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Forwarded message
Frern: Pina Mart¡no <martinocarnpa¡gn@gmail.cor{ì>
Date: Fri, lrtov 18, 203Ê at 7:21P.M
Suþiech Etobicôke Centre Progressive Conservative Party of Ontario Nornination
Meeti,ng
Tor Mike Ríohmond <mi.ke.,iiçhniofìd@racrnillaa"eeÞ
Cc: Geof.,fre̿ Janoscik <Si

Míke,

I have copied rry counsel on this email.

¡ conlirm receùpl of your text.mesêãg,e sênt to. my celt phone numbêr at 5:03 pm today.

The tormat and pararneters of the meeting you are.propos¡og for Sunday everiing are unprecedent€d. You have
ind¡cêted that wh¡lsl aÐ flrl reqlired töattênd, y-ou prDpose for tl¡E fifst tlme to âd¡rlÐe rTle or my rep(€sentative ol
the "cqmplaìrt" braugt¡t againi me by.KÌñga Su¡Ìna.€nd tojnvite rfiy respsnse. The mannet ¡n wh¡ch you propose lo
conduct thE meeting is unaeceptable as.ogly l can aosr,¡er these as yet unkoown alleqations. Thls would
neeess¡late me aÊpearing in.pemon; As yor¡ r,,sre advised'durihg.tny lBlepñone aonversation rrith you at 1:2O this
aftemoan, I have been Éubiect to attemPts loJntiitn¡date me'by'Do¡¡g Fprd in€lud¡ag h¡rn lÔflowinq me home after I
had €ttendsd to personãl busiiìess at 22 ÞjMsion.ôltheT'oronto Pdlce Ssrv¡çe todBy. Funher,.he waited in fte
vicinity of my home aodto¡lo$¡ed me a sesondtlmeas¡ attcndeddr.othe.¡.business- lt is unacceptable that I be put
in a Fos¡tlpo of having to fespond:in psr"son.to a¡legalions that I do, oqt know, aßd to hâve-to do so in the presence of
the very persons who are making those allegêtions €ñd afiernptiflli to ¡ntirôfdâìe me.

Ln any eyent, your prgposal fl¡iÞ€€ç thÊ,po¡flt. lhrough coqnsel; I tieve prgvid€d the party with oubstanlial and

cr€díb¡éevfdeooe o'frdiscreditable conduot oh thapattofl(ìnga Súrrn", ttlslhe mandats and.æspons¡bil¡ty ol the

PNC to considèr my complaint aDd, oñpe.itìd {bstaritìated,:todisqualify Ms. Sunaa as a nominalisn candldate.
Thatdoes oot require a.meetihg r¡¡ithbgth pã,tiês pEçÊiìtì as lhls ls ßota s¡tuatlon thatcan be msd¡ated. There is
no r€¿çgh that I and Ms. Surma oeed;be ¡n the same rgom pr¡or ta Monday's scheduled.ngfirìnstign meql¡ng,

I maintäin rny poslliofl âs $et out in my counÊÞl's lettgr to you sent,earl¡er today.

P¡na Martino
u¡dutplæE¡aslEscorn
647-968.4866

Ðirrâ [,târliñ^

httpsJ/ma¡l.oooole.c!m lñaillull l?ui=2&ik=101e0d8024&ìsver=cAFHaMvshdw.en.&cbl=amail fe 180506.06 o7&v¡ew=Þt&search=inbox&tvoe= 16372f€45628âO

77 City Ceiìtie Diive;West Tower, Sr¡ite 300, Missis5auga, OnraÍo L5 B I [45 . (eli 905:273.3300 . tuxì 905.273.ó920 . toll free: ] .800-323.3781 . wwwpã llettvalo'com

Cçoffrey Janosc¡k
E.mail : sieqaxìi!@!ê!!ll!g!AI9!¡
Dned Líîe. 1905) 213-3022 x.232
November 18,2016

Progressive Conservative Party of Ontario VIA E MA I L r i c k. dv {cs t ra@.on I ar i op c. c o m

Provincial Nomìnation Cornmittee. and PERSONAL DELIVERY
Attention: Rick'Dvkstra. Chair..President of the
Progressive Conservâtiye Paifv of Ontario
59 Adelaide Street East, 4th Floor
Toronto, Ontario
MsC 1K6

Progressive Conservative Party of Ontario VIA EMAIL bob.s tan lev@on'Íariooc. com
Provincìal Nomiiation Comm-jttee øn¡l PERSONAL DELIVERY
Attention: Bob Stanlev. Executive Director of the
Prosièssiv.e, çoirsérvative PÀrùy of Ontârio
59 Adelaidc Street East, 4th Floor
Torontq, Ontario
Msc 1K6

Dear SirS:

Re : Etobicoke Cenfre Progressive Conservative Party of Ontario Nominâfion Mècting

We are. counse.l to Pi.na Martino;-.aQualified eontestant fo¡ the Progressive Conservative Party of
Ontario nominadon in the riding cifEtobiooke Centre,

Ms. M¡tÍtiho has uûcòvered substantial evidence of unethical conduct by another Qualified
Candidale, Kinga Suiana (l¡Surrna").. Specifically,. thal Surma submitted memberships for
registration in the Provincial Party Membership Rógistry ii which the applicant h¿d not paid the
applicable .membership fee fìom thei¡ own funds or those of a¡ immediate family member
residing in, the same household in violation of Rule 4,2.8 ofthe Progressive Conservative Party
of Ontario Rules Governing the Provincíal Membership Registry (the. "Membership Rules')
and/or.did not sign the membership lbrm themselves.

Appended hereto ¿re the following evidentiary records detailing numerous instances of said non-
corqþliance, nainely:

(a) Alfidavitof Pina Manino, swom November 17,2016;

rn"'¡",
"r ili iag ,n,"n,",nd oouoory Gfor¡p.rnreirrãtionãl
 -2-
(b) Affidavit ofGordon Dawson, swom November 17,2016:
(c) Affidavit of Doretra Wilso¡r, sworn Novembef 16, 20.l6; and

(.d) Audio .recordings of interviews . conducred by Ms. Martino with individuals

appeaiing on the Provincial Party Membership Registry.

The Iegitimâcy of the Provincial Party Membership Registry rhat will be dete¡minative of
eligibility to vote at the Nomination Meeting pursuant to the Progressive Conservativi Party of
Ontario Rriles Goveming Candidate No¡ri¡ations 20i.6-2018: (the "Nomination Rules") has
been yiolated as a result of Sr¡rma's âctions,.as outlined aÞove.

Àccordingly, Ms. Marino requests th¿f the ProviíciAl Nominatión Commìttee exerc.ise its
a.uthorily fO revoke the approvâl of Surma as a Qualified Candidatç p-uis'ìant to Rules 2.5 (viii)
a¡d.E.3 of the Nomination Rules On the.grounds that Súrma has breached the Nomination Rules
[8.3 (tv)] and that her continued candidacy would bring harm, disrepute, or dishonor to the
Progressive Conservative Party of Ontario [8.3 (vi)].

Altematively, Ms. Martino requests that the ¡omi¡ation inèeting currÞhtiy scheduled for
Monday, November 21,.2016. be adjourned by the Provincial Nomination Committee pursuant to
Rules 2.5(ii) and 20.1 of the Nominalion Rules on the grounds that such an adjoumment is
necessary to ensure the fair cctnduit Õf the torqi¡ãtion progesù and in particular, the accuracy of
the.Provincial Party Membership Registry.

