1 2 3 IPPERWASH PUBLIC INQUIRY 4 5 6 7 ******************** 8 9 10 BEFORE: THE HONOURABLE JUSTICE SIDNEY LINDEN, 11 COMMISSIONER 12 13 14 15 16 Held at: Forest Community Centre 17 Kimball Hall 18 Forest, Ontario 19 20 21 ******************** 22 23 24 April 19th, 2005 25

2
  1                        Appearances
  2  Derry Millar      )    (np)     Commission Counsel
  3  Susan Vella        )
  4  Donald Worme, Q. C )
  5  Katherine Hensel  )
  6  Jodi-Lynn Waddilove )   (np)
  7  
  8  Murray Klippenstein )  (np)      The Estate of Dudley 
  9  Vilko Zbogar       )   (np)     George and George
 10  Andrew Orkin       )            Family Group
 11  Basil Alexander    ) (np)       Student-at-Law
 12  
 13  Peter Rosenthal  )              Aazhoodena and George
 14  Jackie Esmonde   )              Family Group
 15  
 16  Anthony Ross     )   (np)       Residents of 
 17  Kevin Scullion   )              Aazhoodena  (Army Camp)
 18  William Henderson )   (np)       Kettle Point & Stony
 19  Jonathon George  )              Point First Nation
 20  Colleen Johnson  )   (np)
 21  
 22  Kim Twohig       )   (np)       Government of Ontario
 23  Walter Myrka     )
 24  Susan Freeborn   )   (np)
 25

3
  1                   APPEARANCES (cont'd)
  2  Janet Clermont   )              Municipality of 
  3  David Nash       )   (np)       Lambton Shores
  4  
  5  Peter Downard    )   (np)       The Honourable Michael
  6  Bill Hourigan    )   (np)       Harris
  7  Jennifer McAleer )
  8  
  9  Ian Smith        )   (np)       Robert Runciman
 10  Alice Mrozek     )   (np)
 11  Harvey Stosberg  )   (np)       Charles Harnick
 12  Jacqueline Horvat )   (np)
 13  Douglas Sulman, Q.C. )           Marcel Beaubien
 14  Trevor Hinnegan     ) (np)
 15  
 16  Mark Sandler       ) (np)       Ontario Provincial 
 17  Andrea Tuck-Jackson )            Ontario Provincial Police
 18  Leslie Kaufman     )  (np)
 19  
 20  Ian Roland       )              Ontario Provincial 
 21  Karen Jones      )   (np)       Police Association &
 22  Debra Newell     )              K. Deane
 23  Ian McGilp       )   (np)
 24  Annie Leeks      )   (np)
 25

4
  1                   APPEARANCES (cont'd)
  2  
  3  Julian Falconer  )   (np)       Aboriginal Legal 
  4  Brian Eyolfson   )              Services of Toronto
  5  Julian Roy       )   (np)
  6  Clem Nabigon     )   (np)
  7  Adriel Weaver     )   (np)       Student-at-Law
  8  
  9  Al J.C. O'Marra  )              Office of the Chief
 10  Robert Ash, Q.C. )    (np)       Coroner
 11  
 12  William Horton   )   (np)       Chiefs of Ontario
 13  Matthew Horner   )   (np)
 14  Kathleen Lickers )   (Np)
 15  
 16  Mark Frederick   )   (np)       Christopher Hodgson
 17  Craig Mills      )   (np)
 18  Erin Tully       )
 19  
 20  David Roebuck    )   (np)       Debbie Hutton
 21  Anna Perschy     )   (np)
 22  Melissa Panjer   )   (np)
 23  Danya Cohen-Nehemia ) (np)
 24  
 25

1 TABLE OF CONTENTS 2 Page 3 Exhibits 6 4 5 WALTER PETER HOLMES HARDING, Resumed 6 Cross-Examination by Mr. Andrew Orkin 7 7 Cross-Examination by Mr. Peter Rosenthal 25 8 Cross-Examination by Mr. Kevin Scullion 69 9 Cross-Examination by Mr. Ian Roland 118 10 Cross-Examination by Mr. Al O'Marra 120 11 12 GLEN ALAN MORGAN, Sworn 13 Examination-In-Chief by Ms. Katherine Hensel 132 14 Cross-Examination by Ms. Jackie Esmonde 202 15 Cross-Examination by Mr. Kevin Scullion 227 16 Cross-Examination by Mr. Jonathan George 243 17 Cross-Examination by Mr. Ian Roland 249 18 Cross-Examination by Mr. Al O'Marra 255 19 20 KAREN BAKKER-STEPHENS, Sworn 21 Examination-in-Chief by Ms. Susan Vella 267 22 23 Certificate of Transcript 354 24 25

1 EXHIBITS 2 No. Description Page 3 P-341 Document Number 2001400 St. John's 4 Ambulance, London-Middlesex Corps 5 Missing Items - Not Returned 6 November 1995; Interim Report and 7 Attendants Report Re: Ipperwash 8 Provincial Park, September 06/95. 282 9 P-342 Document Number 1002921 St. John's 10 Ambulance Patient Report of Cecil 11 Bernard George by Witness Ms. Karen 12 Bakker-Stephens, September 06/95 311 13 P-343 Document Number 1005723 September 07/95 14 Will State of Karen Bakker 337 15 16 17 18 19 20 21 22 23 24

1 --- Upon commencing at 9:01 a.m. 2 3 THE REGISTRAR: This Public Inquiry is 4 now in session, the Honourable Mr. Justice Linden 5 presiding. Please be seated. 6 COMMISSIONER SIDNEY LINDEN: Good 7 morning. Good morning. I guess we'll start right off 8 with cross-examination with Mr. Orkin, yes. 9 MR. ANDREW ORKIN: Good morning, Mr. 10 Commissioner. 11 COMMISSIONER SIDNEY LINDEN: Good 12 morning. 13 14 WALTER PETER HOLMES HARDING, Resumed 15 16 CROSS-EXAMINATION BY MR. ANDREW ORKIN: 17 Q: Good morning, Mr. Harding. My name's 18 Andrew Orkin, I'm Co-Counsel to the Dudley George Estate 19 and the Sam George Family Group and as you saw the lineup 20 on what the timing is today, I'm only going to be asking 21 you very few questions. 22 I understand that the St. John Ambulance 23 organization is the world's oldest, or perhaps one (1) of

1 the oldest humanitarian charitable organizations; is -- 2 is that your understanding? 3 A: Yes, it derives its history from -- 4 from the Benedictine Order and goes back to the ten (10) 5 hundreds, officially. And other than the church 6 organizations, I suppose the only oldest one would be in 7 the Masonic Lodge as Knights Templar -- 8 Q: Right. 9 A: -- where the knights were given 10 responsibilities of various responsibilities and ours was 11 hospitallers. We were looking after the pilgrims 12 travelling the Holy Lands, both defending them and -- and 13 looking after their needs. 14 Q: And if I understand the use of the 15 word, 'humanitarian' as it's used in the -- in the St. 16 John Ambulance context, does that have any specific 17 meanings other than caring for human beings in your 18 understanding? 19 A: For the service of mankind. 20 Q: For the service of mankind. The 21 emblem of the St. John Ambulance, which I see you have on 22 your -- your shoulder there and is -- is prominently 23 displayed on all of the vehicles in the pictures we saw

1 yesterday, is there anything you can tell us about the 2 history of that, and perhaps, in particular -- 3 A: A lot of people refer to -- 4 Q: -- the -- the Amalfi Cross. 5 A: I'm sorry, a lot of people refer to 6 it as the Maltese Cross, but it's not, it's the badge of 7 Amalfi. 8 Q: Yes. 9 A: It's -- which is a republic on the 10 south coast of Italy. It was adopted by the Benedictines 11 at the time when the property was bought back from the 12 Turks, around the Holy Sepulchre where the hospital is 13 today, in Jerusalem. And the -- this badge was used as a 14 sign of help to -- in their way- stations. 15 It was on a field of black, same as today, 16 field of black. If you -- the Johanniter is a field of 17 red -- 18 Q: Hmm hmm. 19 A: -- and the same badge of Amalfi is 20 used. A lot of people refer to it as the Maltese Cross 21 because our headquarters was in Malta for three hundred 22 (300) years. And Malta adopted the eight (8) pointed 23 cross also, but half red and half white, half -- the red

1 for the republic, the white for the Knights of Malta who 2 worked -- who lived and defended the -- the Valette. 3 Q: All right. I understand there is 4 perhaps a relationship between the -- the emblem of the 5 Amalfi Cross and that of the Red Cross via the -- the 6 Swiss connection and that the -- do you know anything 7 about that connection in this? 8 A: Well, I can tell you that the Geneva 9 Cross which is -- 10 Q: Right -- 11 A: -- the Red Cross. The Geneva cross 12 is a specific -- it came into being after the -- after 13 St. John, after the White Cross. It was designed for a 14 time of conflict. It was designed specifically for the 15 use of the Red Cross. 16 Q: Hmm hmm. 17 A: if anything happens and there is a 18 conflict, and specifically referring to war, our cross 19 changes to the red cross. We become adaptable and we use 20 the red cross as a sign of -- of our work. 21 Q: So, leading on -- on the discussion, 22 the brief discussion we've just had, there's a tremendous 23 importance, then, is there, in addition to a history,

1 there's a tremendous importance to the existence and use 2 of these emblems and people's general understanding that 3 they represent and mean help? 4 A: There is a specific use for the red 5 cross, under the Geneva Convention. There is not for the 6 Maltese cross which is a sign of just direct help for 7 anyone. 8 Q: Right. So, beyond the -- the 9 trademark interest that the St. John Ambulance might have 10 in its --in its cross and in this emblem of universal 11 help, as you just put it, what reasons might there be to 12 prohibit the misuse of an emblem, of a distinctive 13 emblem, like the St. John Ambulance cross? 14 A: Well, there's specific guidelines 15 laid down for the Red Cross -- 16 Q: Hmm hmm. 17 A: -- in which it says not to be used 18 for specific purposes. We do not have that agreement 19 with the -- with -- under Geneva. 20 When we go into a -- a conflict situation 21 whereby in -- during war, that's why we come under the 22 jurisdiction of the Red Cross and the Red Cross is used 23 in that regard --

