Canada Korea Foundation Court File

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J 013c]> D e cr e. m b e r u J - ^1 a6 r, 2k0#113
No. S123023
Vancouver Registry
IN THE SUPREME COURT OF BRITISH COLUMBIA
BETWEEN
JOHN PARK
PLAINTIFF
AND
CANADA KOREA FOUNDATION, DOO HO SHIN and CHARLES KIM
DEFENDANTS
AFFIDAVIT
1. John Park, businessman, of 2184 - 1055 Dunsmuir Street, Vancouver, British

Columbia, MAKE OATH AND SWEAR THAT:
1 I am a founding director of the Canada Korea Foundation (the
"Foundation") and as such I have personal knowledge of the facts and matters
hereinafter deposed to.
2. I have reviewed the affidavit of Charles Kim in this matter, sworn

November 29, 2013. I have also reviewed the affidavit of Doo Ho Shin in this matter,
sworn December 3, 2013. As set out in further detail below, my recollection of key
events differs sharply from that of Mr. Kim and Dr. Shin.
3. Given the substantial overlap in time between the various issues in this
litigation, I have organized my affidavit thematically rather than chronologically.
532409-1
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The Foundation
4. In or around September 2009,1 attended a round table meeting with

members of the Korean-Canadian community and supporters of that community,
including Dr. Shin, Senator Yonah Martin and then Minister of Foreign Affairs Lawrence
Cannon. Minister Cannon encouraged the community to take a more active role in the
development of strong bilateral ties between Korea and Canada. I asked whether we
could count on the support of the federal government if the community were to create a
national organization for that purpose. Minister Cannon pledged his support, as did
Senator Martin. Minister Cannon specifically requested that I write to him with a
proposal for the organization. Dr. Shin requested that I provide him with an advance
copy of the proposal prior to submitting it to Minister Cannon.
5. Following this meeting, in or around December 2009,1 drafted a proposal

for the incorporation of the Foundation with the object of advancing trade and relations
between Canada and Korea, as had been discussed previously with Minister Cannon. I
provided my proposal to Senator Martin, Minister Cannon and two other prominent
members of the Korean-Canadian community who had been recommended to me by
Senator Martin: Dr. Shin and Charles Kim.
6. In early 2010, Dr. Shin and Mr. Kim advised me that they supported the
proposed Foundation and wished to become involved. In or around May 2010,1
instructed counsel to prepare materials for the incorporation of the Foundation with
myself, Dr. Shin and Mr. Kim as the founding Directors. The Foundation was
incorporated on September 21, 2010.
Government support and initiatives
7. From incorporation to the onset of events that gave rise to this litigation in
mid-2011, the Foundation enjoyed significant support from the Government of Canada.
Until late 2013, the Foundation had two honourary patrons, Senator Yonah Martin and
Member of Parliament Barry Devolin. Senator Martin and Mr. Devolin are the co-Chairs
of the Canada-Korea Inter-Parliamentary Association.
8. In pursuit of its objectives, the Foundation opened discussions in 2010

with the federal government on issues relating to various aspects of Canada-Korea
relations. I developed and pursued this initiative. On August 12, 2010,1 wrote to the
House of Commons' Standing Committee on Finance to engage with the annual pre-
budget consultative process and provide the Foundation's position on key aspects of
the upcoming budget.
9. Following the aforementioned letter, I was contacted by a representative

of the Honourable Peter Van Loan, then Minister of International Trade. In late 2010,1
met with Minister Van Loan along with Senator Martin and Dr. Shin to discuss
cooperation between Canada and Korea on energy issues and the potential for a
Memorandum of Understanding on energy matters between the two countries.
10. On August 5, 2011,1 wrote to Prime Minister Harper on behalf of the

Foundation regarding the promotion of bilateral relations and the creation of a
Memorandum of Understanding between Canada and Korea on energy issues. It was
my idea to write to Prime Minister Harper and the Foundation's support for a
Memorandum of Understanding between Canada and Korea was my initiative.
Attached to this my Affidavit and marked as Exhibit 1 is a true copy of a letter I wrote to
Prime Minister Stephen Harper dated August 5, 2011.
11. My letter to Prime Minister Harper was copied to, among others, the Hon.
Ed Fast, Minister for International Trade and the Asia-Pacific Gateway. On August 28,
2011,1 spoke with Minister Fast at a social gathering and discussed the issues raised in
my August 5, 2011 letter to Prime Minister Harper. On September 24, 2011, I wrote on
behalf of the Foundation to Minister Fast's Executive Assistant to request a meeting
with Minister Fast. Attached to this my Affidavit and marked as Exhibit 2 is a true copy
of an email I wrote to Christine Wylupski dated September 24, 2011.
12. On October 4, 2011,1 received an email from Ms. Wylupski scheduling a

meeting with Minister Fast on October 28, 2011. Attached to this my Affidavit and
marked as Exhibit 3 is a true copy of an email I received from Christine Wylupski dated
October 4, 2011.
13. On October 4, 2011,1 received an email from Tim Norris, the Director of
Policy at the Ministry of Natural Resources. Mr. Norris advised me that the Prime
Minister's Office had asked him to contact me regarding the potential for a possible
Memorandum of Understanding between Canada and Korea. Attached to this my
Affidavit and marked as Exhibit 4 is a true copy of an email I received from Tim Norris
dated October 4, 2011.
14. On October 5, 2011,1 spoke to Mr. Norris at length by telephone
regarding the Foundation's proposal to assist in the development of a Memorandum of

Understanding between Canada and Korea.
15. In September 2011, the Foundation agreed to sponsor three delegates of

the Canada-Korea Inter-Parliamentary Association on a trade mission to Korea. The
mission was a reciprocal visit, at the invitation of South Korean dignitaries who had
visited Canada earlier in the year. Sponsorship of the mission would involve paying
expenses and associated matters. The Foundation also contemplated sponsoring an

event hosted by the Canadian Ambassador at the Canadian Embassy in Seoul. The
financial commitment from the Foundation for sponsorship of this mission was
approximately $8,000. Attached to this my Affidavit and marked as Exhibit 5 is a true

copy of an email from Dr. Shin to Senator Martin dated September 1, 2011.
16. On October 28, 2011,1 met with Minister Ed Fast as planned. At that
meeting, Minister Fast advised me that he had sent a letter to my attention to the
Foundation's office in late September. The Foundation's office is located at Mr. Kim's
5-
offices. I did not receive Minister Fast's letter until I was provided with a copy by
Minister Fast's staff following our October 28, 2011 meeting. Attached to this my
Affidavit and marked as Exhibit 6 is a true copy of a letter I received from Minister Fast
dated September 28, 2011.
17. In addition to lobbying the federal government regarding Canada-Korea

bilateral relations and sponsoring the Korea trip, the Foundation also approved funding
of three internships for members of the Korean-Canadian community to work with
government ministries in Ottawa. The total cost of each internship was $8,000, with
$4,000 to come from the Foundation and $4,000 to come from the ministry at which
each intern is placed. Two internships commenced in 2011, and a third internship was
scheduled to commence in 2012. To my knowledge, the third internship was never
funded by the Foundation.
Agreement by founding directors and members to contribute to the Foundation
18. During the early development of the Foundation, it was understood that
myself, Dr. Shin and Mr. Kim, as the founding directors and members, would each
make matching financial contributions of a certain dollar figure to provide seed money
to assist the Foundation in pursuing its mandate. In one of our first meetings with
Senator Martin after the proposal for the Foundation was drafted, Dr. Shin and I had
represented to Senator Martin that the three founding directors would contribute
$100,000 each. This did not receive the support of Charles Kim. Later, the founding
directors discussed a contribution of $75,000 each, but this was not agreed upon.
19. In early 2011, prior to the launch event with Prime Minister Harper,
discussed below, I reached an agreement with Dr. Shin and Mr. Kim that we would
each contribute $50,000 to the Foundation. The agreement was reached at an in-
person meeting. I cannot recall the exact date of the meeting, but I have a clear
recollection that it was shortly before the February 2011 launch event. The upcoming
launch event was the catalyst for our agreement.
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20. At this time, the founding directors were receiving the assistance of
Tenzin Khangsar, who was a private consultant advising the founding directors on the
most efficient way to set up, structure and launch the Foundation. The founding
directors had discussed Mr. Khangsar as a potential candidate to be the first Executive
Director for the Foundation. Attached to this my Affidavit and marked as Exhibit 7 is a
true copy of an email from Mr. Khangsar to myself, Dr. Shin and Mr. Kim dated January
25,2011.
21. Attached to this my Affidavit and marked as Exhibit 8 is a true copy of an

email from Mr. Khangsar to myself, Dr. Shin and Mr. Kim dated February 1, 2011.
22. Although I do not have an independent recollection of the meeting at

which Dr. Shin, Mr. Kim and I agreed that we would each contribute $50,000 to the
Foundation, based on my review of Mr. Khangsar's emails I believe that meeting took
place between January 25, 2011 and February 1, 2011.
23. In the meeting at which each founding director agreed to contribute

