Levant V The World - 2003

Action No.
: 0301- Oît
IN THE COURT OF QUEEN'S BENCH OF ALBERTA
JUDICIAL CENTRE OF CALGARY
BETWEEN:
MICHAEL COOPER, EZRA LEVANT, MARVIN LEVANT and SEAN McKINSLEY
Plaintiffs
- and GARRY HENNAN, JOHN FLYNN, WALTER WAKULA and JOHN DOES and/or
JANE DOES 1 THROUGH 250
Defendants
STATEMENT OF CLAIM
1. The Plaintiff Michael Cooper (hereinafter "Cooper") is a resident of the
City of St. Albert, in the Province of Alberta. He is a university student, a
political organizer and an elected National Councilor of the Canadian Alliance
party (hereinafter the "Party").
2. The Plaintiff Ezra Levant (hereinafter "Levant") is a resident of Calgary, in
the Province of Alberta. He is a lawyer, journalist, author and political activist.
From August, 2001 to March, 2002 he was a political organizer in the Party's
Calgary Southwest constituency association (hereinafter the "Riding"). During
February and March, 2002, he was the Party candidate in the Calgary
Southwest federal by-election, later stepping aside for Stephen Harper, the
Parry's new leader (hereinafter "Harper"). From March, 2002 until April, 2003
Levant served as a director of the Riding.
3. The Plaintiff Marvin Levant (hereinafter "Dr. Levant") is a resident of
Calgary, in the Province of Alberta. He is a medical doctor and a prominent
member of the community. From August, 2001 to March, 2002 he was a
political organizer in the Riding. From November, 2001 until April, 2003 he
served as a director of the Riding.
-24.
The Plaintiff Sean McKinsley (hereinafter "McKinsley") is a resident of
Calgary, in the Province of Alberta. He is a businessman, political organizer

and pollster. From August, 2001 to March, 2002 he served as campaign
manager for Levant and was a political organizer in the Riding. From January,
2002 until March, 2002 he also served as campaign manager for the Riding m
the Calgary Southwest by-election.
5. The Defendant Garry Hennan (hereinafter "Hennan") is a resident of
Calgary, in the Province of Alberta. He served as a director of the Riding until
being voted out in November, 2001.
6. The Defendant John Flynn (hereinafter "Flynn") is a resident of Calgary,
in the Province of Alberta. He served as a director of the Riding from about late
2002 until June, 2003. From April, 2003 until June, 2003 he was president of
the Riding.
7. The Defendant Walter Wakula (hereinafter "Wakula") is a resident of
Calgary, in the Province of Alberta. He is a member of the Party, but not a
member of the Riding. He is the president of the Parry's Calgary West
constituency association (hereinafter "Calgary West").
8. The true names of the Defendants named herein as John Does and/or
Jane Does 1 through 250 are unknown to the Plaintiffs who therefore sue them
by such fictitious names. These Defendants participated in and propagated the
defamation of the Plaintiffs as alleged herein. The Plaintiffs will amend this
claim to show their true identities and to further particularize their conduct
when same have been ascertained.
9. After Levant stepped aside for Harper as the Riding's by-election
candidate, the Riding retained a professional, independent auditor to review
the Riding financial accounts and related governance issues during the period
of Levant's candidacy. Upon completion of the audit, the auditor made an
extended presentation to the Riding at a board meeting. The report was
-3-
oTz;:rr1"*'cu
i dn
i gHarperv'otedtosisue**
thanks to the campaign team, including the Plaintiffs.
10. Additionally, the Riding's audit as well *<* =ii

tfte-to
h e rmcludmg
e t o i nbank
c l ustatements,
H i u cancelled
, . s ucheques
p p o r tand
ing
hundreds
d o c uofmreceipts
ents
-d -dees, were submitted to the Party, national office for inspect
~ attended at *e Parfy's ffi~ - **

questions put to him, to the satisfaction of Party officials.
11. Both the Riding and the Party's national office have reviewed the Riding,
r:;irmance^haveprovedm--*--^z
conduct, and have approved as legitimate all of the Plaintiffs'conduct regldLg
same, including but not limited *.+ <. . 8
and
purchases
"^
f
^^
CXpenSeS'
Ieases
12- This successful audit and review was or ought to have been public
knowledge to all Riding or Party members who sought to inquire, or to a^d
Hidingboard
meetogs,
which open to Par* members, or to review minuted
Kidmg
meetings.
iLd^tfh ** rigrous accounting> "d in ^ face f *" *>. **
Defendant, have repeatedly published or spoken defamatoxy untruths about

*e Plamnffs regarding the matters treated in the audi, Over the past year the
and
Decants
communicated
have publicly
this threatened
threat to Party
to embarrass
and Riding officials.
the Plaintiffs or any of *em
14. In response, Party and Riding officials have constantly referred the
r^r*processdescrb
i ed^-d-continue
to
do
so.
^^
***
***
15. On or about the 17* day of December, 2002, the Defendants or any of
them, published a letter, addressed
the Secretary
*
" lu tnetosecretariat
committee
of the Party,
-4-
governing National Council (hereinafter the "December 17th Letter"). The

December 17* Letter was also circulated widely to other people across Canada,
including to thousands of members of the Party, to people who were not
members of the Party, and to various news media. The December 17th Letter is
attached hereto and marked as Exhibit A. It is false, and defamatory of the
Plaintiffs.
16. On or about the 24th day of January, 2003, the Defendants, or any of
them, published another letter, addressed to Terry Horkoff, the Executive
Director of the Party (hereinafter "Horkoff"). This letter is hereinafter referred to
as the January 24th Letter.
17. The January 24th Letter was also circulated widely to other people across
Canada, including to thousands of members of the Party, to people who were
not members of the Party, and to various news media. The January 24th Letter
included within its body a copy of the December 17th Letter, as well as certain
additional documents listed within its text, and is attached hereto and marked
as Exhibit B. It is false, and defamatory of the Plaintiffs.
18. On or about the 19th day of May, 2003, the Defendants, or any of them,
published another letter, addressed to "Canadian Alliance Friends" (hereinafter
the "May 19th Letter"). Hennan published the May'19th Letter as an attachment
to an E-mail sent to numerous people (hereinafter the "May 19th Hennan Email"), including the following Party National Councilors who are resident
across Canada:
a. James Carson;
b. Don Irwin;
c. Aria Taylor;
d. Robert Alexander;
e. Michael Cooper (a Plaintiff herein);
f. Doug Sharpe;
-5g.
Jeremy Harrison:
h.
Sam Magnus;
i.
Eric Schenstead;
J-
Ed Agnew;
k.
Don Plett;
1.
Denis Simard;
m.
Pat Dunn;
n.
Nancy Jahn; and
0.
David Leskowski.
19. The subject title of the May 19* Hennan E-mail containing the May 19*
Letter was "Complaints of Misconduct in Calgary Southwest", and it was sent
from Hennan's E-mail account, namely hennan@.shaw.ca. It is defamatory of
the Plaintiffs.
20. In addition to the May 19* Letter, the May 19* Hennan E-mail also
contained the following words in the body of the E-mail itself, which were false,
and defamatory of the Plaintiffs:
"To Members of National Council,
As a very long time member of the Reform - Alliance Party in Canada, I would
like you to teU me if any of you knew about the serious allegations in the
attached documents prior to this release, and, if so, WHY HAS IT BEEN SWEPT
UNDER THE CARPET?
It appears as if all of this has taken place RIGHT UNDER OUR LEADER'S
NOSE!! If we cannot deal with conduct like this in our own party, how do you
expect to run the affairs of an entire country with the honesty and integrity we
have promoted over the years?
I must say, ever since Preston Manning stepped down (or was forced out), this
parry has been lowered to the same level as all the rest of them.
Garry Hennan,
Member since 1991,
-6Calgary Southwest"
21. In addition, the Defendants, or any of them, circulated the May 19*
Letter widely to people across Canada, including to thousands of members of
the Party, to people who were not members of the party, and to various news
media.
22. The May 19* Letter included within its body copies of the December 17*
Letter and January 24* Letter, and is attached hereto and marked as Exhibit
C. It is false, and defamatory of the Plaintiffs.
23. On or about the 21st day 0f May> 2003, the Defendants, or any of them,
published another letter (hereinafter the "May 21st Letter") and sent it by Email to thousands of members of the Party across Canada, to people who were
not members of the Party, and to various news media. The May 21st Letter
included an attached document, which included within its body a copy of the
December 17* Letter and January 24* Letter, and added to those a preface
and postscript similar to that of the May 19* Letter, but with an increasingly
defamatory and malicious tone and with more incendiary language. The May
21st Letter is attached hereto and marked as Exhibit D. It is false, and
defamatory of the Plaintiffs.
24. The May 21st Letter was E-mailed from an anonymous E-mail account
which disguised the true identity of the E-mail's sender, appearing to be sent
instead from the alias "Concerned.Alliance.Members..Please.Act.Now!@domain.com."
25. The May 21* Letter's E-mail subject title was "Wrongdoing in Calgary
Southwest Must Be Investigated."
26. In addition to the aforementioned attached document, fictitious identity
and subject title, the May 21* Letter also contained the following words in the
body of the E-mail itself:
"Dear Alliance Friend,
-7-
Kto ^SiSf06 Tmbfruand Care ab0Ut HONESTY and INTEGRITY
totoSS^SS^ ** atached me ^ FORWARDIT TO ^
Syi^
syrs
jSxSTSS Wonnh,antdeUvered t0 the Executive Director of the party on

