NOTICE PURSUANT TO THE LIBEL AND

SLANDER ACT, R.S.O. 1990, c.L.12

B E T W E E N:

PATRICK BROWN
Plaintiff

- and –

CTV TELEVISION NETWORK LTD., BELL MEDIA INC., WENDY FREEMAN, LISA
LAFLAMME, GLEN McGREGOR, RACHEL AIELLO, JANE or JOHN DOE #1 (being the
producers of the Defamatory Words), JANE OR JOHN DOE #2 (being the editors of the
Defamatory Words), JANE OR JOHN DOE #3 (being the researchers in respect of the
Defamatory Words), JANE OR JOHN DOE #4 (being the fact checkers in respect of the
Defamatory Words), CP24 and TRAVIS DHANJAR
Defendants

NOTICE OF LIBEL

TAKE NOTICE that pursuant to section 5(1) of the Libel and Slander, Act, R.S.O. 1990,
c.L.12 (the “Libel and Slander Act”) Patrick Brown complains of and objects to the false,
malicious, irresponsible and defamatory newscast of and concerning him broadcast on
CTV National News with Lisa LaFlamme on January 24, 2018 headlined as, inter alia,
“Serious allegations against Patrick Brown” and “Women accuse Patrick Brown of sexual
misconduct” and subsequently published to the website www.ctvnews.ca and published
and/or broadcast on such further and other dates as Patrick Brown is currently unaware
(the “Defamatory Broadcast”).

Further take notice that Patrick Brown complains of and objects to the false, malicious,
irresponsible and defamatory publication and/or broadcast of news articles of and
concerning him on the website www.ctvnews.ca on January 24, 2018 and as updated on
January 25, 2018 and on February 13 and 22, 2018 and on such further and other dates
as Patrick Brown is currently unaware under the headlines, inter alia, “Patrick Brown
denies sexual misconduct allegations from two women, resigns as Ontario PC leader”
and “Patrick Brown accusers stand by allegations” (the “Defamatory Articles”).

The Defamatory Broadcast and Defamatory Articles are hereinafter collectively referred
to as the “Defamatory Words”.
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Patrick Brown intends to rely on the entirety of the Defamatory Words including all
accompanying headlines, display, graphics, audio, pictures and text, in support of his
intended action, and all earlier and subsequent versions of the Defamatory Words
published or broadcast, or republished or rebroadcast, in any form whatsoever, in whole
or in part, by the defendants and others.

The Defamatory Words in their natural and ordinary meaning and/or by inference or
innuendo, are false, malicious and defamatory of Patrick Brown, have subjected him to
ridicule, hatred and contempt and have caused and will continue to cause damage to his
reputation personally and in the way of his office, profession, trade and calling.

Patrick Brown states that the Defamatory Words in their natural and ordinary meaning,
and by innuendo, falsely and maliciously meant and were understood to mean that:

a) by engaging in the conduct described, he illegally provided alcohol to a person

under the age of 19;
b) by engaging in the conduct described, he engaged in sexual misconduct;
c) the allegations against him, as described, are true;
d) the resignations of 5 key staff members confirm that the allegations are true; and
e) by virtue of (a) to (d) above, he is unfit for public office.

Further, the defendants published and/or broadcast the Defamatory Words intending or
knowing, that the Defamatory Words would be republished or rebroadcast, in whole or in
part, by others and accordingly the defendants are jointly and severally liable for all such
republication or rebroadcast.

The Defamatory Words were published with express malice, the defendants intending or
knowing, that the Defamatory Words and the innuendo arising from them were false and
defamatory or with careless and reckless disregard for the truth and their publication and
broadcast was calculated by the defendants to disparage and injure the reputation of
Patrick Brown personally and in the way of his office, profession, trade and calling.

The full extent of the damages suffered by Patrick Brown is unknown. In order to mitigate
his damages, Patrick Brown requires that you immediately broadcast and/or publish on
the website www.ctvnews.ca and on CTV National News with Lisa LaFlamme a full
apology and retraction, in a form first approved by Patrick Brown, in respect of the
Defamatory Words, in a manner at least as prominent as the original publication or
broadcast of the Defamatory Words, and that you immediately remove the Defamatory
Words from www.ctvnews.ca and take all steps necessary to ensure that no archived
versions remain on the internet, in whole or in part.

Please be advised that you are named in this Notice of Libel in that you caused,
participated in, authorized, permitted or condoned the publication of the Defamatory
Words and are, as a result, jointly and severally liable for the damages flowing therefrom.
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We hereby demand that you retain in safekeeping all drafts of the Defamatory Words, all
notes and tapes of all interviews and all other notes, documents, computer documents,
tapes, emails, any other materials, documents and records relevant to the Defamatory
Words, and all comments or reaction, in any form, received by the defendants in respect
to the publication and/or broadcast of the Defamatory Words.

Patrick Brown intends to commence an action against you in respect of the Defamatory
Words and reserves all rights in this regard. Patrick Brown hereby gives notice pursuant
to the Courts of Justice Act, R.S.O. 1990, c.C.43 that he will be claiming pre-judgment
interest from the date of this Notice to the date of judgment.

DATED at Toronto this 23rd day of February 2018.

JULIAN PORTER, Q.C.

Suite 1600, 100 King Street West
1 First Canadian Place
Toronto, Ontario M5X 1G5

Tel: 416-862-4297
Fax: 416-862-7661
Email: julian.porter@julianporterqc.com

WINKLER DISPUTE RESOLUTION

39 Glenayr Rd.
Toronto, Ontario M5P 3B9

Howard Winkler and Eryn Pond

Tel: 416-519-2344
Fax: 416-915-6325
Email: hwinkler@winklerlawllp.com

Lawyers for the Plaintiff