bc hydro site c injunction: affidavit #1 of patrick hayes

143
r7 m ^^ This is the 1st Affidavit of Patrick Hayes in this case and was made on January 29,2016 No. S-160488 Vancouver Registry BETWEEN: AND: IN THE SUPREME COURT OF BRITISH COLUMBIA BRITISH COLUMBIA HYDRO AND POWER AUTHORITY PLAINTIFF KEN BOON, ARLENE BOON, VERENA HOFMANN, ESTHER PEDERSEN also known as Rachel Blatt, HELEN KNOTT, YVONNE TUPPE^ JANE DOE, JOHN DOE and all other persons unknown to the Plaintiff occupying, obstructing, blocking, physically impeding or delaying access, at or in the vicinity of the area in and around the south bank of the Peace River upstream (west) of the Moberly River, including the area in and around the heritage site known as Rocky Mountain Fort DEFENDANTS AFFIDAVIT #1 OF PATRICK HAYES I, Patrick Hayes, of 2900 - 550 Burrard St, in the City of Vancouver, Province of British Columbia, lawyer, SWEAR THAT: 1. I am an associate in the law firm ofFasken Martineau DuMoulin LLP, counsel for British Columbia Hydro and Power Authority ("BC Hydro") in the matter herein, and as such have personal knowledge of the facts hereinafter deposed to in this affidavit, except where stated to be on information and belief, in which case I verily believe them tobe true. 2. I viewed a number of news articles and social media posts that contain information about the Defendants opposition to the Site C Clean Energy Project (the "Project ) and what is described as a protest camp at the site of the Rocky Mountain Fort on the south bank of the Peace River ("Protest Camp"). Some of the websites I viewed contained videos and audio files. 240150.00142/90618263.4

Upload: jonny-wakefield

Post on 13-Apr-2016

31 views

Category:

Documents


0 download

DESCRIPTION

An injunction, filed by BC Hydro, detailing how information was gathered on campers blocking construction of the Site C dam, including Facebook and Instagram posts and news articles.

TRANSCRIPT

Page 1: BC Hydro Site C injunction: Affidavit #1 of Patrick Hayes

r7

m ^ ^

This is the 1st AffidavitofPatrickHayes in this case

and was made on January 29,2016

No. S-160488Vancouver Registry

BETWEEN:

AND:

INTHESUPREME COURT OFBRITISH COLUMBIA

BRITISH COLUMBIA HYDRO AND POWER AUTHORITY

PLAINTIFF

KEN BOON, ARLENE BOON, VERENA HOFMANN, ESTHER PEDERSENalso known as Rachel Blatt, HELEN KNOTT, YVONNE TUPPE^ JANE DOE,JOHN DOE and all other persons unknown to the Plaintiff occupying,obstructing, blocking, physically impeding or delaying access, at or in the vicinityofthe area in and around the south bank ofthe Peace River upstream (west) oftheMoberly River, including the area in and around the heritage site known as RockyMountain Fort

DEFENDANTS

AFFIDAVIT #1 OF PATRICK HAYES

I, Patrick Hayes, of2900 - 550 Burrard St, in the City ofVancouver, Province of BritishColumbia, lawyer, SWEARTHAT:

1. Iam an associate in the law firm ofFasken Martineau DuMoulin LLP, counsel for BritishColumbia Hydro and Power Authority ("BC Hydro") in the matter herein, and as such havepersonal knowledge ofthe facts hereinafter deposed to in this affidavit, except where stated to beon information andbelief, in which case I verily believe them tobe true.

2. I viewed a number ofnews articles and social media posts that contain information aboutthe Defendants opposition to the Site C Clean Energy Project (the "Project ) and what isdescribed as a protest camp at the site of the Rocky Mountain Fort on the south bank of thePeace River ("Protest Camp"). Some of the websites Iviewed contained videos and audio files.

240150.00142/90618263.4

Page 2: BC Hydro Site C injunction: Affidavit #1 of Patrick Hayes

-2-

Copies of the videos and audio files referenced in this affidavit have been downloaded onto aUSB stick that is now produced and shown to me and marked as Exhibit "A".

3. This affidavit attaches social media posts by anumber of persons, including an individualwho uses the name "Rachel Blatt" on Facebook. I understand that "Rachel Blatt" is an alias usedby Esther Pedersen, a local landowner, on Facebook. "Rachel Blatt" states on her personalFacebook page that she is an owner at Peace Equestrian Park (from 2002 to present). Nowproduced and shown to me and marked as Exhibit "B" is acopy of the About section fromRachelBlatt's personal Facebook page.

4. Now produced and shown to me and marked as Exhibit is acopy of aBC Onlinesearch for the Peace Equestrian Park, dated January 11, 2016. It shows that Peace EquestrianPark is aregistered General Partnership in B.C., with abusiness address at 271 Rd. South, FortSt. John. The partners of Peace Equestrian Park are listed as Esther Rachel Pedersen and PoulPedersen.

5. Now produced and shown to me and marked as Exhibit "D" is a copy of aBC Onlinesearch for the Peace Valley Landowner Association, dated January 6,2016. The directors off thePeace Valley Landowner Association include, among others. Ken Boon and Poul Pedersen(formerly Esther Pedersen).

Reporting by newsagencies

6. On October 31,2014, CJDC-TV News, Dawson Creek, interviewed Ken Boon regardingthe Peace Valley Landowner Association's legal action against the Site CProject. Now producedand shown to me and marked asExhibit «E'» isa copy ofa transcript ofthe interview prepared

by A-Z Wordsmith Services, Prince George, and transmitted to me by BC Hydro's ProjectCommunications staff. Mr. Boon states: "Ifthey decide to do work on the project as a result of

that decision [the province's final investment decision], we would look at further action to get aninjunction...."

7. Now produced and shown to me and marked as Exhibit is acopy of an article fromthe EnergeticCity.ca website, dated April 14, 2015, titled "PVLA, First Nations prepare for SiteCFederal, Supreme Court cases". The article discusses the Federal and Supreme Court actions

240150.00142/90618263.4

Page 3: BC Hydro Site C injunction: Affidavit #1 of Patrick Hayes

-3

brought by tlie Peace Valley Landowner Association challenging the Environmental AssessmentCertificate. The article states: "However, he [Ken Boon] also conceded nobody can predict whatthe courts are going to do and therefore an injunction stopping construction can't be ruled out."

8. Now produced and shown to me and marked as Exhibit "G*' is acopy of an article fromthe News Talk 980 CBCNW website, dated April 20, 2015, titled "Peace Valley farmers head tocourt to fight Site Cdam". The article states "[Ken] Boon says with construction scheduled tostart as early as this summer, it is likely they will be back in court seeking an injunction beforethe decision on today'scase comes down".

9. Now produced and shown to me and marked as Exhibit "BP* is acopy of an article fromthe Globe and Mail's website, dated May 26,2015, titled "Power from Site Cdam ^dramatically'more costly than thought: expert". The article states "The Site Cproject is facing aseries ofcourtchallenges by the PVLA and local First Nations organizations. Mr. Boon said his group intendsto seek an injunction to delay construction if the Premier will not agree to put the project onhold."

10. Now produced and shown to me and marked as Exhibit "I" is acopy ofan article fromthe EnergeticCity.ca website, dated August 31, 2015, titled "Hydro pleased with rulings on SiteC injunction and judicial review application". With respect to the Federal Court decisiondismissing the Peace Valley Landowner Association's application for a judicial review of theProject, Ken Boon is quoted asfollows:

"So far it's not working too good but we still have some irons inthe fire on ourlegal challenges with our appeal on the BC Supreme Court one. That still doesn'tchange the fact that this isahorrible project. We're seeing that with all thedifferent levels ofgovemment, and different groups and organizations and expertscoming out and saying we need adelay on this project to get itreviewedproperly. That hasn't changed at all. We're moving forward and fighting this inevery way we can."

11. Now produced and shown to me and marked as Exhibit "J" is copy of an article from theCBC News website, dated October 15,2015, titled "Site Cwork camp construction upsets localresidents". The article discusses local residents Esther Pedersen and Poul Pedersen and their

240150.00142/90618263.4

Page 4: BC Hydro Site C injunction: Affidavit #1 of Patrick Hayes

opposition to the Project. Esther Pedersen is quoted as follows: "We're hoping to stop that thing[the Project]."

12. Now produced and shown to me and marked as Exhibit "K" is acopy of an article fromthe Alaska Highway News, dated December 15, 2015, titled "Historic fur trade fort gets new lifeas Site Cprotest camp". It describes acamp established by opponents of the Project near the siteof the Rocky Mountain Fort on the south bank of the Peace River and states "[Ken] Boon said itremains to be seen whether there will bea confrontation over thesite .

13. Now produced and shown to me and marked as Exhibit "L" is acopy of an article fromthe Globe and Mail, dated January 4, 2016, titled "B.C. Hydro orders protesters off land slatedfor logging near Site Cdam". Verena Hofinann is quoted as follows:

"We've just heard that equipment has started up. Itlooks like they are intendingto keep on cutting."

"Treaty 8First Nation people are holding their ground and are not moving fromthe site,so things are intensifying andchanging quickly."

14. On January 4, 2016, CJDC-TV News, Dawson Creek, interviewed Ken Boon regardingthe protest at the Rocky Mountain Fort. Now produced and shown to me and marked as Exhibit"M" is a copy ofa transcript ofthe interview prepared by A-Z Wordsmith Services in PrinceGeorge and transmitted to me by BC Hydro Project Communications staff. Ken Boon states:

"We are used to their bully tactics, and y'know there isjust too much atstake hereto worry about that. I guess there is a line drawn in the sand now, and now itisawhole totally different game. Ithink ifthe general public could see what kind ofdestruction they are doing down here —and then Christy Clark calls this cleanenergy,and whata mockery."

15. Now produced and shown to me and marked as Exhibit "N" is a copy ofan article fromthe CBC News website, dated January 5,2016, titled "First Nations land occupation aims to stop

Site C". Yvonne Tupper is quoted as saying "...we're having apeaceful protest to identify ourlands and post that this isTreaty 8territory and you're trespassing".

240150.00142/90618263.4

Page 5: BC Hydro Site C injunction: Affidavit #1 of Patrick Hayes

-5-

16. Now produced and shown to me and marked as Exhibit "O" is acopy ofan article fromthe Alaska Highway News, dated January 6, 2016, titled "Former PRRD director Hadlandarrested at SiteC protest". Thearticle states, in part:

The protests against Site C are ramping up. Roughly a dozen people haveoccupied thehistoric Rocky Mountain Fort since mid-December...

Esther Pedersen, who was protesting Wednesday, said she'd likely bejoining thatgroup next week.

She told the Alaska Highway News she'salso ready tobearrested.

"Yep. Atsome point, probably down at thecamp," shesaid.

17. Now produced and shown to me and marked as Exhibit "P" isa copy ofan article from

the Vancouver Sun website, dated January 7, 2016, titled "Site C dam protesters dig in and

preparefor arrests at historic site in B.C."

18. Now produced and shown to me and marked as Exhibit "Q" isa copy ofanarticle from

from the Alaska Highway News, dated January 14,2016, titled "Site C campers settle in". The

article includes a picture of two individuals standing beside a fire in front of felling machine,

with the following caption: "Verena Hofmann and Yvonne Tupper stand guard onthe south bank

of the Peace River, near an idle feller buncher. Down the trail from the front line is the

construction bridgeover the Moberly River."

19. On January 13, 2016, Jonny Wakefield of the Alaska Highway News posted a video on

YouTube of an interview with Ken Boon from January 9,2016. The video file, titled "Interview

with Ken Boon, January 9, 2016", is loaded on the USB stick marked as Exhibit "A". Now

produced and shown to me and marked as Exhibit "R" is a copy ofa transcript ofthe video.Ken Boon states, in part:

And here we are justupstream ofthe mouth ofthe Moberly, holding theline here,to save this valley from destruction. The deal-outcome for the whole situation isfor Site C to be stopped.

240150.00I42/906I8263.4

Page 6: BC Hydro Site C injunction: Affidavit #1 of Patrick Hayes

-6-

What they've done, they've put a temporary bridge in on Moberly in order tolog... this isa very important spot here tohold the line.

Acouple ofthe Treaty 8First Nations are waiting for a decision in court on theissuance ofthose permits - whether they were consulted properly - so... they'regetting way ahead ofthemselves here by trying to log this.

Well, the old camp shack that serves as a cookhouse, and a bit ofa bunkhouse,and then a tent with a heater in it, and now we've brought, you know, we havesomemore tentsnow,and we're just slowly building it up.

... There's a come a time when you justhave tostep up. That time has come.

20. On January 19, 2016, a report on the Protest Camp was posted on the website oftheAPTN National News. The video file, titled "APTN National News, January 19,2016", isloaded

on the USB stick marked as Exhibit "A". The report includes a clip of a helicopter dropping a

cabinat the Protest Camp (at the 1;18mark of thevideo).

21. On or about January 19, 2016, an interview with Helen Knott was posted by the user"Free City Radio" on the website Soundcloud.com. The audio file, titled "Helen BCnott Interview,January 19, 2016", is loaded on the USB stick marked as Exhibit "A". At the 5:20 mark oftheinterview, Ms. Knott discusses the activities ofthe protesters at the Protest Camp. She says: "We

hold fire within the worksite, so that we can keep that safe, because if we aren't there, they'll

keep working towards us."

Socialmedia postsby persons participating in the protest

22. Now produced and shown to me and marked as Exhibit "S" is acopy ofaFacebook postby Verena Hofmann dated December 31,2015, Itstates, inpart:

Putting your words and thoughts into practise and action! - headed to the RockyMt. Fort Camp, along thesouth bank ofthePeace River.

All indigenous and non-indigenous people ready to stand up for what is right andsave thePeace River Valley and the integrity ofTreaty 8 are NEEDED &WELCOME!

Helen Knott, Trenton Fox, Emily Gardiner, and Ken Boon are blazing the trail!Let's follow their lead!

240150.00142/90618263.4

Page 7: BC Hydro Site C injunction: Affidavit #1 of Patrick Hayes

-7-

23. Now produced and shown to me and marked as Exhibit "T" isa photograph posted onFacebook by Verena Hofinann on January 1, 2016. The photograph shows three individuals,

including Helen Knott, standing in front ofacabin atthe Protest Camp. Signs on the cabin state:

"No Trespassing Treaty 8 Territory" and "Rocky Mtn. Fort Property of Treaty 8 Members".There is a comment on Verena Hofinann's photograph from Rachel Blatt, which reads:

Hey there's the Flying Fort dropped down from the skies !! a legend inthemaking well at least a Dam Good Viral Video. Ihave video clips ofitslaunch and drop!

24. On January 1, 2016, Yvonne Tupper created a Facebook event page called "Be Idle NoMore - Our Rivers Need Us" ("Event Page"). Now produced and shown to me and marked as

Exhibit "U" is a copy of the Event Page that I accessed on January 5, 2016. The event is

described as follows:

♦Celebrateour Rivers that provided many ofus lives and continues toprovide lifeby joining one orall ofour peaceful protests. Starting this weekend-camping onSouthSideof PeaceRiver- where Moberly Rivermeets at Historical Site- RockyMountain Fort Camp. Cabinandcanvas tent available. Dress warm.

North side-Lookout available forpeaceful protesters opposing SiteC- lookoutShack and outliouse.

♦signs,peaceful protests anytime and any place! Social media -share fb posts andpictures-continue. Email, tweet, telephone, text!

♦January until dam's construction ceases forever^

40years ofprotests done and we will protest another 40 years until itceasescompletely! NO Site C!

25. Now produced and shown to me and marked as Exhibit "V" is a copy ofa Facebook

post by Verena Hofmann on the Event Page, dated January 1, 2016. It provides detaileddirections for accessing the Protest Camp viatheJackfish Road near ChetW3md.

26. Now produced and shown to me and marked as Exhibit "W" is a copy ofa FacebookpostbyHelen Knott dated January 1,2016. It states:

240150.00142/90618263.4

Page 8: BC Hydro Site C injunction: Affidavit #1 of Patrick Hayes

They didn't come to the camp to evict us but they met us at the bridp. The headofsecurity recorded our exchange as he reminded me we were "notified" ofour"eviction". I told him I have a right to be here, I'm exercising my inherent rightsand as aTreaty 8member I have a right to camp and be on the land within myterritory and that they hadn't the right to be clearing on crown land while there arecourt cases pending. I reminded him ofFree Prior and Informed consent and howone ofmy grandfathers signed the treaty sothat I could behere.

27. Now produced and shown to me and marked as Exhibit "X" is a copy ofa Facebookpost by Verena Hofinann, which shows aNews Release from Ken Boon dated January 1, 2016,titled ^TnIcw Year's Eve Celebrated at Historic Rocky Mountain Fort".

28. Now produced and shown to me and marked as Exhibit "Y" is a copy ofa blog postdated January 2, 2016. The blog writer identifies herself as "Helen K". The blog post states, inpart:

We were going to ring the New Year in at the Rocky Mountain Fort Camp, ahistorical site where one oftheearliest trade post settlements inBCwas built. It'slocated at the end of a maze of backroads and a skidoo ride or trek down themoimtain. This would be a New Years to Remember.

Ken Boon, anamazing individual who lives in the Valley and who has long sincebeen opposing the Site C dam met us at the top with his skidoo and brought ourload of gear in. They set up the camp within the previous month and that day(December 31st) they had a small shack that had been insulated flown in viahelicopter.

We need more of our own members of the Treaty 8 Territory to volunteer to manthe camp on shift shedules. You can contact me as Iwill begin keeping a schedulefor rotation @[email protected] Members from across the border(the Dam effects those all along the Peace River), and Indigenous people fromelsewhere welcome too. As camp grows we will need more living structures aswell (IE canvas wall tent with wood stoves. I will have more once am able to talkto the other organizers.

29. On January 2, 2016, Yvonne Tupper posted a video on her personal Facebook pagewhich shows her standing beside a yellow rope near the site ofthe temporary bridge over theMoberly River. Signs affixed to the rope state: "No Trespassing Treaty 8Territory" and "NoCutting Permitted Treaty 8 Territory". The recorder ofthe video identifies herself as Verena

240150.00142/90618263.4

Page 9: BC Hydro Site C injunction: Affidavit #1 of Patrick Hayes

n-1

r-i

fl

ri

-9-

Hofmann and Yvonne Tupper identifies herself asthe person being filmed. The video file, titled

"Tupper and Hofmann at Moberly River Bridge, January 2, 2016", is loaded on the USB stick

marked asExhibit "A". Now produced and shown tome and marked asExhibit "Z" is a copy of

a transcript ofthe video. The following isan excerpt firom the transcript:

Yvonne Andas youcanlook overto yourright, Verena, youcanseethatTupper: there are piles ofdifferent trees ofdifferent ages, piled up, and Tm

not too surewho is supposed to be the watchdog, or who issupposed tobetelling thepeople who are incourt opposing Site C,about these trees and oldgrowth. We'regoing to walk shortly tothe bridge, and show the oldgrowth thatwas protected in thecourtcases, that they removed.

Verena They mayhave notbeen protected in the court case. There wasHofmann: some protected upthe Moberly River, but thesuccess inhaving all

of them protected right here at thisflat, which was requested in thecourt case, was not successful.

This is partof thepurpose of why Treaty members areheretoday.

30. Later in the video, Ms. Hofinann and Ms. Tupper walk to the middle of the temporary

bridge over Moberly River and encounter a security guard contracted by BC Hydro who tells

them this is an activeworksite. Ms. Hoffinan told the security guard "our line of signage thathas

been erected is behind your piece of equipment" and *the signs are clear in terms of what's

expected by Treaty 8 members". Ms. Tupper told the security guard **there is no trespassing on

Treaty 8 territory".

31. Now produced and shown tome and marked as Exhibit "AA" isa copy ofa photograph

posted byYvonne Tupper on the Event Page onJanuary 2,2016. It shows Yvonne Tupper with

a man standing behind a yellow rope vrith signs that read "No Trespassing Treaty 8 Territory"

and "No Cutting Pennitted Treaty 8 Territory".

32. Now produced and show tome and marked as Exhibit "BB" is a copy of a photograph

posted on Facebook by Verena Hofmann on January 2, 2016. The photograph appears to show

Verena Hofmann and three other individuals, two of whom are identified as Ken Boon and

Yvonne Tupper, inside thecabin at theProtest Camp. The caption reads:

240150.00142/90618263.4

Page 10: BC Hydro Site C injunction: Affidavit #1 of Patrick Hayes

F-1

P-l

-10

Jan. 2,2016Evening CrewRocky Mtn. Fort CampPeace River Vdley, BC

Calling all supporters tothe camp - you are needed!

33. On January 4, 2016, Yvonne Tupper posted the following message on the Event Page

(see Exhibit "U"):

**Any interested local or near first nations individuals and or non-aboriginal whoare opposed Site Cthatwould like tojointhe♦Peaceful protest camp* toprotect our Peace Valley,please contact either Verena 250.793.1124, myselfby private messaging me orcommenting, andHelen Knott-via Facebook.

34. On January 4, 2016, Yvonne Tupper posted the following message on the Event Page

(see Exhibit "U"):

Way to go! ATreaty 8member made a feller buncher turn around today.

35. Now produced and shown to me and marked as Exhibit "CC" is a copy ofa post byArlene Boon onher personal Facebook page dated January 6,2016. It states:

Never underestimate the power ofone woman. I walked onto this logging site thismorning. One machine and 8people on the ground. Told the #SITEC contractor Iwas not leaving so they moved the machine back to the bridge and the people left.January 6,2016.Back to Rocky Moimtain Fort I go.

36. Now produced and shown to me and marked as Exhibit "DD" is a copy of a post byHelen Knott on her personal Facebook page dated January 6,2016. Itstates, inpart:

Arlene Boon went outtothefrontline early today and was faced by8men and apiece ofequipment, she said she was staying and they turned away. I came outand say there alone by the fire, the hydro guys came by asked me ifIw^staying,I said yes. He asked me ifI knew they were attempting to clear and I said I wasattempting to usemytreaty rights there.

37. Now produced and shown to me and marked as Exhibit "EE" is acopy ofaphoto postedby Christy Jordan-Fenton on her personal Facebook page on January 7,2016. The caption reads:

240150.00142/90618263.4

Page 11: BC Hydro Site C injunction: Affidavit #1 of Patrick Hayes

-11-

The bunkhouse at the camp. This is Treaty 8Territory! At the site ofthe historicRocky Mountain Fort.

38. Now produced and shown to me and marked as Exhibit "FF" is acopy ofanews releaseissued by Helen Knott and Art Napoleon dated January 7, 2016 from the websitewww.newswire.ca. The title is"First Nations Prepare for Arrest to Stop Site C. Itstates, inpart.

Jomed by local landowners. Treaty 8Stewards ofthe Land say they will notpermit BC Hydro to proceed with plans to clear-cut forests around the RockyMountain Fort site on the west side of tlie MoberlyRiver.

39. Now produced and shown to me and marked as Exhibit "GG" is a copy of a pressrelease issued by "Arlene Boon-Peace Valley Landowners Assoc.'' dated January 8, 2016 fromthe website ofthe Pacific Free Press. The title is "Answering the Peace's Call: Supporting RockyMountain Fort and the Site CBlockade", asking for more supporters to come into camp torotate

persons in and out, and anyone wanting to go in to camp should contact her (Arlene Boon).

40. Now produced and shown to me and marked as Exhibit "HH" is a copy of a postingfrom the website TheEcoReport.com dated January 8, 2016, titled "Treaty 8 Stewards Of TheLand Are Prepared ToBeArrested". It states, inpart:

Local First Nations set up Rocky Mountain Fort Canip before Christmas. Therewere six to eight members ofthe newly formed Treaty 8Stewards ofthe Landsleeping there last night. Spokesperson Art Napoleon said First Nations originallytalked about taking astand near the site ofthe proposed Site CDam, but B.C.Hydro's work crews moved too fast. The once pristine forest that stood there hasbeen destroyed. So First Nations decided to block this most recent perceivedviolation of Treaty 8bysetting upRocky Mountain Fort Camp.

So the group now calling themselves Treaty 8Stewards ofthe Land has set up atRocky Mountain Fort Camp, to deny BC Hydro further access to the land.Though they are across the river from Fort St John, this is aremote location halfamile from the nearest road. People come on arotating basis. There have been asmany as 10, and as few are five. They know the courts could issue an injunctionin favour ofB.C. Hydro. Ifthat happens, Treaty 8Stewards OfThe Land ArePrepared To Be Arrested.

240150.00142/90618263.4

Page 12: BC Hydro Site C injunction: Affidavit #1 of Patrick Hayes

-12-

41. Now produced and shown to me and marked as Exhibit "II" is a copy of a Facebookpost by Rachel Blatt dated January 9, 2016, calling herself a "Camp supply organizer" anddirecting supporters to "PM me or contact Yvonne Tupper Arlene Boon, Helen Knott or VerenaHofmann on Facebook".

42. Now produced and shown to me and. marked as Exhibit "JJ" is a copy ofa Facebookpost by Rachel Blatt on January 10,2016, which includes requests for help with various suppliesfor the camp.

43. Now produced and shown to me and collectively marked as Exhibit "KK" is acopy ofaFacebook post and photograph posted on Facebook by Christy Jordan-Fenton on January 10,2016, who indicates she visited the camp on January 9, 2016. The photograph shows Yvonne

Tupper and Verena Hoffman standing infront ofa fire pit.

44. On January 11, 2016, Yvonne Tupper posted a video on her personal Facebook page

which shows hereelf and another woman speaking with BC Hydro contractors. Ms. Tupper

states that the date is January 7, 2016. The video file, titled "Tupper at work site, January 7,

2016", is loaded on a USB stick marked as Exhibit "A". Now produced and shown to me and

markedas Exhibit "LL" is a copy of a transcript of the video.

45. In this video, BC Hydro contractors advise the two women that it is unsafe for them to

walk into a work site where logging operations are underway. The following is an excerpt from

the transcript:

Yvonne ... We are putting you guys onnotice that this is anactive Treaty 8Tupper: territory site, and we did not give consent. And we're looking for

medicines today,andthe medicines we needis on that side, and we'rewalking the path as you can seeit's a well [inaudible] path. You've usedour path tocome here, and we've been doing this for—and we're going tocontinue to do it until we find what we're looking for.

Contractor: Well, we'renothereto impede you. We'rejust here to saythat it's notsafe to go this way.

Yvoiuie So, I'm sure you guys are well aware, we have seta camp at theRockyTupper: Fort Mountain Camp, and we've been taking care of, well, with the

240150.00142/90618263.4

Page 13: BC Hydro Site C injunction: Affidavit #1 of Patrick Hayes

-13-

numerous people ofsupports, we're going tocontinue to look for themedicine today. Yesterday I also acted as a different activity; we're goingto continueto do that until—because, this is our territory. Before thedams, before the government. This isour land. And itwill beour land.We're thestewards ofthe land. Alright. So, wewould liketo continue.

46. Now produced and shown to me and marked as Exhibit "MM" is acopy ofaphotographthat was posted on Facebook by Yvonne Tupper on January 11, 2016, showing Yvonne Tupperand aman standing in front ofa fire pit. The caption states the photo was taken by "Ken".

47. Now produced and shown to me and marked as Exhibit "NN" is acopy ofa photographofYvonne Tupper and Ken Boon standing near a fire pit, posted on Facebook by Yvonne Tupper

on January 11, 2016. The caption states, in part: "Mr Ken Boon and I on Saturday Jan 9,2016.Same place same time with same cause to Save the Peace Valley, BC."

48. Now produced and shown to me and marked as Exhibit "OO" is a copy ofa tweet bySai-ah Katherine Cox dated January 12, 2016, showing a picture of Ken Boon with the caption

"Peace farmer Ken Boon picks up donated food for #SiteC Rocky Mnt Fort camp."

49. Now produced and shown to me and marked as Exhibit "FP" is a copy ofa Facebook

post by Yvonne Tupper on January 14, 2016 calling for support, and for rides to and from thecamp, shesayscontact Verena or "pm me".

50. Now produced and shown to me and marked as Exhibit "QQ" is a copy of a GoFundMe.com page created by Yvonne Tupper on January 14,2016, which I accessed on January

18,2015. GoFundMe.com is an online fimdraising website that allows people to start fundraisingcampaigns for specific causes and receive online donations. The stated purpose of YvonneTupper's fimdraising campaign is asfollows:

We are raising funds for upcoming projected court legal and legal team battles forthe dedicated Rocky Mountain Fort Campers from January 1,2016 who arewilling to be arrested to protect the Peace Valley from further destmction.

51. Now produced and shown to me and marked as Exhibit "RR" is a copy ofFacebookpost by Yvonne Tupper dated January 15,2016. Itstates:

240150.00142/90618263.4

Page 14: BC Hydro Site C injunction: Affidavit #1 of Patrick Hayes

-14-

We been at camp now successfully for past 16 days!If you can support us with raising funds for legal costs.*Every and any amoimt accepted: $10, 20, 50, 100, 500, 1,000, and $10,000 ormore to help us raise our goal this time at $200,000 Canadian funds.**Please share and spread thisGoFund MeCampaign! **

52. Now produced and shown to me and marked as Exhibit "SS" is acopy ofFacebook postby Rachel Biatt dated January 16,2016, which provides a link to the "Go Fund Me" fundraisingcampaign created by Yvonne Tupper. It states:

Want toHelp Preserve our Valley and the 1700's Historic Rocky Mountain FortSite but can't make it up here right away?

Here is another way. We need help $$ wise topay for moving buildings and forsupplies not donated or loaned.

The support thus far has been astounding from folks coming out to camp and cooketc, donations ofwall tents and equipment and All those busily baking andcooking meals for the campers.

Thank you toallfor what you have contributed. We are standing for the Valleytogetherone way or another

53. Now produced and shown to me and marked as Exhibit "XT" is a copy ofa photograph

of fire pit posted on Facebook by Yvonne Tupper on January 17, 2016. The caption states, inpart:

We are Still Here!!

Minus 20 with windchill, Arlene turned up the heat!Expecting more relations coming today and more cool walks inbushes and trails.

54. Now produced and shown to me and marked as Exhibit "UU" is a copy ofa Facebook

event page created by Yvonne Tupper that I accessed on January 19, 2016. The event is called

"Treaty 8 Steward ofthe Land", which has the same description as the event "Be Idle No More -

OurRivers NeedUs" alsocreated by Yvonne Tupper (noted above at paragraph 24).

