Jared Pearman 4/16/26 Jared Pearman 4/16/26

Day 23

Examination of John von Heyking by Mr. Harrison, Caylan’s Counsel
Mr. von Heyking has a PhD in political science and is a professor at Arizona State University. In 2020 he was a professor and chair of political science at University of Lethbridge.

Examination of Eric Kaufmann by Mr. Harrison, Caylan’s Counsel, regarding Expert Qualification

Mr. Harrison advised the Court that he wished to qualify Dr. Kaufmann as an expert witness qualified to provide the Court with opinion evidence in the fields of sociology, political science and history, with particular expertise in nationalism, ethnic identity, demography, cultural conflict, and elite discourse.

Note: I am a poor note-taker and these summaries will contain errors and omissions which will reflect my limitations. My intention is to report on the facts as accurately as possible although a subconscious bias may creep in. I can only provide glimpses into what I see as relevant and interesting events. My goal is to capture the essence of the day’s events rather than be comprehensive.

Read the reference documents: The Legal Case and Events Leading to Trial to obtain an understanding of the case and its history. Names and terms are abbreviated and defined in Glossary.

· He first met Caylan in 2019 at a Civitas conference in Toronto.

· Civitas is right-of-centre association of journalists, lawyers, academics who meet annually to discuss political, economic, and social policy.

· Caylan was interested in philosophy and political theory and they shared similar intellectual interests.

· He had read of Caylan’s tribulations.

· He had seen articles about those tribulations by the CBC, Global News, and Press Progress.

· He invited Caylan to give a public lecture at the University of Lethbridge.

· The lecture was scheduled for Friday, March 13 and Caylan was to talk on the documentary she had produced called Letter from Masanjia, and to discuss her experiences with cancel culture.

· The University made a poster entitled Free Inquiry in the Age of Outrage advertising Caylan’s talk.

· The posted was displayed on digital screens around the campus.

· Between March 2 and 13 Professor von Heyking received emails from 33 different individuals in the university community – 30 of the emails expressed opposition to Caylan‘s talk.

· Those opposing Caylan’s talk characterized Caylan as a white supremacist and a homophobe, and expressed the view that people such as Caylan did not deserve a platform at the University.

· Some of those opposing the talk stated that they were in favor of free speech but not for this particular person.

· Professor von Heyking had never experienced such a negative reaction.

· He responded to each of the people opposing Caylan’s talk and invited each of them to meet with him to discuss the issue.

· Only one of the 33 opponents took him up on his invitation to come and talk.

· Some of the opponents sent copies of articles from CBC, Global New, or Press Progress as reasons for their opposition.

· Some faculty members wanted to hold a “teach-in” as a counter-event to take attention away from Caylan’s talk.

· The experience was stressful and unpleasant; the aggregate effect was significant.

· Professor von Heyking did not believe that private messages provide a measure of character.

· He wanted to let Caylan speak her piece and tell her story.

· He also believed that the University should be a forum for robust debates, to provide an understanding of the political world.

· The Provost of the University issues a statement affirming the University’s support for free speech.

· The covid shutdown occurred on March 13 and because of covid Caylan’s talk did not proceed.

After a brief cross-examination by Mr. Mack, the testimony of Professor von Heyking was concluded, and he was excused.

Examination of Eric Kaufmann by Mr. Harrison, Caylan’s Counsel, regarding Expert Qualification

Dr. Kaufmann holds a BA from the University of Western Ontario and a MSc and PhD from London School of Economics and Political Science. He is a Professor of Politics at the University of Buckingham.

Dr. Kaufmann’s curriculum vitae was introduced; it was 65 pages long and provided details of his activities. He is the author of 6 books, has contributed to 45 Refereed Articles, is the recipient of 26 Awards and Research Grants, is affiliated with think tanks, is a public commentator, has been interviewed on CBC and BBC, and often participates in podcasts.

Dr. Kaufmann testified for more than 2 hours concerning his CV, and his work with such subjects as ethnic nationalism, historical sociology, demography, cultural left liberalism, group ethnicity, liberal progressivism, intellectual multiculturalism, WASPs, race, bohemian left liberalism, demographics and religion, ethnic conflict, history, the rise of the social justice left – “wokeism“, postmodernism, and political science.

Dr. Kaufmann is also the vice-president of the Centre for Heterodox Social Sciences which he described as a research-based centre established to address a “crisis of viewpoint identity”

He described himself as an empirical quantitative social scientist.

He has expressed criticism of left illiberalism where “woke” cultural leftism is impinging on freedom of speech.

Cross-Examination of Dr. Kaufmann by Defence Counsel regarding Expert Qualification

Three of the Defendants’ Counsel cross-examined Dr. Kaufmann extensively and made the following points:

· Dr. Kaufmann had been a professor at Birbeck College, University of London,

· He was a critical of wokeism;

· At Birbeck, Dr. Kaufmann had hostility with some of the faculty and students concerning wokeism

· He appeared before a tribunal to defend his views

· Dr. Kaufmann is a free speech advocate and his report advocates free speech

· He described Canada is the first woke nation and said the legitimizing ideology was woke

· Dr. Kaufmann is a fellow with several conservative think tanks

· He sits on the advisory boards for the Free Speech Union (UK and Canada) and University of Austin

· One of his books represents fighting back against wokeism and cancer culture

· He does not approve of human rights tribunals

· He has never before been qualified as an expert in court proceedings

· He does not have a degree in history and no teaching post in history

· He re-tweeted a post by Caylan in which she discussed this litigation

Re-Direct Examination of Dr. Kaufmann by Mr. Harrison

Dr. Kaufmann agreed that white nationalism, white supremacy, and racism exist. He is opposed to all three. But he thinks it important to identify them correctly and differentiate between extremism and mainstream opinions that are important in democratic debate.

Legal Argument

Counsel for the Defendants argued vigorously against recognizing Dr. Kaufmann as an expert witness. The factual basis for the arguments appeared to be that Dr. Kaufmann was associated with right wing thought, was in favor of free speech and opposed to cancel culture.

Comment

News outlets are supposedly advocates for free speech, but in this case the Defendants were tenacious in their efforts to prevent Dr. Kaufmann from testifying because he is a true advocate. The Defendants objections to Dr. Kaufmann were largely based on the contention that only orthodox views should be allowed in court.

Ruling

Madam Justice Harris delivered a judgment on the qualification issue, ruling that Dr. Kaufmann was recognized by the Court as an expert witness qualified to give opinion evidence in the fields of sociology, political science and history, with particular expertise in nationalism, ethnic identity, demography, cultural conflict, and elite discourse.

Jared Pearman 4/15/26 Jared Pearman 4/15/26

Day 22

Continued Cross-Examination of Jivraj by Mr. Harrison

Telephone Conversation Between Jivraj and Defendant Luke Lebrun (Press Progress)

On March 18, 2018, Jivraj had a telephone conversation with Defendant Luke Lebrun, then the editor of Press Progress, working under contract with the Broadbent Institute. Press Progress recorded the call, and the recording was played in court. The following quotations come from the official transcript.

Continued Cross-Examination of Jivraj by Mr. Harrison

Telephone Conversation Between Jivraj and Defendant Luke Lebrun (Press Progress)

Page 1617 of transcript:

“So, uh to give you the news. Um, I was disqualified”
“From running for the federal conservative party nomination Calgary Centre”
“Un, so I’m not thrilled about it. Uh, but it kind of liberates me in a way”
“Because I, I have some, some bones to pick”

Page 1619 of transcript:

“Uh, which is a violation of the provincial rules”
“Huge, huge privacy issue”
“Huge privacy issue. Now truth be told, I was absolutely guilty of all of these transgressions, but I’m not a public figure anymore.”

Page 1628 of transcript:

“Um, you need to target Caylan Ford, cause she’s the one who said these thing. Um, and it need, it needs to be an article about her, about those comments.”
“… because the campaign is gonna be announced on March 17th, so I actually went back and forth, um telling myself, wait, should I, should I give these guys the information once the writ is dropped or beforehand? I actually think this should be released now because he [Jason Kenney] still has the option to disqualify her.”

Page 1630 of transcript:

“Caylan Ford has threatened to sue a whole bunch of people in the past; she never follows through.”

Page 1631 of transcript:

“And this is what I find to be the most damaging. But I would wait. I would do the Pride one first. Hit.”

Page 1634 of transcript:

“Okay, so here’s”
“What I would do”
“I can send you a series of questions to ask her, where she will not give you a response, okay. So instead of asking her to comment on the article.”
“What you should ask are pointed questions.”

Page 1637 of transcript:

“And and, most beautifully, the stupidest thing they could have done was to disqualify me because had I been the federal candidate, I would have had to be extremely careful. Um, now I don’t give a shit.”

Evidence of Jivraj

When asked about his motive for speaking with Lebrun, Jivraj testified: “At the time I wanted a hit piece published on Ms. Ford.”
He could not recall what “transgressions” he was referring to when he said he was “absolutely guilty of all of these transgressions.”
He could not say whether he was aware of the Press Progress article when it was published.
On March 17, using his “Whistleblower” identity, he emailed Press Progress attaching a photo of Caylan and Jason Kenney. See the photo, [click HERE to view]
On March 18, Press Progress published its hit piece on Caylan, featuring the identical photo on the front page. [click HERE to view]
He discussed with Press Progress their proposed description of him as a “conservative Muslim.”

Comment

The telephone conversation and Jivraj’s testimony establish that he:

Had a bone to pick with the conservative movement
Was collaborating with Press Progress
Had been pitching multiple stories about Caylan over several months
Wanted a hit piece published on Caylan
Wanted an article designed to inflict maximum damage
Wanted it published at the moment it would cause the most harm
Suggested that Press Progress ask Caylan pointed questions rather than give her a fair opportunity to comment

Press Progress did publish a hit piece on the day before the writ dropped. Press Progress did ask pointed questions rather than provide Caylan a meaningful opportunity to respond.

Some Defendants argue that Jivraj was merely a conduit for information and that his character is irrelevant. The evidence demonstrates the opposite: Jivraj was not an independent conduit but a partisan actor on a vendetta. His objective was to destroy Caylan, and the Defendants enabled him to do so.

Post–March 18 Conduct

Use of Pseudonyms

Using the pseudonym “Mr. Wilson,” Jivraj published numerous derogatory posts about Caylan.
Using the pseudonym “@serena84,” he published additional derogatory posts.

Interference With Caylan’s Interviews

Caylan gave three interviews after March 18:

Joel Crichton
Andrew Lawton Pollock
Danielle Smith

Jivraj sent letters to all three interviewers threatening litigation.

Joel Crichton initially removed his interview but later reposted it.
Jivraj described the Danielle Smith interview as “awful to endure.”
Regarding his interaction with Corus Entertainment, he testified: “that was settled – written apology, financial settlement, and take down of the interview.”

Interaction With Journalist Graeme Gordon

Graeme Gordon later published A Political Hit Job in the Name of Progress: How UCP Candidate Caylan Ford Fell from Grace.
Before publishing, Gordon interviewed Jivraj and recorded the conversation.
When confronted with statements from the transcript, Jivraj repeatedly said he “could not remember” making them.

His Selection of Screenshots

Jivraj testified that:

He chose screenshots he considered “relevant” and “concerning” to white nationalism.
He selected screenshots relevant to “a potential story on the interplay between race and culture.”
He shared the Pride Parade message because it was, in his view, the most “concerning” to the public.
He did not send subsequent messages that provided clarifying context.

Context He Withheld

He did not provide Caylan’s clarifying statements about Pride, including:

“I am too prudish for pride. I believe in sexual modesty, and unrestrained passion and exuberance is just not my idea of a good time.

If there was a gay Haydn concert where the conductor and the musicians were all queer, I would attend. Can I propose that as an alternative to a parade?”

He also withheld messages in which Caylan rejected white nationalist views, including:

“On whether Canada should remain an essentially white country, I’m kind of agnostic. I doesn’t make a lot of sense to me given our history as an immigrant nation to insist that one race ought to remain dominant in perpetuity.I fear that you attribute to me positions that I don't actually espouse. My interest is in seeking truth, and that entails asking questions and sometimes challenging orthodoxies, and I think that's a vitally important process.A white nationalist might say that race is the primary determinant of culture, for instance, and I wouldn’t agree with that.”

He admitted:

He did not want to send messages that contradicted his narrative that Caylan was a white nationalist.
When asked whether he avoided including messages that contradicted his narrative, he replied: “that seems like a fair assessment.”
He could not recall why he did not send the complete conversations.
He claimed the public had a right to know Caylan’s views, but when asked why the public did not have the right to know all of her views, he said: “Can’t answer the question.”
He added: “I can’t recall what my logic was.”

Cross-Examination by Mr. Mack (Broadbent Institute, Lebrun, Magusiak)

The cross-examination confirmed:

Jivraj communicated with both Lebrun and Magusiak.
He sent an affidavit to Lebrun.
Magusiak met Jivraj for coffee and scrolled through messages on Jivraj’s phone to confirm authenticity.

Further Examination

Jivraj was then briefly examined by:

Mr. Franken (Counsel for Nanda)
Ms. Cooper (Counsel for the Toronto Star)

The examinations concluded, and Jivraj was excused.

Court adjourned.

Jared Pearman 4/12/26 Jared Pearman 4/12/26

Day 21

Examination of Karim Jivraj by Mr. Harrison

At the outset, the Court ruled that Mr. Harrison’s questioning of Mr. Jivraj would begin as a direct examination but would convert to cross‑examination if Jivraj provided testimony inconsistent with his prior sworn evidence. His earlier testimony included:

His examinations for discovery
His testimony at a previous trial
The judgment from that earlier proceeding

Within minutes after starting to testify Jivraj made a statement inconsistent with his prior evidence. Mr. Harrison then applied to have him declared a hostile witness, and the Court granted the application. The remainder of the examination was conducted as a cross‑examination.

Examination of Karim Jivraj by Mr. Harrison

Overview of Examination Format

His examinations for discovery
His testimony at a previous trial
The judgment from that earlier proceeding

Note: Jivraj was compelled to attend by subpoena. His characterization as a hostile witness was an understatement: he repeatedly avoided giving direct answers, frequently claiming, “I can’t recall,” “I’m not sure,” “I don’t know,” “It’s possible,” or “maybe.” He admitted facts only when he knew they could be independently proven and sometimes refused to acknowledge facts that were plainly true—such as whether he received emails addressed to him. The day’s evidence nonetheless provided an accurate portrayal of his credibility and character.

Contempt of Court and Unpaid Costs

Jivraj acknowledged or did not dispute that:

He had been found in contempt of court on three prior occasions and had not purged his contempt in two of them.
He had been ordered to pay Caylan multiple costs awards, most of which remained unpaid.
He had not paid the $10,000 penalty imposed by Justice Graeser for contempt of court.

Conduct in Ontario Prior to Moving to Alberta

Jivraj’s evidence concerning his Ontario activities was marked by extensive memory lapses, despite prior sworn admissions:

He said it was “possible” he wrote a derogatory email about a political candidate, attached her photo, and compiled a distribution list, but he “couldn’t recall.”
He claimed he could not remember circulating malicious rumours alleging that Sue Liu was in an intimate relationship with a senior political figure.
He had previously admitted under oath that he circulated those rumours.
He claimed he could not recall receiving emails—even those addressed to him.
He could not recall whether he had provided a particular list of contacts
When confronted with his earlier sworn evidence, he acknowledged that he had provided the particular list of contacts.
He claimed he could not remember publishing derogatory emails under the pseudonym teamblue2018.
He had previously sworn that he authored those pseudonymous emails.

Justice Graeser, in another lawsuit between the parties, wrote:

“Mr. Jivraj acknowledged that he owned and operated the site ‘Teamblue’ while in Ontario… he feels stupid about that and is ‘not particularly thrilled about that fact.’ He testified that using anonymous email accounts was something he stopped doing…”

Additional findings from that decision:

When it was discovered that he authored the defamatory teamblue2018 emails, he was in “big trouble” in Ontario.
A senior party official told him he would not have a political career in Ontario.
Days later, he flew to Calgary.

Events After Moving to Calgary

Jivraj admitted that Caylan helped him find accommodation and employment at a law firm. His employment there was terminated.
He later obtained employment at another firm; that employment was also terminated.

The Phil Shuman Incident

Jivraj admitted:

He told Phil Shuman that Caylan had accused Phil of making “inappropriate advances on her.”
A chain of text messages independently confirmed this.
This occurred during the height of the Me Too movement.
He acknowledged that a woman’s career would be destroyed if she was known to have made false allegations of sexual harassment.
Caylan confronted him about the false accusation.
He later met with Caylan and Phil; he acknowledged that when he met with them he may have been inebriated.
He asked everyone to place their phones on the table so the conversation would not be recorded.
He admitted that Caylan had not accused Phil of inappropriate conduct.
He apologized to both Caylan and Phil.
He said alcohol “possibly” played a role and that he was experiencing substance‑abuse issues.

Purchase of Domain Names

Jivraj admitted:

He purchased caylanford.ca after learning Caylan was seeking the Mountainview nomination.
He claimed he could not recall why he purchased it.

Justice Graeser previously wrote:

“Mr. Jivraj acknowledged that he had purchased the domain name ‘Caylanford’. He testified that it was a ‘stupid idea…’ when he feared Ms. Ford would harm his political aspirations.”

Additional admissions:

He relinquished the domain only after Caylan initiated arbitration.
He knew she had to pay $1,000 to begin the process.
He said it was “possible” he threatened to sue her if she proceeded.
He later said he did not know why he made the threat and described it as an “empty threat.”
He also purchased domain names associated with Licia Corbella when he believed she might seek a federal nomination.