$50,000 to the Foundation, we also discussed the timing of our contributions. Dr. Shin
advised Mr. Kim and I that he wanted to seek out tax advice prior to make his
contribution. We agreed that we would all make our contributions after Dr. Shin
obtained his tax advice.
24. Although I do not recall it being explicitly stated, to me it was understood

that each founding director's contribution was to be conditional on the Foundation's
continued vigorous pursuit of its mandate. I knew that Dr. Shin and Mr. Kim had the
power, as two of the three members of the Foundation, to take the Foundation in an
entirely different direction from that which had been pursued by the Foundation to date.
My understanding was that if this were to take place, Dr. Shin and Mr. Kim would take
the necessary steps to return my contribution back to me and I would sever my
association with the Foundation.
25. Part of the action plan in pursuit of the Foundation's mandate at this time
was soliciting donations from prominent members of the Korean-Canadian community
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and offering spots on the Foundation's board to those who made a significant
contribution to the Foundation. At the meeting where each founding director committed
to contributing $50,000 to the Foundation, I recall discussing this approach with the
other founding directors and obtaining their agreement that the Foundation would
proceed in this manner. In particular, the Foundation had identified specific individuals
who were leaders in the Korean-Canadian community and who we believed had the
resources and willingness to make a substantial contribution to the Foundation. The
individuals identified included Jay Shin, Jason Hong, Lindsay Hall, Soon Kim, Ron Suh,
Michael Hwang, John Kim, Dr. Peter Chung, and Raymond Chun.
26. I disagree with the statements at paragraphs 4(a) and 30 of Mr. Kim's
affidavit wherein he states that there was never an agreement on any specific amount
for the founding directors' contribution to the Foundation.
Fundraising efforts and founding sponsors
27. In February 2011, the Foundation organized a fundraising dinner and

launch event, at which Prime Minister Stephen Harper was the keynote speaker. The
fundraiser was attended by approximately one dozen Cabinet Members, Members of
Parliament and Senators. At the launch event, nine founding sponsors donated
$10,000 each to the Foundation. The nine founding sponsors were all from the group
of individuals who the Foundation had identified as potential contributors, as discussed
in paragraph 25 above.
28. At the launch event, the Prime Minister's staff organized the procession
into the room as well as the seating arrangements at the head table. Mr. Kim took
offence to the order of the processional that had been organized by the Prime Minister's
staff, and walked out of the room shortly before the processional was to take place. I
followed Mr. Kim and convinced him to return to the dinner.
29. I am aware that Mr. Kim had paid the cost of the launch event. Prior to
the launch event, there had been no discussion of who would pay for the cost of the
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event, and I understood that whoever paid would later seek reimbursement from the
Foundation.
The Kamei dinner
30. In March 2011, the Foundation hosted a dinner at Kamei Sushi for its
founding sponsors who had donated $10,000 at the launch event. Five founding
sponsors attended this dinner, along with myself, Dr. Shin and Mr. Kim.
31. At the dinner, the founding directors planned to make an offer of

membership in the Foundation and positions on the Foundation's Board of Directors to
the founding sponsors in exchange for a corresponding donation of $50,000 to the
Foundation. This $50,000 figure was chosen by the founding directors so that the
contribution of new directors would match the contribution each founding director had
committed to making.
32. I disagree with the statements at paragraph 37 of Dr. Shin's affidavit and
paragraphs 4(b) and 52 of Mr. Kim's affidavit in which both state that they did not agree
to offer founding sponsors membership in the Foundation and a position on the board
in exchange for a contribution of $50,000. I recall discussing this matter with Dr. Shin
and Mr. Kim in early March 2011 and both agreed with the proposal. Further, this offer
was in accordance with the general approach of the Foundation to soliciting
contributions, which had been agreed upon by the founding directors in late January or
early February 2011.
33. Immediately prior to the Kamei dinner, Mr. Kim unilaterally attempted to
change the aforementioned agreement between the founding directors by proposing

that each founding director contribute $35,000 instead of $50,000. I did not agree to
this change.
34. However, in light of the fact that we were imminently going to request a
$50,000 commitment from the founding sponsors, I attempted to find a way to respond
to Mr. Kim's concerns while both abiding by the terms of the original agreement and
maintaining the $50,000 "ask" of the founding sponsors. To this end, I proposed that
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each founding director contribute $35,000 in cash, and that the many hours of work we
had each put into the Foundation be valued as an additional $15,000 of in-kind
services.
35. Attached to this my Affidavit and marked as Exhibit 9 is a true copy of an

email I wrote to Dr. Shin and Mr. Kim dated March 15, 2011 which sets out my
proposal.
36. I did not receive a response from Dr. Shin or Mr. Kim to my March 15,
2011 email, nor did I discuss my email with them.
37. The Kamei dinner took place on March 18, 2011. At this dinner, all three
of the founding directors addressed the founding sponsors in turn. Dr. Shin spoke first
and thanked the founding sponsors for their attendance. Mr. Kim spoke next and
discussed the mandate and direction of the Foundation. I spoke last and made the
offer that I had previously discussed with Mr. Kim and Dr. Shin, namely that the
founding sponsors would be offered membership in the Foundation and a seat on its
board in exchange for a contribution of $50,000.
38. In paragraph 61 of his affidavit, Mr. Kim deposes that he paid for the
Kamei dinner as well as a "thank you" dinner for our volunteers on March 19, 2011.
This is false. In fact, I paid for both of those dinners. Attached to this my Affidavit and
marked as Exhibit 10 is a redacted copy of my credit card statement dated March 24,
2011 which includes charges for both the Kamei dinner and the volunteer dinner.
39. On the night of the Kamei dinner, three founding sponsors (Lindsay Hall,
Jason Hong and Soon Kim) verbally expressed interest in becoming directors and
members of the Foundation and making the requested donation. A fourth founding
sponsor (Jay Shin) expressed interest in providing $50,000 of in-kind services in
exchange for membership in the Foundation and a position on the Board.
40. Following the Kamei dinner, on March 23, 2011, I sent a further email to
Dr. Shin and Mr. Kim in which I again referenced the possibility of a $35,000
contribution in place of the agreed-upon $50,000 contribution. Attached to this my
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Affidavit and marked as Exhibit 11 is a true copy of an email I wrote to Dr. Shin and Mr.
Kim dated March 23, 2011.
41. I did not receive a response from Dr. Shin or Mr. Kim to my March 23,
2011 email, nor did I discuss my email with them. Given the silence of Dr. Shin and Mr.
Kim, I formed the conclusion that they rejected my proposal to rework the terms of the
agreement, and that we all remained obligated to contribute $50,000 in cash to the
Foundation as per the original terms of the agreement.
42. Having received the verbal expressions of interest from the founding
sponsors at the Kamei Dinner, I sought to follow through with the Foundation's offer
and have them appointed as Board members in exchange for their donations. Mr. Kim
refused to appoint the founding sponsors as directors at that time, insisting that he be
given an opportunity to review the Foundation's constating documents first. In
deference to Mr. Kim, I agreed to defer the issue of appointing the founding sponsors to
the Board to a later date
.My contribution
43. In July 2011,1 contributed $50,000 to the Foundation in accordance with

my commitment. I made this contribution in support of the Foundation's continued
pursuit of its mandate, which I understood would be furthered by the identical
contributions of Mr. Kim and Dr. Shin, as well as the imminent addition of Mr. Hall, Mr.
Kim, and Mr. Hong (and potentially Jay Shin) to the Board of Directors in exchange for
their proffered financial contributions.
44. Had I known that Mr. Kim and Dr. Shin would not also make their
contributions within a reasonable time, I would not have made my contribution.
45. Had I suspected that the members of the Foundation would not accept the
addition of these founding sponsors to the Board despite the promises made at the
Kamei dinner, I would not have made my contribution.
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46. Had I known that the Foundation would essentially cease pursuing its
mandate throughout late 2011, all of 2012 and most of 2013, I would not have made my
I
contribution.
47. On July 12, 2011, the Foundation's Administrative Assistant, Peter Chung,
emailed Dr. Shin and Mr. Kim to inquire as to the status of their respective
contributions. Attached to this my Affidavit and marked as Exhibit 12 is a true copy of
an email from Peter Chung to me dated September 27, 2011.
48. Attached to this my Affidavit and marked as Exhibit 13 is a true copy of

an email from Peter Chung to me dated September 27, 2011.
49. I am not aware of any response made by either Dr. Shin or Mr. Kim to the
aforementioned messages from Peter Chung.
Canada Korea Business Association
50. Mr. Kim is also a director of the Canada Korea Business Association
("CKBA"). The CKBA is registered under the British Columbia Society Act and exists
for the purpose of encouraging understanding and friendship between the business
communities of Canada and Korea and promoting trade, capital investment and
technical cooperation between the two countries, with a particular focus on trade and
investment in British Columbia. It is my understanding that the mandate of the CKBA is
similar, although not identical, to that of the CKF.
51. On September 1, 2011, Senator Martin requested that Mr. Kim clarify the
distinction between his role with the Foundation and his role with the CKBA. In her
email, Senator Martin noted that "CKBA cannot effectively advance the Canada Korea
relationship in the way CKF intends", and "[t]he KEY difference is the relationship of
CKF to the Government of the day, as evidenced by the PM's attendance at the launch;
and the partnership of the Canada Korea Inter-Parliamentary Group and its counterpart
in Korea".
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52. Senator Martin requested that Mr. Kim provide a clear articulation and
confirmation of his commitment to and prioritization of the Foundation. To my
knowledge, Mr. Kim did not respond to Senator Martin's request.

