TURMEL: #11 Robin Hood Raid on Casino Turmel Trial Transcript

JCT: Since the Project Robin Hood raid on Casino Turmel case was
brought up in the Big Five Marijuana appeals at the Ontario 
Court of Appeal recently arguing against judges imposing new 
criminal sanctions, rather than Parliament, I've decided to to 
publish the transcripts of the trial on the biggest gaming house 
raid in Canadian, probably world, history. 28 tables/155 dealers. 
See: http://www.cyberclass.net/turmel/gambler.htm 

19931213 
#93-18193
        ONTARIO COURT (PROVINCIAL DIVISION)               
               HER MAJESTY THE QUEEN
                      against
                    JOHN TURMEL
                    **********
                     PRETRIAL
    HELD BEFORE THE HONOURABLE JUDGE B. LENNOX  
    on December 13th, 1993, at Ottawa, Ontario.
                    **********
      CHARGE:  S. 201(1) (2 counts), C.C.
               S. 202(1)(e), C.C.
               S. 202(1)(c), C.C.
                    **********
APPEARANCES:
A. Marin, Esq. Crown Counsel
J. Turmel Appearing for Self

[continued]

COURT: O.K. Well, I think the question is fairly straight-forward 
and that is whether or not these premises are kept for gain. That 
was the original question. And if you're prepared...

TURMEL: I see no evidence of any GST-able gain.

COURT: O.K. So that's not something you're admitting.

TURMEL: No. 

COURT: The next matter, Mr. Marin?

MARIN: That's it, Your Honour.

COURT: O.K. Could we move on to the second count? You have asked 
for particulars with respect to the second count. That's been 
given, in effect, Mr. Turmel? Were there any admissions you were 
seeking with respect to the second count specifically, Mr. Marin?

MARIN: No, Your Honour.

COURT: All right. The third count is engaging in the business or 
occupation of betting and I take it your argument is the same as 
for the second count, is it, Mr. Turmel?

TURMEL: Yes, the business of gaming.

COURT: I don't know if we specifically dealt with the fourth 
count, which is controlling the monies for gambling?

TURMEL: Actually, Your Honour, that was an error, and it's 
unfortunate because that's not in the Criminal Code. It says 
controlling monies from this section, the bookmaking section. 
They threw in the word "gambling." They could have thrown in any 
word they wanted. They made it up, and, of course, the indictment 
was challenged but it was viewed as valid even though it is not a 
crime know at law.

COURT: All right. So we'll leave that for the trial court then.

MARIN: Yes, Your Honour. Just one issue that comes up: Is it 
admitted that he is the keeper of the place as per section 
197(a), Your Honour?

TURMEL: I can admit I kept the place but I'm not going to admit I 
kept a betting house.

COURT: I think Mr. Marin, it seems to me, quite frankly, that, if 
you're asking for admission that Mr. Turmel is keeping a gaming 
house, it may as well be a plea of guilty. He is prepared to 
admit that he is the keeper of the premises and the activity on 
the premises you demonstrate to prove whether or not it is 
gambling, but I couldn't expect more than that.

MARIN: All right. So, he is the keeper of the premises.

TURMEL: Yes, that's acceptable. I even admitted in my statement 
that I did rent the place. So it's already there.

COURT: Now, is your admission limited to count number one or does 
it also apply to count number two? The keeper of premises which 
the Crown is attempting to prove is a betting house?

TURMEL: Yes. Count number two also.

COURT: Anything further, Mr. Marin?

MARIN: There will -- obviously number three is intimately tied as 
well with number two, unlawfully did engage in the business or 
occupation of betting.

COURT: Yes, I would think that the fate of both counts will be 
the same, would it not?

MARIN: Yes. So again the keeper of the premises would apply to, 
as well, count three to the extent that that's necessary.

TURMEL: Well, I mean, I don't admit any of it. I mean, I was in 
the business of gaming so I definitely don't admit the business 
of betting. That'll have to be proved.

COURT: O.K. So you admit to being the keeper of the premises 
which the Crown is alleging in one instance, the first count, was 
a gaming house and in the second was a common betting house, and 
the third at which the business or occupation of betting took 
place. Those are the allegations but you are simply admitting to 
being keeper of the premises.

TURMEL: Of the premises, yes.

COURT: Now does it seem to you, Mr. Marin, at this point in time 
that we are dealing with a trial which involves largely expert 
evidence and argument on that evidence, examination, cross-
examination and arguments?