S S a t S r, t ^ ' I 0 " U n m e d i a t e d e l i v e i y t o t h e N a t i o n a l c S u n c
havrSn iiored not?' T T^* CnCemS f ahnost 200 member*
SicateS irfthi! r" f-"f h&S been dne! Meanwhile the very same people
Sfr ? Complaint are trying to secure control of other ridings -most
SSSSS Cntre' ^ * Wn,t StP therd 0thCr ridmSS willôonbe1
1TstSLpÊ^?ut
the core
brought
US
TO THIS PARTY - HONESTY
ANDvalues
INTEGRITYthat
- PLEASE
HELP!
dxes
ssr
should
many of
~cs
Thank you.
5'^1rThe att*chn)ent contains a Member Advisory dated May 2003 a conv
Note#2: File transfer size limits makes it impossible to include n rtw
tStoZZSFZZ?? Ithe Tf31 refer^Ced - atta'hrnentslo
Secret
a^S
pa^^cuVeXtctr"
**
^
"^
C^'
27. On or about the 20* day of May, 2003, Hennan published the May 19*
Letter as an attachment to an E-mail sent to Paul Jackson, a senior columnist
with the Calgary Sun newspaper (hereinafter the "May 20* Hennan E-mail")
On or about the 27- day of May, 2003, Hennan published another E-mail to
Paul Jackson (hereinafter the "May 27* Hennan E-mail", referring to the May
20- Hennan E-mail. Both of these E-mails were false, and defamatory of the
Plaintiffs.
-828. The subject title of the May 20* Hennan E-mail was "Joel Loh May Not
Make It The Way You Think", and the E-mail was sent from Hennan's E-mail
account, namely hennan@shaw.ca.
29. The May 27* Hennan E-mail also contained the following words in the
body of the E-mail itself:
"Hello Paul,
Do you recall the document package I sent to you last week regarding the
problems in Calgary Southwest? Well, both your rising stars Joel and Ezra are
front and centre in this controversy and formal complaint now in the hands of
the Alliance Party National Council.
In fact, there is a more than even chance that Joel may have to withdraw from
his bid for Calgary Centre. The nomination selection committee is having
second thoughts about Mr. Loh now that they have additional information on
his background as former treasurer and president of Calgary Southwest
Constituency Association.
This places you in a difficult position. However, you may send any portion of
your Mexican retirement fund you like to my attention (as noted in your May
27th column). I am calling you on your bet.
Garry Hennan,
Alliance Member,
Calgary Southwest,
680-5735"
30. On or about the 20* day of May, 2003, Wakula published an E-mail sent
to numerous people (hereinafter the "May 20* Wakula E-mail"), including to
Terry Horkoff, the Party's executive director (hereinafter "Horkoff), and Linda
Toews, the party's Southern Alberta volunteer coordinator (hereinafter
"Toews"). This E-mail was false, and defamatory of the Plaintiffs.
31. The subject title of the May 20* Wakula E-mail was "Re: Wrongdoing in
Calgary Southwest", and the E-mail was sent from Wakula's E-mail account,
namely walterwakula@shaw.ca.
-932. The May 20* Wakula E-mail contained the following words in the body of
the E-mail itself (including original typographical errors):
"Dear Concerned Alliance Members, Terry and Linda,
I continue to be amazed at the lack of financial control and poor governance of
some constituency associations, Calgary Southwest in particular, and the lack
of fundamental decency and pure ambition of some people. I have seen some
"Gong shows" but this one surely takes the cake.
However, when all is said and done, this appears to me to be a Calgary
Southwest matter and a forensic audit appears warranted with results reported
at a spacial meeting of the members. My wonder is why a special meeting of the
members has not already been called to deal with the matter and pass a special
resolution to ask National Council for help rather than rallying people from
other ridings.
Though a Calgary Southwest matter, I am concerned of the spillover effects this
matter may have in the rest of Calgary and, indeed, for the party overall if these
allegations get into the press and especially if litigation is launched. On that
basis, I ask that this matter be put on the SACC agenda for June.
Best regards,
Walter Wakula, President
Calgary West Constituency Association
Canadian Alliance
Phone: 246-9290"
33. In or about May, 2003, Flynn published the May 21*t Letter as an
attachment to an E-mail sent to numerous people (hereinafter the "Flynn Email"), including to the entire board of directors of the Riding.
34. On or about the 27* day of May, 2003, Wakula published the May 21st
Letter as an attachment to an E-mail sent to numerous people (hereinafter the
"May 27* Wakula E-mail"), including to the entire board of directors of CalgaryWest. The E-mail was false, and defamatory of the Plaintiffs.
35. The subject title of the May 27* Wakula E-mail containing the May 21s*
Letter was "Alliance Party News - Issue No. 26", and the E-mail was sent from
Wakula's E-mail account, namely walterwakula@shaw.ca.
- 1036. In addition to the May 21st Letter, the May 27* Wakula E-mail also
contained the following words in the body of the E-mail itself:
"Fellow Directors,
Attached are the latest party announcements and sampling of news that I have
received since my Alliance Party News Issue No. 25 about 2 weeks ago.
Significant items among these are:
1. Calgary Center and Calgary SE are looking for volunteers for their
Candidate Selection Meetings (May 31, June 4 and 14) See attached
Email for details.
2. There's a few Canadian Alliance Advocates attached including a special
edition
3. Wrongdoing in Calgary SW is a case study in lax financial controls and
poor governance of a constituency association.
Enjoy.
As usual, if you don't want to receive these Alliance Party News Emails, please
let me know and 111 take you off the list.
Best regards,
Canadian Alliance
Phone: 246-9290"
37. On or about the 6* day of June, 2003, Wakula published an E-mail sent
to numerous people (hereinafter the "June 6* Wakula E-mail"), including to
Horkoff, Toews, and members of the Calgary West's executive committee. The
E-mail was false, and defamatory of the Plaintiffs.
38. The subject title of the June 6* Wakula E-mail was "Fw: Wrongdoing in
Calgary Southwest", and the E-mail was sent from Wakula's E-mail account,
39. The June 6* Wakula E-mail repeated the entire May 20* Wakula E-mail,
and also contained the following additional defamatory words in the body of the
E-mail itself (including original typographical errors):
- 11 "John,
I had responded to your "Wrongdoing ..." Email copying Terry Horkoff and
Linda Toews but the return Email copy to your group bounced.
I just re-read the Email from your "Please Act Now" group and am forwarding
my response, below, made a couple of weeks ago. I understand that you are
being pressured to not pursue an audit by senior members of the Alliance. I
can understand why the Alberta National Councilors are against such an audit
but don't understand why Terry and other senior Alliance officials are against
it. My previous Email comments below also apply.
My position with managing other people's money is always to err on the side of
tranparency, especially when there appears to be malfeasance as your group
alleges. It may just be gross incompetence or naivety of that Board which,
though reprehensible and not financially prudent, would not otherwise be
illegal. If funds were misappropriated by the constituency to pay for a national
councillor election campaign then I believe erring on the side of transparency is
again preferable so the consequences of that can properly be dealt with by the
Alliance.
On the basis of these points I would support a forensic audit being undertaken
so that you can provide a proper financial report to your members. If your
riding is like mine there have been hunderds of $25 donations by poeple who
are strong believers but who can't really afford the donation and don't even
qualify for the tax receipt.
However, extending the audit to a lawyers trust account, over his objections,
may involve obtaining a court order and going through that process, which
could include litigation. This may be a reason for senior Alliance resistance to
such an audit.
I have put this item on tomorrow's SACC agenda despite Terry's objections
and hope to understand the matter better after our discussion.
Best regards,
Canadian Alliance
Phone: 246-9290"
40. On or about the 5* of June, 2003, Flynn chaired a meeting of the Riding.
At that meeting, the auditor who audited the Riding's financial accounts in the
spring of 2002 presented his findings again, in rebuttal to the May 2 l*t Letter.
- 1241. Two days later, on or about the 7* of June, 2003, Flynn attended a
meeting of Party constituency association presidents and other Party officials
from across southern Alberta (the "June 7* Meeting"). At the June 7* Meeting,
Flynn orally repeated the defamatory words, or any of them, contained within
the May 21st Letter, and encouraged other Party officials from across Alberta to
read and believe the May 21st Letter and to officiously launch another audit
into the matters alleged therein. He did so despite having heard the true facts
of the matter from the auditor just two days previously.
42. At the June 7* Meeting, Flynn described Party officials, including
Harper, who were not receptive to this new audit proposal as "cockroaches."
The exact defamatory words used by Flynn at the June 7* Meeting (hereinafter
"June 7* Alberta Meeting Statements") are unknown to the Plaintiffs who will
amend this claim as may be necessary to particularize them when same have
been ascertained. The statements were false, and defamatory of the Plaintiffs.
43. On or about the 7* day of June, 2003, as a result of the June 7* Alberta
Meeting Statements, Harper telephoned Flynn to ask him to resign as president
of the Riding. Following that telephone call, Flynn published an E-mail sent to
numerous people (hereinafter the "June 7* Flynn E-mail"), including to Toews,
Robert Harper (Harper's brother), Ray Novak (Harper's assistant), members of
Calgary West, and members of the Riding. The E-mail was false, and
44. The subject title of the June 7* Flynn E-mail was "Jabs from the
Leader", and the E-mail was sent from one of Flynn's E-mail accounts, namely
calgarysw@aol.com.
45. The June 7* Flynn E-mail contained the following words in the body of
"Mr. Harper,
This afternoon, you had phoned my home and our telephone conversation
ended abruptly. You have interpreted my words as a resignation. Firstly I did
not use the word "resign". Secondly, I do not resign to you. I will resign to the
- 13Board on my terms. Again, I find it appalling that you continue to believe that
you run this Constituency Association. This constituency association is not
yours . You have forgotten that this is a grassroots party with a Constitution.
You had called to tell me that there have been many complaints from National
Council and from Calgary SW Board members about my conduct. You would
not name them for me. (I have also heard that you are not happy with my
stance on this issue and plan on removing me anywayJ.Of course, our members
are quite aware of the two local National Councillors involved. Many could
question their conduct. I know our SW Board members have been called by
your associates. Again, inappropriate conduct. I can say, after the Southern
Aiberta Constituency Council meeting today, that I would have the full support
of all Constituency Presidents in Southern Alberta.
No one can understand why you will not properly and professionally deal with
m^ jerysenous allegations against this riding. It has been one year and
nothing has happened. You have told me that it is not our problem. You have
also said that National Office is dealing with it. I strongly disagree on both of
those statements. This Calgary SW Constituency Association will not be moving
forward until the Complaint against this Association is properly handled There
is also spill over to other ridings. This issue can damage the parry.
Th%?alffry
BoardConstituency
wiU now have
t0 decide agree.
whetherMaybe
to call for
forensic
audit ManySWother
Presidents
an aElections
Canada/Revenue Canada audit would be the best since it would save the
Board a lot of money which we do not have in our account.
I believe I speak for many individual members of this party when I say ... it is
time for some leadership on this issue.
Regards,
John Flynn
President
Calgary SW"
46. On or about the 8* day of June, 2003, Wakula published two defamatory
memoranda, by sending them by E-mail (hereinafter the "First June 8* Wakula
Memo" and the "Second June 8* Wakula Memo"). The First June 8* Wakula
Memo was sent to numerous people, including to Don Plett (the president of
the Party), Harper, Flynn, Horkoff, Gus Barron (the president of the Party's
Calgary Centre constituency association, hereinafter "Barron") and the
executive committee of Calgary West. The Second June 8* Wakula Memo was
sent to the same people, except Horkoff. The First June 8* Wakula Memo is
- 14attached hereto and marked as Exhibit E. The Second June 8* Wakula Memo
is attached hereto and marked as Exhibit F. Both memoranda are false, and
47. On or about the 9* day of June, 2003, Flynn published an E-mail sent to
numerous people (hereinafter the "June 9* Flynn E-mail"), including to
Wakula. The E-mail was false, and defamatory of the Plaintiffs.
48. The subject title of the June 9* Flynn E-mail was "Re: Solutions For The
Calgary Problem", and the E-mail was sent from one of Flynn's E-mail
accounts, namely calgarysw@aol.com.
49. The June 9* Flynn E-mail contained the following words in the body of
"Walter,
I submitted my resignation to the SW board. (What is left of it).There were
people operating behind my back to undermine me and they plan on lynching
me tomorrow anyway.
For your eyes only, Yesterday, I received the typical telephone call/blackmail
attempt.
Of course, I am not entirely scared by this action. I would love to stay and fight.
I am very concerned about my elevated anger and blood pressure.
Having been a member for many years, I also have a really hard time justifying
an enormous amount of my time to clean up this huge mess that was created
by many others who have all been promoted into this party.
Amazing destroy a riding association and get promoted??
I honestly thought that Harper was a better man than Chretien. I do not want
to be a part of the New Liberal Party.
Sincerely,
John Flynn"
50. On or about the 15* day of June, 2003, the Defendants, or any of them,
attended a meeting of Party constituency association presidents, volunteers,
Members of Parliament and senior Party officers, including the Party's national
president, national secretary and senior advisors to Harper (hereinafter the
"June 15* Alberta Meeting"). At the June 15* Alberta Meeting, the Defendants,
including Wakula, orally defamed the Plaintiffs (hereinafter the "June 15*
- 15Alberta Meeting Statements") including repeating words from the May 21st
Letter.
51. On or about the 16* day of June, 2003, Wakula published an E-mail
sent to numerous people (hereinafter the "First June 16* Wakula E-mail"),
including to Linda Slobodian, a reporter and columnist with the Calgary
Herald, the Letters Editor of the Calgary Herald, Barron, and Jim Stevenson,
president of the Party's Calgary Northeast constituency association. The E-mail
was false, and defamatory of the Plaintiffs.
52. The subject title of the First June 16* Wakula E-mail was "Canadian
Alliance - Meeting fails to mend rift over riding vote", and the E-mail was sent
from Wakula's E-mail account, namely walterwakula@shaw.ca.
53. The First June 16* Wakula E-mail contained the following words in the
body of the E-mail itself (including original typographical errors and use of bold
text):
"Re: Canadian Alliance - Meeting fails to mend rift over riding vote
June 16, 2003 by Linda Slobodian
I was disappointed to read in this article that Gus Barron, President of Calgary
Centre Alliance, believes that nothing was accomplished at Sunday's meeting of
Southern Alberta Alliance MPs, Presidents and National Council Executive. On
the contrary, the objectives of the meeting were to hear National Council's
viewpoint and rationale for decisions taken by it on the Calgary situation and
to discuss and provide feedback from Southern Alberta MPs and Presidents on
this situation. A further objective of the Presidents was to encourage National
Council to work with riding officials to bring about a quick, transparent and
fair resolution to the controversy currently engulfing Calgary Southwest and
Calgary Centre Constituency Associations.
In my opinion the Executive of National Council undertook to do just that.
Council President Don Plett committed to provide a report on Calgary
Southwest finances within 10 to 14 days. Council also delegated to an Offficer
of council responsibilty to investigate the Candidate Selection process in
Calgary Centre with a view to resolve the impasse and move forward quickly
with a solution acceptable to the Board and the three candidates. I felt we left
the meeting upbeat and confident that all sides had discussed the issues
openly and honestly and that our objectives had been substantially achieved.
Best regards,
- 16Walter Wakula, MBA

