Electronically issued / Délivré par voie électronique : 20-Apr-2023 Court File No.

/N° du dossier du greffe : CV-23-00698271-0000

Toronto Superior Court of Justice / Cour supérieure de justice

Court File No.

ONTARIO
SUPERIOR COURT OF JUSTICE
B E T W E E N:

HAN DONG
Plaintiff

and

GLOBAL NEWS, a division of CORUS ENTERTAINMENT INC., CORUS

ENTERTAINMENT INC., SAM COOPER, CRAIG OFFMAN, SONIA
VERMA, MACKENZIE GRAY, FARAH NASSER, ANTONY ROBART, and
DAWNA FRIESEN
Defendants

STATEMENT OF CLAIM

TO THE DEFENDANTS

A LEGAL PROCEEDING HAS BEEN COMMENCED AGAINST YOU by the plaintiff. The
Claim made against you is set out in the following pages.

IF YOU WISH TO DEFEND THIS PROCEEDING, you or an Ontario lawyer acting for you
must prepare a statement of defence in Form 18A prescribed by the Rules of Civil Procedure,
serve it on the plaintiff’s lawyer or, where the plaintiff does not have a lawyer, serve it on the
plaintiff, and file it, with proof of service in this court office, WITHIN TWENTY DAYS after
this statement of claim is served on you, if you are served in Ontario.

If you are served in another province or territory of Canada or in the United States of America,
the period for serving and filing your statement of defence is forty days. If you are served
outside Canada and the United States of America, the period is sixty days.

Instead of serving and filing a statement of defence, you may serve and file a notice of intent to
defend in Form 18B prescribed by the Rules of Civil Procedure. This will entitle you to ten
more days within which to serve and file your statement of defence.
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Toronto Superior Court of Justice / Cour supérieure de justice

IF YOU FAIL TO DEFEND THIS PROCEEDING, JUDGMENT MAY BE GIVEN AGAINST

YOU IN YOUR ABSENCE AND WITHOUT FURTHER NOTICE TO YOU. IF YOU WISH
TO DEFEND THIS PROCEEDING BUT ARE UNABLE TO PAY LEGAL FEES, LEGAL
AID MAY BE AVAILABLE TO YOU BY CONTACTING A LOCAL LEGAL AID OFFICE.

TAKE NOTICE: THIS ACTION WILL AUTOMATICALLY BE DISMISSED if it has not been
set down for trial or terminated by any means within five years after the action was commenced
unless otherwise ordered by the court.

Date Issued by
Local Registrar

Address of Superior Court of Justice

court office: 330 University Avenue, 9th Floor
Toronto ON M5G 1R7

TO: Global News, a division of Corus Entertainment Inc.

Corus Quay
25 Dockside Drive
Toronto ON M5A 0B5

AND TO: Corus Entertainment Inc.

Corus Quay
25 Dockside Drive
Toronto ON M5A 0B5

AND TO: Sam Cooper

c/o Global News, a division of Corus Entertainment Inc.

AND TO: Craig Offman

c/o Global News, a division of Corus Entertainment Inc.

AND TO: Sonia Verma

c/o Global News, a division of Corus Entertainment Inc.

AND TO: Mackenzie Gray

c/o Global News, a division of Corus Entertainment Inc.

AND TO: Farah Nasser

c/o Global News, a division of Corus Entertainment Inc.
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Toronto Superior Court of Justice / Cour supérieure de justice

AND TO: Antony Robart

c/o Global News, a division of Corus Entertainment Inc

AND TO: Dawna Friesen

c/o Global News, a division of Corus Entertainment Inc.
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Toronto Superior Court of Justice / Cour supérieure de justice

CLAIM

1. The plaintiff claims as against each defendant, jointly and severally:

(a) general damages in the amount of $5,000,000;

(b) aggravated damages in the amount of $5,000,000

(c) special damages in an amount to be particularized prior to trial;

(d) punitive damages in the amount of $5,000,000;

(e) an interlocutory and permanent injunction, requiring the defendants to remove the

Defamatory Words, defined below, or words of like or similar effect from all

media in their possession, control, or power;

(f) an interlocutory and permanent injunction, prohibiting the defendants from

speaking, publishing, broadcasting, or in any way communicating or

disseminating the Defamatory Words, defined below, or words of like or similar

meaning or effect;

(g) prejudgment interest in accordance with section 128 of the Courts of Justice Act,

R.S.O. 1990, c. C.43, as amended;

(h) postjudgment interest in accordance with section 129 of the Courts of Justice Act,

R.S.O. 1990, c. C.43, as amended; and

(i) the costs of this proceeding, plus all applicable taxes.

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Overview

2. Han Dong is a Member of Parliament (“MP”) and a former Member of Provincial

Parliament (“MPP”) in Ontario. He has devoted over twenty years of his life to public service

and is a dedicated advocate for his constituents, including his Chinese-Canadian constituents. As

one of the first Canadians born in mainland China to be elected to the Legislative Assembly of

Ontario, and one of very few sitting MPs fluent in Mandarin and Cantonese, Dong is a proud role

model for immigrants who aspire to be politicians and public servants. He has worked for

decades to build his good reputation—his career in public service depends on it.

3. The defendants Global News, Sam Cooper, and others have maliciously destroyed Han

Dong’s hard-earned reputation and career and have exposed Dong and his family to a campaign

of hateful messages and threats, including death threats. The defendants have told the public,

directly and by insinuation, that Han Dong is an agent of the People’s Republic of China,

actively involved in election interference networks that seek to undermine Canada’s democracy;

that he used illegitimate tactics to win elections; and that he is a morally bankrupt traitor who

worked to keep two innocent Canadian citizens arbitrarily detained in China.

4. These defamatory allegations—which accuse Han Dong of conduct that any reasonable

person would consider to be utterly offensive and reprehensible—are false. The innocuous truth

is that Han Dong: (i) is a Canadian citizen born in mainland China who speaks fluent Mandarin

and Cantonese; (ii) has enjoyed support from numerous immigrant communities, including the

Chinese-Canadian community, throughout his political career; and (iii) has engaged in routine

diplomatic and advocacy efforts in the interests of his constituents, a significant proportion of
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whom are Chinese-Canadians. Dong has never advocated for the continued imprisonment of

Michael Spavor and Michael Kovrig.

5. Too eager for the bombshell headline, the defendants failed to meet the standards of

responsible journalism when they reported these devastating and untrue claims about Han Dong.

The defendants relied on allegations made by anonymous sources, providing almost no context

about the sources’ backgrounds, positions, and motivations. The defendants failed to report key

facts and contextual information that would have undermined the sources’ credibility and

reliability and the defendants’ biased narrative angle. Most importantly, the defendants published

these defamatory accusations without fulfilling their duty to diligently investigate and scrutinize

them. The defendants failed to verify their allegations that Dong advised the Chinese Consul

General in Toronto to delay releasing Michael Spavor and Michael Kovrig against a transcript or

recording of the conversation in question.

6. Han Dong has been compelled by the defendants’ false, malicious, irresponsible, and

extremely destructive allegations to bring this action to restore his reputation and career, and to

protect himself and his family from further harm.

The parties

The plaintiff

7. Han Dong is the Member of Parliament for the riding of Don Valley North. Until March

22, 2023, he was a member of the Liberal Party of Canada’s caucus. As a result of the

defendants’ defamatory publications and broadcasts, he now sits as an independent MP.

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8. Dong was born in 1977 in Shanghai. His father immigrated to Canada in 1989. In 1990,

when Dong was 13 years old, he and his mother and sister joined his father in Canada.

9. Dong’s family was motivated to leave China for Canada in search of freedom,

opportunity, and democracy, like many others. In 1970, the Chinese state detained Dong’s father

at a state-run forced labour and re-education camp (the May Seventh Cadre School) near

Shanghai because of rumours that he had criticized the Gang of Four, a then-powerful faction of

the Chinese Communist Party. The leaders of the camp forced Dong’s father to perform hard

labour, including plowing the earth with his bare hands, and subjected him to 24-hour

surveillance. When the Gang of Four began to lose their power in 1971, Dong’s father was

released after nearly a year in detention. This experience solidified the family’s determination to

leave China.

10. After arriving in Canada, Dong attended school in downtown Toronto. He began

volunteering with the Liberal Party of Canada in 1995. In 2001, Dong became a Canadian

citizen. Between 2003 and 2005, he worked as a constituency assistant for Maria Minna, then-

MP for the riding of Beaches-East York. From 2005 to 2011, Dong worked as MPP liaison for

Ontario Liberal MPP Gerry Phillips, who held the positions of Minister of Government Services,

Minister of Citizenship and Immigration, and Minister of Energy and Infrastructure, among

others. After Phillips’ retirement, the Minister of Citizenship and Immigration hired Dong as a

senior advisor, due in large part to Dong’s immigrant background and strong relationships with

multiple ethnic communities.

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11. Dong has always been a passionate advocate for newcomer communities, including the

Chinese-Canadian community; providing them with meaningful representation has been a

significant driver for him throughout his political career. As a senior advisor to the Minister of

Citizenship and Immigration, Dong’s primary role was to work with ethnic communities to

understand the everyday effects of government policies. As one of the few political staffers that

spoke fluent Mandarin and Cantonese, he often worked on issues affecting the Chinese-Canadian

community and attended Chinese-Canadian community events. This included developing a

working relationship with the Chinese Consulate General in Toronto on behalf of the cabinet

ministers that he assisted. For example, as senior advisor to the Ontario Minister of Citizenship

and Immigration, he worked with the Chinese Consul General in Toronto to coordinate a visit

between the Vice-Premier of China and then-Premier Dalton McGuinty.

12. In 2013, Dong won the nomination to run as Liberal Party candidate for the Trinity-

Spadina riding and was elected to the Legislative Assembly of Ontario in 2014. He defeated the

incumbent NDP MPP, who had represented the riding (and the previous riding of Fort York) for

24 years. As MPP, he acted as Parliamentary Assistant to the Minister of Advanced Education

and Skills Development, the Minister Responsible for the Poverty Reduction Strategy, and the

Minister of Energy. Dong was a member of the Standing Committee on Finance and Economic

Affairs, the Standing Committee on Estimates, the Standing Committee on Public Accounts, and

the Select Committee on Sexual Violence and Harassment. He was also the Chair of the Cabinet

Committee on Legislation and Regulations.

