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8/9/2019 File 149646 Robertson-Meggs Response to Petition, Plus Supporting Affidavit #1 Geoff Meggs
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BETWEEN:
AND:
No. 149646
Vancouver Registry
IN
THE SUPREME
COURT
OF BRITISH
COLUMBIA
RANDAL HELTEN LBERT
HIN,TERRY
GLENN
MORDEN lso known as
TERRY GLENN
MARTIN
RICHARD .G.NANTEL nd VIRGINIA
A.
RICHARDS
GREGOR
ROBERTSON
and GEOFF
MEGGS
RESPONSE TO
PETITION
FORM 7 RULE
6-1(5))
PETITIONERS
RESPONDENTS
Filed by:
GREGOR
ROBERTSON and
GEOFF
MEGGS
the
petition
respondents )
THIS IS A RESPONSETO he petition
filed
December
12,
2014.
PART : ORDERS CONSENTED
TO
The petition respondents
consent to
the
granting
of
he
orders set out in the following
paragraphs
of
art 1
of
he
petition: NIL.
PART : ORDERS
OPPOSED
The
petition respondents
oppose the granting of
he
orders set
out
in
paragraphs 1
—6 f
art
1 of
the
petition
and seek
dismissal of he
petition
with
special
costs.
PART :
ORDERS ON WHICH
NO
POSITION IS
TAKEN
The
petition
respondents
take
no
position
on
the
granting of
he orders
set
out
in
paragraphs Nil
of art
1
of
he
petition.
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2
PART :
FACTUAL
BASIS
1.
The
supporting affidavits filed
by the
petitioners
contain
no reliable or
admissible
evidence that
could
support
the
allegations levelled against
Mayor
Robertson
and
Councillor
Meggs.
Instead,
the
petitioners
have
chosen
to
swear
affidavits
replete
with
inadmissible
opinion,argument and
anonymous hearsay.
2. In this regard
the
petition and
supporting
affidavits
contain
false
and
defamatory
allegations
and
innuendo. The gravamen of
the
petitioners' complaint is that Mayor
Roberson and
Councillor Meggs re corrupt.
More
particularly,the petitioners allege that
the
petition
respondents,
as representatives
of ision,engaged in a pay to
play
scheme
with
the executive the
Canadian
Union
of
Public
Employees, local
1004 CUPE
Local 1004).
(See
eg.
Affidavit #1 of V.A.
ichards at paragraph 6
nd
7)
(See
Affidavitof eoff
Meggs t
paragraphs
16 — 24)
3.
Had
the
petitioners
published the
defamatory
statements
in a
forum
other
than
court
proceedings,
the respondents
would
have commenced
an
action for defamation as they
did
when
similar allegations
were published by the Civic Non
-Partisan
Association and
its
mayoralty
candidate,Kirk
LaPointe,
during last fall s
civic election.
(See
eg.
Affidavit#1
of eoffMeggs
t paragraph 17)
4. The petition
is ostensibly
premised on an alleged
discussions
between Gregor Robertson
and
Geoff Meggs on the one hand and
representatives ofCUPE Local 1004 on the
other
hand
concerning the
terms
on
which CUPE
Local 1004 would support Vision
candidates,
ncluding
Gregor Robertson
and
Geoff Meggs .
(See
etition,paragraph 12)
5.
The ffidavits do not
ontain
any
evidence:
(a) of discussions
between Gregor Robertson and Geoff
Meggs
and representatives
ofCUPE 004 . Indeed
such a
meeting is
specifically denied by
Geoff
Meggs.
(See Affidavit#1
of eoffMeggs t paragraph 10 ;
(b)
of
he
identity
of he representatives
of
CUPE
ocal 1004 ;
(c) the
date,
time
and place of he
alleged meeting/discussions;
and
(d) what,
fanything,
was
greed
to at the alleged meeting/discussions.
6.
All the petitioners offer
by
way
of evidence
is
second, third or
fourth-hand
hearsay
evidence
obtained
over the
internet
from
a ink
to a reporter's
story
about a ecording
he
obtained from
an
anonymous source.
The
recording is
of
a
small portion
of
a meeting
that occurred on October
14,2011 attended by
GeoffMeggs.