55. The covering photo for the Facebook event "Treaty 8 Steward of the Land" shows

Yvonne Tupper, Verena Hofinann, Ken Boon, Arlene Boon and others standing inside a cabin,

with Ken Boon holding a sign that reads: "Rocky Mountain Fort Camp #KeepTHEPeace Jan

240150.00142/90618263.4

Page 15: BC Hydro Site C injunction: Affidavit #1 of Patrick Hayes

-15-

12/16". Now produced and shown to me and marked as Exhibit "W" is a copy of thatphotograph.

56. Now produced and shown to me and marked as Exhibit "WW" is a copy of a newsrelease issued by the "Treaty 8Stewards of the Land" dated January 18, 2016 from the websitewww.newswire.ca. It states, in part! "Today's release... marks the 20 day that Treaty FirstNation Stewards ofthe Land, joined by local landowners and supporters from across BritishColumbia, have been camped at the historic Rocky Mountain Fort site." The followingindividuals are listed ascontacts: Helen Knott, Yvonne Tupper and Art Napoleon.

57. Now produced and shown to me and marked as Exhibit "XX" is copy a photographposted by Helen Knott on Instagram on or about January 19, 2016. It shows Helen JCnott andanother woman in front ofa cabin at the Protest Camp, with the following caption. Love this

shot, was so blessed this weekend with an abundance ofvisitors to the Rocky Mountain FortCamp and good vibes. We are everyday people saying NO to EC Hydro."

58. Now produced and shown to me and marked as Exhibit "YY" is copy a Facebook postby Rachel Blatton January 22,2016.

SWORN, BEFORE ME at Vancouver,British Columbia, on January 29,2016.

A Commissioner for taking Affidavits forBritish Columbia

KERRY KAUKINENBarrister & Solicitor

Fasken Martineau DuMoulin LLP2900 - 550 Burrard StreetVancouver, BC V6C 0A3

604 631 3210

240150.00142/90618263.4

Page 16: BC Hydro Site C injunction: Affidavit #1 of Patrick Hayes

12/01/2016

I Timeline ' About Friends | Photos More

About

To see witat she shares with friends, send her a Iriend request.

Overview

Work and Education

Pieces She's Lived

Contact and Basic Info

Family and Relationships

Details Atiout Racttel

il Friends

Owner at Peace Equestrian Parkn<Eu 2002 to present

studied Agriculture Skidles at NorthernLights College

No i^aces to show

No relationship inb to show

This is Exhibit referred to in the

affldsvit of

made before me on this

day of 20 imtiJ?

A Commissioner for takingAffidavits for British Columbia

https;//www.facebook,com/peaceequestrian.park/about

Chat (Off)

Sponsorad

Dont waste a mlnuta

wwwpa)^icsniSelzafrie moment. Quil

eiKe'tnoyour oedH cardat checkout and get tiackUta part...

Page 17: BC Hydro Site C injunction: Affidavit #1 of Patrick Hayes

BC RegistryCOufMMA IServices

Mailing Address:PO BOX 9431 Sin Prov Govt.Victoria BC V8W 9V3www.bcregistryservices.gov.bc.ca

Location:2nd Fioor - 940 Blanshard St.Victoria BC

1 877 526-1526

General Partnership Summary

Date and Time of Search:

Currency Date:

Registration Number:

Name of General Partnership:

Registration Date:

Business Start Date:

Nature of Business:

ADDRESS INFORMATION

Business Address:

^71 RD. SOUTHP^ORT ST. JOHN BCCANADA VIJ4M7

PARTNER INFORMATION

Individual or Company Name:

PEDERSEN. M. ESTHER RACHEL

Residential Address:

271 RD. SOUTH

FORT. ST. JOHN BCCANADA V1J4M7Individual or Company Name:

PEDERSEN, POUL HOJFELDT

Residential Address:

271 RD. SOUTH

FORT ST. JOHN BCCANADA V1J4M7

PEACE EQUESTRIAN PARK

January 11, 2016 04:08 PM Pacific Standard TimeJanuary 05, 2015

ACTIVE

FM0353941

PEACE EQUESTRIAN PARK

August 22, 2003

January 01, 2003

HORSE AND HAY SALES. HORSE BOARDING ANDTRAINING

Mailing Address:

SS.2 SITE 21 COMP. 9FORT ST. JOHNBCCANADA VIJ4M7

This is Exhibit....L.... referred to in theaffidavit of

yiSi-kmade before me on tills

day of .3k^.i]|.....; 20

A Commissioner for takingAffidavits for British Columbia

FM0353941

Page 18: BC Hydro Site C injunction: Affidavit #1 of Patrick Hayes

SUBMITTING PARTY INFORMATION

Name:

^EDERSEN, FOUL HOJFELDTpiailing Address:SS.2SITE21 COMP. 9

FORT ST. JOHN BCCANADA V1J4M7

FM0353941

Page 19: BC Hydro Site C injunction: Affidavit #1 of Patrick Hayes

BRITISHCOLUMBU

BCRegistry-Services

Mailing Address;PO BOX 9431 Sbi Prov Govl.Victoria BC V8W9V3www.bcregl5tryservlces.gov.bc.ca

Location:

2nd Roor - 940 Blanshard St.Victoria BC

1877 526-1526

Society SummaryFor

PEACE VALLEY LANDOWNER ASSOCIATION

Januarys, 2016 12:29 PM PacificTimeNovember 10, 2015

Date and Time of Search:

Currency Date:

— ACTIVE -

Society Number: 8-0060524 Business Number: 841264732BC0001Name ofSociety: PEACE VALLEY LANDOWNER ASSOCIATIONIncorporation Date and Time; Incorporated on November 16, 2012 04:17 PM Pacific TimeLast Annual Report Filed: 2015 Reporting Society: NoLast Annual General Meeting: February 21, 2015 Number of Directors:6In Liquidation: No

REGISTERED OFFICE INFORMATION

Physical Address:

gS2, SITE 12, C0MP19§4818 29N HWYFORT ST. JOHN BC VIJ 4M7

DIRECTOR INFORMATION

Last Name, First Name, Middle Name:ARDILL, IRENE E

Physical Address:

17359 HWY 29 N

FORT ST. JOHN BC V1J 4H6

Mailing Address:

882, SITE 12, C0MP1914818 29N HWY

FORT ST. JOHN BC V1J 4M7

Mailing Address:

17359 HVW 29 NFORT ST. JOHN BC V1J 4H6

Last Name, First Name, Middle Name:

BOON. KEN

Physical Address: Mailing Address:

14818 HWY 29 N 14818 HWY 29 N

FORT ST. JOHN BC VIJ 4H6 FORT ST. JOHN BC V1J 4H6

Last Name, First Name, Middle Name:

MEEK. MARYANN

Physical Address;

13938 HW 29NCHARLIE LAKE BC VOC 1H0

Mailing Address:

13938 HWY 29NCHARLIE LAKE BC VOC 1H0

8-0060524 Page: 1 of 2

Page 20: BC Hydro Site C injunction: Affidavit #1 of Patrick Hayes

n

Last Name, First Name, Middle Name:

RECK. ROSS

Physical Address: Mailing Address:153329 HWY 18533 29 HWY

Hudson's hope bo voc ivo Hudson's hope bc voc ivo

Last Name, First Name, Middle Name:

PEDERSEN; FOUL (Name. Correction or Legal; Name Change from PEDERiSENi ESTHER)Physical Address: Mailing Address:7424 271 RD 7424 271 RDFORTST. JOHN BCV1J 4H6 FORTST. JOHN BCVIJ 4H6

Last Name, First Name, Middle Name:

WILSON, HEATHER M

Physical Address: Mailing Address:9922 ADAMS ST 9922 ADAMS STHUDSON'S HOPE BCVOC IVO HUDSON'S HOPE BCVOC IVO

S-0060524 Page: 2 of 2

006

Page 21: BC Hydro Site C injunction: Affidavit #1 of Patrick Hayes

£

Verbatim Transcript

CJDC TV Dawson Creek

October 31,2014

--.nn nm ACommlsaioftef feftaklfig11.00 pm Hffldavlte for British Coiumbtt

Anchor: Jeremy Keefe

Reporter: Faiza Amin

"Ken Boon" President, Peace ValleyLandowners Association

KEEFE: As wedraw closer toa decision on BO Hydro's proposed Site 0 project, groups are stillpetitioning the government to reject the dam. And with time winding down, one organization Is takingdrastic action against the Province. CJDC's Faiza Amin has thedetails.

AMIN: The Peace Valley Landowners Association say they aretaking legal action against theProvincial government. The group decided to take action after the government granted EC Hydro s SiteCan environmental assessment just a few weeks ago. The Association's President Ken Boon saidearlier this week that a petition for a judicial review was filed with the Supreme Court of BC toremove thatassessment.

BOON: And this Is basedon thefact thattheJoint Review Panel wastasked with reviewing theproject, and they had their terms of reference and their mandate on what they had to examine.

AMIN: The petition was served to the Ministers of Environment and of Forests Lands and NaturalResource Operations. The Association feels that the govemment disregarded the Review Panel'srecommendations on how to proceed withthe project

BOON: The certificate Is invalid. Sothey can't - we - we feel itIs impossible for them now, incabinet, to make a decision to go ahead with the project because they would bebasing it on aninvalidcertificate.

AMIN: They also say there wasn't much consideration for those who love in the area, and wouldtherefore be Impacted by the project.

BOON: We are ail going to be impacted by Site 0 if the rates haven't been examined properly,and all our rates are going to go up because of this, which we feel strongly will be the case. So all BritishColumbians will beimpacted by, y'know, this project because the economics haven't been looked atproperly.

AMIN: After BC Hydro was granted the environmental assessment, the Province's Energy andMines Minister Bill Bennett saidhe had notmade a decision onthe project yet, andtheAssociationwasn't going towait for the Minister to make a decision before filing the legal documents.

BOON: If they decide to work on the project asa result of that decision, we would look atfurtheraction to get an injunction. We would assume that the govemment - y'know, because this Is such aserious case, that they would not start work.

AMIN: And although the govemment has yet to give Site Ca final approval, the group says BCHydro isexpected tostart construction in January of2015.

fMOBWrnm

240150.00I63/90632435.I

007

Page 22: BC Hydro Site C injunction: Affidavit #1 of Patrick Hayes

008

-2-

BOON: Whatwe hope, ofcourse, is that the government will decide that this project is not inthebest interestsof BC, and decidenottogo ahead with SiteC, and decideto move forward, and not[inaud]Site C on the back burner.

AMIN: The Association says theywill also launch a second petition for judicial review nextweek-this time asking the federal courts toappeal thefederal Minister ofEnvironment's decision approving theproject Faiza Amin, CJDCTVNews, FortSt. John.

240150.00163/90632435.1

Page 23: BC Hydro Site C injunction: Affidavit #1 of Patrick Hayes

PVLA, First Nations prepare for Site CFederal, Supreme Court cases - Energeticcity.ca Page 1of5 qqq

HAVEANFWSTIP? LOGIN CONTACT

EnergeticForl Stjohn

BC Dodge Deals I®Your Local Offers &Dealerships. See Dodge DealsS Offers Todayl

O O

iittefi Live

HOME LOCAL NEWS LOCAL SPORTS EVENTS JOBS MOVIES

MOOSE FM -100.1% FORT ST. JOHN ADVERTISE NEWS TIP

HOTTOPICS JANUARY 25.2016 ISHAW TV: ROCKIN THE PEACE 2016 search

HOME NEWS NEWSLEHER

Sign up for the daily

Energeticcity.ca

newsletter

sponsored by NLC

Your Email Adc 1

PVLA, First Nationsprepare for Site CFederal,Supreme Court oasesPOSTED BY: ADAM STEINBERG APRIL 14,2015

The Peace ValleyLandownerAssociation hearing inB.C. Supreme Court is scheduled to begin at 10:00a.m. next Monday.

It is arguing the Environmental AssessmentCertificate for the project is invalid and PresidentKenBoon's group is lookingfor a court ruling tohave it stopped.

"Thatall goes back to the [ointReview Panel," saysBoon."They had their mandate on how to review

Thiala Exhibit ratarradto Intha

affidavK

day of.

H>M«

mtOdL

A Commlsslonef for UkingAffidavits tor British Columbia

http://energeticcity.ca/article/news/2015/04/14/pvla-first-nations-prepare-for-site-c-federa.,. 25/01/2016

Page 24: BC Hydro Site C injunction: Affidavit #1 of Patrick Hayes

PVLA. First Nations prepare for Site CFederal, Supreme Court cases ~Energeticcity.ca

Site C and what issues to look at, and they did justthat."

NORTH PEACEVETERINARY CLINIC

Proudly providing small andlarge animal veterinary care to the

Peace Country for over 50 years

250.785.4578 npvc.ca

alternatives to Site C.

Boon is

reminded

of some of

the

recommend

ations that

came out of

that review,

which

include the

need, cost

and

"In response to that, the B.C. government - theyessentially ignored that - they said it was outsidetheir scope and they didn't have the mandate toactually look at those issues."

Boon saysat the veryleast, the project should havebeen directed to the B.C. Utilities Commission.

The Treaty8 FirstNationsare alsoset to be beforethe same B.C. Supreme Court justicelater next week,with the start date for that case set for a week fromThursday.

Then both groups and two Alberta First Nations areset to appear in Federal Court in July to argueagainst Ottawa'sprojectapproval.

Meantime, it remains to be seen if the legal actionblocks B.C. Hydro construction - now expected to bebegin in the latter half of June.

NortheastBCJ

TOP STORIES

JANUARY 18, 2016

Man charged withManslaughter fouryears after Hedleyconcert death

JANUARY 18, 2016

Trackers splitweekend gaMes

http://energeticcity.ca/article/news/2015/04/14/pvla-first-nations-prepare-for-site-c-federa... 25/01/2016

Page 25: BC Hydro Site C injunction: Affidavit #1 of Patrick Hayes

PVLA, First Nations prepare for Site CFederal, Supreme Court cases - Energeticcity.ca Page 3of5

Just I^t week Energy Minister Bill Bennett told theVanc( uver Board of Trade he's confident legal

objec ions won't delay the start of construction.

Howe 'er, he also conceded nobody can predict whatthe cc arts are going to do and therefore aninjunction stopping construction can't be ruled out.

shvrethi:

sa y

Related

f G*122

PVl^ piepaies key Landowneis gioup Court rulingargiimeiUs for its weighiiigappeal pending afterfirst day in after Supreme PVLA, FirstSupreme Court Court decision Nations Site C

April 20,2015 July6,2015 challengesIn "News" In "News" April 27, 2015

In "News"

You May Like Sponsored Links by Taboola

JANUARY 18, 2016

Fort StJohnrtanconvicted for

hunting-relatedoffences

lANUARY 18, 2016

Registrationdeadline for CrystalCup two weeksaway

JANUARY 19, 2016

Man travelling alonein Grande Prairiethreatened, robbed

http://energeticcity.ca/article/news/2015/04/14/pvla-ftrst-nations-prepare-for-site-c-federa... 25/01/2016

Page 26: BC Hydro Site C injunction: Affidavit #1 of Patrick Hayes

PVLA, FirstNations prepare for Site CFederal, Supreme Court cases - Energeticcityxa Page 4of5 2

19+ Most Beautiful Winter Cities from Around

Awesonie Escape

25 Photos That Almost Broke The InternetLifoHackLnne

Rare Historical Photos That Will Leave You

SpeechlessTime To Break

Lost Keys? Never Again With TrackRlTrackR Bravo

Don't Eat These 16 Cancer Causing FoodsNaturalON

Please Don't Pay Full Price for a New iPhone 6.Here's Why.QuiBids

UTESTNEWS

Treaty 8seeks donations to fight civil claif^ frort BCHydro

Duncan Gran student wins iPad prize frort Fire Prevention

Week

Northern Metalic Flyers double up Peace River 4-?

New software presents frustrations, but Ministry, schooldistrict address concerns

Tweets Follow i

10m A.

@EnergeticCily

Treaty 8seeksdonations to

fight civilclaim from BCHydro- goo.gl/qrH9QT ^/yxj#yxjnews ...pic.twitter.com/RJYsdD19Ik

Tweet to @EnergeticCity

http://energeticcity.ca/article/news/2015/04/l4/pvla-first-nations-prepare-for-site-c-federa... 25/01/2016

Page 27: BC Hydro Site C injunction: Affidavit #1 of Patrick Hayes

PVLA, First Nations prepare for Site C Federal, Supreme Court cases - Energeticcity.ca Page 5of5 ^

Shaw TV: RocKIH The Peace 3016

Previous post Next post

MOOSE FM/CKFU ENERGETICCITY.CA HOME I LOCAL NEWS | LOCAL SPORTS | EVENTS | JOBSMOVIES 1 MOOSEFM-MNoFORTSTJOHNADVERTISE I NEWSTIP

http://energeticcity.ca/article/news/2015/04/14/pvla-first-nations-prepare-for-site-c-federa... 25/01/2016

Page 28: BC Hydro Site C injunction: Affidavit #1 of Patrick Hayes

UPDATED: Peace Valley farmers head to court to fight Site C dam jNews Talk980 CK... Page 1of 14 014

CKNW VANCOUVER'S NEWS.VANCOUVER'S TALK.

UPDATED: Peace Valley farmers headto court to fight Site C dam

Vancouver, BC, Canada / News Talk 980 CKNW i Vancouver's News.Vancouver's Talk

Liza Yuzda

Posted; April 20,2015 09:54 am j Last Updated: April 20,201511:03 am

Agroup of landowners from the Peace Valley

are in court to argue that the environmental

assessment certificate for the $8.8-billion Site

C dam should be quashed.

didn't consider all the recommendations from

the Site Cjoint review panel, so it was not possible to come to a reasonabledecision on giving the project an environmental thumbs-up.

She tells the court this decision doesn't just affect the Peace Valley residentswhose land will be flooded, but that protecting the integrity of decision-making on

projects of this scale is important for everyone. {i' This Is Exhibit referred to in the

affidavit of teeaM

The $8.8 mega-dam is set to start being built this summer, made before ma on thisday of weseeeHte 20A,

http://www.cknw.eom/2015/04/20/72778/

« aeae eitvWeM s M M eueetee*we <easesvMeee

A Commfssioner for takingAffidavits for British Columbia

25/01/2016

Page 29: BC Hydro Site C injunction: Affidavit #1 of Patrick Hayes

UPDATED: Peace Valley farmers head tocourt tofight Site Cdam | News Talk 980 CK... Page 2of 14

Ken Boon, president ofthe PeaceValley Landowners Association, says he andothers could lose everything ifthe project goes ahead.

"We farm and we run a camp ground and we run a log home business and itwillall be flooded out by the dam."

He says he's optimistic.

"There are six legal challenges with the potential for six appeals. What are theodds that the government is going to win them all?"

Boon says with construction scheduled to start as early as this summer, It islikely they will be back in court seeking an injunction before the decision ontoday's case comes down.

17 Comments

Comments

I

i Leave a Reply

Loginwith Facebook Login Sign Up

Bon Apr20,2015 at 10:37am said-

Ken Boon says "What are the odds the government is going to winthem all?"

When have snookums and her ilk ever won anything, other than an

election?And that was only because of the fools that votedthemll!!!!!!!!!!!!!!l!l!l!!l!!l!!!!!!n!!l!!!i!!!!!i!!!lH!!!iH!IH!H!

http://www.cknw.com/2015/04/20/72778/ 25/01 /2016

015

Page 30: BC Hydro Site C injunction: Affidavit #1 of Patrick Hayes

Power from Site Cdam 'dramatically' more costly than thought: expert - The Globe and... Page I of9 q.| 0This 18 ExhibitJj— wferred to In tho

affidavit of

msds bsforo ino on thid

day of 20 »*!!^

A Commissioner for takingAffidavits for British Columbia

E^AdChoices

Power from Site Cdam 'dramatically' more costlythanthought: expert

Justine Hunter

VICTORIA — The Globe and Mail

Published Tuesday, May26,2015 8:00AM EOTLast updatedWednesday, May 27,2015 4;53PM EDT

Just weeks before EC Hydro plans tobegin construction ofthe$8.8-biUion Site Cproject, a newreport says the Crown corporation has dramatically understated the cost ofproducing powerfrom the hydroelectric dam.

The Peace Valley Landowners Association (PVLA), which isopposed tothe projectbecause ofthe flooding from creating an83-kilometre reservoir on the Peace River, commissioned aleading U.S. energy economist, Robert McCuUough, to look atthe business case for what will bethe province's mostexpensive public infrastructure project.

The B.C. government approved the project last December, saying it isthemost cost-effectiveoption tomeet the province's future electricity needs. But the province has steadfastly rejectedcalls for an independent review ofthecost estimates for Site C, sa3dng thecosts have beenrigorously scrutinized and verified by independent contractors, the Mimstiy ofFinance and anoutside accounting firm.

Mr. McCullough, inhis report, said it appears the Crown corporation BC Hydro had itsthumbsonthescale to make itsmega project look better thantheprivate-sector alternatives.

"Using industry standard assumptions. Site Cismore than three times as costly asthe leastexpensive option," Mr. McCullough concluded. "While the cost and choice ofoptions deservefurther analysis, thesimple conclusion isthatSite Cismore expensive —dramatically so—thanthe renewable [and] natural gas portfolios elsewhere in theU.S. andCanada."

The report challenges a number ofassumptions that led the government toconclude thatSite Cisthe cheapest option. Mr. McCullough noted that the province adopted accounting changes lastfall that reduced thecost ofpower generated by Site C. He said those changes are illusory andthecosts will eventuallyhave tobepaid either byHydro ratepayers, orprovincial taxpayers.

Mr. McCuUough, aleading expert on power utilities inthe Pacific Northwest, also disputes therate that BC Hydro used tocompare the long-term borrowing cost ofcapital for Site Cagainst

http://www.theglobeandmail.com/news/british-columbla/power-from-site-c-dam-dramati... 25/01/2016

Page 31: BC Hydro Site C injunction: Affidavit #1 of Patrick Hayes

Power from Site Cdam 'dramatically' more costly than thought: expert - The Globe and... Page 2of9

other projects, noting that other major utilities in North America use higher rates for suchprojects because they are considered risl<y investments. The so-called discount rate is critical tothe overall cost projections, and he said tihe paper trail on how the Crown arrived atits figure"canonly be described as sketchy andinadequate."

The report, obtainedbyThe Globe and Mail, will be released on Tuesday by the FVLA.

The group will call on Premier Christy Clark to delay construction to allow time for areview byAuditor-General Carol Bellringer.

Ken Boon, president of the association, said the government needs to put the project on holdbecause it hasapproved theproject based onpoor advice.

"I find itfnastrating," he said inan interview. "How come itis left to us to do the due diligencethat the government shouldbe doing?"

The Site Cproject is facing aseries ofcourt challenges by the FVLA and local First Nationsorganizations. Mr. Boon said bis group intends to seek an injunction to delay construction ifthePremierwill not agree to put the project onhold.

Independent power producers have argued they can meet B.C.'s growing need for electricity at acompetitive cost, but they say the province tilted the playing field last M when itchanged theway itcollects dividends fi*om BC Hydro and reduced water-rental charges for the Crowncorporation. As aresult ofthose accounting changes, the cost per megawatt hour ofSite Celectricity decreased by one-third, firom $83 amegawatthour down to somewhere between $58and $61 amegawatt hour. BC Hydro says itwould cost $96 amegawatt hour for alternativeenergy.

The government has exempted the project from aregulatory review by the B.C. UtilitiesCommission. However theenvironmental review panel thatstudied Site Csaid anindependentreview on BC Hydro's cost estimates, energy demand forecasts and conservation plan shouldbeconducted beforeallowing the project to move forward.

Follow Justine Hunter onTwitter: ft:justineJiimter[http$://twitter.com/Ccdjustine,Mnter]

PVLA Site C report

http://www.theglobeandmail.com/news/british-columbia/power-from-site-c-dam-dramati... 25/01/2016

017

Page 32: BC Hydro Site C injunction: Affidavit #1 of Patrick Hayes

Hydro pleased with rulings on Site Cinjunction and judicial review apf^Icafon- EnergeOccity.ca

HAVCANIiWSTIP? LOGIN CONTACT • •

Energetic fcity.For? StJc^in

Live

HOME LOCAL HEWS LOCAL SPORTS EVENTS JOBS MOVIES

MOOSE FM-lOD.lo/0 FORT ST. JOHN ADVERTISE NEWS TIP

NOT TOPICS JANUARY 25.2016 I DUNCAN CRAN STUDENT WINS (PAD PRIZE search ...

HOME NEWS

Hydro pleased with rulingson Site Cinjunction andjudicial review application

POSTED BY: DWIGHT FORD AUGUST 31, 2015

NEWSLOTER

Sign up for the daily

Energeticcity.ca

newsletter sponsored

byNLC

Your Email Addr

TThis Is Exhibit referred to Inthe

affidavit of

made before me on this.

day of 20

ACommissioner for takingAffidavits for British Columbia

htlp://enefgeUccity.caFartlcle/news/2015/0B/31/hydro-pleased-wilh-ruJin9s-on-sile-c-injuncfiorvand-jucficial-review-applic^c«

Page 33: BC Hydro Site C injunction: Affidavit #1 of Patrick Hayes

Hydro pleased with rulings on Site Cinjunctioi and judicial review application - Energeliccity.ca

TOP STORIES

Apair oflocal area First Nations is pushing forwardwhat it sees as the upside of a Provincial Courtdecision not to force B-C Hydro to stop some of theSite-C dam construction work.

The West Moberly and Prophet RiverChiefs arguebecause they asked the court for protection, the utilitywill not destroyold-growth forest or remove eaglesnests in recognition of the unique ecologicalsignificance of the Peace River Valley.

However, Hydro was the clear winner in this ruling,announced at the end of last week, along with anotherone in which a Federal Court Judge dismissed theapplication of the PeaceValley LandownersAssociation for a judicial reviewof the project,

. fl "We'reChoice is a Beautiful Thing pleased with

: decisions,"Explore your staffing options with AngusOne jg the right

B.C. and we

look forward to continuing with construction work. "

sam uave JANUARY IS, 2016

bSow. Man Charged Withbelieve Site c mansiaugliter fouris the right yggj^ gfl-gp Hedleyproject at the . , .1

concert death

PVLAPresident Ken Boone was disappointed butdetermined to move forward with his claim shared by

several other project critics, that Site-C needs to bereviewed by both the BC Utilities Commission and the ^Agricultural Land Commission. TrSCkfirS Spiit

"So far it's not working too goodbut we still havesome irons in the fire on our legal challenges with our

h«py/enefgeticcityca'ar!icle/nBws/2015rt)8ai/hydro-f^eased-wllh-rulings-on-sit6-c-ir5uncUon-and-jiKSclal-review-applic^on

Page 34: BC Hydro Site C injunction: Affidavit #1 of Patrick Hayes

Hydro pleased with rulings onSite C ir '̂uncfion and judicial review application - Energeticcity.ca

appeal on the BC Supreme Court one. That stilldoesn't change the fact that this is a horrible project.We're seeing that with all the different levels ofgovernment, and different groups and organizationsand experts coming out and saying we need a delay onthis project to get it reviewed properly. That hasn'tchanged at all. We're moving forward and fightingthis in every way we can."

It's also noted that in his 31 page ruling Judge MichaelManson found that each party involved should bear itsown court costs.

Share this:

in «

Related

BC Supreme Court BCHydro expected Hydro eyes mid-turns down Site C to announce dates July as start date

Injunction for Site C job fairs for Site Cwork tcAugust 2S,2015 this week beginin "News" September 22, Iime30,2015

2015 in "News"

In "News"

for Site C work to

begin

lime 30,2015

in "News"

JANUARY 18, 2016

JANUARY 18, 2016

JANUARY 19, 2016

httpy/en8rgeticcity.ca/article/news/2015/oa/31/hydropleased-wHlvrulin9s-on-sile-c-in]unct]cxvand-]udicial-review-applicallon

Page 35: BC Hydro Site C injunction: Affidavit #1 of Patrick Hayes

This Is Exhibit referred to in the

affidavit of MidLJkfJmade before me on this

dayof 20 Jk

A Commissioner for takingAffidavits for British Columbia

021

Page 36: BC Hydro Site C injunction: Affidavit #1 of Patrick Hayes

022

11/01/2016 Site Cwork camp constructit« upsdslocal residents - British Columbia- CBC News

Site C work camp construction upsets locai residentsAbout9,000 cubic metresof trees have been logged so far to make roomfor the work camp.

By Daybreak North, CBC News Posted: Oct 15,2015 6:25 PM PT Last Updated: Oct 16,2015 11:14 AMPT

Construction on a work cannp for theSite Cdam started about two months ago but that isn t stoppingsome local residents from taking a stand againstthe controversial $9 billion project.

• Work begins on massive work camp for Site C dam• Site C construction project for $9-billion dam approved bv B.C. government

Esther Pederson lives with herfamily on the banks ofthePeace River, across from theconstruction site.

She and herhusband, Paul Pederson have a clear view ofthe construction sitefrom the edgeoftheirfarm. Pederson says she cannot open her windows at night anymore because of the noise.

"BC Hydro works atnight aswell and they usually fire up their machines, it seems around 1:30, and theywork around the clock."

Pederson says the noisecomes mostly from the tree mulchers.

About 9,000 cubic metres oftrees have beenlogged so far. according to BC Hydro. That'sapproximately 300 logging truck-loads of lumber.

Pederson cansee the clearing from her property, which borders the Peace River. That's where TwoRivers Lodging Group, an ATCO subsidiary, is building a worker camp that will eventually house up to2,200 people.

Construction iswell underway, with 160 workers onsite, installing utilities, bringing in trailers, andbuilding a temporary bridge across the Peace River.

BC Hydro says it will also install security gates, fences, and guard buildings around the construction site.

But Pederson andotherlocal residents are not giving upon hope theSiteC project can be stopped.

"That's what they say, but we're hoping not," said Pederson of the seven years ofconstruction to come.

"We're hoping to stop that thing."

Tohear the hill interview listen to t/ie audio iabeiied Local residents uoset about Site Cconstruction.