MARIN: Yes, Your Honour. I would tend -- my own feeling of the 
case is that there is much less expert evidence than would appear 
at first lush, because I've identified at least ten areas where I 
am in a position to show gain, without necessarily getting into 
the odds and so on, but simply to show that there is revenue, the 
place was kept for purpose of making money and there are many 
ways to do that, one of which is to bring in expert evidence. But 
I think Your Honour is correct that the evidentiary process of 
the case will be coming down to very few witnesses, actually. I 
have sort of a feel of around three days, Your Honour.

TURMEL: Well, I don't waste a lot of time and I find it hard to 
believe that -- I have never had an Ontario trial take more than 
one day. So I honestly believe that, when you look at all the 
admissions that are there, that they're probably going to walk in 
with one Officer and one expert like they did the last time.

COURT: Can I make a suggestion at this point in time? Could we 
just take a brief recess? If you could just examine the 
admissions specifically to this case that Mr. Turmel is prepared 
to make in conjunction with Exhibit C and the matters that are 
now on record, I am prepared to give the case obviously whatever 
time is required to deal with it, but I would like to have some 
confidence if we have an accurate estimate of time, and if, 
indeed, it is two instead of three days, that's fine, or three 
days.

MARIN: O.K. Your Honour. If I may just make a comment on the 
fourth count before we take a break because there are some issues 
there as well. The fourth count is a charge of controlling monies 
for gambling related to the offence of engaging in the business 
or occupation of betting. The additional wrinkle for that charge 
is that we would want an admission if possible of the bank 
records showing Mr. Turmel received the money and controlled the 
gains arising out of the activities of the premises. There's a 
number of banks, I understand.

SGT. CLEARY: Your Honour, if I may interject here, there are five 
banks involved. One is the casino employee's fund, which does not 
involve Mr. Turmel. However, there is another bank which involves 
three separate accounts. So the other ones would only involve one 
account in each bank with the exception of one which has three 
accounts.

COURT: Mr. Turmel, are you familiar with the accounts of which we 
are speaking at this point in time?

TURMEL: Yes I am and I have absolutely no qualms about admitting 
that I controlled all those accounts and, you know, and most 
people in the cage will remember there were six accounts, so, 
yes, monies went in and out and I am not denying monies were won 
or lost.

COURT: Anything further, Mr. Marin, with respect to any of the 
accounts?

MARIN: No, Your Honour.

TURMEL: Oh, one last thing, Your Honour. In evidence, in the 
Crown's case there is a piece of literature I printed before I 
started all this. I call it "Operation Blackjack" because that's  
the name they give. I would be willing to include this in my 
admissions. If there is anything in here about the operation of 
the game that they want to use, I will throw this in, also. I 
mean I made it public to the world, I may as well admit it to the 
Court. So there's, you know, a hundred K worth of admissions in 
there that they can also choose to work from. I'm sure they've 
read it by now, so I'm not going to deny anything.

COURT: Does that extend to the fact, Mr. Turmel, that you had 
knowledge of the contents and in fact were the author of the 
document? And are you saying that your operations were modelled 
or that was a blueprint for the operation which gave rise to 
these charges? So, if the Crown wishes to use part of that, then 
you are prepared to have it go in as an admission. Is that right?

TURMEL: Yes that's exactly right.

COURT: All right. Thank you. Can we take perhaps five minutes, 
then, to see if Counsel with Mr. Turmel can arrive at an estimate 
of time? Thank you.


UPON RESUMING:

MARIN: Your Honour, I have spoken to Mr. Turmel in the presence 
of the Officers and we have come to the conclusion that two days 
in light of the admissions. The accused sees this as a one- or 
two-witness case. I intend to call more than two witnesses, but, 
in any event, two days ought to be erring on the safe side and I 
would ask that two days be set aside for the trial.  

CLERK: Mr. Marin, are all of the counts absolute jurisdiction 
offences?  

MARIN: They're absolute jurisdictions.

COURT: They're indictable offences, absolute jurisdiction. Just a 
moment.

TURMEL: Your Honour, I may be able to help by saying that I was 
convicted under one of those 202 sections ten or fifteen years 
ago and it was absolute jurisdiction then.

COURT: O.K. Nothing has changed, Mr. Turmel. Thank you very much.

TURMEL: As a matter of fact, they're going for a heavier 
sentence. They've already put in their request for a heavier 
sentence, past the minimum three months, so it's absolute.

