.

'

."

This is Exhibit "N'~ referred to in the Affidavit of Mark Grimes

sworn September l, 201~/~

lust of top ten

Candidates by fundsraised

Funds Raised

10
9
8
7

Kelly
Karygiannis
Grimes
Cho

6 Bailao
5 Augimeri
4 Thompson
3 Domise
2 Berardinetti
1 Lai

$
$

$
$
$
$
$

s
$
$

Cost of Fundraising

$
$
.77,~9.50 $

146,311.30
80,900.44
76,831.80

71,615.50
71,035.11
68,848.63
67,148.31
64,328.65
62,665.50

Per Cent

47,652.10
8,480.30

33%

21,832.21
17,040.11
24,658.87
20,157.25
6,187.00
25,994.74

$
$

26,623.87

23,187.39

10%
28%
22%
~4%

28%
9%
39%
41%
37%
Average Per Cent

28%

expenditure

6 of top ten candidates spent the same or more percentage

of contributions on fundraising costs
Mark Grimes spent the average per cent of contributions on fundraising costs

Statement of Campaign Income and Expenses

.
EIectlon: 2014 Mun1ctpaI Elect1on
,......
---- -:'~ l~~-~ ..-f"I
;
~-'""""
~:$'
__.. )!l..,,,F~~-:;
I~
_:ga
- ~.~--.._...:~.-~~~ -"""-~..._
---~
RJ
a.'"" . ......, ~ ' ~ ..~181iiTao
~I
"""

Loan:
Name of bank or recognized lending institution
Amount Borrowed
Income:
Total amount of all contributions
I

$70,554.37

$71,515 50

Refund of nomination filing fee

$100.00

$100.00

Sign deposit refund

$250.00

$0.00

$0.00

S0.00

$0.00

S0.00

$130.74

so.oo

Revenue from fund-raising events not deemed a contrib

Interest earned by campaign bank account
Other

ir~am~IDlnc:ome(l!oinino.~nct~.-

......

i.....:..-..:.la'fj -

~t11>lssl-,;

:~

~- ~ "ii~\61~756'

Expenses: (Note: value of contributions of goods

and services included)
Expenses subject to the spending limit
Nomination fitina fee
Inventory from previous campaign used in this
campaign

$100.00

5100.00

$696.00

$3.275.00

Advertising

$2,141 .00

$4.292.22

Brochures/flyers

$6,388.50

$7,148.48

$10,563.63

$4,802.50

Signs (including sign deposit)

Meetings hosted
Office expenses incurred until voting day
Phone and/or Internet expenses incurred until voting da
Salaries, benefits, honoraria, professional fees incurred
until voting day
Bank chan:ies Incurred until voting day

$0.00

SO.OD

$6,012.43

SS,449.16

$1 ,326.42

53,178.05

SO.DO

$0.00

$212.59

$175.76

Interest charged on loan untll voting day

$0.00

S0.00

Other

$0.00

$310.85

trOli.l!tf~a~tQJ...fiiiiHimt

--~A~~

~~s2B.-1.a2JWl

Expenses not subject to the spending limit

I

Accounting and audit

Costs of fund-raising events/activities

$2,260.00

$3,390.00

$20,157.25

$24,658.87

Voting day party I aooreciation notices

$16,431 .62

$14,564.87

Office expenses incurred after voting day

$0.00

$837.07

Phone and/or Internet expenses incurred after voting da

$0.00

$0.00

Salaries, benefits, honoraria, professional fees incurred

$0.00

S0.00

Bank charaes incurred after voting day

$0.00

$5.00

Interest charged on loan after voting day

$0.00

$000

Expenses related to recount

$0.00

$000

Expenses related to controverted election

$0.00

$0.00

Expenses related to compliance audit

$0.00

$0.00

, t;_x enses related to candidate's disability

so.oo

$0.00
$0.00

Statement of Campaign Income and Expenses

Election: Municii_iialiE~leic~~ntiolii~~]lllllllll~il~i~~
Loan:
2014

Name of bank or reco nized lendin institution

Amount Borrowed

Income:
Total amount of all contributions
Refund of nomination filin fee
events not deemed a contrib