M$. Martino reserves.all rights to formall:y protest the Nôminati.on Mgeting puisuant to Rule 21
of the NominatiÒn RUIóS and Article.2? of the .Progressive Conservative Party of Onfario
'Constitution.

We look folward to yoqr prompt response to the abovè by no later than November 18, 2016 at
5:00 pm.

Yours very truly,

PALLETT VALO LLP

Pe¡t GeÒffrèy Janoscik

GJlng
Enclosures
Copy: Client;
.Mike Richmond - McMillan
 AFFIDAVIT

l, P¡o.a Martino, of the City of Toronto, ¡n the Province of Ontario, do solemnly swear as follows:

lreside at 14 Eden Valley Diive in the City. ofToronto. lam a reg¡stered nomination
candidate in thè electoral district of Etobièôke Centre for the Ontario Progressive
Conservát¡ve ("PC") Party..

2. ln my capaciW as a nominat¡on candidãte, on November L3,2016,I received from the

Ontâr¡o PC Party a list of Ontar¡o PC Pãrty.members in Etobìcoke Centre.as at November
6, 2016. All individual! on this list are entitled to attend the nominat¡on meeting
scheduled for November 2I,2016 and vote for their choicè for the Ontario PC Party
candidate for Etob¡coke Centre fôr the 2018 general election.

3. On November 14, 2015'ât approx¡mately 11:25 a.m., I attended at a residènce at 2

Fletcher Place and Spoketo a woman who answered tothe name of Anna Pariselli. I
introduced myself and asked her ¡f stfe was coming ta the November 21"t nomination
meeJíng g¡ven that she was rlow a nierhbei of the Oñtâiio PC Party. She was surprised
to hêirr she was a party member. I showed her a blank Ontario PC Pà¡ty membershiÞ
applicat¡on and asked her if shè had signed a fiÍèrnbership form and pâid e. membeÍship
fee. She said shé did ñot and did not.uúderstand úhy she hád to pay to vote. She said
thãt at some point ilthe rpreced¡ng week, Kingâ.Surma and EciuB Ford had come to her
hóme and ¡nvited hèíto a meet¡ng on Novembe¡' 2i'! to vote fôr Kinga. She said that
th¡s visit was ¡n responle to. a robocall she received f¡om Doug,Ford inviting her to a
meeting on November 21"!.. She said that neither Doug Ford nor Kinga Surma had asked
herto sign a membership form or pay a membership fee.

On November 14, 2016 at approximêtely 11:38 €.m;,.I attende.d at a residence at 47

Fenleyand spoke.to a woman rryho answered to the name of:Mrs: Zhang. liñtloduced
myself and asked'her if she was comingto the November 21r nom¡netion meeting Biven
that she was now a member of the Ontar¡o PC Party. She said that she ha! not joined
the Ontario PC Party, She sáid that in the preceding weeks, she had rècèiùed a þhone
'l
call from Doug Ford. showed her where hèr:ràräe appeareil alang with her hùsband' s
on the membership list and she said she would bê spêaking to. her husband. She sâid
she never signed a membership form or pa¡d,ã membership fee.

5. On November 14, 2016 at àpproximately 11:10 a.m, I attended at a residence at 69

Manorhãmpton Dlive. An elderly worhan with.an ltalian accent who answered to the
name of Amelia Nicoletti answered the door.. I am fluent in ltalian and spoke to her ¡n
Italian, I ¡ntroduced rÍrysêlf and asked her if.she was com¡ng to the..upcoming meeting on
Novemher 21st. She said she did not know anything about it. I showed a blank
mèribershlp.fcillm.añd.ãfkêd her if she recalled signing the form or paying a
mem,berShip fee. I askèd her if either Doûg Ford or Angelo Carnevale had recently come
tO Seê her. She sàid it was Angelo Cârneùàlê. She said her'never asked her to sign a form
 and she d¡d not pay him any money. She told me that she d¡d not have any money to
pay.

6. On November 14, 2016 at approximately 2:20 p.n¡. I atterided at a residerice át 20

Featherwood Placé and spoke with a mah who enswered to the name of Aldo Pappa. I
introduced myself and we conversed in ltalian. I âskéd him if he was coming to the
Nóvembel2tr't meeting. He sàid he ieceiVed a phorie call from Doug Ford inviting him
to:à meetin!. I showed him the sample Ontaiiò PC membership form and asked him if
he had signed one and paid a fee. He got qu¡te upset and sa¡d he 'tupports Ford" and
he was..oñly ¡ñvited by Doug to come out to a meeting. He sa¡d he never signed a form
and never paid any money.

7. on Novembet L4,2oL6 at approximately 1:10 pm I attended at a residence at 12

Easthampton and.spoketo a woman who answered to the name ofJoseph¡na Viscont¡, I
iñtrodocêll myself: 5he;had a.strong ltal¡an acce¡t. lnthe ltalian languãge, lintÍoduced
myself asked.her if she was,coming to the November 2L'r meeting givên thãt.ihe had
signed the Oñtar¡O Pc.Pãrtly' membership form and pa¡d the fee. I showed her a blank
Ontãr¡o PC Party mEhbership form. She sãid she:never signed a form and never paid
ányone any.inoñey.

8. On November 14,.2016 ât ãpproximately 2:15 pm lattended ât a res¡denceêt 63

Swordbill€nd spoke:to an elderly woman who tesponded to thename of Rosa
Girimonte. ln the ltalian lahgùage, I introduced myself and asked her if she was com¡ng
to the November 21iÉ meeting.now that she had signed the membership form and paid
the membership fee. I showed her a blank Ontario'Pc Perty,membership form. She said
that she never signed aform and never.paid any meney:, .l.iasked her if e¡ther Doug Ford
or Angelo Carnevale had recently cqmeto see her êt her hOme:. She Said it WaS Angelo
Carnevale. She.said he had inùited she and her,husband to a neet¡ng.on November 21d.

9. ._On November 14, 2016 at approxímately 1:55 p.m, I attended.at a residence at 92

North Drive and spoke to a man who rêsp.onded to the name of Albert Carbone. I
introduced myself and asked him if .he wês:Coming to the Nóvèmber 21s nomination
meet¡ng since he had renewed his party me¡ribership and paÌd his fee. l,Showed him a
blank Ontario PC Party membership form. He said he did not s¡gn a membership form.
Hesaid he was notet home when Doug Ford receñtly canieto visit and ¡t was possible
his wife had signêd it and he wciuld hâve to f¡nd out. He sãid he did not pay the fee.

10. During the coursè of niy.canvas of November 14, 2016, I spoke to 17 individuals,who are
named ¡n Ontario PC Party membershiþ applications.submitted by Kinga Surma. Sêven
of those seventeen individuals adú¡sed me that.they had e¡ther not signed a
membership form or had not paid.a membeilhip fee or both.

11. On Novembe¡. 15, 2016 ât approx¡mately 1xt20,am, I attended at a residence at 63

Yofkleigh Avenue and spoke to a man who answered to the name of Radmito Nada. I
 3

introduced inyself and asked him if he Þla¡ned on attêndingthe November 21sr meeting
givên that he had slgned the member.Ship form and ¡aid his fee. He knew about the
nominat¡on dâte from a çall he had received fram Doug Ford inv¡t¡ng h¡m to a meeting,
Af¡er showing hinÌthê niembersh¡p form and asking hiin if he had signed it or paid a fee,
he indicated he had done néither.

