CITATION: R. v. Cameron, 2022 ONSC 4138  
COURT FILE NO.: 20-47  
DATE: 2022/07/15  
ONTARIO  
SUPERIOR COURT OF JUSTICE  
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BETWEEN:  
HER MAJESTY THE QUEEN  
and –  
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Barb Glendinning, for the Crown  
Sandra Cameron  
John Hale, for the Defendant  
Defendant  
HEARD:  
January 17,18,19,21,24,25,26,27,28, 2022  
April 11,12,14,19,20,21,22,25,28,29, 2022  
REASONS FOR JUDGMENT  
LACELLE, J.  
[1]  
Sandra Cameron worked as the tax collector for the Township of North Glengarry (“TNG”)  
between the years 2008 and 2016. Before that, she was the assistant tax collector for a few  
years.  
[2]  
In the course of her employment with the Township, Ms. Cameron is alleged to have  
committed a number of offences. She is charged with the following offences, all of which are  
alleged to have occurred between January 1, 2007 and December 31, 2017:  
1) breach of trust, contrary to section 122 of the Criminal Code of Canada, R.S.C. 1985,  
c. C-46 (by manipulating data and issuing false tax bills and tax certificates);  
2) defrauding the Township of North Glengarry and its taxpayers, contrary to section  
380(1)(a) of the Criminal Code of Canada;  
1
3) knowingly make false statements in writing with the intent that they should be relied  
upon by taxpayers and the Township of North Glengarry, contrary to section 362(1)(c)  
of the Criminal Code of Canada;  
4) committing mischief in relation to data by rendering tax account data contained in the  
Vadim system meaningless, useless and ineffective, contrary to section 430(5) of the  
Criminal Code of Canada;  
5) knowingly causing forged documents (multiple tax bills and tax certificates) to be  
issued to taxpayers and their lawyers as if they were genuine, contrary to section  
368(1)(a) of the Criminal Code of Canada.  
Overview of the evidence  
[3]  
The narrative of the Crown’s allegations against Ms. Cameron were presented largely  
through the evidence of Linda Lancaster. A summary of her evidence follows.  
[4]  
Ms. Lancaster was the tax collector in South Glengarry Township until her retirement. At  
the request of officials in North Glengarry, she assumed the tax collector position for the TNG  
upon the accused taking a sick leave in December of 2016. She agreed she could only speculate  
as to what the practice and procedures had been in North Glengarry in earlier years.  
[5]  
[6]  
Ms. Lancaster was working in this position in 2017 when irregularities in the tax  
department at the TNG became apparent. She stated that when the property tax notices were  
mailed out, the phone “started ringing off the hook” with taxpayers asking about how they  
were showing taxes past due. Ms. Lancaster ultimately assisted police and accounting officials  
with the subsequent investigation into these complaints, which led to charges against the  
accused.  
Ms. Lancaster provided a great deal of information about a variety of topics. What follows  
is a brief summary of those parts of her evidence that are most central to an understanding of  
the issues in this trial.  
The Vadim system  
[7]  
The computer software used by TNG for tax administration and other issues was created  
by a company called “Vadim”. The software was used throughout Stormont, Dundas and  
Glengarry. An individual from the company, Lorraine Drinkwalter, provided training to Ms.  
Lancaster and other employees. Employees also had the opportunity to attend conferences run  
by Vadim. Ms. Lancaster also said a binder called “Tax Collection Procedures” was kept in  
the tax collector’s work area. She understood it had been prepared by a summer student  
working at the TNG.  
[8]  
As far as Ms. Lancaster could recall, the transition to the Vadim system took place in 2006-  
2007. It was her recollection that 2006 was the year when tax accounts began to show Vadim’s  
recording of interim billings, penalties, payments, interest, and other information not noted by  
the software in use before Vadim.  
[9]  
Not all employees had the same access to the modules in the Vadim system. The treasurer  
determined what level of access to give each employee. Even with access to a certain module,  
there were varying degrees “of what they could do”.  
[10] Ms. Lancaster found it challenging to learn the Vadim system. Parts of the system were  
confusing. While it was simple to use in some respects, it was quite complex in others. It took  
her about one and a half to two years to get to the point where using the system came naturally.  
She was aware that others who used it expressed frustration about the system at a Vadim-  
sponsored conference in Gananoque some four to five years after it was implemented. While  
the accused was also at that conference, Ms. Lancaster could not recall if she was one of the  
people complaining about Vadim.  
[11] Ms. Lancaster agreed that Vadim had a number of default settings for various transactions,  
and “many clicks of the mouse” would be required to opt out of these settings. She said that  
great care had to be taken to ensure that you arrived at the correct result when operating the  
software.  
Usernames, passwords, and access to Vadim  
[12] Employees were given usernames to access Vadim and ultimately could set up their own  
passwords. In many instances, Vadim permitted the identification of the operator who made  
an entry into the system.  
[13] While employees could log in to Vadim from another employee’s workstation, the only  
way to log in to someone’s Vadim’s account was to use their username and password. It was  
Ms. Lancaster’s practice never to share her password with anyone.  
[14] As far as Ms. Lancaster could recall, either her computer or Vadim required that the  
password be updated on a regular basis. She could not recall which.  
[15] It was Ms. Lancaster’s recollection that users would be timed out of Vadim if the computer  
was not used within a set time, and that this was true in 2006, at least in South Glengarry.  
Live v. test  
[16] The Vadim system allowed users to operate in either a “live” or “test” environment. As  
Ms. Lancaster understood the system, the purpose of the test environment was to permit  
preliminary work on difficult transactions. In other words, operators could practice how they  
would enter a transaction in the test environment. The test system was not current in its  
information and in order to operate with up-to-date information, a request had to be made to  
IT support personnel to copy information over to the test environment from the live  
environment. The live system was the one used to conduct actual transactions. A record of  
transactions was kept in the live system.  
[17] At the time of the alleged criminal activity, there was no way to tell the difference between  
a document prepared in the live environment or the test environment. This issue was rectified  
in 2017 as a result of the investigation of complaints that led to these charges.  
Tax certificates  
[18] Tax certificates were produced upon request of a lawyer or taxpayer. They were generated  
by the Vadim system. In preparing a tax certificate, the tax collector would be required to  
certify that the information provided was a true representation of the tax account on that  
particular day. Tax certificates, according to Ms. Lancaster, were only issued in the live system.  
She never had any occasion to issue one through the test environment. Further, she testified  
that they should never be issued in the test system because you could not be sure if the data  
was accurate as to amounts owing unless you had copied the information from the live to test  
environment.  
[19] Tax certificates were uniquely and consecutively numbered. It was not possible in the live  
system to have two tax certificates with the same number.  
The payment process  
[20] Various methods could be used by taxpayers to pay their taxes, including by cash, cheque,  
online banking, or the bank in conjunction with a mortgage payment.  
[21] Some taxpayers could set up a pre-authorized payment. However, their taxes had to be up  
to date to permit this form of payment. While Ms. Lancaster was initially adamant that the  
policy required this payment to be taken the first banking date of the month, she later agreed  
that the practice in North Glengarry was to process such payments later.  
[22] In the TNG, as far as Ms. Lancaster could tell from her review of various files, payment  
was received by the tax collector or the assistant tax collector, and later by a receptionist.  
[23] Monique St-Denis was the receptionist for a period of time, including when Ms. Lancaster  
worked for the TNG. In Ms. Lancaster’s opinion, Ms. St-Denis was not adequately trained in  
the Vadim system. From time to time, Ms. Lancaster would be called to the reception to correct  
mistakes Ms. St-Denis made with receipts when taxpayers came in to pay their bills. This  
lessened as Ms. Lancaster’s time at the TNG went on.  
[24] Ms. Lancaster noticed no pattern in the mistakes made. Ms. St-Denis’s primary job was to  
receive payments from taxpayers, but she also created forms and did other work. She made  
mistakes in entering receipts and required help to balance her cash. Mistakes were discovered  
right away when she entered a receipt, or the next morning when the bank deposit and  
balancing of accounts occurred. When Ms. Lancaster had to assist with corrections, this would  
generally be done from Ms. St-Denis’s workstation. Ms. Lancaster would do the reversal since  
Ms. St-Denis did not have the password required. She agreed that the password may have  
originally been “cash”. She said that information about the reversal and who it showed did it  
depended on whose workstation it was performed on. She also said that the reversal required  
the entry of the person’s username and password.  
[25] Where taxpayers provided one payment (e.g. a cheque) to pay the taxes on multiple  
properties, the payment entry seems to have often been recorded as a cheque even if the  
payment was in cash, and was often entered as one roll number rather than multiple roll  
numbers (where the total payment provided was to satisfy multiple tax bills). This issue was  
discovered when investigating the complaints that came in after the accused left on sick leave.  
Property tax bills  
[26] Property tax bills went out in early February every year. A final bill was sent out in late  
June or early July and provided for payment in two installments. The first payment was due by  
the end of February, while the last installment was due by September 30.  
