ILLER
THO SON
AVOCATS
LAWYERS
ILLER
THO SON
LLP
SCOTIA
PLAZA
40
K NG
STREET
WEST,
SUITE
5800
P
O
BOX
1011
TORONTO,
ON
5H
3S1
CANADA
T
416
595
0500
F
416
595.0695
lLLERTHO SON.CO
October
10,
2018
gent
John
Chapman
Direct
Line:
416.595.8547
Direct
Fax:
416.595.8695
Jchapman@millerthomson.com
Mail
an
d
Email
Canadaland
399-401
Richmond
St.
W.
Toronto,
Ont.
5V
3A
8
Attn:
Jesse
Brown
Dear
Sirs:
Re
:
P oposed
Publication
o
n
"
W
E
Cha ity"
It
is
th
e
understanding
of
m
y
clients
that
yo
u
ar
e
th
e
owner,
publisher
an
d
controlling
mind
of
th
e
website
canadalandshow.com
(
“
Canadaland
”
)
an
d
that
yo
u
ar
e
ultimately
responsible
for
editorial
content
appearing
on
this
website.
It
ha
s
come
to
m
y
clients
’
attention
that
Canadaland
is
preparing
a
feature
story
about
W
E
Charity,
co-founded
by
Craig
an
d
ar
c
Kielburger
(the
“
Kielburgers
”
)
In
th
e
course
of
preparing
a
response
to
inquiries
from
Canadaland
with
respect
to
this
story,
m
y
clients
recently
learned
that
Canadaland
had,
on
Sept
27
,
2017,
published
a
recorded
audio
segment,
titled
HORT
CUT
It
s
Important
To
Kick
These
People
When
They
re
Down
”
(the
“
Podcast
”
)
in
which
yo
u
extensively
discussed
W
E
Charity
an
d
the
Kielburgers.
It
is
clear
in
listening
to
th
e
words
expressed
in
th
e
Podcast,
an
d
from
past
reporting
by
Canadaland,
that
Canadaland
an
d
yo
u
clearly
hold
negative
view
of
W
E
Charity
an
d
its
co
-
founders
an
d
seek
to
do
them
harm.
These
words
and,
past
reporting,
show
clear
malice
towards
m
y
clients.
Further,
Canadaland
ha
s
a
previously
demonstrated
history
of
inaccuracy
with
respect
to
its
statements
about
W
E
Charity
an
d
its
co-founders.
In
your
Podcast,
a
number
of
ke
y
inaccurate
statements
were
made
regarding
W
E
Charity
an
d
th
e
Kielburgers.
Fo
r
example,
at
timecode
0:37
th
e
Podcast
states,
“
...the
Globe
an
d
ail's
ne
w
project
to
teach
kids
about
media
manipulation,
through
media
manipulation...
”
Th
e
Podcast
clearly
implies
that
th
e
Globe
an
d
ail
an
d
m
y
clients
ar
e
at
th
e
root
of
this
alleged
media
manipulation.
CALGARY
ED ONTON
SASKATOON
REGINA
LONDON
KITCHENER-WATERLOO
GUELPH
TORONTO
VAUGHAN
ARKHA
ONTREAL
Page
2
he
factual
inaccuracies
evident
in
the
Podcast
ar
e
numerous.
Another
example
is
th
e
inaccurate
statement
that
th
e
Globe
an
d
ai
l
partnered
with
a
“
private
company.
”
T
h
e
clear
innuendo
an
d
claims
of
th
e
Podcast
a
re
that
this
“
private
company
”
an
d
th
e
Globe
an
d
ail
partnered
to
enter
into
schools
for
nefarious
purposes.
This
claim
about
a
“
private
company,
”
repeated
in
th
e
Podcast,
no
t
once,
bu
t
twice,
is
false.
In
fact,
th
e
Globe
an
d
ail
partnered
with
W
E
Charity,
a
registered
charity
with
th
e
Canadian
Revenue
Agency.
W
E
Charity
an
d
th
e
Globe
an
d
ai
l
have
a
well-documented,
properly
administered,
an
d
well-
regarded
partnership
to
promote
media
literacy.
he
multiple
inaccuracies
in
your
reporting
could
have
been
addressed
by
following
th
e
established
journalistic
practice
o
f
seeking
to
verify
facts
with
W
E
Charity,
and/or
contacting
W
Charity
in
advance
to
allow
th
e
organization
th
e
opportunity
to
comment
on
your
claims.
hat
Canadaland
followed
neither
such
well-established
journalistic
practices
is
further
evidence
of
its
disregard
for
accuracy
an
d
an
intent
to
cause
harm
to
W
E
Charity
an
d
its
founders
by
publishing
inaccurate
an
d
misleading
content.
Recent
correspondence
to
W
E
Charity
from
editorial
staff
affiliated
with
Canadaland
indicates
that
Canadaland
intends
to,
again,
fail
to
ensure
th
e
accuracy
of
its
facts
an
d
fail
to
strive
for
fair
an
d
balanced
reporting.
Your
website
appears
to
be
determined
to
knock
th
e
organization
down.
When
asked
what
th
e
angle
for
th
e
latest
story
is,
th
e
Canadaland
reporter
replied:
We
don
ye
have
a
focus
of
th
e
s ory
....
It
seems
that
your
website
publication
is
pre-determined
to
produce
a
negative
story,
an
d
yo
u
ar
e
simply
shaping
an
article
to
suit
your
bias.
T
he
above
statement
made
by
your
editorial
staff,
as
well
as
listening
to
th
e
views
expressed
on
Canadaland
podcast
an
d
reading
past
reporting
via
th
e
website,
strongly
indicates
a
bias
against
W
E
Charity
an
d
its
co-founders,
an
d
that
yo
u
personally
seek
to
do
harm
to
th
e
charity
an
d
Craig
Kielburger
an
d
ar
c
Kielburger.