With files from Betsy Trumpener

Explore CBC

hltp:/Awww.cbc.ca/news/canada/british-cOlimib»a/site-c-wak-camp-constructian-upsets-!ocal-resid»its-1.3273377 ""3

Page 37: BC Hydro Site C injunction: Affidavit #1 of Patrick Hayes

n

r

#

04/01/2016

[search the Alaska Highw ' Search :

Historic fur trade fort gets new life as Site C protest camp

Jonnv Wakefleld / Alaska Highway News

December 15, 2015 08 08 AM

Thl8 It Exhibit

affidavit of

referrad to In tha

made befora ma on thia.

day of. XO^

A Commtsilonar for takingAffidavits for British Columbia

Former Treaty 8 Tribai Chief Bud Napoleon stands at the old Rocky Mountain Fort site near the Moberly River, where SiteC ooponents have set up a protest camp Photo By Ken Boon

A fort where explorers Alexander MacKenzie and David Thompson took refuge is shaping up to be another

flashpoint in the fight over the Site C dam

Opponents of the project have set up a camp at the site of the Rocky Mountain Fort a provisioning post andthe earliest European settlement in mainland B.C

While BC Hydro has said it will remove any significant artifacts from the fort the site itself is set to disappearbeneath the dam's 83-kilometre reservoir.

Rocky Mountain Fort was lost to history until the mid-70s. according to Arthur Hadland. who as a regionaldistrict director sought to have the site recognized for its historical significance

"i tried the province—that was a waste of time." he said "They would not touch it. they just blew itoff."

aoM i««

location

of the

Mountain

Fort, just

upstream

http;//www.alaskahighvv'aynews ca/regionai-news/historic-fur-trade-for1-gets-neVi'-iife-as-site-c-protest-camp-1... i

023

Page 38: BC Hydro Site C injunction: Affidavit #1 of Patrick Hayes

n

n

n

n

04/01/2016

from the

confluence of the Peace and Moberly rivers

ftfe utJStream'frofrrtHe rribdtHl)f the Moberiy River on the south bank of the Peace. The outline of the

Alexander Mackenzie's 1~83 quest for a route to the Pacific Ocean.

aeeer6Siy4»e*4999«e*ete*)NefleflBeW($^ists David Burley and Scott Hamilton in the journal BC Studies It wasFnri St ^qf;r|rj,| jf]pn located at the mouth of the Beatton River.

fii.-f v-y r»

Ma<i<er;2iejiGtedarrabundanQB o^ammals m tne region which caught the attention of fur trappers with theNorth Wesi Company

The company had expanded its trapping operations into what Is now Northern A.iberta. and needed meat tc

provision its crews Early archaeologists discovered "tens of thousands" of splintered animal bones on the

Rocky Mountain Fort site suggesting i! was used for grease rendering

Local First Nations hunters supplied much of the game making Rocky Miouniain Fort one of the first sites of

sustained contact between European explorers and Indigenous people in the Peace

One such hunter, vwrking freelance drought ina lotai of 14 848 pounds of fresh meat to the fort according tothe joumai of a North West Company officer.

"It's the whole significance of that site being sc symbolic foi v/hites and First Nations." said dam opponent KenBoon, of the decision to Stan a protest camp there alongside Treaty 6 memoers The fact is thai its been

ignored by our provincial government and our federal government in the past'

Few knew about the fort until 1976, when Dr. Knut Fladmark, an archaeologist with Simon Fraser University-ediscovered it after reading a description of the site in DavidThompson's journal.

Fiadmark discovered "trade beads, lead ball, shot, lead sprue and small fragments of brass sheet metal"litteredabout the site, as well as the remains of three stone chimneys, a steel button, a knife blade and thebowl of a "Micmac"-style pipe.

"This site is remarkably well-preserved and completely unaffected so far by modern distuit)ances," Fladmark

wrote in 1985

The 2014 report of the Site C joint review panel noted Rocky Mountain Fort would be inundated should the

dam be built, despite Hydro's plan to mitigate the loss through "relocation, systematic data recovery, capping,monitoring and compensation in-kind (replication),"

http;//vwAV,alaskghighwayriews,ca/ieglonal-news/historic-fur-trade-fort-gets-new-life-as-site-c-protest-camp-1... 2

024

Page 39: BC Hydro Site C injunction: Affidavit #1 of Patrick Hayes

n

04/01/2016 025

While sections of the south bank downstream of the Wloberly River have been logged, the site of the fort

remains untouched. However, the area is slated for clearing, which will take place through the first three

months of 2016.

At some point, boat traffic will be restricted, making site access an issue, Boon said.

Site C spokesperson Dave Conway said Hydro is aware of the encampment, but noted it is "not presentlyinterfering with our on-site construction activities" in an email.

As of Monday, it was not known how many people were livingat the camp.

Boon said it remains to be seen whether there will be a confrontation over the site.

"I guess we'll see," he said. "(Hydro) keeps saying they'regoing to put (construction) buoys in, and I see theysay that initially, boats will be able to pass through that area. So Iguess we'll see what they decree."

reporter^dcdn. ca

© Copyright 2015 Alaska Highway News

http;//www.alaskahighwaynews.ca/regional-news/historic-fur-trade-fort-gets-new-life-as-site-c-protest-camp-1... 3

Page 40: BC Hydro Site C injunction: Affidavit #1 of Patrick Hayes

THE GLOBE AND

11/01/2016 B.C. Hydro orders protesters off land slated for logging near Site0 damaffldavR of

made bsteioiro ond*

day of 20 wlisinmMMfMtMM*

« ACommissioner fortakingAffidavits forBritish Columbia

It^AdChoices

B.C. Hydro orders protesters off land slated for logging" near Site C dam

" FORT ST. JOHN, B.C. — The Canadian Press

Published Monday, Jan. 04, 2016 3:19PM ESTLast updated Monday, Jan. 04, 2016 7:61PM EST

f-t

Members ofasmall butdefiant group arepledging tokeep protesting theSite Chydroelectric projectin northeastern BritishColumbia, despitebeing ordered off the land.

They set up acamp on Dec. 31, when EC Hydro and PowerAuthority issued an eviction notice whilepressing ahead with landclearing forthecontroversial $9-hillion dam.

The crown corporation gave protesters 24 hours to leave thearea known asRocky Mountain Fort,on the southbank ofthe Peace River, just afew kilometres southofFort St.John.

It warned that BC Hydro personnel will remove all contents ofthecamp anddehver it to ROMP butsuch action had not been taken by Monday afternoon.

Verena Hofmann, a Peace River Valley resident who was at theencampment over theweekend, saidcontractors appear ready tobegin logging athree-kilometre region that isFirst Nations territory.

"We'vejustheard that equipment has started up. It looks like they are intending to keep on cutting,"she said on the phone from Fort St. John. "Treaty 8 First Nation people are holding their ground andarenot moving from thesite, sothings areintensifying andchanging quickly."

Ms. Hofmannsaiddemonstratorsbelieve BC Hydrohasno rightto forcethem offthe land in themidst of ongoinglegalchallengesinvolvingSiteC.

m Several court cases raise major concerns about thepotential impact offlooding from thecreation ofa new lakeon the Peace River and the surrounding valley during construction of the dam.

" She said upward of about five people atatime are occupying the west side of the mouth oftheMoherly River inrotating shifts. First Nations people and other landowners are staying inasmallcabin that was flown to the bank, as well as a hunting tent, she said

ih.

It takesabout 30 minutes bywalk or less bysnowmachine to reachan areawhere contractors areset up, she said

^ http://vmw.theglobeandniail.corn/news/british-cdumbla/bc-hydr<>-orders-protesters-off-land-slated-for-lc>ggin9-n8ar-site-c-darn/articl^7997272/ 1/8

Page 41: BC Hydro Site C injunction: Affidavit #1 of Patrick Hayes

m

11/01/2016 B.C. Hydro orders protesters off land slated for logging near Site 0 dam -The Glolje and Mall

"There isno physical structure blockading BC Hydro's construction, it's individual peopleapproaching them and reasonably and respectfully pleading with them to cease construction."

Local people are trying to protect the land —significant because itcontains swatlis of old-growthboreal forest - until court proceedings runtheir full course, Ms. Hofmann said.

She said the group has asked that Prime Minister Justin Trudeau reassess the environmentalapproval granted for the project by the former Conservative government, in conjunction with theB.C. government.

BC Hydro said aspokesman was not immediately available tocomment.

The Rocky Mountain Fort was established in1794 by the North West Company as afur trading postand is the site of the earliest settler post in mainland B.C.

The damwill be the thirdon the Peace River, creatingan 83-kilometre-long reservoir that'sslatedtopower up to 450,000 homes a year.

BC Hydro announced in mid-December that aconsortium ofthree companies will be paid about$i.75-billion tobuild the largest components ofthe Site Cdevelopment over the next eight years.

ALSO ON THE GLOBE AND MAIL

Hydro One: It's a repair job (BNN Video)

027

More Related to this Story

^ httpJ/www,theglobeandmail.ccim/news/british-coluiTibia/bc-hydro-orders-protesters-df-land-slated-for-logging-near-slle-c-dam/article27997272/ 2/8

Page 42: BC Hydro Site C injunction: Affidavit #1 of Patrick Hayes

p-i

VERBATIM TRANSCRIPT

CJDC TV Dawson Creek

January 4, 2016

5:00 pm

Anchor: Ashley WIebe

"Ken Boon" Peace Valley Landowners Association

WIEBE: A battle is just beginning near the Site C Dam. Protestors have vowed to defeat [sic -means defy] an eviction notice issued by 80 Hydro back on December 31^. The eviction covers the areaknown as Rocky Mountain Fort on the south bank of the Peace River, upstreamfrom the moutti of theMoberley River. The notice gave protestors twenty-four hours to leave the area, which is due to belogged as the Crown utility clears land for the massive new dam across the Peace River near Fort St.John. Work crews began moving into the area this morning and were met by protestors. Ken Boon Iscontinuing to fight against Site 0, and says he and others will continue holding downthe fort.

BOON: We are used to their bully tactics, and y'know there is just too much at stake here toworry about that. I guess there is a line drawn in the sand now, and now it is a whole totally differentgame. I think if the general public could see what kind of destruction they are doing down here - andthen Christy Clark calls this clean energy: that is a mockery.

WIEBE: BC Hydro could not immediately be reached for contact [sic - means comment]. RockyMountain Fort will be destroyed by the dam, butdemonstrators say they won't budge because it is the siteof the earliest settlers' post in mainland BC, and was established in 1794 by the NorthwestCompany as afur trading post.

MThis is EjJiiblt referred to In the

affidavit of.

made before me on this

day of f—essoMee 20 ..Ik

A Commissioner for takingAffidavits for British Columbia

028

Page 43: BC Hydro Site C injunction: Affidavit #1 of Patrick Hayes

n

n; I

n11

1

n

n: 1

n

•P

n

n' i

n

n} I

n

n

This is Exhibit referreci to in the

affidavit of

•nade before me on this

-•ay of 20 ..ife—rr-—^

ACommissioner for takingAffidavits for British Columbia

029

Page 44: BC Hydro Site C injunction: Affidavit #1 of Patrick Hayes

(iSt

First Nations land occupation alms to stop Site C

Treaty 8 members say $9 billion mega dam being built without First Nations' consent

By Betsy Trumpener, CBC News Posted: Jan 05, 2016 6:54 PM PT Last Updated: Jan 05, 2016 9:25PM PT

A small number of Indigenous protesters are trying to halt Site C by occupying land near the mega damconstruction site. Construction on the $9 billion dollar dam project has been undenway for four monthsnear Fort St John.

"Wehave a peaceful protest camp," Yvonne Tupper, a Saulteau First Nation woman from Chetwynd,told CBC News.

"Site C is infringing our treaty rights. No Treaty 8 First Nation has ever given consent priortoconstruction. And it's an insult and an assault to continue construction while there are pending courtcases."

• Full coverage: Site C dam

Tuppersays local Treaty 8 First Nations set up the protest camp in late December, with helpfrom localranchers and supporters, on traditional lands at Old Fort camp, on the south bank of the Peace Rivernear the confluence with the Moberly River.

The bush camp is a half hour hike from a newly-built temporary Site C bridge. Protesters say the camphas neither cell service nor road access. Tupper says she hikes in from a rough back road. She saysprotesters are keeping warminthe bitter coldwith wood fires, while sleeping intents, lean-tos, and ahand-built trailer.

'We're not carryingweapons or anything; we're having a peaceful protest to identify our lands and postthat this is Treaty 8 territory and you're trespassing," said Tupper.

in a video exchange dated January 2 and posted on social media, Tupper, dressed in a toque andsnowsuit and another protester speak on a snowy bridge with a man who identifies himself as aconstruction site security guard. The man tells them they have to leave "the active work site." Thewomen notify him he is "trespassing" on Treaty 8 land.

^ North District RCMP Corporal Dave Tyreman says police have not been contacted. Tyreman respondedto an inquiry from CBC Newsby advising, "You would have to inquire with BC Hydro as they have theirown security."

Hydro in discussion with protesters

BC Hydro says it is working to resolve First Nations concerns.

"BC Hydro respects the right of all individuals to peacefully protest and express their opinions about Sitei-t C in a safe and lawful manner," said BC Hydro spokesman Dave Conway.

"We are hopeful this can be resolved. We are indiscussions with the protestors and local authorities toallow us to resume construction activities. BC Hydro is evaluating all options and will continue to monitor

030

Page 45: BC Hydro Site C injunction: Affidavit #1 of Patrick Hayes

the situation."

TheSite C dam project will flood a valley 77 kilometres long. It's long been controversial in theregion and is fiercely opposed in some quarters. Until now, non-indiaenous ranchers wereat theforefront of anti-Site C activism.

The B.C. government says consultations with the local Treaty 8 First Nation began in August 2014 butwouldn't say ifthe two sides had reached a resolution.

Several lawsuits by environmental groups, citizens and First Nations to try to stopconstruction ofthedamare proceeding through the courts, butthe court cases haven'tstopped the building process.

Construction of the almost $9-billion project is touted to generate about 10,000 jobs while itfloods 55square kilometres of river valley between Fort St John and Hudson's Hope.

Proponents say SiteC will boost Hydro's energy supply by eight percent, enough electricity to powerabout 450,000 homes per year.

Explore CBC

CBC Horric Mui-iC Cornec'y CBC Connects

TV Anc-

Radio Kids

Books

Parerv.s

Digital Arct-iives

Games

fviews Local

Sports Docun'ierirsn^rs

Aboriginal

V/eather

Contests

Site Map

mStay Connected

Mobile Podc.asrs Nevv-sletters & Alerts

Services and Information

Locporate Inro R'-iise Perniissioi" CBC Shop Jobs

Ptiblic. Appearances Termsof Use

Commercial Services PrivacyPolicy

Help

Contaa us

Doing Busine.sswith Us

Renting Facalities

(Sa^

CBC IfP Radio-Canada • u A'r.e? «

031

Page 46: BC Hydro Site C injunction: Affidavit #1 of Patrick Hayes

21/01/2016

Search lieAlaska Highw S&3f:h~|

Former PRRD director Hadland arrested at Site C protest

Bromvyn ScdIi 'Alaska Hioriwai News

januarv 6 20i6 iC 05 AM

Thta Is Exhibit ^ Js;... referred to In theaffidavit of

made before ma on thia

day of

•teea M* • I

zf--

. 20 Jk.

A Commlseloner for takingAffidavits for British Columbia

FciTrefOeact Ri,g-fiegiona Dstncldireao' arc vacaiShe Caarr ooponantAniu-nafliaMwas eTeslao dunnea proieslagams' Iht St E-Oiiipr d'Pissiv\emeSDay mcrnmc ^rioicByBrctrwyi' Scah

FORTST.JOHN—Arinur Hadianc IWforme' 'egiona' flisi'ic! airecte-ano a vczz' opponeniofme Sue C flam was arresiec fc mistmiff Qiirnpa proiest i.'vednesaaj morning ai me 256Roac enirancfc tc me dam s consirunior. sue

Hadlandwas me fusiic siano mfromofconsiruchonveniciessiiempimgic enter ano leave tne sits he was soo^ loineo Dy i nandfj' of oinerswnodanoeo logemer to Oiockaoe iralfi:atme sue wmie a second proiest formed at the Oio f on Roao sue entrance

hadiano is me second activist ic be arresteo tor protesting the dam m early December feiiow proieste' MarkWieiert was arresieo for breaciiino me peace

Meiers organized bom protests and toid mt Aiasne Higrrway News ne is wiiimcto be arrested agair

YOU' bet' he said

\'<it have one Peace Rive- vauey and we dor t wani ic see n destroyed lo' corporate greeo'

ProiesiorE o-i ine 266 Roac bicckeo traWr frorr. entering tfie Site C oam vrod' site (or about an hour before police amveO t'lfeO'iesoay • Brcnwyr Scot!

hadiano coulc not be reachea for comment Yveonesoat ahe-nob-i Norm Distnc; RCMF Dp: Dave "yreman nsc no Oetausof the proiesi from the Fort St joh-. detschmcn! Cypiecs tmie11L unoear if anc wnen Hediand was released "here were reoons of iwc adOiUona' afres-s novveve' mnse cotiio not Be cohfirmec

Meiers ano Hadiano are no; aicrie ir. ihei' commttmeni t: protesting ttie oarr-

fiAike Kroecher 75 has iivec m the Peace S"n:e tSf5£

1IT. sr oidlimer and i ve becr^ opposed from say one Id this idiPti: scheme A-.sif can stop n i w:l ' ns ssiC

Spmeiimes as human Bemgt we car t ust srvrays sif cr une stoeknes we have i: make a sisnc snc mts is it A„nc f me; went to arres' me s: ce i,'

http://www.alaskahighwaynews.ca/regionai-news/site-c/former-prrcl-director-hadlanci-arres.. 1

032

Page 47: BC Hydro Site C injunction: Affidavit #1 of Patrick Hayes

21/01/2016

BC Hyoic secumy was or- siie e^o maae Ifie cait lo poi ce once lie Diockaae s;anec ai &aS sit, Traffic was Wackea 'or a'' noir belore RCMP arriveo

'IIwe nao le gei an ambuiantemo-outngnt now wea Oe kma ofbare presseotr get tnataone ano sc ' a hke thaitc be g iien aiiention toas soonas possitMe ' ens security officia sa oin an interview He wouts noi give fus name explaining thai ne s not a Site C spokesperson

•ave Conway a Site C spokesperson :ouia not be immeOiateiy reacnec for ccnmeni

A meoK was also on nano ir> iigni of ihe ingn -21 C tempensiures

°fOiesiors luniJie Ic warmti" m 2* C temperatures at the oain site entrance on Olc Fon Road - BionwynScoli

•nne protest nowe'rei conimuoo atie- MaOlanc was taker, away v.-iih same of tne aci-visis ai Ihe 26r ftoac sue leavmc to; the lasser aitenaec proies' on Ois For Rose

Ncbody 81the Oic For, site was oiockaong traffic by ine iime the Alaska Highway News amvec a' " X a m

First ii was lus: tne thrtte of us inree o- lou- o' us ' saic Rua Neighbo- who was Dorr anc raiseo ;r me a'es ano opposes ihe oam

Tnere wasn | vsfv mucf iraffichere untii later unh now '''hefe was one truck anc one piece of eguipmeni came out" she sac

Fhe proiesis agamsi Site C are romping up Rougniy a opren people have occupiegthe hisionc Rocky Mountain- Fan smce mioDecember oespite an eviction noticefromnyorc

Ssthe' Reaersen wm was proiesimg Wednesdav saio sns o iikeiyoe loinmgthai grouc nex; week

She lalDthe Alaska Highway News she s a'sc reaoy t: oe

arresieo

"ep At some point prooabiy owi at the camp she sac

oeacerepio'tertga'irifs, cf

C- Copyright 2C1E Alaska Hignw-ay News

http://www.alaskahighwaynews.ca/regionat-news/site-c/former-prrd-director-hadland-arres... 2

033

Page 48: BC Hydro Site C injunction: Affidavit #1 of Patrick Hayes

» i

n

n

n

i>ditUil

-i^idavit of

ielt;nod lu ill thu

nade before me on this

:fay of 20 .J.k.

A Commissioner for takingAffidavits for British Columbia

034

Page 49: BC Hydro Site C injunction: Affidavit #1 of Patrick Hayes

Oa'01/2016 Site C dam protesters dig in and prepare for arrests at historic site in B.C.

Site C dam protesters dig in and prepare for arrests athistoric site in B.C.

BY KEVEN DREWS, THE CANADIAN PRESS jANuARV 7, 20'i6

Helen Knott, shown inthis undated handout photo, a memberof the northeastern British Columbia's Prophet River First Nation, isamong those protesting the construction ofthe$9-b!llion Site C hydroelectric project. Aprotest camp has been set up at RockyMountain Fort, the former site ofa North West Company fur-trading post established in1794on the west side of the Moberly River,near Fort St. John. Protesters say they are willing to be arrested. THE CANADIAN PRESS/HO-Heien Knott

First Nations protesting the construction of the $9-biilion Site C dam in northeastern British Columbiaare preparing for their own arrests while they implore Prime Minister Justin Trudeau intervene to stop

the hydroelectric project.

Helen Knott of the Prophet River First Nation said in an interview from the protest site that she and

six other demonstrators are camped at Rocky Mountain Fort, the former site of a North WestCompany fur-trading post established in 1794. near Fort St. John.

RCMP said they arrested three protesters on Wednesday who had been blocking an access roadneeded by BC Hydro crews to begin work on the dam. the third on the Peace River. The dam willcreate an 83-kilometre-long reservoir and flood the area where the protesters are camping,

http://www.vancouversun.com/story_prlnl. html?id=11636286&SFon5or=

035

Page 50: BC Hydro Site C injunction: Affidavit #1 of Patrick Hayes

08/01/2016 Site Cdam protesters dig in and prepare for arrests at historic site in B.C. 036

BC Hydro and Power Authority have issued an eviction notice, warning protesters that all contents of

rm the camp set up on Dec. 31 will be removed and delivered to the RCMP.

#Knott said the protesters are hunkering down while weathering snow and temperatures as low as -20C, awaiting the possibility of arrest.

"It's not necessarily anybody goes into it with that idea, like, yeah, we're going to be arrested, right?

It's that, yeah, we're committed to saving this tract of land and to, you know, actively use our treaty

rights here," she said.

Knott said she would rather not be arrested but is willing to be at the camp and take a stand on the

issue.

Site C spokesman David Conway said the protest is affecting a small clearing area but all other

construction work on the project continues. Contractors had been prepared to log the area where1*1

protesters are camped.

„ The utility hopes to resolve the situation through ongoing discussions with protesters and localauthorities in order to resume construction, he said.

"80 Hydro respects the right of all individuals to peacefully protest and express their opinions about

Site C in a safe and lawful manner," he said in an email. "Our immediate concern is to ensure the

safety of both Site C workers and the protesters."

Several First Nations and local residents have filed legal challenges over the dam, raising concerns

^ about flooding and the impact the lake will create.

Art Napoleon of the Saulteau First Nation said in a phone interview from Victoria that the lake will

^ flood the historic site and other sacred areas.

"That whole.area was a culturally significant area for us, for hunting, trapping, fishing, gathering, a lot

^ of history, all of our history, so that's our cultural institution and it's being raped, and it's still notenough," he said, adding he hopes Trudeau can get involved.

(*i

"Well, I don't know what exactly he can do but it's worth a shot, isn't it?" said Napoleon.

The protest camp is in a remote area. Knott said once protesters leave the main highway, they must

drive on rough, secondary roads for 90 minutes to two hours before making another seven-kilometre

trip by foot or snowmobile.m

The timber needs to be cleared before birds move in for nesting in the spring, and provincial Energy

Minister Bill Bennett said the delay would make the project more expensive.

"Government wants to be respectful of people's right to express themselves and their right to protest.

« We accept that," Bennett said in an interview. "We have to balance that with the right of the BC Hydro

ratepayers to expect that this project would get built on time and budget."

^ http://www.vancouversun.com/storyj3rint.html?id=11636286&sponsor= 2/3

Page 51: BC Hydro Site C injunction: Affidavit #1 of Patrick Hayes

0^01/2016 Site C dam protesters dig in and prepare for arrests al historic site in B.C.

Bennett added that government agrees construction should proceed despite outstanding court

cases. He said those in opposition appear to be using the legal system as a stalling tactic, and also

noted the courts have mostly sided with the utility.

Opponents have been stating their case for a long time, but "the fact of the matter is the majority of

people in the province don't agree with them," Bennett said.

About 75 per cent of the 600 workers currently on the site are from B.C., Bennett added.

BO Hydro announced in December it would spend $1.75 billion to build the earthen dam, foundation,

two diversion tunnels and spillways.

© Copyright (c)

Previous

BG

HERITAGE SHEHOCKY MTN FORT I

ES POST1«?(

Helen Knott, shown in this undated handout photo, a member ofthe northeastern British Columbia's Prophet River First Nation,is among those protesting the construction ofthe $9-billion Site C hydroelectric project Aprotest camp has been set up atRocky Mountain Fort, theformer site ofa North West Company fur-trading post established in 1794 on the west side of theMoberly River, near For! St. John. Protesters say they are willing to bearrested. THE CANADIAN PRESS/HO-Helen Knott

http://www.vancojversun.com/slory_prinl.htm[?id='i1636285&sponso-=

037

Page 52: BC Hydro Site C injunction: Affidavit #1 of Patrick Hayes
Page 53: BC Hydro Site C injunction: Affidavit #1 of Patrick Hayes
Page 54: BC Hydro Site C injunction: Affidavit #1 of Patrick Hayes
Page 55: BC Hydro Site C injunction: Affidavit #1 of Patrick Hayes

This Is Exhibit referred to In the 041

affidavit ofy-QfU

made before me on this

day of.....•e^lfiiftjeseewea^•eae•et•e••20 .ik.

A Commissioner for takingTRANSCRIPT Affidavits for British Columbia

<*i This is a transcript ofan interview with Ken Boon posted on YouTube by Jonny Wakefieldof the Alaska HighwayNews, on January 13,2016.

Downloaded at; httDs://www.voutuhc.com/watch?v=w7Cvg2Evdu4#t=44

This transcript was prepared by staff in the Document & Software Support Servicesdepartment of Fasken MartincauDuMoulin LLP.

Interviewer: So, do you want to tell me who you are, and why we're here?

^ Ken Boon: Ken Boon. And here we are justupstream ofthemouth ofthe Moberly,holding the line here, tosave this valley from destruction. The deal-outcomefor the whole situation is for Site C to be stopped.

Right now, what we're looking for is, you know, isjust to stop this, in orderthat the court cases can be - run the course- um, you know,the pendingcourt

n cases, and then we go from there.

What they've done, they've put a temporary bridge inonMoberly inorder tolog. All this river's flat for a long ways up river, and Eagle Island - that's theirintention is to log all of that, so, so, this isa very important spot here toholdthe line.

A couple ofthe Treaty 8First Nations are waiting for a decision incourt on theissuance of those permits - whether they wereconsulted properly - so, so,they're getting way ahead of themselves here bytrying to log this.

Well, the old camp shack that serves asa cookhouse, and a bitof a bunkhouse,and then a tent with a heater in it, and now we've brought,you know, we havesomemoretentsnow,andwe're just slowly building it up.

Wedon't, we'renot trying, we're not encouraging to many people to comehere, justbecause ofthe capacity. So we rotate people inand out. But, wehave, there's a lotof interest inbeing outhere, you know. We're managingthat sothat people, you know, we can justkeep a manageable amount ofpeople here.

When you have the past Area Cdirector getting arrested, you know, ataprotest, and, 1mean, look atthe wide [gamut] ofpeople who are stepping up,and just saying, "this iswrong." You know, and you know I mean, you know,we're peaceful-type people, and it's, you know, we've reluctantly come to thispoint, but, you know, there comes apoint where you just have to step up. Thattime has come.

240150.00163/90631633.1

Page 56: BC Hydro Site C injunction: Affidavit #1 of Patrick Hayes

bay "NU" to bite "C" uam! 05/01/2016

Say "NO" to Site "C" Dam! Karen Home 20*

ISearcn thisgroup

; Join iNs group lo post end commonl Join group ;4,276 members

S !1

1 * S& ^ 3£ % ^« « ®!e 5 ^

*" 1 1

• :

^ i

I «

I ^3I c E: ^ 3

I So

1 £ XIS b. (0

I SI: O£0

!i ss11"l! o'>

1SII %

^ \•a t

• -• Varena Hofmann

3! December 2015 al U 00

Pulling your words and thoughts into practise and action! - headed lo theRocky Mt Fort Camp, along the south bank of the Peace River.

Al)indigenous and non-indigenous people ready to stand up for what isright and save Ihe Peace River Valley and the integrity of Treaty 8 areNEEDED &WELCOMEI

Helen Knott, Trenton Fox, Emily Gardiner, and Ken Boon are blazing thetrain Let's follow fheir lead!

Words &photos from Helen Knott-

Pholo 1:

Packing for tomorrow, where Iwill be heading out lo the bush camp at Ihehistorical site of the Rocky Mountain Fort along the Peace River with youth

from different FN communities. The site is In the flood zone of the purposesSite C Hydrodam, where they have started clearing old growth forest Inspite of pending court cases I cannot think of a better way to ring in the

New Year then spending it actively reclaiming the inherent right lo be In myterrilory. on the very land my ancestors lived upon, along the river that is amain artery in the body (hat sustains us in the North. It is ours. It is a part of

who we are as Dane Zaa, Nehiyaw, Tse Keh Dene people. IIis a riverloved and fought for by Non Indigenous people who have connected with itand lived In die valley for generations as well. Together we can make achange. Iwill not stop believing that the right thing will hold out. it is not in

my nature to accept defeat or stand silently by waiting for the worst tohappen. I remember my ancestors voices. I remember their strength. I am awarrior. Bush camp here we come ffancestors #land iHkeepthepeace

#redam3ticn ffindigenous fffortheloveoriand ffdecolonize rrfuckoppression#lakeastsnd #warrlar iVbc #peace Analive

Photo 2:

"Only beavers build dams"- Trenton Fox, while looking at the PeaceCanyon dam on the #peaceriver. #keepthepeace ffthroughindjgenouseyes

http5://www.facebook,com/groups/5491717354/permalink/l 0156703959932355/

^ Say "NOrlo theproposedsue Cdam.,do n... ;

CREATE NEWCR0U!>8

: Groups make it easier than 1! I ever lo share viSlh friends, | rea egroup j ,• I family and teammates ;

! : RECetVT GROUP PHOTOS

SUGGESTED GROUPS

W» Support Ihe Unlsfot'onand the Wet'suwot'en

Grassroots r^ovemsnt

4,041 members

Idle No More - West Coast

Turtle Island

4.602 mBTibers

Join { i I

Page 57: BC Hydro Site C injunction: Affidavit #1 of Patrick Hayes

aay'NU"lobite'U"uami

Say"NO"loSite"C"Demi

LillianOawnaPtorrolwiisniDeywouldhavedidthatforuswhenineyFloodusoutin66

UKb331December0015atId2"

EllzabaihBlQgarAwesome

Like1SIDeccinba'SOiSallddi

LoborgMilchSUcoyPeopleshoulddosomeinvcsllgaUonsonIhapeopleelthelorelronio(constiuctiwiIknow(halsomeofthornareuneducatedandit

takespeoplelikethistobeattheforefrontolsuchprofocts

Like321Dt)femBsr20l58115{TV

LillianDawnsPierreYestheylookadvantageIhiSwaythat'showIheymadethedsmfoolinguneducatedpeoplewehad

Liker<iOecombor3915311147

LobergMitchStaceyBecausePer^eIlkaJimHorkolfsliouldnotbeconstructionmanagers.