COURT: Thank you. The estimate of time is two days. I have some 
relatively early dates, a number of them, a combination of any 
two days: January 11th, 12th, 13th, 24th, 25th, February 7th, 
8th, 23rd, 24th, 25th.

TURMEL: All good to me.

MARIN: January, Your Honour, is pretty well out. The 24th and 
25th of February.

COURT: Oh, of February. 

MARIN: Yes. In early February, Detective Cleary, who is in charge 
of this investigation, is on a fraud case until the 11th of 
February. So if possible, the 24th, 25th of February would be the 
first suitable dates.

COURT: Now, what I will do for the present purpose is set this 
for courtroom #13 but it may well be that the court actually used 
will not be 13 but another courtroom, but....

MARIN: That's a gamble, Your Honour.

COURT: No. I had some hesitation in stating the courtroom number 
but that is the courtroom.

TURMEL: Gamblers are allowed to be superstitious.

COURT: Ten o'clock in the morning in number 13 courtroom, the 
trial will either be held there or in another court of which you 
will be advised at that time. So, Mr. Turmel, at this point, 
could you please stand up?

I'll formally remand the charges you until February 24th, 1994 at 
ten o'clock in the morning, Number 13 court for a period of two 
days. Thank you very much. And Mr. Marin, will you be ordering a 
copy of the transcript?

MARIN: Yes, Your Honour.

COURT: Mr. Turmel, the Crown will have a copy of the transcript 
which will contain admissions made by yourself or indications by 
the Crown as to particulars. That may be of some use for you at 
the trial.

MARIN: I've already ordered it. Thank you.

CLERK: Would you like a copy, Mr. Turmel?

TURMEL: Of the transcript? How much?

CLERK: 55 cents a page.

TURMEL: Yes.

MARIN: You get it cheap.

TURMEL: I know.
**********

940208
AFFIDAVIT

1. On page 7 of the transcript of the Dec. 13, 1993 judicial pre-
trial hearing, after I had introduced the Agreed Statement of 
Facts from my 1989 gaming house acquittal, Judge Lennox asked me:

COURT: Would you have any objections to their observations going 
in by way of Agreed Statement of Facts.

TURMEL: No. This is Appendix C of the search warrant and I've 
noted just a few things I do disagree with, opinions mainly.

COURT: I don't expect for you and the Crown to reach agreement 
today but if the only things in issue are the matters you raise, 
then presumably the other matters are matters of admission that 
you are not disputing and that's quite helpful.

COURT: (page 18) And, Mr. Turmel, you have a copy now of an 
agreed statement of facts that you specifically prepared for this 
proceeding, is that right?

TURMEL: Yes, I changed a few of the words, kept it identically 
numbered.

2. I had been informed by Ms. Breault of the Crown's office that 
the statement of facts would be ready for my agreement by Feb. 2, 
1994. On Feb. 2, she indicated to me that the Crown was not 
preparing a statement for my agreement and was going to rely on 
the transcript of the pre-trial hearing. I pointed out that the 
transcript dealt with only issues that were not admitted and that 
the facts which were admitted had not even been discussed. 

3. When Your Honour stated that you did not expect us to reach 
agreement on that day, the court must have expected us to reach 
an agreement some day. I further submit that the trial judge 
should be given a statement of agreed-upon facts, not a statement 
of disagreed-upon facts. 

4. Considering one of the facts I sought to have admitted in the 
statement was that I had not been called upon by any government 
agency to collect or pay G.S.T. and considering the Crown has 
alleged ten or more Section (a) gains I'm supposed to have made, 
it would would be difficult to defend against those 10 gains 
without knowing what they were and if they bore any G.S.T.

5. That the Crown is reneging on their undertaking to prepare the 
Agreed Statement of Facts is disconcerting at best and sinister 
at worst considering the abuse of process a second "no evidence" 
acquittal would imply.

6. This Affidavit is made in support of a application for:

a) an Order that the Crown complete their undertaking and produce 
a draft of an Agreed Statement of Facts within 3 days; or

b) an Order for the resumption of the judicial pre-trial to put 
any agreed-upon admissions on the record.


#93-18193
        ONTARIO COURT (PROVINCIAL DIVISION)               
               HER MAJESTY THE QUEEN
                      against
                    JOHN TURMEL
                    **********
                    PRETRIAL II
    HELD BEFORE THE HONOURABLE JUDGE B. LENNOX  
      on February 8, 1994 at Ottawa, Ontario.
                    **********
      CHARGE:  S. 201(1) (2 counts), C.C.
               S. 202(1)(e), C.C.
               S. 202(1)(c), C.C.
                    **********
APPEARANCES:
A. Marin, Esq. Crown Counsel
J. Turmel Appearing for Self

COURT: Mr. Turmel, are there other matters outstanding with 
respect to the Pre-Trial? 

