Canada RCMP File:

ONTARIO

SUPERIOR COURT OF JUSTICE

(Toronto Region)

IN THE MATTER OF an application for a Production Order pursuant to section487.012(1) of the Criminal Code

AND IN THE MATTER of an application for Search Warrants pursuant to section 487 ofthe Criminal Code.

AND IN THE MATTER of an application for Assistance Orders pursuant to section487.02 of the Criminal Code

AND IN THE MATTER of an application for an Order Denying Access to Information(Sealing Order) pursuant to section 487.3(1) of the Criminal Code.

INFORMATION TO OBTAIN

TABLE OF CONTENTS

lntroduction 3Offences Under Investigation: 5Overview 6

First Response Travel Group! Leximco Ltd 7

Offshore Investments 8

PIN Consulting Group Inc 9

Other Allegations 10

Judicial Authorization Sought 11Subject List 13Sources of lnformatiow 15Grounds Of Belief: 16

OPPA Information Review 16

Witness Statements 16

Martin McNamara 17

Page 1 of 88

CurtisEia.20

Kimberly Tait 28

First Response Travel Group 34

Leximco Ltd 36

PIN Consulting Group Inc 37

New Providence Income Fund Ltd 39

Condos at 1 Cable Beach in Nassau, Bahamas 40

2014 OPPA Audit: 41

OPPA Association Financial Report Presented at the OPPA Annual General Meeting 43

OPP Association Constitution and By-Laws 43

Summary of Grounds 43Solicitor-Client Privilege Considerations 44Things Sought Are Not Protected By Solicitor-Client Privilege 46

Search Warrant for 903 - 180 Bloor Street West, Toronto, Ontario 49

Things Being Sought from 903 - 180 Bloor Street West, Toronto 49

Summary of grounds for Belief the Things being Sought will be Located at Suite 903 - 180Bloor Street West, Toronto, Ontario 51

Special conditions related to the Search Warrant for 903 - 180 Bloor Street West, Toronto:52

Seizure of Electronic Records at 903 - 180 Bloor Street West, Toronto, Ontario 53

Things being sought from Ontario Provincial Police Association Office located at 119 FerrisLane Barrie, Ontario: 58

Summary of grounds for belief the things sought will be located at Ontario Provincial PoliceAssociation Office located at 119 Ferris Lane Barrie, Ontario 60

Grounds To Believe Things Sought From All Locations Will Afford Evidence 86

Time Frame Requeste& 86Sealing Order 86

Page 2 of 88

ONTARIO

SUPERIOR COURT OF JUSTICE

(Toronto Region)

IN THE MATTER OF an application for a Production Order pursuant to section487.012(1) of the Criminal Code

AND IN THE MATTER of an application for Search Warrants pursuant to section 487 ofthe Criminal Code

AND IN THE MATTER of an application for Assistance Orders pursuant to section487.02 of the Criminal Code

AND IN THE MATTER of an application for an Order Denying Access to Information(Sealing Order) pursuant to section 487.3(1) of the Criminal Code.

INFORMATION TO OBTAIN

I, Sergeant Gordon Aristotle, a peace officer and member of the Royal CanadianMounted Police (RCMP) in the Province of Ontario, MAKE OATH AND SAY ASFOLLOWS:

Introduction:

1. I have been a member of the RCMP since 1997 and currently hold the rank ofSergeant. My first posting was in the Province of British Columbia working inboth the General Duty and the General Investigation Sections (GIS). Whileworking GIS, I was involved in the investigation of major crimes such ashomicides, robberies, sexual assaults, drugs offences, counterfeiting and frauds.

2. In 2001, I was transferred to Ontario. I have been assigned to several unitswithin the RCMP which have, as part of their mandate, the investigation offinancial crimes including the following.a. National Security Investigation Section;b. Commercial Crime Section;c. G8-G20 Summits Joint Intelligence Group;

Page 3 of 88

d. Integrated Market Enforcement Team;e. The GTA Financial Crime Unit;f. Joint Securities Intelligence Unit; and

g. Integrated Proceeds of Crime Section.

3. In addition to the above noted units from 2002-2004 1 was seconded to ProjectOIDA to work with RCMP and Toronto Police Service (TPS) investigatorsassigned to the Professional Standards Special Task Force. Project OIDAinvestigated allegations of fraud and corruption which resulted in criminalcharges being laid against police officers formerly assigned to the TPS CentralField Command Drug Section.

4. I have completed complex financial investigations, at times as the team leaderand/or affiant, including those involving:

a. fraud offences;b. money laundering and proceeds of crime offences;c. breach of trust offences; andd. crimes of dishonesty committed by a member of the Law Society.

5. I have prepared and supervised the preparation of numerous judicialauthorizations including search warrants, production orders, tax applications,restraint applications and management orders. I have prepared and supervisedthe preparation of restraint applications for bank accounts controlled by a lawyer.I have prepared search warrants for documents and data stored in law officesand also in the residence of a lawyer, and I prepared and supervised thepreparation of production orders for information pertaining to dozens of bankaccounts controlled by a lawyer. I have also prepared an affidavit for thepurpose of a Lavallee Hearing, which was used to make a determination ofwhether evidence seized by the Referees was protected by solicitor client-privilege.

6. I have a solid understanding of economics, finance, accounting, business,banking and capital markets. This is based on my experience as a financialcrimes investigator, as well as my education. I have completed the followingrelevant courses:a. Honours Bachelor of Business Administration Degree (1990-1 994);b. Commercial Crime Investigators Course (RCMP 2001);c. Counterfeit Investigators Course (RCMP 2002);d. Proceeds of Crime Investigators Course (RCMP 2004); ande. The Canadian Securities Course (2006).

Page 4 of 88

7. In addition, I have attended numerous economic crimes related conferences andseminars. I have prepared materials for and lectured at many conferences andcourses such as the following:

a. Money Laundering Investigators Course provided to Panamanian Police,Prosecutors and Intelligence. (2015);

b. The Osgoode Hall Money Laundering Symposium (2013);

c. Integrated Market Enforcement Team Investigators Course (2008);

d. Joint Securities Intelligence Unit International Fraud Conference (2008);

e. The Ontario Securities Commission, Securities Investigation TrainingCourse (2007);

f. The Toronto Police Service Fraud Conference (2007); and

g. Annual Legal and Compliance Conference of the Investment DealerAssociation Members (2006).

8. My current full time position in the RCMP Greater Toronto Area Financial CrimeUnit (GTA FCU) is that of Team Leader. On November 10, 2014, I wasdirected to assist the RCMP Special Investigations Anti-Corruption Unit with thisinvestigation.

9. Throughout this Information to Obtain (ITO), where I state my belief, the beliefis based on my experience and training. I have personal knowledge of thematters and facts described in this ITO, except where stated to be oninformation and belief. I believe the contents of this ITO to be true to the best ofmy knowledge.

10. I understand that this is an ex parte application and that lam obligated topresent a full, frank and fair disclosure of the material available to me. Whilepreparing this ITO, I did not include every single detail of this investigation. In aneffort to prepare a document that is clear and concise, I have includedinformation that I believe is relevant to this particular investigation and which isnecessary to establish the grounds for granting the requested orders.

Offences Under Investigation:11. Based on the grounds described below, I have reasonable grounds to believe

that the following individuals:a. Martin Bain

Date of Birth: May 13, 1966Address: 7 Maple Court, Oro-Medonte, Ontario

b. James ChristieAKA Jim ChristieDate of Birth: September29, 1967Address: 193 Maple Dawn Drive, Midland, Ontario

Page 5 of 88

c. Karl WalshDate of Birth: November 12, 1963Address: The residence in the southeast part of the property designatedas 41 53/41 55/41 57 31X Line, Bradford, West Gwillimbury, Ontario;

have committed the following offences that are contrary to an Act of Parliament:

a. Section 322 Theft Criminal Code.

b. Section 336 Criminal Breach of Trust Criminal Code;

c. Section 380 (1) Fraud Criminal Code; and

d. Section 462.31 Laundering the Proceeds of Crime.

12. And I have reasonable grounds to believe that the following individuals:

a. Andrew Mckayr AKA Andy MckayL. Date of Birth: September 9, 1961

Address: 64 Montressor Drive, North York, Ontario;

b. KlaraKozakDate of Birth: March 28, 1968Address: Upper Level, 61 Wineva Avenue, Toronto, Ontario; and

c. Noel Francis Chantiam[1 AKA Francis Chantiam

Date of Birth: December 25, 1955Address: Unknown

have committed the following offences that is contrary to an Act of Parliament:

a. Section 341 Fraudulent Concealment Criminal Code;

L b. Section 462.31 Laundering the Proceeds of Crime; andc. Section 380 (1) Fraud Criminal Code.

Overview:1

13. In October 2014, the Ontario Provincial Police (OPP) received complaints fromemployees of the Ontario Provincial Police Association (OPPA) allegingfraudulent activity being conducted by some of the senior members of the

El executive of the OPPA, namely, Chief Administrative Officer (CAD) Karl Walsh

1 Paragraphs 13 to 29 constitute an overview, further details in support of the overview are found in the body of theITO

Page6of88

(Walsh), OPPA President James Christie (Christie), OPPA Vice PresidentMartin Bain (Bain), a lawyer named Andrew Mckay (McKay), and otherindividuals, namely, kiara kozak (Kozak) and Noel Francis Chantiam -(Chantiam). Upon review of the initial information, the OPP referred the case tothe ROMP which formed a team to investigate the allegations.