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3
(See
Affidavit#1 of
andal
Helten at paragraphs 7
9)
(See
Affidavit# f andal
Helten at paragraph 3)
7. Assuming that the
evidence
found
in the various
affidavits filed on
behalf
of
the
petitioners
is
admissible,
ll
that
the
evidence
discloses
is
as
follows:
(a)
CUPE
Local 1004 Political Action
Committee recommended
that
CUPE Local
1004 make a campaign
contribution
to
Vision Vancouver
of 34,000;
(See Affidavit#1 ofRandal
Helten,at paragraph8
nd Exhibit
B )
(b)
various labour
unions,
including CUPE
ocal
1004,made
donations
to
the
Vision
election campaign;
(See
Affidavit#1
of
andal
Helten at paragraph 6)
(c)
that GeoffMeggs spoke at the October 14 meeting ofCUPE
ocal 1004;
(See Response
#4
of essica
Landgraff
o questions
from the petitioners'
counsel)
(d) that GeoffMeggs made he
following
statement
in
the
course
of
is
remarks:
Gregor Robertson,
our
mayor,
has again recommitted
to not
expand
contracting out
to
make sure that
wherever we
can bring
in
new
processes
that members of
1004 will be there delivering those
services in your areas
of
urisdiction,
..
(See Affidavit
#1 of
ilary Renaud, xhibit A
8. There is no evidence that the decision to contribute to the Vision
campaign
was tied to
what
Mr.
Meggs said
in
his remarks
to
those present at the October 14 meeting.
Mr.
Meggs specifically
denies
any knowledge
of he recommendation of he Political Action
Committee of CUPE Local
1004
to
contribute to the Vision campaign
and specifically
denies
that
he
met
with anyone from CUPE 1004
prior
to the meeting . He lso denies
that he had
discussion with anyone
from CUPE
1004
about
promising
any
benefit
to
CUPE
1004 r
its
membership in exchange for a political
donation .
(See Affidavit#1
of
eoff
Meggs t
paragraph
10)
9.
There
is
no evidence
to
contradict
the
sworn
evidence
of Mr.
Meggs at
set out
in
the
preceding
paragraph.
10. The
affidavits filed on
behalf
of
he
petition make
no
eference
to
Mr. obertson at all
11. The evidence
of Mr.
Meggs is that
the
policy of
Vision Vancouver to
not
support
expansion
of ontracting out of ity
services
dates back to the 2008 municipal election.
Mr.
Meggs did nothing more
than
confirm that there
was
no change in
this
policy when
he made
his remarks at the
October 14,2014 meeting.
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4
(See Affidavit 1
of eoff
Meggs
t paragraphs
13)
PART :
LEGAL
ASIS
1.
Nothing
in
the
petition
or
the supporting
affidavits
establishes that
Mayor
Robertson or
Councillor Meggs acted in a conflict
of
interest or may have
had a
direct or
indirect
pecuniary
interest
in the
matter.
2.
Similarly, nothing in the petition or
the supporting
affidavits
establishes that
CUPE
004's
contribution to
the electoral
campaign
of Vision
Vancouver
Vision )_
was made on the
express
understanding that all of
he
Vision candidates,
if
elected,
including Mayor Robertson and Councillor
Meggs,
would deliver their
votes not
to
expand
contracting out.
3.
Rule
22-2(12)and
(13)
ets out the nature of he affidavit evidence a
deponent
may give:
(12)
Subject to subrule (13), an affidavit must state only what a
person swearing or affirming the
affidavit
would be permitted to
state in evidence
at a
rial.
(13)
An
affidavit may contain statements as to the information
and
beliefof
he
person
swearing or
affirming
the affidavit, if
(a)
he
source
of
he information and
belief
s given,and
(b)
he
affidavit
is
made
(i) in respect of n application that does not seek a
final order,
r
(ii) by
leave
of
he court
under Rule 12-5(71) a)
or 22-1(4)
e).
4.
The
orders
sought by the
petitioners are final
orders.
5.
In
C.(KL.)
.
C. J.),
Master
Baker provided a
useful
summary of
he
jurisprudence on
objectionable affidavits:
Counsel for
Mr.
C. elies
upon
F.(J.K.)
v.
F.(J.D.)(1986),
B.C.J.
No. 672; Creber
v. Franklin (1993),
B.C.J.
No.
890; and
Webber
v. Wallace (1994), B.C.J.
No.
894.
All
are decisions of ur court.
Shortly stated, in all
these
cases the court
directed
that portions
of
affidavits be
expunged for various
reasons.
These
reasons include:
hearsay
upon
hearsay,
or
irrelevance (F.(J.K.)
v
F.(J.D.)),
inadmissible
opinion,
adjectival
descriptions, or subjective
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5
descriptions of eactions
Creber),
unidentified witnesses,
opinions
regarding motives,
or
argument Webber).
2000
BCSC
98
Emphasis
n
original]
6.
All these
objectionable
features
are
manifest
in
the
petitioners'
affidavits, and
the
offending portions ought o be
truck out pursuant
to
Rule 9-5(1).
Jones
. Industrial Wood
and llied Workers
of anada
Local -3567),
2011
BCSC
26
t para.
o
17
7.
The
first
affidavit
of
petitioner Randal
Helten is
particularly noteworthy for
its
noncompliance
with
Rule
22-2(12)
nd the
common
law
rules of
vidence.