an email from Senator Martin to myself, Mr. Kim and Dr. Shin dated September 1,
2011.
54. Attached to this my Affidavit and marked as Exhibit 15 is a true copy of a
printout of a page from the CKBA website, retrieved December 12, 2013, listing the
directors and officers of the CKBA.
Discussions regarding Stockwell Day
55. In or around June 2011,1 met with Dr. Shin and Mr. Kim to discuss the
potential expansion of the Board. I suggested Stockwell Day as a candidate for a

directorship, as I believed that Mr. Day's unique combination of skills and experience
would assist the Foundation in furthering its objectives. Dr. Shin was supportive of the
appointment of Mr. Day to the Board, and suggested that the subject be considered at a
subsequent meeting of the Board. Mr. Kim suggested that Mr. Day's appointment be
counterbalanced by the appointment of another director with a different political
affiliation, but did not oppose the appointment of Mr. Day.
56. On or around July 12, 2011,1 met with Dr. Shin and Senator Martin to
further discuss the appointment of Mr. Day. Mr. Kim was unable to attend this meeting.
Senator Martin advised Dr. Shin and me that she supported Mr. Day's appointment as a
director of the Foundation. Senator Martin then left the meeting.
57. Following Senator Martin's departure, I discussed Mr. Day's appointment

with Dr. Shin. Dr. Shin recommended that I draft a resolution appointing Mr. Day to the
Board, and that I table that resolution at the next Board meeting. Dr. Shin advised me
that he would support the appointment of Mr. Day to the Board. I agreed that I would
draft a resolution and present the resolution for consideration at the next Board
meeting.
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58. On August 25, 2011,1 received an email from Dr. Shin, copied to Mr. Kim,
in which Dr. Shin summarized the issues discussed in a meeting that had taken place
between him and Mr. Kim the previous day. In his email, Dr. Shin wrote that he and Mr.
Kim had discussed the fact that "Mr. Stockwell and "others" will join the CKF", and that
"[w]e will discuss it a bit more". Dr. Shin suggested that the Board meet as soon as
possible. Attached to this my Affidavit and marked as Exhibit 16 is a true copy of an
email I received from Dr. Shin dated August 25, 2011.

document evidencing Mr. Day's consent to act as a director of the Foundation, dated
August 30, 2011.
September 1 meeting
60. On September 1, 2011,1 attended a special general meeting of the

Foundation's members (the "September 1 Meeting"). Dr. Shin and Mr. Kim were also in
attendance at the September 1 Meeting.
61. At the September 1 Meeting, I tabled the resolution that I had prepared
appointing Stockwell Day as a director of the Foundation. Discussion ensued regarding
the appointment of Mr. Day as a director. Mr. Kim raised Lindsay Hall as a further
nominee to the Board. I advised Mr. Kim that while I had no objection to Mr. Hall's
appointment to the Board, his appointment was not before the Board and should be
addressed at the same time as the other founding sponsors who had committed to
donate $50,000 to the Foundation in exchange for membership in the Foundation and a
position on the Board.
62. At this point, Mr. Kim left the meeting. Following Mr. Kim's departure, Dr.
Shin and I both voted for Mr. Day's appointment as a director and signed the resolution.
Attached to this my Affidavit and marked as Exhibit 18 is a true copy of the resolution
that was passed at the September 1 Meeting.
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63. After the resolution was passed, Dr. Shin advised me that he wished to
discuss the matter of Mr. Day's appointment with Mr. Kim in order to convince Mr. Kim
that Mr. Day's appointment was a positive step for the Foundation. Dr. Shin asked that
I leave the issue alone for two weeks in order to allow him time to speak with Mr. Kim.
Out of respect for Dr. Shin and a desire to prevent a fracture in the Board, I agreed to
leave the issue of Mr. Day's appointment aside for two weeks.
64. I have reviewed paragraphs 63 to 77 of Dr. Shin's affidavit, and I strongly
disagree with his recollection of the September 1 meeting. My recollection of that

meeting, and my discussions with Dr. Shin during the meeting, is as set out above.
September 9, 2012 meeting
65. Following the September 1 Meeting, I received an email from Dr. Shin in
which Dr. Shin requested a copy of the CKF's constating documents and the "generic
form" for new members of the Board of Directors. Attached to this my Affidavit and
marked as Exhibit 19 is a true copy of an email I received from Dr. Shin dated
September 2, 2011.
66. I responded to Dr. Shin's email and advised that he could obtain the
requested materials from the Foundation's corporate counsel.
67. On or around September 4, 2011,1 received an email from Dr. Shin in

which he advised that a meeting of the Board would take place on September 9, 2011.
At this time, I was travelling, and was unable to attend the scheduled meeting. On
September 8, 2011, I wrote to Dr. Shin and requested that the meeting be postponed. I
did not receive a response to my September 8, 2011 email.
68. On September 9, 2011,1 received an email from Dr. Shin in which he

wrote that a meeting had taken place between him and Mr. Kim that day (the
"September 9 Meeting") and "[a] few Resolutions" had been discussed and passed. Dr.
Shin did not explain what resolutions had been passed, but advised that he would send
me the minutes of the meeting.
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an email I received from Dr. Shin dated September 9, 2011.
70. I received the minutes from the September 9 Meeting on September 13,
2011. The minutes of the September 9 Meeting indicated that Dr. Shin and Mr. Kim
purported to pass the following resolutions:
1. It is resolved that the chair's conduct to date will be reviewed and chair's
suitability for the future will be determined during the next board meeting to be
held on September 14, 2011 at the CKF office at 500 - 530 Hornby Street,
Vancouver B.C.
2. Bank singing [sic] authority
It is resolved that 2 out of 3 directors signatures are required.
3. It is resolved that the appointment of lawyers/accountant/auditors will be

reviewed and determined at the next meeting.
4. Approval of new directors
It is resolved the approval of new directors requires 3 out of 3 directors approval,

until the board members are increased.

an email I received from Dr. Shin dated September 13, 2011, with enclosures.
72. Prior to receiving the minutes of the September 9 Meeting, I was unaware
that either Dr. Shin or Mr. Kim had any concerns about my conduct as Chair of the
Foundation.
September 15, 2012 meeting
73. Having received the minutes from the September 9 Meeting on
September 13,1 had just one day of notice that Dr. Shin and Mr. Kim proposed a further
meeting on September 14, 2011. On September 13, 2011, I wrote to Dr. Shin and
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requested that the proposed meeting take place on September 15, 2011. Dr. Shin
agreed to postpone the meeting. I did meet with Dr. Shin and Mr. Kim on September
15, 2011 (the "September 15 Meeting").
74. Immediately prior to the September 15 Meeting I became concerned

about Mr. Kim and Dr. Shin's motives for the Foundation and its funds, given their
desire to change signing authority on the bank account. I therefore transferred the
funds in the Foundation's bank account to a separate Foundation account over which I
had signing authority. My primary objective in doing so was to ensure that the seed
money I had contributed remained with the Foundation, so that the Foundation could
continue to pursue its mandate.
75. The funds remained in this account and were secure until, during the
course of this litigation, I entered into an agreement with the Foundation pursuant to
which a hold was placed over $58,000 (the amount of my claim) and the remainder of
the funds were released to the Foundation.
76. At the September 15 Meeting, I recall stating on at least two occasions

that the meeting had not been duly convened. I expected that Dr. Shin would disclose
to Mr. Kim that he had voted in favour of Mr. Day's appointment, and that Mr. Day was
a validly appointed director of the Foundation and therefore entitled to notice of any
Board meeting. Dr. Shin did not do so. Out of respect for Dr. Shin and as a result of
my prior commitment to allow Dr. Shin to raise the issue with Mr. Kim, I did not push a
confrontation over the issue.
77. At the September 15 Meeting, I demanded to know the nature of the

veiled allegation of impropriety that had been made against me at the September 9
Meeting. Mr. Kim advised me that he understood that I had provided a CKF business
card to one of my employees, with the imputation that I was taking a private benefit
from my role with the CKF.
78. The incident raised by Mr. Kim at the September 9 Meeting arose as a
result of Senator Martin requesting assistance for a trip to Korea in May 2011. I had
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freed up one of my employees, Brian Kim, to accompany Senator Martin on her trip.
Neither I nor my company received any benefit or remuneration for Brian's time. I
advised Mr. Kim and Dr. Shin that Brian would be provided with a Foundation business
card, with Senator Martin's concurrence, for the purposes of the trip. I have since
spoken with Brian, who advised me that he never received any Foundation business
cards. I have never taken any private benefit as a result of my role with the Foundation,
nor has my company benefitted from my role with the Foundation.
79. Mr. Kim did not raise any other incidents of allegedly improper conduct,
nor have Dr. Shin or Mr. Kim raised any other incidents of allegedly improper conduct
on my part either before or after the September 15 Meeting.
80. At the September 15 Meeting, I asked Mr. Kim what he saw as the future
direction of the Foundation and the use of its funds. Mr. Kim suggested that the funds
that had been raised at the Foundation launch event be returned to the founding
sponsors. It became apparent to me through Mr. Kim's comments that he had no

intention of fulfilling the existing commitments of the Foundation, and did not intend to
pursue the Foundation's objectives as set out in its constating documents.
81. Dr. Shin and Mr. Kim, over my objections as to the validity of the meeting,
purported to pass resolutions appointing Dr. Shin as the new interim chair of the
Foundation, appointing Tristin Lee as counsel to the Foundation and appointing Donald
Cowan as the Foundation's auditor. To my knowledge, both Ms. Lee and Mr. Cowan
were directors of the CKBA at that time, and continue to be directors of the CKBA to
this day.

