In the course of negotiations over Canada's Request for Direction, the lawyer for the Corporation of Catholic Entities Party to the Indian Residential School Settlement (CCEPIRSS), Gordon Kuski, came to believe that a new settlement had been reached. CCEPIRSS would pay the Aboriginal Healing Foundation $1.2 million which would release the Catholic entities from 1) the outstanding $1.6 million of the cash payment, 2) the issue of the unexpected administrative expenses, including the lawyers’ fees, having been deducted from that payment, and 3) CCEPIRSS’ fundraising commitment. The government’s lawyer, Alexander Gay, maintained that while the amount of $1.2 million had been agreed on, its purpose had not, and thus that a new settlement had not been reached. CCEPIRSS filed their own Request for Direction (RFD#2).