13. As MPP, Dong was a key member of the team that developed Ontario’s first

postsecondary international education strategy. He also proposed two private members’ bills,
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which led to the eventual passing of the Home Inspection Act and to changes to the elevator

regulations under the Technical Standards and Safety Act.

14. During his time in the Ontario Legislature, Dong was one of only three Chinese-Canadian

MPPs and was the only MPP that spoke both fluent Mandarin and Cantonese. His riding, Trinity-

Spadina, had a high proportion of Chinese-Canadian constituents. Dong was uniquely positioned

to meaningfully represent members of the Chinese-Canadian community, and his office

frequently worked on issues faced by the Chinese-Canadian community. This sometimes

involved liaising with the Chinese Consulate General in Toronto. For example, Dong worked to

promote trade, cultural, and educational exchanges between Ontario and Jiangsu, Ontario’s twin

province in China. Dong attended Chinese-Canadian community events, which the Toronto

Consul General would often attend as well. Dong also joined a delegation to China in 2015 with

then-Premier Kathleen Wynne.

15. After losing his seat in the 2018 provincial election, Dong worked as a consultant on

government relations, marketing, and strategic planning matters.

16. In 2019, Dong won a hard-fought race for the Liberal Party nomination to run in the Don

Valley North riding in the federal election. Dong was then elected MP for Don Valley North in

the 2019 federal election and was re-elected in 2021.

17. As a Member of Parliament, Dong has served as a member of the Human Resources,

Skills and Social Development and the Status of Persons with Disabilities Committee; the

Access to Information, Privacy, and Ethics Committee; the Public Accounts Committee; and the

Industry and Technology Committee. Dong has also served as a member of the Canadian Group
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of the Inter-Parliamentary Union, the Canada-United States Inter-Parliamentary Group, the

Canadian NATO Parliamentary Association, the Canada-Japan Inter-Parliamentary Group, the

Canada-Europe Parliamentary Association, and the Canada-Italy Inter-Parliamentary Group.

18. Dong also co-chairs the Canada-China Legislative Association (“CACN”) with Senator

Paul Massicotte. The mandate of the CACN is to provide a forum for Canadian parliamentarians

and Chinese diplomats and government representatives to discuss issues facing the two countries

and the Asia-Pacific region. Members of the CACN participate in annual meetings between

Canadian and Chinese state representatives, the Asia-Pacific Parliamentary Forum, and the

General Assembly of ASEAN Inter-Parliamentary Assembly. As part of their role as CACN co-

chairs, Dong and Massicotte also meet with the Chinese Ambassador and Consul General. In

addition, Dong co-chairs the Canada-Armenia Parliamentary Friendship Group and is a director

of the Canada-Ukraine Parliamentary Friendship Group.

19. Dong’s riding of Don Valley North also has a high proportion of Chinese-Canadian

constituents. To effectively represent his constituents, Dong’s office works with the Chinese

Ambassador to Canada and the Chinese Consulate General in Toronto. For example, Dong’s

constituents contact his office from time to time seeking assistance with obtaining emergency

visas to travel to China. Dong’s office liaises with the Consulate General to facilitate this

process, and was especially involved in doing so during the COVID-19 pandemic, when

obtaining visas to visit family in China became more difficult. Dong’s office also assists other

constituent communities in his riding by communicating with diplomatic and consular officials

from other countries. For example, Dong’s office communicates with the Ambassador of the
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Republic of Armenia to Canada to assist the large population of Armenian-Canadians who live in

his riding.

20. Due to Dong’s fluency in both Mandarin and Cantonese, the Liberal Party has often

trusted him with communicating to the Chinese-Canadian community. For example, Dong has

been interviewed in Chinese language media on major issues and events like the federal budget

and Asian Heritage Month. In 2020, Dong co-chaired a meeting between local Chinese-Canadian

businesses, Restaurants Canada, and several Chinese-Canadian business associations to discuss

the impacts of the COVID-19 pandemic and anti-Asian racism.

21. As one of very few provincial and federal representatives born in China, Dong is proud to

have served as a role model for those from immigrant backgrounds interested in politics and

public service, particularly Chinese-Canadians. Dong has devoted two decades of his life to

public service and intends to continue this work for as long as he can.

22. The defendants’ extremely damaging, false, and defamatory claims about Dong have all

but destroyed his future in politics. Dong is compelled to bring this claim to restore his

reputation and protect that future.

The defendants

23. The defendant Corus Entertainment Inc. (“Corus”) is a multinational media and

entertainment conglomerate with activities in radio, publishing, and television.

24. The defendant Global News is a Canadian television and online news broadcaster. It

operates Global National and Global News Morning, two national news broadcasts, and 21 local
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news networks across the country. It also operates globalnews.ca, a website that publishes news

and investigative journalism articles. Global News is a division of Corus. Global News published

and broadcast the Defamatory Articles and Defamatory Broadcasts, defined below.

25. The defendant Sam Cooper is a Global News national online investigative journalist

based in Ottawa. He graduated from Langara College with a one-year journalism certificate.

Cooper frequently reports on issues of foreign influence, financial crime, and political corruption

in the Chinese-Canadian community. Since August 2022, he has published a series of articles on

Global News relating to interference by the Chinese state in Canada. He has a very active Twitter

page in which he engages with discussions on similar topics and republishes his writing. Cooper

is the author of the book Wilful Blindness: How a network of narcos, tycoons, and CCP agents

infiltrated the West. Cooper authored and published the Defamatory Articles and appeared in the

Defamatory Broadcasts.

26. The defendant Sonia Verma is Global News’ Editor-in-Chief. Verma reviewed and

approved the Defamatory Articles and Defamatory Broadcasts.

27. The defendant Craig Offman is Global News’ managing editor for the Enterprise and

Investigations division. Offman reviewed and approved the Defamatory Articles and Defamatory

Broadcasts.

28. The defendant Mackenzie Gray is a senior digital broadcast journalist at Global News. He

appeared in the Defamatory Broadcasts. He was involved in authoring, editing, producing, or

approving at least some of the Defamatory Words.

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29. The defendant Antony Robart is the anchor of Global News Morning Toronto. He

appeared in the Defamatory Broadcasts and interviewed Mackenzie Gray and Sam Cooper. He

was involved in authoring, editing, producing, or approving at least some of the Defamatory

Words.

30. The defendant Dawna Friesen is the chief anchor and executive editor of Global National.

She appeared in the Defamatory Broadcasts and interviewed Mackenzie Gray. She was involved

in authoring, editing, producing, or approving at least some of the Defamatory Words.

31. The defendant Farah Nasser is an anchor of Global National. She appeared in the

Defamatory Broadcasts and interviewed Mackenzie Gray and Sam Cooper. She was involved in

authoring, editing, producing, or approving at least some of the Defamatory Words.

The defendants’ Defamatory Articles and Broadcasts

32. The defendants published and broadcast (or participated in, authorized, permitted, or

condoned the publication and broadcast of) a series of false, malicious, irresponsible, and

defamatory articles and broadcasts concerning Han Dong.

The Defamatory Articles

33. The defendants are jointly and severally liable for the publication of the following

defamatory articles:

(a) On February 25, 2023, Sam Cooper authored an article published on

globalnews.ca headlined “Liberals ignored CSIS warning on 2019 candidate

accused in Chinese interference probe: sources”.

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(b) On March 22, 2023, Sam Cooper authored an article published on globalnews.ca

headlined “Liberal MP Han Dong secretly advised Chinese diplomat in 2021 to

delay freeing Two Michaels: sources”.

34. The words in the February 25 and March 22 articles (the “Defamatory Articles”) are

false and defamatory of Han Dong in their natural and ordinary meaning, as well as by inference

or innuendo. Each Defamatory Article listed above is also defamatory of Dong when viewed in

its entirety, including all accompanying headlines, displays, graphics, captions, links, and videos.

The Defamatory Broadcasts

35. The defendants are jointly and severally liable for the broadcast and publication of the

following news segments and videos:

(a) On February 24, 2023, Global News published a video on globalnews.ca

headlined “Liberal MP allegedly tied to Chinese interference: sources”. Farah

Nasser, Mackenzie Gray, and Sam Cooper appear as journalists in this video. This

video was originally broadcast on the February 24, 2023 television broadcast of

Global National. Global News also published this video on YouTube.

(b) On March 22, 2023, Global News published a video on globalnews.ca headlined

“MP denies affiliation with China interference”. Antony Robart and Mackenzie

Gray appear as journalists in this video. This video was originally broadcast on

the March 22, 2023 television broadcast of Global News Morning.

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(c) On March 22, 2023, Global News published a video on globalnews.ca headlined

“Liberal MP Han Dong secretly advised Chinese diplomat in 2021 to delay

freeing Two Michaels: source”. Dawna Friesen and Mackenzie Gray appear as

journalists in this video. This video was originally broadcast on the March 22,

2023 television broadcast of Global National. Global News also published this

video on YouTube.

(d) On March 23, 2023, Global News published a video on globalnews.ca headlined

“Han Dong to sit as Independent MP following ‘serious’ allegations”. Antony

Robart, Sam Cooper, and Mackenzie Gray appear as journalists in this video. This

video was originally broadcast on the March 23, 2023 television broadcast of

Global News Morning.

36. The words in the videos posted on February 24, March 22, and March 23 and in the

associated broadcasts (the “Defamatory Broadcasts”) are false and defamatory of Han Dong in

their natural and ordinary meaning, as well as by inference or innuendo. Each Defamatory

Broadcast listed above is also defamatory of Dong when viewed in its entirety, including all

accompanying headlines, displays, graphics, captions, links, and videos.

The Defamatory Words and their meanings

37. The particular words in the Defamatory Articles and Defamatory Broadcasts to which

Dong objects (the “Defamatory Words”) are attached as Schedule A.

