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ONTARIO COURT OF JUSTICE (ast Region) IN THE MATTER OF Applications for: Production Orders, pursuant to s, 487.012(1) of the Criminal Code; APPLICATION FOR PRODUCTION ORDERS Application is hereby mace by Corporal Rudy Exantus, a peace officer, of the Royal Canadian Mounted Police, pursuant to the provisions of Section 487.012 of the Criminal Code for an Order authorizing two Production Orders as set out in the Affidavit which accompanies this Application. DATED at the City of Ottawa, in the Province of Ontario, this Gay of Tan , 2018. A peace ofticer a Taw a7, aoiy LY Lite Jusned f eAce Roriwee OM TARY ONTARIO COURT OF JUSTICE (Bast Region) IN THE MATTER OF an Application for: Production Orders, pursuant to , 487,012(1) of the Criminal Code; and APPLICATION FOR PRODUCTION ORDERS CANADA ) In the matter of Applications for ) Production Orders pursuant to ONTARIO COURT OF JUSTICE ) section 487.012 of the Criminal ) Code EAST REGION INFORMATION TO OBTAIN PRODUCTION ORDERS This is the Information of Corporal Rudy Exantus, a peace officer of the Royal Canadian Mounted Police (RCMP), in the city of Ottawa, Ontario, Offences 1. have reasonable grounds to believe and do believe that offences contrary to an Act of Parliament have been committed to wit: a. Pamela Wallin between January 26, 2009 and October 3, 2012 at Ottawa, Ontario, being an official, in the Senate of Canada, did commit a breach of trust by a public officer, in connection with the duties of hor office by making inappropriate expense claims contrary to section 122 of the Criminal Codes b, Pamela Wallin between January 26, 2009 and October 3, 2012 by deceit, falsehood or other fraudulent means defrauded the Senate of Canada of property, money or valuable security in an amount exceeding $5000 contrary to section 380 (1) of the Criminal Code. Documents and/or Data 2. Ihave reasonable grounds to believe and do believe that the following documents and/or data will afford evidence with respect the commission of the offences described above; In Relation to Porter Airlines Inc.: a, All documentation and data (expense claims, invoices, correspondences and. payment information), concerning the reimbursement of all expenses to Senator Pamela Wallin for having attended a lunch with Mr. Robert Deluce (CEO of Porter Airlines Inc.) on Tuesday January 12, 2010; b. All documentation and data (expense claims, invoices, correspondences and payment information), conceming the reimbursement of all expenses to Senator Pamela Wallin for having attended the Fairmont Royal York Hotel in Toronto on ‘Tuesday January 19, 2010, relating to the presentation to Robert Deluce of the Canadian Public Relations Society's CEO Award of Excellence in Public Relations; ¢. All documentation and data (expense claims, invoices, correspondences and payment information), conceming the reimbursement of all expenses to Senator Pamela Wallin for having attended a Board of Trade dinner on Monday January 25, 2010; . All documentation and data (expense claims, invoices, correspondences atid payment information), concerning the reimbursement of all expenses to Senator Pamela Wallin for having attended a meeting with Mr. Robert Deluce on Saturday May 8, 2010; €. All documentation and data (expense claims, invoices, correspondences and payment information), conceming the reimbursement of all expenses to Senator Pamela Wallin for having attended Porter Airlines Inc, board meetings on; i, Friday December 3, 2010; fi, Tuesday September 6, 2011; iii, Monday December 5, 2011; iv. Monday March 5, 2012; v. Tuesday March 6, 20125 £. All documentation and data (expense claims, invoices, correspondences and payment information), conceming the reimbursement of all expenses to Senator Pamela Wallin for having attended Porter Airlines Inc. board dinners on i, Monday June 4, 2012; and ii, Tuesday June 5, 2012. Inrelation to Gluskin Sheff & Associates In: 8 All documentation and data (expense claims, invoices, correspondences and payment information), concerning the reimbursement of all expenses to Senator Pamela Wallin for having attended Gluskin Sheff & Associates Inc, board meetings on; i, Thursday September 17, 2009, i. Thursday February 4, 2010. i. Thursday May 6, 2010. , Monday July 12, 2010 . Thursday September 16, 2010, i, Wednesday November 2, 2011 Thursday May 10, 2012. viii, Thursday September 20, 2012. h, All documentation and data (expense claims, invoices, correspondences and payment information), concerning the reimbursement of all expenses to Senator Pamela Wallin for having attended Gluskin Sheff & Associates Inc. board of Directors dinners on i, Wednesday May 5, 2010. ii, Wednesday September 15, 2010. iii, Wednesday May 9, 2012. iv. Wednesday September 19, 2012 i, All documentation and data (expense claims, invoices, correspondences and payment information), concerning the reimbursement of all expenses to Senator Pamela Wallin for having attended a meeting with Gerald Sheff on Monday March 15, 2010. 3, AND THAT; a. There are reasonable grounds for believing that the documents and/or data or some part of them, that are sought fiom Porter Airlines, are in the possession or control of: Loredana Ritorto, Manager, Taxation & Treasury at Porter Airlines Inc., at Billy Bishop Toronto City Airport, Toronto, Ontario, b. There are reasonable grounds for believing that the documents and/or data or some part of them, that are sought fom Gluskin Sheff and Associates, are in the possession or control of: David Morris, Chief Financial Officer for Gluskin Sheff & Associates Inc., at 333 Bay Street, in Toronto Ontario, Introduction of Applicant 4. 1, Cpl, Rudy Exantus, a member of the Royal Canadian Mounted Police in the Province of ‘Ontario make oath and say as follows: 5. Lam a peace officer and have personal knowledge of the matters set out in this Information, believe all of the information to be true. 6. Thave been a member of the RCMP since July 2001. I am currently assigned to Sensitive and International Investigations within the National Division of the RCMP, responsible for investigating matters of significant risk to Canada’s political, economic, and social integrity. Tam one of the investigators assigned to this investigation. My current role is to obtain judicial authorizations in furtherance of this investigation, 7. Throughout this Application, where I state my belief, that belief is based on my experience ‘as set out above and on the other information in this applicati =e : Overview 8. This application pertains to an RCMP investigation of travel expense claims submitted by Senator Pamela Wallin to the Senate of Canada while occupying the office of Senator representing the Province of Saskatchewan, 9. [believe Senator Pamela Wallin has committed the offences of Breach of Trust and Fraud by submitting fraudulent expense claims to the Senate of Canada, I believe that Senator ‘Wallin traveled to Toronto to pursue personal and business interests, and later represented to the Senate that these travels were parliamentary related as she sought reimbursement for expenses incurred during these travels, 10. On Wednesday August 14, 2013 the Senate Standing Committee on Intemal Economy, Budget and Administration (The standing Committee) asked the RCMP to farther examine the findings of its internal and subsequent external audit (by Deloitte) of Senator Pamela Wallin’s travel expense claims. These reviews had yielded an unusual travel pattern, which included frequent stopovers in Toronto, as well as return travel from Ottawa to Toronto and from Saskatchewan to Toronto. According to Senate rules, reimbursement of expenses for travels to a destination in Canada other than the Senator’s provincial residence, which for Senator Wallin, is Saskatchewan, may only be claimed to the Senate if the senator is attending to parliamentary functions at that destination. The issue at hand pertains to the frequency of alleged parliamentary functions conducted by Senator Wallin in Toronto where she also owns a private residence, 11. In the subsequent investigation, RCMP investigators leaned that Senator Wallin had disclosed to the Senate Ethics Officer that she was a member of the Board of Directors of several corporations, which included Porter Airlines Inc. (Porter) and Gluskin Sheff & Associates Inc. (Gluskin), both located in Toronto. ' 12. The RCMP obtained by way of production orders, relevant documentation from Deloitte and the Senate of Canada, RCMP investigators then scrutinized the 246 travel expense claims that were received from the Senate, Of these 246 claims, investigators have identified 150 claims requiring further investigation to determine whether they included travel and expenses unrelated to Senator Wallin’s parliamentary functions. The dates covered by these 150 travel expense claims are from January 13, 2009 to September 25, 2012, The RCMP investigation therefore focused on the activities of Senator Wallin during the period covered by these 150 identified expense claims. 13. RCMP investigators also obtained copies of Senator Wallin’s electronic Outlook calendar and her two hand-written calendars from Deloitte and the Senate of Canada, I believe that these calendars reflect the proposed agenda of activities of Senator Wallin between 2009 and 2012 + Tlearmed this from reading the Oifice ofthe Senate Puhics Officer conflict of interest code for Senators public disclosure summary of Scnator Wallin dated March 24,2009, 14, The analysis of these calendars, compared against the 150 suspicious expense claims, along with the interview of Porter and Gluskin executives, revealed that during the period under investigation; a, Senator Wallin had attended 11 Porter board related events in her capacity of a Porter independent director; and b, That Senator Wallin had attended 13 Gluskin hoard related events in her capacity ofa Gluskin independent director, 15. The analysis of the 150 suspicious expense claims also revealed that Senator Wallin submitted expense claims surrounding the dates of cach of these 24 board related events in Toronto, 16. The interview of the Porter and Gluskin executives also revealed that both Porter and Gluskin’s common practice is to reimburse their directors for expenses incurred for having attended these board related events. 17, This application pertains only to the travel expense claims involving Porter and Gluskin. ‘The purpose of this application is to obtain fiom Porter and from Gluskin , all documentation and data, including expense claims, invoices, correspondences and payment information, relating to the claiming and the reimbursement of expenses ineurred by Senator Pamela Wallin for having attended these 11 Porter and 13 Gluskin board related events in Toronto, 18, The sought documentation and data will afford evidence relative to Senator Wallin’s travel and expense claims relating to Porter and Gluskin that she also expensed to the Senate of Canada during her stopovers in Toronto, 19, The RCMP is continuing its investigation into the remainder of the 150 identified travel expense claims. Grounds For Belief jenate Governi s In this section, I will provide an overview of the Senate governing policies and procedures, which along with the provisions of the Criminal Code of Canada, established the parameters within which this investigation is conducted. I have read these policies and statues in which I earned in part, the following; 20. The Constitution Acts, 1867 and 1982 defines the requisite qualifications of Senators. I have read The Constitution Acts, 1867 and 1982 and learned that qualifications as legislated by the statute are as follows: a. 30 years old; b. A natural born Commonwealth citizen, or a naturalized citizen of Great Britain or Ireland, or a natural born citizen of Canada or a naturalized citizen of Canada; Own land, within the Province of which he or she was appointed, worth at least $4000 d. His or her Real and Personal Property shall be worth Four thousand Dollars over and above his or her Debts and Liabilities; e. He or she must be a resident of the Province from which they were appointed. 21, The Senate rules relating to travel are located within the following Senate internal policy manuals: a, Senate Administrative Rules b. Senators’ Travel Policy ©. Senators’ Travel Guidelines i, Senators’ Resource Guide ii, Senators’ Living Expenses in the National Capital Region (NCR) Guidelines 22, The Senate Administrative Rules governs Senate administrative practice. They complement and are of equal authority to the Rules of the Senate, which governs Senate procedure, In the interests of good governance, the administrative rules codify comprehensively the fundamental principles and rules governing the internal administration of the Senate and its allocation and use of resources. 23. The Senate Administrative Rules are subject to statute law that applies to the Senate. OF particular note are the Constitution Acts, 1867 and 1982, the Parliament of Canada Act, the Members of Parliament Retiring Allowances Act and the Parliamentary Employment and Staff Relations Act, 24, The Senate Administrative Rules are supplemented by policies, guidelines, opinions, directives, forms and practices adopted or implemented by the Senate, the Standing Committee on Internal Economy, Budgets and Administration and the Clerk of the Senate. 25. Ihave read the Senate Administrative Rules and the Senators Travel Policy and learned that it defines parliamentary functions as duties and activities related to the position of a senator, wherever performed, and includes public and official business and partisan matters, but does not include activities related to; a. the election of a member of the House of Commons during an election under the Canada Elections Act; or b. the private business interests of a Senator or a member of a Senator’s family or household, 26. The Standing Committee is responsible for the administration of the Senate Administrative Rules and for giving guidance on their interpretation to Senators and the Senate Administration, Sixty-Four point Travel System from the Senate Administrative Rules In this section, I will provide an overview of the Senate Administrative Rule’s 64 points travel system and its successor, the June $" 2012 Travel policy. 27. The 64 point travel policy was in effect fiom June 21, 2007 and was replaced by the June 5, 2012 policy that is reflected below. The policy that was introduced on June 5, 2012 was based on the overriding Senate principle of Senate or Parliamentary function for reimbursement of expenses. According to members of the Senate Finance and Procurement Directorate, the June 5, 2012 policy was meant to clarify and provide concrote examples for Senators to use for the preparation of their expense claims, 28. The intent of the 64-point Travel System is to fund travel incurred in the carrying out of senators' parliamentary functions or that is otherwise incurred for the service of the Senate. A Senator is entitled to 64 travel points per fiscal year for the combined travel of the Senator and the Senator's altemates. One point shall be deducted from a Senator's travel points for ‘each four-day period, or portion thereof, of a return national trip or of a return trip to Washington, D.C., U.S.A. Travel is categorized as “regular travel”, between Ottawa and the Senator's home province and “other travel”, either regional, national or international. 29. The purpose of travel is a mandatory field on the Travel Expense Claim form to enable the Finance division to review the claim to ensure that the travel is in accordance with the policy. However, there could be situations where, for confidentiality purposes, senators would not be able to provide details and would include a very brief description (for example, parliamentary functions or Senate business). In those instances, senators will be responsible to ensure that they maintain all details in their office for possible verification ot audit, In al situations, the onus is upon senators to only claim for travel that is related to their parliamentary functions. Senate resources shall not be used to fund travel that is incurred to pursue the private business or personal interests of a senator or alternate; 30. The items below list examples of travel typically carried out by senators and their alternates, specifying whether or not the trip is eligible for reimbursement under the 64-point travel system. Although the list is not exhaustive, it can nonetheless serve as a useful guide to senators and staff in determining whether or not a particular trip meets the intent of the 64- Point Travel System (ie. to fund travel incurred in the service of the Senate) and therefore reimbursable from Senate resources. The travel activities are categorized as being "fully funded", "funded with restrictions" or "unfunded", These terms are defined as follows: a, Fully Funded i, Trips that are "fully funded" are those that may always be claimed against the (64-point system as Jong as points remain available for that fiscal year and all requirements of this poliey aro mot; 1. Between the senators’ province or territory and the NCR to attend Senate sittings, committee meetings, and/or to carry out other parliamentary functions; 2. Participation in patty activities that are related to the work of the Senator or the Senate and its proceedings; Community events such as festivals, BBQs, parades. 4, Speaking engagements on topics related to Senate work or of public interest whether attending as an invitee or upon own initiative and receiving no additional remuneration from a souree outside of the Senate, b. Funded with Restrictions i, ‘Trips that are "funded with restrictions” are those that may be claimed against the 64-point system but which have certain restrictions placed upon them such as a limited number of points or trips per year or the need for prior approval by the Steering Committee. The restrictions are explained in the relevant sections of the policy. ded "Unfunded" trips are those which may not be claimed against the 64-point system under any circumstances, Although there may be instances where the activities undertaken during these trips constitute "public business" for the purpose of the Senators’ Attendance Policy, they are not considered to be parliamentary functions for the purposes of the 64-point Travel System and therefore not eligible for reimbursement. 1, Meetings and activities related to the senator's business or private interests (c.g, board of directors’ meetings of companies or charitable organizations; meetings with clients, suppliers, and other stakeholders; etc.); 2. Participation in party activities that are purely partisan matters such as election activities; 3. Speaking engagements or attendance at fundraising events other than those organized by the Senate; 4, Attendance at training sessions, seminars, or conferences related to the senator's professional qualifications and/or personal interest but not related to Senate wor 5. Attendance at book launches, art exhibits, theatre performances, concerts, etc in support of artists, writers, and performers; 6. Speaking engagements on any topic for which the senator is receiving additional remuneration from a source outside of the Senate, 31. Travel expense claims under the 64-point system shall be submitted to the Senate Finance and Procurement Directorate within sixty (60) calendar days after the completion of a trip. A separate claim shall be submitted for each trip undertaken where expenses have been incurred and for each person claiming reimbursement; 32. Unless otherwise indicated in this policy, all expenses shall be supported and receipts must be originals. Debit or credit card slips, post-dated receipts, and copies of cheques are not considered a sufficient proof. The following supporting documentation, as appropriate, shall be submitted with the travel expense claim: rem meno se k Hotel receipts Car rental receipts Gas receipts when using a rental car ‘Taxi receipts when the fare excceds the threshold established by the Committee Boarding passes Cancellation and change fees information Patickets Receipts for VIA Rail upgrades and VIA Rail tickets Receipts for miscellaneous transportation expenses such as parking, tolls, ferries and bus fares Print-out of road travel itinerary using any suitable mapping application (e.g. google maps, map quest, ete) Requirements related to usage of flight passes 33. It should be noted that when Senate-related travel is combined with private business or personal travel, supporting documentation should clearly differentiate between the two in order to establish the amounts that are reimbursable, Senators should contact the Finance division for advice on the best type of documentation to obtain prior to undertaking the trip (ic, quotes for air travel without the personal component included). 34. The Conflict of Interest Code for Senators was adopted by the Senate in May of 2005 and was revised in May of 2008.” ‘The Code is administered, interpreted and applied by the Senate Ethics Officer. The purposes of this Code are to: a, maintain and enhance public confidence and trust in the integrity of Senators and the Senate; b. provide for greater certainty and guidance for Senators when dealing with issues that ‘may present foreseeable real or apparent conflicts of interest; and . establish clear standards and a transparent system by which questions relating to proper conduct may be addressed by an independent, non-partisan adviser. 35. Section eight of the Code for Senators states that Senators may not act in any way to further their private interests, or those of their family members or to improperly further another person’s or entity’s private interests when performing parliamentary duties and functions; 36, Section eleven of the Code for Senators clarifies Section eight by stating that furthering private interests of a person or entity, including the Senator’s own private interests, means actions taken by the Senator for the purpose of achieving, directly or indirectly, any of the following: ‘a. an increase in, ot the preservation of, the value of the person’s or entity’s assets; b. the elimination or reduction in the amount, of the person’s or entity's liabilities; ©. the acquisition of a financial interest by the person or entity; d. an increase in the person’s or entity’s income from a contract, a business or a profession; ©. an increase in the person’s income from employment; f. the person becoming a director or officer in a corporation, association, trade union or not for profit organization; or g. the person becoming a partner in a partnership. 37, The Code for Senators states that every Senator shall file annually, on or before the date applicable to the Senator as established by the Senate Ethics Officer, a confidential statement disclosing the information required under Section twenty-eight of the Code, * {eared this from reading the website of the Senate Ethies Officer on November 6, 2014. (ittp//sen.parl. ge.calseo-cse/eng/Home-e. html) 10 a, Section twenty-cight of the Code dictates that the confidential statement to the Senate Ethics Officer shall list: ii, iii iv. vi. vii. viii. any employment, profession o business in which the Senator or the Senator's spouse or common law partner participates, including a description of the activities of the Senator, spouse or common law partner; any corporations, income trusts and trade unions in which the Senator or the Senator’s spouse or common law partner is a director or officer and any partnerships in which the Senator or the Senator’s spouse or common law partner is a partner, including a description of the activities of each entity; any associations or not for profit organizations in which the Senator or the Senator’s spouse or common law partner is a director, officer, or patron, including memberships on advisory boards and any honorary positions; the nature but not the amount of any source of income over $2000 that the ‘Senator or the Senator’s spouse or common law partner has received in the preceding 12 months and is likely to receive during the next 12 months; for this purpose; a source of income from employment is the employer, ii. a source of income from a contract is a party with whom the contract is made, iii, a source of income arising from an investment is that investment, the source, nature and value of any contracts or other business arrangements with the Government of Canada or a federal agency or body that the Senator has directly, or through a subcontract; the souree, nature and value of any contracts sub contracts or other business arrangements with the Government of Canada or a federal agency or body that the Senator has by virtue of a partnership or a significant interest in a private corporation that the Senator is able to ascertain by making reasonable inquiries; the source, nature and value of any contracts or other business arrangements with the Government of Canada or a federal ageney or body that a member of the Senator's family has, directly or through a subcontract, or by virtue of a partnership or a significant interest in a private corporation; information regarding the nature but not the value of any assets and liabilities of the Scnator or the Senator's spouse or common law partner over $10,000; and rt ix. any additional information that the Senator believes to be relevant to the Code, 38, The Code for Scnators also states that the Senate Bthics Officer shall prepare a public disclosure summary based on each Senator’s confidential disclosure statement and submit it to the Senator for review. Section 31 of the Code outlines the contents of the public disclosure summary. It lists that the summary shall include: a, any employment, profession and business in which the Senator participates, including the activities of the Senator; any corporations, income trusts and trade unions which the Senator is a director or officer and any partnerships in which the Senator is a partner, including a description of the activities of each entity; ©. any associations and not for profit organizations in which the Senator is a director, officer or patron, including memberships on advisory boards and any honorary positions; d. the source and nature but not the amount of any income over $2000 that the Senator has received in the preceding 12 months and is likely to receive in the next 12 months; ©. any statements filed under sections 17 and 18 of the Code in relation to gifts and sponsored travel, f. for any sponsored travel, all Senators shall disclose the name of the person or the organization paying for the travel, the destination, the purpose and the length of travel is also to be disclosed under the provisions of the Conflict of Interest Code, Senate Expense Controversy Timeline In this section, I will provide a brief chronology of events relative to the Senate expense controversy leading up to the RCMP’s involvement. Once a general timeline is described, I will then address some of these events or topics in greater detail under additional individual headings. 39, On Monday, December 22, 2008 Pamela Wallin was appointed to the Canadian Senate by Prime Minister Stephen Harper representing the Province of Saskatchewan. * 40. Since her appointment as a Senator, Senator Wallin has declared her primary residence as being in Wadena, Saskatchewan. Senator Wallin declared living expenses for a secondary residence in Ottawa, Ontario for the period starting in March 2009 up to June 26, 2011.* 3 1 leamed this fom reading the Senate of Canada website's profile of Senator Pamela Wallin, “Tleamed this from reading Senator Wallin’s 2009, 2010 and 2011's declarations of Primary and Secondary 12 41, In February 2012, Nicole Proulx (The director of Finance and Procurement for the Senate) asked Khatera Akbari (Senate Finance Audit readiness) to conduct a review of Senator Wallin’s travel pattern, and more specifically in relation to her travel expense to Toronto, ‘The rational provided at the time, was that Senator Wallin’s travels {0 Toronto were so frequent that it was difficult to assume that they were all for Senate Business. Moreover, at the time, Nicole Proulx was under the impression that Senator Wallin had a home in ‘Toronto which would explain why she was so often there. In her subsequent review, Akbari noted that Senator Wallin’s travel pattern was different from that of other Senators. ° 42, On Friday, August 24, 2012, Alison Stodin, « former executive assistant to Senator Wallin, wrote a letter to Senator Carolyn Stewart Olsen relating to concems she had over Senator Wallin’s travel and expense claims®, 43. On Wednesday, August 29, 2012, Gary O’Brien, the Clerk of the Senate, asked the Senate Finance and Procurement Directorate to begin an “extensive and thorough” internal review of Senator Wallin’s expenses. ” Consequently, in September 2012, Nicole Proulx asked Khatera Akbari to undergo another “more exhaustive” review of Senator Wallin’s travel coxpense claims 44, In October 2012, Khatera Akbari submitted her initial report. That report highlighted the following findings relating to Senator Wallin's travels”; a, a Toronto pattem; b. the use ofa car rental service; ¢. the discovery of one invoice from the car rental service made on Senate letterhead; d._ the discovery of invoices dated before the actual date of servic; the inconsistencies in the car rental service invoices (different rates); f. the discovery of the same invoice template used for two different companies; & the use of stamps signatures on travel claims; h, late claims; and i. the communication tone of Senator Wallin when addressing Senate Finance staff, residences received from the Senate. 