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Court File No. CV-14-513961 ONTARIO Court File No. CV-14-513961 ONTARIO SUPERIOR COURT OF JUSTICE BETWEEN: THE COUNCIL OF CANADIANS, THE CANADIAN FEDERATION OF STUDENTS, JESSICA McCORMICK, PEGGY WALSH CRAIG, and SANDRA McEWING Applicants -and- HER MAJESTY IN RIGHT OF CANADA AS REPRESENTED BY THE ATTORNEY GENERAL OF CANADA Respondents APPLICANTS' APPLICATION RECORD- VOLUME 6 SACK GOLDBLATT MITCHELL LLP Barristers and Solicitors 20 Dundas Street West, Suite 1100 Toronto, ON M5G 2G8 Steven Shrybman (LSUC No. 20774B) tel: 613-858-6842 fax: 416-591-7333 Solicitors for the Applicants -2- TO: THIS HONOURABLE COURT ANDTO: ATTORNEYGENERALOFCANADA Suite 3400, Exchange Tower 13 0 King Street West Box 36, First Canadian Place Toronto, ON M5X 1K6 Christine Mohr tel: 416-973-0942 fax: 416-973-3004 Solicitor for the Respondents INDEX TO APPLICATION RECORD Tab Page VOLUME 1 1. Amended Notice of Application ............................................................................... 1 - 27 2. Notice of Constitutional Question .......................................................................... 28 - 66 3. Affidavit of Jessica McCormick swom November 26, 2014 ................................. 67- 93 A Exhibit 1 Estimation of Voter Tumout by Age Group and Gender at the 2011 Federal Gender Election, April2012 ......................... 94- 110 B Exhibit 2 National Y outh Survey Report, September 20, 20 Il ................ .111 - 17 5 C Exhibit 3 Who Participates? A Closer Look at the Results of the National Youth Survey, June 28, 2013 ...................................... .176- 206 D Exhibit 4 Generational Change: Loo king at Declining Voter Y outh Tumout over Time, November 30, 2013 ................................... .207- 215 E Exhibit 5 CUSC 2013 First-Year University Student Survey, June 2013 .................................................................................... 216- 284 F Exhibit 6 CUSC 2012 Survey ofGraduating Undergraduate Students, June 2012 .................................................................... 285- 386 VOLUME2 G Exhibit 7 Survey ofElectors Following the 41st General Election, October 2011 ............................................................................... 387- 477 H Exhibit 8 Report on the Evaluations on the 41st General Election of May 2, 2011 ............................................................................ 478- 534 I Exhibit 9 Survey of Administrators Regarding the Use of the VIC, October 2011 ............................................................................... 535- 560 J Exhibit 10 Evaluations of the 40th General Election ofOctober 14,2008 .................................................................... 561- 602 K Exhibit Il Election Imperfection: Problems encountered by the student electorate, Dalhousie Student Union, 2008 .................... 603- 612 -2- (Tab 3 -Affidavit of Jessica McCormick- continued) L Exhibit 12 Report of the Chief Electoral Officer of Canada on the 41st General Election of May 2, 2011 ......................................... 613- 676 M Exhibit 13 Proceedings ofthe Standing Senate Committee on Legal and Constitutional Affairs, April 8, 2014 .......................... 677 -707 N Exhibit 14 Excerpt from Elections Canada website September 16-23 Blog by Jessica McCormick ....................................................... 708 -709 0 Exhibit 15 Elections Canada Strategie Plan 2008-2013 ............................... 710 -729 P Exhibit 16 Office of the Chief Electoral Officer Report on Plans and Priorities 2014-15 ................................................................. 730 -770 Q Exhibit 17 Elections Canada Service Standards for Ensuring Accessible Registration and Voting Processes for Student Electors .......................................................................... 771 -784 VOLUME3 R Exhibit 18 Elections Canada Guide for Community Relations Officers ....................................................................................... 785 - 827 S Exhibit 19 Online Survey of Associations Prepared for Elections Canada, January 2009 ................................................................. 828- 863 T Exhibit 20 Survey of electors following the 40th General Election, March 2009 ................................ ·................................................. 864- 974 U Exhibit 21 Local Outreach in the 41st General Election Key Learnings Report, November 14, 2011 ....................................... 975- 992 V Exhibit 22 Transcript of Proceedings - Procedure and Bouse Affairs Committee, April 7, 2014 ........................................................ 993- 1029 W Exhibit 23 Transcript ofProceedings- Procedure and Bouse Affairs Committee, March 6, 2014 .................................................... 