Overview Report: Fundraising in Support of Protestors

Overview Report:
Fundraising in Support of Protestors
Prepared by: Commission Counsel
1
Summary of Report
The following Overview Report summarizes the major fundraising activities that were
started in order to provide support to protestor activities, including crowdfunding, direct
donation campaigns and cryptocurrency donations. This report also reviews steps taken
by a variety of actors, including crowdfunding platforms, payment processors, banks
and courts that had an impact on the flow of funds. The report summarizes the
information currently available to the Commission about the status of donated funds.
Note to Reader
Pursuant to Rules 41-45 of the Commission’s Revised Rules of Practice and Procedure,
the following Overview Report contains a summary of background facts and documents
relating to the Commission’s mandate.
Overview Reports allow facts to be placed in evidence without requiring those facts and
related documents to be presented orally by a witness during the public hearings. The
Overview Report may be used to assist in identifying issues relevant to the
Commission, make findings of fact and enable recommendations to be made by the
Commission.
The Parties with standing at the Commission have been provided an opportunity to
comment on the accuracy of this Overview Report. Commission Counsel and the
Parties may call evidence from witnesses at the Inquiry that casts doubt on the
accuracy of the content of the documents underlying this Overview Report. The Parties
may also make submissions regarding what, if any, weight should be given to the
Overview Report and the cited documents.
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Contents
Summary of Report ................................ ................................ ................................ .................... 2
Note to Reader................................ ................................ ................................ .......................... 2
1. Introduction to Fundraising Concepts ................................ ................................ ........................ 5
2. The Original Freedom Convoy Campaigns ................................ ................................ .................. 7
2.1 The Freedom Convoy 2022 GoFundMe Campaign................................ ............................. 7
2.2 The Freedom Convoy Email Money Transfer Campaign................................ ..................... 12
3. The Adopt-A-Trucker Campaigns ................................ ................................ ............................. 13
3.1 The Adopt-A-Trucker GiveSendGo Campaign................................ ................................ ... 13
3.2 The Adopt-A-Trucker Email Money Transfer Campaign ................................ ..................... 14
4. Cryptocurrency Fundraising Campaigns ................................ ................................ .................... 15
4.1 Honk Honk Hodl................................ ................................ ................................ .......... 15
4.2 Adopt-A-Trucker Cryptocurrency Campaign ................................ ................................ .... 18
4.3 Freedom Convoy Token ................................ ................................ ............................... 18
5. The Termination of the GoFundMe Freedom Convoy Campaign and the Transition to GiveSendGo ... 19
5.1 Campaign Organizers Request Additional Release of Funds ................................ ............... 19
5.2 The Establishment of the Freedom 2022 Human Rights and Freedoms Non-Profit Corp......... 19
5.3 Organizers Consider Moving to GiveSendGo ................................ ................................ ... 21
5.4 GoFundMe Suspends and then Terminates the Freedom Convoy Campaign ........................ 24
5.5 GoFundMe Refunds Donations to the Freedom Convoy 2022 Campaign ............................. 31
5.6 TD Bank Places Holds on Tamara Lich’s Bank Accounts ................................ ..................... 32
6. The Continuation of Campaigns on GiveSendGo................................ ................................ ......... 34
6.1 The Freedom Convoy 2022 Campaign ................................ ................................ ............ 34
6.2 The Ontario Restraint Order ................................ ................................ ......................... 39
7. The Non-Profit Corporation’s Credit Union Account................................ ................................ .... 44
8. Cash Donations during the Ottawa Protests ................................ ................................ .............. 44
9. Events following the Publication of the Emergency Economic Measures Order ............................... 45
10. The February 17th Mareva Injunction ................................ ................................ ...................... 47
11. Summary of Financial Information Available to the Commission................................ ................. 50
11.1 GoFundMe Freedom Convoy 2022 Donations ................................ ................................ .50
11.2 Email Money Transfer Donations to the Freedom Convoy 2022 Campaign........................... 51
11.3 Adopt-A-Trucker Crowdfunding and Email Money Transfer Donations ................................ 54
3
11.4 GiveSendGo Freedom Convoy 2022 Donations ................................ ................................ 56
11.5 Cryptocurrencies................................ ................................ ................................ ......... 58
11.6 Bank Draft to the Freedom 2022 Human Rights and Freedoms Corp................................ ... 60
12. Visualization of Financial Flows ................................ ................................ .............................. 61
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Overview Report: Fundraising in Support of Protestors
Overview Report: Fundraising in Support of

Protestors
1. Introduction to Fundraising Concepts
1. Crowdfunding platforms include online services that permit individuals or groups
to solicit online donations from multiple donors. These are referred to as “donation
based crowdfunding platforms”. Throughout this report, the term “crowdfunding
platform” refers to donation based crowdfunding platforms. There are numerous
crowdfunding platforms, each of which may operate differently. In general, a
crowdfunding platform permits an organizer to establish a campaign in support of a
beneficiary, who may or may not be the same person as the organizer. Internet users
can view information about a campaign on the crowdfunding platform and can make
online donations through the platform. Depending on the platform, donations may or
may not be made anonymously. Some platforms are for-profit, while others are non-
profit.
2. Both GoFundMe and GiveSendGo are examples of for-profit crowdfunding
platforms. Both are based in the United States of America.
3. Payment processors are entities that manage electronic financial transactions
between merchants and financial institutions. Most crowdfunding platforms are not
payment processors. This means that crowdfunding platforms do not themselves accept
and hold donations or distribute them to a beneficiary’s bank account. Instead, they rely
5
on a payment processor to facilitate the collection of donations and their ultimate
transfer to a beneficiary’s bank account.
4. Stripe is an example of a payment processor. During January and February
2022, Stripe provided payment processing services for GoFundMe and GiveSendGo.
5. Stripe partners with financial institutions in order to provide payment processing
services to clients such as crowdfunding platforms. One type of financial institution
Stripe partners with is a deposit taking institution, such as a bank. When a payment is
processed with Stripe, the funds are held in a depository institution contracted by Stripe
until they are released to the recipient of the payment, such as a crowdfunding
beneficiary.
6. Cryptocurrencies, also referred to as crypto assets or virtual currencies, are a
broad class of digital tokens. They can serve several purposes. One purpose that a
cryptocurrency may serve is to act as a medium of exchange similar to traditional
currencies like the Canadian dollar. Cryptocurrencies are held in an electronic “wallet”
that is identified by a unique alpha-numeric address. An individual can access
cryptocurrencies held in a wallet using seed phrases, pass phrases or other secure
codes.
7. There are several ways in which individuals may purchase, exchange, and sell
cryptocurrencies. Cryptocurrency exchanges permit individuals to convert
cryptocurrencies into “ordinary” currencies such as Canadian dollars or vice versa.
Cryptocurrencies may also be exchanged directly between individuals without the need
for an intermediary such as an exchange or a payment processor.
6
8. Bitcoin is an example of a cryptocurrency. Transactions involving Bitcoin are
reflected on the Bitcoin blockchain, a public ledger that records all transactions involving
Bitcoin. While the blockchain records Bitcoin transactions, including the wallet
addresses involved in each transaction, it does not record the identities of individuals
who engage in those transactions.
2. The Original Freedom Convoy Campaigns

9. In January 2022, two fundraising efforts in support of the “Freedom Convoy”
were established by Tamara Lich: a crowdfunding campaign, and a direct email money
transfer campaign. In the days following their creation, additional individuals became
involved in the management of these fundraisers.
2.1 The Freedom Convoy 2022 GoFundMe Campaign

10. Tamara Lich created a fundraising campaign on the crowdfunding website
GoFundMe on January 14, 2022 called “Freedom Convoy 2022”.1 This campaign was
linked to a personal savings account at TD Bank in the name of Ms. Lich, which was
opened on March 4, 2020 (“the First TD Account”).2
1Letter from GoFundMe Counsel to Commission Counsel, August 9, 2022, p 2,

GFM00000583; Affidavit of Tamara Lich, dated March 28, 2022, para 3, Supplementary
Motion Record of the Mareva Respondents, p 44, HRF00001346.
2Affidavit of Tamara Lich, dated March 28, 2022, para 4, Supplementary Motion Record
of the Mareva Respondents, p 44, HRF00001346; Affidavit of Kevin Moffatt, dated
February 15, 2022, para 16, Application Record of the Toronto-Dominion Bank, p 16,
TDB00000004. See also GoFundMe, Connecting your bank account, GFM00000314.
7
11. The campaign’s description was edited several times after it was created. At the
end of day on January 14, 2022, the description read:
To our Fellow Canadians, the time for political over reach is over. Our
current government is implementing rules and mandates that are destroying
the foundation of our businesses, industries and livelihoods. Canadians
have been integral to the fabric of humanity in many ways that have shaped
the planet.
We are a peaceful country that has helped protect nations across the globe
from Tyrannical governments who oppressed their people, well now it is
happening to us. We are taking our fight to the doorsteps of our Federal
Government and demanding that they cease all mandates against its
people. Small businesses are being destroyed homes are being destroyed,
and people are being mistreated and denied fundamental necessities to
survive. It’s our duty as Canadians to put an end to this mandates. It is
imperative that this happens because if we don’t our country will no longer
be the country we have come to love. We are doing this four our future
Generations and to regain our lives back.
We are asking for Donations to help with the costs of fuel, food and lodgings
to help ease the pressures of this arduous task. But it’s a small price to pay
for our freedoms. We thank you all for your Donations and know that you
are helping reshape this once beautiful country back to the way it was. 3
12. The Freedom Convoy 2022 campaign came to the attention of GoFundMe within
a few hours of its creation due to the speed at which it attracted donations. When the
campaign was reviewed, GoFundMe became concerned about the organizer’s ability to
distribute the funds in accordance with the campaign description.4 GoFundMe’s terms of
service require that all funds raised in a campaign are used consistently with the
campaign’s purpose. Funds must go to the campaign’s beneficiary or a third-party
3 Fund Edit History, p 34, GFM00000001 (sic throughout).

4 Interview Summary: Kim Wilford, p 2, WTS.00000007.
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acting to deliver those funds to the beneficiary. They must also be spent for the purpose
or purposes stated in the campaign.5
13. GoFundMe wished to have more information from Ms. Lich about how she would
ensure that the money raised would go to truckers to reimburse them for the cost of
fuel, food and lodgings. GoFundMe’s “VIP Team”, which was responsible for high-profile
fundraisers, first communicated with Ms. Lich on January 16, 2022. The purpose of this
communication was to gather more information about organizer’s plans with respect to
the distribution of the funds.6
14. On January 18, 2022, the description of the campaign was edited to add the
following text:
**Money raised will be dispersed to our Truckers to aid them with the cost
of the journey**
**Funds will be dispersed via e-transfer (preferred) but can also be sent by
cheque if absolutely necessary**
**Funds will be spent to help cover the cost of fuel for our Truckers first and
foremost, will be used to assist with food if needed and contribute to shelter
if needed**7
15. On January 22, 2022, the description was edited to add the following text:
In order for your generous donations to flow smoothly, the good people at
Go Fund Me will be sending donations directly to our bulk fuel supplier and
are working out the details now which means your hard earned money is
going to straight to who it was meant for and need not flow through anyone
5Interview Summary: Kim Wilford, p 2, WTS.00000007; GoFundMe Terms of Service,

dated December 31, 2021, GFM00000040.
7 Fund Edit History, p 30, GFM00000001.
9
else. Any left over donations will be donated to a credible Veterans

organization which will be chosen by the donors. 8
16. GoFundMe was concerned about the pledge that leftover funds would be
donated to a veterans’ organization chosen by the donors. It was not clear to
GoFundMe how it would be possible for the organizers to get donor approval for an
organization given the large number of donors.9
17. While GoFundMe’s VIP team was making inquiries with the campaign
organizers, it did not release any of the funds that had been raised.
18. On January 26, 2022, GoFundMe emailed a representative of the campaign
organizers with a series of questions. The organizers asked Chad Eros, an accountant
who had been introduced to them by Chris Garrah, for assistance in answering the
questions.10 After receiving a proposed answer from Mr. Eros, the organizers forwarded
it to Jeffrey Rath, a lawyer who had been working with them, who made some changes
to the response.11 A representative of the organizers sent this response to GoFundMe
with the requested information later on the 26th,12 including a copy of a form that the
organizers were requiring truckers seeking reimbursement to use,13 and internal
8 Fund Edit History, p 22, GFM00000001.