14. I have reasonable grounds to believe that the subjects of investigation, namely,Walsh, Christie, Bain, McKay, Kozak and Chantiam, have acted together tocommit criminal offences of fraud and theft against the OPPA. This belief isstrongly based on information that has been received from four employees of theOPPA, who are concerned by the actions of Walsh, Bain and Christie, who areall sworn police officers. Sam and Walsh hold the rank of constable, whileChristie is a detective sergeant. Mckay is a lawyer in private practice with thefirm, Warren McKay Geurts & Bellehumeur (McKay Law Office).

15. I believe that the subjects of investigation have organized various schemes,some which include companies for which they hold hidden beneficial ownership,that have been setup in order to obtain exclusive rights for services required bythe OPPA. These services pertain to but are not limited to the travel andinvestment needs of the OPPA. In addition, some of the services offered bythese companies are being promoted to the OPP membership throughout theprovince.

16. Following is a summary of the schemes that I believe have been used tofraudulently elicit funds from the OPPA, for the benefit of the subjects ofinvestigation.

First Response Travel Group! Leximco Ltd.

17. A company called First Response Travel Group (First Response) was formedon June 16, 2014 and Walsh has directed all OPPA employees to use thiscompany exclusively for all OPPA travel needs. First Response is also being

L utilized to secure contracts for the OPPAs Golf Tournament, the OPPA AnnualGeneral Meeting (AGM) and the OPPA Spring Board Meeting, which have anestimated contract value of $400,000.00. The decision to change travel serviceproviders was made without any cause or explanation OPPA employees havecomplained that First Response is providing the OPPA with inferior service, atinflated prices, compared to the previous travel service provider. First Responseis also being endorsed by the OPPA, and actively marketed for personal travel,to the more than 6,000 OPPA members through the OPPA website, and throughan OPP members magazine called, Beyond the Badge.

18. First Response was registered as a partnership between Chantiam and Kozakwhich was listed as a division of Leximco Ltd. (Leximco), a corporation whosedirectors are shown as kozak and McKay. However, according to emails thathad allegedly been observed on Walshs OPPA email account, Walsh, Christie,

Page 7 of 88

Bain, McKay, Chantiam and Kozak all owned shares in First Response. Thetotal book value of the company was $198,000.00, which is comprised of 198shares each having a value of $1,000.00. Bain, Walsh and Christie own 50% ofthe shares of First Response Travel, while McKay, Chantiam, and Kozak ownthe remaining 50%. It has been alleged that the OPPA was being invoicedmonthly for consulting fees by a company called PIN Consulting Group Inc.(PIN), and that the funds paid by the OPPA were being used for the benefit ofWalsh, Christie and Bain, to pay for 30 First Response shares worth $30,000.00.In order to hide their ownership in First Response, the shares belonging to Bain,Walsh and Christie were being held in trust by Kozak through an offshoreinvestment scheme.

19. Walsh, Bain and Christie have not disclosed their beneficial ownership of FirstResponse to the OPPA Board of Directors and the OPPA membership. Inaddition Walsh, Bain and Christie had failed to disclose their beneficialownership in First Response to the OPPA Auditor and their beneficial gain fromthe funds being paid by the OPPA to PIN. This has caused the auditor toprepare an audit report for the OPPA that does not contain factual informationabout related party transactions, which in turn has deceived the OPPA Board ofDirectors, the OPPA membership and the OPPA Audit Committee.

Offshore Investments

20. At the beginning of 2014, Walsh, Christie and McKay took two trips to theBahamas, after which Walsh, Bain and Christie began to make higher riskinvestment decisions on behalf of the OPPA. This has been a noticeabledeviation from the historically conservative investment strategy of the OPPA astwo of the investments are domiciled in offshore jurisdictions and were allegedlynot preapproved by the OPPA Board of Directors.

21. One of these investments was only discovered when back up paperwork for a$20,000.00 charge on Walshs OPPA issued credit card was requested byOPPA office staff in preparation for the OPPAs annual audit. Walsh explainedthat the $20,000.00 charge was for a deposit that he made on two condos whichwere to be built at I Cable Beach in Nassau, Bahamas. One of the condos wasvalued at $1,563,000.00 and the other was valued at $625,000.00. Walshadvised that the condo was being purchased as a high end vacation rentalproperty investment for the OPPA. This transaction, which was not discussedwith the OPPA Board of Directors prior to its purchase, did not make sense tosome of the OPPA employees as the OPPA is a not-for-profit organization. Thebackup paperwork for the credit card transaction demonstrated that the depositfor the condo was actually made in Walshs personal name, with an associatedmailing address belonging to McKays office. This paperwork for the condo had

F. since been changed to the OPPA and its address. Subsequently Walsh hadadvised that he would be canceling the condo investments, which had resultedin some of the credit card deposit being refunded with a remaining $13,128.00

deposit yet to be refunded The fact that Walsh intended to purchase a

Page8of88

$1,563,000.00 condo in the Bahamas on behalf of the OPPA was not disclosedto the delegates at the OPPA AGM in October 2014. The $13,128.00 that wasnot refunded was accounted for as a prepaid expense on the 2014 OPPAFinancial Statements, however, there were no notations to describe thisexpense to the reader.

22. In August 2014 the OPPA invested in the New Providence Income Fund Inc.(New Providence), a company which is domiciled in the Cayman Islands. Thisinvestment is said to be a high risk, high yielding offshore investment that is notregulated in Canada and there is no guarantee that the principal invested will bereturned. Walsh wired $100,015.00 of OPPA funds to the Cayman Islands topay for shares in New Providence. Walsh had further advised of his intention toendorse New Providence and encourage the OPPA membership to also investin New Providence. Despite the potential for high yield return, this high riskinvestment was counter to the historically conservative investment strategy ofthe OPPA.

PIN Consulting Group Inc.

23. PIN was registered on June 6, 2014, which was 10 days prior to the registrationof First Response. Mckay was the only director listed on the PINs corporationprofile. The registered office for PIN was listed at Suite 702170 Bloor StreetWest, Toronto, Ontario with Natasha Vieira (Vieira) as the contact person.Vieira is Mckays executive assistant and the listed address was also theaddress of Mckays Law Office as well as his other businesses unrelated to thepractice of law, namely Amax Security Solutions Inc., Amax Intelligence Inc. andLeximco Ltd. Walsh and Christie signed a three year contract with PIN on behalfof the OPPA which commenced on July 1, 2014. The total value of the contractis $5,000.00 per month plus expenses, or $180,000.00 over the three year term.The contract described services to be provided by PIN which includedresearching, negotiating and concluding beneficial opportunities for enhancingOPPA membership including but not limited to: real estate investments;commercial investments; vacation property opportunities; travel benefits throughvarious travel agencies by securing exclusive rates for members and theirfamilies; and any other opportunities that PIN was able to procure as adeliverable service.

24. McKay signed the contract on behalf of PIN. Open source checks wereconducted and PIN had no presence on the Internet to describe the company, orthe services they provide clients. Mckay was a former police officer, and iscurrently a criminal defense lawyer. Witnesses do not possess any knowledgeor evidence to demonstrate that Mckay has skills and experience in the traveland/or the investment industry, which would be of any value to the OPPA.

25. Walsh, Christie and Bain are allegedly benefiting financially from PINs businessrelationship with the OPPA, however, the extent of this benefit is not yet known.

Page 9 of 88

PIN is closely associated with much of the alleged fraudulent activity underinvestigation such as the following:

a. Funds being paid by the OPPA to PIN for consulting fees allegedly beingused to pay for shares of First Response which are owned by Walsh, Bain,and Christie;

b. The registered office address for PIN was the same as Mckays law officeas well as his other businesses unrelated to the practice of law. Thebackup documentation and other information associated to the condosbeing purchased in the Bahamas, which were originally secured inWalshs personal name, were kept under the control of Mckay and hisexecutive assistant, Vieira.

c. PIN through McKay was allegedly responsible for the introduction ofKozak and First Response to the OPPA.

d. PIN was allegedly responsible for the OPPA investing in New Providence.

e. Some of the OPPA employees believed that PIN is involved with theevaluation, procurement and development of the proposed site for the newOPPA office, which is to be located in Oro, Ontario. Walsh is allegedlyfixated on moving the OPPA to a new location, and he was alsoattempting to convince the OPPA Credit Union to move to the samelocation and construct a new building. Mckays brother, Barry Mckay,was said to be involved with this project. The Board announced onFebruary 19, 2015 that the OPPA will be spending $100,000.00 on a siteassessment for the property. This amount was broken down into twoparts; $50,000.00 for the work and $50,000.00 for consulting fees with anexpected 10% overrun.2

f. In January 2015, Mckay, believed to be representing PIN, presented anew investment to the OPPA Board of Directors through a firm referred toas the Caldwell Group. This investment was approved by the Board,however, the details of the value and structure of this investment are notknown at this time.

Other Allegations:

26. Witnesses have also made other allegations pertaining to further enrichment byBain, Walsh and Christie relating to fraudulent claims for vacation leave payoutsand personal expenses. These other allegations are being investigated but arenot the primary focus of this investigation. These allegations predate the moreserious complaints as described above. The totality of the alleged behaviordemonstrates an ongoing breach of trust which is being committed by Walsh,

2 The firm that will be receiving the consulting fees is unknown at this time.

Page 10 of 88

[1 8am and Christie that has escalated in sophistication and significance to thepoint where they are now believed to be using a lawyer, a nominee, a consulting

F firm, a travel company, an offshore company and offshore investments to profitand deceive the OPPA membership.