12. On November 15, 2015 at approximately 11:30 am, I attended at a residence at 20

Kingdom and spoke to a woman who ansrirered to the name of Helen Marks. I
íntroduced niyself and asked her if she knew about the November 2l't meeting. She.
said she knew about the meet¡ng as a result of a robo call she received from Doug Ford.
I showed her a blank Ontario.PC Party membership.form and asked her if sherecalled
signing the form and Baving:the membership form, Sle.said that s¡e did not sign the
memberShip form or pav the fee.

13. On Ñ-.ove|¡be t 75,2016 at ãpproxìmately 12:35 pm,-l aüêi1.ded at the residence at 59

Allanhur.sl Drive and spoke with â woman who answered to ihe name of M.rs. Kul¡c. I
introduced myseli and asked her if ihe was coining to the NÕvembêr 21i meêt¡ng given
that she had signed â membership forÍn and Þaid a fee. She said she knèii/ about the
November 21r r¡ieeting. I showed her a blank Ontar¡o PC Party membership form and
she said th¡¡t Doug Ford and Kinga Surma had come to her home in the precediirg
weeks. She.:s'aid she had signed the membership form but did not pay a fee' She said
she was never tôld that she hãd to pay a inembershipfee.

14. On November 15, 2016 at approximately 2:20 Brn I attended at the residence ãt 43
Brampton añd spoke with a man who answered to fhe name,of Gavin Câmpbel¡. I
introduced myself and asked him if he knew about the November 21't nominatiqn
meeting. He said he became awarerof the November 2itt meeting ag'a rèsult of ã robcj
callfiom Doug Ford, I showed him a blank Onta.Iio Pç Party membership form and
asked h¡m if he had s¡gned the form and paid the membership fee. He said he had
s¡gned the form but hêd never paid the fee. He said no one told him he hád tÒ pay a
'fee.

15. On November 15, 2016:...at approx¡matelv 2:25 pm, I ãttended at.a res¡dence ãt 14
S.hiþley.and spoke to a fnan who answered tothé namè.of M¡chael Ftodgson. I
introduced myself and asked him if he wãs Coining to the November 2lr'rrmeet¡ng'g¡ven
tha! he had signed an Ontariò PC Pàrty membêrship form ánd pa¡d the membership fee.
He said he was aivare of a ineeting on Novèiiber 21't. I showed him a blank Ontario PC
Perty rnembership form. Hê said he had not signed a membership form or paid a fee,
He said that recently he ha.dêncountered Doug Fòrd and a young lady at a localTim
Horton's shop. He saìd that during that encounter, Doug Ford invited him to come to a
meet¡ng on November 2.1*. He said he.never agreed to become a member of a polilical
par.ty.
16. On November 15, 2015 ât approxiinately 3:50 pm, I attended at a res¡dence at 24
Millsborough and spoke with a man who answered to the name of Mr. Scilanki. I
introduçed myself and asked him if was coming to the Noveniber 21r meeting given
that he had signed an Ontario PC Pafty membership form and paid the membership fee.
He said he had òot signèd a membership form or paid a fee. He advised that K¡nga
Surma hàd been at his horire earl¡êr today and had gìven him the details on the location
of the rneètihg. Hê said that she did not ask him to sign a membership form or pay a
¡Ìembeish¡p fee,

17-. On NòvÊmber 15, 2016 at âpÞrirxirirately 4:21 pm, I attended at a residence at ¿14
Eriniate arid.sþoke with a woman who answered to the name of Mrs. Sookhdoo. I
introduced myself .and asked her ¡f .she was planning on çom¡ng to the Novembêr 21*
meeting given that she had signed an Ontario PC Patty membership form and paid a
membership fee. I showed her a blank Ontario PC Party membership form and she said
she had signed the membership form but had never paid a fee. She said that she had
never been asked to pay a fêe.

18, On November 15, 2016 at i¡pp.roximetely 4:25 pm, I attended at a residence at 45

Eringate and spoke w¡th a man who answered to the name of Mr. Staropoli. I introduced
riyself and asked him if he plenneii on.coming tothe November 21't meeting given that
hé had'signed the Ontario. PC Party inemberihip fôim and.pa¡d the membership fee. I
Shô\ùed hiriì''a blånk.Ontaiio PC Pâity nieinbership Íoim.. He said that Doug Ford and
K¡ñga Surmá hâd c{tirìe to his homé iri the preceding \¡rreeks. He said he.was given the
membership foiin to s¡gn. He said he:asked if he could read the form first before signing
and was told by.Doug Foi'd to just sign ¡t. He said that.when he asked Doug Ford if he
had to pay, Doug Ford drew an "X" through the payment portion of the form and said
'no'. He said he signed the membership form but did not pay a membership fee.

19. On Noúember 15, 2016 at approximal€ly 4:35 pm, I attended at a residence at 12

Beekwith and spoke with an elderly couple who answered to the names of Mr. and Mrs.
lauria, I introduced myself and asked them if there wère coining to the November. 21*
meet¡ng given thet they had signed the menibership form and pà¡dthe membership fee.
Mrs. Lauiia said that Doug Ford and K¡nga Sui.ma had attended ãt theif home in the
preceding.weeks. Mrs. Laqria said that both she and her husband had signed the forms
but were never asked by either Doug Ford or K¡ngâ Surma to pay a membership fee,
Mr. Lauria asked me why he hâd to pay a fee in orderto vote. ltold.him that the fee
was to cover his,membership in the Ontario PC Pãrty. I showed them a blank Ontario PC
Party meinbership form and pointed out the statement on the form which reads, "My
membership fees ar€ Þaid frôm my own funds or by an immediate family member.".
Mr. Lauria asked fo.r my'b.us¡ñess card and f provided it to him.

20. On Novembèr 15, 2oi6.at appioximately 5:10 pm,.l attended at a residencê at 199
' Wellesworth and spoke with a name who answered to the name of John playter. I
introduced myself and asked him if he was coming to the November 21* meet¡ng given
 5

that he had signed an Qntario Pc Party membership form and paid a membership fee, I
showed him a blank Ontario PC Party Íiembership form. He sãid that he had become
aware of the November 21't meeting as a result of an autohated phone he had received
fiom Doug Ford invíting him to the 'meeting. He said "the girl" had just beén at h¡s
hóme earlier today, He said he not signed a'form or paid a fee. He said that "the girl"
d¡d not ask him to sign a membership.form or pay a fee.