$64,034.85

sn,349.so

$100.00

$100.00

$194.00

$0.00

$0.00

$0.00
$0.00
$0.00

Expenses subject to the spending limit

Nomination filin fee
Inventory from previous campaign used in this
campaign

$100.00

$100 00

$1.402.00

$639.50

$5.475.98

Salaries, benefits, honoraria, professional fees incurred

until voting day

$6,390.25 '

$11,598.54

$7.293 51

S9, 130.47

$10,116.60

$0.00

$000

$824.37

$9,471 .84

$1,041.52

$2,301 .35

$0.00

$0.00

$294 62
$0.00

Accountin and audit

$2,260.00

$1 ,977.50

$26,623.87

S21,832.21

$41093

da

$16,844.46 .

$2,902.06

SO.DO

$114.94

$0.00

$0.00

SO.OD

$149.55

$64.18

$0.00

$0.00

Ex enses related to recount

$0.00

SO.DO

Ex enses related to controverted election

$0.DO

SO.DO

$0.00

$0.00

Exi:>enses relate<!_ to candidate's. disability _

S0.00

S0.00

Statement of Campaign Income and

Expenses

Loan:
Name of bank or reco nized lendin institution
Amount Borrowed
Income:
Total amount of all contribtJtions
Refund of nomination filin fee

$80,900.44
$0.00
$0.00

events not deemed a contrib

$0.00
$0.00

$0.00

$0.00

Inventory from previous campaign used in this

. campaign

$6,349.44
$0.00
$7,232.00

sit

$0.00
$0.00
510,094.01

da
Salaries, benefits, honoraria, professional fees incurred
until voting day

$68350
$0.00
$1 ,769.86

$0.00

Other

$4,500.00

-~~
Expenses not subject to the spending limit
Accounting and audit

$4.500.00

Costs of fund-raising events/activities

SB,480.30

Voting day party I appreciation notices

Office expenses incurred after voting day

$0.00
57,587.11

Phone and/or Internet exDenses incurred after voting da

$114.94

Salaries, benefits, honoraria, professional fees incurred

$19,500.00

Bank charges incurred after votinQ day

Interest charged on loan after voting day

$651 .12
S0.00

Expenses related to recount

SO.OD

Exoenses related to controverted election

S0.00

Exoenses related to comoliance audit

S0.00

Expenses related to candidate's disabilily

$0.00.

Statement of Campaign Income and Expenses

Electlon: 2014 M umc
. IpaI Elecaon
f
~~
1<0:
....

--"'

' a nil?.
IW

~~
' .~ ~

=~-"""'"---- ~,7.0:-.::J:."!;;;

- .......

-~1Kell

...."- ~

. a_~,fa~f~I

Loan:
Name of bank or recognized lending institution
Amount Borrowed
Income:
Total amount of all contributions

$145,955.60

$62,372.00 '

Refund of nomination filinc:i fee

$100.00

$100.00

Sign deposit refund

$193.50

$193 50

Revenue from fund-raising events not deemed a contrib

$0.00

S0.00

Interest earned by campaign bank account

$39.60

$0.00

Other

$22.60

!r9tal~'iflbalarelhcr"

-~-iln.:n:c-,

Jf

'~

~~31:1:00

Expenses: (Note: value of contributions of goods

and services Included)

.,,

SO.DO

- l666l50

Expenses subject to the spending llmlt

Nomination filing fee
Inventory from previous campaign used in this
campaign

Advertising
Brochures/flyers
Signs (including sign deposit)
MeetinQs hosted
Office expenses inCtJrred until votina day
Phone and/or Internet expenses incurred until votinc:i da
Salaries, benefits, honoraria, professional fees incurred
until voting day
Bank charges incurred until votinQ day