Like131Decenilier20i5at1510

BeoihueBosoldTheremustbeastand.

Like121Dscombrir2015at1655

LoborgMItcliStaceyGovernmentCorpsshouldhaveMineducationlevels

Like21December3915ai16ie

JanicoTimberlekeWisnIcoufdbewithyouInmyihoughlsfromiqaluH!

Like21December2015at163S

LobergMllchStaceyMotabunchofHighschooldropouts

Like131Oecombor20lSat1641

LobergMllchSlaccyRunntngaDem.

Like131December20158!1641

RachelBlattyoutrailbluersAREAwesomeyouareneiosofthePeaceRiver!Haveagreelcampstandyourground'

Like431Oacerriher2C16anQ07

D.LynnChapmanStaystrong!Thankyou'

Like31DecemBer2015ai2344

BarbaraOaloyProudtoknowyouguys'

Like11ianiirjryal1148

BanBaniailImproudolyouandaUthaterethereIMSIsareyeariwinmeelyousoon

Like7Januaryel23I3

PhilKirtzingerIsiinotpeoplehornineSauReaubanddoingthecutting'orIsItsomeotherHydrowtwresT

Like3Jfiii'.iaiyat0?53

9|RachelBlattitIspeoplewhoareMredbySCHydrotodestroyourValleyIheyarefromANoverbutfewactually'FROM"PortSIJohn

Uke13Jonuar/a;1010

https://www.facebook.eom/groups/5491717354/permalink/i0156703959932355/

SUGQESTHOPAGES

HughJaekman

PubficFiguie21.958.464hkcsAlexand4otherlilendslikeMm

,LikePeoe~|

Ui/UI/2Ulb

EnglishiilK)'PnvacyTermsCeoloes-AdvenismgAdChoices•Moie

FaceboakO20lG

Page 58: BC Hydro Site C injunction: Affidavit #1 of Patrick Hayes

1

Pi

1

1

06/01/2016 Verena Hofmann - Photos frwn Verena Hofmann's post 1Facebook044

; • I'

Photos from Verena Hofmann's post

Bscli 10 A'hiin-

1 ROCKY mFMIWBTYCFIlBni

NOTFESttSOi

JinBrrma

f^revioijs Najrt

This Is Exhibit 1 referred to in the

affidavit of

made before me on thisr-tk

day of 20

.2^:.,

Verena Hofmann Ssy "NO" to Sllc C" Dam'1^^^ Treaty 6Memtjers fLtoR Trenton Fox Helen Knotl ano Emily Gardiner) Putting Up Signs Hofmann's pcsi

at Camp

• Jen

Maryltn FX. Brandy Little, Devon Bowden and 26 other? like iriis

Barbara Daley Way ic stand up for the Peace!

Rachel Blatt Hey there's the Flying Fob dropped down from theskies I! a legend In the making weii si least s Dam Good ViralVideo I have video clips of its launch and drop!

. ike '2 - f.'.; r,f

From Photos from ^-erena

Shared v.rlr Public

Open Pliolr. X'te.ver

Download

A Commissioner for takingAffidavits for British Columbia

"iig.n Up Log In Mcsseiigi;! '^scebook Lite fVionils "ind Fnenrir. Badges People Pages Places

'iaintJ uoMiioris Abd'.ii Create Adve-t Create Page Developers Careers Pri'.'acy CcoKies AdChoiccs

Terms Helo

Facebaak®20lC

Eriolish (UKl

htlps://www.facet»3k.co"n/phplo-php?fDib= 10153845461772744&sel=pcb.10''56706111W7355&typs=3&theater 1/1

Page 59: BC Hydro Site C injunction: Affidavit #1 of Patrick Hayes

05/01/2016

SItr- 'I

Jliii. Hoslecl ri> 'r i'Onnfc liinDfli

.ai ..-sr. .iSf'Lia-* 'f

I.T -iai i/CK'Pr/iPjfl'i ifiai 12 0C PW

V'.'".e e Vore'. =.^-e '/lef'-s "r-e Wio^iv =-eace -f.'e- 5t;

Be Idle l>loMore' Ou- Rivers needs us now' Save our Water ways' Protect

cur lane animats agnoullure atrandfow. envirortment 40 years ol

proteslinc done anC 40 more years tc go unti' this mega Dam proieci isceased forever

Man) supooners oppcsiric Site C locally regionally provmcialiy nalions

wide iniemationaliy anc world-wtde Please continue to more'

Ou- Grand Chie' ®riillips sialec he will join ine camp ano gladly be arresleo

ic Slop Sue C

Davio SucuKi lone time proiesior opposing Site C stated Treaty Rights tsput Ic the test anc will win this battle- we musi all join together'

West Iv'ioberly Lake Chief Roianc V/ilson this noi-so-ciean-mega dam is noi

needed Ken and Anene BOON-®'.'£A l£ Mere

Garth Lenz captured pnotos o' Site C ' Peace River before and during

consfructior

Cheer oui the photos

^'tt'...r'_-9043; Site C / Peace River: Gart!) LenzSue • Dam ocniru-icr. feact R'ver vsliev

https://ww\v.facebook.com/events/1501364853502402/

Gdiny

pus Sir

57 1.7k

ims c-s cd going invited

mvi-rt rr-ir-NOS

A03 inorWi IC Ih 5 eveni

i-r'pii5'. OSi P'lvBCy terms Dt>Ok«es-Ojemsing ic rtswcet Mo'6

045

This l» Exhibit

affidavit of ......

—iL... refarrtd to fn tha

made t>efore me on thla

day of

Zt-

.1••••••

20

A Commissioner for takingAffidavits for British Columbia

Page 60: BC Hydro Site C injunction: Affidavit #1 of Patrick Hayes

05/01/2016

Aucfe) Moore Eiyra J^v^tc'n Skcaana RaspDerrye ano a o;n6rs like this

Oearrng Dean i arr. wiir you rr spitn

VIckf Creel' srr lisieninf tc Le.*»zsTED lelk in/icrona BCin20li Minaboggiiac

Patrick McGinnis

The true t'osl of oil

iTvtia! Does eiivironmsnta! asvestaiio"' actually iook iive"

k: TEDiUiciorta phoiograDher Ganr teni snares

In case you missed it

AFTN News interview tnank you Tina House Reporter She is from

Dawson CreeK BC and has done an excellent pb beinc updaleo vAtt-events And had watched our first video released

This IS also or the APTN fc wall

aef Summe: Naciura- -oeicne bie'an f . gnmanr -isms eno oiners like irti:

Joe Thomas rtner. ihe\ apfiy ic nee pe'm-i ihet nean tt inr.iudetrie - ifjiPeooir 0' the Lanoe the cnutr- art "lacking rr.upnotdng this " anc tharQufcslot tacJ B=rr-ii; nai fie o/far nermii " Cojns siiuuida askec txr ngh'

npi depe'K; c i; cfeing prese-iiec O' 'onvais cr. la/.yers rts svntier. ripm m

ihE a-.vs 'teen: re-jues" e :-anas i'.udde n

Yvonne Tuppcr .i;ie thsi t nierestnc i w keep that m mms :s tmr irjecu'ifnt stif

Way to go' A Treaty B metmbe' rnaoe a felte' bunche- turn arounc totday

https 'm facabock cor story pnp

Difsplti- exiction iKitiff, Site Cprottsicrs sa\' they're ivii suingan'v"v\-h<?rc-

https./VvA'Av.facebook com/events/150l364853502402y

046

Page 61: BC Hydro Site C injunction: Affidavit #1 of Patrick Hayes

05/01/2016

S!t^ajcI'-OVt-sS-..Jir.!:a"p^afI'lt

"ea:t.'g;savit^e;'enaias'aaanywnereotspuga-ev;:ti5^naiicefrsT3CHydT'ODzenpeapie•ppasedicineSSE-aiNianoarrasi'gcee"

EelcSLffnrr.e-Uaa'MjraAcgpcae^'amesPalisana"3alinerfii^eims

iJ

(1

JoeThomasRescgnniar.camesI'isfionle^rr.i-,clonesaooecrtihErt-raaniiporove-a!'

JoyGonzalez/•.me-

Susaninmannonsj'ea-lotNfiMnvsimeetnsozii

TeaCreeli

i.T..'e•.1-•.••U-

Willdonaiea(luteicmeissuemyasidute.aonaiedgoi25E5

mips'ivv/v.fanepco.'CDm'r";"<i;iepni

SielaniE.s'lnianrHamsRaatie;anaafPennvBooenancfoHiensi*eirns

TeaCreekP:ok;nocj"I'u.fi.ntto3aiFjcsir!oira\»

IK.;.p>;

TeaCreek-uifR

m

TeaCreekHjooi'ioear-sisnai'iJSlikethelasiluteIhalamoo'ialbo

OiniZeToghestiy

KnawIhatyoi.areal.thehoitopicaioundUrns!atenCampWe'i:winthis

Vi'aronmanyfronis

•cressSiimnit:Sre'e'ieLePn-.Enn-ssmr.-oe'riojTissano1Pothersliketrus

https.//vAvwfacebooKcom/events/'501364853502402/

047

Page 62: BC Hydro Site C injunction: Affidavit #1 of Patrick Hayes

05/01/2016

Yvonne Tupper Tnaak yaj al! spotifeabout you toe ove' ine'e as wel;Gooa wcft Fiesst caai nue lo stand yoir groundF-BSSf isi! Prsaa after • waicned ne- stance m rnany vitjecs gave me sifengit-,

"nani vs.-

n£. ','iangfcD me iirt - o'• ie event to i-^ y-.-steraa.

li 01. m Mortda* -E-iuarv 'Fat '200pm

* inc- Yjppct

-t,i£ 1.^, s- '" V.a'i

•"Any mteresiea local or neat first nations indiviQuals ano or non-abonginar

v/ho are opposed Site C thai v/ou(d like to join the

'Peaceful protest camp" to protect out Peace Valley

please contact either verena 250 "93 "124 myself by private rnessagino

me or commenting and Helen Knoti-vis Facebook

jase Jimenec Desnns •apiey Cate' Deania Dear anc r otners litre thit

Dawn Turner' wish ' were aose*

L esK- da. ,v '.

Vicki Creel Prayers uf fo' vciofi

pr-ic'da. n t: • 'j."

Rachel BlaR Deiore yOuset cani • Here is some Odmmmmeni to*thosewhc. are IOC d—5d-'10come out ano suppon our Vaneys'I'll; ttt'l r.a .••in • •ii'-irosr.-ri.jTiS''. •.•....•r ?,;lt

.A.nti-pipelint grandma, willing U.go lu iaii.arre-sled forvkilaling R.C.coutl order

'•If (in. .ii ' ' .n

Spreao the word

APT'n' NEVYS-Ms Tina House -Reponei interviewed me today

She mentioned Rocky Mountain Fort Camp wii! be on APTt\! liJEVt^ tonight

.jroo Isrrc'vr /.nac've wO'fOOfe jCfse jsmener aifi l>Kt ris&

Here are sidme signs tha-, v.'eie made and be posted at voulh Carnp atRocky Mciuntairi Fort Camru-.iar i 16

"More signs are needed'

Sin Elders Buddy &'•'vonne

Pajjine '• vonne S Betsy supporting the No Site C -youtn camp'

https;,-'/vw/w facebook com/events/1501364853502402''

048

Page 63: BC Hydro Site C injunction: Affidavit #1 of Patrick Hayes

06/01/2016

S',

jose Jimens: Paj ChBo-ceier' Waa^e' Mar.ar *'sniDi3> af'.a "f c-l'>er6nke fi'S

Nancy Anderson .Vas tnal yeslerosy'

Yvonne Tapper ii is on^orng unv cor.slrjctia:* is siospw

. • 1 ^ 1- - ill

Yvonne Tapper O- yoij mean: pidure yes

Rachel Blatt Posiec unit spnng oreak up c: unli inis tninj ts s!QW)eO I hope'

I T.; ' di .tf. . il'

Nancy Anderson •A'rte-. are u ooins "i vonne' Yvii' c : ootng eueryoaj'

Yvonne Tapper • an leavng iway ic cemj "Thiscamp y'- neeo a A>^ s: ian. caicnma a nde wir Verena

. ill '• •IHJl'i

Nancy Anderson Or. snap oli den

Rachel Blati laKe ea- piugs » yo- far sieecng'

Yvonne Tapper Nc won was gcmc on-we musi iiac sioppw ihem v/herHeter Em.iy en: "rgriior. gave inerr me lirs' noii» c-' trespassing o'. Treat* Slemic'v Srnar Victor*-lo'us

Rachel Blatl iove: itus -epx wne' r came -ou' "lere 'S sc-me Comm'itmieT

to mo-st v.'oc a'f. i-o-o to ocme ou: an: suppcri oj- vateys

Anli-|ii|)t*line ftrandina. wiliinj: tti In jiiil.1 arresltrci for \-iryiatins BX . mun ordei

Ocanr^a Oean

"his lint If fio/r 2006 bat ti might provioe some waie- insights ans open up

watei pioieolion altiancef with oltie: "HweiKeepers'"River Keepers'

Mips (.'youtu tie''>D/0 MG5UYI.-

Manies LabuOe P«ase sian t- peiit'S' ' w--'. suf sdicc .rtiTied-'Sieii

f , 't' ' tl't

IM f.'K .terj'if eri 'O .1? nepf?*

Thanks tcr the invtstion •"ency Go'Je-o ' l v/ish I ooula come ' My tract, is m

the shop ana ive been v.'O.-king 2 )Cbs just ip sustain my life and can notafford any lime off toe fat behind • would like to Donate some original art

please let me know of any calls for siienl auctmr got^ris A painting i

httpsj/wvfiw.facebook com/events/1501364853502402/

049

Page 64: BC Hydro Site C injunction: Affidavit #1 of Patrick Hayes

05/01/2016

planned ic donate was recenUy sioier, so i made a d'ev/mc instead stii'

needs a frame

Tjan eea Casiel Srianno'- Hecxe' Jeanne Rio-ji ann ; aine'i i*6 inis

"O't ;)-r>niei;;f

Audrey Siegl (nacamat ci

We are ons'

jA' 't ' A'

OInl Ze Toghestiy

Nachurali Abelone

W n..,cinn:rn:> V Haooy'Je*. rss-

' upOf • sc ne - vent pnoU-

fit :

M

r^iisifeianbo- i^s-j IPewien v'/soner t-n Ern-;.-. snt: ninerf'ii-e r.-j

https://\WA'.'.facebook.com/events/1501364853502402/

050

Page 65: BC Hydro Site C injunction: Affidavit #1 of Patrick Hayes

05/01/2016

Ann Brown .'js: n-tar.e$ ai wnat ins) are asms i; the pespta GeiOj: "

. s- .J'l .•[ r-

jennrle^ SoaerQjts', Pa.j ~necv,eien lA'agnei Pieitnei Oaehs ana i oinerE like inis

• Ann Brown hyv.- car ine\ Q: mis me lano Pelongt le me people• ..3-

M .. Verena Hofmann

iD'i'.n't I

Directions ic me Rocky Mtn Camp wa Hie Jack Fish RoaO ;just outside o'Chelwyrid-

I'DT JKkfaM»M. ek> -uraflniMrmti iUr'«n'

(•ravel ittrti 9 rokn

atiVacJu^ eekr

9 • jofighi

.van Road 0 Jfcn rononuc (Uaighl akaad (RRD$s)end '-TMirnaastd 'oad

9 se ek' »ie> ngh-

(}; eiur lurr ngMsfloC-o'ttiMonanl.r' " ftaaver ^jop' oad''.Ml

9-. ikn lumMtontc WiMci I oad<TcmbK)

983 •> gBMlo'TtrraEi<rryrr--'-B-*]'98

^•jkinlaaMi Mt IMwnwn.'oadnroughaAaadandpadctwraj ;• v.mfttai

^•Tlir 3unciwrirnain'oadgomr>1(wett1B</i(ommutvttaight nae.M8;. <part • Jeamf tidpln. i.' :sadqiiad<"toon nachln*'olaar'rdldownMiionorth about: kn gati u rt«wat etdtarMoiung

har - caKMowo rt>oi; - trail aPeui • • >.'< t -1*< •radi" tuM.•hat 9001dtctfr into RockyMourlair, -f

•tOME. WEr >«>ME

i/it-voa-. "fete' r nai; f uaene I- S Btnwr. anr. t ctners like Ihis

ywonnc Tapper "np.'iJ yCc vetena'

rife I . r> • . ••

Shannon Heckei Tifev1i.ioges: you pir iti-s i: Hie icp'

9 I Diprie Abe<

M

https;.'/wiWi' facebook.com/events/1501364853502402/

051

Page 66: BC Hydro Site C injunction: Affidavit #1 of Patrick Hayes

05/01/2016

Heading lomorroA' fnornino ' Anyone v;ani ic ptr me'

Spending the mgh;

Call me at my Moms "^SS-SSE*

Snannor. Hecice- 3"vS! Lesians'S HuDi Caps'-Sisn; anc 2 otne's tiKe inis

Laura Webb He;' wojo love ic gc 'ii be lame isie'' lomgni

d" .«•- v •- • 'r.'"

Yvonne Tuppcr'

^ Ruby Capoi-Blanc i wisi csuia3' i: y.'a-

^ ".<r> .aw i.B.an-•••ci'eo ' f'ec v

tr ..-r, . ,v

Elder jacK A Erecting a Breech of Treaty Rights above No Trespassingsign

Danieies Caste)' Tame- Heie''' KnDttanc te wners bke irus

Susan inman besjtitj' Oooc wc-pk

I!

nr'T

Rachel Blatt 'mesome Ic^iage veer warrr ir ine catnn ano eac'> wtierom.Bany

. rt • "/I.-

Ii«elinda Andreviis A-.vescme ..act- tslo: mv friend'

: i.r i.vi r a'' Add-i

very movino to reao (tiis "Tne fores' is Sive' yes Deep gratitjoe tc tfieselano and nver proieciors -

Ffir tht- of tlie Ki-fpiitgthe- Ptacc- Ri\'{-T from tho Sito C BC

Ih'dro Dsim

- c. 'en-trTue* itai sto-j It,a; inr e-ae- lair us'

Da/.'n me w&i .vna-t ttiv ntsos R v6' meets tne

ifa'hvay R'verr' laskesnsr retemng i; the camr .'.t

fiSc ovB-itifee j-ee's agr r-.o ivar acav' re-

https;//w\VW.facebook.com/events/1501364853502402/

052

Page 67: BC Hydro Site C injunction: Affidavit #1 of Patrick Hayes

05/01/2016

Dsw-nTufrieiAud'ejSiep'EiHieDswesaidSotriferslikethis

JcyGsnzale?

Therewi'ltiyouinspiritUtahintheUSAhaswor>streamaccessandvow

10protectourriversitaggedUtahStreamAccessand1postedaboutyoureffortsStaystrong'

Rilekegnwano'vvonne''uppg-lineinis

JoyGonzalez'eggeoAomVokeytxjisnesorvar^tior^Hoiamgyou'effonsirmynearloniani

IrI,.'...T...|l•-

DennisHetinan

EventISsnaredonmyeventspagewaytcgcbrothersandsisters

.•rnrif"u:^e'an:joyGonzaiezlikeinis

RiteI'leioncoijFcei'isbunFiei:nstOoetiean:uoine'Siti<eimt

Racheleiatla::es5acieOkl•OiFmviiaiior

Sadtimes

https://v/VA'k'.facebookcom/events/1501364853502402/

053

Page 68: BC Hydro Site C injunction: Affidavit #1 of Patrick Hayes

05/01/2016

.leains Ricj) aria Rasne Bialt like inis

Rachel Blatl Bircf irees are m> (evDuHej la: thini auoji out walk ano the

iT-.sgnficeni bircr fees we saw ana loacnec f't siggest •ve seen i^jow goneT.ucner ic ine grojnO r waste

. - T .1' a-. . 31 f'-Slri r

!KDennis Woodrow Burden

, T Mil"

THANK YOU FOR STANDING from Labrador

fnosRoae fuonne "fjype- DeD'aanr Shrar Sevems ana C otngrs like triis

• Yvonne Tupper rou' ver.' welcomeThere are wave to suppcin us opposingShsnng ft' oostf

f-Zriie le'iers i- yoji lacs FTovmua anp leoera' Mmisie'r"e- oeopie yof viev.'s

Dennis Woodrnw Burden

V\'h> I An> Hert fl\v; rii-nnis WoodrnwlUirdtTi- Pnrl Hnpe Simpson, l^brador)

' - ' ',1' iir> . ai r '-liti'i.

Dennis Wondrnw Burden

•I," • "ii '.-"af-iiiS w "fconjtc-.-o-v.' '''eivi f'/.cr/l I

i(.v Shouldn't Wi-Knov^ DetterV - Talldnj: withDt-nnis Wootirow Hiirdirn

, r r.' , 1 . • r . .1 lt.rjPntS'. • Pf

gave &C Hy-jir. Seojrily Gje'r. (htilerriiary anc video laper. anc Rod agnP

https:.'/wtftw.facebook.com./events/1501364853502402.''

054

10

Page 69: BC Hydro Site C injunction: Affidavit #1 of Patrick Hayes

05/01/2016

ElizBbelf". Biggs' Shannon MecKei Susan inman ano 16 oinefs lite Uiis

Susan inman v'\Asn couiC oe irere m person ic oivf supool'

-|^.c . a' K' r- . ••

;anuaiv ai ,;6r>n

Signs made it tc camp

More signs needed

Ctawr.Tume.' Rita'A'onp Ah-Kinlinganc otners li«e in5

Erecting anolher sign hne because trie olhei one Helen K Erraly G . &

•^renton F s sian line

https://vMV>'facebook com/events/1501364853502402/

055

Page 70: BC Hydro Site C injunction: Affidavit #1 of Patrick Hayes

05/01/2016

Haler. Knop Heaine'Pornn Teiy ; Daws anc c oners nk€ irpis

-•<' Tie D «r

-•-..a-. , a ••

'SI there was Freda followed By uz and r>ow we have Helen ano Vvonne

UVay to go girls' Here's a clip of Freda showing how it's done'

hUOS viGfcD » X'Lican nei • ;..75''-£5r' o 1 '7253

Eiiraoein Bigas' Susan inTSr An*KiDingana H one's nke tnis

Viekl Creel Boliieo waie' as a qiTi wov.

UH Rachel Blalt ii: loc siupiaio he msuilmg itsjusi loialK iss^riadlemagine mai poo- Dumr ; s: ceing sem mere v. 'Aaier ivrapoec m aD6l~leuT. prsajOi 85 an oRems

Vicki Creel Ano the '/vay mey maae ine oRennc so crass

. IK? !?'• is'v , a' •' •tian

Vicki Creel Like "here s me gooas honey Nov. lei's get ousy

:• r i-' . , . ai • •iJbn

Rachel Blatl iike Duh

• r «• .'.V, . -I' . -'lOtsn

Perjny Boflen Wo,: Trig' if ar anazmc ana ihsoirihg dip "'"hariks lor sharing

Nactrurall Abelone Dom lorgei Audrey •iih':s w-.v i&vecook oonrvice.' t'".t

in 17; i/ivv.5

Sfcerypcace CanadaWar

-V.' a'eoT -"ci: ".I-; I'. Atriii oniiifxc We v J 00 " tagetfse' oecause

-5 whai x<- a'< "^a - 'r r Sen Vusajoarn NaiiO''

••.VI at IBII sl'il C'ling logelnei TO grnpocrg/lgDi^L.'t >V-cp;OV.O„

4 .d"l.V.. 1.1 . ••SI"

"This Idle IJo More isonooino "

Facebooh only aliowc me to dc Jr weeke notice

Please lel others know

https.//v/vvw facebook com/events/1501364853502402''

056

12

Page 71: BC Hydro Site C injunction: Affidavit #1 of Patrick Hayes

05/01/2016

helef. Knsi; ^acftS' Bialt Jennv ~&3I6 ans I rpisfj like Ui s

kt'if Li:;-

i. ;j-, . -J! ' V-.ai

Aiviri Meac.'avos'i nkes thrs

Elaine Uatkowski Hapoy Nan vea-- '^eipncn-

I ike lariijan at >• O-'-fi'-

K'.Jiry; Ef- i!

.1'i,;a-. ' ,1tf- .-Ja-

Happy l-Jew Year verena

gol the invite will be away

until late Jan All the best

2 U anc yours on 2016

--vonne "unpe-- nkes tn:S

vC-niC- i UL'pC-'

•li'iiid''. : ' II • i;ii

Right on people please continue ic invite anc) share''

Thank you'

i-skiCi Esikiniii Belvedere Sucan-ie AasntsemvE anc z oiners iiKt ins

•iVi I-. ii: •• r ii/i

Prophei River First Nations -voulh rnember • Miss Meter. Knoti siaiement

while speaking to Site C security guard at Youth CarnpWe are not evicled-i am exercising my nghts as a Treaty E member

nitcs '1. tsnenoo'. torr.isir.rv (inp

E'lzatietr Srgge- anc Ashiej Eslkim:' Beiveaert like ims

httpsi/.^VAVwfacebook com/events/1501364853502402/

057

Page 72: BC Hydro Site C injunction: Affidavit #1 of Patrick Hayes

05/01/2016

Jenrt)Poffi6likesIhi;

''•;ntitilai'lv'e'ensHofrnannsposi

•a'ljas'a'Wr"'

Belowpictures(romRockyMountainRonCampLookingoooO-sizeaaregood'

Campersandprotestersneedeo

mips''rr.I'aceoookc3n'group6.'64SiTi~354'

viei,v=Dermalinl.ifiicl:1C-1BC-TOE11-104725?

VefBHSHolmannSay"NO"toSite"C"Dam!J»nj9'>'3'ir?5r"

Pnoi:^'i>naitiiu"Wirr-r.-;8niispji'iz-fts"S'3etyM3oen»Rive"Moott

^laiie^''eaiyE'erntDi,

Sta-w1"SfiMdnivI'-ifpea-Ill.I3S

S'-oVi'

.i^nnntMo-ifiD'nZt'ogriesiu'ra;.Braaierana"ntnetsiiliemis

RachelBlatt'tientva.(a-snanncmessuDOaiecdpoiosKeecmeincoming

Onewishfion-me

"Pleasesharethiseven;enyeuiwallbeforedeleting01uninviting

yourselt"

!amtiopinganmyftfriendstosharethiseveniatleastcnceO'twiceor

moretosupportmeandmanyotherslocallyprovincialiynationwideand

mlernalionallvanoivortowidewhomopposeEiteCCamancasKitto

ceaseforevei

Weprotestedlo'40yearsandwiHcontinuetoProtestneih4Dyearsforthis

megaproieotoceaseforever

Muss.

PleasemvitemorepeecefuprotesterstcTogroupNoabusiveor

demeaningccmmenlswillbetolerated

https//w'twvfacebookcom/events/1501364853502402/

058

14

Page 73: BC Hydro Site C injunction: Affidavit #1 of Patrick Hayes

05/01/2016

^l i -

RanC HsQians Ei.zaoeu'Sggai Fcajsatiiaiaj sno £ cUiers likeinis

; 5' a-ej

Ker.CnamMrs Rajan (vaidu ana Celins Merasty liKa ih;5

.••••irK ' c -sMM an event

^•i.viirs • V • , '"n-T

Ra/ar 'vaiQj ans Cenna Merasiy uka trvs

https //vt'WV.'facebook.com/events/ISOl 364853502402/

059

15

Page 74: BC Hydro Site C injunction: Affidavit #1 of Patrick Hayes

06006/01/2016 Verena Hofimann- Photos from Verena Hofrnann's post in Ba.. | Facebook

•t^r ' •' '.t f -r-u'.-nc^ r-:?hv. r:

Photos from Verena Hofrnann's post in Be Idle No More- Our Rivers Needs Us

From Jackfish Road, (okm ) cross railroad track @ 15.1km,stay north

Gravel starts @ 30km

Cross tracks @ 40km

@ T go right

Leave Jackfish Road @ 48.2km, continue straight ahead (PRD55) end ofmaintained road.

@ 54.4km stay right

@ 70.6km turn right off of North Monais (22km) - Beaver Loop Road onleft

@ 71.1km turn left onto Wilder Road (Tembec)

@ 83.4km go left on Terra Energy 10-18-83-99

@ 85km lease on left (when wet, road is rough ahead and park here) or inwinter

(3 87kmjunction main road goes left (west) But continue straight (north)87.4 km park - clearing to right, unload quad or snow machine follow

trail downhillto north about 3 km, gets to riverat old ferry crossing.

Then go east/down river on trail about 2+ km until see trail cut to leftthat goes directly into Rocky Mountain Fort.

HOME SWEET HOME

This is Exhibit ....V referred to in theaffidavit of

made before me on this ....Jtif.

day o( .......n&Mi&CM 20 ..1.12

A Commissioner for takingAffidavits for British Columbia

Verotis Hofmstir. Bt- Idie Nr. More- Ou< Rivers Needs Us

Directions to the Rocky Il^tn Camp via the Jack Fish Road (just outside of Chetwynd)

• January

Donoven Michigan. Helen Knotl. Eugene A S Brown and 5 others like this.

f-rorr. r

Hct'r.s-

Mo'6- "

Be IB .- N'

Yvonne Tupper Thank you Verenall

. ! ' Jaruary fi- 2' 22

Shannon Hecker may Isuggest you pin this to the top?