Payout of Vacation Leave:

27. The witnessed have advised that payouts have been made by the OPPA tor compensate senior members for hours worked while they were scheduled to be

on personal vacation time. The witnesses claim that in some cases thesemembers were not working and they have falsely made this claim. The payoutof leave was only available to a select few OPPA employees including Walsh,Bain and Christie. The OPPA had historically never made payment for unusedvacation time. These payments were being made directly from the OPPA in alump sum, and are not administered through the OPP, like all other salaries paidto OPPA employees.3

28. Members of the OPPA including Walsh, Bain and Christie have claimed anaggregate amount of $144,000.00 in excess of their salaries for the fiscal yearending September 2014, and were paid out $100,000.00 in excess of theirsalaries for the fiscal year ending September 2013.

Payment for Personal Expenses:

Lr 29. Further allegations have been made that some expenses being charged toOPPA credit cards were in fact for personal expenses that were not related tolegitimate OPPA business. It is also alleged that Walsh and Christie have notbeen submitting back up receipts for their OPPA credit card purchases. Theircredit card bills were paid automatically from the OPPAs bank account andthere is no oversight.

Judicial Authorization Sought:

30. I am seeking the following Judicial Authorizations:FT

a. Search Warrants pursuant to Section 487 of the Criminal Code for:

i. Suite 903-1 80 Bloor Street West, Toronto, Ontario (AndrewMcKays Law Office);

In the OPPA Statement of Financial Position as at August31, 2014 there is a notation in reference to the Board ofDirectors and chief Administrative Officer vacation payouts which states: During the current fiscal year theAssociation changed its policy with respect to their vacation accrual. Previously the Association had not accrued forvacation time payable to members of the Board of Directors or the chiefAdministrative Officer. Approximately$144,000 is payable at year end and is included in accounts payable and accrued liabilities on the statement offinancial position. A liability of approximately $100,000 existed at August 31, 2013 which was not included in the prioryear figures.

Page 11 of 88

ii. Ontario Provincial Police Association Office located at 119Ferris Lane Barrie, Ontario;

iii. 7 Maple Court, Oro-Medonte, Ontario (The offsite OPPA office!Residence of Martin Bain);

iv. The black Ford Edge, with license plate BMKL586 registered tothe Ontario Provincial Police Association and driven by MartinBain;

v. 193 Maple Dawn Drive, Midland, Ontario (The offsite OPPAoffice! Residence of Jim Christie);

vi. The black Ford Edge, with license plate 07YR15 registered tothe Ontario Provincial Police Association and driven by JamesChristie;

vii. The residence in the southeast part of the property designatedas 41 53/41 55/41 57 3rd Line, Bradford, West Gwillimbury,Ontario (The offsite OPPA office! Residence of Karl Walsh);

viii. The black Ford Edge 07YR16 registered to the OntarioProvincial Police Association and driven by Karl Walsh;

ix. Upper Level - 61 Wineva Avenue, Toronto, Ontario (Theresidence of Klara Kozak);

x. The office of Leximco Travel located at 3273 Bloor Street WestUnit 102, Toronto, Ontario;

xi. the grey 2007 BMW registered to Kiara Kozak and bearinglicense plate BMEE6IO;

b. Assistance Orders appointing independent lawyers, approved by theLaw Society of Upper Canada and the Crown, to act as the Referees anda Chief Referee on behalf of the Court to ensure the maximal protection ofsolicitor client-privilege during searches, retention of exhibits, and prior tothe judicial determination of solicitor-client privilege;

c. Assistance Orders for Independent Forensic Computer Examiners tocopy, seize, triage and examine the electronic evidence under theguidance of this Order and further direction from the Court;

Page 12 of 88

Grounds Of Belief:

OPPA Information Review:

33. On November 12, 2014, attended a meeting as a member of an RCMPinvestigation team and was informed by SISgt Keith Latchford, of allegations offraud and theft made by OPPA employees against, OPPA President JamesChristie, Vice President Martin Bain and CAO Karl Walsh, and the OPPssubsequent request of the ROMP to conduct an investigation.

L34. On November 13, 2014, I reviewed a document dated November 3, 2014, which

was prepared by OPP Detective Inspector Chris Avery (D/lnsp. Avery) forDetective Superintendent Dave Truax after D/lnsp. Avery obtained voluntarysworn audio and video recorded statements from OPPA Executive Officer MartyMcNamara (McNamara) and OPPA Manager of Technology, Curtis Elia(Elia). The document is titled Ontario Police Association Information Review.(Attached as Appendix A)

35. At the time of his statement McNamara provided D/Insp. Avery with a copy ofthe performance agreement for PIN (Attached as Appendix B), a copy of aconfidential letter from the auditor to OPPA Finance Committee prepared byGregory N. Ferguson of Powell Jones LLP (Ferguson), dated October 17, 2014(Attached as Appendix C), and a copy of the 2014 OPP Association FinancialReport (Relevant information has been summarized and is attached along withthe report as Appendix D).

36. At the time of his statement Elia provided D/lnsp. Avery with two DVDs and onethumb drive containing electronic material obtained from the OPPA serverpertaining to emails for Walsh, Bain and Christie. D/lnsp. Avery did not reviewthis information because of privacy concerns.

37. D/lnsp. Avery provided the following conclusion on his review, There is nospecific or conclusive ewdence of fraud or other cnminal offence in theinterviews provided by the witnesses on November 2, 2014. D/Insp. Averyfurther noted that materials (two DVDs containing materials from the servers ofthe OPPA and a thumb drive containing six relevant emails) turned over by Eliathat were obtained in the course of his employment had not been reviewed dueto privacy concerns. He also suggested the interview of other OPPA employeesin order to further the investigation.

Witness Statements:

38. On November 14, 2014, D/Insp. Avery provided S/Sgt. Keith Latchford with thesworn audio and video taped statements of McNamara and Elia as well as theOPP Association Constitution and By-Laws, dated May 2014, (relevantinformation of the Constitution and By-Laws has been summarized and isattached along with the report as Appendix E) and the 2014 OPP AssociationFinancial Report.

Page 16 of 88

r39. RCMP investigators have obtained sworn audio and video taped witness

statements from four OPPA employees including McNamara, Ella, OPPA officemanager, Kimberly Tait (Tait) and the OPPA bookkeeper, Sandra Barendregt(Barend regt).

40. In addition, to the sworn statements, investigators have communicated with andreceived information from the witnesses either over the telephone or throughemail.

r1 41. Although these witnesses have communicated with each other before makingU the decision to bring their information to the police, I do not believe that has

affected their credibility or the voluntariness of their statements. None of the

r witnesses have a criminal record and none of the evidence they have providedL has been proven to be untruthful or misleading. The witnesses do not appear tohave anything to gain by providing the evidence, and are concerned aboutnegative professional and personal repercussions from reporting this offence,and cooperating with this investigation.

Martin McNamara:

42. Martin McNamara, who is a police officer and an executive officer of the OPPA,was the initial complainant to the OPP.

43. McNamara has provided two sworn witness statements, the first on November 2,2014, to D/lnsp. Avery and the second on February 12, 2015, to Cpl. StefaneNicolas (CpI. Nicolas) and S9t. Kevin Jory (Sgt. Jory). I reviewed both of thesestatements and learned the following:

44. The following is a summary of McNamaras evidence:

a. McNamara has been a sounding board for some OPPA employees regardingconcerns they had with the actions of Walsh, Bain and Christie, and their fearin reporting the issues to the authorities. He had listened to their complaintsand tried to understand what was occurring within the OPPA.

b. McNamara had signing authority for the OPPA and at the end of August,2014 he was presented with a cheque to be signed that was made payable toPIN Consulting for the amount of $5,000.00. He did not understand thereason for this payment, and when he asked questions, he was provided witha copy of the agreement between the OPPA and PIN.6 McNamara hadpreviously not heard anything from the Board members about PIN and theservices they were to provide, and he did not understand why the OPPA werepaying for these services.

c. A few days later, McNamara learned of two other transactions that did notmake any sense to him; that the OPPA had purchased a condo in the

6 This agreement was provided to D/lnsp. Avery and a copy was provided to the RCMP on the December 1, 2014and is described later in this ITO.

Page 17 of 88

Bahamas; and that the OPPA had wired funds from their bank account to theCayman Islands for an investment.

d. There was an OPPA Board Meeting at the beginning of October 2014 afterthe OPPAs auditor, Ferguson7,conducted the annual audit of the OPPA.McNamara attended this meeting and he was provided a private andconfidential letter from the auditor to OPPA Finance Committee.8 Included inthis letter were recommendations from the auditor and managementsresponse. This report referenced a number of issues, some of which includedthe following:

i. Unsupported expenses;

ii. Vagueness of the OPPAs investment policy for what constitutesacceptable investments; and

iii. A list of significant and unusual transactions which included a depositof $13,128.00 for a condo property located at 1 Cable Beach inNassau, Bahamas, worth $1,563,000.00, and the purchase of 100Class A shares of New Providence which required a cash outlay of$100,015.00 payable to a company in the Cayman Islands.

e. McNamara was extremely upset by these transactions and the perception ofmoney laundering. He asked direct questions in the meeting as to why theOPPA was investing in the Bahamas and the Cayman Islands. Walshresponded by explaining the following:

i. The OPPA was no longer buying the condo in Nassau, Bahamas andtherefore, they would be getting their deposit back; and

ii. The $100,000.00 investment in New Providence was a conduit to amortgage investment corporation in the Cayman Islands and a meansfor OPPA membership to invest their own personal funds. The initialinvestment was required so they could open a bridge for OPPAmembers to invest in this corporation. Walsh advised that theinvestment provided a 12% rate of return.

f. The Board then left the general meeting and went in camera to discussthese issues in private. Upon the Boards return, McNamara was advised thatthe letter from the auditor to the Audit Committee would not be distributed tothe OPPA membership.

