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R. Ford - 110 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 445. 444. 443. BY MR. RUBY: 442. Q. A. Q. Why? What financial records would I have? Any record of amounts received, BY MR. RUBY: 441. records? MR. LENCZNER: He didn't destroy them. Q. Why did you destroy the financial 440. MR. RUBY: referring to. Thank you. That's what I was

He discarded them, some of his documents.

amounts expended. A. I don't control that. That's the

Toronto Community Foundation. information. Q. A. those records. Q.

They have all that

So there were no records? The Toronto Community Foundation had

If what she has there is accurate

and they were discarded, you must have had them at some point. A. I can ask the Toronto Community

R. Ford - 111 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 448. office. 447. 446. Foundation to send me a statement at any time, and ask them how much I gave to the schools, and ask them how much I have in the account, how much has been spent. Q. At paragraph 8 of your affidavit you

state that the football foundation does not have any administrative staff to handle these communications. A. Q. We don't have staff. But the solicitation letters you

sent out had your City Hall office number on them. So any potential donor would have to talk to your staff when they call in. A. No, they don't have my City Hall

Before, many years ago, I had...the

integrity commissioner said I can't use the City Hall letterhead with my councillor or title on it. So I revised all that. information on it. Q. And that was because it was a breach So no, there is no City Hall

of the code of conduct, correct? A. I don't remember why she told me to

change it, but she said, "You can't have your title. You can't have City Hall information on it." revised it, sent it to her. I

She said that was fine.

The envelopes, the return address on the envelopes

R. Ford - 135 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 536. to. Q. A. Page 6 of the material. What is this on? This is on... The report, itself, can BY MR. RUBY: 535. Q. You say: 534. 533. Q. Tell me if you would...take a look

at the report of the commissioner, and tell me whether you agree with the accuracy of it. MR. LENCZNER: question. Don't answer that

We're not taking any issue with We haven't,

what is in these reports.

therefore you can take them as all being accurate. MR. RUBY: Okay.

"...I have to declare a conflict in this..." Explain why that was. A. I have no idea what you're referring


be found at Exhibit O. THE DEPONENT: MR. LENCZNER: Which one is this? It doesn't tell you what

its subject matter is.

R. Ford - 136 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 538. BY MR. RUBY: 537. Q. In terms of the reasons that you THE DEPONENT: I don't know what we are

referring to and what the item is. MR. LENCZNER: This discuss the

issue on the morning radio concerning a real estate transaction proposed by the City for council's approval, and you broadcast a proposed purchase price which was supposed to be confidential. THE DEPONENT: MR. LENCZNER: Okay. The commissioner said

that you shouldn't have said that, and... THE DEPONENT: question? Now, what was your

gave at the time, they were, in part: "...I have to declare a conflict for this..." Do you see that portion? A. Yes, probably because...again, I

don't remember, but probably because Anna or legal told me to do it. Q. You have no memory of the actual

conversation or why you would...

R. Ford - 137 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 543. 542. be true? A. Q. A. How many years ago is this? Two years ago. Okay, yes, I don't remember exactly 541. 540. true? A. I don't recall this. If that's what 539. A. Q. Five years ago, no, I don't. They ask you what is the nature of

your conflict, the speaker asks, and your answer is: "...My conflict is the report is about Councillor Ford, and I cannot vote in favour or against. interest..." Does that reflect accurately your understanding of the application of the conflict of interest rules at that time? A. no to that. Q. Again, I'm not...I can't say yes or I don't know. It might be true; it might not be That's a conflict of

it says, I guess I have no reason not to believe it. Q. A. Well, it's you. I don't recall what I said. I don't How many

even remember what we were talking about. years is this? Q.

This might be true; this might not

R. Ford - 138 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 548. 547. 546. that? A. Q. A. I don't recall this. You don't recall anything? There are so many decisions she I don't recall. 545. recall. Q. And after the speaker said: 544. what happened two years ago. Sorry, the other It was two years

statement I said five years ago. ago. Q.