• 2 ..aiiuary al'2 f)7

Facebook ® 2016B'lOlis;!- .iK

IJrifCf • yrfcfir it i T M'r-

-rc:. • ' " .A- ' r •; .-.Y

Shares vviih Public

C;t -ii Be-v; le

M .;"- r" ••.r Pr.t--. • r

https:/Avww.f3cetiook.com/photo.php?fbicJ=10153846184462744asd=gm.1501440373494850&fype=3&1heater 1/1

Page 75: BC Hydro Site C injunction: Affidavit #1 of Patrick Hayes

04/01/2016 Helen Knotl- MotHle Uploads | Facebook061

S'yn Ut;

Mobile Uploads

Baci: to Aibun Helen's pnotos Helen's Timeline

Helen Knolt

They didn't coime to the camp to evict us but they met us at the bridge. The head ofsecurity recorded our exchange as he reminded me we were 'notfied' of our ' eviction',.1told him Ihave s hght to be here, I'mexercising my inherent rights and as a Treaty 8member i have a right to camp and be on the land wilhir. my territory and that they hadn'ittte right to be clearing or crown land while there are court cases pending. I remindedhim of Free Prior and informed consent and how one ofmy grandfathers signed thetreaty so that I could be here.

Gabriel Luneau, Jod: Nippi-Blanchebe Lindy fi^ilier and 472 others like this

# A.

Sandra Garbitt

Verena Hofmanr Full of sc many emoLons! You and your crew are soproud, strong, and most of all jusUfreo in standing up. An example to all thaiprotecting the land, water, animals and Treaty Rights can be done in areasonable and peaceful way. Deepest deepest thanks to ail of you!

i,' .'..i-.Jf-.i fr' lo - Jfc in 'ofc-:iie • 3ur paf'-v ;•

Previous Nest

This Is Exhibit referrsd to in the

affidavit of

made before me on this

day of 20 ..)£

A Commissioner for takingAffidavits tor British Coiumbia

•-.rt-.i.-m fviobiip Ud

V .'tr Public

Open Photo /iswer

Download

F-mbed Ptdst

https;//wvuw.facebook.com/photo.php?fbid=10l53140450971627&set=a.10150625547751627.385276.52l96'i626&type=3&theater 1/4

Page 76: BC Hydro Site C injunction: Affidavit #1 of Patrick Hayes

04/01/2016HelenKnott-MctiileUploadsIFacebook062

JuanitaLindleyScproudofyoudarling!ThaancestorsspokethroughyoutodaysndyouwereexactlywhereyouweremenitobeLotsofloveandrespecttoyou

Ilovevou

*VerenaHofmannThispicturewillgodowninhistorywiththestoryofhow^^1thePeaceRiverValleywassavedfrorritheSiteC0am'

CsetkweFortier

SueSterling-BurThankyouforstandingupforourInherenlRightslHlove

29|andPrayersIcallontheline)

VickyEtzerzaLaliberteGoodforyouHelenyouareamazing

KutchDeezyYes!CantotallyunderstandandamsendinglotsofsupportfromGundiljmaraCounliyX

hTravisJamesAmazinoAndreaSterling-ShintahAmazing,kwukwscemxforstandingyourground!

m

AngelaGairdnerRighton

AudieWardVourockmvfriend!'

PauletteFlamondVougogir

•.ifir,..5'--el•"1if.

CharleneBrownfi^uchloveandrespecttoourpeaceriverwarriors

hS'

SusanPhillipsYouarefrickenawesomeHelenlliYouwalkintruthandcourage'!;

SharonTsakoza

TashaLuskWaytogoKeepupthefight

StaceyE.SellarsGirpPowehAwesomeK-irh,manyblessings

JoeWesleyWaytogoI'

ii

HelenKnott'-•ii,RB-ir.Ivwjodandfrun'An"3F:xthankyou(orstandingupanospendingyciurnewyearsonthelandforsoemlhingsoimportantyaiiaretfiewamorecomingup

EmilyRBHollywoodLovecl!'

VernieYocoganDianoSnowthemthecourageo'trueirealymember.letthatcouragefiounsnin2D16andfortheyearstocomeuntiljusticeisenjoyed

DebbieRoblinCannolTharikYouenoughfoittiefightyouhaveiryourheartforwhatisn'ghtfullyyourland*V

Janetfi^ltchellThankyou'

MargaretClavinWaytogoCousini'

fil

https://i,vww.facebook.com/photo.php?fb!d=l0'5314045097l627&set=a.10150625547751627,385276.521961626&type=3&theater2/4

Page 77: BC Hydro Site C injunction: Affidavit #1 of Patrick Hayes

04/01/2016HelenKnott-MobileUploads|Facebook^_063

RachelBlatt1sttherewasFreda,followedbyLi2andnowwehaveHelenandYvonne.Waytogogirls!Here'saclipofFredashowinghowIt'sdonelnltps/.Vioscxy.fbcdr.nei..'12254639,S90542?3a3B8~:i1,

22.i£r,..S'-vEl0939

SacheenSettchampleasefilmeveryinteraction

32st'C'^6

HelenKnotthttps.'''recisi'nlhew5rri:iiwordpres;com'./lor-the-love

FortheLoveoftheLand:KeepingthePeaceRiverfromtheSiteCBCHydro...

n'CF.UPFESjl.,'!!/

ifDia

2dsnuar;0'•2'

RachelBlattBeautifullywrittenManyofthewhitecolonistsalsoarefightingthisprojectWearethefarmers,thehuntersandtheloversoftheenvironmenthere.WhitecolonistsfromafaralsostandupagainstthisprojectInfactmunicipalandregionaldistr...Seefvlore

11.z'jf,';z\'"'C"cdaec

HelenKnottOhRachelno...Lotthere'sadifferencebetweenbeinghere,aseOJer.anally,afriendandacolonizer.Colonizationhasa

purpose,assimilationandabsorptionintothemainstreamsociety.

HelenKnott1canonlywritefromwhatIknowandtellstorieshowiknowhowtoo,I'mwellawaretherehasbeenalongfightwagingby

thefarmersandlandownersandthepveaWesharethesamegoal,toKeepthepeace!)

•':Jac-usr.£••F-:i£.-

RachelBlattsocolonizersarethe.1%thatcontrolthewealthInthis

world''CausethatWeeminoritydoesn'tgiveashfrtabouttherestofus.weworkforthemastheirDronesuntiltheydontneedus

anymoreHhhMmmmuchlike"dronesinabeehivewhich

arealsodiscardedlikeSecurityguardswhenthejobIsdone

a

HelenKnottColonizingnashistoricrootsandisaverb.Anaction

thatstillhappenstoday.Iwouldconsiderthecorporationtobeacolonizer,acolonistwouldbeapplicabletothepeopleofthe

onginaifon.IknowfamilieshavebeenInthevalleyforoenerati....Sc-efviore

m

RachelBlattIshouldcomeouttothecamp<Ihaveanotherbhiliant

ideatohelpgetinandoutoftherequickercomeonouttothelookoutpointandslopinilivethere.

.1'-•.E'"-IT•".'t

HelenKnottlwllisometmeverysoon!I'llpmyou

JackieMcvicarStrengthandcourageHelen

DariusMIrshahiAwesome!!!!

TNicoleChermsnok

ShannonHeckerAwesome

SavvyNorwegianYes!

AmbroseEarlAwesome

100%PaulMagnusNice

AudreySieghc'

https://vihA'w,faceb!Xik.CDm/fShoto.php?fbid=10'i53l40450971627&set=a.10150625547751627.385276.521961626&type=3&theater3/4

Page 78: BC Hydro Site C injunction: Affidavit #1 of Patrick Hayes

04/01/2016

Sign Up Log In

Gsmes LocaUons About

Terms Heip

jSbook Si2016Slish (UK)

Messenger t^acebcck Lite Mobile

Create Adven Create Pscie

HelenKnott - MobileUploaids ] Facebook

rina Friende Badges Peooie Pages Ptacss

Developers Careers Privacy Cookies AdChoices

https://wwrw.facebook.com/phDto.php?fbid=10153140450971627&set=a.10150625547751627.385276.521961626&typs=3&lheater

064

4/4

Page 79: BC Hydro Site C injunction: Affidavit #1 of Patrick Hayes

f-7

f-t

04/01/2016

Siyn Up

Verena Hofmann - Photos from Verena Hofmann's pest In Say... | Facebook

01 P-j^r-.-vvord

•_l Keep me logged in Forgotlen your password?

Photos from Verena Hofmann's post in Say "NO" to Site "C" Dam!

Back to Album

NEWS RELEASE

For tmmediate R^esse Ja^ry 1.2016

New Yew's Eve Celebrstsd at ffistprie Rocky Mountain Fort

On OtasouOi tuiritorttw Peaco Riwr, jtei a short distance upstieam kim the mcuth of theMobeily Rtver, jsthesitaofMstortc Ro^ Mountain Fort InNortheast BC. ItwasetiabSsttedin 1794 by OnNoitti West Companyas a furtrai^ post and is the oiiBof theearOestsettler post in mabtiandSC. WhSeno originalstructures stBI stand, this sBa hastremendous stgi^oMsa to both tndigenaus end non-indisanaus peopie. The Fort waswhere maiiy fiist interactions between eeity seltteis andFirstNaOins tookptece. It isa sheof the origlitai relaitetishipfor this territory. FirstNationtrwrpersprovidedcrtbcdsIdSsandneswirces thataflowsd thefurtraders toprosper endadju^into remote northern Bvin^

Theongoingtack rocogrtSion ofthis irnportant historic ale tiyboththe Federeland Prpvlnciaigovsmments has been sharnekjl and it overdue. Now, wtthtee starts constnicScin theSite C darnjust a short distsiOQdovmstresm,Rodcyidountdn Fort is in danger of bOhig tostforever underalmosl206feetof water,tntecL the oM (pewthtimber on theriverHatwIuhbRockyMountain Fortslisis achedided to i>e loggedthiswinter.

In late November 2015, various concerned FirstNations from Tisaty 8 and various tandownersand loc^ estebO^twis protestcamp at Rocky Mountain Fort VUtfitioReily. s .cabin was movedonto the sSe In the last we^cf Oecember

Seveml peoplefrom tiwssgtoi^ decidad toringInthe2016New Yearfrotn th^ camp.TheioBowing is an excerpttionithe fortJoumal from January1,1800 was read:

"ITw rrieri aroiffxf tifada towafiota«frigrwtedotv aridcame/nfom/room arid / gaveihsm each a cof/pteof ikwTis and >4 rtehomtataeeo. &ch siprmf/n atrabotif5 pMSrun and 5fathoms fobaera. CotmcQsr and Cterrtaiasteugfd together and 0w tattergaw the Ast apsk ofMeek and ihe best drubfairv that everhe gofinhisfife....*

The NewYear's ooMvi^on, two hundred and sixteenyears teter thisentry, was dot»peaeeft^ withthe onlyfigttbaing die one to presarva the Peace RiverVaOey. The onlytiringunctviibsd todayb the BCHydro tieingableto go teioadw8hconstruction vrtwn ti»re are ^pentfing courtcases. ThoSSsCDamwilbe ahugBlriadceye'tothePaacarevBrVaBeywMiadiriBC ffetowad to continue.

The only ttring undviSzQdtoday is the BC Hydro being able to go ahead with coRBtiuctioh wiisnthere are atiD pendingcourtcases- The SReC Damwi be a huge Iriack to the PeaceRiverVaiteyand aBof BC Sf aSowsd to confimie.

For furtiiertoformatlon, pleaas contact

Ken Boon: 280 262 0014 or cfrinooktoghonKisQxpiomelcDm

065

Log In

This IsExhibit ....A..... referred to inthe

affidavit of

made before me on this

dayof 20Jh

A Commissioner for takingAffidavits for British Columbia

Verena Hofmann Say "NO" to Site "C" Dam!Press Release from the Rocky Mtn. CampShare far and wide please!

1 January

George Gervals, Robben ConstanL BurttFidierand 31 others like this.

61 shares

Bill Studley How do you get to the site? I wasnl aware that there was roadaccess!

Like - 2-1 January at 08;43

Verena Hofmann Hi Bill,message me your e-mail and I will send.

Like -1 January at 09:16

Scott Donovan The letter reads incorrectly.

Like • 1 January at 20:13

From: Photos from Verena

Hofmann's post In Say "NO" toSite "C" Dam!

Shared with. Public

Open Photo Viewer

Download

Sign Up Log In Messenger Facebook Lite Mobile Find Friends Badges People Pages Places

Games Locabons About Create Advert Create Page Developers Careers Privary Cookies AdChoices

https://vyvvvv.facebook.caTi/photo.php?fbid=10153845008982744&set=gm.10156705679227355&type=3&theater 1/2

Page 80: BC Hydro Site C injunction: Affidavit #1 of Patrick Hayes

04/01/2016

Terms Help

Facebook ®2016

English (UK)

Verena Hofmann - Photos frran Verena Hofmann's post in Say... | Facebook

pn https'i/www.facebook.com/(rirato.php?fb'd=10153845Q08982744&se^gm.10156705879227355&type=3&th8ater

066

2/2

Page 81: BC Hydro Site C injunction: Affidavit #1 of Patrick Hayes

04/01/2016

Dancing with Decotonization

This Is Exhibit ....."i referred to in(y97affidavit of

made before me on this •eMM•MeMeeeeeaaeeeMaeeee

dayof 20

A Commissioner tor takingAffidavits for British Columbia

For the Love of the Land: Keeping the Peace River from the Site C BC Hydro Dam

"You rfincmhei- lhal si tin ihnt Ihu utdi-i lold us - HoivTi tlu- when- llia Puare iliier meets the Haifwai Ri\ery"

asked her, referring to tlie camp wi had cA'ei three ycai-s ago.

Tlie camp was about reclaiming out right as }c)ung Indigenous peopk to

be in our lerrilory. in this Peace River N'alley. lucia'd far into the North

Fast corner of British C'olumiiia. Wi- did not want tlu- proptised Site C

i^ydro Dam tiien. we do not want it now.

"No 1don't remember." Emil\" replied.

We sltiod on lite soft sno\^ on our wii> back to camp. We liad just put a

.sign up to notift Il\drf) workers that this was Treaty 8 Terriior> and they

were trespassing.

"He- told us about iunv wlien lie \i'as young he rememher.t camping somewhere while they were Irai'elling by horse,

.^t night they heui'd weeping coming from tlx foi-e.st annind them anr^ tlnp ciidn'l know wlio it was." 1 said, as 1

stopped lo walcii .snois genlh lall iVoiri tin branciies tif a nearlx spruce Liee.

"He said thai wlien lhe_\ went iiack It. tluil sjiot again, maybt a >ear of st. lalei. litat forest was gone. 11 haci been

cleared lor a road. It was the forest cnang beeanse it knew what was coming."

Emily nodded her liead. "The forest is alive".

"Yeah. V'iih it i.s." 1 echoed In-r word.''.

He had jus! left wlien Pit" Hydro started to cleai f»n (hi- \N'es! sidt of tlx

Moiieri} Ri\er. \^'e walked o\ ei lo the (Ttuie liridge llial tixw" had liiiili K.

cross till' frozen rivet with ilu-ii equi|>nienl. 1 had |f>see if up closi- for m>

oivn c\v> and 1tiad lo la\ im offering of lobacco for tlx- land, for its

suffering and loss.

The ita\ tiefore we jiaeked up m\ little Sl'\. three of us in total. Trenton.

Enii)\-, and m\se)f. Each from a different Idrsl Nations cumniunit) iii tJx^

regif>n, all with tix' same mxlei'staixling thai laixi and water is important Trenfrtn tells me a store on the dri'.c

about iX'W nothing comjiares lo the .'-mile Ins (irtuuhna gi\es him when ix-ghes her ruhiiits iie .snares, lie snaivci

het liirec- rabbits the other Trenton is eiglileen and the land, (he animals, the water, llxw' are all essential foi

his wa\ of life

https://reciaimthewarrior wordpress com/2016/01/02/for-the-love-of-tfne-!and-keeping-the-peace-river-from-th... 1

Page 82: BC Hydro Site C injunction: Affidavit #1 of Patrick Hayes

04/01/2016

Wf were going to ring llie New War in at the Roelcx Mountain Forl Camp, a In-Sloriea) site wheie one of llri-

earliest trade post seliienients in BC was it s located at the end ol a maze ni backroad? and a skidoo ride or

ire]< down tlie moiintaiii. T'hi.^ would hi- a New ears to Remember.

Ken Boon, an amazing indi\idui!l who liws in the X'allto and who ha.s long since been opposing the Site C dam

met us at the lop with his s)dd(5o and brought uui load ofgear in.The\' set u|) the ea)np within the pivN'itnis monthand that da\ tDecemher 3) Ithe\ had a small shack liiat had been insulated nown in \ia helicopter.

\^'hen wearrived to camp wefound new no tre.spassing signs (not oiir.c) po,=ted on trees and an e\'iction noticeptjsted b> hydro on to the shark /Xpparenlh we hadlwent>- lour hours before torred removal would happen. Itwas just a big scare tactic from a corporate bulb.

To whom ft >MVeooetm:

TAKNOnCt

TIMMoaonxM W •* mMarManaUfM Irvn

Mi WMI irtlMi 34 tmn •! IM noHcf

IMMtf mM hML «i C«nM of

Ml ho mw>o< ^ >c

rhc> ha^v no right to renuo'e us from olu own land. Oiu own territon.

Wv .settled in to cami).'[reiilon lielped with brew nod. ijuih unpacked, and ] settled into the- rok- of cam]!

mom'i'oolworganiz.eranci made colfec and chilli. U'hen lhe\ .sl:\ g!-e\\ daii" fxve art taking around 3;30 iii the

riorlli1\\\- \Miited a bit then began 1' shoot off fueworks. and \shen that was o^-lM wt plaved cards in llic shacj.;

Ken. eNcuscd himself to bed and Ihc thj'ct of us slr.\"ed up talking until tiu' N(-w Year came in.

With lh( final minute iefl wt all Jumired outside and staled up at Ibt stars 'Iht- eii,j-s oj oui ancestors 1hat is how

w<' rang in the NYn\ Year, with tin-stars (.\-erhead and the trees surrounding us as .silent witnes.se.s.

https://reclairrithewarrior wordpress.0001/2016/01/02/for-the-love-of-ttie-land-keeping-the-peace-river-from-tf"

068

Page 83: BC Hydro Site C injunction: Affidavit #1 of Patrick Hayes

04/01/2016

In lhf= morning, while the snn was rising 1walked down lo tlu- water, lliei e was a frozei'i inlet bet\\een us and the

Peace River, which never freezes !>ecause of the {\\o Hydi'o Dams Llial alreadv cNisl on it. 1stood cm the ice. with

uiilows and spai-se bru.sti surrounciing me. and watched the sun ri.se and prayed. Tlrere is no heaulc. n(> peace like

Uial. (.ret itV Peace., because we were on the Peace RiNer.

Uime Pu.ns-i.

1began ici look around me and started to notice ail the rabbit trails that looped Ihi.'̂ war'and

the birds that flitted around in tlu nearbr trees. I thought of the grouse and the

coyote wt seen just a sliort distance ur\'a\. There is so much life in tliis valk-\. M\

.'̂ .su ((jrandma) is sei on showing m\ scm horv t<. set snares foi rabbits but the few

times ret went out we couldn't find an>' rabbit trails or signs of them.! heard

someone sa> that the ralrbit is a •'murkei' species", meaning that when shit starts

heading south en\ironmenla!i>' >uurvil) notice because the rabbits v\ill be gone.

Well the rabbits ma\ he hardei to find in .some areas but Ibey are here, but for bow

long will the>' har'e a home here looV

1think of1 rent on his .smiling (inindmuthei. and a pot of rabbit soup.

thai war, 1 listened to

When we make it it. tlie Irridgi hilci that morning 1show Kmib how to niakc tofiacco oifering and we walk down

tfi the frozen Moberlr Rivcti fwhich Icad.'̂ into the Peace Kir eri and v.c pra_\ togi-tiiei'. 1look up .illcr! place m>

oifering down and the Ih liro seciiritr gcir is oiiisidc ol'ln^ Iruck recording mr on his plinnc. 1sa\ a pra\ er fi.'i him

loo

.-^n "Indian" .sa>-ing a praier must he a fearful tiiitig indeed ! fghl back the urg( to xcll. ".M\ medicine- game is

strong!" and do some ominous hand nio-.c ments, pi'elending thai ! just laic! si;me wild old Indian curst-

Birr

https;//reclalmthewarrior.wordpress com/2016/01/02/for-the-love-of-the-lan(j-keeping-the-peace-nver-from-th

069

Page 84: BC Hydro Site C injunction: Affidavit #1 of Patrick Hayes

04/01/2016

I ietn-e e\"en"()ne al llie bridge. ' had a jtjup one. Bob f-. showed up that morning to come willi us) and walk into

the lost forest, .The tears are wxdling up in my eves. 1.see. 1 feel how real this is and 1am filled with a great soi'iw.

it is a sorro\\ youi' spii'it ieeis, and a part of me wants to i'lreak down and sob int'.; the earth, i.el ni> teai's miN \^ith

the srhl. But a part vf me .sa> s that doing .so if- acceptance of wkiut the> are doing, and \\ hat lhe\ are doing must

stop.

The .securityman. still jiosled in his vehicle pops his head out to remind us that we need to "stay on your side of

the bridge". E\ e!yc>ne Iriclcle? towards me atid we begin ti- hang our own signs, telling them that this is Treaty 8

Terriior). Hwntualh unotliei man joins the lone ranger on the bridge and walins o\ ei to "our side".

Boh piped up. "Beltei sla} on >()Ui side c)! the bridge!"

1 notice the man is rec(.>rding us. and begin.'- to talk to Bob aiw-ut the eviction notice and that is -when 1\va)ked

tner.

site supenisoi and ! posted a notice. Toy are aware that you have twenty four hours to vacate..." his \-oice

goes on.

"] lun'e a right to be hcrt you l;n(>\--?" I said to tlie man. Mc is white bii! the hne rangei is .Nati\e and he stands

beside him.

"You ha^•e been notified tliat you must hrcal; down }"our camp..." the \^•hilt• man with a camera in ni} face

continued, tn iiig to tall; o\'ei m> \ cjice

•'] am a Treat> Eight niembei and this is ni} traditional terrilon. 1 ha\e a right to be hei'e and to camp here and he

will continue to do so. I'nder liie I'N l)ectaration ol tlio Rights ol Indigenous Peoples, \\ hicfi Canada ha.s ratified.

\-ou have to Inn^r free Prior and Informed Consent 'Phis hi-re is oui' ierriton. and Ihei-e are court ca.scs in

pi-ogress. 1 haN-e a right to he hert ^ou can t tell me r)ilua-\'.i.se.' )nc of m>' Cu'al grandpas signed the 7 reat\ sci that

1could be here." 1said pointing al the ground, as 1talk. 1watch tin- shock ol the Nati\"e l.one Rangers face and he

mo\es slowly behind Ihi' While man

i don't knn\-, iJ that shock i.s that 1am tliere or that he feels that he i.s on the wrong .side and wants to hide. I feel

sad for him. because 1know that work is \vork and it jiuts i'oodon the taldes of ou!

pe.'.'ple Bu! for how long? t hiti; the job lasts and then what? Our children and great

gi'andchiidren will fed the ramificalioiis oi these-actirins. ] think of m> ,-\su's

ig;randma i -c.-mxls aboui how thc^ Drcanrcr'̂ sjgoke about b.ard times to come and tjoyvhc

https://reclaimthewarrior wordpress.eom/2016/01/02/for-the-love-of-the-iand-keeping-the-peace-river-from-tb

070

Page 85: BC Hydro Site C injunction: Affidavit #1 of Patrick Hayes

04/01/2016

RIGHTSiin'is stu n lot U5- that uili be ali\'e. VVluit if thai is jire\ enlable le some measure? This is

iicii just about u? and h\dro and being right or urong... it's ulioiit the future we arr-

sleaiinii for those who come after us.

T!ie shur! sighleduess of cciloniaiisni neA ei laiU to astound me.

1made Emih pose foi this photo \rith me:

•'\Vli\-?" .she aslted me

"Because Kmiiy. wc- are .•^liil li\ing in the shadows of colonization. Looh at lliis. look around us this is wliat

happens exen when we are sa\ing no This is wh> we are here, to stop us from hi.ning to Ih-e in the shadows on our

rm-n land.' ! said

CiM lor:

\V(- need m-irf^ of our ovni members olTin 'I'l-eal} 8 'lerrilon to \-oiimlecr to man

tlic camp on shift .shedules. Vou can contact me as j will begin keeping a schedi:)c-

https://reclaimthewarrior wordpress.com/2016/01/02/for-the-love-of-the-land-keeping-the-peace-river-from-th

071

Page 86: BC Hydro Site C injunction: Affidavit #1 of Patrick Hayes

04/01/2016

lor rolHlion i" mediocrinsuckso'^iff'hotmail.com Membfr? froiii ikTos? live horciei'

(the D;un cflt-cl« iliose all along fhc Peace Ri\ er!. and Indigenoii.-- people- from

elsewiierc welcome too.

camp gi'invs we will need more lj^^ng structui ei^ as well {Ili cajwus wail tents

*\ilh wood .slo\ es. 1will ha\e more once am able to talk to the oilier organizers.

'note: till coni-'ersations are from memon, somemay hesliglitly paraphrased but ail hold the main pointsof thecon^•ersation.s and exchanges.

Iteir ac M\drn

III lli'iMkin II iloiMi

Ri'silicno and Transformation

11<' Ili'rjil.ni ii iliiun

The I'nfuvoiirahli' Indian

:ii \i:'iri)iiirii

A-aipastel r h-i1 lajgeog,- fclL'jjrv SSlViLiJi^^r ^I'SiNalm-ii lirMCHi-.fl Mie laiUlSl^ii't

)2L/i iji-.iJt— e-ji'-jiii.- n.-jn::.'. sit'. . jtv' .m u-tirijik't

Kfct ttit peace I've i.ano

One Response to For the Love of the Land: Keeping the Peace River from the Site C BC

Hydro Dam

Blanche Huchn

I |n;t\ Cii ^ ,l;'

tlUii

Dancing with Decolonization

https://reclaimthewarrior wordpress com/2016/01/02/for-the-love-of-the-land-l<eeping-the-peace-river-from-th . 6

072

Page 87: BC Hydro Site C injunction: Affidavit #1 of Patrick Hayes

04/01/2016073

https://reclaimthewarrior.wordpress.eom/2016/01/02/for-the-love-of-the-land-keeping-the-peace-river-ffDm-th.. 7

Page 88: BC Hydro Site C injunction: Affidavit #1 of Patrick Hayes

TRANSCRIPT

This te Exhibit wferr^ toIn thaaffidavit of

mads baforomaon this

d&y of -TtOiAAAiCi^sdeaaaeweeee 20 ife

ACommissioner tor takingAffidavits for British Columbia

VaatA»afiaW»Ti»ft»»a

K2FaCnwaa'

This isa transcript ofa video posted on Facebook by Yvonne Tupper on January 2,2016.Downloaded at:bttPs://www.facebook.com/vvonne.tuDPer/videos/vb.665415637/10I5374928064S638/?tvpe=2&tbeater

This transcript was prepared by staff in the Document & Software Support Servicesdepartment of Fasken Martineau DuMouIin LLP.

Verena Hofmann:

Yvonne Tupper:

Verena Hofmann:

Yvonne Tupper:

Verena Hofinann:

Yvonne Tupper:

Recording

Where are they? On that side of the.. .we'regoing to go both sides

It's January 2,2016. My name isVerena Hof&nan, and I'm with YvonneTupper and Jack Askoty, and we're on the south bank inthe Peace RiverValley at the confluence ofthe Moberly and the Peace River. And we're—what you're seeing here isa temporary bridge that was wrongly put onTreaty 8 Territory by BC Hydro. And Yvonne, do you want to describewhat you have in your hand there?

I'm exercising my Treaty 8rights asa Treaty 8 member. Actually it's kindof funny that I have tostate that todo this. I think everybody, anybodywho's treaty, non-treaty, 'cause we're on Crown land, is able to dothis.What I have done is signed my signature, actually printed myname, datedit, and I'm goingto ask for the sign, "do not remove".

Wliy are you putting "do not remove"?

My fellow Treaty 8member was here yesterday, Ms Helen Knott, EmilyGardiner and Travis Fox.

Verena Hofmann: Trenton

Yvonne Tupper:

Verena Hofmann:

Yvonne Tupper:

240150.00142/90619398.1

Trenton Fox, was here thedaybefore, andthey had putthese signs onthebridge over there, and they were removed. And we would like tokeep thesesigns up. There's various signs throughout this area that state that this isTreaty 8territory. Verena, ifyou want tomove tothe front ofthe line. Soalong with mysignatures, JackAskoty is walking...

Back toour camp, the Rocky Mountain Fort Camp, which isabout a half-houi* on foot from where we are right now.

What a sadtrekthis was, to seeall the timber, the willow, the birch, thebands, laying down on the ground, for us to walk over. It'sa sad sight tosee that they used cutters and, I don't know, some other equipment, Tm not

074

Page 89: BC Hydro Site C injunction: Affidavit #1 of Patrick Hayes

r-l

Verena Hofmann:

Yvonne Tupper:

Verena Hofinann:

Yvonne Tupper:

Verena Hofinann:

Yvonne Tupper:

Verena Hofinann:

Verena Hofinann:

Yvonne Tupper:

Security guard:

240150.00142/90619398.1

-2

a heavy equipment operator, but you could tell that they used specialmachines to clear tliis path, and I'm upset about that. Because these treesare older than me. It's older than you, Verena, it's older than Jack. They're200 years old. Tliey produce life, oxygen, homes for animals. We needthese trees. And it's in one of tlie court cases that old growth should besaved. And as you can look over to your right, Verena, you can see thatthere's piles of different trees ofdifferent ages, piled up, and I'm not toosure who is supposed to be the watch dog, or who is supposed to be tellingthe people who are in court opposing Site C, about these trees and oldgrowth. We're gonna walk shortly to the bridge, and show the old growtlithat was protected in the court cases, that they removed.

They may have not been protected in the court case. There was someprotected up the Moberly River, but the success in having all of themprotected right here at this flat, which was requested in the court case, wasnot successfiil. But, is tliere...

[inaudible]

This is part of the purpose ofwhy Treaty members are here today. So we'rewalking towards the bridge. What you can see here is this massive piece ofequipment, and it's the actual machine that's chomping and tearing apartthe trees and the earth and the ground where we are now. And I just want topoint out the irony ofwhat you're seeing right now. It's a pan under thehydraulics, I believe, ofthis machine, to make sure no oil drips onto thesoil. And that's called an environmental practice. But, but look aroundyou, look at the destruction and the wreckage that they've just done to theland here and the timber and the forest, and their environmental practice isputting a pan under the machine to make sure no fluids drip.

Oh look, here they come again. They must have went and got back-up.

Who's coming?

Security. I think this is going to be happening [inaudible]

So what you can see, we're walking on the bridge. All these trees that yousee underneath the fill of the bridge to make this bridge are what they've cutfi-om Treaty 8 Tenitory. I wouldn't call this being resourceful. And so nowyou can see the north banks ofthe river, of our beautiful Peace RiverValley.