For
example,
at
paragraph 9(b)
f is affidavit,
Mr. elten
purports
to lead
evidence ofa secret audio
recording
of
a
CUPE
1004
membership
meeting
that allegedly
occurred
on
October
12,
2014,a meeting
which Councillor Meggs urportedly
attended
(the Audio
Recording ).
8.
The
Audio
Recording is the
only factual
evidence offered
by
the
petitioners that
could
conceivably suggest impropriety by the respondents.
9. The
ifficulty for
the
petitioners
is
this:
In the
hands of
Mr. elten,
the Audio
Recording
is at best,
quadruple hearsay.
According to Mr.
elten,
he
obtained the
Audio Recording
(quadruple hearsay)
from
the
YouTube
website
(triple
hearsay),
which
had
obtained
it
from reporter Bob Mackin double hearsay)
who
obtained it from an anonymous
source
(hearsay)who allegedly
recorded
the
words
spoken therein.
10.
With this
many degrees
of eparation between Mr.
elten and
the
speakers of he
out
-of-
court
statements,
Mr.
Helten could never
authenticate
the Audio
Recording at
trial.
(There
is no suggestion
that Mr.
Helten
was at
the meeting
where the
words were
spoken.) By simply attaching an electronic file of the recording to his affidavit,
Mr.
Helten
does
not
make
he
Audio
Recording
admissible
as
evidence.
R. v.
Andalib-Goortani,
2014ONSC
690 t
para.28 o 34;
R.
v.
George
Jack
Giroux,2013NWTTC
4
and authorities
cited
at
para.18
to
25);
Ulrich v. Ulrich,2004BCSC 5 t para. at 32
11.
It follows
that the
petition is
without
an
evidentiary basis and an
abuse
of
the
Court's
process; t ought
to be
struck
out
ursuant to
Rule 9-5(1)(d).
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Chernen
v
Robertson,
2014
BCSC 1358 at
para.29 o
33.
12. The petitioners originally brought
an
application
to have
the claim
struck
but adjourned
the
application at the
request of
counsel for
the
petitioners in order to
allow the
petitioners
to adduce
further evidence which they
did in the
form of
a
statement
from
Jessica Landgraff,a
union employee who
took
minutes
of he meeting on
her laptop. All
that the
evidence
of
Ms. Landgraff
establishes
is
that
Mr. Meggs attended
the
meeting
and that
the recording
appended
to
Mr.
elten's
affidavit soundsaccurate .
13.
Rather
than renew
the
application
to
strike
the claim the
respondents elected to file
this
response
so that the
petition
would
be
decided
on
ts merits.
To
that
end,
Mr.
Meggs has
sworn
an
affidavit in which he confirmed his presence at
the meeting and acknowledged
that
he aid the words relied
on
by the
petitioners.
14.
Ms. Landgraff
evidence
is important
in one
respect. She
states
that
the
recording
is
incomplete or has
been edited or both . The recording
lasted approximately
9:22 minutes. The meeting lasted from
5:00 p.m. until
6:52
p.m. Ms.
Landgraff
evidence is
also
important
in another respect.
She is
the only witness/affiant
that
was
present
throughout the entire meeting.
Importantly,
her
statement
does not make any
reference to what
f
any
motions
were approved at the
meeting.
15. In summary,even with the evidence of Ms. andgraff, the petitioners have
not met
the
evidentiary
burden on
them
to prove,even
on
a
prima
facie basis,
what,
if
anything,
was
approved
at the
meeting.
16. Leaving
this issue
aside,
there
is no evidence
connecting what
Mr. Meggs said in
his
remarks to the contribution made
by
CUPE
ocal
1004 o the Vision campaign.
There
is
no
offer
and
acceptance
which
is the essence
of
a binding
agreement.
As for
CUPE
Local
1004
t is
impossible to
say
what
they
decided at
the
meeting
because there is only
a artial transcript ofan unverified
recording
which is incomplete or has been edited or
both .
17. Accordingly
the
petition
and supporting
affidavits
fall far short
of what is
required to
support
a
inding that the respondents had
a
irect or indirect pecuniary
interest
that gives
rise to a
onflict
to interest
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8
contribution is
not
enough. In the absence
of
ny factual basis
for
finding that Mr.
King
had
a
pecuniary
interest in the matter, the
finding
based
on
s.201(5)
is
wrong
in law and
must
be
set aside.
21.
The
obvious
lack
of
egal
merit
of
his
proceeding,
together
with
its
apparent
political
purpose,
ought to
attract
an
award
of
pecial costs. In every
respect
it
is reprehensible
and
deserving of
ebuke.
Not
only
does it make
scandalous
and unfounded allegations
and
innuendoes, but
it
is
an
abuse of
his
Court's
process for rank political ends.
22.