2 Tleamed this during the interview I conducted with Khatera Akbari on October 30, 2013. $Teamned this from reading te letter dated 2012-08-24, sent by Alison Stodin o Senator Carolyn Stewart Olsen, ‘ Teamned this during the Interview I conducted with Gary O'Brien on October 22, 2013. $ Ieamed this during the interview I conducted with Khatera Akbati on October 30,2013. ° Teamed this during the interview I conducted with Khatera Akbeti on Octobor 30, 2013. 1B Ms. Akbari said that she came upon an e-mail between Senator Wallin and a committee staff in which, in the opinion of Ms. Akbari, Senator Wallin employed a “make it happen” tone which would lead a new employee to think that it was okay to bend the rules to suit the Senator's demands. 45, In October 2012, Senator Marjory LeBreton, (the leader of the Government in the Senate), spoke to Senator Wallin and expressed concems about the way that she had been claiming expenses, Senator LeBreton told Senator Wallin to get copies of her calendar and all of her ‘expense claims in order to “match the two” and to justify the expenses." 46, In October 2012, the Senate Finance and Procurement Directorate reported to the Senate that the internal audit on Senator Wallin was too large for them to manage.'! 47. On Wednesday, January 3, 2013, the Senate entered into a formal contract with Deloitte LLP (Deloitte), a member firm of Deloitte Touche Tohmatsu Limited. Deloitte was hired by the Senate to review Senator Wallin’s expense claims and supporting documentation and to categorize them into the following three categories’: a. appropriate in keeping with Senate practice; b, subject to reimbursement to the Receiver General; or ¢. subject to interpretation and determination by the Standing Committee on Internal Economy, Budgets and Administration, 48, During the period that Deloitte was conducting the review of Senator Pamela Wallin’s expense and travel claims, Senator Wallin publicly announced during a Canadian Broadcasting Corporation (CBC) interview, that she had repaid some $38,000 for travel claims that she had erroneously claimed, citing human error as its cause, During the interview, Senator Wallin stated that they were her mistakes and that she would pay her bills. Senator Wallin further said “7 was doing what I thought my job was. To not sit in Ottawa in an office, not sit in the Senate chamber always, but to be out there. Connecting with people who had issues, who had concerns, sho wanted to connect with the political process”. 49. [have read the report of Deloitte’s review of Senator Wallin’s travel expenses and living allowance which was made public on Tuesday August 13, 2013. In its report, Deloitte found that Senator Wallin claimed a total of $532,508.00 in travel expense claims during their review period of January 1, 2009 to September 30, 2012, Deloitte also found that; "© Jeamned this fom reading the transcript of the interview of Sen. Marjory Lebreton dated September 24, 2013, "'TJeamed this from reading the transcript of the interview of Sen. Marjory Lebreton dated September 24, 2013. " Teamed this from reading the Senate Standing Committee on Internal Economy, Budget & Administration's ‘Twenty-Seventh report dated August 13, 2013. '® learned this from reading the transcript ofthe Interview of Senator Wallin by CBC’s Peter Mansbridge, posted ‘on Juno 13, 2013 at http://www cbe,ca/n/touch/newaistory/l, 1315233 14 $390,182.00 had been appropriately claimed by Senator Wallin; $121,348.00 was subject to reimbursement to the Receiver General; $20,978.00 was subject to interpretation by the Senate Committee; Non-Senate business claims were comprised of 79 claims for a total of $90,323.00; ‘The incremental costs were associated to 52 claims for a total of $31,025.00 for the total amount of $121,348.00. one re 50, Deloitte reported that the claims that were deemed subject to reimbursement to the Receiver General, can be categorized as; a, corporations or private business; b, 2011 Federal Election campaigning; ¢. networking; 4. incremental costs; and ¢. fundraising involving Senator Wallin, which Senate Administrative Rules (SAR’s) determined to be non-Senate business. 51, On Thursday August 8, 2013, the Toronto Star published an article entitled “Pamela Wallin responds to the Deloitte report”. I have read the article in which I learned that Senator ‘Wallin, asserted that the process relied upon by Deloitte was flawed and that they erroneously applied policies retroactively, Sonator Wallin also asserted that Deloitte relied uupon some arbitrary and undefined sense of what constitutes “Senate Business” of “common Senate practice”. 52. On Tuesday August 13, 2013, the Senate Standing Committee produced its owa report. I have read this report entitled; the Twenty-Seventh Report which summarized the Deloitte review and the final findings of the Senate committee examining the matter. The Senate report stated that they agreed with the Deloitte review and its findings and prescribed remedies and acknowledged that Senator Wallin had paid back $38,369.00 ‘in expenses. 53. On Wednesday August 14, 2014, the RCMP Commissioner Robert Paulson received a letter from Senator Gerald Comeau, the Senate Chair of the Standing Committee. I have read this letter and attachment in which I learned that the Standing Committee is referring the matter dealt in the Deloitte report concerning Senator Pamela Wallin to the RCMP for examination. 54, On Thursday, August 22, 2013, the Steering Committee completed their analysis of the "Subject to Interpretation" claims identified in the Deloitte Report, Ihave read this, document in which the Steering Committee approved or rejected the different claims that Deloitte in its review had classified as “Subject to Interpretation”. 55. On Friday, September 13, 2013, Senator Wallin made a final repayment of $114,539.17, including interests to the Receiver General to bring the total repayment made by Senator * Based on Financial documents received from the Senate (Cash Blotter Summary Report // Freebalance financial ‘management system report) I calculated that the actual amount reimbursed by Senator Wallin between November 20, 2012 and June 26, 2013 is $39,652.12 instead of the $38,369.00 referred to by the Senate’s Twenty-Seventh Report. 15 Wallin between November 20, 2012 and September 13, 2013 to $154,191.29'5, Lhave read the letter sent from Senator Wallin to Senator Gerald Comeau in that regard, in which 1 learned the following; a Senator Wallin, in providing this payment asserted that she fundamentally disagreed with the methodology and conclusions reached by Deloitte and adopted by the Senate Committee in arriving at that figure, that the review process was flawed and arbitrary and does not comply with either procedural and substantive faimess, Moreover, Senator Wallin stated that “the voluntary repayment of this money is not ‘an acknowledgement of the correctness of Deloitte’s nor the Internal Economy Committce’s conclusions, nor an acknowledgement of any wrongdoing,” ‘The Deloitte Report 56. As mentioned previously, Deloitte was retained by the Senate fo examine expenses of Senator Pamela Wallin, In August 2013, Deloitte produced a report; “Deloitte, Review of Senator Wallin’s Travel Expense and Living Allowance Claims”. Lhave read this report, however I have not read copies of materials relied upon by Deloitte for their review and I am basing the present section upon their findings with the belief that Deloitte has consulted the documents, data and people where indicated in their review and in the manner described therein, In the interest of being full, fair and frank, I am providing a summary of Deloitte's findings. I am not relying on their findings to formulate my grounds. I am however relying on the results of their interviews with Senator Wallin and her administrative assistant Renée Montpellier and on documents which they received from Senator Wallin’s office to assist me in the formulation of my grounds of belief, The following is a summary of the report and their findings: a. Senator Wallin has been travelling regularly from and to Saskatchewan with extended stays and stopovers in Toronto, Senator Wallin’s claims have been made mainly with the purpose indicated as “Senate business”. These claims appeared to be compliant with the expense policies and were processed on that basis by Senate finance. In late 2012, Senator Wallin’s travel expense claims were under review as it was brought to the Senate’s attention that, although Senator Wallin had been following the proper procedures for submitting expense claims, the purpose of travel and travel pattems may not be compliant with Senate travel policies and guidelines, b. Deloitte was retained by the Senate to examine expense claims submitted by Senator Wallin for travel and living expenses; ©. Deloitte did perform a forensic examination which utilized methods consistent with established accounting and investigative practices; "5 In February 2013 interview with Deloitte, Senator Wallin and her Executive assistant, Ms, Rene Montpellier stated that they initiated and conducted a review of expense claims that the Senator submitted and that they had been thorough in theit review process and erred conservatively in their approach, As part oftheir methodology, Senator Wallin made repayment on situations where potential questions or isues remained, Senator Wallin stated that payments were made even when they had received conflicting advico. 16 4d. Findings were based on rules and guidelines of the Senate of Canada, which included Senate Administrative Rules, together with their underlying supporting guidelines and policies; €. ‘The time period subject fo the Deloitte Review was from January 1, 2009 to September 30, 2012; £ Inassessing Senator Wallin’s travel expense claims, Deloitte obtained from Senator Wallin and through other means, information regarding the nature of the events that she attended and the underlying purpose of her travel. Deloitte auditors assessed whether the events would be regarded as carrying out the Senator’s ‘parliamentary functions”. g. Senator Wallin was the only Senator whose travel expenses was reviewed by Deloitte and as such, Deloitte does not know if other Senators in previous years had made similar claims that had been reimbursed. h, Deloitte categorized its findings into three categories: i, Claims that determined to be appropriate in keeping with Senate practice. These claims are totaling $390,182; ii, Claims that are subject to reimbursement to the Receiver General. These claims are totaling $121,348; and iii, Claims that are subject to interpretation by the Steering Committee of Intemal Economy. These claims are totaling $20,978. [Senator Wallin has paid back the entire amount '“deemed subject to repayment to the Receiver General, including the amount that was subject to interpretation by the Senate plus the prescribed interest, on her own accord]. ‘The Deloitte review’s recommendations for reimbursement to the Receiver General are broken down into two categories, Non-Senate Business, totaling $90,323. and Incremental Cost, totaling $31,025. J. Non-Senate business i, The amount related to non-Senate business fell into one or more of the following: 1. travel claim was reimbursed by Senator Wallin as she deemed the claim was for personal business; 2. travel claim was for private business commitments made prior to Senator Wallin’s appointment to the Senate (Senator Wallin has indicated that she understood that these costs were to be covered); 1, The amount is $154,191.29 7 3. travel claim included amounts related (0 returning to Ottawa from private business activities; 4, travel claim related to speaking or other events which were non- Senate related; and 5. travel claim related to partisan related activity, such as fundraising, k, Incremental costs. Deloitte quantified the incremental cost as additional costs incurred by the Senator as she stopped in Toronto on her way between Ottawa and Saskatchewan. Stopovers in Toronto of a day or more incurred additional costs fo the Senate in comparison to direct or connecting flights, as the leg ‘between Ottawa and Toronto was generally booked on a separate ticket, Senator Wallin explained to Deloitte that these stopovers were required as: 1. On the westbound leg, she wanted to avoid a late arrival in Saskatchewan because Wadena was an additional two hour drive, which could be problematic especially in Winter; 2. On the eastbound journey, she used her time at her apartment in “Toronto to review materials for her committee work, which took place in Ottawa the following day. Moreover, Senator Wallin told Deloitte that no per diems or living allowance claims for a private residence were made for these stopovers. 1. Deloitte determined that additional costs charged to the Senate were deemed appropriate and not subjected to incremental costs in the following situations: i, Where Senator Wallin had to be in Toronto during the stop over petiod to attend Senate business and/or ii, Where Senator Wallin was required to be in Ottawa or Saskatchewan for Senate business at such times of the day that a direct or connecting flight to/from Saskatchewan would not have been reasonable, given the approximately two hour drive the Senator had to take once on the ground in Saskatchewan KPMG Audit of Financial Statements of the Senate of Canada 54, [read a report from Chartered Accountants, Licence Public Accountants (KPMG) dated September 17, 2013"”. This report is addressed to Mr, Gary O’Brien Clerk of the Senate. From this report, I learned that KPMG performed an audit of the financial statements of ‘The Senate of Canada for the period ended March 31, 2013. 17 This report was brought to the attention of the RCMP on March 31, 2014 by Mr. Michael Lacey, a counsel for Senator Wallin, 18 55. KPMG has identified a significant deficiency in Intemal Control over Financial Reporting. (ICER) at the Senate. KPMG defines this deficiency in control which it describes as “when the design or operation of a control does not allow management or employees, in the normal course of performing their assigned functions, fo prevent or detect misstatements on a timely basis”; 56. KPMG in their letter to the Senate also wrote that “expense claims submitted by Senators ‘for reimbursement are reviewed by Senate administration to verify that the amounts claimed are appropriate and supported by financial documentation. However, the Senate expense claim policies related to housing allowances and travel expenses were not sufficiently detailed with respect fo eligibility and documentation requirements to ensure amounts claimed were appropriate. The potential effect of this deficiency is that ineligible expenses may be approved and pai 57. KPMG made a number of recommendations to the Senate to improve its internal system governing internal contro! over financial reporting. ‘Senator Wallin’s Disclosures to the Senate Ethics Officer 58. On September 4" 2013, Constable Karine Trembay attended the office of the Senate Ethic Officer and obtained from Deborah Palumbo, the five Public Disclosure Summaries and three Statements of Material Change made by Senator Wallin from January 2009 to June 2013. These eight documents are dated; i. January 28, 2009; ii, October 20, 2009; i. September 10, 2010; iv. May 5, 2010; v. October 5, 2011; vi. November 26, 2012; vii. March 20, 2013; and viii, June 28, 2013. 59. Ihave read these eight documents. from which I leamed in part, the following; a. Between her January 2009 and June 2013 disclosures, Senator Wallin declared that she was a member of the board of directors of Porter Airlines, which she describes as “a Canadian airline company”. b. Between her January 2009 and June 2013 disclosures, Senator Wallin declared that she was a member of the board of directors of Gluskin Sheff & Asspciates Inc., which she describes as “an investment management firm”, ©. Between her January 2009 and May 2011 disclosures, Senator Wallin declared that she was a member of the board of directors of CTV globemedia Inc., a multi-media company. d. Between her January 2009 and October 2011 disclosures, Senator Wallin declared that she was a member of the board of directors of Oilsands Quest Inc., whieh she describes as “a public company engaged in projects in the oil and gas industry in Western Canada”, e, Between her January 2009 and September 2010 disclosures, Senator Wallin declared that she was Chancellor of the University of Guelph. On her disclosure, dated November 26, 2012, Senator Wallin declared that she was the Chancellor Emeritus of the University of Guelph. b 60, Senator Wallin also declared holding similar positions with several other corporate and not- for-profit organizations, RCMP investigation In this section, I will provide a chronology of the RCMP’s investigation, which was initiated on August 14, 2013 following the receipts of the letter of referral from Senator Gerald Comeau to the RCMP Commissioner Robert Paulson. ‘The RCMP Interview of France Lagace of the Senate Finance and Procurement Directorate 61, On Thursday October 3, 2013, Corporal Fred Pincince and I, interviewed France Lagace of the Senate Finance and Procurement Directorate, France Lagace is a senior officer for Pay & Pension, reconciliation of AMEX, and suporvises threo clerks who process senator's expense claims, During this interview, I leamed in part, the following; a, France Lagace said that before the introduction of the new amendments to the ‘Travel Policies in June 2012'*, the mention of “Senate Business” or “Parliamentary Functions” was all that was required from a Senator to justify an expense claim, France Lagace further stated that the rules never changed, that the June 2012 additions only provided written examples of the rules what were already in effect since 2009. b, France Lagace remembers that the Finance and Procurement Directorate did have questions in relation to Senator Wallin’s numerous stops in Toronto however having no other explanation but “Senate Business” written on the claims, they had no means to verify the information. ¢. With the June 5, 2012 introduction of the new travel policy Appendix, the Finance and Procurement Directorate is now in a better position to question Senators for clarification on the topic of “Senate Business”. ' Refer to Paragraph 24 of this application which claborates onthe June 5* Travel policy and 64 points travel system. 20 The RCMP Interview of Nicole Proulx , Director of Finance, Finance and Procurement Directorate 62, On Friday September 20, 2013, Corporal Fred Pincince and Sergeant Stephane Gauthier interviewed the Senate Director of Finance, Finance and Procurement Directorate, Ms. Nicole Proulx. Ihave read the transcript of that interview from which I leamed in part, the following; a. Nicole Proulx said that the various guidelines affecting Senate Travel Policies were put in place in November 2009, then in June 2010 followed by a major overhaul in 2012, In regard to Senate travel and claims, the overriding principle of Senate funds for Senate or parliamentary functions has been consistent since 200 s ‘The other policies and guidelines that were introduced after 2009, including the June 5, 2012 travel policy were to further clarify existing policies and guidelines; ©. It was not mandatory for Senators to provide the detail purpose of their trips. The mention of “Senate Business” was sufficient". The Senators were encouraged to provide details however; they were not required to do so. Moreover, as per the existing policy, the onus was upon the senators to only claim for travel that is related to parliamentary functions. ‘This practices changed with the implementation of some of the provisions of the 25" report” of the Standing Committee on Internal Reonomy, Budgets and Administration, 4, Senator Wallin’s general practice was to put “Parliamentary Function” or “Senate Business” on her expense claims, €. The irregularities with Senator Wallin’s claims was brought to Nicole Proulx’s attention in early 2012. £ In August 2012, the Senate Finance and Procurement Directorate initiated a review of Senator Wallin’s travel expense claims. In October 2012, the findings were presented to the Senate Clerk, Gary O’Brien, who then reported to the Steering Committee of Internal Economy Budgets and Administration a sub-committee of the Standing Committee of Intemal Economy, Budgets and Administration ‘The RCMP Interview of Ms. Khatera Akbari, Senate Finance and Procurement Directorate Audit and Project Coordinator 63. On October 30, 2013, Corporal Fred Pincince and I, interviewed Ms. Khatera Akbari, Ms. '® Refer to Paragraph 26 of this application which elaborates on the “purpose of travel” mandatory field on the ‘Senate expense claims. **Thave read the 25% report dated May 9, 2013. The report states, “That in order to more effectively assess compliance of travel claims with policy, travelers be required to provide the specific purpose for each trip. Although names of participants at a meeting or event need not to be disclosed, they should be kept for audit purposes.” an Akbati is the Senate Finance and Procurement Directorate’s audit and project coordinator who undertook the intemal review of Senator Wallin’s expenditures in 2012, During this interview, I learned in part, the following; a. Khatera Akbari’s involvement began in February 2012, when the Senate Finance Director, Nicole Proulx asked her to conduct an analysis in relation to Senator ‘Wallin’s travel pattem in relation to her travel to Toronto. ‘The rationale provided at the time, was that Senator Wallin’s travels to Toronto were so frequent that it was difficult to assume that they were all for Senate Business; b, Khatera Akbari conducted a review and noted that Senator Wallin’s travel pattern was different from that of other Senators. Khatera Akbari’s review yielded a one- page document which identified a clear pattem of going to Toronto. c. Khatera Akbari in September 2012, was asked by Ms. Nicole Proulx to undertake mote extensive review of Senator Wallin’s travel claims; 4. Khatera Akbari gathered all the files and began her review. The period under review was the previous and current fiscal year to date (2011-2012). She started reviewing the committee expenses, as this came from a separate budget and determined that there were enough checks and balances with the committee travels that this area was a low risk area for potential issues. She therefore focused on the travel claims and started with Toronto, as this issue had been brought up previously; ©, On October 10, 2012, Khatera Akbari sent her initial report to Ms. Nicole Proulx. ‘That report highlighted the following findings and or issues in relation to Senator Wallin’s travels; i, The Toronto travel pattern; ii, The use of a car rental service; The discovery of one invoice from the car rental service made on Senate letterhead; iv. The discovery of invoices dated before the actual date of service; . The inconsistencies in the car rental service invoices (different rates); vi. The discovery of the same invoice template used for two different companies; ‘The use of stamps signatures on travel claims; |. Claims that were submitted past the 60 days limitation; and 22 ix, The communication tone of Senator Wallin when addressing Senate Finance staff. Khatera Akbari explained that she came upon an e-mail between Senator Wallin and a committee staff in which, in the opinion of Ms. Akbari, Senator Wallin employed a “make it happen” tone which would Jead a new employee to think that it was okay to bend the rules to suit the ‘Senator’s demands. f. Atsome point, Khatera Akbari does not remember when, the Senate Clerk asked to meet with her along with Nicole Proulx, Senators Tkachuk and Stewart Olsen, At that time, Khatera Akbar provided them with a verbal overview of her findings. ‘The RCMP Interview of Mr. Gary O’Brien Clerk of the Senate 64. On October 22, 2013, Corporal Frederic Pincince and I interviewed Mr, Gary O'Brien, the Clerk of the Senate. During this interview, I leamed in part, the following; 8. Gary O°Brien said that Senators are under a regime where when filing travel claims, they are allowed to justify the claims under the mention of “Senate Business”. The senators are however responsible to retain the related documentation detailing the said senate business in the eventuality of an audit. Senator Wallin’s claims were processes as there were no apparent breaches of that rule, however; on some ‘occasions, thoy were brought to the attention of the Chairman (Senator Tkachuk) who on some instances, spoke to the Senator, particularly about her use of limousine and late claims; b. Issues pertaining to Senator Wallin surfaced because she had an unusual travel pattem consisting of going to Toronto whereas she is a Senator from Saskatchewan, Moreover, issues were also noted due to the consistent use of a limousine service as ‘opposed to taxis in Toronto and late claims; ©. Mr. O’Brien said that on August 29, 2012, after having consulted and obtained the consent of Senator Tkachuk, he asked the Finance and Procurement Directorate to begin an “extensive and thorough” internal review of Senator Wallin’s expenses for one or two fiscal years; d. The Senate Finance and Procurement Directorate had Ms. Khatera Akbari focus on this matter. The first draft of Ms. Akbari’s analysis was presented on October 31%, 2012. It identified several findings, which O'Brien referred to as “disturbing”; 93% of the trips had a Toronto component. (Either origination from, going to or stopovers); ii, 85% of the trips were justified by Senator Wallin with the mention of "Senate Business” with no further details; iii, Regular usage of a limousine service in Toronto; and 23 iv, Some invoices, seemed to be coming from her office as opposed to the receipt originators. e. Following this review, Senator Wallin repaid $38 000" to the Finance and Procurement Directorate on her own initiative, she was never asked to do so by the Steering Committee which just accepted the reimbursement without prejudice; f. On November 1", 2012 Mr. O'Brien met with two members of the Steering Committee, Senators Tkachuk and Stewart Olsen, to discuss the review. During this meeting, it was concluded that in order fo conduct a proper analysis, Senator Wallin’s calendars had to be consulted as they suspected that the Senator was abusing the rules. Senator Tkachuk approached Senator Wallin on November 7, 2012 asking Senator Wallin to supply the supporting documentations on which she answered that she had everything. Senator Wallin’s Windows’ calendar were supplied by her office on November 19, 2012 but they contained just the name of the events as oppose to what was required, which are supporting documentations detailing what was the "senate business” attended and proof that she had attended said events; g. The totality of these issues was then brought to the Stecring Committee and due to the fact that the Senate does not have an audit capacity from within, it was agreed that this matter be referred to an external auditor. At the time, this decision was not made public nor was it conveyed to the Standing Committee because the standing theory was that any senator could be asked to provide supporting documentation. ‘This matter was very serious, however, it was to be processed in a normal fashion; h, Deloitte was selected to do the external review. he RCMP Interview of Senator George re) 65, On Tuesday October 15, 2013, Sergeant Stephane Gauthier and Corporal Fred Pincince interviewed Senator George Furey, a Liberal Senator on the Steering Committee. [have read the Interview transcript fiom which I leamed in part, the following, a, Senator Furey said that there was no type of Senate business that was allowed prior {0 2012 that would not be allowed now; b. If senators travel for reasons other than Senate functions, they are not to claim their expenses fo the Senate. ¢. Generally, corporate board meeting expenses would be paid by the corporation and not the Senate; d. When a Senate event and a personal event are planned on the same day, it is a grey As previously referred in this document, T calculated thatthe actual nuniber is $39,652.12 24 area for the submission of an expense claim ¢. It was not uncommon for Senators to schedule other events on the same day as a Senate event and it was fine as long as no additional cost was to be borne by the Senate; The RCMP Interview of Senator Marjory LeBreton 66, On Monday September 23, 2013, Sergeant Stephane Gauthier and Corporal Fred Pineince interviewed Senator Marjory LeBreton, the leader of the government to the Senate. I have read the transcript of that interview fiom which I leamed in part, the following; a. Senator LeBreton, as the leader of the Government in the Senate and Caucus leader, spoke to Senator Wallin in October 2012 in relation to the “setious problems” ‘Senator Wallin had with the way she’s been claiming expenses. Senator LeBreton told Senator Wallin that copies of her calendars and expense claims should be compared and matched up and her expenses justified. Senator LeBreton thought that this could be easily resolved by Senator Wallin; b. No arrangements were ever made with Senator Wallin whereas she could continue her personal activities engaged upon prior fo Senate appointment and then charge the Senate for her expenses. , Senator LeBreton does not believe that Senator Wallin has committed any criminal offence and does not feel that Senator Wallin deliberately set out to “scam the system”, The RCMP Intervie of Senator David Thachuk 67. On Thursday October 17, 2013, Inspector Costa Dimopoulos and Sergeant Stephane Gauthicr interviewed Senator David Tkachuk, the Chair of the Senate Steering Committee from 2010-2013. I have read the transcript of that interview from which I learned in part, the following; a. Senator ‘Tkachuk defines Senate business as political business and said that private business, private trips and holidays are not in his opinion, Senate business, b. Senator Tkachuk said that if a Senator was invited to an event as a Senator, then that became Senate business; ©. Sometime after March 2010, Senator Tkachuk remembers that there were, from time to time, issues raised by the Senate Finance and Procurement Directorate to the Steering Committee as to Senator Wallin’s travels, particularly her travel patterns to Toronto; d. Senator Tkachuk is aware that Senator Wallin had a second residence in Toronto. 