City Solicitor’s Office
City Of Saskatoon
222 3rd Avenue North,
Saskatoon, SK, S7K 0J5

Canadian Nationalist Party Inc.
Travis Patron
PO Box 490,
11 Broadway Street,
Redvers, SK, S0C 2H0

Date Served: March 23rd, 2020


Canadian Nationalist Party Inc. v City of Saskatoon
QBG 310 of 2020
Judicial Centre of Saskatoon
File No. 110.0445

ATTENTION: Alan Rankine

City Of Saskatoon,

In response to your letter dated February 25th, 2020, the Canadian Nationalist Party retains the right to be represented by Mr. Patron, citing recent decision in the 2014 case of Howden Bros. Construction Limited v Freshair Enterprises Limited, whereby the defendant was entitled to be represented by a “non-lawyer”.

The criteria for this decision in the case was laid out in [18] as follows:

    In light of these authorities, and the emphasis by The Queen’s Bench Rules on access to justice and the timely and cost effective resolution of disputes, I offer the following revised list of factors which may be relevant on a Rule 2 34(2) application:

  • (i) Whether the proposed representative has been duly authorized by the corporation to act as its representative in the action;
  • (ii) The nature of the connection, such as share ownership, an office or employment, between the proposed representative and the corporation;
  • (iii) The structure of the corporation in terms of shareholders, officers and directors, and whether it is closely held;
  • (iv) Whether the interests of shareholders, officers, directors, employees, creditors and other potential stakeholders are adequately protected by the granting of leave, taking account of the significance of the action and its potential impact on the corporation and those stakeholders;
  • (v) Whether the proposed representative is, in light of the nature of both the claim and the proposed representative, reasonably capable of comprehending the issues in the litigation, participating in the court’s processes, and conducting her or himself in a manner that will promote the timely and effective resolution of the claim;
  • (vi) The potential impact of refusing or granting the order on the financial and other interests of the other parties, whether due to the possibility that the proceedings will not be conducted in a manner that is proportionate in light of the nature of the claim, or otherwise;
  • (vii) Whether the corporation is financially capable of retaining counsel; and,
  • (viii) Any other relevant factor arising from the specific facts.

Canadian Nationalist Party Inc. observes that permitting Mr. Patron to act as counsel for the corporation is in alignment with at least criteria (i)(ii)(iii)(iv)(v)(vi).

We intend to have Mr. Patron continue acting as our corporate representation in this matter and are requesting from Court Of Queen’s Bench that this intention be honoured.


Travis Patron
Canadian Nationalist Party Inc.