Do you want to maybe ask them maybe questions about the removal of thesignage?

We're recording right now. My name's Yvonne, this is Verena. Do we haveyour consent to be recorded?

Sure.

075

Page 90: BC Hydro Site C injunction: Affidavit #1 of Patrick Hayes

3-

Verena Hoftnann: Hello.

Security guard:

Verena Hofinaiin:

Security

Yvonne Tupper:

Security guard:

Yvonne Tupper:

Security guard:

Yvonne Tupper:

Verena Hofinann:

Security guard:

Yvonne Tupper:

Security guard:

Verena Hofinann:

Yvonne Tupper:

Hi

WeYe here to camp; we're camping down the way. And we're, actually,I'm exercising my treaty riglit as a Treaty 8 member.

Sure. All I can say to you guys is we're here as security. We have to askyou guys to leave. And any other questions, you have to direct that toHydro.

So, that's just the bridge part.

All on this active work site.

Okay. Well, we don't know when it starts or when it begins. There's nosigns along the way saying it's started or begins, so I think I'm okay here.

Well, like I say, we're just, we're directed to tell you people that, okay?Any other questions or concerns, you guys contact BC Hydro. But I'll get acall on the phone here right away, and we'll make something happen hereon what you have to do, okay? But I'm under orders to get you guys— youguys cannot be on this active worksite, okay? Especially around theequipment and stuff like that.

Oh, we're not going fiirther than the bridge. We're staying here and thenwe're going to head back.

And we've put a line out, Yvonne and Jack, who's further back, have putthe line out with signage similar to the same signage that was erectedyesterday. And we want to ask you why the signage that we erectedyesterday is removed. That's the property ofTreaty 8 members that erectedit, and it's no longer there.

Oh, okay. I don't know, so you can stop that recording there now. That hadnothing to do, I wasn't here or aware of that, right? So, I'm going to haveto ask you guys to please vacate the active worksite, okay? How did youguys get here?

We walked.

Walked.. .walked fi*om where?

And why do you need to know?

The machines are not working, there's nobody in there, so you know it's notan active worksite becaxiseblack smoke would be coming out of thatmachine there.

Security guard: It is an active worksite; tliere's a piece ofmachinery here, right?

240150.00142/90619398.1

076

Page 91: BC Hydro Site C injunction: Affidavit #1 of Patrick Hayes

Yvonne Tupper:

Verena Hofmann:

Security guard:

Verena Hofinann:

Yvonne Tupper:

Security guard:

Yvonne Tupper:

Verena Hofinann:

Security guard:

Yvonne Tupper:

Security guard:

Verena Hofinann:

Yvonne Tupper:

Verena Hofinann:

Security guard:

Verena Hofinann:

Security guard:

Verena Hofinann:

Security guard:

Verena Hofinann:

Yvonne Tupper:

240150.00142.90619398.1

Riglit.

And our line ofsignage that has been erected is behind your piece ofequipment, so that's a line, and the signs are clear in terms ofwhat'sexpected by Treaty 8 members that have just put them up. So we're givingyou notice.

You're giving me notice?

Yeah, just as you're communicating your perspective on your notice.

That's true. And plus, there's no prior consent for this construction, fromany Treaty 8 association member, so..

See, gals, I don't know anything about that, all I know is we're...

We're communicating with you, and we asked you ifwe could videotape,you kind of nodded and you said yes, I think verbally, and we'revideotaping this.

And we're communicating. It's important for us to have an exchange so youcan communicate back to whomever your supervisors are.

But I'm not the person to talk to, right? I'm not the person. That's what Isay, just hang tough here.

Are you just alone, or who else is in the truck?

No, we've got another security person in the truck. So, but that's whatwe're directed to tell you guys. You cannot be on the active worksitewhatsoever, right? That's the end ofit. So just let me go make a couple ofcalls here, just, everybody sit tight.

We're not going to be sitting tight. We're...

We're going to make a fire and give us some

Yeah, we...

Where are you making the fire?

We're at the Rocky Mountain Fort camp on Treaty 8 territory.

I was in there today.

That's good. But did you see the signage that said no trespassing?

I didn't notice it.

Well, now you've been notified.

You've been notified; there's no trespassing on Treaty 8 territory.

077

Page 92: BC Hydro Site C injunction: Affidavit #1 of Patrick Hayes

078

-5-

Security guard: For us? Oh, is that right?

ft Verena Hofinann: And for anyone. Unless you've been welcomed by Treaty 8 members.

Security guard: Okay. Let me get back to you guys.

Verena Hofinann: Okay.

240150.00142/906I9398.I

Page 93: BC Hydro Site C injunction: Affidavit #1 of Patrick Hayes

06rt)1/2016 Yvonne Topper - Photos from Yvonne Topper's post in Be... i Facebook

If r.er • rj- : CffAVTr;'?

Photos from Yvonne Topper's post in Be idle No More- Our Rivers Needs UsBfirt !c Aih,-•

Yvonne Tupper Be idle No More-Our Rivers Needs us Frorr Pnoias trorr Vyonne

Erecting anolhei sgn line because the other one Helen K . Emily G. &Trenton F' s sign Toppers pcsi <"Be Wife Ncline. More-Our Rivers Needs Us

i Jsnje-x

Helen KnoQ Heather Pofrili. Tely C Davis and 6 otners like this

Snared .vitr Public

Open Photo Viev/er

Download

Sign Up Log Ir Messenger FaceoooK .ile MoDiie =(fio Friends Badges People Pages Pisces

Gamer- Locations About

Terms He;c

Create Advert Create Page Developers Careers Pnvacy Coakie? AdChoices

Facebook $2016

Enollsh (UKJ

This is Exhibit ..iJ/l.... referred to in thePa •!( •')/

affidavit of

made before me on thie. m:.....jay of 20

A Commissioner for takingAffidavits for British Columbia

https:/.'Www.faceba)k.com/photo.php?fbid='0153746999905538&set=grr; 15C1678516804369&typs=3&theate'

079

1/1

Page 94: BC Hydro Site C injunction: Affidavit #1 of Patrick Hayes

08/01/2016 Verena Hofmann - Photos from Verena Hofmann's post in Say... | Facebook

DS till Up

Photos from Verena Hofmann's post in Say "NO" to Site "C" Dam!

Back to AibuiT'

* - Verena Hofmann Say "NO" to Site "C Darrtt

10^ Jan 2.2016Evening Crew

Rocky Mm Fort CampPeace River Valley. BC

... See More —'.' t' l-.e* b-Asi-ot; snr t .'on'.e i.jpfie-

2 Jaiijary

KatyNorris D Lynr. Chapman. Amie Sankey and 125 others like this.

I 23 shares

RKb Marilyn Belak My hope was tobe an elder there - carryon leading- youare ail doing a great job' Hope to join you when I return

(.ik? J r "

Rachel Blatt LOL ken you are gettir^c to be an "0:d Timer' out there

Tenneille Metz Hey V. i have a few recruits. Discuss it or Thursday

Arlene Boon looks pretty comfortable in there

Elizabeth Biggar You guys are my heroes

' IK^ h . , r:i £ r • r".

Janice Timberlake Wish I could be with you but sending positive thoughtsand energy from Iqaluit!

Like 2 . n-; =-

Diane Makanachaa i wish I could have been there but to sick with the flu

Mk» 1 ;• kO':- '

Kf-c--. n.f i: .r.Jt" ;r • CConftr VC SlV.Cl7

Frciir Pfioios from verena

Hofmann s oosi m Say "f-JO"to

Site "C" Darrii

Shs'ec !•.ii' Public

Open Photo Viewer

Download

This is Exhibit ..jj.fe..... referred to in theaffidavit of

'.eii' •

made before me on this rUf*

day of 20 ..J.l:

A Commissioner for takingAffidavits for British Columbia

https;//www.facebocA.cCTTi/photo.php?ibid= 10153848059377744&set=gm.10156708595157355&type= 3&dieater

080

1/3

Page 95: BC Hydro Site C injunction: Affidavit #1 of Patrick Hayes

OB/01/2016 Verena Hofmann - Photos from Verena Hofmann's post in Say... | Facebook

Term

HRachel Blatt plan to come as soon as you are over 111 We will need

campers for a long whilei

Like ' j je'u.-c'i e' -

Rachel Blatl Move ic the old Rocky mounlain Forl site this devastation isonly a KM or 2 long it is horrific but what would be more horrific is if weallow it to continue up the entire 100 kms up, our lush and fertile Valley) Weneed to nip this Valley Cancer In .. See Mo'e

Like '• i .leiL..?.'". ei

Helen Knott Woooolll

-ikf : .£'-v £ .<:• i'r

Rhoda Paquette Not sure where this is'' Yvonne can you direct me, I can

come out during the week, or sooner

t - -SL.jan =• rr

Kelly-Patrick Moore Thank you all for being there and standing ground

against this atrocity. Praying everyday for BC hydro and the Liberals to bebe STOPPED, and this so called Site C dam and LNG madness to go away!Hands up to Treaty £ and all the supporters ano allies

Jennifer Soderquist Woni be home till the weekend, and I have no idea

how to gel there.

Jennifer Soderquist I'll ask someone

..lk£ . .*£' w if ' c •

Yvonne Tupper We posted a written map on

Be Idle No More -Our Rivers Needs ue now event page.

'..ikf i . £ni,gr c' •'!' i-f

Bhanne Marie Vv/cni.f & H&er. Kiir)tt I live in Peace River, AB...down the

river from you, and would love to come visll the camp and show support

though Iwork full time so it would be on one of these weekends coming upI know there are a lot of supporters of what y.. bcc Muru

ffiS Rachel Blatt AwesomeCome bringcamera,crew friends foodWHY Yayl

E

Up

Yvonne Tapper Yes Brianne

Come as soon as you can.

l.lKr;

y Brianne Marie Okay. I'm planning either this weekend or next andwill let someone know Please tel me know if I can colled and bring

some donations of food or anything else the campers might need. I'llbring my camera ad well just in case

Like • . ;•.• le- !<• •

m Yvonne Tupper Ok. Confirmi the dates and we set you upLike 1 • f -l ' •

Rachel Blatt Here is Some inspiring Committment (or those who aretoo ??'' to come out ntio .'Y.ww chr. cs'. k'nder-mo'aan-burnaby-

wcrk-s le ,.

Anli-pipeline grandma, uilling to go tojail, arrested for violating B.C. court order

Like •-usn-.isr.-a;

Log In

Locatlors

He'p

Messenger

About

Fgcebock Lite

Create Advert

Mcb'ls

Create Page

Find Friends

Oevclcpers

Batdges

Careers

Facebook @2016English (UK)

People

Privacy

Pages

Cookies

https;/Avww.facebook.com/phato.php?ftHd=10153848059377744&set=gm.10156708595157355&type=3&theater

Places

AdChoices

081

2/3

Page 96: BC Hydro Site C injunction: Affidavit #1 of Patrick Hayes

08/01/2016 Verena Hoftnann - Photos from Verena Hofmann's post in Say... | Facetsook 082

n

hltps://vvww.facetx)ok.com/photo.php?flDid=10153848059377744&s^gm.10156708595157355&type=3&theater 3/3

Page 97: BC Hydro Site C injunction: Affidavit #1 of Patrick Hayes

08/01/2016 Ariene Boon - Never underestimate the power of one woman.,..083

ign Up

Ariene Boon

f Jhnij&ri g: 2C C'C-

Never underestimate the power of one woman. I walked onto this loggingsite this morning. One machine and 8 people on the ground. Told the#SITEC contractor I was not leaving so they moved the machine back tothe bridge and the people left. January 6, 2016. Back to Rocky MountainFort 1 go.

Liker 71- C-ornme'its r- sriarei

Marcus Mitton. Jeremy Williams. Tennellle Metz and t70 others like this

snares

Maggie Murphy Good or ya'

f ..a-.; =.r. a: :• •(

Geraldine Gauthier Good job well donel!'

f .-c-in; ft'* ?• :;•( -!

Gerry Hunter So proud of you all

f ar-., ar^- B1 7'.

Holly Arnben Thank you Adene Boon]!!

Lorraine Ward Yayyyy for you, Ahene Boonlli

fa -Jillian Ridington BRAVO)

Evelyn Sim Way lo go Ariene )

J Caridlcc Michela Campbell Good job Ariene'

Kirk Pearson Thaisawesome Mom. Send Ihem packing.

Connie Greyeyes-Dlck A ex N'ive lookylH

Boudlcca Icenl You Go Gir!) - or ralhet • You Make Them Go Girl!

3 -• .uy a : •

Joan Evans Way to go Ariene! Hibet your Grandpa would have beencheering you on too!

https://www.facebook.eom/arlene.boon.7/posls/10153317239366027?pnref=story

'ocfic yr.u^

This Is Exhibit referred to In the

affidavit of

made before me on this .t..?.

day of 20 .ii;»

A Commissioner for takingAffidavits for British Columbia

1/3

Page 98: BC Hydro Site C injunction: Affidavit #1 of Patrick Hayes

08/01/2016 Arlene Boon - Never underestimate the pCTwer of one woman..,.

2 6 Jaii,ar\'t- :-r

2 Dusty Clarke Burseth Awesome!!I 1 £ Janusfv 1' IE

Karen McKean Wonderful Ariene! Boots on the ground ...

Michelle Varr Stam Well done! Awesome.

• £ jan.i^ary 21 11

Kathy Schroeder Way to go!

vc-slerday ?•

Debbie Robiln Great Job and Thank You I!

1 -'esteroay &• '•.? • •.

Maggie Large Great job Arlene

vesteiday at Of •3

Jerri Lube Well done. Keep up the good Tight

YesiEiaav a; tif-f 3

Sue Worrall Soderstrom well done

Veslerae}' a; 06 'i'-

Anne Clayton Thanks for your commitment!

Vfcsir-roay a; Of.-E?

Vivian Clarke Thanks Ariene

Thanks Ariene wouldnl it be great to see Justin ... See More

1 ^ esi5i:;Ey a; l."

Bonny Wallace Mills Go AMenei

1 ' esieroc; 31il

Sarah Katharine Cox We are cheering you on Arlene!

1 "•eslerdcv s; 03.26

Meianie Foster-Franklin

1 "ESteiaty £• Or .23

Greg Shea So, let's gel serious about planting trees next summer! Thank you,Arlene. Stay strong!

Erika Koenlg-Workman Thank you for your courage, Iam following closelyand tweeting to @VillageCoal, Erikakw

> fcStiiaf.) c:

David Schindier sitting on the side of Wllliston Lake thinking about all thecultural and environmental devastation, i am saddened that more of this

useless destruction Is at foot

aa Greg Shea Is this the David Schindier frorr, Uof A? If so. you sir areamazing' Thank you so much for taking an interest In this debacle

You would, of course, understand die significance of this project onthe Wood Buffalo National Park nitpii'sierrarii.ir.nn na/sierr?-r(irh-|ic-

shsffis-unesco I hope everybody has seen diis ,,.

htlpv/ecowatcn corr.-'2Cl6'6i 'O/hydropower-climcie-nnange'...

Sierra Club BC shares UNESCO

concern about Site C impacts on...

David Schindier nc it is not but! agree with Dr Schindier wholeheatedly and his studies are important for the whole world. 1am not

sure why he is not in ttie forefront of this outrageous action that canonly be described as "a continuation of the environmental

devastation with no accounting for ail that will be lost as a result of it

RHa Churchill Thinking of you and this long-tasting fight. Thank God forpeople like you Ken Mike Arthur and Permy Ic name only a few.

2

Greg Shea Here on the Island the battle is about Shawnigan LakeOver 500 people turned out on Wednesday to protest and it is notgoing to slop anytime soon Then, there is the Chehaiis River

application for e similar contaminated soi! dump And the Mount

Engiisr fUk, Pnyatiy Terms C,o'.>kie5

Acivedisi'ic AoChoi.nti!. Mtirt

-acebook's 2CiC

hHps://www.facebook.com/ariene.b-Don.7/posts/10153317239366027?pnref=story

084

2/3

Page 99: BC Hydro Site C injunction: Affidavit #1 of Patrick Hayes

08/01/2016 Arlene Boon - Never underestimate thepower ofonewoman.... r\oBlloo

Poliey mess. When will Ihis insanity stop? Never- as long as thisgovernment is in power.

i (.rr

, Jodl Hickey Way to go!

1 ;}• h-s

Sarah Stringer I'll help plant fruit trees! We need a northern orchard. We

could also look at using some of this helpfully cleared land for geoUrermaigreenhouses?

mgl Greg Shea Now we're talking! Let's be proactive for agreener future.4 n's

Juiie Roach How awesomellll

53 Jeremy Williams i wish therewere a thousand people with you!t- 's

https;//wwv^.facebook.com/arlene.boon.7/posts/10l53317239366D27?pnref=slory 3/3

Page 100: BC Hydro Site C injunction: Affidavit #1 of Patrick Hayes

08/01/2016086

Helen Knot! - Arlene Boonwent out to the frontlineearly...

Fmaii or Phone Psss-AOf-:)

Log InSign Up

CD Keep melogged in Forgotten your password?

Helen Knott

6 January at 21:17 •

Arlene Boon went out to the frontline early today and was faced by 8 menand a piece of equipment, she said she was staying and they turnedaway. I came out and say there alone by the fire, the hydro guys came byasked me if i was staying, I said yes. He asked me if i knew they wereattempting to dear and i said i was attempting to use my treaty rightsthere. Then Isat and sang to myself, prayed, and though it would be niceto have a drummer. Sure enough a drummer shows up (it's a twentyminute trek from camp to the front line) he sings for the land and I was sograteful. We went down to the bridge. And I got to pray vnth Miss ChrtelyFenton while he sang. Came across hydro guys twice. They were put onnotice that this is treaty 8 land! 'grateful for all the love and for the peoplewho move when needed**

84 Likes 12 Comments 3 Shares

Dawn Turner, Susan Phillips, Angel Adolph and 81 others like ttiis.

3 shares

English (UK) • Privacy - Terms - Cookies 'Advertising •AdCholces • More

FacebookSi2016

This Is Exhibit referred to in the

affidavit of —

made before me on this

..... 20 ..fe

Christy Jordan-Fenton Seeing you today was very good for my spirit Soproud of the beautllul space you are holding. Your strength and voice areInspirettonaini!

2 •6 January at 21:23

Gerry Hunter Ppl willnever forget what you've done proud of you

5 - 6 January at 21:29

Jack Tcth Proud of your commitment

1 -6 January at 21:38

DIni Za Toghestiy Keep It upli You are all haro'sin

1 • 6 January al 21-39

Margaret Clavin Good job

1 -6 January at 22:43

Dawn Koch Slrenglh and peace to you. Ihonour your vision andcommitment Prayers for your focus.

1 • Yesterday al 03:06

Entro Aguas Love and strength from the South. Thanks for the Inspiration

1 • Yesterday at 04:34

Bruce Lantz You all are setting a great example.

1 • Yesterday at 04:39

Dennis Twigg

Yesterday at 07:15

Stacey E. Sallars Love the Shares Helen Knott, Blessings with Yous All;prayers of light shine upon each of you and AllOur RelaQons.

1 Yesterday at 10:14

Billy Burgess Helen your parents must be extremely proud of you god blessyou for protecting pacha mama and the dunne za heartland for all of you whostand against this industrial giant who rapes our lands not for only for ourgeneration but for all mankind In years to come.

1 • 17hrs

Angel Adolph You're incredibly strong spiritually &mentally you're anamazing role model for your littleman &many other people, got tons ofrespect for you

11 hrs

day of

:

A Commissioner for takingAffidavits for British Columbia

https7AiVWW.facebock.com/helenk05/posts/1015314g582g71627?p)ve^story 1/1

Page 101: BC Hydro Site C injunction: Affidavit #1 of Patrick Hayes

11/01/2016

Photos from Christy Jordan-Fenton's post

f- . ^ '' •r^.-S '-.{r • • '^v

•> ^ •*. >

r~1 Cli-iStv Jo'dsri-FonlorTne tjnkhojse af Ine camp This is Treaty B Termofy A! the site ol the histonr RoO.y

Mcunia'ri Fon

087

L mai nf Piione PasSA-D'd

Lug Ir •

ls£ i 501 lie "• ^"fflW you" passwo'd"?

P-e/'f-jf Nen

This is Exhibit referred to in the

affidavit olitfv-K

made before me on this

day ol 20 ..l!?.

A Commissioner for takingAffidavits (or British Columbia

FiDh' •'iijiiis r-.

Jo-dHh-Fs-i;,-;-! s •( M-i

JpioBh;

SheiM wii' Public

Oper Pnoic Viev.f

Do'Anipaa

Emfceci Post

Sic'i;: r/ijiss^et : ir l.'BWf

tOCelOrs ActJvil

Ts^r s He::

!.res!e Fc C.-eai^ ^sc?

rc^rironss Ba'S'^ Feccta Papas t"«MJ

r>?-«riorars "a'osrs iss -\j>.'h-jce5

faeecious ~ ;ciie

E-^gliShiUSl

https://wv/v/.facebook.com/photo.php?fbid=10153817006211462&set=pcb, 10153817042136462&type=3&the.,. 1

Page 102: BC Hydro Site C injunction: Affidavit #1 of Patrick Hayes

11/01/2016 First NaUonsPrepare for Arrest to Stop Site C Dam —ROCKY MOUNTAIN FORT CAMP,BC, Jan. 7,2016088

1 (Sd^PRINTTHIS

^irst Nations Prepare for Arrest to Stop Site CDam

Share

This is Exhibit referred to In the

affidavit of

made before me on this

day of 20 .Al?.

ACommissioner for takingAffidavits for British Columbia

Treaty 8 Stewards oftheLand call on Trudeau to stop megadamin B.C.*s PeaceValley

ROCKY MOUNTAIN FORT CAMP, BC, Jan. 7,2016 /CNW/ - First Nations members camped out atan historic fort site slated for destruction by the Site C dam say they are prepared to face arrest to protecttheir traditional territory.

Joined by local landowners, Treaty 8Stewards ofthe Land say they will not permit BC Hydro toproceed" :ith plans to clear-cut forests around tlie Rocky Mountain Fort site onthe west side of the Moberly

iver. The site, selected by explorer Alexander Mackenzie, was the first trading post in mainland B.C.and is situated in the traditional territory of Treaty 8 First Nations.

The $9 billion Site C dam would flood 107-kilometres of the scenic Peace River and its tributaries,including the traditional hunting and fishing grounds ofTreaty 8First Nations. In late December, despitethree on-going First Nations court cases against the dam, BC Hydro built a bridge across the mouth oftheMoberly River in preparation for logging in the proposed reservoir area.

In addition to its legal, economic, political andarchaeological significance to indigenous and non-indigenous people, the camp is the gateway to the rest ofthe threatened Peace Valley. BC Hydro hasserved notice that the camp must be dismantled.

"Logging and flooding this part of the Peace Valley will irreversibly harm our ability tohunt, fish, trapandexercise other constitutionally-protected Treaty Rights, especially since much of the restof Treaty 8Territory has been devastated byother hydro-electric, oil and gas and industrial developments," said ArtNapoleon, "To have any meaning, these treaty rights require a land base and waterways where there arewildlife and fish, andwhich is capable of supporting a diversity of plant life. Treaty rights also includemanagement level decision-making toprotect moose calving grounds, medicine harvesting and berrypicking, and spiritual practices - all ofwhich will be obliterated bySite C."

delegation ofFirst Nations chiefs told Prime Minister Trudeau's key Cabinet members in December^at suspending federal approval ofthe Site C dam is a critical litmus test ofhis government's promised

Tiew relationship with Indigenous Peoples.

"The Prime Minister says that Canada's most important relationship is with itsIndigenous Peoples andhttpy/www.printthls.cllckabillty.com/pl/cpt?expre=&title=First+Nations+Pr^)are+for+Arrest+toi-Stop+Site+C+Dam+—+ROCKY+MOUNTAiN+FORT+CAM... 1/2

Page 103: BC Hydro Site C injunction: Affidavit #1 of Patrick Hayes

11/01/2016 First Nations Prepare for /Arrestto Stop Site C Dam - ROCKY MOUNTAIN FORT CAMP, BC, Jan. 7,2016089

that he promises to uphold and respect Treaty Rights," said Helen Knott, "This is what we are trying todo at a grassroots level. I speak as Great Great Granddaughter of Chief Bigfoot, the last to sign Treaty 8in 1911, and I am trying to honour my Grandfatlier's original intent and uphold those rights he meant toprotect. I ask Prime Minister Trudeau to also honour that original intent."

^e applaud the court cases being brought by West Moberly, Prophet River and others, but they taketime to wind their way through the courts. Meanwliile, before the court cases are even heard, BC Hydrois destroying the very valley that these court casesare intendedto protect. The way I see it, they arestealingfrom futuregenerations, both Indigenous and non-Indigenous. We are not here just for us but forthe ones that will come after us," said Helen Knott. "As individual Treaty 8 First Nation members, wecannot stand by. Do I want to be arrested? No, I am here peacefully doing what I believe is right andneeded but this land is a part of who I am and I will take a stand for it. Prime Minister Trudeaucan stopBC Hydro from destroying the Peace Valley. Until he does, we will".

SOURCE Treaty 8 Stewards of the Land

For further information: Helen Knott, Prophet River First Nation member and Treaty 8 Steward of theLand, at (250) 280 2277; Art Napoleon, SaulteauFirst Nations member and Treaty 8 Steward of theLand, at (250) 818 5626

Organization Profile

Treaty 8 Stewards of the Land

ore on this organization

Find this article at:http://www.newswire.ca/news-releases/ftrst-nations-prepare-for-arrest-to-stop-site-c-dam-564495361 .html

0 Check thebox to inciude the list oflinks referenced in the article.

hltp://www.prinlthls.cllckattlity.com/pl/cpt?expir6=&fitie=First+Nafions+Prepare+for+Arrest+to+Stop+Slte+C+Dam+~+ROCKY+MOUNTAIN+FORT+CAM... 2/2

Page 104: BC Hydro Site C injunction: Affidavit #1 of Patrick Hayes

11/01/2016

Links

"i r K "

t-KLlhriy. - UiifSilL

AnsM'ering the Peace's Call: Siippoi*ting Rock>'Mountain Fort and the Site C Blockade

-iiic I ! Ct"i

t-(»n

\ i I III' ii> I ii^t S.iiiiiii' iiiil litiJixxU'i It- - ,ii tlii

11 \(tiuniiiH't <itl \\<' hull' Ik i-i- III' III Ihi t<i)Q:iU|. ji lU- mtiull. <>i llit

Mii^h-tIi \t lhi» lliiit- III' -iri' •HIKik ii|' tii-tti u<i-MiiiiiMl.ilriri-

'.i-ti liii-Iwi-llliti Mini'|)i<ii.iiil>>i iiilli iiiiil tiii'ililiinil

l\r ni'ii li.'i<i |ii<-i|ili>iliiii Inn I iimii ii)i Itun \ nin-niii-i in p n-ilu-<.iRi(i Hn-ti i- K'""'

mnnirnliirx -mil --niiiiinl .imlni- inu-il n kn |<tlii |in«>iiti' mi IVIiu'm .iii'-ml-iiH; Itir >> nmri-

Mi|i|iiiniT- ii -iiiini in t- inmi'iiiwl hi-l| --iii. iln i'.-.iii -.iiiii-i

I- iiiiMtijliki 11- riiiuii* |M'rmiin ui iiiiil iini m-1- ni-i-kl- lu-ii-- Inil i<wki miilrl iii-ii lidp tin :i

In -i-ii- lit 11 liiTU' 11m iliii iiiiinm II nm mi- jiii-.i-u .il^>|ij\> llin mi ,iii<llii-lj ^|lll<ullIln

I lit! Ill III .iiiil mini il niiiilil IvcH'-ilii -iiiium i iH ii

-r-ii--nil-ilbi-r- iiitlini II «'\(ii'tiit

II ici-iinil* IILr II b'b mt^iiiL I

nil--- .>t|ii'rilirii ilili

imic^riHnMhbii i(mMil* •< iiitniL i* n \rkrM i'h iv •'iiviUiti

ii. |ihu|i Nvi i>M«hdrrc'l>MM(i Ihi piUH'Mil i«m uiMiisii I -ill-rr) iMil> llii* ^jti 1l»p ilmrrMliK rtrii*

p«i<|rli III'dh loidtlli I Htc* |iin»i>iiih( (iiHtliliit iurt Indu 1uidu

I i< It'll hinuio* i' jiith ItiM I It NnLt MtitluUlHl I'tirl I

\ llN'S I <UMI<M<III I

rT.'siilth

••'I' I I'lli; »»•

< I hit JU V I 4M~

Ihttr< pt'inti'spi 'liM.ruffi

. mj. h'lJM i»'in 1 - IIP-!t •«

'- I- {\y. "< k pra i ci

This Is Exhibit ...Vi.W referred to In the

affidavit of

made before me on this

day of -J.ki, 20 ..lb.

NOW SMOWINC A Commissioner for takingAffidavits for British Columbia

http://www.pacificfreepress.com/rss/1439l-answering-the-peace-s-call-supporting-rocky-mountain-fort-and-th 1

090

Page 105: BC Hydro Site C injunction: Affidavit #1 of Patrick Hayes

11/01/2016

Nnvv SI lowtisic

SPOHSCiHEC

C Comments ' -'ific •''ee.'ss '"logressive "'-ws ' i; Opinion

V "t t)r)m^nrt ^2 St'-i""

Be (tie first lc comment

' login

>jn by t?--?! -

http://www.pacificfreepress.com/rss/14391-answering-the-peace-s-call-supporting-rocky-mountain-fort-and-th... 2

091

Page 106: BC Hydro Site C injunction: Affidavit #1 of Patrick Hayes

10/01/2016

The ECOReport

DAMS

This Is Exhibit referrsd to In the

affidavit of...

made before me on this

day of 20 ..j.b

A Commissioner for takingAffidavits for British Columbia

TREATY 8 STEWARDS OF THE LAND ARE

PREPAREDTO BE ARRESTEDJANUARY 8. 2016 I ROY L HALES . LEAVE A COMMENT

By Roy L Hales

The

ECOfeportvywvy.theECOrepprt.com

Local First Nations set up Rocky Mountain Fort Camp

before Christmas. There were six to eight members of

the newly formed Treaty 8 Stewards of the Land sleep

ing there last night. Spokesperson Art Napoleon said

First Nations originally talked about taking a stand

near the site of the proposed Site C Dam. but B.C. Hy-

http;//theecoreport.com/treaty-8-stewsrds-of-the-land-are-prepared-to-be-arrested/

092

Page 107: BC Hydro Site C injunction: Affidavit #1 of Patrick Hayes

10/01/2016

dro's work crews moved too fast. The once pristine forest that stood there has been de

stroyed. So First Nations decided to block this most recent perceived violation of Treaty 8 by

setting up Rocky Mountain Fort Camp. BC Hydro employees have already scouted the camp.