In
Morriss v.
Prism
Properties
Inc.,
2010
BCSC
54, he Court,
per
Gropper
.
held,
in
making
an
award for
special
costs:
[83] Special
costs
are awarded
in cases where
the conduct of
he
one
of he
parties
is reprehensible .
That
term was
interpreted in
Garcia v. Crestbrook
Forest
Industries
Ltd 1994
CanLII 2570
BC
A), 1994),9
.C.L.R. 3d)
42
t para.
17,
119
D.L.R.
4
740
C.A.):
[17] .. it is my
pinion
that the single standard for
the awarding
of pecial costs is that
the
conduct in
question
properly be categorized
as
reprehensible .
As
Chief ustice Esson said in Leung v.
Leung, he
word reprehensible is a word
of
wide meaning.
It
encompasses
scandalous
or
outrageous
conduct
but
it
also encompasses
milder forms
of misconduct
deserving
of
reproof
or
rebuke. Accordingly, the
standard represented by the word reprehensible,
taken
in
that
sense,
must represent a general
and al l
encompassing
expression
of
he
applicable
standard
for the award of pecial costs.
[84] Special costs can be awarded on the basis that
the
plaintiff's
claims lacked
legal merit,
or
if
the
plaintiff
fails
to ascertain that
there
is no evidence to support the claim before advancing it:
Crown West Steel
Fabricators
v. Capri Insurance Services Ltd.,
2003BCCA 268 CanLII),
2003 BCCA
68,
227
D.L.R.
4
74.
I
am
onvinced
that Mr.
Morriss'
pursuit
of is
claim
based
on
the
alleged option was
not
so
benign. It
was
not
a
mere
failure to
ascertain
that there was
no evidence
to
support
it; rather, it
was
a
premeditated
attempt to harass
the
defendants
to
achieve
Mr.
Morriss'
ends
—
o
get the
property.
[85]
In CatalystPaper
Corp.
. Companhia
de Navegacao Norsul,
2009
BCCA
16
CanLII), 2009 BCCA 16, 307 D.L.R.
4
85,
Mr. ustice
Hall
stated
at para.
17:
[17]
It
seems
to
me that the trend
of
recent
authorities
is
to
the effect that the costs
rules
should
be utilized to have a winnowing
function
in
the
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litigation
process. The costs
rules
require
litigants
to make careful
assessments
of
he strength or
lack
thereof of their
cases at
commencement and
throughout the course
of
litigation The rules
should
discourage the
continuance
of
oubtful cases
or
defences. This
of
course imposes
burdens
on
counsel
to
carefully consider the
strengths
and
weaknesses of
particular fact
situations. Such
considerations
should,
among other
things,
encourage
reasonable
settlements.
23.
Finally,
a
failed
allegation in a
civil
lawsuit
of
orrupt
conduct
will more readily
justify
an
award
of
pecial costs against the
maker
han
will
other
types
of nproven
allegations.
Abakhan
ssociates Inc. v Golden Arch
Resources Ltd,
2012
BCSC
46
t
para.
7
PART :
MATERIALTO BE RELIEDON
1. Affidavit
1
of
eoffMeggs,made March
19,
2015.
The petition
respondents
estimate that
the
application will
take one
day.
xP
Date:
23
March 2015
HARPER GREY up
(Per
Bryan
G. Baynham,
.C.)
Lawyer
or
the
petition
respondents Gregor
Robertson
and
Geoff
Meggs
The petition respondents' address for service is :
HARPER
GREY
LP
Banisters olicitors
3200 650 West Georgia
Street
Vancouver,BC V B 4P7
Telephone:
604 687
0411
Fax
No:
604 669
9385
Attn: Bryan G. Baynham,
.C./sjp/ 131894
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BETWEEN:
AND:
This
s
the 1st
affidavit
ofG.
Meggs
n this
case
and
was
made on
March 19,
2015
Court
ile
No.:
S149646
Vancouver Registry
IN
THE
SUPREME
COURT
OF RITISH
COLUMBIA
RANDAL
HELTEN LBERT HIN,TERRY GLENN
MORDEN
lso known asTERRY
GLENN MARTIN
RICHARD .G.
NANTEL nd VIRGINIA A.
RICHARDS
GREGOR
ROBERTSON
and
GEOFF
MEGGS
AFFIDAVIT
FORM
09 RULE 2-2(2)AND 7))
PETITIONERS
RESPONDENTS
I GEOFF MEGGS ouncillor,
of 819
Sawcut Avenue,
n
the City
of Vancouver,
rovince of
British
Columbia,
MAKE OATH
AND SAY AS FOLLOWS:
1. I
am
a resident of he City of ancouver and elected
member of
ouncil having first been
elected
in
2008 and
re-elected
in 2011 and
2014. As such
I have
personal knowledge of
the matters and
facts
herein
deposed
to save
and except where the same
are stated
to
be
made
upon
information and
beliefand as o the latter
I
verily
believe
them to be
true.
