Date: 19980309
Docket: T-1636-81
T-3150-92
T-956-93
BETWEEN:
T-1636-81
JOE MATHIAS and the SQUAMISH INDIAN BAND et al.
Plaintiffs,
- and -
HER MAJESTY THE QUEEN et al.
Defendants.
And Between:
T-3150-92
CHIEF WENDY GRANT and the MUSQUEAM INDIAN BAND et al.
Plaintiffs,
- and -
HER MAJESTY THE QUEEN IN RIGHT OF CANADA et al.
Defendants.
And Between:
T-956-93
LEONARD GEORGE as Chief,
and the BURRARD INDIAN BAND et al.
Plaintiffs,
- and -
HER MAJESTY THE QUEEN IN RIGHT OF CANADA et al.
Defendants.
REASONS FOR ORDER
on the motion concerning the admissibility
of the Berger and Satzewich Expert Reports
SIMPSON, J.
[1] In this motion, the Crown contests the admissibility of two expert reports filed pursuant to Federal Court Rule 482(1) on behalf of the Squamish Indian Band (the "Squamish"). One such report, dated November 28, 1997, is authored by Mr. Thomas R. Berger, O.C., Q.C. (hereafter described as the "Berger Report"). The other report in issue, dated November 27, 1997, is written by Dr. Victor Satzewich (hereafter referred to as the "Satzewich Report"). I will consider each report in turn.
THE BERGER REPORT
[2] Mr. Berger is an acknowledged expert in the field of native law who was asked to provide an opinion about:
| ...the advice a reasonably diligent Indian client would have received from a competent lawyer in respect of: |
| a) causes of action that could be asserted against the Crown with a reasonable prospect of success, in particular with respect to the issue of breach of fiduciary duty, and |
| b) practical and legal difficulties which would be faced by a band in bringing an action against the Crown seeking relief in respect of alienated reserve lands, |
| during the period from 1927 to 1951, and the period from 1952 to the date of the decision of the Supreme Court of Canada in Guerin v. the Queen (1984), 13 D.L.R. (4th) 321 (S.C.C.). |
[3] Counsel for the Crown submits that the Berger Report is, in reality, a review of legal history followed by analysis and legal argument . This is so, he submits, even though the report is presented in the form of an opinion about what a competent lawyer could have been expected to have advised a reasonably diligent Indian client. The Crown's position is that the Berger Report is of no assistance to the Court because all it says, in substance, is that a competent lawyer could have been expected to have known the state of the law at the time a legal opinion was sought. Counsel for the Crown further submits that all the matters in the Berger Report can be dealt with in argument by counsel for the parties at the end of Phase Two of the trial. In this regard he says that, once the relevant law is presented, counsel are entitled to ask the Court to draw conclusions about what a competent lawyer could have been expected to have known and advised based on that law. He adds that the appearance of justice and the integrity of the trial process will be damaged if an advocate of Mr. Berger's undisputed stature and expertise is permitted to present legal argument while cloaked with the authority of an expert witness.
[4] On the other hand, counsel for the Squamish (supported by counsel for the Musqueam and Burrard Indian Bands) takes the position that evidence from an expert practitioner is admissible to show how lawyers could have been expected to have advised their clients based on the lawyers' perception of the law at a particular time. Counsel for the Squamish further submits that Mr. Berger's statements about what the cases and statutes said are not provided as evidence of the actual state of the law. Rather, the Court is asked to treat the evidence as indicating what a practitioner would have perceived or understood the law to be. As well, counsel says that the evidence in the Berger Report is relevant because is bears on the issues of acquiescence and laches. In particular, it relates to the question whether it was objectively reasonable for the Squamish to have been unaware of their legal rights as they allege was the case. Counsel argues that the evidence in the Berger Report to the effect that legal practitioners had no idea that such rights existed supports the objective reasonableness of his client's position.