They could be preparing to seek an injunction, but this will not make the First Nations move.

Treaty 8 Stewards of the Land are prepared to be arrested.

Someone Has To Make A Stand

' Someone has to make a stand and since we are stewards of the land, we are the ones doing it

- along Vv^ith our allies who live along the banks of the river that is going to be flooded," said

Napoleon.

Treaty 8 gave local First Nations the right to hunt fish. trap, harvest traditional medicines and

continue their spiritual practices in the Peace River area.

http;//theecoreport.com/treaty-8-stewards-of-the-land-are-prepared-to-be-arrested/

093

Page 108: BC Hydro Site C injunction: Affidavit #1 of Patrick Hayes

10/01/2016

If the Site C Dam is built, it will flood 107-kilometres of the Peace River and its tributaries, in

cluding the traditional hunting and fishing grounds of Treaty 8 First Nations.

4

'.•e ; Of" '• p "Tiii?)- iV'vif Thr Volie\ i-noh '.'k( B(^fo''€ Site C

'There is already all kinds of mining, oil and gas, LNG, two other dams that have already been

built: no compensation: no consultation on the first two (dams). Now that the courts have

made consultation a requirement, especially since we have treaty rights, but that has not been

the case." said Napoleon

He added. "We don't think Premier Christy Clark gives a s about treaty rights. I don't even

know if she has the ability to define them. She doesn't take them seriously at all."

"The RCMP would never go out there and arrest someone for violation of a treaty right. We

live in a racist society, that's just how it is."

Appealing To Trudeau

In a press release, issued yesterday, the Stev\/ards of the Land called upon Prime Minister Jus

tin Trudeau to intervene.

http;//theecoreport.com/treaty-8-stewards-of-the-land-are-preparecl-to-be-arrested/

094

Page 109: BC Hydro Site C injunction: Affidavit #1 of Patrick Hayes

10/01/2016

P/c Pi Minisiei says thai innocia s mosi //npoi uinf n iatioiiship is with

inciigenoiis Peoples aiui ihoi he ijionilses to uphold and lespcci Tiea:y Rights said

••Iclcn -^no;This is wha; wr mr •tying to do ar a gia^sioots level. I spcah a'. Guat(.jieot Gianddnugnici of Chict Bigioot. ihe lasi to sign hcaiy 8 in IP] 1. and I amuying to honoLii my Ginnnjathri ' (j/iP/'/idl iiiicni and uphold diose righis he incan: to

I'/oferI sni. hi i/ric Mm P ikPciu ion/so 'lonoui l/ipi oi iginal iniem'

Treaty 8 Court Cases

.applaud die com i cases deing biought by West Mobcdy. Gophet Rivei andodicis.inn ihey.rd e dir - :o \A'ind rPtJi fheccnirts. Menim'/n'/e. Ixj'of c fhecoui;

cases aie eyen heaid. BC Hvdi o is destioying the yei y valley thai diesccouo eases aic

nitc ndecl tc' p': nca I

Napoleon says there is no guarantee the court cases, which are really appeals of the decisionto grant Site C environmental approval will succeed.

He believes there is no need for B.C. Hydro to log this year. They have proceeded despite the

court cases and public outcry in an attempt to railroad this project.

http;//theecoreport,com/treaty-8-stewards-of-the-land-are-prepared-to-be-arrested/

095

Page 110: BC Hydro Site C injunction: Affidavit #1 of Patrick Hayes

10/01/2016

"What they are trying to do is push their way in, show what they have done so there will be no

backing out," he said.

Treaty 8 Stewards Of The Land Are Prepared To Be ArrestedSo the group now calling themselves Treaty 8 Stewards of the Landhas set up at Rocky Moun

tain Fort Camp, to deny BC Hydro further access to the land. Though they are across the river

from Fort St John, this is a remote location half a mile from the nearest road. People come on a

rotating basis. There have been as many as 10, and as few are five. They know the courts could

issue an injunction in favour of B.C.Hydro. Ifthat happens. Treaty 8 Stewards Of The Land Are

Prepared To Be Arrested.

SHARE THIS:

f Facebook 26 ^ Twitter G* Google S5 Email ; ^ Pinterest t Tumblr ^fgi Print O Pocket

^ Reddit

^ ART NAPOLEON ^ BC HYDRO ^ HELEN KNOTT ^ PREMIER CHRISTY CLARK^ PRIME MINISTER JUSTIN TRUDEAU ^ PROPHET RIVER FIRST NATION ^ ROCKY MOUNTAIN FORT CAMP^ SITE CDAM ^ STEWARD OF THE LAND ^ TREATY #8 ^ WEST MOBERLY FIRST NATION

http://theecoreport.com/treaty-8-stewarcls-of-the-land-are-preparecl-to-be-arrested/

096

Page 111: BC Hydro Site C injunction: Affidavit #1 of Patrick Hayes

n

fp?i

11/01/2016

Sigh Up

Rachel Blatt

•'̂ ••-S'V I' i' '

As one of the Camp supply organizers, I have to say that the ongoingsupport to ruri Biis camp from Individuals in and outside of the North Peacearea, has been overwhelmingly positive'

Thank you to Allof you who are contributing yourselves, putting your ownlives on "hold" to come out and stay at the camp and Help us "Hold theFortr' Thank you to those who are donating and loaning food and suppliesto the Brave winter Campers protecting the forests in our Valley... .And thanks for those who firelessly orchestrate the food, supplies and

people in and out of the camp.Thank you to those who cannot come to the Peace but send their positive

comments, prayers and thoughts.Also a BIGthank you to those providing monetary support because withoutyou we could not operate and move buildings and people and purchaseneccessary supplies not donated or loaned.

To find out how you can Help to support the Protection of our Valley,inhabitants historical and sacred sites and the forest that protects all PMme or contact Yvonne Tupper Arlene Boon, Helen knott or VerenaHofmann via Face book

Please Share this post and Keep our Peaceful Protest of the proposed SiteC Dam, Rocky Mountain Fort Camp, going!Not a done deal..

f fif.t t.ifx* . •.??'?

This Is Exhibit...II.... referred to in theaffidavit of , fiddcJ^made before me on this.. m.day ol 20 .1 b

ACommissioner for takingAffidavits for British Columbia

https://www.facebook.com/peaceequestrian.park/posts/988000773288367?pnref=story

097

] Login I

Page 112: BC Hydro Site C injunction: Affidavit #1 of Patrick Hayes

11/01/2016 098

• S.g;up I L 1 I 1LifildKf'a •••f Oiije;: in t COK yinij-pms/, o.:! •

Rachel Blatl

YvSl'i'P.Sv 1. 'I'l;':" ?V'.cj;.S!' Ais-- f'l vSA. Ifii- n i;, iXi( -

P-1 A'.; Ct'icir'-r

Latest RMF camp "Wish List".

We really could do with one (or two) prefab outhouses built so that we couldhaul them to RMF by truck/snowmobile and then assemble them easilyonsight. The bathroom facility is a bit rustic, to stay the least

Ifanyone has a large grate for the firepit (or can weld one together), peoplecould cook on the fire when it is nice outside This would also help conserve

fuel for the Coleman stove

\Ne could also use some help of local supporters who have 4WD pickupsand snowmobiles to transport supplies to RMF It would be a great daytripfor outdoorsy types used to the backcountry. Three-four hours drive fromFort St John (less, ifyou are coming from HH or Chetwynd), ttien a shortsnowmobile ride down the hill (20 minutes) to help out where needed(assembling outhouses, etc.), then back to your truck by late afternoon andhome in time for a fashionably late dinner. (The crew holding down the Fortis too busy to get more firewood, so if someone brought their own chainsaw

f~t they could spend a couple of hours cutting wood and transporting it tocamp).

There is now a small freezer set up at Peace Equestrian Park, Pedersen'sto leave frozen food, preprepared meals in Remember that the campdoesnt have an oven so meals should be stovetop friendly for reheatingThank you

This is Exhibit ...IXJ... reloued lo in iheaffidavit of

made before me on this .......c|

day of 20 ...l!?

A Commissioner for takingAffidavits for British Columbia

https://www.facebook.com/peaceequestrian.park/posts/988384269916684?pnre^story

Page 113: BC Hydro Site C injunction: Affidavit #1 of Patrick Hayes

19/01/2016 Cold day at the camp yraterday (-25C... - Christy JordarvFenton

,1]-, U|,

n-.r lagee: n -argtne' •••fu" i asE'. -.Td?

Christy Jordan-Fenton aooaD 2 Jiew photos

Cold day at the camp yesterday (-25C before windchill), but good to makeprayers for the water and the land, the chief spirits, the ancestors, all livingbeings (and those needlessly destroyed), and ali who are doing their bestto honour this sacred Peace River Valley. Connecting and sharingperspectives that go beyond the Illusion of the lie austerity keeps feedingus...very good for the soul. Lifewas not meant to be played like a game oftaking more than your share just to have it. at the cost of there being notenough for everything else. Nice to find a collective space to step out ofthe game and reconnect with the true purpose of life. Grateful to everyonewho is sharing our plight, providing donations and supplies, praying for the

water and the land, and especially to those making the difficult trip to thecamp, and slaying there in some very extreme cold weather conditions.We think heroes are larger than life figures we see on TV, but 1know theyare really mothers and elders and farmers and ail those other beautiful

people who just feel a calling, who man fires and document medicines and

share stories and pray...and stand by their inner truth at all costs. To all ofyou involved with the camp, I know no greater heroes. You are all the firethat warms the ancestors.

3S Likej 2 Ccnmems I'l Sha'es

Nancy Budd Denham. Wendy Moore. Jodi Sokoloski and 32 others like this.

•" siieres

Patricia Ann Martin

2 c "!3 •

Marian ShIHta Thank you. Christy. Shanng.

' '•' .lar.uJ/j 5 1'' ' 1

Reg Whiten beautiful reflection liiU'S>.>'...your sentiments transcends the'doubie-speak' rhetoric and cuts to the core of what it means to be a witness(or soclai/eco-Justice...feeling proud to be connected withi this circle of trueslewardsi

E'.giist" tUK, Pnvacy icms Ccckies

advertising AdCncces Mo'e

^acebook ~ 23't

This Is Exhibit refsrrsd to In the

affidavit of

made before me on this

day of 20 ..ik

A Commissioner for takingAffidavits for British Columbia

h!tfK://www.f3cebook.com/ChrlstyJordanFenton/posts/10153823573465462

099

og ii'

1/1

Page 114: BC Hydro Site C injunction: Affidavit #1 of Patrick Hayes

11/01/2016 Photos from Christy Jordan-Fenton's post - Christy JordarvPenton | Facebook

Photos from Christy Jordan-Fenton's postBack ic A'Cun

Christy Jordsn-Fenton

Yvonne Tupper and vereit!. Hofmsnr. Heroes In action manning the fire and sharingconversation. Yvonne put in several days of fire keeping in very extreme cold weatherconditions for long hours each day. Ifthis isnl committingto your inner truth, Idon't knowwhatfs.

Yfcslerda\

Brenda Norrell, Johnny Gids. Danielea Castell and I't others like this.

• Yvonne Tupper Thank you. Yes very cold butabig thank you to Ken andJack for taken of me. o They are my heros

Christy Jordan-Ferrton YeS; Ken and Jack are AlviAZING! Inspired byeveryone who contributes

Reg Whiten Awesome commitment by all to keep the sacred fire burning...

Suzanna Raepberrye You GotTTiis Bubba Keep The Fire BurningRl' Bubba.you are Truely Amazing. Niece Love you Baby gtrl

Yvonne Tupper I love you toe AuntySuec Iwish you can put a log or 2 inour ongoing tires.

Everyday 1am out there Ising loud and proud -traditional songs. Ilove howmy voice echoes down towards the MoberlyValley and Boreal Forest- ourmini Rain forest

previous Next

From Photos from Christy

Jordan-Fenton's posiir Mobile

Uploads

Bharec viir Public

Oper. Phoic 'lewei

Downloac

Embed Post

https;//v/ww.facebook.com/photo.php7fbid=10153823578751462&set=pcb.10153823573466462&type=3&tfieater

100

1/2

Page 115: BC Hydro Site C injunction: Affidavit #1 of Patrick Hayes

11/01/2016 Photcs fra-n Christy Jordan-Fenton's post • Christy JordarvFenton | Facebodc

2 If ho.i^ aoc-

SignUc Login Messenger Facebook Lite Mobile Find Friends Badges People Pages Pisces

Games Locations About Create Adved Create Page Developers Careers Privacy Cookies AdChoices

Terms Help

Facebook ©2016

M Englisi- (UKi

https://www.facebook.com/photo.(:^p?ftad=10153823578751462&set=pcb.10l53823573466462&type=3&theater

Page 116: BC Hydro Site C injunction: Affidavit #1 of Patrick Hayes

TRANSCRIPT

This is a transcript of a video posted on Facebook by Yvonne Tupper on January 11,2016.Downloaded at:

https://www.facebook.com/vvonne.tupper/videos/vb.665415637/1015376310341S638/?tVDe=

2&theater

This transcript was prepared by staff in the Document & Software Support Servicesdepartment of Fasken Martineau DuMouIin LLP.

Yvonne

Tupper:They're up here, Beatrice. Four ofthem. January 7,2016, approximately about9 a.m. in the morning. They started moving the machine in, and they're forgingin on the path. They're pretending, I can't hear what they say. I don't think theyknow who I am today because I'm wearing a different jacket and toque. This isBeatrice. This is Lisa, [sound ofwalking in snow]

Good morning.

[Native language spoken] Treaty 8 territory

It's unsafe to travel beyond here. We're conducting logging operations, and it'sunsafe to travel beyond this point at this time.

[Native language spoken] sign that we put up [Native language]

I imderstood you to say you put up a sign there?

IhtoUGMft

MM#

LLMIMWMI

102

e3

Randy Lines:

Beatrice:

Chris Van

Luven:

Beatrice:

Randy Lines:

Beatrice:

Randy Lines:

Yvonne

Tupper:

Contractor:

Yvonne

Tupper:

Randy Lines:

Yeah. [Native language]

I'm sorry, I don't understand.

Can you repeat that please?

I'm sorry?

You said you were sorry, you did not understand?

mMfcilDHMWitil I

II wife*

Chris Van

Luven:

ACommlsMwrfar tiMrioAffidavits for Britlili CoUiinblS

Yeah, I didn't understand anything beyond, she said something about you left asign

1... I heard exactly what my partner did.

240150.00163/90625893.1

Page 117: BC Hydro Site C injunction: Affidavit #1 of Patrick Hayes

-2

Yvonne So do you understand what she's saying to you?Tupper:

Chris Van My understanding is thatyou placed signs butwe don't understand anythingLuven: further.

Randy Lines: I'm not sure whatlanguage you're speaking in, sorry,

Beatrice: Gee. [Native language]

Randy Lines: Are you able to translate for her?

Yvonne Outof respect formyElder, I'11 wait forherto give meconsent to speak onherTupper: behalf.

Beatrice: Okay.

Yvonne She would like to welcome you to the Treaty 8 territory. We're videoTupper: recording, as we see you recording us. We are putting you guys onnotice that

this is an activeTreaty8 territory site,and we did not give consent. And we'relooking for medicines today, andthemedicines weneedis onthat side, andwe're walking thepathas youcanseeit's a well[inaudible] path. You've usedourpathto come here, and we'vebeen doing this for—and we're going tocontinue to do it until we find what we're looking for.

Randy Lines: Well, we're not here to impede you. We're justhere to say that it's notsafe togo this way.

Yvonne Yeah, we noticed there's no worksites anywhere,no worksite signs on anyTupper: structure or treeor willow, anything around here.

Randy Lines: Okay.

Yvonne May I have your name please?Tupper:

Randy Lines: My name's Randy.

Yvonne Where are you from. Randy?Tupper:

Randy Lines: I'm helping outwith security for BC Hydro.

Yvonne What's your last name, Randy?Tupper:

Randy Lines: It's Lines. May I ask yourname?

240150.00163/90625893.1

103

Page 118: BC Hydro Site C injunction: Affidavit #1 of Patrick Hayes

p-i

Yvonne

Tupper:

Chris Van

Luven;

Yvonne

Tupper:

Chris Van

Luven:

Yvonne

Tupper:

Chris Van

Luven:

Yvonne

Tupper:

Chris Van

Luven and

Randy Lines:

Yvonne

Tupper:

Contractor:

Yvonne

Tupper:

Contractor:

Yvonne

Tupper:

Contractor:

Yvonne

Tupper:

What's your name, sir?

My name's Chris.

And your last name, Chris?

Van Luven.

Van Luven, Chris. And what's your role?

I'm helping out BC Hydro when it comes to safety and security.

So, we did not give consent prior to this logging on this side of the river, andthat's why we're here as Treaty 8 First Nations persons. But also, this land'sbeen used, like she said in her language, it's been used for many years. So wewould like to go past.

Well, we're not here to stop you.

Alright.

Gentlemen! [background voices]

May I have your consent to be on video and to be posted on public websites?

No thanks.

And who are you? Say your name so I have it.

Why do you need my name?

Well I have your picture.

Contractor: Okay. My name is Wayne.

240150.00163/9062S893.1

104

Page 119: BC Hydro Site C injunction: Affidavit #1 of Patrick Hayes

Yvonne

Tupper:

WayneHowes:

Yvonne

Tupper:

WayneHowes:

Yvonne

Tupper:

Contractor:

Yvonne

Tupper:

Contractor:

Yvonne

Tupper:

Contractor:

Yvonne

Tupper:

Contractor:

Yvonne

Tupper:

Yvonne

Tupper:

Contractor:

Yvonne

Tupper:

-4

Wayne, and your last name.

Howes.

Where are you from?

Chetwynd.

Gentlemen, who are you?

Do we have to move back?

Okay, we're walking.

Okay, just hold on, I'll stop them ifyou're going ahead, please

Okay. So obviously, they're, it's along our track. Wherewe would like to go.

We'll get the machine shut down for you.

Okay. We're going to go as far as Chris.

It's unsafe to go beyond this point. Pleasejust give us a minute to get themachine shut down.

Can you say that again louderplease? Thatyou're impeding our Treatyrights,that we can't access our land.

[Multiple voices in unison, inaudible]

Are you denying my Treaty rights to come farther?

No, no, I'm telling you it's not safe to go further.

Are you aware that this is Treaty 8 territory?

Contractor: No.

240150.00163/90625893.

105

Page 120: BC Hydro Site C injunction: Affidavit #1 of Patrick Hayes

5-

Yvonne Okay. So I think your companies need to have a culture training to realize whatTupper: territory these are on. And that's clearly noted on our signs.

Contractor: Now, you see the machine.

Yvonne

Tupper:

Beatrice:

Yvonne

Tupper:

Chris Van

Luven:

Yvonne

Tupper:

And there's a warning on the sign that says 150 feet, and I'm not 150 feet, bythe markers, if there's markers. But which, clearly, there's no markers. If thisis an active worksite, I would appreciate construction work signs posted. Canyou guys do that? 'Cause we're going to have Treaty-- like, there's thirty of~oh, I shouldn't say the amount. There's plenty of us here, and when you knowthat there's an active worksite. If there's an active worksite, I think we have tothe authorities that may be, like WCB. So ifyou guys don't want that, pleasepractice safety for us. Weput those signsup for your safety, to let you knowwe're here. We've been putting you on notice daily that we'll be in thisterritory. And we'll continue to be in this territory because this is our territory.Excuse us. The machine stopped, and we're going to continue walking. I cansee, and videotaped there, they stopped.

[Native language spoken] cancer [Native language spoken]

The machine hasn't stopped yet.

The machine has been shut down. It's safe to travel now.

Thank you.

Randy Lines: Oh, hang on. Are you sure? Just double-checkwith those...

Chris Van Wayne, Wayne, I'm just confirming that the machine is in a shutdown position?Luven: Ifs safe to travel?

Contractor: Yep.

Beatrice: It should be right off.

Yvonne Right off and turned around, that's your wish? Shewould like it to be tumedTupper: around.

Beatrice: [Native language]

Yvonne Do you want me to give a summary of that?Tupper:

Beatrice: Yeah.

240150.00163/90625893.1

106

Page 121: BC Hydro Site C injunction: Affidavit #1 of Patrick Hayes

-6-

Yvonne Ourpeople has been affected with cancer, andcancer affects a lotof people.Tapper: And the medicine we're lookingfor, we want to check for logs in the trees that

you tear down without our consent, so that we can find that medicine. Thatmedicine can help a million or so people, it's very powerful on not only cancerbut others, so we're checking the trees and the logs to...

My sister died from cancer.

And her sister has passed away, so this is very important for my Elder.

Beatrice:

Yvonne

Tapper:

Beatrice:

Yvonne

Tupper:

Contractor:

Yvonne

Tupper:

She [inaudible] medicine. Elders need medicine. And the doctors, whateveryou guys use [inaudible]. About two years I [inaudible]. And an Elder madethat medicine for me. I kept drinking, my last drink was in January, and it's abenign, never go back. So, I'm healthy, way healthy. And then I had anotheroperation from that medicine, in the bush here. That one healed me fromdoctor operation. I was so in pain. A few years.

Randy Lines: I think that, what I've heard, is important. I hope that the audio came throughwell. I can assure you that I'll pass it on to the people that. It's not my positionto be saying who can go where, so...

Beatrice: There's medicine here. I came yesterday,I see there's some medicine here thatwould help me in the future.

Contractor; The best we...

Hi there.

How are you?

Cold right now.

Contractor: It is chilly.

Yvonne So, I'm sure you guys are well aware, we have set a camp at the Rocky FortTupper: Mountain Camp, and we've been taking care of, well, with the numerous

people ofsupports, we're going to continueto look for the medicine today.Yesterday I also acted as a different activity; we're going to continue to do thatuntil—^because, this is our territory. Before the dams, before the government.This is our land. And it will be our land. We're the stewards of the land.Alright. So, we would like to continue. We'd like to see, know, if you guystook down our signs.

Randy Lines: I'm not sure. I didn't take down any signs.

240150.00163/90625893.

107

Page 122: BC Hydro Site C injunction: Affidavit #1 of Patrick Hayes

7-

Yvonne Did anybody take down our signs? Becausewe're putting you guys on noticeTupper; that we're here. Andwe're not goingto stop being here untilwhatneedsto be

done for ourselves. We all have our personal connection to the land.

Beatrice: I really believe in this medicine...bush. It healed me. And [inaudible]

Yvonne So we're going to go check. It's like tracking.. .we're going to go see ifourTupper: signs are up, and we're goingto document if the signs were removed, because

again, ifwe're concernedabout your safety, and I know you guys are concernedabout our safety. Hopefully, hopefullyyou're concernedabout our safety!

Contractor; Absolutely.

Yvonne And so we're— that's why we put up tlie signs yesterday, to let you know thatTupper: we're here, right?

Contractor: We didn't [inaudible]

Contractor: No, we didn't take any [inaudible]

Yvonne Okay, so we're goingto go where that machine is, and aroundthe bend,Tupper: because I thinkyouguys wenta littlebit farther today than yesterday, and

we're going to see ifour signs are still there.

Contractor: Okay.

Yvonne So we are going to be on that line.Tupper:

Randy Lines, Absolutely, yeah, and we're okayto eitherbe nearyou if youwish, for yourChris Van safety, or we canjust leave you alone, completely alone, it's up to you.Luven::

Yvonne Only if you're going to be a partof it. I would love foryou guys to be helpingTupper: us with hermedicines andsuch, but if you guys have a job to doandit's off

yourjob time, please come back andhelp us look forwhat we're looking for.It's a very serious medicine.

Contractor: I'm sorry, a gentleman yesterday referred to it bya name and I don't rememberthe name. What was the name of it?

Yvonne Yeah, we watched that video, and I wasprettydisappointed that none of youTupper: guys know ourlanguage. That'saninsult to us, that you guys need to

practice.. .and the ones that sitover there, two ofthem are my cousins. Theydon't how to speak either. And so I'm pretty insulted thatyou'rebringing themto interpret foryou, and they're standing over there. They're not interpretingfor you. SoI want you guys to bebetter prepared when wecome outagain.

240150.00163/90625893.1

108

Page 123: BC Hydro Site C injunction: Affidavit #1 of Patrick Hayes

I*!

-8-

I'm doing this for your sake, because 1might notbehere tomorrow, or thenextday. But if I am, I'm going tosay this again onrecorded tapes, there's twocameras andmy camera, you need to beprepared because wearegoing to bepresent.

Randy Lines: Okay.

Yvonne Thank you. Okay, wehave that macliine turned around and gone. Doyou wantTupper: them to escort us ordo you think we're..,we're okay, because yesterday I was

okay, too, you guys didn't seem tobother me, you guys left me alone, andthank you for doing that.

Contractor: Our desire is not to hinderyou in any way. [inaudible]

Beatrice: Machine turned off.

Contractor: You'd like it shut down?

Beatrice: Yeah

Contractor: We'll pass that on right now.

Yvonne Thank you. We'll wait right here.Tupper:

Beatrice: I want to talk to her alone [End ofvideo]

240150.00163/90625893.1

109

Page 124: BC Hydro Site C injunction: Affidavit #1 of Patrick Hayes

n

n

11/01/2016 Yvonne Tupper - Photos from Yvonne Tupper's post | Facebook

Photos from Yvonne Tupper's post

Back !:• WnuiT;

Yvonne Tupper

Treaty 8 ElOer-Jack A and I at front end waiting to give notice. Ken tool< picture.I am in a skirt in minus 20 something weather

SSaveLnePesce t-"sgi'C-rr;ot'C-' st. 'g:

ftseveourf'st.

ficowboys-and-indians-unitea-lD-save-tbe-Peace

*1 hrs

Rita Neighbor, Slefame Lehmann Harris, ^eah Kaiser and 3 others like this.

Rachel Blatt skiert and leggings warmer than pants! Like rrntts or gloves

lU-ff, me injjocc' ii yoii' faMv.of;'

PrevioiiE Neifl

Prcrr, Piioicf ircm Yvonne

Tuppers posi i- '^Icibiie

Uploads

Shared with Public

Open Priolc X'lev.'er

Download

Embed Post

Sign up Log |r MesseF^gfe' Facebcok Lite Mobile FindPnends Badges Peopts r^gges Places

Gemes [.ocalions About Create Adven Create Page Developers Careers Pnvacy Cookies AdChoices

'erms Heif-

This IS Exhibit .Mlxi.... 1. ... ihsalfidavit of

made before me on thlB

day of

A Commissioner for tai-mgAffidavits for British Coiumoia

http5://www.facebook.com/pholo.php?fbid=10153762587100S38&set=pcb.10153762587420638&type=3&theater

110

1/1

Page 125: BC Hydro Site C injunction: Affidavit #1 of Patrick Hayes
Page 126: BC Hydro Site C injunction: Affidavit #1 of Patrick Hayes

11221/01/2016 Sarah Katharine Cox on Twitter: "Peace fermer Ken Boon packs up donated food for #SiteC Rocky Mnt Fa1 camp. @SavePeaceValley @FNFNTweets.

^ Sarah Katharine Cox/©Sarah K Ccx

Follow

Peace farmer Ken Boon picks up donatedfood for #SiteC Rocky Mnt Fort camp.@SavePeaceValley @FNFNTweets@bcuic

https://twiaer.eom/Sarah_K_Cox/status/686987850919759872 1/1

Page 127: BC Hydro Site C injunction: Affidavit #1 of Patrick Hayes

f-t

14/01/2016 YvonneTupper- Was HungerGames a mythor is it reality,...

Fmai! r>rPhane PaSSV.'Gfd

Styn Up© Keeptneloggedin Forgotten yourpassword?

Yvonne Tupper1 hr-

Was Hunger Games a myth or is it reality. It's seems likea realityfor me.Landowners and Treaty 8- Indigenous individualssaying enough toconstruction/destruction of the Peace Valley.Govt hoping to divide and conquer whilerobbing 9 billion dollars from us-who pay an utility bill. The money we pay monthlyshould be in black-goodstandings but no..reality be hydro is on debt. Yes a years offdebtAs a Treaty member who pays taxes and my hydro bill, i give money tothe provincial utility and they seriously mismanaged money. Seriously itshould be only in the good not in the red. Whose getting rich here? Whereis our money going? Whyshould people pay another 30%on a hydro billthat is being mismanaged.And when the BC Municipalities voted 'No' to the destruction of PeaceValley-govt override it knowingthat Vancouver will not get a new SeaWall- other Municipalities will not get their infrastructure funds in the next10-20 years until the destruction is finished.

If you do not give Consent for this dam to be built, help support our cause; Treaty 8 Stewards Of the Lands.1) People who are opposed Site C-joinus in Camp.

2) Social media champaigns: Write"In SolidaritywithTreaty 8 Stewards Of the Lands as long as the sunshines, River flows and grass grows*Hashtag/# Keep The PeaceAnd tag Helen Knolt or myself.

3)Any financial supports willbe greatly appreciated as well.

4)And rides to and from camp.Contact Verena at 250.793.1124

Or pm me as well.

Thank you for ail the supports thus far. we have a long ways to go.Kinanskotim-many blessings -Yvonne T.

10 Likes 3 Comments

Sassy Handt,Suzanna Raspberrye, Brenda KillsMalsey and 7 others like this.

alereo Rathje Thank you Land Stewards for standing up for what you believein!

1 • 58 mips

• Yvonne Tupper Your welcome.Teree, you are welcome to join us anytimeo spend a day or night or two.

1 • 44 mins

Bronda HUlsMalsey ni do what Ican to spread the word and oppose but Icani stay at the Camp, sorry and Thanks for all the hard workxx

16 mIns

English (UK) • Privacy •Terms •Cookies •Advertising • AdChoices • More

Facebook<S)2016

This is Exhibit referred to in the

affidavit of

made before me on this

day of .vZftmfACti..... ... 20 .J.k

A Commissioner for takingAffidavits for British Columbia

fitlps://www.fac^xKjk.com/yvonn8.tiq)per/posts/10153769K4500638?pnref=story

113

Lay In

1/1

Page 128: BC Hydro Site C injunction: Affidavit #1 of Patrick Hayes

18/01/2016

do before rne on this

. fiii (s Exhibit referred to in the

iiSidavit of 'jQih. 'inHp hpfnrfi rne on this /frS

d»y,.of 20 lb.