And then the speaker says:

"...Nobody has ever heard of that before, but if you wish to absent yourself, well, you just did..." Do you remember that happening? A. Not word for word, no, I don't

"...Nobody has ever heard of that before..." were you impelled to ask some questions of your staff of, "Why am I leaving this debate?" A. Q. I don't know. I don't recall this.

"How do I apply it?" anything like

makes, and so many debates. Q.

So you have no memory of anything

happening as a result of this comment by the speaker?

R. Ford - 139 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 555. 554. 553. 552. 551. 550. 549. A. Q. No. Now, you originally received a

letter from the integrity commissioner about the reimbursement issue that we are concerned with on August 31st, 2010, right? A. Q. that letter? A. Q. A. Q. A. I presume you're telling me. It's a question. I guess so, if that's what it says. I just know of no action you took. I don't remember this. I don't That's Exhibit S.

That's what it says. That's what it says, and you ignored

remember all...every event and every day and every time. If that's what it says, I have no reason not

to believe it. Q. You didn't answer the letter? You

didn't do anything in relation to it? A. Q. If that's what it says. It doesn't say that. I'm suggesting

that's what happened. A. That's what you're reading from.

Obviously it says that, so... Q. Take a look at Exhibit S. It's the

only material we have, page 7, and then I suggest to

R. Ford - 140 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 560. before. 559. 558. 557. BY MR. RUBY: 556. Q. Yes, that's the material we're you... MR. LENCZNER: Page 7, yes.

relying on, what happened, and I'm suggesting to you you ignored that letter. A. If that's what it says I did, that's

what...I guess I did. Q. A. What was going through your mind? I don't remember what was going

through my mind. Q. When you get a letter from the

integrity commissioner, that's, you know, a fairly serious matter, would you not agree? A. Q. A. Saying what? Saying repay. I have answered that question

I didn't believe I should have to pay the

3,150 out of my own pocket. Q. I have got it, but it's a fairly Why would you not do anything? Well, he did. He wrote

serious occasion.

MR. LENCZNER: have heard, he wrote to the donors.

R. Ford - 141 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 565. 564. 563. dates. 562. BY MR. RUBY: 561. Q. Did you do anything beyond THE DEPONENT: numerous times. MR. LENCZNER: Yes. I have explained this

eventually write to the donors? A. I wrote to the donors, and again...I

think I have answered this numerous times already. Q. A. When did you write to the donors? I don't recall. I don't recall the

I have given you an answer already. Q. Can I get the date? Yes, it's in here. We looked at it. What was that date? I can't remember what the It's

MR. LENCZNER: in the report. MR. RUBY: MR. LENCZNER: date was. remember.

I think it was...I don't My memory doesn't stretch back He wrote to the donors, got

far enough.

back a letter from the integrity commissioner . MR. RUBY: MS. CHAISSON: October 24, 2011. Great. Can you give me the page

reference, please?

R. Ford - 142 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 BY MR. RUBY: 569. Q. So you don't write that letter for So when you 568. 567. 566. MR. LENCZNER: Yes, it's at...Mayor Ford

wrote to this office, and revealed that he had corresponded to the donors and attached letters. So that's after Exhibit S that He did respond. I just noted that

you were talking about. MR. RUBY: Thank you.

it is indeed one o'clock. MR. LENCZNER: If you have got a few

more minutes, go ahead. MR. RUBY: What I'm going to suggest is

just that I have not got a lot left, and if you can cope with us for a bit longer, we can try and push through and accommodate the mayor. MR. LENCZNER: about 10 minutes? MR. RUBY: I don't want to predict it, Okay. What have you got,

but I think it'll be short. MR. LENCZNER: finish it. All right. Let's just

almost...a little more than a year. get...

