Episode #10
Episode #10: The Securities Commission “Agreement” with CMT and Paul Maines


This is the final part of my three-part “mini-series” on the Securities Commission within my 25-part “Truth and No Consequences” series. The next episode will return to the initial format with shorter pieces on targeted parts of Judge Campbell’s decision.

It’s been an incredible education for me to put this last episode together. It involved having to learn about things like “shell companies and ” convertible debentures.” Stuff I have no background in – and to be honest – not much interest in either. But it was the only way to sort out “what’s what?” in order to understand”who’s who?” in this entire affair.

Learning about the actual investments and how they were structured with the different corporate entities in the transitioning of CMT to become a “local company” is necessary knowledge. That corporate transition process – including raising funds – was all to achieve a certain objective that intimately connected to the business plan CMT/FMT had with the PEI Government. Making sense out of all that also revealed who was (or was not) telling the truth when they publicly denied that they knew Paul Maines or CMT/FMT, or scoffed at the notion that either Maines or CMT had anything to do with the PEI Government.

Since those days, hundreds of PEI Supreme Court documents and official government records have come to light through Access to Information Requests which now expose a number of pretty serious lies and double-standards with the application of Securities laws that support the claim that CMT and Paul were indeed “targeted” for purposes that constitute “malfeasance”.

This episode is the final “plank”in the backstory laying the foundation needed to understand elements of Judge Campbell’s ruling that will be discussed in subsequent episodes. I see it as the “keel” – the longest plank in the boat – upon which everything else is attached and rests.


Setting the Stage for the Settlement Agreement Signing

I mentioned in the last episode that CMT’s lawyer, Mary L. Biggar, had initiated a legal action after the Hearing against Paul Maines and CMT was cancelled. That prompted the PEI Securities Commission to cancel the second scheduled Hearing set for April 22, 2013.
The Superintendent, Katherine Tummons, noted that the reason for the Adjournment was the “Notice of Constitutional Question,” which Maines and CMT had filed with Hon. Janice Sherry, then Attorney General under Robert Ghiz:

Reason for Adjournment of Hearing

Not long after that transpired, the PEI Securities Commission sent a draft “Settlement Agreement” offer with the absolute minimum fines and restrictions, giving CMT and Maines a clear way out of the quagmire in which they had been embroiled with the Securities Commission investigation.

The Settlement Agreement also effectively “excised” Dowling and the PEI Securities Commissioner from the much bigger story that was fast-emerging – a tale of insider designs, corporate sabotage and cover-up; the kinds of issues Van Der Laan and the PEI Securities Commission made abundantly clear they had absolutely no intention of entertaining.

I don’t have the particular document containing the comment that Mr. Van Der Laan made about his “disbelief” of Paul Maine’s sworn Affidavit testimony which he sent to Ms. Biggar; however, I do have a letter dated April 12, 2013 that Biggar sent to Van Der Laan in response, indicating it was government officials that he had refused to allow to be questioned who were the source of the information Maine’s swore :

Biggar on Newco

Signing the Settlement Agreement was a “No Brainer”

I suspect Maines jumped at the chance to settle for three key reasons, and probably many more:

1. CMT and Maines were suffering severe losses that would continue and worsen as long as this dark cloud of suspicion and allegation was hanging over their heads with an active file at the Commission.

The totally-unreasonable blocks erected by the Securities Commission and Dowling denying due legal process; the denial of documents and “sealing” of documentary information and evidence; and the refusal to allow witness testimony from government officials or even cross-examination of Affidavits…all this made it clear there would be a long and costly battle ahead for Maines and CMT to have a full defence against a “cease-trade” order heard fairly at the Securities Commission.

On top of that, Maines and CMT received no cooperation (or even replies) from Wes Sheridan; Kevin Kiley; Gary Scales; Chris LeClair; Mike O’Brien; Cheryl Paynter; and others when they were sent formal requests by Biggar. Furthermore, the issues needing to be addressed were really not “securities” issues from CMT’s and Maine’s perspective.

2. CMT and Maines were presented an incredibly easy way out of a very big mess without having to “admit” any wrongdoing whatsoever. The “statement of facts” and “penalties” noted in agreement all had to do with either an issue of (a) “late filing” of a document with the PEI Securities Commission, which Jessop argued wasn’t necessary under the corporate set-up and national “exemption” granted to CMT for the Debenture Investments Program they set up; (b) an unsettled difference of legal opinion about whether CMT investments were “loans” or “securities,” and (c) an admission that a “prospectus” (apparently a very costly venture) which had not been required with a virtually identical investment (RevTech) was a “violation of the PEI Securities Act.”

