IN THE COURT OF QUEEN'S BENCH OF 4. JUDICIAL DISTRICT OF BETWEEN: , ROB ANDERS and SEAN McKINSLEY Plaintiffs

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GAUNTLET PUBLICATIONS SOCIETY, SHELAGH PEIRCE, ROBERT BARNETSON and CAREY DuGRAY Defendants

AFFIDAVIT

I, ROB ANDERS, of the City of Calgary, in the Province of Alberta, Student, MAKE OATH AND SAY AS FOLLOWS:

1. I am a Plaintiff in these proceedings and have personal knowledge of the facts herein deposed to.

2. On Wednesday, April 7, 1993, between 6:00 and 7:00 o'clock p.m. I was in an office at MacEwan Hall on the . At that time Mr. Arnold Nowicki a reporter with The Gauntlet came in. I asked him if I could help him as he appeared to be looking for somebody. He replied with words to the effect that he was looking for litigants to beat up.

3. He then commenced into addressing me in a very belligerent and aggressive fashion. He continued his conversation indicating that he was upset that we were engaged in a lawsuit against his friend Carey DuGray.

Dt\BNB\LITIGAT\17640 028AAFF.JLB 4. Previous to this incident on April 7, 1993, I had had a conversation with him which started out about matters not related to the within lawsuit. During that conversation Mr. Nowicki became

particularly belligerent and began striking me by slapping me on the shoulder in an annoying and unsettling manner.

5. While I am physically larger than Mr. Nowicki and did not feel that Mr. Nowicki was about to cause me serious bodily harm his actions were unwelcome and disturbing.

6. At the time I believed that Mr. Nowicki was attempting to

physically challenge me and to harass me and to cause me embarrassment solely because I am a Plaintiff in this action and am suing The Gauntlet and members of its staff.

7. I offered Mr. Nowicki the business card of my solicitor and requested that he leave the office.

8. I make this Affidavit in support of an application to add Mr.

Nowicki, as a Defendant to the within action and for an injunction.

SWORN BEFORE ME at the City ) of Calgary, in the Province ) o f A l b e r t a , t h i s $ & > d a y ) of ^4^V<- A.D. 1993. ) ROB ANDERS

A Commissioner for Oaths in and for the Province of Alberta

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