Invitation to His Campaign Launch,

He invited Caylan to attend. See Tab 104, [click HERE to view]

The invitation included his admission that he had been “an asshole.”
He wrote that Caylan had been “one of the few kind people in [his] life.”
In testimony, he said about the invitation that he was “not sure if [he] was being disingenuous,” adding, “I suspect a part of it was true…”

The October 1 “Fraudulent Resident” Letter

· See the letter, Tab 56 [click HERE to view]

Key points established through testimony and prior sworn evidence:

Jivraj initially claimed he “can’t recall what part he played or who else was involved.”
When confronted with his prior testimony, he acknowledged he was the principal author although Hlady was also involved.
He was then the president of the Mountainview Constituency Association and was required to remain neutral in the candidate nomination contest.
He collaborated with Hlady, who was running against Caylan in the candidate nomination contest.
He solicited signatures from board members, telling them he had evidence supporting the allegations.
He did not sign the letter himself.
The letter accused Caylan of “deliberately misleading” the Party and attempting to “fraudulently circumvent” Party rules.
He could not identify any valid basis for these allegations.
He did not know what representations Caylan had made to the Party.
He did not know how Caylan’s representations were misleading.
There was no board resolution authorizing the letter (9 of 26 members signed).
He knew Caylan was born and raised in Calgary and had a Calgary home in 2017.
The letter was sent Press Progress on October 11 as an attachment to an email; the name of the sender of the email was redacted.
Jivraj testified it was “possible” he sent the email to Press Progress.
When confronted with prior sworn evidence, he admitted he did send the email to Press Progress attaching a copy of the "fraudulent resident" letter.
Jivraj said he didn’t recall circulating the letter to others inside and outside the Party.
When confronted with his former sworn testimony, Jivraj admitted that he had sent the letter to others inside and outside the Party
Jivraj first stated that he understood Press Progress to be a left‑leaning outlet.
He later admitted he knew Press Progress was NDP‑affiliated.

Party Response

Caylan filed a complaint with UCP HQ.
Executive Director Janice Harrington wrote to the board confirming:
- A candidate need only be a resident of Alberta.
- Caylan met all requirements.
- The complaint had been leaked to Press Progress, “an NDP proxy attack site.”
Jivraj claimed only a “vague” recollection of receiving the Harrington email.
Mr. Savelrud, Rules Committee Chair, emailed confirming Caylan was a legitimate candidate.
Jivraj claimed he did not recall receiving the Savelrud email.

Jivraj’s October 13 Email to the Board

He wrote to “Fellow Board Members,” stating:

“It appears there has been a complaint filed…”
The complaint “was not filed on behalf of the Board” but by “individuals who happen to be Board members.”
“No internal party correspondence should be shared outside of the Board.”
Board members had a “fiduciary duty” to protect Party interests.
He asked members to send him information “privately.”

This email is addressed in the Comment section below.

The November 25 “Too Good” Letter

See the letter, Tab 57 [click HERE to view]

The letter alleged:

Caylan made “evasive and misleading statements” about her background.
She had been “deceptive and evasive.”
She refused to be “honest and transparent.”

Additional findings:

It purports to have been written by “Mountainview Grass Roots Conservatives.”
Jivraj admitted he alone was mountainviewconservatives@gmail.com and that he sent the letter on November 25.
It included a fabricated quote attributed to Caylan.
Jivraj admitted that “it’s entirely possible” he fabricated the quote he attributed to Caylan.
Later in his evidence he admitted that Caylan had not made the statement attributed to her.

· Jivraj testified that he didn’t remember who he sent the letter to or where he obtained their addresses

He sent the letter to 1,400 Party members using a confidential membership list available to him only because he was president.
Press Progress also published the letter.

Internal Response

Board member Chris Muldoon investigated and identified Jivraj as the source of the letter.
Muldoon wrote to the other board members stating:

“Karim has outstayed his welcome on this board and has abused his resources (access to email membership list). He is clearly not capable of acting in the best interests of the constituency and definitely not the party. He has been biased since day one, and because of his own personal issues with a candidate, he is in whatever way possible attempting to derail the nomination process by mailing the membership from an account that he created to sound official.

I have growing concerns about our boards ability to operate in an unobstructed and unbiased manner due to Mr. Jivraj’s continued underhanded tactics”

CFO Justin Charbonneau wrote to UCP HQ expressing “serious concerns” about Jivraj’s “underhanded tactics.”
Jivraj acknowledged that multiple board members asked him to resign.
The UCP suspended him as president.
Board member Savelrud wrote to Jivraj:

“Given the recent events and your suspension as president of the Mountainview Constituency Association it would be appropriate if you were to submit your resignation as President and Director”

“If you have not resigned by the end of this week we intend to circulate a motion to the board members for your removal ….”

Jivraj resigned.

Court Adjourned.

Comment

Nothing illustrates the treachery and duplicity of Jivraj more clearly than his October 13 email to the board regarding the October 1 letter. Tab 56 [click HERE to view]

He:

Authored the “fraudulent resident” letter
Solicited signatures
Leaked it to Press Progress and other media
Circulated it further inside and outside the Party

That conduct by the president of the Constituency Association of the UCP was a treacherous betrayal: of the Constituency Association, of the UCP and of candidate Caylan.

In his October 13 email Jivraj wrote as though the letter had appeared from nowhere, stating:

“It appears there has been a complaint filed…”

That statement was a thinly disguised lie about the source of the letter.

Jivraj went on in his email to state that:

“This was a private complaint filed by individuals who happen to be Board members.”

He falsely implied:

He was not involved
The signatories acted independently
The leak was someone else’s doing

The board members who had signed the letter intended it to be a private complaint; it was Jivraj who made it public.

The signatories to the letter didn’t just “happen to be” board members; they were solicited by Jivraj because they were board members.

Although the board members who signed intended the letter to be a private complaint Jivraj had other, nefarious plans, and those other plans involved Press Progress.

The board members who had signed the letter had been deceived into believing that Jivraj would sign the letter and that it was a private Party matter.

Jivraj continued, saying,

“This complaint was leaked to media sources ….”

The letter was indeed leaked to media sources – by Jivraj.

He sent it to Press Progress, which he knew was an organ of the NDP.

Jivraj was again lying by feigning ignorance.

He went on to chastise board members by emphasizing that:

“No internal party correspondence should be shared outside of the Board …”

A peculiar statement coming from Jivraj, who was the author of both the "fraudulent resident" letter and the “Too Good” letter, and who did his best to see that both were widely circulated.

Then, to put a legalistic touch to his sanctimony, Jivraj warned that:

“you have all committed to a fiduciary duty to protect the Board’s and the Party’s interests by accepting elected [sic]the mandate entrusted to you.”

Clearly, Jivraj knew that he had breached his fiduciary duty. It demonstrates that he has no moral compass.

Then, to emphasize that he knew nothing about the letter, and to show that he was intending to investigate, Jivraj stated:

“If anyone has information related to this concern, I would ask that you send me a private email.”

Jivraj didn’t need more information; he needed to confess his guilt.

The most peculiar thing about Jivraj is that he does not appear to recognize that he did anything wrong.

Jared Pearman 4/7/26 Jared Pearman 4/7/26

Day 20

Direct Examination of Michelle Traxel by Richard Harrison

Ms. Traxel was called as a witness by the Plaintiff, Caylan.

She creates videos to promote “social and political awareness” from a left‑wing perspective.

Statements About Caylan

She described Caylan as someone who had to quit the UCP because of “absolutely heinous” and “white supremacist” comments.

Her source for these views was a March 19 CBC article linking Caylan to white supremacy.

Testimony of Michelle Traxel

Direct Examination of Michelle Traxel by Richard Harrison

Ms. Traxel was called as a witness by the Plaintiff, Caylan.

Ms. Traxel identified herself as “a disabled stay‑at‑home mom” who creates online videos.

Background and Social Media Activity

On TikTok, she is known as “knittyknits.”
As of March 2025, she had approximately 100,000 followers on TikTok.
On Instagram, she uses the handle “The real knitty.”
She earns some income from advertisers of underwear and sex toys but testified that social‑media activity is not a meaningful source of income.
She creates videos to promote “social and political awareness” from a left‑wing perspective.
She has no post‑secondary education.
She ran as a federal NDP candidate in 2021.

Videos Concerning the Canada Strong & Free Conference

In March 2025, she created a video discussing all speakers at an upcoming Canada Strong & Free Conference.
She described the conference as a “who’s who of right‑wing hate.”
The video went through the list of speakers, offering commentary on each.

Statements About Caylan

She described Caylan as someone who had to quit the UCP because of “absolutely heinous” and “white supremacist” comments.
Her source for these views was a March 19 CBC article linking Caylan to white supremacy.
She testified that the CBC article affirmed her pre‑existing opinions about Caylan’s ideology, particularly regarding “white replacement.”
She acknowledged she was already biased against Caylan because Caylan was associated with the UCP; the articles she read confirmed her bias.
She did not reach out to Caylan before publishing the video.

Court Playback and Reaction

An excerpt of her first video—the portion discussing Caylan—was played in court.
In the excerpt, Ms. Traxel was flippant and contemptuous, describing Caylan as a heinous white supremacist.

Events Following Publication

Caylan sent a cease‑and‑desist letter requesting an apology.
Ms. Traxel did not comply; instead, she doubled down by publishing a second video.
In the second video, she attacked Caylan’s lawyer, Richard Harrison.
She deleted the Caylan portion of her first video but left Caylan’s photo and name in the remaining content.
She reiterated that her information came from CBC and Toronto Star articles characterizing Caylan as a white supremacist.
Those articles remained live on the CBC and Toronto Star websites in 2025.
After Caylan threatened a defamation lawsuit, Ms. Traxel eventually removed the entire video and issued an apology.

Apology

Her apology video was played in court.
She retracted all statements about Caylan and stated explicitly that Caylan is not a white supremacist.
She acknowledged that her statements were made from pettiness and spite.
She asked her viewers to stop contacting Caylan.
She stated that she made the apology “under duress” because she feared being sued.

Cross‑Examination of Ms. Traxel by Mr. Woodley (Counsel for the CBC)

Ms. Traxel believed Caylan had a conservative bias.
Caylan threatened her with a lawsuit seeking $200,000 in damages.
She believed Caylan’s problems were of her own making.
The portion of her video discussing Caylan was 17 seconds within a 10‑minute video.
She believed that because Caylan used the word “replacement,” she must be a white supremacist.
She had only skimmed a Toronto Star article about Caylan, and that was the basis of her views.

The testimony of Ms. Traxel concluded and she was excused.

Comment

The main point of calling Ms. Traxel was to establish that in 2025 – 6 years after Caylan had resigned -- CBC and Toronto Star still had live articles on their websites describing Caylan as a white supremacist. Their defamation continued for years.

Ms. Traxel’s apology was not sincere; she obviously did not understand that she had wronged Caylan.
She was unhappy to be appearing as a witness for Caylan; she had been subpoenaed.
She was an NDP partisan and had nothing good to say about Caylan.
With over 100,000 viewers, her videos provide a platform capable of mobilizing online hostility.
The CBC and the Toronto Star provided the fuel with which to ignite that hostility.

Additional Proceedings

Lengthy legal argument followed concerning the procedure to be applied when Jivraj is called as a witness.

Court adjourned.

Jared Pearman 4/7/26 Jared Pearman 4/7/26

Day 19

John Vos, a longtime radio executive with Corus Entertainment and former Regional Program Director for CHQR, resumed his testimony. His earlier evidence (Day 15) had been adjourned after it emerged that Corus had entered into a non‑disclosure agreement with Jivraj.

Continuation of Direct Examination

Decision to Remove the Interview

Direct Examination of John Vos by Richard Harrison, Counsel for Caylan

Overview

Continuation of Direct Examination

Decision to Remove the Interview

Mr. Vos testified that:

Corus removed the Danielle Smith interview of Caylan from its website.
The interview was taken down because it did not meet CHQR’s editorial standards, which require fair and balanced coverage.
Petitions and letters denouncing the interview were a factor, though not the primary one.
Advertiser reactions were also a factor.
Corus made no effort to investigate the truth of the statements made by Caylan in the interview.

Cross‑Examination

By Mr. Mack, Counsel for Broadbent Institute, Lebrun, Magusiak

The petition protesting the interview was organized by Progress Alberta, not Press Progress.
The interview was “found wanting” because Ms. Smith did not question Caylan about the Press Progress article.

By Ms. Cooper (Toronto Star and Ms. McIntosh)

Ms. Smith posted a tweet acknowledging that criticism of her interview was fair and that her questioning had not been sufficiently rigorous.
Editorial policy was the primary driver behind the decision to remove the interview.

By Ben Franken (Counsel for Avnish Nanda)

The interview aired during a provincial election cycle.
Mr. Vos knew Caylan was a recently resigned UCP candidate.
The UCP had been experiencing candidate‑selection issues.
Controversial subjects are routinely discussed on talk radio.
CHQR considered it important to treat guests in a fair and balanced manner.

Mr. Vos was excused.

Comment

Regarding Corus Entertainment’s decision to remove the CHQR interview:

· There was an interaction between Jivraj and Corus; Mr. Vos could say no more because of the non-disclosure agreement

· Corus took down the interview

Mr. Vos testified that the decision was primarily driven by editorial policy requiring fairness and balance.
He did not identify what, specifically, was unfair or unbalanced in the interview.
The interview video can be viewed and assessed directly: [click HERE to view].
Mr. Vos stated the interview was removed because Ms. Smith was not sufficiently probing of Caylan.
If the interview had been more probing Caylan would have had more opportunity to tell the story; she had nothing to hide, and her story never changes.
Ms. Smith had characterized the interview at the outset as an opportunity for Caylan to tell her story.
The interview fulfilled that purpose; it was not intended to be a cross‑examination.
Corus capitulated in the face of threats from Jivraj, a person who had no credibility.
Mr. Vos acknowledged that Corus made no effort to determine whether Caylan’s statements were true.
Truth and free speech appeared to be of no concern.
The impression is that principle was abandoned in favour of expedience.

Jared Pearman 4/7/26 Jared Pearman 4/7/26

Day 18

Michaela Frey testified on behalf of the Plaintiff, Caylan. She was elected as the UCP MLA for Brooks–Medicine Hat in 2019, resigned in 2022, and subsequently served as Senior Advisor and Chief of Staff in Premier Danielle Smith’s office.

Mr. Devonshire was retained by Caylan to quantify the financial loss she suffered because of her defamation, and to testify as an expert witness concerning that loss.

Mr. Devonshire is a Chartered Accountant (CPA, CA) and a Chartered Business Valuator (CBV), and currently serves as CFO of Petwin Private Equity.

Chartered Business Valuators specialize in valuation and loss quantification.

Direct Examination of Michaela Frey by Richard Harrison

Overview

Key Evidence from Ms. Frey

Relationship with Caylan

She first met Caylan in 2019 at a UCP candidate retreat, when Caylan already had a high profile as a candidate.
She was impressed by Caylan, describing her as well‑spoken and running in a hotly-contested riding (Calgary‑Mountain View) the UCP believed it could win.
Ms. Frey was elected under the name Michaela Glasgo; she married in 2021 and changed her surname to Frey.

Twitter Activity and Aftermath

She used Twitter extensively during her political career to shape narrative and messaging.
Caylan resigned on March 18.
Shortly afterward, Caylan posted a tweet stating that the NDP “will gleefully destroy people’s lives” to get a member elected.
Ms. Frey “liked” the tweet. Significant backlash followed.

Online Condemnation

An individual named Mohamed, the Broadbent Institute, Press Progress, and the Defendant Nanda extensively denounced Ms. Frey for liking the tweet
Each of them characterized Caylan as a white supremacist:

Mohamed also issued a series of tweets calling on Ms. Frey to remove her “like,” which she eventually did.

Party Direction

The UCP instructed Ms. Frey not to associate with Caylan in any way.

Conclusion of Testimony

There was no cross‑examination. Ms. Frey was excused.

Comment

Ms. Frey’s evidence illustrated the severity of the reputational damage to Caylan.
Ms. Frey was publicly attacked by all the usual suspects for merely “liking” one of Caylan’s posts.
The UCP, the party for which Caylan had been a candidate, completely distanced itself from her and directed its members to do the same.
The defamation had rendered Caylan politically toxic.

Direct Examination of Michael Devonshire by Richard Harrison

Overview

Mr. Devonshire is a Chartered Accountant (CPA, CA) and a Chartered Business Valuator (CBV), and currently serves as CFO of Petwin Private Equity.

Chartered Business Valuators specialize in valuation and loss quantification

Mr. Devonshire was retained by Caylan to quantify the financial loss she suffered because of her defamation, and to testify as an expert witness concerning that loss.

Note:

Before giving evidence as an expert a witness must be recognized by the court as an expert in the field, qualified to give opinion evidence. To obtain that recognition the witness must provide the court with particulars of his/her credentials and experience and must convince the presiding Justice that he/she is an expert in the field.

Expert Qualifications

Before giving expert opinion evidence, Mr. Devonshire testified regarding his credentials and experience.

Bachelor of Commerce from McGill University; obtained CA designation in 2007.
Employment history with Deloitte, Catalyst LLP, and BDO Canada.
Completed extensive study and met high professional standards to obtain the CBV designation in 2010.
Has practised in valuation and loss quantification since 2010.
Previously qualified as an expert seven times in court and arbitration proceedings.
Testified in a Nova Scotia court proceeding.
Focuses on valuation of assets and quantification of loss.
Understands his duty to provide fair, objective, and independent opinion evidence.

Mr. Harrison sought to have the court recognize Mr. Devonshire as an expert in valuation and loss quantification.

Cross‑Examination on Qualifications by Matthew Woodley, for the CBC

Mr. Woodley questioned aspects of Mr. Devonshire’s expert background:

Most of his expert‑witness experience involved companies rather than individuals.
In the Nova Scotia case:
- The court noted his report did not account for certain factors.
- The court expressed concerns about omissions.
- The court rejected his report and accepted the opposing expert’s report.

Ruling: Madam Justice Harris declared Mr. Devonshire qualified to give expert evidence on valuation and loss quantification.

