You be the judge Canadian taxpayers - good use of your hard earned dollars?

POSNER & TRACHTENBERG
Barristers, Solicitors & Notaries Public
710-491 Portage Avenue
Winnipeg, MB R3B 2E4
Fax: (204) 944-8878

Gerald S. Posner
Manitoba & Ontario Bars

Murray N. Trachtenberg
B.A., LL.B
Direct Line: (204) 940-9602
e-mail:mtrachtenberg@ptlaw.mb.ca

July 23, 2007
Mr. Terry Belhumeur
P.O.Box 166Gunton, Manitoba R0C 1H0

Mr. Clare L. Pieuk
2 - 371 Des Meurons Street
Winnipeg, Manitoba R2H 2N6
Gentlemen:

Re: MMF et al vs. Terry Belhumeur et al
Queen's Bench File No. CI 05-01-41955
My File No. 2003-20

I acknowledge receipt of an email from Mr. Pieuk dated July 15, 2007 advising that he is available for discovery on Friday, August 31, 2007 between 8:00 a.m. and 11:00 a.m. No response has been received from Mr. Belhumeur.

I will not start an examination at 8:00 a.m. nor will the Court reporter. I am prepared to accommodate and to start at 9:00 a.m. if that suits your schedule.

Please be advised that I expect to be at least one full day with Mr. Pieuk. As such, I would suggest that we start at 9:00 a.m. and go until approximately noon, break for lunch and resume by 1:30 p.m. and proceed through to approximately 5:00 p.m. If the examination is not completed that day, a further time will have to be scheduled.

As for as my examination of Mr. Belhumeur, I expect that it would last approximately one half day. Both examinations cannot be done on the same day.

Each of you is entitled to attend at each other's examination for discovery.

As far as my examination of Mr. Pieuk is concerned, I am available September 4, 5, 6, and 7, 2007. I am also prepared to examine Mr. Belhumeur on one of these days.

May I please here from both of you in the near future with respect to scheduling discoveries for an appropriate amount of time during those days?

Yours truly,
MURRAY N. TRACHTENBERG
MNT/lec
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File No. CI 05-41955

THE QUEEN'S BENCH
WINNIPEG CENTRE

Between:

Manitoba Metis Federation Inc., Anita Campbell, David Chartrand, Elbert Chartrand, Rita Cullen, Richard DeLaronde, Darrel Deslauriers, Jean Desrosiers, William Flett, John Fleury, Laura Hyrich, Julyda Lagimodiere, Joyce Langan, Leah LaPlante, Judy Mayer, Bonnie McIntyre, Rosemarie McPherson, Darryl Montgomery, Marilee Nault, Jack Park, Claire Riddle, and Denise Thomas

Planitiffs

- and -

Terry Belhumeur, Clare L. Pieuk and Vanessa Everton

Defendants
__________________________________________________
AFFIDAVIT OF OF THE PLAINTIFF
MANITOBA METIS FEDERATION INC.
__________________________________________________

POSNER & TRACHTENBERG
Barristers, Solicitors and Notaries Public
Suite 710 - 491 Portage Avenue
Winnipeg, Manitoba
R3B 2E4

MURRAY N. TRACHTENBERG
Phone No. (204) 940-9602
Fax No. (204) 944-8878
File No. 2003-20

I, OLIVER BOULETTE of the City of Winnipeg, in the Province of Manitoba, MAKE OATH AND SAY THAT:

1. I am the Executive Director of Manitoba Metis Inc. and as such I have conducted a diligent search of the Corporation's records and made appropriate inquiries of others to inform myself in order to make this affidavit. This affidavit discloses to the full extrent of my knowledge information and belief, all documents relating to any matter in issue in this action that are or have been in the possession, control or power of the Corporation.

2. I have listed in Schedule A those documents that are in the possession, control or power of the Corporation and that it does not object to producing for inspection.

3. I have listed in Schedule B those document that are or were in the possession, control or power of the Corporation and it objects to producing because it claims they are privileged and I have stated in Schedule B the grounds for each such claim.

4. I have listed in Schedule C those documents that were formerly in the possession, control or power of the Corporation but are no longer in its possession, control or power and I have stated in Schedule C when and how it lost possession or control of or power over them and their present location.