1 Q: Right. 2 A: -- such as with the military and with 3 other various situations like that. 4 Q: So, you -- it's fair to say that you 5 are aware of the, at least in the Red Cross contexts, the 6 importance of the avoidance of the misuse of emblems that 7 signify help -- 8 A: Oh, most definitely, yes. 9 Q: Right. What -- and you've mentioned 10 the Geneva Convention, which I presume is the fourth 11 convention and others of the immediate postwar -- post 12 World War II era. 13 Are there any Canadian arrangements that 14 you're aware of in law or policy with respect to emblems 15 like the Red Cross emblem? 16 A: The red -- the Canadian Red Cross 17 adopted the same -- the same policies with the Geneva 18 Convention and they follow the same regulations, yes. 19 Q: Now, with the prominent display of 20 this emblem on your vehicles, as we saw yesterday and in 21 particular, such vehicles as the -- the medic vehicle and 22 the command post vehicles that we saw yesterday in those 23 -- in those photographs, could you perhaps tell us what

1 the impulse is in displaying that emblem as prominently 2 on your vehicles as you do? 3 Why -- why is it that those -- that the 4 St. John Ambulance name and that very famous and ancient 5 cross -- 6 A: Well, it's -- 7 Q: -- is so prominently displayed on -- 8 on your vehicles? 9 A: Well, it's -- we -- we -- if you're 10 looking at our perspective, is that 1, the four (4) arms 11 symbolise the Christian virtues; prudence, temperance, 12 justice and fortitude, and the eight (8) points represent 13 the eight (8) beatitudes which spring from the practise 14 of those virtues. 15 Q: Yeah. 16 A: That is why we display it. It is our 17 -- it is our symbol of people coming to us and asking for 18 assistance when it is required. And that was flown for 19 years and centuries as on the field of black. 20 Q: Hmm hmm. 21 A: And it was for those to be recognized 22 to come to us for assistance. That's specifically what 23 the reason was.

1 Q: So, it's not just an accident that 2 one might hope that people gathered in any situation or 3 passing by, when they see one (1) of those vehicles could 4 have a sense of confidence that that is a place or an 5 instrument in which assistance and -- and all of the 6 other virtues as represented in the eight (8) points of 7 that cross in your credo -- 8 A: That's correct. 9 Q: -- is manifested in that place? 10 A: Yes. That's fair -- that's fair to 11 understand, I think. 12 Q: You mentioned yesterday that in 13 providing the vehicle that you did or vehicle -- it was 14 one (1) vehicle -- 15 A: Yes. 16 Q: -- is that correct? 17 A: No, there was two (2) vehicles. 18 Q: There was two (2) vehicles. And 19 provided -- 20 A: And a third vehicle was a -- was a 21 transport-type of unit. 22 Q: Right. 23 A: Actually, about four (4) vehicles

1 were involved, all total. 2 Q: In responding -- in -- in providing 3 those vehicles, you were responding to official requests, 4 were you not? 5 A: We -- yes, requests for assistance 6 from the Ontario Provincial Police, yes. 7 Q: And in -- in receiving those 8 requests, you saw it as appropriate in the event that 9 persons or groups required assistance, that it was 10 appropriate for the St. John Ambulance to be providing 11 equipment and material that -- that might provide aid? 12 A: I forget the first part. We -- I 13 just -- I'm sorry, would you -- 14 Q: In providing those vehicles in 15 response to the official request -- 16 A: Yes? 17 Q: -- your hope in -- in doing so was 18 the equipment and material would be available in the 19 event that individuals or groups needed the assistance of 20 that -- of that equipment and of your... 21 A: It was pretty -- it was narrower -- 22 we agreed to provide the equipment for a specific 23 purpose.

1 Q: Hmm hmm. 2 A: And a specific type of spec -- 3 equipment was used, provided for that purpose and it was 4 provided for communications, yes. 5 Q: For communications. Who was your 6 understanding -- in your understanding, who was it that 7 would be using that equipment for communications? 8 A: It was be -- to be used by the 9 Ontario Provincial Police for communications; that's my 10 understanding at the time of discussions. 11 Q: Now, you mentioned yesterday that the 12 -- one (1) of the outcomes of the situation as you now 13 see it testifying with the -- with the benefit of 14 hindsight, is that there had been a perception of 15 equating of St. John's Ambulance with the police 16 operation; is that correct? 17 You used the phrase, "Equating with the 18 police operation," yesterday. 19 A: I believe we're probably equated with 20 the police operation in very many situations, with our 21 canteen service, with our communications units, with our 22 heavy light generators. Yes, it would be equated with 23 the police operation, yes.

1 Q: But you also said that there was no 2 intent on the part of St. John Ambulance to confuse. 3 Would you like to expand a little on confuse who and 4 confuse who with what? 5 A: Well, I think there's been some 6 speculation around that -- that we -- we had -- were -- 7 that we had misidentified ourselves by helping the 8 Ontario Provincial Police and -- and that was not a fact 9 at all. Our vehicle had -- our vehicles had been in 10 various responsible areas for doing these jobs for quite 11 some time and as we develop these jobs we were doing, 12 such as our various -- our canteen service, our 13 rehabilitation units -- 14 Q: Hmm hmm. 15 A: -- our heavy light generators and 16 that, we started to identify them and we were in the 17 process of identifying these units all the way along. 18 This was -- we were talking ten (10) years 19 ago, I guess, pretty well, and then before that -- so the 20 last fifteen (15) years or so, we've been sort of 21 developing these -- these various responsibilities 22 because really, this area is really the only one that 23 does that St. John-wise.

1 Q: Right. 2 A: And we've been learning. It was a 3 pilot project; we started off with one (1) and we sort of 4 went along. And as we started to develop that, we 5 started to develop the specific vehicles for those 6 purposes and then we started to identify those vehicles 7 like that. 8 Q: Right. As far as you know at the 9 time, did the OPP not have any of its own command post 10 units or command post facilities? 11 A: At that time? 12 Q: Communications facilities? 13 A: At that time? 14 Q: Yes. 15 A: No, they didn't. In fact today they 16 designed a unit much the same as ours. A fifth wheel 17 unit that they use today and they use it very effectively 18 in -- in a lot of different situations that they have. 19 At that time, no, they had much as -- like 20 the railway, they had a very large 18 wheel vehicle that 21 they bring from the Toronto area, the metropolitan areas. 22 And, no, they didn't have any advanced equipment at that 23 time. Lighter equipment -- and they didn't have a great

1 flexibility in that -- that area for communications 2 outside their one (1) command post. 3 Q: When was it that you would have 4 received that request? 5 How -- how much -- and with what kind of 6 lead time might you have received a request for that 7 vehicle? 8 A: I -- I specifically hadn't looked 9 through the -- the -- I believe if I remember correctly, 10 I spoke to Superintendent Carson about a week to a week 11 and a half prior to the vehicle being called. I -- I 12 believe it was around that timeframe. 13 Q: And that vehicle was stored where? 14 A: In London at 741 King Street. 15 Q: Okay. So, it would have taken a 16 matter of an hour or a couple of hours to drive down and 17 bring it to the area? 18 A: To us -- no, it would bring about the 19 same time as we drive now, it drives about the same speed 20 as a normal car. I would say forty-five (45) minutes. 21 To -- well to -- to fifty (50) minutes to an hour, yes. 22 Q: So, this would perhaps have been a 23 matter of the -- of -- of increased convenience in your -

1 - in your view for the -- the Ontario Provincial Police 2 to be requesting to use your equipment rather than to 3 bring a larger vehicle in from Toronto or...? 4 A: No. They brought their unit in from 5 Toronto also. 6 Q: They brought the big unit in from 7 Toronto; the 18 wheel? 8 A: This was -- I think when we talked 9 about it and as we stress with our -- our work with the 10 OPP, is safety. It's all safety and what we try to do, 11 our communication unit was designed to be able to afford 12 at major instances specific for fire what it was, better 13 safety precautions. 14 In other words if you knew what was 15 happening and we had good communications, then it was 16 much safer for everyone. In all aspects of -- of their 17 work and usually the work we were involved in was heavy - 18 - heavy type of work such as very large accidents or 19 derailments and that type of thing. 20 Q: All right. No, I -- thank you. 21 Would you agree going back to the issue of the -- of the 22 emblem and the very distinctive character of your vehicle 23 written with St. John Ambulance written on the side of it

1 and the -- the emblem, the helping emblem on the vehicle, 2 that it might be possible for others -- other 3 organizations, other entities to seek -- to misuse or 4 confuse by having one of your vehicles in a situation 5 where that -- that cover would be provided? 6 A: I -- no, I wouldn't say that. I -- I 7 believe the OPP have got enough moral fibre to say to us 8 if they want to use it that way and make us -- let us 9 have the decision of -- of saying no. We wouldn't 10 provide it for that reason. 11 They were very upfront and they -- they 12 had a concern that they needed communications and that's 13 what we supplied and that was afforded to. There was -- 14 we would not have done that if -- and I think they would 15 have told us. They have in the past if there's been some 16 concern about something, they've always been upfront with 17 us and I think that's the only way you can run a 18 relationship like that really. 19 Q: So, in the event that you were to 20 receive the request and you say you would have had the -- 21 St. John Ambulance would have had the moral capacity to 22 refuse -- 23 A: Well -- I'm sorry.