A Commissioner for takingAffidavits for British Columbia

Rocky Mountain Fort Campers

153 SHARE TWEET

UPDATE 3 DAYS AGO

lie tlK:•i";' to like this upilfte

We been at camp now successfully for past 15 days!

TWEET DONATE

We are raising funds for upcoming projected court legal and legalteam battlesfor the dedicated Rocky Mountain Fort Campers from January 1.2016 who

are willing to be arrested to protect the Peace Valley from further destruction.We are up against a big Corporation - BCHydro and government opposing nomore of lifetime destruction of the Peace Valley - Peace River & MoberlyRiver. We did not consent to this massive destruction and it is an insult to

destroy when there are court cases pending both federal and provincialiysupferne courts. Thus far they had destroyed forever Eagle's nests. Beaver

Dams, many other birds nests and animaldens, timber and changed thelandscaping of this region. It must be stop.

We are standingtrue north andfree to Savethe PeaceValley. Every Canadianhas the rightto Protestandexpress theirconcerns- Canadian Human Rightsand this megadam ison Treaty8 territory and Treatyrightsmatter will be putto the test in court systems.

Landowners & ranchers & farmers have alot to use-their homes, farms and

https://vvww.gofundme.com/s6c4s4vs

si,545 of $200k

Raised by 19 people in 3 days

Donate Now

SHARE ON FACEBOOK

Created JanuaiY 14.2016

Yvonne Tupper

19 DONATIONS

®250Steve andJanet Gray

'• >V.. I'OI' ' V*'

.III iii'.pit.)lion liiii; ii't. '• iwl.!

Cathy FortinJdivagfi

St.••nil Slrfng. Ifi.Wikvui' nilffVit y{4J•I'.-.

®100Caitlin Vince

Julia Noegel

Page 129: BC Hydro Site C injunction: Affidavit #1 of Patrick Hayes

18/01/2016

agrlculturat, if this destruction continues,

BC'-ians would lose a huge amouht'local Treshharvested foods from the PeaceRegion.

Dedicated Rocky Mountain Fort Campers in solidarity are; Treaty 8 Stewards

of Land. Treaty 8 members-Eiders & youths, Peace Valley Landowners and

others who did not consent to this mega dam project- Or David Suzuki and

UCIBC-Grand Chief Stewart Phillip,and numerous entities and groups.Our goal is to continue to protect the Boreal forest all its habitats and

environmental benefits we need as humans. It had old growth trees and

historical value.

Our Northern- mini rain forest; ail the habitats of the two & four leggedanimals, all that flies, and all the swim and air, land and waterways. Eagle island,historical sites and trails, ancestral grave sites, further destruction of thePeace River,it willeffect air changes, weathering, all environmental concernsand pycho-social aspects of us. who choose to live here.

Alldonations accepted will be for legal expenses.

•Email transfers are not accepted at this time -only go fund me app.-

•On behalf of the Rocky Mountain Fort Campers thank you.

•join our social media champaign as well•join other existing fb event pages and fb pages: Stop Site C, Treaty 8-No Dam

V^aymy photos of Peace. And others.

Event page: Treaty 8 Stewards Of the Land•In future, ifgoal is met we willbe Initiatinganother Go Fund Me until Site C is

stopped forever.

' l-L '.-.r'-v L•.•'••i-' 1. '̂ : iui"--:!-''.r.Ky h''-''..li 11 .i; t' .fi'H-vvuh

' VfI ir,;n.: Wllh :j':; f Vi i.V h' C.kiin-'/.'.V t ipl fvli", UOit

Cii v-.d I .iicf Sl'.-w.ii • hhiiiipu.-il-.Br' iiyjiftoh,kI.off. AnJis willingIF-. k'Oiiir- .lO^v'th M.-,-li tuin Foh '" impci:", opposing .i)it.eC

I :.t iiiii' r' iv 'v!.-..'...; i Pi I i.1 ..• i ji !•• •ifi [p, nytli "i f>C

' ifTtr : I.I" r. Uci' -P iv

hUj'. '..'-•I .1.1. >,t i'.(ij PiVLb;

.im'. .-fiii'sL'.Ci- : .y -i!' 1

'.i!h .rVVny-'l. >{'.••.1

r .jlr,"Rivui •..•icjf.-.'• .lip

https://www.gofundme.com/s6c4s4vs

Tenneille Metz

2 da/s .iBf

^50Anonymous

hocLeslie Dickie

hooAnonymous

®50Wayne Bradley

®20Anne Parkinson

1-10 of 19tJonatloni

Page 130: BC Hydro Site C injunction: Affidavit #1 of Patrick Hayes

1*^

p-i

18/01/2016

153 SHARES TWEET DONATESHARE TWEET DONATE

COPY. PASTE S SHAPE; htlps-//www.gofundme.corn/s6c^5Avs

What is GoFiintlMe?

riitnlrrtiiirigfiiactec.i'.v »l.'H'OUI l!N|. CONIACI

NO COMMENTS YET

Please use Facebook to leave a comment below:

CONTINUE

.Ni'tfjiaggp''' po'-'tfl loyuiw vv.ill Only your f-ncelKrok name-6 pl<oto are used.

ii;- m!!: ti i •5n;;ii!'i tOII t| !• a • vv; Ivsil*" 11;'ir: inwfKif

OU STAR! FU

vV; !•-

ICAkN MO fit

ilCKlll; i;--

https://www.gofundme.com/s6c4s4vs

MA.(Oi' fVtNT'i

'.t!•: i!U.' i 1 i !

'i-'i'-M ! ii

I \ 1'

; I I .)il

CONNIX I WITH US

Asl 'no I't r

••Itipfnni';.

Kk ." Hic- am

'̂ oliaw@g!]ti!n<3ntc ?̂70KMIowere { Like (atilkl

0,;il Triv.!',VIV'li'y i lff.T)j v(V ' iitKll-ii-

116

Page 131: BC Hydro Site C injunction: Affidavit #1 of Patrick Hayes

n

21/01/2016

S'yt' U;-

Yvonne Tupper - We been at camp now successfully for past...

Kect fir. lojut " r "•.igciier youi LasE.viir;

Yvonne TupperIf. Janusr) ai iC Ob

We been at camp now successfully for past 16 days!Ifyou can support us with raising funds for legal costs.•Every and any amount accepted: $10. 20, 50 , 100. 500, 1,000, and

510,000 or more to help us raise our goal this time at 5200,000 Canadianfunds.

•'Please share and spread this Go Fund Me Campaign! "

English (UX) Privacy Terms CcokiesActverl'sifc ftpCioicer More

fsceftonk ® 20'r6

Rocky Mountain Fort CampersYvonne Tupper has posted s new update!

Vi'VM' C- V.ow

Lihet

Share

This Is Exhibit referred to In the

affidavit of

made before me on this

day of 20 .JM

A Commissioner for takingAffidavits for British Columbia

htips://www.facebQGk.com/i'vonne.tupper/posts/10153772192550638?pnref=story

117

I OQ I

1/1

Page 132: BC Hydro Site C injunction: Affidavit #1 of Patrick Hayes

n

1*1

18/01/2016

Email« Ptiofie Passwotl

Sign lip ] ] [Ei3 Keep me logged in Forgo) yoirpasswoni''

Rachel Biatt

shared Verena Hofmann's pos'J-^n-Kiry It at P '.•Earn

Want to Help Preserve our Valley and the 1700's HistoricRocky MountainFort Site but can't make it up here right away''

Here is another way We need help S$ wise to pay for moving buildings andfor supplies not donated or loaned

The support thus far has been astounding from folks coming out to campand cook etc. donations of wail tents and equipment and Allthose busilybaking and cooking meals for the campers.

Thank you to all for what you have contributed. We are standing for theValley together one way or another!

Please share this post to your timelines.

Verciia Hofmann Say "NO" to Site "C" Dam!.)n'>ii3fy 16 a; / 5=ain

fjo I-U1K3 Me Fundraistng Campaipn is up 6 running for DieRocky Mlri FortCamp lo access leg-si support S5. S20, S'JO or $100 IIall helps and is uigenllyneo'JeU

I'LtASE PRESS THE SHARE BintON 8 URGE YOUR FRIENDS S FAMILY

TO DONATE

Allthose aiJ'ing ho* you tan siqipon • this if Dev.and we uigently need to raise(thr iieeued rWlaif'

Ihariii you lo ail in©amazing supporleis rvea' £ Isr' Saving tfie Peace RivcVallny is lot the beiielil or all and tiuly retevnni for tlie inteoiily of Die Firsl Nationi luaiies auoss Canada as wellas Die global impoitanceol human nglils. tocrJ

and ciniaie ciiaoge

h'.lpf r/v.'.vw pcfiindme roni(f'jc<1s4'/?

1 III ft

Slwre

English (US) Privacy leans CookiesAdvertising Ad Choices More

Fac€book©2016

TMtH&MI

#

beff"

5S

.....

Log In

A Comml8sfen«r for ttkinflfor Brttioh OolunM

https;//www.facebook.com/peaceequestrian.pai1</posts/971535406268237

118

Page 133: BC Hydro Site C injunction: Affidavit #1 of Patrick Hayes

n

n

21/01/2016 YvonneTupper- Mobile Uploads ) Facebook

QSiy. U|.

Mobile UploadsBacK ic AiDun- Yvonne s pholos Yvonne's Ttmelme

Yvonne TupperWe are Still Here)!

Minus 20 with windchlll Ariene tjrneO up tne neat!

Expecting more relations coming today and more cool walks In bushes and trails.Ofcourse, untimely visits from BC Hydro reps.

' " Jsnusry

Daniel Gallant. Brenda Hills Maisey, Sorene Kampen and 6 others like this.

ji.'.j,; n-c ingpe:. in •^:raoii6r vs." r.ssE-v.".'r.?

Previous Next

Album, MoDiifc Uploads

Shaded wit' Public

Open Ptiolc Viewer

Dnwnioac

Embed Posi

Signup Log ir Messenger Facebook Lite Mobile

Games Locations About Create. Advert Create Page

Terms Help

Find Frterds Badges People Pages Places

Developers Careers Privacy Cookies AdChoices

Facebook 2016

Ergiisf: "JKi

This Is Exhibit referred lo in the

affidavit of

mad© before meonthis

day of lcuW.Z>rfM 20 it^^r..2r:=

ACommissioner for takingAffidavits for British Columbia

https://vAVw.facebook.com/photo.php?fbid=10l5377616058l)63B&set=a.10150102B47595638.310635.665415637&typ6=3&theater

119

I OQ In

1/1

Page 134: BC Hydro Site C injunction: Affidavit #1 of Patrick Hayes

1

H'

n

12019/01/2016 Treaty 8 Stewards Of The Land

- "5 i!;

''etr "If 'i-'sgec ti- Fcijr.nef password''

12 Treaty 8 Stewards Of The Land

Pjpii: Mosian t'v vv'oaiie 'upp6

IS January 3! 00 006 deys age

Rctck\ Uou'Hsiri F'ud CaTic,

Be Idle No More! Our Rivers needs us now! Save our Water ways! Protectour land, animals, agriculture, air and fowl, environment. 40 years ofprotesting done and 40 more years to go until this mega Dam project isceased forever.

Many supporters opposing Site C: locally, regionally, provinclally, nationswide, internationally and world-wide. Please continue to morel

Our Grand Chief Phillips stated he wifl join the camp and gladly bearrested to Stop Site C.David Suzuki long time protestor opposing Site C stated Treaty Rights isput to the test and willwin this battle- we must all join together)West Moberly Lake Chief Roland Wilson this nol-so-clean-mega dam isnot needed. Ken and Arlene BOON-PVEA Landowners opposed Site Cwhole heartedly, o farmlands are needed.

Call out to all peaceful protesters with Drums, notsemakers. signsopposing Site C Dam are needed at either side of Peace River on Crownland.

Why:BC Hydro continuing to assault Treaty 8 iand-rights-and environmentallaws without prior consent and Both Federal and BC Supreme CourtCases pending and in processions.An violent insult and assault to land, animals, and Treaty 8 to not ceaseconstruction until all court cases are finalized.

This power is not neededAn International assault as well. West Moberly Lake Chief: Roland Wilson-this nol-so-clean-mega dam is no! needed. There are many energyalternatives with less environmental destruction and less costs to buildwith more long term emptoyment.BRFN Chief Marvin Yahey: Site C Dam was last straw-thls dam destroysanimals migration and violates our Treaty rights and gravely effects ourlivelihoods.

PRFN Lynette Tsakoza: we need to think abou! the prophecies and ourgrandchildren. What are we leaving behind?"Too much oil and gas, we couldn't celebrate my grandson's kill of his firstmoose" This has to end, Late Coundl Kelvin Davis- Doig River FirstNations.

lTttps;//wv/w,facet)Ook.com/events/1501364853502402/

Going

This Is Exhibit ...(liUL... referred to in the

affidavit of ...

20 .1^.

made before me on this

day of

A Commissioner for takingAffidavits for British Columbia

1/45

Page 135: BC Hydro Site C injunction: Affidavit #1 of Patrick Hayes

il

19/01/2016 Treaty 8 Stewards Of The Land

Other first nations leaders slated publiciy or on fb posts opposing Site C.

Hudson Hope Mayor Gwen Johnson is opposed of the construction anddestruction. Other leaders from Fort St John, Hudson Hope, Tayior,Dawson Creek and Chetwynd oppose Site C

•Spiritual iaws were broken by BC hydro by removing and destroyingEagie's nests and Beaver Dams. And disrupting animal's game trails andbirthing grounds. Historical and ancestral landmarks are ear marked newfor massive destruction.

'Celebrate our Rivers that provided many of us lives and continues toprovide life by joining one or ail of our peaceful protests.Starting this weekend-camping on South Side of Peace River- whereMoberiy River meets at Historical Site- Rocky Mountain Fort Camp. Cabinand canvas tent available. Dress warm.

North side-Lookout available for peaceful protesters opposing Site C-lookoul Shack and outhouse

' signs, peaceful protests anytime and any place! Social media -share fbposts and pictures-continue. Email, tweet, telephone, text!Update with current information.•January until dam's construction ceases forever*40 years of protests done and we will protest another 40 years until itceases completely! NO Site C!

Verens Hofmann snarec Christ\' Jordan-Fenton's video

Donate to the Rocky Mtn. Camp Go Fund Me Page:

https:/.'www. gofundme.com/s6c4s4vs

htips://wv\'w.facebook.com/ChnstyJordanFenlon/videDs/" 015383130947'

462/

OC:Ct<

j Christy Jordan-Fenton aaded s nev, video' : Jeriusr; ai •' 3"

c'v-^. tv.-- Cnyir.c; £ .. tr t'liosi iicalvE Hjun'T

ic.'Ke vi'r.f i t-ik.? fyniK fgri ;iete'ni|r.siir,i. ar.d

: i' £' i e.-.r cty •.-•u ii-'cc. ii v iii

Share

Helen KnoU, Mukws Nbisiing Deanna Dean and 3 others like this.

Deanna Dean District 6 lot. it's good to keep a sense of humour In trying

times, and It's also a good analogy

Thank you for the giggle and there with you m spirit.

Lil:e nrs

Carol Linnitt

"To me that feels like pestering and harassment and it doesn't feel liketrying to find workable solutions as we're hearing in the media quoted by

BC Hydro.'"

https://www.facebook.eom/events/1501364853502402/

121

2/45

Page 136: BC Hydro Site C injunction: Affidavit #1 of Patrick Hayes

n

19/01/2015 Yvonne Tupper - Photos from Yvonne Tufa's post in Treaty... i Facefaoc^

Sign up

•_J Kesc :rifclocgeo ir -v'gctle: vDa? r-6£5worr"

Photos from Yvonne Tupper's post in Treaty 8 Stewards Of The Land

Back ID Album

Yvonne Tupper Treaty 6 Steward! Of The Land

' 3 January

Jille ViAiiiebear, Rita Neighbor. Suzanne Raspberrye and i C others lilce this.

' share

aJllle Whltebear #K&epthepesc6Like 2C nou'E 30C

From Photos from Vvonne

Tupper's post in T'-ealy SStewards Of""he uand

Sharen with Public

Open Pholc Viewer

Download

Sign Up Log In Messenger Fscebook Lite Mobile "ind Fnends Badges People Pages Places

Games LocaUons AdouI Create Aavert Create Page Deveiapers Careers Privacy Cocifnes AdChoices

Terms Help

Facebook &2016

English (UK;

This is Exhibit referred to in theaffidavit ofmade before me on thiaday of J,i

'"T--20 ..Ik,

ACommissioner for takingAffidavits for British Columbia

https;//www.facebook.com/phQto.php?fbid=10153768625705638&set=gm.1504904956481725&typB=3&thea{er

122

1/1

Page 137: BC Hydro Site C injunction: Affidavit #1 of Patrick Hayes

18/01/2016 Treaty 8Stewards ofBie Land setout... - ROCKY MOUNTAIN FORT CAMP, BC. Treaty 8Territory, Jan.18,2016123

GiBiPRINTTHIS

Treaty 8 Stewards of the Land set out conditionsto protect lands

TMs la EAim

aMWavSol

auKlebaloMiMmmiMww^imiKwwiw(toy d w M

A Centmf88loii8f tor takingAmdavita tor Britisli Cotumhla

Peaceful camp occupancy continues at Site C dam construction site

ROCKY MOUNTAIN FORT CAMP, BC,Treaty 8 Territory, Jan. 18,2016/CNW/ - FirstNationmembers today called onthe Canadian and British Columbian governments to embrace a three-point planthat will protect lands at imminent threat ofdestruction aspreparatory work continues tobuild the Site Cdam.

"As Treaty SStewards oftheLand, wehave been camped outatRocky Mountain Fort for many days inaccordance withour beliefthat the SiteC dam project represents a direct, and uimecessary threat to thetraditional lands of Treaty 8 peoples," saidYvonne Tupper. "We callon Prime Minister Trudeau and

^ Premier Christy Clark to work with us to ensme that these lands areprotected by temporarily suspendingapprovals to log forests, build roads, and clear further lands inpreparation for dam construction."

^ The three-point plan calls for:

• A temporary suspension ofallconstruction and land-clearing operations related tothe Site Cdamrn project until court challenges initiated by First Nations and local landowners who are opposed to

the project are finally determined,• The federal government to temporarily suspend all federal Site C dam project approvals and the

PI issuance ofany ftiture permits pending an expedited, open and transparent federal review oftheinfringement of Constitutionally protected Treaty 8 rights by the Site C dam.

• The provincial government totemporarily suspend allconstruction work at the Site Cdam sitef-? pending anindependent review bythe BC Utilities Commission of the Site Cdam project, with full

procedural safeguards, as recommended bythe federal/provincial Joint Review Panel and manyothers.

PI

Today's release of the three-point protection plan marks the 20^^ day that Treaty 8First Nation StewardsofLand, joined by local landowners and supporters from across British Columbia, have been camped atthe historic Rocky Mountain Fort site. The camp stands a short distance from where the Moberly Rivermeets the Peace River, just up-river from the proposed Site Cdam site. The dam, ifbuilt, would flood107 kilometres ofriver valley lands along the Peace River and its tributaries and lead for example to thepermanent loss ofnumerous First Nation burial grounds, other culturally and historically important sites,

httpY/www.[M-inttNs,clickabiiity.com/pt/q)l?expire=atitle=Treaty+B+Stewards+of+flie+Land+set+oirL..+~+ROCKY+MOUNTAIN+FORT+CAMP%2C+BC%Z.. 1/3

Page 138: BC Hydro Site C injunction: Affidavit #1 of Patrick Hayes

n

12410/01/2016 Treaty 8Stewards ofthe Land setout... -- ROCKY MOUNTAIN FORT CAMP. BC, Treaty 8Territory, Jan.18,2016

and valuable farmland.

Historically andstill today, the Peace River has been theentranceway to vastbountiful lands andwaters,as well as being the foothold thathas welcomed andprovided formany different groups of people andenterprises.

There are two significant events that explain why we are united andwith peaceful intent to protect andcare for the Peace RiverValley. First, along these waters and islands of the Peace River, battling Beaver(also known as the Dane-zaa) and Cree agreed to a truce so that theirfuture generations couldco-existand be sustained by the landandwaterin perpetuity. Secondly, the signing of theTreaty in thePeaceRiver Valley between First Nations andtheCrown promised thatwewould live a peaceful shared coexistence. Also, FirstNations wereguaranteed to be ableto always pursue theirusual vocations prior toentering into Treaty and without forced interference.

There areother examples ofpeaceful relationships with First Nations: explorers were guided into newplaces; fur traders were taught ways to survive and prospered; gold seekers passed through freely; and,pioneer families established fanning homesteads.

These longstanding relationships andthe solemn promises of Treaty arewhatguide us and it is in thatspirit thatwearehere today at theRocky Mountain Fort Camp anditssurroundings onthesouth banks ofthe Peace RiverValley. We, the Treaty 8 Stewards oftheLand and our supporters, aredirectdescendants of the people whowerethe first inhabitants, Treaty signatories, andlater, settlers of thePeace River Valley.

We are reasonable, responsible, andlaw abiding citizens. Weare mothers, youth, Elders, farmers,bushmen, business owners, teachers and artists. Our supportis not only local but nation-wide. We arerespectful andhave no intent to be involved in any occurrences that would be unsafe or harmful to eitherhumans and property.

"Wecontinueto be involved in thepeaceful, lawful exercise of our TreatyRights to protectthe land andhighlight our concerns about the irreversible, negative impacts that thisproject will have on the PeaceRiver Valley and on the exerciseof our constitutionally protected Treaty 8 rights," said Art Napoleon.

"Wewant a binding commitment from the federal andprovincial governments thatthey will honor,respect and take into proper consideration thefindings and recommendations emanating from the abovethree action items. Once the three actions are completed, then the govemments can decidewhetheror notto lift the suspension on SiteC's construction or to makethe suspension permanent," said HelenKnott.

The Treaty 8 Stewards oftheLandcontacted internationally respected energy expert Robert McCulloughto askwhether or nota temporary suspension of construction of the SiteC Damwould be costly to BCtaxpayers and hydro ratepayers.

Robert McCullough replied,

"The short answer is no. Thefederal/provincial Site CJointReview PanelfoundthatSite C is being builtbefore it is needed andso the relatively high cost Site Cpower will beexported at a lossfor thefirstfouryearsofoperation. BCHydro is likely to lose 50cents on every dollar ofSite Cpower exported duringthefirstfouryears ofoperation. This amounts toa loss ofhundreds ofmillions ofdollars, which is likelyto more than offset thecosts associated with temporarily suspending Site C Construction.

Ironically, BC Hydro isconcerned about delay while regional bulkpower electricprices arefalling totheir lowest levels in history. The U.S. Energy Information Administration annual on-peak averageprice

http://www.prtntthis.cilckability.com/pt/cpt?expjre=&titie=Trealy+8+Stewards+cf+«Te+Land+set+oirt...+-+ROCKY+MOUNTAIN+FORT+CAMF/o2C+BG%2... 2/3

Page 139: BC Hydro Site C injunction: Affidavit #1 of Patrick Hayes

12518/01/2016 Treaty8 Stewards ofthe Land set out... -- ROCKY MOUNTAIN FORTCAMP. BC,Treaty8 Territory, Jan. 18.2016

for our region hasfallen tojust 41% ofits levelssince 2007. Currentprices —andforwardpricesthrough 2025 —are approximately halfthe price ofSite C."

This information demonstrates the economic folly of Site C. Clearly the Treaty SStewards ofthe Landand their supporters are acting in the best interests of all British Columbians.

SOURCE Treaty 8 Stewards of the Land

For further information: Helen Knott, Treaty 8 Steward of the Land at (250) 280-2277; Art Napoleon,n Treaty 8 Steward ofthe Land at (250) 818-5626;Yvonne Tupper, Treaty 8 Steward of the Land at (250)

874 0079; On Cost of Delay: Robert McCullough, McCullough Research, at (503) 784-3758

m Organization Profile

Treaty 8 Stewards of the Land

• First Nations Prepai-e for Arrest to Stop Site C Dam

f-! More on this organization

Find this article at:http://www.newswire.ca/news-rel0ases/treaty-8-stewards-of-the-land-set-out-conditions-to-protect-lands-56S628881.html

U Check the tx)x to hckjde the listof iinks referenced inthe article.

http-7/www.printthis.dick^lity.com/pt/cpt?explre=&title=Treaty+8+Stewarcfe+of+the+Land+set+out...+—+R0CKY+M0UNTAIN+F0RT+C/\MP%2C+BC%2... 3/3

Page 140: BC Hydro Site C injunction: Affidavit #1 of Patrick Hayes

12621/01/2016 Helen Knott on Inslagram;'Love this shot, was soblessedthisweekend with an abundance ofvisitors to the Rocky Mountain Fort Campand goodvibes.

This Is Exhibit ...M...., referred to In theaffidavit of

/dHSesci- Gettheapp Loginmade before me on this ^

day of 20 ..ih.

helenknottOB

15 likes

A Commissioner for takingAffidavits for British Columbia

TOEATY8„territorymum. FORTmnrffiBntieiee

NOStTECSAM

FOLLOW

htlps://www.instagrarn.com/p/BAugszDqQZu/?fb_actia'i_ids=10153169703341627&fb_actiori_types=instaK)%3Atake&fb_ref=ogexp&fb_source=olhK'_mulli[ine... 1/2

Page 141: BC Hydro Site C injunction: Affidavit #1 of Patrick Hayes

12721/01/2016 Helen Knott on Instagram:"Lovethis shoLwas so blessed this weekend withan abundance ofvisitors to the Rocky Moiffitain Fort Camp and goodvibes...

heienknottOS Love this shot, was so blessed this weekend with an abundance of visitors to the RockyMountain Fort Camp and good vibes. We are everyday people saying NO to BC Hydro. #keepthepeace#rockymountalnfort #nositec

V.oSk'

Log in to like or comment.

ABOUT US SUPPORT SLOG PRESS API JOBS

PRIVACY TERMS LANGUAGE

vt' 2016 INSTAGRAM

httpsJA«ww.instagram,com/p/BAugszDqQZu/?ft)_actiDnJds=10153169703341627&ft)_actionJypes=instapp%3Alake&fb_re^og8xp&ft)_source=olher_mijlliline... 2/2

Page 142: BC Hydro Site C injunction: Affidavit #1 of Patrick Hayes

22/01/2016 Rache! Blatt - Here ts howBCHydro does theirjob.They...

i iTiaii or f iioiie -ass'.vorti

Sign Up

Q Keep melogged In Forgotten your paseword?

Here is how BC Hydrodoes their job. They hire a guy withan Aussieaccent (another "80" employee) to come onto your property repeatedlyharrass you and then serve a family member with papers meant for you,to let you know that having a freezer outside of your garage, that peoplewho wish to feed Treaty 8 members, by leaving food inside and takingfrom as needed, Is an offense to be Sued for. Wow. Oh and also grantingpermission for individuals to access an undeveloped public access roadthat runs on your property, that BC Hydro landed a chopper on the samespot, (without asking permission) FYIthe papers are lyingsomewhere onthe ground outside, Iwas told 3 days ago what Bullshit was in the papers.

Seriously Oh and Hydro troll that trolls this site Fuck You creepy Bastardsthis will NOT stop people protesting this project.

From our homes we will not run.

6 Likes 3 Comments 2 Shares

Yvonne Tupper. Aaron Deborah Krafozyk,Sassy Hardtand 3 others like this.

2 sliares

Ktrsten Pedorson wow Ihey just keep getting lower and lower with theirmoral. Pigs.

1 hr

Helen Knott They served me outside of your house lol

1 hr

Lorraine Ward Apparently there's a whole separate set of laws for thatcorrupt utility.Sending you strength -1 don't know how you stand IL

2 • 1 hr

m Rachel Blatt thanks. IsSII have NOT been served he chucked thepapers In the yard somewhere? Myhusband does not work for Hydro.

1 hr • Edited

Lorralno Ward Times like this Imiss my grandpa, who would havemet anyone with a rifle IfIhey came on the property unannounced.

33 mins

English (UK) • Privacy • Terms • Cookies •Advertising • AdCholces • More

Facebook®2016

This Is Exhibit

aBidavlt 01

madebefore m© on this

day of..,......2li=:..2^b==r.

ACommissioner for takingAffidavits for British Columbia

https://Www.facebock.com/peaGeequestrian.park/posts/974780455943732?pnref=stciry

128

Log III

1/1

Page 143: BC Hydro Site C injunction: Affidavit #1 of Patrick Hayes

I.I

11

1:

11.

No

.S

-I6

04

88

Van

couv

erR

egis

try

INT

HE

SU

PR

EM

EC

OU

RT

OF

BR

ITIS

HC

OL

UM

BIA

BE

TW

EE

N:

BR

ITIS

HC

OL

UM

BIA

HY

DR

OA

ND

PO

WE

RA

UT

HO

RIT

Y

AN

D;

PL

AIN

TIF

F

KE

NB

OO

N.

AR

LE

NE

BO

ON

,V

ER

EN

AH

OF

MA

NN

,E

ST

HE

RP

ED

ER

SE

Nal

sok

no

wn

asR

ache

lB

latt,

HE

LE

NK

NO

TT

,Y

VO

NN

ET

UP

PE

R,

JAN

ED

OE

,JO

HN

DO

Ean

dal

lo

ther

pers

ons

unkn

own

toth

ePl

aint

iff

occu

pyin

g,ob

stru

ctin

g,bl

ocki

ng,

phys

ical

lyim

pedi

ngor

dela

ying

acce

ss,a

tor

inth

evi

cini

tyo

fthe

area

inan

dar

ou

nd

the

sou

thb

ank

of

the

Pea

ceR

iver

upst

ream

(wes

t)o

fth

eM

ober

lyR

iver

,in

clud

ing

the

area

inan

dar

ound

the

heri

tage

site

know

nas

Roc

kyM

ount

ain

Fort

DE

FE

ND

AN

TS

AF

FID

AV

IT

FA

SK

EN

MA

RT

INE

AU

Du

MO

UL

INL

LP

Bar

rist

ers

an

dS

oli

cito

rs2

90

0-

55

0B

urr

ard

Str

eet

Van

couv

er,

BC

,V

6CO

AS

+I

60

46

31

31

31

Co

un

sel:

Ch

arl

es

F.

Wil

lms

Matt

er

No

:2

40

15

0.0

01

63

240I

S0.

00I4

2/90

6182

63.4

|0 10