Our group’s filed court documents are uploaded to this archive:
https://ln2.sync.com/dl/af1c6c880/tt3hs5q6-p9zuqp5y-ytiy9u39-yh9zvvhi
A good introduction to our case that is not too hard for the layperson to read is the Memorandum of Argument. This presents our group’s legal argument for why we believe the Court should grant the interim injunction, which is scheduled to be heard on January 18, 2021. The injunction application includes the same points that are in our main application, the goal of which is to have the May 1, 2020 OIC overturned.
To access the Memorandum of Argument, go to the sync.com archive and follow these links:
3. Interim Injunction Application (January 18, 2021) -> Applicant’s Motion Record -> Motion Record (T-677-20).pdf
There are over 1500 pages in the Motion Record pdf. To get to the Memorandum of Argument go to Tab 18 (or page 923).
A history of the significant steps in our case:
| Date | Description | |
| – | 2020-11-27 | Applicant filed Motion Record in connection with the January 18, 2021 injunction |
| 2020-11-20 | Letter from Applicant… Pursuant to the Order of the Court dated October 7, 2020, Applicants have decided to rely on the written submissions filed by the Applicants in file T-577-20 -scanned to the Case Management Judge | |
| 2020-11-19 | Written directions received from the Court: Associate Chief Justice Gagné dated 19-NOV-2020 (see Court Orders in Court Documents archive) | |
| – | 2020-11-18 | Associate Chief Justice Gagné: case management conference at 1:00 p.m. (Eastern) by Zoom videoconference |
| – | 2020-11-13 | Letter from Applicants in the T-677-20 matter dated 13-NOV-2020 in response to the November 12, 2020 letter from Bruce Hughson, Counsel for the Department of Justice |
| – | 2020-11-12 | Letter from Applicant dated 12-NOV-2020 requesting an order from the Court allowing the service and filing of the following: (i) a Supplemental Affidavit from Rick Timmins, the founder of Magnum Machine Ltd. and an Applicant in T-577-20; (ii) a Reply Affidavit from Travis Bader, an expert who previously filed an Affidavit in T-677-20; and (iii) a right of Reply Written Arguments for each of the Injunction Applicants following receipt of the Respondent’s Motion Record |
| – | 2020-11-12 | Letter from Respondent dated 12-NOV-2020 opposing the Applicant’s request to file Reply submissions and requesting that, if Reply Submissions are allowed, they should be allowed to file their own sur-reply. The letter further does not object to the filing or Mr. Timmins’ supplemental affidavit, but does oppose the filing of the Reply Affidavit of Mr. Bader |
| – | 2020-11-03 | Associate Chief Justice Gagné directed “The Court will entertain the Notice of objection in file number T-677-20 and the Motion to object to expert in file number T-735-20 at the hearing of Motions for injunction that will be held on January 18, 2021.” |
| 2020-11-05 | Cross-examinations of Murray Smith, Adrienne Deschamps | |
| – | 2020-10-29 | Cross-examination of Murray Smith |
| – | 2020-10-30 | Cross-examination of Murray Smith |
| 39 | 2020-10-27 | Affidavit of Travis Bader sworn on 22-OCT-2020 on behalf of the Applicants in reply to the Affidavit of Murray Smith affirmed October 9, 2020 with Exhibits |
| 38 | 2020-10-27 | Notice of Objection on behalf of the Applicants (re Respondent’s Proposed Expert Witness) filed on 27-OCT-2020 |
| 37a | 2020-10-14 | Affidavit of Adrienne Deschamps served upon Applicant by email on 14-OCT-2020 with Exhibits |
| 35a | 2020-10-09 | Affidavit of Murray Smith found in file T-735-20 |
| – | 2020-10-06 | Case management conference (35 min. ZOOM video) |
| 32 | 2020-09-23 | Affidavit of Travis Bader sworn on 18-SEP-2020 on behalf of Applicants in support of Motion Doc. No. 21 with Exhibits a-c |
| 31 | 2020-09-23 | Affidavit of Richard Delve sworn on 10-SEP-2020 on behalf of Applicants in support of Motion Doc. No. 21 |
| 30 | 2020-09-23 | Affidavit of Philip Alexander McBride sworn on 10-SEP-2020 on behalf of Applicants in support of Motion Doc. No.21 with Exhibits |
| 29 | 2020-09-23 | Affidavit of Peter Minuk sworn on 15-SEP-2020 on behalf of Applicants in support of Motion Doc. No. 21 with Exhibits |
| 28 | 2020-09-23 | Affidavit of Nils Robert Ek sworn on 10-SEP-2020 on behalf of Applicants in support of Motion Doc. No. 21 with Exhibits |
| 27 | 2020-09-23 | Affidavit of Michael Doherty sworn on 11-SEP-2020 on behalf of Applicants in support of Motion Doc. No. 21 with Exhibits |
| 26 | 2020-09-23 | Affidavit of Mark Nichol sworn on 11-SEP-2020 on behalf of Applicants in support of Motion Doc. No. 21 |
| 25 | 2020-09-23 | Affidavit of Lindsay Jamieson sworn on 10-SEP-2020 on behalf of Applicants in support of Motion Doc. No. 21 with Exhibits |
| 24 | 2020-09-23 | Affidavit of Christian Rydich Bruhn sworn on 10-SEP-2020 on behalf of Applicants in support of Motion Doc. No. 21 with Exhibits |
| 23 | 2020-09-23 | Affidavit of Andre Perrault on behalf of Applicants in support of Motion Doc. No. 21 with Exhibits a-k |
| 21 | 2020-09-23 | Notice of Motion on behalf of Applicant returnable at Special Sitting in Toronto on 18-JAN-2021 to begin at 10:00 for an Order for interim relief pursuant to R373 and other relief |
| 20 | 2020-09-16 | Order by Associate Chief Justice Gagné: 1. The style of cause is amended with immediate effect, by removing the Royal Canadian Mounted Police as a Respondent from the Style of cause. |
| – | 2020-08-26 | Second case management meeting (55 min. teleconference) for cases T-569-20, T-577-20, T-581-20, T-735-20 and T-905-20 |
| – | 2020-07-29 | First case management meeting (1h25min teleconference) for cases T-569-20, T-735-20, T-577-20, T-581-20, T-677-20 |
| 11 | 2020-07-20 | Affidavit of Dr. Wendy Cukier sworn on 17-JUL-2020 contained within a Motion Record on behalf of Proposed Intervener (Coalition for Gun Control) with Exhibits |
| 7 | 2020-07-10 | Consent on behalf of the Applicants to electronic service of all documents in this application that are not required to be served personally. |
| 6 | 2020-07-06 | Order rendered by Chief Justice Crampton: 1. This proceeding shall continue as a specially managed proceeding. 2. Pursuant to Rule 383, Associate Chief Justice Jocelyne Gagné is assigned as Case Management Judge in this matter.” |
| 2 | 2020-07-03 | Amended notice of application with regard to Judicial Review (Order in Council 2020-298) |