Again, although Maines and CMT agreed to these conditions, Jessop made it very clear that it was purely a “business decision” by CMT’s Board of Directors so they could move past a very bad state of affairs for their company created by the investigation. As Robin Dolittle reported in her Globe and Mail article:

CMT’s litigation lawyer, Mary Biggar, said it was a “relatively minor infraction in the context.” Added lawyer Gary Mr. Jessop: “It was a business decision, made at the time, to settle it and move on.”

3. CMT and Maines immediately realized that the draft “Settlement Agreement” unbelievably did not contain a “waiver” preventing either Maines or CMT from initiating a civil litigation case in the PEI Supreme Court. I suspect Dowling would have known that Maines and CMT would not have waived such rights if they were asked, so he didn’t bother putting that in the agreement.

I imagine by May, 2013, Dowling et al. were becoming increasingly aware and concerned that CMT and Paul Maines were not going away, and when they realized they had come to do battle, and given all the alleged skullduggery that was afoot, I suspect they were anxious to cut ties with that litigious ship sailing out to sea: a vessel that already had a school of PEI government officials and agents in the dragnet, one of which was Dowling.

The more that Tummons (the Superintendent) and other staff at the PEI Securities Commission learned about the “big picture” lurking beneath and behind Dowling’s investigation, the more I’m sure they were looking for a way out of any involvement to mitigate backlash on, or damage to the Commission.

At any rate, the Settlement Agreement was the illusive “key” Maines and CMT needed to unlock the millstone hanging around their necks which had caused them such damage during the previous 8 months. Maines and CMT could finally get on with the PEI Supreme Court litigation, in which Dowling and his Securities Investigation against Maines and CMT play a big part.

It’s good to recall at this juncture that no one ever came forward with a complaint against Paul Maines or CMT alleging that investments were solicited except Dowling. No evidence substantiating such allegations were ever provided. Dowling’s Affidavit (the only evidence “relied on” by the Securities Commission) offered sworn testimony alleging solicitation by Maines without any direct knowledge, which Dowling claimed he received from several CMT/Target-Co investors. And those claims were completely refuted by those very same investors in Affidavits sworn solely for the purpose of correcting Dowling’s inaccurate claims about them.

All 36 investors were happy with their investments. Many are still investors, quite upset about what happened to CMT and Paul Maines. They were all fully-aware of what they were doing according to the documentation. They were mostly either sophisticated Island investors, or family and friends of sophisticated investors. The lengthy Subscription Agreement mapped out the exact nature of the investment and the risks involved in great detail, as well as confirmation of the reporting exception granted CMT to raise the money under authority of the National Instrument 45-106.

It’s also clear no investor made a claim against Maines or CMT, because Dowling wouldn’t have had to ask Jessop for a copy of the “Subscription Agreement” if any investors had complained – he’d have their copy. In the spirit of cooperation (no doubt hoping Dowling would reciprocate and finally tell him what was going on, and give him a chance to clear things up) he provided a copy as a ‘courtesy;’ however, stressing that the document was being shared voluntarily and on a strictly “confidential” basis:

Confidential Subscription Agreement.JPG

How did Dowling respond to this gesture of goodwill and cooperation from a corporate lawyer and director of an international company (CMT)? A company that Dowling had so recklessly put under siege? He never responded to Jessop. To add insult to injury, Dowling filed the Securities Agreement in his Affidavit as an “Exhibit” for the whole world to see.

“No Admission of Wrongdoing” With CMT’s Investment

Maines may have been elated at the opportunity to get out from under the Security Commission’s thumb, but his lawyer, Mary L. Biggar made sure the Commissioner knew there would be no admission of having done anything wrong…just legal questions that remained unsettled, a couple of ‘concessions’ with reservations, and some fines/costs.

Accepting the offer was exclusively “for the purposes of settlement,” and her clients were only prepared to admit that the “loan” might fall within the broad definition of a “security” under the PEI Securities Act. In a letter dated April 12, 2013, Biggar wrote to Van Der Laan saying:

Biggar to Van Der Laan

Earlier, in a response to a “production request” from the PEI Securities Commission dated March 21, 2013 (before the second scheduled-hearing was cancelled) Biggar forwarded documentation to Van Der Laan (cc’d to Dowling) making the same important distinction between “lenders” and “shareholders” in her letter:


Target-Co……RevTech……What the Heck?

