00 Production Orders and Warrants

Canada
RCMP FUe:
ONTARIO
SUPERIOR COURT OF JUSTICE
(Toronto Region)
IN THE MATTER OF an application for a Production Order pursuant to section
487.012(1) of the Criminal Code.
AND IN THE MATTER of an application for Assistance Orders pursuant to section
487.02 of the Criminal Code
PRODUCTION ORDER
TO: Sergeant Gordon Aristotle
TO: Scott Hutchison
TO: Wayne Doney
UPON READING the information on oath of Sergeant Gordon Aristotle, a Peace Officer,
and a member of the Royal Canadian Mounted Police in the Province of Ontario, dated
March 4, 2015;
AND UPON BEING SATISFIED that the requirements of section 487.012(1) of the
Criminal Code have been met;
AND UPON BEING SATISFIED that there are reasonable grounds for believing that the
following offences have been committed, namely:
Section
Section
Section
Section
Section
322 Theft Criminal Code:

336 Criminal Breach of Trust Criminal Code;
380 (1) Fraud Criminal Code;
462.31 Laundering the Proceeds of Crime Criminal Code; and
341 Fraudulent Concealment Criminal Code.
AND UPON BEING SATISFIED that the following data will afford evidence of the said
offences:
a. Copies of emails from the Ontario Provincial Police Association (OPPA)
email accounts of Karl Walsh, Jim Christie and Martin Bain contained on
One Memorex DVD labelled 2014 Email backup JC; One Memorex
DVD labelled Oct 2014 Email backup KW MB; and One Kingston Data
Page 1 of5
AND THAT the following Independent Certified Forensic Examiner (ICFE) be appointed
to assist the Police and the Chief Referee in the search, and seizure of the data:
Wayne Doney
Digital Evidence International Inc.
400 Queens Ave., London, Ontario
SPECIAL CONDITIONS FOR THE PRODUCTION ORDER:
I.
Sergeant Gordon Aristotle will seize the data from Detective Inspector Avery.
The data will be sealed and will not be examined by the police. The data will be
delivered to the ICFE as soon as reasonably practicable.
II.
The ICFE will receive the seized data from the police. If possible, the ICFE will
image the data to create a sound duplication.
Ill.
The ICFE will conduct keyword searches on the data or the images of the data.
The list (s) of key words will be supplied to the ICFE by Sergeant Gordon
Aristotle or his designate. The ICFE will provide the results of the key word
searches to the Chief Referee.
IV.
The ICFE will maintain continuity, security, and store the data and the images of
the data, until the forensic examination is completed. Upon the completion of
the forensic examination the ICFE will deliver all the data and any copies or
images thereof to the custody of the Chief Referee.
POST SEIZURE DUTIES OF THE CHIEF REFEREE:
V.
The Chief Referee will receive the data from the ICFE. Upon receipt, the Chief
Referee will maintain continuity and security, and be responsible for the storage
of the data until otherwise ordered by the Court.
VI.
The Chief Referee will examine the data and assert solicitor-client privilege if
applicable.
VII.
If the Chief Referee does not assert privilege over any data it will be released to
the police as soon as reasonably practicable. The Chief Referee will contact
Sergeant Aristotle, and make arrangement for the release of the data.
VIII.
In the case of any data where privilege has been asserted, the Chief Referee will
separate the data into three categories, and prepare a report that will provide the
Court with rationale why the data:
1. In the opinion of the Chief Referee is not protected by solicitor client
privilege.
Page 3 of 5
2. In the opinion of the Chief Referee may be protected by solicitor clientprivilege.

3. In the opinion of the Chief Referee should be protected by solicitor clientprivilege.
IX.
The Chief Referee will be responsible for notifying clients who have been
affected by the execution of the search warrants, or whose data have been
seized pursuant to the search warrants. This notification will occur as soon as
reasonably practicable following the execution of the search warrants and may
include advising clients of:
a.
The seizure of any of their data;
b. The risk to their privilege interests by the investigative or prosecutorial

authorities;
c. The existence of a conflict of interest if one has arisen;
d. The right to seek and obtain legal advice and legal representation;
e. How solicitor-client privilege may be asserted;
f.
How to request a hearing to determine any issue of privilege by the Court;

and
g. Any other information to assist them in protecting their interests as a result

of the search for and seizure of their data.
X.
The Chief Referee may notify the clients either verbally or in writing and may
request the assistance of the Police in the notification process. In the event that
clients cannot be notified after all reasonable attempts, the Chief Referee may
take steps that will afford continued protection of the clients solicitor-client
privilege, including responding to the Crowns application to gain access to the
seized material, or bringing a motion to have the privilege issues adjudicated by
the Court.
DATED this
5 day of Ma
01
eCitoorontoin the Province of Ontario.
Judge of the Superior Court of Ontario

JUSTICE NDRDHEJME
Page 4 of 5
ONTARIO
(Toronto Region)
IN THE MATTER OF an application for a

Production Order pursuant to section
AND IN THE MATTER of an application
for Assistance Orders pursuant to section
PRODUCTION ORDER
Sergeant Gordon Aristotle

Royal Canadian Mounted Police
345 Harry Walker Parkway South
Newmarket, ON
Page
Canada
ONTARIO
(Toronto Region)
ROMP FHe:

PRODUCTION ORDER
TO: Sergeant Gordon Aristotle
TO: Scott Hutchison
TO: Wayne Doney
UPON READING the information on oath of Sergeant Gordon Aristotle, a Peace Officer,
and a member of the Royal Canadian Mounted Police in the Province of Ontario, dated
March 4, 2015;
AND UPON BEING SATISFIED that the requirements of section 487.012(1) of the
Criminal Code have been met;
AND UPON BEING SATISFIED that there are reasonable grounds for believing that the
following offences have been committed, namely:
Section
Section
Section
Section
Section
322 Theft Criminal Code:

336 Criminal Breach of Trust Criminal Code;
380 (1) Fraud Criminal Code;
462.31 Laundering the Proceeds of Crime Criminal Code; and
341 Fraudulent Concealment Criminal Code.
AND UPON BEING SATISFIED that the following data will afford evidence of the said
offences:
1. Backups of OPPA email mailboxes utilized by Martin Bain, Karl
Walsh and James Christie to locate emails pertaining to:
i. Association, ownership or control over any company by the Ontario
Provincial Police Association (OPPA), Karl Walsh, Jim Christie,
Page 1 of 5
Martin Bain, Kiara Kozak, Noel Francis Chantiam, or Andrew

McKay;
ii. Investment or ownership by the OPPA, Karl Walsh, Jim Christie,
Martin Bain, Klara Kozak, Noel Francis Chantiam, or Andrew
McKay in investments including but not limited to: real property,
corporations, securities, and bank accounts;
iii, Any business transaction made by the OPPA, Karl Walsh, Jim
Christie, Martin Bain, Klara Kozak, Noel Francis Chantiam, or
Andrew McKay;
iv. Communication between any of the following individuals: Karl
Walsh, Jim Christie, Martin Bain, Klara Kozak, Noel Francis
Chantiam, Barry McKay, Andrew McKay or Natasha Vieira; and
v. OPPA expenses, annual leave, or the payout of annual leave.
AND UPON BEING SATISFIED that the requested data is in the possession or
control of Curtis Ella.
IT IS HEREBY ORDERED THAT Curtis Ella shall produce the requested data to
Sergeant Gordon Aristotle of the Royal Canadian Mounted Police (RCMP), at the
RCMP Detachment located at 345 Harry Walker Parkway South, Newmarket, Ontario,
as soon as practicable and, in any case, no later than 30 days from the date of this
Order.
AND THAT the following independent lawyer be appointed to act as the Chief Referee
in order to protect solicitor-client privilege:
Scott Hutchison
Henein Hutchison LLP
3rd Floor
235 King Street East
Toronto, Ontario
LSUC # 29912J
AND THAT the following Independent Certified Forensic Examiner (ICFE) be appointed
to assist the Police and the Chief Referee in the search and seizure of the data:
Wayne Doney
Page 2 of 5
SPECIAL CONDITIONS FOR THE PRODUCTION ORDER:

Sergeant Gordon Aristotle will seize and secure the data from Curtis Ella. The
data will be sealed and will not be examined by the police. The data will be
delivered to the ICFE as soon as reasonably practicable.
The ICFE will receive the seized data from the police. If possible, the ICFE will
image the data to create a sound duplication.
Ill.
The ICFE will conduct key word searches on the data or the images of the data.
The list (s) of key words will be supplied to the ICFE by the Sergeant Gordon
Aristotle or his designate. The ICFE will provide the results of the key word
searches to the Chief Referee.
IV.
The ICFE will maintain continuity, security, and store the data and the images of
the data, until the forensic examination is completed. Upon the completion of
the forensic examination the ICFE will deliver all the data and any copies or
images thereof to the custody of the Chief Referee.
POST SEIZURE DUTIES OF THE CHIEF REFEREE:
V.
The Chief Referee will receive the data from by the ICFE. Upon receipt, the
Chief Referee will maintain continuity and security, and be responsible for the
storage of the data until otherwise ordered by the Court.
VI.
The Chief Referee will examine the data and assert solicitor-client privilege if
app1 ica b le.
VII.
If the Chief Referee does not assert privilege over any data it will be released to
Sergeant Aristotle, and make arrangement for the release of the data.
VIII.
In the case of any data where privilege has been asserted, the Chief Referee will
separate the data into three categories, and prepare a report that will provide the
Court with rationale why the data:
1. In the opinion of the Chief Referee is not protected by solicitor client
privilege.
2. In the opinion of the Chief Referee may be protected by solicitor client
privilege.
3. In the opinion of the Chief Referee should be protected by solicitor client
privilege.
Page 3 of5
IX.
The Chief Referee will be responsible for notifying clients who have been
affected by the execution of the search warrants, or whose data have been
seized pursuant to the search warrants. This notification will occur as soon as
reasonably practicable following the execution of the search warrants and may
a.
The seizure of any of their data;

authorities;
f.

and

of the search for and seizure of their data.
X.
The Chief Referee may notify the clients either verbally or in writing and may
the Court.
DATED this SThay of March, 2015 at the 9ity of Toronto in the Province of Ontario.
Judge of the Superior Court of Ontario

JUSTICE NDfDHEJMEf
Page 4 of 5
ONTARIO
(Toronto Region)
IN THE MATTER OF an application for a

Production Order pursuant to section
AND IN THE MATTER of an application
for Assistance Orders pursuant to section
PRODUCTION ORDER
Sergeant Gordon Aristotle

Royal Canadian Mounted Police
345 Harry Walker Parkway South
Newmarket, ON
Page
..
RCMP File:
Canada
ONTARIO
(Toronto Region)

487.012(1) of the Criminal Code
AND IN THE MATTER of an application for Search Warrants pursuant to section 487 of
the Criminal Code.
AND IN THE MATTER of an application for an Order Denying Access to Information
(Sealing Order) pursuant to section 487.3(1) of the Criminal Code.
INFORMATION TO OBTAIN
TABLE OF CONTENTS
3
5
6
lntroduction
Offences Under Investigation:
Overview
First Response Travel Group! Leximco Ltd
Offshore Investments
PIN Consulting Group Inc
10
Other Allegations
Judicial Authorization Sought
Subject List
Sources of lnformatiow
Grounds Of Belief:
11
OPPA Information Review
16
Witness Statements
16
Martin McNamara
17
13
15
16
Page 1 of 88
Curtis Eia. 20
28
Kimberly Tait
First Response Travel Group
34
Leximco Ltd
36
PIN Consulting Group Inc
37
New Providence Income Fund Ltd
39
Condos at 1 Cable Beach in Nassau, Bahamas
40
2014 OPPA Audit:
41
OPPA Association Financial Report Presented at the OPPA Annual General Meeting
43
OPP Association Constitution and By-Laws
43
43
Summary of Grounds
Solicitor-Client Privilege Considerations
Things Sought Are Not Protected By Solicitor-Client Privilege
Search Warrant for 903
44
46
49
180 Bloor Street West, Toronto, Ontario
Things Being Sought from 903
49
180 Bloor Street West, Toronto
Summary of grounds for Belief the Things being Sought will be Located at Suite 903
Bloor Street West, Toronto, Ontario
Special conditions related to the Search Warrant for 903
180
51
180 Bloor Street West, Toronto:

52
Seizure of Electronic Records at 903
180 Bloor Street West, Toronto, Ontario
53
Things being sought from Ontario Provincial Police Association Office located at 119 Ferris
58
Lane Barrie, Ontario:
Summary of grounds for belief the things sought will be located at Ontario Provincial Police
60
Association Office located at 119 Ferris Lane Barrie, Ontario
Grounds To Believe Things Sought From All Locations Will Afford Evidence
86
86
86
Time Frame Requeste&

Sealing Order
Page 2 of 88
ONTARIO
(Toronto Region)

487.012(1) of the Criminal Code
AND IN THE MATTER of an application for Search Warrants pursuant to section 487 of
the Criminal Code
AND IN THE MATTER of an application for an Order Denying Access to Information
(Sealing Order) pursuant to section 487.3(1) of the Criminal Code.
INFORMATION TO OBTAIN
I, Sergeant Gordon Aristotle, a peace officer and member of the Royal Canadian
Mounted Police (RCMP) in the Province of Ontario, MAKE OATH AND SAY AS
FOLLOWS:
Introduction:
1.
I have been a member of the RCMP since 1997 and currently hold the rank of
Sergeant. My first posting was in the Province of British Columbia working in
both the General Duty and the General Investigation Sections (GIS). While
working GIS, I was involved in the investigation of major crimes such as
homicides, robberies, sexual assaults, drugs offences, counterfeiting and frauds.
2.
In 2001, I was transferred to Ontario. I have been assigned to several units

within the RCMP which have, as part of their mandate, the investigation of
financial crimes including the following.
a. National Security Investigation Section;
b. Commercial Crime Section;
c. G8-G20 Summits Joint Intelligence Group;
Page 3 of 88
d. Integrated Market Enforcement Team;

e. The GTA Financial Crime Unit;
f.
Joint Securities Intelligence Unit; and
g. Integrated Proceeds of Crime Section.