[5] The most recent expression of the test governing the admissibility of expert evidence is found in R. v. Mohan, [1994] 2 S.C.R. 9 at page 20. There the Supreme Court of Canada said:
| Admission of expert evidence depends on the application of the following criteria: |
| (a) relevance |
| (b) necessity in assisting the trier of fact; |
| (c) the absence of any exclusionary rule; |
| (d) a properly qualified expert. |
[6] The principle that expert evidence must assist the trier of fact was discussed in earlier cases. For example, in R. v. Béland, [1987] 2 S.C.R. 398 at 415, McIntyre J. speaking for the Court, said:
| The function of the expert witness is to provide for the jury or other trier of fact an expert's opinion as to the significance of, or the inference which may be drawn from proved facts in a field in which the expert witness possesses special knowledge and experience going beyond that of the trier of fact. The expert witness is permitted to give such opinions for the assistance of the jury. Where the question is one which falls within the knowledge and experience of the triers of fact, there is no need for expert evidence and an opinion will not be received. |
(my emphasis)
[7] As well, a prohibition against argument being presented through an expert witness is well established. In Yewdale v. Insurance Corp. of British Columbia, 3 B.C.L.R. (3d) 240 at 243 (B.C.S.C.), Newbury J. (as she then was) expressed the law in the following terms:
| 4. Given the special privilege accorded to experts to testify as to their opinions, they must not become advocates. They must express their opinions as opinions and must leave for the court the required conclusions of law. In theory at least, the court "knows the law" - in practise it has the responsibility of finding and applying it. Thus the expert should express his or her opinion in an objective and impartial manner, and must not present argument in the guise of expert evidence. |
| (my emphasis) |
[8] The prohibition against argument is also discussed in Surrey Credit Union v. Willson, 45 B.C.L.R. (2d) 310 at 314 (B.C.S.C.), where McColl J. noted that:
| Expert opinions will be rendered inadmissible when they are nothing more than the reworking of the argument of counsel participating in the case. Where an argument clothed in the guise of an expert's opinion is tendered it will be rejected for what it is. |
| (my emphasis) |
[9] I have carefully reviewed the Berger Report and have concluded that, in large measure, it consists of legal argument. For this reason, it will not assist me in carrying out my duties as a trier of fact. I have reached this conclusion based on the following analysis of the opinions expressed in the Berger Report:
| " The report begins with a discussion of section 141 of the Indian Act , R.S.C. 1927, c. 98, and, on page two, provides the following opinions: |
| Section 141 is a statement of Parliamentary policy to (sic) which would have made it unlikely that any band would ever have visited a lawyer's office, let alone been in a position to provide a retainer. |
| ... |
| But one cannot imagine that Indian bands would not have been inhibited by this provision, indeed would have regarded it as if it were a prohibition. |
| ... |
| This would have operated as an effective bar to any Indian band retaining a lawyer for an opinion, let alone commencing an action. No effective right to take action in truth arose until this section was repealed in 1951. |
| In my view, these opinions are conclusions about the probable effect of the provision and appear to be based entirely on an interpretation of the language of the section. An analysis of this kind can be undertaken by the Court without expert assistance. The situation would be far different if the Berger Report had drawn on its author's experience as a practitioner and had said, for example, that consent of the Superintendent General was never sought under section 141, or, if sought, was routinely refused, or if the report had stated that section 141 was well known to practitioners and native people and had a chilling effect on litigation. |
| " On page 4 of the Berger Report, the author concludes that Kinlock v. Secretary of State for India (1882), 7 App. Cas. App. C.A.S. 619, was the relevant law and would have been relied on by an ordinary lawyer. In my view, this is legal argument in the guise of opinion. |
| " On page 5 of the Berger Report the following opinion appears: |
| The judgment in Tito v. Waddell (No. 2) (1977), 3 All. E.R. 129 bears out that conventional line of thinking. |
| This statement is made with reference to the Kinlock case. I have concluded that it is pure legal argument. |
| " The same can be said of the following statements of opinion which also appear on page 5: |
| In any event, even if a lawyer had been consulted and if he had been drawn to the U.S. cases and a theory of legal trust, such is not and never has been a proper cause of action in Canada in relation to a surrender of reserve land. |
| A trust relationship depends on a property interest. A fiduciary obligation depends on the nature of the relationship between the parties. |
| " The two paragraphs below appear on page 7 of the Berger Report. In my opinion, they are also legal argument. |
| In the end, in Calder, and the cases which follow it, the idea of Aboriginal rights was adopted and is now part of Canadian law. It sprang from the great judgments of Chief Justice Marshall: Johnson v. McIntosh 21 U.S. Wheat 543 (1823); Cherokee Nation v. Georgia 31 U.S. (5 Pet.) 1 (1831); Worcester v. Georgia 31 U.S. (6 Pet.) 515 (1832). We know now, since Guerin, that a claim may be made for breach of fiduciary obligation. The related idea, springing from Aboriginal rights, of fiduciary obligation, as developed in Guerin, was not founded on U.S. jurisprudence. |