You may recall that the Auditor General raised a concern about an “investment” that then-chief-of-staff to Ghiz, Chris LeClair, had made in “RevTech” in the summer of 2011. Robin Doolittle’s exposé on e-gaming, “Big Bet Small island: How PEI lost its online gambling gamble,” published in the Globe and Mail in early 2015, mentions LeClair’s investment. What he said is worth revisiting.

LeClair told Doolittle that he and his wife made the investment “…because we heard it [CMT] was a company that could be used for a variety of purposes, including financial services,” adding that: “It was a small sum of money that we invested into a debenture, perhaps mistakenly on our part, without a lot of due diligence. … However, in the event that any investment in any company ever posed a potential conflict of interest to me, we would have forfeited any potential benefit.

The issue with LeClair isn’t just his “conflict of interest” when he made the investment, but also that he engaged in “insider trading.” LeClair was not only “involved” with the gaming file, he was leading that file with Wes Sheridan. When LeClair left government, he kept working on the file. By the Fall of 2012 when the Securities Commission investigation was launched by Dowling, LeClair had already secretly “presented” a new company (which Maines had heard about from Tracey Cutcliffe).

When the main players involved discovered Paul Maines was asking questions about “Newco” they clearly got spooked. It was then decided that Innovation PEI would need to extend the MOU as a sign of good faith with the heat on from Maines. In fact, they were “ready to go with NewCo” when the first 60-day MOU expired, and submitted their plan to Government the very same day. The email chains show they were clearly “waiting” for the MOU to expire, something that was explicitly stated in emails during the time the MOU was still in force.

As LeClair and Sheridan and others looked into the future: the initiative their secret initiative they were all ready to launch was suddenly never going to happen because the 30-day extension provided ample time to conclude the deal with FMT and sign the agreement, and there was no tangible or legitimate reason for Innovation PEI to stop the two-year process and say “no deal” at the 11th hour.

Enter the Securities Investigation initiated by Dowling about a week after the MOU extension was signed. The MOU was subsequently suspended. No Agreement was ever signed.

A lot more of this will be unpacked in future episodes. What is important to understand now is that the investments that Chris LeClair (and lawyer Billy Dow, etc.) made in RevTech were exactly the same kind of investments made by the 36 investors to CMT with Target-Co. RevTech was a “shell company” with no assets other than a stock market listing, so the plan was for CMT to acquire RevTech and use that shell to provide a stock market listing for FMT – the “local presence” for the CMT/Simplex financial transaction hub in PEI.

Why weren’t Chris LeClair and Billy Dow and all the other investors in RevTech investigated by Dowling? If it wasn’t really a “security” (share) but a “debenture” (loan) – as LeClair told Robin Doolittle, why were Maines and CMT dragged before the Commission in an investigation since those investments were exactly the same as those of RevTech investors?

To this day it is not known who invested in RevTech beyond a few people. The Auditor General mentioned RevTech in conjunction with LeClair and Dow’s investments, but there’s never been any annual reportings, or no one knows how much was lost in the venture.

LeClair – one of the people who Biggar wanted to call as a witness at the Securities Hearing – and Billy Dow, did exactly the same thing that the 36 other investors did with “Target-Co”: they invested in a venture by loaning money on the hope that the venture would prosper, so at some point down the road, those “debentures” could be “converted” into shares in the company and everyone would make a ton of money, having come in on the ground floor of a very promising venture at a very low share price.

All 36 Island investors happily invested their money in the “Target-Co” with full knowledge of the risks – which they had to read and acknowledge with their signature in pages of documentation. The vast majority were sophisticated investors, many of whom you’ll probably recognize as prominent PEI business people: see the following list of investors.

Again, why has the PEI Securities Commission never investigated RevTech? Why hasn’t Dow or LeClair or other investors who invested in CMT before RevTech started being called “Target-co”? Some would call it a double-standard, others would call it being “targeted” for very deliberate and unsavoury reasons.

I want to take a look at exactly what was in the Settlement Agreement a little later, as well as what Judge Campbell said about what was in the Agreement. But there’s a far more important “bigger-picture” story to tell first about how the PEI Supreme Court would be the only possible place the issues which Maines and CMT/FMT needed to have addressed could be addressed, and the “settlement agreement” was what made that possible, and this seems like a good place to do it.