3.
In addition to the above noted units from 2002-2004 1 was seconded to Project
OIDA to work with RCMP and Toronto Police Service (TPS) investigators
assigned to the Professional Standards Special Task Force. Project OIDA
investigated allegations of fraud and corruption which resulted in criminal
charges being laid against police officers formerly assigned to the TPS Central
Field Command Drug Section.
4.
I have completed complex financial investigations, at times as the team leader

and/or affiant, including those involving:
a. fraud offences;
b. money laundering and proceeds of crime offences;
c. breach of trust offences; and
d. crimes of dishonesty committed by a member of the Law Society.
5.
I have prepared and supervised the preparation of numerous judicial

authorizations including search warrants, production orders, tax applications,
restraint applications and management orders. I have prepared and supervised
the preparation of restraint applications for bank accounts controlled by a lawyer.
I have prepared search warrants for documents and data stored in law offices
and also in the residence of a lawyer, and I prepared and supervised the
preparation of production orders for information pertaining to dozens of bank
accounts controlled by a lawyer. I have also prepared an affidavit for the
purpose of a Lavallee Hearing, which was used to make a determination of
whether evidence seized by the Referees was protected by solicitor clientprivilege.
6.
I have a solid understanding of economics, finance, accounting, business,

banking and capital markets. This is based on my experience as a financial
crimes investigator, as well as my education. I have completed the following
relevant courses:
a. Honours Bachelor of Business Administration Degree (1990-1 994);
b. Commercial Crime Investigators Course (RCMP 2001);
c. Counterfeit Investigators Course (RCMP 2002);
d. Proceeds of Crime Investigators Course (RCMP 2004); and
e. The Canadian Securities Course (2006).
Page 4 of 88
7.
In addition, I have attended numerous economic crimes related conferences and

seminars. I have prepared materials for and lectured at many conferences and
courses such as the following:
a. Money Laundering Investigators Course provided to Panamanian Police,
Prosecutors and Intelligence. (2015);
b. The Osgoode Hall Money Laundering Symposium (2013);
c. Integrated Market Enforcement Team Investigators Course (2008);
d. Joint Securities Intelligence Unit International Fraud Conference (2008);
e. The Ontario Securities Commission, Securities Investigation Training
Course (2007);
f.
The Toronto Police Service Fraud Conference (2007); and
g. Annual Legal and Compliance Conference of the Investment Dealer

Association Members (2006).
8.
My current full time position in the RCMP Greater Toronto Area Financial Crime
Unit (GTA FCU) is that of Team Leader. On November 10, 2014, I was
directed to assist the RCMP Special Investigations Anti-Corruption Unit with this
investigation.
9.
Throughout this Information to Obtain (ITO), where I state my belief, the belief
is based on my experience and training. I have personal knowledge of the
matters and facts described in this ITO, except where stated to be on
information and belief. I believe the contents of this ITO to be true to the best of
my knowledge.
10.
I understand that this is an ex parte application and that lam obligated to

present a full, frank and fair disclosure of the material available to me. While
preparing this ITO, I did not include every single detail of this investigation. In an
effort to prepare a document that is clear and concise, I have included
information that I believe is relevant to this particular investigation and which is
necessary to establish the grounds for granting the requested orders.
Offences Under Investigation:

11.
Based on the grounds described below, I have reasonable grounds to believe

that the following individuals:
a. Martin Bain
Date of Birth: May 13, 1966
Address: 7 Maple Court, Oro-Medonte, Ontario
b. James Christie
AKA Jim Christie
Date of Birth: September29, 1967
Address: 193 Maple Dawn Drive, Midland, Ontario
Page 5 of 88
c. Karl Walsh
Date of Birth: November 12, 1963
Address: The residence in the southeast part of the property designated
31X
Line, Bradford, West Gwillimbury, Ontario;
as 41 53/41 55/41 57
have committed the following offences that are contrary to an Act of Parliament:
a. Section 322 Theft Criminal Code.
b. Section 336 Criminal Breach of Trust Criminal Code;
c. Section 380 (1) Fraud Criminal Code; and
d. Section 462.31 Laundering the Proceeds of Crime.
12.
And I have reasonable grounds to believe that the following individuals:

a. Andrew Mckay
AKA Andy Mckay
Date of Birth: September 9, 1961
Address: 64 Montressor Drive, North York, Ontario;
L.
b. KlaraKozak
Date of Birth: March 28, 1968
Address: Upper Level, 61 Wineva Avenue, Toronto, Ontario; and
c. Noel Francis Chantiam
AKA Francis Chantiam
Date of Birth: December 25, 1955
Address: Unknown
[1
have committed the following offences that is contrary to an Act of Parliament:

a. Section 341 Fraudulent Concealment Criminal Code;
b. Section 462.31 Laundering the Proceeds of Crime; and

c. Section 380 (1) Fraud Criminal Code.
1
Overview:
13.
El
In October 2014, the Ontario Provincial Police (OPP) received complaints from
employees of the Ontario Provincial Police Association (OPPA) alleging
fraudulent activity being conducted by some of the senior members of the
executive of the OPPA, namely, Chief Administrative Officer (CAD) Karl Walsh
Paragraphs 13 to 29 constitute an overview, further details in support of the overview are found in the body of the
ITO
Page6of88
(Walsh), OPPA President James Christie (Christie), OPPA Vice President

Martin Bain (Bain), a lawyer named Andrew Mckay (McKay), and other
individuals, namely, kiara kozak (Kozak) and Noel Francis Chantiam
(Chantiam). Upon review of the initial information, the OPP referred the case to
the ROMP which formed a team to investigate the allegations.
-
14.
I have reasonable grounds to believe that the subjects of investigation, namely,

Walsh, Christie, Bain, McKay, Kozak and Chantiam, have acted together to
commit criminal offences of fraud and theft against the OPPA. This belief is
strongly based on information that has been received from four employees of the
OPPA, who are concerned by the actions of Walsh, Bain and Christie, who are
all sworn police officers. Sam and Walsh hold the rank of constable, while
Christie is a detective sergeant. Mckay is a lawyer in private practice with the
firm, Warren McKay Geurts & Bellehumeur (McKay Law Office).
15.
I believe that the subjects of investigation have organized various schemes,

some which include companies for which they hold hidden beneficial ownership,
that have been setup in order to obtain exclusive rights for services required by
the OPPA. These services pertain to but are not limited to the travel and
investment needs of the OPPA. In addition, some of the services offered by
these companies are being promoted to the OPP membership throughout the
province.
16.
Following is a summary of the schemes that I believe have been used to

fraudulently elicit funds from the OPPA, for the benefit of the subjects of
investigation.
First Response Travel Group! Leximco Ltd.
17.
A company called First Response Travel Group (First Response) was formed
on June 16, 2014 and Walsh has directed all OPPA employees to use this
company exclusively for all OPPA travel needs. First Response is also being
utilized to secure contracts for the OPPAs Golf Tournament, the OPPA Annual
General Meeting (AGM) and the OPPA Spring Board Meeting, which have an
estimated contract value of $400,000.00. The decision to change travel service
providers was made without any cause or explanation OPPA employees have
complained that First Response is providing the OPPA with inferior service, at
inflated prices, compared to the previous travel service provider. First Response
is also being endorsed by the OPPA, and actively marketed for personal travel,
to the more than 6,000 OPPA members through the OPPA website, and through
an OPP members magazine called, Beyond the Badge.
18.
First Response was registered as a partnership between Chantiam and Kozak

which was listed as a division of Leximco Ltd. (Leximco), a corporation whose
directors are shown as kozak and McKay. However, according to emails that
had allegedly been observed on Walshs OPPA email account, Walsh, Christie,
Page 7 of 88
Bain, McKay, Chantiam and Kozak all owned shares in First Response. The
total book value of the company was $198,000.00, which is comprised of 198
shares each having a value of $1,000.00. Bain, Walsh and Christie own 50% of
the shares of First Response Travel, while McKay, Chantiam, and Kozak own
the remaining 50%. It has been alleged that the OPPA was being invoiced
monthly for consulting fees by a company called PIN Consulting Group Inc.
(PIN), and that the funds paid by the OPPA were being used for the benefit of
Walsh, Christie and Bain, to pay for 30 First Response shares worth $30,000.00.
In order to hide their ownership in First Response, the shares belonging to Bain,
Walsh and Christie were being held in trust by Kozak through an offshore
investment scheme.
19.
Walsh, Bain and Christie have not disclosed their beneficial ownership of First
Response to the OPPA Board of Directors and the OPPA membership. In
addition Walsh, Bain and Christie had failed to disclose their beneficial
ownership in First Response to the OPPA Auditor and their beneficial gain from
the funds being paid by the OPPA to PIN. This has caused the auditor to
prepare an audit report for the OPPA that does not contain factual information
about related party transactions, which in turn has deceived the OPPA Board of
Directors, the OPPA membership and the OPPA Audit Committee.
Offshore Investments
F.
20.
At the beginning of 2014, Walsh, Christie and McKay took two trips to the
Bahamas, after which Walsh, Bain and Christie began to make higher risk
investment decisions on behalf of the OPPA. This has been a noticeable
deviation from the historically conservative investment strategy of the OPPA as
two of the investments are domiciled in offshore jurisdictions and were allegedly
not preapproved by the OPPA Board of Directors.
21.
One of these investments was only discovered when back up paperwork for a
$20,000.00 charge on Walshs OPPA issued credit card was requested by
OPPA office staff in preparation for the OPPAs annual audit. Walsh explained
that the $20,000.00 charge was for a deposit that he made on two condos which
were to be built at I Cable Beach in Nassau, Bahamas. One of the condos was
valued at $1,563,000.00 and the other was valued at $625,000.00. Walsh
advised that the condo was being purchased as a high end vacation rental
property investment for the OPPA. This transaction, which was not discussed
with the OPPA Board of Directors prior to its purchase, did not make sense to
some of the OPPA employees as the OPPA is a not-for-profit organization. The
backup paperwork for the credit card transaction demonstrated that the deposit
for the condo was actually made in Walshs personal name, with an associated
mailing address belonging to McKays office. This paperwork for the condo had
since been changed to the OPPA and its address. Subsequently Walsh had
advised that he would be canceling the condo investments, which had resulted
in some of the credit card deposit being refunded with a remaining $13,128.00
deposit yet to be refunded The fact that Walsh intended to purchase a
Page8of88
$1,563,000.00 condo in the Bahamas on behalf of the OPPA was not disclosed
to the delegates at the OPPA AGM in October 2014. The $13,128.00 that was
not refunded was accounted for as a prepaid expense on the 2014 OPPA
Financial Statements, however, there were no notations to describe this
expense to the reader.
22.
In August 2014 the OPPA invested in the New Providence Income Fund Inc.
(New Providence), a company which is domiciled in the Cayman Islands. This
investment is said to be a high risk, high yielding offshore investment that is not
regulated in Canada and there is no guarantee that the principal invested will be
returned. Walsh wired $100,015.00 of OPPA funds to the Cayman Islands to
pay for shares in New Providence. Walsh had further advised of his intention to
endorse New Providence and encourage the OPPA membership to also invest
in New Providence. Despite the potential for high yield return, this high risk
investment was counter to the historically conservative investment strategy of
the OPPA.
PIN Consulting Group Inc.
23.
PIN was registered on June 6, 2014, which was 10 days prior to the registration
of First Response. Mckay was the only director listed on the PINs corporation
profile. The registered office for PIN was listed at Suite 702170 Bloor Street
West, Toronto, Ontario with Natasha Vieira (Vieira) as the contact person.
Vieira is Mckays executive assistant and the listed address was also the
address of Mckays Law Office as well as his other businesses unrelated to the
practice of law, namely Amax Security Solutions Inc., Amax Intelligence Inc. and
Leximco Ltd. Walsh and Christie signed a three year contract with PIN on behalf
of the OPPA which commenced on July 1, 2014. The total value of the contract
is $5,000.00 per month plus expenses, or $180,000.00 over the three year term.
The contract described services to be provided by PIN which included
researching, negotiating and concluding beneficial opportunities for enhancing
OPPA membership including but not limited to: real estate investments;
commercial investments; vacation property opportunities; travel benefits through
various travel agencies by securing exclusive rates for members and their
families; and any other opportunities that PIN was able to procure as a
deliverable service.
24.
McKay signed the contract on behalf of PIN. Open source checks were
conducted and PIN had no presence on the Internet to describe the company, or
the services they provide clients. Mckay was a former police officer, and is
currently a criminal defense lawyer. Witnesses do not possess any knowledge
or evidence to demonstrate that Mckay has skills and experience in the travel
and/or the investment industry, which would be of any value to the OPPA.
25.
Walsh, Christie and Bain are allegedly benefiting financially from PINs business
relationship with the OPPA, however, the extent of this benefit is not yet known.
Page 9 of 88
PIN is closely associated with much of the alleged fraudulent activity under
investigation such as the following:
a. Funds being paid by the OPPA to PIN for consulting fees allegedly being
used to pay for shares of First Response which are owned by Walsh, Bain,
and Christie;
b. The registered office address for PIN was the same as Mckays law office
as well as his other businesses unrelated to the practice of law. The
backup documentation and other information associated to the condos
being purchased in the Bahamas, which were originally secured in
Walshs personal name, were kept under the control of Mckay and his
executive assistant, Vieira.
c. PIN through McKay was allegedly responsible for the introduction of
Kozak and First Response to the OPPA.
d. PIN was allegedly responsible for the OPPA investing in New Providence.
e. Some of the OPPA employees believed that PIN is involved with the
evaluation, procurement and development of the proposed site for the new
OPPA office, which is to be located in Oro, Ontario. Walsh is allegedly
fixated on moving the OPPA to a new location, and he was also
attempting to convince the OPPA Credit Union to move to the same
location and construct a new building. Mckays brother, Barry Mckay,
was said to be involved with this project. The Board announced on
February 19, 2015 that the OPPA will be spending $100,000.00 on a site
assessment for the property. This amount was broken down into two
parts; $50,000.00 for the work and $50,000.00 for consulting fees with an
expected 10% overrun.
2
f.
In January 2015, Mckay, believed to be representing PIN, presented a

new investment to the OPPA Board of Directors through a firm referred to
as the Caldwell Group. This investment was approved by the Board,
however, the details of the value and structure of this investment are not
known at this time.
Other Allegations:
26.
Witnesses have also made other allegations pertaining to further enrichment by

Bain, Walsh and Christie relating to fraudulent claims for vacation leave payouts
and personal expenses. These other allegations are being investigated but are
not the primary focus of this investigation. These allegations predate the more
serious complaints as described above. The totality of the alleged behavior
demonstrates an ongoing breach of trust which is being committed by Walsh,
The firm that will be receiving the consulting fees is unknown at this time.
Page 10 of 88
Bahamas; and that the OPPA had wired funds from their bank account to the
Cayman Islands for an investment.
d. There was an OPPA Board Meeting at the beginning of October 2014 after
, conducted the annual audit of the OPPA.
7
the OPPAs auditor, Ferguson
McNamara attended this meeting and he was provided a private and
8 Included in
confidential letter from the auditor to OPPA Finance Committee.
this letter were recommendations from the auditor and managements
response. This report referenced a number of issues, some of which included
the following:
i.
Unsupported expenses;
ii.
Vagueness of the OPPAs investment policy for what constitutes

acceptable investments; and
iii.
A list of significant and unusual transactions which included a deposit

of $13,128.00 for a condo property located at 1 Cable Beach in
Nassau, Bahamas, worth $1,563,000.00, and the purchase of 100
Class A shares of New Providence which required a cash outlay of
$100,015.00 payable to a company in the Cayman Islands.
e. McNamara was extremely upset by these transactions and the perception of

money laundering. He asked direct questions in the meeting as to why the
OPPA was investing in the Bahamas and the Cayman Islands. Walsh
responded by explaining the following:
f.
i.
The OPPA was no longer buying the condo in Nassau, Bahamas and
therefore, they would be getting their deposit back; and
ii.
The $100,000.00 investment in New Providence was a conduit to a

mortgage investment corporation in the Cayman Islands and a means
for OPPA membership to invest their own personal funds. The initial
investment was required so they could open a bridge for OPPA
members to invest in this corporation. Walsh advised that the
investment provided a 12% rate of return.
The Board then left the general meeting and went in camera to discuss
these issues in private. Upon the Boards return, McNamara was advised that
the letter from the auditor to the Audit Committee would not be distributed to
the OPPA membership.
Ferguson is an accountant with Powell Jones, the accounting firm used by the OPPA.
This letter was provided to the D/lnsp. Avery and a copy was provided to the RCMP on December 1,2014 and is
described later in this ITO.
Page 18 of 88
g. After the Board meeting was finished McNamara was still very upset about
the offshore investments and other things that just did not seem right. He
discussed the issues with other OPPA employees, including Elia.
h. While McNamara was driving to the OPPA AGM with Barendregt and Elia,
they discussed the issues at the OPPA. Elia then advised him that while he
was working on Walshs computer he had located some emails pertaining to
First Response and PIN which contained the following information:
I.
Leximco Travel was purchased by First Response and Walsh, Christie

and Bain owned shares in First Response;
ii.
Correspondence from McKay to Walsh explaining that these shares

were not traceable because they were held offshore; and
iii.
Kozak was holding shares in trust in the Cayman Islands on behalf of