the minutes of the September 15 Meeting.
83. On September 23, 2011,1 received an email from Dr. Shin in which he
purported to call an annual general and special meeting of the Foundation on October
8, 2011. Included in the proposed agenda for that meeting was a discussion of the
"future vision/direction of CKF including membership matters". Attached to this my
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Affidavit and marked as Exhibit 23 is a true copy of an email I received from Dr. Shin
84. On September 23, 2011, Dr. Shin wrote to Senator Martin to advise that
he had replaced me as the Chairman of the Foundation. Attached to this my Affidavit
and marked as Exhibit 24 is a true copy of an email from Dr. Shin to Senator Martin
Korea mission
85. On September 26, 2011, Senator Martin convened a meeting with all
three of the Foundation's directors to discuss the Foundation's sponsorship for the
upcoming Korea mission. Senator Martin expressed her support for the addition of Mr.
Day to the Board. At this time, Dr. Shin revealed to Mr. Kim that he had in fact voted in
favour of Mr. Day's appointment. Upon learning that Mr. Day had been appointed, Mr.
Kim reiterated his previous suggestion that the funds raised at the Foundation's launch
event be returned to the founding sponsors.
86. On September 29, 2011, Dr. Shin wrote to Senator Martin and stated that
the Foundation was withdrawing from its sponsorship of the Korea mission in October
2011. Attached to this my Affidavit and marked as Exhibit 25 is a true copy of a letter
from Dr. Shin to Senator Martin dated September 29, 2011.
Continued commitment of founding sponsors
87. Despite the dispute that developed amongst the Board, it was my
understanding in late 2011 that at least three of the four founding sponsors who had
previously committed to contributing $50,000 (or $50,000 of in-kind services) in
exchange for membership in and directorship of the Foundation remained committed.
These three founding sponsors were Lindsay Hall, Soon Kim and Jason Hong.
Attached to this my Affidavit and marked as Exhibit 26 is a true copy of a letter I
received from Soon Kim dated October 11, 2011.
-19-
88. To my knowledge, the Foundation has never taken any steps to follow up
with Mr. Kim or Mr. Hong regarding their pledge to contribute $50,000 to the Foundation
in exchange for a position on the Board. Mr. Hall is currently a member of the Board,
but to my knowledge has not made any financial contribution to the Foundation.
Funding of internships
89. On November 7, 2011, I received an email from Senator Martin advising

that the Foundation had not yet paid the $8,000 it had committed for the two internships
commencing in 2011. Attached to this my Affidavit and marked as Exhibit 27 is an

email exchange between Senator Martin and I with respect to the internship payments
dated November 7-8, 2011.
90. On November 9, 2011, my counsel J. Kenneth McEwan wrote to Mr. Kim's

counsel requesting his consent for the payment of $8,000 for the aforementioned
internships out of the Foundation's funds. Mr. Kim did not respond to this request.
Attached to this my Affidavit and marked as Exhibit 28 is a true copy of a letter from J.
Kenneth McEwan to D. Geoffrey Cowper dated November 9, 2011.
91. On November 9, 2011, I paid the $8,000 owed by the Foundation to the
two interns out of my own funds.
92. The Foundation refused to repay me the $8,000 I had paid on its behalf,
and I was forced to make a claim for those funds in the present action. That aspect of
my claim was settled in October 2013.
-20-
Proposed expansion of the Board
93. In or around late October 2011, in light of the continued commitment of

the founding sponsors and in an effort to resolve the conflict that developed amongst
the Board, I proposed expanding the Board from four members (myself, Mr. Kim, Dr.
Shin and Mr. Day) to include the three founding sponsors who had committed to
contribute $50,000 to the Foundation.
94. On November 2, 2011, Mr. McEwan received a letter from Mr. Kim's
counsel, D. Geoffrey Cowper, Q.C., in which Mr. Cowper rejected two of the founding
sponsors as "unsuitable" additions to the Board. Mr. Cowper provided no further
explanation as to why the founding sponsors were not suitable. I did not receive any
further explanation as to why those two founding sponsors, Soon Kim and Jason Hong,
were "unsuitable" additions to the Board until I read the transcript from Mr. Kim's
examination for discovery in this action.
95. I note that in his letter, in response to my position that the three members
of the Foundation had each agreed to contribute $50,000 to the Foundation, Mr.
Cowper stated that "[w]e are advised that, in fact, the members initially agreed to
contribute $30,000". This is at odds with paragraph 30 of Mr. Kim's affidavit, where he
deposes as follows:
30. I have never communicated to anyone any confirmation or

agreement to a specific amount of financial contribution to be made by us
to the Foundation, and to my knowledge neither has Dr. Shin.
96. Mr. Cowper attached a Requisition, signed by Mr. Kim, requisitioning a

special general meeting of the Foundation's members to consider the addition of the
following individuals to the Board: Dr. John Kwok, Lindsay Hall, Joseph Yang, Professor
Kyung Ae Park and Stockwell Day.

letter from Mr. Cowper to Mr. McEwan dated November 2, 2011.
-21 -
98. To my knowledge, both Lindsay Hall and Joseph Yang are directors of the
Canada Korea Business Association.
99. I am not familiar with Dr. Kwok or Professor Park. Mr. Cowper's letter did
not provide any background on Mr. Yang, Dr. Kwok or Professor Park, nor did it explain
why any of these individuals would make suitable Board members.
100. I later learned, through receipt of the minutes of the Foundation's board
meetings, that the individuals proposed in Mr. Kim's Requisition had, in fact, been
elected to the Foundation's board.
101. In 2012, Yong Keun Kim was added to the Foundation's board. It is my
understanding that Mr. Kim is also a director of the CKBA.
Requested apology
102. On January 23, 2012,1 wrote to Mr. Kim and Dr. Shin following a meeting
that we had convened in an attempt to resolve our disagreements. Attached to this my
Affidavit and marked as Exhibit 30 is a true copy of an email I wrote to Mr. Kim and Dr.
Shin dated January 23, 2012.
103. On February 4, 2012,1 received a letter from Dr. Shin in which Dr. Shin
requested that I apologize for my actions. I was not and am not aware of anything I had
done which necessitated an apology, and therefore I did not respond to this email.
Attached to this my Affidavit and marked as Exhibit 31 is a true copy of a letter I
received from Dr. Shin dated February 3, 2012.
104. I have learned in the course of this litigation that Dr. Shin made a $35,000
contribution to the Foundation on or about February 11, 2012. I was not aware of that
contribution at the time it was made.
Actions of the Foundation post-2011
105. I continue to be both a director and a member of the Foundation. In light

of my dispute with Mr. Kim and Dr. Shin, I have refrained from attending any members
22-
or directors meetings of the Foundation since September 2011. I do not want my

dispute with the other founding directors to distract from the conduct of the
Foundation's business. Nevertheless, I continue to receive copies of the minutes of
each meeting, and I review these minutes upon receipt.
106. It is my understanding, based on a review of the minutes that I have

received and the documents I have reviewed in connection with this action, that the
Foundation has only participated in one event since late 2011. That event was a
reception and panel discussion with Ambassador Sung-Joon Yim as discussed at

paragraph 111 of Dr. Shin's affidavit. Throughout late 2011 and 2012, it is my
understanding that the Foundation did not pursue any initiatives. In 2013, the
Foundation developed a handful of initiatives, but to my knowledge none of these have
been seen through to fruition except for the reception for Ambassador Yim, and many
have been put on hold or cancelled.
Resignation of honourary patrons
107. On November 17, 2013, Senator Martin and Barry Devolin resigned from
their roles as honourary patrons of the Foundation. Attached to this my Affidavit and
marked as Exhibit 32 is a true copy of an email I received from Senator Martin dated
November 17, 2013. /?
SWORN BEFORE ME at Vancouver,

British Columbia, on December 16, 2013
AcomrrjM
affidavits f<
er for taking
British Columbia

j j -
JOHN/FAR f
Greg Alien
Barrister & Solicitor
Hunter Litigation Chambers
2100-1040 West Georgia Street
Vancouver, B.C. V6E4H1
Telephone: 604-647-4562
530 Hornby Street, Vancouver, BC, Canada, V6C 2E7
T: 604.694.2040 F: 604.688.9684 www.canadakoreafoundarion.com
i
August 5; 2011
This is Exhibit "_JL " referred to in the

Right Honourable Stephen Harper, P.C., M.P.
CANADA Affidavit of 3k2 QaA< :
Prime Minister of Canada
KOREA
FOUNDATION 80 Wellington Street Sworn before me at fej^
Ottawa; ON K1A 0A2 This ^Lu^&r 20 Jl
A Commi ner for taking

Affidavits r British Columbia
Honourary Patrons Dear Prime Minister,
Senator Yonah Kim Martin
Barry Devolin, M.P.
Firstly let me congratulate you on your electoral victory. I am glad to see that your
leadership and track record of results was widely recognized by Canadians including
our own Korean-Canadian community. Your stable majority mandate will lend itself
well to both plan and successfully implement global partnerships for Canada that
advance our leading economic status.
-*^ In this spirit; I am writing to you in my capacity as Founding Chair of the Canada Korea
Foundation (CKF). We are uniquely focused to enhance Canada's bilateral relationship
with Korea, including promoting foreign direct investment and advancing a Free Trade
Agreement (FTA).
As we discussed when you attended the launch of CKF in February, Canada can play a
unique role in helping Korea to meet its energy needs. We recommend a focus on an
energy partnership to significantly enhance relations and advance mutual benefits.
We welcome the recent news that the beef issue is finally on a path to be resolved.
This bodes very well for Canada -Korea relations and will ideally move us much closer
to securing a FTA.
Under your leadership it is clear that the Government of Canada is sincerely

committed to improving ties with Korea. Like most Asian nations, meaningful progress
will require that there is a focus on the Canada-Korea relationship at the highest levels
of both governments. It is critical that the South Korean Government views Canada's
commitment in a way that allows the dialogue to be elevated to the highest diplomatic
and political levels. Essentially, the relationship must be "on the radar" and jointly
prioritized. Despite your personal efforts, our channels to leadership of the Korean
government confirm their view that Canada has not consistently displayed a sustained
high level interest in advancing relations.
530 Hornby Street,Vancouver, BC, Canada, V6C 2E7
T: 604.694.2040 F: 604.688.9684 www.canadakoreafoundation.com
CKF recommends a symbolic joint-action to be taken in the first year of your majority
mandate. Canada has employed successful symbolic joint actions with China. Canada
and China signed the Memorondum of Understanding Concerning Cooperation in the
CANADA
Field of Energy in 2001, which was followed up in 2005 with the Canada-China
KOREA
Statement on Energy Cooperation in the 21st Century. While neither of these actions
FOUNDATION
bound either government to specific action, they provided a tangible demonstration of
commitment from both sides to promoting the bilateral relationship. Subsequently,
more confident Chinese capital has entered Canada with greater frequency.
Honourary Patrons Furthermore, you signed a similar strategic MOU with Mongolia last year.
Senator Yonah Kim Martin
Barry Devolin, M.P.
It is the CKF's view that a similar symbolic agreement or statement would send the
powerful signal that is needed to foster a renewed focus within the South Korean
Government on strengthening the bilateral relationship with Canada. In our view,
resource development and renewable energy technology are the ideal focus for our
partnerships. You indicated a keen interest in this area during our discussions in
February. We would welcome further discussions with your senior officials at PMO
and interested Ministers.
I also would like to share the broad strokes of a potential strategy to give Canada and
Korea the 'win-win' that could help close a FTA in the near future. Canada's Arctic
offers enormous natural resource potential. However, exploration costs are enormous
due to labour and logistical difficulties. At present only the world's largest energy
companies can afford to explore the Arctic, and few, if any, Canadian companies have
the necessary financial capacity to join them.
For Korea, it would be an extremely enticing proposition, if Canada were able to