Ferguson is an accountant with Powell Jones, the accounting firm used by the OPPA.8 This letter was provided to the D/lnsp. Avery and a copy was provided to the RCMP on December 1,2014 and isdescribed later in this ITO.

Page 18 of 88

g. After the Board meeting was finished McNamara was still very upset aboutthe offshore investments and other things that just did not seem right. Hediscussed the issues with other OPPA employees, including Elia.

h. While McNamara was driving to the OPPA AGM with Barendregt and Elia,they discussed the issues at the OPPA. Elia then advised him that while hewas working on Walshs computer he had located some emails pertaining toFirst Response and PIN which contained the following information:

I. Leximco Travel was purchased by First Response and Walsh, Christieand Bain owned shares in First Response;

ii. Correspondence from McKay to Walsh explaining that these shareswere not traceable because they were held offshore; and

iii. Kozak was holding shares in trust in the Cayman Islands on behalf ofBain, Walsh and Christie.

i. McNamara found an accrued vacation bank file on the OPPA server, andwhen he asked what it was for, the access to the file was locked down. Helearned that in the year 2014, they, along with McKay, went to the Bahamason what was first described as a personal vacation, however, their workschedules were subsequently changed to show that they were working for theOPPA during this trip. There was also a second trip to the Bahamas, at theend of May or June, for Bain9,Walsh, Christie and Mckay. Subsequentlylarge payouts of approximately $30,000.00 were made to Walsh and Christiefor unused vacation time.1

j. McNamara first heard that the OPPA Audit Committee Members were veryupset when they learned of the findings of the auditor, however, theirconcerns were somehow alleviated. He has learned that the Audit CommitteeReport11 was authored by Walsh.12

k. It was during the 2014 annual OPPA golf tournament where McNamara firstmet Kozak. During their conversation, Kozak told McNamara that she wouldbe starting up First Response, organizing next years golf tournament andgetting involved with the OPPA, all of which was news to McNamara.

McNamara was the only witness who mentioned that Bain travelled to Nassau, Bahamas with the others. It ispossible that McNamara received this information second hand and Bain never actually went to the Bahamas withChristie, Walsh and McKay.10 In the OPPA Statement of Financial Position as at August 31, 2014 there was a notation advising of a change inpolicy in relation to the Board of Directors and cAos vacation policy whereby the year end payable for vacation timewould be recorded on the financial statements.

9 The Audit Committee Report was provided to the OPP Interviewer and has since been provided to the RCMP andwill be described later in this ITO.12 Walsh was not a member of the Audit Committee but he allegedly was responsible for selecting the AuditCommittee from a list of delegates who volunteered for this role. The Audit Committee members were Bruce Qwigg,

9 Dave Vitti, and Dave Sanbatini.

Page 19 of 88

.9

I. McNamara approached the OPP with his concerns and not the Boardbecause he felt this was a criminal matter pertaining to the misappropriationof OPPA funds.

45. On February 20, 2015 McNamara sent Cpl. Nicolas an email advising thefollowing:

a. That the OPPA Board announced on February 19, 2015 that the OPPAwill be spending $100,000.00 on a site assessment fora property which isto be the site of the new OPPA office. The $100,000.00 amount wasbroken down into two parts; $50,000.00 for the work and $50,000.00 forconsulting fees with an expected 10% overrun. McNamara did not statewho the consulting firm or what service the consulting firm will beproviding;

b. That all lawyers on the OPPA callout list, that are contracted as requiredto assist OPPA members, have now been ordered to use First ResponseTravel Group;

c. That one of the Executive Officers has been fired, his OPPA issuedequipment has been taken away, and his retirement party has beencancelled; and

d. That McNamara has been told that they will be trying to fire him soon aswell.

Curtis Elia:

46. Elia has provided two sworn witness statements, the first on November 2, 2014,to D/lnsp. Avery and the second on January 13, 2015, to Cpl. Nicolas and Sgt.Jory. He also provided an additional statement on March 1, 2015.

47. The following is a summary of Ellas evidence:

a. Elia is the OPPA Manager of IT and Infrastructure and has been employedwith the OPPA since 2010. He worked as a consultant to the OPPA for 8to 9 years prior to accepting a permanent position.

b. Ella provided information pertaining to where relevant electronicinformation could be obtained on the OPPA server.

c. Elia had seen an email on Walshs computer while he was working in hisoffice in June 2014. At first the email he saw which was about thepurchase of shares did not mean anything to him. He then heard fromother OPPA employees about questionable OPPA expenses and vacation

Page 20 of 88

payouts. He also learned of the OPPAs suspicious offshore investmentsand a contract with PIN for $5,000.00 per month. Ella had concerns aboutthis activity which prompted him to review certain emails and form thebelief that Walsh, Christie and Bain were involved in criminal activity. Eliamade copies of Walsh, Bain and Christies email mailboxes13to preserveevidence which was later provided to D/lnsp. Avery14.

d. Ella had backed up Walsh, Bain and Christies email mailboxes in themonths of October, November and December.

e. According to the emails Ella has read pertaining to Walsh, Christie, Bain,McKay, Chantiam and Kozak, he had noted the following:

i. Walsh, Christie, Bain, McKay, Chantiam and Kozak have allpurchased shares of First Response. The total book value of thecompany was $198,000.00, and was comprised of 198 shares eachhaving a value of $1,000.00. The share structure was comprisedas follows: Mckay, Chantiam, and Kozak own one half of theshares of First Response. Bain, Walsh and Christie own theremaining half of the shares, with Walsh owning 50% and Bain andChristie each owning 25% of this portion. OPPA funds were beingfunneled through a company called PIN in what was beingdescribed as consulting fees to pay for 30 of these shares havinga value of $30,000.00. Bain, Walsh ad Christie would eachbenefit $10,000.00 from this arrangement. The shares belonging toBain, Walsh and Christie were being held in trust by Kozak throughan offshore investment scheme. They believe that these shareswere not traceable if someone was looking into the company to seewho owned it.

ii. Mckay introduced Kozak and Chantiam to Walsh, Bain andChristie. kozak and Chantiam affended the OPPA in the summerof 2014 in a stretch limousine to meet with Walsh and Christie. Itwas Chantiam who proposed the fraudulent scheme to Walsh, Bainand Christie.

iii. Elia read aloud a portion of one email written by Walsh, I raisedour issue with PIN. Francis talks fast and assumes we are as smartas he is. In the end he does not appear to be tied to PIN. He is

13 Ella retileved the emails on his own and he has advised investigators that he backed up the OPPA mailboxes forBain, Walsh and christie so that evidence would not be lost if the emails were to be purged or deleted. Investigatorshave not advised Ella that they will be conducting a search warrant and they have not instructed Ella to review emailsor preserve evidence. Investigators were unaware of Ellas actions until they were already done. On December 4,2014 S/Sgt Roy Steinebach advised Eliato maintain discretion to preserve the integrity of the investigation and on

J. January 13,2015, cpl. Nicolas advised Elia not to take any additional actions for the purpose of this investigation.14 Due to privacy concerns the OPP had not reviewed this material, and RCMP investigators have not requestedthese electronic storage media devices from the OPP. These electronic storage media devices are now being soughtby judicial authorization supported by this ITO.

Page 21 of 88

leaving that up to us and Andy. He mentioned we could makepayments through Andy. That way we could coordinate the OPPAconsulting fee. Ella advised that there were lots ofcorrespondence on the emails between Mckay and Walshpertaining to PIN.

iv. One email viewed by Ella gave the bank account information wherethey were to transfer the funds for the shares of First Response.Ella believed that it was a Bank of Montreal (BMO) bank account.

v. Ella advised that in one of the email from either Walsh or Christie toKozak, she was asked to cease using the OPPA emails forcommunication and to use their personal email accounts, believedto be the following accounts; karlwalsh(yahoo.com;ichirstie(2qmail.com; and martin.bain@sympatico.ca.

g. EIia was concerned because OPPA employees were being forced to useFirst Response for their travel needs, and Ella believed the OPPA wasbeing overbilled for this service. He was also concerned because FirstResponse was now being endorsed and promoted to the entire OPPAmembership.

h. Ella believed that the OPPA Board of Directors approved the monthlyexpenditure for PIN, but they were not aware of the involvement of McKay,Walsh, Christie and Bain at that time.

I. Ella advised that Mckay later made a presentation to the OPPA Board topitch them on an investment with the Caldwell Group.15 Ella had seen anemail between Mckay and Walsh saying that everything was good,Caldwell would take .5%, PIN would take .5% and the OPPA will not betaking any money out of the investment. Ella could not provide any furtherdetails on this investment.

j. Ella advised of the discussion he had with McNamara and Barendregtwhile they were driving to the OPPA Annual General Meeting at the end ofOctober. They discussed the financial issues within the OPPA and howthey should stand up, but none felt they were in the position to do so. Itwas at this time that he told McNamara and Barendregt about the emails.They were shocked to learn of this information, and McNamara asked Eliato hold off as the OPP should be made aware of the situation. McNamarasaid he would contact someone at the OPP, and the next day confirmationwas received that it would be investigated.

15 There is an investment firm named caidwell Securities that is located at 150 King Street West, Toronto, ON. Nofurther information was provided and I am unsure if this company is the one that has been described.