TURMEL: Well, yes, Your Honour. I have here a copy... Now, first 
of all I spoke to the Crown's office last Wednesday when I was 
told that they weren't going to be preparing an Agreed Upon 
Statement of Facts, I then prepared and filed this Motion and 
after it had been already served and handed in, I was told by Ms. 
Breault, that she was working on something. I said; "Well that's 
nice but it's a little late", and then on Monday, yesterday, I 
was given the Crown's Agreed Upon Statement of Facts. I have a 
copy here which I would like to give you, as well I have a copy 
of the Agreed Upon Statement of Facts from 1989 and you will see 
they are virtually identical except that the Crown has dropped 
several points which I don't understand the reasons behind the 
dropping of those points. I've underlined those points in the 
Agreed Upon Statement from John and Ray Turmel in 1989. Point 
number 11 was dropped. Not too important. Point number 17 was 
dropped. Now she entitled it or - I don't know. Mr. Marin did you 
prepare this with Ms. Breault? 

MARIN: She prepared it. 

TURMEL: Number 17 has been dropped and, I guess, they want to 
dispute the fact that Black Jack is a bank game. Now this was a 
point made by the Crown back in 1989 and I find it hard to 
understand why the Crown would wish to consider this a disputed 
fact at this point. And, of course, the same thing for number 18 
and, of course, parts of number 19. These are important facts 
relative to the case which the Crown thought sufficiently 
important to present to you in 1989 and now we see that some 
relevant information has been chopped out of this draft Agreement 
between us and I just don't understand why this information 
wouldn't be included unless the Crown would rather spend time 
proving it's a bank game. 

So just to start with I think very much that the original 
statement, as handed in from 1989, should be a starting point 
unless the Crown has valid reasons for not wanting any of those 
admissions put in at this stage. It can only complicate things at 
trial. So can we start with just this piece first and find out 
what Mr. Marin hopes to accomplish by deleting these portions? 

COURT: I don't know if that's a particularly useful exercise, Mr. 
Turmel. I'm not in a position to compel anybody to make 
admissions or to seek admissions. I don't know. Mr. Marin, was 
the one Agreed Statement of Facts prepared using the other as a 
kind of model? 

MARIN: Yes it was, Your Honour, and I can indicate for your 
benefit and the benefit of Mr. Turmel that we simply went through 
the exercises sitting around a table and putting down on paper 
what we could not dispute. I don't remember the particular reason 
why this one was dropped but we tried to put in as many of the 
facts as Mr. Turmel wanted in. 

TURMEL: Well again, Your Honour, I think that the original start 
should be what we had in 1989, unless... 

COURT: Well not necessarily, Mr. Turmel, because each fact 
situation is different. You keep trying to equate this and it may 
well be directly equated to the 1989 situation but matters that 
aren't admitted, of course, are matters that require proof. 

TURMEL: So does the Crown choose now to prove Black Jack is a 
bank game rather than accept my admission? is what this point 
boils down to, point 17? I admit it's a bank game and is the 
Crown going to hope to prove that and bring witnesses rather than 
just accept my admission? I figure the more I admit, the less we 
have to do. 

COURT: Perhaps we could simplify it somewhat. Point number 11, of 
course, is specific to the charge dealing with February, 1988 
(sic) as you said that. 

TURMEL: By the way, Your Honour, I had prepared... This is the 
one I handed into the Crown. It had up-to-date information for 
this case here including the address on St. Laurent and the 
address on Baxter Road and the fact that 4,000 people came 
instead of several dozen. But I mean I drafted it identically. 

COURT: I take it, Mr. Turmel, that what you're really saying to 
me is that if the Crown wished you're prepared to make admissions 
identical to those made in 1989 with respect to the paragraphs 
you pointed out?

TURMEL: That's right. 

COURT: And in addition to make admissions as set out in your 
Agreed Statement of Facts? 

TURMEL: That's right. I assume we'd make another and we'd start 
with this as a basis. I don't understand these deletions because 
they seem to be things that the Crown is going to want to spend 
time proving and yet I admitted them in '89 and they didn't have 
to prove them then so why would they choose to prove something 
I'm willing to admit? 

