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Their "statement as to docs" is sloppy and relates to unnumbered pieces of paper in boxes gathering dust

They have been charging plaintiff Richard Klassen .25 per page to sort it out for them!

If you are new to this story, we recommend you go back to the map and read the background material. This material was compelling enough to engage the interest of fifth estate producers Harvey Cashore and Howard Goldenthal who used it as the basis for the prize-winning show Scandal of the Century. The show has been aired several times and each time it is shown, we receive many e-mails supporting our fight to get the story to the public and agreeing the wrongly accused should receive large exemplary damages.

Ed Holgate, lawyer for the plaintiffs in QB 271 has had in his possession the following lists since 1995. He did not show the material to the plaintiffs

This material would have been helpful to fifth estate as well.

The cover-up in this case is almost unbelievable. Dueck is now the most powerful cop in the Saskatoon Police Service, having risen to his present position almost entirely on the strength of his "work" on the Scandal of the Century, the case he named when he first held a press conferece to announce he had rounded up members of a generational satanic cult.

Most of this material is properly part of what should have been the Crown's disclosure package when the innocent accused were first charged.


Dueck's Statement as to Documents | Prosecutors' Statement as to Documents

Prosecuters statement as to documents, June 7, 1995

FIRST SCHEDULE
PART ONE

SHOWING DOCUMENTS IN THIS DEFENDANT'S POSSESSION WHICH THESE DEFENDANTS DOES NOT OBJECT TO PRODUCE:(SIC)

1. A memo from Transcript Services to Matthew Miazga dated January 16, 1992 and six volumes of transcript of the preliminary hearing respecting Donald Leo Ross, Helen Susan Ross and Donald George White conducted in Provincial Court in Saskatoon November 21, 25, 27 and 28 and December 2, 1991.

2. A letter from C.V. Reporting Services Ltd. attaching a one volume transcript of the evidence of Dr. Zilla Ann Parker given Oct. 13, 1992 in the criminal trial of Donald Leo Ross, Helen Susan Ross and Donald George White.

3. Twenty volumes of transcript of the criminal trial of Donald Leo Ross, Helen Susan Ross and Donald George White which commenced Oct. 29, 1992.

4. Transcript of the judgment of Justice Batten dated December 18, 1992 in criminal trial of Donald Leo Ross, Helen Susan Ross and Donald George White.

5. The transcript of the proceedings March 17, April 2, 19 and 20, 1993 in the criminal trial of Donald Leo Ross, Helen Susan Ross and Donald George White.

6. A copy of the transcript of proceedings a judgment held Aptril 19, 1993 in the criminal trial of Donald Leo Ross, Helen Susan Ross and Donald George White.

7. A copy of a letter from Saskatchewan Justice to counsel for Donald George White dated Dec. 9.

8. A copy of a letter from Saskatchewan Justice to counsel for Helen Susan Ross dated Dec. 9.

9. A copy of a letter from Saskatchewan Justice to counsel for Donald Leo Ross dated Dec. 9.

10. A copy of the Court of Appeal factum filed on behalf of Helen Susan Ross.

11. A copy of the Court of Appeal factum filed on behalf of Donald Leo Ross.

12. A copy of the Court of Appeal factum filed on behalf of Donald George White.

13. A bound book of authorities filed with the Court of Appeal on behalf of Helen Susan Ross.

14. A bound book of authorities filed with the Court of Appeal on behalf of Donald Leo Ross.

15. A collection of handwritten notes respecting the Court of Appeal proceedings concerning Donald Leo Ross, Helen Susan Ross and Donald George White.

16. A file folder with contents labelled Donald Leo Ross, Helen Susan Ross, Donald George White - October 26, 1992 - December 11, 1992 - Matt.

17. A file folder with contents labelled "Memos to File/Correspondence".

18. A file folder with contents labelled "Notes re Children".

19. A letter from Transcript Services to Matthew Miazga dated April 14, 1994 attaching a copy of the transcript of the February 2, 1993 sentence proceedings respecting Peter Klassen presided over by Justice Wedge.

20. A letter from Transcript Services to Matthew Miazga dated February 5, 1993 attaching a copy of the transcript of Justice Batten's judgment of December 18, 1992 respecting Donald Leo Ross, Helen Susan Ross and Donald George White.

