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February 20, 2017

Good evening everyone,

I wish to make a statement and proposal, as afforded by the Liberal Party of Canada's Constitution,
before any executives are elected, acclaimed or appointed to the new Simcoe-Grey Federal Liberal
Riding Association's board of directors.

Section 10, Subsections B and G read that:

Each registered Liberal has the right, subject to the Constitution, to do the following:

Attend, speak and vote at a general meeting of their home EDA, with which they are registered


Exercise any other right granted to them by the National Board, or any other board, commission,
committee or association of the Party.

The LPC's Bylaw #6 that pertains to Elections also states in Section 1.3 Subsection E that:

This bylaw shall govern all internal electoral contests of the Party, including the election of executive
members of any Electoral District Association, at a general meeting of the EDA.

It is through this authority that I call on the National Returning Officer to invoke Section 2.2 Subsection
B of the LPC Bylaw #6:

That he or she may consider complaints, resolve issues, and impose discipline upon any candidate for
any electoral event, and without limiting the foregoing, disqualify any candidate for breach of any rules,
including without limitation:

For conduct inconsistent that shows a marked disrespect for opposing candidates, the Party, or its

Section 2.2 Subsection C of Bylaw #6 also gives the returning officer the power to make decisions in
the administration of the electoral event.

In addition to procedural regulations I cite the Liberal Party of Canada's Bylaw #2, that pertains to

Subsection 10.6 states:

The meeting chair may delay the opening of the meeting, suspend the meeting, postpone the meeting,
or request that changes be made to the physical organization of the meeting location, in order to
comply with this bylaw, the Constitution, or any other bylaw of the Party.

And Subsection 2.2. states:

The National Board may revoke the recognition of any EDA that ceases to serve the purposes of an
EDA, or meet the criteria to be recognized, or that engages in actions that are harmful to the Party.

I'm requesting these immediate interventions from the meeting chair, the returning officer and the
national board, based on these regulations. I will now describe the reasons for pursuing this action in
each case.

According to the LPC's Bylaw #2, regarding Electoral District Associations:

Section 10.3 provides that all General Meetings must give 28 days written notice to every registered
Liberal who resides in the district. The notice shall be accompanied by an Agenda, and both shall be
posted on a Party website that can be accessed by registered Liberals.

In the case of the Simcoe-Grey Federal Liberal Riding Association, notice of this AGM did not include
the mandatory Agenda. The riding association withheld information regarding any candidates and
refused to respond to inquiries as well. No registered Liberals were able to learn about the
contestants, prior to arriving this evening. Therefore this procedure is not democratic or
constitutionally compliant.

Moreover a notice posted to the EDA website required a $10 fee to attend. No distinction was made
that attendance is free to the Annual General Meeting and there was absolutely no reference or
information about an electoral event. Therefore registered Liberals in Simcoe-Grey were not invited to
cast a ballot, or even witness the acclamation of any executives. They were distinctly excluded by
way of suppressing and obstructing this election.

In Section 10.5, Subsection A of the LPC Bylaw #2 it states:

The AGM must be held at a time and place that is easily accessible by registered Liberals in the
electoral district.

I submit this building isn't disabled-friendly and members with mobility issues have been further
excluded from participating in an electoral event.

Associating a $10 fee and RSVP with tonight's events also discriminates against financially vulnerable
individuals. Any electoral events in Canada are supposed to be free and this is a transgression
against the Constitution as well as Elections Canada.

The LPC is already being scrutinized for 'pay-to-play' accusations, and charging for ballots reeks of
more scandal to come. So does limiting attendance to 75 people in a riding with more than 700
members, as the Notice of AGM clearly advertised.

This conduct is unbecoming of a Liberal, as per Section 9.1 of the LPC's Bylaw #2.

It states:

The members of EDA boards of directors must behave in accordance with the Party Code of Conduct,
and, without limiting the foregoing, conduct themselves to the highest standards, and in a manner that
will not be detrimental to the interests and reputation of the Liberal Party of Canada.

Which brings us to the most serious matters that need to be addressed.

While it may not have been known by the general public, a person by the name of Jared Nolan was
the Executive Vice President of the Simcoe-Grey Federal Liberal Riding Association. He actively
served the position when he was criminally charged for abusing a position of trust in the community, to
lure children and participate in the distribution of child pornography.

Some charges have been laid and more are pending. The investigation is so serious that a special
police task force is continuing the investigation for a wider network of child victims and/or criminal
associates. Mr. Nolan remains under the strictest bail conditions during this time, including house

The Party and police have both been notified that 2 of Mr. Nolan's colleagues associated with the
investigation are also part of this EDA board of directors. One of those individuals was involved in
intimidating a fellow executive of this EDA, for co-operating with authorities for the purpose of this

At issue is Mr. Nolan and any potential associates having access to youths and/or youth information
contained in The Liberalist database, that could potentially serve to put them in danger. Only Mr.
Nolan has been charged to date and all persons involved in the investigation are presumed to be
innocent. But the investigation is expanding and 2 new child complainants have already been
identified. We don't yet know where the allegations arise, or if they may be connected in any way to
abuse of Liberal data or Party contacts. This very point is only now being discussed.

I'm also aware that the current riding executive failed to exercise Section 9.3 of the LPC Bylaw #2. It's
the only section that appears in bold in the LPC's governing documents, for a procedure to remove
inappropriate members from the board of directors.