[27] Property tax bills were printed by the Vadim system. The system provided no way to create  
a record of the exact bill sent to the taxpayer. Consequently, to have a record of what was  
actually sent to the taxpayer, a pdf copy had to be made. It was Ms. Lancaster’s practice when  
working in South Glengarry to take this step, where records going back at least seven years  
were kept by the Township. There was no practice in the TNG of saving a pdf version of the  
tax bill sent to the taxpayer.  
[28] Ms. Lancaster raised the problem of the inability of the Vadim system to record this  
information with the company. She reported Vadim requested input from its users on this issue  
and said “that was put forward many times”.  
[29] When printing a tax bill in Vadim, the default setting for the document was such that it  
would not show amounts past due. It was possible, however, to select the option of “show past  
due” and to save that option so that bills would always show what was owing on the account.  
Ms. Lancaster testified that a bill should always show what was owing, and so this box should  
be checked off and this option saved. If this setting was not saved, the operator would have to  
click a box with every use to ensure that any bill printed also showed the amounts past due.  
[30] If a taxpayer did not receive a tax bill that reflected the amounts past due, they would never  
know that an amount was due unless they were sent a reminder notice.  
[31] Further, without having the tax bill that was sent to the taxpayer, there was no way of  
knowing if the taxpayer was advised of the true balance on the account at the time the bill was  
sent.  
Reminder notices  
[32] The Vadim system did not have an automated way to ensure that reminders were sent out  
for accounts where the owners were in arrears. It was the responsibility of the tax collector to  
be aware of which properties required notices. Ms. Lancaster testified that it was best practice  
to send reminder notices out after the second installment date had passed, and that reminder  
notices should be sent out at least once a year to taxpayers who were in arrears. The only way  
to have a record of a reminder notice that was sent was to save a copy.  
Reversals of payments  
[33] Payments could be reversed in the Vadim system. In order to reverse a payment, various  
steps had to be taken. The payment process included creating a “batch” number and a deposit  
number. Batches and deposits would have to be balanced, and then posted to the general  
ledger. A batch could be kept open until the operator directed Vadim to close it. While it was  
not good practice to do so, it was possible to keep a batch open all month. It was also possible  
for more than one person to contribute receipts to a batch if they knew how to do so.  
[34] A reversal might be necessary where, when balancing a batch and deposit, it became clear  
that a number had been mis-entered. In these instances, there would be a follow up entry with  
the correct am  
t.  
[35] Another circumstance requiring a reversal might occur when the Township treasurer or  
deputy treasurer had balanced their bank account and determined that the total amount for a  
deposit was incorrect. In this instance, the tax collector might be asked to pull out the batch  
and deposit listing to investigate. It might be that a receipt was mis-entered, or a roll number  
was entered incorrectly (but was a valid roll number). In these cases, the tax collector would  
have to reverse the entry on the tax account because it was made incorrectly. This type of error  
relates to manual key entry. Ms. Lancaster testified that in that circumstance, she would expect  
to see some indication noted in the file that this was the reason for the reversal . There were  
two options in Vadim to add notes to the file to this effect and explain how the error was fixed.  
[36] Where errors were not caught and corrected, Ms. Lancaster said that she would expect that  
when tax notices were sent out indicating amounts past due, or when reminder notices were  
sent, the taxpayer would be informed of what the Township said was owing. If the taxpayer  
contested this and said they had in fact made a payment, they would be asked to show proof of  
that payment. This would cause an investigation of the circumstances to occur, and the error  
might then be discovered and corrected.  
[37] Payments and subsequent reversals are documented within Vadim in a report referred to as  
an “audit trail report”. The name of the operator who entered the transaction appears on the  
report. In the case of payments, the date and time of the payment is noted. In the case of  
reversals, while the date is noted, all reversals show the same time midnight. Ms. Lancaster  
did not know why that was. The operator has no control over this information. She also did not  
know why the operator’s name appeared in all capital letters for reversals. It was her  
understanding that the username on the document reflected the workstation used and it  
identified whoever had accessed the system.  
Downloading the information from MPAC into Vadim  
[38] Twice a year, the tax collector would receive a CD from the Municipal Property  
Assessment Corporation (“MPAC”) that updated property tax information. The tax collector  
was responsible for downloading the data from the CD into Vadim. Ms. Lancaster said the  
operator had to be careful to not override information in Vadim that was more current about  
who owned a particular property. A box on the relevant Vadim screen had to be checked to not  
override this information during the download. If this was not done, manual entries were  
required to correct the information.  
The documents found in the area of Ms. Cameron’s workstation  
[39] Ms. Lancaster testified about documents that were found in the area of Ms. Cameron’s  
workstation after Ms. Cameron went on her sick leave. Some were in a credenza, some in a  
rolling filing cabinet. If all the documents had been placed in a pile, she estimates there would  
have been a few that were ten to twelve inches thick.  
[40] The filing cabinet contained files where taxes had been owing for more than three years.  
Ms. Lancaster did not think there was anything unusual about this. As the tax collector, you  
might want easy access to particular files.  
[41] At least some of the documents in Ms. Cameron’s work area were tax bills. Ms. Lancaster  
testified that as the tax collector, you might keep such documents to remind you that you had  
an adjustment to do on the account. While she could envision a practice of setting aside a bill  
where the tax collector expected an imminent change (such as when a property assessment was  
under appeal), she said the better practice would be to put a note on the tax bill that there was  
an event pending and send the bill.  
[42] Ms. Lancaster estimated there were thousands of documents in the area of the accused’s  
workstation. There were also documents relating to other things, like local improvements. Ms.  
Lancaster could not say whether there were issues with any of the tax files to which the tax  
documents pertained. She did not go through the documents.  
[43] Ms. Lancaster also confirmed that there was a shredder in the office, and documents could  
be easily destroyed.  
[44] Given the state of the work area used by Ms. Cameron, Ms. Lancaster agreed that in some  
aspects of her job, Ms. Cameron was very disorganized. She also noted that Ms. Cameron was  
very organized in other aspects.  
Tax Roll 2 Property owners: Seguin/Doyle/Barr  
[45] On her first day of work for the TNG, Ms. Lancaster dealt with a letter that had been  
received in the office in December of 2016, between the time the accused went on sick leave  
and the time Ms. Lancaster took over the tax collector position in early January of 2017. The  
letter was from a lawyer asking that a change in ownership be noted in respect of property that  
had been purchased by the Doyles. When Ms. Lancaster went into the system to change the  
ownership information on the tax account, she noticed there were taxes owing and past due.  
She contacted the lawyer and informed him.  
[46] The lawyer for the Doyles and the prior owners provided a copy of the tax certificate that  
had been provided to them. It showed no arrears for the years 2014 and 2015. While it  
identified an upcoming amount that was due ($830), the certificate stated that there were no  
amounts owing from prior years. The signature on the tax certificate was in the name of the  
accused. Her office telephone number was hand-printed below the signature line. It was dated  
August 3, 2016.  
[47] Ms. Lancaster then began an examination of the tax account. She determined that the tax  
certificate provided to counsel had not been issued in the live system, but in the test system.  
She arrived at this conclusion after searching in Vadim for the tax certificate the lawyers had  
provided to her. She could not find it. The only tax certificate issued in relation to that property  
that she could find was issued in 2006.  
[48] Ms. Lancaster also created a new tax certificate for the day before the tax certificate that  
had been provided to counsel. According to this document, the amount owing for unpaid  
arrears as of a day before the tax certificate provided to counsel was $6,866.45, and included  
amounts owing in 2014, 2015 and 2016.  
[49] In reviewing the records for the property roll number, Ms. Lancaster concluded that the  
accrual of arrears began as a result of an increased assessment by MPAC effective in November  
of 2007. She said that the taxpayer would have received two notifications about the increase  
to their taxes. They would be notified first by MPAC, and then by receiving a supplementary  
tax notice.  
[50] In this instance, notwithstanding that there were unpaid arrears from 2007, the taxpayers  
were permitted to go on a preauthorized payment plan that came into effect at the beginning of  
2008. This was contrary to council’s policy.  
[51] Ms. Lancaster also discovered there had been a number of reversals of payments on this  
tax account. The receipts involved were cross-referenced to their corresponding audit trail  
report, which permitted Ms. Lancaster to confirm the operator during those transactions. The  
operator was “scameron”.  
[52] Ms. Lancaster testified that a reversal might occur if a payment had been entered  
incorrectly, or if an error was discovered when trying to balance various figures for the purpose  
of a bank deposit or when posting to the general ledger. In those instances, however, you would  
also see the new correctly entered figure on the tax account documents. In this case, there were  
at least eight reversals on the account between 2010 and 2016. This is not something she would  
expect to see on an individual tax roll account. In at least one instance, the reversal was on the  
same date as a “true payment” (a payment that was not subsequently reversed). The operator  
for both transactions was “scameron”.  