COURT: I find it a little bit odd that you seem to be complaining 
about matters that you think strengthen the Crown's case, the 
Crown not being prepared to admit them. 

TURMEL: Well it may be so that, you know, they may have a little 
more difficulty proving it's a bank game without an admission but 
I figure that's a large waste of time. 

Specifically point 17 and 18 the ones dealing with the game. I'd 
like them to mention that it's the same game and best done if 
they admit the same facts. What's the purpose in trying to, you 
know, not admit it's a bank game when the Crown is going to want 
to prove that eventually anyway. 

COURT: This process is a little unusual. First of all I'd like to 
say that in terms of the Pre-Trial process I certainly appreciate 
the efforts that you're making, Mr. Turmel and Mr. Marin, 
essentially to limit the issues to those which ar are not admitted become the 
subject of the litigation and of evidence and argument. It's 
somewhat awkward for me to sit here and enter into what amounts 
to a negotiation between the defence and the Crown as to 
admissions when it is really entirely within the capacity of 
either of the Crown, or of yourself, to make or not make 
admissions as you will. 

You seem to think that the Crown will wish to prove that the game 
of Black Jack is a bank game. That may well be the case. I don't 
know if that's Mr. Marin's view or whether he intends to call 
evidence on it but, at least, when an Agreed Statement of Facts 
is prepared and presented I would assume that you could presume 
that the document provided to you which is entitled Undisputed 
Facts Between the Parties. 

I believe that's a Crown document constitutes the admissions the 
Crown is prepared to make and the Crown is accepting. So they're 
joint admissions. No one party can bind the other to make a 
decision. You can admit certain things which the Crown could then 
refuse. The ultimate, for example, you could admit you're not 
guilty and the Crown may choose not to accept that. That's more a 
question of fact in law. So you can't bind the Crown by making an 
admission. The Crown may wish to prove the fact which you admit 
or may wish to prove something slightly different but I take 
these as being documents, joint documents. So what has happened 
now is you've made a series of admissions, the Crown seems to 
have taken the bulk of them and put them in a list of undisputed 
facts. You've produced another document, which you entitle Agreed 
Statement of Facts which contains admissions you're prepared to 
make. If the Crown wishes to accept those as admissions it will, 
if it doesn't it won't and the same goes for you. Do you follow 
that logic?

TURMEL: Yes, I do. It's just that I'm kind of shocked why the 
Crown would delete these portions when they are going to have to 
prove them in court. 

COURT: I would think that when Mr. Marin has a chance to review 
that he may be in a position where he would tell you, in fact, 
that he is going to accept the admission and doesn't wish to 
prove it.

TURMEL: It could be admitted at trial I suppose. 

COURT: That's right. And really if in your view defending this 
case, matters which you are prepared to admit are essential for 
the Crown to establish its case and the Crown wishes not to have 
those as admissions then in point of fact you may actually 
benefit from that. 

TURMEL: I appreciate that angle and I just, you know, my purpose 
was to try and make the admissions as close to the 1989 ones for 
an analogous reason. If the Crown wants them well the point is 
I've made the admission at a Pre-Trial earlier than these were 
all made. 

COURT: As I said and I say it again, because I think it is worth 
stressing, that in cases like these, or such as this one, often 
take considerably more time than we have set aside. The reason 
that we have been able to set the limited time for the trial is 
because you have been more than generous in terms of the 
agreements that you're prepared to make with facts and, of 
course, that's the Court's experience with you in the past is 
that you seem to be prepared, which is unusual for a person 
representing himself, to deal with those matters that would 
appear fundamentally in issue. 

We appreciate that but we can only go so far and if you're 
prepared to make an admission which the Crown doesn't choose to 
accept then there's nothing I could, or should, do and there's 
nothing that necessarily you could do which would change that. I 
would suspect that as we get closer to the trial date that Mr. 
Marin may well be in a position to indicate to you that certain 
of the matters which you've stated in your Agreed Statement of 
Facts are, in fact, matters which the Crown is prepared to accept 
by way of admission. 