Continuation of Direct Examination by Richard Harrison

Overview of Reports

Mr. Devonshire’s primary report and sur‑rebuttal report were entered as exhibits.
The primary report, including appendices, is 27 pages.
He personally prepared the report.
His engagement letter directed him to quantify Caylan’s economic damages, primarily lost employment income.
The report was prepared in accordance with CBV professional standards.
His fees are time‑based and not contingent on the report’s conclusions.
The report identifies all sources of information relied upon.
It considers mortality rates, bond yields, inflation, employment compensation, and pension plans.
It incorporates conclusions from Dr. Mandel, another expert for the Plaintiff.

Loss Periods and Scenarios

The report quantifies losses in two periods:

· Past losses – are those sustained during the period from March 2019 to June 2025

· Future losses – are those sustained from June 2025 until Caylan’s retirement at age 65

Past Losses

Mr. Devonshire postulated 4 scenarios for Caylan’s career during the past loss period had she not been defamed:

Scenario A: Caylan was successful in 2019 election; appointed to Cabinet
Scenario B: Caylan was successful in 2019 election; not appointed to Cabinet
Scenario C: Caylan was unsuccessful in 2019 election; returns to Global Affairs
Scenario D: Caylan was unsuccessful in 2019 election; appointed Deputy Minister

Mr. Devonshire determined the losses sustained by Caylan in each scenario:

Scenario A – $814,141
Scenario B – $387,085
Scenario C – $537,160
Scenario D – $1,502,265

Future Losses

Mr. Devonshire postulated three scenarios for Caylan’s career during the future loss period had she not been defamed:

Scenario A: Caylan was elected and served two‑terms an MLA, Cabinet, then senior Alberta government role
Scenario B: Two‑term MLA, then return to Global Affairs
Scenario C: Unsuccessful in 2019 election; appointed Deputy Minister; continues in similar roles to retirement

Future Loss Calculations:

Scenario A – $3,115,557
Scenario B – $2,882,725
Scenario C – $4,265,060

Sur‑Rebuttal Report

His sur‑rebuttal was a critique of the Defendants’ experts reports.

Cross‑Examination on Report Content by Mr. Woodley

Mr. Woodley challenged several assumptions and methodological choices:

Relied on Dr. Mandel’s report.
Discussed potential career paths with Caylan and created scenarios accordingly.
Did not consider additional alternative scenarios.
Did not account for potential disability or unemployment.
Assumed Caylan was in the growth phase of her career.
Did not review her actual Global Affairs income from 2012–2018.
Assumed reputational and mental‑health impacts would continue indefinitely.
Assumed full‑time work to retirement.
When discounting to present values, Mr. Devonshire used the nominal rate method of interest calculation rather than the effective rate method.

He acknowledged:

Using the effective rate method would reduce the calculated losses.
Accounting for disability would also reduce the losses.

By Ms. Cooper

He assumed Caylan was past child‑bearing.
He did not consider the possibility of her returning to school.

Mr. Devonshire was excused.

Comment

The CBV designation is the gold standard in Canada for loss‑quantification expertise.
Experts must select a limited number of plausible scenarios; the test is whether they are reasonable and whether any other plausible alternatives should have been considered.
Each scenario chosen by Mr. Devonshire was possible and could reasonably have been followed by Caylan.
Notably, he did not include any scenario with greater upside for Caylan—she could have achieved even more.

Jared Pearman 4/7/26 Jared Pearman 4/7/26

Day 17

Shuvaloy Majumdar testified on behalf of the Plaintiff, Caylan.

He is currently a Member of Parliament representing the constituency of Calgary-Heritage.

Mr. Majumdar has an extensive background in Canadian conservative politics, including work with Preston Manning, General David Petraeus, former Prime Minister Stephen Harper, the Macdonald‑Laurier Institute, and informal advisory work for Jason Kenney.

Direct Examination of Shuvaloy Majumdar by Richard Harrison

Overview

Shuvaloy Majumdar testified on behalf of the Plaintiff, Caylan.

He is currently a Member of Parliament representing the constituency of Calgary-Heritage.

Relationship with Caylan

He first met Caylan in a Calgary coffee shop in 2018.
Prior to meeting her, he had heard she had a “quirky” reputation and had produced human‑rights‑focused documentaries.
He found her intelligent, thoughtful, and someone with whom he shared a deep interest in conservative philosophy and policy.
He enjoyed her company and valued their wide‑ranging discussions, from ancient history to contemporary politics.

Interactions with Mr. Jivraj

He met Jivraj in 2018 when both he and Jivraj were considering running for the Conservative nomination in Calgary‑Centre.
Jivraj attempted to dissuade him from running.
He found Jivraj manipulative, conniving, and obsessive, and Mr. Majumdar decided to disassociate from Jivraj.

Reaction to the March 18 Press Progress Article

He was horrified when he saw the Press Progress article about Caylan, describing it as a “character assassination”.
He saw Press Progress as an organization that presents itself as a press outlet but functions as a propaganda arm of the NDP.
He believed Jivraj was the source of the article.
He was particularly troubled by Press Progress describing Jivraj as “a long‑time Muslim Conservative with deep ties to the party.”
He knew that Jivraj had been denounced by the UCP.
The article did not change his opinion of Caylan.

Impact on Caylan

He testified that Caylan’s alleged white‑supremacist views were widely denounced and she was maligned within conservative circles.
He defended her consistently whenever her name arose, feeling strongly that people were making assumptions without knowledge.
He believed Press Progress had inflicted such severe reputational damage that helping Caylan seemed impossible.

Support for Caylan

He agreed to appear in Caylan’s documentary When The Mob Came because others were reluctant to participate.
The Conservative Party initially expressed concern about his involvement, but those concerns dissipated after the documentary was viewed.
He spent time with Caylan after her resignation, wanting to support her and help her emerge from her shock and grief.
He encouraged her to write about cancel culture or human rights, believing she was a gifted writer.
He wanted to help her reclaim her reputation and rebuild her life.
Caylan was beyond help; the depth of her depression and despair made her inconsolable.

Cross‑Examination

There was no cross‑examination. Mr. Majumdar was excused.

Court adjourned.

Comment

The reputational harm to Caylan was so severe that she was denounced by conservatives across Canada.
She remained mired in deep depression.

Jared Pearman 4/1/26 Jared Pearman 4/1/26

Day 16

Day 16 focused on evidence relating to the personal, professional, and reputational consequences Ms. Ford experienced following the publication of the March 18 Press Progress article. Three witnesses—her mother, her former husband, and a senior professional recruiter—provided testimony illustrating the profound impact on Ms. Ford’s mental health, family life, social relationships, and employment prospects. In addition, testimony from a prominent constitutional‑rights advocate highlighted the extent to which Ms. Ford’s reputation rendered her “toxic” even within organizations ideologically aligned with her prior work.

Overview of Day 16

The day’s evidence collectively emphasized:

the long‑term emotional and psychological toll on Ms. Ford and her family
the collapse of her social and community relationships
the professional doors that closed to her because of online allegations
the broader reputational harm that persisted years after her resignation

No cross‑examinations occurred for two of the witnesses, and the testimony proceeded efficiently, building a cumulative picture of reputational damage and its real‑world consequences.

Day 16

Direct Examination of Cynthia Mackenzie

By Richard Harrison, Counsel for the Plaintiff

Ms. Cynthia Mackenzie testified on behalf of her daughter, Ms. Ford. She is a Calgary real estate agent.

Background and Early Life

Ms. Ford was born and raised in Calgary.
Ms. Mackenzie and her husband separated when Ms. Ford was 13; Ms. Ford lived with her mother thereafter.
At age 14, while still in junior high, Ms. Ford learned about Calgary’s alternative high school and wished to attend, though it only admitted high‑school students.
She independently approached the principal to request admission.
The principal agreed to accept her if she met certain academic objectives and if students and staff approved.
Ms. Ford met the objectives, was accepted by the school community, and enrolled.

Human Rights Interests

While attending the alternative high school, Ms. Ford developed a strong interest in human rights issues and became a practitioner of Falun Gong.
She focused on Chinese human rights concerns and taught herself Mandarin using a computer‑based program.
Her advocacy centered on assisting prisoners of conscience in China.
During her undergraduate studies at the University of Calgary, she frequently communicated with individuals overseas at all hours.

Education, Early Adulthood, and Return to Calgary

Ms. Ford lived in the Sunnyside district during her undergraduate years.
After completing her first Master’s degree and marrying, she lived and worked in Ottawa and Toronto.
In 2016, she and her husband began considering a return to Calgary.
They purchased a home in July 2017, took possession in November, renovated it, and moved in February 2018.

Political Involvement and Aftermath

In 2018, Ms. Ford sought the UCP nomination in the Mountainview riding.
She worked extremely hard, door‑knocking through winter while pregnant or nursing.
Ms. Mackenzie described her as honest, attentive, and persuasive, winning supporters one at a time.
After Ms. Ford’s resignation, she fell into a deep depression.
Ms. Mackenzie testified that Ms. Ford “lost herself,” and nothing seemed to help.
The sudden rise and fall was difficult to explain to friends.
Ms. Mackenzie lost one of her closest friends due to online information about Ms. Ford.
People still avoid discussing Ms. Ford with her.

There was no cross‑examination. Ms. Mackenzie was excused.

Direct Examination of Andrew Crooks

By Richard Harrison, Counsel for the Plaintiff

Mr. Andrew Crooks testified on behalf of Ms. Ford. He is a retired lawyer active in philanthropic, cultural, and political organizations, a former member of the Canadian Taxpayers Federation, and currently Chair of the Canadian Constitution Foundation (CCF).

Background and Impressions of Ms. Ford

In 2019 and today, Mr. Crooks serves as Chair of the CCF, a non‑partisan national charity focused on constitutional rights, government accountability, and public education.
The CCF oversees the Runnymede Society, which promotes rule‑of‑law debates among law students and lawyers.
Its membership includes former attorneys general, judges, professors, and politicians.
After Ms. Ford resigned as a candidate, Mr. Crooks met her at a Civitas Canada conference.
He formed a highly favorable impression of her: strong academic credentials, effective committee and board contributor, and experienced fundraiser.

Attempt to Nominate Ms. Ford to the CCF Board

Mr. Crooks proposed Ms. Ford as a potential board member.
The Foundation’s manager “recoiled in horror” at the suggestion.
Mr. Crooks informally raised the idea at a board meeting; it was “shot down in flames” with an enthusiastic negative response.
He testified that Ms. Ford was considered “toxic” due to reputational damage.
The Foundation could not risk the reputational consequences of associating with her.

Cross‑Examination by Ben Franken, Counsel for Avnish Nanda

Mr. Crooks was involved with Canada Strong and Free.
He had delivered a land acknowledgement but generally objects to land acknowledgements.
He maintains a website and blog, including a post about “Wokeness.”

Mr. Crooks was excused.

Direct Examination of Jared Pearman

By Richard Harrison, Counsel for the Plaintiff

Mr. Jared Pearman, Ms. Ford’s former husband and father of their two daughters, testified on her behalf. He is a writer, producer, and video‑game designer.

The Rise and Fall

Mr. Pearman met Ms. Ford while working in Washington, D.C. as a producer for National Geographic. He encouraged her to complete her undergraduate degree in Washington, which she did.
They married in 2008 and divorced in 2024.
They have two daughters, now aged 8 and 10.
When Ms. Ford sought the UCP nomination in Mountainview, the family went “all in.”
Mr. Pearman became the primary caregiver, largely giving up his career; they lived on an inheritance from his father.
Ms. Ford worked intensely on her campaign, including door‑knocking while nursing.

Impact of the Press Progress Article

When the March 18 Press Progress article was published, Mr. Pearman believed all allegations were false.
He expected people to defend Ms. Ford, but they did not.
As public hostility grew, Ms. Ford became severely depressed.
She spent afternoons alone in her bedroom crying; her only joy came from their children.
Their eldest daughter, Everen, noticed her mother’s distress and tried to comfort her.
Parents at Everen’s preschool became aware of allegations that Ms. Ford was a white supremacist; the family was shunned.
Their social life collapsed, and they became isolated.
For Ms. Ford’s September birthday, Mr. Pearman and Mr. Valliani attempted to organize a party, but no one would attend.
Mr. Pearman wrote a poem, To Know the Mobs of Modern Days, to lift her spirits.

March 18 and the Aftermath

When Ms. Ford returned home after resigning, Mr. Pearman was angry and wanted her to fight.
Ms. Ford remained dignified and stoic, believing she could not win.
Their hopes and dreams, invested in her political future, were shattered in one night.
Mr. Pearman deleted his social media due to the volume of negative posts.
Ms. Ford’s depression deepened as redemption seemed impossible.
She was disappointed that Mr. Pearman had no career to fall back on and no solution to offer.
He wished he had done better; he tried but felt he failed.
Living with someone experiencing acute depression was extremely difficult.
Their relationship deteriorated; Mr. Pearman became depressed, began drinking, gained weight, and accumulated credit‑card debt.

Attempts at Redemption

Ms. Ford wrote and directed a two‑hour autobiographical documentary, When The Mob Came, which Mr. Pearman co‑produced.
He attempted to market it, but no one would engage due to Ms. Ford’s reputational damage.
The theatre scheduled to host the premiere cancelled for the same reason.
Ms. Ford later founded the Calgary Classical Academy charter school and became its Chief Development Officer in 2023.
Mr. Pearman described it as “the best school in Canada.”

About Ms. Ford

Her credo is “truth, compassion, and tolerance.”
She never made derisive comments about anyone.
She was neither homophobic nor Islamophobic; their best friend, Mr. Valliani, is Muslim.

Cross‑Examination by Amy Cooper, Counsel for the Toronto Star and Ms. McIntosh

Mr. Pearman met Jivraj only once; when he arrived at a lunch between Ms. Ford and Jivraj, Jivraj left.
He did not know about the extensive Facebook messages between Ms. Ford and Jivraj.
He did not know Ms. Ford had deleted the messages.
Although divorced, he and Ms. Ford cooperate well in raising their daughters. He made their breakfast, took them to school that day, and cares for them while Ms. Ford attends court.

Mr. Pearman was excused.

Direct Examination of Susan Besler

By Richard Harrison, Counsel for the Plaintiff

Ms. Susan Besler testified on behalf of Ms. Ford. She holds a B.Comm., has been a chartered nurse and registered accountant, and is now a senior consultant at Amrop Rosin, an executive search firm.

The Calgary Chamber of Commerce Recruitment

In 2019, Ms. Besler was assisting the Calgary Chamber of Commerce in hiring a Director of Communications—a senior policy and government‑relations role.
Her research identified Ms. Ford as a strong candidate, particularly due to her experience as a senior policy advisor with Foreign Affairs.
Ms. Ford warned that her recent history might impede her candidacy.
A Google search by Ms. Besler revealed allegations that Ms. Ford was a white supremacist, had made controversial statements, and had resigned as a candidate.
Based on this, the Chamber eliminated Ms. Ford from consideration.
Ms. Besler informed Ms. Ford that they could not proceed due to her controversial history.

There was no cross‑examination. Ms. Besler was excused.

Comment

Ms. Ford’s reputational damage prevented her from joining a prestigious national board.
It also prevented her from securing employment commensurate with her qualifications and experience.
Mr. Pearman’s poem To Know the Mobs of Modern Days used a distinctive structure: eight stanzas, each with eight lines of eight syllables. [click HERE to view]

Jared Pearman 4/1/26 Jared Pearman 4/1/26

Day 15

Direct Examination of Graeme Gordon By Richard Harrison, Counsel for the Plaintiff

Mr. Graeme Gordon testified on behalf of Ms. Ford.

Background and Article Preparation

Mr. Gordon has written for both left‑leaning and right‑leaning publications and considers himself non‑partisan.
In 2019, he published A political hit job in the name of progress: how UCP candidate Caylan Ford fell from grace in The Post Millennial,

Direct Examination of Graeme Gordon

By Richard Harrison, Counsel for the Plaintiff

Mr. Graeme Gordon testified on behalf of Ms. Ford.

Background and Article Preparation

Mr. Gordon has written for both left‑leaning and right‑leaning publications and considers himself non‑partisan.
In 2019, he published A political hit job in the name of progress: how UCP candidate Caylan Ford fell from grace in The Post Millennial, Tab 105, [click HERE to view].
He spent approximately two weeks preparing the article, interviewing 12 sources, reviewing emails, social media posts, and documents, and reading prior Press Progress publications.
He conducted four or five interviews with Jivraj (the first two lasting several hours), two interviews with Ms. Ford, wrote to Press Progress, and spoke with knowledgeable individuals, most off the record.

Assessment of the Press Progress Article

He read the March 18 Press Progress article and considered it damaging and defamatory.
He believed Press Progress had a reputation for “shoddy work.”
He testified that Ms. Ford resigned because of the article and that he sensed “intrigue” behind the story.
He described Ms. Ford as a “star candidate” with a strong résumé.

Specific Criticisms of the March 18 Article

Mr. Gordon testified that the article:

defamed Ms. Ford by portraying her as a white supremacist
lacked a byline, which he considered inappropriate for a story of such seriousness
referenced the Christchurch terrorist attack, which he viewed as irrelevant and prejudicial
provided anonymity to Jivraj despite his lack of credibility, noting he had renounced Islam, been disgraced by the UCP, and was not involved in UCP politics
allowed Ms. Ford only three hours to respond despite allegedly working on the story for months
would have contacted Ms. Ford earlier if truth‑seeking had been the goal

Political Context

His article examined connections between Press Progress, the Broadbent Institute, and the NDP.
He testified that Press Progress was widely known to be partisan and to publish articles targeting conservatives.

Backstory and Jivraj’s Conduct

His article recounted Ms. Ford’s past friendship with Jivraj, her assistance to him, the rupture of their relationship, and his email apologizing for his conduct.
He sought to understand why Jivraj would disclose private communications.
He testified that Jivraj had a reputation in Ontario as a political “hatchet man,” had fallen out with the Ontario PC Party, had a history of pseudonymous or anonymous attacks, and changed his story when confronted with contradictory facts.