38. The Defamatory Words mean and were understood in their natural and ordinary meaning

or by inference or innuendo to mean that:

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(a) Han Dong knowingly participated in and was a “witting affiliate” of the Chinese

state’s election interference networks and efforts in Canada;

(b) Canadian national security officials tracked Dong because he in fact was a

“witting affiliate” of the Chinese state’s vast election interference networks and

efforts in Canada;

(c) Dong is a suspicious, nefarious, and untrustworthy character who has been

tracked by Canadian national security officials;

(d) Dong is knowingly supported by the Chinese state;

(e) Dong’s support from Chinese-Canadian individuals and community groups

indicates that he is being supported by the Chinese state;

(f) Dong benefitted from election interference conducted by the Chinese state,

particularly in the race for the Liberal Party nomination in Don Valley North;

(g) Dong was able to run for the Liberal Party nomination in Don Valley North in

2019 because agents of the Chinese state orchestrated a campaign which forced

the incumbent to withdraw his nomination;

(h) Dong was aware of, complicit in, or participated in the campaign orchestrated by

the Chinese state which forced the incumbent to withdraw his nomination;
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(i) Dong was able to run for the Liberal Party nomination in Don Valley North in

2019 because agents of the Chinese state influenced the Liberal Party to support

him;

(j) Dong was aware of, complicit in, or participated in the Chinese state influence of

the Liberal Party;

(k) Michael Chan’s support of Dong’s candidacy for the Liberal Party nomination in

Don Valley North in 2019 indicates that Dong’s candidacy was supported by the

Chinese state;

(l) Dong and Michael Chan’s close contact indicates that they together are part of the

Chinese state’s election interference networks and efforts in Canada;

(m) Chinese state-led voter fraud and coercion helped Dong win the Liberal Party

nomination in Don Valley North in 2019;

(n) Dong was aware of, complicit in, or participated in the Chinese state-led voter

fraud and coercion that helped him win the Liberal Party nomination in Don

Valley North in 2019;

(o) Dong won the Liberal Party nomination in Don Valley North in 2019 in part

because Chinese international students were supplied with fake addresses, brought

to the riding, and coerced to vote for him by Chinese officials;

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(p) Dong won his nomination as an MP in part because Chinese-Canadian seniors

who had Dong’s name hidden under their sleeves were brought to the riding and

coerced to vote for him;

(q) Dong is an agent of the Chinese state;

(r) Dong colluded and conspired with Chinese diplomats to advance China’s

interests;

(s) Dong used his public office to advance China’s interests in Canada;

(t) Dong is directed by Chinese state officials;

(u) Dong pressured an MP not to travel to Taiwan because doing so would not have

been in line with China’s policy goals;

(v) Dong intended to meet and did meet with individuals from Chinese state groups

that engage in foreign interference such as the United Front Work Department;

(w) Dong’s candidacy for the Liberal Party nomination in Don Valley North in 2019

was a threat to Canada’s democratic institutions and national security;

(x) Dong advised the Chinese Consul General in Toronto that China should “hold off

freeing” Michael Kovrig and Michael Spavor;

(y) Dong advocated for the continued arbitrary imprisonment of two innocent people

without due process and in denial of their basic human rights;

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(z) Dong acted improperly, covertly, and outside of appropriate diplomatic channels

when speaking with the Chinese Consul General in Toronto;

(aa) Dong used the arbitrary imprisonment of Michael Kovrig and Michael Spavor in

an attempt to benefit himself and his political party;

(bb) Dong’s advice to the Chinese state influenced the Chinese state to hold a secret

trial of Michael Kovrig and Michael Spavor;

(cc) Dong’s relationship with Chinese diplomats is nefarious and suspicious;

(dd) Dong’s relationship with Chinese diplomats indicates that he is being directed by

Chinese officials or is colluding with Chinese officials;

(ee) Dong is unfit and unworthy for public office;

(ff) Dong cannot properly fulfill his duties as an MP;

(gg) Dong betrayed Canada;

(hh) Dong betrayed Michael Kovrig and Michael Spavor;

(ii) Dong is a traitor;

(jj) Dong is deceitful;

(kk) Dong has committed crimes of dishonesty including involving election fraud;

(ll) Dong is immoral;

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(mm) Dong advocates for the abuse of human rights and rights to due process;

(nn) Dong was aware of, complicit in, or participated in efforts to subvert Canadian

democracy;

(oo) Dong is disloyal to Canada;

(pp) Dong is loyal to China’s authoritarian state;

(qq) Dong is a threat to Canadian citizens; and

(rr) The allegations made by the anonymous sources against Dong are true.

39. The above meanings and innuendos, Defamatory Words, Defamatory Articles, and

Defamatory Broadcasts (the “Defamatory Content”) lower Han Dong’s reputation in the eyes

of a reasonable person and have also subjected and will continue to subject Dong and his family

to hatred, contempt, and ridicule. They have caused and will continue to cause serious damage to

Dong’s personal reputation and reputation in the way of his office and profession.

Repetition by the defendants

40. The defendants have repeated, republished, and rebroadcast the Defamatory Content on

many occasions and across many platforms, including on YouTube, Twitter, and through links

and videos embedded in other articles. These repetitions and republications remain available on

globalnews.ca and other websites and applications as of the date of this claim. Further, the

defendants have persistently defended their reporting, explicitly or impliedly asserting the truth

of the Defamatory Words.

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Republication and rebroadcasting by others

41. The defendants, individually and together, intended and knew or ought to have known

that the Defamatory Content would be widely republished and rebroadcast in other publications,

broadcasts, and on social media platforms across Ontario, Canada, and throughout the world (as

they in fact were). For example, the Defamatory Content has been republished by CBC, National

Post, Toronto Star, BBC, the Guardian, and Al Jazeera. Widespread republication of the

defendants’ defamatory allegations is the predictable result of reporting incendiary accusations

against a sitting MP. The defendants are accordingly jointly and severally liable for all

republication and rebroadcast of the Defamatory Content.

The defendants acted irresponsibly by publishing the Defamatory Content

42. Due to the seriousness of the allegations against Han Dong—which include claims that

he attempted to subvert Canada’s democratic processes, acted as a foreign agent, and is a

traitor—the defendants had a duty to thoroughly research, investigate, and scrutinize the veracity

of the anonymous sources’ comments before publishing them. The defendants also had a duty to

report information of which they were aware or could reasonably ascertain that was inconsistent

with or raised questions about the anonymous sources’ allegations.

43. The defendants failed to fulfil these duties. On the contrary, the Defamatory Articles and

Defamatory Broadcasts are insufficiently researched and replete with bald allegations that lack

evidentiary support. These allegations were made by anonymous sources whose credibility and

reliability were assumed, rather than vigorously tested. The Defamatory Articles and Defamatory

Broadcasts also contain easily identifiable errors and omit key facts and context that would have
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created a more balanced and fairer story had they been included. There was no urgency to

publish the Defamatory Articles and Defamatory Broadcasts that could have justified any of

these failures.

44. Under these circumstances, a responsible journalist would not have published the

Defamatory Content.

45. The below examples illustrate some of the ways in which the defendants failed to meet

the standards of responsible journalism.

The defendants portray the allegations of their anonymous sources as fact

46. The defendants’ Defamatory Content is based on allegations made by anonymous

sources, which the defendants deliberately or recklessly portray as credible, reliable, and true.

The defendants vaguely describe their anonymous sources as “intelligence” and “national

security” sources, without providing details about the sources’ occupation or seniority, for

example, and without explaining the sources’ motivations and why they should be considered

credible and reliable. Most importantly, the defendants do not specify how the sources came to

know the allegations against Dong: the sources could have direct, personal knowledge of the

allegations, or they could be relying on many levels of hearsay.

47. Intelligence is not fact nor is it inherently trustworthy. Rumours about the existence of

intelligence are even less trustworthy. By identifying the anonymous sources with Canada’s

intelligence and national security apparatus without providing basic contextual information, the

defendants deliberately give their sources (who are willing to destroy Han Dong’s reputation

based on suspicion, but will not risk their own) more credibility and authority than they are
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owed. Further, the defendants do not explicitly and clearly state in all of the Defamatory Articles

and Defamatory Broadcasts that they have not independently verified the sources’ allegations.

The defendants deliberately or recklessly chose not to caveat all of their reporting with this key

disclaimer, creating the impression that the allegations are true.

Dong’s campaigns were funded by Canadian citizens and permanent residents

48. Han Dong has complied with election finance requirements throughout his political

career. He has never received election funding from the Chinese state. In 2019, 2020, and 2021,

election contributions to federal candidates could not exceed $1,600, $1,625, and $1,650,

respectively, and were limited to Canadian citizens or permanent residents. Companies and

political groups were not and are not permitted to make election contributions. Nor are foreign

governments.

49. To his knowledge, Dong has also never received campaign contributions that originated

from the Chinese state. His campaigns have taken prudent steps to ensure that election funding

requirements are complied with, and funds come from legitimate sources.

50. As required by the Canada Elections Act, Dong’s nomination and election campaigns

have always employed a financial agent who administers and reports his campaigns’ financial

transactions, including contributions to him and his riding association. Dong also appoints an

auditor for each of his campaigns who audits the financial transaction reports. Dong’ financial

agent submits both the financial transaction report and audit to the Chief Electoral Officer at

Elections Canada and to the Liberal Party. If the Chief Electoral Officer identifies any potential
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issues with a contribution, it contacts Dong’s financial agent. Elections Canada has not found

any problematic donations made to Dong’s campaigns.

Dong’s nomination was not “suspicious”

51. The Defamatory Articles and Defamatory Broadcasts suggest that Han Dong’s

nomination as the Liberal MP for Don Valley North was the result of a campaign led by the

Chinese state. This is untrue.

52. Dong did not cause and is unaware of any plots (Chinese state-led or otherwise) to cause

the withdrawal of Geng Tan as Liberal Party candidate for the 2019 election. Dong did not have

a close relationship with Geng Tan. He did not pressure him not to travel to Taiwan—

particularly not at the behest of Chinese consular officials.

53. Dong ran for nomination as the Liberal Party candidate in Don Valley North against

Bang-Gu Jiang. David Caplan, a former Liberal Minister of Health for Ontario, intended to run

for the nomination, but sadly passed away before formally launching his campaign. Laura

Huang, Geng Tan’s wife, had also applied for the nomination, but her application was turned

down by the Liberal Party.

54. The contest between Dong and Jiang was hard fought and Dong ultimately prevailed by

fewer than 50 votes. The defendants deliberately or recklessly did not mention any of these facts

in the Defamatory Articles and Defamatory Broadcasts in order to bolster their angle implicating

Dong with Chinese interference.

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Dong was not complicit in or a beneficiary of voter fraud

55. To facilitate voter turnout in the 2019 Liberal Party nomination race, Han Dong’s

campaign rented buses to transport voters who needed a ride to the polling station. This included

transporting Chinese-Canadian, Iranian-Canadian, and other seniors from retirement homes

within the riding to polling stations.