provide a vehicle for Korea to engage in Arctic energy exploration. Understandably,
the exact nature of the arrangement would need to be designed to ensure that
Canada's national interests are maintained. However, this could be accomplished in
numerous ways including: regulatory oversight, public-private partnership with a
Federal Crown Corporation, or other arrangement. CKF believes such initiatives will
be supported by Canada's Oil &Gas community and be a positive catalyst for
stakeholders in deciding to commence with the MacKenzie Delta pipeline
development, now that regulatory approvals have been met.
In return, Canada could seek investment in southern Ontario in the auto sector.
Undoubtedly and despite your majority mandate, new jobs with Hyundai could go a
530 Hornby Street,Vancouver, BC, Canada, V6C 2E7
T: 604.694.2040 F: 604.688.9684 www.canadakoreafoundation.com
- ^
long way to help reduce predictable apprehension from the auto workers, their unions
and likeminded opposition parties towards a FTA.

Ultimately, recognizing Canada's sovereignty in the Arctic, collaborating with our
CANADA
government could give the Korean government the political capital necessary to help
KOREA
relieve some of the other trade irritants such as auto parts that are current obstacles
FOUNDATION
to securing an FTA. Moreover, such an approach could be pursued in concert with
Canada's Northern Strategy as the increased activity would help to assert Canada's
Arctic sovereignty and promote economic development in the far north.
Honourary Patrons
Senator Yonah Kim Martin It is worthy to mention that in recent months, Total and BP have announced
Barry Devolin, MP.
agreements with Russian state companies to explore their Arctic regions.
The CKF has excellent relationships in South Korea including direct access to the Blue
House. With your active support, we welcome the opportunity to work closely with
your political advisors and officals to advance any of the ideas expressed in this letter.
"^ I hope that you find our recommendations helpful. If you or any of your staff would
like any additional information, or wish to discuss any aspect of these proposals, I will
make myself jvailable at your convenience.
Sincerely;
'a/Kjihair
(nada Korea Foundation
(604) 716-3324
John.ParkOcanadakoreafoundation.com
C.C. Hon. Ed Fast, Minister of International Trade

Hon. John Baird, Minister of Foreign Affairs
Hon. Jason Kenney, Minister of Citizenship, Immigration and Multiculturalism
Hon. Joe Oliver, Minister of Natural Resources Canada
Hon. Yonah Martin, Co-Chair of Canada-Korea Parliamentary Association
Hon. Barry Devolin, Co-Chair of Canada-Korea Parliamentary Association
Nigel Wright, PM Chief of Staff
^
^
Minister, of International Trade and ifiKfflm Ministre du Commerce International et

Minister for the Asia-Pacific Gateway ^^^S rninistre de la porte d'entree de PAsie-Pacrfique
Ottawa, Canada K1A 0G2
SEP 2 8 2M\ [his is Exhibit "_&_" referred to in the

A f fi d a v i t o f _ f o ~ P ^
Mr. John Park Va^-puva/
Chair Sworn before me at
Canada Korea Foundation j, [fe^ A&y 0f __û-r^cr 20 ^
530 Hornby Street &//Z---~
Va n c o u v e r B C V 6 C 2 E 7 7 - " - # / ^ T 1 Q 1 , i n 7
A Comm<vioner lor taking
Dear Mr. Park: Affidavimor British Columbia
Thank you for sending to me and to my colleague the Honourable John Baird, Minister
of Foreign Affairs, a copy of your letter of August 5,2011, to Prime Minister Harper
underscoring the value of Canada's relations with Korea, and the potential for
expanded collaboration in the field of energy. The Canada-Korea Foundation plays
a crucial role in supporting Canada's strong and positive relationship with Korea, and
1 am pleased that you have identified energy as apriority. As Minister .of International
Trade, it is my pleasure to Tespond to you on Minister Baird's behalf as well .as my
own on this important issue.
Foreign Affairs and International Trade Canada (DFAIT) shares .your view of energy
engagement as a key area of potential in Canada's relations with Korea, and more
broadly with North Asia. Over the course of the past year, we have devoted significant
resources, and cooperated extensively with our interdepartmental community, with a
view to fostering engagement in this area.
As you know, the

' partnershas Embassy
hosted of Koreaofinthe
three meetings Canadain cooperation
Canada-Korea Energywith provincial
Forum, the most
Tecent of which took place in Toronto this past June. DFAIT was happy to send a senior
official to participate in each of these meetings, and to offer the keynote addresses in
Toronto arid at the previous event in Calgary. These remarks served .a a public"
statement of our level of commitment to developing an enhanced energy partnership
with Korea.
Consistent with this position, we have taken proactive steps to advance this
partnership. Jn June 2011, DFAIT organized a Natural Gas Export Mission to Seoul"
with the objective of advancing Pacific liquefied natural gas export capacity. The
mission included a delegation often high-level representatives from the Government
of Canada, the Government of Alberta and the Government of British Columbia, as
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91
11
Charles Kim
From: Te n z i n D a r g y a l K h a n g s a r [ t e n z i n k h a n g s a r @ g m a i l . c o m l ^
Sent: J a n u a r y - 2 5 - 11 1 2 : 0 3 P M T h i s i s E x h i b i t " J L " r e f e r r e d t o i n t h e
To: 'John Park'; Charles Kim; dshin@telus.net Affidavit of ^cU^ V*A
Cc: 'Tenzin Dargyal Khangsar'
Subject: RE: CKF Action Plan 2011 Sworn before me at \Ja*ca^\/iS-
Attachments: CKF 2011 Action Plan.pdf
This!!Lcia i f ^ 20 Q
Importance: High **>W
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A Commi^ncr for taking
A f fi d a v i t s m r B r i t i s h C o l u m b i a
Gentleman,
I hope all is well. If you will permit me, I would like to go straight to some key points.
1) I have spoken to each of you individually since our last group teleconference in mid-December. After that
teleconference, I was asked to submit a one page action plan which I did. Attached.
2) Both Charles and John have committed $50 K each to get to ACTION for CKC. Dr. Shin was to decide if he would join
as a committed founding director after meeting with Charles and-or John.
3) Charles suggested a partnership with CKBA. I am working with Canadian Chamber of Commerce to get the rights to
the name Canada Korea Council as an option to move away from CKF - especially as we do not plan to give our
charitable tax receipts as most foundations do. As such, it is best to be called Canada Korea Council as we initially
agreed more than a year ago.
Friends, as I am focused on my consultancy practice and my time is literally how I pay my mortgage and family expenses,
I must respectfully request that the founding directors of CKC make a decision about next steps. It is my own view that if
we have at least $100 K to start, we can:
1. Navigate a merger with CKBA

2. Develop partnership with Hanca Foundation
3. Proceed with the action plan
4. Launch of CKC with the PM for late spring-early summer.
I would respectfully request your definitive decisions by Sat January 29th. If you are not able to come to a decision, I trust
that you will understand that I will have to devote my limited time to other more lucrative projects. .
I remain willing and passionate to advance the goals of the CKC. Please feel free to call me to discuss further. My cell is
613-869-4765.
I meet with Senator Martin on Sunday Jan 30,h and will give her my personal update than about my involvement with
CKC.
Best regards,
Tenzin
Prom: Tenzin Dargyal Khangsar [mailto:tenzinkhanqsanfoqmail.com}"

Sent: Tuesday, December 21, 2010 9:41 PM
To: 'John Park*; Charles Kim (kimOtranspacfibre.coml; 'dshin@telus.net'
Subject: CKF Action Plan 2011
Gentlemen, *_****
believe this addresses some key concerns raised on our
As promised, here is the one pager CFK action plan for 2011.
CaH: a) Corporate sponsors - A targeted prospect list is included and the confirmation of the support of the founding
d i r e c t o r s w i l l b e a n i m p o r t a n t p a r t o f t h e m o m e n t u m b u i l d i n g . J K F. 0 Q 1 2 4 7 o c
b)} Results
rmplement - There are four
wril yield clear priorities
the results that we and are itallisanxious
my viewfor,
that this focus
especially - along
after morewith
thandedicate*
a year ofresources
d.scuss.onto
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Charles Kim
13
Y From: tenzinkhangsar@gmail.com
Sent: F e b r u a r y - 0 1 - 11 2:23 PM
To : J o h n P a r k ; C h a r l e s K i m ; d s h i n @ t e l u s . n e t
Subject: Re: CKF Action Plan 2 0 11 s
Gents,
I'm happy to confirm that you've all confirmed your full commitment to finally realize CKC.
As your advisor, I recommend the following next steps:
1. Write cheque to Canada Korea Foundation for $50 K each 2. Work with John's lawyer to make a
by-law to open bank account.
3. Join teleconference to plan for PM Harper event-meeting on Feb 21st. I will send invite for a
call this Thursday. Standby.
4. Tenzin to come to Van and meet CKBA, make recommendations for smooth merger based on existing
CKF action plan.
5. Tenzin to finalize contractual agreement with appointed founding director. (Charles?)
on " ftK - referred
' nis is Exhibit -** to in the
Feedback is welcome. A f fi d a v i t of__5*ajU