Page 22 of 88

k. Walsh and Christie went to the Bahamas on two occasions; from March 27to 30, 2014 and from July l6to 21, 2014. Ella knew this because he wasrequested to purchase a cellphone plan for Walsh and Christies phonesfor their trip to the Bahamas. Since he was unable to obtain a compatiblecellphone plan, he asked Walsh and Christie to refrain from using their

r OPPA cellphones while they were in the Bahamas. However, Elia was toldthat due to the business nature of the trip, they were required to use theircellphones and as a result Walshs bill was between $2,000 and $3,000.

I. In the summer, Ella attended McKays law office to do IT work and duringthe course of these duties he saw the following:

i. The scheduling of McKays meetings between Mckay, Chantiamand Kozak.

ii. Emails that showed McKay had introduced Chantiam and Kozak toChristie, Bain and Walsh.

48. On February 26, 2015 CpI. Nicolas received an unsolicited email from Eliaadvising that McKay had contacted him to do some IT work at his new officelocated at Suite 903 -180 Bloor Street West, Toronto, Ontario. Elia advised thathe would be meeting with McKay at this office on March 1, 2015 CpI. Nicolasemailed Elia back and thanked him for the information.

49. As a result of Elias information investigators conducted surveillance in the areaof 180 Bloor Street West, Toronto, Ontario on March 1, 2015. Elia was notinformed that investigators would be conducting this surveillance, and he wasnot provided any instruction from CpJ. Nicolas or any other member of theinvestigation team. The following are the relevant observations for thesurveillance:

a. At 11:07 Andrew Mckay was observed carrying a vacuum and anextension cord into the rear of 180 Bloor Street West, Toronto, Ontario.

b. At 11:54 Sgt. Jory attended outside of Suite 903 -180 Bloor Street West,Toronto, Ontario and noted two large front opening filing cabinets and oneblack office chair in the hallway to the left of the entrance to Suite 903.Sgt. Jory opened the unlocked door to Suite 903. Sgt. Jory observed anoffice space but he did not observe anyone inside the office and he did notenter the suite. Sgt. Jory noted a desk located to the left of the entranceand a number of large boxes on the floor.

c. At 11:57 Elia was observed standing outside to the west of 180 BloorStreet West on the sidewalk. Elia was then observed entering the lobby of180 Bloor Street West where he met with Andrew Mckay and an unknownmale. All three males were seen entering the elevator.

Page 23 of 88

d. At 18:20 McKay and Ella were observed leaving 180 Bloor Street Westand entering a black Sport Utility vehicle that was parked in a lot at therear of the building. Mckay was observed driving away in the vehicle withElla in the front passenger seat.

50. On the evening of March 1, 2015, Cpl. Nicolas called Ella and requested that heprovided a statement. At 20:38 Cpl. Nicolas and Sgt. Jory obtained a statementfrom Ella. During this statement Ella advised the following:

a. He confirmed that he was at 180 Bloor Street West earlier that day toassist Mckay in establishing the IT requirement for the new office. Headvised that the whole Warren Mckay legal firm was moving to this newlocation. There were seven to eight lawyers moving into the new location.

b. He advised that Mckay had completely moved out of his previous office at170 Bloor Street West and he will be commencing operations at the newoffice this week. All of Mckays legal files are now in the new office. OnTuesday (March 3, 2015) they will be getting the Internet and will beworking with what they have for the time being. He described the newoffice as having boxes throughout containing equipment and files.

c. Ella advised that Mckay has a desk top computer which is networked withthe bookkeeper, Natasha Vieiras desk top computer. Vieira does thebilling for Mckay.

d. He advised that there are four physical offices, a boardroom and abackroom. Ella provided a diagram of the office and advised that Mckaywas sharing an office with a lawyer named, Craig Branagan.

e. Elia advised that he was asked to go back to Mckays office next Sunday(March 8, 2015).

f. Ella advised that he had the backups previously described, includingWalsh, Bain and Christies emails accounts on his hard drive at hisresidence.

Sandra Barendregt:

51. On December 8, 2014, Barendregt attended the RCMP Newmarket Detachmentand provided a sworn audio and video recorded witness statement. I monitoredthe statement which was obtained by Sgt. Jory and CpI. Nicolas and learned thefollowing:

a. Barendregt has been employed by the OPPA for twenty years. She doesthe accounting for the OPPA, and her duties include payroll, accounts

Page 24 of 88

payable, accounts receivable and preparing the financial statements.Barendregt provided information about the OPPA, the structure,employees, the OPPA office and OPPA home offices.

b. Barendregt was aware that Ella located and turned over emails to thepolice. Elia showed her an email which described how Walsh invested$46,000.00, while Christie and Bain each invested $23,000.00 into acompany. She was not sure if the company they invested into was PIN orFirst Response. In one of the emails Mckay said not to worry, no one willever know because Kiara was the trustee of the shares.

c. Kozak ran First Response and all OPPA travel must be purchased throughher. At the OPPA AGM, First Response was presented to the delegation.Members were told that if they book through First Response they wouldget a discount.

d. Barendregt received an email from Walsh telling her to pay a PIN invoicefor $5,000.00 plus HST. The invoice did not breakdown the services thatwere provided by PIN. The PIN office had the same mailing address asMckays Law Office. Mckay had provided legal services for OPPAmembers for about 10 years and he was friends with Walsh, Christie andBain.

e. Barry McKay is Mckays brother and Barendregt thinks he was a realtor.She frequently hears his name in the office and he was somehow involvedwith the property that the OPPA may purchase for their new office. Walshwas fixated on acquiring this property which was located on the 7th line inOro between the Shell Station and the airport. A company called DialogueInc. has done a survey of the property. Right now they are in the planningstage and there may be some problems with the soil. Barendregt does notthink there was a need for the OPPA to move as there was nothing wrongwith the OPPAs current office in Barrie, and there was plenty of space.Walsh says that he wanted to move the OPPA out of Barrie because theOPP did not police the City of Barrie.

f. McKay had rich friends in Toronto including a man named, FrancisChantiam. Chantiam had a box at the Rogers Center where he hadhosted members of the OPPA. Chantiam had been to the OPPA officeand he arrived in a limo with Kozak. Barendregt had been seeing hisname quite frequently at the OPPA.

g. Barendregt provided the following information about the OPPA purchaseof a condo in Nassau, Bahamas:

i. On Walshs April 2014 OPPA Visa statement, she observed a$20,000.00 US charge which occurred in the Bahamas. She askedWalsh about this transaction and requested backup documentation.

Page 25 of 88

It took a number of months to produce and was forwarded for theOPPA audit. Walsh explained that the $20,000.00 US charge wasa deposit for two condos that that the OPPA had purchased inNassau, Bahamas; one for $1.59 million and the other for$625,000.00.

ii. Barendregt had not heard anything about the OPPA purchasingcondos in the Bahamas until she saw the charge on the credit cardstatement. When she received back up documentation, she notedthat the paperwork was in Walshs name instead of the OPPA.Walsh explained that he also purchased a condo and thought theysent the wrong paperwork. Barendregt received another documentand noted that the condo was associated to Mckay. Barendregtunderstood that the OPPA was to receive their money back. Therewas one Visa refund received for one of the condos, but as ofDecember 5, 2014 no refund was received for the second condo.

h. Barendregt provided information about the New Providence investment inthe Cayman Islands:

I. Barendregt received a phone call from Walsh and was told to go tothe Credit Union and wire $100,000.00 US funds to CaymanIslands for an investment. Walsh explained that this was a timesensitive transaction that needed to be completed before August31, 2014. Barendregt was told that the Board would be advised at alater date and that the decision.to wire these funds was made byWalsh, Christie and Bain. The Credit Union required a personalname to be associated to this wire. Barendregt refused to put hername on this transaction and ultimately Walsh used his passport forthe identification that was required in order to wire the funds to theCayman Islands.

ii. The contract for the investment stated there was no guarantee theinvestor would get their money back. Barendregt was aware of aplan to offer this investment to OPPA members, and form one biginvestment pool. Barendregt was concerned about this and did notunderstand why they would want members to invest in a high riskCayman Island fund, where they could lose all of their investment.

iii. To facilitate a wire transfer from the Cayman Islands, the OPPAwas required to open a new US funds bank account at the OPPACredit Union. She believed that these funds, around $500.00, werereceived as a dividend payment on the investment, but she had notseen any backup documentation to describe this transaction

Page26of88

i. The OPPA had approximately $15 million in investments which includedlegal investments, insurance investments and operations investments.Only the operations investments were not restricted and these were thefunds that have been invested. The OPPA cannot make profits or they willrisk losing their not for profit status with the CRA.

j. Barendregt provided information in relation to the 2014 OPPA AuditProcess:

i. The auditor, Ferguson of Powell Jones, discovered many issueswhich he explained in a meeting attended by the OPPA AuditCommittee members, Barendregt and Tait. The Audit Committeeconsisted of three delegates who were picked by Walsh. Christieand Bain came into the meeting and made light of the issues thatwere raised by the auditor. They fluffed it off and the AuditCommittee was content with their explanation. Ferguson was topresent to the Board of Directors but Walsh called it off. Fergusonwas also scheduled to present at the OPPA Annual GeneralMeeting. He advised Walsh that it was his intention to bring up hisfindings at the AGM. Barendregt later learned that the OPPAintended to fire Ferguson, and she told him this. Ferguson wasunsure if he would have a job and in the end he did not present theissues to the delegates at the AGM.

ii. The condo purchase was not mentioned in the OPPA AnnualStatements becauseWalsh had said he would be cancelling thedeal and the OPPA would be getting a refund. Although theCayman Island investment is mentioned in the OPPA AnnualStatements none of the delegates at the OPPA opened thisdocument and asked about this transaction. Barendregt was veryupset that no one said anything at the AGM, and that nothing was

r done to rectify the situation.iv. Barendregt was handing out expense claims at the end of the AGM

when Walsh saw her and said, We could have spent a milliondollars and these idiots wouldnt have said a thing. Bain then saidto Barendregt, Youre not going to bite are you?

