Canada
Form 5 RCMP File:
ONTARIO
SUPERIOR COURT OF JUSTICE
(Toronto Region)
IN THE MATTER OF an application for a Search Warrant pursuant to section 487(1) of
the Criminal Code.
WARRANT TO SEARCH
TO: Sergeant Gordon Aristotie or any Peace Officers in the Province of Ontario
assisting him:
WHEREAS it appears on oath of Sergeant Gordon Aristotle, a Peace Officer, and a
member of the Royal Canadian Mounted Police in the Province of Ontario;
THAT there are reasonable grounds for believing that the following offences have been
committed:
Section 322 Theft Criminal Code;
Section 336 Criminal Breach of Trust Criminal Code;
Section 380 (1) Fraud Criminal Code;
‘Section 462.31 Laundering the Proceeds of Crime Criminal Code; and
Section 341 Fraudulent Concealment Criminal Code;
AND THAT there are reasonable grounds for believing that the following things for the
time period from September 1, 2013 to present will afford evidence of the said
offence(s):
1. All records in paper and electronic format pertaining to:
i. PIN Consulting Group Inc.:
ji, Leximco Ltd. (operating as Leximco Travel);
ii, First Response Travel Group; and
iv. An unknown offshore company which is believed to be associated
to one or all of the following individuals: Karl Walsh, Jim Christie,
Martin Bain, Andrew McKay, Klara Kozak or Noel Francis
Chantiam,
including but not limited to the following:
Page 1 of 4a. All financial documents and records such as: banking
records and copies thereof, bank statements, cancelled
cheques, deposit slips, debit and credit memos, cheque
stubs, cheque registers, credit card statements, loan
accounts, investment accounts both domestic and foreign,
money transfer receipts, mortgage and loan agreements,
account applications, mortgage applications, credit card
applications, bank correspondence, accounting records,
general ledgers, journal entries, sales invoices, purchase
invoices, expenses, fee schedules, correspondence files,
financial statements, net worth statements, working paper
files, permanent files containing information on shareholders,
shareholder meetings, details of long term debt, details of
capital assets, deed documents and other supporting
documents;
b. Income tax documents, including but not limited to original
and copies of the T2 returns of income including all
supporting documentation such as financial statements,
correspondence and working papers.
- All records in paper and electronic format pertaining to the association,
‘ownership or control over any company by Karl Walsh, Jim Christie,
Martin Bain, Klara Kozak, Noel Francis Chantiam or Andrew McKay
including but not limited to Leximco Travel, First Response Travel Group,
PIN Consulting Group Inc. and an unknown offshore company;
. All records in paper and electronic format pertaining to investment or
ownership by the Ontario Provincial Police Association (OPPA), Karl
Walsh, Jim Christie, Martin Bain, Klara Kozak, Noel Francis Chantiam, or
Andrew McKay including but not limited to: real property, corporations,
securities, and bank accounts;
. All records in paper and electronic format pertaining to funds being
transferred and received to, from or on behalf of Karl Walsh, Jim Christie,
Martin Bain, Andrew McKay, Klara Kozak, Noe! Francis Chantiam, the
OPPA, First Response Travel Group, PIN Consulting Group Inc. or
Leximco Travel;
. All electronic equipment, electronic devices and media, including but not
limited to computers, tablets, cell phones or other hand held devices
utilized by Klara Kozak;
. All records in paper and electronic format pertaining to phone records for
Klara Kozak;
Page 2 of 47. All records in paper and electronic format pertaining to correspondence,
including emails, letters and faxes of any of the following: the OPPA, Karl
Walsh, Jim Christie, Martin Bain, Andrew McKay, Klara Kozak, Noel
Francis Chantiam, Barry McKay or Elena Rabenok;
8. Content of emails sent or received by Klara Kozak; and
9. All records in paper and electronic format pertaining to tax returns for
Klara Kozak.
AND THAT there are reasonable grounds to believe that the said things or some part of
them are located in Upper Level - 61 Wineva Avenue, Toronto, Ontario, hereinafter
called the premises.
THIS IS THEREFORE, to authorize and require you on the 6th day of March, 2015
between the hours of 8am and 4 pm, to enter into the said premises and to search for
the said things and bring them before me or some other Judge, or submit a report in
writing in respect of anything seized.
DATED this_S day of March, 2015 at the City of Toronto in the Province of Ontario.
Page 3 of 4S| at
2 FU OS FLIES UHRA
et iar
6 elnie o nan STEED Pp
UP PeONTARIO
SUPERIOR COURT OF JUSTICE
(Toronto Region)
IN THE MATTER OF an application for a
Search Warrant pursuant to section
487(1) of the Criminal Code.
WARRANT TO SEARCH
Sergeant Gordon Aristotle
Royal Canadian Mounted Police
345 Harry Walker Parkway South
Newmarket, ON
Page