1 Q: No, go ahead. 2 A: Yes, I think -- for instance they 3 came to us, between their team and the London City Police 4 team, they had a -- a grow-op type of thing, there was 5 special chemicals and that, that we had the acid to 6 respond to but they put up front what the problem could 7 have been for us when we went there and what we would -- 8 and that was -- I mean, they would tell us something if 9 they wanted to and that was not the case. 10 Q: Now, with the benefit of hindsight of 11 the last ten (10) years and the way that particular 12 operation turned out and we'll be hearing evidence, much 13 more evidence about what was involved when we get to 14 police witnesses, but with the benefit of -- of your 15 experience in the following years, have you thought -- 16 have -- has St. John's Ambulance thought about putting 17 policies in place in which specific questions are asked 18 of police and other organizations about the nature of the 19 potential use of your emblem and your vehicles to ensure 20 that they're not inserted into contexts into which things 21 can go awry? 22 A: I think we're getting very -- quite - 23 - as we work with the various entities, we're getting

1 much better at that to -- to put these things -- see this 2 was a very a -- very pilot, this was a very focussed type 3 of operation within the structure here, and we are 4 becoming very, I said familiar with, what things that -- 5 that might come up, and -- such as our SAR unit with 6 letters of understanding, that type of thing. 7 So, as we progress along, yes, we are 8 asking for more clarification on the various things and I 9 think, also, people are -- know where we stand a little 10 closer, too. 11 Q: Hmm hmm. Do you feel at all that the 12 event, as it turned out at Ipperwash Park in September of 13 1995, has in someway resulted in a -- in a black mark on 14 St. John's Ambulance reputation? 15 A: Do I think so? 16 Q: Yes. 17 A: No, I don't think it has. I think 18 that -- that there was a misconception around at the 19 time that we were involved. 20 Now, I picked it up through the various 21 Court cases and that, that I've had to attend to, and 22 listen to talk and that, but generally I don't think it 23 has. But, I think, as I said, I have -- my family was

1 around from around this area and that we travelled this 2 area and we had noticed that, in someone's mind, there 3 was still some concern, yes. 4 Q: Have you been receiving requests for 5 provision of vehicles to aboriginal pow-wows or to 6 aboriginal gatherings of any kind? 7 Are those requests -- have those continued 8 to come in, if they did before, or -- 9 A: Yes -- 10 Q: -- they have? 11 A: -- yes, they have, yes. Very much 12 so, yes. 13 Q: Good. 14 A: In fact, more than we had before. 15 Q: Good. 16 A: I -- 17 Q: Thank you for that. 18 A: Thank you. 19 Q: Thank you, Mr. Commissioner. 20 COMMISSIONER SIDNEY LINDEN: Thank you. 21 Yes, Mr. Rosenthal...? 22 23 (BRIEF PAUSE)

1 MR. PETER ROSENTHAL: Thank you, Mr. 2 Commissioner. Good morning. 3 COMMISSIONER SIDNEY LINDEN: Good 4 morning. 5 6 CROSS-EXAMINATION BY MR. PETER ROSENTHAL: 7 Q: In the process of coming to the 8 podium my computer crashed, but I think it will come up 9 in a moment. Excuse me. 10 11 (BRIEF PAUSE) 12 13 Q: It's did. Okay. Good morning, sir. 14 A: Morning. 15 Q: My name is Peter Rosenthal. I'm one 16 of the Counsel representing a group of people from Stoney 17 Point, under the name Aazhoodena and George Family Group. 18 Now, before I get into some more general 19 areas, I wanted to begin with a narrow, discrete topic if 20 I could. 21 The issue of Karen Bakker, your ambulance 22 driver and her monitoring of Cecil Bernard George -- 23 A: Yes, yes.

1 Q: -- on the way to hospital. Now, I 2 gather you spoke to her about that situation prior to her 3 filling out her ambulance call report; is that correct? 4 A: No, I -- well, we have what we call 5 debriefing -- 6 Q: Yes. 7 A: And during the debriefing, one of the 8 concerns that any senior officer has, is how it affects 9 people at a specific, given time -- 10 Q: Yes. 11 A: -- and we have to -- we try to 12 monitor what is. And specifically with a younger person, 13 at the time, and a person just starting into, and a 14 person that was placed into a position that we hadn't 15 thought they would be in, I took specific -- myself, to 16 speak with her to -- to find out how she -- she was 17 feeling with the situation and she was a little nervous 18 and she was a little upset. 19 Q: Okay. And -- 20 A: Because she was just starting into 21 her career, and that was a major thing for her. 22 Q: Yes. And at that debriefing you 23 suggested to her something like, anybody could have

1 missed the vital signs given the noise as one travels in 2 an ambulance like that. 3 A: No, I wouldn't do that. I wouldn't 4 say I suggested to her. And she had brought -- mentioned 5 to me, and she had mentioned the fact that the medics on 6 scene had said the person had been stable. Once they 7 started travelling, that point in time in travelling, she 8 lost -- she could not obtain the vital signs, 9 specifically when she was doing the blood pressure and 10 that. 11 And she said then all of a sudden it was 12 back again, and I'm not sure what the wording was in 13 between that -- 14 Q: Yeah. 15 A: -- but then the person was stable and 16 was back again, and she said, How could that happen? 17 Well, she sort of indicated, How could that happen? 18 And I said, That it most certainly can in 19 -- in professionally -- even professionally. It is very 20 difficult. It takes a little bit of -- of -- of training 21 to distinguish the road noise coming up through the 22 system as you're travelling and that, and it is -- it is 23 difficult if you're -- and especially if you're nervous

1 yourself and your own adrenalin's pumping. 2 Q: Yeah. And this conversation took 3 place, though, before she filled out her ambulance call 4 report; is that correct? 5 A: I'm -- I'm not sure. I -- she -- 6 yes, she -- in fact, I think she had -- they fill it out 7 immediately after -- immediately after the call. 8 Q: Yes. 9 A: And I think she -- she had it with 10 her. I'm not sure if she had it with her or it was 11 handed in to the box as it usually is. 12 Q: And what had she told you she had 13 done in order to try to check Mr. Cecil Bernard George's 14 vital signs? 15 She had felt manually for a pulse I take 16 it; is that correct? 17 A: Well, she did a -- a -- from what I 18 understood and what she laid out, she had done a -- a 19 precursory examination. I think she found something at 20 the back of the head when she went around the head. She 21 followed through an examination of -- of the patient -- 22 Q: Yes. 23 A: -- after she was in -- the patient

1 was in the unit. 2 Q: But -- but specifically, with respect 3 to the vital signs, she would have done a manual check 4 for pulse, would she, by reaching at his wrist or his 5 throat? 6 A: I would say, yes. 7 Q: And, also, did she tell you that she 8 applied a blood pressure cuff at any time? 9 A: Yes. 10 Q: And the blood pressure read zero? 11 The blood pressure cuff read zero? 12 A: Well, I -- I'm not sure, I -- I 13 didn't -- I can't -- it's been ten (10) years is why. We 14 sort of had a view and I didn't write down notes on it -- 15 Q: Yeah. 16 A: -- and I'm sorry. I -- if -- I'd be 17 -- I'd be guessing at it to tell you right now, like, 18 from word-to-word exactly what she said, how she put it-- 19 Q: Yes. 20 A: -- at that time. 21 Q: You would agree, sir, that it happens 22 from time-to-time that a person's heart stops and then 23 spontaneously starts again ten (10) seconds later, twenty

1 (20) seconds later or a minute later; isn't that correct? 2 A: I can't -- I can't dispute that. I'm 3 -- I'm not a medical person to be able to say. I have 4 heard it happening, but I can't tell you what 5 circumstances at all. I wouldn't even try and guess it. 6 Q: Okay. I'm moving to another area, 7 then. 8 Now, sir, you've had a lot of experience 9 with the Fire Department over the years, you've told us, 10 and with ambulance services. 11 In Toronto it seems, I don't know about 12 other parts, that when there's an emergency and a 9-1-1 13 call, the Fire Department almost invariable gets there 14 before ambulance service does. Is that -- 15 A: Sometimes. 16 Q: Sorry? 17 A: Sometimes. 18 Q: Now, is that your understanding as to 19 what generally happens in this area, for example? 20 A: In this area, yes, it would be -- 21 well, no, just a minute. Depends on -- on the state of 22 whatever -- whatever the -- the emergency facilities 23 would be.

1 In other words, if your car is -- I 2 believe they run two (2) cars out of Forest or this area, 3 and at the time that we're talking about, and if they -- 4 one (1) car was in London and one (1) car was in Sarnia 5 or vice versa, then it could be the Fire Department would 6 be there and deal with it a lot longer, maybe they would 7 have first response maybe here, yes. 8 Q: Yes. 9 A: I don't know. 10 Q: Generally, when there's a 9-1-1 call 11 indicating a first aid emergency of some kind, both fire 12 and ambulance respond to that call; is that correct? 13 A: In larger centres, yes. 14 Q: Yes. And you don't know what the 15 practise is in this centre, then, sir? 16 A: I'm not sure if they have a first -- 17 first call response system or not here. 18 Q: I see. Thank you. And, you don't 19 have any understanding as to -- it appears that the Fire 20 Department never responded to the Ipperwash situation? 21 A: Not -- 22 Q: In this case, you don't have any 23 understanding as to what would occur?

1 A: No, I do not have any understanding 2 of that. 3 Q: Thank you. Now, sir, getting into 4 the area that Mr. Orkin, the previous Counsel, asked you 5 about a bit, first off, the St. John's Ambulance Service 6 is particularly respected I would to suggest to you in 7 general, because people know not only is it a medical 8 service that gives first aid, but also it's staffed by 9 volunteers and people particularly respect that. 10 Is that your understanding, sir? 11 A: Yes, we're all volunteer. All the 12 people in uniform. 13 Q: But, it gains particular respect, it 14 appears, because of that additional factor as well? 15 A: I -- yes, I believe so. 16 Q: Now, on the other hand, except for 17 that factor, in general, members of the public don't have 18 a clear understanding as to the difference between the 19 St. John's ambulance and other ambulance services; isn't 20 that fair to say? 21 A: No. That's -- fair to -- well, they 22 do not realize, a lot of people do not realize it's not 23 subsidized by the Government. In other words they feel

1 it's a Government service. 2 Q: Yes. And they don't realize that 3 there are any particular operational differences between 4 them even though they are in fact are? 5 A: They're not -- no, they're not 6 educated to that fact, no. 7 Q: I'm sorry? 8 A: There's no -- there's no education to 9 that fact. Yeah. 10 Q: Yes. So -- so people think they're 11 pretty much the same operation. 12 A: They're part of the system. 13 Q: Yes. Now -- 14 A: And -- and I might just qualify that 15 and say one (1) -- one (1) point. And they are part of 16 the system and is accepted by the Ministry that at the 17 time, that they were on the call order. 18 Q: Yes. Yes. They are part of the 19 system in a certain sense -- 20 A: Yes. 21 Q: -- but the general public doesn't 22 realize the limitations of that -- 23 A: Yes, yes.

1 Q: -- is that fair to summarize it? 2 A: That's fair to say, yes. 3 Q: Now, you told us that the purpose of 4 the communication trailer was for safety; is that 5 correct, sir? 6 A: That's correct, yes. 7 Q: Now we've of course had much evidence 8 at this Inquiry and you may have heard of some of it and 9 you undoubtedly learned some from the press over the 10 years, that the operation that it was involved in, in 11 fact, was a policing operation at Ipperwash Park at which 12 it was used for, apparently to further the police 13 operation and the police operation ended up with the 14 killing of Dudley George. 15 You understand that; is that correct, sir? 16 A: I understand that, yes. 17 Q: Now, an additional fact that we've 18 learned at this Inquiry is that after Mr. George was 19 shot, there was no ambulance that came to transport him 20 to a hospital. He was transported by his brother Pierre 21 in a harrowing drive and, unfortunately, by the time he 22 arrived at hospital, he was unable to be saved. 23 You understood that too, did you, sir?