21. A fax transmittal sheet dated September 30, 1993 attaching a copy of the Affidavit of Donald Mullord.

22. A copy of a Brief of Law on behalf of Donald Mullord in the matter of Her Majesty the Queen v. Donald Leo Ross, Helen Susan Ross and Donald George White.
in the Court of Queen's Bench in Saskatoon.

23. A letter from Roger Kergoat to Matt Miazga dated May 20, 1993 with attachments.

24. A handwritten memo from Sonja Hansen to Matthew Miazga dated February 5, 1993 with attachments.

25. A letter from John D. Hillson to Matthew Miazga dated May 10, 1993 with attachments.

26. An unsigned form of indictment naming Peter Klassen, Marie Klassen, Peter Dale Klassen, Anita Janine Klassen, John Klassen, Myrna Klassen, Richard Klassen, Keri Klassen, Dennis Kvello, Diane Kvello and Pamela Klassen.

27. A copy of a memo from Matthew Miazga to Sargeant Mike Grisdale dated November 18, 1993.

28. A 13 page fax transmittal from Roger Kergoat to Matt Miazga dated May 7, 1993.

29. A notice of application for hearing puruant to section 276.1(1) to adduce evidence of the complainants sexual activity other than the sexual activity that forms the subject matter of the charge provided by counsel for Donald George White.

30. A photocopy of a warrant to search dated June 18, 1991 respecting 1813 Avenue C North, Saskatoon attaching one page of handwritten notes, copy of an information to obtain a search warrant with appendix, a copy of a warrant to search dated June 18, 1991 respecting Plan AL 466, part of Parcel C Laird Saskatchewan, a page of handwritten notes, and a copy of an Information to obtain a search warrant with appendix.

31. Copies of five Saskatoon Police Services Supplemental Narrative texts.

32. Copy of a letter from Public Prosecutions office at Regina to the Public Prosecutions Office at Saskatoon dated May 11, 1993 with attachment.

33. A copy of a letter from the Public Prosecutions office at Regina to the Public Prosecutions Office at Saskatoon dated May 31, 1993 with attachment.

35. An indictment dated February 11, 1992 naming Donald Leo Ross, Helen Susan Ross and Donald George White.

36. A pre-sentence report respecting Donald Leo Ross showing its date of delivery as April 16, 1993.

37. A report from Dr. Robin P.B. Menzies to Justice Batten dated March 15, 1993.

38. A copy of a pre-sentence report respecting Helen Susan Ross.

40. A copy of a pre-sentence report respecting Donald George White.

41. A copy of a report from Dr. Menzies to Justice Batten dated March 15, 1993 respecting Donald White.

42. A copy of a report from Dr. Menzies to Justice Batten respecting Helen Ross dated December 25, 1993 .

43. A copy of a report from Dr. Menzies to Justice Batten respecting Donald White dated March 15, 1993.

44. A page of handwritten notes undated and unsigned.

45. A page of handwritten notes undated and unsigned.

46. A handwritten note dated November 12, 1991.

47. A collection of Saskatoon Police Department occurence reports.

48. A collection of Saskatoon Police Department occurence reports.

49. A collection of Saskatoon Police Department occurence reports.

50. A collection of Saskatoon City Police occurence reports.

51. A collection of Saskatoon City Police occurence reports.

52. A telephone message action memo from Mary Ann Murray to Bruce dated February 10, 1992.

53. A subpoena requiring Dr. Zillah Parker to attend the Saskatoon Court House on October 26, 1992 repecting the criminal trials of Donald Leo Ross, Helen susan Ross and Donald George White.

54. A copy of Saskatoon Police Department occurence report Occurrence 91-55245.

55. A collection of Saskatoon City Police Force Case Summaries.

56. A collection of Saskatoon Police Force Case Summaries.

57. A photocopied page headed "Royal Canadian Mounted Police - Identification Services" containing information repecting Linda Klassen.

58. A photocopied page headed "Royal Canadian Mounted Police - Identification Services" containing information repecting Mary Mavis Klassen.

59. A photocopied page headed "Royal Canadian Mounted Police - Identification Services" containing information repecting Richard Allen Klassen.

60. Copies of medical reports respecting Kathleen Ross, Michael Lundon Ross, Michelle Ross, Trevor Heinrichs and Crystal Morin.