| In fact, the idea of Aboriginal rights in Canadian law was reasonably well established in 19th century cases. Nevertheless, it was rejected explicitly by the B.C. Court of Appeal in Calder v. A.G.B.C. (1970), 13 D.L.R. (3d) 64. |
| " On page 8 of the Berger Report, the first full paragraph and the third, fourth and fifth paragraphs read as follows: |
| Before 1984, if an Indian band had asked a lawyer of ordinary competence to advise in respect of possible causes of action it is most unlikely that such a lawyer would have advised that the band could pursue a cause of action on the basis of a breach of a sui generis fiduciary obligation, founded on Aboriginal title and the inalienability of Indian land. |
| ... |
| The Supreme Court of Canada developed the theory of sui generis fiduciary obligation. |
| The Supreme Court's judgment in Guerin came after the most extensive argument at three levels of the judicial hierarchy. Eight judges of the Supreme Court considered the matter. Three judgments were written by members of the Supreme Court. |
| The process itself yielded the new cause of action. |
| In my view, these passages are, in substance, legal argument which deals with the effect of Guerin v. The Queen (1984), 13 D.L.R. (4th) 321 (S.C.C.). They do not address a practitioner's perception of the law except to say that Guerin was the law in 1984 and Guerin's principles were not known before that date. There is no suggestion that a practitioner's advice would be anything other than a reflection of the then existing law. The Court does not require expert assistance on this matter. It can be dealt with by counsel in argument. |
| " On page 8, the Berger Report also deals with the period before the Supreme Court of Canada decision in Calder v. A.G.B.C. (1973), 34 D.L.R. (3d) 145 (S.C.C.) and provides an opinion about whether it would have been reasonable to expect a lawyer to prepare a sui generis argument of the kind developed in Guerin,either before the Supreme Court's decision in Calder or in the post-Calder and pre-Guerin period from 1973 to 1984. The report states: |
| To expect a lawyer before 1973 to have crafted such an argument would be unreasonable, since one of the elements of the cause of action, Aboriginal title, was not generally acknowledged to be part of Canadian law prior to the judgment of the Supreme Court of Canada in Calder. Even after 1973, it would be unreasonable to expect a lawyer to join the Aboriginal title with inalienability of Indian land. |
| Again, it is my view that this is argument about the state of the law in the guise of an opinion about what a practitioner could have been expected to know. |
| " On page 9, the Berger Report includes the following statements of opinion which, in my view, are also argument: |
| The precise nature and extent of the new law of fiduciary obligation is still unfolding: |
| Dickson J. said in Guerin that the duty arose after a surrender had been obtained by the Crown. It is still unclear to what extent a fiduciary obligation may exist pre-surrender. |
| But the precise scope and extent of this pre-surrender duty is by no means clear even today. |
| " Finally, at page 10, the Berger Report provides an illustration of the type of pleading that was filed by a native rights specialist in 1978. This is helpful but should properly be presented in argument at the conclusion of Phase Two of the trial. |
[10] The Berger Report illustrates the difficulty that may arise when a legal expert files an expert report providing an opinion directed to an ordinary practitioner's perception of the law. When, as in this case, the expert concludes that the case law and statute law of the time would be the law relied on by an ordinary practitioner, the opinion will be of little assistance to the Court because it is grounded entirely in the law. It is also inevitable that such an opinion will take on the characteristics of a legal argument.
[11] There are, however three aspects of the Berger Report which are properly the subject of expert evidence. They are not legal argument and could potentially assist the trier of fact. They are:
| " On page 3, the Berger Report advises that, in the 1950's, the law school at the University of British Columbia did not offer courses on the rights of native peoples or Indian bands. The report also notes that the first text on native rights did not appear until 1970. These facts support Mr. Berger's opinion that the repeal of section 141 of the Indian Act , in 1951, did not provide an effective right to take action. |
| " On page 5 of the report, Mr. Berger indicates that it was not common for lawyers in British Columbia to rely on American authorities prior to the Guerin case. |
| " On pages 7 and 8 of his report, Mr. Berger expresses the opinion that the words of Mr. Justice H.W. Davey (as he then was) in the British Columbia Court of Appeal in Calder v. A.G.B.C. (1970), 13 D.L.R. (3d) 64, exemplified the attitude of the legal profession towards the rights of Indians and Indian bands at that time. |
[12] It is my conclusion that the Berger Report is inadmissible in its entirety because, as illustrated above, it is largely comprised of statements of the law which will not assist the trier of fact. It will be for counsel for the Squamish to decide whether to file a brief amended expert report which may include only the three points which I have determined to be proper expert evidence.