56. Contrary to the innuendo conveyed by the defendants’ Defamatory Articles and

Broadcasts, there was nothing nefarious or covert about this: Dong’s campaign reported the

expense of renting these buses on its campaign report. Providing transportation to those who

cannot otherwise access polling stations is common practice among those running for public

office—a fact that the experienced political reporters at Global News knew or ought to have

known. The defendants deliberately or recklessly neglected to report that Dong’s opponent in the

Liberal Party nomination race for Don Valley North also provided transportation to get voters to

and from the polls.

57. Since many of these seniors did not speak or read English, Dong’s staff told them that

Dong’s name would be first on the ballot. To claim that seniors were “told” to vote for Dong

casts a misleading cloud of suspicion and wrongdoing over this innocuous (and inclusive)

practice. Dong did not tell any voters to write his name on their arms, nor is he aware of voters

doing so.

58. Dong did not bring seniors into his riding who did not live there, nor did he force them

from their retirement residences onto the buses and coerce them to vote for him, as the

defendants’ reporting suggests. The seniors who voted for Dong chose to support him. Dong’s
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campaign facilitated their access to the polls and helped them vote in a language they did not

speak, as any other campaign would have done.

59. Far from the allegations in the Defamatory Articles and Broadcasts that Dong benefitted

from sweeping voter fraud in the 2019 nomination race, he won by a margin of less than 50

votes.

60. The allegations that Dong was complicit in and benefited from a Chinese state-led

campaign to extort Chinese international students who did not live in Dong’s riding to vote for

him using fake addresses are similarly false and outrageous. Dong encourages international

students to get involved in his campaign as volunteers to give them the opportunity to learn about

the democratic process in Canada, not to subvert it.

61. The defendants failed to note in their reporting that it would be very difficult to

coordinate the alleged voter fraud in the first place for the following reasons, at a minimum:

(a) To vote in a Liberal nomination race, a voter must be a registered Liberal.

(b) To register, a prospective Liberal must submit a valid home address at least one

week prior to voting day. In the week prior to voting day, each candidate’s

campaign can scrutinize the list of eligible voters issued by the Liberal Party. A

candidate’s campaign will typically challenge anything on the list that strikes

them as suspicious (for example, if a large number of voters have registered with

the same address).

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(c) To vote on voting day, a voter must bring a piece of ID that shows a photo, name,

and home address matching the address they used to register; two pieces of ID, at

least one of which must have a valid address matching the address they used to

register; or have another registered Liberal with piece of ID that shows their home

address vouch for the voter’s address. A registered Liberal may only vouch for

one other registered Liberal, or up to five if they are immediately family living in

the same household.

(d) On voting day, scrutineers from each candidate’s campaign can again challenge

voter eligibility, including based on IDs, providing an additional layer of

protection against illegitimate voting.

62. The Defamatory Articles and Defamatory Broadcasts also illogically state that the

Chinese Consulate General told the Chinese international students to vote for Dong or risk their

student visa status. The Canadian government, not the Chinese state, determines the visa status

of an international student studying in Canada.

63. Again, the above are all facts that the experienced political reporters at Global News

knew or ought to have known and could have easily discovered. The defendants deliberately or

recklessly did not mention any of these facts in the Defamatory Articles and Defamatory

Broadcasts because they undermine the credibility of the sensational voter fraud allegations.

These facts should have served as a clear warning to the defendants that the anonymous sources

they were relying on were not credible or reliable.

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64. Further, the defendants intentionally or recklessly used misleading images in their

Defamatory Articles and Defamatory Broadcasts to lend a false sense of credibility and

reliability to their allegations. In the February 24 Defamatory Broadcast, the defendants overlaid

photographs of buses from an October 2019 event run by Dong’s campaign while discussing the

allegations that Dong’s campaign bused in seniors and students from outside the riding and

coerced them to vote for him in the September 2019 Liberal nomination race. In the February 25

Defamatory Article, the defendants also included a photograph of Dong with students directly

above the paragraph discussing the allegation that Chinese international students were bussed

into the riding and coerced to vote for Dong. This photograph depicts volunteers on Dong’s

campaign, and the photos were taken after Dong won the Liberal Party nomination (as the date

shown in the photo’s caption indicates).

65. The defendants took these photos from Dong’s public Facebook page, where each photo

is clearly labelled with the date. Additionally, both photos feature Liberal Party signs bearing

Dong’s name, indicating that they were taken after Dong won the Liberal Party nomination. The

photos do not provide evidence to support the defendants’ voter fraud allegations, and to use

them in a manner that suggests they do is misleading and irresponsible. The defendants knew

that they were misleading the audience about the true context of the photos.

Dong went to New York for a Buddhism conference, not to meet the United Front
Work Department

66. Han Dong is a practicing Buddhist. He travelled to New York City to attend a trilateral

Buddhism conference with Buddhist leaders from China, Canada, and the United States. Dong
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attended this event on the invitation of the Venerable Dayi Shi, the President of the Buddhist

Association of Canada and the Abbot of Cham Shan Temple in Thornhill.

67. Dong made this trip in February 2019 in his personal capacity, when he was not an

elected government official. Dong did not make this trip to meet with the United Front Work

Department, nor did he knowingly meet any member of the United Front Work Department on

his trip.

68. The defendants’ failure to provide any context whatsoever to the allegation that Dong

met with a United Front member, and to investigate or report on any of the above context,

demonstrates that the defendants’ reporting lacked diligence and was imbalanced and dishonest.

Dong properly communicated with Chinese diplomats in his capacity as MP

69. The Defamatory Articles and Defamatory Broadcasts suggest that Dong had a nefarious

and improper relationship with Chinese diplomats. This is untrue. It is common practice for MPs

and MPPs to speak with diplomats as part of their work, particularly if their constituents require

access to services provided by these diplomats. For example, as part of his duties as an MPP and

MP, Dong’s office liaised with the Chinese Embassy and the Chinese Consulate General in

Toronto to expedite travel visas to China on behalf of Dong’s constituents in Trinity-Spadina and

Don Valley North.

70. Dong and Senator Massicotte also spoke with Chinese diplomats in their capacities as co-

chairs of the Canada-China Legislative Association. These conversations were recognized

methods of diplomatic communication. Prior to some of these calls, Dong’s office would seek

advice from Global Affairs Canada on Canada’s policy positions and key speaking points so that
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he could clearly deliver these positions to foreign diplomats. From time to time, Dong’s office

would provide notes from these calls to Global Affairs Canada.

71. As MP, Dong developed working relationships with diplomats from several countries.

Due to the high proportion of Armenian-Canadians in the Don Valley North riding and Dong’s

membership in the Canada-Japan Inter-Parliamentary Group, he has communicated with the

Armenian and Japanese Ambassadors to Canada. Dong has also taken part in delegations to Sri

Lanka at the invitation of the High Commissioner of Sri Lanka to Canada, and has met with the

Ambassador of Thailand to Canada during the Asia Pacific Parliamentary Forum. As a member

of the Canada-Ukraine Parliamentary Friendship Group, Dong has met with Ukrainian

parliamentarians to discuss the Russian invasion of Ukraine.

72. The fact that politicians liaise with diplomats as a routine aspect of their work, that Dong

is co-chair of the Canada-China Legislative Association, and that Dong has relationships with

diplomatic officials representing countries other than China are facts that the experienced

political reporters at Global News knew or ought to have known and could have easily

discovered. The defendants deliberately or recklessly neglected to report these facts because they

would have weakened the implication that Dong communicating with diplomatic officials (at

least those who represent China) is inherently suspicious and suggests he colluded with them.

73. The defendants also bolstered the false narrative that Dong had a nefarious relationship

with Chinese diplomats by failing to provide any context to their allegations that Dong

“frequently” called Chinese officials in Ontario and was a “close” friend of the Chinese

Consulate in Toronto. Dong’s relationships with the Chinese Ambassador and the Consul
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General are professional; they are not close friends. To the best of Dong’s knowledge, he had

phone conversations with the Consul General five times and the Ambassador seven times

between 2020 and 2022. Either the defendants did not do the work they ought to have done to

determine what their sources meant by “frequently” (which would be careless, at a minimum), or

the defendants intentionally embellished this allegation (which would be deceitful and

malicious).

Dong advocated for an end to the arbitrary imprisonment of Michael Spavor and
Michael Kovrig

74. When Han Dong had the opportunity to speak with Chinese diplomats during the period

in which Michael Spavor and Michael Kovrig were arbitrarily detained in China, he advocated

for the two Canadians’ speedy release and for improvements in the conditions of their

imprisonment. For example:

(a) In February 2020, Dong and Senator Massicotte spoke with the Chinese

Ambassador and advocated for the release of and improved conditions for

Michael Spavor and Michael Kovrig.

(b) During a May 20, 2020 call with the Chinese Ambassador, Dong advocated for

the release of Michael Spavor and Michael Kovrig.

(c) During a July 21, 2021 call with Han Tao, the Chinese Consul General in

Toronto, Dong advocated for the release of Michael Spavor and Michael Kovrig.

75. On February 19, 2021, around the time of Chinese New Year, Dong and Tao had a phone

conversation at approximately 5:30PM. This conversation was in Mandarin because the Consul
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General is not fluent in English. Although Dong does not have notes from that call, he is certain

that he did not (and would never) advocate for the continued arbitrary detention of Michael

Spavor and Michael Kovrig.

76. While this would be a vile thing for anyone to do, it would be a particularly shocking and

bizarre thing for Han Dong to do. A significant factor that motivated Dong’s family to leave

China and come to Canada was his father’s subjection to forced labour and re-education at the

hands of the Chinese state.

77. The allegations in the Defamatory Articles and Defamatory Broadcasts that Han Dong

tried to extend the imprisonment of Michael Spavor and Michael Kovrig, acting against their

interests and against Canada’s interests, are so offensive, outrageous, and devastating that a

responsible journalist would be required and expected to exercise an extremely high degree of

diligence in verifying them before reporting. The obligation to verify was heightened for at least

two other reasons:

(a) The allegations are illogical on their face. It does not make sense that releasing

Michael Spavor and Michael Kovrig while the Liberals were in power and facing

heavy criticism over their inability to secure a release would benefit the

opposition Conservatives. The defendants did not even attempt to provide an

explanation for this apparent absurdity, which should have raised serious

questions about the credibility and reliability of their anonymous sources.

(b) The defendants knew or ought to have known that the call took place in a specific

cultural context and in Mandarin. There was an obvious risk that Canadian
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intelligence “sources” could have interpretative challenges in this context. This

also required the defendants to take extra caution, which they failed to do.