R. Ford - 143 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 573. BY MR. RUBY: 572. Q. So more than a year passes. You get 571. 570. MR. LENCZNER: year? MR. RUBY: This is the letter to the What letter for almost a

donors, October 24th, 2011. MR. LENCZNER: Yes, it is some time

before that, because that's when he writes to the integrity commissioner. MR. RUBY: same time. MR. LENCZNER: Okay, about the I think it's probably the

same...well, let's take that, sure.

the first letter from the integrity commissioner August 31, 2010. You didn't do anything? Well, no, wait a minute. I mean, we're not now


I'm going to object.

into, "Well, I didn't write a letter back for a year. that." Therefore, let's examine on

It has got nothing to do with this So I object. And you're instructing him /R

application. MR. RUBY: not to answer? MR. LENCZNER:

I'm instructing him not

R. Ford - 144 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 578. BY MR. RUBY: 577. Q. Six letters, and I suggest to you 576. 575. 574. to answer. MR. RUBY: And with respect to the

second letter dated September 15, 2010, you're doing the same? MR. LENCZNER: MR. RUBY: The same thing. And the third letter he /R

ignored, May 10, 2011, the same instruction? MR. LENCZNER: July 4. Exactly, and June 7 and /R

How is that? That's very helpful.


that you didn't reply because you simply were not going to be pushed around by this integrity commissioner. that true? A. I think that's probably the fifth You were going to ignore her. Is

time you said that, and I disagree. Q. Okay. You couldn't provide proof of

reimbursement to the integrity commissioner or council unless you first paid the amount. true, right? A. Repeat that again. That's

R. Ford - 145 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 582. 581. order? A. How would you challenge the 580. couldn't. Q. Now, you made it clear, I think, 579. Q. You couldn't provide proof of

reimbursement to the integrity commissioner or council unless you first paid the amount, correct? A. I never reimbursed them, so yes, I

that you failed to pay back the $3,150 because you thought it was wrong that council was trying to force you to do that. A. I don't believe I should have to pay

that out of my own pocket. Q. And did you challenge the council's

council's order? Q. Well, a legal challenge. How would you do that? See, Mr. Ruby, you


Why would you do that?

think this down the road, council could bring no action against him. it. He didn't pay Could

Could they initiate a lawsuit?

it...anyway, we don't need to have this debate. The answer is no, they could not.

They have no enforcement mechanism, because of course what they did was beyond their

R. Ford - 146 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 BY MR. RUBY: 587. Q. Now, before you answer this 586. 585. no. Q. And from what your lawyer says, I 584. BY MR. RUBY: 583. Q. You didn't seek judicial review of authority.

the council's order? A. Q. No. Did you consult with staff or a

lawyer about any way of challenging council's order? A. You already asked me that. I said

take it you didn't think you could do anything in terms of a lawsuit challenging the council's order? A. Q. No. Now I have a series of questions

about his relationship with the integrity commissioner, and I suspect you're going to tell me that that's not relevant. MR. LENCZNER: you're right. It's irrelevant, and /R

question, give your lawyer a chance to take a deep breath so he can object if he wants to. Would you

R. Ford - 147 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 BY MR. RUBY: 590. Q. And you had on that occasion a joint BY MR. RUBY: 589. Q. And you lied to a Toronto Sun R. LENCZNER: Don't answer that. /R BY MR. RUBY: 588. Q. You have a criminal record, as I agree with me that you tell lies from time to time, especially when you're caught acting wrongly? that true? Is

For your assistance, I want to focus

first on the Maple Leafs game of April 15, 2006, where he got drunk and lied about being there, and had to apologize for the lie. MR. LENCZNER: go into that. I'm not going to let you /R

understand it, for driving?

reporter about a marijuana charge in Florida. MR. LENCZNER: question. Don't answer that /R

in your back pocket? MR. LENCZNER: Don't answer that

R. Ford - 148 1 2 3 4 5 6 591. question. MR. RUBY: Thank you very much. My /R

friend may have some questions he wants to ask you. MR. LENCZNER: you very much. No. Thank you. Thank