10 Witness Summary: Chad Eros, p 1, WTS.00000032.
11 Witness Summary: Chad Eros, p 2, WTS.00000032.
Email exchange between GoFundMe and Campaign Organizers, January 26, 2022,
12
GFM00000078; Witness Summary: Chad Eros, p 2, WTS.00000032.

13 Freedom Convoy 2022 Registration Form, GFM00000150.
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guidelines related to reimbursement rates and procedures.14 The organizers also
requested that GoFundMe release an initial $1,000,000 CAD of the donated funds.
19. On January 27, 2022, GoFundMe sent a “Letter of Attestation” to Tamara Lich,
who signed and returned it the same day.15 The purpose of this letter was to help
ensure that funds raised by Ms. Lich would be used as outlined in the campaign. It
confirmed that Ms. Lich would only use the funds as outlined in the campaign and
confirmed the existence of a five-person Finance Committee that was responsible for
the funds. The letter required the Finance Committee to obtain documentation from
recipients that demonstrated their eligibility to receive funds. It also required that the
funds be distributed via e-transfer, which would create a record of payments made. 16
20. After the attestation letter was signed, GoFundMe concluded it could make an
initial disbursement of funds to Ms. Lich. GoFundMe directed its payment processor,
Stripe, to initiate a $1,000,000 CAD payment to the First TD Account on January 27,
2022 and notified the organizers that the payment was being made. 17 This transfer did
not “settle” (that is, it was not finalized) until February 2, 2022. According to GoFundMe,
this was due to an error on the part of Stripe, which did not process GoFundMe’s
14 Trucker Freedom Convoy 2022 Financial Support, GFM00000151.

15 GoFundMe Attestation Letter, dated January 27, 2022, GFM00000156.
17 Email from GoFundMe to Organizers, January 27, 2022, 1:05pm, GFM00000106.
11
direction until February 1, 2022.18 According to Stripe, the delay was because
GoFundMe directed Stripe to pause, and then un-pause this transaction.19
21. On February 1, 2022, Chris Barber was added as a second account holder on
the First TD Account.20 On the same day, Ms. Lich and Mr. Barber opened a second
joint account with TD Bank (“the Second TD Account”).21
22. TD Bank was monitoring the use of the First and Second TD Accounts. The
steps taken by TD with respect to these accounts is addressed below in Section 5.6.
2.2 The Freedom Convoy Email Money Transfer Campaign

23. After Ms. Lich created the Freedom Convoy 2022 GoFundMe campaign, some
donors expressed a dislike of donating through GoFundMe. This led to the creation of a
campaign to raise funds via email money transfer. 22
18Interview Summary: Kim Wilford, p 3, WTS.00000007; Email from GoFundMe to

Organizers, February 1, 2022, 6:38pm, GFM00000106; Affidavit of Kevin Moffatt, dated
TDB00000004; Screenshot of Bank Transfer, Application Record of the Toronto-
Dominion Bank, p 118, TDB00000004.
19 Interview Summary: Sam Swartz & Dan Alexander, pp 2-3, WTS.00000005.
20Affidavit of Kevin Moffatt, dated February 15, 2022, para 17, Application Record of the
Toronto-Dominion Bank, p 17, TDB00000004; TD Bank, Financial Services Agreement,
dated February 1, 2022, Application Record of the Toronto-Dominion Bank, p 65,
TDB00000004.
21 TD Bank, Financial Services Agreement, dated February 1, 2022, Application Record
of the Toronto-Dominion Bank, p 209, TDB00000004.
22Affidavit of Tamara Lich, dated March 28, 2022, para 5, Supplementary Motion
Record of the Mareva Respondents, p 44, HRF00001346.
12
24. A Contact Identifier email address is an address an individual associates with a
bank account to enable that account to receive email money transfers. The email
address [email protected] was added as a Contact Identifier email
address to the First TD Account on January 14, 2022. On January 18, 2022, the email
address [email protected] was added as another Contact Identifier
email address for the First TD Account.23 The latter email address was posted to the
Freedom Convoy Facebook page on January 18, 2022.24
25. Ms. Lich received the first email money transfer donation on January 18, 2022.25
3. The Adopt-A-Trucker Campaigns

3.1 The Adopt-A-Trucker GiveSendGo Campaign
26. Chris Garrah first articulated the concept of “Adopt-A-Trucker” on his personal
Facebook page to support truckers participating in the Freedom Convoy. On January
18, 2022 he created a fundraising campaign on the crowdfunding website GiveSendGo
Toronto-Dominion Bank, pp 17-18, TDB00000004; Screenshot of contract identifier
address added on January 14 and 18, 2022, Application Record of the Toronto-
Dominion Bank, pp 83, 85, TDB00000004.
24Affidavit of Tamara Lich, dated March 28, 2022, para 5, Supplementary Motion
Record of the Mareva Respondents, p 44, HRF00001346; Freedom Convoy 2022
Facebook Post, February 18, 2022, HRF00000480, HRF00000482, HRF00000481.
25Statement of Account, January 18, 2022 to February 10, 2022, Application Record of
the Toronto-Dominion Bank, p 140, TDB00000004.
13
called “Adopt-A-Trucker” to implement this idea. Mr. Garrah designated a bank account
at Royal Bank of Canada to receive donated funds (“the RBC Account”).26
27. The description of the Adopt-A-Trucker campaign, as of January 21, 2022, was
as follows:
We at Warroomcanada have started up Adopt a trucker in Ottawa as part

of the convoy 20/22 that will be coming in on January 28/2022. We are
endorsed by Pat King and Canada-unity. These people will need housing,
water, food and shuttle. Any donations would be amazing! The truckers will
need accommodations. This is a Canadian wide rally to stop all mandates
and allow CANADA to be free again and to go back to what we call freedom.
This is for everyone who wants to contribute but cannot be there in person.
This is a great way for you to be a part of this movement, all the effort we
put in now will bring us one step closer to gaining back ALL our
constitutional rights and freedoms. We are also looking for volunteers on
ground zero, right in Ottawa. Please email if your interested. A need for all
levels of logistics like food preps, generators, showers, security and pilons
etc. [email protected] or [email protected]
28. Following its creation, Adopt-A-Trucker immediately began to raise funds. 28
These funds were deposited into the RBC Account.29
3.2 The Adopt-A-Trucker Email Money Transfer Campaign

29. After posting about the concept of Adopt-A-Trucker on his Facebook page, Mr.
Garrah was contacted by a number of individuals who supported the concept. One of
Affidavit of Chris Garrah dated March 8, 2022, paras 6-7, Motion Record of the
26
Mareva Respondents, pp 68-69, HRF00001357.

27 Adopt-A-Trucker page on GiveSendGo, January 21, 2022, COM00000571.
28 Interview Summary: Jacob Wells, p 2, WTS.00000004.
29Affidavit of Chris Garrah, March 7, 2022, paras. 7-8, Motion Record of the Mareva
Respondents, March 8, 2022, p 69, HRF00001357.
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these individuals, known as “Serge” assisted Mr. Garrah by creating a website for
“Adopt-A-Trucker”.30
30. The Adopt-A-Trucker website solicited email money transfer donations, which
could be sent to [email protected] Donations sent to this email address
were deposited into the same RBC account as the donations to the GiveSendGo
campaign.32
4. Cryptocurrency Fundraising Campaigns

31. The Commission has identified a range of activities related to cryptocurrencies in
connection with the Freedom Convoy. This section addresses three of these
campaigns: Honk Honk Hodl, which was the largest of the campaigns; Adopt-A-Trucker,
which was associated with the efforts of Chris Garrah; and Freedom Convoy Token, an
effort by Pat King and others to create a new cryptocurrency that could provide a long-
term source of funding.
4.1 Honk Honk Hodl

32. On or around January 27, 2022, the “Honk Honk Hodl” Bitcoin fundraiser in
support of the Ottawa protestors was started by Nicholas St. Louis on Tallycoin, a
Affidavit of Chris Garrah dated March 8, 2022, paras 6, 10, Motion Record of the
30

31 Adopt-A-Trucker Website, February 14, 2022, COM00000564.
32Notice of Motion, March 8, 2022, para 58, Motion Record of the Mareva
Respondents, p 16, HRF00001357; Redacted Bank Statements Adopt-A-Trucker,
GAR00000001.
15
Bitcoin crowdfunding platform that allows individuals to donate small amounts of Bitcoin
at no cost.33
33. Court documents suggest that a number of individuals were associated with the
efforts of Mr. St. Louis, including Benjamin Dichter, Ben Perrin, Jeff Booth, Greg Foss,
Francis Pouliot and an individual using the Twitter handle “@JWWeatherman_”.34
34. On February 12, 2022, a website associated with Mr. St. Louis reported that
donated funds were being moved to a multisig wallet, which would eventually be placed
under the control of the directors of the Freedom 2022 Human Rights and Freedoms
Non-Profit Corporation.35 A multisig wallet is a digital wallet that requires a minimum
number of electronic “signatures” to authorize any transfer of Bitcoin out of it.
35. As of March 2022, Mr. St. Louis had access to at least two signatures, and
Benjamin Dichter had access to at least one signature, meaning that they could jointly
authorize disbursements from the wallet.36 According to Chad Eros, Mr. Dichter was
involved in cryptocurrency fundraising since at least February 11.37
33 Affidavit of Jeremy King, February 15, 2022, paras 73-74, COM00000570.