President
Canadian Alliance
143 Windermere Road S.W.
Calgary, AB
T3C 3K9
Phone: (403) 246-9290
Cell: (403) 816-6206"
54. On or about the 16* day of June, 2003, Wakula published another Email sent to numerous people (hereinafter the "Second June 16* Wakula Email"), including to the entire board of directors of Calgary West. The E-mail
was false, and defamatory of the Plaintiffs.
55. The subject title of the Second June 16* Wakula E-mail was "My Letter
to the Herald Editor Re; Calgary SW & Centre", and the E-mail was sent from
Wakula's E-mail account, namely walterwakula@shaw.ca.
56. The Second June 16* Wakula E-mail contained within its body an exact
copy of the First June 16th Wakula E-mail and the following additional words
(including original typographical errors):
"Fellow Directors,
I had believed that the problems in Calgary SW and Calgary Center were
problems that needed to be solved by their Boards and members. However,
after last week's Southern Alberta Constituency Council ("SACC") meeting I
was appalled to learn more about the serious allegations being circulated, was
concerned about the threats of litigation against those volunteers providing
evidence of alleged malfeasance and was concerned about the effect these
matters may have on Calgary West and other Southern Alberta constituencies.
Because of these factors I moved a motion in SACC for SACC to arrange a
meeting with Don Plett, President of National Council, and his executive before
they left town on Sunday.
Following up on that motion I wanted you to be aware that I was one of the
organizers of a joint meeting among SACC, National Council Executive and the
Calgary area MPs held Sunday morning, June 15, 2003. It was important to us
to get National Council more informed on the issues and to urge them to work
with riding officials to bring about a quick, transparant and fair resolution to
the controversy. Further, I emphasized to the meeting that a high priority be
given to this by Council for a number of reasons not the least of which is that
- 1723 percent of the membership of the Alliance is represented by SACC. A

problem spreading in Calgary less than a year before the next election has, in
the opinion of several presidents, the potential to erode a substantial base of
the party, especially if hostile Board takeovers domino into more Calgary area
ridings.
I thought the concensus of the Sunday morning meeting was upbeat and that
the issues had been discussed openly and honestly and that Council had
committed to proceed quickly and openly to resolve the disputes. I woke up to a
Herald article stating that Gus Barron, President of Calgary Centre, disagrees.
Accordingly, I have written the following letter to the editor of the Herald. I
would appreciate any comments you may have on this.
Best regards,
Canadian Alliance
Phone: 246-9290"
57. On or about the 18* day of June, 2003, Wakula published an E-mail
sent to numerous people (hereinafter the "June 18* Wakula E-mail"), including
to the entire board of directors of Calgary West. The E-mail was false, and
58. The subject title of the June 18* Wakula E-mail was "Alliance Party
News - Issue No. 27", and the E-mail was sent from Wakula's E-mail account,
59. The June 18* Wakula E-mail included, as attachments, an exact copy of
the May 20* Wakula Letter, the June 6* Wakula E-mail, the June 7* Flynn
Letter, the First June 8* Wakula Memo and the Second June 8* Wakula
Memo.
60. On or about the 19* day of June, 2003, the Defendants, or any of them,
sent the May 21st Letter, including the names of 177 of the Defendants referred
to herein as John Does and Jane Does, to the National Post newspaper's
Ottawa bureau.
61. The defamatory written documents referred to in paragraphs 15 through
60 and the Exhibits thereto are hereinafter referred to collectively as the
- 18"Letters". The defamatory oral statements referred to in paragraphs 15 through

60 are hereinafter referred to collectively as the "Statements."
62. The Plaintiffs state that they are the persons referred to in the Letters
and the Statements. Their identify is readily apparent to readers of the Letters
and those who heard the Statements, especially to members of the Party and
the Riding, even though euphemisms and pronouns are generally used in the
Letter instead of the Plaintiffs' names. As well, many people who are not
members of the Party but who follow the news, as well as members of the news
media, other political activists, clients, patients, friends and other associates of
the Plaintiffs would identify the Plaintiffs as the persons defamed in the Letters
and the Statements.
63. The Letters and the Statements could not be referring to anyone else but
the Plaintiffs.
64. In particular, Cooper is well-known as a National Council candidate and
member of the "PAL* Party slate referred to in the Letters and the Statements
Every member of the Party, especially those in Alberta, has received several
letters, both from the Party and from Cooper, to that effect. All references to
PAL", "PAT or National Council elections refer to him. As well, Cooper was the
recipient of a $500 fee for service on the campaign. By implying that this $500
payment was inappropriate, the Defendants again clearly identify and defame
Cooper.
65. In particular, Levant is well-known as the candidate referred to
throughout the Letters and the Statements, and as the author of various
brochures and correspondences referred to therein, including fundraising
appeals, and the host of various fundraising events referred to therein
Members of the Party, especially those in the Riding, would have known that
fact, not only from media coverage but from several letters, brochures and
telephone messages from the Parry and Levant himself. Levant's candidacy is
also well-known to the news media, political activists, lawyers, the Jewish
- 19community and the public in general, especially in Alberta, Toronto, Ottawa

and nationally.
66. In particular, Dr. Levant is well-known as a director of the board of the
Riding and a leading volunteer in and organizer of Levant's campaign activities
referred to throughout the Letters and the Statements. Members of the Party
and others, especially those in the Riding, would have known that fact, not
only from media coverage but from a letter sent to hundreds of Alberta doctors
by Dr. Levant. Dr. Levant's involvement is also well-known to Harper, and to
other Members of Parliament, the news media, political activists, the Jewish
community and the public in general.
67. In particular, McKinsley is well-known as the businessman, campaign
manager and general political and financial organizer referred to throughout
the Letters and the Statements. Members of the Party, especially those in the
Riding, would have known that fact. As campaign manager and a guest at
many Riding meetings, McKinsley is well known to Party volunteers including
Riding board members and Harper. McKinsley is also well-known within the
Party in general and the general business, news media and political
community.
68. The Plaintiffs claim that the Letters and the Statements are false and
defamatory in their material and ordinary meaning.
69. The December 17* Letter and the Statements were meant or reasonably
understood to mean that:
a. the Plaintiffs are not honest;
b. the Plaintiffs have no integrity;
c. the Plaintiffs engage in wrongful conduct;
d. the Plaintiffs, particularly Levant, Dr. Levant and McKinsley, refuse
to make disclosures of properly disclosable information;
-20e. the Plaintiffs disregard appropriate standards of conduct;

f. the Plaintiffs, particularly Levant, Dr. Levant and McKinsley ran
the Riding into the ground, into debt, and broke it;
g. the Plaintiffs are tainted;
h. Cooper was elected to National Council improperly;
i. the Plaintiffs, particularly Levant, Dr. Levant and McKinsley
improperly handled $30,000 from a December, 2001 fundraising
dinner that should have been deposited with the Riding;
j. the Plaintiffs, particularly Levant, Dr. Levant and McKinsley did
not contribute to the election campaign, after promising to do so;
k. the Plaintiffs engaged in fundraising tactics that are contrary to the
Party's policy, and that the Party has criticized in Parliament;
1. Levant and McKinsley misled the Party into paying inappropriate
or personal debts;
m. the Plaintiffs inappropriately used Party funds to pay for Cooper's
election campaign for National Council, including inappropriate
use of postage, photocopying, printing and telephones;
n. the electoral results at the Riding's Annual General Meeting in
November, 2001, including Dr. Levant's election to the board, were
not legitimate, but rather the result of a hostile act by the
Plaintiffs;
o. Party funds were inappropriately used to recoup costs for personal
expenses of the Plaintiffs, particularly Levant;
p. Riding funds were used to pay an election deposit for Cooper;
-21 q. McKinsley inappropriately paid fundraising commissions, and

funds raised through those commissions were inappropriately
spent;
r. Levant inappropriately received a candidate refund twice;
s. cash donations were improperly accounted for by the Plaintiffs;
t. Riding funds were turned over by Dr. Levant to Levant or
McKinsley without authority, prematurely, and without armslength controls;
u. Levant and McKinsley inappropriately had early access to the Party
membership list, and continue to use it improperly;
v. Levant's choice of an official agent was inappropriate and illegal;
w. the Plaintiffs have breached their fiduciary duties to Party
members in the Riding;
x. $50,000 of Party money was improperly and unaccountably
transferred by the Plaintiffs to a lawyer's trust fund;
y. the Plaintiffs have improperly kept or converted property belonging
to the Riding;
z. McKinsley improperly enriched himself by giving himself or his
company $40,000 from Party funds;
aa. McKinsley has received money from the Riding without proper
accounting;
bb. Levant and McKinsley improperly acquired durable assets
purchased by the Riding, and did not meet their fiduciary duties;
cc. the Plaintiffs conduct warrants a professional investigation, or an
additional professional investigation;
-22-
dd. the Plaintiffs conduct warrants a criminal investigation, have

conducted themselves illegally, and are criminals; and
ee. the Plaintiffs are deserving of sanction by the Party.
70. In addition to the meaning of the December 17* Letter, which was
repeated in the January 24* Letter, the January 24* Letter and the
Statements also were meant or reasonably understood to mean that:
a. the Plaintiffs are vexatious and frivolous litigants who abuse the
court system; and
b. the Plaintiffs are controlling the Riding and the Party and are
refusing to allow proper investigations or complaints to be made.
71. In addition to the meaning of the December 17* Letter and the January
24* Letter, which was repeated in the May 19* Letter, the May 19* Letter and
the Statements also were meant or reasonably understood to mean that:
a. the Plaintiffs were not being honest;
b. the Plaintiffs have no integrity;
c. the Plaintiffs are corrupt and engage in corruption, and do so
blatantly;
d. the Plaintiffs engage in questionable, intolerable and shocking
conduct;
e. the Plaintiffs are scandalous, and attempt to cover up their
scandals;
f. the Plaintiffs throw away money belonging to the Party;
g. the Plaintiffs engage in deceitful behaviour, and deceive Party
members throughout Calgary;
-23-
h. the Plaintiffs siphon money out of Party coffers, and do so

inappropriately and secretly;
i. the Plaintiffs improperly enrich themselves and personally benefit
from property that belonged to or ought to have belonged to the
Party;
j. the Plaintiffs misappropriate money that was supposed to go to
fight the Liberal party;
k. the Plaintiffs violate conflict of interest guidelines;
1.
McKinsley grants himself contracts, with Levant's approval, and

both do so inappropriately;
m. the Plaintiffs are discreditable;

n. the Plaintiffs have been implicated by these accusations;
o.
the Plaintiffs make the Party a corrupt imitation of the Liberals;

and
p. the Plaintiffs are generally disreputable, odious and worthy of

contempt.
72. In addition to the meaning of the December 17* Letter, the January 24*
Letter and elements of the May 19* Letter which were repeated in the May 19*
Letter, the May 21st Letter and the Statements also were meant or reasonably
understood to mean that:
a. the Plaintiffs are committing or are about to commit misconduct in
the Party's Calgary Centre constituency association, and
potentially elsewhere, and that the Party's finances are nowhere
safe from the Plaintiffs;
b. the Plaintiffs and their conduct are like a cancer; and
-24c. Levant was not properly scrutinized by the Party before becoming
the Riding's candidate, and that he was and is not fit to become
the candidate.
73. The May 21 Letter and the Statements contained adjectives and adverbs
throughout which served to emphasize the defamation by portraying the
Plaintiffs conduct as superlatively disreputable.
74. The May 20* Hennan E-mail and the Statements were meant or
reasonably understood to mean that:
a. the allegations outlined in the Letters were true;
b. wrongdoing by Plaintiffs had been covered up;
c. the Plaintiffs and their conduct lacked honesty and integrity; and
d. the Plaintiffs had lowered the moral character of the Party.
75. The May 20* Hennan E-mail, the May 27* Hennan E-mail and the
Statements were meant or reasonably understood to mean that:
a. Levant's career as a rising star is over, or ought to be over; and
b. anyone associated with the Plaintiffs is of dubious character.
76. The May 20* Wakula E-mail and the Statements were meant or
reasonably understood to mean that:
a. it was an established fact that the Plaintiffs committed wrongdoing
in the Riding; and
b. any wrongdoing was the result of laxity and poor governance on
the part of the Riding's directors, including Dr. Levant.
77. The June 6* Wakula E-mail was meant or reasonably understood to
mean that:
-25a. the Plaintiffs' conduct warrants a further audit, and a forensic