L- v. Barendregt was advised that Kim Tait and Leanna Maltby (Maltby)had a similar experience where they were told we just got awaywith murder

k. Barendregt explained that Walsh could approve expenses between$10,000.00 and $50,000.00 and that the board should approve anypurchase over $100,000.00.

Page 27 of 88

I. Barendregt advised that the OPPA Visa statement balances are paid for infull directly by the OPPA Credit Union This practice is in place to preventcharges for late fees, and it has made it easy for employees to use theirOPPA issued credit card withoutproviding backup receipts. This problemhas been brought up repeatedly at board meetings. There is no oversight

p and Walsh and Christie are the worst at not providing backup receipts, soit is impossible for her to determine if their expenses are for OPPAbusiness or personal in nature. Bain is not as bad as Christie and Walshand he does submit support for expenses incurred.

m. Christie, Walsh and Bain have all been part of the Association for about 15years. Walsh was the President for 6 years and then ran for public office.When he returned to the OPPA he became the CAO.

n. There is a separate set of books for Bain, Christie and Walshs lieu timewhich Maltby keeps track of, and this allows them to get their vacationpaid out in cash by the OPPA. This practice of paying out leave beganwhen Walsh decided to have his vacation paid out in August 2013 andthen again in January 2014. Walsh was in Los Cabos and because heanswered his phone and checked his emails, no leave time was deductedfor this vacation. There is no oversight for this practice. 16

Kimberly Tait:

52. Tait has provided two sworn witness statements to Sgt. Jory and Cpl. Nicolas. Imonitored both of these statements, the first which occurred on December 8,2014, and the second which occurred on January 5, 2015, and learned thefollowing:

a. Tait has been employed by the OPPA for 5 years. She overseesoperations, the budget, finances, human resources, and generally makessure the OPPA is running smoothly. She is a former teacher, has aBachelor of Economics, and a College Accounting Diploma. Her husbandis a sergeant with the OPP.

b. Tait provided information about the OPPA, the structure, employees, theOPPA office and OPPA home offices.

c. Tait and the staff which she supervises have many issues with recentfinancial dealings and decisions being made. She has repeatedly brought

E her concerns to Walsh. He is her direct supervisor, and she has nowhereelse to take these complaints.

16 in the OPPA Statement of Financial Position as at August 31, 2014 there is a notation advising of a change inpolicy in relation to the payout of leave for Board of Directors and chief Administrative Officer vacation.

Page 28 of 88

d. Tait described the Bahamas condo transaction as follows:

Walsh, Christie and McKay went to the Bahamas twice. She had seensome purchases on the Visa that were made in the Bahamas includingone large charge to put a hold on two condos in the Bahamas. Onecondo was worth $1.3 million and the other was worth $700,000.00.They met with a developer and they were to buy these condos andhave a manager rent them out. The OPPA had never owned realestate investment property.

There was no back up produced for this transaction, only a charge onthe Visa. The OPPA audit sparked a need for the backupdocumentation and Walsh advised her that McKay had the condoinformation, and she should contact him for the information sherequired. She contacted Mckay and he sent the documentation whenhe knew why it was required. The backup paperwork for the condothat was received from McKay was in Walshs personal name, withMckays office address. The name on the paperwork has since beenchanged and now it has the OPPAs name and address.

iii. This transaction was not mentioned in the 2014 OPPA FinancialStatements, and was not described as an asset purchase. Instead theamount of the deposit had been accounted for as a prepaid expense,because it was described as a right to purchase, and because Walshadvised that the OPPA could get their deposit returned.

iv. Tait had told Walsh that she does not understand the logic behind thisinvestment, and she explained to him that a deal like this needs tohave backup.

e. Tait described OPPA historical information about OPPA investments and theinvestment in the Cayman Islands:

r i. The OPPA uses, Terry Cheaney from RBC Dominion Securities toinvest their funds. They are very happy with Cheaney, and theinvestments he had selected for the OPPA have done very well.

ii. On August 28, 2014, Tait was not working but she was asked to wiretransfer $100,000.00 in OPPA funds offshore for an investment. Therewas a sense of urgency to get the transfer done. Barendregt hadrefused to do this transfer, and ultimately it was Walsh who transferredthe funds.

iii. The wire transfer was for an investment in the New Providence, a fundthat is run by a company domiciled in the Bahamas. Tait has seen a

Page 29 of 88

72 page document describing the investment fund, and fourteen pagesof this document describe the risks of investing into the fund. For thefive years she had worked at the OPPA all investment selections havebeen low risk. She did not understand or agree with the suddenchange in investment selection.

iv. Tait spoke to Cheaney and Ferguson about the investment. Cheaneyadvised that Mike Harris was on the Board of Directors to addcredibility, but the investment appeared too good to be true. He saidhe would not invest in this company. Ferguson also had concerns andadvised Tait to put her concerns in writing to protect herself. She sentan email to Walsh outlining her concerns as per Fergusons advice. Atone point she thought Walsh might retract the investment, but he didnot.

v. It has been explained to Tait that the investment was made so thatother OPPA members could also invest. A $100,000.00 minimuminvestment was required so that all OPPA members could pool theirfunds and invest. Tait was told that the BMO would be taking over thisinvestment. The OPPA recently received a dividend payment from thisinvestment and had to open a US funds account at the OPPA CreditUnion to facilitate the deposit of this money.

f. Tait provided some information pertaining to Mckay and PIN:

i. Walsh and Christie have known Mckay for years. McKay was a formerpolice officer and now is one of the external counsels who are calledby OPPA members who need assistance with criminal matters. Therewas a list of twenty lawyers that can be called for defense work, butMcKay and his firm are the primary contacts for this type of work.

ii. PIN was costing the OPPA $5,000.00 to 6,000.00 per month and thecompanys address was also McKays Law Office address. It wasWalsh and Christie who signed the OPPA Agreement with PIN.17

iii. Tait was usually privy to everything that was going on within the OPPAbut with PIN she was kept in the dark. Tait had searched the Internetand could not find any information on PIN and she was not sure what itdoes. Tait was not aware of any knowledge that Mckay has withinvestments.

17 reviewed a copy of the OPP Association constitution and By-Laws, dated May 2014, and noted the following inthe contracts Section, Contracts and engagements on behalf of the Corporation shall be signed by the President orthe vice-President and the ChiefAdministrative officer, or their delegates, and the ChiefAdministrative Officer shallaffix the seal of the corporation to such instruments requiring same.

Page 30 of 88

62. Kozak and Mckay commenced as officers of Leximco on October 10, 2014.McNamara advised in his statement that Leximco was purchased by FirstResponse but the source of his information had not been confirmed. It is notpossible from reviewing the corporation profile to determine the beneficialownership and any consideration that may have been paid to the transferownership. It was possible that the ownership of Leximco changed and thatsome or all of $198,000.00 that is believed to have been invested by Walsh,

p Bain, Christie, Mckay, Chantiam and Kozak in First Response, was used topurchase Leximco.

PIN Consulting Group Inc.

63. on December 1, 2014 I reviewed a five page Consulting Services Agreementbetween PIN and the OPPA, attached as Appendix B. This Agreement wassigned on August 20, 2014 by Mckay, on behalf of PIN and witnessed by Vieira.There was no signature on the Agreement by a representative of the OPPA.26The document contains the following information:

a. PIN will assist with research, negotiation and conclude beneficialopportunities for the purpose of enhancing Association membership, morespecifically but not limited to: real estate investments; commercialinvestments, vacation properties opportunities, travel benefits through

LI various travel agencies by securing exclusive rates for members and theirfamilies; and any other such opportunities that the Corporation was able toprocure as a deliverable service under this Agreement, and directed by[. the client.

b. PIN would provide reports on an ongoing basis and not less than onceevery six months to the OPPA as to the performance of the services underthe agreement.

c. The Agreement shall be in effect commencing July 1, 2014 and terminateon July 1, 2017. The Agreement may be renewed and the either partymay terminate the contract with 90 days written notice without cause.The OPPA may terminate the agreement for cause without giving notice.

d. The OPPA shall pay $5,000.00 per month plus sales tax for services. Inaddition the OPPA shall pay travel expenses for mileage at a rate of $.601km, accommodations, meals, airfare and incidental costs.

64. I have reviewed the corporation profile for PIN and noted the following:

a. It was registered on June 6, 2014;

26 Tait had stated that there was an agreement between PIN and the OPPA that was signed by Walsh and Christie. Ido not know if there was anything different in the version that she has referred to.

Page 37 of 88

b. Mckay was the sole director;

c. The registered office was listed at 702170 Bloor Street West, TorontoOntario (Mckays Law Office) and Mckays executive assistant, Vieira,was listed as a contact person. This address was also the office ofMckays other businesses including: Amax Security Solutions Inc. andAmax Intelligence Inc.

65. As stated above in his statement to investigators, Elia had seen emailsdemonstrating that Walsh, 8am and Christie were financially benefitting from theOPPA consulting fees that were being paid to PIN. Specifically that feescharged to the OPPA by PIN were being used to pay for $30,000.00 worth ofshares of First Response for the benefit of Walsh, Christie, and Bain.