78. Under these circumstances, no journalist could responsibly report these allegations—

which communicate to the public that Han Dong is a morally depraved traitor—without directly

verifying them. It is telling that other journalists chose not to report them. Instead, the defendants

relied on two “separate” anonymous sources who may not have even verified the allegations

directly themselves: the reader does not know how many levels of hearsay lie beneath these

devastating accusations, because the defendants neglected to explain it to them.

The defendants omitted key facts and did not take vital investigative steps

79. In addition to the examples of the defendants’ irresponsible journalism outlined above,

the defendants intentionally or recklessly omitted further key pieces of information to create the

impression that Han Dong is a “witting affiliate” in Chinese foreign interference schemes. This

resulted in unfair and imbalanced reporting.

80. The defendants failed to independently investigate or corroborate the anonymous

sources’ allegations, many of which are easily disprovable. Many of the Defamatory Articles and

Defamatory Broadcasts do not include any disclaimers or notes about the unverified nature of the

sources’ allegations. In this way, the defendants elevated their allegations by omission.
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The defendants did not review a transcript or recording of the conversation

between Dong and Tao

81. The defendants’ lack of diligence is most apparent in their decision to publish the

Defamatory Articles and Defamatory Broadcasts without access to a transcript or recording of

the February 2021 conversation between Dong and the Chinese Consul General of Toronto.

82. By contrast, Robert Fife and Steven Chase of the Globe and Mail apparently received the

same allegations about the conversation from anonymous sources but made a different decision.

In an article published on March 23, 2023, they wrote that “The Globe did not report on the

alleged contents of this conversation because it was unable to obtain transcripts or a tape

recording to authenticate what actually transpired.”

The Prime Minister’s Office found that there was “no actionable evidence”
against Dong

83. The article by Fife and Chase also provides vital pieces of information that were omitted

by the defendants and that contradict the defendants’ anonymous sources. Fife and Chase wrote:

The Trudeau government determined that there was no ‘actionable evidence’ after
it received a CSIS transcript of an early 2021 conversation between Liberal MP
Han Dong and China’s top diplomat in Toronto, according to a senior government
source – saying conclusions could not be drawn that Mr. Dong asked Beijing to
keep two Canadians in prison for political reasons.

84. The defendants did not include this information in the Defamatory Articles or

Defamatory Broadcasts. The defendants either failed to thoroughly investigate and seek the

assessment of the Prime Minister’s Office about the conversation or misrepresented the response

they received from the Prime Minister’s Office. The information is highly relevant and seriously
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undermines the credibility and reliability of the defendants’ anonymous sources. It should have

been reported.

Many public figures attended Dong’s 2019 Liberal nomination press conference

85. The February 25 Defamatory Article states that Dong and Michael Chan—another

individual that the defendants have implicated in Chinese interference networks—held a press

conference for “Chinese media” when Dong announced he would seek the Liberal nomination in

Don Valley North in 2019. The defendants purposely omit that Gerry Phillips (former MPP for

Scarborough-Agincourt), Jonathan Tsao (former city councillor for Don Valley East), Sharifa

Khan (former president of the Chinese Canadian Liberal Association), and Reza Moridi (former

MPP for Richmond Hill) also attended the press conference. Michael Chan’s attendance at the

press conference as a former MPP for Markham-Unionville is not suspicious.

86. The photo that the defendants selected from this press conference to be the banner image

for the February 25 Defamatory Article reveals their bias. Of numerous photos from this event,

the defendants selected one of the few that prominently featured both Michael Chan and Han

Dong. The defendants deliberately cropped Sharifa Khan out of this photo to create the

impression that Chan’s support of Dong was of outsized importance and was insidious.

Dong has criticized the Chinese state on many occasions

87. The February 24 Defamatory Broadcast alleged that Chinese interference “creates a bond

of obligation for the candidates it supports” so that “these Canadian politicians won’t criticize

China on human rights issues”. The defendants did not report on the instances in which Dong

criticized Chinese policies or voted against China’s policy interests. For instance, at the
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November 16, 2020 meeting of the Standing Committee on Access to Information, Privacy and

Ethics, Dong moved for the Committee to “study ways to further protect Canada's democratic

and electoral institutions from cyber and non-cyber interference”, which was ruled in order.

88. In Parliament, Dong also voted for motions to:

(a) “strongly condemn the unacceptable sanctions imposed by the People's Republic

of China against one of the Committee's Vice Chairs, the Member of Parliament

for Wellington—Halton Hills, and the House of Commons Subcommittee on

International Human Rights which represent an affront to Canada's democracy

and parliamentary system”;

(b) support “the full participation of Taiwan in the World Health Assembly (WHA)

and the World Health Organization (WHO)”; and

(c) call “for dialogue between representatives of the Tibetan people (his Holiness the

Dalai Lama or his representatives and/or the Central Tibetan Administration) and

the government of the People's Republic of China with a view to enabling Tibet to

exercise genuine autonomy within the framework of the Chinese constitution.”

89. Dong has also been a vocal critic of China’s zero COVID policy. In April 2022, Dong

spoke out on WeChat against the extreme COVID lockdowns in Shanghai and urged affected

Canadians to connect with the Canadian Consulate in Shanghai.

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Senior government officials have explicitly contradicted or clarified key aspects of

the Chinese interference allegations

90. In addition, the defendants intentionally or recklessly omitted highly relevant testimony

from senior government officials that did not support the allegations in their defamatory

reporting. For example:

(a) In December 2022, Jody Thomas, the Prime Minister’s national security advisor

unequivocally testified at the House of Commons defence committee that “The

news stories that you have read about interference are just that, news stories…We

have not seen money going to 11 candidates, period.”

(b) During the March 2, 2023 meeting of the Standing Committee on Procedure and

House Affairs (“PROC”), Michael Duheme, Deputy Commissioner of Federal

Policing at the RCMP, testified that “We are not investigating any elements from

the 2019 and 2021 elections. We did not receive any actionable intelligence that

would warrant our initiating a criminal investigation.”

(c) During the same PROC meeting, David Vigneault, Director of the Canadian

Security Intelligence Service (“CSIS”), testified that the government officials

briefed on foreign interference concluded that there had been no incidents of

interference that threatened the integrity of the 2019 and 2021 elections.

(d) During the March 1, 2023 meeting of the PROC Committee, Shawn Tupper,

Deputy Minister of Public Safety and Emergency Preparedness, testified that the

RCMP has assessed the evidence of foreign interference and has “concluded that
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they will not pursue a criminal investigation.” Mr. Tupper additionally testified

that “I can confirm that the RCMP is not investigating any of the allegations

arising from the last election.”

91. Even though this testimony directly contradicts or provides important clarification to key

aspects of the defendants’ allegations, the defendants did not mention it in the Defamatory

Articles or Defamatory Broadcasts. Instead, the defendants identified Han Dong as one of the

alleged 11 candidates that received support from the Chinese state.

92. Had the defendants exercised an appropriate level of diligence and editorial oversight,

and maintained the appropriate levels of journalistic integrity expected of a sophisticated national

media organisation like Global News and Corus, the Defamatory Articles and Defamatory

Broadcasts would not have been published.

93. Indeed, since the defendants published the March 22 Defamatory Article, a number of

journalists have publicly questioned the anonymous sources’ credibility and reliability and the

defendants’ adherence to journalistic standards. They have noted the media’s history of treating

intelligence information as fact and the consequences of this dangerous approach on individuals

like Maher Arar. They have also criticized the manner in which the defendants sensationally

framed potentially innocuous facts as insidious allegations (as described above).

94. The Defamatory Articles and Defamatory Broadcasts violated Global News’ own

journalist principles and practices. Far from adhering to the foundations of “integrity, fairness,

and transparency”, the defendants manipulated and omitted facts to suit their narrative. While the

defendants purport to be committed to “reporting news without distortion or misrepresentation”,

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the Defamatory Articles and Defamatory Broadcasts are rife with both. In this instance, Global

News wanted to “get it first” rather than “get it right.”

The Defamatory Content had a devastating impact on Han Dong

95. The Defamatory Content has subjected and will continue to subject Dong and his family

to ridicule, hatred, risk to personal safety, and contempt. The Defamatory Content has caused

and will continue to cause damage to their reputation.

96. The defendants’ false accusations concerning Han Dong go to the core of his reputation

as an elected public official. The Defamatory Content portrays Dong as an immoral traitor who is

loyal to China and who has attempted to undermine Canada’s democracy, deliberately calling

into question his very presence in Canada’s Parliament. As a result, to avoid distracting from the

business of Parliament and the Liberal caucus, Dong has been forced to sit as an independent

MP.

97. The Defamatory Content has inflicted lasting damage on Dong’s political career. The

allegations, which are extremely serious and have been reported and repeated extensively, have

permanently stained Dong in the eyes of the public.

98. The devastating impact of the Defamatory Content is most acutely shown in the

thousands of hateful messages that Dong and his family have received since the defendants

released their reporting. Dong has been subjected to a slew of racial slurs and death threats

directed at his social media accounts and his MP email address. For instance, one such message

said: “You’re a traitor. Piece of shit. I hope someone deals with you permanently. Hope your

family goes down with you. Forever.” Another said: “I personally think we should change some
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laws allow justice to be served so I can watch your last gasping breaths of your existence on this

earth for the treason you committed.” Dong received a letter at his constituency office on March

10, 2023 which stated:

This grave scandal will also spell the demise of your political career, Mr. Dong.
People like you, who have a difficult time demonstrating gratitude and loyalty to
our country and to our free way of life, should be deported, if not hanged in public
sans reservation. Yes hanged from the scaffold.

99. Dong’s family reported these threats to the RCMP and officers performed a security

assessment of Dong’s home in response. Dong has also had to keep the doors of his constituency

office locked to protect himself and his staff.

100. Further, after the defendants published the February 25 Defamatory Article, far-right

media website Rebel News organized a petition to fire Dong, a fundraiser for a billboard truck

calling for Dong’s firing, and a protest outside Dong’s constituency office also calling for his

firing. At the protest, which occurred on March 6, 2023, protesters directly referenced the

defendants’ allegations in the February 25 Defamatory Article and played the Chinese national

anthem over loudspeaker.