1030- 1080 X Exhibit 24 Transcript ofProceedings- Procedure and Bouse Affairs Committee, April8, 2014 ...................................................... 1081- 1118 Y Exhibit 25 Transcript of Proceedings - Procedure and Bouse Affairs Committee, March 25, 2014 .................................................. 1119 -1152 - 3- (Tab 3 -Affidavit of Jessica McCormick- continued) z Exhibit 26 Elections Canada Quarterly Financial Report 2014-2015 For the quarter ended June 30, 2014 ....................................... 1153 -1159 AA Exhibit 27 Elections Canada's Proposed Amendments to Bill C-23 as of April 8, 2014 .................................................................. 1160- 1173 VOLUME4 4. Affidavit of Sandra McEwing swom January 7, 2015 ................................... 1175- 1178 A Exhibit A Affidavit of Sandra McEwing swom April 16, 2012 Federal Court file No. T -619-12 ............................................ .1179- 1181 5. Affidavit of Peggy Walsh Craig swom October 29, 2014 .............................. 1183 -1188 A Exhibit 1 Reasons for Judgment and Judgment released on May 23, 2013- Federal Court file Nos. T-619-12, T-620-12, T-621-12, T-633-12, T-634-12, T-635-12 ............. 1189 -1287 B Exhibit 2 Affidavit of Peggy Walsh Craig swom April14, 2012- Federal Court file No. T-633-12 ................................ 1288- 1291 C Exhibit 3 Matthews Production Order dated June 8, 2011 .................... .1292- 1313 D Exhibit 4 Dickson Information to Obtain a Production Order November 2012 ....................................................................... 1314- 1345 E Exhibit 5 Chief Electoral Officer's statement dated March 15, 2012 ... .1346- 1347 F Exhibit 6 Chief Electoral Officer's Report to Standing Committee On Procedure and Bouse Affairs, March 29, 2012 ................ 1348 -1391 G Exhibit 7 Preventing Deceptive Communications with Electors C.E.O. Report issued March 26, 2013 ................................... .1392 -1409 VOLUMES 6. Affidavit of Harry Neufeld swom December 30, 2014 ................................. .1411- 1423 A ExhibitA Harry Neufeld Curriculum Vitae ............................................ 1424 -1428 B Exhibit B Compliance Review - Interim Report ................................... 14 29 - 15 04 - 4- (Tab 6 -Affidavit of Harry Neufeld- continued) C Exhibit C Compliance Review- Final Report and Recommendations ............................................................ 1505 -1581 D Exhibit D Transcript of Proceedings - Standing Committee on Procedure and Bouse Affairs, March 27, 2014 ...................... .1582 -1592 E Exhibit E Senate Legal and Constitutional Affairs Committee Proceedings report of April8- 10, 2014 ............................... .1593- 1614 7. Affidavit of Harry Neufeld swom January 8, 2015 ....................................... .1616- 1618 8. Affidavit of François Gélineau swom January 14, 2015 ............................... .1619 -1627 A Exhibit A François Gélineau Curriculum Vitae ..................................... .1628 -1639 B Exhibit B Who Participates? A Closer Look at the Results ofthe National Youth Survey, June 28, 2013 ........................ .1640- 1669 C Exhibit C National Youth Survey Report, September 20, 2011 ............................................................... .1670 -1733 D ExhibitD List of Documents Reviewed ................................................. .1734- 1735 VOLUME6 9. Affidavit of Henry Milner swom January 9, 2015 ........................................ .1737- 1753 A ExhibitA Henry Milner Curriculum Vitae .............................................. 1754- 1762 B Exhibit B Letter from leading political scientists in Canada and Intemationally, Globe and Mail, March 19,2014 ................. .1763 -1765 C Exhibit C Youth Electoral Engagement in Canada, January 2011 ........................................................................... 1766 -1791 D Exhibit D Open Letter- statement by leading political scientists In Canada, April2014 ............................................................. 1792- 1822 10. Affidavit ofDavid C. Eider swom January 12,2015 .................................... .1824 -1849 A ExhibitA David C. Eider Curriculum Vitae .......................................... .1850- 1853 B Exhibit B List of Documents Consulted .................................................. 1854 - 1857 - 5- 11. Affidavit of Ilona Dougherty swom January 8, 2015 ..................................... 1859- 1876 A ExhibitA Ilona Dougherty Curriculum Vitae ......................................... 1877- 1882 B Exhibit B Implementation of the Identification Requirements in the Canadian North Final Report, October 7, 2008 ............ 1883- 1914 C Exhibit C Youth Engagement and Mobilization in the 2010 Toronto
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