S100.00

$100.00

S305.60

SO.OD

$0.00

$932.80

$11 ,034.45

$11,620.13

$1 ,143.18

$6,896.71

$0.00

$0.00

$17.493.54

$1,649.48

$1 ,14591

$124 30

$0.00

$2,783.00

s113.n

S862 87

Interest charged on loan until voting day

so.co

$0.00

Other

S0.00

$5,302.04

~~

~~

Expenses not subject to the spending limit

'

Accounting and audit

Costs of fund-raising events/activities

$2,712.00

$1,695.00

$47,652.10

523,187.39

Voting day party I aooreciation notices

$18,007.39

$6,733.00

SJ.on.so

$467.80

Phone and/or Internet exoenses incurred after volinQ da

$0.00

$0.00

Office expenses incurred after voling day

Salaries, benefits, honoraria, professional fees incurred

$0.00

$0.00

Bank chari:ies Incurred after votina day

$0.00

$281 .09

Interest charged on loan after voting day

$0.00

$0.00

Exoenses related lo recount

$0.00

$0.00

Expenses related to ccintroverted election

$0.00

$0.00

Expenses related to comoliance audit

$0.00

S0.00

Expenses related to candidate's disability

Other

$0.00

$139.99

$25,632.83

SO.OD

Statement of Campaign Income and Expenses

El ect1on: 2014 Muni c1pa
I I Eleel on

I~~~ ~~
- '$!~
Loan:

-----

ia!i.

-~

"'=='".~'ii
eui -~,.,,,, ......
~~ BMti~nae~..
-

Name of bank or recognized lending institution

Amount Borrowed
Income:
Total amount of all contributions

$68,402.25

Refund of nomination filing fee

$100.00

Sign deposit refund

$0.00

Revenue from rundraising events not deemed a contrtb

$0.00

Interest earned by campaign bank account

$0.00

Olher

t'-odlfciii&1ahmu:orn~-=r ..._.~ ~~~

$346.38
--~

'1111

,:_.

'!"""".""~~

Expenses: (Note: value of contributions of goods

and services included)
Expenses subject to the spending llmlt
Nomination filing fee
Inventory from previous campaign used in this
campaign

$100.00
$1,506.25

Advertising

$0.00

Brochures/flyers

$5,328.51

Signs (including sign deoosil)

$3,353.28 .

Meetings hosted

$0.00

Office expenses incurred unlll voting day

$9,608.59

Phone and/or Internet expenses incurred until voting da

Salaries, benefits, honoraria, professional fees incurred
until voting day
Bank charges incurred until voting day

1r"itil .

$5,800.00
$178.88

Interest charged on loan until voting day

Other

$1 .395.62

$0.00
SO.DO

llOJ~Qiitr~

Expenses not subject to the spending limit

ii&

. ,.,;1
~1r="'-=oo

Accounting and audit

Costs of fund-raising events/activities

SS,187.00

Voting day party I aooreclation notices

$17,057.36

$5,390.00

Office expenses incurred after voling dav

$0.00

Phone and/or Internet expenses incurred after voting da

$0.00

Salaries. benefits, honoraria, crofessional fees incurred

$0.00

Bank charges incurred after voting day

$0.00

Interest charged on loan after voting day

$0.00

Expenses related lo recount

$0.00

Exoenses related to controverted election

SO.OD

Expenses related lo compliance audit

$0.00

Expenses related to candidate's disability

Other

$000

Statement of Campaign Income and Expenses

Election: 2014 Municl al Election

Loan:
Name of bank or rec
Amount Borrowed

nized lendin institution

Income:
Total amount of all contributions

$76,481 .80

Refund of nomination filin fee

$67,148.31

$100.00

so 00

$250.00

$0.00

S0.00

$000

$0.00

$0.00

$100.00

$100.00

$2,531 .80

$0.00

$200.00

$1,706.91

Expenses: (Note: value of contributions of goods

and services included)