1 A: The particulars, I understand he 2 arrived at the hospital by car. I'm not sure what in 3 between with the exception that you stated to me, all 4 that I know there were three (3) amb -- there were two 5 (2) ambulances besides ourselves located with the OPP. 6 Q: Yes, in any event, sir, I just wanted 7 to suggest that to you is background. You told us that 8 you understand why people might have been frustrated, to 9 some extent, as to what happened and with respect to your 10 vehicle and so on. 11 And I thought it might be useful to you to 12 put some of the testimony of one (1) person explaining 13 that relation as he did. David George was one of the 14 witnesses who testified at this Inquiry. He was one of 15 the First Nations people who were in the Park that night. 16 And he testified on October 21st at page 17 82 for those who want to check that I'm reading 18 accurately. 19 "Question: Yeah, you told us that the 20 next day you went to the MNR parking 21 lot with the St. John's Ambulance 22 vehicles? 23 Answer: Yes.

1 Question: And then you beat the van? 2 Answer: Yeah, I gave it a couple of 3 kicks. 4 Question: Why did you do that? 5 Answer: I was just venting my 6 frustration and anger. 7 Question: What -- was it the fact 8 that it was labelled St. John's 9 Ambulance? Did that have any 10 particular affect on you? 11 Answer: Well yeah. Because St. 12 John's Ambulance, they wouldn't help. 13 They wouldn't come to help Dudley or 14 anybody else that night. It was their 15 God damn ambulance. They wouldn't let 16 us use it. And it wasn't -- that one 17 that was there wasn't even an 18 ambulance. There was no lifesaving 19 equipment in there." 20 Now, that's one person's expression of the 21 reason that he felt angry when he saw your vehicles in 22 the parking lot that had been used as command 23 headquarters for the operation that killed Dudley George.

1 A: And he did not realize that that 2 later that time, we were asked to help and we did the 3 relation of -- one of the George's at that time. 4 And we -- and we were caught off guard 5 with that, but because of the nature of the request, we 6 -- we then responded and that was not -- we were not 7 planning on doing that. 8 Q: But, sir, I gather that in the ten 9 (10) years since that event, there hasn't been any high 10 level discussion within St. Johns as to how to guard 11 against something like that happening in future; am I 12 correct? 13 A: Oh I think there has been. We -- 14 we've discussed this a number of times, of protocols; 15 trying to make sure that all our protocols are clear. Oh 16 yes, we -- we've discussed it with the emergency service 17 officer in both levels, national and provincial. 18 Q: Now, sir, if Inspector Carson came to 19 you tomorrow then, with the same request, would you allow 20 him to use the vehicle in the same way as you did ten 21 (10) years ago? 22 A: If he came to me and asked me for the 23 vehicle for communications, I would certainly agree to

1 loan him the vehicle, yes. 2 Q: In spite of what we've learned about 3 the affect it had on people when they saw that a vehicle 4 that they thought of as an ambulance vehicle that should 5 help people was, in their view, implicated in killing, 6 without any justification, Dudley George? 7 A: That would be the same way of 8 refusing the OPP assistance with the rehab -- 9 rehabilitation unit at Ingersoll during the protest. 10 It's there to help -- it's there to help people. It's 11 there to -- to do the best they can for people. 12 That would be like saying the same thing 13 to the Fire Department; We will not respond to a fourth 14 alarm fire because our unit is on the street, and -- and 15 three (3) people die in the fire. 16 I mean, I'm just trying to relate that. I 17 -- I don't know -- I don't know how to answer that. 18 Q: Well, may I -- may I give you 19 suggestion and find out if this has been considered, sir? 20 Has it at least been considered within St. 21 John's that in a situation where the police are 22 requesting use of one (1) of your vehicles for their own 23 operational purposes and where it's going to be under

1 their command as you indicated it was in this instance, 2 that at least the labelling on the outside, 'St. John's 3 Ambulance' and so on, be covered over so that it does not 4 appear to people to be an ambulance vehicle when it's 5 really being used as a police support vehicle? 6 A: We -- we talked about that and -- and 7 what we thought would be a better thing is what we have 8 been trying to do is label the units very clearly again 9 with very defined cresting, in other words, such as a 10 city cresting, such as communications. 11 And that's what we've been trying now, is 12 to increase that so it's not mistaken for another type of 13 vehicle. You're -- yes. 14 Q: Well, sir, isn't it the case that the 15 mobile trailer as now labelled -- 16 A: Yes. 17 Q: -- would still be taken by virtually 18 everyone as being a medical unit when they look at it in 19 spite of the fact that it says, 'Communications Unit' on 20 it? 21 A: I -- I really don't -- besides 22 saying, 'Communications Unit' on it, with all the 23 antennas, I would -- I'd be hard pressed to try to make a

1 judgment. I don't know. I -- I would not, but of 2 course, I'd read it -- I -- but, on the other hand, it 3 maybe could be, I -- I couldn't tell you that. 4 Q: Now, sir, I would suggest to you that 5 virtually everyone except for those in the know like you 6 who know what the numbers mean and so on, would assume 7 that such a vehicle is a communications vehicle if they 8 were able to read that smaller print -- 9 A: Well, it's supposed to be -- 10 Q: -- that was used -- excuse me, sir -- 11 A: Sorry. 12 Q: -- that even if they read that, a 13 communications vehicle to be used for medical assistance 14 purposes rather than for an OPP operation against the 15 First Nations people occupying a park? 16 A: Well, the only thing I can say to you 17 in this regard is, not only is -- St. John's is not only 18 medical, it's safety -- it's safety. We -- we train in 19 first aid to prevent accidents. 20 We provide equipment to prevent accidents, 21 prevent things happening, to make it easier so that we 22 don't run into these specific problems and that's -- it's 23 not just medical; it's safety. It's safety all around in

1 all aspects and that's what we try to teach and that's 2 what we try to provide. 3 Q: And it's your understanding, sir, 4 that in this instance your vehicle contributed to safety? 5 A: I hope so. 6 Q: And in what way was it your 7 understanding it committed -- it contributed to safety 8 rather than lack of safety to the Native people? 9 A: I provided -- oh, I'm sorry, go 10 ahead. 11 Q: What was your understanding as to how 12 it contributed to safety in this instance, sir, where we 13 have the evidence that Dudley George was killed, Cecil 14 Bernard George was very badly beaten -- 15 COMMISSIONER SIDNEY LINDEN: You don't -- 16 you don't need to do -- 17 MR. PETER ROSENTHAL: I don't need to 18 reiterate all that. 19 COMMISSIONER SIDNEY LINDEN: Your 20 question was fine: How did it contribute to safety? 21 MR. PETER ROSENTHAL: Thank you, sir. 22 THE WITNESS: Well, by providing a -- a 23 communicating system to -- virtually in that -- in that

1 unit was directly to -- to ambulance communications; they 2 could have used it. They could have used -- there's a 3 number of systems in that, but it provided a good source 4 of work out of location that they could process the work 5 that they were doing and do it fairly clearly, instead of 6 maybe on pads of paper in -- in cars and that. 7 It provided -- so in that way, it was a 8 much safer way to work. Now, I can't comment what 9 happened during that, but it -- it was a -- good 10 communications is safer in any -- any type of business. 11 12 CONTINUED BY MR. PETER ROSENTHAL: 13 Q: Sir, as you may know, one of the 14 purposes of this Inquiry, in addition to finding out as 15 much as we can about what happened in the events 16 surrounding the death of Dudley George, is the 17 possibility of making recommendations to avoid violence 18 in future. 19 Now, sir, if this Commission were to make 20 a recommendation to the effect that any vehicles that are 21 used in a police operation as part of the police 22 operation as opposed to medical use, should not be 23 labelled medically, should not give people the impression

1 that they're medical vehicles, would St. John's Ambulance 2 take such a recommendation seriously and -- and consider 3 that policy, sir? 4 A: Oh, certainly we would. We would 5 certainly take any recommendation that the Commission 6 would offer and act accordingly and try to do the best to 7 -- to follow through with it. 8 But, I -- to -- to suggest that we not 9 involve ourself with the police in any aspect is, I 10 think, a disservice to the community and to the public, 11 because it is public equipment that we try to be use to 12 the best -- to the best of everyone. 13 Q: Now, you told us, I believe, that -- 14 and in any event, I understand that one of them will tell 15 us, that -- that the two (2) persons from St. John's who 16 went to accompany the trailer, were to act under the 17 direction of the Ontario Provincial Police; is that 18 correct? 19 A: They -- to provide -- they were -- 20 when they went, they -- we were to provide fuel for the 21 unit, to check the -- the generators and that and to 22 refuel the tanks when as required. And that was done on 23 the request of the OPP when the fuel was running low.

1 Q: And were there any restrictions, sir, 2 that you gave them, as you set them on this duty? 3 Did you -- did you caution them they 4 shouldn't think of themselves as police officers, they 5 should just do the specific job, they shouldn't get 6 involved as police officers; anything like that? 7 A: Oh, yeah, yes, very much so. They -- 8 and they were quite aware that they weren't around the 9 actual vehicle, they were back away from the vehicle, so 10 they were set aside from the actual operation. 11 Q: Now, you told us that Inspector 12 Carson attended London about a week before the vehicle 13 was sent in order to make a request that you provide the 14 vehicles -- 15 A: Yeah -- 16 Q: -- and that he inspect them; is that 17 correct? 18 A: A week, a week and a half. 19 Q: Week, week and a half, yes. 20 A: Yes. 21 Q: I'm not worried about the precise 22 date, but I am interested in what he told you they were 23 required for, more specifically.