2.
I was a
founding member of
he
municipal
political party
known
as
Vision
Vancouver
and
have personal knowledge concerning its policies over
the
years
including the
longstanding commitment
not to expand
contracting out
of
obs
performed
by the City s
unionized
employees
including
members
ofCUPE 004.
3. I recall the issue of
ontracting
out
coming
up
in the
2008
nomination to
be the mayoralty
candidate for Vision which
was
contested by Raymond Louie, Gregor Robertson and
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2
Allan De
Genova. Raymond
Louie,
who
lost
the
nomination battle
to Gregor
Robertson,
publicly declared
during the campaign
that he
was gainst contracting out
as city
workers
provide
good
value for money.
Gregor
Robertson,
to the
best ofmy
ecollection, did
not
make
a
definitive
statement that he
was against further contracting
out until after
he
won
the
nomination.
4.
In
the
2008
municipal election
all Vision
candidates
including
Mayor
Robertson and
myself publicly
stated that we
opposed
any expansion
of
ontracting
out
of
ivic
jobs.
This policy was
widely
publicized in the media as
was
the
fact that
Vision
was
supported
by the union movement,
including CUPE 004. By way
of
example,
a
GEORGIA STRAIGHT ditorial
dated
November 2008 stated
as
ollows:
Keep in mind that there are some ignificant differences between
Vision and
the
NPA. Vision is supported
by
many unions,
so it
shouldn't surprise
voters
when its
mayoral candidate,
Gregor
Robertson,
promises
not to
contract
out
civic
services.
Attached and
marked as
Exhibit
A
o
this my ffidavit
is
a copy of
he online editorial
dated November
12,2008.
5. There was no
change in
the Vision policy with
respect to contracting out in
the
2011 civic
election in which Mayor Robertson and I were
both
re-elected.
Once again,
the
position
of he
Mayor and of
ll
Vision
councillors
was
a
matter
of
ublic record.
One
example
of
the public record is the
GEORGIA
STRAIGHT
andidate
survey
which all hopefuls
including
all seven
Vision
councillors
answered.
Question
10 ead as
follows:
10. Do you favour contracting out more
city
services to the
private
sector?
along with the other
six Vision candidates answered
no to this question.
Attached
and
marked as
Exhibit B o this my affidavit is
a
copy
of the
GEORGIA
STRAIGHT uestionnaire.
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6. The
2011
Vision
Vancouver campaign
again
sought
the
support
of he
union
movement
and
union
members. As
was
the case in
2008 various unions
including CUPE
1004
publicly
supported Vision
Vancouver and donated
funds
o
Vision's
election
campaign.
7. In the
lead
up
to the
2014
election
campaign
the Vancouver
District
Labour
Council
Political
Action Committee
( VDLC ) ent out
a
candidate survey to those
seeking the
office
of mayor r
councillor.
One
of
he
questions
in
the
survey was as ollows:
3.
Under
what ircumstances would
you
consider
contracting
out
or rivatizingpublic services?
My
nswer
o that
question was s follows:
Our council has not expanded contracting
out or
privatization
and I do not support any
change
to thatapproach.
It
is my
nderstanding that
Mayor Robertson and each of he
Vision councillors answered
this
question,
if
not in
the
identical
words, in words to the same
effect, that is they
answered
that
they
did
not support
any expansion of ontracting out.
Attached
and
marked as
Exhibit C o
this
my ffidavit is a copy of my
answers
to the
VDLC
andidate
survey
for
mayor
and
counsel.
8.
In
the lead up to the 2014 civic election
Vision again
sought
donations from
and
the
support
of
arious public
sector unions. As
art of isions' fundraising
efforts
I
assisted
in
preparing
a
undraising
letter
addressed
to
various unions that was ltimately
approved
of nd signed
by Mayor
Robertson.
In
the letter
Mayor
Robertson
specifically
confirmed
that those
seeking
election under
the Vision Vancouver
banner were committed to
encouraging no
privatization
or contracting out.
Attached and marked
as
Exhibit D o
this
my
affidavit is
a
copy of
the generic
fundraising letter
sent out
under
the
signature
of
Mayor obertson.
9. On
October
14, 2014
during the
civic
election
campaign
I
attended
a
membership
meeting
of
CUPE
1004 along
with Councillor
Raymond Louie
and
Parks Board
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commissioners
Trevor Loke and
Niki Sharma. As I understood
it
several
civic
political
parties
were
invited to
the
meeting
and
were
given an
opportunity to
seek financial
support
and
endorsement by the
membership of CUPE
004.