Bain, Walsh and Christie.
i.
McNamara found an accrued vacation bank file on the OPPA server, and
when he asked what it was for, the access to the file was locked down. He
learned that in the year 2014, they, along with McKay, went to the Bahamas
on what was first described as a personal vacation, however, their work
schedules were subsequently changed to show that they were working for the
OPPA during this trip. There was also a second trip to the Bahamas, at the
, Walsh, Christie and Mckay. Subsequently
9
end of May or June, for Bain
large payouts of approximately $30,000.00 were made to Walsh and Christie
1
for unused vacation time.
j.
McNamara first heard that the OPPA Audit Committee Members were very
upset when they learned of the findings of the auditor, however, their
concerns were somehow alleviated. He has learned that the Audit Committee
12
11 was authored by Walsh.
Report
k. It was during the 2014 annual OPPA golf tournament where McNamara first
met Kozak. During their conversation, Kozak told McNamara that she would
be starting up First Response, organizing next years golf tournament and
getting involved with the OPPA, all of which was news to McNamara.
McNamara was the only witness who mentioned that Bain travelled to Nassau, Bahamas with the others. It is
possible that McNamara received this information second hand and Bain never actually went to the Bahamas with
Christie, Walsh and McKay.
10
In the OPPA Statement of Financial Position as at August 31, 2014 there was a notation advising of a change in
policy in relation to the Board of Directors and cAos vacation policy whereby the year end payable for vacation time
would be recorded on the financial statements.
The Audit Committee Report was provided to the OPP Interviewer and has since been provided to the RCMP and
will be described later in this ITO.
12
Walsh was not a member of the Audit Committee but he allegedly was responsible for selecting the Audit
Committee from a list of delegates who volunteered for this role. The Audit Committee members were Bruce Qwigg,
Dave Vitti, and Dave Sanbatini.
Page 19 of 88
.9
I.
45.
McNamara approached the OPP with his concerns and not the Board
because he felt this was a criminal matter pertaining to the misappropriation
of OPPA funds.
On February 20, 2015 McNamara sent Cpl. Nicolas an email advising the
following:
a. That the OPPA Board announced on February 19, 2015 that the OPPA
will be spending $100,000.00 on a site assessment fora property which is
to be the site of the new OPPA office. The $100,000.00 amount was
broken down into two parts; $50,000.00 for the work and $50,000.00 for
consulting fees with an expected 10% overrun. McNamara did not state
who the consulting firm or what service the consulting firm will be
providing;
b. That all lawyers on the OPPA callout list, that are contracted as required
to assist OPPA members, have now been ordered to use First Response
Travel Group;
c. That one of the Executive Officers has been fired, his OPPA issued
equipment has been taken away, and his retirement party has been
cancelled; and
d. That McNamara has been told that they will be trying to fire him soon as
well.
Curtis Elia:
46.
Elia has provided two sworn witness statements, the first on November 2, 2014,
to D/lnsp. Avery and the second on January 13, 2015, to Cpl. Nicolas and Sgt.
Jory. He also provided an additional statement on March 1, 2015.
47.
The following is a summary of Ellas evidence:

a. Elia is the OPPA Manager of IT and Infrastructure and has been employed
with the OPPA since 2010. He worked as a consultant to the OPPA for 8
to 9 years prior to accepting a permanent position.
b. Ella provided information pertaining to where relevant electronic
information could be obtained on the OPPA server.
c. Elia had seen an email on Walshs computer while he was working in his
office in June 2014. At first the email he saw which was about the
purchase of shares did not mean anything to him. He then heard from
other OPPA employees about questionable OPPA expenses and vacation
Page 20 of 88
payouts. He also learned of the OPPAs suspicious offshore investments

and a contract with PIN for $5,000.00 per month. Ella had concerns about
this activity which prompted him to review certain emails and form the
belief that Walsh, Christie and Bain were involved in criminal activity. Elia
13 to preserve
made copies of Walsh, Bain and Christies email mailboxes
.
14
evidence which was later provided to D/lnsp. Avery
d. Ella had backed up Walsh, Bain and Christies email mailboxes in the
months of October, November and December.
e. According to the emails Ella has read pertaining to Walsh, Christie, Bain,
McKay, Chantiam and Kozak, he had noted the following:
i. Walsh, Christie, Bain, McKay, Chantiam and Kozak have all
purchased shares of First Response. The total book value of the
company was $198,000.00, and was comprised of 198 shares each
having a value of $1,000.00. The share structure was comprised
as follows: Mckay, Chantiam, and Kozak own one half of the
shares of First Response. Bain, Walsh and Christie own the
remaining half of the shares, with Walsh owning 50% and Bain and
Christie each owning 25% of this portion. OPPA funds were being
funneled through a company called PIN in what was being
described as consulting fees to pay for 30 of these shares having
a value of $30,000.00. Bain, Walsh ad Christie would each
benefit $10,000.00 from this arrangement. The shares belonging to
Bain, Walsh and Christie were being held in trust by Kozak through
an offshore investment scheme. They believe that these shares
were not traceable if someone was looking into the company to see
who owned it.
ii. Mckay introduced Kozak and Chantiam to Walsh, Bain and
Christie. kozak and Chantiam affended the OPPA in the summer
of 2014 in a stretch limousine to meet with Walsh and Christie. It
was Chantiam who proposed the fraudulent scheme to Walsh, Bain
and Christie.
iii. Elia read aloud a portion of one email written by Walsh, I raised
our issue with PIN. Francis talks fast and assumes we are as smart
as he is. In the end he does not appear to be tied to PIN. He is
13
J.
Ella retileved the emails on his own and he has advised investigators that he backed up the OPPA mailboxes for
Bain, Walsh and christie so that evidence would not be lost if the emails were to be purged or deleted. Investigators
have not advised Ella that they will be conducting a search warrant and they have not instructed Ella to review emails
or preserve evidence. Investigators were unaware of Ellas actions until they were already done. On December 4,
and on
2014 S/Sgt Roy Steinebach advised Eliato maintain discretion to preserve the integrity of the investigation
January 13,2015, cpl. Nicolas advised Elia not to take any additional actions for the purpose of this investigation.
14
Due to privacy concerns the OPP had not reviewed this material, and RCMP investigators have not requested
these electronic storage media devices from the OPP. These electronic storage media devices are now being sought
by judicial authorization supported by this ITO.
Page 21 of 88
leaving that up to us and Andy. He mentioned we could make

payments through Andy. That way we could coordinate the OPPA
consulting fee. Ella advised that there were lots of
correspondence on the emails between Mckay and Walsh
pertaining to PIN.
iv. One email viewed by Ella gave the bank account information where
they were to transfer the funds for the shares of First Response.
Ella believed that it was a Bank of Montreal (BMO) bank account.
v. Ella advised that in one of the email from either Walsh or Christie to
Kozak, she was asked to cease using the OPPA emails for
communication and to use their personal email accounts, believed
to be the following accounts; karlwalsh(yahoo.com;
ichirstie(2qmail.com; and [email protected].
g. EIia was concerned because OPPA employees were being forced to use
First Response for their travel needs, and Ella believed the OPPA was
being overbilled for this service. He was also concerned because First
Response was now being endorsed and promoted to the entire OPPA
membership.
h. Ella believed that the OPPA Board of Directors approved the monthly
expenditure for PIN, but they were not aware of the involvement of McKay,
Walsh, Christie and Bain at that time.
I.
Ella advised that Mckay later made a presentation to the OPPA Board to
15 Ella had seen an
pitch them on an investment with the Caldwell Group.
email between Mckay and Walsh saying that everything was good,
Caldwell would take .5%, PIN would take .5% and the OPPA will not be
taking any money out of the investment. Ella could not provide any further
details on this investment.
j.
Ella advised of the discussion he had with McNamara and Barendregt

while they were driving to the OPPA Annual General Meeting at the end of
October. They discussed the financial issues within the OPPA and how
they should stand up, but none felt they were in the position to do so. It
was at this time that he told McNamara and Barendregt about the emails.
They were shocked to learn of this information, and McNamara asked Elia
to hold off as the OPP should be made aware of the situation. McNamara
said he would contact someone at the OPP, and the next day confirmation
was received that it would be investigated.
15
There is an investment firm named caidwell Securities that is located at 150 King Street West, Toronto, ON. No
further information was provided and I am unsure if this company is the one that has been described.
Page 22 of 88
k. Walsh and Christie went to the Bahamas on two occasions; from March 27
to 30, 2014 and from July l6to 21, 2014. Ella knew this because he was
requested to purchase a cellphone plan for Walsh and Christies phones
for their trip to the Bahamas. Since he was unable to obtain a compatible
cellphone plan, he asked Walsh and Christie to refrain from using their
OPPA cellphones while they were in the Bahamas. However, Elia was told
that due to the business nature of the trip, they were required to use their
cellphones and as a result Walshs bill was between $2,000 and $3,000.
I.
In the summer, Ella attended McKays law office to do IT work and during
the course of these duties he saw the following:
i. The scheduling of McKays meetings between Mckay, Chantiam
and Kozak.
ii. Emails that showed McKay had introduced Chantiam and Kozak to
Christie, Bain and Walsh.
48.
On February 26, 2015 CpI. Nicolas received an unsolicited email from Elia
advising that McKay had contacted him to do some IT work at his new office
located at Suite 903 -180 Bloor Street West, Toronto, Ontario. Elia advised that
he would be meeting with McKay at this office on March 1, 2015 CpI. Nicolas
emailed Elia back and thanked him for the information.
49.
As a result of Elias information investigators conducted surveillance in the area

of 180 Bloor Street West, Toronto, Ontario on March 1, 2015. Elia was not
informed that investigators would be conducting this surveillance, and he was
not provided any instruction from CpJ. Nicolas or any other member of the
investigation team. The following are the relevant observations for the
surveillance:
a. At 11:07 Andrew Mckay was observed carrying a vacuum and an
extension cord into the rear of 180 Bloor Street West, Toronto, Ontario.
b. At 11:54 Sgt. Jory attended outside of Suite 903 -180 Bloor Street West,
Toronto, Ontario and noted two large front opening filing cabinets and one
black office chair in the hallway to the left of the entrance to Suite 903.
Sgt. Jory opened the unlocked door to Suite 903. Sgt. Jory observed an
office space but he did not observe anyone inside the office and he did not
enter the suite. Sgt. Jory noted a desk located to the left of the entrance
and a number of large boxes on the floor.
c. At 11:57 Elia was observed standing outside to the west of 180 Bloor
Street West on the sidewalk. Elia was then observed entering the lobby of
180 Bloor Street West where he met with Andrew Mckay and an unknown
male. All three males were seen entering the elevator.
Page 23 of 88
d. At 18:20 McKay and Ella were observed leaving 180 Bloor Street West
and entering a black Sport Utility vehicle that was parked in a lot at the
rear of the building. Mckay was observed driving away in the vehicle with
Ella in the front passenger seat.
50.
On the evening of March 1, 2015, Cpl. Nicolas called Ella and requested that he
provided a statement. At 20:38 Cpl. Nicolas and Sgt. Jory obtained a statement
from Ella. During this statement Ella advised the following:
a. He confirmed that he was at 180 Bloor Street West earlier that day to
assist Mckay in establishing the IT requirement for the new office. He
advised that the whole Warren Mckay legal firm was moving to this new
location. There were seven to eight lawyers moving into the new location.
b. He advised that Mckay had completely moved out of his previous office at
170 Bloor Street West and he will be commencing operations at the new
office this week. All of Mckays legal files are now in the new office. On
Tuesday (March 3, 2015) they will be getting the Internet and will be
working with what they have for the time being. He described the new
office as having boxes throughout containing equipment and files.
c. Ella advised that Mckay has a desk top computer which is networked with
the bookkeeper, Natasha Vieiras desk top computer. Vieira does the
billing for Mckay.
d. He advised that there are four physical offices, a boardroom and a
backroom. Ella provided a diagram of the office and advised that Mckay
was sharing an office with a lawyer named, Craig Branagan.
e. Elia advised that he was asked to go back to Mckays office next Sunday
(March 8, 2015).
f.
Ella advised that he had the backups previously described, including

Walsh, Bain and Christies emails accounts on his hard drive at his
residence.
Sandra Barendregt:
51.
On December 8, 2014, Barendregt attended the RCMP Newmarket Detachment

and provided a sworn audio and video recorded witness statement. I monitored
the statement which was obtained by Sgt. Jory and CpI. Nicolas and learned the
following:
a. Barendregt has been employed by the OPPA for twenty years. She does
the accounting for the OPPA, and her duties include payroll, accounts
Page 24 of 88
payable, accounts receivable and preparing the financial statements.

Barendregt provided information about the OPPA, the structure,
employees, the OPPA office and OPPA home offices.
b. Barendregt was aware that Ella located and turned over emails to the
police. Elia showed her an email which described how Walsh invested
$46,000.00, while Christie and Bain each invested $23,000.00 into a
company. She was not sure if the company they invested into was PIN or
First Response. In one of the emails Mckay said not to worry, no one will
ever know because Kiara was the trustee of the shares.
c. Kozak ran First Response and all OPPA travel must be purchased through
her. At the OPPA AGM, First Response was presented to the delegation.
Members were told that if they book through First Response they would
get a discount.
d. Barendregt received an email from Walsh telling her to pay a PIN invoice
for $5,000.00 plus HST. The invoice did not breakdown the services that
were provided by PIN. The PIN office had the same mailing address as
Mckays Law Office. Mckay had provided legal services for OPPA
members for about 10 years and he was friends with Walsh, Christie and
Bain.
e. Barry McKay is Mckays brother and Barendregt thinks he was a realtor.
She frequently hears his name in the office and he was somehow involved
with the property that the OPPA may purchase for their new office. Walsh
th
7
line in
was fixated on acquiring this property which was located on the
Oro between the Shell Station and the airport. A company called Dialogue
Inc. has done a survey of the property. Right now they are in the planning
stage and there may be some problems with the soil. Barendregt does not
think there was a need for the OPPA to move as there was nothing wrong
with the OPPAs current office in Barrie, and there was plenty of space.
Walsh says that he wanted to move the OPPA out of Barrie because the
OPP did not police the City of Barrie.
f.
McKay had rich friends in Toronto including a man named, Francis

Chantiam. Chantiam had a box at the Rogers Center where he had
hosted members of the OPPA. Chantiam had been to the OPPA office
and he arrived in a limo with Kozak. Barendregt had been seeing his
name quite frequently at the OPPA.
g. Barendregt provided the following information about the OPPA purchase

of a condo in Nassau, Bahamas:
i. On Walshs April 2014 OPPA Visa statement, she observed a
$20,000.00 US charge which occurred in the Bahamas. She asked
Walsh about this transaction and requested backup documentation.
Page 25 of 88
It took a number of months to produce and was forwarded for the