25 Sometime during his tenure as Chair of the Stereing Committee, Senator Tkachuk spoke to Senator Wallin about the fact that she resides in Saskatchewan and that she should be careful of other trips to Toronto. Moreover, that she needed {o have a professional reason to be there in order to make claims to the Senate Finance and Procurement Directorate for reimbursement; ¢. Senator Tkachuk believes that it was cheaper for Senator Wallin to fly to Toronto than it was to fly to Saskatoon however that the stop overs that Senator Wallin. made in Toronto on her way to Saskatchewan cost the Senate additional expenses; m Senator Tkachuk said that it was a unanimous decision of the Steering Committee to send Senator Wallin’s expense claims to an external review body; 8, Sometime during the period that Deloitte was conducting its review, Senator ‘Tkachuk asked Senator Wallin to remove all personal information from her Mictosoft Word calendar that was irrelevant in order to make the audit go quicker; The RCMP Interview of Senator Carolyn Stewart Olsen 68. On Wednesday October 23, 2013, Sergeant Stephane Gauthier and Corporal Fred Pinoince {interviewed Senator Carolyn Stewart Olsen who is a member of the Steering Committee, I have read the transcript of that interview from which I learned in part, the following; a. Senator Stewart Olsen stated that it is difficult for the Senate Finance and Procurement Directorate to approach a Senator and ask questions on the “purposes of the travel” when the reason written is Senate Business”. As a result, the Steering Committee tried to clavify and created examples to provide guidance to Senators and Senate Finance; b. According to Senator Stewart Oslen’s opinion, the Travel Claims Policy was always in place, and has never changed. In June 2012 some clarification with example, were provided to the Senators for some guidance, The Senate Travel has not changed since 2000 but has been clarified for the Senators which includes the June 5, 2012 policy clarifications. What was allowed before 2012 was still allowed after; and what was disallowed before June 2012 was sill disallowed after. The changes to the Travel policy were to bring it more in line with reality. The Senators cannot write down “Senate Business” anymore, they have to write the reason of the business; ©. Senator Stewart Olsen said that the length of time that Senator Wallin would stay in Toronto on a stop-over is what raised questions about Senator Wallin’s travel expenses. She further said that if there is a valid Senate Business event at one location, there is nothing in the policy that prevents a Senator from booking another event personal at that same location. The Senator must not claim this private event to Senate Finance, 26 The RCMP Interview of Ms, Shelly Clark-Chenette, former Executive Assistant to Senator Wallin 69. On Wednesday May 21, 2014 Corporal Fred Pincince and Constable Victor Paskal interviewed Ms. Shelly Clark-Chenette, a former executive assistant of Senator Wallin, I have read the transcript of that interview from which I learned in part, the following; a. Shelly Clark-Chenette worked for Senator Wallin between January and August 2009, She looked after the travel arrangements for Senator Wallin which included air travel, accommodations, rental vehicles, and ground transportation both in Toronto and Ottawa, Clark-Chenette said that she would input meetings and commitment information in Senator Wallin’s electronic Outlook calendar; b. Shelly Clark-Chenette said that Senator Wallin’s main events were in her Outlook calendar, however there were last minute events that were not necessarily in the Outlook calendar; ©. Upon returning from her trips, Senator Wallin would provide Shelly Clark-Chenette with the various receipts related to that trip. She would then submit the completed expense claim form to Senator Wallin for her signature, Shelly Clark-Chenctte said that at one point as a result of the amount of travel undertaken, Senator Wallin signed several blank travel claim forms and instructed her to fill them out, Shelly Clark-Chenette said that she kept the forms but never used them as she felt it “didn’t fee! right”. “henette felt that Toronto was the city of primary residence of Senator Shelly Clar Wallin; ¢. Shelly Clark-Chenette felt that Senator Wallin believed that she was assigned to some boards of directors because she was a Senator; thus making all her commitments Senate-related. Shelly Clark-Chenette therefore understood that all the receipts she would be receiving from Senator Wallin had to be processed through a travel expense claim. £. Shelly Clark-Chenette remembered instances where she expressed doubts to Senator Wallin regarding the eligibility of some expenses which she believes were personal expenses, Shelly Clark-Chenette remembered that Senator Wallin would reply that she had spoken to someone who confirmed that it was eligible, At times Senator Wallin would get mad, telling Shelly Clark-Chenette something to the effect of “do it, just get it done, do it anyway”. Shelly Clark-Chenette interpreted this as a clear direction to submit the claims regardless. hh, Shelly Clark-Chenette said that as a Porter board member, Senator Wallin almost always flew with Porter, 27 The RCMP Interview of Ms. Helen Krzyzewski, former Executive Assistant to Senator Wallin 70. On Tuesday December 17, 2013, Constable Linnea Gallant and I interviewed Ms, Helen Krzyzewski, a former executive assistant to Senator Wallin, During this interview, I learned in part, the following; a. Ms. Helen Krzyzewski worked for Senator Wallin between September 2009 and October 2010; b, Ms. Krzyzewki said that she did not believe that Senator Wallin would intentionally 4g0 to a corporate board meeting and claim Senate funds; ©. Ms. Krzyzewki said that if Senator Wallin had a corporate related event, that she would do so on her private time, not on Senate time, She further said that if Senator Wallin for instance, was on her way to Ottawa, and had a Porter Board meeting, that Senator Wallin would attend the meeting prior to board her flight; d, Whenever Senator Wallin had an event scheduled, Helen Krzyzewski would populate the event in Senator Wallin's Outlook calendar, Senator Wallin concurrently had her own paper 8% x 11 calendar which she carried around, Senator Wallin kept her private schedule in that paper calendar; ¢. Because of the Outlook calendar, Helen Krzyzewski had a good idea of Senator Wallin’s schedule, however she would never on her own initiative book flights because she never knew what was Senator Wallin’s activities before and after the events showing in the Outlook calendar; f Ms. Krzyzewksi belioves that the Outlook calendar was complete as far as Senate related events. However, the Outlook calendar was far from being complete as far as the overall picture all the other events Senator Wallin attended on her personal time; g. Ms. Krayzewski’s responsibilities were to populate the elaims and to have them reviewed by Senator Wallin, She was not responsible to make a determination on the eligibility of the claims; h, Upon retuming from any given travel, Senator Wallin would give Ms. Krzyzewski the receipts, tickets and boarding passes generated during the trip for processing, Senator Wallin would tum over a hand full of receipts to Ms. Krzyzewski saying, “this is my receipts fiom the weekend”. Ms. Krzyzewski would in turn populate the travel claims based on the documentation provided by Senator Wallin, Once completed, Ms. Krzyzewski would submit the travel claim to Senator Wallin for review and signature, At the conclusion of this process, the claims were submitted to the Senate Finance and Procurement Directorate for processing; 28 During the entire time when she worked for Senator Wallin, Ms, Krzyzewski has never questioned any of Senator Wallin's travel expenses, Moreover, Ms. Krzyzewski is of the opinion that if Senator Wallin gave her receipts to be claim, that surely thoy were legitimate elaims. The RCMP Interview of Ms. Sabrina Hamilton former Executive Assistant to Senator Wallin 71. On Wednesday December 18, 2013, Corporal Fred Pincince interviewed Ms, Sabrina Hamilton, a former executive assistant to Senator Wallin. I have read the transcript of that interview from which I learned in part, the following; a Ms. Sabrina Hamilton worked for Senator Wallin between October 2010 and June 27, 2012, Her duties included; i, Scheduling of events for Senator Wallin; ii, Managing Senator Wallin’s calendar; and iii, Managing and organizing Senator Wallin’s travels, ‘Ms, Hamilton said that she was taught by Helen Krzyzewski to categorize all travels completed by Senator Wallin as “Senate Business”; Upon returning to Ottawa, Senator Wallin would hand over the receipts; mainly taxi, hotel, and boarding passes to Ms. Hamilton who would then prepare the expense claims; Ms. Hamilton felt that the Senate Finance and Procurement Directorate was the check and balance system and that if they approved the expense claims, they were legitimate claims and that Senator Wallin would not try to get personal gain out of, expense claims; Generally, Ms. Sabrina Hamilton would put the entries in Senator Wallin’s Outlook calendar as Senator Wallin rately did so herself. The calendar entries contained information on the contact, date, time and the purpose of the event, The calendar would include mostly Senate business but also contained a small portion of personsl stuff such as hair appointments. The board or director meetings were noted in the calendar in order to manage the Senator’s schedule effectively; Ms. Hamilton believed that Senator Wallin’s primary residence was in Toronto; Ms. Hamilton stated that Senator Wallin would go back to Toronto “a lot of times” Just to be at her residence; Ms. Hamilton said that as a member of Porter’s board of directors, Senator Wallin preferred to use Porter rather than a competitive airline; Ms. Hamilton said that Senator Wallin’s Porter board meetings were in Toronto and that the flights were not billed to Porter because Senator Wallin was flying back to 29 Toronto as part of the regular Ottawa to Toronto travel. That if Senator Wallin was returning from Ottawa on a Thursday and had a Porter meeting on Friday, that they ‘would not have billed Porter for the flight as Senator would be on Senate Business, The Deloitte Interview of Ms. Sabrina Hamilton 72. On Monday June 24, 2013, Ms. Hamilton was interviewed by Mr. Gary Timm and Mr. Alan Stewart of Deloitte. I have read the summaty of that interview written by RCMP Corporal Frederic Pincince, in which I learned in part, the following: a. Ms. Hamilton said that Senator Wallin would remove specific receipts related to personal matters from the receipts that were being claimed as Senate business; b. Ms. Hamilton does not remember submitting expense claims related to Porter; c. Ms. Hamilton did not have any concems in relation to travel claims during the time of her employment and believed everything was done in good faith; d. Ms, Hamilton said that Senate travels were arranged to correspond with board of directors meetings in Toronto. The RCMP Interview of Mr. Gary Timm and Alan Stewart of Deloitte 73, On Monday September 16, 2013, Corporal Fred Pineince interviewed Mr, Alan Stewart and Mr, Gary Timm of Deloitte. Ihave read the transcript of that interview in which I earned in part, the following; a, Alan Stewart and Gary Timm are engagement partners at Deloitte and were co- ‘engagement partners on the review of Senator Pamela Wallin’s travel claims; b, According to Mr. Timm and Mr. Stewart, Senator Wallin made comments about the retroactivity of the travel polioy and their response to Senator Wallin was that the inciples had not changed. Deloitte took into account all the roles within the Senate that Senator Wallin played, including participation in Senate committees and considered each event claimed in line with the overriding principle of the Senator performing parliamentary functions. ‘The Deloitte Interviews of Senator Pamela Wallin and her Executive Assistant Renée Montpellier by Deloitte 74, Senator Pamela Wallin along with her then Executive Assistant Ms. Renée Montpellier were interviewed together on four occasions and individually on one occasion each by Mr. Gary Timm and his Deloitte associates. These six interviews occurred between Monday February 11 and Monday July 15, 2013” during the period when Deloitte was contracted On January 21, 2014, I spoke to RCMP Corporal Fred Pincince who told me; that (1), On June S* 2014, he spoke to the Senate deputy Law Clerk, Michel Patrice who said that a Senator was not compelled to participate in 30 by the Senate to conduct the review of Senator Wallin’s travel expense Claims. [have read the transcripts of these six interviews from which I leamed in part, the following; a, Senator Wallin said that after going through the exercise of reviewing her travel claims, she felt that her office did not have a good understanding of the policies and guidelines governing travel expenses. Senator Wallin stated that she is taking responsibility for not studying those policies and explained that her busy schedule may have prevented her from taking appropriate time to review them. Senator Wallin stated that she was reliant on her staff and was expecting them to review the policies and guidelines. Senator Wallin expected her staff to follow up with Senate Finance or the Internal Economy Committee when they were unsure of the process; b. Senator Wallin said she received conflicting advice from Senator David Tkachuk and his Executive Assistant in relation to the eligibility of events where Senator Wallin would be engaging in conversation with the public and this even when attending a so called private event. Scnator Wallin stated that this same situation was not clear from the Senate Finance policy perspective. Senator Wallin said that she later repaid the expenses in relation to these events in spite of what Senator ‘Tkachuk had told hner; c. Senator Wallin found it difficult to get a clear definition of what constituted "Senate business". Senator Wallin stated that the advice would vary from the point of view of the Senators, the Senate Finance and Procurement Directorate or the Office of the Ethics Commissioner. Senator Wallin felt that what constituted "Senate business" was subjective; d. Senator Wallin said that they discovered one or two cases in whieh flights to Toronto were charged to the Senate for private business (i,e.: Potter Board of Directors meetings). Senator Wallin stated that those cases were mistakes; ¢. Senator Wallin provided the following methodology regarding the processing of the travel claim at her office: i, Senator Wallin's Executive Assistants would put the travel claims together; ii, ‘The claims would come to Senator Wallin with receipts stapled to them; iii, ‘The Senator would then sign the claims; the Deloitte review process nor that there is any requirements or legislation compelling a Senator to do so. Mr. Patrice also said that that they were encouraged to participate and that Senator Wallin chose to cooperate. And (2), that on June 6, 2014, he spoke to Gary Timm of Deloitte who said that Deloitte did not address the voluntatiness aspect in their discussion with Senator Wallin, and that in the course of their review, Deloitte requested documents ‘and information from Senator Wallin who fully cooperated by providing a variety of documents (ie, handwritten calendars, spreadsheets ets.). Mr. Timim said that he could not atest o the Senate requirements and that Senator Wallin could lave felt competted by the Senate. 31 £. Senator Wallin said that in November (I botiove she is referring to 2012) sho accidently found out about a review of her travels undertaken by the Senate Finance and Procurement Directorate . g. Ms. Montpellier stated that Senator Wallin and herself went through claims ranging from October 2012 to February 2013 and flagged some minor issues. h. Senator Wallin said that they have been thorough in their review process and erred conservatively in their approach. As part of their methodology, Senator Wallin made repayment to the Receiver General on situation where potential questions or issues remained, Senator Wallin stated that payments were made even when they had received conflicting advice”. i. Senator Wallin said that she did a lot of back and forth to her Toronto apartment for clothes, for work, and for business; j. Senator Wallin said that she made additions and deletions to her Outlook calendar which she provided to Deloitte, Senator Wallin said that the changes were made as she attempted to reconcile the events with her notes and her book. Senator Wallin said that the calendar was mostly a tool for her staff which included planned events which she didn’t necessarily attend. Senator Wallin said that the Outlook calendar was not clearly reflecting what she was doing. The changes to the Outlook calendar ‘were therefore made in order to clearly reflect what she was doing, Senator Wallin said that the Outlook calendar was not her primary tool since other third parties could input items into her calendar. Senator Wallin stated that she used notes as she mostly operated on the phone. k. Senator Wallin said that in relation to board meetings, Porter would book the tickets ‘on her behalf, and for other corporations, she would pay and seek reimbursement, 1. Senator Wallin said that as @ Porter director, she can fly every day to Toronto for free. She although chose to pay for the flights because she didn’t want to be in a conflicting position, At the same time, paying for the flights is detrimental to her as she is using her points (64 points system). 75. Moreover, during these interviews, Senator Wallin was asked to provide additional information in relation to a number of specific events she had attended and how these events constituted “Senate business”. I will further elaborate about a number of these specific events, 76. In addition to the interviews, Senator Wallin also provided Deloitte with several documents. Ina memo dated February 1, 2013 addressed to Gary Timm of Deloitte, Senator Wallin wrote, * We have prepared these documents to try to explain the nature of » As previously stated, the actual amount reimbursed by Senator Wallin between November 21, 2012 and June 26, 2013 is $39,652.12 32 the work Ido when Lam not actually sitting in Chamber or chairing a committee. a, Senator Wallin’s office provided Deloitte with seven calendar Spreadsheets®. [ have read these seven Spreadsheets which are divided as follows; i, a January 2009 to March 2009 calendar Spreadsheet’; ii, a 2009/2010 calendar Spreadsheet”; iii, 2010/2011 calendar Spreadsheet”; iv, a 2011 calendar Spreadsheet”; v. an updated 2011 calendar Spreadsheet™*; vi. a 2012 calendar Spreadsheet”!; and vii. an updated 2012 calendar Spreadsheet’. b, Senator Wallin’s office provided Deloitte with copies of six written calendars belonging to Senator Wallin”, [have read these six handwritten calendars, which are in my belief, very convoluted and difficult to analyze, These six handwritten calendars ate divided as follows; a December 2008 to September 2009 calendar; i. an August 2009 to December 2010 calendar; iii, a December 2010 to January 2012 calendar; . a December 2010 to January 2012 calendar; aDecember 2011 to August 2012 calendar; and vi, a March 2012 to December 2012 calendar ©. Senator Wallin’s office provided Deloitte with three printed Microsoft calendars containing travel and event descriptions of Senator Wallin, [have read these calendars which are divided as follows”; 2 | feared this fiom reading a memo dated February 1, 2013 from Senator Wallin o Mr. Gary Tinum of Defoite, 2 ‘Those Spreadsheets were received from Deloitte on December 3, 2013 pursuant tothe Production Order issued by Ontario Court Justice Hugh Fraser on November 1, 2013 Learned this from reading the memorandum & calendar Spreadsheet sont from Rengo Montpellier to Gary Timm sf Deloitte dated Juno 25, 2013. Feared this from reading the memorandum & calendar Spreadshect sont from Renée Montpelier to Gary Timm gf Deloitte on May 13, 2013 Tjeamed ths ftom reading the memorandum & calendar Spreadsheet sent from Renée Montpelier to Gary Timm ‘9 Deloite on May 1, 2013 ® Learned this from reading the e-mail & calendar Spreadsheet sent from Renée Montpelier to Gary Timm of on Rebruary 5, 2013, * T earned this from reading the e-mail & calendar Spreadsheet sent from Renée Montpellier to Gary Timm of on February 8, 2013 3 Nearned this from rei Janoary 15, 2013. 2 teamed this from reading the e-mail & calendar Spreadsheet sent from Renée Montpelier to Gary Timm of on February 4, 2013, * These handwriten calendars were received from Deloitte on December 3, 2013 pursuant to the Production Order issued by Ontario Court Justice Hugh Fraser on November 1, 2013. These printed ealendars wore received from Deloite on December 3, 2013 pursuant to the Produeti issued by Ontario Court Justice Hugh Fraser on November 1, 2013, the e-mail & calendar Spreadshect sent from Renée Montpellier to Gary Timm of on Order 33 i. a January to March 2009 calendar; ii. an April 2009 to March 2010 calendar; and ii, an April 2010 to March 2011 calendar. 4, Senator Wallin’s office also provided Deloitte with a number of other supporting documents such as news printouts and e-mails containing explanations on specific days and events attended by Senator Wallin. 77. On Friday November 1, 2013, Constable Michael Johnson applied for and was granted by Ontario Court Justice Hugh Fraser, production orders to obtain from Deloitte and the Senate, relevant documentation in support of the RCMP’s investigation of Senator Wallin’s travel expense claims*’, Clarifications provided by Nicole Proulx [read a report prepared by Corporal Fred Pincince in which I learned the following; On January 27, 2014, Corporal Fred Pincince spoke to Nicole Proulx who said that the RCMP had mistakenly represented elements of her interview in the Information sworn to Ontario Court Justice Hugh Fraser on November 1, 2013. Nicole Proulx clarified the following; The meeting involving the Clerk of the Senate, Gary O'Brien and Senator Wallin occurred in 2009 and not in 2012. That a monitoring report was sent to Mr, O'Brien in 2012 and Ms. Proulx does not know if Senator Wallin had met with Mr. O'Brien at that time, ‘The Steering Committee allowed payment in relation to the car service (limousine) only on one instance even though the Senate Finance Directorate kept reimbursing Senator Wallin for subsequent similar claims. Some employees from the Senate Finance Directorate were unaware that the exception only applied to the specific expense claim looked at by the Steering Committee. It is for that reason that subsequent car services expenses were paid by the Senate Finance Directorate. The Steering committee met with Senator Wallin in September 2009 in order to tell her that her Senate business conducted in Toronto had to comply with Senate policy. Ms, Proulx did not attend a similar meeting in January of 2012 as reported in Constable Johnson's Information. } 53. On Friday, November 8, 2013, Constable Michael Johnson applied for and was granted by TJeamed this from reading a copy of the Production Order issued by Justice Hugh Fraser on November 1, 2013. 34 Ontario Court Justice Hugh Fraser, a production order to obtain from Deloitte, relevant documentation in support of the RCMP’s investigation of Senator Wallin’s travel expense claims”’, 54, On Saturday November 9, 2013, Corporal David Connors of the RCMP’s Integrated Technical Crime Unit attended the Senate of Canada and retrieved electronic data sought in the Production Order issued by Ontario Court Justice Hugh Fraser on November 1% 2013”, a, This electronic data included the following; i, calendar information, contact lists and e-mail messages pertaining to appointments and meetings requests fiom Senator Wallin’s Microsoft Exchange mailbox; the 2009, 2010, 2011, 2012 electronic annual backups of the Senate's Microsoft Exchange database; and the January to June 2013 electronic monthly backups of the Senate's Microsoft Exchange database 58. On Friday, November 29, 2013, Constable Victor Paskal and I attended the Senate of Canada and received from the Senate legal Counsel, Michel Patrice, six DVDs containing the documentation sought in the Production Order issued by Ontario Court Justice Hugh Fraser on November 1° 2013. a. The six DVDs contained several documents, including the following; i, the travel expense claim forms and supporting documentation submitted by Senator Pamela Wallin covering the period of January 6, 2009 to October 3, 2012; ii, the declaration of primary residence forms submitted by Senator Wallin between January 19, 2009 and April 1“, 2013; and iii, the financial reports reflecting the reimbursement made by Senator Wallin to date. 56, On Tuesday December 3, 2012, Corporal Fred Pincince and Constable Victor Paskal attended the offices of Deloitte and received from Mr. Gary Timm, three boxes of documents, containing the documentation sought in the Production Order issued by Ontario Court Justice Hugh Fraser on November 1, 2013°. a, The three boxes contained several documents, including the following; * | Jeamed this from reading a copy of the Production Order issued by Justice Hugh Fraser on November 8, 2013. 37 T teamed this from reading an exhibit report prepared by Constable Victor Paskal, dated November 21, 2013. > 1 leamed this from reading an exhibit report prepared by Constable Victor Paskal dated 2014-01-23 35 i, a printed Microsoft calendar containing Travel & Event descriptions for Senator Wallin for the period of January 2009 to March 2011 provided to Deloitte by Senator Wallin’s office; ii, a printed Handwritten calendar containing Travel & Event descriptions for Senator Wallin for the period between December 2008 and December 2012; iii, a printed Spreadsheet consisting of a calendar detailing Travel & Event descriptions of Senator Wallin for the period between April 2008 to March 2010 and between April 2011 to March 2013; iv. a USB key containing the electronic version of Senator Wallin’s Microsoft Outlook calendar. 57. On Tuesday, December 10, 2013, Constable Michael Johnson applied for and was granted by Ontatio Court Justice Hugh Fraser, a production order to obtain from the Senate, amended further relevant data in support of the RCMP’ investigation of Senator Wallin’s travel expense claims”, a, This electronic data included the following; i, calendar information, contact lists and e-mail messages pertaining to appointments and meetings requests from Senator Wallin’s Microsoft Exchange mailbox; ii, the July to November 2012 electronic monthly backups of the Senate’s Microsoft Exchange database, 58. On Thursday December 19, 2014, Corporal David Connors of the RCMP?’s Integrated Technical Crime Unit attended the Senate of Canada and retrieved electronic data sought in the Production Order issued by Ontario Court Justice Hugh Fraser on December 10, 2013. 59. On Tuesday, February 18, 2014, Corporal Fred Pincince and Constable Victor Paskal attended the Senate of Canada and obtained from counsel Michel Pattice, additional items pursuant to the Production Order issued by Justice Hugh Fraser on November 1, 2013"! RCMP analysis of documents obtained from Deloitte and from the Senate of Canada 60. The RCMP investigators reviewed and analyzed the documentation received from Deloitte and from the Senate, This documentation included; 2» TJeamed this from reading a copy of the Production Order issued by Justice Hugh Fraser on December 10, 2013. * LIcarned this from reading an exhibit report prepared by Constable Victor Paskal dated January 8, 2014, ' Tlearmed this from reading 2 report dated February 18, 2014, prepared by Corporal Fred Pineinee. 