Having listened to a
recording of a portion
of that meeting and having
had the opportunity to
review
the
agenda
Exhibit B o
affidavit 1 of
Randal
Helten), I understand
that
the Political
Action Committee
of
CUPE
1004
had met in a previous meeting and
recommended that
$34,000 be donated
to the Vision
campaign and that the Political
Action Committee's
recommendations would be put to a vote at the
meeting.
10.
At
he
time
I
had no
knowledge
of
he
fact that
the
Political Action Committee had made
a
recommendation
to contribute to the campaign
of
Vision Vancouver. I had not met
with anyone from CUPE
1004
prior
to
the meeting nor did
I
have
any
discussion
with
anyone from CUPE 1004
about
promising any benefit to CUPE 1004 or its membership
in exchange for a
olitical
donation.
11.
The
four representatives
of Vision
Vancouver
including
myself
were
only
present
for a
small portion
of
the meeting.
I was present for and
heard
the oral presentation by
representatives of
COPE. There
was
also a presentation
from two
school board
candidates.
I made a brief
presentation and
listened
to
the
presentations
thereafter by
Niki
Sharma,
Trevor
Loke
and Raymond Louie. My
remarks
were intended
to
convey,
and I believe did convey, that those running under the
Vision
Vancouver banner had
close
ties and were supportive of he union
movement generally
and would appreciate
their
support.
12.
knew that
the
issue of ontracting out was
mportant
to
the
membershipof
CUPE 1004,
as
well
as
other unions,
as
it
had
been
in
the campaigns
of 2008
and 2011.
Recognizing
this fact, I reiterated
the
longstanding commitment
of ision
Vancouver not to
support
an
expansion
of ontracting out of ity
services.
13.
My
emarks were intended to confirm that our commitmenton his issue had not changed
since 2008.
The same
commitment had
been made
in
past
campaigns and was also
contained
in
the fundraising
letter
sent by Mayor Robertson to various unions
approximately six weeks before the meeting.
The commitment not to
expand
contracting
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5
out was not
in
any way
tied to
whether
or
not CUPE 1004
or any
other
union for
that
matter
made
a donation
of ny size
to the
Vision Vancouver
campaign.
14. Following
the
presentation
of
Raymond
Louie
I
left
the
meeting with
the other
three
representatives. do
not know what was
discussed
after
we
eft nor the
outcome
of
he
vote,
save
and except for the
transcript
that
has
been produced as
Exhibit
D to
affidavit 1
of ilary
Renaud. I
have read
the
transcription
of he audio
recording
and
have
listened to
the audio
recording attached as Exhibit
C
o
Mr.
elten's
affidavit 1.
The
transcription
of my remarks
and
those of
Ms. Sharma,
Mr. Loke
and Mr.
Louie
appear
to
be accurate.
As
was
not present for
the remainder of he
meeting
I
cannot say
whether the transcription ofwhat
was aid
by
unnamed
individuals
after
I left
is
accurate.
15.
Prior to
swearing
this affidavit I had
the
opportunity to review the
response
of
essica
Landgraff
to
questions put
to
her in
writing by
the petitioner's
counsel.
note,
in
particular,
her
answer to
paragraph 9
where
she states that
the
recording in question is
approximately 9 inutes and 22 econds
in
length and while the meeting
lasted
for
almost
2
ours
from 5:00
p.m. until
6:52 p.m. Ms. andgraff also
states that
the
recording is incomplete
or
has
been
edited or both .
A
copy
of Ms.
andgraff statement is
attached
and
marked as Exhibit E
o
this my
affidavit.
16.
As disclosed in
Mr. elten's affidavit
1
my
presentation
to
the
membership of
CUPE
1004 at
the
general meeting on October
14
th
was
disclosed
in
a
news
story
published
in the VANCOUVER COURIER by Bob Mackin.
Included
in the
online
version of Mr. Mackin's tory was a ink
to
a ecording
of mall portion
of
he
meeting.
17.
Based
on
Bob
Mackin's
story
and
a
link to
a
recording
of a
portion
of
he October
14
meeting, the NPA mayoralty candidate, Kirk
LaPointe, in
an OPED piece in
the
PROVINCE
newspaper,at
a press conference, in
paid
advertisements on television and
radio stations and in postings
on
the Civic Non-partisan Association website accused
Mayor
Robertson
and
me
of
orruption,buying
votes,
dishonesty and a ack of
ntegrity.
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18. We were
not prepared
to
allow these
defamatory
statements to go
unchallenged
and
instructed
counsel
to
commence an
action for
defamation.
The action
for
defamation
was
served
and a response
filed on
behalf
of Mr. LaPointe
and the
Civic Non-partisan
Association
prior
to election day. I
value
my reputation for
personal
integrity and
honesty
very highly
as does Mayor
Robertson.