THE SATZEWICH REPORT
[13] Dr. Satzewich is a sociologist who was asked by counsel for the Squamish to provide evidence about the general policies and practices of the Federal Department of Indian Affairs (the "Department") from an historical perspective. In particular, he was asked to respond to the following questions:
| (i) What were the duties and practices of Indian Agents, or other officials of the Department of Indian Affairs, with respect to the conduct of Band Council business, eg. setting agendas, presiding at meetings, drafting resolutions, preparing minutes, etc. If these duties changed through time, please provide details. |
| (ii) Were the duties of Indian Agents, or other officials of the Department of Indian Affairs, to represent the Indians, as opposed to representing the Department? If the agent was to represent both, how were conflicts resolved? Was it the duty or practice of Indian Agents to require or encourage Bands and Band Councils to follow policies of the Department, implement decisions of the Department, etc.? |
| (iii) What was the extent of reliance of Bands and Band Councils on the Indian Agent, or Departmental Officials? To what extent did Bands or Band Councils act autonomously with respect to the administration of reserve lands and related matters? |
[14] The Crown, in its opposition to the Satzewich Report, says that it is inadmissible on the basis that the historical evidence which is presented does not relate to any of the issues in this case. In the alternative, the Crown submits that, if the report contains anything of relevance, it is minimal and prejudicial, and the report should be inadmissible because whatever probative value it may have is greatly outweighed by its prejudicial effect.
[15] Counsel for the Squamish concedes that the Satzewich Report does not deal with any of the specific issues before the Court in this case, and that it does not even mention the Indian bands which are the parties in this action. In addition, the Satzewich Report contains only one reference to a Departmental official acting in the capacity in which he appears in this case. That official is Agency Superintendent Letcher, and Dr. Satzewich notes that he insisted on being addressed as 'Captain Letcher' by Indian people in his agency and by his co-workers. There are other references in the Satzewich Report to Departmental officials who appear in the case at bar. However, at the time of the references, they were serving in jurisdictions unrelated to this action.
[16] The Satzewich Report is offered as general historical material to show how Departmental officials conducted Indian affairs and how they related to Indian bands across Canada. It is acknowledged by counsel for the Squamish that the Satzewich Report is not proof that the general Departmental and Indian agent practices it describes were in fact applied in dealings with the parties in this case. However, it is submitted by counsel for the Squamish, with the support of counsel for the Burrard Indian Band, that the general practices revealed in the Satzewich Report are relevant and admissible because they provide an historical context that may help the Court understand the documentary evidence which is filed in this case. Finally, counsel for the Squamish takes the position that the Crown's objections to the Satzewich Report go to the question of the weight of the evidence rather than to the issue of its admissibility.
[17] The Satzewich Report is divided into two parts which are described by its author in these terms:
| Part one presents some background information on the place of the Indian Agency within the administration of Indian Affairs in Canada, the methods by which Indian Agents were appointed and the general roles and responsibilities of Indian Agents. Part two examines the role that Indian Agents played in relation to band councils and begins by considering the Departmental policy objectives in relation to their formation and operation. It then goes on to analyze the way in which the power to depose chiefs and councillors was used by the Department of Indian Affairs in the early part of this century, the powers of the band council, and the duties of Indian Agents with respect to band council business. Part two concludes with a discussion of in whose interests Indian Agents were expected to act, and how contradictions between competing interests were resolved within Indian Affairs. |
[18] In part one, the Satzewich Report indicates that, between 1900 and 1970, the number of Indian agencies and Indian agents in Canada varied between 100 and 110. The agencies in British Columbia are said to have been different from the rest of Canada in that one agency would administer a larger number of reserves than would be the case elsewhere in the country. For example, in 1938, 16 agencies with 16 Indian agents administered over 1600 reserves in British Columbia.
