0510512015 1 5:45 Justice Canada A)514 496 7876 P.002/002

* Ministre de a Justice Department of JusticeCanada CanadaQuebec Regloral OfflcaGuy-Favreu Comprox200 Rn4LvequH Blvd. WestEast Tower, 9th FloorMontrl, Qubec H2Z 1X4

Telephone; (514)283-9184Fax: (514) 498-7878

May 5,2015

BY TELECOPIER

Mtre Mitchell Goldberg1980 Sherbrooke Street WestSuite 900Montreal) Quebec H3H 1E8Re: Au SBEITI v. The iUtorney General of Canada (The Minister of Foreign

Affairs and International Trade) and Passport CanadaCourt file: T-2557-14Our file: 7767996

Dear comfrre,In accordance with our earlier telephone conversations today, this is to confirm that theAttorney General of Canada (AGC) will apply to the Federal Court, at the earliestopportunity, for an order with respect to the disclosure of information in this file pursuantto section 38 of the Canada Evidence Act.The AGC and the Respondent agree that during the section 38 proceeding, and until itscompletion, the judicial review application in the above file wifl be suspended. Duringthat time, neither party to the litigation will be bound by the time limits applying to anyprocedural steps not yet taken under Part S of the Federal Cowls Rules.

Yours truly,

Gretchen Timrnins,Counsel for the Respondent

c.c. Registrar of the Federal Court.

M05--2015 15:46 514 4% 78% 97> P.02

rutcneii : aiuuer9 attorney HYocat fo58OO wi-ec1erai iourt Ib14ZS6W1) 11:0205/04/15 ESTP9 2-3

MITCHELL 3. GOLDBERGLaw Offices of Mitchell Goldberg

Avocat I Attorney I Abogado

NOTICE OF FAX

A/To: Me. Gretchen TimminsDepartment of Justice Canada200 Ren-Lvesque WestEast Tower, 12th FloorMontral (Qubec)

Telcopieur/Fax: 514-496-7876

De/From: Me Mitchell Goldberg, Attorney

Date: May 4th, 2015

This sending, including the present, is two (2) pages.

Please be advised that the contents of this transmission are highly confidential information and areprotected by lawyer-client privilege

Si toutes les pages du document ne scot pas reues, S.V.P. appelerau (514) 844-7528If all the pages of this document are not received please call (514) 844-7528

RE: Ali Sbeiti v. The Attorney General of Canada (The Minister of ForeignAffairs and International Trade) and Passport Canada.

Court Fi1e T-2557-14

Dear Me, Timrnins,

Your client indicated its objection to disclosing certain documents notwithstandingour request for the complete tribunal file pursuant to section 317 of the FederalCourt Rules. Reference was made to Section 38 of the Canada Evidence Act, andRule 318(2) of the Federal Court Rules.

However, we note that up until the present, the respondent has not submitted amotion for an exemption, pursuant to the Canada Evidence Act or to the FederalCourt Rules, despite the fact that all the relevant documents are necessary for thejudicial review.

1980 Sherbrooke St. West, Suite 900, Montral, Quebec, H3H ]E8TL 5l4) 844-7528 Fax (514) 807-4302

mitche1JoIdberg@gmailcom

MflYg42a15 17:03 M1tch11 J. Gdb 97% Pfl2

llitchell a. Goldberg flttorney - flvocat- 1o9ado To:Federal Court (15147836004) 17:03 05104/15 EST Pg 3-3

MITCHELL J. GOLDBERGLaw Offices of Mitchell Goldberg

Avocat / Attorney / Abogado

Unless we receive a complete copy of the tribunal file within twenty-four hours ofthe receipt of this fax, or an application for an exemption under Section 38 of theFederal Court Act and under the Federal Court Rules, please note that we willinform the Court of the respondents failure and will argue that the refusal to act inaccordance with the law and with the Federal Court Rules, constitute in itself aground justifying the quashing of the decision under judicial review.

If the respondent does not fIle the application mentioned above as requested,given the tight timelines for producing the Applicants Record the additionalmaterial that you gave us after the filing of the Applicants Affidavit, please notethat we will need an extension of the deadlines to file an additional affidavit and theApplicants Record,

We would therefore request a delay of June 25th for our affidavits, if our client isback in Montreal, and the Applicants Record.

Sincerely,

tchellGoldCounsel for the ApplicantMG/mid

C..C.: Federal Court (by fax 514-283-6004)

1980 Sherbrooke St. West, Suite 900, Montral, Qubec, H3H I E8Tl: (514) 844-7528 ; Fax: (514) 807-4302

mitcheILgo1dberggniaiLcom

MRY42j5 17:24 Mjtrkpll 7 fldh.r P 2