The “Big Picture” Story Behind the Settlement Agreement

I’m now convinced there was indeed a very deliberate plan to sabotage Maines and CMT to make room for LeClair and Newco, or possibly other potential clients the PEI government were also in negotiations with at the time, in violation of the MOU (a future episode).

Wes Sheridan could have taken a few minutes to drop by the PEI Securities Commission Office to clear everything up – but he chose not to – and that says a lot about his (and other government agent’s) willingness to deliberately hurt Maines and CMT. This is a pretty serious accusation, so I want to provide the documentary evidence that has led me to draw that conclusion.

How might Sheridan have cleared up any misunderstanding with the Securities Commission’s investigation concerning the money that was being raised for CMT/FMT? He could have told the truth and confirmed what Jessop swore in his Affidavit was indeed true:

CMT Incorporation by Jessop.JPG

Take special note of the words “…for the purpose of having a Canadian entity resident in Prince Edward Island with local management.”

In the last episode I drew attention to how CMT/Simplex and especially Paul Maines had already been working with Innovation PEI to move things forward for nearly two years by the time the investigation was initiated by Dowling in mid-September, 2012. When that investigation commenced not a single person involve with the project, Paul Maines and CMT/FMT/Simplex, including PEI government officials such as Wes Sheridan, would cooperate or even reply to Maines, Jessop or Biggar to vouch for what CMT was doing with the plan to raise funds for a legitimate “government-endorsed” and recommended project. Why not? Why didn’t Sheridan tell the truth and go to bat for CMT/FMT and Paul Maines?

Wes Sheridan definitely could have made the problem disappear for Maines and CMT because what those “Target-co” CMT investors in PEI were doing is exactly what the PEI Government asked CMT/Simplex to do!
In a October 24, 2011 email from Philip Walsh to Brad Mix (copied to Wes Sheridan, Paul Jenkins, Chris LeClair and Neil Stewart) Walsh begins by saying how it was “great to connect on Friday” and went immediately into the need to move quickly to “executive this transaction”. Any such transaction would have been executed with FMT. Besides being Technology Partners with Simplex, CMT also owned 33% of Simplex at that time and had “veto” voting power on the Board.

Walsh 44

Efforts to establish a financial transaction hub in PEI were already well underway on a number of fronts, including the RevTech/Target-co investments aiming to raise funds and establish a “local company” for the CMT/Simplex transaction hub, and the recruitment of “gaming companies” or other clients to PEI by CMT/FMT to support and build the transaction Hub .

Mix reiterated to Walsh that there would need to a “local company” presence. This was first mentioned in a “recruiting package” provided to FMT from Mix in early 2011. That’s another crucial part of the story we’ll get to in a future episode – but for now what’s important to know is that Campbell completely ignored entire sections of CMT/FMT’s Statement of Claim dealing with core issues in the “pre-Mou” period. One of those issues was the recruiting package that guaranteed “first mover advantage” and promised that CMT/Simplex “would thrive” if they came to PEI to establish a financial transaction hub. But as Mix spelled out in a his letter to Walsh concerning “next steps”:

Brad Mix to Philip Walsh - populated locally.JPG

Locally-populated”, “the simpler the better” – that’s exactly what happened with CMT: the newly incorporated company was first called 764 then FMT. The RevTech/Target-Co investments were all raised to help CMT establish FMT in PEI, have FMT listed on the stock exchange, then have CMT’s assets moved into FMT. Dowling and Campbell were both well-informed of this entire strategy from various sources, including from Jessop’s 2013 Affidavit:

CMT Incorporation by JessopIf Mix believed “simpler was better” you can’t get anything less complicated than what CMT did – “Paul Jenkins” became the sole director of FMT in the interim, start-up period, in advance of a permanent Board being established when the corporate transition process was complete.

Jenkins also became the “face of the company” so to speak. Paul Jenkin’s name appears on dozens of documents both to and from Wes Sheridan, Brad Mix, Chris LeClair and many other – everyone knew at the time that Jenkins represented FMT – wholly-owned by CMT, and they were working with Government to lay the groundwork for the transaction hub.

CMT and FMT have always effectively been one and the same in terms of ownership and control, although Campbell doesn’t see it that way in his ruling and treats them as completely separate corporate entities i.e., the MOU was with FMT, which Campbell says has absolutely nothing to do with CMT. Well, he may be technically correct, but who cares if he is? Both companies are named in the lawsuit.

What’s really important to understand is how FMT was part of the CMT/PEI plan to establish this new financial hub, but from the minute the securities investigation started against Maines and CMT – then extending into the future from the time the Settlement Agreement was signed til now – no one in the PEI government apparently knew Paul Maines or CMT.