36 e the numerous travel expense claims covering the period between January 6, 2009 and October 3, 2012; the verbal rationales provided by Senator Wallin to Deloitte during her interviews; the written rationales provided by Senator Wallin and her office to Deloitte in the form of emails and Spreadsheets; the different paper and electronic calendars associated to Senator Wallin; and the electronic backups of the Senate's Microsoft Exchange database. 61, The RCMP examination of Senator Wallin’s Microsoft Outlook calendar along with that of the electronic calendar backups of the Senate’s Microsoft Exchange database was done u ing Intella, a forensic search tool utilized by the RCMP. In the context of this, estigation, I will be referring to calendar “entries”. These entries are appointments that RCMP investigators have found in the numerous electronic and handwritten calendars associated to Senator Wallin. 62. The Intella software, enabled RCMP investigators to see modifications, including additions and deletions made to the entries in Senator Wallin’s electronic Outlook calendar between 2009 and June 2013, 63. The RCMP analysis of Senator Wallin’s electronic Outlook calendar revealed an unusual pattern, The analysis revealed that 101 entties that were present in the April 2013 backup, were missing from the May 2013 backup and reappeared in the June 2013 backups. Corporal David Connors“ of the RCMP Integrated Technological Crime Unit wrote a report in that regard. I have read this report in which I leamed the following; a vb. Some sort of user interaction with Senator Wallin’s Outlook calendar was necessary to cause the disappearance of 101 calendar entries in the May 2013 backup. This could have been accomplished through multiple methods, including by a user modifying the “Subject”, “Start Date” and/or “End Date”, or by the user moving the calendar entry to another Outlook calendar that was not captured as part of the regular backup of Senator Wallin’s account; Itis not possible to determine precisely which user performed these actions by only the examination of the Outlook calendar; An “authorized user” is a user that has a Microsoft Exchange account that has been granted access to another user’s Outlook calendar. This results in a “Shared” Outlook calendar. This user could be granted permission to access, modify, add, delete or move entries. Multiple users can have coneurrent aceess to multiple © ‘This Microsoft Outlook calendar was obtained from the Senate on November 9, 2013. © Opl. Connors has 11 yeats" exper the RCMP. He holds a Bachelor of Science in Computer ce wi Engineering and has been working with the RCMP’s Technological Crime Branch for the past 8 years. 37 calendars, 64, I read a letter dated July 26, 2013, authored by Terence O’Sullivan (a civil litigation lawyer) addressed to Mr. Gary Timm and Alan Steward of Deloitte. This letter addresses the changes to Senator Wallin’s electronic Microsoft Outlook calendar. I have read this letter in which I learned in part, the following; (The full version of this letter is annexed to the Deloitte Report. The letter is attached to this application as Exhibit 1) a, Senator Wallin was asked to and did supply certain information which included information from her Outlook calendar. In the interest of giving Deloitte and the Senate Committee a full picture of the extent of her activities, Senator Wallin supplied information containing not only her Senate related business but other matters as well. Following the delivery of the first preliminary repoxt, Senator David Tkachuk expressed to Senator Wallin that the review process was taking a Jong time because Senator Wallin was supplying too much unrelated information. ‘Senator Tkachuk expressed that further submissions should be restricted to that information which was tied to specific travel claims, In subsequent submissions, Senator Wallin followed Senator Tkachuk’s advise. The decision to exclude some information was based not only on Senator Tkachuk’s advice but also on a desire by Senator Wallin to protect the legitimate expectations of privacy of those with whom. she dealt in a non-senate capacity. Moreover, when consulting other sources, Senator Wallin and her administrative assistant discovered that on occasion there were events which appeared in the Outlook calendar which Senator Wallin had not attended and they were deleted. It also appeared that there were events that she attended that were not reflected in the Outlook calendar and so they were added. 65. [read a Senator's Network Service Request Forms dated October 1, 2012 and learned that in May 2013, there were only two individuals from Senator Wallin’s office who had access to the Microsoft Outlook calendar associated to Senator Wallin. These two individuals are; a. Senator Wallin; and b, Renée Montpellier. 66. From this analysis, the RCMP investigators have identified 150 travel expense claims ‘requiring further investigation to determine whether they included travel and expenses unrelated to Senator Wallin’s parliamentary functions ‘These 150 travel expense claims are for the period between January 15, 2009 and September 25, 2012, Moreover, these 150 travel expense claims were all submitted for reimbursement by Senator Wallin and her office under the representation that the activities undertaken by the Senator were parliamentary related. “* “ [Jeamed this from reviewing the Rational Spreadsheet generated by Sergeant Stephane Gauthier on 2014-06-09. 38 ——————————— 2 Investigation Specific To Porter Airlines _ Interview of Mr. Bob Deluce ~ Chief Executive Officer for Porter Airlines 67. On Tuesday September 23, 2014, Constable Victor Paskal and I interviewed Mr. Robert Deluce, the Chief Execitive Officer of Porter Airlines. Mr. Greg Sheahan, (Council for porter) was also in attendance, During this interview, I learned in part, the following; a, Mr, Deluce said that Senator Wallin was an independent Porter director between 2008 and 2013, holding fiduciary responsibilities towards Porter. b. Mr, Deluce said that the board of directors convened generally quarterly with the exception of ad hoc meetings to address any unpredicted event, and that committee ‘meetings are held three to four times per year. ©. According to Mr. Deluce, each board member, including Senator Wallin, is entitled to; i, an annual retainer; ii, stock options; iii, free porter flights (assuming they ate on Porter business or leisure); and iv. reimbursement for “out of pocket” expenses such as; transportation, accommodation & meals, ineurred for while attending to Porter business. d. Mr, Deluce was able to confirm the attendance of Senator Wallin at 11 events, during the period covered by expense claims submitted by Senator Wallin to the Senate,‘* Mr. Sheahan later confitmed via e-mail, additional information which Mr. Deluce was unable to provide during his interview“, pense Claims related to Porter Airlines In this section, I will present cach of the travel expense claims submitted for reimbursement to the Senate Finance and Procurement Directorate by Senator Wallin, that pertains to the timing of Senator Wallin’s attendance to Porter Board events; 68. As previously stated; a, Between her January 2009 and June 2013 public disclosures, Senator Wallin declared that she was a member of the board of directors of Porter; b. RCMP investigators received 246 Travel expense claims from the Senate, Of the 246 claims, we have identified 150 travel expense claims requiring further ‘© will further elaborate about each of these events in a later paragraph, “ Mr. Sheahan sent me this email on October 21, 2014. The information pertains toa lunch, a board of trade dinner and a meeting attended by Senator Wallin in Toronto, 39 investigation. Of the 150 claims, 12 coincide with the timing of [1 Porter board vents attended by Senator Wallin, Ihave read these 12 travel expense claims and accompanying supporting documents”, and learned the following; Travel expense claim T64-10436 (1 of 12) 69. This travel expense claim is for the period between December 21, 2009 and January 13, 2010. a, On December 21, 2009, Senator Wallin flew from Toronto to Regina; b. On December 31, 2009, Senator Wallin flew from Regina to Toronto; c. On January 1, 2010, Senator Wallin flew from Toronto to New York City; d. On January 6, 2010, Senator Wallin flew from New York City to Toronto; e. On January 7, 2010, Senator Wallin flew from Toronto to Regina; £ On January 10, 2010, Senator Wallin flew from Regina to Toronto; and g On January 13,2010, Senator Wallin flew from Toronto to Ottawa, 70, Senator Wallin expensed the December 21, 2009 airfare from Toronto to Regina, the January 10, 2010 airfare from Regina to Toronto, the January 13, 2010 airfare from Toronto to Ottawa, the associated ground transportation, some per diems along with private and commercial accommodations to the Senate. Senator Wallin did not expense the airfares between Regina and New York, nor its associated ground transportation. 71. The purpose written on this claim is “Senate Business”, The expense claim bears Senator Wallin’s signature and is dated January 26, 2009. [1 believe that there was an error in the date and that the year should read 2010 instead of 2009]. The claim was submitted to the Senate Finance and Procurement Directorate for reimbursement. Sunday January 10, 2010 Flight to Toronto a. A flight itinerary attached to the expense claim shows that Senator Wallin flew from Regina to Toronto, arriving in Toronto at approximately 23:29 hours on January 10, 2010. b. The RCMP analysis of Senator Wallin’s calendars and electronic backups also revealed no entries for events scheduled in Toronto that evening, fo the #7 These 12 travel expense claims were received from the Senate on November 29, 2013 subsequen Production Order dated November 1, 2013. 40 Monday January 11, 2010 Meeting with Robert Johnstone c. The RCMP analysis of Senator Wallin’s calendars and electronic backups revealed; i, an entry in her electronic Microsoft Outlook Calendar for “ Shelly and Doug” scheduled between 16:00 and 17:00 hours on January 11, 2010, The analysis also revealed that this entry was amended in May 2013 and replaced by “Mig. B. Johnstone” scheduled between 18:00 and 19:00 hours on January 11, 2010; ii, an entry in her handwritten calendar for “Reg - Toronto, Shelley and Doug” scheduled on January 11, 2011. There are no entries in Senator Wallin handwritten calendars for a meeting with B. Johnstone on that date; and i, an entry in printed version of the Microsoft calendar for “Dinner Mig w. B. Jolnstone” scheduled on January 11, 2010. [There is no indication as to when this entry was entered into this Calendar because this is a printed version of the calendar]. 4. Senator Wallin, in a spreadsheet her office gave to Deloitte, explained that on January 11, 2010, she was invited to a dinner given by “B. Johnstone”, the Senior Advisor at the Canadian Intemational Council, also attended by BMO Scholarship winner, “M. Fernandez”, brilliant young Canadian women with a desire to serve in the Foreign Service. ‘That the Canadian international Council is an independent, member-based council established to strengthen Canada's role in international affairs and that they discussed the role of public service and foreign affairs". ¢. Senator Wallin in an interview with Deloitte, said that on January 11, 2010, she attended a dinner hosted by Mr. Johnstone and his wife at their residence, Senator ‘Wallin said that there were probably 14 people at the event.” £ Mr. Robert Johnstone who retired fiom the Canadian Intemational Couneil (CIC) in 2010, was interviewed by Corporal Holly Chappell, During his interview, Mr, Johnstone said in part, the following”; Mr. Johnstone may have had Senator Wallin at his residence but never to discuss business beyond what people working in the same field might at a social gathering. Mr. Johnstone said that he has never given Senator Wallin advice nor has she ever asked him for any. Mr, Johnstone does not recognize the name “M. Fernandez” and thinks that Senator Wallin may ‘8 Learned this from reading a Spreadsheet Rene Montpellier gave (o Deloite on May 13, 2013, {8 Lleamed this from reading the Transcript of Senator Wallin’s Deloitte interview dated Sune 7, 2013. 5 THearned this from reading the summary of Mr, Johnstone's Novemiber 20, 2014 interview, prepared by Cpl. Chappell 41 have attended his residence once but cannot remember the date, Mr. Johnstone further said that the CIC does put on events and invites people but that he does not remember this specific event or who hosted the event, g. The RCMP analysis of Senator Wallin’s calendars and electronic backups revealed no other entries for scheduled events in Toronto on that day. ‘Tuesday January 12, 2010 Dinner with Robert Deluce h. ‘The RCMP analysis of Senator Wallin’s calendars and electronic backups revealed; i, an entry in hor Microsoft Outlook calendar for “Dinner with Bob Deluce — Porter Airlines” scheduled for 12:15 hours on January 12, 2010; and ii, an entry in her handwritten calendar for “Porter lunch Bob DeLuce” on Janaury 12, 2010 i, Robert Deluce, of Porter, in his RCMP interview said that his records show that on January 12, 2012, he did have lunch with Senator Wallin, Mr, Deluce does not recall where this dinner took place and the nature of the dinner", ‘The RCMP analysis of Senator Wallin’s calendars and electronic backups revealed no other entries for scheduled events in Toronto on that day. Wednesday January 13,2010 ‘Walrus — Canada’s role in Afghanistan .. The RCMP analysis of Senator Wallin’s calendars and electronic backups revealed an entry in her Mictosoft Outlook calendar for "Walrus — Canada’s role in Afghanistan” scheduled on Janvary 13, 2010. (The time appearing in the entry is, 00:00 hours]. ‘The analysis also revealed that this entry was only entered in the Outlook calendar, sometime on May 2013 and that it was not present in the calendar in January 2010. b. Senator Wallin, in a Spreadsheet her office gave to Deloitte, explained that on January 13, 2010, she “was invited, as a Senator and Deputy Chair of the Senate National Security and Defence Committee, to take part and to address the editorial board of Walrus Magazine on Canada's role in Afghanistan -a broad range of defence and humanitarian issues were discussed”. c. Ms, Shelly Ambrose, the executive director of the Walrus Foundation, was 5" earned this during the interview of Robert Deluce dated September 23, 2014, * Tleauned this from reading the Spreadsheet Renée Montpellier gave to Deloitte on May 13, 2013, 42 interviewed by Constable Linnea Gallant, During her interview, Ms. Ambrose said in part, the following; i, The Walrus Foundation has an educational mandate to create forums for conversations on matters vital to Canadians, They do this through a magazine, website, a scries of national public events called “The Walrus Talks”, a private series of leadership dinners in the law, finance, health, and energy sectors, Walrus TV, Walrus o-books, a. Ms. Ambrose said she is a very close friend of Senator Wallin whose Television show she once produced. Ms. Ambrose said that for January 13, 2010, there is a notation in her calendar that says “dinner”. That she and her husband host many dinner parties and if Senator Wallin happens to be in town at the time, she would attend as it is a standing invitation, 4. Mr, John Macfarlane, the Editor and Co-Publisher of the Walrus since 2008, was interviewed by Constable Linnea Gallant. During his interview, Mr. Macfarlane said in part, the following™; a. Mr, Macfarlane remembers meeting Senator Wallin for an editorial board meeting but he cannot confirm the date. Senator Wallin would have been coming in to talk to the editorial staff to educate thom. They have a variety of people come in to speak to the editorial staff including scientists and educators. When they identify an area they are interested and don't know as much about as they'd like to, they reach out and ask people fo come in and talk to them. b. Mr. Macfarlane said that his records show that on January 13, 2010, he had a story conference on that date but cannot confirm if Senator Wallin was in attendance, He remembers Senator Wallin attending the offices of the ‘Walrus for a meeting with the editorial board at some point but cannot confirm the date. The topic would have been wide ranging and might have been about her Senate duties and committees, Ottawa, polities, whatever issues were the issues of the day, tar sands, US Canada relations; all topics she would have expertise on, ©. The outcome of these meetings is focus. There is no guarantee they will doa story. Sometimes they get story ideas fiom those meetings, They hope to come out of the meetings more educated. These story conferences are altended by the 4 or 5 senior editors at the Walrus, * 1 Jeamed this from reading the summary of the November 18, 2014, interview of Ms. Ambrose prepared by Cst Gallant, * Tleamed this from reading the Summary of the January 14, 2015 interview of Mr. Macfarlane, prepared by Cst Gallant 43 €. Corporal Holly Chappell spoke to Ms. Alexandra Molotkow, a former member of Walrus’ editorial staff. Ms. Molotkow worked at the Walrus during 2010. Ms, Molotkow said®; a. That on Monday January 11, 2010, she received an email addressed to the Walrus staff, advising that Peter Macleod of MASS LBP (an advisory firm) was coming to Walrus’ offices on Wednesday January 13, 2010 at 14:00 hours to address the editorial staff about Canada’s Sesquicentennial. ‘This is part of the regular series called “Speak to the Walrus Editors/staff”. The e- mail also expressed apologies for tho short notice, b, That on Wednesday January 13, 2010, at 11:14 hours, she received another email from Fiona Wilson (of Walrus), advising the Walrus staff that Mr. Peter Macleod could not attend the session scheduled that day, duc to delays at the airport. ¢. Ms. Molotkow does not recall if someone else attended in lieu of Mr, Macleod that afternoon. Ms. Molotkow also said that she is aware that in the past, Senator Wallin has addressed the editorial staff of Walrus but never during Ms. Molotkow’s employment at Walrus, Guelph Board of governors meeting f. The RCMP analysis of Senator Wallin’s calendars and electronic backups revealed an entry in her electronic Microsoft Outlook calendar for “Guelph board of governors meeting” scheduled for 13:00 hours on January 13, 2010. g Corporal Holly Chappell interviewed Ms. Vietoria Hodgkinson, the Secretary of the University of Guelph. Ms, Hodgkinson said that her records show that there was a board of governors meeting on Jenuary 13, 2010 and that the then Chancellor, Senator Wallin, was in attendance™’. Retum flight to Ottawa h. A flight itinerary attached to the expense claim shows that Senator Wallin flew from ‘Toronto to Ottawa, leaving Toronto at approximately 18:10 hours on January 13, 2010. i, The RCMP analysis of Senator Wallin’s calendars and electronic backups revealed no other entries for scheduled events in Toronto that day. 72. The RCMP analysis of Senator Wailin’s calendars and electronic backups also revealed entries, in relation to events that Senator Wallin, in her explanation to Deloitte, does not % 1 Leamed this from talking o Corporal Chappell, I also reviewed her investigative report and notes on interaction wih Ms, Molotkow dated January 21, 2015 * Tleamed this from reading the Transcript of Ms, Hodgkinson’s interview dated September 16, 2014. 44 represent as Senate related. These entries such as a dentist appointment and a book event are in my belief to be Senator Wallin’s personal affairs. 73. therefore believe that on January 10, 2010, Senator Wallin flew ftom Regina to Toronto in order to attend to her personal affairs *” which included a lunch with the CEO of Porter, and attending a Guelph board of governors meeting (which at the time, she was Chancellor of). While in Toronto, Senator Wallin may have also attended a social gathering at the residence of Robert Johnstone. | also believe that someone fiom Senator Wallin’s office modified her Outlook calendar in May 2013 and amended an existing entry from “shelly and Doug” to “Mig. B. Johnstone”. I believe that Senator Wallin misrepresented the nature of this social gathering at Mr. Johnstone's in the Spreadsheet her office gave to Deloitte, representing this social gathering as an official event, Senator Wallin, in a spreadsheet her office gave to Deloitte, also asserted that on Wednesday January 13, 2010, she was invited to address the editorial board of the Walrus magazine on Canada's role in Afghanistan. Moreover, the entry in relation to this event, was only entered in Senator Wallin’s electronic Calendar in May 2013 and not in 2010. I do not believe that Senator Wallin attend this event, Senator Wallin arrived in Toronto on Sunday January 10, 2010. At that time, the scheduled speaker was Mr. Petet MacLeod. On Wednesday January 13, 2010, due to unforeseen delays, Mr. MacLeod cancelled, If in fact Senator Walllin attended this event, she would have been notified that same morning while she was already in Toronto, Neither the director nor the editor of Walrus have records of Senator Wallin ot anyone else addressing the editorial staff on that day. Moreover, Ms. Molotkow, a former Walrus employee said that she has no recollection of Senator Wallin over addressing the editorial staff in 2010 when she worked at the Walrus, Senator Wallin then flew to Ottawa on January 13, 2010, after having attended to her personal affairs in Toronto, Senator Wallin submitted an expense claim to the senate for reimbursement of expenses incurred during this trip, [believe that by submitting claim 164-10436 to the Senate Finance and Procurement Directorate for reimbursement under the representation that the activities she undertook in Toronto during this portion of her trip were “Senate Business", Senator Wallin committed a fraud and a breach of trust. Moreover, based on my interview with Mr. Deluce, of porter, I also believe that Senator Wallin may have received reimbursement from Porter for some expenses incurred during this tr 74, Senator Wallin was reimbursed a total of $5,197.72 for this claim. Ms, Tracy Hayward of the Forensic Accounting Management Group, calculated that of that amount, $2,745.95 was fraudulently claimed by Senator Wallin’® . Teamed this rom reading the Intella report generated from the analysis of Senator Wallin’ calendars, These are events showing in the calendars that Senator Wellin’s office doesnot represent as Senate Business in her £4planations to Deloite * Ms, Tracy Hayward is a Senior Forensic accountant with the Forensic Accounting Management Group. Ske is assigned to this investigation to assist RCMP investigators with the financial aspect ofthis investigation, Ms. Tracy Hayward calculated this amount based on my belief that the trp to Toronto was not Senate related. This amount ‘encompasses the airfare and ground transportation. 45 Travel expense claim T64-10437 and T64-10438 (2 & 3 of 12) 75. These travel expense claims are for the period between January 16, and January 27, 2010; On January 16, 2010, Senator Wallin flew from Ottawa to Toronto; On January 21, 2010, Senator Wallin flew from Toronto to Ottawa; On January 22, 2010, Senator Wallin flew from Ottawa to Toronto; On January 26, 2010, Senator Wallin flew from Toronto to Ottawa; and On January 27, 2010, Senator Wallin flew from Ottawa to Toronto. eeese 76. Senator Wallin expensed the airfare to and from Toronto, the associated ground transportation along with some meals to the Senate. ‘The purpose written on the claims is “Senate Business”, The expense claims bears Senator Wallin’s signature and are respectively dated February 3, 2010 and January 29, 2010. ‘They ‘were then submitted to the Senate Finanee and Procurement Directorate for reimbursement. Saturday January 16, 2010 Flight to Toronto a. A flight itinerary attached (o the expense claims shows that Senator Wallin flew from Ottawa to Toronto, arriving in Toronto at approximately 13:30 hours on January 16, 2010; b. The RCMP analysis of Senator Wallin’s calendars and electronic backups revealed no entries for events scheduled in Toronto on January 16, 2010. Sunday January 17, and Monday January 18, 2010 ©, Senator Wallin in a Spreadsheet her office gave to Deloitte, explained that on January 17, and 18, 2010, she spent time in Toronto, at no cost to the Senate, while awaiting an event. [The Spreadsheet does not elaborate as to the nature of the event] ‘Tuesday January 19, 2010 Empire Club event d. The RCMP analysis of Senator Wallin’s calendars and electronic backups revealed; i, an entry in her electronic Microsoft Outlook calendar for “empire club event” on January 19, 2010 in her Microsoft Outlook calendar. {The time appearing in the entry is 00:00 hours]. The analysis also revealed that this % [earned this from reading the Spreadsheet that Renée Montpellier gave to Deloitte on 2013-05-13, 46 entry was only entered in the Outlook calendar sometime in May 2013 and was not in the Calendar in January 2010; ii, an entry in the printed version of her Outlook calendar for “EMPIRE CLUB ~ Invited guest” scheduled for January 19, 2010. [There is no indication as to when this entry was entered into this Calendar because this is a printed version of the calendar]; ii, an entry in her electronic Microsoft Outlook calendar for “Luncheon - PORTER 7th annual ceo of the year award” at 12:00 hours on January 19, 2010; and iii, an entry in her handwritten calendar for “Porter Lunch CEO” on January 19, 2010, , Senator Wallin, in a Spreadsheet her office gave to Deloitte, explained that on January 19, 2010, she attended an empire club luncheon as an invited guest, Senator Wallin further explained that “the Empire Club Event, Established in 1903, the Empire Club of Canada (ECC), is recognized as one of Canada's oldest, largest, more important speaker's forum. Through a variety of presentation formats, the Empire Club invites local, national and international leaders and other change- agents to address the topical issues of the day, As Invited Guest this was the perfect networking opportunity to discuss the current business climate. Rob Deluce was the Keynote - he talked about the future of the airline sector in Canada” £ Greg Sheahan (legal counsel for Porter), in an email I received following my interview with Mr. Deluce, wrote that Porter records show that on January 19, 2010, Robert Dehuce was at a Luncheon at the Fairmont Royal York Hotel in Toronto relating to him receiving the Cantadian Public Relations Society's CEO Award of Excellence in Public Relations, in recognition of his work at Porter. A number of Porter directors were accordingly in attendance, including Senator Wallin, at Potter's invitation, ‘Wednesday January 20, 2010 8 Senator Wallin, in a Spreadsheet her office gave to Deloitte, explained that on January 20, 2010, she spend the day in Toronto, at no cost to the Senate, prior to returning to Ottawa, £ Learned this from reading the Spreadsheet that Renée Montpelier gave to Deloitte on May 13, 2013, © TTeamed this from reading an email which I received from Greg Sheahan (council for Porter) on October 21, 2014 TLeamed this from reading the Spreadsheet that RenSe Montpellicr gave to Deloit on May 13, 2013, 47 ‘Thursday January 21,2010 Flight from Toronto hh, A flight itinerary attached to the expense claim shows that Senator Wallin flew from Toronto to Ottawa, leaving Toronto at approximately 08:30 hours on January 21,2010. i, The RCMP analysis of Senator Wallin’s calendars and electronic backups revealed no entries for scheduled events in Toronto on January 21, 2010, iday January 22, 2010 Flight to Toronto A flight itinerary attached to the expense claim shows that Senator Wallin flew fiom Ottawa to Toronto, arriving in Toronto at approximately 16:45 hours on January 22, 2010 Dinner with Lou Clancy Kk, The RCMP analysis of Senator Wallin’s calendars and electronic backups also revealed; i, anentry in her electronic Microsoft Outlook calendar for “Dinner Lou Clancy” scheduled for 18:00 hours on January 22, 2010, ‘The analysis also revealed that this entry was only entered in the Outlook ealendar sometime in May 2013 and that it was not present in the calendar in January 2010. ii, an entry in the printed version of her Outlook calendar for “Dinner for L. Clancy” scheduled for January 22, 2010. [There is no indication as fo when this entry was entered into this Calendar because this is a printed version of the calendar). 