5. The Corproation has never had in its possession, control or power any documents relating to any matter in issue in this action other than those listed in schedules A, B and C.

SWORN BEFORE ME AT the)
City of Winnipeg, in the Province)
of Manitoba, this 6th day of)
July, 2006)

Murray N. Trachtenberg)
A Notary Public in and for the)
Province of Manitoba.)
____________________
OLIVER BOULETTE

CERTIFICATE OF LAWYER

I CERTIFY that I have explained to the deponent Oliver Bopulette the necessity of makig full disclosure of all relevant documents.

July 6th, 2007
____________________
Murray N. Trachtenberg

SCHEDULE A

Documents in the Corporations' possession, control or power that they do not object to producing for inspection.

1. Posting from cybersmokesignals.com dated June 21, 2003 (6 pages);

2. Posting from cybersmokesignals.com dated September 15, 2003 (22 pages);

3. Articles from Grassroots News dated October 22, 2003 (3 pages);

4. Posting from cybersmokesignals.com dated November 11, 2003 (26 pages);

5. Posting from cbersmokesignals.com dated November 12, 2003 (4 pages);

6. Posting from cybersmokesignals.com dated November 21, 2003 (5 pages);

7. Posting from cybersmokesignals.com dated November 25, 2003 (24 pages);

8. Posting from cybersmokesignals.com dated January 21, 2004 (2 pages);

9. Posting from cybersmokesignals.com dated January 22, 2004 (14 pages);

10. posting from cybersmokesignals.com dated January 28, 2004 (2 pages);

11. Posting from cybersmokesignals.com dated January 28, 2004 (3 pages);

12. Posting from cybersmokesignals.com dated January 28, 2004 (3 pages);

13. Posting from cybersmokesignals.com dated January 30, 2004 (5 pages);

14. Posting from cybersmokesignals.com dated January 30, 2004 (7 pages);

15. Posting from cybersmokesignals.com dated February 5, 2004 (3 pages);

16. Posting from cybersmokesignals.com dated February 5, 2004 (11 pages);

17. Posting from Manitoba Metis News dated February 5, 2004 (3 pages);

18. Posting from cybersmokesignals.com dated February 6, 2004 (4 pages);

19. Posting from cybersmokesignals.com dated February 6, 2004 (2 pages);

20. Posting form cybersmokesignals.com dated February 6, 2004 (1 page);

21. Posting from cybersmokesignals.com dated February 7, 2004 (2 pages);

22. Posting from cybersmokesignals.com dated February 9, 2004 (3 pages);

23. Copy of letter form Murray Trachtenberg to Lionel Chartrand dated February 9, 2004 (2 pages);

24. Copy of letter from Murray Trachtenberg to Terry Belhumeur dated February 9, 2004 (2 pages);

25 Posting from cybersmokesignals.com dated February 10, 2004 (2 pages);

26. Posting from metisvoices.com dated February 11, 2004 (6 pages);

27. Posting from cybersmokesignals.com dated March 3, 2004 (1 page);

28. Postig from cybersmokesignals.com dated April 10, 2005 (2 pages);

29. Posting from cybersmokesignals.com dated April 13, 2005 (2 pages);

30. Posting form cybersmokesignals.com dated April 15, 2005 (1 page);

31. Posting from cybersmokesignals.com dated April 15, 2005 (2 pages);

32. Posting from cybersmokesignals.com dated April 16, 2005 (3 pages);

33. Copy of email from Murray Trachtenberg to metis_mom@hotmail.com dated April 18, 2005 with attached copy of posting, from cybersmokesignals.com dated April 16, 2005 (4 pages);

34. Posting from cybersmokesignals.com dated April 18, 2005 (2 pages);

35. Posting from cybersmokesignals.com dated April 25, 2005 (3 pages);

36. Posting form cybersmokesignals.com dated April 26, 2005 (3 pages);

37. Posting from cybersmokesignals.com dated May 5, 2005 (11 pages);

38. Posting from cybersmokesignals.com dated May 16, 2005 (2 pages);

39. Posting from cybersmokesignals.com dated June 17, 2005 (2 pages);

40. Copy of fax form MMF dated June 23, 2005 with attached posting, form cybersmokesignals.com dated May 6, 2005 (4 pages);