34Affidavit of Jeremy King, February 15, 2022, paras 38-49, COM00000570; Affidavit of
Jeremy King, February 24, 2022, paras 5-16, Motion Record (Mareva Injunction –
Extension), February 25, 2022, pp 28-38, HRF00001354.
35 Affidavit of Jeremy King, February 15, 2022, para 78, COM00000570.
36 Affidavit of Nicholas St. Louis, March 7, 2022, para 8, Motion Record of the Mareva
Respondents, March 8, 2022, p 29, HRF00001357; Affidavit of Benjamin Dichter, March
7, 2022, para 3, Motion Record of the Mareva Respondents, March 8, 2022, p 63,
HRF00001357.
37 Interview Summary: Chad Eros, p 11, WTS.00000032.
16
36. When the Tallycoin fundraiser raised approximately 22 Bitcoin (roughly
equivalent to $1 million CAD at the time), Mr. St. Louis shut the Tallycoin fundraiser
down. This occurred sometime around February 14, 2022. 38
37. On February 17, 2022, Mr. St. Louis posted on Twitter that he and another
individual had distributed 14.6 Bitcoin (roughly equal to $800,000 CAD at the time) over
the previous 24 hours to truckers in Ottawa.39 This had been accomplished by handing
out physical envelopes that contained instructions on how to access approximately
$8,000 CAD of Bitcoin using a mobile phone.40
38. The envelopes had been distributed over a 24-hour period starting on the
evening of February 16, 2022.41
39. In a February 19, 2022 video broadcast on Twitter Spaces, Mr. St. Louis
indicated that approximately 6.17 Bitcoin remained in a multisig wallet that had
members of the Freedom 2022 Human Rights and Freedoms Non-Profit Corporation as
key holders.42

39 Affidavit of Jeremy King, February 24, 2022, para 8, Motion Record (Mareva
Injunction – Extension), February 25, 2022, p 31, HRF00001354.
Injunction – Extension), February 25, 2022, pp 35-36, HRF00001354.
41 Affidavit of Jeremy King, February 24, 2022, paras 6-17, Motion Record (Mareva
Injunction – Extension), February 25, 2022, p 41, HRF00001354.
17
4.2 Adopt-A-Trucker Cryptocurrency Campaign

40. The Adopt-A-Trucker website created by “Serge” solicited various types of
cryptocurrency donations in addition to email money transfer donations.43 Chris Garrah
deposed that he did not control any of the cryptocurrencies raised from this campaign. 44
4.3 Freedom Convoy Token

41. On February 13, 2022, Pat King announced on a Facebook Live event the
creation of a new cryptocurrency called the Freedom Convoy Token (“FCT”).45 A
webpage launched for FCT explained that individuals should purchase another
cryptocurrency – BNB – and then exchange it for FCT on the PancakeSwap platform.
The FCT website also indicated that 4% of every FCT transaction would be taxed and
sent to an entity called the Freedom Convoy Foundation.46
42. It appears that the attempt to launch FCT was largely unsuccessful. The
Commission does not have any information on the status of the Freedom Convoy
Foundation.
43Affidavit of Chris Garrah dated March 8, 2022, paras 6, 10, Motion Record of the
Mareva Respondents, pp 68-69, HRF00001357; Adopt-A-Trucker Website, February
14, 2022, COM00000564.
44Affidavit of Chris Garrah dated March 8, 2022, para 10, Motion Record of the Mareva
Respondents, p 69, HRF00001357. See also First Report of KSV Restructuring Inc. as
Escrow Agent, p 3, JCF00000096 (escrow agent confirms interviewing “Serge” and
taking possession of cryptocurrency assets).
45Affidavit of Jeremy King, February 15, 2022, paras 29, COM00000570; OPP Situation
Report, February 13, 2022, p 6, OPP00001629; Freedom Convoy Token,
OPS00010821.
46Freedom Convoy Token Webpage, February 14, 2022, Exhibit I to the Affidavit of
Affidavit of Jeremy King, February 15, 2022, COM00000570.
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5. The Termination of the GoFundMe Freedom Convoy Campaign and

the Transition to GiveSendGo
5.1 Campaign Organizers Request Additional Release of Funds
43. On January 28, 2022, organizers of the Freedom Convoy 2022 fundraising
campaign asked GoFundMe about what they needed to do to have additional funds
released.47 GoFundMe responded that they would need information on how much the
organizers were requesting and how many trucker expenses they anticipated
reimbursing. GoFundMe also inquired as to whether the organizers intended to create a
separate bank account for donations.48
44. In a subsequent series of emails on January 28, organizers mentioned that they
were considering setting up a separate bank account to handle donations, and that they
were now working with an accountant, Chad Eros.49
5.2 The Establishment of the Freedom 2022 Human Rights and Freedoms Non-
Profit Corp
45. On January 30, 2022, Chad Eros incorporated “Freedom 2022 Human Rights
and Freedoms” pursuant to the Canada Not-for-Profit Corporations Act (“the Non-Profit
Email from Campaign Organizers to GoFundMe, January 28, 2022, 1:34pm,

47
GFM00000106.
Email from GoFundMe to Campaign Organizers, January 28, 2022, 2:21pm,
48
GFM00000106.
49 Email from Campaign Organizers to GoFundMe, January 28, 2022, 2:32pm; Email
from GoFundMe to Campaign Organizers, January 28, 2:45pm; Email from Campaign
Organizers to GoFundMe, January 28, 3:05pm; Email from GoFundMe to Campaign
Organizers, January 30, 2020, 12:38pm, GFM00000106.
19
Corp.”). The purpose of the Non-Profit Corp., as stated in its Articles of Incorporation,
was:
Advocacy against government, agents of government and any other

organization person or individuals’ actions, laws policies and practices that
violate human rights and freedoms paying special attention to creation of
class systems through mandates, social credit systems (rewards and
punishments for government compliance), passport systems and more. 50
46. The initial directors of the Non-Profit Corp. were Chad Eros and Chris Garrah. 51
Mr. Eros notified Tamara Lich and other individuals about the creation of the Non-Profit
Corp. on the evening of January 30, 2022. Mr. Eros explained that he made Mr. Garrah
a director in order to use his Ontario address as the Non-Profit Corp.’s address.52
47. On January 31, 2022, Chad Eros emailed Ms. Lich and other organizers,
recommending that Ms. Lich transfer donated funds held in her bank accounts to the
Non-Profit Corp. Mr. Eros also wrote:
I recommend a fund raising campaign to raise funds paid directly to the non-
profit bank account that will free you to do whatever is lawful and
transparent with the funds.53
50Certificate of Incorporation and Articles of Incorporation for Freedom 2022 Human

Rights and Freedoms, GFM00000124.
51Initial Registered Office Address and First Board of Directors, Freedom 2022 Human
Rights and Freedoms, GFM00000124.
52 Email from Chad Eros, January 30, 2022, 8:34pm, HRF00001253.
53 Email from Chad Eros, January 31, 2022, 1:45pm, HRF00001601.
20
48. When the Non-Profit Corp was established, it attempted to open a bank account
at TD Bank. The Bank rejected the application.54
5.3 Organizers Consider Moving to GiveSendGo

49. On January 26, 2022, John Ballard contacted Jacob Wells, the Co-Founder of
GiveSendGo. Mr. Ballard identified himself as being associated with a social media
platform known as CloutHub. Mr. Ballard told Mr. Wells that he was aware of the
Freedom Convoy GoFundMe campaign and thought they should work to have it moved
to GiveSendGo in case GoFundMe decided to shut down the campaign it was hosting.55
50. On January 27, 2022, Mr. Ballard told Mr. Wells that he had obtained Ms. Lich’s
email address and wanted to design a mock -up of what the Freedom Convoy campaign
would look like on the GiveSendGo platform. Mr. Wells agreed and created a campaign
on GiveSendGo using the content of the Freedom Convoy 2022 GoFundMe page. The
mock-up campaign was not set up to receive donations.56
51. On the evening of January 27, 2022, Mr. Ballard asked Mr. Wells if Mr. Wells
could provide him with Chris Garrah’s contact information. A GiveSendGo employee
contacted Mr. Garrah, who agreed to share his contact information. It was provided to
Mr. Ballard on January 28, 2022.57 Mr. Ballard then obtained the contact information for
54Affidavit of Chad Eros, March 7, 2022, para 7, Motion Record of the Mareva
21
Mr. Eros from Mr. Garrah. Mr. Ballard contacted Mr. Eros on January 30 to arrange for a
call the next day with a representative of GiveSendGo to discuss starting a fundraiser
on that platform.58
52. Later on January 30, 2022, James Peloso called Mr. Eros about the fundraising
call that was set to occur the next day. Mr. Peloso was associated with a group called
Taking Back Our Freedoms (“TBOF”), a Canadian group opposed to vaccine mandates.
Mr. Peloso indicated that he should be involved in fundraising calls, and that he had
major donors who would not contribute unless Mr. Peloso were on “the inside”. 59
53. On January 31, 2022, the fundraising phone call that Mr. Ballard had organized
took place. Jacob Wells, recalls that he, John Ballard and Chad Eros and “other
Freedom Convoy 2022 campaign representatives were present.”60 Mr. Eros recalled
that Mr. Peloso and Jeff Brain were on the call.61
54. During the January 31 call Mr. Ballard described a plan in which the campaign
organizers would create a new crowdfunding campaign on GiveSendGo, and would use
CloutHub to host the convoy movement’s main web-presence. Mr. Ballard indicated that
CloutHub could be used as a secure means to communicate between organizers. Mr.

22
Brain offered Mr. Eros $250,000 in operational expenses pending the organizers’ ability
to get access to donated funds from crowdfunding platforms.62
55. Mr. Eros did not ultimately use CloutHub for any purpose. He did, however,
agree to work with Mr. Wells to create a fundraising campaign on GiveSendGo that
could begin to solicit funds while organizers continued to negotiate with GoFundMe for
the release of additional funds.63
56. During this phone call, participants discussed the fact that the recently created
Non-Profit Corp. did not yet have a bank account. To create a fundraiser on the
GiveSendGo platform, organizers needed to create an account with Stripe,
GiveSendGo’s main payment processor. A person is required to have a bank account to
set up a Stripe account.64
57. To allow the GiveSendGo campaign to start quickly, Jacob Wells volunteered to
use a Stripe account in his name, connected to his US bank account, to connect to the
Freedom Convoy 2022 fundraiser until such time as the Non-Profit Corp. set up its bank
account. Once the Non-Profit Corp. had a bank account and Stripe account, Mr. Wells

63Interview Summary: Jacob Wells, p 2, WTS.00000004; Interview Summary: Chad
Eros, p 3, WTS.00000032.
64Interview Summary: Jacob Wells, pp 1-2, WTS.00000004; Interview Summary: Chad
Eros, p 3, WTS.00000032.
23
would switch the fundraiser over to the Non-Profit Corp.’s Stripe account, and transfer
any funds that had been received to the Non-Profit Corp.65
58. The GiveSendGo Freedom Convoy fundraiser went live on January 31, 2022.66
As of February 2, 2022, the campaign description for the GiveSendGo campaign was
largely the same as the description for the GoFundMe campaign.67
5.4 GoFundMe Suspends and then Terminates the Freedom Convoy Campaign
59. Starting on or about January 28, 2022, GoFundMe became aware of media
reports describing activities including harassment and violence that were connected to
protestors in Ottawa. GoFundMe was also aware of other media reports that indicated
the protests were peaceful. These reports were monitored both by GoFundMe senior
leadership as well as its Trust and Safety Team. The Trust and Safety Team is
responsible for monitoring both on and off -platform activities by campaign organizers
and beneficiaries to ensure compliance with GoFundMe’s terms of service. 68
60. GoFundMe’s terms of service prohibit campaigns with the explicit or implicit
purpose of promoting the violation of any law, as well as the promotion of hate,
violence, or discrimination.69