Media Handling of Jivraj’s Material

CBC and the Toronto Star received material from Jivraj in January but did not investigate him.
By March, both outlets knew he was the sole source of the material they published.
Mr. Gordon testified that Jivraj had previously attempted to harm Ms. Ford, including in the Phil Schuman incident.
He identified Jivraj as the author of the “fraudulent resident” letter and the “Too Good” letter, both containing falsehoods intended to sabotage Ms. Ford’s candidacy.
Jivraj leaked both letters to Press Progress.

Verification Concerns

Mr. Gordon emphasized that responsible reporting requires verifying authenticity and that one anonymous source is insufficient.
He stated that both Press Progress and CBC should have obtained the full Facebook message thread, which neither did.
He explained that Ms. Ford’s reference to “demographic replacement” was a term used by demographers and distinct from the “Great Replacement” conspiracy theory.
He described Ms. Ford’s fall from leading candidate to resignation as typical of “cancel culture.”
He noted that Ms. McIntosh of the Toronto Star repeatedly referred to Ms. Ford as a white supremacist on social media.

Cross‑Examination of Mr. Gordon

By Mr. Mack (Broadbent Institute), Mr. Lebrun, and Mr. Magusiak

Mr. Gordon acknowledged he already held a negative view of Press Progress.
He considered Press Progress tied to the NDP and biased.
He could not recall the source for his statement that Press Progress had worked on the story for two months.
Press Progress did not answer his inquiry about the timeline.
He confirmed he did not know how long they worked on the story.
He spoke with Ms. Ford for three to four hours during his investigation.
He recorded his interviews with both Ms. Ford and Jivraj.
He discussed the context of the messages and the Press Progress quotes with Ms. Ford.
He read Ms. Ford’s Apologia before publishing.
He discussed the UCP’s decision not to respond to Press Progress, summarized as: “If you are explaining, you are losing.”

By Ms. Layton (CBC)

Mr. Gordon did not recall whether Ms. Ford told him the UCP instructed her to resign.
His article did not address CBC contacting Ms. Ford after her resignation, CBC publishing part of her resignation letter, CBC publishing after she resigned, or CBC asking about the Pride Parade message.
His article focused on Press Progress, not CBC.
He did not know how long CBC had the information, why they delayed publication, or what they had received from Jivraj.

By Ms. Cooper (Toronto Star) and Ms. McIntosh

Mr. Gordon began writing shortly after March 18; the article was published April 15.
He and his editor spent two days editing and shortening it.
Publication occurred shortly before Alberta’s election day.
He did not contact Ms. McIntosh or the Toronto Star before publishing.
His article quoted only one statement from Ms. McIntosh and focused on Press Progress.

Mr. Gordon was excused.

Direct Examination of John Vos

By Richard Harrison, Counsel for the Plaintiff

Mr. John Vos, a longtime radio executive with Corus Entertainment and former Regional Program Director for CHQR, testified on behalf of Ms. Ford.

The CHQR Interview and Aftermath

Danielle Smith, then a CHQR employee, reported to Mr. Vos.
Mr. Vos authorized her to interview Ms. Ford.
The interview aired live and was posted on the Corus website on March 29, Tab ?, [click HERE to view].
After airing, a coordinated campaign emerged encouraging complaints against CHQR and Ms. Smith.
A form petition was circulated to facilitate complaints.
Mr. Vos testified that Press Progress orchestrated the campaign and “fomented concern.”
An exhibit of petition emails was entered: 366 pages, representing more than 500 complaints.
Corus and Ms. Smith reviewed whether airing the interview had been appropriate and considered apologizing if they had erred.
Ms. Smith issued a “clarification,” acknowledging she had not been sufficiently probing.
Communications occurred between Corus and Jivraj or his lawyers, but these were subject to a non‑disclosure agreement.

The examination was adjourned pending resolution of NDA issues.

Direct Examination of Philip Schuman

By Richard Harrison, Counsel for the Plaintiff

Mr. Philip Schuman testified on behalf of Ms. Ford. In 2018, he was a candidate for the UCP nomination in Calgary‑Glenmore.

The False Allegation Incident

Mr. Schuman met Ms. Ford and Jivraj at a 2018 UCP fundraising event.
He recalled a memorable conversation with Ms. Ford.
He found Jivraj lively, boastful, and claiming powerful connections.
He later received a text from Jivraj claiming Ms. Ford accused him of sexual misconduct.
The allegation terrified him due to his political ambitions and relationship.
He testified that Jivraj sowed “seeds of chaos.”
After consulting friends, he met Ms. Ford, who denied the allegation.
He became certain Jivraj fabricated it.
He confronted Jivraj, who proposed a three‑person meeting.

The Meeting

They met at a restaurant; Jivraj arrived late and inebriated.
Jivraj admitted fabricating the allegation and apologized.
He confessed to alcoholism.
He consumed six or seven drinks; Mr. Schuman had soda; Ms. Ford does not drink.
When the bill arrived (approximately $75), Jivraj claimed he forgot his wallet.
An argument and scuffle ensued, broken up by staff.

There was no cross‑examination. Mr. Schuman was excused.

Court adjourned for the day.

Jared Pearman 3/31/26 Jared Pearman 3/31/26

Day 14

STUART THOMPSON

Background and Role

Parliamentary Bureau Chief at the National Post, based in Ottawa.
Has written thousands of articles; currently writes two columns per week.
Understood that Caylan met Mr. Kenney at a political meet‑and‑greet in Calgary.
Was impressed when he first met Caylan; they discussed political philosophy; he believed she was rising through the political ranks.
Published a favourable article about Caylan in the National Post in September 2018.

STUART THOMPSON

Background and Role

Parliamentary Bureau Chief at the National Post, based in Ottawa.
Has written thousands of articles; currently writes two columns per week.
Understood that Caylan met Mr. Kenney at a political meet‑and‑greet in Calgary.
Was impressed when he first met Caylan; they discussed political philosophy; he believed she was rising through the political ranks.
Published a favourable article about Caylan in the National Post in September 2018, Tab 105, [click HERE to view].

Reaction to the March 18 Press Progress Article

Press Progress published its damaging and defamatory article about Caylan on March 18.
Mr. Thompson knew Press Progress was funded by the Broadbent Institute; he often read it but was sceptical of its content.
The defamatory article contained material at odds with Caylan’s philosophy as he understood it.
He called Caylan because his instinct told him there was more to the story.

Information Provided by Caylan

After speaking with her, he knew his instinct had been correct.
Caylan told him about the campaign of political harassment Jivraj had conducted against her.
She told him Jivraj was the source of the Press Progress article; that she had deleted her copies of the Facebook messages and could neither confirm nor deny the quotes attributed to her.
She provided him with emails and documents relating to Jivraj showing his cunning and treacherous nature.

Mr. Thompson’s Investigation

He wanted to write another article to give the full story.
Spent about a month interviewing people to get both sides.
Interviewed Mr. Kenney, Caylan, and Jivraj; sent an inquiring email to Press Progress.
Spoke to knowledgeable political actors, particularly senior UCP officials.
All senior UCP personnel insisted on speaking off the record because Caylan had become toxic to the Party.
Conducted about six off‑the‑record interviews.
Mr. Kenney told him politics is not always fair; the Party could not spend days defending Caylan; getting elected was the most important thing.

Correspondence with Press Progress

Mr. Thompson wrote probing questions to Press Progress about their defamatory article.
The exhibit shows his email at the bottom and the Press Progress response at the top: Tab 1000253.pdf, [click HERE to view].
Press Progress did not answer any of his questions.
Instead, they falsely stated: “… there is no context in which the statement that one is ‘saddened by the demographic replacement of white people in their homelands’ is not self evidently racist.”
Press Progress claimed the quotes were matters of public interest and had been independently verified.

Outcome

He interviewed Jivraj on the record and recorded the conversation.
Wrote a rough draft of a column giving the other side of the story.
The National Post did not publish it because they required more authentication; they did not have the Facebook messages, and good journalism required verification.
He listened to Caylan’s interview with Danielle Smith, enjoyed it, and was surprised by the blowback and venom on social media.

Cross‑Examination by Mr. Mack (Broadbent Institute)

Before joining the National Post, he was editor‑in‑chief of The Hub, a centre‑right outlet.
Thought Caylan was smart and interesting and invited her to write; The Hub published two of her articles.
His intended story would have profiled Caylan and the “crazy situation” she found herself in; Press Progress and Jivraj would have been included, but Caylan would have been the feature.

Cross‑Examination by Ms. Cooper (Toronto Star)

Not every drafted story is published.
He considered his intended piece an investigative feature.
Jivraj would have been part of the story, and he was not a public figure.

Mr. Thompson was excused.

LICIA CORBELLA

Background and Role

Long‑time journalist who worked in Vancouver, Toronto, and Calgary; winner of many awards.
Most recently editor of the editorial page at the Calgary Herald; retired in 2022.

Her Article About Caylan

A movie critic friend told her about a documentary titled Letter from Masanjia.
The film was about a Chinese dissident and won an award at the Calgary International Film Festival.
She watched the film and learned that Caylan was a co‑writer and co‑producer.
Learned that Caylan had studied at Oxford and was deeply concerned about human rights.
Learned that Caylan was interested in politics — making her a strong subject for a profile.
Interviewed Caylan for about two hours at her home.
The interview covered the film, Caylan’s education, political personalities, and her nomination campaign.
She wrote a glowing article about Caylan, published in the Calgary Herald: Tab 37, [click HERE to view].

Events Surrounding the “Fraudulent Resident” Letter

She became aware of the “fraudulent resident” letter written by Jivraj: Tab 56, [click HERE to view].
The letter was published by Press Progress on the same day her article appeared.
She was not interested in writing about political backstabbing or ugly machinations.

Whistleblower Tweet and Jivraj

A tweet by “Whistleblower” claimed her article was a puff piece written at the request of the UCP.
Whistleblower was in fact Jivraj, and the statements were false.
She first came to know of Jivraj when he was living in Toronto; he described himself as a lawyer.
She later learned he was not a lawyer.

Interaction with Press Progress

In January 2018, she received a phone call from Defendant Magusiak of Press Progress.
Magusiak was angry and aggressive, accused her of becoming a federal nomination candidate, and told her Jivraj had purchased domain names including liciacorbella.com and liciacorbella.ca.
The next day, by coincidence, she encountered Magusiak at a press conference.

Reaction to the March 18 Article

She felt sick when she saw the defamatory March 18 article; she considered it character assassination.
She thought the article was false because “white supremacists don’t write and co‑produce movies about Chinese dissidents.”
Postmedia prohibited her from writing about Caylan.

Cross‑Examination by Mr. Mack

She was a member of the UCP when she wrote the favourable article.
Her membership was a reason Postmedia prohibited her from writing about Caylan.
Some of her columns were removed from the Herald because she was a UCP member.
The phone call she received was from someone who identified himself as Magusiak.
The person she met the next day also identified himself as Magusiak.

Re‑Direct Examination

She had joined the Conservative Party of Alberta to vote in the “Unite the Right” campaign.
When the Conservative and Wildrose parties amalgamated, she automatically became a UCP member; she had not purchased a UCP membership.
She was suspended from writing about politics for two months when Postmedia learned she was a UCP member.

Ms. Corbella was excused.

ALAN HALLMAN

Background and Role

Extensive experience in Alberta politics at both municipal and provincial levels.
His company, Alan Hallman & Associates, is in the government relations business.
Considered a power broker in the UCP.
Called to give evidence on behalf of Caylan.

Relationship with Mr. Kenney and Early Interactions

In 2017, he encouraged Mr. Kenney to come to Alberta, unite the right, and become leader of the amalgamated party.
Mr. Kenney became leader of the UCP and then Premier in 2019.
Mr. Hallman met Caylan at a political function in 2018 and invited her, Jivraj, and Phil Shuman to an after‑party at his house.
At the party, Jivraj was drinking heavily.

The Phil Shuman Incident

The next morning, Phil called Mr. Hallman, concerned about information Jivraj had given him.
Jivraj told Phil that Caylan had accused him of sexual impropriety.
Mr. Hallman suggested Phil call Caylan; Phil learned the allegation was fabricated by Jivraj.
Mr. Hallman confronted Jivraj, berated him, and told him never to return to his house.

Caylan as a Candidate

Mr. Hallman worked closely with Mr. Kenney in 2018 looking for outstanding candidates.
Both he and Mr. Kenney saw Caylan as a potential outstanding candidate and wanted her to win a nomination.
He helped with her nomination campaign, though the Party did not intervene.
He considered her a tremendous candidate, one of the strongest in all 87 constituencies.
He said her interaction with people was excellent and that she was bound for a cabinet position if elected.

Events Leading to March 18

Caylan brought the “fraudulent resident” letter to his attention; he believed the directors who signed it had been hoodwinked.
Two of her nomination opponents were credible candidates.
Hlady was also a candidate, but Mr. Kenney instructed Mr. Hallman to tell Hlady the Party would not accept him; Hlady was disqualified.
There was innuendo circulating about inappropriate conduct by Hlady.

The March 18 Article and Aftermath

The defamatory March 18 article was published by Press Progress.
Mr. Hallman was not initially alarmed because “everyone knew Press Progress was NDP propaganda.”
He said Press Progress deceived the public by presenting propaganda as news.
He knew Jivraj was the source of the article, although Press Progress granted him anonymity.
He knew Jivraj was not “a long‑time conservative Muslim with deep ties to the Party,” as alleged.
By March 2018, Jivraj had no role in the UCP; he had been asked to resign as president of the Mountain View constituency association.
Mr. Hallman understood Jivraj had been “run out of Ontario” and moved to Alberta.
Caylan was “thrown under the bus” by the UCP and resigned.
After her resignation, she was treated very poorly by the Party.

Later Interactions

At Mr. Hallman’s 2018 annual BBQ, attended by hundreds, both Mr. Kenney and Caylan were present.
Mr. Hallman asked Mr. Kenney to speak to Caylan; Mr. Kenney did not and left the event.
The treatment of Caylan strained the friendship between Mr. Hallman and Mr. Kenney.

Cross‑Examination by Mr. Mack

Mr. Hallman had been involved in a social media controversy in 2017.
He supported Mr. Kenney for UCP leader, but Party bosses supported another candidate.
He made derogatory comments about that candidate and was suspended from the Party for a year.

Mr. Hallman’s evidence concluded and he was excused.

Comment

It is unfortunate that the article Mr. Thompson intended to write was never published; he had done the research and understood what had happened, and the article could have spared Caylan much agony and misery.
Caylan was considered cabinet material by both Mr. Kenney and Mr. Hallman.

Jared Pearman 3/31/26 Jared Pearman 3/31/26

Day 13

Day 13 featured testimony from three witnesses called by Caylan: The Honourable Jason Kenney, Matthew Solberg, and John Reid.
Their evidence addressed Caylan’s political trajectory, the falsity and impact of the Press Progress article, the conduct and credibility of Jivraj, the UCP’s internal response on March 18, and the consequences for Caylan’s campaign and future within the party.

Overview

Day 13 featured testimony from three witnesses called by Caylan: The Honourable Jason Kenney, Matthew Solberg, and John Reid.
Their evidence addressed Caylan’s political trajectory, the falsity and impact of the Press Progress article, the conduct and credibility of Jivraj, the UCP’s internal response on March 18, and the consequences for Caylan’s campaign and future within the party.

The Honourable Jason Kenney

Background and Relationship with Caylan

Mr. Kenney described his extensive political career, including several federal ministries and serving as Premier of Alberta.
He first met Caylan at a political meet‑and‑greet in Calgary in 2017.
Caylan showed interest in Alberta politics and Mr. Kenney was impressed with her.
He was seeking young, intelligent, well‑spoken candidates, preferably female, who believed in conservative principles; Caylan fit the bill perfectly.
He described her as well‑read, articulate, and possessing a deep intellectual background with thoughtful views on human rights.
He considered her a star candidate and testified that he viewed her as cabinet material, with the education ministry specifically in mind for her.

Press Progress and Other False Narratives

Press Progress published an article claiming: • they met at a cocktail party • they met in Ontario • Caylan was a parachute candidate
Mr. Kenney testified that all three particulars were false.
He stated that Press Progress, the Toronto Star, and Mark Hlady each published false stories about the origins of his political relationship with Caylan.
Several promotional campaign videos were made featuring Caylan and Mr. Kenney.

Evidence Concerning Jivraj

In October 2017, Caylan told Mr. Kenney she had been friends with Jivraj, shared intellectual interests, and had exchanged extensive Facebook messages.
She also told him that Jivraj had begun acting irrationally, making threats, and behaving in a hostile manner.
Mr. Kenney first met Jivraj in 2015 when Jivraj became a federal Conservative candidate; he was initially impressed.
After Jivraj moved to Calgary, Mr. Kenney encountered him several times and recognized that Jivraj had a drinking problem and became loud and aggressive when inebriated.
He knew that Jivraj had been president of the Mountain View Riding Association and had been asked to resign.

March 18 and the Decision to Remove Caylan

Mr. Kenney recalled the damaging Press Progress article published on the night of March 18.
He knew Press Progress was a creation of the Broadbent Institute and the NDP.
His first reaction to the allegations was that they were ridiculous; he knew Caylan was deeply committed to human rights and human dignity.
He testified that it was transparently absurd to accuse her of racism.
The article gained political momentum: • the NDP issued a press release • Mayor Nenshi commented adversely • the Canadian Council of Muslims also commented
Mr. Kenney saw the attack as highly organized and was concerned further attacks would follow.
Caylan told Party HQ she could neither confirm nor deny the quotes because she had deleted her copies of the messages.
It was impossible for her to provide an explanation of her true beliefs in the time available.
There was a high risk of destabilizing the entire UCP campaign and Mr. Kenney was not prepared to jeopardize other candidates.
He made a very bitter decision and decided it was prudent to ask Caylan to step aside.
His decision was communicated to her by campaign staff.
Less than four hours elapsed between publication of the Press Progress article and Caylan’s resignation.