[53] Ms. Lancaster was asked what this signified to her. She responded: That payments are  
being entered and leaving an incorrect balance on the account until some type of transaction  
happens, whether a true payment, or a request for a tax certificate there should not be that  
many reversals on a tax account reducing the balance, then accepting a real payment, and then  
reversing a payment back onto the account … it is a red flag to see this many reversed receipts  
without an explanation”.  
[54] Ms. Lancaster was directed to a reversal by operator scameronin 2010 that was not  
proximate to the issuance of a tax certificate. When asked if she could say what triggered this  
reversal given that no tax certificate was issued, she suggested there had been some kind of  
verbal request to the operator that prompted the reversal. When she was asked what benefit  
there might be to crediting an amount to the account and then reversing it three weeks later,  
she said this had the effect of putting the account back up to where it should be. She testified  
that in her view, “something triggered this entry, whether it was a phone call or email from  
lawyers or [the property owners] indicating they were about to sell their property … this could  
have been the trigger to the operator to enter the reversal”.  
[55] The file also contained a letter from 2010 from a lawyer involved in the sale of the property  
at that time. The letter noted that a cheque was provided in the amount given verbally by  
“Sandra”.  
[56] Ultimately, the Doyles were not required to pay the amount that Vadim showed was owing  
at the time of Ms. Lancaster’s investigation. There was no record of reminder notices having  
been sent to them prior to 2017. Because the Township could not show that the taxpayers were  
advised of the amounts that were owing, these were “written off”. In this case, the amount was  
$7,478.01.  
Tax Roll #13 Property owners: Germain/Gordon  
[57] Another tax account reviewed by Ms. Lancaster related to a property referred to as Tax  
Roll #13 during the trial. The issue with this account was a misapplication of a payment.  
[58] Documents from this file showed that on February 21, 2014, the TNG had received a daily  
payment report from a bank confirming payments from two taxpayers named Mr. Germain and  
Mr. McMillan. Mr. Germain’s tax payment was in the amount of $529.81.  
[59] Receipts reprinted from Vadim showed that operator “scameron” entered the payments on  
February 24, 2014. The receipts indicated that the Germain payment was for $265.98, not the  
$529.81 indicated on the bank’s report. The remainder of the funds were directed to the account  
of a third taxpayer, Rita Taylor.  
[60] Ms. Lancaster confirmed that a payment should not be applied anywhere except to where  
the property owner was directing the payment to be applied, and that the full amount of the  
payment should be indicated.  
[61] Notwithstanding that the misallocated payment resulted in a shortfall to Mr. Germain’s  
account due to penalties and interest for the unallocated portion of his payment, Mr. Germain  
was provided with a letter dated September 29, 2016, stating that his property taxes for the  
year 2015 were paid in full. This was not accurate.  
[62] In fact, according to the investigation and documents in the Vadim system, arrears of  
$439.10 were owed. This amount was written off by the TNG following its investigation since  
it had evidence that Mr. Germain had, in fact, made his payment in full in 2014. In addition to  
the documents within the Township’s possession, Mr. Germain also brought in his bank receipt  
showing he had made the payment.  
[63] Ms. Lancaster also testified that no funds were applied at all to the McMillan-owned  
property.  
[64] When asked about the consequence of these misallocated payments, Ms. Lancaster said  
that the consequence for Mr. Germain is that he was told he was in arrears in 2017 for an  
amount for which there is proof in the file that he had in fact paid. The amount he was told he  
was in arrears was the penalty and accrued interest from the misapplied portion of his payment.  
[65] A further consequence of that misapplied payment was that the tax account for Rita Taylor  
would have shown a payment to reduce her tax account, when in fact she had not made any  
payment in that amount. She benefited from that entry. As for Mr. McMillan, who had also  
made a payment through the bank, he did not benefit from that payment on that date and would  
have been advised he was in arrears “unless further manipulation was made to his account”.  
This would have resulted in him incurring penalties and, potentially, annual interest.  
Tax Roll #1 Property owners: Picard/Ranger  
[66] The issue for this account also related to an allegedly fraudulent and inaccurate tax  
certificate provided to a lawyer.  
[67] Ms. Lancaster’s investigation of the Vadim documents for this account showed a missed  
payment in September of 2007. A series of payments and reversals then took place in October  
of 2007. They were done by operator “scameron”. After this, penalties and interest began to  
accrue such that through to 2010, the amount payable on the account was never reduced to  
zero.  
[68] The file also showed that on July 13, 2011, a tax certificate was issued to lawyer P. Serdyk.  
The certificate stated that the account had a zero balance for outstanding tax arrears. It was  
signed by Micheline Larocque for Sandra Cameron.  
[69] The file documents also show that prior to that certificate being issued, a reversal was done  
on the account by operator “scameron”. The reversal of $509.99 brought the account balance  
to zero. This meant that the tax certificate could show that nothing was owing.  
[70] Subsequently, on August 2, 2011, a reversal of the payment from July 13, 2011 was made  
by operator “scameron”. This reversal had the effect of showing that there were amounts past  
due on the account.  
[71] The review of the file showed that there were seven reversals of payments on the account  
between 2007 and 2011. There were no subsequent entries for any of these that suggested the  
reversal occurred because a number was mis-entered. There were no notes in Vadim explaining  
why the reversals had occurred.  
[72] According to Ms. Lancaster, this number of reversals on a file is not common. Further, she  
testified that they all “occurred because of some event or payment that was about to happen”.  
She explained that the reversals she observed were relative to a tax certificate being issued  
showing false amounts owing, or payments that taxpayers were actually making that were  
subsequently reversed. In some cases where interest was going to be charged, a receipt was  
entered and it reduced the charges to the point that interest would not be charged to the account.  
[73] The result was that the arrears owing to the TNG were not reducing as they should be if  
normal processes were being followed. Ms. Lancaster testified that this should have been a red  
flag to the Township’s treasurer and its auditors.  
[74] The investigation of activities on this account included an interim tax bill from 2016,  
brought into the Township by the Picards. There were no amounts showing as being due on  
that bill. While Ms. Lancaster initially testified that there was whiteout on the bill, she later  
stated she could not be sure that this was the case for this bill. Regardless, the bill was showing  
that no amounts were past due when this was not the case. The bill did not reflect the true  
amount owing on the account, which was $3,610.26.  
[75] Ms. Lancaster did not find any evidence in the file that any reminder notices had been sent  
out regarding these arrears. None were saved. There was no notation within Vadim referencing  
the issuance of a reminder notice.  
[76] Consequently, the Township adjusted the Picards’ account and wrote off $1,167.21, which  
represented the accrued penalties and interest that originated with the missed payment in 2007.  
[77] Because the file showed that the property owners for this account both consistently paid  
their bills, Ms. Lancaster said this suggested that the Picards were not shown that they had past  
amounts due or sent any reminder notices. After three years’ worth of penalties and interest  
had accrued, she would expect a reminder notice to be issued given the more significant  
consequences for the property owners. Ms. Lancaster said she did not locate any document  
from this file in Ms. Cameron’s filing cabinet that contained files with taxes owing for over  
three years.  
Tax Roll #10 Property owners: Menard/Leblanc  
[78] The allegation involving this account is that a fraudulent and inaccurate tax certificate was  
issued by the accused through the use of Vadim’s test environment.  
[79] The documents presented during Ms. Lancaster’s testimony demonstrate that this tax roll  
account had a zero balance at the beginning of 2007, and then fell behind. Penalties and interest  
were charged for the subsequent years.  
[80] In 2016, a request was received for a tax certificate by lawyer J. Bergeron. A certificate  
was issued in the name of Sandra Cameron indicating that there were no past due amounts on  
the account. Below the signature line, Ms. Cameron’s office phone number was handwritten.  
[81] In 2017, the new owner of the property, Mr. Leblanc, contacted the tax department about  
his account being in arrears. This initiated Ms. Lancaster’s investigation of this account. She  
could not find a copy of the tax certificate in Vadim, which indicates it was not issued in the  
live environment. Further, she located a tax certificate with the same number this one had  
been issued months earlier to a different lawyer.  
[82] Ms. Lancaster recreated a tax certificate for the day before the property’s sale, and it  
showed that at that time, there was a total of $3,114.26 past due, in addition to upcoming taxes  
levied.  
[83] In this case, the previous owner (Mr. Menard) produced a copy of a cheque that had been  
used to pay his account in 2007. Ms. Lancaster concluded that the cheque was not applied, as  
Mr. Menard directed, to this roll number (the cheque was for the taxes due on a number of  
properties, including this one). She was unable to find any deposit cheque in that amount.  
Further, Ms. Lancaster said it appeared that the taxpayer was never notified of any amounts  
past due and interest, at least on their tax bills.  
[84] Consequently, the Township wrote off the amounts owing on the account in 2017, which  
by then totalled $3,519.88.  
Tax Roll #7 Property owners: Sultan/Delormes/Burke/Beauclair  
[85] This tax roll investigation led to another allegation that Ms. Cameron issued or caused to  
be issued fraudulent and inaccurate tax certificates. Another employee of the Township, Ms.  