In
short,
yo
u
have
shown
a
clear
pattern
of
acting
with
malicious
intent.
Regarding
th
e
latest
article
Canadaland
is
planning,
m
y
clients
an
d
th
e
executive
o
f
W
E
Charity
an
d
E
to
W
E
have
provided
your
journalist
with
answers
to
every
question
posed,
in
detail,
supported
by
facts.
hey
have
provided
more
than
100+
pages
of
detailed
information
to
your
reporter
about
th
e
charity
an
d
its
work.
Included
in
these
documents
is
detailed
information
on
its
activities,
policies,
HR
practices,
th
e
accurate
nature
o
f
its
corporate
partnerships,
as
well
as
th
e
significant
actions
it
takes
to
ensure
th
e
protection
an
d
safety
o
f
th
e
hundreds
of
thousands
young
people
across
Canada
w
ho
W
E
Charity
is
proud
to
empower
through
th
e
programs
th
e
charity
offers.
O
u
r
specific
concerns
regarding
th
e
newest
website
article
yo
u
ar
e
planning
rest
on
th
e
specific
issues
below:
1.
y
clients
have
no
w
asked
five
times
for
what
specific
claim(s)
will
be
made
in
th
e
article
without
a
proper
answer.
T
he
e-mail
of
your
journalist
on
October
5
ha
s
shared
that
this
is
the
la e
of
ques ions
for
this
ar icle.
”
Clearly
stating
a
claim
is
journalistic
best
practice,
as
it
allows
th
e
organization
th
e
opportunity
to
respond,
including
correcting
an
y
inaccurate
facts
or
statements.
If
yo
u
were
truly
interested
in
Page
3
an
accurate
article,
yo
u
would
fo ow
this
journa ist
best
practice,
an
d
th
e
norm
of
any
publication
that
holds
itself
to
responsible
journalism.
2.
In
th
e
limited
interactions
with
m
y
clients,
based
on
th
e
questions
of
your
journalist,
he
ha
s
already
stated
half
a
dozen
errors
in
his
understanding
of
th
e
“
facts
”
(They
ar
e
highlighted
in
th
e
detailed
response
which
ha
s
been
recently
submitted
to
your
journa ist
on
October
10
th
)
O
ur
concern
is
that
if
so
many
mistakes
ca
n
be
made
through
a
series
of
basic
questions,
w
e
ar
e
concerned
that
th
e
article
itself
will
be
,
once
again,
riddled
with
inaccuracies.
Facts
an
d
accuracy
of
information
are
both
critical
elements
of
responsible
journalism.
y
clients
have
no
w
provided
your
journa ist
with
accurate
data
an
d
information
on
a
variety
of
topics.
However,
we
ar
e
concerned
about
th
e
consistent
lack
of
attention
to
detail
of
your
journa ist
an
d
your
website
in
your
collection
an
d
us
e
of
facts.
There
are,
fo
r
example,
serval
glaring
errors
in
hi
s
questions
that
show
that
your
journa ist
lacks
basic
understanding
or,
at
th
e
very
least,
a
lack
of
attention
to
important
details.
A
n
inaccurate
reporting
of
“
facts
”
could
result
in
significant
damage
an
d
cause
irreparable
harm
to
th
e
good
works
of
m
y
c ients
’
organization
an
d
th
e
millions
of
young
people
we
have
th
e
privilege
to
serve
in
Canada
an
d
around
th
e
world.
3.
y
clients
have
also
taken
th
e
step
to
provide
your
journa ist
detailed
quotes
an
d
contact
details
of
ke
y
people
w
ho
ar
e
fami iar
with
their
work.
y
clients
previously
requested
if
your
journa ist
wanted
to
have
a
n
y
interviews
se
t
up
for
him,
providing
a
balanced
perspective
on
important
issues,
an
d
your
journa ist
did
accept
this
offer.
y
clients
have,
as
a
result,
no
w
pro-actively
provided
your
journa ist
with
this
information,
in
th
e
hopes
that
Canadaland
will
seek
to
either
quote
and/or
contact
these
sources
to
have
a
fair
an
d
balanced
article.
True
an
d
fair
journa ism
would
be
done
without
bias
o
r
malice,
in
th
e
spirit
of
wanting
to
collect
as
much
information
as
possible,
attention
to
detail
on
facts,
an
d
allowing
fair
opportunity
for
comment.
Allow
us
to
reiterate
th
e
following
requests:
A.
Request
for
th
e
basis
of
claim(s)
by
your
publication,
your
journa ist
and/or
others:
It
is
th
e
right
of
m
y
clients
to
know,
understand
an
d
given
an
opportunity
to
respond
to
th
e
exact
nature
of
an
y
claim(s).
In
th
e
interest
of
fair
an
d
balanced
reporting,
Canadaland
needs
to
provide
th
e
specific
claims
being
made
by
either
your
publication
and/or
your
journa ist
and/or
others
associated
with
th
e
article
an
d
m
y
clients
need
to
have
th
e
opportunity
to
respond
appropriately.
It
is
reasonable
to
provide
m
y
clients
with
a
72-hour
window
of
time
to
answer
an
y
claims.
oreover,
they
ar
e
provided
with
adequate
context
an
d
basis
to
these
claims
o
r
accusations,
an
d
that
any
claim
is
c ear
whereby
they
ar
e
no
t
shrouded
in
innuendo.
Refusal
shows
a
lack
of
journa istic
integrity
an
d
that
your
website
ha
s
little
interest
in
th
e
truth.
It
further
shows
that
yo
u
an
d
your
team
ar
e
acting
with
malice.
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