Overview Report: Fundraising in Support of Protestors
Overview Report: Fundraising in Support of Protestors
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
to solicit online donations from multiple donors. These are referred to as “donation
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.
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
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Overview Report: Fundraising in Support of Protestors
2022, Stripe provided payment processing services for GoFundMe and GiveSendGo.
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.
broad class of digital tokens. They can serve several purposes. One purpose that a
currencies like the Canadian dollar. Cryptocurrencies are held in an electronic “wallet”
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 may also be exchanged directly between individuals without the need
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Overview Report: Fundraising in Support of Protestors
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
were established by Tamara Lich: a crowdfunding campaign, and a direct email money
transfer campaign. In the days following their creation, additional individuals became
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
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Overview Report: Fundraising in Support of Protestors
11. The campaign’s description was edited several times after it was created. At the
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
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Overview Report: Fundraising in Support of Protestors
acting to deliver those funds to the beneficiary. They must also be spent for the purpose
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
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
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16. GoFundMe was concerned about the pledge that leftover funds would be
GoFundMe how it would be possible for the organizers to get donor approval for an
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.
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
with the requested information later on the 26th,12 including a copy of a form that the
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Overview Report: Fundraising in Support of Protestors
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
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Overview Report: Fundraising in Support of Protestors
direction until February 1, 2022.18 According to Stripe, the delay was because
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
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.
donors expressed a dislike of donating through GoFundMe. This led to the creation of a
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Overview Report: Fundraising in Support of Protestors
bank account to enable that account to receive email money transfers. The email
address to the First TD Account on January 14, 2022. On January 18, 2022, the email
email address for the First TD Account.23 The latter email address was posted to the
25. Ms. Lich received the first email money transfer donation on January 18, 2022.25
23Affidavit of Kevin Moffatt, dated February 15, 2022, para 19, Application Record of the
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.
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called “Adopt-A-Trucker” to implement this idea. Mr. Garrah designated a bank account
27. The description of the Adopt-A-Trucker campaign, as of January 21, 2022, was
as follows:
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
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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
were deposited into the same RBC account as the donations to the GiveSendGo
campaign.32
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-
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
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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,
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
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
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Overview Report: Fundraising in Support of Protestors
equivalent to $1 million CAD at the time), Mr. St. Louis shut the Tallycoin fundraiser
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
38. The envelopes had been distributed over a 24-hour period starting on the
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
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Overview Report: Fundraising in Support of Protestors
deposed that he did not control any of the cryptocurrencies raised from this campaign. 44
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
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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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
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
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
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.
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Corp.”). The purpose of the Non-Profit Corp., as stated in its Articles of Incorporation,
was:
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
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
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48. When the Non-Profit Corp was established, it attempted to open a bank account
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
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
Respondents, March 8, 2022, p 98, HRF00001357.
55 Interview Summary: Jacob Wells, p 2, WTS.00000004.
56 Interview Summary: Jacob Wells, p 2, WTS.00000004.
57 Interview Summary: Jacob Wells, p 2, WTS.00000004.
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Overview Report: Fundraising in Support of Protestors
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
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
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Brain offered Mr. Eros $250,000 in operational expenses pending the organizers’ ability
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
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
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
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would switch the fundraiser over to the Non-Profit Corp.’s Stripe account, and transfer
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
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
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
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61. On January 31, 2022, GoFundMe’s VIP team emailed campaign organizers with
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.
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
64. GoFundMe’s email also informed organizers that GoFundMe intended to contact
GFM00000106.
Email from GoFundMe to Campaign Organizers, February 1, 2022, 11:55am,
71
GFM00000106.
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65. Campaign organizers responded to this email copying Chad Eros and stated that
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
67. On February 1, 2022, GoFundMe’s Trust and Safety team emailed the Ottawa
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
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.
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campaign organizers to ensure that funds did not support those individuals.75 The police
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
2022 at 1:29pm. GoFundMe indicated that the suspension was due to reports:
70. GoFundMe asked the campaign organizers to respond to its February 1, 2022
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.
77 Interview Summary: Kim Wilford, p 4, WTS.00000007.
Email from GoFundMe to Campaign Organizers, February 2, 2022, 1:29pm,
78
GFM00000160.
Email from GoFundMe to Campaign Organizers, February 2, 2022, 1:29pm,
79
GFM00000160.
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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
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
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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
Wilson’s letter indicated that the organizers’ “intention is not to reimburse those
The intention [of the organizers] is to transfer the [already released] funds
to the Convoy Corp so proper disbursement and accounting is completed.