Wray, assisted the Ontario Provincial Police (OPP) with this part of the investigation.  
[86] During her testimony, Ms. Lancaster reviewed a number of documents and provided an  
overview of the events alleged.  
[87] The first problematic tax certificate was dated May 24, 2013 and was provided to lawyer  
P. Syrduk. It was signed by Micheline Larocque for Ms. Cameron. It indicated there were no  
amounts past due. However, other Vadim documents show that the balance owing as of that  
date was $4,968.38.  
[88] Ms. Lancaster confirmed this certificate was issued in the live environment. Other Vadim  
documents also showed that operator “scameron” entered a receipt on the same date. The  
receipt was for a payment of $4,968.38. The payment had the effect of reducing the amount  
owing on the account to zero. The payment was subsequently reversed by operator “scameron”  
on June 3, 2013.  
[89] A second tax certificate was issued on May 25, 2016 and was provided to lawyer M.  
MacLean. It was signed by Sandra Cameron and her office phone number was handwritten  
under the signature line. It indicated there were no amounts past due.  
[90] Ms. Lancaster testified that this tax certificate would not have been issued in the live  
environment, but in the test environment. She knew that because, when she tried to reprint it  
based on the roll number, it is not available in the live environment. Instead, she found that tax  
certificate was issued to another roll number and a different law firm. Based on other Vadim  
records, Ms. Lancaster determined that the actual amount owing at the time was $7,248.00.  
[91] In addition to these irregularities, Ms. Lancaster testified that there were a number of  
reversals on this account going back to 2011. A number of these preceded a true payment on  
the account.  
[92] Ultimately, the Township also wrote off amounts owing for this account totaling $8,243.16.  
[93] Ms. Lancaster was asked whether, following her review of the 14 files that are the subject  
of the charges, there was a particular theme throughout. She said there was. She said that  
payments entered by operator “scameron” were entered in the system in the live environment,  
in some cases preceding a true payment. There were also instances where the payment was  
entered by the operator to reduce the payment down to zero, at which time a tax certificate was  
issued, in some cases in the live environment, and sent to a lawyer showing nothing was due  
and owing when in fact there were arrears owing. In some instances, she was unable to trace  
the tax certificates provided by the lawyers in the live environment and she determined that  
these tax certificates were produced in the test environment.  
Who benefitted from the transactions?  
[94] At various points in her testimony, Ms. Lancaster was asked to explain who might benefit  
from a particular transaction.  
[95] She said that where reversals were done proximate to a request for a tax certificate, the tax  
certificate would not show the true amounts past due. The taxpayer would benefit by not having  
to pay interest on amounts due.  
[96] Taxpayers would also benefit if they were placed on an automated payment plan despite  
having outstanding balances due. This was because the default settings in Vadim were such  
that penalties and interest would not continue to be assessed on those accounts. The  
municipality was therefore not collecting interest payments that were due.  
[97] Ms. Lancaster did not offer any insight into any benefit that might otherwise be obtained  
by entering a payment and then reversing it a number of weeks later.  
[98] At one point during cross-examination, Ms. Lancaster was asked if she was suggesting a  
scheme by operator “scameron” to dishonestly help taxpayers by showing that they owed no  
taxes. She replied: “The suggestion is that those receipts are entered in many cases incorrectly  
to show incorrect balances on the tax accounts prior to various events, e.g. a tax certificate  
requested by a lawyer”. She said that in some cases, accounts were not charged the correct  
amount of interest and emphasized this was all she was saying.  
[99] Ms. Lancaster was then asked the following: if the operator intended to somehow assist the  
seller in a property sale by showing there were no arrears owing, would it not make sense to  
credit an amount that wiped out the arrears? She was then asked whether she saw anything in  
that scheme that benefited the operator who created the false receipt and false reversal. Ms.  
Lancaster said that while it was only a suggestion, a benefit could be that the operator did not  
have to deal with an angry taxpayer questioning where arrears came from and explain things  
to them in detail.  
[100] When she was asked to confirm she could not see any financial benefit to the operator from  
this scheme, she said “I can’t answer that because we don’t have the records back in 2007-  
2008”. When she was asked whether any of the payments could be diverted into personal funds,  
she said she had no way of knowing that.  
[101] Ms. Lancaster re-iterated again, later in her testimony, the potential benefit of not having  
to deal with an irate taxpayer questioning why there were arrears owing on the tax account  
when they were led to believe that nothing was past due. She was deducing that taxpayers  
would have paid what they were billed, and confirmed there was no way of knowing if a tax  
bill had not been mailed out to a particular taxpayer.  
[102] Ms. Lancaster was asked whether she found any notes in Ms. Cameron’s workstation that  
referenced reversals to be made in the future. She said she did not and added that just because  
she did not find them did not mean there were some she did not find. She appeared to agree  
that there had to be some kind of record kept because of the volume of reversals that took place.  
Later in her testimony, she disagreed that it would take a lot of organization or planning to  
keep track of receipts to be reversed, explaining that Vadim could be searched by using batch  
and deposit numbers, as well as roll numbers.  
[103] She noted that after Ms. Cameron had gone on sick leave, she found “diaries” (which she  
described as like a calendar/agenda book) which were turned over during the investigation.  
She did not see any notes regarding reversals in those books.  
[104] Ms. Lancaster was not aware of any personal connection between Ms. Cameron and any  
of the property owners involved in the problematic transactions.  
Reversals by operator “scameron”  
[105] Ms. Lancaster reviewed a spreadsheet containing data relating to the reversals done by  
operator “scameron” (Exhibit 26). A number of these occurred on the same day as the receipt  
was entered. In other instances, more than two weeks had elapsed, with the longest gap being  
35 days. Ms. Lancaster said that typically, if a cashier error had been made in entering a  
payment, the reversal would be done within a day or two.  
[106] The spreadsheet referenced 2212 reversals over a number of years. It indicated that in the  
year 2012, 859 reversals were entered by “scameron”. In Ms. Lancaster’s experience, this was  
greatly above normal.  
The evidence of Johanna (a.ka. Annie) Levac  
[107] Johanna Levac was the treasurer for the TNG during the timeframe of the alleged offences.  
She and the accused had worked together for years by that point. They met while working for  
another township in 1995.  
[108] Ms. Levac was no longer working for the TNG when she testified. She had been  
“terminated with cause”. It was her understanding that the TNG took the position that she had  
not properly done her job. Ms. Levac disputes this. There is ongoing litigation in respect of her  
dismissal.  
The accused’s positions and responsibilities  
[109] Ms. Levac confirmed that Ms. Cameron’s role in the office changed over time before she  
stopped working at the TNG in early December of 2016.  
[110] Prior to 2008, Ms. Cameron was the assistant tax collector for a number of years, working  
alongside Jean McLeod who was the tax collector. When Ms. McLeod retired, Ms. Cameron  
was the successful applicant for the tax collector position. She started this position in early  
2008. She had been the assistant tax collector for about five years at that point.  
[111] When Ms. Cameron became the tax collector, a new assistant tax collector was hired.  
Micheline Larocque assumed the role shortly after Ms. Cameron moved into her new position.  
When Ms. Cameron had the position, the assistant tax collector worked fulltime. Ms. Larocque  
worked in the position only half-time.  
[112] The tax collector was responsible for a number of tasks. This included sending out property  
tax billings (including an interim billing in February and the final billing in June), all  
adjustments, minutes of settlement, transactions regarding appeals of property assessments,  
and reminder notices. Ms. Levac said these were usually sent out six to seven times a year to  
remind people when they owed money. For many years, the tax collector was also responsible  
for counting the cash, and she balanced the taxes on a monthly basis. As Ms. Levac put it,  
anything with tax collection funneled through that position”. She confirmed that only the tax  
collector had the authority to authorize a taxpayer to start on a preauthorized payment plan.  
The Vadim system  
[113] Ms. Levac was familiar with the Vadim system. It was her recollection it had been in use  
in the tax department since 2007 (she also said the tax module was implemented in 2006).  
There was an overlap period when both Vadim and the old system were in use. Following that,  
outstanding balances on approximately 6,000 accounts were transferred to Vadim. She could  
not recall if the system was fully implemented in 2006 or 2007. Ms. McLeod, Ms. Cameron,  
and someone from Vadim were involved in ensuring that the required information was carried  
over from the old system into Vadim.  
[114] When the software was adopted, she had received an overview of how the modules  
worked. Her own work was done in Vadim using a general ledger and budgeting module.  
[115] According to Ms. Levac, the initial training on Vadim was done over three days with  
Lorraine Drinkwalter. Ms. McLeod and the accused attended that training, which included  
another employee as well. At the time, Ms. Cameron was being trained as a back up to Ms.  
McLeod. She was only working part time as an assistant tax collector and her time was split  
with other departments.  
[116] Ms. Levac agreed that the training did not use actual file data but involved hypotheticals.  