[19] Part one of the Satzewich Report also describes the method of appointing Indian agents and the roles that political patronage, religious politics and the Federal Government's post-war veterans preference policy played in the selection of Indian agents. With regard to the duties of Indian agents, the Satzewich Report notes that, while the duties in part depended on local circumstances and conditions, an overall picture of agents' duties can be gleaned from the provisions of the Indian Act and from job descriptions found in the Department's files. In 1933, general instructions were prepared for Indian agents. These are already in evidence in this case. Later, in 1946, a field manual was prepared for the use of agents. It is also in evidence.
[20] Part two of the Satzewich Report examines the relationship between the Department, Indian agents and band councils in the context of the following issues:
| 1. The imposition of an elective system of band governance; however, Dr. Satzewich notes that this policy was not aggressively pursued in British Columbia. |
| 2. The deposing of chiefs and councillors across Canada. In British Columbia four chiefs were deposed and, in footnote 54, Dr. Satzewich notes that far fewer chiefs were removed in British Columbia than elsewhere in Canada. |
| 3. The powers of band council. Dr. Satzewich acknowledges that the extent to which individual councils exercised their powers varied from band to band. The examples under this heading are taken from British Columbia and deal with: |
| " a Departmental refusal to provide the Metlakatla band council with travel money for further meetings with the Indian agent in Prince Rupert. |
| " a Departmental refusal to allow the Metlakatla band council to purchase English bone china despite of the Indian agent's support for the purchase. |
| " the Department's slow response to a Metlakatla band council request to purchase a generator and wiring for houses on the reserve in spite of the Indian agent's support for the purchases. |
| " the construction of a public wharf on the East Saanich Indian reserve on Vancouver Island, which was blocked by the Department and the Indian agent against the wishes of band council. |
| 4. The activities of Indian agents and Departmental officials. Under this heading, Dr. Satzewich provides information about the following events: |
| " in 1944 an Indian agent at Massett in the Queen Charlotte Islands called a band council meeting to secure council's approval for the removal of trespassers living on the reserve. |
| " in 1899 an Indian agent formed a band council for the China Hat band to approve rules for "moral" conduct. |
| " in 1919 an Indian agent in Kamloops called a meeting of band council to deal with the marital problems of a newly elected chief. |
| " in 1910 the Indian agent and the Department became deeply involved in the election of a chief for the Penticton band. |
| " the Department refused to support the Kamloops band council's wish to depose a councillor for his work for the Allied Tribes of British Columbia. |
| " in the mid-1920's Chief Johnny Chillihitza of the Kamloops band was working on behalf of an organization called the Interior Tribes of British Columbia. He apparently described himself as the chief of the whole interior of British Columbia and he collected money from Indians to pay for a trip he planned to take to visit the King of England. The Department and the Indian agents tried to curb his activities. The Department considered deposing him but did not do so. |
| " the Department and Indian agents dealt with conflicts of interest between the Department and Indian people, and between the Department and interests within Euro-Canadian society, such as 1) a problem with power lines over the Penticton reserve; 2) a problem with complaints against the chief of the Kamloops band and the Indian agent; 3) a problem relating to an effort to relocate the Kamloops band; 4) the problem of how to deal with dance halls on the Port Essington reserve; 5) the problem of how to respond to community dissatisfaction when Indians near Chilliwack leased land to Chinese farmers; and 6) a problem which arose when an Indian agent allowed non-natives to bribe Indians to encourage them to surrender land (the Department reversed the surrender). |
[21] I have described the contents of the Satzewich Report in order to illustrate my conclusion that it is of virtually no relevance to the issues, or to the parties, or to the Departmental officials who dealt with the parties in this case. What is clear to me from the Satzewich Report is that the outcome of any interaction between the Department, the Indian agents and band councils depended on a variety of factors which included:
| - the personalities of all those involved (there were approximately 100 Indian agents at any time) |
| - the problem at issue |
| - the workload of the Indian agents |
| - the year in question |
| - the sophistication of the Indian band council involved and whether it was an elected body |
| - the geographical location of the band - it having been made clear that the situation in British Columbia was often different from that in other parts of the country |
[22] In view of these considerations, I am not at all sure that the Satzewich Report reliably establishes any Departmental practices as suggested by counsel for the Squamish. However, even if practices are established, it is acknowledged that they do not relate to any of the specific issues before me. As the Supreme Court of Canada said in R. v. Mohan, supra, at page 20, "Relevance is the threshold requirement for the admission of expert evidence...". When this passage is applied it is clear that the Satzewich Report is generally inadmissible, because none of the examples of Departmental conduct it contains relate to any issues in this case.