OPPA audit. Walsh explained that the $20,000.00 US charge was
a deposit for two condos that that the OPPA had purchased in
Nassau, Bahamas; one for $1.59 million and the other for
$625,000.00.
ii. Barendregt had not heard anything about the OPPA purchasing
condos in the Bahamas until she saw the charge on the credit card
statement. When she received back up documentation, she noted
that the paperwork was in Walshs name instead of the OPPA.
Walsh explained that he also purchased a condo and thought they
sent the wrong paperwork. Barendregt received another document
and noted that the condo was associated to Mckay. Barendregt
understood that the OPPA was to receive their money back. There
was one Visa refund received for one of the condos, but as of
December 5, 2014 no refund was received for the second condo.
h. Barendregt provided information about the New Providence investment in
the Cayman Islands:
I. Barendregt received a phone call from Walsh and was told to go to
the Credit Union and wire $100,000.00 US funds to Cayman
Islands for an investment. Walsh explained that this was a time
sensitive transaction that needed to be completed before August
31, 2014. Barendregt was told that the Board would be advised at a
later date and that the decision.to wire these funds was made by
Walsh, Christie and Bain. The Credit Union required a personal
name to be associated to this wire. Barendregt refused to put her
name on this transaction and ultimately Walsh used his passport for
the identification that was required in order to wire the funds to the
Cayman Islands.
ii. The contract for the investment stated there was no guarantee the
investor would get their money back. Barendregt was aware of a
plan to offer this investment to OPPA members, and form one big
investment pool. Barendregt was concerned about this and did not
understand why they would want members to invest in a high risk
Cayman Island fund, where they could lose all of their investment.
iii. To facilitate a wire transfer from the Cayman Islands, the OPPA
was required to open a new US funds bank account at the OPPA
Credit Union. She believed that these funds, around $500.00, were
received as a dividend payment on the investment, but she had not
seen any backup documentation to describe this transaction
Page26of88
i.
The OPPA had approximately $15 million in investments which included

legal investments, insurance investments and operations investments.
Only the operations investments were not restricted and these were the
funds that have been invested. The OPPA cannot make profits or they will
risk losing their not for profit status with the CRA.
j.
Barendregt provided information in relation to the 2014 OPPA Audit

Process:
i. The auditor, Ferguson of Powell Jones, discovered many issues
which he explained in a meeting attended by the OPPA Audit
Committee members, Barendregt and Tait. The Audit Committee
consisted of three delegates who were picked by Walsh. Christie
and Bain came into the meeting and made light of the issues that
were raised by the auditor. They fluffed it off and the Audit
Committee was content with their explanation. Ferguson was to
present to the Board of Directors but Walsh called it off. Ferguson
was also scheduled to present at the OPPA Annual General
Meeting. He advised Walsh that it was his intention to bring up his
findings at the AGM. Barendregt later learned that the OPPA
intended to fire Ferguson, and she told him this. Ferguson was
unsure if he would have a job and in the end he did not present the
issues to the delegates at the AGM.
L-
ii. The condo purchase was not mentioned in the OPPA Annual
Statements becauseWalsh had said he would be cancelling the
deal and the OPPA would be getting a refund. Although the
Cayman Island investment is mentioned in the OPPA Annual
Statements none of the delegates at the OPPA opened this
document and asked about this transaction. Barendregt was very
upset that no one said anything at the AGM, and that nothing was
done to rectify the situation.
iv. Barendregt was handing out expense claims at the end of the AGM
when Walsh saw her and said, We could have spent a million
dollars and these idiots wouldnt have said a thing. Bain then said
to Barendregt, Youre not going to bite are you?
v. Barendregt was advised that Kim Tait and Leanna Maltby (Maltby)
had a similar experience where they were told we just got away
with murder
k. Barendregt explained that Walsh could approve expenses between
$10,000.00 and $50,000.00 and that the board should approve any
purchase over $100,000.00.
Page 27 of 88
I.
Barendregt advised that the OPPA Visa statement balances are paid for in
full directly by the OPPA Credit Union This practice is in place to prevent
charges for late fees, and it has made it easy for employees to use their
OPPA issued credit card withoutproviding backup receipts. This problem
has been brought up repeatedly at board meetings. There is no oversight
and Walsh and Christie are the worst at not providing backup receipts, so
it is impossible for her to determine if their expenses are for OPPA
business or personal in nature. Bain is not as bad as Christie and Walsh
and he does submit support for expenses incurred.
m. Christie, Walsh and Bain have all been part of the Association for about 15
years. Walsh was the President for 6 years and then ran for public office.
When he returned to the OPPA he became the CAO.
n. There is a separate set of books for Bain, Christie and Walshs lieu time
which Maltby keeps track of, and this allows them to get their vacation
paid out in cash by the OPPA. This practice of paying out leave began
when Walsh decided to have his vacation paid out in August 2013 and
then again in January 2014. Walsh was in Los Cabos and because he
answered his phone and checked his emails, no leave time was deducted
16
for this vacation. There is no oversight for this practice.
Kimberly Tait:
52.
Tait has provided two sworn witness statements to Sgt. Jory and Cpl. Nicolas. I
monitored both of these statements, the first which occurred on December 8,
2014, and the second which occurred on January 5, 2015, and learned the
following:
a. Tait has been employed by the OPPA for 5 years. She oversees
operations, the budget, finances, human resources, and generally makes
sure the OPPA is running smoothly. She is a former teacher, has a
Bachelor of Economics, and a College Accounting Diploma. Her husband
is a sergeant with the OPP.
b. Tait provided information about the OPPA, the structure, employees, the
OPPA office and OPPA home offices.
c. Tait and the staff which she supervises have many issues with recent
financial dealings and decisions being made. She has repeatedly brought
her concerns to Walsh. He is her direct supervisor, and she has nowhere
else to take these complaints.
16
in the OPPA Statement of Financial Position as at August 31, 2014 there is a notation advising of a change in
policy in relation to the payout of leave for Board of Directors and chief Administrative Officer vacation.
Page 28 of 88
d. Tait described the Bahamas condo transaction as follows:

Walsh, Christie and McKay went to the Bahamas twice. She had seen
some purchases on the Visa that were made in the Bahamas including
one large charge to put a hold on two condos in the Bahamas. One
condo was worth $1.3 million and the other was worth $700,000.00.
They met with a developer and they were to buy these condos and
have a manager rent them out. The OPPA had never owned real
estate investment property.
There was no back up produced for this transaction, only a charge on
the Visa. The OPPA audit sparked a need for the backup
documentation and Walsh advised her that McKay had the condo
information, and she should contact him for the information she
required. She contacted Mckay and he sent the documentation when
he knew why it was required. The backup paperwork for the condo
that was received from McKay was in Walshs personal name, with
Mckays office address. The name on the paperwork has since been
changed and now it has the OPPAs name and address.
iii.
This transaction was not mentioned in the 2014 OPPA Financial

Statements, and was not described as an asset purchase. Instead the
amount of the deposit had been accounted for as a prepaid expense,
because it was described as a right to purchase, and because Walsh
advised that the OPPA could get their deposit returned.
iv.
Tait had told Walsh that she does not understand the logic behind this
investment, and she explained to him that a deal like this needs to
have backup.
e. Tait described OPPA historical information about OPPA investments and the
investment in the Cayman Islands:
i. The OPPA uses, Terry Cheaney from RBC Dominion Securities to

invest their funds. They are very happy with Cheaney, and the
investments he had selected for the OPPA have done very well.
ii. On August 28, 2014, Tait was not working but she was asked to wire
transfer $100,000.00 in OPPA funds offshore for an investment. There
was a sense of urgency to get the transfer done. Barendregt had
refused to do this transfer, and ultimately it was Walsh who transferred
the funds.
iii. The wire transfer was for an investment in the New Providence, a fund
that is run by a company domiciled in the Bahamas. Tait has seen a
Page 29 of 88
72 page document describing the investment fund, and fourteen pages

of this document describe the risks of investing into the fund. For the
five years she had worked at the OPPA all investment selections have
been low risk. She did not understand or agree with the sudden
change in investment selection.
iv. Tait spoke to Cheaney and Ferguson about the investment. Cheaney
advised that Mike Harris was on the Board of Directors to add
credibility, but the investment appeared too good to be true. He said
he would not invest in this company. Ferguson also had concerns and
advised Tait to put her concerns in writing to protect herself. She sent
an email to Walsh outlining her concerns as per Fergusons advice. At
one point she thought Walsh might retract the investment, but he did
not.
v. It has been explained to Tait that the investment was made so that
other OPPA members could also invest. A $100,000.00 minimum
investment was required so that all OPPA members could pool their
funds and invest. Tait was told that the BMO would be taking over this
investment. The OPPA recently received a dividend payment from this
investment and had to open a US funds account at the OPPA Credit
Union to facilitate the deposit of this money.
f.
Tait provided some information pertaining to Mckay and PIN:

i. Walsh and Christie have known Mckay for years. McKay was a former
police officer and now is one of the external counsels who are called
by OPPA members who need assistance with criminal matters. There
was a list of twenty lawyers that can be called for defense work, but
McKay and his firm are the primary contacts for this type of work.
ii. PIN was costing the OPPA $5,000.00 to 6,000.00 per month and the
companys address was also McKays Law Office address. It was
17
Walsh and Christie who signed the OPPA Agreement with PIN.
iii. Tait was usually privy to everything that was going on within the OPPA
but with PIN she was kept in the dark. Tait had searched the Internet
and could not find any information on PIN and she was not sure what it
does. Tait was not aware of any knowledge that Mckay has with
investments.
17
reviewed a copy of the OPP Association constitution and By-Laws, dated May 2014, and noted the following in
the contracts Section, Contracts and engagements on behalf of the Corporation shall be signed by the President or
the vice-President and the Chief Administrative officer, or their delegates, and the Chief Administrative Officer shall
affix the seal of the corporation to such instruments requiring same.
Page 30 of 88
62.
Kozak and Mckay commenced as officers of Leximco on October 10, 2014.

McNamara advised in his statement that Leximco was purchased by First
Response but the source of his information had not been confirmed. It is not
possible from reviewing the corporation profile to determine the beneficial
ownership and any consideration that may have been paid to the transfer
ownership. It was possible that the ownership of Leximco changed and that
some or all of $198,000.00 that is believed to have been invested by Walsh,
Bain, Christie, Mckay, Chantiam and Kozak in First Response, was used to
purchase Leximco.
PIN Consulting Group Inc.
63.
on December 1, 2014 I reviewed a five page Consulting Services Agreement

between PIN and the OPPA, attached as Appendix B. This Agreement was
signed on August 20, 2014 by Mckay, on behalf of PIN and witnessed by Vieira.
26
There was no signature on the Agreement by a representative of the OPPA.
The document contains the following information:
a. PIN will assist with research, negotiation and conclude beneficial
opportunities for the purpose of enhancing Association membership, more
specifically but not limited to: real estate investments; commercial
investments, vacation properties opportunities, travel benefits through
various travel agencies by securing exclusive rates for members and their
families; and any other such opportunities that the Corporation was able to
procure as a deliverable service under this Agreement, and directed by
the client.
LI
[.
b. PIN would provide reports on an ongoing basis and not less than once
every six months to the OPPA as to the performance of the services under
the agreement.
c. The Agreement shall be in effect commencing July 1, 2014 and terminate
on July 1, 2017. The Agreement may be renewed and the either party
may terminate the contract with 90 days written notice without cause.
The OPPA may terminate the agreement for cause without giving notice.
d. The OPPA shall pay $5,000.00 per month plus sales tax for services. In
addition the OPPA shall pay travel expenses for mileage at a rate of $.601
km, accommodations, meals, airfare and incidental costs.
64.
I have reviewed the corporation profile for PIN and noted the following:
a. It was registered on June 6, 2014;
26
Tait had stated that there was an agreement between PIN and the OPPA that was signed by Walsh and Christie. I
do not know if there was anything different in the version that she has referred to.
Page 37 of 88
b. Mckay was the sole director;

c. The registered office was listed at 702170 Bloor Street West, Toronto
Ontario (Mckays Law Office) and Mckays executive assistant, Vieira,
was listed as a contact person. This address was also the office of
Mckays other businesses including: Amax Security Solutions Inc. and
Amax Intelligence Inc.
65.
As stated above in his statement to investigators, Elia had seen emails

demonstrating that Walsh, 8am and Christie were financially benefitting from the
OPPA consulting fees that were being paid to PIN. Specifically that fees
charged to the OPPA by PIN were being used to pay for $30,000.00 worth of
shares of First Response for the benefit of Walsh, Christie, and Bain.
66.
The total value of this consulting fee contract over the three year team was
$180,000.00, plus HST and travel.
67.
Thus far PIN has allegedly been involved with the following activities:
a. The purchase of the condos in the Bahamas worth over $2 million.
Though PIN was not directly mentioned, the backup documentation for the
condos purchase was being held by Mckay and Vieira.
b. The introduction of Kozak and First Response to the OPPA which was
being used for the purchase of OPPA employee and OPPA membership
travel, and for the negotiation of contracts worth an estimated $400,000.00
in relation to the OPPAs AGM, Spring Board meeting and its Golf
Tournament.
c. The New Providence investment which has commenced with a
$100,015.00 OPPA investment, and was to be promoted to the OPPA
members for their personal investment.
d. The procurement and development of the land for the new OPPA office in
Oro, Ontario. The Board announced on February 19, 2015 that the OPPA
will be spending $100,000.00 on a site assessment for the property. This
amount was broken down into two parts; $50,000.00 for the work and
27
$50,000.00 for consulting fees with an expected 10% overrun.
e. An investment with the Caldwell Group whereby Caldwell will earn .5%
and PIN will earn .5%. This investment was approved by the Board and
further details were not known at this time.
27
The firm that will be receiving the consulting fees is unknown at this time.
Page 38 of 88
68.
The recommendations made by PIN have been the focus of the complaints and
concerns voiced by the OPPA employees. It is unclear who actually works for
PIN and if there was any benefit that this company will bring to the OPPA. The
office manager, Tait who usually knows everything about the business activities
of the OPPA is being kept in the dark in relation to PIN for reasons that she
cant explain. The financial risk associated to the alleged recommendations that
have been made by PIN is very significant for the OPPA and its membership. If
the controlling minds of PIN do not have the best interest of the OPPA in mind,
the negative financial consequences could place the OPPA in jeopardy.
New Providence Income Fund Ltd.
69.
Concerns have been raised by employees of the OPPA and the auditor in
relation to the OPPAs offshore investment of $100,015.00 in 100 Class A
shares of New Providence on August 28, 2014. Witnesses have stated that it
was Walshs intention to promote this investment to the membership of the
OPPA. Walsh had advised that the funds invested by the OPPA were required
so that the OPPA members could also invest in this security.
70.
The investment was described in the 2014 OPPA Financial Report, Notes to the
Financial Statements, as follows: On August 28, 2014 the Association invested
in 100 class A shares of New Providence Income Fund Ltd. (the Fund9. The
Fund is a company incorporated under the Companies Law of the Cayman
Islands as an exempted company limited by shares. The Fund is registered as a
mutual fund: The Fund:s in vestment objective is to deliver consistent returns
with enhanced protection of investment principal. It aims to achieve overall
returns of between 10 and 15% per annum net of fees and operating expenses.
It intends to generate the returns to accomplish this objective through investing
in a wide range of loans and securities and financial instruments. Subject to the
availability of distributable amounts and the discretion of the directors the Fund
intends to declare and pay dividends on the shares on a quarterly basis in an
amount representing a yield of 7% on the subscription amount.
71.
On November 19,20141 conducted internet checks and was unable to find a