There was no opportunity to do live entries. The training also occurred several months before  
the tax module was implemented and employees did not actually start using Vadim after this  
training.  
[117] Thereafter, there were Vadim conferences that employees could attend, and the area’s tax  
collectors and their assistants also met and had occasions to learn from one another. Ms. Levac  
said that Ms. Cameron had attended at least three or four Vadim conferences. Vadim also had  
a support line where assistance could be sought.  
[118] Ms. Levac said she was not aware of any policies in place around the use of the test  
environment in the tax module. She understood that the test environment was a working tool.  
There was nothing to distinguish documents done in the test environment, though this changed  
after the accused left the Township.  
[119] Ms. Levac had the authority to grant access to Vadim to employees. Not all employees had  
the same access. Over time, certain parts of the tax module were made available to the  
receptionist so that person could see what was owing on an account when a taxpayer came in.  
The receptionist could then conduct all deposits and enter payments when residents came in.  
The receptionist did not have the authority to make changes to accounts but could access  
information. The tax collector and assistant tax collector, as well as the treasurer and her  
deputy, had the authority to make corrections or adjustments.  
[120] The receptionist position was held by Ms. St-Denis, and then by Chloe Crack and other  
individuals whose names Ms. Levac could not recall. Ms. Crack was given more authority  
under the Vadim tax module because she was also acting as the assistant tax collector for a  
time after Ms. Larocque had moved on. She would also have been able to make “adjustments”.  
Ms. Levac explained that this term was not the same as a “reversal”, but referred to things like  
dealing with a NSF cheque, or adjusting an account to credit penalties and interest when a  
payment was received but not processed on the last day taxes were payable.  
Evaluations of the accused’s performance  
[121] Ms. Levac was responsible for employee evaluations in her office, including for the tax  
collector. For the most part, these were conducted annually.  
[122] In 2008, as part of her evaluation of the accused’s job performance, Ms. Levac  
recommended that the accused be moved up to a level 4 pay grade this was the second highest  
pay grade. By February of 2009, she was recommending that Ms. Cameron be moved to level  
5, which was the top level.  
[123] The performance evaluations referenced recurring issues. For instance, Ms. Cameron’s  
lack of organization was a persistent theme. She had a habit of piling papers on her desk and  
not filing them as she should so other people in the office could also access information from  
the file. Performance evaluations done with input from other employees also remarked on her  
lack of organization.  
[124] Ms. Levac confirmed that dealing with taxpayers was a difficult part of the job. Some  
would get vocal “and take it out on staff”. Ms. Levac said the accused did a good job and  
handled them quite well. She gained confidence in this area over the years. If there was a very  
angry taxpayer who was complaining about the taxes assessed, Ms. Cameron would refer them  
to Ms. Levac. Calls relating to potential errors in accounting were handled by Ms. Cameron.  
She assumes Ms. Cameron dealt with them because those calls did not come to her.  
[125] Ms. Cameron was consistently evaluated at the top of the scale for following rules and  
regulations. Ms. Levac said, “there were never any issues there”. She scored consistently  
highly for respecting public funds. Ms. Levac agreed that the accused seemed deeply  
committed to her job and that she was a dedicated employee with impeccable attendance.  
[126] In an evaluation from 2001, the accused identified that she needed to be more organized  
and prioritize work over personal issues. Ms. Levac agreed the accused could have been  
referring to having to assist her brother who had significant health problems.  
[127] Ms. Cameron also identified the need for training, including on Vadim when it was in its  
first year of use. She identified her objective of focusing “on a new attitude toward change”  
and gave as an example the Vadim system. Ms. Levac recalled that at the time there was a lot  
of resistance from Ms. McLeod, Ms. Cameron, and other staff to using Vadim since they were  
comfortable with the old system. In later years, Ms. Cameron did not raise with Ms. Levac any  
ongoing issues or difficulties with Vadim. Evaluations from other years noted Ms. Cameron’s  
intention to become more proficient with technology and not need IT staff’s assistance as much  
(2007), and requests for additional training in Vadim (2007) or “any information or courses  
available” (2011).  
[128] Ms. Cameron also identified in 2011 that she had missed some errors in checking certain  
accounts. She intended to work on “lowering tax arrears” and being more diligent in catching  
errors. Ms. Levac recalled that at the time, the tax arrears in the Township were quite high.  
They had escalated since the recession in 2008. People were falling behind on their taxes and  
it was a pervasive problem. To her knowledge, it was a common problem across other  
municipalities in the region. In the evaluation for 2012, Ms. Levac noted that Ms. Cameron  
“strives to reduce tax arrears”. She said that at this time, she was not aware of any reminder  
notices that were not going out.  
[129] The 2012 evaluation also included a comment by Ms. Levac that Ms. Cameron had  
“excellent knowledge in the property tax module in Vadim”.  
[130] In the final evaluation done in 2013 (in respect of the accused’s job performance for 2012),  
Ms. Levac noted in the evaluation that Ms. Cameron met all deadlines for tax billings; she met  
all standards; she respected public funds; she did not require supervision; she was willing to  
accept additional work; and she welcomed new responsibilities. Ms. Cameron was described  
as a “very reliable and dependable employee”.  
Reversals  
[131] Ms. Levac testified that reversals were necessary from time to time but should not happen  
often. They would be necessary where a payment was mistakenly posted to the wrong account.  
In those cases, she expected there would be some kind of explanation noted.  
[132] It was Ms. Levac’s practice to make a note providing an explanation when she was asked  
by the receptionist to do a reversal. After she had made the correction, the receptionist would  
then make the proper posting. When Ms. Levac was making the reversal entries, she logged in  
and out of Vadim using her own credentials. The receptionist’s transactions would be done  
under her own credentials.  
[133] Ms. Levac became aware of all the reversals that had occurred in the tax department after  
the 2017 investigation. At the time, she was not aware. She said she never had any reason to  
go into Vadim to look at spreadsheets such as the one compiling all the reversals made by  
operator “scameron” (Exhibit 26).  
Username and password access to Vadim  
[134] The username for Vadim reflected a pattern using the employee’s names. Ms. Levac agreed  
it would have been easy to determine another employee’s username.  
[135] It was Ms. Levac’s recollection that passwords for Vadim eventually had to be changed on  
a monthly basis. However, there were no policies in place regarding security in the early stages  
of using Vadim. It was not necessary to have complicated password with special characters in  
the early years. She agreed that when it became necessary to change passwords monthly, it  
could have been possible to use a prior password. In other words, it was possible to alternate  
between two passwords indefinitely.  
[136] Inactivity in Vadim would result in an employee being logged out. Ms. Levac believes  
Vadim always had this feature and recalled that it was frustrating to staff. She agreed that over  
time, various security features were tightened in Vadim, including the amount of inactive time  
allowed before being automatically logged out.  
[137] Ms. Levac was asked if she agreed that it was fairly common for the accused to allow others  
in the office to make a quick entry using the accused’s credentials in Vadim. Ms. Levac said  
she was not aware of that. She also suggested that would not have happened since other  
employees did not have training or experience in conducting certain transactions in Vadim.  
Reminder notices  
[138] Reminder notices were sent out to taxpayers in arrears at various times after billing dates  
had passed (e.g. in May, June, October, November and December). The notices were printed  
on green paper. As far as Ms. Levac knew, they were being sent out. She could see staff  
working on them when she was in the tax collector’s work area.  
[139] Ms. Levac said she remembered one occasion where she asked the accused why she was  
flipping through the reminder notices. The accused said she knew that some taxpayers were  
appealing and there might be an adjustment on the account, and she wanted to put a note on  
the file. Ms. Levac did see the accused putting such notes on files. She was also aware that if  
a taxpayer had multiple properties, the accused would pull all the notices for the same owner  
together to save on postage. Ms. Levac said there was nothing untoward about that. She thought  
the accused was doing her due diligence” and that it was a nice gesture to make a notation on  
their reminder notices. Ms. Levac saw the notations the accused made in 2017 because some  
were still on her desk that had not been mailed out yet. In other instances, she saw the notation  
when residents brought in their documents.  
[140] Ms. Levac also saw some of the letters that the accused sent out with the reminder notice.  
She said they had worked together to bring the arrears down, particularly where the taxpayer  
was more than three years in arrears.  
Reversals  
[141] Ms. Levac believed that it was possible to reverse a whole batch in Vadim, even one with  
many entries. The entries would all be reversed together.  
[142] She agreed the spreadsheet containing reversals by “scameron” referenced separate lines  
for entries from a single batch. Some of these batches contained upwards of 100 individual  
entries. It was suggested to her that reversing these entries from the same batch on different  
dates would require a high degree of organization. Ms. Levac answered that she knew that in  
2017 the auditors questioned these entries, and she could not answer why such transactions  
would be done. The money was in and out and it did not make sense.  
The improper use of the cash box  
[143] There was a cash box in the office that was used to store cash that taxpayers used to pay  
their bills. Cheques were placed in the box as well. The cash and cheques were taken to the  
bank daily after the deposits were balanced.  