1. Senator Wallin, in a Spreadsheet her office gave to Deloitte, explained that on January 22, 2010, she “attended dinner in honour of L. Clancy, now Post media vice-president of editorial as well as editor-in-chief. An excellent opportunity to network with members of the media community including media owners. A full range of political issues were discussed” m, Mr, Lou Clancy, a senior manager of Post media, was interviewed by Constable Linea Gallant. During his interview, Mr. Clancy said in part, the following; ® 1 teamed this from reading the Spreadsheet that Renée Montpellier gave to Deloitte on 2013-05-13, TJearned this from seading the summary of the interview dated November 18, 2014 of Lou Clancy prepared by Constable Gallant 48 i, Mr. Clancy has known Senator Wallin since the mid to late 70°s when he hired her as a reporter, They have been colleagues and friends since then, ii, Mr. Clancy said that on September 22, 2010, there was a surprise dinner party at Pier 4 restaurant in Toronto, in honor of his retirement. The dinner party was attended by 200 to 300 people, including Senater Wallin who was one of the many speakers. iii, Mr. Claney said that the event’s key organizers were Greg Weston, a columnist with Sun Media, and Bill Fox, a very good friend of his. iv, Mr. Claney described the event as a “roast and toast”. Saturday January 23 and Sunday January 24, 2010 n, Senator Wallin, in a Spreadsheet her office gave to Deloitte, explained that on January 23 and 24, 2010, she spent two days in Toronto at no cost to the Senate, awaiting two events the following Monday. [The Spreadsheet does not elaborate as to the nature of the two events)", Dinner with Ron Moore ©, The RCMP analysis of Senator Wallin’s calendars and electronic backups revealed an entry in her electronic Microsoft Outlook calendar for “Dinner -ron MOORE” scheduled between 18:00 and 19:00 hours on January 24, 2010, P. Mr. Ron Moore, a Toronto based marketing executive and is the CEO of Sonar Mediathink Corporation, was interviewed by Constable Linea Gallant. During his interview, Mr, Moore said in part, the following, i, Mr, Moore met Senator Wallin over 20 years ago through mutual friends in the broadcasting business and they are good friends. Mr. Moore has engaged Senator Wallin approximately 3 times over the last decade, to speak to corporate groups. Senator Wallin spoke about a number of issues. To one group she spoke about the role in Afghanistan because she was closely involved in the Canadian effort there. She also spoke on Canada US bilateral relations and on the role of Canada in supporting the US after the attacks on onl ii, Mr. Moore further said that each time she spoke at these events, Senator Wallin was paid a speaker's fee and her transportation and expenses wore paid for. © 1 earned this from reading the Spreadsheet that Renée Montpellier gave to Deloitte on 2013-05-13, © 1 teamed this from reading the Summary of Mr. Moore's November 18, 2014 interview, prepared by Constable Gallant. 49 iii, Mr. Moore has no records of a dinner with Senator Wallin January 24, 2010 however said that it may have occurred because she often had to connect flights through Toronto, Often when they got together, it was just about ‘hearing from Senator Wallin about Afghanistan, Mr. Moore’s son served in Afghanistan and he and Senator Wallin had areas of mutual interest in that. Mr, Moore would ask Senator Wallin what was going on there because he was interested and Senator Wallin was always willing to tell him what she was heating. Monday January 25, 2010 Mowet Centre event 4g. The RCMP analysis of Senator Wallin’s calendars and electronic backups revealed an entry in her electronic Microsoft Outlook calendar for “Mowatt centre & annual board of trade” scheduled between 18:00 and 19:00 hours on January 24, 2010. The analysis also revealed that this entry was only entered in the Microsoft Outlook Calendar in May 2013 and that it was not present in the Calendar in January 2010, x, Senator Wallin, in a Spreadsheet her office gave to Deloitte, explained that on January 25, 2010, [I noted that there is a discrepancy with the date appearing in the Microsoft Outlook Calendar which shows January 24, 2010] she attended as an invited guest, to the “opening af the Mowat Centre for Policy Innovation, University of Toronto: the centre's research, findings and recommendations are timely, relevant and informed by a realistic understanding of government, service delivery and Canadian society” That she was invited “because of her wide ranging interest in policy matters”; 8, Mr. Matthew Mendelsohn, the founder and director of the Mowat Centre, was interviewed by Corporal Holly Chappell. During his interview, Mr. Mendelsohn said in part, the following; i, Mr, Mendelsohn remembers the launch of the Mowat center and was nyolved in making the invitation list. The event took place on January 25, 2010 between 17:00 and 20:00 hours. Mr, Mendelsohn's records indicate that Senator Wallin was not invited to this event nor that she attended, ii, Mr. Mendelsohn said that Senator Wallin may have just “walked in” with someone else, but that he does not recall seeing her there. Annual Board of Trade Dinner © | Ieamed this from reading the Spreadsheet that Renée Montpellier gave to Deloitte on May 13, 2013. ‘1 Jeamed this from reading the transcript of the October 30, 2014 RCMP interview of Matthew Mendelsohn. 50 (. Senator Wallin, in a Spreadsheet her office gave to Deloitte, explained that on January 25, 2010, “she also later attended the Annual Board of Trade Dinner as Invited Guest. Where the premier and former Ambassador Frank McKenna was celebrated for his contribution to public service, He was the Deputy Chair of the TD Bank Financial Group." u. The RCMP analysis of Senator Wallin’s calendars and electronic backups revealed; i. an entry in her electronic Microsoft Outlook calendar for “12nd Annual Board of Trade Dinner - featuring Frank McKenna (Reception and Dinner)” at 17:30 hours on January 25, 2010. The analysis also revealed that, this entry was removed from Senator Wallin’s Outlook calendar sometime on May 2013 and was re-entered in the calendar sometime in June 2013: and ii, an entry in her handwritten calendar for “CEO update Dinner” on January 25, 2010. v. Mr. Deluce, in his RCMP interview said that he does not recall this specific event, however that if Senator Wallin had indeed attended this Board Of Trade dinner, it would have been on behalf of Porter”, w. Greg Sheahan (legal counsel for Porter), in an email I received following the interview of Mr. Deluce, wrote that Porter records show that on January 25, 2010, Senator Wallin was in attendance at the Board Of Trade dinner at Porter’s invitation”, wesday January.26, 2010 Flight from Toronto x. A flight itinerary attached to the expense claim shows that Senator Wallin flew from Toronto to Ottawa, leaving Toronto at approximately 08:30 hours on January 21, 2010. 77. The RCMP analysis of Senator Wallin’s calendars and electronic backups also revealed entries, in relation to events which Senator Wallin, in her explanation to Deloitte, does not represent as Senate related, These entries such as Birthday reminders, medical appointments, and dinners are in my belief to be Senator Wallin’s personal affairs”, @ learned this from reading the Spreadsheet that Renée Montpellier gave to Deloitte on May 13, 2013, learned this during the interview of Robert Deluce dated September 23, 2014. Tleamned ths from reading an email which I received from Greg Sheahan (council for Porter) on October 21, 2014, Teamed this from reading the Intlla report generated from the analysis of Senator Wallin’s calendars. These are fovents showing in the calendars that Senator Wallin’s office does not represent as Senate Business in her explanations to Detoitte. Sl 78. therefore believe that on January 16, 2010, Senator Wallin flew from Ottawa to Toronto in order to attend to her personal affairs which included attending as a member of the board of directors of Porter, to a Luncheon , honoring the CEO of Porter, Mr. Robert Deluce, at Porter's request. That Senator Wallin misrepresented the nature of this event in a Spreadsheet her office gave to Deloitte. That someone from Senator Wallin’s office modified her Microsoft Outlook Calendar in May 2013 to reflect her attendance at an Empire Club event in January 2010. That Senator Wallin flew back to Ottawa on January 21, 2010. That Senator Wallin then returned fo Toronto on January 22, 2010, in order to attend to her personal affairs, which included a surprised dinner party honoring the retirement of her friend Lou Clancy. That while in Toronto, Senator Wallin also attended a Board of Trade’s dinner as a Porter director, at the invitation of Porter. That Senator Wallin misrepresented the nature of this Board of ‘Trade dinner event in the Spreadsheet her office gave to Deloitte. That Senator Wallin also may have attended to a dinner with her ftiend Ron Moore for whom she has in the past, delivered some speeches on topics such as Canadian efforts in Afghanistan and Canada US bilateral relations, Senator Wallin, in a Spreadsheet her office gave to Deloitte, does not represent this dinner as Senate related, Senator Wallin flew back to Ottawa on January 26, 2010 after having attended to her personal affairs in Toronto. ‘That Senator Wallin submitted expense claims to the Senate for reimbursement of expenses incurred during this trip to Toronto. I believe that by submitting claims, T'64-10437 and T'64-10438 to the Senate Finance and Procurement Directorate for reimbursement under the representation that the activities she undertook in ‘Toronto during this portion of her trip were “Senate Business”, Senator Wallin committed a fraud and a breach of trust, Moreover, based on my interview with Mr. Deluco, I also believe that Senator Wallin may have received reimbursement from Porter, for some expenses incurred during these trips. 79, Senator Wallin was reimbursed a total of $3,344.45 for these two claims, Ms. Tracy Hayward of the Forensic Accounting Management Group, calculated that of that amount, $2,402.55 was fraudulently claimed by Senator Wallin” . Travel expense claim T64-12101 (4 of 12) [This travel expense claim is pertinent to both Porter and Gluskin, The subsequent paragraphs are therefore represented twice in this application. Once in this section as it pertains to Porter, and onee in relation to Gluskin,] 80. This travel expense claim is for the period between May 3 and May 12, 2010, a, On May 3, 2010, Senator Wallin flew from New York to Ottawa; b. On May 5, 2010, Senator Wallin flew from Ottawa to Toronto; and c. On May 10, 2010, Senator Wallin flew from Toronto to Ottawa; ® Ms, Tracy Hayward calculated this amount based on my belief that the (1) January 16 to January 21 2010 and the (2) January 22 (0 January 26 trip to Toronto were not Senate related, This amount encompasses the airfare and ‘ground transportation, 52. 81, Senator Wallin expensed the May 10, 2010 airfare from Toronto to Ottawa, the associated ground transportation along with some meals to the Senate. 82. The purpose written on the claim is “Senate Business”. The expense claim bears Senator Wallin’s signature and dated May 13, 2010. It was submitted to the Senate Finanee and Procurement Directorate for reimbursement, Wednesday May 5, 2010 ight to Toronto a. A handwritten note in the expense claim, read that Senator Wallin left Ottawa on May 5, to go on a “personal trip”. [I did not see any clarification written on the expense claim as to the nature of this personal trip). b. The RCMP analysis of Senator Wallin’s calendars and electronic backups revealed an entry in her Microsoft Outlook calendar for a flight from Ottawa to Toronto on Porter 270, arriving in Toronto at 18:15 on May 5, 2010. The entry also read that this flight was claimed to Gluskin; Gluskin board dinner ¢, The RCMP analysis of Senator Wallin’s calendars and electronic backups revealed an entty in her electronic Microsoft Outlook calendar for a Gluskin board dinner on May 5, 2010 at 18:30 hours. The analysis also revealed that this entry was removed from Senator Wallin’s Outlook calendar sometime in May 2013 and re-entered in the calendar sometime in June 2013; and i, an entry in Senator Wallin’s handwritten calendar for a “G/S dinner” on May 5, 2010 [I believe that G/S stands for Gluskin Sheff} d. On September 22, 2014, I interviewed David Morris the current Chief Financial Officer for Gluskin Sheff & Associates (Gluskin). Mr. Mortis said that his records show that there was a Gluskin board of directors’ dinner in Toronto on May Sth 2010 and that Senator Wallin attended the dinner. The RCMP analysis of Senator Wallin’s calendars and electronic backups revealed no other entries for scheduled events in Toronto on that day. Personal Trip £ A handwritten note in the expense claim, read that Senator Wallin left Ottawa on May 5, to go on a “personal trip”. [The author of the note is unknown, It appears to have been written by someone from the Senate Finance and Procurement directorate. I did not sce any clarification written on the expense claim as to the nature of this personal trip). 33 ‘Thursday May 6, 2010 Return to Toronto from personal trip g. A handwritten note in the expense claim, read that Senator Wallin returned to ‘oronto on May 6, from the “personal rip”. Gluskin board meetings h. The RCMP analysis of Senator Wallin’s calendars and electronic backups revealed three entries in her electronic Microsoft Outlook calendar for Gluskin board meetings, scheduled between 08:00 and 11:00 hours on May 6, 2010, ‘The analysis also revealed that these entries were removed from Senator Wallin’s Outlook calendar sometime in May 2013 and re-entered in the calendar sometime in June 2013. i. David Mortis of Gluskin, in his RCMP interview said that his records show that there were Gluskin board and committee meetings on May 6, 2010 and that Senator ‘Wallin had attended these meetings”. May 7,201 j. Senator Wallin in the Spreadsheet her office gave to Deloitte, explained that on May 7, 2010, she flew from Ottawa to Toronto for private business and spent the ‘weekend in Toronto. That the flight to ‘Toronto was not expense to the Senate”®. [I did not see any mention of this May 7" flight in the expense claim.] k, ‘The RCMP analysis of Senator Wallin’s numerous calendars and electronic backups revealed an entry in her Microsoft printed calendars for “Ottawa/T.0” on that date. [there is no indication as to when this entry was made into this calendar as this is a Printed version of the Calendar]. There are no entries in Senator Wallin’s electronic or handwritten calendars for a flight taken by Senator Wallin on May 7, 2010. Moreover, I believe that on May 7, 2010, Senator Wallin was already in ‘Toronto as she had attended at Icast two Gluskin Board meetings in Toronto the day before. 83, The RCMP analysis of Senator Wallin’s calendars and electronic backups revealed an entry in her electronic Microsoft Outlook calendar for “Meeting Bob from Porter”, scheduled for 08:00 hours on May 8, 2010. Tleamed this daring the interview of David Morris on September 22, 2014, * Tleamed this from reading the Spreadsheet, which Renée Montpellier gave to Deloitte on May 13, 2013. 54 84, Robert Deluce of Porter, in his RCMP interview, said that on May 8, 2010, his records show that he met with Senator Wallin at 08:00 hours”. 85. Grog Sheahan, of Porter, in an email I received following my interview with Mr. Deluce, \wrote that on May 8, 2010, Mr. Deluce met with Senator Wallin at Porter's offices to discuss various Porter board related matters”, 86. The RCMP analysis of Senator Wallin’s calendars and electronic backups revealed no other scheduled events in Toronto on that day. Sunday May 9, 2011 87. The RCMP analysis of Senator Wallin’s calendars and electronic backups revealed no scheduled events in Toronto for May 9, 2010, Monday May 10, 2010 Flight to Ottawa 88. A flight itinerary attached to the expense claim shows Senator Wallin flew from Toronto to Ottawa, leaving Toronto at approximately 08:45 hours on May 10, 2010. 89, Senator Wallin, in a Spreadsheet her office gave to Deloitte, explained that on May 10, 2010, she returned to Ottawa after private business and that $586.53 was erroneously charged to the Senate”. 90, The RCMP analysis of Senator Wallin’s calendars and electronic backups also revealed entries, in relation to events which Senator Wallin, in her explanation to Deloitte, does not represent as Senate related. These entries, such as birthday reminders, a medical appointment and private meetings are in my belief to be Senator Wallin’s personal affairs”. 91. I therefore believe that on May 5, 2010, Senator Wallin flew from Ottawa to Toronto and claimed the flight to Gluskin, That same evening, Senator Wallin attended a Gluskin Board of Directors dinner in Toronto, That while in Toronto, Senator Wallin attended to her personal affairs which included attending to Gluskin Board mectings and to a meeting with the CEO of Porter, Mr. Robert Deluee (whose company she was a director of at the time). Senator Wallin then flew from Toronto to Ottawa on March 10, 2010. I also believe that Senator Wallin misrepresented to Deloitte that on May 7, 2010 , she flew from Ottawa to Toronto at her own expense when the documentation suggest that she was already in 7 1 teamed this during the interview of Robert Deluce on September 23, 2010. teamed this from reading an email which I received from Greg Sheahan (couneil for Porter) on October 21, 2014, ® teamed this from reading the Spreadsheet that Renée Montpellier gave to Deloitte on May 1, 2013. ® [learned this from reading the Intella report generated from the analysis of Senator Wellin’s calendrs. These are events and entries showing in the calendars that Senator Wallin’ office does not represent as Senate Business in her explanations to Deloitte, 5S Toronto on May 6, 2010. Senator Wallin submitted an expense claim to the senate for reimbursement of expenses incurred during this trip. I believe that by submitting claim ‘T64-12101 to the Senate Finance and Procurement Directorate for reimbursement under ‘the representation that the activities she undertook in Toronto during this portion of her trip were “Senate Business”, Senator Wallin committed a fraud and a breach of trust. Moreover, based on my interview with Mr. Deluce, I also believe that Senator Wallin may have received reimbursement from Porter, for some expenses incurred during this trip, 92. Senator Wallin was reimbursed a total of $1,130.28 for this claim. Ms, Tracy Hayward of the Forensic Accounting Management Group, calculated that of that amount, $623.28 was fraudulently claimed by Senator Wallin™. Travel expense claim T64-13683 (5 of 12) 93. This travel expense claim is for the period between December 2, and December 13, 2010, a. On December 2, 2010, Senator Wallin flew fiom Ottawa to Toronto; and b. On December 13, 2010, Senator Wallin flew from Toronto to Ottawa. 94, Senator Wallin expensed the airfare to and from Toronto, the associated ground transportation and some meals to the Senate. 95. The purpose written on this expense claim is “Senate Business”. The expense claim bears Senator Wallin’s signature and is dated January 4, 2011, The claim was submitted to the Senate Finance and Procurement Directorate for reimbursement. ‘Thursday December 2, 2010 Flight to Toronto a. A flight itinerary attached to the expense claim shows that Senator Wallin flew from Ottawa to Toronto, arriving in Toronto at approximately 20:00 hours on December 2, 2010, b. The RCMP analysis of Senator Wallin’s calendars and electronic backups, revealed no entries for events scheduled in Toronto on December 2, 2010. ©. Senator Wallin, in a Spreadsheet her office gave to Deloitte, explained that on December 2, 2010, she flew from Ottawa to Toronto for private business and that the flight should have been covered by Senator Wallin. The cost of the flight was erroneously charged to the Senate and that a portion of the claim has been ‘ Ms. Tracy Hayward calculated this amount based on my belie that the May 5 to May 7, 2010 trip (0 Toronto, Wes not Senate related. This amount encompasses the airfare and ground transportation. 56 reimbursed for December 2, 2010, in the amount of $787.98", Friday December 3 and Saturday December 4, 2010 Porter board meeting d. The RCMP analysis of Senator Wallin’s calendars and electronic backups revealed three entries in her electronic Microsoft Outlook calendar for Porter board meetings scheduled between 08:00 and 13:00 hours on December 3, 2010 ¢. Robert Deluce, of Porter, in his RCMP interview said that his records show that there was a Porter board meeting on December 3, 2010 and that Senator Wallin was in attendance, £. Senator Wallin, in a Spreadsheet her office gave to Deloitte, explained that she spent December 3" and 4" in Toronto prior to flying to Edmonton with the Committee on National Security and Defence®. Sunday December 5 and Monday December 6, 2010 Committee travel to Kdmonton g. Senator Wallin, in a Spreadsheet her office gave to Deloitte, explained that on December 5, 2010, she flew fiom Toronto to Edmonton where on December 6, she visited CFB Edmonton and land Forces Western Area headquarters, including a visit to Joint Personnel Support Unit. Tuesday December 7 to Friday December 10 , 2010 Governmental travel to Mexico hh, Senator Wallin, in a Spreadsheet her office gave to Deloitte, explained that between December 7 and December 10, 2010, she was in Cancun Mexico, attending the United Nations’ Climate Change Conference and that the flights to and from Cancun was paid for by the Federal Government, On December 10, 2010, Senator Wallin flew from Cancun to Toronto, Friday December 10, 2010 i, Senator Wallin, in a Spreadsheet her office gave to Deloitte, explained that on December 10, 2010, she flew from Cancun to Toronto at no cost to the Senate*®. *'TJeamed this from reading the calendar Spreadsheet Renée Montpellier gave to Deloitte on May 1, 2013. ® 1 teamed this from reading the calendar Spreadsheet Renée Montpellier gave to Deloitte on May I, 2013. ® | Leamed this from reading the calendar Spreadsheet Renée Montpellier gave to Deloitte on May 1, 2013. 57 teamed this from reading the calendar Spreadsheet Renée Montpellier gave to Deloitte on May 1, 2013. 1 Leamed this from reading a Spreadsheet that Renée Montpellier gave to Deloitte on May 1, 2013, 37 j, Renée Montpellier, in an e-mail she sent to Deloitte, wrote that since there is a direct flight from Cancun to Toronto, that “if made sense for the Senator to fly to Toronto, stay at no cost to the Senate in her personal accommodation versus returning to Ottawa and checking into her hotel for 2 days plus per diems at a direct cost to the Senate”. Saturday December 11 and Sunday December 12,2010 k, Senator Wallin, in a Spreadsheet her office gave to Deloitte, explained that she spent December 11 and December 12, 2010 in Toronto at no cost to the Senate”. Monday December 13, 2010 Flight to Ottawa 1. A flight itinerary attached fo the expense claim shows that Senator Wallin flew from Toronto to Ottawa, leaving Toronto at approximately 10:56 hours on December 13, 2010, m, Senator Wallin, in a Spreadsheet her office gave to Deloitte, explained that on December 13, 2010, she flew from Toronto to Ottawa to attend the Senate®, 96. The RCMP analysis of Senator Wallin’s calendars and electronic backups also revealed entries, in relation to events scheduled while Senator Wallin was in Toronto, that Senator ‘Wallin, in her explanation to Deloitte, does not represent as Senate related. These entries, such asa party reminder, hair appointment, dry cleaning, and personal meetings are in my belief to be Senator Wallin’s personal affairs. 97. I therefore believe that on December 2, 2010, Senator Wallin flew from Ottawa to Toronto in order to attend to her personal affairs, which included a Porter board of directors’ ‘meeting on December 3, 2010. I believe that between December 5, and December 12, 2010 Senator traveled to Edmonton and Cancun, respectively on Senate Committee and Federal governmental affairs. I believe that Senator Wallin returned to Toronto on December 12, 2010 and flew to Ottawa the following day at the Senate’s expense. I believe that during that time period, Senator Wallin traveled to and from Toronto to attend to her personal affairs which also included a Porter board of directors’ meeting, Senator Wallin submitted an expense claim fo the senate for reimbursement of expenses ineurred during this trip. I believe that by submitting claim T64-13683, to the Senate Finance and Procurement Directorate for reimbursement under the representation that the activities she * 1 learned this from reading an e-mail thet Renée Montpellier sent to Deloitte on June 25, 2013. ®° [earned this from reading a Spreadsheet that Renée Montpellier gave to Deloitte on May 1, 2013. ' [teamed this from reading a Spreadsheet that Renée Montpellier gave to Deloitte on May 1, 2013. ® Teamed this from reading the Intella report generated from the analysis of Senator Wallin’s calendars. These are events showing in the calendars that Senator Wallin’s office does nol represent as Senate Business in her explanations to Deloite 58 undertook in Toronto during this portion of her trip were “Senate Business”, Senator Wallin committed a fraud and a breach of trust. Moreover, based on my interview with Mr, Deluce, | also believe that Senator Wallin may have received reimbursement from Porter, for some expenses incurred during this trip. 98. Senator Wallin was reimbursed a total of $1,652.71 for this claim, Ms. Tracy Hayward of the Forensic Accounting Management Group, calculated that of that amount, $1,482.31 ‘was fraudulently elaimed by Senator Wallin”, Travel expense claims T64-15675 & T64-19234 (6 & 7 of 12) 99, These two travel expense claims are for the period between September 5, 2011 and September 14, 2011 On September 5, 2011, Senator Wallin flew from ‘Toronto to Ottawa; On September 5, 2011, Senator Wallin flew from Ottawa back to Toronto; On September 7, 2011, Senator Wallin flew from Toronto to Ottawa; On September 8, 2011, Senator Wallin flew from Ottawa to New York; On September 14, 2011, Senator Wallin flew from New York to Ottawa. eae op 100, Senator Wallin expensed the flighis to and from Toronto, the flights to and from New York, the associated ground transportations, commercial accommodation and some meals to the Senate. 101. The purpose written on claim T64-15675 is “Senate Business - DFAIT dinner. The purpose written on claim T64-19234 is “Senate Business — Mtg with Cdn Amb to U.N". ‘These expense claims bears Senator Wallin's signature and ate respectively dated September 12 and September 29, 2011. The claims were submitted to the Senate Finance and Procurement Directorate for reimbursement, Monday September 5, 2011 Flight to Toronto a. A flight itinerary attached to the expense elaim shows that Senator Wallin flew from Ottawa to Toronto, arriving in Toronto at approximately at 23:30 hours, on September 5, 2011. b, Senator Wallin, in a Spreadsheet her office gave to Deloitte, explained that on September 5, 2011, she flew from Ottawa to Toronto for personal business and that $1,055.79 was erroneously charged to the Senate”! ° Ms. Tracy Hayward calculated this amount based on my belief that the December 2, and December 12, tips to Toronto were not Senate related. This amount encompasses the airfare and ground transportation. % Tleamned this from reading a Spreadsheet that Renée Montpellier gave to Deloitte on February 5, 2013, 59 ‘Tuesday September 6, 2011 Porter Board meeting c. The RCMP analysis of Senator Wallin’s calendars and electronic backups revealed two entries in her electronic Microsoft Outlook calendar for Porter board meetings scheduled between 10:00 and 13:00 hours on September 6, 2011. d. Robert Deluce, of Porter, in his RCMP interview said that his records show that there was a Porter board meeting on September 6, 2011 and that Senator Wallin was in attendance, e. The RCMP analysis of Senator Wallin’s calendars and electronic backups revealed no other entries for scheduled events in Toronto on that day. Wednesday September 7, 2011 Flight from Toronto £. A flight itinerary attached to the expense claim shows that Senator Wallin flew from Toronto to Ottawa, leaving Toronto at approximately at 08:15 hours, on September 7, 2011 8. Senator Wallin, in a Spreadsheet her office gave to Deloitte, explained that on September 7, 2011, she flew from Toronto to Ottawa after personal business and that $738.88 was erroneously charged to the Senate”. h. The RCMP analysis of Senator Wallin’s calendars and electronic backups revealed no other entries for scheduled events in Toronto on that day, 102. I therefore believe that on September 5, 2011, Senator Wallin flew from Ottawa to ‘Toronto in order to attend a Porter board of directors meeting on September 6, 2011 Senator Wallin then flew back to Ottawa on September 7, 2011. Senator Wallin su ‘expense claims to the senate for reimbursement of expenses incurred during this trip. I believe that by submitting claims T64-15675 & T64-19234 to the Senate Finance and Procurement Directorate for reimbursement under the representation that the activ undertook in Toronto during this portion of her trip were “Senate Business”, Senator ‘Wallin committed a fraud and a breach of trust. Moreover, based on my interview with Mr. Deluce, I also believe that Senator Wallin may have received reimbursement from Porter, for some expenses incurred during this trip, ted she 103. Senator Wallin was reimbursed a total of $4,842.49 for these two claims. Ms, Tracy Hayward ofthe Forensic Accounting Management Group, calculated that ofthat amount, $2,503.45 was fraudulently claimed by Senator Wallin”. 