prospectus for this company. It does not appear that it has filed any materials
with any Securities Regulators in Canada, and there was no evidence that these
securities were approved to sell in Canada. In addition, I could find no
information published for this company since January 25, 2013, or any
information published pertaining to any regulation or oversight over this
company.
72.
I also have reviewed other documents found on the Internet that contained
unverified comments on New Providence including:
a. An article published by Nassau Guardian Business Reporter, Jamal Smith,
titled Loan activity picking up at SFG Inc. which mentions the launch of
Sterling Financial Groups third mortgage fund called New Providence
Page 39 of 88
Income Fund. A company representative states that the fund has already
seen a 5.22 percent return.;
b. A news release, dated January 25, 2013, published by SFG Inc., the
manager and promoter of New Providence, reporting that the Fund had
returned 1.01% netto its investorsforthe month ended December3lst,
2012 representing a 19.27% return for the year. Fund investors were
being paid out an interim dividend of approximately 12.27% per annum
compounded return which was supplemental to the 7% per annum
preferred return paid out as quarterly dividend;
c. Information from Business Week that only stated that that New
Providence did not have any Key Executives recorded and the words
Cayman Islands in the company overview;
d. A new release on Localbahamas.com prepared by SFG Inc. announcing
that New Providence Income Fund Announces a New Director on January
25, 2013, Mr. Mike Harris, the former premier of Ontario; and
e. Information located on the BMO website for information purposes only.
BMO advised that as required the company must file a prospectus with a
securities commission before their securities can be sold in Canada. As
mentioned above, I was unable to locate any information to suggest that
this company had filed a prospectus with any regulator in Canada.
73.
I reviewed a copy of the OPP Association Constitution and By-Laws, dated May
2014 and noted the following in relation to investments. Monies accumulated
by the Corporation may be in vested from time to time with the subsequent
approval of a General Meeting, and shall adhere to investment policies,
standards and procedures that a reasonable and prudent person would apply in
respect of a portfolio to avoid undue risk and obtain a reasonable return. (Page
24 and 25). I believe that this investment is a significant deviation from the risk
adverse strategy demonstrated in the OPPAs historic investment choices.
74.
Tait advised that the OPPA was in possession of a 72 page document

containing 14 pages of risk related warnings in relation to this investment. I
have not viewed this report, but based on my knowledge and experience, and
the limited information I have gathered, I believe that this offshore investment
places OPPA funds at undue risk. Given all of the investment choices available
to management, I am unable to think of any legitimate reason why OPPA funds
would be invested in this company, and why they would want to market this fund
to the OPPA members they represent.
Condos at I Cable Beach in Nassau, Bahamas
75.
Concerns have been raised by employees of the OPPA and the auditor in
relation to a deposit of $20,000.00 that was placed on Walshs OPPA issued
Page 40 of 88
Visa to secure the purchase of two condos in Nassau, Bahamas. The deposit
for one of the condos has since been returned and according to the Draft Letter
from the Auditor, dated October 17, 2014, the OPPAs investment is for
$13,128.00 on a condo worth $1,563,000.00 USD located at 1 Cable Beach in
Nassau, Bahamas.
[i
U
76.
None of this information was disclosed to the OPPA membership at the AGM or
in the 2014 OPPA Financial Statements. There is no evidence that there was
any consultation with the OPPA Board prior to this purchase. The purchase of
two condos, worth over $2 million US, is a very significant investment for the
OPPA.
77.
This investment involves an offshore jurisdiction, specifically the Bahamas, it

exposes the OPPA to undue risk, and it is inconsistent with the investment
strategy of the OPPA. This investment was described by Walsh to be for the
purpose of making a profit by renting out the condos, which according to one
witness could place the OPPAs status as a not-for-profit organization in
jeopardy.
2014 OPPA Audit:
78.
LI
Witnesses have advised the auditors from Powell Jones performed the 2014
audit and at the conclusion of their audit they expressed many concerns that
were outlined in a three page letter, attached as Appendix C. The letter is for
the purpose of communicating the findings of an audit of the accounts of the
OPPA for the year ending August 31, 2014. Upon my review of this letter, I
learned of the following specific matters that were identified:
a. Instances were noted where there was a lack of back up to support the
reimbursement of expense claims and Visa statements.
b. A vague investment policy that did not specify what type of investment
was acceptable.
c. Accrual amounts for receivables and liabilities had not been updated from
the prior year.
d. Not all investment income and management fees were being recorded on
a monthly basis.
e. Significant unusual transactions were identified including: a deposit of
$13,128.00 for a property located at I Cable Beach in Nassau, Bahamas
which was being purchased by the OPPA for $1,563,000.00 USD; and the
purchase of 100 class A shares of New Providence, a foreign investment
of the Cayman Islands which occurred on August 28, 2014 and required
the cash outflow of $1 00,01 5.00.
Page 41 of 88
f.
There were no disagreements with management during the audit and

management acknowledged recommendations made by the auditor and
provided a response to address the identified issues.
g. The audit did not identify any illegal acts, acts of fraud, misappropriations
of assets, intentional misstatements or errors, which were not otherwise
reported.
h. Management advised the auditor that no related party transactions

occurred. It is managements responsibility to disclose to the auditor if it
was aware of or suspected any related third party transactions had
occurred. The auditor conducted various tests to identify transactions
considered to involve related parties and found that all related party
transactions that were identified in the audit had been disclosed in the
notes of the financial statements.
79.
Witnesses have advised the following:

a. The letter was presented by the auditor to the three members of the OPPA
Audit Committee: Bruce Qwigg; Dave Vitti; and Dave Sanbatini in the
presence of Bain, Taft and Barendregt. Christie attended the meeting to
speak to the Audit Committee members who were content with his
explanations. One witness stated that Christie fluffed off the issues.
b. The auditor, Ferguson of Powell Jones was to present to the Board of
Directors this year but Walsh called it off.
c. Walsh was not a member of the OPPA Audit Committee but he was
responsible for selecting the Audit Committee members. It is also alleged
that Walsh wrote the OPPA Audit Committee Report that claimed that their
audit found nothing wrong.
d. At the AGM the delegates were not given time to review the financials
prior to the meeting. This is the first year that Walsh opted out of going
through the financials line by line at the AGM.
e. Ferguson advised Walsh that it was his intention to bring up the
deficiencies he had found at the AGM. However, Barendregt advised
Ferguson that the OPPA intended to fire him, and for unknown reasons
the issues were not presented at the AGM. Instead the audit was
presented as clean, and none of the issues found in the audit were
mentioned in the Independent Auditors Report or the Auditors AGM
Presentation.
80.
As demonstrated by the information provided by the witnesses there was

interference in the audit process and the reporting of related party transactions,
by the senior members of the OPPA, who are the subjects of this investigation.
Ultimately, the 2014 OPPA Audit publicly concluded that there were no illegal
Page 42 of 88
acts, related party transactions or even minor issues. The auditors findings
were based on the information that was presented to the auditor by the OPPA
and by management. There is no evidence to suggest that the auditor was privy
to any information that demonstrates that Walsh, Bain and Christie are
financially benefiting from the OPPAs relationship with PIN and First Response.
As stated in the letter prepared by the auditor, OPPA management has an
obligation to advise the auditor of related party transactions and did not do so.
Management advised the auditor that no related party transactions occurred. It
is managements responsibility to disclose to the auditor if it is aware of or
suspects any related third party transactions have occurred.
OPPA Association Financial Report Presented at the OPPA Annual General

Meeting
81.
82.
On November 18, 2014 I reviewed a package entitled the 2014 OPP Association
Financial Report that was received by McNamara at the 2014 OPPA AGM. I
have included this document at Appendix D and provided a summary of
relevant information.
OPP Association Constitution and By-Laws
On November21, 2014 I reviewed a copy of the OPP Association Constitution
and By-Laws, dated May 2014. I have included this document at Appendix E
and provided a summary of applicable sections pertaining to the structure of the
OPPA, specific roles of OPPA employees and board members, honoraria
employment contracts, expenditures, contracts and investments.
S u rye ii lance:
83.
Between November 20, 2014 and February 19, 2015, physical surveillance was
conducted on the subjects of investigation and the associated businesses,
namely, Christie, Bain, Walsh, Mckay, kozak, Chantiam, First Response,
Leximco and PIN Consulting. The objective of surveillance was to determine any
associations between the subjects of investigation and the businesses as well as
confirming the places of residence and business. The results of the surveillance,
relevant to this investigation, are summarized throughout this ITO including in
the places to be searched section of this ITO.
Summary of Grounds:
84.
I have reasonable grounds to believe that the offences of criminal breach of

trust, fraud, theft and money laundering have been committed. I base my belief
on the following as set out in this ITO:
Page 43 of 88
a. That four witnesses employed by the OPPA have provided sworn witness
statements in relation to criminal offences committed by senior members of
the OPPA. These witnesses have viewed emails allegedly from Walshs
OPPA email mailbox that describe specific offences of fraud and theft that
have been committed by Walsh, Christie and Bain, against the members of
the OPPA, utilizing the companies First Response and PIN Consulting.
Emails reveal that the fraudulent scheme has been carried out with the
knowledge, guidance and assistance of Mckay, Kozak and Chantiam;
b. That after Walsh, Christie and Mckay took two trips to the Bahamas in 2014,
they made significant investments in the Cayman Islands and the Bahamas
on behalf of the OPPA. These investments have exposed the OPPA
membership to financial risk and allegedly involve PIN, a company that has
allegedly been used to defraud funds from the OPPA membership;
c. That concealment of the beneficial ownership of a company using trustees
and offshore schemes is a technique used by those in Canada and
internationally who wish to commit fraud and launder proceeds of crime. The
use of an offshore company makes it difficult if not impossible to obtain
necessary evidence in a timely fashion;
d. That funds being paid by the OPPA to PIN Consulting, via Andrew Mckay,
are allegedly being laundered, specifically to pay for shares in First Response
Travel on behalf of Bain, Walsh and Christie. The use of a lawyer to conceal
beneficial ownership, and to act publicly as the directing mind of a company is
a technique used by those in Canada and internationally, who wish to commit
fraud and launder proceeds of crime. The protection afforded to
presumptively solicitor-client privilege material that is stored in a lawyers
office makes it laborious, expensive and almost impossible for investigators to
obtain necessary evidence in a timely fashion;
e. That CAO Karl Walsh, President Jim Christie and Vice President Martin Bain
have made numerous decisions that demonstrate an intentional lack of
stewardship and accountability. I believe that they have financially benefitted
from their actions, breached the trust of the OPPA membership, and placed
the OPPA and its membership at a significant financial risk.
Judicial Authorizations Sought:
Solicitor-Client Privilege Considerations:
85.
I understand that solicitor-client privilege is a principle of fundamental justice

embodied in section 7 of the Charter of Rights and Freedoms. I am seeking to
search the law office of Andrew Mckay where business records and other
material relevant to this investigation, which I believe do not pertain to the
practice of law, have been commingled with solicitor-client privileged material. I
have considered whether it is possible to request a production order to obtain
Page 44 of 88
the things sought. I am aware that a production order would be a less disruptive
and intrusive manner to acquire the things sought, however, McKay is in control
of the things sought, and he is a subject of this investigation. I believe that
McKay is conflicted and also unable to provide the things sought without
potentially incriminating himself. I have considered other options and there is no
other alternative to obtain the things sought than to search this location. It is
imperative that the evidence be collected, and I am unaware of an alternate
location where the things sought could be located.
86.
I am also seeking a search warrant for the OPPA office, OPPA offsite
offices\residences, three OPPA owned vehicles and two Production Orders for
emails that were copied from the OPPA server for the accounts used by Walsh,
Bain and Christie. I believe that some of the work done by the OPPA on behalf
of the members involves lawyers, both in house OPPA lawyers and external
counsel including Andrew Mckay. For this reason I believe that there is
information that is protected by solicitor-client privilege at the OPPA office. I am
aware that there are three lawyers who are employed by the OPPA, Gavin May,
James Girvin and Michelle Hamilton-Mayers. Their offices are on the third floor
away from other employees of the OPPA, and this is also the area where their
paper files are located. The OPPA lawyers have their own drive on the OPPA
server, which is called Drive L. Only legal staff members of the OPPA, Ella and
Walsh have access to the L Drive. Investigators will not be searching for the
things sought on the L-Drive or on the third floor where the lawyers work and
store their files.
87.
This ITO outlines the grounds to support multiple judicial authorizations that
would be executed simultaneously. As described, one of the locations is a law
office, and in other locations associated to the OPPA there is possibility that
solicitor-client privileged material may be encountered. For each judicial
authorization sought, I have proposed conditions to ensure the maximum
protection of solicitor-client privilege. In the conditions, I have proposed the
appointment of Court Appointed Referees, Independent Computer Forensic
Examiners (ICFE) and a Chief Referee to perform the post execution process
and proceedings required to protect solicitor-client privilege.
88
I have discussed this proposal with Janice LaForme, Senior Counsel of the
Professional Regulation Division of the Law Society of Upper Canada (LSUC).
She sent me an email on February 23, 2015 stating the following:
9
-
a. To my knowledge the appointment by a Court of more than one lawyer to

act as an independent Referee in the context of one criminal investigation
where the maximal protection of privilege is a concern is not in and of itself
contrary to the Supreme Court of Canada 2002 decision in Lavallee and
other common law jurisprudence. In my view consideration should be
given to inclusion of terms and conditions of a search warrant and / or
assistance order that would:
Page 45 of 88
i. Recognizes and affirms the role of the Court as the sole arbiter of
privilege.
ii. Address the role and responsibility of each Referee; that of a
Senior! Chief Referee and an Assistant Referee.
ill. Address the relationship between a Senior! Chief Referee and
the Court.
iv. Ensure the real and apparent independence of the Senior!Chief

Referee and Assisting Referees from Crown, law enforcement
and targeted lawyer or third party suspect (Referees need to be at
arms length from these parties)
v. Ensure that Senior!Chief Referee and Assisting Referees are
individuals licensed to practice law in Ontario and are members of
good standing with the Law Society of Upper Canada.
89.
I have ensured that the conditions laid out in this ITO are in accordance with the
recommendations made by LaForme and the Law Society Guidelines.
28 I have
also ensured that each of the Referees proposed are acceptable to LSUC.
Things Sought Are Not Protected By Solicitor-Client Privilege:
90.
As described in the grounds of this ITO one of the individuals under investigation
is a lawyer named, Andrew Mckay. On November 12, 2014, I searched the
Lawyer Directory on the Law Society of Upper Canada website and found that
Andrew Peter Mckay is a licensed lawyer. His status is In Private Practice.
The website lists his business as Andrew McKay Law Professional Corporation
located at 702-170 Bloor Street West, Toronto, Ontario. However, as described
in the grounds for this ITO Mckay and his firm Warren Mckay Geurts
Bellehumeur have relocated to Suite 903 180 Bloor Street West, Toronto,
Ontario.
91.
I conducted open source Internet checks on Mckay and found his Linkedln page
which states:
a. Barrister & Solicitor Warren Mckay Geurts Bellehumeur, 1999 Present
(15 years) Mr. Mckay is a private practitioner of Law in Toronto, Canada.
His practice includes conducting criminal and administrative prosecutions
and defense. He also has extensive expertise and experience in training
investigative personnel in the area of search and seizure, investigations,
and the rules of evidence. In conjunction with his policing background and
superior advocacy experience, Mr. Mckay has built up his firms reputation
28
The Law Society Guidelines and the email from Janice LaForme are included at Appendix F.
Page 46 of 88
for the representation of police officers throughout Canada on criminaI

regulatory and discipline matters including Special Investigations Unit
(SIU) investigations. Furthermore, Andrew has been the key coordinator
and facilitator of several courses for various provincial ministries across
Canada.
b. In the Projects section it states, CounseI Past and Present for Ontario
Provincial Police Association, Toronto Police Association, York Region
Police Association, Durham Region Police Association, Cob ourg Poilce
Association, Port Hope Police Association, Orange ville Police Association,
Niagara Region Police Association, Windsor Police Association, Ministry
of the Attorney General, Per Diem Crown Attorney, RCMP and Peel Police
Association.
92.
I have viewed the Website of Warren Mckay Geurts Bellehumeur and I noted
the following information Warren Mckay Geurts Bellehumeur offers experience
in select areas of Criminal Law. Our areas of concentration include: fraud,
sexual offences, driving offences, domestic issues as related to the Criminal
Code, Youth Criminal Justice Act Matters and Representation of Professionals.
93.
In addition to his law practice, according to his Linkedln Profile, Mckay is the
President and CEO of Amax Security Solutions Inc., and the President and CEO
of Amax Intelligence Inc. These businesses, along with PIN share the same
corporate office address as Mckays law practice, 702170 Bloor Street West,
Toronto, Ontario.
94.
As described by Elia, Mckay and Vieira have fully vacated 702170 Bloor Street
West, Toronto, Ontario. Mckays legal files and both Mckays and Vieiras
computers are now located at Suite 903 180 Bloor Street West, Toronto,
Ontario. I believe that Mckay has also moved information related to his non-law
firm businesses including PIN to Suite 903 180 Bloor Street West, Toronto.
[t.
95.
I have met Mckay on one occasion in 2003 when he was present in the capacity
of legal counsel representing his client. I was one of two police officers who
obtained a warned statement from his client. Mckay was professional and our
interaction on that date was respectful and courteous. I have no personal
knowledge of any other cases that McKay has worked on.
96.
Some of the evidence being sought contains communication to, or from, Mckay.
Mckay is a lawyer but I do not believe that the things sought are protected by
solicitor-client privilege for the following reasons
a. Mckay practices criminal law and the things being sought are not related
to criminal law. There is no evidence to demonstrate that Mckay practices
law in relation to real estate, investments, or corporate law of any sort.
Page 47 of 88
b. Some of the things being sought relate to travel businesses; First