101. Rebel News’ efforts represent a highly visible, inflammatory, and predictable repetition

of the allegations in the February 22 Defamatory Article in Dong’s own riding. On the day of the

protest, Rebel News drove a billboard truck around Don Valley North. The truck displayed

several images of Dong, Justin Trudeau, and Xi Jinping, along with communist symbols and the

text “Liberal MP Han Dong was allegedly chosen as a Chinese Communist Party operative in

Canada’s 2019 federal election. If true, this is election meddling and a crime”. The truck also

referred to a website called FireDong.com, which redirects to a page on Rebel News’ website
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calling for Dong’s firing and repeating the Defamatory Content. Many of Dong's constituents

saw the protest and contacted Dong's office to voice their concerns about it.

102. As a result of the Defamatory Content, the defendants have deliberately or recklessly

fueled the fires of anti-Asian and anti-Chinese hate. In the series of articles written by Cooper on

Chinese interference, he has only identified Han Dong, Michael Chan, and Vincent Ke—three

prominent and influential Chinese-Canadian politicians born in China—as subject to Chinese

interference, even though the defendants claim that there are 11 Toronto-area political candidates

affected by the alleged interference. The defendants have intentionally or recklessly portrayed

Dong’s representation of and support from the Chinese-Canadian community as indicative of

insidious Chinese interference, effectively vilifying Dong’s association with the Chinese-

Canadian community. Numerous public officials have conversations with Chinese diplomats—

only Dong has been singled out as an affiliate of the Chinese state because of it.

103. In this way, the Defamatory Content discourages officials—particularly from a Chinese

background—from forming relationships with the Chinese diaspora within Canada and

discourages Chinese-Canadians from running for public office, alienating this community from

participation in the democratic process.

104. In their reporting, the defendants have also intentionally or recklessly portrayed

Canadians of Chinese descent as excessively susceptible to interference from the Chinese state.

To suggest that Chinese-Canadian seniors and Chinese international students can be “bussed

into” a riding en masse to vote for any political candidate they are told to offensively robs

members of those communities of political agency (and as explained above, does not cohere with
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easily ascertainable facts). It is even more egregious to suggest that Dong would accept

interference efforts from China and somehow feel obligated to China to advocate for the

continued imprisonment of two innocent Canadians simply based on his association with his own

ethnic community.

The defendants’ shocking conduct should be sanctioned by an award of punitive damages

105. The Defamatory Content includes a series of statements and imputations that are false,

misleading, malicious, libelous, and highly prejudicial to Han Dong. They strike at the core of

his reputation as an elected public official. As described above, the defendants deliberately or

recklessly concealed and manipulated material facts to create a falsely sinister and highly

damaging narrative about Dong that suited their biased angle, representing malice at law.

106. The defendants’ malicious publication of the Defamatory Content was motivated by

profit, which they allowed to overtake the integrity of their journalism. The defendants knew that

publishing more articles and broadcasts—and more sensational articles and broadcasts—would

attract more readers and advertising revenue to their website and television programs. Each

Defamatory Article and Defamatory Broadcast is interlaced with numerous advertisements,

generating significant profit for the defendants.

107. For instance, Sam Cooper’s tweet on March 22 sharing the March 22 Defamatory Article

has over 3.7 million views. His tweet on February 24 repeating the Defamatory Content has over

2.4 million views. On Mackenzie Gray’s Twitter, a video of the March 23 Defamatory Broadcast

has over 822,000 views and a video of the February 24 Defamatory Broadcast has over 1.4
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million views. On the Global News Toronto Twitter, a video of the March 23 Defamatory

Broadcast has over 116,000 views. These Twitter posts have thousands of retweets.

108. As Cooper was sharing the Defamatory Articles and Defamatory Broadcasts on his social

media, garnering millions of views, he encouraged readers to buy his book, also about Chinese

interference.

109. Additionally, the defendants, and in particular Sam Cooper, have a history of deliberately

using sensational accusations of Chinese interference for profit. The vast majority of Cooper’s

journalism focuses on the threat of China in Canada—since August 2022, Cooper has published

a series of stories on Chinese interference, many of which center on prominent Chinese-

Canadians. Aside from Cooper’s accusations against Han Dong, Vincent Ke, and Michael Chan,

he has reported on the alleged nefarious dealings and connections to Chinese interference

networks of numerous Chinese-Canadian businesspeople such as Wei Chengyi, Wu Shumin, Sun

Yingying, Yongtao Chen, Ishiang Shih, Xiao Jianhua, Zhou Hongwen, Zhou Liwen, and Fan

Yanfeng. As noted above, Cooper is also the author of a book about how Chinese agents

“infiltrated the West”. Accusing Chinese-Canadians of suspicious activities based on their

connections to China is Cooper’s bread and butter.

110. Global News, Corus, Sam Cooper, Sonia Verma, and Craig Offman have all been served

with libel notices and statements of claim for some of their articles on Chinese interference.

Despite having to issue apologies and retractions as a result of these claims, the defendants have

not been deterred from continuing to publish unfounded accusations against Chinese-Canadians

like Han Dong.

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111. The defendants’ malicious, high-handed, callous, oppressive, and highly reprehensible

conduct warrants an extraordinary award of aggravated and punitive damages to reflect the

exceptional harm done to Dong and to ensure that the defendants are appropriately punished for

their conduct and to deter the defendants and others from such conduct in the future.

Libel Notice

112. Dong delivered a Notice of Libel to the defendants on March 31, 2023, expressly

notifying them that Dong complained of the Defamatory Articles, Broadcasts, and Words as

false, defamatory, malicious, and irresponsible. Dong demanded that the defendants retract the

Defamatory Articles, Broadcasts, and Words and publish an apology. Despite this, the

defendants have maintained the public availability of their defamation as of the date this claim

was issued and continue to repeat and republish the defamatory allegations about Dong.

113. Dong relies on Rule 17.02 of the Rules of Civil Procedure, and in particular Rules 17.02

(g) and (i), in serving this statement of claim outside Ontario. The libel was committed in

Ontario, and Dong seeks an injunction that will have effect in Ontario.
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114. Dong proposes that this action be tried in Toronto, Ontario.

April 20, 2023 POLLEY FAITH LLP

TD North Tower
77 King St. W., Suite 2110
Toronto ON M5K 2A1

Mark Polley (44413O)

[email protected]

Emily Young (77217D)

[email protected]

Jeffrey Wang (85736W)

[email protected]

Tel: 416.365.1600

Lawyers for the plaintiff

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SCHEDULE A – DEFAMATORY WORDS

Defamatory Words in the Defamatory Article published February 25, 2023, headlined “Liberals

ignored CSIS warning on 2019 candidate accused in Chinese interference probe: sources”:

Three weeks before Canada’s 2019 federal election, national security officials allegedly
gave an urgent, classified briefing to senior aides from Prime Minister Justin Trudeau’s
office, warning them that one of their candidates was part of a Chinese foreign interference
network.

According to sources, the candidate in question was Han Dong, then a former Ontario
MPP whom Canadian Security Intelligence Service had started tracking in June of that
year.

National security officials also allege that Dong, now a sitting MP re-elected in 2021, is
one of at least 11 Toronto-area riding candidates allegedly supported by Beijing in the
2019 contest. Sources say the service also believes Dong is a witting affiliate in China’s
election interference networks.

Three sources with knowledge of the investigation said Dong emerged as a successor to
MP Geng Tan as the 2019 Liberal candidate in ways the service found suspicious. These
sources spoke to Global News on the condition of anonymity, which they requested because
they risk prosecution under the Security of Information Act.

CSIS allegedly had intelligence that Beijing preferred Han Dong to Tan. “The Consulate
was not pleased with Geng Tan’s performance,” a national security official aware of the
service’s investigation told Global News.

In late September, about 48 hours before the federal election nomination deadline, CSIS
urged Trudeau’s team to rescind Dong’s candidacy, a national security official said.

Sources alleged that Dong frequently called Chinese officials in Ontario and “was
considered a close friend of the Toronto Consulate.”

CSIS was also allegedly concerned about the Liberal Party’s nomination process. Among
other irregularities observed in the September 2019 contest, sources say, was that Chinese
international students with fake addresses were allegedly bussed into the riding and
coerced to vote in Dong’s favour.

An official with knowledge of the brief also said that the service alleged that “Han Dong
was a close contact of Michael Chan, who is a target of CSIS.”
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Chan, a former Ontario cabinet minister, is a political kingmaker and pivotal Liberal
fundraiser. Three intelligence sources said investigators believed Chan had orchestrated
Tan’s ouster with a campaign that persuaded Justin Trudeau’s aides to back Dong instead.

Sources aware of the intelligence said the alleged warning to the PMO about Dong and
Chan did not provide details of the ongoing investigation but instead outlined the concerns.
They said the warning was intended to protect Canada’s democratic institutions.

Another reason the service decided to target Dong, an intelligence official said, was his
alleged meeting with a senior official from Beijing’s United Front Work Department in
New York state, according to sources and documents. This event is alleged to have taken
place during the service’s 2019 election interference probe.

This organ of the Chinese Communist Party is facilitating Beijing’s vast political
subversion operations in Canada, according to a January 2022 Privy Council Office
“Special Report” that summarizes findings from the service’s 2019 investigations. Beijing,
however, denies using the United Front to support CCP policy abroad.

Delving more deeply into the alleged irregularities in Dong’s 2019 nomination, sources
say a case cited in an October 2022 CSIS report, under the subheading “Nomination
Processes,” outlines systemic issues in the contest, beginning with who is actually voting.

“Individuals who are not Canadian citizens, and therefore cannot vote in elections at any
level of government in Canada — can still vote in a party nomination process as long as
they are party members,” the CSIS record says.

It adds that “gaining a party’s nomination in a riding that has long supported that party
is akin to winning the subsequent election,” and hostile state actors “exploit this loophole
to engage in Foreign Interference that target specific candidates in particular electoral
ridings.”

While it does not identify Dong or his riding, the report describes the service’s Don Valley
North investigation findings, an intelligence official said.

“CSIS reporting indicates that, during a political party nomination vote prior to the 2019
General Election in Canada, two busloads of Chinese Canadian seniors were brought in
to support a specific candidate,” the report says.

It adds that the seniors had the name of the candidate they were told to vote for concealed
under their sleeves.
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Sources also say CSIS investigations alleged that Chinese international students with fake
addresses were bussed into Don Valley North and coerced to vote for Han Dong’s
nomination in 2019.