21. During the course of .my canvas on November L5,ãOtß I spoke with 20 individuals who
are named in Ontario PC Party membership applications submitted by Kinga Surma.
Eleven of those twenty ind¡viduals advised me that they þad either not signed a
membership form or paid a membership fee or both,

22. On Novêmber 76,2076 at approximately 11:34 am, I aftended at a res¡dence at 39

Farningham Drive,and spoke with a man who answered tothe name of Bruce
Suiherland. I introduced myself aniJ'askèd h¡m if hé was comingtothê November 2L't
meetlng'aird he sêid that he was plañhing on coming hiin. I showed him a blank Ontario
Pc Párty mèrnb:eilhip form and asked him if he had signed it. Hè sáid he did not need to
s¡gn ¡t. I asked him if he had paid a fee. He said hè may have a long time ago. He sàid
that he had become.aware of the November 21s mèeting from'K¡hgâ Surma, He said he
Was not going to.sign anything and that he just planned on coming out to vote. He said
he plans on virting. Liberal. I asked him again if.he sígned a membership form,or paid a
fee and he said he 'did not. I recorded my conversation wìth Mr. Sutherland on my cell
phone-

23-. On November 16; 2016.at approximately 11:52 am; I attended at a resídence at 14

. Benedict Road and spoke with.a young woman who answered to the name of Emily
French. -l introduced myself and asked her if she knew about the November 21'1
r.neetingìand she sA¡d she d¡d not know about it. I showed her a blank Ontario PC Party
membership form and asked her if she had signed such a Íorm. She said he did not sign
the fo¡m and perhaps her father had signed it because she is uirder 18. I asked her ¡f
she.had paid a fee or if she knew whether her father had signed it for her. She said she
' ditl not know. I recorded my conversât¡on wìth Miss French on äy cell phonê.

24. Oi Novemþer 16, 2016 at apÞróximatèly 12:25 pm, I attended at a Íêsidence at 1

Cqwley and spoke w¡th a man who ãnswered to the name of Petei Schieiber, I
introdriced myself and sãid that s¡nCe he had signed ã.inembership form and paid a
meinbèrship fee, he could vote. He said he d¡d not know about a nom¡nation meet¡ng.
He said hè had been a PC member years ago. I asked him if he had received e call from
either Doug Ford or Kinga Surma and he sa¡d Doug Ford had called. He saíd Doug Ford
and someone else had come to the¡i home. He Was raking leaves and did not speak
with them but his w¡fe d¡d. I showed him a blank Ontar¡o Pc Party membership form
and asked him again if he had signed it or paid a membership fee. He said he did not. I
asked him if he uriderstood that he had become an Ontario PC Pa.rty member and he
said he díd ngt, lfeçgr.ded ny conversation withMr. Schrelber on myç¡ll ph94q.
 6

25. Oil November 15, 2016 ãt apprôximately 12:25 pm, I attended et a residence at 31
Eastglen and,spoke w¡th a man who answefed tq the namê of Jan Jâcyla. I introduced
myself to hiilì. He said he wàs plahnihg .on coming to the meeting. I showêd h¡m ã
blank Ontario PC Party membership form and he said he signed it "for Suima" He said
Doug Foid was her and he signed the fotm to support her.. He signed a form. I askéd
him if he paid a membership fee and he said he did not. I asked him if they had asked
him to pay a fee to become a member of the Ontario PC Party and he said that they did
not ment¡on that. I recorded my converset¡on with Mr. Jacyla on my cell phone.

26. On November 16, 2016 at approximately.1:13 pm, in the company of Doretta Wilson, I

ãttended at a residence at 42 Dixfield. I spoke to ã woman who answered to the name

of Phyllis Samaroo. I introduced myself as an Ontârio PC Nomination Candidate. ln
response to a quest¡o.n ffgm me, she said she was aware of the meeting on Monday,
NoVerrñber 21st. I sâi-d thet beCause she had signed an gntar¡o PC membership form and
had paid her fee, she was entitled to vote at the meeting. I showed Phyllis Samaroo a
blank Oñtariir PC Party i¡iid.ahe saìd,she siÈned a form. She Said ¡i lãdy Èaírìe tct sèè hér
and she Signed a form but She did not krÍow what she had signed. t asked her if thelady
who cameto see her was named Kinga Surma and she said.did not know. laskedherif
she pa¡d anything and Ms. Samaroo said she.did not pay'anything. I asked her if the lady
who came to see her asked her to pay a $10 or 515 fee añd Miss Samaroo said she did
not sav anything about paying. I recorded my conversat¡on w¡th Miss Samaroo on my
cell phone.

27. On Novembet 16,2oL6, at approximately 2:06 pm, in the company of Doretta w¡lson, I
attended at¿ residence ãt 56 B¡rgitta. I spoke to ã .man who answered to the name of
Mr. Vêrgara. lintroduced myself as an Ontario PC Nominatiôn Candida-te, ln response
to a questÍon from me, he saíd he was aware of the meeting on Monday, NOVembèr
21't. l showed him a blank Ontãrio ÞC Þartv membership form and asked him if he
signed a nlenbership form. He said he signed it, I asked him if he pald S10 ar S15 and
he said lre did not pi¡y any.thing. I askgd hiri rii'ho.camê to see hiín to fill out thè fórm
and h¿ said itwas Doug Fofd and K¡ngâ SUrmá who had come to.see h¡m and they
iegistered him and h¡s son to vote. He sa¡d thev did not ask him'to pay S10 or 515. I
asked him if rhey told him that he had to pay á fee of SXo oi 515to join the Ontario PC
Party and he said they did not tell him anything. I recorded my conversation w¡th Mr.
Vergara oh my cell phone.

28. On November L6,2076 at approx¡mately 2:10 p.m., in the company of Doretta Wilson, I
attended at'a. res¡dence et 119 Birgitta. I spoke to a man who,answered to the name of
Mr. Foon. I ¡ntroduced herself as an Ontario PC Nomination Candidate. ln response to a
question.froÍi.me, he said he was aware of the meet¡ng on Monday, November 21't. I

showêd hirh.a blank.Ohtario PC.Party membership form and asked him if he signed a
membersh¡p form and paÌd a fee. He.said he did not sigo anything and did not pay
anything. lasked him who had told him aboutthe meetin€, He replied that ¡t was
 7

Doug Ford. I asked h¡m if he was asked to pay a $10 or $15 membership fee and he said
he did not pay arÍything, He said he could not afford to pay ànything.

29. On November 16, 2016 at approtifüately 5.:08 Þ.m., I attehilèd ãt a res¡dêncê ãt 48

Chapman Road. I spoke to a man who answered to the name óf:.Mr. SiniaVskaia. I
¡ntiodúced myself as an Ontario Pc Nórñinät¡on CBndidate. lh Ìèsponse to a quest¡on
from me, he said he was not aware of the meeting on Mondày, Nòvember 21s. I
showed him a blank Ontario PC Party membersh'ip form arid asked him if he had signed
it. Mrs. Siniavskaia also came to the door. she in¡t¡ally said they did not s¡8n any forms.
She then said she had signed forms with Doug Ford and Kinga. I asked them if they had
paid a membership fee of 510 or S15 to join the Ontar¡o Pc Party and she said they did
not pay. She said thet she did not know there was a fee to join. I recorded my
conversation w¡th Mr. & Mrs. Siniavskaia on rny cell phone.

30. On November 16, 2016 at approximately 5:29 p.m., I attended at a residence at 35

Crane. I spoke to a woman who ariswèred to the nameof Mrs. Elkis. I introduced
myself as an Ontar¡o Pc Nom¡natioi Cand¡date. ln respo¡se to a from nie,'she
-question
said she was aWare of the meeting on Matnday, trlovember 2i1 i shOwed her a blank
Ontario PC ParÇ räembership form ãnd asked her if she had filled out the form and paid
a membershipfêe,. Shesãid Doug Ford vi3ited them ãnd shè did not f¡ll out a form or
pay a fee, She said Doúg Fórd told them they could voie for Kinga on.November 21. I
said.the meeting on Novembei 215t was a meeting of the Ontario PC Party. She then
spoke with her husband in a foreign language, She said that her husband could not vote
because he did not understand English: lrecorded my conversation wíth Mr. and Mrs.
Elkis on my cellphone.

