Applications & Motions

Written Final Submissions

Written Submission - K Edwards-S Sinclair

Written Submission - MGEU

Written Submission - D Faria

Written Submission - R Dick

Written Submission - D Verrier

Amended Joint Written Submissions - Authorities and ANCR (July 17 2013)

Written Submission - AMC-SCO

Written Submission - ICFS

Written Submission - General Child and Family Services Authority

Written Submission - Department

Written Submission - University of Manitoba

Written Submission - MMF

Written Submission - Ka Ni Kanichihk

Written Submission - Aboriginal Council of Winnipeg

Applications for Standing – June 28 and 29, 2011

Applications for standing were heard on June 28 and 29, 2011:

 

Applications for Stated Case

January 31, 2012
Request for Commissioner to state a case in writing to the Manitoba Court of Appeal (34 KB PDF)

February 3, 2012
Originating Notice of Motion of Manitoba Government Employees’ Union [Court of Appeal]

February 8, 2012
Notice of Motion of Manitoba Attorney General [Court of Appeal]
(Note: A copy of other material filed by the parties in this matter can be obtained through the Manitoba Court of Appeal)

 

August 3, 2012
Request for Commissioner to state a case in writing to the Manitoba Court of Appeal (39.5 KB PDF)

Authorities/ANCR Notice of Motion – August 16, 2012

Affidavit of Sandie Stoker (No. 1) – August 15, 2012

Affidavit of Sandie Stoker (No. 2) – August 15, 2012

Motion Brief of Authorities/ANCR – August 16, 2012

 

Publication Ban/Redaction Motions – July 4, 5 and 6, 2012

Motions have been made by:

The Canadian Union of Public Employees (CUPE);
The Department of Family Services and Consumer Affairs (now known as the Department of Family Services and Labour);
The General Child and Family Services Authority, First Nations of Northern Manitoba Child and Family Services Authority, First Nations of Southern Manitoba Child and Family Services Authority and Child and Family Services All Nation Coordinated Response Network;
Intertribal Child and Family Services (ICFS);
Potential Witnesses SOR1#, SOR# 2, SOR#4, PHN & TM;
Potential Witnesses SOR#5 and SOR#6;
Potential Witness SOR#8; and
University of Manitoba.

These motions are scheduled to be heard at 9:30 a.m. on Wednesday, Thursday and Friday, July 4, 5 and 6, 2012 in the
Pan Am Room at the Winnipeg Convention Centre, 375 York Avenue, Winnipeg, Manitoba.

The Commissioner will issue his decision on these motions at 9:30 a.m. on Thursday, July 12, 2012 in the Pan Am Room at the Winnipeg Convention Centre, 375 York Avenue, Winnipeg, Manitoba.

The following materials have been filed in support of the motions:

CANADIAN UNION OF PUBLIC EMPLOYEES (CUPE)

Notice of Motion
Affidavit of Scott Clark affirmed April 4, 2012

DEPARTMENT OF FAMILY SERVICES AND CONSUMER AFFAIRS (now known as THE DEPARTMENT OF FAMILY SERVICES AND LABOUR)

Notice of Motion dated April 3, 2012

THE GENERAL CHILD AND FAMILY SERVICES AUTHORITY, FIRST NATIONS OF NORTHERN MANITOBA CHILD AND FAMILY SERVICES AUTHORITY, FIRST NATIONS OF SOUTHERN MANITOBA CHILD AND FAMILY SERVICES AUTHORITY AND CHILD AND FAMILY SERVICES ALL NATION COORDINATED RESPONSE NETWORK

Notice of Motion dated April 11, 2012
Affidavit of Bruce Rivers sworn/affirmed March 30, 2012