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
GFM00000106.
86 Letter from Keith Wilson to GoFundMe, February 3, 2022, pp 2-3, GFM00000131.
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earlier in the day, and Mr. Eros provided information to GoFundMe about how he
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
with Deputy Chief Bell. Deputy Chief Bell informed GoFundMe that the situation was
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
GoFundMe had serious concerns about the safety and wellbeing of its employees. 90
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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
its platform, there was a significant amount of money that had been donated but not
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
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
received.94
GFM00000583.
94Interview Summary: Kim Wilford, p 5, WTS.00000007; Letter from GoFundMe
Counsel to Commission Counsel, August 9, 2022, p. 5, GFM00000583.
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81. GoFundMe then decided to refund all donations made to the Freedom Convoy
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
84. TD Bank continued to try to contact Ms. Lich, but was unsuccessful.99
GFM00000273.
97Affidavit of Kevin Moffatt, dated February 15, 2022, para 46, Application Record of the
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.
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Overview Report: Fundraising in Support of Protestors
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:
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.
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
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
the Toronto-Dominion Bank, p 26, TDB00000004.
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Overview Report: Fundraising in Support of Protestors
on her account. Ms. Lich indicated that another individual was assisting her with her
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,
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
presence to direct donors to the GiveSendGo Freedom Convoy 2022 page. The rate of
102 Affidavit of Kevin Moffatt, dated February 15, 2022, paras 52-53, Application Record
of the Toronto-Dominion Bank, pp 26-27, TDB00000004; Wire Payment Information
Form, Application Record of the Toronto-Dominion Bank, p 225, TDB00000004.
103 Affidavit of Kevin Moffatt, dated February 15, 2022, paras 54-57, Application Record
of the Toronto-Dominion Bank, p 27, TDB00000004.
Notice of Motion, dated February 17, 2022, Application Record of the Toronto-
104
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Overview Report: Fundraising in Support of Protestors
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
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
adopting bylaws, appointing officers, and issuing memberships. The documents also
suggested that on February 3, 2022, Chis Garrah resigned his position as Director of
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Overview Report: Fundraising in Support of Protestors
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
95. At this time, Mr. Eros had still not been able to set up a bank account for the
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
GiveSendGo.113
96. On February 7, 2022, Mr. Eros began collecting donated funds into his Stripe
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-
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Overview Report: Fundraising in Support of Protestors
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
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
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
STR00000061.
117 Message from Jacob Wells to Stripe, February 9, 2022, STR00000058.
118 Interview Summary: Jacob Wells, p 4, WTS.00000004.
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Overview Report: Fundraising in Support of Protestors
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
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
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Overview Report: Fundraising in Support of Protestors
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
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-
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
106. When RBC received a copy of the Restraint Order, it restrained the account in
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
Email from Peoples Group to Stripe, February 11, 2022, 9:33am, STR00000004; Email
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Overview Report: Fundraising in Support of Protestors
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
108. HSBC Canada responded, asking whether Stripe had also paused charges and
109. A similar message was provided to Peoples Group, another of Stripe’s Canadian
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
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Overview Report: Fundraising in Support of Protestors
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
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
133 Email from HSBC Canada to Stripe, February 11, 2022, 9:40pm, STR00000008.
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.
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Overview Report: Fundraising in Support of Protestors
USD.140
115. On February 13, 2022, GiveSendGo received a copy of the Restraint Order from
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
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
140 Email from HSBC Canada to Stripe, February 17, 2022, 12:39, STR00000021;
Interview Summary: Jacob Wells, p 4, WTS.00000004.
141 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.
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Overview Report: Fundraising in Support of Protestors
…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
Hi,
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
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Overview Report: Fundraising in Support of Protestors
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
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
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Overview Report: Fundraising in Support of Protestors
were kept of the identities of the individuals who were given envelopes, and this
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
Stripe had a series of communications with its Canadian financial institution partners
45
Overview Report: Fundraising in Support of Protestors
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
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
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.
155 Email from HSBC Canada to Stripe, February 15, 2022, 11:54pm, STR00000016.
156 Email from HSBC Canada to Stripe, February 17, 2022, 8:31pm, STR00000023.
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.