audit;
b. senior members of the Party are covering up the Plaintiffs' conduct;
c. the Plaintiffs mismanaged other people's money;
d . t h e P l a i n t i ff s ' fi n a n c i a l d e a l i n g s w e r e n o t a p p r o p r i a t e l y
transparent;
e. the Plaintiffs were guilty of malfeasance;
f. the Plaintiffs were guilty of gross incompetence and naivete;
g. the Plaintiffs conduct was reprehensible;
h. the Plaintiffs are not financially prudent;
i. the Plaintiffs, especially Cooper, misappropriated funds for a Party
National Council election;
j. the Plaintiffs took advantage of hundreds of hard-working people,
who can't afford it; and
k. Levant's lawyer's trust fund should be audited.
78. The June 7* Flynn E-mail was meant or reasonably understood to mean
that:
a. the Plaintiffs have been let off improperly and unprofessionally by
Harper;
b. the financial allegations against the Plaintiffs are very serious;
c. no material or real audits or investigations have been made;
d. the Party's National Office has not properly punished the Plaintiffs;
-26-
e. the May 21st Letter has not been properly handled by the Party or
Harper;
f. the Plaintiffs' conduct is spilling over into other Party constituency
associations;
g. a forensic audit is needed, and other Party constituency
associations agree with that conclusion; and
h. the Plaintiffs' conduct is egregious enough to warrant an
investigation and audit by both Elections Canada and Revenue
Canada.
79. The First June 8* Wakula Memo was meant or reasonably understood to
mean that:
a. the Plaintiffs' conduct is appalling;
b. the allegations against the Plaintiffs are serious;
c. the Plaintiffs, especially Levant, threaten volunteers and witnesses;
d. the Plaintiffs engage in malfeasance;
e. other Party constituency associations in the Calgary area are at
risk from the Plaintiffs;
f. the Plaintiffs' conduct was not appropriately transparent;
g. the Plaintiffs, especially Dr. Levant, have not properly disclosed
financial information for three years running, and have not
complied with proper accounting procedures; and
h. the Plaintiffs' conduct warrants an audit or a forensic audit.
-2780. In addition to the meaning of the First June 8* Wakula Memo, the
Second June 8* Wakula Memo was meant or reasonably understood to mean
that:
a. Cooper inappropriately funded his National Council campaign
through Riding funds; and
b. the Plaintiffs, especially Levant, bully people who seek solutions.
81. The June 9* Flynn E-mail was meant or reasonably understood to mean
that:
a. the Plaintiffs, particularly Levant, engage in blackmail;
b. the Plaintiffs have created a huge mess that needs cleaning up;
and
c. the Plaintiffs have destroyed the Riding.
82. The First June 16* Wakula E-mail and the Second June 16* Wakula Email were meant or reasonably understood to mean that:
a. the Plaintiffs are controversial, and have created a situation
requiring the intervention of outside officials;
b. the Plaintiffs' conduct was appalling;
c. the Plaintiffs were threatening witnesses and others with evidence
of the Plaintiffs' malfeasance;
d. Wakula had to educate the Party's National Council about the facts
regarding the Plaintiffs;
e. the Plaintiffs represent a problem that is spreading around Calgary
and threatens to erode the Party; and
-28-
f.
the Plaintiffs did not succeed in the Riding through democratic

means, but rather through hostile means, and threaten to do the
same in other Party constituency associations.
83. The use of capital letters, bold and underlined text in the Letters was
deliberately designed to inflict maximum damage on the Plaintiffs, by
emphasizing particularly defamatory words.
84. The Plaintiffs state that by reason of the publication of the aforesaid
Letters and Statements the Plaintiffs have been severely injured in their credit,
character, and reputation and have been brought into public scandal, odium,
and contempt, and have suffered damages.
85. The Plaintiffs claim that the Defendants acted with malice, in that the
Defendants, or any of them, had a pre-existing political hostility towards and
disagreement with the Plaintiffs, and that pre-existing hostility and
disagreement was the real motivation behind the Letters and the Statements.
86. The Plaintiffs claim that the Defendants, or some of them, continue to act
with malice, in that they continue to exhibit political hostility towards and
disagreement with the Plaintiffs, as revealed by their reference to the Calgary
Centre Party contest and other potential Party contests, and their Statements.
Defendants conducted themselves as officious intermeddlers. The Defendants
had no reasonable basis for publishing the Letters and the Statements, and
had no public or private duty or interest which obligated them to do so. Those
Defendants who live outside the Riding and who were therefore not members of
the Riding were especially officious, as were those Defendants who published
the Letters and the Statements to persons who live outside the Riding.
questions raised in the Letters and the Statements were answered exhaustively
by the auditor and by the Plaintiffs, especially by Levant and McKinsley, and
- 29 their answers were accepted and approved by the Party and the Riding. The
Defendants persisted with their defamation despite their defamatory
complaints being rejected by the auditor, the Riding, the Party and all other
proper authorities.
89. The Defendants acted with malice, in that the Letters and the Statements
were published with reckless disregard of the truth, or fairness, or for the
Plaintiffs' reputations, as the Defendants knew the Letters and the Statements
were false.
90. Flynn acted with malice in that, just days after he heard the auditor's
report debunking the defamation described herein, Flynn attended the June 7*
Alberta Meeting and uttered the June 7* Alberta Meeting Statements.
91. The Letters and the Statements were not genuine complaints or
inquiries, but rather crude attempts to smear the Plaintiffs. The Letters and the
Statements pretend to be good faith complaints, or unprejudiced questions, but
in fact repeatedly state defamatory conclusions and false statements of fact,
and therefore are not legitimate complaints or inquiries.
92. The Plaintiffs state that the anonymous nature of the Letters reveals the
malicious and sneaky mindset of the Defendants and their knowledge that they
were not making genuine complaints.
93. The Plaintiffs state that none of the Defendants ever contacted the
Plaintiffs, or any of them, for an explanation or response to the questions posed
in the Letters and the Statements, and that this omission is a sign of bad faith
and malice.
94. The Plaintiffs state that, by organizing approximately 200 co-signers to
the Letters, the Defendants were not actually interested in a formal complaint,
put discreetly and properly to the Party's appropriate committee, but rather
were interested in drumming up a public scandal and circulating the rumours
-30contained in the Letters as widely as possible, including to people who had no

business receiving them.
95. The Letters and the Statements contain exhortations to all recipients of
the Letters to forward and republish the Letters to others indiscriminately, and
this is an act of malice.
96. The Plaintiffs also claim that the Letters and Statements imputed
dishonourable motives to the Plaintiffs, and this is an act of malice.
97. Cooper states that the Letters and the Statements were particularly
damaging to him, as he is a National Councilor of the Party whose reputation
in the Party, the news media, at university and in the community at large, was
severely damaged by accusations of corruption and other malfeasance and
improper or illegal conduct.
98. Levant states that the Letters and the Statements were particularly
damaging to him, as he is a lawyer whose reputation with his firm, colleagues,
judges, clients and potential clients and the Law Society of Alberta was severely
damaged by accusations of corruption and other malfeasance and improper or
illegal conduct.
99. Levant further states that the Letters and the Statements were
particularly damaging to him, as he is a newspaper columnist and author
whose public reputation in the community at large, with the newspapers that
publish him, with his readers and with book-buyers was severely damaged by
accusations of corruption and other malfeasance and improper or illegal
conduct.
100. Levant further states that the Letters and the Statements were
particularly damaging to him, as he is a political organizer and was a director
of the Riding whose public reputation in the voting public at large, with the
Riding, with others within the Party and with the news media was severely
-31 damaged by accusations of corruption, other malfeasance and improper or

illegal conduct.
101. Dr. Levant states that the Letters and the Statements were particularly
damaging to him, as he is a prominent medical doctor whose public reputation
amongst other doctors, medical staff, current and prospective patients, health
administrators and the College of Physicians and Surgeons of Alberta, the news
media and the public at large was severely damaged by accusations of
corruption, other malfeasance and improper or illegal conduct.
102. McKinsley states that the Letters and the Statements were particularly
damaging to him, as he is a political organizer and pollster, whose public
reputation in the news media, the business community, the voting public at
large, with the Riding and with others within the Party, and with other current
and potential clients, including the Party, was severely damaged by
accusations of corruption, other malfeasance and improper or illegal conduct.
103. In the opinion of the Plaintiffs, this action will take more than 25 days to
try. The Plaintiffs propose that the trial of this action be held at the Court {/
House, in the City of Calgary, in the Province of Alberta.
104. WHEREFORE THE PLAINTIFFS EACH CLAIM AGAINST THE
DEFENDANTS JOINTLY AND SEVERALLY:
a.
general damages in the amount of $1,000,000.00;
b. punitive, aggravated and exemplary damages in the amount of

$450,000.00;
c. interest on any amounts awarded in accordance with the Judgment
Interest Act, RSA 2000, c. J-l;
d. costs of this action on a solicitor and own client basis or on such
other basis as this Honourable Court may determine; '
-32-
e. an interim and permanent injunction against the Defendants,

enjoining them from continuing to defame the Plaintiffs; and
f. such further or other relief as this Honourable Court deems just.
DATED at the City of Calgary, in the Province of Alberta, this 19* day of June,
2003, AND DELIVERED by C. David Ryan, Solicitor for the Plaintiffs, whose
address for service at 2380, Ernst & Young Tower, 440 - 2nd Avenue S.W.,
Calgary, Alberta, T2P 5E9.
ISSUED out of the Office of the Clerk of the Court of Queen's Bench of Alberta,
Judicial Centre of Calgary, this 19* day of June, 2003.
EAlrl A "hecwUr n*
LetHTr
COMPLAINT
&
REQUEST FOR
I N V E S T I G AT I O N A N D
CONSEQUENTIAL ACTION
December 17,2002
Canadian Alliance Party
National Council Secretariat
Dear Members,
We thank you for taking the time to consider this material and recommending such
follow-up action as you deem appropriate.
We believe your decision in this matter is vital to the long-term survival of this party. You
can either unequivocally affirm that the Reform party's bedrock commitment to honesty,
integrity and "doing politics differently" survived the evolutionary process that gave birth
to the Canadian Alliance party, or not. We believe those fundamental values should be at
the core of what the Canadian Alliance party stands for.
If basic concepts of "right" and "wrong" are to have any currency in this party then
members must be assured that suspected "wrongful" conduct will be investigated. Most
importantly, members need to be confident that where misconduct is proven, after
appropriate investigation, those responsible will be held accountable.
We, the undersigned members, believe an immediate investigation into recent activities in
Calgary Southwest is required. Regrettably, based on the incomplete but alarming
disclosures that have been made to date, it appears that a significant number of party
members may have flagrantly disregarded appropriate standards of conduct in Calgary
Southwest since November 21, 2001. Because the Calgary Southwest board has solicited
funds throughout the province and across the country the conduct of this board has
affected members all over Alberta and from coast to coast. Calgary Southwest was a
premier riding but since November, 2001 it has been run into the ground and is now
broke and in debt.
The scope of the possible misconduct referenced within, extends to the campaign and
subsequent election of the self-styled "PAL" slate of Alberta councilors to National
Council. Just as the election of the current board in Calgary Southwest was tainted by
misconduct so too may have been the election of Alberta's three councilors.
- 2 -
Specifically, the possible misconduct suggested by the partial evidence currently