Affidavit of Cheryl Regehr sworn/affirmed March 30, 2012

Supplemental Affidavit of Bruce Rivers sworn/affirmed April 11, 2012
Supplemental Affidavit of Cheryl Regehr sworn/affirmed April 11, 2012
Motion Brief dated April 11, 2012
Reply Motion Brief dated June 25, 2012
Reply Brief List of Authorities – Tabs 1-11
Reply Brief List of Authorities – Tab 12
Reply Brief List of Authorities – Tab 13

MANITOBA GOVERNMENT EMPLOYEES UNION (MGEU)

MGEU Letter to All Media Outlets dated August 22, 2011 (110 KB PDF)
Notice of Motion dated August 18, 2011 (64 KB PDF)
Affidavit of Janet Kehler affirmed June 27, 2011 (522 KB PDF)
Motion Brief (203 KB PDF)

Supplementary Affidavit of Janet Kehler affirmed April 4, 2012

Transcript of cross-examinaton of Janet Helen Kehler on May 22, 2012

Affidavit of Evelyn Wotherspoon sworn April 13, 2012

Transcript of cross-examinaton of Evelyn Wotherspoon on May 22, 2012

Affidavit of Elizabeth McLeod sworn April 3, 2012

Reply Brief dated June 21, 2012

POTENTIAL WITNESSES SOR#1, SOR#2, SOR#4, PHN & TM

Notice of Motion dated April 11, 2012
Affidavit of Regan Spencer affirmed April 10, 2012
Affidavit of Lynda Tjaden affirmed April 10, 2012
Motion Brief dated April 11, 2012

WITNESS SOR#3

Notice of Motion dated June 1, 2012
Motion Brief dated June 6, 2012
Affidavit of Tim Herkert affirmed June 1, 2012

POTENTIAL WITNESSES SOR#5 and SOR#6

Notice of Motion dated April 4, 2012
Affidavit of Alison McCullough-Butchart sworn April 4, 2012
Motions Brief dated April 4, 2012

POTENTIAL WITNESS SOR#7

Notice of Motion dated June 8, 2012
Affidavit of Alison McCullough-Butchart sworn on June 8, 2012

UNIVERSITY OF MANITOBA

Affidavit of Gwendolyn M. Gosek sworn April 4, 2012

Transcript of cross-examinaton of Gwendolyn Mildred Gosek on June 1, 2012

Motion Brief re Motion to Strike the Affidavit of Gwendolyn Gosek dated June 22, 2012

ASSEMBLY OF MANITOBA CHIEFS AND THE SOUTHERN CHIEFS ORGANIZATION

Motion Brief

Intertribal Child and Family Services

Notice of Motion dated April 4, 2012
Affidavit of Shirley Cochrane affirmed April 3, 2012
Transcript of Cross-examination of Shirley Anne Cochrane on May 24, 2012
Motion Brief dated April 4, 2012

KIMBERLY-ANN EDWARDS and NELSON DRAPER STEVE SINCLAIR

Motion Brief

BROADCASTING CORPORATION, CTV WINNIPEG, GLOBAL WINNIPEG AND THE WINNIPEG FREE PRESS

Motion Brief
Book of Authorities
Affidavit of Allison Lamontagne sworn on May 11, 2012
Affidavit of Allison Lamontagne sworn on May 22, 2012
Affidavit of Cecil Rosner sworn on May 9, 2012
Transcript of Cross-examination of Cecil Rosner on May 28, 2012
Affidavit of Michael Bear sworn on May 11, 2012
Transcript of Cross-examination of Michael Bear on May 30, 2012
Affidavit of Shavonne Hastings sworn on May 10, 2012
Transcript of Cross-examination of Shavonne Hastings on May 30, 2012
Notice of Motion to Strike the Affidavit of Elizabeth McLeod dated June 2012
Notice of Motion to Strike the Affidavit of Gwendolyn Gosek dated June 2012
Notice of Motion to Strike the Affidavit of Janet Kehler dated June 2012
Notice of Motion to Strike the Affidavit of Scott Clark dated June 2012
Notice of Motion to Strike the Affidavit of Bruce Rivers dated June 2012
Notice of Motion to Strike the Affidavit of Evelyn Wotherspoon dated June 2012
Notice of Motion to Strike the Affidavit of Shirley Cochrane dated June 2012