1 Did he -- he told you that there was going 2 to be some operation involving First Nations people in 3 this area; is that correct? 4 A: What -- no, he said they were 5 expecting to have to provide facility that they could 6 work in, do their paperwork, provide communications and 7 what would we have available. 8 He looked at two (2) different units; 9 actually three (3) different units of -- we got a smaller 10 type of van that has a desk in it and so on and so forth. 11 So, it was more or less a location that 12 they could put out into the field and be able to work out 13 of, to do their paperwork and to provide communication; 14 that type of thing. 15 Q: Yes. 16 A: That's what he sort of looked at and 17 that's what he was looking at -- 18 Q: But, he explained it was with respect 19 to some First Nations people, did he not? 20 A: I don't know if he said first Nations 21 people. He said, I believe he did say Ipperwash -- 22 Q: Ipperwash -- 23 A: -- or the --

1 Q: Yes. So he gave you the 2 understanding in whatever words he might have used, and I 3 realize it's ten (10) years later and you wouldn't recall 4 the words probably, but he gave you the understanding 5 that it was some operation to do with Ipperwash Park and 6 some policing operation with respect to that -- 7 A: Yes. 8 Q: -- is that correct? 9 A: Yes, yes, yes. 10 Q: That he anticipated, I believe you 11 told us yesterday, he anticipated such an operation being 12 required sometime but he wasn't sure when and where? 13 A: He wasn't even sure it was going to 14 come to fruition. 15 Q: Okay. 16 A: He just said if -- if this something 17 materialized would we be able to assist him with the 18 facility to be able to provide this office type space. 19 Q: And did you understand that it was 20 with respect to anticipated occupation of Ipperwash Park 21 or no? 22 A: No, I don't -- I can't say that, no. 23 Q: You can't recall if --

1 A: No, I can't say, no. 2 Q: You recall Ipperwash Park, but you 3 don't recall -- 4 A: No. 5 Q: -- more detail? 6 A: Yes. Well, Forest area. The 7 Ipperwash Forest area, he said. 8 Q: Now, when you were answering 9 questions for Mr. Worme yesterday, you indicated 10 something like, you were always cautioned not to speak 11 about such matters when you were involved in such 12 discussions with police officers. 13 You recall that evidence, sir? 14 A: No, I said it's always -- no matter 15 where we go -- 16 Q: Yeah -- 17 A: -- we're always cautioned, both CN, 18 fire, anywhere, that there's only one (1) speaking voice 19 and not to -- not -- if anyone is to ask, it's always to 20 be directed through the public relations person for that 21 specific entity. 22 Q: Yes, but then the -- 23 A: And he -- and Carson had spoken to

1 me, he said that I was to deal with him and any was to be 2 referred to him if there was any questions. 3 Q: Yes. But then, more specifically, 4 Inspector Carson told you something to the effect of, we 5 should keep this information to ourselves -- 6 A: Well, I think the -- the point -- 7 yes, he said that it should not be -- it should not be -- 8 it should not make -- spoken around or that if there's 9 any questions about us, it should be directed to him. 10 That's -- it's as simple as that. It's 11 not like he was saying that I wasn't -- he just -- it 12 wasn't supposed to be, you know, just bandied about, hey. 13 And that's common practice; that's a 14 caution that they always say. The police always say, you 15 know, You talk to us, you do not talk to anybody else 16 about any type of their work. 17 And that's not only police, but that's 18 pretty well anyone we deal with. You can't -- you can't 19 do that. It's got to go through one (1) person. One (1) 20 person's the boss, eh, when you get involved? 21 Q: Yes, one (1) person's boss and one 22 (1) person is spokesperson, but, sir, I would suggest to 23 you in this case, you were told specifically by Inspector

1 Carson, let's keep this to ourselves and you understood 2 that this had some particular secrecy about it, did you 3 not, sir, at the time? 4 A: No, I don't think -- sorry, no I 5 don't think so; the secrecy isn't that much. I think he 6 wanted to make sure that if anyone was questioning 7 anything that he had -- he was able to deal with it. 8 I -- I don't think there was any secrecy 9 on it. He just didn't want us to -- to direct it to any 10 other Detachment, because he was from Region (phonetic), 11 I believe. 12 And there -- there was, I think, another 13 Detachment on Exeter Road, I believe. So, there was a 14 couple of different places, so I think what he was trying 15 to tell me was to -- to direct everything to him, not to 16 -- to go through any other locations. 17 18 (BRIEF PAUSE) 19 20 Q: Sir, would you please turn to your 21 Tab 11, which is a document entitled, Anticipated 22 Evidence of Peter Harding, and it's the SIU interview 23 with you, sir, that took place on 27 September, 1995.

1 A: Page...? 2 Q: Do we -- 3 A: I'm sorry, page? 4 Q: It's your Tab 11. 5 A: My eleven (11), but page? 6 Q: Yes, I'll refer to the page in a 7 moment, sir -- 8 A: Oh -- 9 Q: -- but I wanted to ask you first. Do 10 you recall being interviewed by the SIU, an officer named 11 -- or an SIU person named Muir (phonetic), apparently? 12 A: It's getting a little murky, but I -- 13 I -- I must have been interviewed at least four (4) or 14 five (5) times -- 15 Q: Yes. 16 A: -- by various entities. 17 Q: Yes. And this one at the -- at first 18 page, it says today is Wednesday 27 September, 1995. So, 19 you would -- 20 A: I won't dispute that, no. 21 Q: You probably were interviewed by this 22 person on that day, sir? 23 A: Yes, I probably -- yes, I would think

1 so, yes. 2 Q: So, this would have been several 3 weeks after the event? 4 A: All right. Yes. 5 Q: As opposed to ten (10) years and you 6 been -- 7 A: Yes, oh yeah. 8 Q: -- would have been much better, 9 obviously. 10 Now, sir, on Page 3 then, virtually right 11 in the middle of the page, you're asked by Officer Muir: 12 "Okay. And what happened after that 13 time?" 14 And you answer as follows, according to 15 the transcript: 16 �Inspector Carson asked me if I would 17 keep this visit completely within our 18 own -- ourselves, as they were 19 expecting an operation at Ipperwash. 20 They didn't know when or where, or if 21 it would materialize, but they were 22 planning in case something did happen." 23 A: "Ourselves"; I -- in that context, it

1 means our region rather than the other policing units 2 there. And there was a London detachment on Exeter Road 3 and the regional detachment was out somewhere else, so I 4 think that not -- that's where I -- what I had meant to 5 tell the SIU, when they were talking is that what you 6 want to do is not to -- if I had to deal with them, was 7 not to these other detachments. 8 It was to the regional unit within 9 ourselves, within the unit to -- to deal with him rather 10 than units there, because there is a number of -- of -- 11 and now, today, it's even more confusing than ever with 12 the various detachments around. 13 Q: Now, you understood at the time you 14 were speaking with Inspector Carson that there was a 15 potential for violence at this incident that he was going 16 to use your vehicle for; is that correct? 17 A: I -- I wouldn't say that, no. In 18 fact, no, I thought they were, as most cases be, that 19 they were going to arbitrate and there would be -- there 20 would be nothing come of it. No one would ever have 21 guessed that that would have happened really, I don't 22 think, not -- especially the police. 23 Q: Well, sir, you were concerned about

1 the security of the people that you were sending, right? 2 A: Security of them? 3 Q: Security of your persons? 4 A: I was -- I was concerned that, like 5 in every case that we -- we put them in, that they do not 6 bother the -- the entity with -- they're serving with and 7 that they keep themselves separately from it. I'm not 8 sure with the safety of them. 9 Q: Well, sir, if you could turn, please, 10 to page 8 of the same document that you have in front of 11 you? 12 A: Page -- page 3? 13 Q: Page 8, sir. 14 A: Oh, eight (8), I'm sorry. 15 Q: Towards the -- the bottom, the last 16 entry under the name, 'Harding' on that page says: 17 "He -- I had some specific questions of 18 him [and 'him' is obviously Inspector 19 Carson from the context] and I 20 questioned him as to the security of -- 21 of our people on such an operation. Of 22 course, we always do that and we had 23 agreed that our people would not be

1 part of the overall operation with 2 exception of what it took to maintain 3 any specific unit we had there and it 4 would be a very secondary role." 5 So, evidently, sir, you did express 6 concern about security of your people? 7 A: Well, that not only means them being 8 hurt an any way. We're always concerned about heavy 9 equipment and that, no matter where we put our unit. 10 Security is -- does not mean one (1) 11 specific thing, but that they're -- they're out of the 12 way, that they have -- they're not in the way of anyone 13 specifically. Security is sort of a broad term, too. 14 Q: Now, sir, I would refer to the next 15 page of that document, the SIU interview, as well. Your 16 name appears again right in the middle of the page and 17 the answer attributed to you is: 18 "Yes, and he explained at that time it 19 was like a two-fold. The reason why we 20 had to keep the request confidential 21 and one (1) was, they weren't sure that 22 there was going to be anything -- 23 anything happen at all was one (1)

1 thing. And the other situation was 2 that if something did happen, or if 3 they did not want to give, you know, 4 second-guessing from anyone or any 5 agency. 6 So, they -- the people they wanted 7 involved, they wanted them -- indicated 8 to them directly themselves, so in the 9 applying stages that they weren't sure 10 what was going to happen so they wanted 11 it to be kept fairly quietly." 12 Now, sir, I would ask you several things 13 about your answer there. 14 It does suggest, does it not, that there 15 was a particular request about confidentiality in this 16 case as opposed to the general notion that there's only 17 one (1) spokesperson? 18 A: They wanted -- well, still it's -- I 19 refer back -- it's going back to the region. They wanted 20 to deal with the regional unit, rather than getting 21 involved with any other of the constables or any other of 22 the -- of the -- the staff, as it were, within our whole 23 area and they wanted to keep it within the regional

1 because it's their -- it was their responsibility and it 2 was their assignments. 3 Q: Now, what did this mean about 4 Inspector Carson not wanting any second-guessing from 5 anyone or any agency? 6 What did you understand that to mean, sir? 7 A: That -- they didn't want us to -- 8 they wanted -- if there was any question that we had, we 9 were not to ask any other person on the department 10 because they would not know exactly what was happening. 11 I was to go directly to him. Now, if 12 anyone else was involved with our units, our units -- our 13 search and rescue or whatever the case may be, not search 14 and rescue, but our emergency services support team, they 15 were to go directly to him. 16 In other words, if I assigned a senior 17 officer to it, he was to -- to directly deal with Mr. 18 Cars -- or Superintendent Carson. 19 Q: Sir, do you assert that that's a 20 common request also that the police or other agencies 21 requesting assistance from you say words to the affect 22 of, We don't want any second-guessing from anyone or any 23 agency?

1 A: That could've been my term. I don't 2 remember John Carson saying that. That could have been 3 my interpretation of what he told me, because I think I 4 said, a second-guessing. 5 Q: Well, sir, did you -- you do agree 6 that you would have said these words on September 27, 7 1995? 8 A: Yes I -- if they're written down, I 9 would agree that I said them, yes. 10 Q: And would you agree that what you 11 said at that time was that he explained to you, among 12 other things, that he didn't want any second-guessing 13 from anyone or any agency? 14 And that's what you said at that time; is 15 that not true, sir? 16 A: That's what I said at that time -- I 17 must have. I -- I can't remember exactly, no. 18 Q: Yes. 19 A: But, if you're asking me now to 20 interpret what I suggest at that time, I'm -- I'm asking 21 -- just saying to you that that meant that we were not -- 22 we're to go directly to him. We weren't to try to send a 23 unit out without having it cleared with him.