Despite a long-term, heavily-involved relationship with CMT/FMT & Simplex, Wes Sheridan stood up in the Legislative Assembly on November 21, 2014 and presented Simplex as only having a relationship with the Mi’Kmaq Confederacy. In fact, the contract with Simplex identified “the PEI Government” as the “client. Sheridan also unbelievably denied that there was any connection between CMT and Simplex:

Two of them not mixed.JPG

Robin Dolittle got the same line from him in early 2015:

“In a December interview with The Globe, the finance minister said he had no idea CMT and Simplex were connected. “I to this day do not know that Paul Maines and Philip Walsh had a business relationship. And he wasn’t part of any of our work,” Mr. Sheridan said.”

Sheridan resigned days after the Globe article was published.

I should also point out that the Ontario Securities Commission action was simply a reciprocal Order accepting PEI’s Order, and not a different investigation or matter.

It might be a good time to mention that part of the multi-pronged plan was for CMT/FMT to bring new gaming companies to PEI. Paul Jenkins noted in his Affidavit that Paul Maines had a lot of contacts on Bay Street to help do deals, find shell companies to acquire etc. Maines did in fact secure an agreement with Virgin Gaming to establish in PEI. You may remember that event – there was a big announcement from the PEI Government at the time.

Paul Jenkins, as the “face of FMT in PEI” and sole director had all the connections FMT needed with both business and government, so it was Jenkins who delivered the news to Mix that FMT had secured a tentative agreement from Virgin Gaming to set up in PEI. Jenkins made plans with Brad Mix to have the Virgin Gaming people meet with Ministers Wes Sheridan and Allen Campbell:


Look at the date. June 8, 2011. Notice that Wes Sheridan is being copied on the email from Brad Mix. Paul Maines isn’t mentioned here for good reason – he didn’t involve himself or participate in communications or meetings other than to set them up and put the right people around the table or on the file to keep things moving forward – his work as Business Development V-P was already over with Virgin Gaming, and Jenkins – the local guy with all the government connections – was taking it from there, so to speak.

Sheridan fully understood all of that and much more. Read what Paul Jenkins said in a Voluntary Statement he gave during that period of time between the first Cancelled Hearing and the second Scheduled hearing,

“So from there, we [Garth Jenkins and Paul Jenkins] invested in,the first of September and, you know, we continued on to work with, with Big Paul [Maines] and their group, Philip Walsh and, and Simplex, to introduce the Island opportunity. And that, that resulted in a whole bunch of different things. One was, you know, did, you know, is there, was there an opportunity to recruit businesses to P.E.I.using the P.E.I., kind of, advantages on, you know, innovation and such like that; labour force; et cetera. Another arm of it really was the CMT, the transactions piece, in creating a transaction hub. So I would introduce Big Paul and the group to, you know, various people that I knew inside the community and try to move that business forward. The same as you would move any business that you were invested in, at that point, forward.”

When asked how he came to be in Ottawa with “Big Paul” [Maines] registering FMT as a new company with him as the sole director, “little Paul” (that’s how he said people referred to him in the transcript) provided the following information:

“A. Well, to do business on Prince Edward Island, you need to be local. You need to have a local address. You need to have a local flavour. That’s just the way this community works. So, you know, they – you know, we would invest in, it needed a local address of which I used my address. And since I was the only local person there, that’s how, I was subsequently placed on the Board of Directors, I guess.”

“I guess?” I would think that’s something an experienced businessman wouldn’t have to guess about.

Now here’s what Walsh proposed to the PEI Government on October 24, 2011: Note the reference to FMT (FMT was by this time understood by all the players to be the “local company,” and CMT would effectively become FMT once that corporate transition process was complete, so FMT rather than CMT is used in the correspondence):


What Judge Campbell doesn’t seem to fully appreciate is that at all material times, CMT had 100% ownership and control of FMT, and 764/FMT (the very same incorporated company) was part of the plan to establish a PEI-based, Canadian-registered and “stock exchange-listed” company in PEI.

Thirty-six (36) people wanted in on the ground-floor action of the “hub” project and spin-offs trusting that if things went as expected and their debentures (loans, e.g., unsecured investment) were eventually “converted” into Shares in FMT, they would likely make a killing.

