file 149646 robertson-meggs response to petition, plus supporting affidavit #1 geoff meggs

8/9/2019 File 149646 Robertson-Meggs Response to Petition, Plus Supporting Affidavit #1 Geoff Meggs

1/30

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.

131894/2812940.1


2/30

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.

131894/2812940.1


3/30

-

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.

131894/2812940.1


4/30

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

131894/2812940.1


5/30

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).

131894/2812940.1


6/30

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

131894/2812940.1


7/30


8/30

-

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

131894/2812940.1


9/30

9

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

131894/2812940.1


10/30

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

13189412815200.1


11/30

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.

131894/2815200.1


12/30

-3

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

13189412815200.1


13/30

-4

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

131894/2815200.1


14/30

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.

13189412815200.1


15/30

6

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

131894/2815200.1


16/30

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

13189412815200.1


17/30

8

ex

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men

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not

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pe

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c

ontr

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PE

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1318

94/28

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18/30


19/30

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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file 149646 robertson-meggs response to petition, plus supporting affidavit #1 geoff meggs

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