61. A copy of Saskatoon Police Department occurence report Occurrence 91-55245.

62. A binder including 24 photographs.

63. A collection of Saskatoon Police Service Incidence Reports.

64. A copy of a letter from Matthew Miazga to Correctional Services of Canada dated May 11, 1993.

65. A copy of a letter from Correctional Service Canada to Matthew Miazga dated April 27, 1993.

66. A page of handwritten notes headed "Don White."

67. A page of handwritten notes headed "Bodnar, April 2, 1963".

68. A page of handwritten notes.

69. Four pages of handwritten notes headed "April 19, 1993 Application for reopening of White's case".

70. A page of handwritten notes.

71. Pad with three pages of handwritten notes.

72. Activity Report showing fax transmission from Saskatoon Crown Prosecutors Officve April 15, 1993.

73. Fax cover sheet showing a five page fax from Matthew Miazgas to Roger Kergoat April 15, 1993.

74. A page of handwritten notes.

75. A page of handwritten notes dated March 17, 1993.

76. A handwritten note from May to Matt with attachments.

77. A copy of an indictment naming Donald Leo Ross, Helen Susan Ross, Donald George White.

78. A copy of a certificate certifying the accuracy of the attached conviction repecting Peter Klassen also attaching a photocopied excerpt from McWilliams Canadian Criminal Evidence text and a copy of Regina v. Kendall and McKay (1987) 35 C.C.C. (3d) 105.

79. A list of witnesses over the signature of Matthew Miazga repecting the criminal proceedings against Donald Leo Ross, Helen Susan Ross, Donald George White.

80. A copy of the list of witnesses signed by Matthew Miazga repecting the criminal matter against Donald Leo Ross, Helen Susan Ross, Donald George White.

81. A copy of an invoice sent by Physicians Building Office, Royal University Hospital to Matthew Miazga.

82. Saskatchewan Attorney General disbursement voucher No. 06941.

83. A copy of Saskatchewan Deaf and Hard of Hearing Services Inc. invoice No. 6068.

84. A copy of Saskatchewan Deaf and Hard of Hearing Services Inc. invoice No. 6062 dated November 17, 1992.

85. A bill for attending court from Royal University Hospital dated November 10, 1992.

86. A copy of a bill for services from Community Child Care Consultants dated November 10, 1992.

87. A copy of a bill for services attaching related receipts received from Dr. Joanna SantaBarbara.

88. A photocopy of some pages from McWilliams Canadian Criminal Evidence (3d ed.).

89. A copy of Regina v. Kendal and McKay 35 C.C.C. (3d) 105.

90. A copy of an indictment naming Donald Leo Ross, Helen Susan Ross, Donald George White.

91. A photocopy of some pages from Canadian Criminal Evidence Second Edition.

92. A draft of an Admission of Facts Pursuant to Section 655 of the Criminal Code respecting rgw Criminal proceedings against Donald Leo Ross, Helen Susan Ross, Donald George White.

93. A copy of the signed Admission of Facts pursuant to section 655 of the Criminal Code.

94. A copy of a certificate of conviction repecting Peter Klassen.

95. Eight pages of handwritten notes.

96. Six pages of handwritten notes

97. Ten pages of handwritten notes headed "Argument".

98. Three pages of handwritten notes.

99. An unsigned copy of an Admission of Facts Pursuant to Section 655 of the Criminal Code attaching a copy of certificate of conviction respecting Peter Klassen.

100. Four pages of handwritten notes.

101. A copy of the Crown's list of witnesses respecting the criminal proceedings in Court of Queen's Bench respecting Donald Leo Ross, Helen Susan Ross and Donald George White.

102. A file folder labelled "Medical Reports" with its contents.

103. A file folder labelled "Psychological reports of victims".

104. A file folder labelled "Child Care Protection File" with its contents.

105. A file folder labelled "Information" with its contents.

106. A file folder labelled "Undertakings" with its contents.

107. A pad with 23 pages of handwritten notes beginning with the date December 9, 1992.

108. A pad with 47 pages of handwritten notes beginning with the date November 3, 1992.

109. A collection of ten pages of handwritten notes with the heading "Notes from court tape re Garnet Francis."

110. A pad with 43 pages of handwritten notes beginning with the heading "Garnet Francis cross examine."

111. A pad with 54 pages of handwritten notes beginning with the heading "Ross case Trial notes October 28, 1992".

112. A pad with 49 pages of handwritten notes beginning with the heading MCHE Con't."

113. A pad with 34 pages of handwritten notes beginning with the notes "Crown Case Closes Roger File Admissions".

114. A pad with 26 pages of handwritten notes beginning with the heading "November 25, 1992 Dr. Santa-Barbara."

115. A pad with 30 pages of handwritten notes beginning with the heading "November 9, 1992 A.M. Kathy (in chief cont'd.)"