The evidence shows that Maines was never personally involved with this endeavor, other than providing some background information on CMT and Simplex and the workings of the financial transactions platform services they offered together, including other potential ways it could be used once established (e.g., “loyalty Card”), activities falling within the scope of his capacity as CMT’s V-P of Business Development.

No investor lost a cent investing in CMT. All were offered their money back with interest (interest wasn’t required in the Settlement Agreement). Many decided to remain investors to this day.

On the other hand, all of the Investors [there is only evidence in Court Records and other government documents of Billy Dow, Chris LeClair, Paul Jenkins and some of the staff at Lawton’s pharmacy (Jenkins owns Lawton’s) bought debentures in RevTech] and they all lost 100% of their money.

I was having a hard time sorting out the connection between “RevTech” and “Target-Co” until I read in the Debenture Subscription Agreement that CMT had submitted a “letter of intent” to buy RevTech – the shell company that CMT was going to acquire to then be able to “list” on the Stock Exchange, and then have CMT fold into FMT.

The plan would likely see CMT takeover RevTech by giving them some percentage of CMT shares. That plan fell through once the Securities Investigation commenced, and all those RevTech investors (it wasn’t managed through CMT/Jessop, but by Jenkins and/or others locally who were adept in such undertakings.

The “Modified” Plan Proposed by Walsh and Adopted by PEI

That letter to Philip Walsh at Simplex indicated that the PEI Government was supportive of the proposal that Walsh had presented. An opportunity came up for the purchase of “Sterci” (you don’t need to know details) which would greatly increase the value of the entire transaction hub endeavour, creating a “win-win” for both PEI and CMT/Simplex.

Without getting bogged down in details, Walsh was proposing that the PEI Government would become a temporary “Partner” to effect the purchase of Sterci, and then FMT would buy out the PEI government after 2 years. The deal was “time sensitive” and Simplex had “first right of refusal” on the deal, but that was expiring in a few months.

Summary Observations

If you were to read what Judge Campbell said about the Securities Commission without the background provided in this episode and the last three, you would have no real understanding of what transpired. You’d assume that some really serious “illegal” activity was identified, intercepted and halted by an astute and fair Securities Commission Order delivering swift justice. It was a parking ticket. It was a parking ticket that caused an international corporation to miss its flight leaving it stranded.

I underlined the conditions/restrictions to make the analysis short and sweet:

Paragraph 21: Dowling undertook an investigation of the activities of Maines, CMT, and 764. Dowling concluded that in excess of $700,000 had been raised for CMT from some 36 investors on Prince Edward Island in contravention of the Securities Act, R.S.P.E.I. 1988, Cap. S-3.1, and in contravention of National Instrument 45-106. Each of CMT, 764 and Maines, who at all material times was an officer of CMT, signed a Settlement Agreement acknowledging the facts surrounding the illegal distribution of securities and confirming they had each received full and proper independent legal advice prior to executing the Settlement Agreement. The Order issued by the Superintendent of Securities [1] imposed restrictions on CMT’s ability to market its securities for a period of five years and required CMT to [2] pay a fine (administrative penalty) in the sum of $10,000, together with a further sum of [3] $5000 to cover the costs of the investigation.

Here’s the bottom-line on each of those three “conditions and/or restrictions” in the Settlement Agreement:

[1] Imposed restrictions on CMT Maines and CMT: Do you honestly think Maines, Walsh or any other business person they talk to for the rest of their lives would ever, ever do business in PEI again? I’m thinking maybe Maines insisted that go in the agreement.

[2] Pay a fine (administrative penalty): That unsettled dispute about whether CMT – who never did business in PEI before and relied on well-established exemption criteria under federal law never got resolved and Jessop provided copious evidence that everything was above board and legal, and that his clients had done absolutely nothing wrong. Paying a fine rather than turning down a “get out of PEI Securities Commission Free” card was quite frankly a no-brainer.

[3] $5,000 to cover the costs of the investigation. Wrong. That low figure was no where near what that investigation cost PEI taxpayers. The BC Securities Commission Charges $300 bucks an hour, so do the math. And that’s another  shocking part of the hidden story for PEI taxpayers – I don’t know what the total costs might have been but likely a couple of hundred thousand at least. Dowling even subcontracted outside legal help from a colleague at Cox and Palmer, and that alone was $37,000, so $5,000 was definitely not going to cover the costs of the investigation. That information was obtained in an Access to Information Request


The next much, much shorter episode will talk a bit about one of CMT’s greatest assets and how Judge Campbell thought what they had 100%-owned was a completely different UK company.


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