?
T ep nw zai rnd ! Si w b e f/ o r e me ^ at .. * V^ c~ ^v ^
Sent from my BlackBerry smartphone This ______ davrof Q&-t*-~\tAr'
Original Message , A .-~%jryam

From:- "Tenzin Dargyal Khangsar" <tenzinkhangsar(agmail.com> ff.mm'Sgjffier for taking
D a t e : T u e , 2 5 J a n 2 0 11 1 5 : 0 3 : 2 6 " " a f fi d a v i t s f o r B r i t i s h C o l u m b i a
To: 'John Park'<ipark(arcicapitalgroup.com>; Charles Kim<kimfStranspacfibre.com>; <dshin(3telus.net>
Cc: 'Tenzin Dargyal Khangsar'<tenzinkhangsar(Sgmail.com>
Subject: RE: CKF Action Plan 2011
Gentleman,
I hope all is well. If you will permit me, I would like to go straight to
some key points.
1) I have spoken to each of you individually since our last group

teleconference in mid-December. After that teleconference, I was asked to
submit a one page action plan which I did. Attached.
2) Both Charles and Dohn have committed $50 K each to get to ACTION for CKC.
Dr. Shin was to decide if he would join as a committed founding director
after meeting with Charles and-or John.
3) Charles suggested a partnership with CKBA. I am working with Canadian

Chamber of Commerceto get the rights to the name Canada Korea Council" as an
option to move away from CKF - especially as we do not plan to give our
charitable tax receipts as most foundations do. As such, it is best to be
called Canada Korea Council as we initially agreed more than a year ago.
Friends, as I am focused on my consultancy practice and my time is literally

how I pay my mortgage and family expenses, I must respectfully request that
the founding directors of CKC make a decision about next steps. It is my ri/pnni7Afl
own view that if we have at least $100 K to start, we can:
472
A 14
1. Navigate a merger with CKBA
2. Develop partnership with Hanca Foundation
3. Proceed with the action plan
4. Launch of CKC with the PM for late spring-early summer.
I would respectfully request your definitive decisions by Sat January 29th.

If you are not able to come to a decision, I trust that you will understand
that I will have to devote my limited time to other more lucrative projects.
I remain willing and passionate to advance the goals of the CKC. Please
feel free to call me to discuss further. My cell is 613-869-4765.
I meet with Senator Martin on Sunday Jan 30th and will give her my personal
update than about my involvement with CKC.
Best regards,
Tenzin
From: Tenzin Dargyal Khangsar rmailto:tenzinkhangsarlSigmail.com]

Sent: Tuesday, December 21, 2010 9:41 PM
To: "John Park'; Charles Kim (kiml&transpacfibre.com); *dshin@telus.net
Subject: CKF Action Plan 2011
Gentlemen,
As promised, here is the one pager CFK action plan for 2011. I believe this
addresses some key concerns raised on our call:
a) Corporate sponsors - A targeted prospect list is included and the

confirmation of the support of the founding directors will be an important
part of the momentum building.
b) Results - There are four clear priorities and it is my view that

this focus - along with dedicated resources to implement - will yield the.
results that we are all anxious for, especially after more than a year of
discussion
c) Government support - Events in Canada and Korea are planned to CKF001245

secure visible and concrete high level political support. This should also ^
advance our efforts to secure a core group of corporate sponsors.
473
^
V
I suggest that we have a call to discuss this paper once you have a chance
to review it.
Best,
Tenzin
fA
CKF001246
U 474
Greg J. Allen
This is Exhibit , < \ referred to in the

Affidavit of *3*** PH
Sworn before me at _\ j O / ^ L b \ j \ j V
Thii s i ^ : Jot/" 20J2_
Original Message A Commi?f6#eT for taking

F r o m : J o h n P a r k A f fi d a v i I s f o r B r i 1 i s h C o l u r n b i a
Sent: Tuesday, March 15, 2011 5:33 PM
To: Charles Kim; 'Doo Shin'
Subject: CKF Friday dinner
Gent's. By way of update for Friday's CKF dinner at Kamei 6h30.
Confirmed attendees are:

1. Charles Kim
2. Dr. Shin
3. John Park
4. Jason Hong
5. Soon Kim
6. Jay Shin
7. Raymond Chun
8. Lindsay Hall
Pending are:
1. Dr. Peter Chung (I've left a message) 2. John Kim (dr.Shin says he may be late or no show) 3. Michael
Hwang (Dr.Shin has left a message)
I am in favor of our original thought of requesting additional directors to financially contribute. CKF strength
and activities would be best served by having as much start up capital as possible. Those that meet the financial
hurdle (as we did) would indicate they truly want to help make CKF a success and champion our cause. Thus
limiting floaters and make it an issues driven working board.
Charles decided our contribution should be $35k. I propose we add our

1.5 year of sweat equity and time to be worth another $ 15k, making our total contribution to be $50k. Then
ask the new prospective directors to write $50K cheques to play in our sandbox. So-2-4 additions would add
another $ 100K to $200k. We know Lindsay and Jason has in the past agreed to contribute. Will this work?
Please pass on your thoughts or suggest other ideas. This subject will likely be raised Friday evening.
John
Bev Bernacki
This is Exhibit "j3 " referred to in the
A f fi d a v i t of. ^k^-M "
Sworn before me at _\WgoMt/;. -' '' ' 2 |
Thisii^toof^lk-^^ 20 JL-
A Com mi sprier for taking

Al'l'UIkU^ Ui BiilMi Columbia
From: Martin, Yonah [mailto:martiv@SEN.PARLGC.CA1
Sent: Thursday, September 01, 201111:00 AM
To: John Park; 'shindooho@gmail.com'; 'kim^ranspacfibre.com'
Cc: Devolin, Barry - M.P. Mobile
Subject: *IMP* confirmation and recommendations - pis RSVP
Hello CKF Directors:
Happy September! Please find attached our Summer newsletter, which features the CKF launch event (on page 4).
Please confirm the CKF sponsorship (of THREE Canadian delegates to Korea in the 2nd week of October) no later than
Mon, Sept. 5, so that our staff can begin communicating with CKF and all the key offices to prepare our
itinerary/program.
Also, I received an email from David Thomas about CKBA going to Korea in the third week of October and wishing to
^-^potential get plugged into our program.
' Barry and I have discussed this and wish to express the primary concern with the CKBA email, and our recommendations
to CKF, going forward:
CONCERN -1 am the Honorary Patron of CKF, and we had been having our internal discussions about the proposed Oct
trip. Ahead of the CKF sponsorship, it is concerning that another organization would contact me directly about a
program that is still in progress. I am not opposed to CKBA potentially being invited as guests to event(s)/meeting(s), if
that is what CKF chooses to do, but I would not want to negotiate any arrangements with a third party group. Barry and I
have every reason to work with CKF as your honorary patrons. I have yet to reply to David Thomas.
OUR RECOMMENDATIONS TO CKF:
Please read the following recommendations and send us your confirmation of the CKF sponsorship by Sept. 5.
#1. Establish clear "confidentiality" protocol for CKF (as would exist for all Boards). Simply put, what is discussed at the
CKF Board meetings (or online) must be confidential, to protect the CKF initiatives and projects, and to preserve the
integrity of CKF.
(Note: In terms of CKBA, I recall that before the CKF launch, we had discussed the option of inviting CKBA to officially
partner with CKF. Charles, you had. expressed your preference against that option. I know that CKBA members were
invited at the launch and its former President Lindsay Hall's company is a founding sponsor. CKBA's lingering presence in
our discussions today reminds me of the slight confusion that we all felt with Dr. Shin's duo involvement with Hanca
r^ foundation and CKF. Dr. Shin ultimately cleared the air on this. I suggest Charlie to do the same with CKF and CKBA,
'being mindful of your key pioneering role in CKBA. However, as per our discussion before the CKF launch, CKBA cannot
'' effectively advance the Canada Korea relationship in the way CKF intends. The KEY difference is the relationship of CKF
to the Government of the day, as evidenced by the PM's attendance at the launch; and the partnership of the Canada
Korea Inter-Parliamentary Group and its counterpart in Korea. Charlie - Your clear articulation/confirmation of your
commitment to and priority for CKF and a reasonable advisory relationship with CKBA will be important going forward.
. Review and re-affirm the CKF mandate and key objectives. -''' fV $
^
*Truthfully, upon our review of how and why CKF was established, knowing that there are no nationally mafnstreamed
organizations (but for CKF) that can engage with all levels of government at the highest level other than CKF, Barry and I
firmly believe that the Oct trade mission is perfectly in line with the CKF mandate. What an accomplishment it would be
for CKF to fulfill two key objectives (in sponsoring the Parliamentary Internships and a Parliamentary trade mission to
Korea) in its first year!
Therefore, we request that CKF confirm sponsorship no later than Mon, Sept. 5. We will make alternate arrangements as
needed, but await your confirmation.
Thank you.
Respectfully,
Yonah Martin
"Be happy and do good in this life..." Eccl. 3:12
At your service,
Hon. / L'hon. Yonah Martin

jGovernment Deputy Whip / Whip adjointe du gouvernement
v
_.,hartin@sen.parl.gc.ca
1-613-947-4078 (Toll
' 1-800-267-7362 (o) free)
The Senate of Canada / Le Senat du Canada
East Block, Room 240 / Edifice de I'Est, piece 240

Ottawa, ON K1A0A4
From: Leah Buchholz [mailto:leahbuchholz@qmail.com1

Sent: Tuesday, August 30, 2011 01:05 PM
To; Martin, Yonah
Subject: Re: Newsletter, Summer 2011
No virus found in this incoming message.