116. A file folder labelled St. Paul's Hospital Records" with its contents.

117. A file folder labelled "Social Services" with its contents.

118. A file folder labelled "Marilyn's notes" with its contents.

119. A file folder labelled "Carol's notes" with its contents.

120. A file folder labelled "Criminal records" with its contents.

121. A file folder labelled "Star Phoenix Applications".

122. A copy of a document entitled "Curriculum Guidelines for Career Training in Child Psychiatry (revised September 1990)".

123. A one page summary of the curriculum vitae of Michael F. Elterman.

124. A copy of the curriculum vitae of Viva Joanna Santa Barbara.

125. Two copies of the curriculum vitae of Dr. V. Joanna Santa Barbara.

126. A copy of the curriculum vitae of Zillah Ann Parker dated June 30, 1992.

127. A copy of a document headed "Workshops Hypnosis, Psychotherapy and Dissociative Disorders".

128. A letter from MacDermid LaMarsh law office to Matthew Miazga dated October 7, 1992.

129. A letter from MacDermid LaMarsh to Matthew Miazga dated October 7, 1992.

130. Three pages of handwritten notes headed with the date September 18, 1992.

131. Two pages of handwritten notes headed with the date September 18, 1992.

132. An action memo from Carol to Sonja/Matt with handwritten notes on both sides.

133. A page of handwritten notes headed with the name "Dr. Parker".

134. A copy of the curriculum vitae of Viva Joanna Santana faxed to Sonja Hansen September 18, 1992.

135. A copy of a page numbered 13 with the heading "Administrative Responsibilities".

136. A copy of a memorandum from Sonja E. Hanson to Staff Sargeant Mawson dated September 24, 1992.

137. A copy of a letter from Royal Ottawa Hospital to Leslie Sullivan dated July 10, 1992 with attachment.

138. A page of handwritten notes dated September 16, 1992.

139. A page of handwritten notes dated September 10, 1992.

140. A page of handwritten notes dated September 8, 1992.

141. An action memo from Liz Newton to Sonja dated September 3, 1992.

142. An action memo from Liz Newton to Sonja dated July 7, 1992.

143. An action memo from Roger Kergoat to Sonja dated August 31.

144. Three pages of handwritten notes attaching the July 10, 1992 letter and curriculum vitae of George A. Fraser.

145. A page of handwritten notes dated September 1, 1992.

145. An action memo from Roger K. to Sonja dated May 14, 1992.

147. A page of handwritten notes dated May 27, 1992.

148. Three volumes of transcripts transcribing interviews conducted by Corporal Brian Dueck and Carol Bunko-Ruys with Kathleen Ross on October 21 and 28 and November 15 and 29 of 1990, with Michelle Mimi Ross on October 21 and 28 and November 15 of 1990, and with Michael Mundon Ross on October 20 and 28 and November 16 of 1990 and six videotapes with together contain two copies of a video and audio record of the entirety of the interviews described above.

149. A videotape labelled "Helen Ross (00:53:40) Donald George White (00:58:31).

150. A videotape lebelled "Occ46066/90 Steven Hardy, Shannavia Hardy and Sarde Hardy".

151. A videotape labelled "OCC46066/90 Krystal Heinrichs 91-01-19, Trevor Heinrichs 91-04-15.

152. A one volume transcript respecting proceedings in Court of Queen's Bench regarding Donald Leo Ross, Helen Susan Ross and Donald George white labelled "evidence and proceedings of preliminary applications before The Honourable Justice W. F. Gerein - evidence of the witness - Carol Bunko-Ruys Monday, October 5, 1992.

153. Four binders with duplicate sets of 24 photographs each.

154. Four binders each with a set of three copies of the same photographs.

155. Three binders each containing copies of the same 11 photographs.

156. A copy of a memorandum from Doreen Wilson, Supervisor, West District Family Services to John Nicholson, Supervisor West District Financial Services dated June 5, 1984.