41. Posting from cybersmokesignals.com dated July 1, 2005 (2 pages);

42. Posting from cybersmokesignals dated July 25, 2005 (2 pages);

43. Posting from cybersmokesignals.com dated July 26, 2005 (1 page);

44. Copy of fax from Mr. Al Brolly to Murray Trachtenberg dated July 29, 2005 (2 pages);

45. Leter from Jeffrey J. Niederhoffer to Murray Trachtenberg dated July 29, 2005 and enclosures (56 pages);

46. Posting from cybersmokesignals.com dated July 30, 2005 (5 pages);

47. Posting from cybersmokesignals.com dated July 30, 2005 (5 pages);

48. Posting from cybersmokesignals.com dated July 30, 2005 (5 pages);

49. Posting from cybersmokesignals.com dated August 5, 2005 (1 page);

50. Posting from cybersmokesignals.com dated August 11, 2005 (1 page);

51. Posting from cybersmokesignals.com dated August 15, 2005 (3 pages);

52. Posting from cybersmokesignals.com dated August 15, 2005 (2 pages);

53. Posting from cybersmokesignals.com dated August 15, 2005 (3 pages);

54. Posting from cybersmokesignals.com bated August 15, 2005 (2 pages);

55. Posting from cybersmokesignals.com dated August 17, 2005 (6 pages);

56. Posting from cybersmokesignals.com dated August 20, 2005 (2 pages);

57. Posting from cybersmokesignals.com dated August 26, 2005 (2 pages);

58. Posting from cybersmokesignals.com dated August 26, 2005 (2 pages);

59. Posting from cybersmokesignals.com dated August 29, 2005 (32 pages);

60. Posting from cybersmokesignals.com dated August 29, 2005 (2 pages);

61. Posting from cybersmokesignals.com dated August 30, 2005 (3 pages);

62. Posting from cybersmokesignals.com dated August 31, 2005 (2 pages);

63. Posting from cybersmokesignals.com dated August 31, 2005 (2 pages);

64. Posting from cybersmokesignals.com dated September 6, 2005 (2 pages);

65. Posting from cybersmokesignals.com dated September 9, 2005 (2 pages);

66. Posting from cybersmokesignals.com dated September 13, 2005 (4 pages);

67. Posting from cybersmokesignals.com dated September 14, 2005 (2 pages);

68. Posting from cybersmokesignals.com dated September 19, 2005 (7 pages);

69. posting from cybersmokesignals.com dated September 23, 2005 (3 pages);

70. Posting from cybersmokesignals.com dated October 15, 2005 (7 pages);

71. Posting from cybersmokesignals.com dated October 17, 2005 (1 page);

72. Posting from cybersmokesignals.com dated October 24, 2005 (2 pages);

73. Posting from cybersmokesignals.com dated Novermber 11, 2005 (4 pages);

74. Posting from cybersmokesignals.com dated November 15, 2005 (3 pages);

75. Posting from cybersmokesignals.com dated November 15, 2005 (2 pages);

76. Posting from cybersmokesignals.com dated November 16, 2005 (2 pages);

77. Posting from cybersmokesignals.com dated November 28, 2005 (3 pages);

78. Posting from jeffreyniederhoffer.blogspot.com dated November 30, 2005 (3 pages);

79. Positng from cybersmokesignals.com dated November 30, 2005 (3 pages);

80. Posting from freedominion.ca dated November 2005 (2 pages);

81. Posting from pressbox.co.uk dated November 30, 2005 (2 pages);

82. Posting from cybersmokesignals.com dated December 7, 2005 (3 pages);

83. Posting from cybersmokesignals.com dated December 7, 2005 (3 pages);

84. posting from cybersmokesignals.conm dated December 8, 2005 (2 pages);

