Thursday, January 24, 2008

Government funders, how does this minimum $250/hour taxpayer expenditure help our Manitoba Metis citizens?

WITHOUT PREJUDICE

As a Winnipeg lawyer laughingly remarked upon seeing the original Statement of Claim in 2005 (subsequently revised several times), "This looks like Murray's retirement project."

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

January 23, 2008

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

Dear Mr. Pieuk:

Re: MMF et al vs. Clare L. Pieuk et al
Queen's Bench File No. CI 05-01-41955

MMF will be providing an amended affidavit of documents in the future. At this time, I am providing you with a revised Schedule A and Schedule B which will form part of that affidavit. The following additional documents have been added to Schedule A:

1(a), 55(a), 110(a), 114(a), 119, 120 and 121.

Yours truly,
MURRAY N. TRACHTENBERG
MNT/lec
Encs.

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);

1 (a) Administrative Panel Decision dated June 5, 2001;

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 cybersmokesignals.com dated November 12, 2003 (4 pages);

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

7. Posting from cybersmokesignals.com 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 from 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 (1 page);

23. Copy of letter from 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);

26 (a) Copy of letter from Murray Trachtenberg to Petition Co-ordinator in Duck Bay, Winnipegosis, Camperville and Skownan, Manitoba dated February 24, 2004 (2 pages);

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

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

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

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

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

30. Posting from 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 (4 pages);

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

37. Posting from cybersmokesignals.com dated May 5, 2005 (1 page);

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 from MMF dated June 23, 2005 with attached posting from cybersmokesignals.com dated May 6, 2005 (3 pages);

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

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

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

43 (a) Posting from Manitoba Metis News dated July 28, 2005 (1 page);

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

45. Letter 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 dated August 15, 2005 (2 pages);

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

55 (a) Copy of email from Clare Pieuk to publisher Grassroots News;

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

80. Posting from freedominion.ca dated November 30, 2005 (4 pages);

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

81 (a) Copy of letter from Murray Trachtenberg to Jeffrey J. Niederhoffer - Niederhoffer Law Firm dated December 1, 2005 with attached copy of Press Release dated November 30, 2005 (4 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.com 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 5, 2006 (4 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 January 29, 2006 (3 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 February 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);

107. Posting from derrylsanderson.blogspot.com dated February 17, 2006 (6 pages);

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

109. Posting from cybersmokesignals.com dated February 21, 2006 (3 pages);

110. The Manitoba Metis Federation Board of Directors Report on the Cybersmokesignals.comLawsuit dated February 24, 2006 (13 pages)

109 (b) Posting from cybersmokesignals.com dated March 24, 2006 (3 pages);

109 (c) Posting from cybersmokesignals.com dated March 26, 2006 (3 pages);

109 (d) Letter from Clare L. Pieuk to Murray Trachtenberg dated May 1, 2006 (1 page);

109 (e) Posting from cybersmokeblog.blogspot.com dated May 8, 2006 (1 page);

109 (f) Email from Terry Belhumeur to Murray Trachtenberg dated May 9, 2006 (1 page);

109 (g) Posting from cybersmokeblog.blogspot.com dated May 9, 2006 (1 page);

109 (h) Posting from cybersmokeblog.blogspot.com dated May 13, 2006 (1 page);

109 (i) Posting from cybersmokeblog.blogspot.com dated May 14, 2006 (1 page);

109 (j) Posting from cybersmokeblog.blogspot.com dated May 16, 2006 (5 pages);

109 (k) Posting from cybersmokesignals.com dated May 16, 2006 (3 pages);

109 (l) Posting from cybersmokeblog.blogspot.com dated May 29, 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 @ June 10/05)

Orange folder entitled MMF @ June 21/05 Copies

Orange folder entitled Clare Pieuk - Folder #1 (Copies @ June 10/05)

110 (a) Posting on cybersmokesignals.com dated August 3, 2006 (1 page);

111. Letter to MMF Inc. Persident 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;

114 (a) Posting from cybersmokeblog.blogspot.com dated September 5, 2007 (9 pages);

115. Pleadings;

116. Routine correspondence with defendants;

117. Routine correspondence between counsel;

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

119. Register.com Whois Results search for cybersmokesignals.com;

120. Register.com Whois Results search for cybersmokesignalscanada.com;

121. Register.com Whois Results search for cybersmokesignalsinternational.com;

SCHEDULE B

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

A. Lawyer and client communications

The following groups of documents are in themselves communications between client and lawyer 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 document or documents 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 and the Office of the Auditor General of Canada.

4. Correspondence between Posner & Trachtenberg and Manitoba Justice.

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

6. Without prejudice letter from T. Belhumeur received May 4, 200

Distribution List

bkaternick@mnbc.ca

tonyb@metisnation.org

mdevlin@metis.org

Media

cadler@cjob.com

boris.hrybinsky@freepress.mb.ca

david.kuxhaus@freepress.mb.ca

dan.lett@freepress.mb.ca

carol.sanders@freepress.mb.ca

colleen.simard@freepress.mb.ca

gordon.sinclair@freepress.mb.ca

louise_charette@cbc.ca

terry_macleod@cbc.ca

brendan_o'hallarn@cbc.ca

staff@taiga-communications.com

publisher@grassrootsnews.mb.ca

publisher@thundervoice.ca

theverdict@ctv.ca

stymofichuk@ctv.ca

cblatchford@globeandmail.com

pcheney@globeandmail.com

jibbitson@globeandmail.com

gmason@globeandmail.com

mwente@globeandmail.com

dwalton@globeandmail.com

dmartin@nationalpost.com

pgoodspeed@nationalpost.com

Federal

The Prime Minister (Harper.S@parl.gc.ca)

Minister of Indian And Northern Affairs Canada (Strahl.C@parl.gc.ca)

Minister of Finance (Flaherty.J@parl.gc.ca)

President, Treasury Board of Canada (Toews.V@parl.gc.ca)

Minister of Justice (Nicholson.R@parl.gc.ca)

Rod Bruinooge (Bruinooge.R@parl.gc.ca)

Stephane Dion (Dion.S@parl.gc.ca)

Raymond Simard (Simard.R@parl.gc.ca)

Jack Layton (Layton.J@parl.gc.ca)

Pat Martin (MartiPD@parl.gc.ca)

Auditor General of Canada (petitions@oag-bvg.gc.ca)

Canadian Taxpayers Federation - National (jwilliamson@taxpayer.com)

Provincial

Premier, Manitoba (premier@leg.gov.mb.ca)

Minister of Finance (minfin@leg.gov.mb.ca)

Minister of Justice (minjus@leg.gov.mb.ca)

Auditor General of Manitoba (contact@oag.mb.ca)

Canadian Taxpayers Federation - Manitoba (abatra@shawbiz.ca)

Legal Community

PublicInterest Law Centre - Winnipeg (bwilliams@pilc.mb.ca)

Lionel R. R. Chartrand - Legal Aid Manitoba (licha@legalaid.mb.ca)

abruun@campbellmarr.com

jnieder@shaw.ca

thefirm@fleurcom.on.ca

bamyot@heenan.ca

jgj@aikins.com

wonchulenko@ltgg.ca

The Lawyers Weekly (tlw@lexisnexis.ca)

admin@cba-mb.ca

media@scc-csc.gc.ca

law-droit@scc-csc.gc.ca

harvey_secter@umanitoba.ca

lawdean@osgoode.yorku.ca

cchisick@osgoode.yorku.ca

afineblit@lawsociety.mb.ca

mtrachtenberg@ptlaw.mb.ca

lcoulombe@ptlaw.mb.ca

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