“Chinese international students were also transported in to support the same candidate,”
the report says. “The students were given letters that provided them with an address in the
specific riding, thereby enabling them to participate in the nomination vote. The students
were also ‘told by the PRC Consulate’ to support the specific candidate, ‘if they want(ed)
to maintain their student visa status.’ CSIS intelligence indicates that this candidate is very
close to — and receives support from — the PRC Consulate.”

Sources said some of the service’s more pointed concerns about Chan and Dong’s actions
in the Ontario legislature are documented in a July 2018 CSIS record, “Foreign Influenced
Activities in Canada: Critical Threats to Canadian Democracy.”

“A provincial Cabinet Minister responsible for the province’s ‘dealings with PRC officials
appeared to favour China’s interests in many of his activities,'” a document referring to
the 2018 CSIS record says. “This individual provided political information to the PRC
Consulate and offered to verbally attack other members of the provincial assembly who
raised Chinese human rights issues.”

The same document also says: “PRC Consulate officials and two members of a provincial
legislature persuaded a Member of Parliament at a specific community event to decline an
invitation to travel to Taiwan. The PRC Ambassador was kept apprised throughout the
event on the progress of their efforts.”

Three intelligence sources said Michael Chan and Han Dong were the unidentified Ontario
Liberal MPPs who pressured Liberal MP Geng Tan to forgo the Taiwan trip.

Beijing’s top foreign policy is the so-called “reunification” of Taiwan, a democratic nation
that the Chinese Communist Party considers a renegade province. Thus, much of Beijing’s
interference in Canada is aimed at blocking any political engagement with Taiwanese
officials, the January 2022 Privy Council Office “Special Report” reviewed by Global
News said.

In December 2018, Tan announced he’d run for re-election. His Facebook page shows he
continued to attend political events for Trudeau’s government until April 2019.

Around the same time, Geng Tan became engulfed in a bizarre scandal, making him a
potential liability for Trudeau in an overwhelmingly Liberal riding where a nomination is
equivalent to an election win.
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On May 11, a report was published on WeChat, a Chinese state-controlled messaging app,
alleging Tan was having an extra-marital affair. A second Chinese media article reported
the allegations on May 19.

Tan has repeatedly denied the affair and declined to comment on this story. “I’m a private
citizen,” he told Global News at his home.

An intelligence source directly aware of the Chan investigation said the service believes
Chan could have influenced these reports. According to sources with knowledge of the
CSIS probe, Chan recommended to Trudeau’s office that Dong should replace Tan as the
nominee for Don Valley North.

Within a month, Tan announced on Facebook he wouldn’t run: “After much consideration,
I have come to [the] conclusion that time has now come to spend more time with family
and pursue other careers.”

On June 25, the National Post ran a story with the following headline: “Liberal MP hired
girlfriend to work in riding office, then fired her and refused to support their baby, lawyers
allege.”

Two days later, on June 27, Michael Chan and Han Dong held a press conference for
Chinese media in the office of a community leader, announcing Dong’s bid to be the
Liberal candidate in Tan’s vacated riding.

Defamatory Words in the Defamatory Article published March 22, 2023, headlined “Liberal MP

Han Dong secretly advised Chinese diplomat in 2021 to delay freeing Two Michaels: sources”:

Liberal MP Han Dong, who is at the centre of Chinese influence allegations, privately
advised a senior Chinese diplomat in February 2021 that Beijing should hold off freeing
Michael Kovrig and Michael Spavor, according to two separate national security sources.

Both sources said Dong allegedly suggested to Han Tao, China’s consul general in
Toronto, that if Beijing released the “Two Michaels,” whom China accused of espionage,
the Opposition Conservatives would benefit.

At the time, the two Canadians had been in Chinese custody for over two years. However,
it was widely perceived that they were jailed in retribution for Canada’s detention of Meng
Wanzhou, the Huawei executive facing extradition to the United States.

Dong also allegedly recommended that Beijing show some progress in the Kovrig and
Spavor cases, the two sources said. Such a move would help the ruling Liberal Party, which
was facing an uproar over China’s inhumane treatment of Kovrig and Spavor.
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Dong, who represents the Toronto-area riding of Don Valley North, was the one to initiate
the discussion with the consul general, the two sources said, adding that Dong stipulated
at the outset that it was both a personal and a work-related conversation.

In an emailed statement to Global News sent Tuesday, Dong confirmed that he had a
discussion with Consul General Han, but disputed that he initiated it and also denies that
he advised Beijing to delay releasing Kovrig and Spavor from prison.

While there have been a series of revelations about Chinese interference in Canadian
affairs since Global News broke several stories in late 2022, the conversation between
Dong and Consul General Han illustrates how political interference is not just affecting
institutions but also has an impact on people – in this case, with two lives at stake, one of
the two national security sources said.

Global News has granted anonymity to sources on the Dong investigation because they
face possible prosecution for sharing information on China’s allegedly vast subversion of
Canada’s democracy, including clandestine interference in the 2019 and 2021 federal
elections.

When the February 2021 conversation occurred between Dong and Consul General Han,
CSIS reporting had already classified Dong as a “close friend of the Consulate based on
his history of calls,” the national security official said.

Apart from the discussion about the Two Michaels, the two sources said Dong and Consul
General Han allegedly spoke at length about China’s problematic reputation in Canada,
as well as discussing perceptions of human rights accusations against Beijing.

Following the February conversation between the consul general and the MP, sources say
that CSIS questioned whether or not Dong was acting outside of appropriate diplomatic
channels.

CSIS also deliberated whether or not the conversation proceeded because he believed it
was within his purview as an MP to find solutions, the sources said.

Concerns regarding the Dong communications were briefed up to CSIS management in

Ottawa, the two sources said.

It remains unclear whether or not CSIS has ever conveyed them to the Prime Minister’s
Office or anyone else in the federal government.

When asked to comment on the information provided by sources on the alleged Dong
communications, CSIS spokesperson Eric Balsam wrote in a statement that the service
could neither confirm nor deny the authenticity of the information.
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“There are important limits to what I can publicly discuss given the need to protect
sensitive activities, techniques, methods, and sources of intelligence,” he wrote.

Weeks after the conversation between Dong and Consul General Han, China announced
it had tried Spavor and then Kovrig behind closed doors on espionage charges.

Looking at the timing of Dong’s alleged communication with the Toronto Consulate and
the announcement of Chinese court proceedings in mid-March, CSIS investigators
considered whether Dong’s alleged recommendation to Consul General Han had indeed
influenced Beijing to show some progression in the case, the national security official said.

As Global News reported last month, Dong was already the subject of a CSIS probe started
in the summer of 2019, three sources said, because the service believed a “subtle but
effective” election-interference network directed by the Toronto Chinese Consulate had
clandestinely supported Dong’s 2019 candidacy.

The network had targeted at least 11 candidates, three sources said, one of whom they
allege was Dong.

CSIS believed him to be a witting affiliate in the alleged scheme, the two separate national
security sources said.

Defamatory Words in the Defamatory Broadcast published and broadcast on February 24, 2023,

headlined “Liberal MP allegedly tied to Chinese interference: sources”:

FARAH NASSER: … After a months-long investigation into alleged attempts by Beijing to

interfere in Canada’s democratic process, Global News can reveal new allegations
emerging from an ongoing probe by the Canadian Security Intelligent Service. Intelligence
sources tell Global News that investigators have been tracking current Liberal Ontario
MP Han Dong since the summer of 2019 and those sources say he is one of 11 Toronto-
area riding candidates believed to be supported by Beijing in the lead-up to that year’s
federal election and alleged to be an affiliate in China’s election interference networks.
Tonight, Mackenzie Gray has the new revelations in this Global News investigation.
Mackenzie.

MACKENZIE GRAY: Farah, after an 8-month investigation intelligence sources have told
Global News that current Liberal MP Han Dong is alleged to have been supported by
Beijing in 2019 and the Prime Minister’s senior staff were warned about it. Reliably red
since 1993, scoring the Liberal nomination in Don Valley North has been harder than
winning a general election recently, but instead of leaning on his connections as a former
Ontario MPP, sources say Han Dong had help from the Chinese Consulate in Toronto to
become the 2019 Liberal candidate in the riding. Through a combination of CSIS
documents and intelligence sources, Global News has learned the Consulate allegedly sent
two busloads of Chinese Canadian seniors to the Don Valley Liberal nomination meeting
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and those seniors knew who to vote for because Dong’s name was written on their arm.
Sources also say CSIS suspected that Chinese international students with faked addresses
were bussed in and told by the PRC consulate to support their preferred candidate if they
wanted to maintain their student visa status.

GRAY: Dong won the nomination, but he still needed Justin Trudeau’s stamp of approval
to carry the Liberal banner in the suburban Toronto riding, one with a sizable diaspora of
Chinese Canadians. A senior intelligence official told Global News CSIS shared their
concerns about Dong in late September 2019 during a classified briefing with senior
Liberal Party staff who hold security clearances. In that meeting, CSIS urged them to
rescind Dong’s nomination. CSIS was concerned that Han Dong was connected to the
People’s Republic of China for an interference network in Canada, an official with
knowledge of the brief told Global News. Despite the alleged warnings to his staff, Trudeau
approved Dong’s candidacy. During the election, a top Liberal organizer even warned
Dong’s team that it was allegedly a CSIS target according to sources. Dong is still an MP
today.

Global News asked the Prime Minister’s office multiple questions including if Trudeau
knew Dong was allegedly a CSIS target, but the PMO didn’t respond to any of our
questions saying there were so many factual inaccuracies that it is not possible to begin to
even answer them. Farah?

NASSER: Mackenzie Gray in Ottawa. Thank you, Mackenzie. With me now is investigative
reporter Sam Cooper. He broke the first stories about attempted Chinese interference and
has been working his sources on this for months. Sam, let me start with what is your
understanding of why the Liberal candidate, this Liberal candidate Han Dong, now an
elected MP, was the preferred candidate for the Chinese Communist party?

SAM COOPER: Farah, our sourcing says that the point of Chinese interference is that it
wants Canadian officials to favour China’s interests, so China targets favoured
candidates, and by giving them clandestine support and funding, helps elect them. This
creates a bond of obligation, so these Canadian politicians won’t criticize China on human
rights issues, or they might support China on big issues such as perhaps the case of Meng
Wanzhou and our Michaels imprisoned in China for example. With regards to Mr. Dong
specifically, to be clear he has denied the allegations, but what our sources say is that CSIS
called Dong a close contact of Toronto Consulate officials, also, in 2019 he allegedly met
with a senior Chinese Communist Party official in New York state as part of China’s
interference plot, so the concern is he is being directed by these officials.