Eros, p 3, WTS.00000032.
67 Freedom Convoy 2022 GiveSendGo Page, February 2, 2022, COM00000569.
69 GoFundMe Terms of Service, dated December 31, 2021, pp 14-18 GFM00000040.
24
61. On January 31, 2022, GoFundMe’s VIP team emailed campaign organizers with
the following message:
Hi folks,
Are you able to confirm that funds raised will only go to reimburse the fuel
costs of participants: (1) for their travel to Ottawa (not any other locations or
with any other convoys); and (2) who engage in peaceful and lawful
protests, i.e., no vandalism of property, no blockades of roads and
highways?
We just want to make sure we are still aligned and there isn’t anything that
may be considered a violation of GoFundMe’s Terms of Service.
Thanks in advance for your insight.70
62. GoFundMe did not get a reply to this email.
63. On February 1, 2022, GoFundMe’s VIP team sent the campaign organizers a
follow up email that asked a number of additional questions about how funds had been
distributed to date, how further funds would be distributed, whether there was a
separate bank account set up for the fundraiser, and whether they intended to make a
statement on their fundraising page stating that the organizers did not condone acts or
threats of violence. GoFundMe requested a response within 24 hours. 71
64. GoFundMe’s email also informed organizers that GoFundMe intended to contact
local law enforcement in Ottawa:
Email from GoFundMe to Campaign Organizers, January 31, 2022, 12:46pm,

70
GFM00000106.
Email from GoFundMe to Campaign Organizers, February 1, 2022, 11:55am,
71
GFM00000106.
25
Lastly, we wanted to let you know that, as is our standard practice in

potentially volatile situations like this, we will be reaching out to local law
enforcement to obtain information on the individuals suspected of engaging
in illegal activity during the protests. We will provide as much information as
possible regarding the individuals to you so that you can ensure they do not
receive a disbursement of money from your fundraiser. It is very important
that funds are only distributed to those who engage in peaceful protesting
as our platform cannot be used to fund violence, vandalism or illegal
activities. This is against our terms of service.72
65. Campaign organizers responded to this email copying Chad Eros and stated that
he would be in the best position to answer GoFundMe’s questions.73 GoFundMe
responded later in the day, asking Mr. Eros to provide information on the number of
convoy participants who had been reimbursed to date, the sum of funds that had been
reimbursed to date, and the amount that organizers were requesting be released by
GoFundMe.74
66. GoFundMe did not get an immediate reply to this email.
67. On February 1, 2022, GoFundMe’s Trust and Safety team emailed the Ottawa
Police Service to establish a line of communication. GoFundMe also asked for
information on individuals that the Ottawa Police suspected had engaged in criminal
activities. GoFundMe indicated it was seeking this information so it could work with the

72
GFM00000106.
Email from Campaign Organizers to GoFundMe, February 1, 2022, 2:34pm,
73
GFM00000106.
Email from GoFundMe to Campaign Organizers, February 1, 2022, 6:38pm,
74
GFM00000106.
26
campaign organizers to ensure that funds did not support those individuals.75 The police
acknowledged receipt of the email a few minutes later.76
68. On February 2, 2022, GoFundMe decided to suspend the Freedom Convoy 2022
campaign. While it was suspended, the campaign remained visible on the GoFundMe
website, but had a banner indicating that the campaign was under review. Donations to,
and withdrawals from the campaign were also disabled. The decision to suspend the
campaign was taken by senior executives of GoFundMe. 77
69. The campaign organizers were notified of GoFundMe’s decision on February 2,
2022 at 1:29pm. GoFundMe indicated that the suspension was due to reports:
of potentially unlawful activities by protesters in Ottawa and nonresponse to

our multiple requests for assurance that no funds raised by GoFundMe have
been or will be transmitted to individuals suspected of acting unlawfully. 78
70. GoFundMe asked the campaign organizers to respond to its February 1, 2022
email with answers to the questions it has asked. 79
71. On February 2, 2022, members of GoFundMe’s Trust and Safety team had a
telephone call with Deputy Chief Bell of the Ottawa Police Service. During this phone
Email from GoFundMe to the Ottawa Police Service, February 1, 2022, 4:30pm,
75
GFM00000183.
Email from Ottawa Police Service to GoFundMe, February 1, 2022, 4:42pm,
76
GFM00000180.
78
GFM00000160.
79
GFM00000160.
27
call, Deputy Chief Bell told GoFundMe that the protests taking place in Ottawa involved
the harassment of residents and that there were concerns for safety and livability for the
people of Ottawa.80
72. On February 3, 2022, three representatives of GoFundMe, including its General
Counsel, spoke by video with Ottawa Mayor Jim Watson and City Solicitor David
White.81 The Mayor discussed the situation in Ottawa. The Mayor recalls indicating in
that meeting that the GoFundMe funds were funding what he considered to be unlawful
activity that was harmful to the City.82 Kim Wilford, GoFundMe’s General Counsel,
recalls the Mayor describing a violent situation with individuals having their masks
ripped off, gas canisters circulating, guests destroying hotel rooms and threatening
behaviour on the street and in stores. Ms. Wilford recalls the Mayor identifying the
perpetrators of these acts as convoy participants, and expressing concern about the
possibility of GoFundMe releasing additional funds. 83
80Interview Summary: Kim Wilford, p 3, WTS.00000007; Letter from GoFundMe

Counsel to Commission Counsel, August 9, 2022, p. 3, GFM00000583; 2022 02 02
Meeting with Gofundme notes, OPS00005719.
Counsel to Commission Counsel, August 9, 2022, p. 3, GFM00000583; Interview
Summary: Jim Watson, p 4, WTS.00000018; Interview Summary: David White, p 3,
WTS.00000036; Microsoft Teams Calendar Invitation – 11am Meeting between City and
GoFundMe, OTT00006470.
82 Interview Summary: Jim Watson, p 4, WTS.00000018.
28
73. On February 3, 2022, Keith Wilson, counsel for the Non-Profit Corp. sent a letter
to GoFundMe alerting them to the creation of the Non-Profit Corp.84 The letter provided
responses to the questions contained in GoFundMe’s February 1, 2022 email.85 Mr.
Wilson’s letter indicated that the organizers’ “intention is not to reimburse those
committing unlawful or criminal acts.” The letter also stated:
The intention [of the organizers] is to transfer the [already released] funds
to the Convoy Corp so proper disbursement and accounting is completed.
We have recommended to the Committee that the monies received today

be treated by the Committee as trust funds to be transferred to the Freedom
2022 bank account for disbursement in accordance with the posted objects.
This will ensure provision of proper bookkeeping, accounting and legal
oversight of the disbursement of funds.
The Committee is not requesting a further release at this time as the

Committee continues to complete the establishment of the banking
arrangements for Convoy Corp. The Committee and its accountant
anticipate that the process will be completed in the next 24 hours. Once we
provide you with confirmation that this has occurred, the Committee
requests that the full balance is transferred to the Convoy Corp bank
account.86
74. A meeting also was arranged to take place on February 3 involving GoFundMe,
Ms. Lich, Mr. Wilson, and Mr. Eros. The parties discussed Mr. Wilson’s letter from
84 Letter from Keith Wilson to GoFundMe, February 3, 2022, GFM00000131.

85
GFM00000106.
86 Letter from Keith Wilson to GoFundMe, February 3, 2022, pp 2-3, GFM00000131.
29
earlier in the day, and Mr. Eros provided information to GoFundMe about how he
intended to structure the financial operations of the Convoy Corporation.87
75. When GoFundMe reviewed Mr. Wilson’s letter, they had concerns about the
organizers’ ability to implement their stated intention not to disburse funds to individuals
who were involved in illegal activities.88
76. On February 4, 2022, representatives of GoFundMe had a second phone call
with Deputy Chief Bell. Deputy Chief Bell informed GoFundMe that the situation was
escalating and that acts of violence were taking place. 89
77. Throughout this period of time, GoFundMe employees had been receiving
harassing messages from members of the public, including death threats. On February
4, 2022, GoFundMe’s Trust and Safety Team identified a man who was using his social
media accounts to encourage this harassment as an associate of Tamara Lich.
GoFundMe had serious concerns about the safety and wellbeing of its employees. 90
87Interview Summary: Chad Eros, p 8, WTS.00000032; Interview Summary: Keith

Wilson, p 5, WTS.00000058; Email from Eva Chipiuk to GoFundMe, February 3, 2022,
1:53pm, GFM00000083; Email from Keith Wilson to GoFundMe, February 3, 2022,
1:53pm, GFM00000086.
88 Interview Summary: Kim Wilford, pp 4-5, WTS.00000007.
30
78. On February 4, 2022, GoFundMe decided to remove the Freedom Convoy 2022
campaign from its platform. The decision was made with the input of its senior
leadership.91
5.5 GoFundMe Refunds Donations to the Freedom Convoy 2022 Campaign

79. When GoFundMe decided to remove the Freedom Convoy 2022 campaign from
its platform, there was a significant amount of money that had been donated but not
distributed. GoFundMe initially decided to permit donors to choose whether to receive a
refund, or to have their donation given to another charity chosen by the campaign
organizers and verified by GoFundMe.92 The second option was included due to the
statements in the campaign description and the January 27, 2022 Attestation Letter that
indicated that excess donations would be donated to a charity.93
80. When this refund decision was announced on February 4, 2022, some online
statements claimed that GoFundMe would itself be selecting the charity that non-
refunded donations would go to, or that GoFundMe would keep the funds for itself. This
resulted in an increase in the volume of threatening emails that GoFundMe staff
received.94

Counsel to Commission Counsel, August 9, 2022, p. 4, GFM00000583; GoFundMe
Statement on the Freedom Convoy 2022 Fundraiser (2/4/2022), GFM00000273.
Letter from GoFundMe Counsel to Commission Counsel, August 9, 2022, p. 4,
93
GFM00000583.
Counsel to Commission Counsel, August 9, 2022, p. 5, GFM00000583.
31
81. GoFundMe then decided to refund all donations made to the Freedom Convoy
2022 Campaign without an option for donations to be sent to an alternative charity. 95
This decision was announced on February 5, 2022. 96
5.6 TD Bank Places Holds on Tamara Lich’s Bank Accounts

82. On January 28, 2022, a branch manager with TD Bank attempted to contact
Tamara Lich by phone to discuss the status of her accounts with TD. She sent Ms. Lich
an email later that day indicating that she wished to speak with her because TD
understood that Ms. Lich was “receiving charitable donations via email money
transfers.”97
83. TD attempted to contact Ms. Lich at this time because it engages in routine
monitoring of public source media for potential impacts on its business. This monitoring
identified fundraising related to the “Freedom Convoy” and its connection to Ms. Lich’s
personal bank account.98
84. TD Bank continued to try to contact Ms. Lich, but was unsuccessful.99

UPDATE: GoFundMe to refund all Freedom Convoy 2022 donations (2/5/2022),
96
GFM00000273.
Toronto-Dominion Bank, p 25, TDB00000004; Email from TD Bank to Tamara Lich,
January 28, 2022, 4:31pm, Application Record of the Toronto-Dominion Bank, p 219,
TDB00000004.
98 Toronto Dominion Bank Institutional Report, para 3, TDB.IR.00000001.
99 Toronto Dominion Bank Institutional Report, paras 6-9, TDB.IR.00000001.
32
85. On February 2, 2022, $1,000,000 CAD from the GoFundMe Freedom Convoy
2022 campaign was transferred into the First TD Account. The next day – February 3 –
TD emailed Ms. Lich and Mr. Barber separately with identical emails that read:
As we continue to be unable to reach you, we are further writing to request

that you contact [a TD Bank representative] with regard to your account.
We noticed that the funds you have received via Go Fund Me were recently
deposited into your personal account. We need to speak with you to discuss
specific account requirements for funds that have been collected in trust for
beneficiaries.
In the meantime, we have placed a temporary hold on these funds