85. Posting from cybersmokesignals.com dated December 13, 2005 (3 pages);

86. Posting from pressbox.co.uk dated December 14, 2005 (2 pages);

87. Posting from cybersmokesignals.com dated December 23, 2005 (5 pages);

88. Posting from cybersmokesignals.com dated January 4, 2006 2006 (5 pages);

89. Posting from cybersmokesignals.com dated January 5, 2006 (4 pages);

90. Posting from cybersmokesignals.com dated January 17, 2006 (4 pages);

91. Posting from jeffreyniederhoffer.blogspot.com dated January 19, 2006 (3 pages);

92. Posting from cybersmokesignals.com dated January 19, 2006 (2 pages);

93. Article from the Winnipeg Free Press dated January 19, 2006 (1 page);

94. Posting from cybersmokesignals.com dated January 20, 2006 (2 pages);

95. Posting from cybersmokesignals.com dated January 24, 2006 (1 page);

96. Posting from cybersmokesignals.com dated January 26, 2006 (4 pages);

97. Posting from cybersmokesignals.com dated Jauary 28, 2006 (4 pages);

98. Posting from cybersmokesignals.com dated January 30, 2006 (2 pages);

99. Posting from cybersmokesignals.com dated January 31, 2006 (2 pages);

100. Posting from cybersmokesignals.com dated February 11, 2006 (5 pages);

101. Posting from cybersmokesignals.com dated February 12, 2006 (6 pages);

102. Posting from cybersmokesignals.com dated Februiary 14, 2006 (6 pages);

103. Posting from cybersmokesignals.com dated February 15, 2006 (2 pages);

104. Posting from jeffreyniederhoffer.blogspot.com dated February 16, 2006 (2 pages);

105. Posting from cybersmokesignals.com dated February 16, 2006 (3 pages);

106. Posting from jeffreyniederhoffer.blogspot.com dated February 17, 2006 (3 pages);

106. Posting from jeffreyniederhoffer blogspot.com dated February 17, 2006 (3 pages);

107. Posting from derrylsanderson.blogspot.com dated February 17, 2006;

108. Posting from cybersmokesignals.com dated February 17, 2006 (3 pages);

109. Posting from cybersmokesignals.com dated February 21, 2006 (2 pages);

110. Letter from Christian Asselin, Office of the Auditor General of Canada to Murray Trachtenberg dated July 7, 2006 enclosing various documents bundled and labelled as:

MMF Binder Part I
MMF Binder Part II
MMF Binder Part III
Orange folder entitled Pieuk, Clare (Rec'd @ July 4/05) Chartrand Insurance
Orange folder entitled Clare Pieuk - Folder #2 (Copies @ June 10/05)
Yellow Folder entitled "Red Binder" (re Clare Pieuk: copies at June 10/05)
Orange folder entitled Clare Pieuk - Folder #1 (Copies @ June 10/05)

111. Letter to MMF Inc. President David Chartrand signed by Vanessa Everton dated November 9, 2006);

112. Posting from cybersmokeblog.blogspot.com dated May 13, 2007 (2 pages);

113. Posting from cybersmokesignals.com dated May 13, 2007 (7 pages);

114. Letter from Gordon E. Hannon - Manitoba Justice to Murray Trachtenberg dated June 21, 2007 and enclosures;

115. Pleadings;

116. Routine correspondence with defendants;

117. Routine correspondence between counsel;

118. Box of documents containing bundles of docyuments produced by Mr. Pieuk in May, 2006;

SCHEDULE B

Documents that are or were in the Corporation's possession, control or power they object of producing on the grounds of privilege.

A. Lawyer and client communications

The following groups of documents are in themselves communications between client and lawyers made with a view to receiving advice with respect to the matters at issue in the action or instructing counsel in this action;

1. Correspondence between Posner & Trachtenberg and the plaintiff Manitoba Metis Federation Inc. and individual plaintiffs.

2. Various memoranda prepared by counsel relative to discussions with the plaintiffs.

B. Lawyers' work product or brief

The following groups of documents or douuments were created or obtained by Posner & Trachtenberg to enable them to act for the plaintiffs in this action:

1. File notes of case law or issues of fact or law to consider in this matter

2. File notes prepared by counsel relating to discussions with third parties.

3. Correspondence between Posner & Trachtenberg adn the Office of the Auditor General of Canada.

4. Correspondence between Posner & Trachtenberg and Manitoba Justice.

5 Correspondence between councel on a "without prejudice" basis.

SCHEDULE C

Documents that were formerly in the Corporations' possession control or power but are no longer in their possession, control or power.

Nil