available and requiring immediate investigation by the Secretariat includes the following:
Questionable Fundraising Solicitations
On December 3, 2001, when the Calgary Southwest Constituency Association had
assets of $89,534 available, a fundraising solicitation was directed to party members
throughout Calgary inducing members to donate by asserting that the Calgary
Southwest constituency had no funds. Members were specifically asked to contribute
towards constituency by-election expenses. Questions have arisen as to where the
$30,000 reportedly raised at the subsequent December 12th event were deposited.
Were the funds deposited to the constituency association account or were those
member donations deposited to an "In Trust" account not in the control of the
constituency association?
On January 5, 2002 the constituency association solicited funds from other ridings
assuring them that Calgary Southwest had enough money for the writ portion of the
by-election campaign. But when the by-election was called the money had all been
spent and we've been told that no money at all was contributed bv the constituency
association to the Leaders by-election campaign. Was there flagrantly irresponsible
spending engaged in by the directors and if so, to what end?
A March 10, 2002 mailer asked members to send a tax-deductible donation but then
urged members on the payment form to take a "business expense" tax receipt rather
than a political donation receipt. Is it appropriate to engage in that kind of fundraising
practice and isn't that similar to the kind of Liberal party fundraising that this party
has questioned in the House of Commons?
Questionable Representations to National Office
When the Calgary Southwest Constituency Association approached the party in April
for a loan representations were allegedly made that there were creditors pressing the
riding association for payment of by-election campaign expenses. Examination of the
Southwest Alliance Campaign Fund accounts suggests that the expenses were not
constituency by-election expenses, to what extent has the party been asked to fund
debts that are not its responsibility ?
Questionable Use of Constituency Funds and Resources
The "PAL" letter, distributed throughout the province to secure the election to
National Council of three candidates may have been funded using Calgary Southwest
constituency funds. The same Canada Post account was used both for alleged
constituency expenses and for the "PAL" mailer. Since photocopying expenses paid
for by the constituency association are not identified, or in any way broken down, the
Southwest Alliance Campaign Fund may also have been used to cover that portion of
- 3 -
the "PAL" letter costs as well. Additionally, it certainly appears that the predictive
dialer and the color printer, the purchase of which the constituency contributed to,
was used to craft the "PAL" letter and broadcast messages on their behalf. Were
Calgary Southwest constituency funds used to fund the "PA1" campaign ?
It appears that membership funds may have been solicited and retroactively used to
finance the takeover of the Calgary Southwest Constituency Association in
November 2001. At a Calgary Southwest Director's meeting on May 15, 2002 it was
disclosed that an " In Trust" account was used to finance an individual's hostile
takeover of the board at the November 21, 2001, AGM and that the same account
was used to finance that same individual's subsequent candidate selection. Numerous
fundraising solicitations for donations to that "In Trust" account were paid for by the
Calgary Southwest Constituency Association. Did an individual in Calgary
Southwest attempt to recoup board takeover expenses from party member donations
secured after the November 21,2001 AGM?
Records of the Southwest Alliance Campaign Fund disclose that one "PAL"
candidate, not even resident in the riding, accepted direct payment of $500.00 from
the Calgary Southwest Constituency Association. Members want to know why that
payment was made? Was that payment was made to fund the individual's required
candidacy deposit.
1 Some $18,000, more or less, in direct payments were made to other individuals, also
from constituency association funds. Many of those direct payments are described in
the records of the Southwest Alliance Campaign Fund as payments made for
"fundraising", however, no corresponding fundraising deposits to the constituency
association are immediately identifiable. If constituency association funds were used
to pay "commissions" to raise funds, all of the funds so raised belong to the
constituency association. Why were "commissions" paid? What fundraising was
done for those "commissions"? Where was the money that was raised deposited into the Calgary Southwest Constituency Association, the Southwest Alliance
Campaign Fund or the "In Trust" account?
The unopposed default candidate for Calgary Southwest received direct payment
from constituency funds and may have been reimbursed twice for his nomination fee
of $2,000. On November 22, 2001 the board unanimously agreed to impose a $2,000
non-refundable registration fee for candidates. On February 27th a cheque for $2,000
described as a "candidate honorarium" was issued and on May 15th, 2002 a motion
was passed and carried by the board to again provide a $2,000 payment using
constituency funds. Did the constituency association actually provide $4,000 to the
default candidate?
Questionable Accounting for Constituency Donations
It appears that bulk of all membership donations solicited between December, 2001
and May, 2002 requested that payments be made to an "In Trust" account that was
- 4 -
beyond the control of the constituency association. None of those funds have been
accounted for in the Southwest Alliance Campaign Fund records. The constituency
association paid for some or all of the mail solicitations that went out during that
time. In those mailers, members were asked to make donations payable to the "In
Trusfaccount. The fact that the constituency association funded those mailers, in our
view, entitles the party to full disclosure of all funds so received. What funds were
received and where were they deposited?
It is believed that cash donations were received at numerous public meetings that
were fully or partially funded by the constituency association however there is no
record of those funds being deposited to the constituency association account. What
record keeping did the constituency association do in regards to cash donations?
Where did those funds go?
Constituency funds may have been advanced and placed under the control of a
possible candidate prior to his election as candidate. The Southwest Alliance
Campaign Fund was apparently established before the candidate selection meeting.
Did the default candidate or his close friends and advisors have access to that account
prior to the candidate selection meeting?
It appears that constituency funds were used to construct and advertise the default
candidate's website (refer to March 10 mailer and March 2002 mailer) and that
website was then used to solicit donations to an "In Trust" account rather than to the
party. The Southwest Alliance Campaign Fund records disclose payments on
February 27, 2002 of $500.00 and a subsequent payment of $1,000 in that regard.
What donations were received by the "In Trust" account from the web page and has
the constituency ever been compensated for the expenses associated with the web
page construction?
Abuse of Membership Lists
A candidate was mailing solicitations to members as early as December 3, 2001, long
before that candidate became the default candidate in Calgary Southwest and
consequently long before that candidate was entitled to a copy of the membership list
(the Minutes of December 10, 2001 show that the candidate was not interviewed until
December 10, 2001 and only then was consequently entitled to the membership lists).
How did that individual obtain access to Calgary Southwest membership lists ? Is that
individual continuing to contact Calgary Southwest members to promote fundraising
unrelated to the constituency?
Questionable Elections Act Practices
Before the Calgary Southwest by-election was called mailers were sent out that
appear to have been paid for with constituency funds that described a friend of the
- 5 -
candidate as his Official Agent. Questions have been asked as to whether or not that
is appropriate. Has there been any breach of Election Act requirements?
Questionable Constitutional Conduct
Decisions were made this past year by the Calgary Southwest board to conduct
unconstitutional candidate selection meetings. Why was it necessary for National
Office to intercede to ensure compliance by the Calgary Southwest directors of the
party constitution?
The Minutes of meetings have been prepared without referencing who moved or
seconded motions, no executive minutes have been produced, responsible
constituency management appears to have been ignored. From December to April
not a single report was made at a directors meeting as to constituency finances.
When the Financial Statements for the so-called Southwest Alliance Campaign Fund
were presented to the board it wasn't the Treasurer who offered an explanation for
the accounts it was the default candidate who had to explain the existence of three
separate accounts. Members are asking what standards are expected of directors and
whether or not directors in Calgary Southwest have breached their fiduciary duty to
members particularly when the irresponsible spending that has taken place is
factored in. If the directors themselves were relying on the advice of the board
Executive have those executive officers breached their fiduciary duty to members?
$50,000.00 Unaccounted For
At the December 17th, 2001 Board of Director's Meeting a motion was passed to
move $50,000 of the liquid assets of the constituency to an unidentified lawyers' trust
account. What happened to those funds?
Questionable Tax Receipt Instructions to Members
Donors have been urged to contribute to an "In Trust" account for "business expense"
tax receipts rather than being asked to contribute in a fashion that would entitle them
to "political contribution" tax receipt, but which would result in National Office
receiving 20%. Is this appropriate?
Questionable Conduct Surrounding Constituency Property

It appears that property paid for using constituency association funds are not in the
control of the constituency association. The candidate stated in mailers that funds
donated by members were to have been used for lawn signs, brochures,
-6-
advertisements, and other by-election campaign expenses. The Southwest Alliance

Campaign Fund Financial Statements establish that those lawn signs, brochures and
advertisements were paid for by the constituency association. Where has that
property gone?
Questionable Conduct Relative To Apparent Conflicts Of Interest
Individuals with a clear personal/corporate financial interest have entered into
contracts and arrangements with the constituency association and have thereby
secured personal benefit for themselves or business benefit for their corporate
entities. One individual was given control of Southwest Alliance Campaign Fund
spending and he was also the recipient of approximately $40,000 in direct payments
to himself or his corporation. What were the funds used for? Why was this individual
allowed to receive such a benefit? What interest in the property does the constituency
association have in return for the $40,000?
Undocumented Payments Made
Thousands of dollars have been paid to one particular individual with no indication
as to what the expenditures were for. What was the moneyused for and where are the
receipts or invoices to substantiate those payments?
Questionable Attribution of Expenses
Numerous accounts have been maintained by a very close group of individuals and
that has enabled that small group to selectively attribute expenses such that
consumables have been run through the constituency association but durables have
been paid for from an " In Trust" account. Why was this allowed to happen and is it a
breach of director's duty to the members to allow such questionable business
practices? Why did directors not protect the members interests? Why did the default
candidate not protect the members interests in this regard?
Questionable Refusal bv Board to Pay Creditors
The board selectively neglected to pay two outstanding creditors. Have the actions of
the board brought the party into disrepute?
As a consequence of the questioned activities outlined above, the undersigned members
are asking the Secretariat to do the following immediately:
1. Launch an investigation into what has taken place in the Calgary Southwest
Constituency from November 21, 2001 to the present, using such internal resources,
external investigative agencies and professional associations or societies as necessary
to ascertain all relevant facts. The investigation should include examination and audit
of all the Calgary Southwest Constituency Association's financial accounts and all
other as yet undisclosed accounts directly or indirectly related to the by-election
- 7 -
Z^lSlEST"* iDClUdin8 * ***** **- Campaign Flmd
E2E Z^t^S rs S n4 orough tavesti^ *
deem it to be appropriate: S' lf the Secretanat and National Council
3 " S LT * " " " ^ ^ S - 3 W W o f - P ^ c o n s t i t u t i o n a s
- 22 SStbmitted ^ *- """" Wh *~ < * county
"^
Ration
and
Consequential A.^ m me attachedPomplamt ft Revest Fnr fa^^w-,, ^
JSi yazrcs jets*. 2M2,r
executive office nositinn* ,- h.v * t. do currently hold

Members fromthmZiZ r*Z "^ U ">**** boards.
Southwest,
Ca,gary
^C^^^**"^0*-*
Calgary Southeast, Madeod! WiloTe^^^^
C-^^ZTS^^TS d,S^bUti0n- Membe" signing the

~
,
strict
coPn=fe
^
S^
~^^
- 8 -
conduct was being investigated - these are people with a track record of
belligerent and bullying behaviour.
Every member of this party who cares about political decency and
honesty should immediately contact the Leader's Office (Attention
Stephen Harper - Phone (403) 253-7990, the Executive Director
(Attention Terry Horkoff - Phone (403) 269-1990) the National Council
Secretariat (Attention Jerry Rice - email to:
jerry.rice@canadianalliance.ca) or the Calgary Southwest Constituency
Association (Attention the President - Mr. John Flynn Email to:
calgarysw@aol.com) to demand to know what has been done to
address the very serious questions raised in this complaint.
The people implicated in this Complaint continue to seek control of
other ridings. It is not fair to those ridings or to party members to leave
these important questions unanswered.
The party has responsibility to its members to perform and conclude
this investigation and publicly exonerate those that have been
implicated if they have done nothing wrong or appropriately sanction
those that have engaged in misconduct.
Democracy works best under the light of truth and fails miserably when
cloaked in the darkness of secrecy. Members are being asked to perform
an essential democratic task and they cannot do that if the party
withholds vital information.
We all know from bitter experience that the failure of any one riding to
diligently accept their responsibility to carefully examine potential
candidates can do immeasurable harm to every other riding. Every
Canadian Alliance member who receives this e-mail has a duty to
demand that the party not shirk from its duty.
B4lt a "^.w 2fL 14

