This affidavit was filed on behalf of the Attorney General of Canada in response to the 2014 Request for Directions (RFD #2) filed by the Corporation of Catholic Entities Party to the Indian Residential School Settlement (CCEPIRSS) 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 Canada’s position.

At the time of this affidavit, Alexander Gay was a lawyer and senior advisor for Public Works. He had previously worked on the 2013 Request for Direction (RFD #1) filed by the Attorney General of Canada. In this affidavit, Gay discusses his work on Canada’s Request for Directions, and the subsequent negotiations leading up to the disagreement between CCEPIRSS and Canada regarding whether or not the parties reached a new settlement agreement.

This document includes Alexander Gay's affidavit and several exhibits as follows:
Exhibit "A": Canada's Request for Direction filed on December 24, 2013
Exhibit "B": Email from Gordon J. Kuski to Alexander Gay, including Anne McConville, dated September 18, 2014
Exhibit "C": Email from Alexander Gay to Gordon J. Kuski dated, including Anne McConville, September 18, 2014
Exhibit "D": Email from Alexander Gay to Zora Ariss, including Gordon J. Kuski dated September 19, 2014
Exhibit "E": Email from Alexander Gay to Gordon J. Kuski dated September 24, 2014
Exhibit "F": Email from Gordon J. Kuski to Alexander Gay dated September 24, 2014
Exhibit "G": Letter from Gordon J. Kuski to Alexander Gay dated October 29, 2014
Exhibit "H": Letter from Alexander Gay to Gordon J. Kuski dated October 29, 2014
Exhibit "I": Letter from Alexander Gay to Gordon J. Kuski dated November 10, 2014