157. A letter from Royal University Hospital to Sargeant Brian Dueck dated October 22, 1992 attaching hospital records of Kathleen Ross.

158. A letter from Royal University Hospital to Sargeant Brian Dueck attaching hospital records from Michelle Ross.

159. Fifteen volumes of transcript of the preliminary hearing respecting the plaintiffs commenced December 2, 1991.

160. A copy of the transcript of the sentencing proceedings respecting Peter Klassen dated February 2, 1993.

161. A letter from Matthew Miazga to Don McKillop attaching photocopies of excerpts from Mr. Miazga's diaries of 1991-1993.

162. A file folder labelled "Informations/Subpoenas - Phone Numbers" and its contents.

163. A copy of a transcript of a recording of a telephone conversation between Richard Klassen and Darryl Lablach (sic) or April 26, 1984 (sic).

164. A memo from D. Murray Brown to Matt Miazga dated May 13, 1994 attaching copies of affidavits from the Court of Appeal sworn by Richard Klassen and Peter Klassen.

165. A copy of the indictment respecting Peter Klassen.

166. One photocopied page headed "Assignments for November 18-29/91."

167. A copy of a memo from C. Richard Quinney to all Regional Prosecutors dated May 27, 1992 with the attachment referred to.

168. An action memo from Labach to Sonja dated July 8, 1992.

169. A photocopy of Regina v. Elliot [1975] 28 C.C.C. (2d) 546.

170. An unsigned copy of an indictment respecting Peter Marie, Peter Dale, Anita Janine, John MYrna, Richard and Kari Klassen and Dennis, Diane and Pamela Klassen attaching an unsigned list of witnesses respecting the same proceedings.

171. An action memo with handwritten notes on both sides of the page.

172. A four page unsigned document headed "Outline of circumstances regarding the Ross and Klassen sexual assault prosecution."

173. A copy of pages A1 - A12 of the Star Phoenix newspaper of Fridat, July 23, 1993.

174. A copy of a letter from Robert L. Borden to Ms. Mary Grunow dated June 5, 1992 attaching an envelope in which that letter was sent to Sonja Hansen.

175. A letter from the Law Society of Saskatchewan to Sonja Hansen dated January 10, 1994.

176. An action memo from Wilf to Sonja undated with attachment.

177. A page of handwritten notes dated April 21, 1992 attaching an action memo from Darryl Labach to Sonja dated April 22, 1992.

178. A letter from Darryl E. Labach to Sonja Hansen dated May 19, 1992 attaching a page of handwritten notes.

179. An undated page of handwritten notes.

180. A collection of six pages of handwritten notes, the first of which is headed "Crown applications".

181. A page of handwritten notes dated June 3, 1992.

182. A page of handwritten notes dated July 17, 1992.

183. A page of handwritten notes dated July 17, 1992.

184. A copy of a memorandum from Sonja Hansen to all prosecutors dated July 17, 1992.

185. A page of handwritten notes dated September 8, 1992.

186. A page of handwritten notes dated September 8, 1992.

187. A page of handwritten notes dated September 10, 1992.

188. A collection of five pages ofphotocopied handwritten notes, the first page of which is dated December 14, 1992.

189. A page of handwritten notes dated January 13, 1993.

190. A page of handwritten notes dated January 13, 1993.

191. A page of handwritten notes.

192. A page of handwritten notes.

193. A copy of a letter from Chief Justice D.K. MacPherson to Anne M. Wallace dated March 29, 1993 attaching a copy of Ms. Wallace' letter to the Saskatoon Local Registrar dated February 15, 1993, a copy of Ms. Wallace' letter to Bruce Bauer dated April 13, 1993 and a fax transmittal sheet from the Saskatoon Crown Prosecutors to Barry Singer dated January 7, 1994.

194. A fax transmittal record dated January 7, 1994.

195. A photocopy of excerpts from the Lawyers' Weekly of December 6, 1991.

196. A collection of eight pages of handwritten notes dated October 16, 1992.

197. A subpoena requiring Judy Hjertaas to attend before Court of Queen's Bench at Saskatoon on February 1, 1993 to testify respecting the cxriminal proceedings against Pamela and Peter Klassen.