1 If we changed a unit breakdown it had to 2 be cleared with him, if we replaced a unit; I believe 3 that's what we're trying to get across. 4 Q: But, you don't recall now, ten (10) 5 years later, what you meant at that time, right? 6 A: What I meant at that time? 7 Q: When you explained to SIU that John 8 Carson told you he didn't want anyone second-guessing. 9 A: Well, I think that's quite right. He 10 didn't want -- he wanted to be -- look after the complete 11 operation and he didn't want anyone suggesting to him to 12 change what we had agreed upon. 13 Q: Now, sir, you told us something 14 cryptically yesterday that I'm not sure if I understood 15 in answering questions to Mr. Worme. You were asked by 16 Mr. Worme on page 153 towards the end of the page, and 17 then it continues on page 154, if anyone wants to check 18 that I'm reading it accurately. 19 "Question: Outside of London you 20 provided these services? 21 Answer: Yes, we do. We do on the 22 request. It has clear our Province and 23 if it goes outside of our Province it

1 has to clear on National Headquarters." 2 Now, I wanted to ask you, sir, the first 3 part of that: 4 "We do on the request. It has to clear 5 our Province." 6 What is the process for clearing our 7 Province? 8 A: I, if -- if it goes anywhere outside 9 our Province, anywhere outside my area -- 10 Q: Outside the London area that you're 11 faced with. 12 A: London to Middlesex. 13 Q: Yes. 14 A: With the exception of the corridor 15 between Windsor and Toronto, I have agreements to work in 16 that corridor because of the equipment we have. It's not 17 handled anywhere else than St. John, in the province. 18 If outside that -- the norm of our 19 operations by going to the Province I cleared -- I mean I 20 have to call the emergency service officer for the 21 Province of Ontario and tell him that our equipment has 22 been requested and that it is now being used. 23 In other words, he can't rely on it for

1 another situation might come up. 2 Q: I see. And that's an emergency 3 service officer of the St. John's Ambulance unit? 4 A: That's correct, yes. 5 Q: And so in this case when this request 6 was made, was that sufficiently out of -- was that out of 7 your area and therefore requiring such -- 8 A: No. That's -- this request was in 9 the -- within our jurisdiction between Windsor and 10 Toronto in southwestern Ontario. And that was -- we 11 responded on 12 that -- 13 Q: So, you did not have to seek anyone 14 else's permission or notify anyone else in order to 15 dispatch this vehicle? 16 A: No, but we did. 17 Q: But you did? 18 A: Yes. 19 Q: I see. And who -- who did you re -- 20 A: We notified our emergency service 21 officer that our equipment was being used. 22 Q: I see. 23 A: When it was dispatched. Not -- not

1 prior to it -- 2 Q: Yes. 3 A: -- but when the equipment went out 4 the door and we said now it's -- it's being used and it's 5 not available to anyone else. 6 Q: And after the events that transpired 7 -- did transpire with respect to this, was there any 8 discussion at higher levels of how your vehicle had been 9 used on that occasion, within St. John's Ambulance 10 Service? 11 A: Yes, there was. 12 Q: And can you tell us about that, sir? 13 A: Well, of course I had to -- to submit 14 a report on the whole operation and, of course, that's -- 15 report was regarding the damage and there was a number of 16 meetings in reference to it. 17 Q: And was there any conclusion about 18 whether it was appropriate to deploy the vehicle in these 19 circumstances, whether there should be any cautions in 20 future or anything like that? 21 A: They ask or they rely on every 22 officer within the -- within the structure to be able to 23 -- be able to make a judgment to when to respond units,

1 and there is very little time that we wouldn't respond a 2 vehicle. 3 I mean, I can -- when we sent these five 4 (5) units to Nyann (phonetic) in Quebec for five (5) 5 weeks, that was a very dangerous situation and, you know, 6 if I was looking at -- you know, I wouldn't have gone if 7 I -- if I was concerned about danger or not -- of losing 8 some equipment. 9 It could happen any time and in any 10 situation, but I'm not -- I don't know what you're 11 driving at in regard to... 12 Q: Now, you told us yesterday and, to a 13 naive person like me and, I would assume, to other naive 14 people, it seems odd that you were concerned about the 15 possibility of your vehicles being used for ambulance 16 services, because there are restrictions on that, and you 17 weren't concerned about them being used for non-ambulance 18 services. 19 But, getting to the restriction on 20 ambulance services, you -- you understood, you told us, 21 that there were no other ambulances available, is why the 22 St. John's ambulance was pressed into service with 23 respect to Cecil Bernard George; is that correct?

1 A: Well, I -- you have to -- you have to 2 question the people onsite. On the report that I 3 received and on the brief -- debriefing, I understood 4 that at the time that our unit has -- was asked to 5 request to be of help to Mr. George, was when they had 6 been standing by. 7 One (1) vehicle left, a second vehicle 8 left, because they had two (2) Ministry ambulance units 9 standing by there; obviously they had been sent out on 10 call somewhere. And then we were then asked to assist 11 when Mr. George came up. 12 Q: Yes. And it was your understanding 13 that there were no other Ministry ambulance vehicles 14 available, and that's why you were called upon to assist; 15 is that correct? 16 A: All I can say, there was none there. 17 There was none right, physically -- 18 Q: Yes. 19 A: -- at this location. 20 Q: And if there had been Ministry 21 ambulances available nearby, then they should have been 22 utilised rather than your ambulance; is that correct? 23 A: If they had have been there, they

1 would have been probably used, yes. Well not probably, 2 they would have been used. 3 Q: And should have been? 4 A: Yes. 5 6 (BRIEF PAUSE) 7 8 Q: Now, you spoke to Inspector Carson, 9 also, after the incident at Ipperwash Park on September 10 6th; is that correct? 11 A: That's correct. 12 Q: And what explanation did he give you, 13 sir, for having left your equipment in the Ministry of 14 Natural Resources parking lot? 15 A: He explained to me that the officers 16 had to leave. And I'm trying to figure out his way -- 17 how he put it; I didn't -- I didn't review that. 18 He had a -- they had to leave and they had 19 to also leave some of their equipment at the same time, 20 and they had to leave in a -- in a hurry, type of thing. 21 I'm just -- can't remember the word he 22 used, but they left in a hurry. 23 Q: I see. And did he -- did he indicate

1 at what time that was, in relation to the killing of 2 Dudley George? 3 A: No. 4 Q: Was it right after, did he say, or 5 some other point? 6 A: No, he didn't -- he didn't emphasize 7 any time specifically, just that it had happened. And, 8 see, prior to that he called me and asked me to come up 9 to see him. I was in London and he asked me to come to 10 Forest to see him and I came to Forest and that's when he 11 explained to me what happened. 12 And then he just went on to explain of -- 13 that the equipment was still not returned and that they 14 would keep us informed of what was happening. 15 Q: At the time you had this 16 conversation, you knew and it was evident to you that 17 Inspector Carson knew, that Dudley George had been 18 killed; is that correct? 19 A: I'm trying to think back. I -- I'm 20 assuming I knew with that -- that -- I probably didn't 21 know that. 22 Q: Yes. 23 A: I --

1 Q: Well -- and you also certainly knew 2 that Cecil Bernard George had been badly beaten because 3 you had had the debriefing with Ms. Bakker? 4 A: I knew -- I knew that, yes. 5 Q: And you -- had you, perhaps, heard 6 that some other people had been injured as well or no? 7 A: No. No. 8 Q: Okay. So, in your discussion with 9 Inspector Carson after the event, did he give you any 10 information about what had happened with respect to 11 Dudley George -- 12 A: No. 13 Q: -- and your -- Mr. Cecil Bernard 14 George? 15 A: No. 16 Q: No? 17 A: No. 18 Q: That wasn't discussed? 19 A: No. 20 Q: Did he explain to you why the Ontario 21 Provincial Police had marched on the Park at night time? 22 A: No. 23 Q: Did he indicate to you in any way

1 that there was political pressure surrounding the OPP 2 activities on that occasion? 3 A: No, he didn't at all. 4 Q: Were you aware of such allegations 5 from any source, sir? 6 A: Not until quite a while after, I -- 7 only reading the papers and that I was able to see there 8 was some concern. 9 Q: Now, you told us, I believe 10 yesterday, that Inspector Carson was very concerned about 11 how the damage to your vehicle would affect the whole 12 community; is that correct? 13 A: Well, as -- as far as being of 14 service to, if it was needed again for something else, he 15 was concerned. He was concerned about the damage to the 16 equipment and not being available if -- if anything 17 happened and they would try to alleviate that as soon as 18 possible. 19 And, he didn't know anything about the 20 damage at the time, I don't think, when I was talking to 21 him because we hadn't even gotten it back yet. I don't - 22 - I mean, I'm not sure, because I'm not sure if he said 23 anything about the damage, he just said the equipment was

1 -- was at the Park and they did not have it back. He 2 never really emphasized much damage on the equipment at 3 that time. 4 Q: I see. Did he express to you any 5 concern about how the killing of Dudley George might 6 affect the community? 7 A: No. No, he -- he never -- he never 8 mentioned anything to me about anybody at all other than 9 our part. 10 Q: Did he, in any way, suggest to you 11 any regret about the way the OPP operation had taken 12 place? 13 A: I'm not so much sure he said it, I 14 think he was -- I think he was disappointed that -- that 15 it all unfolded the way it did. 16 I think he was surprised it unfolded the 17 way it did to a certain degree. You could almost see it 18 -- the way when he was sort of halfway apologizing that 19 we didn't have the equipment and that, that he was -- he 20 was surprised and I think he was taken aback and I think 21 he was concerned. I don't know how to put other than 22 that. He wasn't -- he wasn't his cheerful self, anyway, 23 I'll tell you that right now.