3 Heamed this from reading a Spreadsheet that Renée Montpellier gave to Deloitte on February 5, 2013. ® Ms, Tracy Hayward calculated this amount based on my belief that the September 5 to September 7, 2011 trip to 60 Travel expense claims T64-20857 (8 of 12) 2 : | 104. This travel expense claim is for the period between December 5 and December 8, 2011. a. On December 4, 2011, Senator Wallin flew from New York to Toronto; b, On December 5, 2011, Senator Wallin flew from Toronto to Ottawa; and cc. On December 8, 2011, Senator Wallin flew from Ottawa to New York. 105. Senator Wallin expensed the December 5 and 8, 2011 airfares to and from Toronto, the associated ground transportation, some associated meals along with some associated commercial accommodation to the Senate. 106. The purpose written on this claim is “Senate Business”. The expense claim is sign by Senator Wallin and is dated December 13, 2011. The claim was submitted to the Senate Finance and Procurement Directorate for reimbursement. Sunday December 4, 2011 Flight fo Toronto a. The RCMP analysis of Senator Wallin’s calendars and electronic backups revealed an entry in her electronic Microsoft Outlook calendar for a flight fiom New York to Toronto, arriving in Toronto at 15:02 hours on December 4, 2011. Senator Wallin did not expense this flight to the Senate. b. Senator Wallin, in a Spreadsheet her office gave to Deloitte, explained that on December 4, 2011, she spent the day in Toronto™. c. ‘The RCMP analysis of Senator Wallin’s calendars and electronic backups revealed no scheduled events in Toronto for that day. Monday December 5, 2011 Porter board meetings d. The RCMP analysis of Senator Wallin’s calendars and electronic backups revealed three entries in her electronic Microsoft Outlook calendar for Porter board meetings between 08:00 and 13:00 hours on December 5, 2011 e. Robert Deluce, of Porter, in his RCMP interview said that his records show that on December 5, 2011, the board of directors met and that Senator Wallin was in ‘Toronto was not Senate related. This amount encompasses the airfare and ground transportation. * T learned this from reading the Spreadsheet that Renée Montpellier gave to Deloitte on February 5, 2013, 61 attendance, f, The RCMP analysis of Senator Wallin’s calendars and electronic backups revealed no other scheduled events in Toronto that day. Flight from Toronto g A flight itinerary attached fo the expense claim shows that Senator Wallin flew from Toronto to Ottawa, leaving Toronto at approximately 14:45 hours on December 5, 2011 107. I therefore believe that on December 4, 2011, Senator Wallin flew from New York to Toronto in order to attend Porter board of directors’ meetings on December 5, 2011. Senator Wallin did not expense the flight from Now York to the Senate, Senator Wallin then flew from Toronto to Ottawa after having attended these board meetings. Senator Wallin submitted an expense claim to the senate for reimbursement of expenses incurred during this trip. I believe that by submitting claim ‘T64-20857 to the Senate Finanee and Procurement Directorate for reimbursement under the representation that the activities she undertook in Toronto during this portion of her trip were “Senate Business”, Senator Wallin committed a fraud and a breach of trust. Moreover, based on my interview with Mr. Deluce, I also believe that Senator Wallin may have recived reimbursement from Porter, for some expenses incurred during this trip. 108, Senator Wallin was reimbursed a total of $2,250.19 for this claim, Ms. Tracy Hayward of the Forensic Accounting Management Group, calculated that of that amount, $663.85 was fraudulently claimed by Senator Wallin”®. Travel expense claims T64-20867 & T64-20865 QO & 10 of 12) 109. These travel expense claims are for the period between February 27, 2012 and March 8, 2012. On February 27, 2012, Senator Wallin flew from Toronto to Ottawa; ‘On March 2, 2012, Senator Wallin flew from Ottawa to Toronto; On March 6, 2012, Senator Wallin flew from Toronto to Ottawa; and ‘On March 8, 2012, Senator Wallin flew from Ottawa to Toronto. ae ge 110, Senator Wallin expense the airfares to and from Toronto along with the associated ground transportation, 111. The purpose written on both expense claims is “Senate Business”. These expense claims ears Senator Wallin’s signature and are respectively dated March 6, 2012 and March 20, 2012. The claims were submitted to the Senate Finance and Procurement Directorate for % Ms. Tracy Hayward calculated this amount based on my belief that the December 4 to December 5, 2011 trip to Toronto was not Senate related. This amount encompasses the airfare and ground transportation, 62 reimbursement, riday, March 2, 2012 Flight to Toronto a. A flight itinerary attached to the expense claims shows that Senator Wallin flew fiom Ottawa to Toronto, artiving in Toronto at approximately at 11:00 hours, on Mareh 2, 2012. b. Senator Wallin, in a Spreadsheet her office gave to Deloitte, explained that on March 2, 2012, she flew from Ottawa to Toronto for personal business and that $741.08 was erroneously charge to the Senate”, Saturday March 3, to Monday Mareh 5, 2012 Porter board mectings ©, Senator Wallin, in a Spreadsheet her office gave to Deloitte, explained that she stayed three days in Toronto (March 3 to March 5) on personal business at no cost to the Senate”, d. The RCMP analysis of Senator Wallin’s calendars and electronic backups revealed two entties in her electronic Microsoft Outlook calendar for Porter board meetings between 12:00 and 13:00 hours on March 5, 2012. ¢, Robert Deluce, of Porter, in his RCMP interview said that his records show that there was a board compensation committee meeting on March 5, 2012 and that Senator Wallin was in attendance, ‘uesday March 6, 2012 £ The RCMP analysis of Senator Wallin’s calendars and electronic backups revealed an entry in her Microsoft Outlook calendar for a Porter board meeting scheduled for 08:00 hours on March 6, 2012. g Robert Deluce, of Porter, in his RCMP interview said that his records show that there was a board meeting on March, 2012 and that Senator Wallin was in attendance. Flight from Toronto h. A flight itinerary attached to the expense claim shows that Senator Wallin flew from Toronto to Ottawa, leaving in Toronto at approximately at 12:00 hours, on. % 1 Jeamed this from reading the Spreadsheet that Renée Montpellier gave to Deloitte on February 5, 2013, 2 1 Teamed this from reading the Spreadsheet that Renée Montpellier gave to Deloitte on February 5, 2013. 63 March 6, 2012. i, Senator Wallin, in a Spreadsheet her office gave to Deloitte, explained that on March 6, 2012, she flew ftom Toronto to Ortawa, retuming from personal business and that $806.98 was erroneously charged to the Senate’®, 112. The RCMP analysis of Senator Wallin’s calendars and electronic backups also revealed ‘entries, in relation to events scheduled while Senator Wallin was in Toronto which Senator ‘Wallin, in her explanation to Deloitte, does not represent as Senate related, ‘These events such as various medical appointments, personal appointments and a birth day reminder are in my belief to be Scnator Wallin’s personal affairs, [ believed that these events are personal in nature, 113. I therefore believe that on March 2, 2012, Senator Wallin flew from Ottawa to Toronto in order to attend to her personal affairs which also included Porter board meetings on March 5, 2012, Scnator Wallin then flew back to Ottawa on March 6, 2012, Senator Wallin submitted these expense claims to the senate for reimbursement of expenses incurred during her trip. I believe that by submitting claims T64-20867 0865 to the Senate Finance and Procurement Directorate for reimbursement under the representation that the activities she undertook in Toronto during this portion of her trip were “Senate Business”, Senator Wallin committed a fraud and a breach of trust. Moreover, based on my interview with Mr. Deluce, I also believe that Senator Wallin may have received reimbursement from Porter for some expenses incurred during this trip. 114, Senator Wallin was reimbursed a total of $4,596.34 for this claim, Ms. Tracy Hayward of the Forensic Accounting Management Group, ealeulated that ofthat amount, $1,468.16 was fraudulently claimed by Senator Wallin”, Travel expense claims T64-22184 & T64-22182 (11 & 12 of 12) 115. These travel expense claims are for the period between June 1, 2012 and June 13, 2012, ‘Senator Wallin flew from Toronto to Saskatoon on June 1, 2012; Senator Wallin flew from Saskatoon to Toronto on June 3, 2012; Scnator Wallin flew from Toronto o Washington on June 5, 2012; Senator Wallin flew from Washington to New York on June 8, 2012; Senator Wallin flew from New York to Toronto on June 10, 2012; Senator Wallin flew from Toronto to Ottawa on June 11, 2012; and Senator Wallin flew from Ottawa to Toronto on June 13, 3012. Breeege 116. Senator Wallin expensed the airfares, the associated ground transportation, some commercial accommodation, and meals to the Senate, Senator Wallin did not expense the & LJeamed this from reading the Spreadsheet that Renée Montpellier gave to Deloitte on February 5, 2013, Ms. Tracy Hayward calculated this amount based on my belief that the Match 2 to March 6, 2012 trip to ‘Toronto was not Senate related. This amount encompasses the airfare and ground transportation, 64 airfares and related expenses to and from the United States of America, 117. ‘The purpose written on both expense claims is “Senate Business”. These expense claims are signed by Scnator Wallin. T64-22184 is undated and T64-22182 is dated June 21, 2012. The claims were submitted to the Senate Finance and Procurement Directorate for reimbursement. Sunday June 3, 2012 ight to Toronto a. A flight itinerary attached to the expense claim shows that Senator Wallin flew from Saskatoon to Toronto, arriving in Toronto at approximately 18:25 hours on June 3, 2012. b, The RCMP analysis of Senator Wallin’s numerous calendars and electronic backups revealed no scheduled events in Toronto on June 3, 2012. Monday June 4, 2012 Porter board dinner c. The RCMP analysis of Senator Wallin’s numerous calendars and electronic backups revealed an entry in her electronic Microsoft Outlook calendar for a Porter board meeting dinner scheduled for 18:00 hours on June 4, 2012, 4d, Senator Wallin in a Spreadsheet her office gave to Deloitte, explained that on June 4, 2012, she spent the day in Toronto, waiting to fly to Washington with the Senate Committee on National Security and Defence, at no cost to the Senate". ¢. Robert Deluce, of Porter, in his RCMP interview, said that there was a board dinner on June 4, 2012 and that there are no records of who attended. Mr. Deluce said that he believes that Senator Wallin had attended the board dinner. ‘Tuesday June 5, 2012 to Sunday June 10,2012 Porter board meeting £ The RCMP analysis of Senator Wallin’s numerous calendars and electronic backups revealed an entry in her electronic Microsoft Outlook calendar for a Porter board meeting scheduled between 08:00 and 11:00 hours on June 5, 2012, Mr, Deluce, of Porter, in his RCMP interview, said that his records show that there was a board of directors meeting on June 5, 2012 and that Senator Wallin was in attendance. leamed this from reading the Spreadsheet that Renée Montpellier gave to Deloitte on 2013-01-15 65 Committee travel to the USA h, ‘The RCMP analysis of Senator Wallin’s numerous calendars and electronic ‘backups revealed an entry for a flight from Toronto to Washington, leaving Toronto at 16:10 hours on June 5, 2012, i, Senator Wallin, in a Spreadsheet her office gave to Deloitte, explained that between June 5, and June 10, 2012, she flew to Washington and New York with the Senate Committee on National Security and Defence, That she retumed to Toronto on June 10, 2012 at no expense to the Senate" Sunday June 10,2012 Flight to Toronto j. The RCMP analysis of Senator Wallin’s numerous calendars and electronic backups revealed an entry electronic Microsoft Outlook calendar for a flight from New York to Toronto scheduled between 14:30 and 16:05 hours on June 10, 2012. Monday June 11, 2012 Flight from Toronto k. A flight itinerary attached to the expense claim shows that Senator Wallin flew from Toronto to Ottawa, leaving Toronto at 10:05 hours on June 11, 2012, 1. The RCMP analysis of Senator Wallin’s numerous calendars and electronic backups revealed no entries for scheduled events in Toronto on June 11, 2012. 118. ‘The RCMP analysis of Senator Wallin’s calendars and electronic backups also revealed several other entries, in relation to events scheduled while Senator Wallin was in Toronto which Senator Wallin, in her explanation to Deloitte, does not represent as Senate rélated, ‘These entries such as medical appointments, a dinner reminder, and private meetings are in my belief to be Senator Wallin’s personal affairs". 119. I therefore believe that on June 3, 2012, Senator Wallin flew from Saskatoon to Toronto in order to attend to her personal affairs which also included a Porter Board Dinner and a Porter Board meeting. Senator Wallin then flew to the Washington and New York on Senate Committee affaires, returning to Toronto on June! 0, 2012. I believe that in order to travel to Washington from Saskatoon, Senator Wallin had to transit via Toronto. I do not believe however that Senator Wallin had to return to Toronto on her way back from | leamed tis from reading the Spreadsheet that Renée Montpellier gave to Deloitte on 2013-02-04, " Teamed this from reading the Intella report generated from the analysis of Senator Wallin's calendars. These are evens showing inthe calendars that Senator Wallin's office does not represent as Senate Business in her explanation to Deloitte. 66 Washington I believe that Senator Wallin retumed to Toronto to attend to her personal affairs" on June 10, 2010. Senator Wallin then flew from Toronto to Ottawa the following, day. Senator Wallin submitted expense claims to the senate for reimbursement of expenses incurred during this trip. I believe that by submitting claims T64-22182 to the Senate Finance and Procurement Directorate for reimbursement under the representation that the activities she undertook in Toronto during this portion of her trip were “Senate Business”, Senator Wallin committed a fraud and a breach of trust. Moreover, based on my interview with Mr, Deluce, I also believe that Senator Wallin may have received reimbursement from Porter, for some expenses incurred during this trip. 120. Senator Wallin was reimbursed a total of $7,891.30 for these two claims. Ms, Tracy Haywatd of the Forensic Accounting Management Group, calculated that ofthat amount, $2,401.88 was fraudulently claimed by Senator Wallin", Investigation Specific To Gluskin Sheff & Associates Inc. Interview of Mr, David Morris — Chief Financial Officer for Gluskin Sheff & Associates 121. On Monday September 22, 2014, Constable Vietor Paskal and I interviewed Mr. David Morris, the current Chief Financial Officer for Gluskin Sheff & Associates (Gluskin). During this interview, I leaned in part, the following; a. Mr. Morris said that Senator Wallin was an independent director between 2006 and 2013, holding fiduciary responsibility toward Gluskin, b. Mr. Morris said that board meetings were held quarterly, meetings that were scheduled up to two years in advance; ©. According to Mr. Morris, each board member, including Senator Walli, is entitled 0; i, an annual retainer; fi, meeting fees; . stock options (this practice ended in 2010); and reimbursement for reasonable expenses incurred such as; transportation, accommodation & meals. 4. Mr. Mortis was able to confirm the attendance of Senator Wallin at 12 events, during the time period covered by expense claims submitted by Senator Wallin to "earned this from reading the Intella report generated from the analysis of Senator Wallin’s calendars, These are events showing in the calendars that Senator Wallin’s office does not represent as Senate Business in her explanations to Deloitte. "Ms, Tracy Hayward calculated this amount based on my belief that the June 3 and June 10, 2012 trips to ‘Toronto were not Senate related. This amount encompasses the airfare and ground transportation. 67 the Senate," ¢. Inrelation to Senator Wallin’s attendance at Gluskin events, Mr. Morris stated that he was in care and control of all documents and data sought in the present Information to Obtain, Expense Claims related to Gluskin Sheff & Associates In this section, I will present each of the travel expense claims submitted for reimbursement to the Senate Finance and Procurement Directorate by Senator Wallin, that coincide with the timing of Senator Wallin attending to Gluskin board related events; 122, As previously stated; a. between her January 2009 and June 2013 public disclosures, Senator Wallin declared that she was a member of the board of directors of Gluskin; b. RCMP investigators received 246 travel expense claims from the Senate, Of the 246 claims, we have identified 150 travel expense claims requiring further investigation, Of the 150 claims, 14 coincide with the timing of Senator Wallin’s attendance at 13 Gluskin related board events. 123. Ihave read these 14 travel expense claims'*, and leamed the following; i: Travel expense claim T64-13670 (1 of 14) 124, This travel expense claim is for the period between September 14 and September 17, 2009, a. On September 15, 2009, Senator Wallin flew from Ottawa to Toronto; and b. On September 17, 2009, Senator Wallin flew from Toronto to Ottawa, 125. Senator Wallin expensed the airfare, the associated ground transportation , some per diems along with some private accommodations to the Senate. 126. ‘The purpose written on the claim is “Senate Business”. The expense claim bears Senator Wallin’s signature and is dated September 25, 2009. It was submitted to the Senate Finance and Procurement Directorate for reimbursement. ‘5 | will further elaborate about each of these events in a later paragraph, °° These 14 travel expense claims were received from the Senate on November 29, 2013 subsequent to the Production Order dated 2013-11-01, 68 ‘Tuesday, September 15, 2009 Flight to Toronto a. A flight itinerary, attached to the expense claim shows that Senator Wallin flow from Ottawa to Toronto, arriving in Toronto at approximately 18:30 hours on September 15, 2009. Dignitas Intemational reception a. Senator Wallin, in a Spreadsheet her office gave to Deloitte, explained that on September 15, 2009 she flew to Toronto to attend a reception by Dignitas International, That she was “Invited fo a reception by Dignitas International, a ‘medical humanitarian organization which works with commumities to increase access to life-saving HIVIAIDS-related treatment and prevention in resource- limited settings, founded by Dr.'s Without Borders. Also attending was Dr. J. Nutt, a founder and Executive Director of War Child Canada", b. Ms. Marilyn Metiarg, President and CEO of Dignitas International sent an e-mail to Corporal Williams-Pelly. [have read this email dated November 19, 2014, in which earned in part, the followings i, Ms. McHarg wrote that in response to the RCMP’s inquiries, Dignitas International has reviewed its records and determined that Senator Pamela ‘Wallin was not on the Dignitas International guest list for the inaugural Cinema Against AIDS event held in Toronto on September 15, 2009. ii, Ms. McHarg further wrote that although Senator Wallin was not on the Dignitas International guest list, she may have attended in substitution for another guest or may have been a last minute addition to the event whose attendance was not entered on the list, b. Constable Guy Brassard spoke to Dr. Samantha Joan Nutt, the founder and Executive Director of War Child Canada. During the ensuing conversation, Dr. Nutt said that she does not recall attending the Dignitas reception on September 15, 2009 and that there are no records in her and her husband’s calendars about this event. ©. On January 21, 2015, I access the Dignitas International website and leamed the following”; 4°" Jeanned this ftom reading the Spreadsheet, which Renée Montpellier gave to Deloitte on 2013-05-13. T teamed ths from reading a Task Action report prepared by Constable Guy Brassard, detailing his December 3, 2014 conversation with Dr. Samantha Joan Nutt 1 feared this from reading the invitation pamphlet ofthe event at htps/dignitas.unxvision.com/Event/upload/TORONTO-Aug?.pdf 69 "7 Jeamed i, On September 15, 2009, Dignitas Intemational hosted an event called “Cinema Against AIDS 2009 Toronto” in Toronto, to benefit amfAR the Foundation for AIDS Research and Dignitas International; ii, The time table for the event is as follows: 1, 18:30 hours, Champagne Reception; 2. 20:00 hours, Dinner, live auction and performance; and 3. 22:00 hours, The Round Room lounge. [Of interest, Senator Wallin’s flight itinerary shows that she was scheduled to Jand in Toronto at 18:30 hours] Council of Ontario Universities Chancellor's dinner c. The RCMP analysis of Senator Wallin’s calendars and electronic backups revealed an entry in her electronic Microsoft Outlook Calendar for “UNIVERSITY of GUELPH - Chancellor's dinner” scheduled between 19:00 and 21:30 hours on September 15, 2009, along with entries in her handwritten calendars for “Chancellor's dinner” on the same day. 4. Corporals Holly Chappell interviewed Ms. Mary Murphy, (legal counsel for the University Of Guelph). In her interview, Ms. Murphy said there was a Chancellor dinner scheduled by the Council of Ontario Universities on September 15, 2009 and that Guelph has no record that could attest to Wallin’s attendance”, €. Corporal Holly Chappell interviewed Ms. Jennier Grass, the Senior Director of Communications and Public A ffaits at the Council of Ontario Universities. During her interview, Ms. Grass said in part, the following''; a. Ms. Grass’s records indicate that there was an Ontario Chancellors dinner ‘on September 15, 2009 at the University club, and that Senator Wall attended, b. Senator Wallin attended in her capacity of a Chancellor. ¢. The discussion revolved around University matters and never about the Senate. Meeting with former Premier David Peterson f£. The RCMP analysis of Senator Wallin’s calendars also revealed an entry in the printed version of her Microsoft calendars, which she gave to Deloitte, for a meeting with former Premier David Peterson schedule on September 15, 2009. is from reading the transcript of the RCMP interview of Vicky Hodgkinson & Mary Murphy dated September 16, 2014 HN" Tleamed this from reading the transcript of Jennifer Grass’s interview dated December 17, 2014. 70 [There is no indication as to when this entry was made into this Calendar because this is a printed version of the calendar]. g ‘The Honorable David Peterson, 20" Premier of Ontario was interviewed by Corporal Holly Chappell. During his interview, Mr. Peterson said in part, the following! a. In 2009, Mr Peterson was Chancellor at the University of Toronto. Mr. Peterson’s diary confirms that he had attended the Ontario Chancellors Dinner at the University Club on September 15, 2009, Mr. Peterson remembers that Senator Wallin was in attendance on that day. Mr. Peterson does not remember having a separate meeting with Senator Wallin, outside of the dinner. Mr. Peterson does not recall a topic of discussion they would have planned to discuss during the meeting, nor does he recall any of the specific topics they discussed. Mr. Peterson confirms that the group had no formal relationship with the govemment, Wednesday, September 16,2009 Gluskin Board dinner h. The RCMP analysis of Senator Wallin’s calendars and electronic backups revealed; iii, an entry in her electronic Microsoft Outlook calendar for a Gluskin Board of director’s dinner for Wednesday scheduled for 18:30 hours on September 16, 2009. The analysis also revealed that this entry was removed from. Senator Wallin’s Outlook Calendar sometime in May 2013 and re-entered in the calendar sometime in June 2013; and, iv. an entry in her handwritten calendar for “G/S” dinner on September 16, 2009. [I believe that G/S is Gluskin Sheff] i, David Mortis (CFO for Ghuskin), in his RCMP interview said that his records show that there was a Gluskin board of directors’ dinner in Toronto on Wednesday September 16, 2009. There are no records of who attended and Morris cannot confirm Senator Wallin’s attendance; j. Senator Wallin, in a Spreadsheet her office gave to Deloitte, explained that on September 16, 2009, she spent the day in Toronto prior to retumning fo Ottawa and that that private accommodations and per diem were ettoneously claimed for this day through an administrative error!”, "J [earned this ftom reading the summary of Mr, Peterson’s interview dated January 14, 2015. The summary was srepared by Cpl. Chappell "teamed this from reading the Spreadsheet, which Renge Montpellier gave to Deloitte on May 13, 2013, n Thursday. September 17, 2009 Gluskin Board meetings k, The RCMP analysis of Senator Wallin’s calendars and electronic backups revealed; y. an entry in her electronic Microsoft Outlook calendar for a Gluskin Board of director's meeting scheduled for 08:00 hours on September 17, 2009. ‘The analysis also revealed that this entry was deleted from Senator Wallin’s Outlook calendar sometime in May 2013 and re-entered sometime in June 2013; and vi. an entries in her handwritten calendars for “G/S” board meetings on September 17, 2009, 1. David Morris (CFO for Gluskin), in his RCMP interview said that his records show that there were Gluskin board meetings in Toronto, on Tuesday September 17, 2009 and that Senator Wallin had attended; Elight to Ottawa 1m, A flight itinerary attached to the expense elaim shows that Senator Wallin flew from Toronto to Ottawa, leaving Toronto at approximately 12:00 hours on September 17, 2009, 127. ‘The RCMP’s analysis of Senator Wallin’s calendars and electronic backups also revealed several entries, pertaining to events scheduled while Senator Wallin was in Toronto between September 15 and 17, 2009, that Senator Wallin, in her explanation to Deloitte, docs not represent as Senate related, These entries, such as “Elvis show”, “Heather's birth day” and “welcome back BBQ” are in my belief, to be Senator Wallin’s personal affairs '"4, 128, I therefore believe that on September 15, 2009, Senator Wallin flew {rom Ottawa to Toronto in order to attend to her personal affairs, which included attending to a Gluskin board of directors’ meeting and to the Council of Ontario University Chancellor dinner in her capacity of Chancellor at the university of Guelph. This dinner was attended by other Ontario university chancellors which included the Hon, David Peterson, the then Chancellor at the University of Toronto. Senator Wallin, in a Spreadsheet her office gave to Deloitte, asserted that on September 15, 2009, she attended as an invited guest, to a reception by Dignitas International, that this event was also attended by Dr. J Nutt, founder and Executive Director of War Child Canada. I do not believe thet Senator Wallin attended this event in her capacity of Senator. Senator Wallin’s name does not appear on the Dignitas guess list for that event, Dr. Samantha Joan Nutt whom Senator Wallin identified "teamed this from reading the Intella report generated from the analysis of Senator Wallin’s calendats, These fare events showing in the calendars that Senator Wallin’s office does not represent as Senate Business in her explanations to Deloitte. 2 as having attended this event does not have any records or recollection of having attended this event, and moreover, our interviews with the Hon. David Peterson and with Ms. Jennier Grass confirms that on September 15, 2009 Senator Wallin was at the Council of Ontario University Chancellor dinner which took place at the same time as the Dignitas event, Senator Wallin flew back to Ottawa on September 17, 2009 ater having attended to her personal affairs in Toronto, Senator Wallin submitted a claim to the senate for reimbursement of expenses incurred during this trip. I believe that by submitting claim ‘T64-13670 to the Senate Finance and Procurement Directorate for reimbursement under the representation that the activities she undertook during this trip were “Senate Business”, Senator Wallin committed a fraud and a breach of trust, Moreover, I also believe based on my interview with Mr, Morris (CFO for Gluskin) that Senator Wallin was entitled to, and may have received reimbursement from Gluskin, for some expenses incurred during this trip, 129. Senator Wallin was reimbursed a total of $1,318.10 for this claim, Ms. Tracy Hayward of the Forensic Accounting Management Group, calculated thet of that amount, $965.90 ‘was fraudulently claimed by Senator Wallin''*, Travel expense claim T64-10441 (2 of 14) 130. This travel expense claim is for the period between February 1 and February 3, 2010. a. On February 1* 2010, Senator Wallin flew from Toronto to Ottawa; b. On February 3, 2010, Senator Wallin flew from Ottawa to Toronto. 