198. A page of handwritten notes attaching an action memo from Pam Jutras to Matt.

199. A witness request form with attachments.

200. A page of handwritten notes.

201. A faxed memorandum from the Regina Prosecution Unit to Terry Hinz dated July 4, 1990 with attachments.

202. A copy of an affidavit sworn by Peter Klassen April 28, 1994.

203. A file folder labelled "Michael Klassen - Ann Kayer" with its contents.

204. A file folder labelled Krystal Heinrichs with its contents.

205. A file folder labelled Trevor Heinrichs with its contents.

206. A file folder labelled "Steven Hardie - Susan Hardie" with its contents.

207. A page of handwritten notes clipped to a two page computer printout and attaching a file folder labelled Klassen (subpoena) with its contents.

208. A six page fax from Matt Miazga to Kenneth MacKay dated December 3, 1993.

209. A copy of a letter from Morris Bodnar to Matthew Miazga dated March 16, 1993.

210. A copy of the Fiat of Justice Kindred in Saskatoon Queen's Bench action 409 of 1984.

211. A letter from Marusia A. Kobrynsky to Matthew Miazga dated March 17, 1993.

212. A photocopy of a page from the wekly Criminal bulletin.

213. A copy of a Quebec Court of Appeal decision in Thomas Bernard Brigham v. The Queen.

214. A copy of a document styled in the Court of Queen's Bench in criminal proceedings regard Donald George White entitled "Brief of Law on behalf of Donald George White".

215. A large collection of handwritten notes of court proceedings beginning December 2, 1991.

210A. A binder containing 23 photographs.

211A. A binder containing 24 photographs.

212A. A binder containing 11 photographs.

213A. A copy of a two page document headed "Saskatchewan Police Service Supplemental Narrative Text Case No: 93:-59960, reported: 1993 - August 27 at 08:15 hours.

214A. A four page document addressed to Mr. Chris Axworthy M.P. headed "Publication Ban Be Damned".

215A. A copy of a page headed "Star Chamber Publications."

216. A copy of the Order issued by Justice Lane June 7, 1993 respecting Donald George White.

217. A copy of the Order issued by Justice Jackson May 13, 1993 respecting Helen Susan Ross.

218. A letter from John D. Hillson to Matt Miazga dated July 9, 1993.

219. A transcript of the judgment of Justice Batten dated December 18, 1992 respecting the criminal proceedings involving Donald Leo Ross, Helen Susan Ross and Donald George White.

220. A copy of the indictment naming Peter Klassen.

221. A six page fax from Fred Dehm to Richard Quinney dated August 24, 1993.

222. A copy of a letter from Fred Dehm to Richard Quinney dated August 16, 1993.

223. A copy of a fax from Matt Miazga to Richard Quinney dated January 29, 1993.

224. Three pages of handwritten notes attaching a fax from the Saskatoon Prosecutor's Office to Richard Quinney dated August 12, 1993.

225. A page of handwritten notes dated February 11, 1993 attaching copies of letters from Matthew Miazga to Daryl Labach, Jay Watson and Robert Borden all dated February 11, 1993.

226. A page of handwritten notes headed "Sentencing by Wedge, J. on Peter Klassen February 8, 1993."

227. Two copies of a letter from Matthew Miazga to Richard Quinney dated January 27, 1993.

228. A three page fax from Matt Miazga to Richard Quinney dated February 1, 1993.

229. A page headed "Royal Canadian Mounted Police - Identification Services" containing information respecting Peter Klassen.

230. A page of handwritten notes.

231. An envelope of notes some handwritten and some typewritten.

232. A copy of an "Admission of Facts pursuant to Section 655 of the Criminal Code" attaching fax transmission sheets showing delivery of that document from Matthew Miazga to Bob Borden, Darryl Labach and Roger Kergoat all on November 29, 1991.

233. A copy of the birth certificate of Michael Lundon Ross.

234. A Saskatchewan Health Vital Statistics mailing label.

235. A page of handwritten notes dated July 16, 1991.

236. Copies of Saskatoon Police Department Charge and Booking Forms respecting Richard Allen Klassen, Peter Dale Klassen, Myrna Lynne Klassen, John Randy Klassen, Anita Janice Klassen and Kari Leanne Klassen.