1 MR. PETER ROSENTHAL: Your indulgence, 2 Mr. Commissioner. Thank you, Mr. Commissioner. Thank 3 you, sir. 4 COMMISSIONER SIDNEY LINDEN: Thank you 5 very much, Mr. Rosenthal. 6 Mr. Scullion...? 7 8 (BRIEF PAUSE) 9 10 MR. KEVIN SCULLION: I can say, Mr. 11 Commissioner, I have a new found appreciation for my 12 fellow Counsel over the past eight (8) months, as I 13 follow along the cross-examinations and made a couple of 14 checkmarks on my notes, but I'll try to keep close to my 15 time estimate, although it may be a little disjointed. 16 17 CROSS-EXAMINATION BY MR. KEVIN SCULLION: 18 Q: Superintendent Harding, as I've 19 listened to your evidence, it's clear to me that you're 20 quite proud of the St. John Ambulance organization. 21 You've been there with -- for thirty-two 22 (32) years; is that fair to say? 23 A: Thirty-five (35) getting close to,

1 now. 2 Q: Thirty-five (35) now. Okay. Back in 3 '95, you'd been around twenty-five (25) years, then, with 4 the St. John? 5 A: Yes. 6 Q: Okay. And you had significant 7 experience from your days as Chief of the London Fire 8 Service? 9 A: Experience in what? 10 Q: I guess in all kinds of life saving 11 techniques and -- and situations? 12 A: Community response and overall EMS, 13 yes. 14 Q: Okay. 15 A: Yes, I think so. 16 Q: You'd agree with me that this was a 17 fairly extraordinary situation or it turned into an 18 extraordinary situation? 19 A: It did, to say the least. 20 Q: Okay. I've -- I've been proceeding 21 on the assumption that you are ultimately responsible for 22 the St. John Ambulance vehicles being in this parking lot 23 and assisting the OPP; is that -- is that fair or did you

1 report to somebody else? 2 A: No, I was ultimately responsible. 3 They -- I have a certain amount of leeway and 4 flexibility in -- in -- in issuing the units and that, 5 yes. 6 Q: Okay. 7 A: I was totally responsible. 8 Q: But, the decisions were ultimately 9 made by you after you received phone calls from, I guess, 10 initially it was somebody from the OPP and then you 11 consulted with Superintendent Carson? 12 A: I was contacted once. I believe it 13 was one of the corporals I believe, and I didn't mark the 14 name down, and he said that Inspector Carson, we can 15 contact in the -- in that -- there wasn't any other 16 discussion. They just if you want to talk, where could 17 he get a hold of me that was all. 18 Q: Right. It was just a contact person. 19 They set up a meeting with you and Superintendent Carson. 20 And that was about a week, week and a half beforehand 21 from what I've heard? 22 A: Yeah I -- 23 Q: I'm not looking for the exact.

1 A: -- between a week and a week and a 2 half, yes, roughly. 3 Q: Okay. Is it fair to say that when 4 you met with Superintendent Carson, he indicated to you 5 that they expected something to happen the week of 6 September 4th in the Ipperwash area? 7 A: He -- he indicated to me that 8 something happened. He -- I'm not sure if he said that 9 there was going to be something happening. He wasn't 10 sure if they were going to be involved in a response to 11 that area and how -- the size of the response would be; 12 if that's a way to put it. 13 He wasn't sure of yes or no, if it was 14 going to happen, it wasn't going to happen, but there was 15 something afoot. That's all I can say. 16 Q: Okay. Just to be clear. You had a 17 discussion with Superintendent Carson when he came to 18 visit and take a look at your equipment, the trailers -- 19 A: Yes. 20 Q: -- and you had a discussion with 21 Superintendent Carson after the incidents of September 22 6th? 23 A: That's correct.

1 Q: Did you speak with him between those 2 two (2) time periods? 3 A: Only on telephone. He called me and 4 -- and said -- asked me to -- to attend in Forest; that 5 was after the incident happened. 6 Q: Okay. 7 A: And he explained that he had some 8 equipment problems. 9 Q: Okay. I'm -- I'm just trying to 10 clarify. So, before the vehicle -- or before you 11 received a call to move the vehicles September 4th, you 12 met with Superintendent Carson? 13 A: At our station, yes. 14 Q: -- right. You walked him through 15 your equipment, he picked the one that he preferred -- 16 A: Yes. 17 Q: -- which is what we've now seen as 18 four four four (444)? 19 A: Right. 20 Q: After that point in time you didn't 21 speak with Superintendent Carson, specifically, up until 22 after the September 6th incident? 23 A: That's correct.

1 Q: All right. You received a call from 2 somebody on September 4th saying that what they had 3 expected to occur was now occurring and they needed your 4 assistance? 5 A: They asked us to attend. And I said 6 Forest yesterday and I'm mistaken. 7 We were sent to a checkpoint. It was out 8 of Forest, the checkpoint was supervised out of Forest, 9 and to meet an officer; I believe it was an NCO. And the 10 NCO would take the vehicle into that location, but they 11 had to go to a checkpoint first. 12 Q: Okay. But, that wasn't 13 Superintendent Carson who called you at that point. 14 A: No. No. 15 Q: It struck me as curious, you 16 mentioned today in response to one of the questions, I 17 believe it was from Mr. Rosenthal, that you thought they 18 were going to arbitrate. And that's what I noted from 19 your evidence this morning that they were going to 20 arbitrate. 21 I suggest to you that when you spoke with 22 Superintendent Carson, when you walked him through the 23 vehicles, he indicated to you that he expected there to

1 be a peaceful protest of the Ipperwash Provincial Park 2 and he thought it might happen after September 4th. 3 A: Yeah. That's what he suggested. I 4 mean he asked -- that's sort of the an inference. And he 5 wanted the equipment for good communications and that 6 they wanted sort of an office advance type of office 7 where the -- where the protest was happening. 8 And now we use "protest," he didn't use 9 the word "protest." I think he -- he used demonstration 10 or something like that or -- but I can't tell you, 11 exactly, the wording. 12 Q: No I understand. A protest, 13 occupation, demonstration. But, he used something along 14 those lines and said it's going to be a peaceful 15 occupation of the Park and that they -- they needed your 16 assistance and he picked out 444 Trailer? 17 A: Yes. And then he wanted a place they 18 could work out of, like office and communication space. 19 Q: Sure. And if I understand you 20 correctly, you understood this to be your -- your trailer 21 would be used as their advance location and that they 22 would have a far more sophisticated or larger trailer or 23 operation that would be located presumably in Forest or

1 back from where your advance position would be? 2 A: Well he didn't go -- he said that 3 they had -- he didn't have any plan at this -- this -- it 4 was going to be an advance situation to them and that if 5 it unfolded, there would be -- we didn't know and I 6 didn't know that they did have a command -- a large 7 command unit. 8 And he indicated to me when we were 9 talking that there was a -- if anything unfolded that 10 this would be used also and I don't think he mentioned 11 where it was going to be or anything like that. I know 12 where it eventually ended up was in Forest. 13 Q: Right. On September 4th they 14 indicated where they needed yours to go. 15 A: Yeah. Well they -- they said they 16 would direct it to where they wanted it to do. 17 Q: Somebody would take you but you 18 understood it would be in the general vicinity of the 19 Park? 20 A: Well, we weren't sure that -- before. 21 Prior to that, no, they said in the Forest/Ipperwash 22 area. 23 Q: Okay, just generally?

1 A: Yes. 2 Q: All right. He didn't 3 specifically you were going to be an advance unit close 4 to the Park or in the Park? 5 A: No, no, no. 6 Q: All right. Is it fair to say that 7 when he was discussing this with you, you understood it 8 would be simply a communications situation; you were just 9 providing support for their communications? 10 A: Communications and office space 11 availability to conduct business type of things, yes. 12 Q: Right, to add on to what they already 13 had? 14 A: Yes. Correct, yes. 15 Q: And if I understood you correctly, 16 you now say that they have a fifth wheel of their own 17 now, kind of mimics what you had back in '95? 18 A: I think they may have a couple of 19 them, but yes, almost the same type of unit. 20 Q: Okay. Your understanding was they 21 didn't have that back in '95 and they needed to borrow 22 yours for this purpose? 23 A: No, they didn't have. No, they

1 didn't it have because it just came out after -- 2 Q: Okay. There was some question this 3 morning about security of your people and I understood 4 your evidence to be that simply your general 5 understanding or generally you like to look out to see 6 what they're doing, how they're doing it, and -- and 7 what's going to happen as opposed to making sure they're 8 not going to be shot or part of an incident? 9 A: Well, it's not only that, but 10 depending on wherever we go, for instance, if we're with 11 the Railway, we sure don't want them on track line with 12 the heavy equipment unless they're, you know, they're 13 protected, too, to make sure that -- we don't want to put 14 them in harm's way in any way, shape or form. That's 15 all. 16 Q: Okay. And that's how you were using 17 the term "security" at the time? 18 A: Yes. 19 Q: All right. Yesterday there was a 20 booklet made in Exhibit P-339 that seemed to set out a 21 protocol. 22 A: Yes. 23 Q: Do you need to take a look at that or

1 do you know it fairly well? 2 A: No, I think I -- I think I know. 3 It's changed now. The protocol's changed a little bit, 4 but I -- I think I can remember back. 5 Q: Well, I noticed that you wrote it, so 6 I assume that you knew it pretty well. 7 A: Yeah, well, I can remember -- I think 8 I remember the changes. 9 Q: Okay. My impression from that 10 protocol was, it has to do with situations where you're 11 called in for medical assistance or other kind of 12 assistance as opposed to simply providing this 13 communication system? 14 A: Yes. The -- they can ask for 15 whatever they wish. If -- you noticed in the protocol 16 there's a list of -- of seven (7) -- five (5) different 17 areas -- areas of -- rehabilitation, canteen, heavy light 18 generators, communications; there are various areas of 19 responsibility. 20 Q: Right. 21 A: And the protocol follows any one of 22 those responsibilities, say. So, in other words, if 23 anyone wanted -- see, that book is usually at all of the

1 communication centres within our area. 2 And what happens there with that book is 3 that they are able to look through it and find what 4 service or what they may require. They look at the 5 equipment that they may want and then they'll go through 6 the procedure in notifying us. 7 Q: Okay. And the protocol is the 8 general process that you look to your personnel to follow 9 so you can keep track of their requests, what the 10 response is, what the result is and any debriefings 11 afterwards? 12 A: That's correct, yes. 13 Q: All right. And my comment was that I 14 didn't see anything specific to the provision of the 15 communications unit. I'm assuming that's done on a 16 little more of an ad hoc basis. 17 There isn't as much paperwork that goes 18 with that type of request? 19 A: There is now. The communications 20 unit -- you mean it's not listed in there? 21 Q: It's not. 22 A: Well, it is now. 23 Q: All right. So, it's changed?