Checked by AVG - www.avg.com
Version: 8.5.449 / Virus Database: 271.1.1/3868 - Release Date: 08/31/11 18:34:00
30
^
TO: Canada Korea Foundation

510-609 Granville Street
Vancouver, BC V7Y 1G5
I, Stockwell Day, hereby consent to act as a Director of Canada Korea Foundation (the
"Foundation") and confirm that this consent shall continue to be effective until I either revoke it
in writing or resign as a director of the Foundation.
DATED as of 2011
STOCKWELL DAY
Residential Address: This is Exhibit " *** " referred to in the

A f fi d a v i t n f J o W P * r k
3326 Holmes Road
West Kelowna, BC VIZ 2X8 Sworn before me at Va^ccow
20J1
A Commissioner for taking
Affidavits for British Columbia
S4285.I01\772623.1
Bev Bernacki
A l
From: Doo Shin [mailto:shindooho@gmail.comj

Sent: Friday, September 23, 201111:23 AM This is Exhibit" J^L." referred to in the
To: Martin, Yonah
Cc: John Park; Charles Kim Affidavit of
Subject: Re: IMP update re: CKF Sponsorship V<6 A t o O W
Sworn before me at
This of Qojlcv-sUx 20 J2~~
Dear Senator Martin,
A Commfcgffbner for taking
Thank you for your e-mail dated September 19dfiffidavits
, updating usforonBritish Columbia
the upcoming October Korea Program.
Canada Korea Foundation (""CKF") is very pleased to support such a worth endeavour.
Meanwhile, please be advised that I have replaced John Park as the Chairman of the CKF at a Board
meeting held on September 15, 2011. Thus, we need to assure that any reference to the CKF be changed
to reflect this change. So far, the CKF delegation consists of Dr. Doo Ho Shin, Chairman and John Park,
Founding Director.
As I am currently making the travel arrangements to visit Korea, your assistance on the logistics would be
greatly appreciated. Thank you.
On behalf of board of directors,
Doo Ho Shin
From: yonah martin rmailto:vonahm(5>vahoo.com]

Sent: Monday, September 19, 2011 3:31 PM
To: John Park; Doo HoShin; CharlesKim
Cc: Barry - M.P. MobileDevoJin; harrybloy; JulieKim; GraceSeear: barbara.spitz(a)ieQ.bc.ca
Subject: IMP update re: CKF Sponsorship
Dear John and CKF Board:
As Honorary Co-Patrons of Canada Korea Foundation, MP Barry Devolin and I are pleased to
welcome Minister Harry Bloy as the third member of our Canadian delegation for the upcoming Oct.
10-14, 2011 trade mission to the Republic of Korea.
) CKF is the result of your vision and commitment - first introduced as an "idea" at a community round-
table, then put into writing in a proposal paper; and eventually launched in Feb 2011. As a
mainstream bridging organization, CKF is well positioned to promote and achieve key bi-lateral
initiatives that will be mutually beneficial to Canada and Korea. CKF's sponsorship of the
Parliamentary Internship Program (of three capable Korean-Canadian interns from BC, Alberta and
Ontario) and the upcoming Korea program for Canadian legislators is a testament of your expansive
vision and commitment to the national Korean Canadian community and to the Canada-Korea
(Relationship. J^ ^
Please read this important update about the October Korea Program and reply as requested in a
timely manner:
CANADIAN DELEGATION
1. Barry Devolin *Head of the Delegation

Assistant Deputy Speaker of the House
Member of Parliament, Haliburton-Kwatha Lakes-Brock
Co-Chair, Canada Korea Inter-Parliamentary Group
Honorary Patron, Canada Korea Foundation
2. The Honourable Yonah Martin
Deputy Government Whip, Senate of Canada
Co-Chair, Canada Korea Inter-Parliamentary Group
Honorary Patron, Canada Korea Foundation
3. The Honourable Harry Bloy
Minister of Social Development & the Minister responsible for Multiculturalism
I Member of the Legislative Assembly, Burnaby-Lougheed
| Government Liaison to the Korean community of BC
j 4. Ms. Julie Kim
I Parliamentary Assistant
ô MP Barry Devolin and to Canadian Delegation
; Canada Korea Foundation Delegation
l Please confirm names/emails of official CKF Delegation to give to the Embassy and to the
\ World Knowledge Forum organizers (for Oct. 13 morning/lunch)
I 1. John Park *Head of the Delegation
i Chairman, Canada Korea Foundation
| 2. Dr. Doo Ho Shin
l Founding Director, CKF
| 3. Dr. Peter Chung
S Chairman, Eminata Group (founding Sponsor of CKF)
I 4. TBC
\ 5. TBC
i
I SPONSORSHIP DETAILS
Travel
Barry Devolin and Min. Harry Bloy - will submit receipt to CKF for reimbursement
Yonah Martin does not require sponsorship of air travel
Hotel
Three rooms for 3 nights (Oct. 11, 12,13) have been booked at the newly opened Sheraton D
Cube City Hotel (located in the southeastern district of Shindorim, near the National Assembly
and centrally located to other key venues)
Other hotels were too expensive or too out of the way, so this hotel has been selected to be a
good compromise
Rate: $227/night
Reservation has been made, and Barry Devolin will pay on his card and submit one receipt to
CKF upon our return
Three delegates will make personal arrangements for any additional nights as needed
^ P r o p o s e d ) O c t . 1 3 R e c e p t i o n a t E m b a s s y o f C a n a d a - .
Mike Williams is working on the overall itinerary as well the proposal for this event.
Confirmation pending.
CKF sponsorship for reception will be approximately $3500
Remaining budget for the reception will be sponsored by one of CKF's founding sponsors,
Eminata Group. Amount TBC by Embassy.
CKF Guest List - please prepare a list with contact information to send to Mike Williams at
your earliest convenience
PROGRAM NOTES
Oct. 13 - World Knowledge Forum (http://www.wkforum.org/)

*we are committed to participate AM and for lunch event
Barry and I are currently listed as "Speakers", Barry under "B" and Yonah under "Y" (Former
PM Gordon Brown, Sarah Palin, author/Yale prof Amy Chua and many others part of 2011
WKF impressive Speakers line-up)
Min. Bloy is Invited to sit at the head table at lunch
Grace Seear (my EA) is in communication with the WKF liaison re: adding CKF delegation for
the lunch. Confirmation pending
As you can see.from this update, there are many moving pieces that need to be fitted together, but
the fact remains, without the CKF sponsorship, this trip would not have been possible. Thank you on
behalf of our Canadian Delegation to John Park and the CKF Board of Directors for your vision and
Commitment!
Sincerely,
Yonah Martin

Checked by AVG - www.avq.com

Version: 8.5,449 / Virus Database;271.. 1.1/3868- Release Date: Q9/22/1.1 18:34.:QQ
Original Message . ~
From: Martin, Yo n a h r m a i l t o : m a r t i v @ S E N . PA R L . G C . C A 1 - Q<?
Sent: Monday, November 07, 2011 10:35 PM
To: John Park
Cc: 'es01@telus.net'; 'graceseear@gmail.com'
Subject: Re: Interns
John,
Julie only called me today as she didn't want to worry anyone, hoping the cheque would eventually arrive. But
she and Ji-Young are in need of the funds, so phoned me, inquiring...
I had no idea that they were still waiting.
Your urgent attention to their payment (which was agreed upon long before the dispute) is much appreciated.
Thank you.
At your service,

Government Deputy Whip / Whip adjointe du gouvernement The Senate of Canada / Le S6nat du Canada
martin @sen.parl.gc.ca
1-613-947-4078 (o)
1-800-267-7362 (Toll free)
East Block, Room 240 / Edifice de l'Est, piece 240 Ottawa, ON Kl A 0A4
Original Message
From: John Park rmailto:ipark@rcicapitalgroup.coml
Sent: Monday, November 07, 2011 12:49 PM
To: Martin, Yonah
Cc: es01@telus.net <es01 @telus.net>: graceseear@ gmail.com <graceseear@ gmail.com>
Subject: RE: Interns
Hello senator.
The conflict has not been resolved, but I believe Kim and Shin should agree to release the funds.
I will ask my counsel to seek their consent to release the entire amount just in case.
John
Original Message
From: Martin, Yonah rmailto:martiv@SEN.PARL.GC.CA1
Sent: Monday, November 07, 2011 9:32 AM
To: John Park
-'., Cc: 'es01@telus.net'; 'graceseear@gmail.com'
J Subject: Interns
Hi John,
} It has come to my attention today that the two interns (the third will be doing her internship next year) have not
received their sponsorship payment of $4000 yet. It is now November, so it is over 2 months later than
originally agreed upon.
Despite the internal conflict that has unfortunately plagued CKF, I know you will agree that the interns should
get their payment.
Please confirm the date and time when Ed can pick up the two cheques: for Julie Kim and Ji-Young Kim. And
he will Fed-ex the cheques to Ottawa to expedite their chq delivery.
I am late for an appt and have mtgs until 2pm today, but will have my bb to retrieve your response to this email.
Thank you.
Yonah
At your service,

Government Deputy Whip / Whip adjointe du gouvernement The Senate of Canada / Le Senat du Canada
martin @sen.parl.gc.ca
1-613-947-4078 (o)
1-800-267-7362 (Toll free)
East Block, Room 240 / Edifice de l'Est, piece 240 Ottawa, ON Kl A 0A4 No virus found in this incoming
message.