TURMEL: Okay. So what they chose not to accept is fine by me. But 
I mean what this is ending up to be is John Turmel admits all the 
obvious facts and the Crown admits none. For instance, if you 
take a look at the one titled; Regina v. Turmel, Agreed Statement 
of Facts there are some statements at the bottom there that are 
important for me to know whether or not I'm going to have to 
prepare a defence to these allegations, like point 20. Point 20 
was not on the original one in 1989 because it was germane to 
1993. That the tips given to Turmel's dealers were the sole 
property of the dealers. Now is there any dispute with that 
point? My point is; should I actually go out and subpoena all my 
dealers to come in because it looks like the crown wants to 
dispute that fact or are saying that they have evidence that I 
did take part of the dealers' tips. I mean, from a Defendant's 
point of view, if this is not going to be an accepted statement 
I'm going to have to bring in all the dealers and have them say. 
So that's one example of an admission that I would like from the 
Crown. 

I mean it can't be a one way street. There's two or three here 
and the second one therefore is the Goods and Services Tax. Now 
if the crown has any evidence of any government body or any time 
when I was charging, or collecting, G.S.T., fine let's hear about 
it and I can prepare a defence to it. But if the Crown is not 
going to present such evidence let's take that out so that I 
don't have to prepare a defence against a possible accusation of 
collecting G.S.T. 

MARIN: Well just on that point, Your Honour, may I say this that 
I have already explained to Mr. Turmel what my position was on 
that and it is that we are not alleging that he did pay it. We 
don't know if he did not pay it. We have no information on the 
G.S.T. So what I've told him is that we can't sort of go along on 
an Agreed Statement that he hasn't paid G.S.T. when it has not 
been claimed on him when I don't know if it's true or not. So I'm 
saying if he calls evidence that he hasn't paid G.S.T. I mean 
there's no way for me to contest it at this point but I can't go 
along with an Agreed Statement of Facts on it because I don't 
know. There's no way I can verify that. 

TURMEL: But you don't have any facts that, you know, anyone 
did... I mean is there any evidence at all of any transactions 
with G.S.T. and if there are 1 will know what to defend against. 
Now the Crown is now saying there is no evidence of any G.S.T. 
transaction and that's fine by me as an admission. 

MARIN: Mr. Turmel has received full disclosure of the case. 
There's nothing concerning G.S.T. on it. I'm not aware of 
anything concerning G.S.T. 

COURT: It's not your position, or not your evidence, that Mr. 
Turmel has in fact been called on to collect, or remit, G.S.T. 
You have no evidence of that? 

MARIN: No. Neither do I have evidence to the contrary. 

COURT: Well the absence of evidence is the same as no evidence, 
so there's nothing to establish that. 

MARIN: That he has been called upon to pay G.S.T.? 

COURT: Yes, that's right. 

MARIN: That's right. 

TURMEL: Well that's good enough for me if this counts. 

COURT: Well everything... What Mr. Marin is saying is he has no 
evidence in his possession to show that you've been called upon 
at any time to remit or collect G.S.T. 

TURMEL: Well I'm happy then. 

COURT: So you will not hear that in evidence and presumably not 
in argument because there will be no evidence to support it. 

TURMEL: That one's solved. If we could go back to 20 for just a 
moment. Do I have to prepare any defence at all to an allegation 
that I touched, in any way, the dealers' tips? Oh, one last 
point. One last piece of paper I was given by the Crown's office 
is their short Synopsis of Admission. 

MARIN: Actually there are three things. 

TURMEL: And the third one says I had control of all bank accounts 
and if you remember correctly I didn't have control of the 
dealers' tips account. It was the only bank account I did not 
control and I do believe at the Pre-Trial the officer did admit 
that the dealers' tips had their own account. So that line there, 
in the third one, it can't be control of all accounts, but it 
would be all but one. 

COURT: The matter you have now raised is whether or not you had 
control of all of the bank accounts and your position is there 
was one account over which you had no control and that was the 
tips? 

TURMEL: Yes. That was admitted by the officer at the Pre-Trial. 
Okay. Well that's strictly for bank accounts but point 20 will 
solve my having to call any employees to discuss tips whatsoever. 
That the tips given to the employees were their sole property. 
Does the Crown allege any evidence that I, in any way, touched 
any of those tips. If so, I'll prepare a defence but if there is 
no such evidence that I touched the tips we have another 
admission which saves a lot of work. 

MARIN: Yeah, but I remember going through that, Your Honour, and 
it's not part of the Agreed statement of Facts because it's not 
admitted by the Crown. 
--
Abolitionist Slave Leader John C."The Banking Systems Engineer" Turmel
for UNILETS interest-free time-based currency in U.N. resolution C6
to Governments in the http://www.un.org/millennium/declaration.htm 
http://www.cyberclass.net/turmel 519-756-1325 USENET: can.politics