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Friday, December 14, 2018 at 10:21:17 AM Eastern Standard Time

Subject: PCPO Elec)on Issues


Date: Sunday, November 18, 2018 at 9:51:45 AM Eastern Standard Time
From: ScoF Hutchison
To: Arthur Hamilton
CC: Alex Smith

Dear Mr Hamilton

As you know I am counsel to Mr Karahalios, a candidate for President of the party.

I am wri)ng to record certain concerns arising from apparent irregulari)es in the vo)ng list at the conven)on
presently underway and to request modest protec)ve measure to ensure that these concerns can be
addressed, if necessary. As vo)ng is about to close it is too late to repair those irregulari)es, but not too late
to ensure that in the event those irregulari)es may have impacted the result then an appropriate review can
take place.

One issue of par)cular concern is a discrepancy between the list of “paid and registered” delegates and those
who are being permiFed to vote. In essence, people who are being treated a ‘delegates’ have not registered,
or at least have not been reflected on the list provided to Mr Karahalios and his team last night. It is
therefore essen)al that

1. Ballots not be destroyed without the consent of all candidates


2. A process be put in place to determine how many unregistered delegates were permiFed to vote

Thank you for your aFen)on to this maFer.

ScoD C. Hutchison
HENEIN HUTCHISON LLP | BARRISTERS |
235 KING STREET EAST, FIRST FLOOR, TORONTO, ONTARIO M5A 1J9
T: 416.368.5000 | M: 416.388.1200 | F: 416.368.6640 | www.hhllp.ca |

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Ontario PC Party Statement regarding irregularities in 2018 convention vote for party executive
November 21, 2018

Thanks for reaching out to us.

We are confident in the integrity of the results of the most recent executive election held at the 2018 PC
Convention in Toronto. The entire election process from start to finish included input from both
Presidential candidates and their teams.

During the voting, it is important to note that scrutineers representing both Presidential candidates
oversaw the process of verifying eligible voters and, all other aspects of the election including the count.
At any given time during the voting, scrutineers outnumbered election officials at the polls. No concerns
were raised at the time with the process, nor did any candidate representative appeal the integrity of
our method.

We are confident that the results of the election are sound and correct due to the many precautions
taken by election officials and, due to the oversight provided by scrutineers selected by the Presidential
candidates themselves.

Our party is proud to operate an open, fair and, transparent election process. We are thankful for our
many volunteers, supported by party staff, who gave their time to ensure the 2018 PC convention was
successful.

Marcus R. Mattinson
C~ /

CASSELS BROCK
L A!N Y E ~t S

November 26, 2018


VIA EMAIL ahamilton@casselsbrock.com
tel: 416.860.6574
Mr. Scott Hutchison fax: 416.640.3009
Henein Hutchison LLP fi le #: 51294-1
235 King Street East
3rd Floor
Toronto, Ontario M5A 1 J9

Dear Mr. Hutchison:

Re: PC Party of Ontario Executive Elections(2018 AGM)

Thank you for your email of November 18, 2018.

In your correspondence, and in previous communications, your client instructed you to


q uestion the integrity of the election and voting process, and make reference to
unspecified "irregularities". You were also instructed to assert that the officials
overseeing the voting process were not impartial or neutral, and that this has somehow
"....almost certainly impacted the outcome".

Each of these assertions or allegations are simply wrong. We note that at no time has
Mr. Karahalios provided a specific example of even one person receiving a ballot to vote
in the Executive Elections who was not a delegate duly entitled to vote. Mr. Karahalios
had his campaign's scrutineers present at every stage of the voting process, including
having scrutineers present at the credentials table. Those scrutineers were also in
possession of the list of eligible delegates, for their use throughout the entirety of the
registration process. At no time did any of Mr. Karahalios' scrutineers raise any type of
concern which would suggest that someone other than an eligible delegate was
afforded the opportunity to vote in the Executive Elections. Had any concern been
raised, at any point in the registration or voting process, those concerns would have
been addressed immediately.

Fortunately, no issues were brought forward, which reinforces both the integrity of the
results and the appropriateness of the procedures that were in place to ensure the
results of the Executive Elections represented the will of the voting delegates.

In the absence of providing particularized examples of persons other than registered


delegates casting ballots in the Executive Elections, Mr. Karahalios should cease any
statements that in any way seek to undermine the results if the Executive Elections that
were announced on November 18.

C8S5@IS BPOC~i &c 618C~tW@I) I~LP Suite 2100, Scotia Plaza, 40 Kinq Street West, Toronto, ON Canada MSH
3C2
Tel: 416 869 5300 Fax: 416 360 8877
www.casselsbrock.com
CASSELS BROCK
L AWYER S

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HENEIN HUTCHISON LLP

BARRISTERS

November 30, 2018

Mr. Arthur L. Hamilton


Cassels Brock Lawyers
Suite 2100, Scotia Plaza
40 King Street West
Toronto, ON M5H 3C2

Dear Mr. Hamilton:

RE: Jim Karahalios & the PCPO Presidential election

As you know from our correspondence both before and after the abovementioned election, Mr.
Karahalios has good reason to believe that it was marred by significant fraud. Having reflected on the
issues and with the benefit of legal advice, Mr. Karahalios has instructed us to write you to schedule an
appointment to examine the ballot boxes, which we understand from you have been held by Cassels Brock
for safe keeping since the election. Please advise when counsel can attend at your office to inspect them.
We can be available to start any day next week other than Monday.

Investigating this matter will also require an inspection of the Delegate Lists. We would be happy
to discuss this aspect of the matter when we attend at your office to inspect the ballot boxes. Or copies
could simply be provided to us, subject to an appropriate undertaking.

We are confident that your client respects the importance of taking steps to protect the integrity
of party democracy. If, with further scrutiny, it turns out that the process was substantially fair, then Mr.
Karahalios will acknowledge as much. If mistakes were made, they should be acknowledged and guarded
against in future. If a deliberate fraud was perpetrated, it should be called out so that members of the PC
Party of Ontario can be confident that the Party is seen to be committed to exposing corruption wherever
it may be found, not covering it up.

Yours very truly,

HENEIN HUTCHISON LLP

Scott C. Hutchison

SCH