31. On Novemo'er' 16;,2016- at.approximately 5:39 p.m., latlendgd at a residence at32 Hill
Garden. I spoke to.a.Woman who answered to the name oJ MrS. Poutsoungas, I
introduced mysejf'as an,.O¡taijo PC Nomination Candidate. in responsê to a quest¡on
about the meet¡ng on.Mondåy, November Z1't she said she would ihink about it. I
asked.herwhen Kiriga Surmá 0i Doug Ford .câr!e tq her hofüe, if she. hAd filled out a
fôrm and paid afee. She sAìd she did not remember. I recorded niy coriversetiòn with
Mrs, Poutsoungas on my cellphonè.

32. On November 16, 2016 at approximàtely 5:47 p.m., I attended at a res¡dence at 4 La

Rush. I spoke to a Íìân who answered to the name of Sam Fiorino. t introduced myself
as an Oritario PC Nomination Candidate. I asked him if he had signed a membership
form or pay a membership fee. He said he did not, I recorded my conversation w¡th Mr.
F¡oiino on my cellphone.

33. During the coursê óf iny:cánvason Nóvèmber L6,2016,lspoke with 17 individualswho

are námèd ii1 Ontêiio PC Party metibershiþ applications submitted by Kinga Surma.
Thirteen of thesê.sevehtèêñ ¡nd¡vidi:¡als advised me that they hãd either not,s¡gn€d a
membership fôrm orrpàid a membersh¡p fee or both.
34. On November !6,2076 between the hours of 6:30 pm and 8:00 pm, lcalled and spoke
to the follorlving individuals who advised me that they had signed a form presêñted to
them by Doug Ford but they did not pay a mémbe¡sh¡p fêe aird were not advised by
Doug Ford that they were required to pay e membership fee:

a) Tom Anderson and Betty Anderson residing at 390,Renforth Di¡ve;

b) Bette-Jean Argeropoulos residing.at 14 Eigham Crescent;
c) Balwinder Badhan residing at 416 The Westway, Unit 604;
d) Maureen .Beckley residing at 65 Garbutt Crescenu
e) Robert Bobyk residing at 385 Markland Drive;
fl Cynthia Roberts residing at 451 The Wes.t Màll, Unit 404;
g) Mr. Salad residing at 364 The East Màll, Unit 312;
h) Êileen Sãnt resid¡ng at 33 Rhinestone Drive;
i) Mohammad Shahrukh residing et 416 The Westway, Unit 106;
j) Sãnja Simanic residing at 25 Longfield Road;
k) Sat¡irder Singh res¡d¡ng at 3 R¡sdon court;
l) Alicia Sirireczynski residing at 36 Pebble Vàlley.Lane;
m) Lee-Anne Soper iesid¡ng at 695 Mãrtin Giove Road, Unit 1110;
n) Margaret Sorcik residing at 272 Burr¡hamthorpe Road; and
o) Mathew Stèfênowits residing at 15 Tyler Place.

35.. Dur¡ng thls same time period, I called.and spoke to Wolfgang Schroter residing at 20
F.ontefiãy Court, Unit 210. ln response to a question from me, he said thät he d¡d .not
-sign .a lorm and did not pay a fee. He said he was unaware of a nomination meet¡ng.
Whenrl asked him how he came to be on a list of Ontar¡o PC Party members, he said he
did not know-

t0¡, During tþe morning and afternoon.of November 17, 2016, Iwent canvassing with
Gordon Dawson, a volunteer on my campaign. He was present during each ofthe
conversat¡on detailed below,

37. On November 17, 2016 at âp.praximately 11:23 am Gordon Dawson and I attended at a
residence at 36 Gentien,. .l .spokè.tó a Women who ánjwered to.thþ rÌañe of Mrs.
Haeuserer. I introduae.d rnyself as an Ontãrio PC Nomination Candidate. ln response to
a.question from mê;:shérs¿id she was aware of the'meet¡ng,on Monday, November 21't
aild wãs plann¡ng oiì attèñd¡hg. I Sa¡d that because:she had signed an Ontar¡o pC
rirêmbership form áñd hàd paid her fee, she was entitled to vote at the meeting, I
showed Mrs. Haeuserer a blank,Ontàrio PC Pàrty and she said she signed a form. She
Could not recall if she had þaid a fee. I alsó spoke to Mr., Haeuserer. He sâid that he had
s¡gried.the membership form. When asked, he said he did not pay a feë: He said he
does not want to be a member. He said Doug Ford and Kinga Surma told him about the
meeting. I explained the purpose ofthe nomination meeting and that it was only opên
to Oñtario PC Pàrty members.. He said he did not want to contr¡bute financíally. When
asked, he.said he not pay fee at the time that he.signed for:m. I read him the clarrse in
 9

the application about paying for the membership fee from one's own funds. He said
Doug Ford phoned and he comm¡tted himself arid someone carñe by tlie house. He said
they did not ask for anyth¡ng. I rècorded my cónversat¡on with Mr. & Mrs. Haeuserer on
my cell phone.

38. on November u, 2016 at approximately 11:55 a.m., Gordon and I attended at a

ièsidence at 49 Rangoon. lspoke to a woman who answered to the nariìe of Ml'S,
Welegedera, I introduced myself as an ontar¡o PC Nomination Candidate. ln response
to a question, she said she was aware of the meet¡ng on Monday, November 21't. I
showed her the membership form and asked her if she signed a membership form. She
said she did not s¡gn the form. She said she did not pay e fee. She.said she was.not sure
if her.husband had paid the fee or signed the form for her. She said Doug Èord came to
her door. I recorded my conversation w¡th Mrs. Welegedera on my cell phone'

39. On Novemþel !7,2A76 at Lz|rO& pm, Gordon Dawson and I attended at a res¡dence at 9
Dimplefield. I sp'o.te tò.a nian who answered to the name of Mr, Beauvais. I introduced
myself as an Ontar¡o PC Nom¡nation Candidate. ln response to a question from me, he
said he wâs àware,of the meeting on Monday, November 2f . I showed him the'
membership form and asked him if he signed a membership form ánd paid a fee. He
said he signed the form w¡th Doug Ford but did not pây anything. He said DÒug Ford did
not tell h¡m that he had to pay, I recorded my coñversat¡on with Mr, Beauvais on rny
cell phone.

40. On November 17,20'1,6 ataiÞiox¡mately 12:48 pm., Gordon Dawson and I attend€d at a
¡:esidence at 27 Littlewood, I .spoke to a man who answered to the name of Mr. Nénic, I
introduced myselfas an Ontario PC Nomination Candidate. ln response to a question
from me, he,said he was aware ofihe meeting on Monday, November 2i*. lshowed
hím the membership form and asked him if he signed a membership form. He said he
did not sign the form. He said he did not pay a fee. He said he was not sure if his wife
had silned the'form or paid the fee for him. He said Doug Ford came to his door. I
re¡orded my conversation w¡th Mr. Nen¡c on my cell phone.