Inventory from previous campaign used in this

campaign
1

Advertisin

da
da
Salaries, benefits, honoraria, professional fees incurred

until voting day

Other

$5,809.60

$4,849.42

$16,059.30

$7,262 76

$0.00

$403.62

$8,158.12

$9,928.44

$838 26

$2,785.36

$0.00

$3.000.00

$273.08

$2,142.99

$0.00

$000

$1,220.08

$0.00

-~~1?"". ~ ~
Expenses not subject to the spending limit
Accounting and audit

$2,712.00

$2,487.00

Costs of fund-raising events/activities

$17,040.11

$25,994.74

Voting day party I aooreciation notices

$2,545.02

$5,126 93

Office excenses incurred after voting day

$3.541.84

$191 .74

$379.84

$815 70

Phone and/or Internet expenses incurred after voting da

Salaries, benefits, honoraria, professional fees Incurred

S0.00

$668.13

$344.48

$77.35

Interest charged on loan after voting day

$0.00

$0.00

Expenses related to recount

S0.00

$0.00

Exoenses related to controverted election

$0.00

$0.00

Exoenses related to compliance audit

S0.00

$000

Bank charges incurred after votina dav

Expenses rel(tled lo candidate's disability

Other

$0.00
514,000.70

IN THE MATTER OF AN APPLICATION BY MICHAEL CRAIG

UNDER THE MUNICIPAL ELECTIONS ACT, 1996 (THE HACT") TO THE
CITY OF TORONTO CO:MPLIANCE AUDIT COMMITTEE IN RESPECT
OF THE FINANCIAL STATEMENT OF MARK GRIMES, CANDIDATE
FOR ELECTION TO TORONTO CITY COUNCIL, WARD 6 (THE
"CANDIDATE").

AFFIDAVIT OF CHRIS SZARKA

1, CHRIS SZARKA, ot the City of Toronto, in the Province of Ontario, MAKE OATH

AND SAY:
I.

I am the President and sole owner Fifth Ground Entertainment Inc. ("FOE"), and, as such,

have knowledge of the matters contained in this Affidavit. I make this Affidavit to provide certain
infonnation in connection with the Application described above and for no improper purpose.

2.

FOE is an entertainment production company that develops and produces its own content,

as well as performs service production for other companies.

3.

My wife and I are long-time friends and supporters of Councillor Grimes and volunteered

for his 2014 election campaign, including by delivering flyers and attending events. I also
suggested to Councillor Grimes that he hire Mr. Matthew Lochner ("Mr. Lochner") to provide
videography and editing services at a lower rate than that charged by FGE. I further suggested that
he hire Mr. James Heaslip to provide photography services, and a Humber College student to
perform videography for the voting day party.

4.

FGE routinely retains the services of other professionals in the course of completing its

various projects. Staffing decisions are made on an ad hoc basis depending on the scope of the
project, the skills required, and whether the project is a union or a non-union shoot.

5.

I perfonn the role of Producer on all FGE projects. As Producer, l decide when FGE will

contract with outside professionals.

6.

I have retained the services of Mr. Lochner on numerous occasions and still do so from

time to time. On every occasion, his association with FGE was on a contract basis for a particular
project.

7.

l have reviewed the invoices that Mr. Lochner rendered lo Councillor Grimes, which arc

attached to this Affidavit as Exhibit A. The rates reflected Lherein are reflective of the rates FOE
would pay for his services.

8.

9.

In 2014, FGE paid the following rates for the services of Mr. Lochner:

(a)

Approximately $31.00 per hour for editing; and

(b)

Approximately $500.00 per 8-hour day for videography/camera work.

At no time was Mr. Lochner required to work exclusively for FGE. Mr. Lochner has

always been free to take on projects independent of his ad hoc association with FGE.