66. The total value of this consulting fee contract over the three year team was$180,000.00, plus HST and travel.

67. Thus far PIN has allegedly been involved with the following activities:

a. The purchase of the condos in the Bahamas worth over $2 million.Though PIN was not directly mentioned, the backup documentation for thecondos purchase was being held by Mckay and Vieira.

b. The introduction of Kozak and First Response to the OPPA which wasbeing used for the purchase of OPPA employee and OPPA membershiptravel, and for the negotiation of contracts worth an estimated $400,000.00in relation to the OPPAs AGM, Spring Board meeting and its GolfTournament.

c. The New Providence investment which has commenced with a$100,015.00 OPPA investment, and was to be promoted to the OPPAmembers for their personal investment.

d. The procurement and development of the land for the new OPPA office inOro, Ontario. The Board announced on February 19, 2015 that the OPPAwill be spending $100,000.00 on a site assessment for the property. Thisamount was broken down into two parts; $50,000.00 for the work and$50,000.00 for consulting fees with an expected 10% overrun.27

e. An investment with the Caldwell Group whereby Caldwell will earn .5%and PIN will earn .5%. This investment was approved by the Board andfurther details were not known at this time.

27 The firm that will be receiving the consulting fees is unknown at this time.

Page 38 of 88

68. The recommendations made by PIN have been the focus of the complaints andconcerns voiced by the OPPA employees. It is unclear who actually works forPIN and if there was any benefit that this company will bring to the OPPA. Theoffice manager, Tait who usually knows everything about the business activitiesof the OPPA is being kept in the dark in relation to PIN for reasons that shecant explain. The financial risk associated to the alleged recommendations thathave been made by PIN is very significant for the OPPA and its membership. Ifthe controlling minds of PIN do not have the best interest of the OPPA in mind,the negative financial consequences could place the OPPA in jeopardy.

New Providence Income Fund Ltd.

69. Concerns have been raised by employees of the OPPA and the auditor inrelation to the OPPAs offshore investment of $100,015.00 in 100 Class Ashares of New Providence on August 28, 2014. Witnesses have stated that itwas Walshs intention to promote this investment to the membership of theOPPA. Walsh had advised that the funds invested by the OPPA were requiredso that the OPPA members could also invest in this security.

70. The investment was described in the 2014 OPPA Financial Report, Notes to theFinancial Statements, as follows: On August 28, 2014 the Association investedin 100 class A shares of New Providence Income Fund Ltd. (the Fund9. TheFund is a company incorporated under the Companies Law of the CaymanIslands as an exempted company limited by shares. The Fund is registered as amutual fund: The Fund:s investment objective is to deliver consistent returnswith enhanced protection of investment principal. It aims to achieve overallreturns of between 10 and 15% per annum net of fees and operating expenses.It intends to generate the returns to accomplish this objective through investingin a wide range of loans and securities and financial instruments. Subject to theavailability of distributable amounts and the discretion of the directors the Fundintends to declare and pay dividends on the shares on a quarterly basis in anamount representing a yield of 7% on the subscription amount.

71. On November 19,20141 conducted internet checks and was unable to find aprospectus for this company. It does not appear that it has filed any materialswith any Securities Regulators in Canada, and there was no evidence that thesesecurities were approved to sell in Canada. In addition, I could find noinformation published for this company since January 25, 2013, or anyinformation published pertaining to any regulation or oversight over thiscompany.

72. I also have reviewed other documents found on the Internet that containedunverified comments on New Providence including:

a. An article published by Nassau Guardian Business Reporter, Jamal Smith,titled Loan activity picking up at SFG Inc. which mentions the launch ofSterling Financial Groups third mortgage fund called New Providence

Page 39 of 88

Income Fund. A company representative states that the fund has alreadyseen a 5.22 percent return.;

b. A news release, dated January 25, 2013, published by SFG Inc., themanager and promoter of New Providence, reporting that the Fund hadreturned 1.01% netto its investorsforthe month ended December3lst,2012 representing a 19.27% return for the year. Fund investors werebeing paid out an interim dividend of approximately 12.27% per annum

r compounded return which was supplemental to the 7% per annumpreferred return paid out as quarterly dividend;

c. Information from Business Week that only stated that that NewProvidence did not have any Key Executives recorded and the wordsCayman Islands in the company overview;

d. A new release on Localbahamas.com prepared by SFG Inc. announcingthat New Providence Income Fund Announces a New Director on January25, 2013, Mr. Mike Harris, the former premier of Ontario; and

e. Information located on the BMO website for information purposes only.BMO advised that as required the company must file a prospectus with asecurities commission before their securities can be sold in Canada. Asmentioned above, I was unable to locate any information to suggest thatthis company had filed a prospectus with any regulator in Canada.

73. I reviewed a copy of the OPP Association Constitution and By-Laws, dated May2014 and noted the following in relation to investments. Monies accumulatedby the Corporation may be invested from time to time with the subsequentapproval of a General Meeting, and shall adhere to investment policies,standards and procedures that a reasonable and prudent person would apply inrespect of a portfolio to avoid undue risk and obtain a reasonable return. (Page24 and 25). I believe that this investment is a significant deviation from the riskadverse strategy demonstrated in the OPPAs historic investment choices.

74. Tait advised that the OPPA was in possession of a 72 page documentcontaining 14 pages of risk related warnings in relation to this investment. Ihave not viewed this report, but based on my knowledge and experience, andthe limited information I have gathered, I believe that this offshore investmentplaces OPPA funds at undue risk. Given all of the investment choices availableto management, I am unable to think of any legitimate reason why OPPA fundswould be invested in this company, and why they would want to market this fundto the OPPA members they represent.

Condos at I Cable Beach in Nassau, Bahamas

75. Concerns have been raised by employees of the OPPA and the auditor inrelation to a deposit of $20,000.00 that was placed on Walshs OPPA issued

Page 40 of 88

[i

UVisa to secure the purchase of two condos in Nassau, Bahamas. The depositfor one of the condos has since been returned and according to the Draft Letterfrom the Auditor, dated October 17, 2014, the OPPAs investment is for$13,128.00 on a condo worth $1,563,000.00 USD located at 1 Cable Beach inNassau, Bahamas.

76. None of this information was disclosed to the OPPA membership at the AGM orin the 2014 OPPA Financial Statements. There is no evidence that there wasany consultation with the OPPA Board prior to this purchase. The purchase oftwo condos, worth over $2 million US, is a very significant investment for theOPPA.

77. This investment involves an offshore jurisdiction, specifically the Bahamas, it exposes the OPPA to undue risk, and it is inconsistent with the investmentstrategy of the OPPA. This investment was described by Walsh to be for thepurpose of making a profit by renting out the condos, which according to onewitness could place the OPPAs status as a not-for-profit organization injeopardy.

2014 OPPA Audit:

LI

78. Witnesses have advised the auditors from Powell Jones performed the 2014audit and at the conclusion of their audit they expressed many concerns thatwere outlined in a three page letter, attached as Appendix C. The letter is forthe purpose of communicating the findings of an audit of the accounts of theOPPA for the year ending August 31, 2014. Upon my review of this letter, Ilearned of the following specific matters that were identified:

a. Instances were noted where there was a lack of back up to support thereimbursement of expense claims and Visa statements.

b. A vague investment policy that did not specify what type of investmentwas acceptable.

c. Accrual amounts for receivables and liabilities had not been updated fromthe prior year.

d. Not all investment income and management fees were being recorded ona monthly basis.

e. Significant unusual transactions were identified including: a deposit of$13,128.00 for a property located at I Cable Beach in Nassau, Bahamaswhich was being purchased by the OPPA for $1,563,000.00 USD; and thepurchase of 100 class A shares of New Providence, a foreign investmentof the Cayman Islands which occurred on August 28, 2014 and requiredthe cash outflow of $1 00,01 5.00.

Page 41 of 88

f. There were no disagreements with management during the audit andmanagement acknowledged recommendations made by the auditor and

r provided a response to address the identified issues.g. The audit did not identify any illegal acts, acts of fraud, misappropriationsof assets, intentional misstatements or errors, which were not otherwise

U reported.h. Management advised the auditor that no related party transactionsoccurred. It is managements responsibility to disclose to the auditor if itwas aware of or suspected any related third party transactions hadoccurred. The auditor conducted various tests to identify transactionsconsidered to involve related parties and found that all related partytransactions that were identified in the audit had been disclosed in thenotes of the financial statements.

79. Witnesses have advised the following:

a. The letter was presented by the auditor to the three members of the OPPAAudit Committee: Bruce Qwigg; Dave Vitti; and Dave Sanbatini in thepresence of Bain, Taft and Barendregt. Christie attended the meeting tospeak to the Audit Committee members who were content with hisexplanations. One witness stated that Christie fluffed off the issues.

b. The auditor, Ferguson of Powell Jones was to present to the Board ofDirectors this year but Walsh called it off.

c. Walsh was not a member of the OPPA Audit Committee but he wasresponsible for selecting the Audit Committee members. It is also allegedthat Walsh wrote the OPPA Audit Committee Report that claimed that theiraudit found nothing wrong.

d. At the AGM the delegates were not given time to review the financialsprior to the meeting. This is the first year that Walsh opted out of goingthrough the financials line by line at the AGM.

e. Ferguson advised Walsh that it was his intention to bring up thedeficiencies he had found at the AGM. However, Barendregt advisedFerguson that the OPPA intended to fire him, and for unknown reasonsthe issues were not presented at the AGM. Instead the audit waspresented as clean, and none of the issues found in the audit werementioned in the Independent Auditors Report or the Auditors AGMPresentation.