159 Interview Summary: Sam Swartz & Dan Alexander, p 4, WTS.00000005.
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Overview Report: Fundraising in Support of Protestors
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
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:
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
160 Email from HSBC Canada to Stripe, February 23, 2022, 11:38pm, STR00000038.
161 Email from Stripe to HSBC Canada, February 24, 12:26am, STR00000039.
162 Order, dated February 17, 2022, JCF00000092.
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Overview Report: Fundraising in Support of Protestors
digital wallets.
exchanges and custodians were specifically required to freeze any such assets under
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
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
TDB00000002; Li et al. v Barber et al., 2022 ONSC 1543, paras 8-11, COM00000405.
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Overview Report: Fundraising in Support of Protestors
135. On March 14, 2022, GiveSendGo disabled both the Freedom Convoy 2022 and
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
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
138. On March 28, 2022, Stripe confirmed to GiveSendGo that it had initiated a refund
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Overview Report: Fundraising in Support of Protestors
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
Commission, including the amounts raised by various fundraisers and their ultimate
disposition. A visual summary of the information for which there are specific dollar
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.
Letter from GoFundMe Counsel to Commission Counsel, August 9, 2022, p. 6,
175
GFM00000583.
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Overview Report: Fundraising in Support of Protestors
(3%).176
142. This campaign raised approximately $10,060,000 CAD before it was shut down.
CAD originated from the United States of America (9%). Approximately $190,000 CAD
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
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
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Overview Report: Fundraising in Support of Protestors
Freedom Convoy 2022 campaign and deposited into the First TD Account. 180 The total
146. On January 31, 2022, an email money transfer for $3,000 was sent from the First
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
148. The following amounts were transferred from the First TD Account to the Second
TD Account:
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.
183Affidavit of Kevin Moffatt, dated February 15, 2022, para 43, Application Record of
the Toronto-Dominion Bank, p 24, TDB00000004.
184Affidavit of Kevin Moffatt, dated February 15, 2022, para 43, Application Record of
the Toronto-Dominion Bank, p 24, TDB00000004.
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Overview Report: Fundraising in Support of Protestors
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
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)
185Affidavit of Kevin Moffatt, dated February 15, 2022, para 41, Application Record of
the Toronto-Dominion Bank, p 24, TDB00000004.
186Account Balance of Second TD Account, Application Record of the Toronto-
Dominion Bank, p 215, TDB00000004. See also Affidavit of Kevin Moffatt, dated
February 15, 2022, para 42, Application Record of the Toronto-Dominion Bank, p 24,
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
February 15, 2022, para 42, Application Record of the Toronto-Dominion Bank, p 24,
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
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Overview Report: Fundraising in Support of Protestors
and the Second Account had a balance of $132,334.38 CAD.189 These funds were
Canada (43%). 4,293 donations originated from the United States of America (51%).
$244,526.10 USD originated from the United States of America (41%). $19,419.95 USD
155. Donations made to the Adopt-A-Trucker campaign prior to the Ontario Restraint
RallyPay.
189Total Accounts Inquiry for Tamara Lich, Application Record of the Toronto-Dominion
Bank, p 229, TDB00000004.
190 First Report of KSV Restructuring Inc. as Escrow Agent, p 3, JCF00000096.
191 GiveSendGo Donation Totals, GSG00000004.
192 GiveSendGo Donation Totals, GSG00000004.
193 Interview Summary: Sam Swartz & Dan Alexander, p 5, WTS.00000005.
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Overview Report: Fundraising in Support of Protestors
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
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
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
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Overview Report: Fundraising in Support of Protestors
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
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
163. The RBC account contained $141,482 CAD when this account’s contents were
Canada (35%). 67,264 donations originated from the United States of America (59%).
Notice of Motion, March 8, 2022, para 58, Motion Record of the Mareva
199
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Overview Report: Fundraising in Support of Protestors
165. A total of $9,776,559.50 USD was donated to the Freedom Convoy 2022
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
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Overview Report: Fundraising in Support of Protestors
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-
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
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Overview Report: Fundraising in Support of Protestors
172. The Escrow Agent reported receiving 5.964053980 Bitcoin on March 9, 2022
173. In addition, approximately 1.6 Bitcoin raised as part of the Honk Honk Hodl
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
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
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
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
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Overview Report: Fundraising in Support of Protestors
b. Ethereum: 0.392300813
c. Litecoin: 0.047724040
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
219 First Report of KSV Restructuring Inc. as Escrow Agent, pp 4, 20, JCF00000096.
BscScan report for Freedom Convoy Token, accessed September 7, 2022,
220
60
Overview Report: Fundraising in Support of Protestors
61