($1,000,000.00) and we would like the opportunity to speak with you about
these requirements.
Please contact us at your earliest convenience. I am in the office each day

from 9am – 5pmEST.100
86. On February 3, 2022, TD Bank became aware of a large transfer of funds from
the First TD Account – which had email money transfer donations in addition to the now
frozen $1 Million GoFundMe funds – to the Second TD Account. On February 4, 2022,
TD Bank also placed a hold on the Second TD Account.101
87. On February 5, 2022, Tamara Lich attempted to make a wire transfer to Northern
Air Charter (P.R.) Inc. from an Ottawa TD Branch. This transaction was denied. Ms.
Lich also left a voicemail message with TD on February 5, inquiring into the hold placed
100 Affidavit of Kevin Moffatt, dated February 15, 2022, paras 48-49, Application Record
of the Toronto-Dominion Bank, pp 25-26, TDB00000004; Email from TD Bank to
Tamara Lich, February 3, 2022, 11:12am, Application Record of the Toronto-Dominion
Bank, p 221, TDB00000004.
101Affidavit of Kevin Moffatt, dated February 15, 2022, para 50, Application Record of
33
on her account. Ms. Lich indicated that another individual was assisting her with her
finances related to her accounts.102
88. TD Bank spoke with Ms. Lich and her advisor on February 6 and 10, 2022. TD
Bank was not satisfied with the explanations provided. As a result, on February 10,
2022, TD implemented a freeze on both the First and Second TD Accounts.103
89. On February 17, 2022, TD Bank brought an application in the Ontario Superior
Court of Justice for an order to pay the donations contained in the First and Second TD
Accounts into Court on the basis that the money was beneficially owned by unknown
third parties.104 This type of order is known as an “interpleader” order.
6. The Continuation of Campaigns on GiveSendGo

6.1 The Freedom Convoy 2022 Campaign
90. After the GoFundMe campaign was removed, organizers used their social media
presence to direct donors to the GiveSendGo Freedom Convoy 2022 page. The rate of
donations to the GiveSendGo campaign increased significantly as a result. 105
of the Toronto-Dominion Bank, pp 26-27, TDB00000004; Wire Payment Information
Form, Application Record of the Toronto-Dominion Bank, p 225, TDB00000004.
of the Toronto-Dominion Bank, p 27, TDB00000004.
Notice of Motion, dated February 17, 2022, Application Record of the Toronto-
104
Dominion Bank, p 26, TDB00000004.

34
91. On February 4, 2022, Chad Eros sent Jacob Wells the Certificate of
Incorporation and Articles of Incorporation for the Non-Profit Corp.106 Jacob Wells
granted Chad Eros administrative privileges for the Freedom Convoy 2022 GiveSendGo
page.107
92. Between January 31 and February 7, 2022 donations to the Freedom Convoy
2022 GiveSendGo campaign accumulated in the Stripe account that Jacob Wells had
created pending the Non-Profit Corp. establishing its own Stripe account. Stripe became
aware that Mr. Wells was raising funds on behalf of the Freedom Convoy organizers
and contacted Mr. Wells to obtain assurances that the intended recipients of the funds
would in fact receive them.108
93. On February 7, 2022, approximately $4.9 Million USD was transferred from this
Stripe account into Mr. Wells’ personal bank account. Mr. Wells indicated that this
occurred automatically, and that he was surprised when this transfer occurred.109
94. Later in the day on February 7, 2022, Chad Eros emailed Jacob Wells additional
documents related to the Non-Profit Corporation.110 These were unsigned documents
adopting bylaws, appointing officers, and issuing memberships. The documents also
suggested that on February 3, 2022, Chis Garrah resigned his position as Director of
106Certificate and Articles of Incorporations of Freedom 2022 Human Rights and

Freedoms, GSG00000005.
108 Interview Summary: Sam Swartz & Dan Alexander, p 3, WTS.00000005.
35
the Non-Profit Corp., and that Tamara Lich, Benjamin Dichter, Sean Tiessen, Chris
Barber and Miranda Gasinor were added as directors.111 The next day, Mr. Eros
emailed Mr. Wells a similar package of documents which bore signatures, as well as
some additional handwritten amendments.112
95. At this time, Mr. Eros had still not been able to set up a bank account for the
Non-Profit Corporation. On or about February 6 or 7, 2022, Mr. Eros asked whether
lawyers for the Justice Centre for Constitutional Freedoms (“JCCF”) could use their trust
account to receive funds. Keith Wilson agreed to do so and Mr. Eros signed a retainer
agreement with Mr. Wilson for this purpose. Mr. Eros then worked with Mr. Wells to set
up a stripe account and connect it to the Freedom Convoy 2022 fundraiser on
GiveSendGo.113
96. On February 7, 2022, Mr. Eros began collecting donated funds into his Stripe
account via a GiveSendGo fundraiser. There is conflicting evidence available on the
number of Freedom Convoy 2022 fundraisers that existed on GiveSendGo at this time.
97. According to Stripe, there existed two distinct fundraisers on GiveSendGo. The
first was a US-based fundraiser linked to Mr. Wells’ Stripe and a separate Canadian-
based fundraiser linked to Mr. Eros’s Stripe account.114
111 Documents of Incorporation and Bylaws – Unsigned, GSG00000002.

112Interview Summary: Jacob Wells, p 3, WTS.00000004; Documents of Incorporation
and Bylaws – Signed, GSG00000007.
36
98. According to both Mr. Wells and Mr. Eros, there was only ever one Freedom
Convoy 2022 fundraiser on GiveSendGo. They explained that when Mr. Eros’s Stripe
account was set up, Mr. Wells switched the Stripe account associated with the
fundraiser from his own to Mr. Eros’. 115
99. On February 8, 2022, Stripe contacted Jacob Wells and asked him to provide a
copy of the agreement between himself and the Freedom Convoy 2022 campaign
organizers that showed that Mr. Wells was authorized to collect funds on their behalf.
Stripe also asked what measures GiveSendGo was taking to ensure that funds from the
campaign would not be used to promote or support violence or other unlawful activity.116
Mr. Wells replied on February 9, 2022 indicating that he would respond shortly.117
100. On February 9, 2022, Mr. Wells emailed Chad Eros a document entitled
“Authorization to Fundraise”. The purpose of this document was to formalize the
agreement that Mr. Wells had reached with the campaign organizers on the January 31,
2022 phone call to collect funds while the organizers were setting up the Non-Profit
Corp. bank account.118

Eros, p 5, WTS.00000032. See also Message from GiveSendGo to Stripe, February 21,
2022, 1:38am, STR00000073 (Jacob Wells indicating to Stripe that some funds from the
Freedom Convoy campaign were received into a Stripe account in the name of the
organization’s treasurer).
Message from Stripe to Jacob Wells, February 8, 2022, STR00000056,
116
STR00000061.
117 Message from Jacob Wells to Stripe, February 9, 2022, STR00000058.
37
101. The Authorization to Fundraise was eventually signed by Chad Eros, Tamara
Lich and Jacob Wells, and was dated February 9, 2022. 119
102. On February 8, 2022, Chad Eros was notified by Stripe that they had put a pause
on his account due to questions about certain products that they believed Mr. Eros was
selling. This message was in error as Mr. Eros’ account was connected to a fundraiser,
and there were no products being sold in connection with his account. 120 According to
Stripe, the pause was removed the same day.121 According to Mr. Eros, Stripe indicated
that they would no longer provide Mr. Eros with services, but that the account was able
to receive donations. It could not pay out any money received.122
103. Mr. Eros reports that Keith Wilson provided Jacob Wells with wire transfer
information on February 9 for the purposes of transferring over $3 million dollars from
the donated funds that had previously been paid into Mr. Wells’ personal account into
Mr. Wilson’s trust account. On February 10, Mr. Wilson asked Mr. Eros to get Mr. Wells
to cancel the wire, which he did.123
119Authorization to Fundraise, dated February 9, 2022, Exhibit C to the Affidavit of Chad

Eros, dated March 8, 2022, Motion Record of the Mareva Respondents, March 8, 2022,
p 138, HRF00001357.
Eros, p 5, WTS.00000032; Text Message from Chad Eros to Jacob Wells, February 8,
2022, GSG00000010; Interview Summary: Sam Swartz and Dan Alexander, p. 3,
WTS.00000005.
121 Interview Summary: Sam Swartz and Dan Alexander, p 3, WTS.00000005.
123 Interview Summary; Chad Eros, p 4, WTS.00000032.
38
104. Mr. Eros contacted Jacob Wells about the pause that had been placed on his
account, and Mr. Wells switched the Freedom Convoy 2022 account back to his
personal Stripe Account sometime between February 10 and 11, 2022.124
6.2 The Ontario Restraint Order

105. On February 10, 2022 the Attorney General of Ontario obtained an ex parte
restraint order pursuant to section 490.8 of the Criminal Code of Canada from the
Ontario Superior Court of Justice.125 The Court held that there were reasonable grounds
to believe that the donations made to the Freedom Convoy 2022 and the Adopt-A-
Trucker campaigns on GiveSendGo constituted offence related property. The order
provided that all persons, including GiveSendGo, Stripe, Chris Garrah and the Non-
Profit Corp were prohibited from disposing of, or otherwise dealing with, in any manner
whatsoever, any interest in the property.
106. When RBC received a copy of the Restraint Order, it restrained the account in
the name of Chris Garrah that was receiving donations.126
107. Starting on February 11, 2022, Stripe began receiving inquiries from its partner
financial institutions about how it was responding to the Restraint Order. 127 Stripe

Eros, p 5, WTS.00000032.
125 Restraint Order, dated February 10, 2022, STR00000009.
Letter from RBC to Keith Wilson, February 24, 2022, Motion Record of the Mareva
126

Email from HSBC Canada to Stripe, February 11, 2022, 12:03pm, STR00000001;
127
Email from Peoples Group to Stripe, February 11, 2022, 9:33am, STR00000004; Email
39
responded to its Canadian financial institutions that it was suspending payments to and
from the Adopt-A-Trucker campaign.128 The last pay-out by Stripe to Mr. Garrah’s RBC
account was on February 14, 2022.129
108. HSBC Canada responded, asking whether Stripe had also paused charges and
payouts to the Freedom Convoy 2022 campaign.130 Stripe answered:
We are evaluating with our counsel if we are required to take steps in

relation to any accounts in addition to the Canadian Adopt-A-Trucker
campaign, given the global nature of protest actions. We note that the
“Freedom Convoy 2022” campaign referenced in the Order is a U.S.
campaign that is currently being processed with our U.S. financial
partners.131
109. A similar message was provided to Peoples Group, another of Stripe’s Canadian
financial institution partners.132
110. HSBC Canada responded by stating that “it’s clear that we don’t fully understand
how GiveSendGo processes transactions in this scenario” and asked Stripe a series of
questions, including:
from Wells Fargo to Stripe, February 11, 2022, 10:34am, STR00000198; Email from
Mastercard to Stripe, February 15, 2022, 10:22pm, STR00000173.
128Email from Stripe to HSBC Canada, February 11, 5:43pm, STR00000005; Email
from Stripe to Peoples Group, February 11, 2022, 5:39pm, STR00000004. See also
Email from Stripe to Wells Fargo, February 16, 2022, 6:11pm, STR00000198; Email
from Stripe to Mastercard, March 2, 2022, 6:20pm, STR00000195.
Redacted Bank Statements Adopt-A-Trucker, GAR00000001; Project TCH Subject
129
Report, Case No. C2202559939, p 2, PB.NSC.CAN.00005944_REL.0001.