Aftermath

The UCP won the election and Mr. Kenney became Premier.
When the new government was formed, about 125 political staffing positions were available.
Campaign volunteers and unsuccessful candidates were often chosen for such positions.
Jeremy Wong, who replaced Caylan as the candidate and lost the election, was appointed to a government post.
Caylan was never considered for any position; she had become toxic to the party.

Cross‑Examination by Mr. Mack (Broadbent Institute)

Mr. Kenney did not read the quotes attributed to Caylan; staff read them to him.
He could not recall what defamatory material he personally reviewed.
He never spoke directly to Caylan on March 18.
He considered the attributed quotes contentious but not extreme.
He believed Caylan was a person of good faith with no hatred in her heart, devoted to human rights and religious freedom.
He did not believe she was a white supremacist or racist.
He compelled her resignation because of the prospect of further leaks and the inability to assess political risk.
Cabinet ministers can be shuffled or dismissed at any time for any number of reasons.
He condemned the remarks attributed to Caylan; he did not condemn Caylan.

Cross‑Examination by Ms. Cooper (Toronto Star)

The UCP never made Hlady’s nefarious conduct public.
At a press conference, Mr. Kenney said Caylan resigned because she did not want to become a distraction to the party.
He added: “Let me be clear I condemn the remarks.”

Re‑Direct Examination

Mr. Harison established that five or six unsuccessful UCP candidates or activists were appointed to senior political staff positions in the new government.
Mr. Kenney was excused.

Matthew Solberg

Background and Role

Mr. Solberg is a partner in a public affairs firm in Calgary.
He was the Director of Communications and spokesperson for the UCP in the 2019 election.
He first met Caylan in December 2018 after she won the nomination.
He learned that she was young, multilingual, and had strong philosophical and political views.
She was a star candidate representing the face the party wanted to present.
The Party produced several promotional videos featuring Caylan and Mr. Kenney.
Mountain View was a target seat for the UCP; they believed Caylan was the right candidate with the right message.

Evidence Concerning Jivraj

Caylan told Mr. Solberg about her long series of Facebook messages with Jivraj and that she had deleted her copies.
Mr. Solberg knew of: • the “fraudulent resident” letter • Jivraj’s unauthorized use of a private Party mailing list • his spurious accusations • his purchase of Caylan’s domain name • his attack ads • the anonymous “Too Good” letter sent to the entire Mountain View membership

The Toronto Star

Mr. Solberg had a good relationship with Toronto Star reporter Kieran Leavitt.
In early 2019 he told Kieran that Jivraj was not credible, had a history of spreading false stories about Caylan, was obsessed with her, and that she had deleted her copies of the messages.

March 18

In the late afternoon, Caylan texted Mr. Solberg advising that Press Progress was publishing an article containing quotes from the messages and that she could neither confirm nor deny them.
She wanted to respond; he told her not to.
By late evening, the Party recognized she could not continue.
She was asked to resign and prepared her resignation letter.
After her resignation, she became a pariah within the UCP—“radioactive”—and no one in the party or government could associate with her, even on social media.
After brief cross‑examination, Mr. Solberg was excused.

John Reid

Background and Role

Mr. Reid started a fibre‑optics company in Calgary in 2016; it was acquired by Bell in 2018. He now runs an advertising business.
He lived in Mountain View and was not involved in politics until 2017.
He was impressed by Caylan’s website, met her for coffee, and became involved in her campaign.
He was originally the volunteer coordinator and became campaign manager after she won the nomination.
He door‑knocked five days per week through the winter.
He learned during the nomination contest that there was a contentious history between Caylan and Jivraj.

The 2019 Campaign and March 18

Caylan won the nomination handily.
The 2019 campaign was exciting; they had strong fundraising, good name recognition, and confidence in electoral success.
On the night of March 18, Mr. Reid had organized volunteers to go door‑knocking.
Caylan pulled him aside and said a negative problem had arisen.
He believed she could weather any adversity because of the campaign’s momentum.
Upon returning to headquarters, he learned the Press Progress article had been published and the political damage was escalating.
He recalled Caylan receiving a call from UCP HQ and resigning.
Everyone was in shock.
Mr. Reid testified that Caylan never supported white nationalism, terrorism, or white supremacy.
The impact of her resignation created a pervasive feeling of helpless melancholy.
Mr. Reid never worked in politics again; he lost trust in journalism, politicians, and politics.
He recognized “why good people don’t go into politics.”

Comment

Mr. Kenney’s testimony made clear that Caylan would have been a cabinet minister had she been elected, and that he had the education ministry in mind for her.
He also highlighted Jivraj’s drinking problem and the seriousness of concerns about his conduct.
His decision to ask Caylan to resign was politically necessary, and she was sacrificed in the interests of the UCP.
Mr. Solberg’s evidence established that Toronto Star reporter Kieran Leavitt knew in early 2019 that Jivraj was a liar, obsessed with Caylan, and had a history of spreading false stories about her, and that she had deleted her copies of the messages.
Every derogatory story published by the Toronto Star after March 18 was published with knowledge of Jivraj’s character.
Mr. Reid’s evidence established that Caylan would have been elected but for Press Progress and Jivraj.
His statement that “good people don’t go into politics” is a saddening comment about the state of politics today.

Jared Pearman 3/29/26 Jared Pearman 3/29/26

Day 12

Direct Examination of Janice Herrington

By Caylan’s Counsel, Richard Harrison

In 2019, Ms. Herrington was the Executive Director of the UCP, a position she had held since the Party’s formation in 2017.

She testified on behalf of the Plaintiff, Caylan.

Mr. Kenney asked Ms. Herrington to manage the UCP when it was formed.
She first met Caylan at a political event and was impressed by her.

Direct Examination of Janice Herrington

By Caylan’s Counsel, Richard Harrison

In 2019, Ms. Herrington was the Executive Director of the UCP, a position she had held since the Party’s formation in 2017.

She testified on behalf of the Plaintiff, Caylan.

Mr. Kenney asked Ms. Herrington to manage the UCP when it was formed.
She first met Caylan at a political event and was impressed by her.
At the time, Caylan was a candidate in the Mountainview nomination contest.
Caylan told Ms. Herrington about difficulties she was experiencing because Jivraj, as president of the Constituency Association, was attempting to prevent her from becoming the candidate.
The “fraudulent resident” letter, written by Jivraj and signed by nine directors, accused Caylan of misrepresenting herself and committing deliberate fraud to become a nomination candidate.
Jivraj had “leaked” the letter to Press Progress and had also purchased Caylan’s domain name.
Press Progress published the letter.
Caylan filed a formal complaint with the UCP and requested an investigation.
Ms. Herrington investigated and asked Jivraj to respond to the complaint.
Jivraj did not provide a reasonable response; his reply was aggressive and litigious.
The investigation concluded that Caylan was a legitimate candidate.
Caylan had been thoroughly vetted by the Party before her application was approved.
The Constituency Association Board, under Jivraj’s presidency, was not proceeding with the nomination process.
Hlady was also a candidate for the nomination.
Ms. Herrington discouraged Hlady from running because she personally knew he had engaged in inappropriate sexual behaviour when he had been an MLA.
Press Progress published the damaging and defamatory article about Caylan on March 18, and Caylan resigned.
After resigning, Caylan told Ms. Herrington that the quotes in the Press Progress article had been taken out of context.

Direct Examination of Sadiq Valliani

Witness for the Plaintiff

Mr. Valliani has extensive political experience at local, provincial, and federal levels. He provides high‑level managerial and consulting services, including war‑room operations, and owns a voter‑survey company.

Caylan and Her Campaign

Mr. Valliani met Caylan at a UCP function in 2017. He described her as brilliant, knowledgeable, passionate about public service; the right person for the right reasons. He believed she would have a successful political career.
He volunteered on her campaign and became the manager responsible for every aspect of her nomination campaign.
Caylan had her own style and views; when door‑knocking, she often spent 10–20 minutes speaking with voters and could discuss a wide range of topics knowledgeably.
She worked extraordinarily hard; she was nursing her baby and scheduled door‑knocking around breastfeeding.
She faced two very capable opponents in the nomination contest.
Caylan won the nomination by a large margin.

About Jivraj

Caylan told Mr. Valliani she had experienced “weird interactions” with Jivraj and feared he would interfere in her campaign.
Jivraj had purchased her campaign domain name, forcing her into a dispute‑resolution process to recover it.
Mr. Valliani had prior experience with Jivraj:
- As chair of the nomination committee in Calgary‑Centre, he was approached by Jivraj, who sought his help to become the chosen candidate.
- Mr. Valliani, a neutral chairman, refused; Jivraj became angry and aggressive.
Mr. Valliani stated that “weird things happened around Jivraj”; at one point, Jivraj threatened to sue him.

Projecting Election Results

Working with a data‑collection company, Mr. Valliani’s firm developed a sophisticated system for analyzing voter intentions.
The campaign had lists of all Party members in the riding.
The data‑collection company conducted repeated phone and text surveys and provided the results to Mr. Valliani’s firm.
His firm combined that data with information collected by door‑knockers and entered everything into spreadsheets
Reliable election results could be predicted from the spreadsheets.
The system is used for both nomination contests and elections; similar systems are used by all competent political campaigns.
Each Party member or voter was surveyed multiple times; 15,000–20,000 calls were made during Caylan’s nomination contest.
The process cost tens of thousands of dollars but was highly accurate.
The system’s prediction for the nomination contest was within 3% of the actual result.
The same surveys were conducted for the general election after Caylan’s nomination.
The system predicted that Caylan would likely win the Mountainview riding.

Events of March 18

Late on March 18, Caylan called Mr. Valliani seeking help and advice.
He was managing three other campaigns but immediately drove to Caylan’s campaign HQ.
Caylan showed him the emails from Mr. Lebrun at Press Progress (Tab TB1000144), [click HERE to view].
They both knew Jivraj had planted the story and that Press Progress would publish it regardless.
Because Caylan did not have her copies of the Facebook messages with Jivraj, she could neither confirm nor deny the quotes attributed to her.
In a state of anxiety, they contacted other candidates and Party officials.
Press Progress published the article only 2–3 hours after Caylan received the Lebrun emails.
Caylan was called by two different CBC journalists asking for comment and posing loaded questions.
Mr. Valliani reviewed the personal social‑media accounts of the two CBC journalists and saw posts showing bias against Caylan.
CBC invited her to be a guest and be interviewed on the Eye Opener program the next morning.
Caylan and Mr. Valliani knew the interview would be an ambush, not a genuine interview.
Mr. Valliani advised Caylan not to respond to the loaded questions and not to appear on the Eye Opener.
Caylan did not respond and she did not appear.
The UCP offered Caylan the chance to resign, and she wrote a resignation letter.
Mr. Valliani posted the resignation letter on the campaign website.

Effect on Caylan

After writing her resignation letter, Caylan was quiet, solemn, sad, deeply hurt, but stoic.
Over time, she became deeply depressed; she was a “broken shell,” afraid of being recognized, and stopped going out. People went out of their way to hurt her.
Mr. Valliani recognized her hurt and depression and called her every night for about 18 months.
Even after her resignation, Jivraj continued to pursue her, attempting to further damage her life.

Calgary Classical Academy (“the School”)

In 2021, while Mr. Valliani was working in Ottawa, Caylan called him and said she wanted to start a charter school and needed his help.
He returned to Calgary.
When the School opened, he became CFO and secretary‑treasurer.

Cross‑Examination of Mr. Valliani by Mr. Mack, Counsel for the Broadbent Institute and the Defendants Magusiak and Lebrun

He confirmed he was not a professional pollster.
He conducted voter surveys, which differ from polls.
Data was collected from 4,615 people who answered the phone; every number on the voter list was called 2–3 times.
The data‑collection company made the calls and provided the results to his firm.
His firm combined that data with door‑knocking data to predict outcomes.
His firm received about $5,000 for the survey; the data‑collection company received about $20,000.
He understood that both candidates opposing Caylan in the election were strong.

Next Witness: Chad Hallman (“Chad”)

Richard conducted the direct examination of Chad, who testified on behalf of Caylan.

Chad has worked in politics for a decade in both junior and senior roles, including in Premier Kenney’s office as a special advisor and later as a ministerial assistant.

Experience with Jivraj

Chad met Jivraj in 2015 at Conservative Party functions in Toronto.
In 2017, he saw Jivraj at a Calgary BBQ; Jivraj said he had moved to Calgary to enter federal politics.
Chad later recruited him as a volunteer in a municipal campaign.
Jivraj was unreliable; on one occasion he was late and inebriated. Chad stopped asking him to volunteer.
Chad knew of Jivraj’s sordid political activity in Toronto and that he had been effectively black‑listed in Ontario politics.
Jivraj demonstrated strange behaviour and abused alcohol.

Experience with Caylan

Chad met Caylan in 2018 and was tremendously impressed with her.
He believed she could positively change the UCP’s image.
He volunteered during her nomination campaign and became very active after she was nominated.
He became aware of derogatory posts about Caylan made by Jivraj.
He confronted Jivraj, told him he knew about his deceit and treachery, and told him to leave town.

After March 18

It was common for campaign volunteers and unsuccessful candidates to be hired by a new government, sometimes in senior roles.
The UCP did not communicate with Caylan after her resignation.
The Party wanted no association with her, and political staff understood they must not associate with her.
Chad “liked” an online post by Caylan.
He was severely reprimanded by a senior Party member and told his career could be threatened.
Chad appeared in Caylan’s documentary When The Mob Came but later asked to be removed due to concerns about his political career.
Nobody in the UCP believed Caylan was a white supremacist, but Party politics made any association with her impossible.

Court adjourned.

Comment

· Mr. Valliani’s system for analyzing voter intentions and projecting election results was highly accurate.

· The system projected a likely win for Caylan prior to March 18.

· Caylan suffered deep and acute depression after her resignation.

· The UCP completely disassociated from Caylan after her resignation.

Jared Pearman 3/29/26 Jared Pearman 3/29/26

Day 11

Caylan’s lawyer, Richard Harison, conducted the direct examination of Justin Charlebois. Mr. Charlebois is a partner and advisor with a financial firm and holds several financial accreditations. He gave evidence on behalf of the Plaintiff, Caylan.

The 2018 Mountainview UCP Constituency Association Annual General Meeting

Mr. Charlebois was a resident of Mountainview in 2018 and attended the AGM.

Caylan’s lawyer, Richard Harison, conducted the direct examination of Justin Charbonneau. Mr. Charbonneau is a partner and advisor with a financial firm and holds several financial accreditations. He gave evidence on behalf of the Plaintiff, Caylan.

The 2018 Mountainview UCP Constituency Association Annual General Meeting

Mr. Charbonneau was a resident of Mountainview in 2018 and attended the AGM.
He met Jivraj at the meeting; he thought Jivraj knew many people and was charismatic.
Mr. Charbonneau was elected to the Board of Directors (the “Board”) and appointed treasurer of the Association.
A president was to be elected, and Jivraj nominated himself.
Jivraj appeared to have many supporters; in hindsight, Mr. Charbonneau realized that Jivraj had “stacked” the meeting.
Jivraj was elected president of the Constituency Association.

Functioning of the Board

At the outset, the Board appeared to function normally.
Over time, the Board became chaotic and dysfunctional.
Jivraj invited Mr. Charbonneau for coffee and presented him with the “fraudulent resident” letter, Tab 56, [click HERE to view]
Jivraj claimed he had evidence about Caylan and persuaded Mr. Charbonneau to sign the letter.
Unsuspecting, Mr. Charbonneau signed, assuming Jivraj would also sign.
Jivraj never signed the “fraudulent resident” letter.
Mr. Charbonneau believed the letter was confidential and would be sent to UCP HQ.
Instead, the letter was “leaked” to Press Progress by Jivraj.
When Mr. Charbonneau learned that Jivraj had not signed the letter, a “shit storm” erupted.
He was livid about Jivraj’s conduct.
He contacted Caylan, who clarified the residency issue, told him about the domain name appropriation, and described Jivraj’s other nefarious conduct.
Mr. Charbonneau concluded that Jivraj was a liar, dishonest, corrupt, and had a vendetta against Caylan.
He made an official complaint to Ms. Herrington, Executive Director of the UCP, Tab 106.
In his complaint letter, he wrote: “I have growing concerns about our boards ability to operate in an unobstructed manner due to Jivraj’s continued underhanded tactics.”
The Party investigated Jivraj and the “fraudulent resident” letter.
The Party exonerated Caylan and confirmed she was a legitimate nomination candidate.
The Party described Press Progress as “an NDP attack site.”
Mr. Charbonneau confronted Jivraj and accused him of deceit.
At the next Board meeting, Jivraj “threw the signers of the letter under the bus” and renounced the letter.
At a subsequent meeting, Jivraj admitted writing the letter, persuading members to sign, and leaking it to Press Progress.
Mr. Charbonneau realized Jivraj was stonewalling the nomination process and attempting to eliminate Caylan from the contest.
Although supposed to be neutral, Jivraj was backing Hlady as a nomination candidate.
Mr. Charbonneau knew Jivraj was behind the attacks on Caylan.
Board members told Jivraj he could resign as president or be forced out.
Jivraj resigned.

Caylan’s Election

Caylan was elected as the Mountainview candidate in a fair and equitable nomination process.
Mr. Charbonneau considered her a strong, well‑spoken candidate with solid conservative views and socially liberal positions.
She seemed like the right candidate.
He headed fundraising for Caylan and raised a record amount.

The Fatal Publication

The March 18 Press Progress article about Caylan was published.
Caylan resigned as a candidate.
Mr. Charbonneau resigned from the Board.
He had never experienced corruption comparable to that demonstrated by Jivraj.
He never formed the opinion that Caylan was a white supremacist or homophobic.