[144] Ms. Levac became aware that some staff were borrowing from the cash box. They would  
place an IOU in the box and withdraw funds. She agreed it was also common for employees,  
including the deputy treasurer, to write a cheque to the Township and then take the  
corresponding funds from the cash box. She agreed these practices made it problematic to  
manage, as these were non-tax paying transactions. She put a stop to both practices and  
employees were advised they could not use the cash box to make personal withdrawals.  
Ms. Levac’s observations of irregularities in the tax department  
[145] After Ms. Cameron left on sick leave in December 2016, Ms. Levac hired Linda Lancaster  
to act as the tax collector at the beginning of 2017. One of the first things she started to do was  
organize payments for persons on a pre-authorized payment plan. Ms. Lancaster told her that  
a number of these taxpayers had outstanding balances. This was a red flag.  
[146] As the month progressed and the interim tax bills went out, phone calls started coming in  
from taxpayers who had arrears owing. It was then that Ms. Levac definitely realized that  
something was amiss.  
[147] Some of the phone calls from upset taxpayers were referred to Ms. Levac.  
[148] In one instance, Ms. Levac spoke with the son of a senior taxpayer who was questioning  
why his mother had been sent a reminder notice indicating she had a balance owing. Ms. Levac  
informed him that his mother appeared to have missed a payment and that penalties and interest  
had been accruing for ten years. The son ultimately produced a receipt for the taxes that the  
Township alleged had not been paid. The receipt indicated the amount owing had been paid in  
full in cash. Ms. Levac apologized, told the taxpayer’s son it was their error, and adjusted the  
taxpayer’s account. The Township wrote off the penalty and interest.  
[149] After Ms. Cameron left, two employees cleared her work area. Everything was put in  
boxes. The documents included reminder notices and tax bills that had not been mailed out to  
taxpayers. Ms. Levac said that it should not be common to not send out these documents. A  
document might be held back if the tax collector knew there was a large appeal pending. She  
remembered one time asking the accused why certain tax bills were not mailed out. The  
accused said she had to go through them because some were waiting for credits and she wanted  
to put a notation so that when the resident received the bill, the taxpayer would know what was  
happening in the process. This would avoid a phone call. Ms. Levac said that seemed to be a  
logical explanation.  
[150] Ms. Levac also testified about an incident in 2014 that led to the accused tendering her  
resignation. She did not end up following through on that. Ms. Levac convinced her not to.  
[151] The incident in 2014 involved another employee in the office, Sylvie Major, who had  
discovered her uncle’s account had tax arrears. Because she knew her uncle to always pay his  
bills, Ms. Major looked into the situation. She brought to Ms. Levac’s attention that the  
payment made by her uncle had not been properly allocated to his account. His payment was  
part of a group of four to five payments from other taxpayers that had been made to the  
Township by their bank.  
[152] Ms. Levac confronted Ms. Cameron about this very serious issue. She did so in the presence  
of the Chief Administrative Officer for the Township, Dan Gagnon, in the office boardroom.  
The accused said she did not know what she did and that maybe it was the medications she  
was on (Ms. Levac demonstrated that Ms. Cameron was holding her head as she said this). Ms.  
Cameron said something to the effect of “I must have screwed up”.  
[153] The accused went to her workstation afterward. Within a half hour, Mr. Gagnon came to  
Ms. Levac with a letter of resignation from Ms. Cameron. Ms. Levac called Ms. Cameron up  
to her office. The accused said she was handing in her resignation in view of the fact that Ms.  
Levac no longer trusted her. Ms. Levac told the accused that the tax collector position was a  
good job with very good benefits and not to walk out if she had made one mistake. She said if  
only one error had been made, they could correct it. The accused was emotional during this  
conversation, almost in tears. The accused reiterated that she did not know what happened and  
she must have screwed up.  
[154] While Ms. Levac was aware that the accused had health issues, she was not aware of the  
accused having an appointment with a cardiologist on the same day. When it was suggested  
to her that in fact the accused had gone to the hospital between the conversation in the  
boardroom and the conversation in her office, Ms. Levac said she did not believe there would  
have been enough time for that given the time between the conversations.  
[155] Afterwards, Ms. Levac and her deputy, Ms. Kitchen, went through six months of cash  
receipts to make sure the postings had been done properly and there were no other issues of a  
similar nature. The focus of their investigation was to make sure that money that was deposited  
had been applied to the proper accounts. They were not looking for receipts that were reversed.  
The normal process for the discovery of errors or irregularities  
[156] Ms. Levac agreed that if receipts were created for fictional funds that were not actually  
paid to the Township, this would be picked up very quickly. This is because the deposits for  
the bank were balanced daily. It would be a huge red flag if a receipt was created and there  
was no corresponding deposit. Ms. Levac would be notified if there was an issue with a deposit.  
[157] If the funds had actually been deposited but the receipt was credited to the wrong taxpayer,  
then the bank balance would still be what it is supposed to be. The error would not be picked  
up in that daily balancing. A posting error might only come to Ms. Levac’s attention when a  
taxpayer discovered the error and complained.  
[158] Ms. Levac said she got a monthly tax reconciliation to make sure all accounts were  
balanced. She never came across anything of concern when either Ms. McLeod or Ms.  
Cameron were the tax collectors.  
[159] There were also regular audits. Twice a year, the Township’s finances were audited. The  
auditors dealt with the accused and were able to ask her for documents. Nothing of concern  
was reported to Ms. Levac following the audits. The auditor might make a “small”  
recommendation, and Ms. Levac would ask if there were any red flags she should be concerned  
about. None were ever identified to her.  
[160] Ms. Levac was also asked about the process for issuing a tax certificate. She was asked  
about the tax certificate issued in Tax Roll #1, and whether she could explain how a tax  
certificate might show no arrears owing when they are indicated on the client inquiry document  
in Vadim. Ms. Levac noted that in this situation, there had been a reversal, so that when the  
tax certificate was issued there was a zero balance. This was not a proper method, because the  
amount owing on a tax certificate is as of a specific date. She could not think of any scenario  
where a tax collector would go into Vadim and not recognize there were arrears owing as of  
the date the tax certificate was requested. She said they would see it right away.  
[161] Ms. Levac was asked the following: whether or not the original problem was from a  
misapplied payment, by 2011, should the tax collector have realized that there was a problem  
with this account? Ms. Levac replied “Yes, I would have said there is something going on,  
there is no reason for that”. She added that if there was an issue with the Vadim system, it  
should have been brought to her attention. Nothing was.  
Items found in the accused’s work area  
[162] Ms. Levac confirmed that after the accused went on sick leave, she asked two employees  
to clean out her work area. Ms. Levac and another employee went through the boxes  
afterwards. She did not recall finding anything that could be called a diary, notebook or steno  
pad. She did recall finding notes on loose pieces of paper.  
[163] Ms. Levac was asked about reminder notices that were found in Ms. Cameron’s work area.  
She said they were recent, dating within four months of Ms. Cameron’s leave. While she said  
she would be guessing at this point, she estimated that about half of the documents found in  
Ms. Cameron’s work area were reminder notices and half were tax bills.  
The tax roll accounts investigated in 2017  
[164] Ms. Levac confirmed that transactions from 2007 are from when Ms. McLeod was the tax  
collector and the accused was the assistant tax collector.  
[165] During cross-examination, Ms. Levac reviewed the spreadsheets that had been prepared  
showing the losses allegedly sustained by the Township. She reviewed this spreadsheet in most  
of the fourteen files that were the focus of the OPP investigation and resulted in these charges.  
[166] In a few instances, Ms. Levac agreed there were accounting or data entry errors made. In  
one instance, she agreed that the spreadsheet included losses in relation to funds that a taxpayer  
had proved had been paid by supplying the relevant receipt. This was a different incident than  
the one involving the senior taxpayer whose son had called to complain.  
[167] In all instances, including the instance with the senior taxpayer whose file was not a focus  
of the OPP investigation, Ms. Levac agreed that the original source of the penalties and accrued  
interest not paid on the account dated to a period between 2006 and 2008, when Ms. McLeod  
was the tax collector and the accused was the assistant tax collector. Since many of these  
taxpayers were otherwise up to date in paying their bills, she agreed that it was possible or  
even likely that the taxpayer had in fact paid a tax installment and this had not been properly  
recorded in the Township’s records.  
[168] A summary of Ms. Levac’s evidence in relation to each tax roll file follows.  
Tax Roll #1  
[169] Ms. Levac agreed that the documents available for this tax roll showed that between 2008  
and 2016, the taxpayer paid in full all amounts owed for their annual taxes.  
[170] She further agreed that the root problem causing the accumulation of penalties and interest  
for a period of ten years was a shortfall in paying what was owed in 2007. When she was asked  
if she agreed on a balance of probabilities that given the taxpayer’s history of payment, that it  
was likely that they had paid in full in 2007 and the payment was not showing up for some  
reason, she said “it didn’t get credited to the account, no”. She agreed the only way to know if  
the taxpayer made the payment was to reference the municipality’s bank records or be provided  
with proof of payment by the taxpayer.  