41. On Novefüber 17, 2016 at äpproximately 12:55 p.m., Gordgn Dawso4 and lattended at
q rËsidencè at 18 Firestqne. lspoketg-aWomqn WhO answered'tb the hame ef Mrs.
Donegan. I introduced myself as an Ontario PC Nom¡nat¡on Candidate. ln response to a
qúestion from me, she.said she was.awafe ofÌhe inêet¡ng ori Mondãy, NoveÍnbea 2I5t I
showed herthe rnembetshiþ form ãrid.askêd hèifShe ahd hér huSband signed,a
membership form. Shèsãid she did notsign the fitim. Shesaidshedìd not paya.fee.
She said she did not knoû if her husba¡d.had signed a form. I recorded my conversat¡on
with Mrs. Donegan on my cell phone.

42. On November 17; 2016 at aþproximately 12:57 p.m., Gordon Dawson and I attended at
a residencé at 33 Firestone. I spoke to a man who answered to the name of Mr. Castro.
I ¡ntroduced myself as,an Ontario PC Nomination Cand¡date. ln response to a question
 10

frqm me, he said he was aware of the meeting on Monday, November 215t. I showed
.him the membership form arid asked him if he signed a mèmbership form. He said he
signed it.. He said he did not pay.a fee. He said he was not told there was a fee. I
recorded my conversation vvith Mr. Castro on my céll phone.

43. On November t7,20!6 at approxímately 1;02 p.m., Gclrdon Dawson and I attended at a
residence at 68 Holl¡3ter. I spoke to a man. who answered to the name of Mr. O'Marra. I
introduced mysélf as an Ontar¡o PC Nomination Candidate. ln.response to a question
from me, he said he was aware,of the meeting on Monday,.November 21s. I showed
him the membership.form and asked him if he'signed the form and he sa¡d he had not,
He said he did not pav.ã fee. He said Doug Ford cãme to hls door. He said he was not
home when Doug Ford çame, He seemed upset when I showed him that his name
appeared on the merib. ership l¡st. I provided him with the phone number for the
Ontario PC. Party Hea.dquarters and told him he could tell them that he did not sign a
membership form and could askto be removed from the pàrty's membership list. I
recorded my conversation with Mr. O'Mafrâ on my cell phone,

¿14. On November 17, 2016 at aÞproximately 2:46 p.m., Gordon Dawson and I attended.at a
residence eti 123 crendon. I spoke to a woman who añsúered to the name of Ms.
McPhee. I ihtróduced my.self as an Ontar¡o PC Nominatioñ Cand¡datê. ln response to a
question from me, she said she was aware of the meet¡ng on Monday, November.2l't. I
showed her the membership form and.asked her if she signed a 6e-niþe¡sh!p,for¡1, She
said shetigned the form. She said she,d¡d notsav,a,fee.,. .She.seid:that,the person who
brought her the form to sþn dld nottell lrcrth.erewasa feeto jo¡n the Ontar¡o PC Party.
She rsaid they did not ask het for a fee. I recor'ded my conversation with Ms. McPhee on
my cell phone.

45. On November 77, ?016 at apprgximately 2i5Ip,tî., Gordon Dawsori and I alten.ded at a
res¡dence àt 25 West Wareside. P¡na spoke to a woman Who answered to the.namê of
Mrs. Klamãnn. I introducet myself as an Ontario PC Nomination Candidate. ln resporise
to a.guesJ¡on from me, she said she was aware of the meeting.on Moniláy, Nôvember
21:t. I showed her the membershþ form ãñ(l aSkéd her ¡f she signed a membership
forn, She sàid she d¡d notsign the form and peihaps her husband hâd signed it. She
called her husband to the door- Mr. Klamann said he signed the form, Hesaid.hedid
not pay a fee. He said someone came to his door. He said he did not jóin the pàrtv. He
sâid he did not íntend.on joiningthe Ontario.PC Party and asked úhy heshould þay. I
recordêd my conversâtion w¡th Mr. & Mrs. Klamann on my cell phone.

46. On November 17, 2016 at:approx¡mately 3:15 p.m., Gordon Dawson and lattended at a
res¡dende at 12 Renova. I spoke to a man who answered to the name of Mr, Oblak; I
introduced myself as an Ontario PC Nomination Candidate. ln response to.a quest¡on
from me, he.said he was aware of the meeting on Monday, Novembe¡ 211. I showed
him the membership form and.asked him if he had signed a membership form. Hesaid
he may.havesigned the form, Hesaidhe could not remember iirhe paid afee. He.said
 11

someone came to his home and perhaps his wife had signed ¡t. I recorded my
conversation with Mr. Oblak on my cell phone,

47. On November !7 ,20L6 at approximately 3:29 p.m., Gordon Dawson and I ãttended at a
res¡dence at I Queènsland.. I spoke to a \¡iofüan who answered to the name of Mis.
Kóshyk, l introduced myself as an ohtario Pc Nom¡nat¡on Candidate. ln rèlponse to a
quèstiori from me, she sâidrshe was aware of the rneeting on Monday, November 21r' I
showed her the:rireriìbership:form and asked her if:she had signed a membeiÈhiþ form.
She said she signed the fórm but did not pay a fee. She said she was nottôld rthat she
had to pay a'fee to join the Ontarìo PC ParÇ and said they did not tell her anything
about the'money. I asked her if she understood that she was joining the PC party and
she replied, "not really". I recorded my conversation with Mrs. Koshyk on my cell
phone.

48. On Novembei 17, 2016 at appiqximately 3.31 p.m., Gordon Dawson.and lattended at a
residènCe €t 1e Queénsland. l,spoke to a Woman who answerèd to the name of Mrs.
Kfyklywy. t ìntrô.duce.d myself as a¡ Ontario PC Nomination Candidéte, ln response to a
questiôn from r¡ê, shè 5aid shè:ùãs áwarê of the meeting ôn Mitridi¡y, November 21't, I

showed her the membership form and asked her if she had completed a membership
forÍì. She said she.did not.coÌnpleté thê form. She säid she, ditj not pay a fee. She
believed she likelydid not hãve to pay because ofthe "Ford donation thing" and years
ago she had Þaid."S10O or sòmething" for the bobblehead. Shesaid shefound out
about the. meeting:as a result of Doug Ford coming to her home, in her words "from
Dougz.. She said she did not remember filling out a form and she did not pay a fee. I
recorded my conversat¡on with Mrs. Krykìywy on her cell phone.

49. Dur¡ng the course ofmy canvas on November 17,2076,1 spoke w¡th 19 individuals who
are naned ¡n Ontar¡o PC Party membership ãpplicat¡ons submitted by Kinga Surma.
Fourteen of these n¡neteen individuals advised me that they had e¡ther not signed.a
membership form or paid a membership fèe or both.

SWORN BEFORE ME at the City of Toronro

ln the Prov¡nce of Ontario
This / t'tL ¿.Y of November, 2016

A CD¡¡¡ ov4-< r,(

¡tt tÇSi
D9V ts ê/h A.'Lefi/rôùrù
4 Aar-t s 7-zl<- i -çë,¿-/ c./ 70 ß-

I
:
 AFFIDAVIT

l, Gordon Dawson, of the C¡ty of Toionto, in the Province oJ Ontario, do soleninly sweai as
follows:

I rejide at 78 Farn¡ngham Crescent in the City of Toronto in the electoral district 0f

Etobicoke Centre.