January 24,2003
Canadian Alliance
300,717-7th Avenue SW
Calgary, Alberta T2P 0Z3
ATTENTION: Mr. C. TERRY HORKOFF, EXECUTIVE DIRECTOR
RE: COMPLAINT AND RFOf fEST FPU mvnmnAT, , ^ rnrnroUENTAIT. apt,
Dear Sir,
S o u t h w e s t c o n s t i t u e n c y, s i n c e N o v e m b e r 2 1 , 2 0 0 1 . g ^
2001 have a well-known track record ZiSwL if .g^ Southwest since November,
ôr ^signatories,
t h a tbet hkepte ini strict
T ^ confidence.
S ^ ^ It has been verv rfS^ * organizers
.
the reputation of those who are to be the mtofZ^ 7 * eUre s,enatures. given
only on condition that confid7ntoS^^^T^^"" ""* ""*" **
representation
^ ^ d ^ J Z Z T ^ S ^ ^ ^ T ^ 1 0 ^ ^ 0 11 ^
fashion is that the Calgary Southwest Constituency Association is controlled by the very people
who must answer for the conduct complained of. Since it appears that the Constituency
Association cannot be relied upon to defend the rights of members, we the concerned members
must do so.
Thank you for your attention in this matter. In the event that you require any additional
information or representations please advise when members of our group contact you to follow
up.
it******************************
Attachments Included:
Complaint and Request For Investigation and Consequential Action and party member
signatures.
Southwest Alliance Campaign Fund Financial Statements - January 17,2002 to April 30,
2002 (including cheques)
Minutes of Board of Directors Meetings, November 22,2001 - August 8,2002
Previous Board's Financial Statements showing $89,534.07 was provided to the new board.
December 3,2001 - Re: Calgary Roundup Centre
December 5,2001 - Re: December 19th
January 5,2002 - Request to all Constituencies for funds
March 10,2002 - "business expense" donation to Ezra Levant-in Trust or lose 20% if to
Canadian Alliance-Calgary Southwest - Canada Post 7023157
March 22,2002 - Community Events
Brochure #2
PAL Letter - Canada Post 7023157
MEMBER ADVISORY
GROSS MISCONDUCT IN CALGARY SOUTHWEST
SUSPECTED!
I M M E D I AT E
MEMBERSHIPS
OF
ANY
ACTION
REPONSIBLE
REQUIRED
SHOULD
BE
REVOKED
May, 2003
Canadian Alliance Friends,
About fifteen years ago, tens of thousands of us were attracted to the Reform/Alliance party by
the honesty and integrity of one man, Preston Manning. The founder of the Reform/Alliance
movement believed that politicians must tell the truth, even when it hurts. That rock-solid
adherence to the "truth" made membership in the Reform/Alliance party something to be proud
of.
Regrettably, since Mr. Manning transferred the care and trust of this party to others, the core
values of honesty and integrity have been constantly threatened. Just as the PC party imploded
when it turned its back on its members, so too is the Canadian Alliance party in danger of
driving out the very people who nurtured its growth. The decent men and women who came to
the party to "do politics differently" are being ignored. Rather than enforcing our own
constitutionally enshrined rules for proper conduct this party is increasingly toiling a blind eye
to corruption in our own ranks and never more blatantly than in Calgary Southwest.
Please read the attached Complaint and Request for Investigation and Consequential
Action - signed by more than 150 party members - exposing questionable conduct that no
honest party member could tolerate if proven. The Compliant was forwarded to the Executive
Director of the party for delivery to the National Council Secretariat in January, 2003. Until now
the concerned members who uncovered this scandal have relied on the party to act but
unfortunately the party has erected a wall of silence. Rather than investigate the substantial
concerns contained in the Complaint the party has ignored the concerns and apparently seems
determined to shelve the Complaint. Now it's time for the members to act! The party can only
get away with what members allow them to - LET'S NOT LET THE PARTY ABANDON
HONESTY AND INTEGRITY!
Here are some shocking allegations that you haven't been informed of - because the party
apparently wants to hide the truth from it's own members:
The Calgary Southwest Constituency Association contributed no money to the
leader's May, 2002, by-election campaign - despite having been entrusted with
almost $90,000 only four months earlier? The Constituency Association threw away
$90,000 !
The Calgary Southwest Constituency Association allowed members in the riding
and throughout Calgary to be deceived into believing that the election war chest was
empty when it in fact had $90,000.
-2-
One individual was allowed to siphon out donations from members in Calgary
Southwest and across the country from November, 2001 on without those donations
ever being turned over to the party or to the constituency association.
Money from members in Calgary Southwest appear to have been used to finance
nothing but consumable expenditures, leaving the Constituency Association with
nothing to show for having spent tens of thousands of dollars, while durables were
purchased from another account to the personal benefit of the people controlling the
money.
Money donated by honest Reform/Alliance members over the years, intended to
fight the Liberals may have been misappropriated to offset the expenses of just one
member who chose to conduct a hostile takeover of the Calgary Southwest board in
November, 2001.
Constituency money was handed over to individuals who ignored accepted conflict
of interest guidelines and beneficially contracted with "themselves" - sucking your
hard earned money into their pockets ?
The very same people who are implicated in the possible wrongdoing outlined above are now
trying to take over in Calgary Centre. Because the party has failed to investigate Calgary Centre
could end up with a candidate the opposition will easily discredit using the very information our
own party has ignored. It's time for all honest members of this party to demand that the party
investigate these allegations. The party has the authority to secure production of records that will
prove the allegations or exonerate those that have been implicated.
The party has a duty to act and to serve its members. Here's what you can do:
1. Contact the Calgary Southwest Constituency Association President, Mr. John Flynn,
(email to: calgarysw@aol.com) and demand to know what is being done by the
Southwest Board to investigate this Complaint
2. Contact the Leader's Office (phone: (403) 253-7990) and ask Stephen Harper why he's
not protecting the members of this party to make sure they're treated honestly.
3. Contact the Executive Director of the Party (phone: (403) 269-1990) and ask Terry
Horkoff why National Office hasn't done anything to obtain answers to the Complaint.
4. Contact the National Council, Secretariat (Attention Jerry Rice - email to:
jerry.rice@canadianalliance.ca) and tell them in no uncertain terms that the proud
members of this party want to preserve core values of- honesty and integrity !
5. Forward e-mail copies of this Advisory and the Compliant to all your Alliance friends, to
other constituency board directors and to MP's and print off copies to give to members
without computers.
PLEASE ACT NOW!
DON'T LET THIS PARTY BECOME A CORRUPT IMITATION OF THE LIBERALS!
January 24,2003
Canadian Alliance
300,717-7th Avenue SW
RE; COMPLAINT AND REQUEST FOR INVESTIGATION AND CONSEOUENTAIL ACTION
Dear Sir,.
As you know, the Leader has been made aware of very significant concerns that many concerned
Canadian Alliance party members have regarding the conduct of matters in the Calgary
Southwest constituency, since November 21,2001.
Concerned members have been told that the appropriate constitutional procedure to initiate a
thorough investigation into this matter is by way of a Formal Complaint forwarded under the
signature of those members. In compliance with that request, enclosed please find the above
mentioned "Compliant and Request For Investigation and Consequential Action" which has been
signed by dozens of Canadian Alliance members in numerous ridings in and outside of Calgary
Southwest. We would urge you to look carefully at the names of the long standing, committed
party members who are asking the Secretariat to take this very significant step. All are dedicated
party members who want this party to continue to stand for the principles of integrity and
honesty that brought us to the party in the first place. Many have served or are currently serving
in significant party roles. All have given their time and energy to the growth of this party and
will not stand idly by as others bring it down. Members are continuing to ask for the opportunity
to sign this Complaint however we feel compelled to put this into the hands of the Secretariat as
soon as possible. Accordingly, as additional member signatures are collected we will forward
them to your attention.
This document is being provided to you for delivery to the National Council Secretariat. As you
well know, certain of the individuals who have controlled Calgary Southwest since November,
2001 have a well-known track record for litigiousness. For that reason we are expressly
requesting that the names of all individuals associated with this Complaint, either as organizers
or signatories, be kept in strict confidence. It has been very difficult to secure signatures, given
the reputation of those who are to be the subject of the investigation, and many members signed
only on condition that confidentiality would be maintained.
In the event that the Complaint is responded to by way of litigation we are also expressly asking
that the party provide to all participants on this Complaint the same level of support for legal
representation that would be extended to any Director acting in the course of constituency
business. The only reason that it has been necessary for this Complaint to come forward in this
must do so.
up.
********************************
signatures.
Minutes of Board of Directors Meetings, November 22,2001 - August 8,2002
December 3,2001 - Re: Calgary Roundup Centre
Brochure #2
COMPLAINT
&
REQUEST FOR
December 17, 2002

Dear Members,
SSL^"*
T fraction
takiDg **
t0 Consider
te materi*> and
recommending such
such
follow-up
astime
you
deem appropriate.
recommencing
We believe your decision in this matter is vital to the long-term survival of this oartv You
The scope of the possible misconduct referenced within extend tn a* .

subsequent election of the self-styled >VA17JT^L^1 * camPMSn **
2 -
Specifically, the Possib3e_misconduct suggested by the partial evidence currently

association to the Leaders bv-election campaign. Was there flagrantly irresponsible
- 3 -
dialer and the color printer, the purchase of which the constituency contributed to,
secured after the November 21,2001 AGM?
candidacy deposit.
Some $18,000, more or less, in direct payments were made to other individuals, also
to pay "commissions" to raise funds, all of the funds so raised belong to the
constituency association. Why were "cornmissions" paid? What fundraising was
default candidate?
- 4 -
beyond the control of the constituency association. None of those funds have been
accounted for in the Southwest Alliance Campaign Fund records. The constituency
association paid for some or all of the mail solicitations that went out during that
time. In those mailers, members were asked to make donations payable to the "In
Trusfaccount. The fact that the constituency association funded those mailers, in our
view, entitles the party to full disclosure of all funds so received. What funds were
received and where were they deposited?
It is believed that cash donations were received at numerous public meetings that
were fully or partially funded by the constituency association however there is no
record of those funds being deposited to the constituency association account. What
record keeping did the constituency association do in regards to cash donations?
Where did those funds go?
Constituency funds may have been advanced and placed under the control of a
possible candidate prior to his election as candidate. The Southwest Alliance
Campaign Fund was apparently established before the candidate selection meeting.
Did the default candidate or his close friends and advisors have access to that account
prior to the candidate selection meeting?
It appears that constituency funds were used to construct and advertise the default
candidate's website (refer to March 10 mailer and March 2002 mailer) and that
website was then used to solicit donations to an "In Trust" account rather than to the
party. The Southwest Alliance Campaign Fund records disclose payments on
February 27, 2002 of $500.00 and a subsequent payment of $1,000 in that regard.
What donations were received by the "In Trust" account from the web page and has
the constituency ever been compensated for the expenses associated with the web
page construction?
Abuse of Membership Lists
A candidate was mailing solicitations to members as early as December 3, 2001, long
before that candidate became the default candidate in Calgary Southwest and
consequently long before that candidate was entitled to a copy of the membership list
(the Minutes of December 10,2001 show that the candidate was not interviewed until
December 10, 2001 and only then was consequently entitled to the membership lists).
How did that individual obtain access to Calgary Southwest membership lists ? Is that
individual continuing to contact Calgary Southwest members to promote fundraising
unrelated to the constituency?
Questionable Elections Act Practices
Before the Calgary Southwest by-election was called mailers were sent out that
appear to have been paid for with constituency funds that described a friend of the
- 5 -
Questionable cw^,^^ r |m {
Office to mtercedeTeTurLr^T8* ^ WaS * ""^ for Nati<'

party constitution? ""Prance by me Calgary Southwest directors of the
' *^l^Zl7Zrr*1; "*"* Wh êd or

consnmencymanagemLrellr K ^ been prduCed> sponsible
not a single reportf wTmade af a h^T ^0W4 Frffl December to AP*1

When
JLuLl
j
for
mêdûttS,
A.^"^
^
were presented to the board it w^srft the Tr.!c SUthwe ^^ Campaign Fund
the accounts it was the defeuk Zdl^ ^ f Wh ffered exPôn for
separate accounts Membet^tl ^ had t0 eXplain * existe><* of three
whether or XST^sS^ fT^ " eXpeCted f *** ">
Behave ttsisr^^^-îir
$50.000.00 Unaccounted go-
^5^^^^"--" ** a motion was passed to

account What happenX *0Se"f2S "^t0 *" ^^ IaW^s' ^
.Questionable Tar Receinf w^... tff Mr ,
Donors have been urged to contribute to an "In Trust" account f k
tax receipts rather than heme asked fn LiT\ account for business expense"
to "poHtical contribu&n^L Ocelot ^ v ? ' ^ **WOuId entitle *
receivmg20%.IsthirapproSaterrt "*"* W0UM reSU,t m National OiBce
Questionable Conduct SnmmM.r ^---tituen-v p,^
donated by members werfto C fcent'edifTT * nta * *-d

oeen used for lawn signs, brochures,
- 6 -

property gone?
as to what the expenditures were for. What was the money used for and where are the
- 7 -
campaign in Calgary Southwest, including the Southwest Alliance Campaign Fund

