LAM) RN File No: 23,461 Attention: Ian Aikenhead, QC. September 7, 2017 Fleming & Associates 4571 Marine Avenue Powell River, BC V8A 2K5 Attention: Robert Hainsworth Dear Sir: Re: Wilson v. HMTQ et al Jan Aikenhead, Q.C* 316-2800 East 1" Avenue Andrea Jones ‘Vancouver, BC V5M 4P3 Joseph Wong* ‘Tel: 604-253-4525 ‘Annabel Kim* Fax: 604-253-1080 Dustin Paul Betony Rowland www.amylaw.ca Mark Trischuk ‘Alex Choi Michael Moscovich (Ret) ‘e-mail: gikenhead@amilaw.ca Direct Line: 604-215-2833 By Email Please find enclosed for service upon you the Response to Civil Claim filed September 7, 2017 on behalf of the Defendant Bruce Ralston, Kindly acknowledge service in the usual manner. Yours very truly, AMILAW Ian Aikenhead, Q.C. Aes enc. cc: client ‘U\Monika ITIGATION MISCiRalsto, Brucel.T Hainsworth Sep 7, 2017 (w RCC). wpao7-Sep-1T No. $2600 REGIST Powell River Registry IN THE SUPREME COURT OF BRITISH COLUMBIA BETWEEN: GORDON FREDRICK DAVID WILSON PLAINTIFF AND: HER MAJESTY THE QUEEN IN RIGHT OF THE PROVINCE OF BRITISH COLUMBIA BY OFFICER OF THE GOVERNMENT, THE HONOURABLE JOHN HORGAN, PREMIER OF BRITISH COLUMBIA, HER MAJESTY THE QUEEN IN RIGHT OF THE PROVINCE OF BRITISH COLUMBIA BY OFFICER OF THE GOVERNMENT, THE HONOURABLE BRUCE RALSTON, MINISTER OF JOBS, TRADE AND TECHNOLOGY, JOHN JOSEPH HORGAN, BRUCE H. RALSTON AND RACHEL A. BLANEY DEFENDANTS RESPONSE TO CIVIL CLAIM Filed by: Bruce H. Ralston (the “defendant”) Part 1: RESPONSE TO NOTICE OF CIVIL CLAIM FACTS Division 1 — Defendant's Response to Facts 1, The facts alleged in paragraphs 2 to 8 of Part | of the notice of civil claim are admitted. 2. The facts alleged in paragraphs 16 to 37 inclusive of Part 1 of the notice of civil claim are denied, 3. The facts alleged in paragraph 1 and paragraphs 9 to 15 of Part 1 of the notice of civil claim are outside the knowledge of the defendant Bruce H. Ralston (“Ralston”). Division 2 - Defendant's Version of Facts 1, Paragraph 17, paragraph 19, 20 and paragraphs 22 to 37 inclusive of Part 1 of the notice of civil claim: a. do not disclose a reasonable claim; and/or-2- b. are unnecessary, frivolous, or vexatious; and/or ©. may prejudice or delay the fair trial or hearing of this action; and/or 4. are otherwise an abuse of the process of this court and should therefore be struck out, 2. Further, and in the alternative, if the defendant Ralston made any statements about the plaintiff, those statements were not capable of being defamatory of the plaintiff, and were not in fact defamatory of the plaintiff, as alleged or at all. 3. Further, and in the alternative, any statements about the plaintiff were fully protected by the defence of fair comment and/or the defence of qualified privilege. 4, Further, and in the alternative, the defendant's statements were made without malice on a matter of public interest on the basis of information from apparently reliable and qualified sources within the British Columbia government, and were protected by the defence of responsible communication in all the circumstances. 5. Further, and in the alternative, the defendant Ralston expressly denies that the plaintiff has suffered injury, loss or damage as alleged or at all. Division 3 - Additional Facts 1. Further, and in the altemative, if the plaintiff has suffered injury, loss or damage as alleged or at all, which is not admitted but expressly denied, the defendant Ralston published a full and fair retraction and apology on August 7, 2017, which was given wide dissemination in the print, broadcast and online media, Further, in response to a request by the plaintiff on August 9, 2017, Ralston provided a further full and fair retraction and apology of the words complained of on August 10, 2017, and further disseminated that at the specific request of the plaintiff, and that further full retraction and apology was given wide dissemination in the print broadcast and online media. Part 2:RESPONSE TO RELIEF SOUGHT 1, ‘The defendant Ralston consents to the granting of the relief sought in paragraphs NIL of Part 2 of the notice of civil claim.-3- 2. The defendant Ralston opposes the granting of the relief sought in paragraphs 1. a. to 1. i. inclusive of Part 2 of the notice of civil claim. 3. The defendant Ralston takes no position on the granting of the relief sought in paragraphs NIL of Part 2 of the notice of civil claim. Part 3:LEGAL BASIS 1. The common law including the common law relating to defamation, misfeasance in public office and damages. 2. The common law relating to pleading claims for defamation, misfeasance in public office and damages. 3. The notice of civil claim does not comply with Rule 3-/(2) or Rule 3-7 of the Supreme Court Civil Rules and the common law. 4, Paragraph 1.(f) of Part 2 of the notice of civil claim violates Rule 3-7(14) of the Supreme Court Civil Rules and the common law. 5. Rule 9-5(1) and the inherent jurisdiction authorizes the Court to strike the offending paragraphs of the notice of civil claim. Defendant's address for service: #316 2800 East 1 Avenue Vancouver, BC VSM 4P3 Fax number address for service (if any): 604-253-1080 E-mail address for service (if any): None Date: September 7, 2017 Ian Aikenhead, Q.C. AMJLAW Rule 7-1(1) of the Supreme Court Civil Rules states: (1) Unless all parties of record consent or the court otherwise orders, each patty of record to an action must, within 35 days after the end of the pleading period, (@) prepare a list of documents in Form 22 that lists @ all documents that are or have been in the party’s possession or control and that could, if available, be used by any party at trial to prove or disprove a material fact, and (ii) all other documents to which the party intends to refer at trial, and (b) serve the list on all parties of record.