131. Senator Wallin expensed the airfare to and from Toronto, the associated ground transportation along with some meals to the Senate. 132. ‘The purpose written on the expense claim is “Senate Business”. The claim bears Senator Wallin’s signature and is dated February 24, 2010, It was then submitted to the Senate Finance and Procurement Directorate for reimbursement. Wednesday, February 3, 2010 Flight to Toronto a. A flight itinerary attached to the expense claim shows that Senator Wallin flew from Ottawa to Toronto, arriving in Toronto at 12:00 hours on February 3, 2010; Meeting with Mr. Decter b. The RCMP analysis of Senator Wallin’s calendars also revealed an entry in the inted version of her Microsoft calendar, for a meeting with M. Decter scheduled 5 Ms, Tracy Hayward calculated this amount based on my belief that the September 15 to September 19, 2009 trip to Toronto was not Senate related. This amount encompasses the airfare and ground transportation. 73 on February 3, 2010, [There is no indication as to when this entry was entered into this Calendar because this is a printed version of the calendar]. ‘There is no mention of this meeting in Senator Wallin’s electronic Outlook calendar of handwritten calendars. ¢. Senator Wallin in a Spreadsheet her office gave to Deloitte, also explained that on February 3, 2010, she “met with Mr. Decter, President and CEO of the investment management firm LDIC Inc.. Mr. Decter is a Harvard-trained economist and leading Canadian expert on health systems, She met with him regarding business, finance & health care issues specifically the Federal Government's role”"*, 4. Senator Wallin, in her interview with Deloitte, said that she met with Mr. Decter with whom she had a long standing personal relationship. That Mr. Decter is one of the country leading experts on health care. Senator Wallin said that there was a funding issue that he wanted to talk about!” . Mr. Michael Decter, an investment firm owner and member of several health care related boards was interviewed by Constable Linnea Gallant. Mr. Decter said in part, the following!'*; i, In the past, Mr Decter was in an intimate relationship with Senator Wallin, ‘The relationship ended approximately 10 years ago and they have remained friends. Over the last 10 years, Mr, Decter and Senator Wallin have seen cach other approximately 6 times per year, usually for dinner while she was in Toronto, Mr.Decter said that he and Senator Wallin had a wide ranging of conversations about the world, usually featuring some discussion about Afghanistan because of her work on the Afghanistan task force. Mr, Decter has no recollection and records which could corroborate a meeting with Senator Wallin on February 3, 2010. Gluskin board dinner £. The RCMP analysis of Senator Wallin’s calendars and electronic backups revealed; i, an entry in her electronic Microsoft Outlook calendar for a Gluskin board of directors’ dinner scheduled for 18:30 hours on February 3, 2010; ii, an entry in her handwritten calendar for “G/S Dinner Toronto Club 6:30” on February 3, 2010. [I believe that this entry is referring to the Gluskin board dinner scheduled for 18:30 hours]. 8. David Morris (CFO of Gluskin), in his RCMP interview said that his records show that that there was a board dinner on February 3, 2010, There are no records of who 1 leamed this from reading the Spreadsheet, which Renée Montpellier gave to Deloitte on May 13, 2013. 7 eared this from reading the transcript ofthe Deloitte interview of Senator Wellin dated June 6, 2013. * J earned this from reading the transcript of the October 25, 2014 RCMO interview of Michael Decter. 74 attended and Mr. Morris cannot confirm Senator Wallin’s attendance; ‘Thursday February 4" 2010 Gluskin board meetings h, The RCMP analysis of Senator Wallin’s calendars and electronic backups revealed an entry in her electronic Microsoft Outlook calendar for a Gluskin Sheff — Nominating and Governance Committee meeting, scheduled for 10:00 hours on February 4, 2010, The analysis also revealed that this entry was deleted from Senator Wallin’s Outlook calendar sometime in May 2013 and re-entered sometime in June 2013. The analysis also revealed an entry in her handwritten calendar for “10am G/S Board Mig” on February 4, 2010, [1 believe that this entry is referring to a Gluskin board meeting at 10:00 hours). David Mortis (CFO of Gluskin), in his RCMP interview said that his records show that there were Gluskin board and Committee meetings on February 4, 2010 and that Senator Wallin attended both meetings. Personal travels to Calgary, Washington and New York City j. The RCMP analysis of Senator Wallin’s calendars and electronic backups revealed an entry in her electronic Microsoft Outlook calendar indicating that she will be traveling from Toronto to Calgary on February 4, 2010, in relation to Oilsands Quest. k, Senator Wallin in a Spreadsheet her office gave to Deloitte, explained that between February 4 and February 12, 2010, she was on personal business travel to Washington and New York City at her own expense!”, 133. The RCMP analysis of Senator Wallin’s calendars and electronic backups also revealed several entries, pertaining to events scheduled between February 3" and February 12, 2010, while Senator Wallin was in Calgary, Washington and New York , that Senator Wallin; in her explanation to Deloitte, does not represent as Senate related. These entries, such as Cilsand Quest board meetings, birthday reminders and dinners are in my belief to be Senator Wallin’s personal affairs’, 134, I therefore believe that on February 3, 2010, Senator Wallin flew from Ottawa to Toronto in order to attend to her personal affairs, which included a dinner with Michael Decter, a personal friend with whom she was previously in a relation with. I believe that Senator Wallin also attended two Gluskin board meetings and other events, which she qualified to Deloitte as “personal business travel”, Senator Wallin submitted an expense [ leamed this from reading the Spreadsheet, which Renée Montpellier gave to Deloitte on 2013-05-13. T feamed this from reading the Intella report generated from the analysis of Senator Wallin’s calendars. These are events showing in the calendars that Senator Wallin’s office does not represent as Senate Business in her explanations to Deloitte, 15 claim to the Senate for reimbursement of expenses incurred during this ttip to Toronto. I believe that by submitting claim, 764-1041 to the Senate Finance and Procurement Directorate for reimbursement under the representation that the activities she undertook in Toronto, during this portion of her trip were “Senate Business”, Senator Wallin committed a fraud and a breach of trust. Moreover, [ also believe based on my interview with Mr. Mortis (CFO for Gluskin) that Senator Wallin was entitled to, and may have received reimbursement from Gluskin, for some expenses incurred during this trp. 135. Senator Wallin was reimbursed a total of $1,735.05 for this claim. Ms. Tracy Hayward of the Forensic Accounting Management Group, calculated that of that amount, $604.45 was fraudulently claimed by Senator Wallin’?. Travel expense claims T64-10446 and T64-10448 (3 & 4 of 14) | 136. ‘These two travel expense claims are for the period between March 8 and March 18, 2010. On March 8, 2010, Senator Wallin flew from Toronto to Ottawa; On March 11, 2010, Senator Wallin drove from Ottawa to Montreal; ‘On March 11, 2010, Senator Wallin flew from Montreal to Toronto; ‘On March 15, 2010, Senator Wallin flew from Toronto to Ottawa; and On March 18, 2010, Senator Wallinflew from Ottawa to Toronto. oP eae 137. Senator Wallin expensed the airfare to and from Toronto, the associated ground transportation along with some per diems to the Senate, 138. The purpose written on claim T64-10448 is “Senate Business”. ‘There is nothing written in the purpose for claim T64-10446, however in an e-mail dated March 26, 2010, Senator Wallin’s Executive Assistant, Ms. Helen Kryzewski wrote (o the Senate Finance and Procurement Directorate that the Senator was on “Senate Business” in relation to this claim. The expense claims bears Senator Wallin’s signature and are respectively dated March 20, and March 29, 2010. They were then submitted to the Senate Finance and Procurement Directorate for reimbursement. ‘Thursday Mareh 11, 2010 Flight to Toronto a. A flight itinerary attached to the expense claim show that Senator Wallin flew from Montreal to Toronto, arriving in Toronto at approximately 22:20 hours on March 11, 2010. b. The RCMP analysis of Senator Wallin’s calendars and electronic backups revealed '°! Ms. Tracy Hayward calculated this amount based on my belief that the Februery 3, 2010 tip to Toronto was ‘not Senate related. This amount encompasses the airfare and ground transportation, 16 no entries for scheduled events in Toronto on March 11, 2010. ¢. Senator Wallin, in a Spreadsheet her office gave to Deloitte, explained that on March 11, 2010, she flew from Montreal to Toronto for a business meeting the next day’, [The spreadsheet does not elaborate on the nature of this business meeting]. Meeting with Mr, Peter Munk d. The RCMP analysis of Senator Wallin’s calendars and electronic backups revealed; i. an entry in her electronic Microsoft Outlook calendar for “Eco Cardiogram 3” floor, Peter Monk {sic}, Rm 530, Toronto General” scheduled between 08:00 and 08:30 hours on March 12, 2010; ji, an entry in her handwritten calendar for “8am Peter Munk”; and iii, an entry in printed version of the Microsoft calendar for “Toronto, Mig with P. Munk” scheduled on Match 12, 2010. {There is no indication as to when this entry was entered into this Calendar because this is a printed version of the calendar). On December 12, 2014, I conducted intemet queries and learned that the Toronto General hospital is host to the Peter Munk Cardiac Centre,!?° £ Senator Wallin, in a Spreadsheet her office gave to Deloitte, explained that on March 12, 2010, she attended a business meeting with Mr. Peter Munk of Barrick Gold for a briefing on the state of his industry and to discuss Canada/U.S relations." g. Senator Wallin, in interview with Deloitte, said that Peter Munk is someone she knew for a while and tries to keop in touch with. He has broad interests beside his corporation and is useful to talk to, Senator Wallin said that this generally can be called networking’, h. Mr. Peter Munk, the Founder and now the Chairman Emetitus of Barrick Gold was interviewed by Corporal Fred Pincince. Mr. Munk said that he knows Senator Wallin but that she is neither a personal nor an intimate friend of his, Mr. Munk said that he has never had a private lunch or private dinner with Senator Wallin, Mr. Munk confirmed that he did not meet with Senator Wallin on March 12, 2010 since ‘he was in Switzerland, but that he could have had a phone call with her. Mr Munk also said that it would be possible that Senator Wallin may have met with his 1 feared this from reading the Spreadsheet, which Renée Montpellier gave to Deloitte on 2013-05-13, "57 Ieamed this from visiting the Toronto Gencral hosptal’s web site at htip:/Avwwwahn,ca/PMCCI. ng the Spreadsheet, which Renée Montpellier gave to Deloitte on May 13, 2013. 51 teamed this ftom reading the Transcript Senator Wallin’ interview with Deloitte dated Jone 7, 2013. 7 President or CEO, although Barrick Gold does not generally deal with Senators.!°> Saturday March 13, and Sunday 14, 2010 i, Senator Wallin in the Spreadsheet her office gave to Deloitte, explained that on March 13 and 14, 2010, she spent 2 days in Toronto prior to returning to Ottawa at no cost to the Senate!?”, Monday March 15,2010 Meeting with Mr. Gerald Sheff The RCMP analysis of Senator Wallin’s calendars and electronic backups revealed; i. an entry in her electronic Microsoft Outlook calendar for a Gluskin appointment, scheduled between 08:30 and 09:00 hours on March 15, 2010, ‘The analysis also revealed that this entry was removed from Senator Wallin’s Outlook calendar sometime in May 2013 and re-entered in the calendar sometime in June 2013; and ii, an entry in her handwritten calendar for “25" Gerry Scheff” on Match 12, 2010. [Lbelieve that this entry is referring to a meeting with Mr. Gerald Sheff, co-Founder of Gluskin], k. David Morris (CFO for Gluskin), in his RCMP interview said that his records show that on March 15, 2010, Senator Wallin attended the offices of Gluskin and met with Mr, Gerald Sheff in his office. Flight from Toronto 1, A flight itinerary attached to the expense claim shows that Senator Wallin flew from Toronto to Ottawa, leaving Toronto at approximately 10:30 hours on March 15, 2010. 139. ‘The RCMP analysis of Senator Wallin’s calendars and electronic backups also revealed several entries, in relation to events scheduled while Senator Wallin was in Toronto, which Senator Wallin, in her explanation to Deloitte, does not represent as Senate related. These entries, such as bone density test, Dinner with Lou and Picking up candle holders are in my belief to be Senator Wallin’s personal affairs'*. 140. I therefore believe that on March 11, 2010, Senator Wallin flew fom Montreal to 61 teamed this from reading the Transcript of Peter Munk’s RCMP interviow dated September 25, 2014, 27 leamed this from reading the Spreadshect, which Renée Montpellier provided to Deloitte on May 13, 2013. "*[ leamed this from reading the Intella report generated from the analysis of Senator Wallin’s calendars. These are events showing in the calendars that Senator Wallin’s office does not represent as Senate Business in her explanations to Deloitte. 8 Toronto in order to attend to her personal affairs, which included a meeting with Mr. Sheff at the offices of Gluskin in Toronto. I believe that Senator Wallin may have attended to an. Eco Cardiogram at the Peter Munk Cardiac center. I believe that Wallin misrepresented this ‘medical appointment to Deloitte by representing it as an appointment with Mr. Peter Munk himself, Senator Wallin then flew from Toronto to Ottawa on March 15" 2010 after having attended to her personal affairs in Toronto. Senator Wallin submitted expense claims to the setate for reimbursement of expenses incurred during this trip to Toronto. I believe that by submitting claims T64-10446 and T64-10448 to the Senate Finance and Procurement Directorate for reimbursement under the representation that the activities she undertook in ‘Toronto duting this portion of her trip were “Senate Business”, Senator Wallin committed a fraud and a breach of trust. Moreover, I also believe based on my interview with Mr. Morris (CFO for Gluskin) that Senator Wallin was entitled to, and may have received reimbursement from Gluskin, for some expenses incurred during this trip. 141, Senator Wallin was reimbursed a total of $4,085.41 for these two claims. Ms. Tracy Hayward of the Forensic Accounting Management Group, calculated that of that amount, $605,45 was fraudulently claimed by Senator Wallin'””. Travel expense claim T64-12101 (5 of 14) [This travel expense claim is pertinent to both Gluskin and Porter, The subsequent paragraphs are therefore represented twice in this application. Once in this section as it pertains to Gluskin, and once in relation to Porter.] 142. This travel expense claim is from May 3 2010 to May 12, 2010. a. On May 3, 2010, Senator Wallin flew from New York to Ottawa; b, On May 5, 2010, Senator Wallin flew from Ottawa to Toronto; and c. OnMay 10, 2010, Senator Wallin flew from Toronto to Ottawa; 143. Senator Wallin expensed the May 10" 2010 airfare from to Toronto to Ottawa, the associated ground transportation along with some meals to the Senate. 144, The purpose written on the claim is “Senate Business”. The expense claim bears Senator ‘Wallin’s signature and is dated May 13, 2010. It was submitted to the Senate Finance and Procurement Directorate for reimbursement. Wednesday May 5, 2010 Flight to Toronto a. The RCMP analysis of Senator Wallin’s calendars and electronic backups revealed; " Ms, Tracy Hayward calculated this emount based on my belief that the March L1 to 15, 2010 trip to Toronto ‘was not Senate related. This amount encompasses the airfare and ground transportation, 79 i. an entry in her electronic Microsoft Outlook calendar for a flight from Ottawa to Toronto, scheduled between 17:15 and 18:15 hours on May 5, 2010, The entry also shows that this flight was claimed fo Gluskin; Gluskin board dinner ii, an entry in her electronic Microsoft Outlook calendar for a Gluskin board dinner, scheduled at 18:30 hours on May 5, 2010, The analysis also revealed that this entry was removed from Senator Wallin’s Outlook calendar sometime in May 2013 and re-entered in the calendar sometime in June 2013; and iii, an entry in Senator Wallin’s handwritten calendar for a “G/S dinner” on May 5, 2010 {I believe that G/S stands for Gluskin] b. David Morris (CFO for Gluskin), in his RCMP interview said that his records show that there was a Gluskin board of directors’ dinner on May Sth 2010 and that Senator Wallin attended the dinner. Personal Trip c, A handwritten note in the expense claim, read that Senator Wallin left Ottawa on May 5, to go ona “personal trip”. [I did not see any clarification written on the expense claim as to the nature of this personal trip]. ‘Thursday May 6, 2010 Retum to Toronto from personal trip . A handwritten note in the expense claim, read that Senator Wallin retumed to ‘Toronto on May 6, from the “personal trip”. Gluskin board meetings ¢. The RCMP analysis of Senator Wallin’s calendars and electronic backups revealed three entries in her electronic Microsoft Outlook calendar for Gluskin board meetings scheduled between 08:00 and 11:00 hours on May 6, 2010, The analysis also revealed that these entries were removed from Senator Wallin’s Outlook calendar sometime in May 2013 and re-entered in the calendar sometime in June 2013. f. David Morris (CFO for Gluskin), in his RCMP interview said that his records show that there were Gluskin board and committee meetings on May 6, 2010 and that Senator Wallin had attended these meetings, 80 May 7,201 g. Senator Wallin in the Spreadsheet her office gave to Deloitte, explained that on May 7, 2010, she flew from Ottawa to Toronto for private business and spent the weekend in Toronto, That the flight to Toronto was not expense to the Senate. [I did not see any mention of this May 7" flight in the expense claim.] h, The RCMP analysis of Senator Wallin’s numerous calendars and electronic backups revealed an entry in her Microsoft printed calendars for “Ottawa/T.0” on that date. [There is no indication as to when this entry was made into this calendar as this is a Printed version of the Calendar]. There are no entries in Senator Wallin’s electronic or handwritten calendars for a flight taken by Senator Wallin on May 7, 2010, Moreover, I believe that on May 7, 2010, Senator Wallin was already in Toronto as she had attended at least two Gluskin Board meetings in Toronto the day before. Saturday May 8, 2010 Meeting with Robert Deluce i, The RCMP analysis of Senator Wallin’s calendars and electronic backups revealed an entry in her electronic Microsoft Outlook Calendar for “Meeting Bob from Porter* scheduled between 08:00 and 08:30 hours on May 8, 2010, j. On September 23, 2014, I interviewed Robert Deluce, the Chief Executive Officer (CEO) of Porter Airlines. Following my interview with Mr. Deluce, I received an e- mail from Mr, Greg Sheahan (council for Porter Airlines) with some clarifications on events that Mr, Deluce, during his interview was unable to provide, From this interview and subsequent e-mail, I learned that on May 8, 2010, Mr. Deluce met with Senator Wallin at Porter’s offices at 08:00 hours, to discuss various Porter board related matters, k, The RCMP analysis of Senator Wallin’s calendars and electronic backups revealed no other entries for scheduled events in Toronto on May 8, 2010. ‘Sunday May 9, 2010 1. ‘The RCMP analysis of Senator Wallin’s calendars and electronic backups revealed no scheduled events in Toronto for May 9, 2010. Monday May 10,2010 Flight to Ottawa 1m, A flight itinerary attached to the expense claim shows Senator Wallin flew from "89 T leamed this from reading the Spreadsheet, which Renée Montpellier gave to Deloitte on 2013-05-13, 81 Toronto to Ottawa, leaving Toronto at approximately 08:45 hours on May 10, 2010. 145. The RCMP analysis of Senator Wallin’s calendars and electronic backups also revealed entries, in relation to events scheduled while Senator Wallin was in Toronto, which Senator Wallin, in her explanation to Deloitte, does not represent as Senate related. These entries, such as birthday reminders, medical and personal appointments, are in my belief to be Senator Wallin’s personal affairs"! 146. I therefore believe that on May 5, 2010, Scnator Wallin flew from Ottawa to Toronto and claimed the flight to Gluskin. That while in Toronto, Senator Wallin attended to her personal affairs which included Gluskin Board meetings and dinner, along with a Porter related meeting. Senator Wallin then flew from Toronto to Ottawa on May 10, 2010 after ‘having attended to her personal affairs. I also believe that Senator Wallin mistepresented to Deloitte that on May 7, 2010 , she flew from Ottawa to Toronto at her own expense when the documentation suggest that she was already in Toronto on May 6, 2010. Senator Wallin submitted an expense claim to the senate for reimbursement of expenses incurred during this trip toToronto. I believe that by submitting claim T64-12101 to the Senate Finance and Procurement Directorate for reimbursement under the representation that the activities she undertook in Toronto during this portion of her trip were “Scnate Business”, Senator Wallin committed a fraud and a breach of trust. Moreover, I also believe based on my interview with Mr. Morris (CFO for Gluskin) that Senator Wallin was entitled to, and may have received reimbursement from Gluskin, for some expenses incurred during this trip. 147, Senator Wallin was reimbursed a total of $1,130.28 for this claim, Ms, Tracy Hayward of the Forensic Accounting Management Group, calculated that of that amount, $623.28 was fraudulently claimed by Senator Wallin’, E Travel expense claim T64-12123 (6 of 14) 148, This travel expense claim is for the period between July 8, and July 12, 2010. a, On July 8, 2010, Senator Wallin flew from Ottawa to Toronto; b. On July 9, 2010, Senator Wallin flew from Toronto to Regina; ¢. OnJuly 11, 2010, Senator Wallin flew fiom Regina to Toronto; and d. On July 12, 2010, Senator Wallin flew from Toronto to Ottawa 149. Senator Wallin expensed the airfare to and from Toronto and Regina along with the associated ground transportation, 150. ‘The purpose written this expense claim “Senate Business”. The expense claims beats earned this ftom reading the Intella report generated fiom the analysis of Senator Wallin’s calendars. These are events and entries showing in the calendars that Senator Wallin's office does not represent as Senate Business in her explanations to Deloitte, Ms. Tracy Hayward calculated this amount based on my belief that the May 5 to May 10, 2010 ttip to Toronto ‘was not Senate related, This amount encompasses the airfare and ground transportation. 82 Senator Wallin’s signature and is dated August 4, 2010. The claim was submitted to the Senate Finance and Procurement Directorate for reimbursement. ‘Sunday July 11,2010 Flight to Toronto, a. A flight itinerary attached to the expense claim shows that Senator Wallin flow from Regina to Toronto, arriving in Toronto at approximately 15:07 hours on July 11,2010, b, The RCMP analysis of Senator Wallin’s calendars and electronic no entries for events scheduled in Toronto on July 11, 2010. ¢. Senator Wallin, in a Spreadsheet her office gave to Deloitte, explained that on July 11, 2010, she flew Regina to Toronto on her way back to Ottawa, Monday July 12. 2010 luskin Board meeting: d. The RCMP analysis of Senator Wallin’s calendars and electronic backups revealed three entries in her electronic Microsoft Outlook calendar for Gluskin board meetings on July 12, 2010 between 10:00 and 12:30 hours. The analysis also revealed that two of the three entries were deleted from the Outlook calendar sometime in May 2013 and re-entered sometime in June 2013. e. David Morris (CFO for Gluskin), in his RCMP interview said that his records show that there was a Gluskin Board of Directors meeting on July 12, 2010 and that Senator Wallin attended this meeting. £ Senator Wallin, in a Spreadsheet her office gave to Deloitte, explained that on July 12, 2010, she flew Toronto to Ottawa for Senate Business, Flight to Ottawa a. A flight itinerary attached fo the expense claim shows that Senator Wallin flew from Toronto to Ottawa, leaving Toronto at approximately 12:30 hours on July 12, 2010, 151. I therefore believe that on July 11, 2010, Senator Wallin flew from Regina to Toronto in order to attend to attend to Gluskin board meetings on July 12, 2010, Senator Wallin then flow from Toronto to Ottawa on July 12, 2010 after having attended these board meetings. Senator Wallin submitted an expense claim to the senate for reimbursement of expenses 2 leamed this from reading the ealendar Spreadsheet Renée Montpellier gave to Deloitte on May 1, 2013, "1 leamed this from reading the calendar Spreadsheet Renée Monipellier gave to Deloitte on May 1, 2013. 83 incurred during this trip. [ believe that by submitting claim T64-12123, to the Senate Finance and Procurement Directorate for reimbursement under the representation that the activities she undertook in Toronto during this portion of her trip were “Senate Business”, Senator Wallin committed a fraud and a breach of trust. Moreover, | also believe based on. my interview with Mr. Morris (CFO for Gluskin) that Senator Wallin was entitled to, and may have received reimbursement from Gluskin, for some expenses incurred during this tip. 152, Senator Wallin was reimbursed a total of $6,176.73 for this claim, Ms. Tracy Hayward of the Forensic Accounting Management Group, calculated that of that amount, $2,713.21 was fraudulently claimed by Senator Wallin’, Travel expense claim T64-18054.and T64-18055 (7 & 8 of 14) 153. These two travel expense claims are for the period between September I1 and September 18, 2010. a. On September 11, 2010 Senator Wallin flew from Toronto to Ottawa; b. On September 11, 2010 Senator Wallin flew from Ottawa to Toronto; c. On September 12, 2010, Senator Wallin flew from Toronto to Regina; d. On September 15, 2010, Scnator Wallin flew from Regina to Toronto; &, On September 17, 2010, Senator Wallin flew from Toronto to Ottawa; and £. On September 18, 2010, Senator Wallin flew from Ottawa to Toronto. 154. Senator Wallin expensed the airfares to and from Toronto, Ottawa and Regina , the associated round transportation along with some associated meals to the Senate. 155. The purpose written on both expense claims is “Senate Business”. These expense claims bears Senator Wallin’s signature. Claim T64-1805¢ is undated and claim T64-1805S is, dated September 20, 2010. The claims were submitted to the Senate Finance and Procurement Directorate for reimbursement, Wednesday September 15 and Thursday September 16,2010 Flight to Toronto a. A flight itinerary attached to the expense claim shows that Senator Wallin flew from Regina to Toronto, arriving in Toronto at approximately 15:07 hours on September 15, 2010. b. Senator Wallin, in the Spreadsheet her office gave to Deloitte, explained that on September 15, 2010, she flew from Regina to Toronto to attend an event the next "° Ms, Tracy Hayward calculated this amount based on my belief that the July 11 to July 12, 2010 trip to Toronto ‘was not Senate related. This amount encompasses the airfare and ground transportation. 84 day. [Senator Wallin did not elaborate as to the nature of that event] c. The RCMP analysis of Senator Wallin’s calendars and electronic backups revealed two entries for a Gluskin board and Committee meetings scheduled for 15:00 hours ‘on September 15, 2010, and for a Gluskin board of directors dinner that same day at 18:30 hours. 