130 Email from HSBC Canada to Stripe, February 11, 2022, 5:56pm, STR00000006.
131 Email from Stripe to HSBC Canada, February 11, 2022, 8:51pm, STR00000007.
132 Email from Stripe to Peoples Group, February 14, 2022, 10:51pm, STR00000123.
40
Under the scenario where the GiveSendGo platform for Freedom Convoy
2022 is based in the USA, does Stripe (and in turn HSBC Bank Canada)
play any role in accepting any donations within Canada or payouts within
Canada?133
111. Stripe replied the following day, stating that “Stripe’s Canadian operations do not
play any role in accepting donations within Canada or processing payouts within
Canada for U.S.-based Freedom Convoy 2022 campaigns on GiveSendGo.” 134
112. Stripe had, however, frozen the account associated with Chad Eros that received
funds in connection with the GiveSendGo Freedom Convoy 2022 fundraiser .135
113. On February 11, 2022, Stripe notified Chris Garrah that it was “pausing charges
and payouts for the Canadian Adopt-A-Trucker campaign” as a result of the restraint
order.136 Stripe sent a similar notification to Jacob Wells. 137 Mr. Wells responded
“Thanks for reaching out about this. Not a problem. We will move this campaign over to
our alternative payment solution.”138 Mr. Wells then moved the Adopt-A-Trucker
campaign from Stripe to GiveSendGo’s alternative payment processor, RallyPay.139
134 Email from Stripe to HSBC Canada, February 12, 2022, 5:20am, STR00000011.
135Message from GiveSendGo to Stripe, February 21, 2022, 1:38am, STR00000073;
Message from Stripe to GiveSendGo, February 21, 7:48am, STR00000073; Message
from Stripe to GiveSendGo, February 22, 12:37am, STR00000073.
136 Stripe, “Important Notice Regarding Your Fundraiser”, STR00000060.
137 Stripe, “Regarding Adopt-a-trucker Campaign”, STR00000070.
138 Message from Jacob Wells to Stripe, STR00000063.
139Interview Summary: Jacob Wells, p 4, WTS.00000004; Email from HSBC to Stripe,
February 18, 2022, 4:04pm, STR00000038.
41
114. The Adopt-A-Trucker campaign on GiveSendGo continued to accept payments in
USD.140
115. On February 13, 2022, GiveSendGo received a copy of the Restraint Order from
Detective Christopher Rhone of the Ottawa Police Service.141
116. On February 15, 2022, Stripe contacted GiveSendGo to follow up on its request
for a copy of the agreement between Jacob Wells and the Freedom Convoy 2022
campaign organizers. Stripe also requested a phone call to discuss GiveSendGo’s
distribution plans in the light of the invocation of the Emergencies Act and the
promulgation of the Emergency Economic Measures Order.142 Mr. Wells responded and
apologized for not yet sending a copy of the agreement over. He agreed to Stripe’s
requested call.143
117. A call took place on February 16, 2022. Afterwards, Stripe sent GiveSendGo a
message that stated in part:
We understand that you only plan to distribute the funds in a manner

compliant with Canadian law. Please provide (i) a confirmation that you will
not make any disbursements unless it is legal to do so and (ii) detail other
plans GSG has to comply with the Emergency Order. 144
118. GiveSendGo responded:
140 Email from HSBC Canada to Stripe, February 17, 2022, 12:39, STR00000021;
Interview Summary: Jacob Wells, p 4, WTS.00000004.
142 Message from Stripe to GiveSendGo, February 15, 3:26am, STR00000073.
143 Message from GiveSendGo to Stripe, February 15, 3:52am, STR00000073.
144 Message from Stripe to GiveSendGo, February 16, 3:41am, STR00000073.
42
…I can confirm that I will not disbursed any funds that I am holding until
there is a legal plan in place for them to be disbursed under Canadian Law.
We are also in receipt of the Emergency Order you provided and are still
assessing what requirements it will obligate us to. I will respond quickly as
I can to that question once I have received word from our legal team. 145
119. Stripe asked GiveSendGo to update its donation page to confirm that it would
only distribute funds in a manner permitted under Canadian law and to disclose to
donors that there were restrictions in place that could impede the ability of GiveSendGo
to disburse funds. Stripe indicated that if these steps were not taken by 2pm on
February 17, 2022, it would pause the account.146
120. GiveSendGo responded:
Hi,
Campaign update has been posted as follows:
***Funds from this campaign will be disbursed in a manner permitted under

Canadian Law and ***There are current restrictions in place that might
impede the immediate ability to disburse funds to this recipient.147
121. On February 16, 2022, Stripe emailed Wells Fargo, a US financial institution, and
confirmed that Stripe was continuing to process payments for the Freedom Convoy
2022 campaign.148
145 Message from GiveSendGo to Stripe, February 16, 6:46pm, STR00000073.

146 Message from Stripe to GiveSendGo, February 17, 2022, 3:39am, STR00000073.
147 Message from GiveSendGo to Stripe, February 17, 2022, 4:38pm, STR00000073.
148 Email from Stripe to Wells Fargo, February 16, 2022, 6:11pm, STR00000198.
43
7. The Non-Profit Corporation’s Credit Union Account

122. Non-Profit Corp. opened an account with the Steinbach Credit Union for a brief
period of time. While this account was open, an individual deposited $10,000 CAD into it
as a donation. Shortly thereafter, the Credit Union closed the Non-Profit Corp.’s account
and sent a $10,000 bank draft in the name of the Corporation to Chris Garrah. 149
8. Cash Donations during the Ottawa Protests

123. During the Ottawa protests, many participants left cash donations at tents that
were collecting money to purchase fuel and food. One donation site was set up next to
the main stage that had been erected in the downtown core. An unknown person placed
a water jug there along with a sign soliciting donations for the Adopt-A-Trucker
campaign. Mr. Eros reported that neither he nor Mr. Garrah was involved in setting this
up.150
124. Money that was left at the stage was taken to the Swiss Hotel where Mr. Garrah
and Mr. Eros were staying, sometime around February 10 or 11. Mr Eros indicated that
they should take steps to account for the money. A system was later put into place
whereby the money was placed into numbered envelopes with $500 in each one.
People would then sign out these envelopes and distribute them to truckers. Records
Affidavit of Chad Eros, March 7, 2022, para 8, Motion Record of the Mareva
149

44
were kept of the identities of the individuals who were given envelopes, and this
information was tracked on a spreadsheet maintained by Piper Bulford.151
125. Mr. Eros estimates that, on an average day, approximately $20,000 CAD in cash
flowed through the Swiss Hotel from the main stage donation collection. 152
126. Mr. Eros reported that a similar system was in place at the ARC hotel with a
group of individuals associated with TBOF. Mr. Eros did not have direct knowledge of
the source of their funding, but understood that individuals would bring cash to the ARC
hotel, which would be processed and placed into envelopes in the amount of $2,000
CAD before being distributed to protestors.153
9. Events following the Publication of the Emergency Economic

Measures Order
127. Following the proclamation of a public order emergency on February 13, 2022,
Stripe had a series of communications with its Canadian financial institution partners
related to their obligations under the Emergency Economic Measures Order.154

154 Email from HSBC Canada to Stripe, February 15, 2022, 3:59pm, STR00000012;
Email from Stripe to HSBC Canada, February 15, 2022, 4:22pm, STR00000013; Email
from HSBC Canada to Stripe, February 15, 2022, 5:15pm, STR00000014; Email from
Stripe to HSBC Canada, February 15, 2022, 5:54pm, STR00000015; Email from HSBC
Canada to Stripe, February 15, 2022, 11:54pm, STR00000016; Email from Stripe to
HSBC Canada, February 16, 2022, 4:10pm, STR00000018; Email from HSBC Canada
to Stripe, February 16, 2022, 5:18pm, STR00000019; Email from HSBC Canada to
Stripe, February 17, 12:39am, STR00000021; Email from HSBC Canada to Stripe,
45
128. HSBC Canada provided Stripe with a list of persons HSBC had reason to believe
were designated persons under the Emergency Economic Measures Order on February
15, 2022.155 This list included Adopt-A-Trucker, Chris Garrah, the Non-Profit-Corp., and
its directors including Chad Eros and Tamara Lich. HSBC Canada provided updated
lists to Stripe on February 17, 156 and twice on February 18.157
129. As a result of the Emergency Economic Measures Order, Stripe suspended 119
accounts.158 This included older, inactive accounts, as well as other accounts that, while
associated with designated persons, were not directly connected to activities prohibited
by the Emergency Measures Regulations.159
130. On February 23, 2022, HSBC Canada informed Stripe that the “Emergency
Measures Order restrictions are being eased and all the subject names associated with
February 17, 2022, 8:31pm, STR00000023; Email exchange between Peoples Group
and Stripe, February 15 – February 18, 2022, STR00000027; Email from Stripe to
HSBC Canada, February 18, 2022, 12:55am, STR00000028; Email from HSBC Canada
to Stripe, February 18, 2022, 3:12pm, STR00000030; Email from HSBC Canada to
Stripe, February 18, 2022, 7:10pm, STR00000033; Email from Stripe to HSBC Canada,
February 18, 2022, 7:22pm, STR00000035; Email from Stripe to HSBC Canada,
February 18, 2022, 9:12pm, STR00000036; Email from HSBC Canada to Stripe,
February 18, 2022, 9:28pm, STR00000037.
Email from HSBC Canada to Stripe, February 18, 2022, 3:12pm, STR00000030;
157
Email from HSBC Canada to Stripe, February 18, 2022, 7:10pm, STR00000033.
158 Stripe Institutional Report, p 3, STR.IR.00000001.
46
that order no longer need to be frozen/blocked” but that the Restraint Order remained in
place.160 Stripe confirmed that it continued to freeze accounts pursuant to the Order.161
10. The February 17th Mareva Injunction

131. On February 17, 2022, the Plaintiffs in a proposed class action lawsuit against
organizers and participants in the Ottawa protests obtained a Mareva Injunction from
the Ontario Superior Court of Justice.162 The defendants in the class action included
Chris Barber, Benjamin Dichter, Tamara Lich, Chad Eros, Chris Garrah and Nicholas
St. Louis. The order prohibited the named defendants from dealing with a range of
assets, including:
a. All assets of the Non-Profit Corp.;
b. All funds held in the bank accounts in which Tamara Lich received email
money transfers;
c. All funds held in the bank accounts in which Chris Garrah received
donations via the GiveSendGo Adopt-A-Trucker campaign;
d. All cryptocurrencies controlled by Chris Garrah or contained in six listed
wallet addresses; and
161 Email from Stripe to HSBC Canada, February 24, 12:26am, STR00000039.
162 Order, dated February 17, 2022, JCF00000092.
47
e. All cryptocurrencies controlled by Nicholas St. Louis and/or Benjamin
Dichter or contained in 17 listed wallet addresses or transferred to other
digital wallets.
132. A series of banks, crowdfunding platforms, and cryptocurrency platforms,
exchanges and custodians were specifically required to freeze any such assets under
their control pursuant to the order.
133. On March 6, 2022, GiveSendGo informed Stripe that it had decided to initiate a
refund of donations made to the Freedom Convoy 2022 campaign into Jacob Wells’
Stripe account.163 This did not occur immediately because many of the funds had been
deposited to Mr. Wells’ personal bank account.
134. On March 9, 2022, the terms of the Mareva injunction were varied to appoint an
escrow agent to receive and hold the frozen cryptocurrencies and Adopt-A-Trucker
funds in Chris Garrah’s bank account. 164 The funds held in the First TD Account and
Second TD Account, which were the subject of TD’s interpleader application, were
subsequently also transferred to the escrow agent.165
163 Email from GiveSendGo to Stripe, March 6, 2022, 7:01pm, STR00000079.