80. As demonstrated by the information provided by the witnesses there wasinterference in the audit process and the reporting of related party transactions,by the senior members of the OPPA, who are the subjects of this investigation.Ultimately, the 2014 OPPA Audit publicly concluded that there were no illegal

Page 42 of 88

acts, related party transactions or even minor issues. The auditors findingswere based on the information that was presented to the auditor by the OPPAand by management. There is no evidence to suggest that the auditor was privyto any information that demonstrates that Walsh, Bain and Christie arefinancially benefiting from the OPPAs relationship with PIN and First Response.As stated in the letter prepared by the auditor, OPPA management has anobligation to advise the auditor of related party transactions and did not do so.Management advised the auditor that no related party transactions occurred. Itis managements responsibility to disclose to the auditor if it is aware of orsuspects any related third party transactions have occurred.

OPPA Association Financial Report Presented at the OPPA Annual GeneralMeeting

81. On November 18, 2014 I reviewed a package entitled the 2014 OPP AssociationFinancial Report that was received by McNamara at the 2014 OPPA AGM. Ihave included this document at Appendix D and provided a summary ofrelevant information.

OPP Association Constitution and By-Laws82. On November21, 2014 I reviewed a copy of the OPP Association Constitution

and By-Laws, dated May 2014. I have included this document at Appendix Eand provided a summary of applicable sections pertaining to the structure of theOPPA, specific roles of OPPA employees and board members, honorariaemployment contracts, expenditures, contracts and investments.

S u rye ii lance:

83. Between November 20, 2014 and February 19, 2015, physical surveillance wasconducted on the subjects of investigation and the associated businesses,namely, Christie, Bain, Walsh, Mckay, kozak, Chantiam, First Response,Leximco and PIN Consulting. The objective of surveillance was to determine anyassociations between the subjects of investigation and the businesses as well asconfirming the places of residence and business. The results of the surveillance,relevant to this investigation, are summarized throughout this ITO including inthe places to be searched section of this ITO.

Summary of Grounds:

84. I have reasonable grounds to believe that the offences of criminal breach oftrust, fraud, theft and money laundering have been committed. I base my beliefon the following as set out in this ITO:

Page 43 of 88

a. That four witnesses employed by the OPPA have provided sworn witnessstatements in relation to criminal offences committed by senior members ofthe OPPA. These witnesses have viewed emails allegedly from WalshsOPPA email mailbox that describe specific offences of fraud and theft thathave been committed by Walsh, Christie and Bain, against the members ofthe OPPA, utilizing the companies First Response and PIN Consulting.Emails reveal that the fraudulent scheme has been carried out with theknowledge, guidance and assistance of Mckay, Kozak and Chantiam;

b. That after Walsh, Christie and Mckay took two trips to the Bahamas in 2014,they made significant investments in the Cayman Islands and the Bahamason behalf of the OPPA. These investments have exposed the OPPAmembership to financial risk and allegedly involve PIN, a company that hasallegedly been used to defraud funds from the OPPA membership;

c. That concealment of the beneficial ownership of a company using trusteesand offshore schemes is a technique used by those in Canada andinternationally who wish to commit fraud and launder proceeds of crime. Theuse of an offshore company makes it difficult if not impossible to obtainnecessary evidence in a timely fashion;

d. That funds being paid by the OPPA to PIN Consulting, via Andrew Mckay,are allegedly being laundered, specifically to pay for shares in First ResponseTravel on behalf of Bain, Walsh and Christie. The use of a lawyer to concealbeneficial ownership, and to act publicly as the directing mind of a company isa technique used by those in Canada and internationally, who wish to commitfraud and launder proceeds of crime. The protection afforded topresumptively solicitor-client privilege material that is stored in a lawyersoffice makes it laborious, expensive and almost impossible for investigators toobtain necessary evidence in a timely fashion;

e. That CAO Karl Walsh, President Jim Christie and Vice President Martin Bainhave made numerous decisions that demonstrate an intentional lack ofstewardship and accountability. I believe that they have financially benefittedfrom their actions, breached the trust of the OPPA membership, and placedthe OPPA and its membership at a significant financial risk.

Judicial Authorizations Sought:

Solicitor-Client Privilege Considerations:

85. I understand that solicitor-client privilege is a principle of fundamental justiceembodied in section 7 of the Charter of Rights and Freedoms. I am seeking tosearch the law office of Andrew Mckay where business records and othermaterial relevant to this investigation, which I believe do not pertain to thepractice of law, have been commingled with solicitor-client privileged material. Ihave considered whether it is possible to request a production order to obtain

Page 44 of 88

the things sought. I am aware that a production order would be a less disruptiveand intrusive manner to acquire the things sought, however, McKay is in controlof the things sought, and he is a subject of this investigation. I believe thatMcKay is conflicted and also unable to provide the things sought withoutpotentially incriminating himself. I have considered other options and there is noother alternative to obtain the things sought than to search this location. It isimperative that the evidence be collected, and I am unaware of an alternatelocation where the things sought could be located.

86. I am also seeking a search warrant for the OPPA office, OPPA offsiteoffices\residences, three OPPA owned vehicles and two Production Orders foremails that were copied from the OPPA server for the accounts used by Walsh,Bain and Christie. I believe that some of the work done by the OPPA on behalfof the members involves lawyers, both in house OPPA lawyers and externalcounsel including Andrew Mckay. For this reason I believe that there isinformation that is protected by solicitor-client privilege at the OPPA office. I amaware that there are three lawyers who are employed by the OPPA, Gavin May,James Girvin and Michelle Hamilton-Mayers. Their offices are on the third flooraway from other employees of the OPPA, and this is also the area where theirpaper files are located. The OPPA lawyers have their own drive on the OPPAserver, which is called Drive L. Only legal staff members of the OPPA, Ella andWalsh have access to the L Drive. Investigators will not be searching for thethings sought on the L-Drive or on the third floor where the lawyers work andstore their files.

87. This ITO outlines the grounds to support multiple judicial authorizations thatwould be executed simultaneously. As described, one of the locations is a lawoffice, and in other locations associated to the OPPA there is possibility thatsolicitor-client privileged material may be encountered. For each judicialauthorization sought, I have proposed conditions to ensure the maximum

J protection of solicitor-client privilege. In the conditions, I have proposed theappointment of Court Appointed Referees, Independent Computer ForensicExaminers (ICFE) and a Chief Referee to perform the post execution process

J and proceedings required to protect solicitor-client privilege.

9 88 I have discussed this proposal with Janice LaForme, Senior Counsel of the- Professional Regulation Division of the Law Society of Upper Canada (LSUC).

She sent me an email on February 23, 2015 stating the following:

a. To my knowledge the appointment by a Court of more than one lawyer toact as an independent Referee in the context of one criminal investigationwhere the maximal protection ofprivilege is a concern is not in and of itselfcontrary to the Supreme Court of Canada 2002 decision in Lavallee andother common lawjurisprudence. In my view consideration should begiven to inclusion of terms and conditions of a search warrant and / orassistance order that would:

Page 45 of 88

i. Recognizes and affirms the role of the Court as the sole arbiter ofprivilege.

ii. Address the role and responsibility of each Referee; that of aSenior! Chief Referee and an Assistant Referee.

ill. Address the relationship between a Senior! Chief Referee andthe Court.

iv. Ensure the real and apparent independence of the Senior!ChiefReferee and Assisting Referees from Crown, law enforcementand targeted lawyer or third party suspect (Referees need to be atarms length from these parties)

v. Ensure that Senior!Chief Referee and Assisting Referees areindividuals licensed to practice law in Ontario and are members ofgood standing with the Law Society of Upper Canada.

89. I have ensured that the conditions laid out in this ITO are in accordance with therecommendations made by LaForme and the Law Society Guidelines.28 I havealso ensured that each of the Referees proposed are acceptable to LSUC.

Things Sought Are Not Protected By Solicitor-Client Privilege:

90. As described in the grounds of this ITO one of the individuals under investigationis a lawyer named, Andrew Mckay. On November 12, 2014, I searched theLawyer Directory on the Law Society of Upper Canada website and found thatAndrew Peter Mckay is a licensed lawyer. His status is In Private Practice.The website lists his business as Andrew McKay Law Professional Corporationlocated at 702-170 Bloor Street West, Toronto, Ontario. However, as describedin the grounds for this ITO Mckay and his firm Warren Mckay GeurtsBellehumeur have relocated to Suite 903 180 Bloor Street West, Toronto,Ontario.

91. I conducted open source Internet checks on Mckay and found his Linkedln pagewhich states:

a. Barrister & Solicitor Warren Mckay Geurts Bellehumeur, 1999 Present(15 years) Mr. Mckay is a private practitioner of Law in Toronto, Canada.His practice includes conducting criminal and administrative prosecutionsand defense. He also has extensive expertise and experience in traininginvestigative personnel in the area of search and seizure, investigations,and the rules of evidence. In conjunction with his policing background andsuperior advocacy experience, Mr. Mckay has built up his firms reputation

28 The Law Society Guidelines and the email from Janice LaForme are included at Appendix F.

Page 46 of 88

for the representation of police officers throughout Canada on criminaIregulatory and discipline matters including Special Investigations Unit(SIU) investigations. Furthermore, Andrew has been the key coordinatorand facilitator of several courses for various provincial mini