Tax Roll #2  
[171] This was another tax account where the shortfall in payment dated from 2007.  
Notwithstanding that a Vadim document indicated the taxpayer owed over $2,000 at the end  
of 2007, the account was placed on a pre-authorized payment plan that began in 2008. Ms.  
Levac agreed it was very possible that this pre-authorized payment plan might have been set  
up by Ms. Cameron’s predecessor, Ms. McLeod, in December of 2007. She said either Ms.  
Cameron or Ms. McLeod could have done so in that time frame.  
[172] Ms. Levac agreed that the taxpayer was generally up to date with the payment of annual  
taxes billed after that.  
Tax Roll #3  
[173] In this file, the root problem leading to penalties and interest being charged arose in 2006,  
when there was a shortfall in payment of $1,300. After that, the amounts owing accumulated  
year after year. It resulted in a write-off by the Township of $7,111.  
[174] Ms. Levac agreed this was the third file where the initial problem arose during the transition  
between the old tax software and Vadim.  
Tax Roll #4  
[175] In this file, Ms. Levac agreed that the figure used in the spreadsheet for the beginning  
balance in 2006 was in error.  
[176] She further agreed that the root problem in this file related to a missed payment in 2007,  
and that this was during the transition period between the old software and Vadim. She agreed  
that it was possible the payment was either missed or misallocated.  
Tax Roll #6  
[177] Ms. Levac agreed that the taxpayer in this file paid what was owed “give or take a few  
dollars” for every year between 2008 and 2016. A shortfall of $400 was noted in 2007. She  
agreed that 2007 was an anomaly in the payment history. She was asked if she agreed there  
was a very strong possibility that the taxpayer actually did pay their taxes in full in 2007 but  
that this was somehow not credited to the account. She replied: “that is very possible”.  
[178] Ms. Levac also agreed that if the taxpayer had paid in full, they would not in fact owe any  
penalties and interest. She agreed in that scenario, the Township would not be out any money.  
Tax Roll #7  
[179] In this file, the shortfall in payment was a little over $800 in 2007. The taxpayer’s history  
otherwise showed a history of being up to date during most years before and after 2007.  
[180] Ms. Levac agreed that 2007 was an anomalous year in the taxpayer’s history. Further, three  
of the four payments required in 2007 were made in full. Only one installment was missed in  
July. As of 2017, this missed payment led to a further amount owing of over $1,000 in penalties  
and interest.  
[181] Ms. Levac agreed that there was a strong likelihood that the taxpayer had made the July  
payment but for some reason it was not credited to the account. She agreed that without the  
municipality’s bank records, it was not possible to conclude that the municipality had in fact  
suffered a loss in this case.  
Tax Roll #8  
[182] The taxpayer in this file was up to date by the end of both 2006 and 2007. They also paid  
the annual taxes levied between 2009 and 2017 in full. In 2008, however, there was a shortfall  
of approximately $500.  
[183] Ms. Levac agreed that the spreadsheet prepared for this file was inaccurate, since it showed  
an opening balance of $27 in 2008, while other Vadim documents indicate nothing was owed.  
Nevertheless, this amount was included in the write-off by the Township.  
[184] Ms. Levac agreed this was another file that showed the taxpayer had failed to make a  
payment for one installment, and that it did not make sense given the payment history that the  
taxpayer would fail to pay one installment. Further, the taxpayer in this case provided the  
Township with proof the payment had, in fact, been made. His receipt showed he had paid in  
cash. It was initialed “JB”, which Ms. Levac believes was Jennifer Bourdon, who had worked  
as a receptionist in the office. The receipt was dated July 29, 2008. Ms. Levac agreed that we  
know that a payment made by this taxpayer was not recorded in the Vadim client inquiry  
document. She said she would have expected that Ms. Bourdon would have included the  
receipt in the cash for the day, and that the tax collector or assistant tax collector would have  
inputted the transaction and conducted the balancing.  
[185] Penalties and interest were assessed as a result of the allegedly missed payment. Ms. Levac  
agreed that because the Township had actually received the payment on time, there was no loss  
to the Township. Even though she made a note in the file that the taxpayer had provided proof  
of payment, this amount was written-off by the Township.  
Tax Roll #9  
[186] Ms. Levac agreed that the spreadsheet prepared for this file made reference to a different  
roll number than the Vadim client inquiry document that was otherwise said to document the  
transactions on the account. She did not understand why.  
Tax Roll #10  
[187] This file involved another taxpayer who appeared to pay their bill in full every year but  
who fell short in 2007. Ms. Levac agreed this could be another instance where the taxpayer  
had paid but was not credited for the payment in 2007.  
[188] At this point, Ms. Levac indicated that what surprised her about all of these cases was that  
the taxpayer did not realize for ten years that they had a balance owing. The balance owing for  
arrears should have shown up on the 2008 bill and thereafter. It surprised her that with new  
bills showing arrears and reminder notices, that the taxpayer would not have known for ten  
years that a balance was owing.  
Tax Roll #11  
[189] In this file, the taxpayer was up to date between 2002 and 2007. One installment was not  
paid by the late September due date in 2008. Ms. Levac agreed this could well be a situation  
of a payment that was received but not applied to this account, saying she really did not know  
if that payment had been made.  
Tax Roll #12  
[190] The taxpayer in this file was up to date at the end of 2006, and again after 2007. A shortfall  
was noted in 2007, which resulted in penalties and interest. Ms. Levac agreed that 2007 was  
an anomalous year in the taxpayer’s payment history. She could not say if the payment missed  
in 2007 was not made or not properly credited.  
Tax Roll #13  
[191] Ms. Levac was unable to say whether this account involved the same deposit with a  
misallocated payment that she had confronted Ms. Cameron about in 2014.  
Other issues  
[192] Ms. Levac agreed that taxpayers who were in arrears could arrange with their bank to pay  
on a monthly basis, but this kind of payment was not referred to within the tax department as  
a “pre-authorized payment plan”. Such payments could be set up since penalties and interest  
would continue to be charged to the account. It was suggested to Ms. Levac that from time to  
time, though relatively rarely, she allowed someone to be placed on a pre-authorized payment  
plan even though they owed arrears. She said she would never authorize that. If she authorized  
anything, it was not to permit a pre-authorized payment plan but monthly payments.  
[193] While Ms. Levac said she had never heard of employees having any problems downloading  
the MPAC disc to Vadim, she agreed that it was possible that printing tax bills became  
problematic, and that the process of printing bills had to be started over. She thought in that  
case there would be a report available to show which documents had not been printed.  
[194] Ms. Levac never saw anyone other than the accused use the accused’s workstation.  
Similarly, she never saw the accused using someone else’s workstation, except potentially  
when training was in session.  
The beneficiary of the problems in the tax department  
[195] Ms. Levac was asked if she ever saw any sign that the accused benefitted in any way from  
the accounting irregularities discovered in 2017. She said she had no reason to think that way  
at all. She did not see any change in the accused’s lifestyle. She was asked if any of the  
transactions, including reversals, put any money in Ms. Cameron’s pocket. She said she could  
not see how it would.  
[196] Ms. Levac said in some cases there was a benefit to the taxpayer. She agreed, however,  
that in some instances, she really could not say if the taxpayer had actually paid the amount  
owing.  
Additional evidence adduced by the Crown  
[197] Additional evidence was given by other employees of the Township. Their evidence was  
consistent to the effect that after Ms. Cameron went on her leave, various problems with the  
tax accounts were reported by taxpayers or otherwise came to their attention.  
[198] Their evidence differed about what passwords and usernames were required to log into  
Vadim, which is not surprising given the passage of time. However, no witness agreed that  
they had ever used Ms. Cameron’s credentials to perform any functions in Vadim.  
[199] Many of the witnesses testified that Ms. Cameron was usually the first person in the office  
in the morning, and that she stayed to the end of her full shift or later. Ms. Cameron had to be  
forced to take vacations.  
[200] What follows is a summary of the more salient points in the evidence to the issues in dispute  
in this case.  
The evidence of Rick Elderbroom  
[201] Rick Elderbroom is responsible for IT services for the Township and has been for 17 years.  
[202] Mr. Elderbroom was asked about how Vadim showed certain information in certain  
documents. He was not aware of whether there was any significance to the username being  
indicated in upper- or lower-case lettering, or why that might be happening. He theorized it  
might be because a different module was being used for each type of entry. He could not  
explain why receipts showed specific times for each entry, while reversals were consistently  
shown as having been made at midnight. He said: “I assume it is a glitch in the reporting system  
of this particular module that it is not pulling up the time”.  
[203] Mr. Elderbroom was asked if he was aware of the system crashing during the printing of  
tax bills. He confirmed that he was aware of the printer freezing and that employees would  
need to re-print or start over. He said this did not happen often.  