and the "In Trust" account.
The undersigned members also ask that following a full and thorough investigation due
consideration be given to the following, as and if the Secretariat and National Council
deem it to be appropriate:
2. Diligently pursue all criminal or civil remedies that may be available to secure
recovery of all assets which may have been misappropriated or diverted from the
membership, including civil judgements against responsible individuals or directors.
3. Impose sanctions in accordance with s. 3 (d) (iii) of the party constitution as
necessary.
All of which is respectfully submitted by those members who have signed in counterpart
on the attached signature lists.
***************************
We the undersigned members support the request for an immediate investigation and
follow up action as outlined in the attached Complaint & Request For Investigation And
Consequential Action.
NOTE: In the space of only 38 days, between December 17, 2002 and
January 24, 2003 more than 150 dedicated Canadian Alliance members,
committed to political honesty and integrity put this Complaint
together. Hundreds more would have signed but it was essential that the
Complaint be forwarded to the Secretariat for investigation as quickly
as possible.
Members who prepared and signed the petition include long-standing
party volunteers and loyalists and many past and current riding
presidents along with members who have held or do currently hold
executive office positions or directorships on constituency boards.
Members from the following ridings signed the Complaint: Calgary
Southwest, Calgary Centre, Calgary North East, Calgary Nose Hill,
Calgary Southeast, Macleod, Wildrose, Edmonton Strathcona.
The names and signatures of the members who signed that document
have been removed from this email distribution. Members signing the
Complaint were promised that the party would be asked to keep all
names in strict confidence to avoid retaliation from the people whose
- 8 -
belligerent and bullying behaviour.
honesty should immediately contact the Leader's Office (Attention
Stephen Harper - Phone (403) 253-7990, the Executive Director
(Attention Terry Horkoff - Phone (403) 269-1990) the National Council
Secretariat (Attention Jerry Rice - email to:
jerry.rice@canadianalliance.ca) or the Calgary Southwest Constituency
Association (Attention the President - Mr. John Flynn Email to:
calgarysw@aol.com) to demand to know what has been done to
address the very serious questions raised in this complaint.
other ridings. It is not fair to those ridings or to party members to leave
these important questions unanswered.
this investigation and publicly exonerate those that have been
ix
MEMBER ADVISORY
GROSS MISCONDUCT IN CALGARY SOUTHWEST
S U S P E C T E D . . . S A M E G R O U P N O W TA R G E T I N G
CALGARY CENTRE ! WHO'S NEXT?
I M M E D I AT E
MEMBERSHIPS
OF
ACTION
REQUIRED
ANY
RESPONSIBLE
FOR
SHOULD
BE
REVOKED
MISCONDUCT
May 2003
Canadian Alliance Friends,
About fifteen years ago, tens of thousands of us were attracted to the Reform/Alliance party by the honesty and
integrity of one man, Preston Manning. The founder of the Reform/Alliance movement believed that politicians
must tell the truth, even when it hurts. That rock-solid adherence to the "truth" made membership in the
Reform/Alliance party something to be proud of.
Regrettably, since Mr. Manning transferred the care and trust of this party to others, the core values of honesty
and integrity have been constantly threatened. Just as the PC party imploded when it turned its back on its
members, so too, is the Canadian Alliance party in danger of driving out the very people who nurtured its
growth. The decent men and women who came to the party to "do politics differently" are being ignored. Rather
than enforcing our own constitutionally enshrined rules for proper conduct this party is increasingly turning a
blind eye to corruption in our own ranks, and never more blatantly than in Calgary Southwest. The problem is
now spilling over into other ridings - and the problem will continue to grow, like a cancer, until members put a
stop to it!
Please read the attached Complaint and Request for Investigation and Consequential Action - signed by
nearly 200 party members - exposing questionable conduct that no honest party member could tolerate if
proven. The Complaint was forwarded to the Executive Director of the party for delivery to the National
Council, Secretariat in January 2003. Until now, the concerned members who uncovered this scandal have
relied on the party to act, but unfortunately, the party has erected a wall of silence. Rather than investigate the
substantial concerns contained in the Complaint the party has ignored the concerns and apparently seems
determined to shelve the Complaint. Now it's time for the members to act! The party can only get away with
what members allow them to - LET'S NOT LET THE PARTY ABANDON HONESTY AND
INTEGRITY!
~~
Here are some shocking allegations you haven't been informed of - because the party apparently wants to
hide the truth from its own members:
The Calgary Southwest Constituency Association contributed no money to the leader's May 2002,
by-election campaign - despite having been entrusted with almost $90,000 only four months
earlier? The Constituency Association threw away $90,000 !
The Calgary Southwest Constituency Association allowed members in the riding and throughout
Calgary to be deceived into believing that the election war chest was empty, when it in fact had
$90,000 - more than enough to fight any election campaign.
- 2 -
One individual was allowed to siphon out donations from members in Calgary Southwest and
across the country from November 2001 on, without those donations ever being turned over to the
party or to the constituency association.
Money from members in Calgary Southwest appears to have been used to finance nothing but
consumable expenditures, leaving the Constituency Association with nothing to show for having
spent tens of thousands of dollars, while durables were purchased from another account to the
personal benefit of the people controlling the money.
Money donated by honest Reform/Alliance members over the years, intended to fight the Liberals
may have been misappropriated to offset the expenses of just one member who chose to conduct a
hostile takeover of the Calgary Southwest board in November, 2001.
Constituency money was handed over to individuals who ignored accepted conflict of interest
guidelines and beneficially contracted with "themselves" - sucking your hard earned money into
their pockets ?
The SCARY thing is - the very same people implicated in the possible wrongdoing outlined above are now
trying to take over in Calgary Centre. If members don't stop this, the $100,000 + raised by hard working
volunteers in Calgary Centre could go up in smoke, just as it did in Calgary Southwest. And it won't stop there
- more and more ridings will become future targets ! When the next election comes, because the party has failed
to investigate, Calgary Centre and other ridings could be saddled with candidates the opposition might easily
discredit using the very information our own party has ignored. It's time for all honest members of this party to
demand that the party investigate these allegations. The party has the authority to secure production of records
that will prove the allegations or exonerate those that have been implicated.
The party has a duty to act and to serve its members. Here's what you can do:
1. Contact the Calgary Southwest Constituency Association President, Mr. John Flynn, (email to:
calgarysw@aol.com) or the Calgary Centre Constituency Association President, Mr. Gus Barron (email
to: gusbarron@zwallet.com / phone: (403) 230-8616) and demand to know what is being done to
investigate this Complaint. Copy your emails to National Office (email to: info@canadianalliance.ca)
so they have a record of your concerns/
2. Contact the Leader's Office (email to: harper@canadianaltiance.ca / phone: (403) 253-7990) and ask
Stephen Harper why he's not protecting the members of this party to make sure they're treated honestly.
3. Contact the Executive Director of the Party (email to: terry.h@canadianalliance.ca / phone: (403)
269-1990) and ask Terry Horkoff why National Office hasn't done anything to obtain answers to the
Complaint.
jerry.rice@canadianalliance.ca) and tell them in no uncertain terms that the proud members of this
party want to preserve core values of- honesty and integrity !
5. Forward e-mail copies of this Advisory, Covering letter and Complaint to all your Alliance friends, to
other constituency board directors, to National Councilors and to MP's - and print off copies to give to
members without computers.
PLEASE ACT NOW!
DON'T LET THIS PARTY BECOME A CORRUPT IMITATION OF THE LIBERALS!
January 24, 2003

Canadian Alliance
300, 717-7th Avenue SW
RE: COMPLAINT AND REQUEST FOR INVESTIGATION AND CONSEOUENTABL ACTION
Dear Sir,
As you know, the Leader has been made aware of very significant concerns that many concerned
Canadian Alliance party members have regarding the conduct of matters in the Calgary
Southwest constituency, since November 21,2001.
Concerned members have been told that the appropriate constitutional procedure to initiate a
thorough investigation into this matter is by way of a Formal Complaint forwarded under the
signature of those members. In compliance with that request, enclosed please find the above
mentioned "Compliant and Request For Investigation and Consequential Action" which has been
signed by dozens of Canadian Alliance members in numerous ridings in and outside of Calgary
Southwest. We would urge you to look carefully at the names of the long standing, committed
party members who are asking the Secretariat to take this very significant step. All are dedicated
party members who want this party to continue to stand for the principles of integrity and
honesty that brought us to the party in the first place. Many have served or are currently serving
in significant party roles. All have given their time and energy to the growth of this party and
will not stand idly by as others bring it down. Members are continuing to ask for the opportunity
to sign this Complaint however we feel compelled to put this into the hands of the Secretariat as
soon as possible. Accordingly, as additional member signatures are collected we will forward
them to your attention.
This document is being provided to you for delivery to the National Council Secretariat. As you
well know, certain of the individuals who have controlled Calgary Southwest since November,
2001 have a well-known track record for Iitigiousness. For that reason we are expressly
requesting that the names of all individuals associated with this Complaint, either as organizers
or signatories, be kept in strict confidence. It has been very difficult to secure signatures, given
the reputation of those who are to be the subject of the investigation, and many members signed
only on condition that confidentiality would be maintained.
In the event that the Complaint is responded to by way of litigation we are also expressly asking
that the party provide to all participants on this Complaint the same level of support for legal
representation that would be extended to any Director acting in the course of constituency
business. The only reason that it has been necessary for this Complaint to come forward in this
must do so.
up.
signatures.
Minutes of Board of Directors Meetings, November 22,2001 - August 8, 2002
December 3, 2001 - Re: Calgary Roundup Centre
Brochure #2
COMPLAINT
&
REQUEST FOR
December 17,2002
Dear Members,
We thank you for taking the time to consider this material and recommending such
follow-up action as you deem appropriate.
We believe your decision in this matter is vital to the long-term survival of this party. You
can either unequivocally affirm that the Reform party's bedrock commitment to honesty,
integrity and "doing politics differently" survived the evolutionary process that gave birth
to the Canadian Alliance party, or not. We believe those fundamental values should be at
the core of what the Canadian Alliance party stands for.
If basic concepts of "right" and "wrong" are to have any currency in this party then
members must be assured that suspected "wrongful" conduct will be investigated. Most
importantly, members need to be confident that where misconduct is proven, after
We, the undersigned members, believe an immediate investigation into recent activities in
Calgary Southwest is required. Regrettably, based on the incomplete but alaraiing
disclosures that have been made to date, it appears that a significant number of party
members may have flagrantly disregarded appropriate standards of conduct in Calgary
Southwest since November 21, 2001. Because the Calgary Southwest board has solicited
funds throughout the province and across the country the conduct of this board has
affected members all over Alberta and from coast to coast. Calgary Southwest was a
premier riding but since November, 2001 it has been run into the ground and is now
broke and in debt.
The scope of the possible misconduct referenced within, extends to the campaign and
subsequent election of the self-styled "PAL" slate of Alberta councilors to National
Council. Just as the election of the current board in Calgary Southwest was tainted by
misconduct so too may have been the election of Alberta's three councilors.
- 2 -
Specifically, the POssible_misconduct suggested by the partial evidence currently

association to the Leaders bv-election campaign. Was there flagrantly irresponsible
- 3 -
dialer and the color printer, the purchase of which the constituency contributed to
secured after the November 21, 2001 AGM?
candidacy deposit.
Some $18,000, more or less, in direct payments were made to other individuals, also
to pay "commissions'' to raise funds, all of the funds so raised belong to the
constituency association. Why were "commissions" paid? What fundraising was
default candidate?
- 4 -
Trusf'account ThefacZ^ ^ ""^ donations payable to the "In

view, entit."^ S 'CSrf^f f" " *Me"^ "
received and where w<L they dJS? S ^^ ^ ^ Were
' w e r e SH r p ^ C Sr 7 " "^ a t n U Pu b l i c sti n g s th a t
record ofZe'SeSeoo^ ST""** ^^ h0WeVer Mere is n

record keeping ^ fte c^stTenef Jl ^^ aSSdation coont ^
Where did Lfe fun<k go? ^ ** do regards to cash donations?
Campaign F^JZ^J^T/t Z**** ^ SUthwest ****

DidLdefauhcSS^ if ^ befre * candidate selecti meeting,
prior to .baSSE^S?* adViSre ^ ,00-t0 ** aCC0UDt
^dSstib^So^trTo11^40 "r* -* -**e-**
website was th used to so Lf^nt T^f"1 " 2002 mailer> ^ ttat

party. The Somhwlst AlKan" r * ? ^ Trust" acc^ rather than to the
FebLry 27 200^ $5^ Lh ^ FUD<1 rerdS disclose Pênts on
what stol:{z% sz:acpcarrrf i1,000 * ** ^
the constituency ever been comnen^H f 1 l frm * Web Pae ^ has

page construction? comPensated for me expenses associated with the web
Abuse of Membership T l..
December 10,2001 andomv ihen w7 , ,date Was not mtervieweduntil

How did ^tmZlôSZZT^r1^ Ttitled t0 *" -"êrship lists),
individual continuing IZ^cT^ll% ^ ^^^ mbership lists ? Is that
unrelated to the corXncyf ^^ SUthweSt members to promote fundraising
Ouestinnahle Election.; Act Practi
Before the Calgary Southwest by-election was callerf m-i.
appear to have been paid for ^
c-^^g^^J*
-5-
candidate as his Official Agent. Questions have been asked as to whether or not that
is appropriate. Has there been any breach of Election Act requirements?
Questionable Constitutional Conduct
Decisions were made this past year by the Calgary Southwest board to conduct
unconstitutional candidate selection meetings. Why was it necessary for National
Office to intercede to ensure compliance by the Calgary Southwest directors of the
party constitution?
The Minutes of meetings have been prepared without referencing who moved or
seconded motions, no executive minutes have been produced, responsible
constituency management appears to have been ignored. From December to April
not a single report was made at a directors meeting as to constituency finances.
When the Financial Statements for the so-called Southwest Alliance Campaign Fund
were presented to the board it wasn't the Treasurer who offered an explanation for
the accounts it was the default candidate who had to explain the existence of three
separate accounts. Members are asking what standards are expected of directors and
whether or not directors in Calgary Southwest have breached their fiduciary duty to
members particularly when the irresponsible spending that has taken place is
factored in. If the directors themselves were relying on the advice of the board
Executive have those executive officers breached their fiduciary duty to members?
$50,000.00 Unaccounted For
At the December 17th, 2001 Board of Director's Meeting a motion was passed to
move $50,000 of the liquid assets of the constituency to an unidentified lawyers' trust
account. What happened to those funds?
Questionable Tax Receipt Instructions to Members
Donors have been urged to contribute to an "In Trust" account for "business expense"
tax receipts rather than being asked to contribute in a fashion that would entitle them
to "political contribution" tax receipt, but which would result in National Office
receiving 20%. Is this appropriate?
Questionable Conduct Surrounding Constituency Property

It appears that property paid for using constituency association funds are not in the
control of the constituency association. The candidate stated in mailers that funds
donated by members were to have been used for lawn signs, brochures,
-6-

property gone?
as to what the expenditures were for. What was the money used for and where are the
- 7 -
a n TA w C c o ' u n f ^ ' ^ ^ * " ^ ^ A l l i C * ^ *

c^WeSf be" ri^tht m" ^ f0UTg a m md ttaw* ^^ *
deemitto bTapproS: ^ " ^ * ** SeCTetariat *> Natinal Council
2- syjsris ss* * r1 redies **may be avaiawe to memberehin

inrZl civil
? judgements
^ * beenagainst
^W^Priated
or individuals
divertedor from
the
membership, including
responsible
directors
3' SZT^ * aCCr<W ** * 3 > <"*> of * P* institution as
fi 22! &!**"by *"members who have sg

i ned n
i p*
***************************
foUoweurî8ned T*? SUPPrt &e re"uest for "^te investigation and
to^^wTiof ?,yd8 days'between December 17'2002*
January 24, 2003 close to 200 (177 with many wanting to sign who
StS17sh,TtUne)dedciatedCanada
i nAUa
i nce
toSer Hundred "^ "nd integri* Put this CP^n