2, D.uring the morning and afternoon of November 77, ZOf6,l went canvassing with Pina
Martino, a nomination candidate for the Ontar¡o PC Party ¡n.Etobicoke Centre

3, .On November 17, 2016 at approximately 11:23 am Pina Martino and I attended at a
residence at 36 Gentian; Pina spoke to a woman who answered to the name of Mrs.
Haeuserer. Pina introduced herseü as.anrOntar¡o PC Nominãtion Candidate, ln
response to a question froÍì Pina, she said,she was aware ofthe meetin8,on Monday,
November 21't and was planning on attending. Pina said that because she had signed
an Ontar¡o PC membershipform and'hed pa¡d her feé, she was eritítled to vote at the
meeting. Pina showed Mrs. Haeuserer a blank Ontario PC P¡rty.andshe sâid she signed
aform. Shecould not recall if shehadÞaidefee. P¡na alsógpoketo Mr. Haeuserei. He
sá¡d that he had signed the membership fÒrm. When asked, he said he did not pay a
fee. Fle said he does not wantto bè ã member. Hesaid.Doug Ford and Kiriga Surma told
h¡m about the meet¡ng. Pina explained the purpose of the nomination meeting and that
¡t was only.opên tò Ontàriô,gcParw members. Hè.sâíd hê did not wan?to côiìtribute
financially. When asked,hesaid he not pay fee atthetimethat hesigned fo-rm. Pina
read him the clause in the apÞlication, about payinB forthe membership fee from one's
own funds. He said Doug Ford phoned'and he committed himself and someone came
by the house. He said they did not ask for ànything. Lam aware that P¡ha was record¡ng
her conversation with Mr. & Mrs. Haeuserer on her cell phone.

4. on November 17, 2016'at approximately 11:55 â,m., Pina Martino and I altended at a
residence at 49 ftangoon, Pina spoke to a woman who answeied to the name:of Mrs,
Welegedera, Piña ¡ntroduced herself as an Ontario PC Nominat¡on Candidate. ln
response to a.question from Pina, she sa¡d she was aware ofthe meeting on Monday,
November 2Lsl: 'Pina:showed.her the membership form and asked her if she signed a
membershigform. 5hÞ saìd.,she did not sign the form. Shesêid she did notpäya fee.
She said.stté was not sure.if her husband had paid the fee Þr signèd the form fÒr her.
She said,Doug FOrd eAnEto hèr door. I am aware that Pina was rècordihg her
conversãt¡on with Mrs. Wélêgederaon her.cell phone.

On November 17,.20i6 at 1,2:08 pm, Pina Martino and I attended at a residence at 9.

Dimplef¡eid. P¡na spoke to. ã .man who answered to the name of Mr. Beauvais, Pina.
introduced herself ás an Ontario PC Nominat¡on Candidate. ln response to .a quést¡on
from Pina, he said he was aware of the meeting on Monday, November 21'r. Pina
showed him the membersh¡p form and asked h¡m if he signed a membership form and
 2

pe¡d ã fee.
He said he signed the form w¡th Doug Foid but did ñot pay anything. He said
Doug Ford d¡d not tell him that he had to pay. I ariì'aware that P¡na was recording her
conversation w¡th Mr. Beauvais on heÍ:cell phone.
'

6. On November L7,20!6 at approximately 12:48 pm., Pina Martino and lattended at a

res¡dence at 27 Littlewood. Pina spoke to a man who answered to the name of Mr.
Nenic. Pína introduced herself as an Ontario PC Nominat¡on Candidate. ln response to
a question from Pina, he said he was aware ofthe meeting on Monday, November 21't.
Pina showed him the membersh¡pform and asked him if hesigned.a membership form.
Hesaid hedid notsigntheform, He.seid he did not pay a fee. Hesaid hewasnot surè
6¿¡ if his wife had s¡gned the form, had paid the fee or signed the form for him. He said
Doug rord came to his door. í am aware that P¡na was recording her conversation with
¡iP
N Mr. Nenic on her cell phone.

on November 17,20i6 at approxlmately 12:55 p.m., Pinã Mãrtino aild I attended at a

rêsidence at 18 F¡resto'ne. Pina spokè to a wornan who ariswered to the name of:Mrs.
ÞÒnêgan. Pina introducêd herself ãi an Ontar¡o PC Nomination Candidate. ln response
to a q.ûèst¡on.from Pina; She.said she was aware of the meet¡ng on Monday, November
21i. Piña showéd her the mèälbership form and asked her if she.and her husband
signèd a membership form. She said she did not sþn the form. She said she did not pay
afee, She.saidshe did notkñowif herhusband hadsignedaform. I am aware that P¡na
was record¡hg her conversâtion with Mrs. Ðonegan on her cell phone.

8. On November 17, 2016 at.approximat€¡y 12:57 p¡m;, Pina Martino and I attended at a
residence at 33 Firestone. Pina spoketo a man Who answer€d to the name of Mr.
Castro. pìna introduced. herself as an Ontario PC Nomination Candidate. lri responsê to
a quest¡on from Pina, he said he was,aware of the meeting on Manday, Novembei 21n.
Pina,showed him the membership fotm-:and asked hìm if hesjgned ã rhembership form.
He said he signed it. Hè said he did not pay a feê. He said he Was not told there was a
fee. Lam aware that Pina was. recording her conve¡sat¡on with.Mr..Castio on. her cell
phone.

9. On Noveniþer L7, 2016 ât approximately 1:02 p.m., Pina Martino anij l.attended at a
residence at 68 Hollister. Pina spìke to a man who answered to the name of Mr.
O'Marra. P¡ña intrôduced hersèlfas an Ontaiio. PC Nomiñation Candidate. ln response
to a question fiom Pina, he said he was aware ofthe meet¡hg on Monday, November
.21s. P¡na shoi¡teil h¡ñ the rnembership form and. asked him if he signed the form and
he said he had not. He said he did.not pay a fee. He said Doug Ford came to his.door.
He said he was not home when Doug Ford came, Pina provided hiin with the phone
number for the Ontãr¡o PC Party Headquarters and told him so he could tell them that
he did not s¡gn,ã inembership form and could aók.to be removed from the party's
inembersh¡p l¡st. I am aware that Pina was recording her conversation with.Mr. O'Marra
on her céllphone.
 3

10. On Nóvember 17, 2016 at epproximately 2:46 p.m., Pina Mart¡rio and lattended at a
ies¡dence at 123 Crendon. Pina spoke to a woman who answered to the name of Ms.
McPhee. Pina introduced herself as an Oñtario PC Nominat¡on Candidate. ln response
to a quest¡on from Pina, she said she was aware of the meeting on Mondaç Nov.ember
21f. Pina showed hér the iryiembership form and asked her if she signed a membership
form. Shè saiiJ she signed the form. She sà¡d she did not þay a fee. She said that the
persori who bîòl.¡glit her the form to sign did not tell hei there was a fee to join the
Ontario PC Party. She,said they did not ask her for a fee. I am awáre that Pina was
.recording her conveísation with Ms..McPhee on hei cell phone.