 

Preliminary Motions – July 24, 2012

ASSEMBLY OF MANITOBA CHIEFS AND THE SOUTHERN CHIEFS ORGANIZATION

Notice of Motion dated July 4, 2012

THE GENERAL CHILD AND FAMILY SERVICES AUTHORITY, FIRST NATIONS OF NORTHEN MANITOBA CHILD AND FAMILY SERVICES AUTHORITY, FIRST NATIONS OF SOUTHERN MANITOBA CHILD AND FAMILY SERVICES AUTHORITY AND CHILD AND FAMILY ALL NATION COORDINATED RESONSE NETWORK

Notice of Motion dated July 4, 2012
Motion Brief
     Tab 1
     Tab 2
     Tab 3
     Tab 4
     Tab 5
     Tab 6
     Tab 7
Reply Motion Brief dated July 24, 2012
     Tab 1
     Tab 2
     Tab 3
     Tab 4
     Tab 5
     Tab 6
     Tab 7
     Tab 8

MANITOBA MÉTIS FEDERATION AND THE MÉTIS CHILD AND FAMILY SERVICES AUTHORITY INC.

Application for Standing dated July 17, 2012

COMMISSION COUNSEL

Motion Brief dated July 19, 2012

 

Motion – February 26, 2013

INTERTRIBAL CHILD AND FAMILY SERVICES
Notice of Motion dated February 22, 2013
Affidavit of Bobbi Rachelle Lee affirmed February 22, 2013
     Exhibit A
     Exhibit B
     Exhibit C
     Exhibit D
     Exhibit E

Publication Ban Motions - March 11, 2013

DOE #1, DOE #2, DOE #3, DOE #4
Notice of Motion - February 5, 2013
Affidavit – Doe #1 sworn February 5, 2013
Affidavit – Doe #2 sworn February 5, 2013
Affidavit – Doe #3 sworn February 5, 2013
Affidavit – Doe #4 sworn February 5, 2013
Motions Brief dated February 5, 2013

DOE #3
Notice of Motion dated February 13, 2013
Affidavit of Kalyn Bomback sworn February 13, 2013
Motions Brief dated February 14, 2013

DOE #1, DOE #2, DOE #3, DOE #4
Supplemental Motions Brief dated February 25, 2013
     Tab 1
     Tab 2
     Tab 3
     Tab 4

INTERTRIBAL CHILD AND FAMILY SERVICES
Motion Brief dated February 22, 2013
Affidavit of Bobbi Rachelle Lee affirmed February 22, 2013
     Exhibit A
     Exhibit B
     Exhibit C
     Exhibit D
     Exhibit E
Supplemental Motion Brief dated March 7, 2013
Book of Documents and Authorities Index Volume I
     Tab 1
     Tab 2
     Tab 3
     Tab 4
     Tab 5
     Tab 6
     Tab 7
     Tab 8
     Tab 9
     Tab 10
Book of Documents and Authorities Index Volume 2
     Tab 11
     Tab 12
     Tab 13
     Tab 14
     Tab 15
     Tab 16
     Tab 17
     Tab 18
     Tab 19
     Tab 20
     Tab 21

ASSEMBLY OF MANITOBA CHIEFS AND THE SOUTHERN CHIEFS ORGANIZATION
Motion Brief
     Tab 1
     Tab 2
     Tab 3
     Tab 4
     Tab 5

Applications for Standing – April 15, 2013

Ka Ni Kanichihk Inc – March 12, 2013
Aboriginal Council of Winnipeg Inc. – March 14, 2013

 

© 2011 Commission of Inquiry into the Circumstances Surrounding the Death of Phoenix Sinclair