T-2191-04: Written Supplementary
Representations of the Proposed Intervener Tom Jackson
Court File No. T-2191-04
Federal Court - Trial Division
Arthur Mainil (Plaintiff)
The Canadian Wheat Board and Meyers Norris Penny (Defendants)
Written Supplementary Representations of
the Proposed Intervener Tom Jackson
Part I -- Facts
- Tom Jackson is a 2004 candidate for the
position of director of The Board in district 4.
- Further, Tom Jackson was a candidate for the
position of director of The Board in district 4 in 2000, and, in the
first set of elections, in district 1 in 1998.
- Tom Jackson has had numerous conversations
with the Board Election Coordinator Peter Eckersely and Board
management over the voter list's creation and composition over the
course of the 2000, 2002, and 2004 Board Director's Elections.
Part II -- Subject
of Proposed Intervener
- Tom Jackson proposes there is a need for the
Honourable Court to define and discover why exactly the Canadian Wheat
Board and Meyers Norris Penny required valid permit holders to swear
false Statutory Declarations before they were allowed to participate
in the 2004 election.
Part III -- Submissions
- The proposed intervener Tom Jackson wishes to
submit that the Canadian Wheat Board and Meyers Norris Penny first
agreed to send out ballot packages to 2004-05 "new" permit
holders without Statutory Declarations. This opinion was offered by
Gwen of the Election Coordinators office, as recorded in Exhibit
"C" to the Affidavit of Tom Jackson. It is further
submitted, as indicated in Exhibit "C" the Election
Coordinator then later required an unreasonable action by
"new" valid permit holders to actually participate in the
2004 Directors Election, a requirement to swear a false Statutory
Declaration. It is then submitted that more producers than normal did
not take out Canadian Wheat Board permits in 2002 and 2003 because of
droughts and high non-board domestic feed grain prices. It is finally
submitted that these noted problems create a significant issue that
needs to be dealt with by this Honourable Court.
Part IV -- Relief
- The proposed intervener Tom Jackson request
the Honourable Court clarify exactly why Statutory Declarations were
requested when a producers were already a valid permit holders. The
Proposed Intervener requests the Honourable Court determine how many
producers were affected by this procedure. The Proposed Intervener
requests the Honourable Court determine how many other new producers
with valid permits were not sent ballot packages, that could have been
voters if they had been treated fairly.
- The proposed intervener Tom Jackson requests
the Honourable Court clarify whether the producers ballots represented
in Statutory Declarations (Exhibits "E", "F", and
"G"); resulted in 3 "Scannable ballots" being
present today at the Election Coordinator's facilities. In the opinion
of the Honourable Court, are these producer's "scannable
ballots" still valid votes for tabulation, if the 2004 ballot
tabulation actually proceeds?
All of which is respectfully submitted this 17th
day of December 2004.
(Signed by Thomas R. Jackson)