[23] The question remains whether the Satzewich Report should be admissible because it may contain opinions which bear on matters of general historical context, even though the examples used to illustrate the opinions are irrelevant. An oft-repeated theme in the Satzewich Report is the fundamental conflict between how the Department and Indian agents viewed the best interests of native peoples compared to how native peoples themselves defined those interests. Dr. Satzewich criticizes the Department and concludes that it consistently considered its own interests to be identical to the best interests of the native peoples under its charge. In Dr. Satzewich's view, when the Department and/or the Indian agents acted under this false assumption, they failed to protect the best interests of the native people. Presumably this underlying theme of the report is an important part of the "general historical context", that the Squamish want the Court to consider. However, the opinions and conclusions expressed by Dr. Satzewich in his report are all based upon illustrations which, in addition to being irrelevant in respect of the issues and parties before this Court, are not even similar to the events in this case. Accordingly, I have determined that the conclusions expressed in the Satzewich Report about the Department's approach to native affairs are of minimal relevance and cannot be reliably applied to the issues before me.
[24] It is also my view that the admission of the Satzewich Report into evidence will unduly extend an already lengthy trial to no valuable purpose. I accept the Crown's submission that, if the Satzewich Report is admitted, a lengthy cross-examination will be required to test Dr. Satzewich's examples and his conclusions. The trial time needed to accommodate this report is not commensurate with its value. In this regard, I again rely on the Supreme Court of Canada's decision in R. v. Mohan, supra, in which it stated at pages 21-22:
| Relevance is a matter to be decided by a judge as question of law. Although prima facie admissible if so related to a fact in issue that it tends to establish it, that does not end the inquiry. This merely determines the logical relevance of the evidence. Other considerations enter into the decision as to admissibility. This further inquiry may be described as a cost benefit analysis, that is "whether its value is worth what it costs." See McCormick on Evidence (3rd ed. 1984), at p. 544. Cost in this context is not used in its traditional economic sense but rather in terms of its impact on the trial process. Evidence that is otherwise logically relevant may be excluded on this basis, if its probative value is overborne by its prejudicial effect, if it involves an inordinate amount of time which is not commensurate with its value or if it is misleading in the sense that its effect on the trier of fact, particularly a jury, is out of proportion to its reliability. |
[25] For all these reasons, I have concluded that an order will be made striking out the Satzewich Report in its entirety without leave to amend.
(Sgd.) "Sandra J. Simpson"
Judge
VANCOUVER, BRITISH COLUMBIA
March 13, 1998
NAMES OF COUNSEL AND SOLICITORS OF RECORD
STYLE OF CAUSE:
T-1636-81
JOE MATHIAS et al.
- and -
HER MAJESTY THE QUEEN et al.
- AND -
T-3150-92
CHIEF WENDY GRANT et al.
- and -
HER MAJESTY THE QUEEN et al.
- AND -
T-956-93
LEONARD GEORGE et al.
- and -
HER MAJESTY THE QUEEN et al.
PLACE OF HEARING: Vancouver, B.C.
DATE OF HEARING: March 9, 1998
REASONS FOR ORDER: SIMPSON, J.
DATED: March 13, 1998
APPEARANCES ON THE MOTION:
Mr. John Rich for Squamish Indian Band
Mr. Gregory McDade, Q.C.
Mr. Malcolm Maclean for Musqueam Indian Band
Ms. Candice Metallic
Mr. Stan Ashcroft for Burrard Indian Band
Ms. Christine Sweet
Mr. Geoffrey Cowper, Q.C. as agents for HMQ
SOLICITORS OF RECORD:
Ratcliff & Co. for Squamish Indian Band
North Vancouver, B.C.
Blake, Cassels & Graydon for Musqueam Indian Band
Vancouver, B.C.
Ganapathi, Ashcroft for Burrard Indian Band
Vancouver, B.C.
Russell & DuMoulin as agents for HMQ
Vancouver, B.C.
George Thomson for HMQ
Deputy Attorney General
of Canada