Cross‑Examination by Mr. Mack, Counsel for the Broadbent Institute, Mr. Magusiak and Mr. Lebrun

Mr. Charbonneau became involved in politics because he believed Alberta politics were headed in the wrong direction under the NDP.
He and several Board members were involved in forcing Jivraj’s resignation.
He spent about an hour with Jivraj at the café before signing the “fraudulent resident” letter.
He could not recall whether other signatures were already on the letter.
When he signed, he knew nothing about Caylan.
He understood he was making serious allegations, including fraud.
He did not ask Jivraj for evidence; he relied on Jivraj’s representations and was too trusting.
He did not know how many Board members would be solicited or would sign.

Cross‑Examination by Amy Cooper (Toronto Star)

When they first met, Jivraj told Mr. Charbonneau he was a lawyer.
Jivraj was a good salesperson.

Direct Examination of David Savelrud

Mr. Savelrud is a retired lawyer with extensive corporate governance experience. He gave evidence on behalf of Caylan.

He joined the Board at Hlady’s request and became chair of the Rules Committee.
Jivraj was elected president of the Constituency Association.
Jivraj chaired the LCNC (Local Candidate Nomination Committee).
The LCNC accomplished nothing under his chairmanship.
As LCNC chair, Jivraj asked Mr. Savelrud to investigate Caylan but provided no reason or evidence.
The “fraudulent resident” letter was published by Press Progress, accusing Caylan of misrepresentation and deliberate fraud.
Mr. Savelrud reviewed UCP rules and confirmed Caylan was a legitimate nomination candidate.
He was incensed that 9 of 26 Board members had signed the letter, falsely representing it as a Board decision.
He found it egregious that Jivraj used the Board’s private membership list to circulate the letter.
Jivraj did not seem to accept or respect UCP rules and bylaws.
The Party investigated the letter and suspended Jivraj as a Party member.
Jivraj continued to represent himself as president after suspension.
The Board became increasingly dissatisfied with his conduct.
Jivraj was given the option to resign or be forced out; he resigned.
Caylan won the nomination contest.
Mr. Savelrud became president after Jivraj’s resignation.
The Board then became cohesive and focused, and Caylan’s campaign progressed well.

Direct Examination of Christopher Muldoon

Mr. Muldoon is a director of investment banking and a Mountainview resident. He gave evidence for Caylan.

He was elected to the Board.
He had never been involved in politics before or since.
He became involved in 2018 because the NDP had created challenging conditions for the oil and gas industry.
Hlady, his neighbour, asked him to join the Board.
He did not attend the first meeting but learned Jivraj had been elected president.
He did not know Jivraj.
Hlady later visited his home and alleged Caylan was a parachute candidate, persuading him to sign the “fraudulent resident” letter.
Mr. Muldoon believed the letter was a private Party matter and assumed Jivraj would sign.
He learned Jivraj had not signed only after Press Progress published the letter.
He was embarrassed because his signature was visible in the article and regretted signing.
Hlady told him the letter was Jivraj’s work; Mr. Muldoon distanced himself from Jivraj.
Hlady’s breach of trust damaged their acquaintance.
Mr. Muldoon became more engaged in Board work after the letter.
He recognized that bad actors were at work in the Association.
He was angry at Hlady, Jivraj, and Press Progress.
He received the official UCP letter confirming Caylan was a legitimate candidate.
Initially, Jivraj denied writing and leaking the letter, pretending rogue directors were responsible; in fact, he had written and leaked it.

Direct Examination of Harrison Fleming

Mr. Fleming has extensive senior political experience, including work in the Harper administration and as director of communications for the Kenney government. He gave evidence on behalf of Caylan.

In 2019, he was in the UCP “war room,” where Party decisions were made.
He became aware of Caylan and was impressed.
The Party was seeking young, capable candidates, ideally female.
Caylan broke the mould and broadened the Party’s appeal.
He considered her a star candidate and front‑row cabinet material.
Press Progress published its defamatory March 18 article.
The article made Caylan disreputable and required senior‑level consideration.
Her reputational damage threatened the Party and its campaign.
The Party decided Caylan must resign or be terminated; she was given the option to resign.
She resigned, and the Party lost a star candidate.
Political parties must operate on news that becomes part of the narrative, whether true or false.
Caylan had become toxic, and for expedient political reasons the Party had to abandon her.
As director of communications, Mr. Fleming convened daily meetings with 40–50 chiefs of staff.
He made it clear that no Party member or operative could be seen supporting or associating with Caylan.
The message was clear, and no one thereafter had anything to do with her.

Cross‑Examination of Mr. Fleming

On the night of March 18, senior campaign members were in the war room.
After the article was published, the war room was flooded with media inquiries nationwide.
When Mr. Fleming read the quotes attributed to Caylan, he thought they resembled an academic discussion of public issues.
Press Progress posed charged questions of the “Why did you beat your dog” type.
He knew Press Progress was not seeking a credible response but a panic response.
The war room knew Caylan wanted to respond but instructed her not to.
Mr. Fleming stated that political reality trumps truth and that engaging with Press Progress was pointless.
He said that when truth, narrative, and electoral needs conflict, the Party must choose the latter.
He was controlling the message in the Party’s interest, not Caylan’s.
Jason Kenney made the decision that Caylan had to resign.
Caylan “fell on her sword.”

Re‑Direct Examination of Mr. Fleming

Media outlets across Canada contacted the UCP war room after the article: Canadian Press, CBC, the Toronto Star, radio stations, and TV shows.
Mountainview shifted from a riding the UCP expected to win to one they assumed they would lose.
The Party stopped allocating resources to the riding.
Had Caylan run and lost, she would have secured a senior staff position in government.

Court adjourned.

Comment

· The testimony of Mr. Charbonneau and Mr. Savelrud highlighted the duplicitous character of Jivraj.

· Mr. Muldoon’s evidence highlighted the collaboration between Jivraj, Hlady, and Press Progress, all of them intent on destroying Caylan.

· Mr. Fleming’s evidence made it clear that Caylan would have been in cabinet had she been elected.

· Mr. Fleming also confirmed that after her resignation Caylan was deemed toxic by the UCP Party and all association with her ceased.

Jared Pearman 3/25/26 Jared Pearman 3/25/26

Day 10

Continued Cross‑Examination of Caylan by Matthew Woodley, Counsel for the CBC

· Canadian Press, the Globe & Mail, Post Media, and the Calgary Sun all published defamatory articles about Caylan

· She did not sue those publications

· Caylan obtained a court restraining order against Jivraj in 2023

Continued Cross‑Examination of Caylan by Matthew Woodley, Counsel for the CBC

· Canadian Press, the Globe & Mail, Post Media, and the Calgary Sun all published defamatory articles about Caylan

· She did not sue those publications

· Caylan obtained a court restraining order against Jivraj in 2023

· The CBC published an article about the restraining order and about a fine given to Jivraj for contempt of court

· While an employee of Foreign Affairs, Caylan progressed through different employment categories but never became categorized as a permanent employee of Foreign Affairs

· Caylan’s current annual income from her school is $135,000

Cross‑Examination of Caylan by Amy Cooper, Counsel for the Toronto Star

Concerning the Toronto Star:

· A defamation notice is a notice given to newspapers advising that they may be sued for a defamatory publication; it is a necessary preliminary step before suing

· Post Media and the Calgary Sun were among the many that published articles derogatory of Caylan

· Caylan gave defamation notices to 8 parties, but did not sue all the parties given notice

· she did not sue Post Media or the Calgary Sun

· Caylan confirmed that a reporter from Star Edmonton (a free handout publication of Toronto Star) had emailed her asking to speak to Caylan that afternoon;

· Caylan referred him to her resignation letter; they did not talk;

· Caylan told the reporter that if he had questions to email them to her; she did not receive any emails from him;

· In an article published on March 19 the Toronto Star included a reference to Caylan’s resignation letter and quoted some of the exculpatory statements made in that letter;

· Kevin Leaman, a Toronto Star reporter, reached out to talk to Caylan on March 25;

· Caylan advised him that she could not speak on that day but would be happy to talk 2 days later;

· Caylan received no further communication from Leaman;

· Caylan was questioned about the fact that she never sent information to the Toronto Star;

· Caylan made the point that she did not have investigative obligations; that she was not the journalist, they were;

· In April 2019, Caylan published Apologia (described in Glossary)

· She did not send a copy of that essay to Toronto Star, although she did send it to other news media;

· Toronto Star published quotes from Mark Hlady [identified in Glossary] claiming that Caylan was hand picked b Kenney to run as a candidate and that he Hlady could have beaten her in the nomination contest if he had not been unfairly disqualified;

· Emma McIntosh, a Toronto Star reporter, wrote many defamatory columns about Caylan;

Concerning Caylan’s relationship with Jivraj:

· Caylan suspected as early as March, 2017 that Jivraj was a sketchy character;

· By 2018 she knew he was cunning, deceitful and treacherous, had a drinking problem and was intent on destroying her ;

· in January 2018, Caylan told the UCP communications director about the FB Messages she had exchanged with Jivraj, and that Jivraj was posting derogatory messages about her;

· The UCP party retained a lawyer to write a cease-and-desist letter to Jivraj;

Cross‑Examination of Caylan by Ben Franken, Counsel for Defendant Avnish Nanda:

The cross-examination largely involved questions and answers about exhibits I could not see. Because I did not know anything about the subject of the Q and A, I can not summarize it well. The following is the best I could do:

· Nanda wrote op-eds and tweets derogatory of Caylan;

· Nanda and a person named Mohamed made defamatory statements about Caylan;

· Nanda also communicated with Emma McIntosh of the Toronto Star making defamatory statements about Caylan;

About Caylan publicity after resigning:

· Caylan did a podcast with Joel Chrichton in March;

· She was a podcast guest on True North in Sep 2019;

· She was scheduled for a talk at the University of Lethbridge but the event never happened;

· She and Barbara Kay (a National Post columnist) were speakers at a public meeting in Calgary;

· In July 2020, Caylan launched a podcast named, “Worst Thing Ever”; did 3 podcasts;

· Caylan was twice interviewed by Cory Morgan;

· Caylan did a podcast interview with a Harvard professor; the podcast was entitled "Lapidation and Cancel Culture”

· Caylan published several times in The Hub, an online magazine;

· She also published a piece called They Can’t Cancel your Soul for The American Mind

· She was a panelist in a seminar at a Britania Fellowship conference in the UK

· Caylan was on a podcast called Truth Exists

· She was a guest and spoke at a Civitas conference on 2 occasions

· She published more articles on genocide in communist China

· Caylan finished her documentary entitled When the Mob Came in 2023

Re-Direct Examination of Caylan by her Counsel, Richard Harrison:

Concerning Caylan’s productive abilities:

· Caylan now has a more limited capacity for work than she formerly had; her productive ability is impaired

· Because of her reduced endurance, Caylan now needs days off, suffers social anxiety and finds it mentally taxing to deal with people

About pharmaceutical medications:

· Caylan and Dr. Lucido discussed different medications for the treatment of Caylan’s depression

· They discussed the side effects of the medications and the mechanisms by which they work

· Dr. Lucido was sceptical about the use of pharmaceutical medications unless all alternatives had failed

· Caylan chose not to take the medications because science does not understand the mechanisms by which they work

· Caylan was concerned about long-term side effects

Comment:

· The fact that Caylan did not sue every organization that defamed her does not detract from the defamations by the Defendants who were sued.

· If the sued Defendants thought other media organizations should bear some of the defamation damages, they could bring those other organizations into the lawsuit, seeking contribution to the damages

· The legal procedure by which those other organizations could be brought into the lawsuit is called a Third Party Notice

· Some Defendants appear to be contending that because Caylan was not completely crushed their defamation was harmless.

Jared Pearman 3/25/26 Jared Pearman 3/25/26

Day 9

Cross‑Examination of Caylan by Mr. Mack, Counsel for the Broadbent Institute

Philosophical and Political Concepts

Cross‑Examination of Caylan by Mr. Mack, Counsel for the Broadbent Institute

Philosophical and Political Concepts

• Q&A covered racial identitarianism, identity politics, metaphysics, genocide, racial identity, feminized society, toxic masculinity, demographic replacement, culture, white nationalism, and white supremacy
• Caylan provided definitions and intellectual explanations of these concepts
• She denied being a white supremacist or white nationalist

Accuracy of the Press Progress Article

• She agreed some quotes were accurate but selectively bolded and underlined
• One quote omitted her statement, “I would reject that appellation”
• Another omitted her words to the effect of, “but who agrees with you, I think is unlikely”
• She testified that the final quotes were “not reproduced with fidelity”
• She explained how the omissions altered the meaning of the quotes

Cross‑Examination by Mylene Tiessen, Second Counsel for the Broadbent Institute

Calgary Classical Academy (the “School”)

• the charter school was Caylan’s idea and her creation; she applied for a charter in 2021, and it was approved in January 2022
• The application required extensive work: drafting the charter, determining student numbers, explaining the School’s uniqueness, preparing a budget, obtaining 100 parent signatures, drafting bylaws, creating a website, and identifying potential locations
• She completed most of the work herself
• Initial enrollment was 300; current enrollment is approximately 1500

Medical Treatment

• Her family doctor referred her to Dr. Lucido
• She received psychodynamic therapy in summer 2023
• Pharmacological options were discussed during intake
• She declined medication because she believed science does not understand the mechanisms by which such drugs work
• Dr. Lucido advised that severe depression can impair brain function
• She believed her depression was situational and medication was not the solution

Cross‑Examination by Matthew Woodley, Counsel for CBC

Background Context

• Caylan understood that a politician’s conduct is a matter of public interest
• She was aware of 2019 debates about gay‑straight alliances and related LGBTQ issues
• Jivraj provided CBC the same defamatory material he gave Press Progress regarding the October 1 “fraudulent resident” letter
• CBC contacted her but did not publish anything about that material
• By late 2018 she feared Jivraj would not stop attempting to destroy her
• She did not inform CBC of her concerns

Events of March 18

Lebrun Email

• Defendant Lebrun emailed Caylan stating Press Progress would publish quotes attributed to her within two hours
• The email caused a crisis because she had deleted her copies of the FB Messages and could not confirm or deny the quotes
• She knew Press Progress was collaborating with Jivraj

CBC Contact During the Crisis

• Two CBC journalists repeatedly called during the crisis
• Ms. Ward discussed whether their call should be recorded and whether it was “off the record”; Caylan agreed to have it recorded
• CBC sought a full oral interview for broadcast the next day
• She declined due to the ongoing crisis
• She told CBC that Press Progress was not credible, was collaborating with Jivraj, and had refused to correct past false statements
• She explained that she lacked the FB Messages and could not verify the quotes
• She told Ms. Ward the quotes sounded “odd” and she doubted she had said them

Eye Opener Invitations

• CBC invited her to appear on the Eye Opener the next morning
• She asked about CBC’s purpose and the intended line of questioning
• A CBC journalist referenced an alleged quote about gay pride parades
• Ms. Ward said the Eye Opener would need to address the racism allegation
• Caylan feared the interview would be framed as “why did you say these things”
• Uncertain of CBC’s intentions, she declined the invitations
• The invitations were repeated several times
• She felt the journalists’ questions were loaded and did not answer them

Source of the Quotes

• She told CBC that Jivraj was the source of the quotes
• She described him as reviled in Alberta politics despite having lived in Calgary only two years

CBC’s Position vs. Caylan’s Position

• CBC maintains it could not publish her comments about Press Progress and Jivraj because the call was “off the record”
• Caylan maintains she informed CBC about Jivraj and that they should have investigated further

CBC Publication

• She understood CBC would not publish anything based on the Press Progress Article until she had an opportunity to comment
• CBC published its first article seven hours later without obtaining her comment
• On March 20 CBC emailed saying they remained open to hearing from her
• She named persons who CBC could contact to learn more about Press Progress and Jivraj

Questions on Pride Parades and Gay Marriage

• She explained that attendance at pride parades should be voluntary and that people should not be condemned for not attending
• She stated she prefers sexual modesty
• She explained that gay marriage redefined the term “marriage”
• She also said gay unions should have official recognition and rights

Comment

• The events of March 18 destroyed Caylan’s political career
• the CBC offered Caylan the opportunity of an oral interview and several times offered an appearance on Eye Opener
• she suspected CBC would not treat her fairly in an interview or on the Eye Opener
• Subsequent CBC conduct confirmed those suspicions

Jared Pearman 3/25/26 Jared Pearman 3/25/26

Day 8

Unfortunately, my trial notes for Day 8 were lost or inadvertently deleted.

On this day, Mr. Harrison concluded his direct examination of Caylan. Mr. Mack, appearing for the Broadbent Institute, then commenced his cross‑examination.

Unfortunately, my trial notes for Day 8 were lost or inadvertently deleted.

On this day, Mr. Harrison concluded his direct examination of Caylan. Mr. Mack, appearing for the Broadbent Institute, then commenced his cross‑examination.

The evidence addressed, and many of the questions posed, are expected to re‑emerge later in the proceedings through other witnesses and counsel, often in different forms.