Mayor
Robertson and I intend to see
the
case
to trial and have instructed
our
counsel to obtain the
earliest
possible trial date.
19. have
read Affidavits #1 and #3
of
Randal Helten who ran
unsuccessfully
for mayor
against
Mayor
Robertson in
2011.
In paragraphs
11
to
13 of
his
first affidavit and
in
paragraphs
o 8
of
is
third
affidavit, Mr.
Helten leaves no doubt
that
he
believes and
his fellow
petitioners believe
that I
was
party
to
a
corrupt
agreement between
Vision
Vancouver
and CUPE
004.
I
consider this
a
direct attack on
my
ntegrity
and
honesty,
as well as a direct
attack
on
Mayor
Robertson's
integrity
and honesty.
In
effect, Mr.
Helten
is using the defence
of
bsolute
privilege that applies
to
affidavits
filed
as
partof
court proceeding to echo
defamatory
statements
that
are the
subject of separate
proceedings.
20. I find it
particularly
offensive that Mr.
Helten
purports to
be the
voice of
thousands of
electors in Vancouver
and
that
he and his
fellow affiants are simply
bringing
this
claim
so that issues
that
are important to our democracy can be resolved by the Court
notwithstanding the
verdict of
he voters,
who re-elected Mayor Robertson
and
me.
In
his
affidavit,
Mr. Helten also purports to
be
an advocate
for
promoting transparency
and
accountability , while at
the
same time he refuses to answera question from
Charlie
Smith of
he
GEORGIA STRAIGHT s to
who
was
unding the
petition.
In my iew
this
petition is
nothing
more than a desperate attempt by
Mr.
Helten and others to use the
courts
for
political purposes.
21.
I have
also read
the
Affidavit
#1 of Virginia Richards. To my knowledge I
have
never
met Ms.
ichards,
nor
do
I know
anything
about
her
background
and
politics
save and
except
for what
is
contained
in her
affidavit.
I
consider
the
statements contained
in
paragraphs
5 o
7
o be
a direct
attack on
my
ntegrity
and honesty and an
attack on the
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7
integrity and
honesty
of
Mayor
Robertson.
This
is
clear from
paragraph
7
f
er
affidavit
where she
specifically
states
that
t
is her belief that
we
re corrupt .
22.
I
have
also
read the
Affidavit
#1 of
lbert
Chin.
In paragraphs
6
nd
7
r.
Chin
takes
a
slightly
different
attack
on
my
ntegrity and
the
integrity of
Mayor Robertson
by
alleging
that as a result
of accepting
a
donation
from
CUPE
1004
Mayor
Robertson, Raymond
Louie
and I lack
ethical
standards .
In
paragraph7 he defames the
three of
us
by
alleging that we engaged
in
pay
for
play by
offering to exchange
influence for
a
political
donation,even if hat as not
actually
said
on the
recording .
Once
gain I
consider this
to
be a
direct attack
on
the
integrity
and
honesty
of me, Mayor
obertson
and
Councillor
Louie
which
would
form
the basis
for an
action in defamation were t not for
the
fact
that
the
defamatory allegations
were
made
n an
affidavit
in support of
he
present petition.
23. I have also read
the
Affidavit#1
of erry Glenn
Morden,
who
lso ran
unsuccessfully
for
council in 2011
as
a
member of Mr.
Helten's
electoral organization. At
paragraphs
9
to
11, after referencing
the article
by Bob Mackin, Mr. Morden
asserts that
by
exchanging
promises
I had done a terrible
thing
which
subverts
our democracy .
Once
again,
consider
this to be a irect attack
on
my ersonal
integrity
and
honesty.
24. I have
also read
the
Affidavit#1 of
Richard J.G. Nantel. In paragraphs
to
9 of his
affidavit, Mr. antel makes vague references to
done deals
and then references his
concerns about
my
statements
at
the
October 14
meeting and
the
resulting lawsuit
against
the
NPA and Mr.
aPointe.
He
concludes by stating
that
That kind
of
money
exchange
to
me
seems
violation of
proper conduct under the
Vancouver
Charter .
While Mr. Nantel's
statements are
more
nuanced than the
outright
allegation
of
corruption
by Ms. ichards,
I
still consider it to be
an attack on
my
ntegrity and
honesty
by
implying
that I was
a
party
to
a
pay
to play scheme
by
accepting money or
Vision
in
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8
ex
cha
nge
fo
r a
com
mit
men
t
not
t
o
pe
rmi
t
c
ontr
act
ing out
of
ci
ty
serv
ice
s
in th
e
nex
t
coll
ecti
ve
ag
ree
ment
be
twe
en
t
he Ci
ty
of
a
nco
uve
r
a
nd
CU
PE
004
.
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1318
94/28
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The
Straight
slate
for
municipal
elections
in
Vancouver and
the
burbs
Georgia
Straight, ..
