Benjamin D.

Tinholt
Barrister & Solicitor
Tel: 226.921.8998
Fax:226.240.9144
benjamin @ti n holts.com
File No.: 00020

September 17, 2019

Monique Ghoiselat

3J 1T5
outlook. com

Yogi Henderson
3723 Porlage Avenue
Winnipeg, Manitoba R3K 2A8

The Honourable Steven Fletcher, PG

3224 Portage Avenue
Winnipeg, Manitoba R3K 0Y8

People's Party of Ganada

290 St-Joseph Blvd, office 205
Gatineau, Quebec J8Y 3Y3
Fax: (819) 205-2383
ATTN: The Honourable Maxime Bernier, PC MP

Via REGISTERED MAIL, EMAIL and FAX: 1 (819) 205-2383

Dear Ms. Choiselat, Mr. Henderson, Mr. Fletcher, and the People's Party of Canada:

Re: Notice of Intended Action

My Client: Omar Kinnarath

I have been consulted by Oumer "Oma/' Kinnarath with respect to defamatory and invasive social
media posts dated July 23, 2019 by agents, employees, representatives and members of the
People's Party of Canada (hereinafter, the "PPC").

22 King Street South Suite 300, Waterloo, Ontario N2J 1N8 Ganada www.tinholts.com
On July 23,2019, the Twitter account "PPC Winnipeg Centre" (@PPCWpgCntre) posted online
a colour photograph of Mr. Kinnarath's face with the word "TERRORIST" beneath it, surrounded
by the following words:

Terrorism is not Free Speech. Just saying. THIS lS THE TERRORIST'S DETAILS:
[Mr. Kinnarath's name, home address and phone number] This terrorist shut down our
Rally to introduce our PPC Candidate by ruining online the little woman who was renting
us our venue. He called this activity, "Free Speech" Definition of terrorism: the
systematic use of terror especially as a means of coercion [slc]

On July 23,2019, PPC Winnipeg Centre Chief Executive Officer Monique Choiselat posted the
same picture and text to her Facebook account.

ln a July 24, 2019 article by Carol Sanders published by the Winnipeg Free Press headlined
"People's Party of Canada calls anti-racist a 'terrorist' after gallery cancels political rally", PPC
Winnipeg Centre candidate Yogi Henderson was described as equating Mr. Kinnarath's conduct
with the "extreme views" expressed by Ms. Choiselat.

In the same article, the author states that PPC Charleswood-St. James-Assiniboia-Headingley
candidate The Honourable Steven Fletcher, PC

contacted the Free Press to defend the post. 'The original sin is this person (Kinnarath)
threatening a free and democratic activity and a business," said Fletcher "What is ironic
is this group (Fascist Free Treat 1) calls themselves fascist-free yet what they're doing
is exactly what fascists do.. using severe bully tactics to prevent free and democratic
activities,' he said.

On August 30,2019, members of the PPC accosted Mr. Kinnarath at his place of business and
harassed him.

The above Twitter and Facebook posts, including and in particular their direct allegations of
terrorism, are false and defamatory. The above statements of Steven Fletcher and Yogi
Henderson as reported in the Winnipeg Free Press are endorsements and repetitions of the
defamatory statements and constitute the tort of slander. The conduct of Ms. Choiselat, Yogi
Henderson, and Steven Fletcher amounts to a very serious defamation of Mr. Kinnarath for which
the PPC and its leader, The Honourable Maxime Bernier, PC MP are vicariously and otherwise
liable.

Fudher, the conduct of Ms. Choiselat constitutes the tort of invasion of privacy for which the PPC
and Mr. Bernier are also vicariously and othenruise liable.

Further, the above conduct amounts to the tort of intentional infliction of mental suffering.

Mr. Kinnarath has suffered and will continue to suffer serious damage, including visible and
provable injury, as a result of the above libel, slander, invasion of privacy, and intentional infliction
of mental suffering.

I have been instructed to request that you submit immediately to me in draft a clear and unqualified
apology and retraction for publication in an equally conspicuous position on the PPC's relevant
Twitter and Facebook pages, as well as clear and unqualified apologies from Mr. Henderson, Mr.
Fletcher, and Mr. Bernierto be published in theWinnipeg Free Press.

Further, having regard to the seriousness of the allegations made, the high number of followers \l
of the PPC's relevant Twitter and Facebook accounts, and the wide readership of the Winnipeg
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