237. A page of handwritten notes dated July 11, 1991.

238. Two unsigned copies of an information respecting Peter Klassen.

239. A handwritten memo from Marie/B. to Gary McElroy dated July 14, 1991 with attachments.

240. A copy of Information No. 1632285.

241. A copy of an Information respecting Donald Leo Ross, Helen susan Ross and Donald George white attaching copies of unsigned warrants for arres naming these people.

242. Unsigned warrants for arrest naming Peter Klassen, Marie Klassen, Peter Dale Klassen, Anita Janine Klassen, John Klassen, Myrna Klassen, Richard Klassen, Karey Klassen, Dennis Kvello, Dianne Kvello and Pamela Klassen.

243. A page of handwritten notes.

244. A collection of copies of Saskatoon City Police Force occurrence reports.

245. A copy of a single Saskatoon city Police Force occurence report.

246. A file folder containing three pages of handwritten notes dated December 2, 1991.

247. A copy of Information No. 1632285.

248. A copy of Information No. 3054840.

249. A copy of Information No. 3054839.

250. A copy of Information No. 1774644 attaching copies of a number of excerpts of the Provincial Court file repecting proceedings related to that Information.

251. A page of handwritten notes dated January 16, 1992.

252. A page of handwritten notes dated January 16, 1992.

253. An action memo dated June 15.

254. A letter from Daryl Labach to Sonja Hansen dated May 27, 1992.

255. A letter from Daryl Labach to Sonja Hansen dated May 22, 1992 with attached handwritten notes.

256. A page of handwritten notes.

257. A file folder labelled "Misc. Notes" with its contents.

258. A file labelled "Pre-Trial and lawyer correspondence" with its contents attaching a collection of copies of 11 photographs.

259. A file folder labelled "Witnesses (Therapists)".

260. A file folder labelled Nov. 21/91 P.I. (Notes)".

261. A form of admission of facts pursuant to section 655 of the Criminal Code.

262. A one page fax from Sonja Hansen to Daryl Labach dated November 28, 1991.

263. A form of admission of facts pursuant to section 655 of the Criminal Code signed by Robert Borden and Daryl Labach.

264. A Saskatoon City Police Force court witness and process report dated December 2, 1991 attaching a copy of a subpoena requiring Sargeant Don MacEwan to attend at Provincial Court in Saskatoon December 3, 1991.

265. A copy of Saskatoon Police Force court witness and process report dated November 15, 1991.

266. A copy of a subpoena requiring Corporal Dueck to attend at Provincial Court in Saskatoon December 2, 1991.

267. A copy of a subpoena requiring Andrea Bilous to attend at Provincial Court in Saskatoon December 5, 1991.

268. A copy of a fice page fax from Matt Miazga to Haubrich, Borden, Trach & Carlson dated December 6, 1991.

269. A copy of a page headed "Criminal Information #5."

270. A copy of a page headed "Star Chamber Trials."

271. A copy of a one page document headed "Star Chamber Publication".

272. A copy of a two page document dated November 11, 1993 "Re foster children secret trials held in Saskatoon."

273. A copy of a one page document headed "Star Chamber Publications" signed at the bottom of the page "Richard Allen Klassen."

274. A copy of a 27 page document headed "Star Chamber Trial".

275. A memorandum from Richard Quinney to Leanne Lang dated April 28, 1994 with attachments.

276. A handwritten memorandum from Richard Quinney to Don McKillop dated February 23, 1994 attaching files of the Central Office of Saskatchewan Justice, Public Prosecution respecting the Ross and Klassen criminal proceedings.

277. A handwritten memo from Sonja to Matt dated November 29, 1991 attaching a chart headed "Klassen - Ross occurrence No 90-46066".

FIRST SCHEDULE
PART TWO
SHOWING DOCUMENTS IN THE POSSESSION OF THESE DEFENDANTS WHICH THEY

OBJECT TO PRODUCE:

1. Various communications between these defendants and their legal advisors either being with respect to the provision of legal advice respecting matters in issue in the action or having been prepared in contemplation of this litigation but in any ievent be protected by solicitor and client privilege.

SECOND SCHEDULE
SHOWING DOCUMENTS WHICH THESE DEFENDANTS GOVERNMENT HAD BUT DO NOT NOW HAVE IN THEIR POSSESSION OR POWER:

1. Originals of the documents referred to in the First Part of the First Schedule and described as copies, the originals of which these Defendants presume were delivered to the addresses on or about the date shown on each of the documents.