Page
f 17 2.
HALF
PRICE
PAYMENTS
W
OR A
1,000
NEW
YEAR
BONUS
>
FIND
OUT
MORE
Tho
ower o urortto
KIA
VANCOUVER
candidate, s
ar
aswe an
ell,
has
ttered
a peep
about he
provincial
government s
punitive
social-welfare
and axation
policies,which are t
the root
of ampant
omelessness.
NoNPA
candidate,
s
ar
as
we an ell,
has oiced any oncerns
about he
provincial
government s
refusal to
do nything or
trban aboriginal
youth in
Vancouver, ho
re sometimes
he most t
riskof
becoming
drug
ddicts.
It s
temptingto recommend
a
pox on
both major
artiesand rge
the public to
otefora
lateof
ndependents.
But hat
wouldn t
result
n
the
best
city
council
or Vancouver, ecause th e
independents
have
no xperience.
hat s
why we avour a alanced
slate
that
mixes xperience with
idealism.
Keep n
mind
hat there aresome
ignificant
differencesbetween
Vision
and
he NPA.
ision
is supported by many
nions,
o
t
shouldn t surprise
voters when
ts mayoral candidate, regor
Robertson, romises not to
ontractout
ivic services.
NPA
ayoral
candidate
Peter Ladner
has
aid he s open to
the
dea
of
contracting
out
ervices f his provides
a
etter
deal or
axpayers.
The
NPA as lready upported an Boo,000 xpansionof
he
Downtown
Ambassadors
program; his s,
n
effect,
ontracting
out
security
to business-improvement ssociations. Many roperty
ownerson
he boards
f
hese associations
are
also
ontributorsto
the
NPA.
During ouncil s
last
term,
ision,
nd
not
the NPA, as
he
oudest
proponent for
ncreasing
the number f
olice
officersin
Vancouver.
The
olice union is
a
ontributor
to
Vision,which opposes
expanding
he Downtown Ambassadors program.
If
you hinkVancouverhas oo many
olice
already—another96
officers
and22
ivilians
were
lated
this
year
and
next—then
you
probably houldn t vote or
ither
Robertson or Ladner or mayor.
Ata
November
9 andidates
meeting,
ndependent
mayoral
candidate MarcEmery
dvocated
freezing
the
policebudget orever
and aking away fficers
asers
fhebecomes hair
of
he
Vancouver
olice board.You
on t
hear
that
from Robertson or
Ladner.
Vision
and he NPA lso
have
istinctlydifferent
positions
regardingthe
ix
-lane
Burrard
Bridge. ision
and
ts
ally,
he
Coalition
of
rogressive Electors,
avoura rial converting
one
ane
of
rafficfor cyclists,a alf-lan eeach n
either
direction.During
he
trial,
there
would
be ignals
nstalled
that would
change
he
directionof he car
anes
similarto the
signalson
he
Lions Gate
Bridge)
o here
would
lways be
hree
lanesopen or
rush-hour
vehicles.The
ther
two ar
anes
would
always ravel n the
opposite
direction.
The
NPA
now
opposes ts earlier
plan to widen the bridge,which
would
have
ost up o 63 illion.During
he recentcampaign,
Ladner
proposed hata barrier
be nstalled separating cyclistsand
pedestrians
and raffic.
According to the
NPA,
his
would
cost 33
millionand etain
all
six
lanes or motorized vehicles.
The
esky
eft-wing
gnat n this election,
he
Work ess arty,
supportsdedicated bike-lane
corridors inking all parts
of he ity,
as ell as edicated bike
and bus
anes
on
ll
roads
and
ridges.
The Work
Less
arty,whose
ayoral
candidate
s ntilogging
activist
Betty
Krawayk,
lso
favours reducing
reliance
on
rivate
cars by ntroducing road tolls.COPE
as alled
fora
ree bus oop
between
the downtown ore and the
Broadwaycondor
and
will
push
or
a
ingle
transit
fare for
the
whole region.
On
evelopment ssues, ision and the NPA ave
oted
in
favour of
freezing
the
rate
of hange n
certain neighbourhoods,which has
slowed the
number f victions.
As
esult,
t s
harder
or
developers to convert rental
buildings into strata
-title
condominiums.
SEE FULL
IST OF
BEST
OF
ANCOUVER
WINNERS r
LATEST
STORIES
Video:
How
o behave as a
Fernen
activist
(warning: nudity)
ET CETERA
s
4
MINUTES
AGO
Fourteen
things to do
n Metro
Vancouver on
Friday,January 16
LIFE 7 MINUTES AGO
Pot
ctivist Marc
Emery
alks shop
at UBC
LIFE 9 MINUTES AGO
http://www.straight.com/news/straight-slate-municipal-elections-vancouver-and-burbs
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