Response and Leximco for which Mckay is allegedly a director and a
beneficial owner. Mckay was identified to the OPPA as Kozaks boss in
relation to the travel business. For this reason, I believe that solicitorclient privilege does not apply to communications to or from McKay, in
relation to First Response and Leximco.
c. Some of the things being sought relate to PIN. McKay is a director of this
company. He and his executive assistant, Vieira, were the only individuals
known by investigators to be overtly associated to PIN. McKay appears to
be a directing mind of PIN. For this reason, I believe that solicitor-client
privilege does not apply to communications to or from McKay, in relation
to PIN.
d. There is no indication that Mckay has performed legal work for the named
companies or individuals in relation to the things being sought.
97.
This ITO outlines the manner in which Mckay has communicated with the other
targets of this investigation, allegedly for the purpose of committing a crime or a
fraud, and any such communication would not be protected by solicitor-client
privilege. As described in this ITO:
a. Mckay is a director of Leximco and PIN.
b. He traveled to Bahamas with Walsh and Christie and this trip resulted in:
the purchase of the condos in the Bahamas and the investment in New
Providence;
c. He introduced Kozak and Chantiam to the OPPA and attended the OPPA
to discuss performance issues with Kozak in relation to travel services.
During that meeting McKay was described as Kozaks boss;
d. McKay is an owner of First Response, and has allegedly hidden his own
beneficial ownership, and that of Bain, Walsh and Christie through an
offshore scheme;
e. He has used his office as the registered office of PIN. This office invoiced
the OPPA a monthly consulting fee of $5,000.00, received these
payments, and allegedly used $30,000.00 to pay for shares in First
Response for the benefit of Bain, Christie and Walsh.
f.
Through PIN, he has allegedly been involved with the procurement and
development of land for the new OPPA office in Oro, Ontario. It is also
possible that he introduced his brother to the OPPA to work on this
project.
Page 48 of 88
g. McKay has allegedly pitched the OPPA on an investment with the

Caidwell Group whereby Caldwell will take .5% and PIN will take .5%.
h. McKay is holding business documents at his office that are relevant to this
investigation including the backup documentation and information about
the condos that are to be purchased in the Bahamas, and records
associated to PIN, Leximco and First Response.
Search Warrant for 903
98.
180 Bloor Street West, Toronto, Ontario:
In addition to being a location where Mckay keeps his business records, Suite
903 180 Bloor Street West, Toronto, Ontario is also a law office, and it is
shared with up to eight other lawyers. I believe solicitor-client privileged material
is stored at this location. With the exception of things that are clearly not
protected by solicitor-client privilege, such as share certificates and personal
material belonging to Mckay, I propose that paper and electronic material that is
seized during the search be treated as presumptively privileged and not be
examined by police until otherwise directed by the Court. Further detail on the
proposed methodology for this search, including the proposed method to handle
electronic data is described below.
-
Things Being Sought from 903-180 Bloor Street West, Toronto:

99.
I am seeking to seize the following things from Suite 903

West, Toronto, Ontario:
180 Bloor Street
a. All records in paper and electronic format pertaining to:

I. PIN Consulting Group Inc.;
ii. Leximco Ltd. (operating as Leximco Travel);
iii. First Response Travel Group; and
iv. An unknown offshore company which is believed to be associated
with one or all of the following individuals: Karl Walsh, Jim Christie,
Martin Bain, Andrew Mckay, Klara Kozak or Noel Francis
Chantiam;
including but not limited to the following:
1. All financial documents and records such as: banking
records and copies thereof, bank statements, cancelled
cheques, deposit slips, debit and credit memos, cheque
stubs, cheque registers, credit card statements, loan
accounts, investment accounts both domestic and foreign,
money transfer receipts, mortgage and loan agreements,
account applications, mortgage applications, credit card
applications, bank correspondence, accounting records,
Page 49 of 88
general ledgers, journal entries, sales invoices, purchase

invoices, expenses, fee schedules, correspondence files,
financial statements, net worth statements, working paper
files, permanent files containing information on shareholders,
shareholder meetings, details of long term debt, details of
capital assets, deed documents and other supporting
documents; and
2. Income tax documents, including but not limited to original
and copies of the T2 returns of income including all
supporting documentation such as financial statements,
correspondence and working papers;
b. All records in paper and electronic format pertaining to domestic and
foreign investments which are associated with any of the following:
Ontario Provincial Police Association (OPPA), Karl Walsh, Jim Christie,
Martin Bain, Andrew McKay, Klara Kozak or Noel Francis Chantiam,
i. Condominiums at I Cable Beach, Nassau, Bahamas;
ii. Investment with the New Providence Income Fund Ltd. and the
Sterling Financial Group Inc.;
iii. Investment with the CaIdwell Group;
iv. The OPPA procurement planning, assessment and development of
land for the proposed new OPPA Head office;
v. Investment in Leximco Travel;
vi. Investment in First Response Travel Group;
vii. Investment in an unknown offshore company; and
viii. Investment in PIN Consulting Group Inc.
c. All records in paper and electronic format pertaining to funds being
transferred to and received from, or on behalf of Karl Walsh, Jim Christie,
Martin Bain, Kiara Kozak, Noel Francis Chantiam, the OPPA, First
Response Travel Group, PIN Consulting Group Inc., or Leximco Travel;
d. All records in paper and electronic format pertaining to Karl Walsh, Jim
Christie, Martin Bain, Klara Kozak, Noel Francis Chantiam, Barry Mckay,
Elena Rabenok, the OPPA, First Response Travel Group, PIN Consulting
Group Inc., or Leximco Travel, including but not limited to emails, letters
and faxes;
e. All records in paper and electronic format pertaining to tax returns for
Andrew McKay.
Page 50 of 88
Summary of grounds for Belief the Things being Sought will be Located
at Suite 903 180 Bloor Street West, Toronto, Ontario:
-
100. I believe that evidence will be found in this location for the following reasons:
a. The address 702 -170 Bloor Street West, Toronto, Ontario, was the address
associated to Mckays companies including PIN Consulting, Amax
Intelligence Inc., Amax Security Solutions Ltd., and Andrew Mckay Law
Professional Corporation. On their individual Linkedin profiles, McKay and
Vieira state that they work at Warren McKay Geurts Bellehumeur. The
website for Warren Mckay Geurts Bellehumeur provides the address of Park
Plaza 170 Bloor Street West, Suite 702, Toronto, Ontario;
b. Elia has provided a statement to investigators advising that McKay and the
other lawyers from his practice have moved from Suite 702 -170 Bloor Street
West, Toronto, Ontario to Suite 903 180 Bloor Street West, Toronto,
Ontario. Elia advised that Mckay does not have any other belongings left in
his former office. I believe that the contents of Mckays office have been
moved to Suite 903 180 Bloor Street West, Toronto, Ontario;
-
c. I believe that Mckay works at this location as he was witnessed at this

address by investigators. Elia has done work at this location for Mckay and
was told by Mckay that he was commencing work at this office in the week
commencing March 2, 2015;
d. Elia has advised that both McKay and his assistant, Natasha Vieira have
computers in this office. As Mckay has been party to email correspondence
with Walsh, Bain, Christie and others specifically pertaining to the offenses
under investigation, I believe that the computers and other electronic devices
that were used to create, send and receive the electronic communications
sought will be located in this office;
e. The corporation profile for PIN lists the registered office as Natasha Vieira
702-170 Bloor Street West, Toronto, Ontario. The Consulting Services
Agreement between the OPPA and PIN Consulting is signed by Mckay and
witnessed by Vieira. The OPPA was being billed by PIN with an address of
702-1 70 Bloor Street West, Toronto, Ontario. Elia has advised that Vieira has
also moved into the new location of Suite 903 180 Bloor Street West,
Toronto, Ontario. As McKay and Vieira are the only names publicly known to
be associated to PIN, I believe that records associated to PIN will be found in
this location;
-
f.
Vieira possessed details on the Bahamas condo development schedule.

Walsh advised OPPA staff that McKay was to be contacted when backup
documentation was required for the purchase of the condos in Nassau,
Bahamas. The address on this backup information was McKays previous
Page 51 of 88
Summary of grounds for belief the things sought will be located at Ontario
Provincial Police Association Office located at 119 Ferris Lane Barrie, Ontario:
129. As described in this Information to Obtain the Ontario Provincial Police
Associations head office is located at 119 Ferris Lane, Barrie, Ontario.
130. I believe the things sought will be found at 119 Ferris Lane, Barrie, Ontario
because of the following evidence provided by the four witnesses in their
statements:
a. The OPPA head office is located at 119 Ferris Lane, Barrie, Ontario.
b. Hardcopy financial records and documents are maintained at the OPPA
office and are accessible by Barendregt.
c. Elia, Barendregt and Tait are the only three people in the OPPA who have
access to the OPPAs financial information on Quick books.
d. Contracts and investment documents are stored on the server and
Barendregt and Tait have access.
e. OPPA email accounts that are stored on the OPPA server and accessible
by Elia.
f.
The minutes for meetings of the Board of Directors are stored on the
OPPA server.
g. It is the OPPAs practice to scan all documents and save them to the
server.
h. Bain, Walsh and Christie have offices on the main floor of the OPPA
where they spend a portion of their work days.
i.
There is information pertaining to the OPPA purchase and development of

land for the proposed future new OPPA office inside Walshs office.
Time of Execution:
131. I propose that the search commence during the normal working hours of 8:00
a.m to 4:00 p.m. This will allow for the assistance of OPPA employees who
have access to the things sought.
Assistance Orders:
132. I propose that the following OPPA employees be required by the Court, pursuant
to an Assistance Order, to assist police, the Referee and the ICFE to locate the
things being sought during the search of 119 Ferris Lane, Barrie, Ontario: Curtis
Page 60 of 88
Elia (manager of IT), Kimberly Tait (office manager), and Sandra Barendregt
(bookkeeper).
133. As has been described in their witness statements, as part of their duties, these
three employees have full access to the things being sought. I am proposing
that these employees, instead of the police, do the searching at the OPPA office
for the things being sought. In doing so, these employees may request the
assistance of other employees of the OP PA.
134. I propose that the following lawyer, who has been approved by the LSUC and is
acceptable to the Crown, be appointed by the Court pursuant to an Assistance
Order, to perform the duties of the Chief Referee with respect to the execution of
the office search warrant at 119 Ferris Lane, Barrie, Ontario:
Scott Hutchison
3rd Floor
Toronto, Ontario
LSUC # 29912J
135. I propose that the following ICFE, who is a certified forensic examiner, and
persons under his direction, be appointed by the Court pursuant to an
Assistance Order, to assist the Police and the Chief Referee in the search and
seizure of electronic devices and media
31 at 119 Ferris Lane, Barrie, Ontario:
Wayne Doney
400 Queens Ave., London, Ontario,
Special Conditions for the Search of the OPPA Office located at 119 Ferris
Lane Barrie, Ontario:
136.
Police will not be searching for the things sought on the L-Drive of the OPPA
Server, or on the third floor of the premises, where the OPPA lawyers work and
store their files.
Search Procedures for Paper Things:
137. Curtis Elia, kimberly Tait, and Sandra Barendregt, will be presented with the
Order and be directed to locate the paper things being sought, or some part of
Electronic Devices and Media means any computers, lap tops, servers, servers used in cloud computing and the
like and peripheral media on which data can be found. It may include, but is not limited to, photocopy machines, fax
machines, Blackberrys, Palm Pilots, Smartphones, memory sticks, cell phones, mobile phones, GPS devices,
lPhones, iPods, USB, cDs, DVDs, zip disks, floppy disks, backup tapes and the forensic image of an electronic
device/media.
j
Page 61. of 88
them. Once these said paper things are located, they will be viewed by the
Chief Referee, who will assert solicitor-client privilege, if applicable.
138. The Chief Referee will seize the things over which solicitor-client privilege is
asserted. The Chief Referee will maintain continuity, security, and store all of the
paper things over which solicitor client privilege is asserted.
139. The police will review and may seize the paper things located by Curtis Elia, Kim
Tait and Sandra Barendregt when there is no assertion of privilege made by the
Chief Referee.
Search Procedures for Electronic Equipment, Devices and Media:
140. Curtis Elia, Kimberly Tait, and Sandra Barendregt will be presented this Order
and directed to locate the things being sought or some part of them which are
stored electronically. Once a thing is located, it will be viewed by the Chief
Referee, who will assert solicitor-client privilege if applicable.
141. With the assistance of the ICFE the Chief Referee will seize a true electronic
copy of the said things stored electronically when solicitor-client privilege is
asserted. The Chief Referee will maintain continuity, security, and store all
things seized over which solicitor-client privilege is asserted.
142. With the assistance of the ICFE the Police will seize a true electronic copy of the
electronically stored things located by Curtis Elia, Kim Tait and Sandra
Barendregt when there is no assertion of privilege made by the Chief Referee.
Search Procedures for Emails:
143. In relation to the email accounts utilized by Karl Walsh, Jim Christie and Martin
Bain, because of time constraints it may not be possible to review and seize all
said things on the day of the search, in the manner as described above. If that is
the case, the ICFE will take whatever steps are necessary to seize a true
electronic copy of the email accounts. The ICFE will maintain continuity and
security over the true electronic copies, and conduct a further forensic
examination offsite for the things being sought
-]
Search Procedures for Devices and Media Utilized by Karl Walsh. Jim
Christie and Martin Bain:
144. The ICFE will image the devices and media utilized by Karl Walsh, Jim Christie
and Martin Bain to create a sound duplication of the devices and media. It is
anticipated that the ICFE should be able to image the devices and media on site.
However, in the event that this is not possible, the devices and media will be
seized by the ICFE. The ICFE will make further attempts to image the devices
Page62of88
and media offsite. The ICFE will document a description of the device or media
and where it was located.
Offsite Forensic Examination by the ICFE:
145. The ICFE will take steps to locate the said things on the devices or media, or the
images of the devices or media, including but not limited to the following:
c. The ICFE will conduct key word searches on the true electronic copies, the
devices or media, or the images of the devices or media. The list (s) of key
words will be supplied to the ICFE by the Sergeant Gordon Aristotle or his
designate.
d. The ICFE will provide all things located as a result of the key word searches
to the Chief Referee.
146. The ICFE will maintain continuity, security, and store the true electronic copies,
the devices or media, or the images of the devices or media, until the forensic
examination is completed. Upon the completion of the forensic examination the
!CFE will deliver all electronic devices and media, whether imaged, copied or
seized, and any copies or images thereof to the custody of the Chief Referee.
Post Seizure Duties of the Chief Referee:
147. The Chief Referee will receive the said things seized by the ICFE from the
search site. Upon receipt, the Chief Referee will maintain continuity and security,
and be responsible for the storage of both the things he seized, in paper and
electronic form, and the things seized by the ICFE until otherwise ordered by the
Court.
148. If the Chief Referee does not assert privilege over a thing it will be released to
myself, or my designate and make arrangement for the release of the thing.
149. In the case of any thing where privilege has been asserted the Chief Referee will
separate the things into three categories, and prepare a report that will provide
the Court with rationale why the thing:
a. In the opinion of the Chief Referee is not protected by solicitor client
privilege.
b. In the opinion of the Chief Referee may be protected by solicitor client
privilege.
c. In the opinion of the Chief Referee should be protected by solicitor client
privilege.
Page 63 of 88
150. The Chief Referee will be responsible for notifying clients who have been
affected by the execution of the search warrant, or whose things have been
seized pursuant to the search warrant. This notification will occur as soon as
reasonably practicable following the execution of the search warrant and may
a
fl
U
The seizure of any of their things,

authorities;
f.