Version: 8.5.454/Virus Database: 271.1.1/4001 - Release Date: 11/07/11 19:34:00

P
This is 1-xhibit ".J2_M referred to in the *
A f fi d a v i t o f ^ o u ^ f V k
Sworn before me at V/<*><^>ovtr-
his iL_ o>y of fletx*4tt^___ 90 \3
/^---
A CommnSjJgTncr for taking
A ff?r!f viis Tor Hritish Columbia
From: Martin, Yonah lmailto:Yonah9.Martin(5)sen.parl.gc.ca1
Sent: November-17-13 9:35 AM
To: 'shindooho@gmail.com1; John Park; 'kim@transpacfibre.com'
Cc: Devolin, Barry- M.P. Mobile
Subject: Letter
Dear Founding Directors of Canada Korea Foundation:
Please find attached a letter of resignation as Honorary Patrons of CKF, effective immediately.
As Co-Chairs of Canada Korea Inter-Parliamentary Friendship Group, and as Deputy Assistant Speaker of the House and
Deputy Leader of the Government in the Senate, we have an obligation to declare our public activities, which we submit
to our respective Ethics Commissioner each year.
At this time, we submit our letter, with wishes for a clear resolution of the legal conflict.
Sincerely,
Yonah Martin & Barry Devolin
From: Doyle, Kristin

Sent: Thursday, November 14, 2013 06:14 PM
To: Martin, Yonah
Subject:
Tins e-mail is confidential. This e-mail is intended only tor the named recipients) and may contain information that is privileged,
confidential and/or exempt from disclosure- under applicable law. No waiver of privilege, confidence or otherwise is intended by
virtue of communication via the internet. Any unauthorized use. dissemination or copying is strictly prohibited. If you .have received
this e-mail in error, or are not named as a recipient, please immediately notify the sender and destroy all copies of this e-mail and anv
attachments.
By submitting your or another individual's personal information to RCJ Capital Group Inc. or its affiliates, service providers and
agents, you agree, and confirm your authority from such other individual, to our collection, use and disclosure of such personal
lmonnaiion 111 accordance with our privacy policy.
xfi Canada Korea Inter-parliamentary Group <ffi*\ 7 2
November, 2013
To the Board of Canada Korea Foundation:
This letter is to inform you of our resignation as Honorary Patrons of the Canada Korea
Foundation, effective immediately.
We would like to thank the Board, staff and volunteers of CKF with whom we have worked
over the years since its inception.
Sincerely,
The Honourable Yonah, Senator Barry Devolin, MP

Co-Chair CKIFG Co-Chair CKIFG
1 involved Jay Shin, a lawyer at BLG? A Yes, I did. I introduced Tenzin to both Dr. Shin
2 A. VlVraVS. ve\\ >is lav Shin was counsel to and Charles.
3 Argo Ventures, and at the end of the day, I've 91 Q When was that?
4 there was issues related to to that, A Well, I know for a fact that Tenzin and
5 c l i e n t - s o l i c i t o r c o n fi d e n t i a l i t y i s s u e s , a n d Charles Kim knew each other before that
6 there was some legal action taken. introduction.
7 84 Q Right. 92 Q Okay. But when did you "bring them together,"
8 A Ye a h . let's say?
9 85 Q But generally there was an issue between -- or at 9 A It was after my initiative in establishing the
10 least a potential issue between Jay Shin and 10 CKF with the support of the Conservative Party
11 Mr. Hong? 11 government in which Tenzin was was a key, I
12 A I I understand there was, but I don't know the 12 guess, advisor to the government in community
13 details. 13 outreach ~ outreach programs of the government.
14 86 Q Right. And you discussed that with Mr. Kim; 14 93 Q And so when did - but - and so I've got the
15 correct? These difficult -- and let me rephrase 15 series, but when around was this date that you
16 that. 16 brought them together?
17 You discussed these -- the financial 17 A I'm going to say the spring of 2010.
18 difficulties and these disputes that you 18 94 Q How did you know Mr. Khangsar?
19 understood Mr. Hong to be having with Mr. Kim? 19 A I knew him through my -- my relationship with the
20 A It was discussed that Charles Kim has another
20 party. So specifically his boss, Jason Kenney.
21 close friend named -- a lawyer named John Park in 21 Tenzin was chief of staff to Jason Kenney at that
22 another law firm which acted for some of the
22 time.
23 investors.
23 95 Q But around the time you brought the three
24 87 Q Can I just -- I'm sorry to interrupt. This is
24 together?
25 another John Park?
25 A Ye s .
.17
19
A Ye s .
96 Q So if I have your evidence correctly, it's that
MR. NAKANISHI: My apologies to Madam Reporter, but we'll try
Mr. Khangsar first became involved with the
to work through this.
Foundation early 2010; is that right?
THE WITNESS: Yeah.
A He was a cheerleader of the community
MR. NAKANISHI:
establishing a national organization to be the
88 Q Ye s ?
voice o" of Korean Canadians.
A So I recall one conversation where he disclosed
97 Q Before we get into the detail of this all getting
that some of the investors were represented by
launched, Mr. Park, what - you say
his other John Park friend's firm. I forget 9 "cheerleader." What was his role?
the name of the firm. 10 A To encourage that some leaders in the community
All this to say, I - you know, I understand
11 step up, expend time and energy, and eventually
Charles Kim has some real estate business, and
12 contribute to the establishment of such an
he's very - you know, he's on guard or always
13 organization.
alert to what other members in the community are
14 98 Q And did he do that?
doing in the real estate sector, and both
15 A He encouraged all three of us through multiple
Soon Kim and Jason Hong were players in that same
16 meetings.
sector.
17 99 Q He was never a director or a member?
89 Q O k a y.
18 A N e v e r.
A So I think he was more sensitive to what they --
19 100 Q He was never a patron or anything like that?
what they were doing than myself. So many cases,
20 And so you never had - he wasn't able to
I think Charles was just poking around to -- to
21 vote or make decisions for the Foundation?
see what I knew, but, yeah.
22 A No.
90 Q Now, Mr. Park, around that same time when you
23 101 Q I'm sorry. I didn't hear.
were discussing your business with Mr. Kim, did
24 A No.
you introduce Mr. Kim to Tenzin Khangsar?
25 102 Q And why did he become involved with the
18
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*^ D K * 3 /2

IN THE SUPREME COURT OF BRITISH COLUMBIA

CANADA KOREA FOUNDATION, DOO HO SHIN and CHARLES KIM

1. John Park, businessman, of 2184 - 1055 Dunsmuir Street, Vancouver, British

1 I am a founding director of the Canada Korea Foundation (the

2. I have reviewed the affidavit of Charles Kim in this matter, sworn

litigation, I have organized my affidavit thematically rather than chronologically.

4. In or around September 2009,1 attended a round table meeting with

5. Following this meeting, in or around December 2009,1 drafted a proposal

8. In pursuit of its objectives, the Foundation opened discussions in 2010

9. Following the aforementioned letter, I was contacted by a representative

10. On August 5, 2011,1 wrote to Prime Minister Harper on behalf of the

12. On October 4, 2011,1 received an email from Ms. Wylupski scheduling a

14. On October 5, 2011,1 spoke to Mr. Norris at length by telephone

regarding the Foundation's proposal to assist in the development of a Memorandum of

15. In September 2011, the Foundation agreed to sponsor three delegates of

expenses and associated matters. The Foundation also contemplated sponsoring an

approximately $8,000. Attached to this my Affidavit and marked as Exhibit 5 is a true

17. In addition to lobbying the federal government regarding Canada-Korea

Agreement by founding directors and members to contribute to the Foundation

21. Attached to this my Affidavit and marked as Exhibit 8 is a true copy of an

22. Although I do not have an independent recollection of the meeting at

23. In the meeting at which each founding director agreed to contribute

24. Although I do not recall it being explicitly stated, to me it was understood

Fundraising efforts and founding sponsors

27. In February 2011, the Foundation organized a fundraising dinner and

The Kamei dinner

31. At the dinner, the founding directors planned to make an offer of

change the aforementioned agreement between the founding directors by proposing

35. Attached to this my Affidavit and marked as Exhibit 9 is a true copy of an

43. In July 2011,1 contributed $50,000 to the Foundation in accordance with

48. Attached to this my Affidavit and marked as Exhibit 13 is a true copy of

Canada Korea Business Association

53. Attached to this my Affidavit and marked as Exhibit 14 is a true copy of

54. Attached to this my Affidavit and marked as Exhibit 15 is a true copy of a

Discussions regarding Stockwell Day

potential expansion of the Board. I suggested Stockwell Day as a candidate for a

57. Following Senator Martin's departure, I discussed Mr. Day's appointment

59. Attached to this my Affidavit and marked as Exhibit 17 is a true copy of a

August 30, 2011.

60. On September 1, 2011,1 attended a special general meeting of the

position on the Board.

64. I have reviewed paragraphs 63 to 77 of Dr. Shin's affidavit, and I strongly

disagree with his recollection of the September 1 meeting. My recollection of that

September 9, 2012 meeting

requested materials from the Foundation's corporate counsel.

67. On or around September 4, 2011,1 received an email from Dr. Shin in

68. On September 9, 2011,1 received an email from Dr. Shin in which he

69. Attached to this my Affidavit and marked as Exhibit 20 is a true copy of

purported to pass the following resolutions:

2. Bank singing [sic] authority

It is resolved that 2 out of 3 directors signatures are required.

3. It is resolved that the appointment of lawyers/accountant/auditors will be

4. Approval of new directors

It is resolved the approval of new directors requires 3 out of 3 directors approval,

71. Attached to this my Affidavit and marked as Exhibit 21 is a true copy of

September 15, 2012 meeting

73. Having received the minutes from the September 9 Meeting on

74. Immediately prior to the September 15 Meeting I became concerned

76. At the September 15 Meeting, I recall stating on at least two occasions

77. At the September 15 Meeting, I demanded to know the nature of the

sponsors. It became apparent to me through Mr. Kim's comments that he had no

82. Attached to this my Affidavit and marked as Exhibit 22 is a true copy of

Continued commitment of founding sponsors

^ D K 3 /2