164Li et al. v Barber et al., 2022 ONSC 1351, COM00000404; Order, dated February
28, 2022, Appendix A to the First Report of KSV Restructuring Inc. as Escrow Agent,
JCF00000096.
Motion Record of the Interested Party, the Toronto Dominion Bank, March 8, 2022,
165
TDB00000002; Li et al. v Barber et al., 2022 ONSC 1543, paras 8-11, COM00000405.
48
135. On March 14, 2022, GiveSendGo disabled both the Freedom Convoy 2022 and
the Adopt-A-Trucker campaigns from receiving any new donations. 166
136. On March 22, 2022, Stripe emailed GiveSendGo to inquire whether they had
wired a top-up payment into Mr. Wells’ Stripe account “with funds already paid out
($5,561,217.09)”.167 Mr. Wells replied that day, indicating that the funds would be wired
within the next day or two.168 On March 23, 2022, Mr. Wells confirmed that the wire had
been initiated.169
137. On March 24, 2022, Stripe confirmed that it would start the refund process, and
that donors would receive their donations back in roughly 4-5 days. Stripe asked
GiveSendGo to inform donors that donations to the US Freedom Convoy 2022
campaign (i.e., donations made into Mr. Wells’ Stripe account) would be refunded, but
that Donations to the Canadian Freedom Convoy 2022 campaign (i.e., donations made
into Chad Eros’s Stripe account) and the Adopt-A-Trucker campaign would not be
refunded due to the Ontario Restraint Order.170
138. On March 28, 2022, Stripe confirmed to GiveSendGo that it had initiated a refund
of donations made to Mr. Wells’ Stripe account.171

167 Email from Stripe to GiveSendGo, March 22, 2022, 5:57pm STR00000079.
168 Email from GiveSendGo to Stripe, March 22, 2022, 4:49pm, STR00000079.
169 Email from GiveSendGo to Stripe, March 23, 2022, 10:42am, STR00000079.
170 Email from Stripe to GiveSendGo, March 24, 2022, 11:01pm, STR00000079.
49
139. On May 4, 2022, Stripe contacted HSBC Canada, which held the accounts where
the Adopt-A-Trucker/Garrah and Freedom Convoy 2022/Eros funds were held, notifying
them of the escrow order.172 A series of emails followed regarding the transfer of the
restrained funds into escrow.173 Stripe eventually paid these funds into escrow.174
11. Summary of Financial Information Available to the Commission

140. This section summarizes the financial information currently available to the
Commission, including the amounts raised by various fundraisers and their ultimate
disposition. A visual summary of the information for which there are specific dollar
figures available is contained at the end of this report.
11.1 GoFundMe Freedom Convoy 2022 Donations

141. According to information provided by GoFundMe, the Freedom Convoy 2022
campaign hosted on GoFundMe had 133,836 donors. 175 Approximately 107,000
donations originated in Canada (86%). Approximately 14,000 originated in the United
172 Email from Stripe to HSBC Canada, May 4, 2022, 4:25pm, STR00000045.
173 Email from HSBC Canada to Stripe, May 4, 2022, 9:05pm, STR00000045; Email
from Stripe to HSBC Canada, May 5, 2022, 5:58pm, STR00000046; Email from HSBC
Canada to Stripe, May 9, 2022, 1:23pm, STR00000047; Email from HSBC Canada to
Stripe, May 9, 2022, 9:20pm, STR00000048; Email from Stripe to HSBC Canada, May
9, 2022, 10:26pm, STR00000049; Email from HSBC Canada to Stripe, May 10, 2022,
2:56pm, STR00000050.
174 Interview Summary: Sam Swartz and Dan Alexander, pp 4-5, WTS.00000005.
175
GFM00000583.
50
States of America (11%). Approximately 4,000 originated from 80 other countries
(3%).176
142. This campaign raised approximately $10,060,000 CAD before it was shut down.
Approximately $9 million CAD originated from Canada (89%). Approximately $870,000
CAD originated from the United States of America (9%). Approximately $190,000 CAD
originated from 80 other countries (2%).177
143. As of February 10, 2022, 93% of all donations to the GoFundMe Freedom
Convoy 2022 campaign had been refunded. The remaining refunds were either awaiting
settlement or – in the case of 144 donations – were subject to chargebacks or
disputes.178
144. According to court documents, the $1 million CAD that was disbursed to Ms.
Lich’s TD account was frozen and ultimately paid into escrow. 179
11.2 Email Money Transfer Donations to the Freedom Convoy 2022 Campaign
145. According to records obtained from the Toronto Dominion Bank, approximately
3,000 email money transfers were made to the email addresses associated with the
Interview Summary, Kim Wilford, p 6, WTS.00000007; Letter from GoFundMe

176
Counsel to Commission Counsel, September 19, 2022, GFM000000584.

Interview Summary, Kim Wilford, p 6, WTS.00000007; Letter from GoFundMe
177
Counsel to Commission Counsel, September 19, 2022, GFM000000584.

178Email from Stripe to Peoples Group, February 10, 2022, 5:41pm, STR00000098;
GFM00000583.
179 First Report of KSV Restructuring Inc. as Escrow Agent, p 4, JCF00000096.
51
Freedom Convoy 2022 campaign and deposited into the First TD Account. 180 The total
amount of money deposited by email money transfer was approximately $419,416.63
CAD.181 These donations originated from Canadian domiciled financial institutions.182
146. On January 31, 2022, an email money transfer for $3,000 was sent from the First
TD Account to an individual who appeared to be a security guard in Ottawa.183
147. On January 31, 2022, an email money transfer for $3,000 was sent from the First
TD Account to another TD Account in the name of Tamara Lich. This money was
immediately withdrawn as cash at a TD Bank branch in Ottawa. 184
148. The following amounts were transferred from the First TD Account to the Second
TD Account:
a. January 31, 2022 - $3,000
b. February 1, 2022 - $10,000
c. February 1, 2022 - $10,000
180 Affidavit of Kevin Moffatt, dated February 15, 2022, para 37-38, Application Record
of the Toronto-Dominion Bank, p 22-23, TDB00000004; Statement of Account: January
18 – February 10, 2022, Application Record of the Toronto-Dominion Bank, p 140-207,
TDB00000004.
181Statement of Account: January 18 – February 10, 2022, Application Record of the
Toronto-Dominion Bank, p 140-207, TDB00000004.
182 Institutional Report of Toronto Dominion Bank, para 16, TDB.IR.00000001.
52
d. February 3, 2022 - $129,342.03185
149. On February 1, 2022, there was a $10,000 cash withdrawal from the Second TD
Account.186
150. On February 1, 2022, there was a $10,000 wire transfer made from the Second
TD Account to “Fillerup.ca”.187
151. Ms. Lich deposed in the Mareva proceedings that, of the $26,000 that was
withdrawn from the First and Second TD Accounts:
a. $10,000 was payment to a bulk fuel supplier, fillerup.ca;
b. $3,000 was payment to a bulk fuel supplier in Quebec; and
c. $13,000 was withdrawn in cash and used for “various purposes”. 188
152. As of February 10, 2022, when the two TD Accounts were frozen by TD, the First
Account had a balance of $1,261,072.60 CAD (including the $1 million from GoFundMe)
186Account Balance of Second TD Account, Application Record of the Toronto-
Dominion Bank, p 215, TDB00000004. See also Affidavit of Kevin Moffatt, dated
TDB00000004. Mr Moffatt deposes that the withdrawal was on January 31, 2022.
However, the account statement lists the date as 02/01/2022.
187Account Balance of Second TD Account, Application Record of the Toronto-
Dominion Bank, p 215, TDB00000004. See also Affidavit of Kevin Moffatt, dated
TDB00000004. Mr Moffatt deposes that the transfer was on January 31, 2022.
However, the account statement lists the date as 02/01/2022.
Affidavit of Tamara Lich, dated March 28, 2022, para 14, Supplementary Motion
188
Record of the Mareva Respondents, pp 45-46, HRF00001346.
53
and the Second Account had a balance of $132,334.38 CAD.189 These funds were
ultimately paid into escrow.190
11.3 Adopt-A-Trucker Crowdfunding and Email Money Transfer Donations

153. According to information provided by GiveSendGo, the Adopt-A-Trucker
campaign hosted on GiveSendGo had 8,380 donors. 3,640 donations originated in
Canada (43%). 4,293 donations originated from the United States of America (51%).
447 donations originated from other countries (5%).191
154. According to GiveSendGo, a total of $591,789.18 USD was donated to the
Adopt-A-Trucker campaign. $327,843.13 USD originated in Canada (55%).
$244,526.10 USD originated from the United States of America (41%). $19,419.95 USD
originated from other countries (3%).192
155. Donations made to the Adopt-A-Trucker campaign prior to the Ontario Restraint
Order were processed by Stripe. Donations made afterward were processed by
RallyPay.
156. According to Stripe, the Adopt-A-Trucker campaign collected $793,584.74 CAD
in donations while it was being processed by Stripe.193
189Total Accounts Inquiry for Tamara Lich, Application Record of the Toronto-Dominion
Bank, p 229, TDB00000004.
191 GiveSendGo Donation Totals, GSG00000004.
192 GiveSendGo Donation Totals, GSG00000004.
54
157. According to both Stripe and RBC, $330,470.92 CAD was paid out of the Adopt-
A-Trucker GiveSendGo campaign. These funds were paid into an RBC account in the
name of Chris Garrah in 18 payouts initiated between January 24 and February 14,
2022.194
158. Stripe turned over $375,999.68 CAD raised through the Adopt-a-Trucker
campaign to an escrow agent pursuant to the terms of the Mareva injunction.195
159. The discrepancy between the amount collected and paid out to Mr. Garrah’s
RBC account, and the amount ultimately paid into escrow was due to various account
actions such as chargebacks or chargeback reversals, application fees for Connect
accounts and Stripe fees. 196
160. Jacob Wells has advised that donations processed by RallyPay were refunded to
donors.197 RBC records do not reflect any payments from RallyPay into the account that
received other Adopt-A-Trucker payments.198
194Interview Summary: Sam Swartz & Dan Alexander, p 5, WTS.00000005; Redacted

Bank Statements Adopt-A-Trucker, GAR00000001; Project TCH Subject Report, Case
No. C2202559939, p 2, PB.NSC.CAN.00005944_REL.0001.
195Interview Summary: Sam Swartz & Dan Alexander, p 5, WTS.00000005. See also,
Email from Stripe to Peoples Group, February 18, 2022, 12:55am, STR00000028; Email
from Stripe to HSBC, February 24, 2022, 12:26am, STR00000039; Stripe, Ontario Court
Order Actions and Status Spreadsheet, STR00000040.
198 Redacted Bank Statements Adopt-A-Trucker, GAR00000001.
55
161. Email money transfer donations made to [email protected] were
deposited into the same RBC account that received donations from GiveSendGo.199
Between February 7 and February 11, 2022, this account received 170 email money
transfers totalling $31,067.53 CAD.200
162. Approximately $220,000 CAD was withdrawn from Mr. Garrah’s RBC account
between January 31 and February 11, 2022. This includes approximately $150,000
CAD in cash withdrawals, bank drafts and other transfers; $10,553.44 CAD in payments
to the Swiss Hotel; $2130.15 CAD in Best Buy purchases; $1061.02 CAD in grocery
store purchases; and a $576.30 CAD payment to a sanitation company.201
163. The RBC account contained $141,482 CAD when this account’s contents were
paid into escrow.202
11.4 GiveSendGo Freedom Convoy 2022 Donations

164. According to information provided by GiveSendGo, the Freedom Convoy 2022
campaign hosted on GiveSendGo had 113,152 donors. 39,498 donations originated in
Canada (35%). 67,264 donations originated from the United States of America (59%).
6,390 donations originated from other countries (6%).203
Notice of Motion, March 8, 2022, para 58, Motion Record of the Mareva
199
Respondents, p 16, HRF00001357.