and

of the search for and seizure of their things.
151. The Chief Referee may notify the clients either verbally or in writing and may
the Court.
Search Warrants For Three OPPA Offsite OfficeslResidences and Associated
Vehicles:
152. I am seeking Search Warrants to seize the things listed below from the following
addresses and vehicles:
a. 7 Maple Court, Oro-Medonte, Ontario (The offsite OPPA office!
residence of Martin Bain);
b. The black Ford Edge, with license plate BMKL586 registered to the
Ontario Provincial Police Association and driven by Martin Bain;
c. 193 Maple Dawn Drive, Midland, Ontario (The offsite OPPA office!
residence of Jim Christie);
Page 64 of 88
d. The black Ford Edge, with license plate 07YR15 registered to the
Ontario Provincial Police Association and driven by James Christie;
e. The residence in the southeast part of the property designated as
4153/4155/4157 3rd Line, Bradford, West Gwillimbury, Ontario (The
offsite OPPA office! residence of Karl Walsh);
f.
The black Ford Edge with license plate 07YR16 registered to the
Ontario Provincial Police Association and driven by Karl Walsh;
Things Being Sought for the Three OPPA Offsite Offices/ Residences and
Associated Vehicles:
153. I am seeking to seize the following things from the locations noted in the
previous paragraph:
a. All records in paper and electronic format pertaining to:
i. PIN Consulting Group Inc.;
ii. Leximco Ltd. (operating as Leximco Travel);
iii. First Response Travel Group; and
iv. An unknown offshore company which is believed to be associated
to one or all of the following individuals: Karl Walsh, Jim Christie,
Chantiam,
permanent files containing information on shareholders,
files,
documents,
Page 65 of 88

and co pies of the T2 returns of income including all
correspondence and working papers.
b. All records in paper and electronic format pertaining to domestic and
foreign investments which are associated with any of the following:
Ontario Provincial Police Association (OPPA), Karl Walsh, Jim Christie,
Martin Bain, Andrew McKay, Klara Kozak or Noel Francis Chantiam,
i.
A condominium at 1 Cable Beach, Nassau, Bahamas;
ii. Investment with the New Providence Income Fund Ltd. and the
Sterling Financial Group Inc.;
iii. Investment with the Caldwell Group;
iv. The OPPA procurement planning, assessment and development of
land for the proposed new OPPA Head office;
v. Investment in Leximco Travel;
vi. Investment in First Response Travel Group;
vii. Investment in an unknown offshore Company;
viii. Investment in PIN Consulting Group Inc.
c. All records in paper and electronic format pertaining to: Natasha Vieira,
Andrew McKay, Kiara Kozak, Noel Francis Chantiam, Elena Rabenok and
Barry Mckay;
d. All records in paper and electronic format pertaining to phone records of
Martin Bain;
e. All records in paper and electronic format pertaining to travel and
associated expenses for Karl Walsh, Jim Christie, Martin Bain, or Andrew
McKay;
f.
All records in paper and electronic format pertaining to OPPA expenses

claimed by Karl Walsh, Jim Christie or Martin Bain;
g. Content of emails sent or received by Karl Walsh, Jim Christie or Martin

Bain;
Page 66 of 88
h. All electronic equipment, electronic devices and media, including but not
limited to computers, tablets, cell phones or other hand held devices
utilized by Karl Walsh, Jim Christie or Martin Bain; and
i.
All records in paper and electronic format pertaining to personal tax

returns for Karl Walsh, Jim Christie or Martin Bain.
Summary of grounds for belief that the things being sought will be located in 7
Maple Court, Oro Medonte, Ontario and a black Ford Edge, with license plate
BMKL586 registered to the Ontario Provincial Police Association and driven by
Martin Bain:
154. I believe that things being sought will be found in the three OPPA offsite offices
and the three associated vehicles for the following reasons:
a. Barendregt stated that Bain resides at 7 Maple Court, Oro-Medonte,
Ontario;
b. Tait, Elia and Barendregt have advised that Bain routinely works from
home and he has a home office which is an extension of his OPPA office.
He has been issued an OPPA cellphone, laptop computer, IPAD, printer,
and keyboard and drives a Ford Edge vehicle provided by the OPPA. It is
likely that OPPA material including electronic and paper files are kept in
his home office in relation to his day to day work for the OPPA, along with
a lap docking stations and the ability for him to access the OPPA server
using a Cisco VPN;
c. I believe that many of the things being sought are moved between Bains
home office and the OPPA Head Office inside his company vehicle. The
proposed searches would be conducted simultaneously, and commence
sometime after 8:00 am. At that time, Bain could be inside his vehicle in
transit and if that is the case, I believe that he would have some of the
things being sought with him. At the very least I believe that evidence of
expenses such as receipts will be found inside the vehicle.
d. MTO checks show that Martin R Bain resides at 7 Maple Court, Oro
Medonte since 2013-08-23;
e. On December 10, 2014 physical surveillance showed a black Ford Escape
BEKW951 registered to Heather A. Bain parked in driveway;
:1
f.
On December 29, 2014 physical surveillance showed a black Ford Edge

BMKL586 registered to the Ontario Provincial Police Association parked in
driveway;
Page 67 of 88
32 on December 15, 2012 showed 7 Maple Court,

g. A Geowarehouse check
Oro Medonte being purchased by Martin Bain and Heather Bain on
August 1,2013.
h. On February 21, 2015 physical surveillance showed a black Ford Edge
BMKL586 registered to the Ontario Provincial Police Association and a
black Ford Escape BEKW95I registered to Heather A. Bain parked in
driveway;
i.
From my experience I believe that individuals keep documents and assets

in their residence, for example records relevant to personal assets,
investments and expenditures such as deeds, share certificates, trust
declarations, receipts for asset purchases, banking documents, safe
deposit keys and tax filings.
Summary of grounds for belief that the things being sought will be located in 193
Maple Dawn Drive, Midland and a black Ford Edge, with license plate 07YR15
registered to the Ontario Provincial Police Association and driven by Jim
Christie:
155. I believe the things being sought will be found in these locations for the following
reasons:
a. Barendregt has advised that Christie resides at 193 Maple Dawn Drive,
Midland, Ontario;
b. Tait, Elia and Barendregt have advised that Christie routinely works from
home, and he has a home office which is an extension of his OPPA office.
He has been issued by the OPPA a cellphone, laptop computer, IPAD,
printer, keyboard and a Ford Edge. It is likely that OPPA material including
electronic and paper files are kept in his home office in relation to his day to
day work for the OPPA, along with a lap docking stations and the ability for
him to access the OPPA server using a Cisco VPN;
c. I believe that many of the things being sought are moved between Christies
proposed searches would be conducted simultaneously, and commence in
the morning. At that time, Christie could be inside his vehicle in transit and if
that is the case, I believe that he would have some of the things being sought
with him. At the very least I believe that evidence of expenses such as
receipts will be found inside the vehicle.
LI-
d. MTO checks show that James R Christie residing at 193 Maple Dawn Drive,
Midland since June 18, 2009;
GeoWarehouse is a web-based, centralized property information source that provides state of the art mapping and
research tools, as well as professional reports.
32
Page 68 of 88
e. On December 10, 2014 and December 16, 2014 physical surveillance

showed a white Mazda BLTJ449 registered to Caroline Christie parked in
driveway;
f.
p
On December 29, 2014 physical surveillance showed a black Ford Focus with
license plate BHEN874, registered to James R Christie, and black Ford Edge
O7YRI 5 registered to the Ontario Provincial Police Association parked in the
driveway;
g. On February 21, 2015 physical surveillance showed a white Mazda BLTJ449

registered to Caroline Christie and black Ford Edge O7YR1 5 registered to the
Ontario Provincial Police Association parked in the driveway;
h. A Geowarehouse check on December 16, 2014 showed that 193 Maple
Dawn Drive, Midland was purchased by James Christie and Caroline Christie
on April 30, 2009.
i.
From my experience I believe that individuals keep documents and assets in

their residence, for example records relevant to personal assets, investments
and expenditures such as deeds, share certificates, trust declarations,
receipts for asset purchases, banking documents, safe deposit keys and tax
filings.
Sum mary of Grounds for Belief the Things Being Sought will be Located in the
3
Residence in the Southeast Part of the Property Designated as 41 53/41 55/4157
Line, Bradford, West Gwillimburv, Ontario and a Black Ford Edge with license
07YR16 Registered to the Ontario Provincial Police Association and Driven by
Karl Walsh:
156. I believe the things being sought will be found in these locations for the following
reasons:
a. MTO checks show that Karl Walsh resides at 4157
Gwillimbury, Ontario.
rd
3
Line Bradford, West
b. Elia has advised that there is a landscaping company, which is owned by

Walshs wifes father, located on the same property where Walsh lives. Elia
also advised that the OPPA recently paid for a new desk and a designated
fax line at Walshs home office.
-,
A Geowarehouse check on December 15, 2014 showed that 4157 3rd Line,
Bradford was purchased by 360550 Ontario Ltd (Dunkerron Nurseries Ltd) on
November 15, 1978.
d. A corporation check on December 17, 2014 showed that Paula Christie

Walsh was listed as the secretary of Dunkerron Nurseries Ltd.
Page 69 of 88
r
e. Tait, Ella and Barendregt have advised have advised that Walsh routinely
works from home and he has a home office which is an extension of his
OPPA office. He has been issued an OPPA celiphone, laptop computer,
IPAD, printer, and keyboard drives a Ford Edge vehicle provided by the
OPPA. It is likely that OPPA material including electronic and paper files are
kept in his home office in relation to his day to day work for the OPPA, along
with a lap docking stations and the ability for him to access the OPPA server
using a Cisco VPN;
[j
f.
g. I believe that many of the things being sought are moved between Walshs
proposed searches would be conducted simultaneously, and commence
sometime after 8:00 am. At that time, Walsh could be inside his vehicle in
transit and if that is the case, I believe that he would have some of the things
being sought with him. At the very least I believe that evidence of expenses
such as receipts will be found inside the vehicle
h. From my experience I believe that individuals keep documents and assets in

their residence, for example records relevant to personal assets, investments
and expenditures such deeds, share certificates, trust declarations, receipts
for asset purchases, banking documents, safe deposit keys and tax filings.
p.
Li
Special Conditions Related to the Search Warrants Being Sought for the
Three OPPA Offsite Offices and Associated Vehicles:
157. Walsh, Bain and Christie are not lawyers, but it is possible that solicitor-client
privileged material could be present during the search of these locations.
Furthermore, one of the individuals under investigation is a lawyer and has done
legal work for the OPPA. I am proposing special conditions for the searches to
protect solicitor-client privilege protection.
On January 20, 2015 surveillance confirmed that Walsh was at a residence

located on southeast part of property. In the early morning hours Walsh was
observed exiting the residence carrying a shoulder bag and hand bag both of
which he placed inside a black Ford Edge. He was then observed departing
this residence driving the black Ford Edge, and then attending the OPPA
offices at 119 Ferris Lane, Barrie. The Ford Edge had license plate O7YR1 6
and is registered to the Ontario Police Association.
Appointment of Referees for the Three OPPA Offsite Offices! Residences

and Associated OPPA Vehicles:
158. I propose that the following independent lawyer, who has been approved by the
LSUC and is acceptable to the Crown, be appointed by the Court pursuant to an
Assistance Order, to perform the duties of the Referee with respect to the
execution of the office search warrant at the residence! offsite office of Martin
Bain, located at 7 Maple Court, Oro-Medonte, ON:
Page 70 of 88
Christine Mainville
3rd Floor
Toronto, Ontario
LSUC # 59603Q
execution of the office search warrant at the residence! offsite office of Jim
Christie of 193 Maple Dawn Drive, Midland:
Matthew Gourlay
3rd Floor
Toronto, Ontario
LSUC # 57685H
execution of the office search warrant at the residence! offsite office of Karl
Walsh, located at the residence in the southeast part of the property designated
as 41 53/41 55/41 57 3rd Line, Bradford, West Gwillimbury, Ontario:
SherifFoda
3rd Floor
Toronto, Ontario
LSUC # 65050V
161. I propose that the following person, who is a certified forensic examiner be
appointed by the Court pursuant to an Assistance Order, to assist Police, the
Referee and the Chief Referee in relation to the electronic devices and media
that are seized from the residence! offsite offices and vehicles associated to Karl
Walsh, James Christie and Martin Bain
Wayne Doney
Digital Evidence International Inc
Page 71 of 88
LSUC, and who is acceptable to the Crown, be appointed by the Court, pursuant
to an Assistance Order, to perform the duties of the Chief Referee in order to
protect solicitor-client privilege:
Scott Hutchison
3rd Floor
Toronto, Ontario
LSUC #29912
Seizure of Paper Records with Assistance of the Referee for the Three
OPPA Offsite Offices and Associated Vehicles:
163. I propose that the police will conduct the search to locate the said things in
paper form.
164. The Referee will monitor the search, and will review all material that is located
during the search. The Referee will assert solicitor-client privilege, if applicable,
over any thing. The Referee will seize the said things when solicitor-client
privilege is asserted. Upon seizure, the Referee will maintain continuity, security,
and store these things. As soon as reasonably practicable the Referee will turn
these things over to the Chief Referee.
rEf
165. The police will review and seize any said thing in paper form when there is no
assertion of privilege made by the Referee.
Search Procedures for Electronic Equipment, Devices and Media:
166. The police will seize, secure and seal all electronic devices and media located
during the search. These things will not be examined by the police, but will be
delivered to the ICFE at Digital Evidence International Inc. as soon as
reasonably practicable.
167. If possible, the ICFE will image the electronic devices and media seized to
create a sound duplication of the electronic devices and media.
168. The ICFE will take steps to locate the said things on the electronic devices or
media, or the images of the electronic devices or media, including but not limited
to the following:
e. The ICFE will conduct key word searches on the electronic devices or media,
or the images of the electronic devices or media. The list (s) of key words will
be supplied to the ICFE by myself, or my designate.
Page 72 of 88
f.
The ICFE will provide all things located as a result of the key word searches
to the Chief Referee.
169. The ICFE will maintain continuity, security, and store the electronic devices or
media, or the images of the electronic devices or media, until the forensic
examination is completed. Upon the completion of the forensic examination the
ICFE will deliver all electronic devices and media, whether imaged, copied or
seized, and the any copies or images thereof to the custody of the Chief
Referee.
Post Seizure Duties of the Chief Referee:
170. The Chief Referee will receive the said things seized by the Referee and the
ICFE from the search site both in paper and electronic form. Upon receipt, the
Chief Referee will maintain continuity and security, and be responsible for the
storage of these things until otherwise ordered by the Court.
171. The Chief Referee will examine each thing that has not already been reviewed
by the Referee at the search site. The Chief Referee will assert solicitor-client
privilege if applicable.
172. If the Chief Referee does not assert privilege over a thing, it will be released to
myself, or my designate and make arrangements for the release of the thing.
173. In the case of any thing where privilege has been asserted by either a Referee
or the Chief Referee, the Chief Referee will separate the things into three
categories, and prepare a report that will provide the Court with rationale why
the thing:
a. In the opinion of the Chief Referee is not protected by solicitor clientprivilege.
b. In the opinion of the Chief Referee may be protected by solicitor clientprivilege.
c. In the opinion of the Chief Referee should be protected by solicitor client
privilege.
174. The Chief Referee will be responsible for notifying clients who have been
affected by the execution of the search warrant, or whose things have been
seized pursuant to the search warrant. This notification will occur as soon as
reasonably practicable following the execution of the search warrant and may
nclude advising clients of
a.
The seizure of any of their things;
Page 73 of 88

authorities;
f.