Jared Pearman 3/22/26 Jared Pearman 3/22/26

Day 7

Direct Examination of Caylan by Her Counsel, Richard Harrison

General Allegations

• David Kahn, then leader of the Alberta Liberal Party, referred to Caylan as a white supremacist
• Caylan reiterated that she had described white supremacy as “odious and perverse”
• She was accused of being a white nationalist, an Islamophobe, a racist, and a white supremacist

Direct Examination of Caylan by Her Counsel, Richard Harrison

General Allegations

Testimony About the Toronto Star

Coverage and Headlines

• A Toronto Star headline read: “Star Candidate Removed for Racist Views Will Not Be Removed From Party”
• The Star frequently quoted third parties critical of Caylan
• The Star made no effort to quote anyone supportive of her; its coverage lacked balance
• It equated her with other disqualified candidates and suggested her candidacy reflected a failure of the vetting process
• The Star often featured large photos of Caylan, including a front‑page image with the headline: “We Need Higher Standards”

Use of the Press Progress Article

• The Star frequently quoted or paraphrased the Press Progress Article
• It claimed Caylan portrayed herself as a victim
• It suggested she had made statements that were hateful, racist, homophobic, and transphobic

Caylan’s Testimony About the Coverage

• She testified that the Star’s publications were extremely misleading and false
• She stated she never expressed animus toward others and never portrayed herself as a victim
• She believed she was enduring a “trial by media” in which she was not allowed to defend herself
• She felt the Star was attempting to humiliate her
• The Star never sought comment from her
• She described the portrait being painted of her as a “doppelgänger inverse image” of who she actually was

Impact on Caylan

• She developed agoraphobia due to widespread circulation of her photos alongside defamatory articles
• She did not want to be seen in public

Interactions With Star Reporters

• A Star reporter contacted her twice
• On one occasion she asked him to email his questions; he never did
• On the other, she said she could not speak that day but would be available two days later; she never heard from him again

Testimony About Defendant Nanda

Statements and Conduct

• He made statements based on the Press Progress Article and attributed views to her that were not her views
• He claimed Caylan’s membership in the UCP was evidence the Party held racist, white nationalist views
• He stated, “white supremacy has no place in Alberta”
• He was working for third‑party advertisers supporting the NDP
• He wrote articles for Press Progress, including one criticizing Danielle Smith for interviewing Caylan
• He was associated with, and acted as lawyer for, Progress Alberta (a settled defendant)
• He associated Caylan with mass murderers
• He never spoke to her, despite her invitation to meet for coffee to discuss her views

Conduct During the Danielle Smith Interview

• When Caylan appeared on Danielle Smith’s show, Nanda began posting negative comments shortly after the interview began and continued throughout
• He stated he was in disbelief that Caylan was allowed to explain her “white supremacist views”
• He stated that she had made no apology as if an apology was owed
• He paraphrased allegations from the Press Progress Article and condemned Danielle Smith for conducting the interview

Testimony About the Danielle Smith Radio Interview

Reaching Out to Danielle Smith

• In March 2019, Caylan contacted Danielle Smith, stating that the media coverage of her was unfair
• Although advised by the Party to “lay low,” she wanted to explain that she did not hold the abhorrent views attributed to her
• She sought a platform to explain what had happened
• She reached out to Danielle because she viewed Danielle as an open‑minded intellectual who would conduct a fair interview

The Interview

• Danielle conducted a 30‑minute live interview on radio and online
• Caylan explained how she had been sabotaged by Jivraj and Press Progress and that the views attributed to her were not her own
• Listener responses were initially positive, and she received supportive messages, which brought her relief

Negative Reaction

• Negative tweets soon followed, showing angry bias
• Nanda and Toronto Star reporter Emma McIntosh joined in the criticism
• McIntosh mischaracterized Caylan’s statements, writing that she was racist, unapologetic, and had made extreme white supremacist statements
• Caylan hoped the interview would redeem her, but those hopes were “suffocated”

Pressure Campaign Against Corus

• A movement began to pressure Corus Entertainment to fire Danielle Smith for airing the interview
• An online petition, written by Nanda and published by Press Progress, included a form letter making it easy to complain to CHQR
• The petition described Caylan as a “disgraced candidate,” accused Danielle and Corus of “shocking dereliction of duty,” repeated quotes from the Press Progress Article, and included the phrase “say no to white supremacy on CHQR”
• 737 people sent the form letter to Corus
• The Broadbent Institute and Nanda launched a defamation lawsuit against Corus
• Corus capitulated and removed the interview
• Danielle Smith was forced to issue a public apology
• A senior Corus executive asked Caylan to remove the interview from her website

Impact on Caylan

• She believed the interview would help clear her name, but every attempt to do so was undermined
• She felt as though she had been buried, clawed her way to the surface, and then been buried again
• The most distressing part was that she could do nothing; no one would hear her story

Additional Testimony About the Toronto Star

Social Media Activity

• Toronto Star reporter Emma McIntosh began tweeting criticism before Caylan had even spoken during the Danielle Smith interview
• McIntosh questioned why airtime was being given to an “unapologetic white supremacist,” called it disturbing and problematic, and asked how CHQR could claim to be responsible media
• She tweeted, “Hilariously, Caylan is claiming she has friends”
• Nearly 54,000 people viewed McIntosh’s tweets

Subsequent Star Coverage

• The Star reported that Caylan resigned after making racist comments, without disclosing that Jivraj was the source
• It wrote that she dodged questions about racist, Islamophobic, and anti‑LGBTQ views
• Despite Caylan having participated in three hours of public interviews explaining her views, the Star never made any positive or balancing comments
• Anyone who supported Caylan was immediately attacked online
• Neither the Star, the Broadbent Institute, nor Press Progress published anything reflecting Caylan’s perspective as set out in her resignation letter or interviews

Testimony About Caylan’s Apologia

• In 2022, Caylan wrote a 9,000‑word essay titled Apologia, (see Glossary) in which she attempted to explain that the Facebook Messages were academic and philosophical conversations
• She sent copies of Apologia to CBC reporter Ms. Ward and to Nanda, but neither gave any indication they had read it
• For every 1,000 readers of a CBC article, only one person read Apologia

Testimony About the Effect on Caylan

Immediate Aftermath

• The events of March 18 were life‑changing for Caylan; people online said she should die or be “shot into space”
• Friends abandoned her out of fear of backlash
• She was the family’s primary breadwinner and suddenly had no employment

Attempts to Respond Publicly

• She continued writing and tried to find an editor or journalist willing to publish her material; none would take it on or were permitted to publish it
• She felt her survival depended on “writing her way out of the hole,” but this proved impossible
• She became self‑conscious about writing because no one would publish her work

Social and Personal Isolation

• She felt as though she was in “eternal exile”
• Her social life collapsed immediately; she was removed from Christmas party lists
• People told her they did not want to appear to be supporting a “white supremacist”
• Her husband Jared attempted to organize a surprise birthday party for her, but no one would attend
• Friends said they were afraid to socialize with her because it would appear to be supporting her
• She described herself as sitting “in the ruin” of her life—treated like a pariah and very alone
• She felt like a ghost, existing somewhere between living and dying, and felt she no longer belonged in Alberta or Canada

Online Abuse and Media Repetition

• Brutal posts and tweets about her were ubiquitous on social media
• Canada’s largest publications repeatedly portrayed her as a horrible person
• She received hostile emails telling her she was trash, worthless, or should die
• She did have a small number of private supporters

Support From Individuals

• Sadiq (see Glossary) called her every day for months after March 18
• Jared tried to encourage and support her
• When she and Sadiq visited the Ranchmen’s Club, a friend told them a waiter was tweeting that he never thought he would have anything to do with Caylan

Loss of Hope for Redemption

• She hoped for several months that she could redeem herself, but by autumn 2019 it became clear she could not
• She experienced acute anxiety episodes similar to PTSD
• When applying for jobs, she struggled with how to explain what had happened in 2019

Psychological Impacts

• At times while driving she had to pull over because she felt she was losing her mind
• She experienced episodes where she could not speak and felt mentally disintegrated
• She was gripped by terror, hopelessness, and despair
• She lost her self‑esteem, her earning capacity, and her friendships
• She gave up hope that justice would be done and began “looking toward the other shores,” wanting to die
• For relief she hiked in the mountains; in winter 2019 she climbed a high mountain, lay in the snow, and asked to die

Cognitive Impairment

• She felt she was losing her mind and could not control her thoughts
• Her ability to concentrate was severely diminished; she would read and realize she retained nothing
• At times Jared would speak and she “wasn’t there”
• She recognized her own cognitive dissonance
• She suffered acute and severe depression

Employment Consequences

• Her maternity leave ended shortly after her resignation
• She sought re‑employment with Global Affairs but was not hired
• She made many job applications but received no replies
• Anyone Googling her name saw only derogatory statements; her name was “toxic”
• As the primary breadwinner, the financial stress was severe
• In 2019 her income was $38,000, with legal fees and school expenses
• In 2020 her income was $50,000—insufficient to support a family of four
• Because of her reputational damage, employment in fields for which she was qualified was impossible

Attempts to Pursue Further Education

• She considered returning to postgraduate studies and applied to the University of Calgary; she received no reply
• She applied for a professorial position at the University of Calgary; she never heard back
• Search results for her name made her unemployable

Testimony About the Non‑Existent NDP

Legal Identity Issues

• Caylan wanted to sue the NDP for its role in the events of March 18 but learned that the Alberta NDP does not exist as a legal entity
• She was seeking a remedy against a party that legally did not exist; no entity was responsible for its conduct
• Identifying a responsible party required multiple court proceedings, including an appeal to the Alberta Court of Appeal
• the legal proceedings concerning NDP extended for years and entailed significant legal fees

The “Straw Man”

• Ultimately, the non‑existent party appointed a “straw man” to accept responsibility for the 2018 conduct
• The straw man was supposedly indemnified by an entity that Caylan knew did not exist
• She settled with the straw man

About the UCP in Power

• After the UCP was elected, many UCP volunteers and campaign staff obtained government employment
• Defeated UCP candidates were appointed to senior positions in the new administration
• Caylan was never contacted by the UCP

Comment:

Credibility was essential to Caylan’s life; her credibility was destroyed by false allegations. It was impossible to correct the false allegations. Deep depression and despair understandably overwhelmed Caylan.

Jared Pearman 3/22/26 Jared Pearman 3/22/26

Day 6

Direct Examination of Caylan by Her Counsel, Richard Harrison

Initial CBC Coverage

• On March 18, the first CBC article was published; it quoted from the Press Progress Article and adopted its framing
• Thereafter, CBC repeatedly referred to Caylan as a white supremacist
• CBC repeatedly described Jivraj as “a longtime Muslim Conservative with deep ties to the Party”

Direct Examination of Caylan by Her Counsel, Richard Harrison

Initial CBC Coverage

CBC’s Reporting on the 2017 Messages

• In the 2017 Facebook Message conversations with Jivraj, Caylan had posed rhetorical questions about the value of pride parades to invite debate
• CBC reported that she resigned over “white supremacist comments” and that she had questioned pride parades
• Caylan explained her view that participation in pride parades should be voluntary, that people should not be condemned for choosing not to walk, and that she personally preferred gay concerts over gay parades

CBC’s Claims About the Messages

• CBC proclaimed that it had “seen and verified FB messages,” when in fact it had only seen screenshots of selected images taken out of the Messages
• CBC reported that Caylan had refused to comment
• Caylan had declined to give a live oral interview to Ms. Ward on March 19 and reiterated her reasons
• CBC claimed it had offered her a chance to respond but published its article seven hours later without giving her that opportunity
• On March 18, Caylan gave Ms. Ward full particulars of Jivraj’s deceit and treachery, both in a telephone conversation and through her resignation letter

About the CBC

Selective Use of Information

• CBC quoted only portions of Caylan’s resignation letter, omitting key reasons behind her decision to resign
• CBC did not share with its readers, listeners, or viewers any part of the taped conversation between Caylan and Ms. Ward

Amplification of Third‑Party Defamation

• CBC further publicized defamatory comments about Caylan by third parties, including:
• Ms. Ganley, an NDP candidate, who described Caylan as a racist
• Mayor Nenshi, who condemned Caylan for not apologizing and said she was not fit

CBC Internal Records

• Internal CBC records showed that one column about Caylan had been viewed 358,334 times
• Another internal record revealed that nearly 100,000 people had viewed one CBC post

More Testimony About Caylan

Search Results and Public Perception

• Before March 17, Google search results for Caylan’s name were complimentary and flattering
• After March 19, with only two exceptions, search results were condemnatory
• She was repeatedly accused of being a white supremacist or white nationalist; she explained why neither term could be attributed to her

Association With the Charlottesville Shooter

• In one Facebook Message, Caylan had written that the Charlottesville massacre was “sickening”
• Despite this, she was continually associated with the shooter
• Publications repeatedly linked her to the massacre

Testimony About the Toronto Star

Use of Press Progress Material

• The Star published many articles quoting or paraphrasing Press Progress
• It stated that Caylan promoted white supremacist and racist talking points and expressed sympathy for white nationalist views

Failure to Seek Her Perspective

• The Star emphasized that Caylan never apologized
• Caylan testified she did not apologize because she did not know what she was supposed to apologize for; everything published about her was false, and the views attributed to her were not her views
• The Star had been in touch with Jivraj since January, when they received screenshots from him
• They described Jivraj as a “Muslim conservative with ties to the UCP”
• They never asked Jivraj to produce the full Messages

Limited Contact With Caylan

• Caylan received one email inquiry about her resignation from a Star reporter
• She referred him to her resignation letter and told him to email any further questions
• She never received anything else from that reporter or any other Star journalist

Amplification of Third‑Party Criticism

• The Star frequently quoted third parties who criticized Caylan
• They quoted Mayor Nenshi and “gave him a lot of ink”
• They quoted Hlady (see Glossary), who claimed he had been unfairly ousted as the Mountainview candidate so Caylan could run
• Hlady said “they couldn’t beat me,” despite polling showing he had 3% support before being disqualified
• Hlady had been disqualified by the Party for sexually inappropriate conduct while an MLA

Distribution

• The Toronto Star publishes Star Metro, a free street‑handout that reproduced Star articles and was widely distributed
• Editions of the Star’s publications were available in Calgary and Edmonton

Testimony About Defendant Nanda

• Nanda made approximately 70 defamatory statements about Caylan, both in op‑eds and in tweets
• Caylan and Nanda had never met, and she knew nothing about him
• She invited Nanda to meet her for coffee so she could explain the truth; he did not accept the offer, nor did he contact her or ask for an explanation

Testimony About the Taped Podcast Played in Court

• The podcast featured four individuals who cruelly, mockingly, and derisively disparaged Caylan, as well as Jason Kenney and Licia Corbella
• One of the participants was Defendant Stephen Magusiak, a reporter with Press Progress
• One speaker, repeating or paraphrasing Press Progress quotes, said Caylan had a “very well‑formed white nationalist philosophy”
• Caylan was accused of being a misogynist and repeatedly called a white nationalist
• The speakers described Licia Corbella as a “shill” for the UCP
• They contemptuously questioned Caylan’s Oxford degree and mocked her documentary Letter from Masanjia
• They stated that her UCP nomination was rigged and called her a grifter
• One participant compared Caylan to a member of the Ku Klux Klan
• Magusiak knew of Jivraj’s history of treachery and his attempts to harm Caylan
• Magusiak mocked Caylan’s husband and children

Testimony About Harm Done

• The Chair of the Canadian Constitution Foundation initially spoke to Caylan about joining their board, but after March 19 he told her that other board members considered it a “non‑starter”
• He said she would never be rehabilitated and would be a reputational liability
• Caylan testified that she had always believed her cognitive and intellectual gifts were meant to be used in service of others — “If we have gifts, we owe them to other people”
• She found she could not use her gifts to help anyone because her name and reputation would harm any cause she supported
• She could not support her family or help her friends; she felt she was of no use to anyone
• The most difficult part for her was feeling that her life no longer had purpose

Testimony About Speaking Engagements

• In fall 2019, she was invited to speak at a Calgary event attended by 50–100 people
• She spoke, but masked protesters attended, calling her a white supremacist
• Dr. John von Heyking of the University of Lethbridge invited her to speak about freedom of speech and political science
• Student groups attempted to cancel the event and compared it to events that led to the Holocaust
• The university did not cancel the event but stated it would allow protests
• The COVID‑19 lockdown intervened, the event was cancelled, and she was never invited back

Testimony About Employment

• Caylan applied to Global Affairs to renew her employment, but her application did not result in a position
• She was unemployed and applied for long‑term disability benefits
• In 2021, her income was $80,000, consisting mostly of disability benefits
• She was uncomfortable receiving benefits — being paid money she did not earn
• She wanted employment, but her reputational damage made her unemployable
• In late 2021, she reapplied to Global Affairs through her union
• Global Affairs rehired her, but in a role not commensurate with her previous work — essentially clerical, answering emails for a consular emergency fund
• The position involved no policy or analytical work
• It was a teleworking role; security rules required her to be isolated and work only from her bedroom
• She was humiliated that no one had any interest in using her abilities
• She became depressed; her return to work was deemed unsuccessful
• Her supervisors could not give her a positive review
• She returned to disability benefits for the last three months of 2022
• Unemployment was difficult, but the psycho‑social and cognitive effects were worse

About Caylan’s Struggle

• She applied for employment but received no responses
• Interviews of her that had been available online were taken down
• She felt as though she was drowning in grief, no longer present or attached to the world
• She welcomed the idea of death
• Her capacity for joy disappeared
• She suffered severe fatigue and was constantly tired
• She often had no incentive to get out of bed and sometimes stayed in bed all day
• When out in public, she would sometimes feel grief well up as if it were a physical substance her body could no longer contain
• She would begin crying spontaneously

Therapy and Diagnosis

• She began cognitive therapy with Dr. Lucido
• On her intake form, Dr. Lucido wrote that she needed help dealing with unremitting grief and passive suicidal ideation
• Her symptoms were consistent with severe depressive disorder and PTSD‑like symptoms

Impact on Her Children

• Her daughter Anora was less than one year old; Caylan missed much of Anora’s first year
• Anora has no memory of her mother before the trauma
• Caylan tried to put on a normal façade for her daughters, but it was always forced
• She felt she was never truly present with them
• Her older daughter, Everen, once asked Caylan to tell her a story; Caylan replied she was too sad to tell stories
• Everen told her, “You need to go campaigning again,” because she could see how sad her mother was
• Everen said that next time she would protect her mother
• Caylan felt it was wrong that her three‑year‑old believed she needed to protect her
• Everen was perceptive and could tell that Caylan had changed

Loss of Purpose

• In the background, Caylan was trying to figure out how to earn a living, find employment, and rebuild
• She could not support her family or help her friends; she felt she was of no use to anyone
• The most difficult part was the feeling that her life no longer had purpose

