This affidavit was filed by the Corporation of Catholic Entities Party to the Indian Residential School Settlement (CCEPIRSS) in support of its 2014 Request for Directions (RFD #2) regarding the 2006 Indian Residential Schools Settlement Agreement (IRSSA). An earlier Request for Direction (RFD #1), had been filed by Canada questioning CCEPIRSS’ deduction of its legal fees from its financial payments under IRSSA. CCEPIRSS and Canada had entered into negotiations. In the course of the negotiations, CCEPIRSS came to believe it had reached a new agreement with Canada. Canada disagreed. This affidavit supports CCEPIRSS’ contention.

At the time of this affidavit, Gordon J. Kuski was a lawyer representing CCEPIRSS. He had been retained by CCEPIRSS on February 21, 2014 after Canada filed its Request for Directions (RFD #1) on December 24, 2013. In this affidavit, Kuski discusses his work with CCEPIRSS following Canada's Request for Directions and the subsequent negotiations leading up to the disagreement between CCEPIRSS and Canada regarding whether or not the parties had reached a new settlement agreement.

This document includes Gordon J. Kuski's affidavit and several exhibits as follows:
Exhibit "A": Gordon J. Kuski's Curriculum Vitae
Exhibit "E": Transcript of Pamela Stellick's cross-examination
Exhibit "G": Letter from Gordon J. Kuski to Alexander Gay dated June 26, 2014
Exhibit "H": Email from Gordon J. Kuski to Pierre Baribeau and Rod Donlevy dated September 17, 2014
Exhibit "I": Email from Alexander Gay to Gordon J. Kuski, including Anne McConville dated September 18, 2014
Exhibit "J": Email from Gordon J. Kuski to Alexander Gay, including Anne McConville dated September 18, 2014
Exhibit "K": Letter from Gordon J. Kuski to Alexander Gay dated September 18, 2014
Exhibit "L": Email from Alexander Gay to Gordon J. Kuski dated September 18, 2014
Exhibit "M": Email from Alexander Gay to Gordon J. Kuski dated September 18, 2014
Exhibit "N": Email from Zora Ariss, including Gordon J. Kuski, to Alexander Gay dated September 18, 2014
Exhibit "O": Draft General Final Release from Gordon J. Kuski
Exhibit "P": Email from Alexander Gay to Zora Ariss, including Gordon J. Kuski, dated September 19, 2014
Exhibit "Q": Email from Gordon J. Kuski to Alexander Gay dated September 24, 2014
Exhibit "R": Email from Alexander Gay to Gordon J. Kuski dated September 24, 2014
Exhibit "S": Email from Gordon J. Kuski to Alexander Gay dated September 24, 2014
Exhibit "T": Email from Alexander Gay to Gordon J. Kuski dated September 24, 2014
Exhibit "U": Email from Alexander Gay to Gordon J. Kuski dated September 30, 2014
Exhibit "V": Draft General Final Release from Alexander Gay
Exhibit "W": Letter from Gordon J. Kuski to Alexander Gay dated October 1, 2014
Exhibit "X": Email from Alexander Gay to Gordon J. Kuski dated October 2, 2014
Exhibit "Y": Letter from Gordon J. Kuski to Alexander Gay dated October 29, 2014
Exhibit "Z": Letter from Alexander Gay to Gordon J. Kuski dated October 29, 2014
Exhibit "AA": Letter from Alexander Gay to Gordon J. Kuski dated November 10, 2014

The following Exhibits are not included in this scanned version of the file:
Exhibit "B": Canada's Request for Directions
Exhibit "C": CCEPIRSS' Response to Canada's Request for Directions
Exhibit "D": Pamela Stellick's Affidavit (without exhibits)
Exhibit "F": IRSSA Schedule "O-3"