and

of the search for and seizure of their things.
1 75. The Chief Referee may notify the clients either verbally or in writing and may
the Court.
Production Order for Data in the Possession and Control of Curtis Ella:
176. I have reasonable grounds to believe that data in Ellas possession will provide
evidence of the named offences. I base my belief on the following as set out in
this ITO:
a. Elia is a witness who has provided three statements to investigators.
During two of these statements he described emails that he has read on
Karl Walshs OPPA email account. As has been described in this ITO,
these emails provide evidence of the offences under investigation.
b. On January 13, 2015, Elia told investigators in a sworn witness statement
that he had produced backups of the OPPA email mailboxes utilized by
Bain, Walsh and Christie, for the months of October, November and
December 2014.
c. On March 1, 2015 Ella provided a statement advising that the backups
which he produced are in his possession and are being stored on his
home computer.
Page 74 of 88

Chantiam,
files, permanent files containing information on shareholders,
documents;
and copies of the T2 returns of income including all
correspondence and working papers.
b. All records in paper and electronic format pertaining to the association,
ownership or control over any company by Karl Walsh, Jim Christie,
Martin Bain, Kiara Kozak, Noel Francis Chantiam or Andrew Mckay
including but not limited to Leximco Travel, First Response Travel Group,
PIN Consulting Group Inc. and an unknown offshore company;
c. All records in paper and electronic format pertaining to investment or
ownership by the Ontario Provincial Police Association (OPPA), Karl
Walsh, Jim Christie, Martin Bain, Klara Kozak, Noel Francis Chantiam, or
Andrew Mckay including but not limited to: real property, corporations,
securities, and bank accounts;
d. All records in paper and electronic format pertaining to funds being
transferred and received to, from or on behalf of Karl Walsh, Jim Christie,
Martin Bain, Andrew Mckay, Klara Kozak, Noel Francis Chantiam, the
OPPA, First Response Travel Group, PIN Consulting Group Inc. or
Leximco Travel;
Page 82 of 88
e. All electronic equipment, electronic devices and media, including but not
limited to computers, tablets, cell phones or other hand held devices
utilized by Klara Kozak;
f. All records in paper and electronic format pertaining to phone records for
Klara Kozak;
fl
LI-
g. All records in paper and electronic format pertaining to correspondence,

including emails, letters and faxes of any of the following the OPPA, Karl
Walsh, Jim Christie, Martin Bain, Andrew Mckay, Kiara Kozak, Noel
Francis Chantiam, Barry Mckay or Elena Rabenok;
h. Content of emails sent or received by Klara Kozak; and

All records in paper and electronic format pertaining to tax returns for
Klara Kozak.
Summary of Grounds for Belief That the ThIngs Being Sought will be Located at
Upper Level 61 Wineva Avenue. Toronto, ON and in a Grey 2007 BMW
Registered to Kiara Kozak and Bearing License Plate BMEE6IO:
-
208. I believe Upper Level 61 Wineva Avenue, Toronto, ON is the residence of

Kiara Kozak and that she is also operating a portion of First Response Travel
from this location. I believe things being sought will be found in this location for
the following reasons:
-
a. On November 20, 2014, I attended Leximco Travel, Suite 102 3273

Bloor Street West, Etobicoke and spoke with employee Victoria
Fartushenko who was a travel consultant with Leximco. Fartushenko told
me that she (Victoria) worked from home and always answered her phone
for business travel related calls;
b. Surveillance conducted on February 2, 2015, showed Klara Kozak

travelling from the OPPA offices to the residence of Andrew Mckay and
then to her residence at 61 Wineva Avenue. She was observed parking a
BMW registered in her name on Wineva Avenue and then entering the
residence at 61 Wineva She was subsequently observed departing the
residence a few hours later dressed in different clothes;
c. Surveillance conducted on February 4, 2015, February 5, 2015, and
February 11, 2015 showed kozak departing from 61 Wineva Avenue in
the late morning driving her BMW. She subsequently attended Leximco
Travel at Suite 102 3273 Bloor Street West, Etobicoke spending several
hours at this location. On February 11,2015 kozak was observed bringing
appeared to be a laptop bag out of her residence and then travelling
what
Page83of88
p
by vehicle to the business location of Leximco Travel. She subsequently
spent numerous hours at Leximco Travel and was observed departing the
business at approximately 9:30 in the evening and followed to her
residence at 61 Wineva Avenue. She was observed parking her vehicle in
the driveway of 61 Wineva Avenue and entering the front door of the
residence. Kozak has also been observed on February 4, 2015, February
5, 2015 and February 11, 2015 taking two dogs from 61 Wineva for walks
and dropping of these dogs at various locations prior to her attending
Leximco Travel. Surveillance conducted on February 5, 2015 also
revealed a dog on the upper balcony of the residence at 61 Wineva
Avenue. I believe her observed behavior and habits are consistent with an
individual who is living at a residential location and proceeding to her
place of work on a regular basis;
U
Ii
d. On February 10, 2015 documents were obtained in curbside refuse for the
residence of 61 Wineva Avenue, Toronto, ON which demonstrated that
Kozak was operating a travel business and was storing business material
in this residence. The following seized things are relevant:
i. Envelopes to Klara Kozak bearing the address of Uppr, 61 Wineva
Avenue, Toronto, Ontario;
ii. Correspondence from the OPPA in regard to the Annual General
Meeting and Presidents Banquet;
iii. An envelope addressed to Kiara Kozak, First Response Travel
Group, 61 Wineva Avenue, Toronto, Ontario from the OPPA;
iv. Business cards in Kozaks name for First Response Travel Group;
v. A sheet of paper bearing a number of travel agent related websites

and passwords;
[1-
e. From my experience I believe that individuals keep documents and assets

in their residence, for example records relevant to personal assets and
expenditures such as deeds, share certificates, trust declarations, receipts
for asset purchases, banking documents, safe deposit keys and tax filings;
f.
Kozak has been a party to email correspondence with Walsh, Bain,

Christie and others specific to the offenses under investigation. I believe
that computers and other electronic devices that were used to create,
send and receive the electronic communication being sought will be found
in this location;
g. I believe that many of the things being sought are moved between Kozaks
residence and Leximco Travel inside her vehicle. The proposed searches
Page 84 of 88
would be conducted simultaneously, and commence sometime after

8:00am. At that time, Kozak could be inside her vehicle in transit and if
that is the case, I believe that she would have some of the things being
sought with her.
p
v
Summary of grounds for belief the things being sought will be found in The
Office of Leximco Travel located at 3273 Bloor Street West Unit 102, Toronto,
Ontario:
209. I believe that Suite 102 3273 Bloor Street West, Toronto, ON is the business
location for First Response Travel and Leximco Travel, and that things being
sought will be found in this location for the following reasons:
[1
fl1
a.
On November 20, 2014 I attended this address and noted that it was
Leximco Travel based on the sign outside, and the literature that was
found inside. I noted that it was an operating travel business, and that the
checks for travel fares were done on-line, on a computer. I also noted that
the employees had desks that could be used to store paper documents. I
noted that Leximco representatives Elena Rabenok, Lena Maydanyuk and
Victoria Fartushenko each had their own desk. I did not observe a work
station for Kozak, but it could have been in the back part of the office that I
did not see.
b. A corporation check on Leximco Travel, on November 17, 2014, showed

the directors of Leximco as Klara Kozak and Andrew Mckay.
c. On February 2, 2015, Andrew McKay was identified to Kim Tait as
kozaks boss in regards to the travel business.
d. Open source checks on November 17, 2014 show a website for First
Response Travel Group which identifies that it is located at 3273 Bloor
Street West, Etobicoke and that it is a division of Leximco.
e. Surveillance on February 4, 2015, February 5, 2015, and February 11,
2015 showed Kozak travelling from her residence at 61 Wineva Avenue,
Toronto to the Leximco Travel location. On all three occasions Kozak
remained within the business for many hours consistent with an individual
who is working from that location.
f.
Surveillance on February 11, 2015 showed Kozak bringing what appeared

to be a laptop bag from her residence to Leximco Travel.
g. I believe that Kozak works at this location. As she has been party to email
correspondence with Walsh, Bain, Christie and others specific to the
offenses under investigation, I believe that computers and other electronic
I
Page 85 of 88
devices that were used to create, send and receive the electronic
communication being sought may be located in this office.
h. As this is an operating travel business where Kozak works, I believe that

there are relevant business records pertain to Leximco Ltd. and First
Response Travel Group both in paper and electronic format inside this
location.
Grounds To Believe Things Sought From All Locations Will Afford Evidence:
210. I believe that the things for which I am seeking judicial orders will be of
substantial benefit to this investigation and will afford evidence that will
substantiate the offences under investigation.
Time Frame Requested:
211. Criminal activity including the fraudulent claims by OPPA Board Members and
Executive for accrued unused vacation time and the fraudulent claiming of
personal expenses is alleged to have been occurring in 2012. I am seeking
documents and data for the period of time from September 1, 2013 to present, to
coincide with the OPPA fiscal year that ran from September 1, 2013 to
September 1, 2014.
Sealing Order:
212. I am requesting, pursuant to section 487.3(1) of the Criminal Code, that an order
denying access to information (sealing order) be granted, for a period of one
week from the time of the search, to prohibit the access to or disclosure of any
information included in this ITO. In accordance with section 487.3(3), I am also
requesting that the documents be placed in a sealed packet that shall be kept in
the custody of the Court and in a place where the public has no access or in any
other place that the Justice may authorize. I am making this request because
disclosure may:
a. Compromise the nature and extent of the ongoing investigation, as
interviews of other OPPA staff, including the Board of directors, will be
occurring soon after the execution of the Orders and if the witnesses view
the grounds in this ITO prior to their interview, their evidence may be
tainted Further judicial authorizations are also anticipated, some which
may require discretion
Page 86 of 88
b. Prematurely identify key witnesses who are employed by the OPPA, and
who are subordinates to three of the subjects under investigation.
[1..
213. I believe that these grounds outweigh the importance of accessing the
information in this ITO.
Li
SWORN BEFORE ME at the City of

Toronto in the Province of Ontario
This 4th day of March, 2015.
)
)
)
A o missioner of Oaths
in d for the Province of Ont rio
)
)
Page 87 of 88
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List of Appendices
[
1
Appendix A
Ontario Police Association Information Review
Appendix B
Consulting Services Agreement between PIN and OPPA
Appendix C
Letter from the auditor to OPPA Finance Committee prepared by

Gregory N. Ferguson of Powell Jones LLP, dated October 17, 2014
Appendix D
2014 OPP Association Financial Report and Summary
Appendix E
OPP Association Constitution and By-Laws, dated May 2014 and

Summary
Appendix F
The Law Society Guidelines and Email from Janice LaForme
Appendix G
List of Key Words for ICFE
[1
Appendix A
U
IS EXHIBIT
,...,.
AFFIDAVIT OF
SWORN BEFORE ME
A Ooi
El
TO THE
onr, iflc.
Ontario Provincial Police Association

Information Review
November 3, 2014
Submitted to: Detective Superintendent Dave Truax

Director
Criminal Investigation Branch
Criminal Investigation Services
Compiled by: Detective Inspector Chris Avery
Criminal Investigation Branch
Criminal Investigation Services
November 3, 2014
2. MoNamara and Ella provided names of witnesses who they believed

have first-hand knowledge of further evidence. It is suggested that the
following persons by interviewed:
I. Kim Tait OPPA Office Manager
ii. Sandra Barendregt Accountant
iii. Leanna Maitby Executive Assistant
iv. Chantelle Dean Executive Assistant
While this list of suggested witnesses is not exhaustive, these interviews

are an appropriate next step to determine if a criminal offence exists.
Much of the information provided by McNamara and Ella is second hand.
Once further information is gathered from these specified witnesses
above, there may be a need to interview both McNamara and Elia again,
should a criminal offence be identified.
3. It appears if a criminal offence is identified; the offence

location,urisdiction would be within the City of Barrie.
November 3, 2014

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Canada

322 Theft Criminal Code:

2. In the opinion of the Chief Referee may be protected by solicitor clientprivilege.

The seizure of any of their data;

b. The risk to their privilege interests by the investigative or prosecutorial

How to request a hearing to determine any issue of privilege by the Court;

g. Any other information to assist them in protecting their interests as a result

eCitoorontoin the Province of Ontario.

Judge of the Superior Court of Ontario

IN THE MATTER OF an application for a

Sergeant Gordon Aristotle

IN THE MATTER OF an application for a Production Order pursuant to section

322 Theft Criminal Code:

Martin Bain, Kiara Kozak, Noel Francis Chantiam, or Andrew

SPECIAL CONDITIONS FOR THE PRODUCTION ORDER:

The seizure of any of their data;

b. The risk to their privilege interests by the investigative or prosecutorial

How to request a hearing to determine any issue of privilege by the Court;

g. Any other information to assist them in protecting their interests as a result

Judge of the Superior Court of Ontario

IN THE MATTER OF an application for a

Sergeant Gordon Aristotle

IN THE MATTER OF an application for a Production Order pursuant to section

PIN Consulting Group Inc

OPPA Information Review

PIN Consulting Group Inc

New Providence Income Fund Ltd

Condos at 1 Cable Beach in Nassau, Bahamas

2014 OPPA Audit:

OPP Association Constitution and By-Laws

180 Bloor Street West, Toronto, Ontario

Things Being Sought from 903

180 Bloor Street West, Toronto

180 Bloor Street West, Toronto:

Seizure of Electronic Records at 903

180 Bloor Street West, Toronto, Ontario

Time Frame Requeste&

IN THE MATTER OF an application for a Production Order pursuant to section

In 2001, I was transferred to Ontario. I have been assigned to several units

d. Integrated Market Enforcement Team;

Joint Securities Intelligence Unit; and

g. Integrated Proceeds of Crime Section.

I have completed complex financial investigations, at times as the team leader

I have prepared and supervised the preparation of numerous judicial

I have a solid understanding of economics, finance, accounting, business,

In addition, I have attended numerous economic crimes related conferences and

The Toronto Police Service Fraud Conference (2007); and

g. Annual Legal and Compliance Conference of the Investment Dealer

I understand that this is an ex parte application and that lam obligated to

Offences Under Investigation:

Based on the grounds described below, I have reasonable grounds to believe

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

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

b. Section 462.31 Laundering the Proceeds of Crime; and

(Walsh), OPPA President James Christie (Christie), OPPA Vice President

I have reasonable grounds to believe that the subjects of investigation, namely,

I believe that the subjects of investigation have organized various schemes,

Following is a summary of the schemes that I believe have been used to

First Response was registered as a partnership between Chantiam and Kozak

In January 2015, Mckay, believed to be representing PIN, presented a