Marriage Breakdown

• Caylan testified that her former husband Jared would testify and she did not want to impinge on his evidence
• Jared’s social world had been Caylan’s social world; when her world collapsed, his collapsed as well
• It was traumatic for him; he felt powerless watching Caylan be attacked and become suicidal
• The stress on the family was immense
• Jared tried to give Caylan space to work and heal
• His ability to work full‑time was impaired because Caylan was deeply depressed and he had to care for the girls
• He fell into a deep depression
• They separated in the summer of 2021 but continued living in the same house because they could not afford to live separately
• They eventually divorced
• Caylan described it as a profound failure; she was so embarrassed that it took years before she told anyone

Testimony About Jivraj’s Treachery

Online Attacks

• Jivraj continued feeding ideas to Press Progress about how to socially isolate Caylan
• He targeted anyone who said anything positive about her
• He created two pseudonymous Twitter accounts to attack her: the “Serena R” account and the “Mr. Wilson” account

The “Serena R” Account

• “Serena R” was portrayed as a liberal‑leaning woman with children
• The account amplified negative remarks about Caylan and directed people to hostile stories
• These included claims that she promoted white genocide and made “racist, antisemitic comments”

The “Mr. Wilson” Account

• “Mr. Wilson” attacked Caylan from the right
• He called her a coward, weak, “no Margaret Thatcher,” and someone who “folds like a cheap suit”

Targeting Journalists Who Interviewed Her

• Joel Crichton and Andrew Lawton had both interviewed Caylan and published favourable interviews
• Jivraj contacted both men and threatened them with lawsuits if they did not remove the interviews
• Both removed their interviews
• Crichton later restored his interview after speaking with Caylan

Removal of the Danielle Smith Interview

• Caylan noticed her interview with Danielle Smith had been removed from the Corus network
• Corus told her it had been removed for editorial reasons
• Jivraj had threatened Corus with a libel lawsuit
• Corus asked Caylan to remove the interview from her own website

Importance of the Interviews

• It was important to Caylan to keep the interviews online because hundreds of publications were describing her as a white supremacist, terrorist sympathizer, Nazi, and someone unfit for polite society
• The interviews were the only way she could show the world who she really was
• They were her only means of defending herself
• She was trying to clear her name

Further Interference

• Cass Sunstein wrote about modern “stonings” (cancellations) and what drives people to participate in such campaigns
• “Mr. Wilson” responded to Sunstein, saying Caylan had cowered in the face of controversy and shown no moral courage
• Andy Signor, from Florida, reached out to Caylan and recorded a podcast with her about how people cope with being cancelled
• Before the podcast was published, Jivraj contacted Signor — both under a pseudonym and his real name — and threatened Signor and his associates
• Signor published the interview despite the threats

Testimony About Caylan’s Mental State

• A psychiatrist friend told her that her symptoms were the type long‑term disability benefits were designed for
• She applied for and received those benefits for about two years
• She did not feel good about being on benefits; she disliked receiving money she had not earned
• She remained unemployed
• She met with a therapist for talk therapy
• She suffered not only reputational harm but also severe psycho‑social and cognitive effects
• Her ability to complete tasks was impaired; she felt broken

Symptoms and Therapy

• In the immediate aftermath of March 2019, she was traumatized but still hoped she could clear her name
• As time passed — with no ability to publish essays, no responses to job applications, and interviews being taken down —
• She began to feel as though she was drowning in grief
• She welcomed the idea of death

Comment

• The egregious conduct of the Defendants was on full display
• Listening to the Magusiak podcast was disturbing and saddening; it revealed how nasty, cruel, and dishonest people can be in pursuit of ideological or political goals
• Caylan’s career and life were devastated

Jared Pearman 3/15/26 Jared Pearman 3/15/26

Day 5

The quotes which Press Progress included in the damaging and destroying article about Caylan (the Article”) are quoted within the Lebrun email to Caylan, Tab TB1000144, [click HERE to view].

Caylan testified about the Article:

· it had been approved for publication by Broadbent Institute, the owner of Press Progress ;

Note: I am a poor note-taker and these summaries will contain errors and omissions which will reflect my limitations. My intention is to report on the facts as accurately as possible although a subconscious bias may creep in. I can only provide glimpses into what I see as relevant and interesting events. My goal is to capture the essence of the day’s events rather than be comprehensive.

The quotes which Press Progress included in the damaging and destroying article about Caylan (the Article”) are quoted within the Lebrun email to Caylan, Tab TB1000144, [click HERE to view].

Caylan testified about the Article:

· it had been approved for publication by Broadbent Institute, the owner of Press Progress ;

· the Article or versions or excerpts of it immediately became national news; it was headlined in both national and local newspapers; broadcast on both local and national TV stations, and became the subject of thousands of tweets, posts, and podcasts;

· for an example of another Press Progress publications, Tab 5, {click HERE to view];

· the publications continued for years, and the Article is still live on the Press Progress website;

· a graphic designer had been used to make the quotes in the Article look real; highlights had been added;

· the statements she made had been altered and edited; words had been removed; half of one statement had been deleted; portions were highlighted.

Caylan dealt with each of the quotes, identifying what had been omitted and what altered. She explained at length the context of the discussions from which the quotes had been taken and how they would be understood in the context of the discussion.

She explained that when she used the words “demographic replacement” she was using the term as it was then understood by social scientists; she didn’t then even know about the odious “Great Replacement” theory.

Caylan testified concerning journalists that, after March 18 :

· one column favorable to her was published in the National Post;

· she knew and talked to other columnists who wanted to take up her cause, but were prevented from publishing; [Caylan identified by name the journalists who were favorably inclined];

· except for those so identified and conversations with Ms. Ward on March 19, no Canadian journalist, publisher or broadcaster consulted Caylan;

The testimony continued:

· Press Progress, CBC, and Toronto Star all referred to their source as “a credible long time Conservative Muslim;”

· Caylan explained why Jivraj was not “credible” nor a “long time Conservative” nor a Muslim;

· He was not a Conservative because he had had been driven out of Ontario for his political conduct, never volunteered or worked for the Party, and was effectively removed by the Party as president of the constituency association;

· Muslim: Caylan read in Jivraj’s own words in emails in which he expressly declared that, “the substances of the Islamic doctrine never meant anything to him,” and that he “never really viewed Ishmael as my community”;

· Jivraj provided both the Toronto Star and CBC with his sworn, 16-page affidavit containing images of screenshots of excerpts from the Messages; Jivraj swore they were authentic;

· both the CBC and Toronto Star considered that affidavit as their “reliable source”;

· both had reason to suspect Jivraj’s honest and credibility;

· Caylan provided both with information to prove that Jivraj had a history of false attributions; that he was conniving and deceitful;

· they chose to rely on Jivraj;

· both of them gave Jivraj anonymity presumably because of his bad reputation; they tried to cloak him with credibility;

· neither of them interviewed Caylan or gave her an adequate chance to state her case.

Among the allegations published by Toronto Star, CBC, and Press Progress were words to the effect that:

· she endorsed white supremacy and white nationalism and was analogous to the shooter in the Charlottesville massacre;

· she was morally unfit to be a candidate;

· she was “handpicked” by Kenney as a candidate while living in Ontario, Tab4, {click HERE to view] ;

· she was or potentially was a believer in the odious “Great Replacement” theory;

· she was critical of Islam.

Caylan testified that:

· in the Messages she had expressly renounced both white nationalism and white supremacy;

· she met Kenney only after moving to Alberta and had been “picked” as a candidate by >500 voters in a contested nomination contest;

· she didn’t even know about the Great Replacement theory in 2017; she now rejects the theory;

· she has never criticized Islam but has criticized the beliefs and conduct of some members of that faith.

Concerning her personal situation on March 19 Caylan testified that:

· she was 32 and her daughter was 3.5;

· She had been campaigning for a year and had seen little of her husband and daughter;

· She and husband Jared had made huge sacrifices to allow her to run; they thought the sacrifice worthwhile;

· Jared had largely given up his career to stay at home, tend their daughter, and do the household duties;

· Neither she nor Jared had any significant income; they were living on a small inheritance Jared had received;

· their financial position was precarious; Caylan was worried that her employment with Foreign Affiars would no longer be available;

· When she eventually went home on the night of the 18th her husband Jared was angry about what had happened;

· Caylan became the subject of Jared’s anger;

· She was shell-shocked and in denial; she couldn’t sleep;

· She received kind, supportive messages from campaign workers and voters; and cried upon reading a particular message from a director;

· She tried to be philosophical about the disaster, and read Plato.

Testimony continued:

· A CBC journalist’s tweet drew the Article to the attention of Caylan’s employer, Foreign Affairs;

· The National Council of Canadian Muslims said they were happy that she had resigned; that white supremacy had no place in Alberta politics;

· Her friends were feeling peer pressure to denounce her;

· She was repeatedly denounced as a white supremacist and the Party denounced as a white supremacist party;

· She was called many names, some of which were “a hateful woman”, “fucking excrement”, an “asshole”, “bad white trash”, “white scum”, “human piled garbage”, a nazi, a white supremacist and a white nationalist;

· She was accused of racism and intolerance;

· It was said of her that she would have been happy 200 years ago when white men killed 2 million indigenous;

· Only a week ago someone sent her an email saying she was running a Hitler training school;

· The CBC contacted her by email and threatened her with more leaks they were going to publish; they then posed a series of loaded questions;

· The Party had “cut her loose” and no longer provided support; she understood the political reason was that she had become toxic.

Regarding the CBC, Caylan said that:

· She had expected better based on her understanding of journalistic ethics;

· They had been sitting for months on defamatory materials provided by Jivraj;

· They never inquired of her as to the truth of the allegations against her;

· They published to the effect that Caylan had homophobic beliefs and had denigrated pride parades;

· They asked emotionally-loaded, bizarre questions of Caylan;

Court Adjourned.

Comment

· Caylan was completely cancelled by false articles and couldn’t do anything about it; her situation was hopeless;

· the tape of the conversation between Caylan and Ms Ward demonstrated that the CBC was advised of the nefarious conduct of Jivraj and Press Progress; but only seven hours after receiving that advice CBC published and broadcast the defamatory material which originated with Jivraj and was first published by Press Progress;

· the standards of the CBC, the Broadbent Institute, and Toronto Star were appalling; has anything changed?

· CBC and Toronto Star maintain that they gave Jivraj anonymity because he was a “confidential source”;

· they did not disclose his identity because of his sordid reputation;

· what can be concluded about the ethics and editors of CBC and Toronto Star?

Jared Pearman 3/15/26 Jared Pearman 3/15/26

Day 4

Caylan again took the stand and testified to the effect that:

· Licia Corbella, a Calgary Herald journalist, interviewed Caylan at length, and on Oct 13, she published a flattering profile of Caylan in the Herald;

· Mountainview riding maintained a highly-confidential email address list of UCP members who lived in the riding;

· As president of the constituency association, Jivraz could access this list;

· On November 25, an email was sent to about 1400 of those party members in the riding;

NB: I now have the tape of the conversation between Caylan and Jivraj reported in my Day 3 summary. It is the conversation in which she disclosed to him that she knew about his treachery concerning the Phil incident and he denied and obfuscated. It is a 25-minute-long tape but clearly identifies the character of each of them. If interested, start at the 4 minute mark. [click HERE to listen] Tab 110.

DAY 4

Caylan again took the stand and testified to the effect that:

· Licia Corbella, a Calgary Herald journalist, interviewed Caylan at length, and on Oct 13, she published a flattering profile of Caylan in the Herald;

· Mountainview riding maintained a highly-confidential email address list of UCP members who lived in the riding;

· As president of the constituency association, Jivraz could access this list;

· On November 25, an email was sent to about 1400 of those party members in the riding;

· the email was entitled Caylan Ford: Too Good to Live Here; Tab 57, [click HERE to view]

· the email contained a letter purportedly signed by ”Mountain Vew Grassroots Conservatives”;

· The letter, written by Jivraj, contained many false and derogatory accusations about Caylan;

· The letter alleged that Caylan was deceptive and evasive, a liar, arrogant, that she refused to be honest and transparent, was disdainful of Mountainview residents, that she had never had a job in Calgary, she was not trustworthy, and that she thought of Mountainview as a pit stop on the way to Ottawa;

Caylan introduced her letter called “A Response To Your Concerns” clearly identifying the falsehoods in the “Too Good” letter. [It is a good read] [click HERE to view] Tab: A Response To Your Concerns

She then continued:

· Caylan asked Janice Herrington, Executive Director of the UCP to conduct a formal investigation into the “Too Good” letter and to terminate Jivraj;

· after investigating, the Party issued an official public statement totally exonerating Caylan of the accusations made in that letter;

· Members of the constituency board became unhappy with Jivraj;

· the UCP Party gave Jivraj the option of resigning or being forced out as president; he resigned.

· Caylan spoke highly of two of her opponents in the nomination contest, Jeremy Wong and Becca Polak;

· Hlady [identified in Glossary] was for a short while a candidate in the nomination contest; the Party subsequently disqualified him;

· Hlady was a Jivraj ally and published false material concerning Caylan;

· Caylan’s campaign was progressing well; her volunteers had put in thousands of hours of work; the campaign was confident of success, especially after Jivraj was removed from the board;

· There was a massive turnout for the nomination vote which Caylan won with 501 votes; the closest opponent, Wong, received 371;

· although she had been successful in the nomination contest, Caylan had foreboding about Jivraj because she knew he would not stop trying to destroy her;

· Press Progress was trying to assassinate Caylan; their articles became increasingly defamatory as time progressed; versions of or extracts from them were published across Canada on the air, in the press, and became ubiquitous on social media;

· Caylan wrote Press Progress 6 different times informing them that their allegations about her were false and explaining why; for an example, Tab 58 [click HERE to view].

· Press Progress did not change their articles after being informed they were false; they never interviewed Caylan or asked for a statement from her;

· In Jauary or February 2019, Jivraj gave Press Progress the quotes which were later to appear in the damaging Press Progress Article of March 18;

· Jivraj and Press Progress collaborated to withhold publication until it would “do the most damage”; that date turned out to be March 18;

· In January, 2019, screen shot images of content from the Messages exchanged between Caylan and Jivraj in 2017 began appearing on social media; Caylan knew that Jivraj was responsible and became worried he would do worse;

· Caylan filed a police report against Jivraj after someone unknown entered her house;

· Thomas Lukaszik, former deputy premier of Alberta turned anti-Conservative activist, posted a Jivraj screen shot making adverse inferences about Caylan;

· Jivraj filed a police report about Caylan accusing her of assault after she had touched him on the shoulder at a café; Caylan heard nothing from the police and assumed that they considered it a vexatious report;

· Jivraj claimed that she had been investigated by the police

· Starting in January or February 2018, both CBC and Toronto Star received material from “Whistleblower” containing 6 pages of deranged, conspiratorial allegations against Caylan, including an allegation of corruption;

· Toronto Star later received a subsequent document from Whistleblower, it was 8 pages long, suggesting inflammatory headlines for Toronto Star articles about Caylan;

· Whistleblower was Jivraj;

· CBC and Toronto Star both “sat upon” the Whistleblower allegations from January or February until March 18;

· Neither of them contacted Caylan or inquired about those allegations until March 19;

· Caylan’s campaign was going well; phone surveys showed she had more support than any other candidate; they were prepared and organized, had an experienced campaign manager, and had over 100 volunteers, Caylan was growing confident of electoral success;

· March 18 was the critical day; the writ was to be dropped the next day;

· Caylan’s campaign had a “launch party” at party HQ attended by about 12 volunteers; she had received shipment of 1000s of lawn signs; they were making a distribution plan and the door-knocking campaign; it was busy;

· At about 4:00 PM Caylan first saw an email from the Press Progress reporter Lebrun [identified in Glossary] containing quotes of statements allegedly written by Caylan, stating that Press Progress intended to publish an article about Caylan containing those quotes, then asking questions of Caylan and demanding a response by 6:00 PM;

[The email is a critical document, Tab TB1000144, [click HERE to view] Go to the bottom of the exhibit and then scroll up for sequence.]

· Caylan couldn’t tell whether the quotes were authentic because she had deleted her copies of the Messages;

· Caylan knew that Press Progress had already published 3 false and defamatory articles about her and had never corrected any of them when given the true facts;

· The questions asked in the email were loaded with embedded assumptions about her beliefs and those embedded assumptions were false;

· The unfair questions could never be answered in 2 hours;

· she knew that Press Progress would not give any meaningful opportunity to respond, that their objective was to elect her NDP opponent;

· she knew that Jivraj was the source of the quotes;

· she knew that Press Progress wanted to keep Jivraj anonymous because of his sordid reputation; they were trying to mask him with credibility;

· Caylan did not respond to Press Progress.

Court adjourned.

Testimony about the Press Progress publication was to the effect that:

· it was published at 6:45 PM;

· it was immediately picked up every Canadian news organization, and started circulating broadly on the internet;

· none of the news organizations contacted her before publishing;

· the NDP immediately published a press release entitled “UCP Candidate Complained ‘White Supremacist Terrorists’ Are Treated Unfairly’, Leaked Messages Show”;

· pressure on the Party intensified; around 11:00 PM on March 18th, the Party asked her to resign as a candidate within 10 minutes;

· she resigned;

· Her resignation letter explained her situation Tab 61 [click HERE to view];

· Lebrun was the editor of Press Progress and author of the article;

· he knew that Jivraj had been making up lies about Caylan for a year;

Comment

After Caylan had decisively won the nomination contest to become the UCP candidate her prospects for election looked excellent despite the ongoing attempts by Jivraj and Press Progress to sabotage her.

March 18th changed everything; her political career was shattered on that day.

Press Progress knew how dishonest and treacherous Jivraj was because of their history publishing his false materials;

CBC should have known how dishonest and treacherous Jivraj was, both from Caylan’s resignation letter and, particularly, from the taped conversation;

Jivraj and Press Progress, with the help of the CBC, had succeeded in destroying her political career.

The worst was yet to come.