Redacted Bank Statements Adopt-A-Trucker, GAR00000001; Project TCH Subject
200
Report, Case No. C2202559939, p 2, PB.NSC.CAN.00005944_REL.0001.

201 Redacted Bank Statements Adopt-A-Trucker, GAR00000001.
203 GiveSendGo Trucker Totals, GSG00000004.
56
165. A total of $9,776,559.50 USD was donated to the Freedom Convoy 2022
campaign. $4,627,660.00 USD originated in Canada (47%). $4,593,686.50 USD
originated in the United States of America (47%). $555,213.00 USD originated in other
countries (6%).204
166. Donations made to the Freedom Convoy other than between February 7-11,
2022 were paid into the Stripe account of Jacob Wells. Payments made between
February 7-11, 2022 were paid into the Stripe account of Chad Eros.
167. Stripe declined to provide the Commission with specific figures related to the
amount of money received into Mr. Wells’ Stripe Account due to US privacy rules. 205
Donations made to Mr. Wells’ Stripe account were ultimately refunded to donors.206
168. Mr. Eros’ Stripe account received $3,763,180.40 CAD in donations, and no funds
were ever paid out.207 Stripe turned over $3,401,844.30 CAD to an escrow agent
pursuant to the terms of the Mareva injunction.208
204 GiveSendGo Trucker Totals, GSG00000004.

205 Interview Summary: Sam Swartz & Dan Alexander, p. 4, WTS.00000005.
208Interview Summary: Sam Swartz & Dan Alexander, pp 4-5, WTS.00000005. See
also Email from Stripe to HSBC, February 24, 2022, 12:26am, STR00000039; Stripe,
Ontario Court Order Actions and Status Spreadsheet, STR00000040.
57
169. The discrepancy between the amount collected and paid into escrow from Mr.
Eros’ Stripe account was due to various account actions such as chargebacks or
chargeback reversals, application fees for Connect accounts and Stripe fees. 209
11.5 Cryptocurrencies
170. The Honk Honk Hodl fundraiser raised approximately 22 Bitcoin on TallyCoin
before it was shut down.210 Approximately 100 wallets were prepared each containing
the equivalent of $8,000 CAD in bitcoin, and were distributed on or about February 16-
17, 2022 to persons participating in the Ottawa protests.211
171. On February 28, 2022, the Ontario Provincial Police executed a search warrant
on the home of Nicholas St. Louis and seized four bitcoin wallets, including two “seed
phrases” that were needed to access the multisig wallet.212 On March 8, 2022, Benjamin
Dichter provided the Escrow Agent with his seed phrase for the multisig wallet. On
March 9, 2022, the Crown provided the Escrow agent with the two seed phrases seized
from Mr. St. Louis.213

211 Affidavit of Jeremy King, February 24, 2022, paras 6-17, Motion Record (Mareva
Affidavit of Nicholas St. Louis, March 7, 2022, paras 7-10, Motion Record of the
212
Mareva Respondents, March 8, 2022, p 28-29, HRF00001357.

Affidavit of Nicholas St. Louis, March 24, 2022, paras 3-4, Supplementary Motion
213
Record of the Mareva Respondents, March 28, 2022, p 29, HRF00001346.
58
172. The Escrow Agent reported receiving 5.964053980 Bitcoin on March 9, 2022
from an individual referred to as Respondent B by the Agent.214
173. In addition, approximately 1.6 Bitcoin raised as part of the Honk Honk Hodl
campaign were stored on various Lightning/OnChain addresses, which is an alternative
method of transferring Bitcoin. Mr. St. Louis deposed that these funds were under the
control of Benjamin Perrin.215 The Escrow Agent interviewed Mr. Perrin on March 22,
2022. The same day, the Escrow Agent received 1.60797938 Bitcoin from an individual
referred to as Respondent C in the Agent’s report. 216
174. The Adopt-A-Trucker webpage solicited donations of six types of cryptocurrency:
Bitcoin (BTC), Ethereum (ETH), Litecoin (LTC), Cardano (ADA), Monera (XMR), and
Ethereum Classic (ETC). 217 Chris Garrah deposed that he did not control these assets
and indicated that a person named “Serge” controlled them.218
175. The Escrow Agent interviewed a person identified as “Serge (last name
unknown)” on March 7 and 23, 2022. The same day, the Escrow Agent reported
receiving the following from an individual listed as Respondent A on March 7, 2022:
a. Bitcoin: 0.052312520
214 First Report of KSV Restructuring Inc. as Escrow Agent, pp 4, 20, JCF00000096.
Affidavit of Nicholas St. Louis, March 7, 2022, para 11, Motion Record of the Mareva
215

217 Adopt-A-Trucker Website, February 14, 2022, COM00000564.
Affidavit of Chris Garrah dated March 8, 2022, paras 6, 10, Motion Record of the
218
59
b. Ethereum: 0.392300813
c. Litecoin: 0.047724040
d. Ethereum Classic: 1.140560130219
176. According to publicly available sources, 77.3% of Freedom Convoy Tokens
remain on PancakeSwap, the platform advertised to be used to exchange FCT for other
cryptocurrencies. The remaining FCT is held in 702 wallets. No wallet holds more than
5% of all FCT.220
11.6 Bank Draft to the Freedom 2022 Human Rights and Freedoms Corp
177. While the Non-Profit Corp. briefly had an account open with the Steinbach Credit
Union, it received $10,000 CAD. When the account was closed, a bank draft made out
to the Non-Profit Corp. was sent to Chris Garrah.221 This bank draft was subsequently
placed into escrow.222
BscScan report for Freedom Convoy Token, accessed September 7, 2022,
220
COM00000567. See also Re: February 16 SIRA Update, p 1,

SSM.NSC.CAN.00000117_REL.0001.
221Affidavit of Chad Eros, March 7, 2022, para 8, Motion Record of the Mareva
Respondents, March 8, 2022, p 99, HRF00001357; Affidavit of Chris Garrah, March 24,
2022, para 10, Supplemental Motion Record of the Mareva Respondents, March 29,
2022, p 39, HRF00001346.
60
12. Visualization of Financial Flows
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Overview Report: Fundraising in Support of

based crowdfunding platforms”. Throughout this report, the term “crowdfunding

platform” refers to donation based crowdfunding platforms. There are numerous

crowdfunding platforms, each of which may operate differently. In general, a

crowdfunding platform permits an organizer to establish a campaign in support of a

2. Both GoFundMe and GiveSendGo are examples of for-profit crowdfunding

platforms. Both are based in the United States of America.

3. Payment processors are entities that manage electronic financial transactions

on a payment processor to facilitate the collection of donations and their ultimate

transfer to a beneficiary’s bank account.

4. Stripe is an example of a payment processor. During January and February

5. Stripe partners with financial institutions in order to provide payment processing

services to clients such as crowdfunding platforms. One type of financial institution

6. Cryptocurrencies, also referred to as crypto assets or virtual currencies, are a

cryptocurrency may serve is to act as a medium of exchange similar to traditional

that is identified by a unique alpha-numeric address. An individual can access

cryptocurrencies. Cryptocurrency exchanges permit individuals to convert

cryptocurrencies into “ordinary” currencies such as Canadian dollars or vice versa.

for an intermediary such as an exchange or a payment processor.

8. Bitcoin is an example of a cryptocurrency. Transactions involving Bitcoin are

who engage in those transactions.

2. The Original Freedom Convoy Campaigns

involved in the management of these fundraisers.

2.1 The Freedom Convoy 2022 GoFundMe Campaign

opened on March 4, 2020 (“the First TD Account”).2

1Letter from GoFundMe Counsel to Commission Counsel, August 9, 2022, p 2,

end of day on January 14, 2022, the description read:

campaign’s purpose. Funds must go to the campaign’s beneficiary or a third-party

3 Fund Edit History, p 34, GFM00000001 (sic throughout).

or purposes stated in the campaign.5

the distribution of the funds.6

5Interview Summary: Kim Wilford, p 2, WTS.00000007; GoFundMe Terms of Service,

else. Any left over donations will be donated to a credible Veterans

donated to a veterans’ organization chosen by the donors. It was not clear to

organization given the large number of donors.9

18. On January 26, 2022, GoFundMe emailed a representative of the campaign

to the response.11 A representative of the organizers sent this response to GoFundMe

organizers were requiring truckers seeking reimbursement to use,13 and internal

8 Fund Edit History, p 22, GFM00000001.

GFM00000078; Witness Summary: Chad Eros, p 2, WTS.00000032.

guidelines related to reimbursement rates and procedures.14 The organizers also

14 Trucker Freedom Convoy 2022 Financial Support, GFM00000151.

GoFundMe directed Stripe to pause, and then un-pause this transaction.19

joint account with TD Bank (“the Second TD Account”).21

2.2 The Freedom Convoy Email Money Transfer Campaign

campaign to raise funds via email money transfer. 22

18Interview Summary: Kim Wilford, p 3, WTS.00000007; Email from GoFundMe to

24. A Contact Identifier email address is an address an individual associates with a

address [email protected] was added as a Contact Identifier email

address [email protected] was added as another Contact Identifier

Freedom Convoy Facebook page on January 18, 2022.24

3. The Adopt-A-Trucker Campaigns

Facebook page to support truckers participating in the Freedom Convoy. On January

18, 2022 he created a fundraising campaign on the crowdfunding website GiveSendGo

at Royal Bank of Canada to receive donated funds (“the RBC Account”).26

We at Warroomcanada have started up Adopt a trucker in Ottawa as part

28. Following its creation, Adopt-A-Trucker immediately began to raise funds. 28

These funds were deposited into the RBC Account.29

3.2 The Adopt-A-Trucker Email Money Transfer Campaign

Mareva Respondents, pp 68-69, HRF00001357.

could be sent to [email protected] Donations sent to this email address