11. On November 1.7, 2016at approximately 2:51 p.m., Pina Martino and lattended at a
residence at 25 West Wareside- Pina spoke to a woman who answered to the name of
Mrs, Klamann. P¡na ¡ntroduced herself as an Ontar¡o PC Nomination Candidate' ln
response to a question from Pina, she said she was aware ofthe meeting on Monday,
November 21s. Pina showed her the membership form and asked her if she signed a
membérsh¡p form. She said.she did.not s¡gn the fofm and perhaps her husband had
srgned ¡t. She called her husband to the door. Mn Klamanri said he signed the forr.n. He
sâid he did not pay a fee. He said someone canie to his door. He said:he did not jitin the
party. He sa¡d he did not iìltend on joining the Ontario PC Party and said why should I
pay, I ãrn.ãware that P¡na was recoid¡ng her convèrsatio.n with Mr. & Mrs' Klamann on
her cell phone.

.12. On Novembei 1¿ 2016 at aÞp.roxiniatel}l 3:15 p'm', Pina Maitino arid.l attended at a
residence at 12 'Reflova. Pine'9poke to a man Úho'answered to the nãme of Mr. Oblak,
Pinâ introduced hêiself as an Ontar¡o PC Nomination Candidate. ln response to a
qùestion from Piha, he said he was aware ofthe meeting on Monday, November 21"t.
Pinashowed him,the membership form and asked him if he had ligned a membership
form. He said he may have signed the form. He said he could not remember if he paid a
fee, He said someone came to h¡s. home and perhaps his wife had signed it. I am awãrc
that Pina was recording her conversation with Mr. Oblak'on her cell phone.

13. 0n November 17,20iþ at approximatqly 3:29 pm., Pina Martino and lattended at a
resi4ênce at Iquee¡slq¡d. Pina.spok9 to a woman who ianswered to the nâme of Mrs.
XoShik, Pina introduced- herself as an Ontario PC Nom¡nation Cand¡date. ln resporìse tg
a question from Pina, she saíd she was awafe of the.meet¡ngoiì Monday, November
21d.. Pina showed her the membership form and asked her if she had signed a
ûieñbèlsh¡p form. She said she signed the form but díd not Þãy'a fee. She said she was
not told that she had to pay a fee to join the onterio PC Party and said they did not tell
her anything about the riìgney. She was asked by Pina if she understood that she was
joining the PC party and replied not really. lam aware that Pina was recording her
conversation w¡th Mrs. Koshyk on her cell phoile.

14. On November 17, 2016 at approximately 3.31p.m., Pina Martino and I âttended at â
residence at 12 Queensland, Pina spoke to.a woman who answered to the name of Mrs'
 4

Kryklywy. Pina introduced herself as an Ontario PC Nomination Candidate. ln response

to a questioil from Pina, she- sâíd she was aware of the meeting on Monday, Novembêr
2ft. Pina showed herthe membership form arid aÉked her if she had completed a
membership form. She said she.did not complete the form. She s¡¡id she did not pay a
fee. She believed she likely did not have to pay because ofthe "Foid donation thing:'
and years agò she had paid "51o0 or something" for the bobblehéad. She said she
found out about the meeting as a result of DouB F.ot'd coming to her home, in her words
'Trom Dou8j'. She said she did not remember filling out a form and she did not pay a fee.
i am awarethat Pina was recording her conversat¡on with Mrs. Kryklywy on her cell
phone'.

SWORN BÉÍORE ME at the City of Toronto

ln the Province oî Antario this ,/'7 *
Day of November, 2016

/n Cornm,s€/ùv&- Ev'L .
D&tt¡ çÉ ¡r./? Ar¿ øt ¿t z- ¡*¡z-)
M re r¿t çz€¡€ ì,fact ei 7ð <-
 AFFIDAVIT

l, Doretta Wilson, of the C¡ty of Toronto, in the Prov¡nce of Ontario, do solemnly swear as
follows:

I reside at 57 Twyford Road in the City of Toronto in the electoral d¡sti¡ct of Etobicoke
Centre.

Duringthe afternoon ofNovember 16,2016, lwènt canvassing with Pina Mãrtino, a

non¡nAtion candidate for the Ontario PC Party in Etobicoke Centre

I On NÒvêmber 16, 20!6 P¡na Martino and I êttended at à res¡dence at 42 D¡xfield. Pina
spoke to a womán who answered to the name of Phyllis Samaroo. Pina introduced
herself as an Ontario PC Nomination Candidate. ln response to a question from Pine,
she said she was aware of the meeting on Mondaí November 21't. Pina said that
because she had signe¡J an Ontario PC membership form and had paid her fee, she was
ent¡tled to vote at the meeting. Pina showed Phyllis Samaroo a blank Ontario PC Party
an she said she signed a form. She said a lady came to see nefff\þe signed a form but TÂ/
she did not know what she had signed. Pina asked her if the laffi"who came to see her
wéS nâmed Kinga Surma and shê sãid did not know. Pina aiked her if she paid,an¡hing
and Ms. Samaioosaid she did not.pav anything. Pina asked her if the lady who.cðme to
seè hêr asked her to pay a S10 or 515 fee and Miss Samaroo sa¡d she did not say
anyth¡ng about paying. I am awargthat P¡na was recordin8-her conversation with Miss
Samaroo on her cell phone. The audio recording is an accurate account ofthe
conversâtion that took place between Pina Martlno and Phyllis Samaroo.

On November 16,2Ot6, Pina Martîno and I attended at a residence at 56 3¡rgitta. Pina

spoke to a man who answered to the name of Mr. Vergara. Pini¡ íntroduced herself as
an Ontârio PC Nom¡nation Candidate. ln response to a question frotn Pina, hê sãìd he
was ãware.of the meeting on Monday, November 21rt. Pina Showêd him the
membership form and asked him if he,signed a membersh¡p form; Hè,.said he Si8ned it.
Pina asked hiin if he paid S10 or S15 and he said he did not pay anything. She asked him
who cäme to see hìm to fill out the fôrm and he said it was Doug Ford and K¡nga Surmã
who had come to see him and they registered him arid his son to vote. He sa¡d thèy did
not ask him to pay $t0 or stS. Pina asked hÌm if they told him that he had to pay a fee
of S1O or $15to join the ôntario PC Party and he said they did not tell h¡m anything. f am
aware that Pina was recording her conversation wìth Mr. Vergar:a on her cell phone.
The audio recording is an accùrate account of the conversat:Oñ betweeh Pina Martino
and Mr. Vergara.

On November 16, 20i0, Pina Martino and lattèndéd,at a residén¿e aT:119 Birgitta. Pina
spoke to a.man Who answered tij the name of Mr. Fóon. Pina iñtroduced herself as an
Ontario PC Nom¡natioä Cand¡dãte. lñ response to a question. from Pina, he said he was
aware of the meetlng on Monday, November 21"t. Plna showed hlrn the iîembershtp
form and asked him if hesigned a membership form arid paid a fee. He said he did not
s¡gn anyth¡ng and d¡d not ftay ãnything. Pina asked hiim who told him about the
meeting. He replied thât it was Doug Ford. pina asked him if he was asked to pay a S10
or S15 membership fee and he said he did not pay anything. He said he could not afford
to pay anwh¡ng.

SWORN BEFORE M E at the City of Toronto

lh the Province of Ontario this/fiL
Day of November, 2016

(n ,o-.ncçt è^J& 6.<- rru.truo

Arctrt 6.a) n3 )