NASSER: Hmm. Well it would tie in … the Prime Minister says that he is aware of Chinese
interference generally and knows that it is a serious issue. He even raised it when he met
Chinese president Xi Jinping last year. Yet your sources have told you that senior officials
in the Prime Minister’s Office were given a classified briefing, warning one of their
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candidates was part of this clandestine election interference network and urging them to
rescind his nomination but they didn’t do that, so what’s behind the disconnect there?

COOPER: Farah, first of all I pressed the Prime Minister’s Office, but they would not
confirm they received this briefing. But my sources say Michael Chan, a veteran Liberal
politician who was a top target in these investigations and allegedly promoted Dong in
2019 is a significant fundraiser for Trudeau’s party and also has the ability to recommend
nomination candidates in Toronto. Farah, Michael Chan has denied the allegations, but
my sources raise the question of whether the Liberal Party may be downplaying CSIS’s
warnings on Chan because of the influence and success he has inside the party. Farah,
also my sources fear the Prime Minister isn’t addressing the real issue here. As we report
and CSIS believes elections are fixed in party nominations, so if China controls the riding’s
funding and community volunteer networks and successfully promotes a candidate in a
riding that is almost always won by a certain party this is akin to winning a seat in Ottawa.
Farah?

NASSER: Explosive reporting. I’m sure reaction will start pouring in. Sam Cooper in
Ottawa. Thank you, Sam.

Defamatory Words in the Defamatory Broadcast published and broadcast on March 22, 2023,

headlined “MP denies affiliation with China interference”:

ANTONY ROBART: Liberal MP who national security sources have told Global News was
part of an alleged foreign interference network spoke to reporters in Ottawa yesterday.
Han Dong, according to sources, was one of at least 11 Toronto-area candidates supported
by the Chinese government in the 2019 election. Now sources also told Global News that
CSIS believes that Dong is a witting affiliate in China’s election interference networks.
Mackenzie Gray was there during that scrum. He joins us from Ottawa. Mackenzie, we
appreciate this, so, let’s talk about the takeaways from what Dong said. What are they?

MACKENZIE GRAY: Yeah, he spoke for 20 minutes with reporters and this was the first
time I had seen him on the Hill or he spoke with any of my colleagues in the press gallery
and he denied the allegations put forward in our reporting here at Global News. Let me
just go through the allegations, you know, you said in the intro again, Antony. The two key
things that we alleged in this story based on documents that we saw and sources that we
spoke with was that Han Dong had help in his 2019 nomination meeting from the Chinese
Consulate in Toronto in two key ways to help him win. That they bussed in Chinese
Canadian seniors to vote for him in his nomination meeting and they also bussed in
international students and they kind of coerced them into voting for him, because they said
that they could remove their student visa status. And we asked Mr. Dong if he agreed with
those allegations, if any of those things happened, here’s what he had to say about that.

…
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ROBART: Okay, so what is he saying about what he has done to try to learn more about
these allegations?

GRAY: Well, he has written to CSIS to ask them about what has happened in this situation.
CSIS has said that he, they received the letter, but it is important to note that CSIS has not
reached out to Mr. Dong and asked him about the alleged interference. But one person he
has not asked about this is the Prime Minister and here is what Mr. Dong had to say about
why he has not reached out to the Prime Minister about these allegations.

GRAY: Yeah, and Antony, this is important, because, some of the documents that we have
had in our reporting come to the peri… Privy Council, and for folks who don’t know the
Privy Council, that’s an office that is essentially that gives advice and information to the
Prime Minister and the Prime Minister’s Office, so the Prime Minister would have some
knowledge about these documents and be able to give Dong some information. But there
seems to not have been a conversation between the two of them nearly a month now after
we’ve reported these allegations here at Global News.

Defamatory Words in the Defamatory Broadcast published and broadcast on March 22, 2023,

headlined “Liberal MP Han Dong secretly advised Chinese diplomat in 2021 to delay freeing

Two Michaels: sources”:

DAWNA FRIESEN: We begin tonight with more allegations about a Liberal MP who
national security sources tell Global News was in contact with the Chinese Consul General
in Toronto, in 2021. Han Dong, an Ontario MP, is the politician who national security
officials allegedly briefed senior aides to the Prime Minister, Justin Trudeau, about before
the 2019 election, warning them Dong was believed to be part of a Chinese foreign
interference network. Dong denies the allegations. Now, Global News has learned about a
conversation Han Dong had with a Chinese diplomat about the two Michaels while they
were still being held in a Chinese jail. Mackenzie Gray has our top story tonight.

MACKENZIE GRAY: In February 2021, Michael Kovrig and Michael Spavor had been
detained in a Chinese prison for nearly 800 days. But while they languished away, Ontario
Liberal MP Han Dong allegedly advised a top Chinese diplomat to hold off on immediately
freeing them. Two independent national security sources have told Global News that Dong
spoke with China’s Consul General in Toronto, Han Tao, and suggested to him that if
Beijing released the two Michaels, then federal Conservatives would benefit. How exactly,
is not clear.

Dong allegedly initiated the discussion with the Consul General where he also allegedly
recommended that Beijing offer some show of progress with the two Michaels’ cases to
help benefit the Liberals, according to the two sources.
Electronically issued / Délivré par voie électronique : 20-Apr-2023 Court File No./N° du dossier du greffe : CV-23-00698271-0000
Toronto Superior Court of Justice / Cour supérieure de justice

-52-

Dong confirmed to Global News that the conversation took place, but he denied he initiated
the discussion and says that he advocated for the two Michaels to be set free. “At every
opportunity before they returned home, I adamantly demanded their release to Canada
without delay”, said Dong. “Any suggestions otherwise are false and are attempts to
mislead you, your readers and slander me”.

The two Michaels had been jailed in apparent retribution for Canada’s detention of
Huawei executive, Meng Wanzhou. But at the time of Dong’s conversation with the Chinese
diplomat, the Prime Minister had publicly been calling for their release.

GRAY: Trudeau’s office says the Prime Minister only learned of the conversation with the
Chinese envoy after Dong told PMO. But Dong only informed the Prime Minister’s team
after Global News reached out for comment.

A national security official told Global News that by the time the alleged conversation in
February 2021 took place, CSIS had already classified Dong as a close friend of the
Consulate based on his history of calls. But they had also considered if Dong was acting
as a backchannel interlocutor between the Canadian and Chinese government. The PMO
denied that theory, saying at no time was Mr. Dong ever used as a backchannel. Global
News has not been able to independently verify what was said in the communication
between Dong and the Consul General.

Last month, Global News reported that Dong allegedly received help from the Chinese
Consulate in Toronto during his 2019 Liberal nomination meeting in Don Valley North,
allegations Dong denies.

We reached out to CSIS for comment on the Dong conversation. A spokesperson for the
agency said they can neither confirm nor deny the authenticity of the information.

Defamatory Words in the Defamatory Broadcast published and broadcast on March 23, 2023,

headlined “Han Dong to sit as Independent MP following ‘serious’ allegations”:

ANTONY ROBART: … Han Dong, an MP at the centre of foreign election influence

allegations, has resigned from the Liberal caucus, now sitting as an Independent. His
resignation comes after more bombshell allegations including that Dong advised a Chinese
diplomat to delay freeing the prisoners known as the two Michaels. Sam Cooper, Global’s
national investigative reporter, broke the story among many others, and many other
developments in this overall story, joins me now to discuss these latest updates.
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Toronto Superior Court of Justice / Cour supérieure de justice

-53-

Sam, we appreciate this, explosive allegations on top of previous explosive allegations.

Recap what we know so far.

SAM COOPER: They are very serious allegations. What national security sources allege
is that CSIS conducted an investigation into a conversation in February 2021 between MP
Dong and China’s senior diplomat in Toronto, Han Tao. The allegations are that Mr. Dong
initiated this conversation. It was a lengthy conversation. Mr. Dong allegedly provided his
thoughts on political matters in Canada, China’s reputation, and then raised the case of
the Michaels. Allegedly Dong recommended that China should not immediately release the
Michaels because that would affirm the opposition Conservative Party’s position on the
matter. Mr. Dong allegedly recommended China, though, needed to see some progression
in the case because allegedly this could benefit the Liberal Party of Mr. Dong. We need to
stress that Mr. Dong acknowledges having this conversation. However, he strongly denies
giving any recommendation that China should hold off on releasing the Michaels, and his
answer to Global News suggested that he believed that it was within his purview to have
such conversations.

ROBART: Interesting, so he in Parliament spoke last night, tearing up in his speech, saying
effectively you and the reporting attacked his reputation. He will defend himself against
these quote absolutely untrue claims. That is how he is responding. How is the Prime
Minister responding?

COOPER: We contacted the Prime Minister’s Office this week on the same day that we
contacted MP Dong. We asked the same set of questions essentially. We asked the Prime
Minister’s Office, were you aware of this alleged conversation? They answered, they had
no awareness prior to Global News asking about the conversation. Again Mr. Dong has
acknowledged having the conversation, denied making certain statements. The Prime
Minister’s Office maintained that Mr. Dong was not acting for the Liberal government in
any way in these communications. So in those set of answers, we see really a shocking
division between an individual MP and the Prime Minister’s Office who says they were not
aware in any way of this conversation. One point to add, Antony, the national security
sourcing asserts at the time of this call, Mr. Dong was assessed by CSIS to be quote a close
friend of the Toronto Consulate based on his previous call history.
Court File No./N° du dossier du greffe : CV-23-00698271-0000

HAN DONG -and- GLOBAL NEWS, a division of CORUS ENTERTAINMENT INC.

et al.
Plaintiff Defendants
Court File No.
ONTARIO
SUPERIOR COURT OF JUSTICE
PROCEEDING COMMENCED AT TORONTO
STATEMENT OF CLAIM
POLLEY FAITH LLP
TD North Tower
77 King St. W., Suite 2110
Toronto ON M5K 2A1
Mark Polley (44413O)
Electronically issued / Délivré par voie électronique : 20-Apr-2023

[email protected]
Toronto Superior Court of Justice / Cour supérieure de justice

Emily Young (77217D)

[email protected]
Jeffrey Wang (85736W)
[email protected]
Tel: 416.365.1600
Lawyers for the plaintiff