AFFIDAVIT OF WARREN KINSELLA (sworn June 9, 2010) 1, Warren Kinsella, of the Cty of Toronto, in the Province of Ontario MAKE OATH ANDSAY: 1, At 932 aim. on May 11, 2010, T spoke with Alfred Apps, President of the Liberal Party of Canada. 1 took detailed notes of our conversation, in order that I could later brief others. 2, ‘The subject matter of our conversation was cooperation between the Liberal Party and the NDP. What Mr. Apps said surprised me. Mr. Apps stated: “There is lot of interest in ‘merger in the NDP. There have been many discussions at a high level..involving the NDP ssints [whom he described as Droadbent, Romanow].” 3. Tid not know how such an arrangement would work, Mr. Apps stated: “Two board resolutions would be required..The NDP is really pushing this, bat they would need to do thyee things.” 4, He suid those things were: “One, renounce socialism and embrace « mixed-matket economy. Two, be prepared to have Michael Ignatieff as leader. Three, the senior saints must [promote the concept.” 5. Told Mr. Apps the idea sounded risky. He replied: “It is a profoundly democratic act ‘and would lead to the creation of a new party.” He then went on to state that unions would need o lose guaranteed votes under the NDP constitution. 6. Mr. Apps and I had other conversations about this subject on other dates. I was not involved in any discussions with the NDP, and I did not initiate any. However, I supported ‘hat Mr. Apps had to say.7. Tmake this affidavit for no improper purpose, and only to set the record straight about ‘what I know about this subject ‘SWORN BEFORE ME at the City of ‘Toronto, in the Province of Ontario on June 9,2010, WARREN KINSELLAAFFIDAVIT OF WARREN KINSELLA (sworn JUNE 9, 2010)