10.

As stated above, I am the sole owner of FGE. At no time did Mr. Lochner have an

ownership interest in FGE, nor was he ever a upartner".

SWORN BEFORE ME at the City of

T~r'fto, in the P(o~ince of Ontario on

l ~...,,.,..3..S...t~ 2015

er for aking Affidavits

~~

l4ti

f<

'

'

This is Exhibit "A" referred to in the Affidavit of Chris Szarka

sworn September 1, 2015

*y1lle.J. '!Ta-: Mark Grimes

2014 Campaign

*Dat-e..:

10 I 31 I 2014

*9~#~0111 '

*J:l-c:T'!T#:

*"P~ #:

END CHANNEL CARD/

820927804RT0001
Mark Grimes

$930

30hrs

EDITING SERVJCES

$120.90
.

Mt:ltthl!!W l e><:l'lnet

3 175 Madison Ave

MSR 2C6

$1050.90

j locnoer.matt.~w@>gmall.com ~ (SOSJ 5997216

1:11.ll.eJ '!Ta-~ Mark Grimes

2014 Campaign

*VR.te. :

10 / 31 I 2014

*9~#:0120

*J/-49"#:

*'P~#:

711UeJ

820927804RT0001

MarkGrimes.

'!TafL

CAMERA WORK.
MULTIPLE l.OCATIONs

1DAY.

$500

$65
$565

tvlatthew Lochner

3 17S Madison Aw.

f. M5R 2c6 Jlochner.m~nticw@gmarl.c:om j (905) 5997216

'

'

IN THE MATTER OF AN APPLICATION BY MICHAEL CRAIG

UNDER THE MUNICIPAL ELECTIONS ACT, 1996 (THE "ACT") TO TI-tE
CITY OF TORONTO COMPLIANCE AUDIT COMMITTEE IN RESPECT
OF THE FINANCIAL STATEMENT OF MARK GRIMES, CANDIDATE
FOR ELECTION TO TORONTO CITY COUNCIL, WARD 6 (THE
"CANDIDATE").

AFFIDAVIT OF SHEILA PAXTON

1,

SHEILA PAXTON, of the City of Toronto, in the Province of Ontario, MAKE

OATH AND SAY:

I.

I was a volunteer on Counci1Jor Mark Grimes' 2014 election Campaign and as such have

knowledge of the matters contained in this Affidavit. I make this Aftidavit to provide certain
information in connection with the Application described above and for no improper purpose.

2.

At no time did I make a statement to Mr. Russ Ford ("Mr. Ford") in regards to my

volunteering on Councillor Grimes' 2014 Campaign indicating that l needed a job, nor do I recall
Mr. Ford making any statement to me that "we all have lo eat", as alleged.

3.

The reason I volunteered for Councillor Grimes' Campaign is that I was advised by my

psychiatrist treating me for a major depressive disorder that ( needed to do volunteer work of some
nature to help with my mental health.

4.

Both my employer, the City of Toronto Council Support Service and Manulife Insurance,

who monitors my eligibility for long-term disability, were advised of the necessity for me to do
volunteer work

we1=e

-ach iseci ef.the ne1:essity fer me-

tldo volunteer work and aware of my

involvement as a volunteer in Councillor Grimes' Campaign.

5.

Contrary to Mr. Craig's allegations, at no time have I worked as a campaign manager. In

fact, I have never worked on any political campaign in a paid position. My roles in previous
campaigns, which included canvassing has been strictly on a volunteer basis. and involved
canvassing, data input and local issues monitoring.

SWORN BEFORE ME at the City of

... IP Tor~ito n t~royince of Ontario on
]U....(... .. . ...
~O 15

J.i?/f

This is Exhibit "A" referred to in the Affidavit of Sheila Paxton

sworn ................................... , 2015 .

Commissioner for Taking Affidavits (or as may he)