of Surrey under CCFC, but the CCFC rentals are being used by Canadian
Eagles FC. Further, CCFC membership fees are being used to pay for field rentals
for Canadian Eagles FC. The seven members that sit on Canadian Eagles FC are
using CCFC's membership data base to expand the membership of Canadian
Eagles FC. Lastly, CCFC Management is making payments to Canadian Eagles
FC, in direct violation of the Constitution and Bylaws of the Club. CCFC
Management is carrying out the above in conflict with their duties owed to CCFC,
without membership approval, and contrary to the Club's Constitution and Bylaws.

BC SOCCER RULES & REGULATIONS VIOLATIONS

Rule 13(e) provides:

Youth Districts forming an inter-district youth
league shall make application annually for
sanction to BC Soccer 45 days before
commencement of the season. The inter-district
league shall be under the jurisdiction of the
districts in whose areas they will operate. An
inter-district youth league must be comprised of
a minimum of four (4) teams.
CCFC Management has failed to apply within the time frame of 45 days. Further, the
CCFC Management has failed to apply to the Surrey Metro Soccer Association or
the South District Girls Soccer Association. Damningly, the current CCFC
Management has insisted that members register for a full year, including
Spring/Summer. The Spring/Summer season, however, the members are then
placed on the to the non-affiliated BC Soccer Association/District(s) Association
soccer club Canadian Eagles FC.
Request / Demand
CCFC is a BC Soccer Association/District(s) Association soccer club. CCFC should
not be associated with any non BC Soccer Association/District(s) Association soccer
club program.
Further, the CCFC Management has abused its authority by targeting the current
members of the Club by not upholding the Constitution and Bylaws of CCFC, and
violating the Rules of its governing bodies namely, South District Girls Soccer
Association, Surrey Metro SoccerAssociation, BC SoccerAssociation, and Soccer
Canada Association FIFA (the "Rules").
Based on the above we request that both the South District Girls Soccer Association
and the Surrey Metro Soccer Association investigate the business of CCFC to
ensure that the CCFC Management are complying with the Bylaws of the Club, the
Society Act, and the Rules.

This letter has clearly outlined and provided evidence in regards to abuse of power.
lf there is no action taken by the districts and BC Soccer within a reasonable time,
this serious matter will be put forth to the supreme court of Canada. At that time all
governing bodies will also be held accountable and responsible for allowing this nonprofit organization to operate outside the guidelines and boundaries of your
individual constitutions and bylaws.
Govern yourselves accord ingly.

,/--e€2
Amar Bains
604-417-2627

Newton'Athletic'Park'
7925'–'128th'Street'
Surrey,'BC'
(604)'589'–'GOAL'(4625)'

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July'26,'2015'
South'District'Girls''Soccer'Association'(the'"District")'
Attention:'

Bruce'McCallum,'SDGSA'Chair'

'

'

Mike'Grohmann,'SDGSA'Discipline'Chair'

Re:$

CCB$Suspension'

I'write'on'behalf'of'the'Central'City'Football'Club'("Club")'in'response'to'your'letter'of'July'
24,'2015.''
You'reference'having'received'complaints'about'our'Club,'yet'we'have'only'been'notified'of'
a'single'complaint.''We'were'provided'details'of'that'complaint'on'July'23,'2015'and'have'
not'been'given'an'opportunity'to'respond'to'the'allegations'in'such'complaint.'
Your'letter'also'only'references'allegations'made'against'our'Club;'it'does'not'make'clear'
what,'if'any,'determination'the'District'has'made'in'relation'to'these'allegations.''Yet,'the'
District'has'already'imposed'discipline'on'the'Club.''Discipline,'I'might'add,'which'impacts'
every'youth'in'our'Club'wishing'to'play'soccer'in'British'Columbia.'
We'would'like'to'draw'your'attention'to'BC'Soccer'Discipline)Policy)and)Procedure,'which'
enshrines'the'principles'of'natural'justice'and'duty'to'act'fairly'in'matters'of'discipline.''
Specifically'I'draw'your'attention'to'Section'1.1'which'states'the'following'(emphasis'
added):'
"All'individuals'have'the'right'to:'1)'a'process'free'of'bias,'2)'
prior%notice,%advance%access%to%pertinent%information,%and%
an%opportunity%to%respond,'3)'and'a'fair'hearing'with'timely'
opportunity'to'present'their'case'at'hearing."'
Please$provide$the$following$without$delay:$

A'clear'written'statement'of'the'determination'made'by'the'District'in'these'matter'
which'has'led'to'the'discipline'imposed'as'stipulated'in'your'letter'of'July'24,'2015;'

A' itemized' list' and' full' details' (including' all' supporting' documentation)' of' each'
complaint' the' District' took' into' consideration' when' making' the' foregoing'
determination;'and'

Pursuant'to'Section'37'of'the'Society)Act'(Inspection'by'Members),'the'minutes'and'
all'documents'considered'at'every'meeting'of'the'District'Board'since'the'date'of'the'
first'complaint'about'the'Club'received'by'the'District.'

Newton'Athletic'Park'
7925'–'128th'Street'
Surrey,'BC'
(604)'589'–'GOAL'(4625)'

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Surrey
Honda

Given'that'discipline'has'already'been'imposed'on'the'Club'and'its'youth'players,'I'request'
that'the'above'be'provided'no'later'than'July'29,'2015.'
I'suggest'you'give'this'letter'your'most'serious'attention.''The'Club'reserves'all'rights'and'
remedies'against'the'District'and'the'members'of'its'Board'of'Directors'in'respect'of'these'
matters'including'the'right'to'be'indemnified'and'saved'harmless'from'all'expense,'cost'and'
liability'arising'from'the'discipline'imposed'and'all'related'actions'by'the'District.'
Please'govern'yourself'accordingly.'
Yours'truly,'
'
'
'
Dr.'Harj'Dhaliwal'
President,'CCB'FC'
c.c.'

Dan'Turvill,'British'Columbia'Soccer'Association'

'

Roger'Barnes,'British'Columbia'Soccer'Association'

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