JJ Hundreds
more would
signed but
was essential
the
OmlUt
b. forwarded
to thehave
Secretariat
for itinvestigation
as that
quicSy
Members who prepared and signed the petition include long-standing
party volunteers and loyalists and many past and curren ridinf
SSf ? -i* memb h0 hay/hPd ^ I =t riding

22S*?!
r,0Wing
ridingS
theCalgary
aSNose
Calg
Southwest,^Calgary
Centre,
CalgarySig"ed
North East,
Hi?
executive office positons or directorships on constituency board,
Calgary Southeast, Macleod, Wildrose, Edmonton StrathcoTa '

The names and signatures of the members who signed that document
CoVmeIeeyemVed
frm tWS
en,aU
distribution.
Member
sig^Hh
Complaint were promised
that the
party
would be asked
to keen
all
names ,n strict confidence to avoid retaliation from the people who^
- 8 -
belligerently litigious behaviour.
honesty should immediately:
1. Contact the Calgary Southwest Constituency Association President, Mr.
John Flynn, (email to: caIgarysw@aol.com) or the Calgary Centre
Constituency Association President, Mr. Gus Barron (email to:
gusbarron(2).zwalletcom / phone: (403) 230-8616) and demand to know what
is being done to investigate this Complaint. Copy your emails to National
Office (email to: info@canadianalliance.ca) so they have a record of your
concerns.
2. Contact the Leader's Office (email to: harper(g).canadianalliance.ca / phone:
(403) 253-7990) and ask Stephen Harper why he's not protecting the
members of this party to make sure they're treated honestly.
3. Contact the Executive Director of the Party (email to:
ter17.h@canadianalliance.ca / phone: (403) 269-1990) and ask Terry Horkoff
why National Office hasn't done anything to obtain answers to the
Complaint.
jerry.rice@canadianalliance.ca) and tell them in no uncertain terms that the
proud members of this party want to preserve core values of- honesty and
integrity!
5. Forward e-mail copies of this Advisory, Covering letter and Complaint to all
your Alliance friends, to other constituency board directors, to National
Councilors and to MP's - and print off copies to give to members without
computers.

other ridings. It is not fair to those ridings, or to dedicated and honest
party members, to leave these important questions unanswered.
this investigation and pubhcly exonerate those that have been
-9-
Page 1 of2
**$* 3Ja*.8* VvAlCvAa M-eiMb

From:
To:
Cc:
"Walter Wakula" <walterwakula@shaw.ca>

"Don Plett" <don.plett@canadianalliance.ca>
"John Flynn" <calgarysw@aol.com>; "George Lane" <geolane@shaw.ca>; "CalWest Executive
Committee" <walterwakula@shaw.ca>; "Terry Horkoff (Alliance)" <terryh@canadianalliance.ca>;
"Gus Barron" <gusbarron@zwallet.com>; "Stephen Harper MP"
<calgary@stephenharpermp.com>
Sent:
June 9, 2003 9:52 AM
Attach:
LtrtoPlett-June8-03.doc
Subject: Solutions For The Calgary Problem
^m^^
4r
c aCANADIAN
na
'^lT ALLIAN
CANAD1ENNE
MEMORANDUM
Don Plett, President, National Council
From:
Walter Wakula, President, Calgary West
Cc: Stephen Harper, Terry Horkoff, John Flynn, Gus Barron, George Lane, Calgary
West Executive Committee.
Date:
8 June 2003
RE: Solutions for the Calgary Problem

This is a belated congratulations on your election as President and a current regrets on the baptism under fire you
are encountering with the Calgary problem.
I am responding to your April invitation to constituency Presidents to contact you with concerns. I had
believed that the problems in Calgary SW and Calgary Center were problems that needed to be solved
by their Boards and members. However, after yesterday's Southern.Alberta Constituency Council
meeting I am appalled to learn more about the serious allegations being circulated, am concerned about
the threats of litigation against those volunteers providing evidence of alleged malfeasance and am
concerned about the effect these matters may have on Calgary West and other Southern Alberta
constituencies. I have summarized my understanding of the problems in the attached memorandum.
The following are our proposed solutions for these problems:
1. Calgary SW - My position with managing other people's money is always to err on the side of
transparency, especially when there appears to be malfeasance. The solution, then, is easy. The Calga:
SW Board should continue its efforts to either find or prepare 3 years of financial statements in accordance
with Canadian generally accepted accounting principles. These statements must include a schedule of
ayments exceeding $200 on all bank and trust accounts so the Board knows where the monev went. Based
on these results, they can decide if they need go further for a review engagement, an audit or a forensic
Page 2 of2
3
audit.
2. Calgary Centre- There now appears to be a stand-off in the positions of National Council and the
Calgary Centre Board in 2 levels of jurisdiction in the Constitution. There are committed and extended and
innocent parties caugfr in between these positions plus, of course, the membership. Mv advice is to Jointly
appoin a mediator who can mediate a solution with decision, to h, reached on ror^romise bv the tin,/
oi
the
June
National
Council
meeting
"
*
We look to the leadership of the two constituency Boards and to the leadership of the Alliance to settle these
aUegations promptly so they don't continue to fester until the election. The Calgary West Board is prepared to
ass^tjou with this to bring the matter to closure. Please call me at 403-246-9290 if you would like to discuss this
Best regards,
Walter Wakula
CANADIAN
ALLIANCE
MEMORANDUM
To: Don Plett, President, National Council
From: Walter Wakula, President, Calgary West
Cc: Stephen Harper, John Flynn, Gus Barron, George Lane, Calgary West Executive Committee
Date: 8 June 2003
Our Understanding fty Calgary Prnhlpm
This memorandum provides background information in support of our Email Memorandum which proposes
solutions to the current Calgary problems. I have summarized our understanding of the problems Sws:
1. There are the following allegations from the Calgary SW situation:
allegations of malfeasance in the spending of constituency funds;
allegations of funding campaigns of the three Alberta councilors from constituency funds no financial statements for the past 2 or 3 years; and
allegations of a cover up involving senior Alliance officials.
There are the following key issues/events from the Calgary Center nomination contest:
an Alberta national councilor has been acting as official agent for candidate Loh <????)
L ô ^YGT f Calgaiy SW When alleged malfea**ce and council campaign took place;
the CSC withdrew its support of Loh for allegedly lying in a first interview and breaking several
campaign rules, which is its right under the Alliance constitution;
Loh appealed the CSC decision to the Secretariat of National Council-
^ CrZTl ^rtl ^ CSC> WhiGb iS S blue cMp ^0UP 0f P^le consisti*g of a Dean
Emeritus of the Faculty of Busmess of the U of Calgary, a former multi-term Mayor of Calgary
and a Senior Partner at Bennett Jones and other highly respected Calgarians Officials of National Council never met with CSC prior to suspending it;
The Board folly supports its CSC and is proceeding with the nomination contest; and
IteJT^ ^ thV^d? ^ refoSe t0 Sign ** Candidate PaPers of *e <*her 2 nominees if
they do not withdraw from this contest. "
3. Several Alliance members and volunteer activists are being bullied and threatened with legal action for
4.
revealing evidence of their allegations and for seeking solutions g

SSc^Snf MrT fficialsattemPt^ a CafeBy SW cover up together with Council
SSdSKE Cf^ Centre nonimation race has led to rumours that there is some sort of back
A1 Wa d^clarerLh *e ca? ^te. This deal is rumoured to be among certain councillors lobbied by
Salary sTS^ ^f ^ ?* "^f*? Wh* ^ fficial *&* * the councillor who ^ me
^Mcl^n- dunng |he Penod of alleged malfeasance), the OLO's office and certain bakers of

Levant V The World - 2003

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Levant V The World - 2003

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Action No.

The Plaintiff Sean McKinsley (hereinafter "McKinsley") is a resident of

Calgary, in the Province of Alberta. He is a businessman, political organizer

10. Additionally, the Riding's audit as well *<* =ii

~ attended at *e Parfy's ffi~ - **

iLd^tfh ** rigrous accounting> "d in ^ face f *" *>. **

Defendant, have repeatedly published or spoken defamatoxy untruths about

governing National Council (hereinafter the "December 17th Letter"). The

Nancy Jahn; and

Kto ^SiSf06 Tmbfruand Care ab0Ut HONESTY and INTEGRITY

totoSS^SS^ ** atached me ^ FORWARDIT TO ^

jSxSTSS Wonnh,antdeUvered t0 the Executive Director of the party on

havrSn iiored not?' T T^* CnCemS f ahnost 200 member*

- 16Walter Wakula, MBA

- 1723 percent of the membership of the Alliance is represented by SACC. A

- 18"Letters". The defamatory oral statements referred to in paragraphs 15 through

- 19community and the public in general, especially in Alberta, Toronto, Ottawa

-20e. the Plaintiffs disregard appropriate standards of conduct;

-21 q. McKinsley inappropriately paid fundraising commissions, and

dd. the Plaintiffs conduct warrants a criminal investigation, have

h. the Plaintiffs siphon money out of Party coffers, and do so

McKinsley grants himself contracts, with Levant's approval, and

m. the Plaintiffs are discreditable;

the Plaintiffs make the Party a corrupt imitation of the Liberals;

p. the Plaintiffs are generally disreputable, odious and worthy of

-25a. the Plaintiffs' conduct warrants a further audit, and a forensic

the Plaintiffs did not succeed in the Riding through democratic

-30contained in the Letters as widely as possible, including to people who had no

-31 damaged by accusations of corruption, other malfeasance and improper or

general damages in the amount of $1,000,000.00;

b. punitive, aggravated and exemplary damages in the amount of

e. an interim and permanent injunction against the Defendants,

Specifically, the possible misconduct suggested by the partial evidence currently

Questionable Conduct Surrounding Constituency Property

advertisements, and other by-election campaign expenses. The Southwest Alliance

Z^lSlEST"* iDClUdin8 * ***** **- Campaign Flmd

E2E Z^t^S rs S n4 orough tavesti^ *

deem it to be appropriate: S' lf the Secretanat and National Council

3 " S LT * " " " ^ ^ S - 3 W W o f - P ^ c o n s t i t u t i o n a s

- 22 SStbmitted ^ *- """" Wh *~ < * county

JSi yazrcs jets*. 2M2,r

executive office nositinn* ,- h.v * t. do currently hold

C-^^ZTS^^TS d,S^bUti0n- Membe" signing the

B4lt a "^.w 2fL 14

December 17, 2002

appropriate investigation, those responsible will be held accountable.

The scope of the possible misconduct referenced within extend tn a* .

Specifically, the Possib3e_misconduct suggested by the partial evidence currently

Office to mtercedeTeTurLr^T8* ^ WaS * ""^ for Nati<'

' *^l^Zl7Zrr*1; "*"* Wh ^ed or

not a single reportf wTmade af a h^T ^0W4 Frffl December to AP*1

^5^^^^"--" ** a motion was passed to

receivmg20%.IsthirapproSaterrt "*"* W0UM reSU,t m National OiBce

Questionable Conduct SnmmM.r ^---tituen-v p,^

donated by members werfto C fcent'edifTT * nta * *-d

advertisements, and other by-election campaign expenses. The Southwest Alliance

campaign in Calgary Southwest, including the Southwest Alliance Campaign Fund

January 24, 2003

Specifically, the POssible_misconduct suggested by the partial evidence currently

Trusf'account ThefacZ^ ^ ""^ donations payable to the "In

' w e r e SH r p ^ C Sr 7 " "^ a t n U Pu b l i c sti n g s th a t

record ofZe'SeSeoo^ ST""** ^^ h0WeVer Mere is n

Campaign F^JZ^J^T/t Z**** ^ SUthwest ****

10. Additionally, the Riding's audit as well < =ii

iLd^tfh ** rigrous accounting> "d in ^ face f " >. **

Z^lSlEST"* iDClUdin8 * *** - Campaign Flmd

- 22 SStbmitted ^ - """" Wh ~ < * county

' ^l^Zl7Zrr1; "" Wh ^ed or

receivmg20%.IsthirapproSaterrt "" W0UM reSU,t m National OiBce

Campaign F^JZ^J^T/t Z ^ SUthwest

^dSstib^So^trTo11^40 "r* -* -e-

**$* 3Ja.8 VvAlCvAa M-eiMb