Motion Brief - Phoenix Sinclair Inquiry

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37. By tendering evidence of this nature, the Applicants attempt to introduce second
hand information and opinions from unidentified sources whose expertise has not been
established and who are not available for cross examination.
Cross Examination of Shirley Cochrane, paras 15 to 21
38. It is submitted that the hearsay evidence and opinion is not admissible and
should carry no weight.
V. Response to Particular Allegations in Applicant Affidavits
A. Introduction
39. This section of the brief addresses some of the factual claims underlying the
Applicants’ arguments.
B. The identities of social workers are generally known to the community
and social workers do not generally conceal their identities or their
occupations
40. In paragraph 26 of her affidavit, Janet Kehler makes the statement that social
workers make every attempt to keep the nature of their work private. The evidence has
shown this statement to be incorrect.
41. The Manitoba Institute of Registered Social Workers lists the name of every
registered social worker in Manitoba on its public website.
Affidavit of Allison Lamontagne, May 22, 2012, at Exhibit “B”