1 A: In the new -- the new -- that was -- 2 Mr. Worme asked me for the original units, you notice the 3 cresting is not on the vehicles or anything else, either, 4 in that. And that was the original protocol book we had. 5 The one now has got the communications 6 listed and -- and, I believe, one (1) more 7 responsibility. SARS is also listed now, too, which 8 wasn't in that book. 9 Q: Okay. All right. So, that's changed 10 since 1995? 11 A: That's correct, yes. 12 Q: We -- we were focussed in 1995. 13 A: Okay. 14 Q: That's why all these requests have 15 been made for the '95 period. We're trying to see what 16 was in place at that point in time. 17 A: All right. 18 Q: So, is it fair to say that there was 19 no note or no log book in effect back in 1995 where you 20 would make a note say, I was called by so-and-so for the 21 following purpose for the communications vehicle? 22 A: Yes. Well -- no, when I was called 23 originally, you mean for the first interview?

1 Q: Yes. 2 A: No. 3 Q: Okay. 4 A: I didn't log that. The only -- the 5 log would start for that vehicle when the second call 6 came for the unit to respond. 7 Q: Right. 8 A: Then the time would be marked down 9 and who called and then it would follow on from that 10 point. 11 Q: All right. So, you didn't log the 12 first call, you didn't log the visit by Superintendent 13 Carson, only when you got called on the 4th and the 14 vehicle was arranged to travel? 15 A: That's correct, because it was not 16 even -- at the time, we didn't even know it was going to 17 be a fact. 18 Q: Okay. 19 A: It was just suspecting the incident. 20 Q: Fair enough. On the 4th, when you 21 were called, you still thought this was a simple, 22 straightforward request for a communications system that 23 would be assisting the OPP in whatever they were doing in

1 the Ipperwash area? 2 A: That's correct, yes. 3 Q: And your vehicle responded, it had a 4 police escort and they took it where it needed to go? 5 A: Once it reached the checkpoint, yes, 6 then they escorted it to where it had to go. 7 Q: Okay. Were you involved at all in 8 this particular operation after, or from September 4th up 9 until the call after the September 6th incident? 10 And I'll be more -- 11 A: I was not involved. Once that unit 12 left London, I was not -- I had a senior officer involved 13 from that point on to -- when the equipment was lost. 14 The next time I became involved was when I received a 15 phone call to attend at Forest, and then I became 16 involved with seeing Inspector Carson and listening to 17 what happened and -- 18 Q: I'll -- 19 A: -- then receiving -- 20 Q: -- I'll get to that in a -- 21 A: Okay. 22 Q: -- in a little bit. 23 A: Okay, sorry.

1 Q: So, you didn't receive any phone 2 calls, I understand, on the 4th, 5th or the 6th up until 3 the one we're now speaking of -- 4 A: No. 5 Q: -- and who was the senior officer 6 that was in charge of the area for you? 7 A: Paul -- Paul Harding. 8 Q: That's your son? 9 A: Yes. 10 Q: All right. Would he be in constant 11 contact with the people that were manning the service of 12 this communications centre? 13 A: Yes, he had been there since its 14 placement. The unit was placed in position and he left 15 the location because it was very quiet and it was -- they 16 were expecting no problems whatsoever. 17 He went back and changed shifts for the 18 next day and went -- came back to London for some rest. 19 Q: Okay. Let's go through that in 20 pieces. You say that he left the area; I'm assuming 21 that's on September the 6th? 22 A: No, he took the unit in, I'm just -- 23 I haven't got the dates here, he took the unit in and I

1 think by the time they got it placed, it was being close 2 to midnight, it was 11:00 -- 11:00 at night, it was very 3 late in the night. 4 Q: Yeah. Let me help you with the 5 dates. Your evidence and notes that we have indicate 6 it's around midnight, 12:30 the morning of September the 7 5th, the Tuesday. 8 That's when it arrives -- 9 A: Arrived at site -- 10 Q: -- and was put in place. 11 A: Yes. 12 Q: All right. So Paul Harding is in 13 charge of that -- 14 A: The unit -- 15 Q: -- operational unit -- 16 A: -- at that time. 17 Q: -- and he sits-- 18 A: He was there all day, pretty well. 19 Q: All right. 20 A: And he would be there for some time 21 and then he made arrangements for a replacement of crews. 22 Q: Okay. 23 A: He returned, as it was all quiet.

1 They were expecting -- it was pretty normal and there was 2 no problem. He came back to London for a rest and the 3 crew -- other crew went up and changed places. 4 Q: Okay. So, that takes us into 5 September the 6th. When does the next crew change place, 6 or change positions? 7 A: I'd have to -- I haven't got that 8 right here, but I believe that that would be when Bakker 9 and -- and -- Bakker came on duty and the other chap, the 10 driver. 11 Q: Okay. And do you recall when that 12 shift change would have occurred -- 13 A: No. 14 Q: -- when Bakker -- 15 A: Not right here, no. 16 Q: Would you have a log book that would 17 indicate when that change occurred? 18 A: Yes, there should be -- the SIU had - 19 - had the log books and that. 20 Q: Okay. 21 A: It should be in their report 22 somewhere. I'm pretty sure that they -- because I wasn't 23 there, so I don't know exactly when -- when it happened.

1 Q: No, I understand. I'm just trying to 2 get your information from what was reported back to you. 3 So, Paul Harding didn't attend on the 6th 4 in the area, September 6th? 5 A: No. 6 Q: All right, so Bakker and I believe it 7 was Morgan -- 8 A: Chris -- yes, Morgan. 9 Q: Morgan the driver, come on shift, but 10 you don't know at what point in time that is in the 11 evening of the 6th? 12 A: I believe they reported to one (1) 13 location and they were held for a few minutes and then 14 they went to the other location. They had to check in at 15 a checkpoint or in Forest; I'm not too sure which one 16 that was now. 17 Q: Okay. 18 A: I can't recall that. 19 Q: I'm just looking -- 20 A: I'm sure I was told, but I can't 21 recall now. I can't tell you for sure. 22 Q: I'd like to look at the process. 23 They checked in with the OPP, then they went to the

1 location -- 2 A: Yes. 3 Q: -- where the vehicle was? 4 A: Anytime -- anytime the crews were 5 coming or going, they always had to go through a 6 checkpoint and check with the OPP. 7 Q: All right. And they were there for 8 simple support? 9 A: They were there, they had -- they 10 took up a second medic unit, that's what they were 11 travelling in. But, they parked the medic unit to take 12 over the -- the tender unit that was there with the gas 13 and diesel and all that equipment in it. 14 Q: Okay. So, when they arrived there 15 was three (3) St. John Ambulance vehicles there -- 16 A: Yes. 17 Q: One (1) was the main trailer that was 18 being used by the OPP? 19 A: Trailer and tractor, yes. 20 Q: Trailer and tractor, the truck part 21 had been parked off to the side. 22 A: Yes. 23 Q: Then there's the tender unit which --

1 A: The tender unit, yes. 2 Q: -- that carries the gas and the 3 replacement parts -- 4 A: That's right. 5 Q: -- anything that they need to fix 6 what's happening with the trailer? 7 A: Yes. 8 Q: And then you've got the medic unit 9 that they drove there in? 10 A: That's correct. 11 Q: And if I understand your evidence 12 yesterday, you said that: 13 �We didn't go near the trailer unless 14 we were called upon by the police.�? 15 A: That's correct. Once -- once they 16 started their work, no matter what is, we -- I mean 17 people want to be able to conduct their business and -- 18 and we don't get involved in that unless we are asked to 19 look at something specific. 20 Q: Okay. 21 A: And that's gas and that type of 22 thing. In fact, they set up a routine, I believe, where 23 -- how they were to be contacted with the person in

1 charge of the vehicle -- 2 Q: All right. And -- 3 A: -- when the gas came down and that 4 type of thing. 5 Q: That routine was recorded in a log 6 for the individuals being -- 7 A: No, it's recorded on -- if you saw 8 the photos from the SIU or the involved in 9 investigations, it was recorded on a white board on the 10 vehicle -- in the vehicle. 11 Q: On or in the vehicle? 12 A: In the vehicle. 13 Q: All right. 14 A: The information was recorded there 15 for -- there's various types of information; one was 16 where to get a hold of us, how to get a hold of us, what 17 time the gas and oil were changed last, et cetera, et 18 cetera. 19 So, they kept a log on -- on this white 20 board within the vehicle. Then they had other numbers 21 for other business that they had. 22 Q: All right. The OPP kept track of 23 what needed to be done according to their log board and

1 your individuals remained outside in the tender vehicle? 2 A: Yes. And they were set over in an 3 area, you'd have to get exact area from them, but 4 apparently there was two (2) ministry ambulance units and 5 some other equipment stationed in the same location, away 6 from the trailer park itself -- or away from the command 7 and communications unit, itself. 8 Q: Okay. And this trailer was powered 9 by one (1) main 7,000 Watt generator; is that correct? 10 A: That's correct. There is a gas 11 generator on the vehicle. There's a second vehicle, but 12 it's not a backup. It doesn't start automatically, you 13 have to start it. But you also have to have gas in the 14 main tank to be able to start the second generator. 15 Q: And the main tank, from what I 16 understand, ran both of these generators? 17 A: Yes. 18 Q: So, if you ran out of gas, not only 19 did the main generator go, but so did its backup. 20 A: Well, you couldn't start the backup 21 generator. The backup generator is only if the main 22 generator goes down for some mechanical reasons. 23 Q: Okay.

1 A: The gas -- it's a fairly big tank. 2 It's a very big -- fairly big tank on the unit. 3 Q: How long would that tank last for 4 that unit, on average? 5 A: A good six (6) hours or more. No, it 6 would be a good eight (8) hours. 7 Q: So six (6) to eight (8) hours this 8 gas tank would -- 9 A: Depending on how -- depends on what 10 they're using it, too, ow much power they're using, 11 because it -- it begins to fluctuate; the generator goes 12 into heavier working mode. 13 Q: All right. But, minimum six (6) 14 hours and up to eight (8) hours -- 15 A: At least, yes. Between six (6) and 16 eight (8) hours. 17 Q: All right. And when this power went 18 out on the main generator, would all the lights go out, 19 all the communications go out in the trailer? 20 Is that the effect of losing -- 21 A: If the power -- 22 Q: -- power? 23 A: -- if the power from the generators -

1 - if the generators stopped for any reason, then all the 2 power in the -- the trailer would go out, unless they had 3 a shoreline. 4 Q: Unless they had a shoreline? And 5 from your knowledge of this situation, they didn't have a 6 shoreline? 7 A: No, not that I -- 8 Q: You weren't aware of one? 9 A: No. 10 Q: So, it would