Though I respect Mr. Nolan's Charter rights, as well of the presumed innocence of his colleagues, the
fact remains that at least 2 of them are in a conflict of interest to make decisions about Nolan,
pertaining to this EDA and his access to youth information. Proof of this conflict is evident because
they did not seek to remove Nolan as a precautionary measure, as the investigation completes.
Instead they waited months for Nolan to resign of his own accord, after he'd been criminally charged
and maintained access to Young Liberals in secret. That secrecy occurred because executives of the
Simcoe-Grey Federal Liberal Riding Association deleted all evidence from the Internet, that Nolan was
ever the riding Vice President, or that he remained an executive while accused. The SGFLRA sought
to hide that relationship during the very moment a forensic warrant was executed by the OPP as well.

This matter is highly contentious and both the Party and EDA are aware it's being considered by the
police task force. In fact, threats to deter any cooperation or transparency arose from this situation,
and a subsequent request to require Vulnerable Sector checks for EDA executives, who handle
sensitive member data and community outreach, was also denied in the process.

The Simcoe-Grey Federal Liberal Riding Association refused to take any precautions whatsoever.
Anna Gainey and Rob Jamieson of the LPC-O also remain defiant about protecting Young Liberals, as
this criminal process unfolds. So far this riding association and the Liberal Party have sided with the
accused, by denying a reasonable middle ground through Vulnerable Sector checks during this
extraordinary calamity.

For anyone who isn't familiar, Vulnerable Sector clearance is a deeper, criminal record check
performed by the police, that ensures a volunteer is safe to work with children. They're standard at
most volunteer organizations that work with young persons in Canada. It's not a prejudiced
requirement in any shape or form. It's just good and common sense that was adopted as a volunteer
industry norm. But the Liberal Party of Canada and this EDA are adamantly opposed to employing it,
even in the case of our riding association, where an executive with access stands criminally accused.

Since that official request for Vulnerable Sector checks was denied, I believe it's up to the parents of
Young Liberals and Young Liberals themselves, to decide if they consent to placing their information in
the hands of anyone under investigation, related to crimes against children. Profiles in The Liberalist
are generated through surveys and various contact with the Party, that build a significant political,
demographic and psychological profile. That's why this information is so valuable to political parties.
But it can also be tremendously abused by anyone suffering from illness related to child predation, and
used to target vulnerable youths at 'family friendly' events like the one tonight.

This is therefore an argument between the privacy and protection of minors, versus the Charter rights
of Mr. Nolan and/or his network. I don't believe that adopting standard industry measures to
safeguard Young Liberals competes with the presumption of innocence, but this riding association and
and the LPC-O have taken a different opinion.

Due to these disagreements and various obstructions of the police investigation, I believe the Liberal
Party of Canada's National Board must take control of this EDA until the issues are resolved entirely.
Although the other community organization affected by Mr. Nolan is conducting its own internal
investigation, in addition to the police, this riding association and the Liberal Party are refusing to take
similar action. As I said, official requests and concerns were met by suppressing his relationship with
the LPC, deleting evidence, and intimidation to discourage cooperation with police. I have evidentiary
emails with me to support this allegation, if anyone seeks to challenge these facts.

Finally, Section 6.4 Subsection C, of the LPC's Bylaw #2, directs the EDA to work with Party staff, to
monitor the use of data management tools for the purpose of utilizing volunteers.

Youths in Ontario must complete 40 hours of volunteer work to graduate from high school and this is a
mandatory requirement to obtain a diploma. Political parties benefit from this arrangement and
members can join the LPC as young as 14 years old. Through fulfilling this obligation, they are then
included in The Liberalist and contacted by riding executives to assist at events in person. They may
even be transported by EDA execs, like Mr. Nolan and/or his associates.

I believe the Simcoe-Grey Federal Liberal Riding Association and the Liberal Party of Canada are
failing their fiduciary duty to safely manage the data of youths, by denying an internal investigation,
transparency, and cooperation with police, as well as Vulnerable Sector checks. I'm not a lawyer, but I
believe the actions to blatantly conceal Mr. Nolan's relationship with Young Liberals could spawn legal
liability issues and the Party needs to consult with an attorney before giving control of this EDA to any
local executives whatsoever.

Any current executives are already conflicted by the police probe until it's concluded. Regardless of
pending charges, each figure could be called as a witness by the prosecution or defence and only
these executives are familiar with the destruction of evidence related to Mr. Nolan and the riding
association. Any new executives wouldn't be familiar with these events, nor could they cooperate with
a forensic warrant that has already placed the accused's communications with Liberal members in the
hands of police. I note that warrant is still active and the investigation is still expanding, as we speak.

If the Liberal Party of Canada allows a new executive slate to take control of EDA records, it may be
directly interfering with the OPP task force probe, to bury the riding association's knowledge further.
And if it allows any executives to continue as incumbents, they will be in an unavoidable conflict of
interest, given the meddling that has already occurred. The only reasonable and legally sound option
is for the national party to take control of the riding until judicial evidence gathering has completed.

Thank you for hearing my issue and a decision is required immediately, at the very least to suspend
the AGM until legal counsel for the Liberal Party of Canada can determine a course of action.