4d, ‘The RCMP analysis also revealed four entries for Gluskin board and committee meetings scheduled between 08:30 and 12:00 hours on September 16, 2010, The analysis also revealed that these six Gluskin entries were removed for Senator Wallin’s Outlook calendar sometime in May 2013 and re-entered in the calendar sometime in June 2013. , David Morris (CFO for Gluskin), in his RCMP interview, said that his records show that there was a Board dinner on September 15, 2010. There are no records of who attended, Mr, Mortis believes based on his record of expenses, that Senator Wallin may have attended the dinner. Mr Mortis further said that there were Board ‘meetings, on September 16, 2010 and Senator Wallin attended these meetings. MP Mike Wallace's riding event £ Senator Wallin, in the Spreadsheet her office gave to Deloitte, wrote that on September 16, 2010, she attended MP Mike Wallace’s riding event in Burlington as keynote speaker'?’, & The RCMP analysis of Senator Wallin’s calendars and electronic backups revealed an entry for a Burlington Golf and Country club event scheduled for 16:00 hours on September 16, 2010. hh, Senator Wallin in interview with Deloitte, said that she flew from Regina to ‘Toronto where she attended Mike Wallace’s event. When asked if this was a fundraiser, Senator Wallin replied that she assumed “people paid for dinner”, and that it was not solely a patty event. Senator Wallin also said that her understanding ‘was that these events were acceptable unless there they oceur during an election campaign. "°° i, Richard Mitchell, the Financial Agent of the Burlington Electoral District Association (EDA) was interviewed by Constable Victor Paskal. During his interview, Mr. Mitchell said that on September 16, 2010, the EDA held a fundraiser at the Burlington Golf and Country club in Burlington Ontario, in an effort to amass funds for the next elections, Mr. Mitchell said that Senator Wallin had attended this 6 T lcamed this from reading the Spreadshect provided by René Montpellier fo Deloitte dated May 1, 2043. +37 | teamed this from reading the Spreadsheet provided by René Montpellier to Deloitte dated May 1, 2013, 8 Tleamed this from reading the Transcript of the Deloitte interview of Senator Wallin dated June 27, 2013, 85 event as the event’s speaker, Mr. Mitchell said that the ovent was not partisan in nature; however, that money would benefit the Burlington Conservative EDA and its conservative Member of Parliament, September 17, 2010 Flight from Toronto J. A flight itinerary attached to the expense claim shows that Senator Wallin flew from Toronto to Ottawa, Leaving Toronto at approximately 10:30 hours on September 17, 2010. 156. ‘The RCMP analysis of Senator Wallin’s calendars and electronic backups also revealed entties, in relation to events, which Senator Wallin, in her explanation to Deloitte, does not represent as Senate related. These entries, such as birthday reminders, personal appointments and a University of Guelph cabinet meeting, are in my belief to be Senator Wallin’s personal affairs'®, 157. I therefore believe that on September 15, 2010, Senator Wallin flew from Regina to Toronto in order to attend to her personal affairs, which included a Gluskin board of directors" dinner, a Gluskin board of directors’ meeting and a partisan Conservative party fundraising event for MP Mike Wallace in Burlington. Senator Wallin then flew fiom ‘Toronto {o Ottawa September 17, 2010. Senator Wallin submitted an expense claim to the senate for reimbursement of expenses incurred during this portion of her trip, I believe that by submitting claim T64-18054 and T64-18055, to the Senate Finance and Procurement Directorate for rcimbursement under the representation that the activities she undertook in ‘Toronto during this portion of her trip were “Senate Business”, Senator Wallin committed a fraud and a breach of trust. Moreover, I also believe based on my interview with Mr. Mortis (CFO for Gluskin) that Senator Wallin was entitled (0, and may have received reimbursement from Gluskin, for some expenses incurred during this trip, 158. Senator Wallin was reimbursed a total of $7,055.26 for these two claims. Ms. Tracy Hayward of the Forensic Accounting Management Group, calculated that of that amount, $673.53 was fraudulently claimed by Senator Wallin'*!, 12 Tleamed this from reading the Transoript of the interviow of Richard Mitchell dated October 22, 2014, ‘© J leamed this from reading the Intelle report generated from the analysis of Senator Wallin’s calendars, These are events and entries showing in the calendars that Senator Wallin’s office does not represent as Senate Business in her explanations to Deloitte, '! Ms, Tracy Hayward calculated this amount based on my belief that the September 15, to September 17, 2010 trip to Toronto was not Senate related. This amount encompasses the airfare and ground transportation, 86 Travel expense claim T64-19240 , T64-19241 and 164-20858 (9, 10 & 11 of 14) 159, These travel expense claims are for the period between October 31, 2011 and November 2, 2011. a. On Noyember 1, 2011, Senator Wallin flew from Toronto to Ottawa; b. On November 1, 2011, Senator Wallin flew from Ottawa back to Toronto; ¢. On November 2, 2011, Senator Wallin flew from Toronto to Ottawa; and d. On November 2, 2011, Senator Wallin flew from Ottawa back to Toronto, 160. Senator Wallin expensed the airfares along with the associated ground transportation, 161. The purpose written on both expense claims is “Senate Business”. These expense claims bears Senator Wallin’s signature and are respectively dated November 2, 2011, November 9, 2011 and December 6, 2011. The claims were submitted to the Senate Finance and Procurement Directorate for reimbursement. ‘Tuesday November 1, 2011 a. A flight itinerary attached to the expense claim shows that Senator Wallin flew from Toronto to Ottawa, arriving in Ottawa at approximately at 12:10 hours, on November 1, 2011. Flight to Toronto A flight itinerary attached to the expense claim shows that Senator Wallin flew from Ottawa to Toronto, arriving in Toronto at approximately at 17:45 hours, on November 1, 2011. Gluskin board dinner c, The RCMP analysis of Senator Wallin’s numerous calendars and electronic backups revealed an entry in her electronic Microsoft Outlook calendar for a Gluskin Board of directors dinner presentation scheduled for 18:30 hours on November I, 2011. 4d. David Morris (CFO for Gluskin), in his RCMP interview, said that his records show that there was a board dinner on November 1%, 2011, There are no records of who attended and Mr. Morris cannot confirm Senator Wallin’s attendance. €. Senator Wallin, in a Spreadsheet her office gave to Deloitte, explained that on November 1, 2011, she flew back to Toronto for personal business and that 87 $1,829.57 was erroneously charged to the Senate!, Wednesday November 2, 2011 Gluskin board meetings £. The RCMP analysis of Senator Wallin’s numerous calendars and electronic ‘backups revealed three entries for Gluskin meetings scheduled between 08:30 and 11:00 hours on November 2, 2011. g. David Morris (CFO for Gluskin), in his RCMP interview, said that his records show that there was a Gluskin Board of Directors mecting, followed by a committee meeting on November 2" 2011, and Senator Wallin attended both meetings. h, Senator Wallin, in a Spreadsheet her office gave to Deloitte, wrote that on November 2, 2011, she flew from Toronto to Ottawa after personal business and that $763.78 was erroneously charged to the Senate'**, Flight from Toronto a, A flight itinerary attached to the expense claim shows that Senator Wallin flew fiom Toronto to Ottawa, leaving Toronto at approximately 12:25 hours, on November 2, 2011. 162. The RCMP analysis of Senator Wallin’s calendars and clectronic backups also revealed entries, in relation to events scheduled while Senator Wallin was in Toronto, which Senator Wallin, in her explanation to Deloitte, does not represent as Senate related, These entries, such as book launch, and reminders are in my belief to be Senator Wallin’s personel affairs’, 163. I therefore believe that on November 1, 2011, Senator Wallin flew from Ottawa to Toronto in order to attend to her personal affairs, which included various Gluskin Board ‘meetings. Senator Wallin then flow from Toronto to Ottawa on November 2, 2011 after having attended to these personal affairs. Senator Wallin submitted expense claims to the senate for reimbursement of expenses incurred during this portion of her trip to Toronto, 1 believe that by submitting claim T64-19240 and T64-19241 to the Senate Finance and Procurement Directorate for reimbursement under the representation that the activities she undertook in Toronto during this portion of her trip were “Senate Business”, Senator Wallin committed a fraud and a breach of trust, Moreover, | also believe based on my interview with Mr. Montis (CFO for Gluskin) that Senator Wallin was entitled to, and may have received reimbursement from Gluskin, for some expenses incurred during this trip. ‘1 Jearned this from reading the spreadsheet that Renée Montpellier gave to Deloitte on February $, 2013. J earned this from reading the spreadsheet that Renée Montpellier gave to Deloitte on February 5, 2013. Teamed this ftom reading the Intella report generated fiom the analysis of Senator Wallin’s calendars, These are events and entries showing in the calendars that Senator Wallin’s office dos not ropresent as Senate Business in her explanations to Deloitte, 88 164, Senator Wallin was reimbursed a total of $3,162.94 for these three claims. Ms. Tracy Hayward of the Forensic Accounting Management Group, calculated that of that amount, $2,987.84 was fraudulently claimed by Senator Wallin’. Travel expense claim T64-22189 and T64-22191 (12 & 13 of 14) 165. These travel expense claims are for the period between May 7, and May 10, 2012. Senator Wallin flew from Toronto to Ottawa on May 7, 2012; Senator Wallin flew fiom Ottawa to Toronto on May 9, 2012; Senator Wallin flew from Toronto to Ottawa on May 10, 2012; and Senator Wallin flew from Ottawa to Toronto on May 10, 2012 aese 166. Senator Wallin expensed the airfares to and from ‘Toronto along with ground transportation. 167, The purpose written on both expense claims is “Senate Business”. These expense claims bears Senator Wallin’s signature and are both dated May 23, 2012. The claims were submitted to the Senate Finance and Procurement Directorate for reimbursement. ‘Wednesday May 9, 2012, Flight to Toronto a, A flight itinerary attached to the expense claim shows that Senator Wallin flew from Ottawa to Toronto, arriving in Toronto at approximately 18:25 hours on May 9, 2012. Gluskin board dinner b, The RCMP analysis of Senator Wallin’s numerous calendars and electronic. backups revealed an entry in her electronic Microsoft Outlook calendar for a Gluskin Board of Directors dinner presentation, scheduled for 18:30 hours on May 9, 2012. c. David Morris (CFO for Gluskin), in his RCMP interview, said that his records show that there was a Gluskin board dinner on May 9, 2012 and that Senator Wallin attended the dinner, 4d, Senator Wallin, in a Spreadsheet her office gave to Deloitte, wrote that on May 9, 2012, she flew from Ottawa to Toronto for personal business, that $522.99 was 45 Ms, Tracy Haywaed calculated this amount based on my belief that the November 1, to November 2, 201 trip to Toronto was not Senate related. This amount encompasses the airfare and ground transportation, 89 erroneously charged to the Senate!"*, ‘Thursday May 10, 2012 Gluskin Board meetings e. The RCMP analysis of Senator Wallin's numerous calendars and electronic ‘backups revealed three entries for Gluskin Board and committee meetings scheduled between 08:00 and 10:00 hours on May 10, 2012. David Morris (CFO for Gluskin), in his RCMP interview, said that his records show that there was a Gluskin board of directors meeting, followed by a committee meeting on May 10" 2012, and Senator Wallin attended both meetings. Flight from Toronto g. A flight itinerary attached to the expense claim shows that Senator Wallin flew from Toronto to Ottawa, leaving Toronto at approximately 12:20 hours on May 10, 2012. h. Senator Wallin, in a Spreadsheet her office gave to Deloitte, wrote that on May 10, 2012, she flew from Toronto to Ottawa, after personal business, that $504.04 was erroneously charged to the Senate!*?”, 168. I therefore believe that on May 9, 2012, Senator Wallin flew from Ottawa to Toronto in order to attend a Gluskin board of directors dinner in the evening of May 9, 2012 and Gluskin Board meetings the following day, Senator Wallin then flew from Toronto to Ottawa on May 10, 2012, leaving Toronto at approximately 12:20 hours. Senator Wallin submitted these expense claims to the senate for reimbursement of expenses incurred during this trip. I believe that by submitting claim T64-22189 and T64-22191 to the Senate Finance and Procurement Directorate for reimbursement under the representation that the activities she undertook in Toronto during this portion of her trip were “Senate Business”, Senator Wallin committed a fraud and a breach of trust. Moreover, I also believe based on my interview with Mr. Morris (CFO for Gluskin) that Senator Wellin was entitled to, and may have received reimbursement from Gluskin, for some expenses incurred during this trp. 169. Senator Wallin was reimbursed a total of $3,344,65 for these two claims. Ms. Tracy Hayward of the Forensic Accounting Management Group, calculated that of that amount, $1,751.61 was fraudulently claimed by Senator Wallin’ 4% T feared this stom reading the spreadsheet Renée Montpellier gave to Deloitte on January 15, 2013. 7 {leaned this from reading the spreadsheet Renée Montpellier gave to Deloitto on January 15, 201 "Ms, Tracy Hayward calculated this amount based on my belief that the May 9 to May 10, 2012 trip to'Toronto ‘was not Senate related. This amount encompasses the airfare and ground transportation. 90 Travel expense claim T64-22216 (14 of 14) 170. These travel expense claims are for the period between September 20 and September 23, 2012. a, Senator Wallin flew from Toronto to Regina on September 20, 2012; and b, Senator Wallin flew from Regina to Toronto on September 23, 2012, 171, Senator Wallin expensed the September 20, 2012 airfare from ‘Toronto to Regina along with the associated ground transportation to the Senate, 172. The purpose written on the expense claim is “Senate Business ~ Military appreciation day”. The expense claim bears Senator Wallin’s signature and is dated October 3, 2012 The claims were submitted to the Senate Finance and Procurement Directorate for reimbursement, ‘Thursday September 19,2012 Flight to Toronto a. The RCMP analysis of Senator Wallin’s numerous calendars and electronic backups revealed an entry for a flight from Saskatoon to Toronto scheduled between 10:10 and 15:16 hours on September 19, 2012. Senator Wallin did not expense this flight to the Senate, b. Senator Wallin, in a Spreadsheet her office gave to Deloitte, explained that on September 19, 2012; she flew from Saskatoon to Toronto to attend “Senate Business”. Senator Wallin does not elaborate as to the nature of this senate business, Gluskin board dinner c. The RCMP analysis of Senator Wallin’s numerous calendars and electronic backups revealed an entry in her electronic Microsoft Outlook calendar for a Gluskin board of directors’ dinner presentation scheduled between 18:30 and 21:30 hours on September 19, 2012, d. On January 19, 2015, Constable Victor Paskal spoke to David Morris who after verifications, said that his records indicates that there was indeed a board dinner on. September 19, 2012 and that Senator Wallin appears to have been in attendance’. + J Jearned this from speaking with Constable Paskal on January 19, 2015 and from reading his investigative report on the subject. 91 iday September 20, 2012 Gluskin board meeting ¢. The RCMP analysis of Senator Wallin’s numerous calendars and electronic backups revealed three entries in her electronic Microsoft Outlook calendar for Gluskin board and committee meetings scheduled between 08:30 and 12:00 hours ‘on September 20, 2012. f. David Morris (CFO for Gluskin), in his RCMP interview, said that his records show that there was a Gluskin board of directors meeting, on September 20, 2012 and that Senator Wallin had attended. Flight from Toronto g. A flight itinerary attached to the expense claim shows that Senator Wallin flew fiom Toronto to Regina, leaving Toronto at approximately 16:35 hours on September 20, 2012, h, Senator Wallin, in a Spreadsheet her office gave to Deloitte, explained that on September 20, 2012, she flew back to “her home province”, i, Senator Wallin, in another Spreadsheet her office gave to Deloitte, explained that ‘on September 19, 2012, she flew fiom Saskatoon to Toronto at no cost to the Senate. That on September 20, 2012, she flew from Toronto to Regina after having conducted personal business. That asa result, $2,619.26 was erroneously charged to the Senate". 173, ‘The RCMP analysis of Senator Wallin’s calendars and electronic backups also revealed entries, in relation to events scheduled while Senator Wallin was in Toronto, which Senator Wallin, in her explanation to Deloitte, does not represent as Senate related. These entties, such as Football and various reminders are in my belief to be Senator Wallin’s personal affairs'*', 174. I therefore believe that on September 19, 2012, Senator Wallin flew to from Saskatoon to Toronto and did not expensed this flight to the Senate, That while in Toronto, Senator ‘Wallin may have attended to a Gluskin board of directors dinner that evening, That Senator ‘Wallin attended a Gluskin board of directors meeting the following day. That Senator Wallin then flew from Toronto to Regina on September 20, 2012 after having attended to this Gluskin board meeting. That Senator Wallin submitted this expense claim to the senate for reimbursement of expenses incurred during this trip to Toronto. [believe that by submitting the claim 1164-22216 to the Senate Finance and Procurement Directorate for "© [ Jearned this from reading the Spreadshee! that Renée Montpellier gave to Deloitte on On February 4, 2013. '*! [earned this from reading the Intella report generated from the analysis of Senator Wallin’s calendars. These are events and entries showing in the calendars that Senator Wallin’s office does not represent as Senate Business in her explanations to Deloitte. 92 reimbursement under the representation that the activities she undertook in Toronto during this this trip were “Senate Business”, Senator Wallin committed a fraud and a breach of trust. Moreover, I also believe based on my interview with Mr. Morris (CFO for Gluskin) that Senator Wallin was entitled to, and may have received reimbursement from Gluskin, for some expenses incurred during this trip, 175. Senator Wallin was reimbursed a total of $2,900.30 for this claims, Ms. Tracy Hayward of the Forensic Accounting Management Group, calculated that the entire amount ($2,900.30) was fraudulently claimed by Senator Wallin’, Conclusion Z 176. Based on the information stated in this application, I believe the following; a. Senator Pamela Wallin was appointed to the Senate of Canada, by Prime Minister ‘Stephen Harper in December 2008, representing the Province of Saskatchewan; b. Senator Wallin, since her appointment to the Senate, has maintained that her primary residence is in Wadena Saskatchewan in accordance with the The Constitution Acts, 1867 and 1982 which requires that a Senator must be a resident of the Province from which they are appointed; ©. Senator Wallin, since her appointment to the Senate, has never declared a residence in Toronto, Ontario; d, The Senate travel policy’s overarching principle is that Senators are entitled to reimbursement of expenses incurred while carrying out parliamentary functions. ‘The term parliamentary function is not clearly defined in the Senate Travel Policy'®’, The Senate Travel Policy does however define what is not considered to be “parliamentary functions”, ‘These activities are those whose related expenses cannot be claimed to the Senate under any circumstances. The Senate Travel Policy identifies these activities as follows; i, Meetings and activities related to the senator's business or private interests (c.g, board of directors’ meetings of companies or charitable organizations; meetings with clients, suppliers, and other stakeholders; etc.); ii, Participation in party activities that are purely partisan matters such as election activities; iii, Speaking engagements or attendance at fimdraising events other than those organized by the Senate; 15 Ms, Tracy Hayward calculated this amount based on my belief thatthe September 19, to September 20, 2012 y {rp to Toronto was not Senate elated. ‘his amount encompasses the airfare and ground transportation. am referring to the June 5, 2012 Senate Travel Policy. 93 iv. Attendance at training sessions, seminars, or conferences related to the senator's professional qualifications and/or personal interest but not related to Senate work; v. Attendance at book launches, art exhibits, theatre performances, concerts, te in support of artists, waiters, and performers; and vi, Speaking engagements on any topic for which the senator is receiving additional remuneration from a source outside of the Senate, €. When submitting a travel expense claim fo the Senate, Senators are required to ‘qualify the nature of the activity undertaken during the period covered by the expense claim. For confidentiality reasons, Senators arc allowed to qualify this activity using terms such as “Parliamentary Funetion or Senate Business”. By signing and submitting a claim on which “Parliamentary Function ot Senate Business” is written on, a Senator is in effect, telling the Senate Finanee and Procurement Directorate that the activities for which reimbursement are sought, are in compliance with the Senate Travel Policy; £. Scnator Wallin was an independent Director for Porter Airlines Inc, and for Gluskin Sheff & Associates, from the time when she was appointed to the Senate to June 2013, when she resigned fiom these boards; g. Asa director, Senator Wallin attended to Porter and Gluskin’s board and committee meetings in Toronto, along with board events such as dinners, Itis both Porter and Gluskin’s practice to reimburse its directors, for expenses incurred for having attended these board events; fh, RCMP investigators, through analysis and interviews, have determined that Senator ‘Wallin attended to 11 Porter board related events, in Toronto, in her capacity of a Porter divector, during the period covered by 12 of the 150 travel expense claims that are under investigation; i. RCMP investigators, through analysis and interviews, also determined that Senator Wallin attended to 13 Gluskin board related events in Toronto, in her capacity of a Gluskin director, during the period covered by 14 of the 150 travel expense claims that are under investigation; J. Moreover, the analysis of these travél expense claims revealed that Senator Wallin has qualified the activities she undertook on all 25'* claims as “Senate Business” contrary to the findings of this investigation; k. [therefore believe that Senator Wallin submitted these 25 travel expense claims to 'S | calculated 25 claims instead of 26 because Claim # T64-12101 is represented twice, once in relation to Gluskin and once in relation to Porter, the Senate Finance and Procurement Directorate for reimbursement of expenses incurred while attending to meetings and activities in Toronto, related to her private interests and to her position as a member of the board of directors for Porter Airlines and Gluskin Sheff & Associates Inc, Senator Wallin used Public funds to travel to Toronto in order to pursue these privates and business interests, Senator Wallin when confionted by an external audit, misrepresented the nature of these ‘tips to Toronto, and at time, fabricating meetings which the RCMP was able (0 determine (through interviews) to have never taken place. In doing so, I believe that Senator Wallin breached the standard of responsibility and conduct demanded of her and by the nature of her office. I believe that Senator Wallin’s conduct represent aserious and marked departure from the standards expected of a Canadian Senator, 1. Ibelieve that by submitting those 25 travel expense claims to the Senate Finance and Procurement Directorate for reimbursement under the representation that the activities she undertook were “Senate Business”, Senator Wallin committed a fraud and a breach of trust by a public officer. m, Ms. Tracy Hayward of the Forensic Accounting Management Group, calculated based on my belief, that the following amounts were fraudulently claimed by Senator Wallin; i, Senator Wallin fraudulently expensed approximately $14,291.43 to the Senate in order to attend to 11 Porter related board events in Toronto between January 12, 2010 and June 5, 2012. ii, Senator Wallin fraudulently expensed approximately $13,202.29 to the Senate in order to attend to 13 Gluskin board events in Toronto between September 17, 2009 and September 20, 2012. n. I therefore beliove that between September 17, 2009 and September 20, 2012, Senator Wallin fraudulently sought reimbursement from the Senate Finance and Procurement Directorate in the amount of approximately $27, 493,72. for expenses she incurred, while traveling to Toronto to pursue her personal and business interest, relating to her involvement with the board of directors of Porter Airlines and Gluskin Sheff & associates. 177. Ubelieve that it is necessary to obtain from Porter Airlines and from Gluskin Sheff & Associates, all documentation and data, pertaining to expense claims submitted by Senator Wallin to those companies, for having attended these 11 Porter and 13 Gluskin board related events in Toronto, This documentation and data will afford evidence relative to Senator Wallin’s travel and expense claims relating to Porter and Gluskin that she also expensed to the Senate of Canada during her travels in Toronto, In Relation to Porter Airlines: 178. Greg Sheahan (council for Porter) told me on October 21, 2014, that Loredana Ritorto 95 has possession and control of the sought documents and/or data at Portet Airlines Ine., Billy Bishop Toronto City Airport, Toronto, Ontario MSV1A1. 179. Greg Sheahan also told me on January 23, 2015 that 30 days is a sufficient time to prepare the sought documents and/or data, 180. 1 therefore request that a production order be issued to obtain from Loredana Ritorto of Porter Airlines Inc., the following documents; a, All documentation and data (expense claims, invoices, correspondences and payment information), conceming the reimbursement of all expenses to Senator Pamela Wallin for having attended a lunch with Mr, Robert Deluce (CEO of Porter Airlines Inc.) on Tuesday January 12, 2010; b. All documentation and data (expense claims, invoices, correspondences and payment information), concerning the reimbursement of all expenses to Senator Pamela Wallin for having attended the Fairmont Royal York Hotel in Toronto on ‘Tuesday January 19, 2010, relating to the presentation to Robert Deluce of the Canadian Public Relations Society’s CEO Awatd of Excellence in Public Relations; ©. All documentation and data (expense claims, invoices, correspondences and payment information), conceming the reimbursement of expenses to Senator Pamela Wallin for having attended a Board of Trade dinner on Monday January 25, 2010; 4. All documentation and data (expense claims, invoices, comespondences and payment information), concerning the reimbursement of all expenses to Senator Pamela Wallin for having attended a meeting with Mr, Robert Deluce on Saturday May 8, 2010; €. All documentation and data (expense claims, invoices, correspondences and payment information), concerning the reimbursement of all expenses to Senator Pamela Wallin for having attended Porter Airlines Ine, board meetings on; iii, Friday December 3, 2010; iv. Tuesday September 6, 2011; v. Monday December 5, 2011; vi Monday March 5, 2012; vii. Tuesday March 6, 2012; £ All documentation and data (expense claims, invoices, comespondences and payment information), conceming the reimbursement of all expenses to Senator Pamela Wallin for having attended Porter Airlines Inc, board dinners on viii, Monday June 4, 2012; and ix, Tuesday June 5, 2012. 96 In relation to Gluskin Sheff & Associates Inc; 181. David Mortis (CFO for Gluskin) told me on September 22, 2014, that he has possession and control of the sought documents and/or data at 333 Bay Street, in Toronto Ontario, 182. Mr, John Keefe (Council for Gluskin) told me on January 22, 2015 that 30 days is a sufficient time to prepare the sought documents and/or data, 183. I therefore request that a production order be issued to obtain from David Morris of Gluskin Sheff and Associates Inc., the following documents; a. All documentation and data (expense claims, invoices, correspondences and payment information), concerning the reimbursement of all expenses to Senator Pamela Wallin for having attended Gluskin Sheff & Associates Inc. board meetings on; i, ‘Thursday September 17, 2009. ii, ‘Thursday February 4, 2010. iii, ‘Thursday May 6, 2010. iv. Monday July 12, 2010 v. Thursday September 16, 2010. vi. Wednesday November 2, 2011. vii, ‘Thursday May 10, 2012, viii, Thursday September 20, 2012. ». All documentation and data (expense claims, invoices, correspondences and payment information), concerning the reimbursement of all expenses to Senator Pamela Wallin for having attended Gluskin Sheff & Associates Inc. board of Directors dinners on i, Wednesday May 5, 2010, Wednesday September 15, 2010. iii, Wednesday May 9, 2012. iv. Wednesday September 19, 2012 ¢. All documentation and data (expense claims, invoices, correspondences and payment information), conceming the reimbursement of all expenses to Senator Pamela Wallin for having attended a meeting with Gerald Sheff on Monday March 15, 2010. 184. Neither Loredana Ritorto, David Morris, Gluskin Sheff and Associates Inc, nor Porter Airlines Inc. is under investigation for the named offences. This Application is swom for the purpose of obtaining a production order pursuant to section 487.012 of the Criminal Code. 97

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