Cox &PALMER

November 15, 2017

Via Fax: 506-529-5183

Via E-mail: town@townofstandrews.ca

His Worship Mayor Doug Naish and Members of Council

Town of Saint Andrews
212 Water Street
Saint Andrews, NB
E5B 1B4

Your Worship and Members of Council:

Re: Indian Point Land Lease

We are solicitors representing The Concerned Citizens Action Committee.

This is to advise that should the Council proceed to approve the motion that is on the
agenda for this evening's Special Meeting in which Council is asked to ratify a Letter of
Intent between the Town and the Kiwanis Club for the land lease at Indian Point, our clients
intend to commence proceedings in the Court of Queen's Bench of New Brunswick to
overturn any such decision and seek costs against the Town.

The principal basis upon which our clients intend to seek relief from the Court is that any
such decision will have been tainted by conflicts of interest on the part of Council members
who are also members of the Kiwanis Club, and the Town's failure to put the land lease at
Indian Point to an open and competitive bidding process.

Our clients' position is that, in addition to the defects identified above, the process leading
to the motion before Council has lacked transparency and openness with respect to the
finances of the Indian Point campground contrary to the representations made at the
Special Meeting of March 27, 2017 and the demands of the citizens.

Govern yourselves accordingly.

Yours very truly,

CO ;ft;l~"7
:~Ie*

Patrick J. O. Dunn

Arthur T. Doyle* I Partner

Direct 506 633 2730 Main 506 632 8900 Fax 506 632 8809 Emall adoyle@coxandpalmeLcom
1 Gerrnam Street, Suite 1500 ' Saint John, NB I E2L 4V1 I Canada
Correspondence: P. O. Box 1324, Saint John. NB E2l 4H8
*Practising through Arthur T. Doyle Professional Corporation