[204] Mr. Elderbroom confirmed it was possible to be logged into both the test and live systems  
of Vadim at the same time. While in the test environment, there was nothing on the screen to  
“scream at you that you are in the test module”. While there was an indication on the screen  
about which system you were in, it was not prominently displayed. He agreed that if one was  
going back and forth, it might be easy to lose track of which system you were in.  
[205] Mr. Elderbroom was aware of issues arising from importing data from MPAC. He assisted  
Ms. Cameron in downloading this information. He agreed that information about who owned  
a particular property could be several months out of date.  
The evidence of Micheline Larocque  
[206] Ms. Larocque worked for the Township for 16 years up until June of 2018. In 2008, she  
became the assistant tax collector.  
[207] Ms. Larocque recalled that Ms. Cameron did talk to her about problems in transitioning  
from the old system to Vadim. Ms. Larocque was aware of problems in transferring  
information over from MPAC.  
[208] Ms. Larocque said she had never done any reversals of more than a few dollars. She only  
made such reversals where a payment was entered the day after it was made and a minimal  
amount was added as a penalty. Any reversals she made were under her name.  
[209] Ms. Larocque was involved in sending out reminders to taxpayers who were in arrears. She  
helped in posting them. She said Ms. Cameron would keep some of those notices because she  
said she had to review them. Ms. Larocque could not say what proportion of the reminders Ms.  
Cameron kept.  
[210] Ms. Larocque was involved in issuing tax certificates. She said that the client inquiry  
document was not what she would see when going into Vadim to prepare a tax certificate.  
Vadim generated the tax certificate. She did not check it for accuracy before sending it to the  
lawyer who requested it. She said that doing a tax certificate was not complicated and was not  
something you should be doing in the test environment. She agreed, however, that Ms.  
Cameron had more complex tasks to complete and that Ms. Cameron had to go into the test  
system to do these things.  
[211] Ms. Larocque agreed with the suggestion that when in “test”, nothing jumps out on the  
screen to tell you that you are in the test system. She agreed you would have to be looking  
carefully. She recalled there were “little icons” – one said test, the other said live.  
[212] Ms. Larocque testified that every year, there were problems because of information  
downloaded from MPAC. Some people got bills for properties they did not own. In other  
instances, bills were sent back because the taxpayer did not live there anymore. She also  
recalled problems with printing bills. The only way they would know if someone had been  
missed in the re-print effort was if someone came in and said their tax bill was missing.  
The evidence of Chloe Crack  
[213] Chloe Crack worked for the Township from 2013 to 2019. For a few years, she was  
employed as the receptionist. She also performed other duties relating to property tax,  
including issuing tax certificates. In 2016, she moved to the recreation department and no  
longer did work relating to taxes.  
[214] Ms. Crack began to notice what she felt were odd transactions. Taxpayers would come in  
and indicate they owed something different than what was indicated in Vadim. She would  
direct those taxpayers to Ms. Cameron. Ms. Cameron would then make adjustments on the  
account.  
[215] As this started to happen more and more, Ms. Crack thought it was odd that so many  
accounts were not up to date when they should have been. Her instinct was that something was  
off, and she started taking screenshots from the accounts to protect herself.  
[216] Ms. Crack began to take screenshots of the account balances in Vadim before she talked to  
Ms. Cameron, and a further screenshot after Ms. Cameron had made the adjustment on the  
account. She felt this was happening far too often and did not understand why. Consequently,  
she brought her concern to the attention of Ms. Levac and provided Ms. Levac with pdfs of the  
screenshots for about 10-12 accounts.  
[217] As far as she knew, Ms. Cameron would have been aware that a concern had been raised  
about these adjustments. The situation did not resolve after that. The transactions “stepped up”.  
There were another 50 or so over a year and a half to two years.  
[218] Ultimately, Ms. Crack brought her pdfs of the screenshots for about 25 accounts to Ms.  
Levac. She kept the others as proof for herself if she ever needed it. She did not keep copies of  
what she provided to Ms. Levac. She shredded the remaining documents when she stopped  
working in the tax department and began a full-time position in another department.  
[219] Ms. Levac did a “post mortem” with her and said only that Ms. Cameron needed to make  
adjustments to the account. Ms. Crack said she was told these were just year end adjustments.  
She agreed that Ms. Levac seemed to verify that these were proper adjustments.  
[220] Ms. Crack agreed that she had no way of knowing what the accurate figure was for the  
balances on the tax accounts, and for all she knew, when Ms. Cameron made the adjustments,  
they could have been “correct adjustments”.  
[221] Ms. Crack also agreed that adjustments were occasionally necessary in circumstances  
where a taxpayer owned more than one property and their tax payments did not get properly  
allocated to each property. When she began working in the department, she did not know to  
inquire about how payments should be distributed when she received payments at the  
reception. On those occasions, Ms. Cameron informed her that the payment had to be reflected  
on each different tax roll account.  
The evidence of Monique St-Denis  
[222] Monique St-Denis continues to be employed by the Township. She is the receptionist. She  
performed duties for the tax department when Ms. Cameron was the tax collector.  
[223] Ms. St-Denis testified that there were occasions when taxpayers disputed information she  
gave them about their tax accounts. On those occasions, she would ask Ms. Cameron to come  
and speak with the taxpayer. She agreed that in the majority of those situations, Ms. Cameron  
would tell the taxpayer that the system was accurate and they owed money. On some occasions,  
Ms. Cameron would accept the taxpayer’s explanation and make adjustments to the account.  
[224] Ms. St-Denis also testified about putting white out on the final tax bills for taxpayers who  
were on pre-authorized payment plans. She said Ms. Cameron asked her to do so. Ms. Cameron  
had directed her to do so because she did not want to upset these taxpayers by having an amount  
showing as owing when their payments were being taken automatically. Ms. Cameron said she  
did not want the residents to call her and to white out the amount owing because Ms. Cameron  
had adjustments to do to their accounts.  
[225] Ms. Cameron was open about the fact that she was asking to have that part of the bill whited  
out. Ms. St-Denis agreed that sometimes residents would come in a foul mood and would  
become outraged if the paperwork said they owed more than they felt they did. Some taxpayers  
came in to ask why there was whiteout on their bill. She would refer them to Ms. Cameron.  
[226] Ms. St-Denis agreed that sometimes payments were credited to the wrong tax roll in  
instances of taxpayers who owned more than one property. That was a type of adjustment that  
had to be done from time to time. She agreed that it was not unusual for there to be a mix up  
in how money got attributed to the properties owned by the taxpayer. People would then come  
in upset about any suggestion that they owed money. These types of problems were also  
common with properties that had severances.  
The evidence of Jennifer Wray  
[227] Jennifer Wray worked for the Township in 2016. While she worked under the supervision  
of Mr. Elderbroom in the IT department, she also assisted with other duties.  
[228] Ms. Wray testified about helping Ms. St-Denis white out the balance due on approximately  
500 tax bills. Ms. St-Denis was the person who asked her to do this and it took them two days  
to complete. The work was performed at the front desk.  
[229] Ms. Wray also assisted with filing for Ms. Cameron. Her recollection was that because of  
health issues, Ms. Cameron was “way behind”. She agreed that Ms. Cameron would just let  
files pile up rather than go and file them.  
The evidence of Sgt. Armit  
[230] Sgt. Armit works with the anti-rackets division in the OPP. He became the lead investigator  
in this case after first being asked to assist in May of 2018.  
[231] Sgt. Armit testified that the material provided by the Township was very difficult to  
comprehend. It was not until they interviewed Linda Lancaster that police felt there was  
evidence of criminality.  
[232] Sgt. Armit confirmed that police never had grounds to seek records from Ms. Cameron’s  
financial institution. A search on FINTRAC, however, indicated that there had not been any  
suspicious transactions reported by her financial institution. Police received no information  
about Ms. Cameron’s lifestyle that suggested that she was living beyond her means.  
[233] Sgt. Armit testified that due to the problems with the Township’s record retention practices,  
the fruits of the investigation did not support charges for theft of funds. He said that the struggle  
they had in the investigation was that they had to rely on documents brought to them by  
taxpayers. Sometimes these documents indicated that the taxpayer had in fact paid their bills  
when the Township was saying they owed money. When the taxpayer had kept records, this  
greatly assisted their investigation. However, not everyone they interviewed was able to  
provide them with documents.  
[234] Sgt. Armit effectively agreed that the lack of records and the passing of time combined  
with technology issues prevented him from drilling down to see if the Township lost money  
“somewhere down the road”.  
[235] While the investigation indicated that some of the reversals on accounts that were of  
concern to investigators started in late 2007, Ms. McLeod was not interviewed. Sgt. Armit was  
not aware if she was still alive.  
The evidence of the accused  
[236] The accused started working for the Township in 1995. Prior to that, she had worked for  
the federal government for ten years. Her recollection was that she assumed the duties of the  
assistant tax collector in 2004. She replaced Jean McLeod as the tax collector in 2008.  
[237] Ms. Cameron said she enjoyed her work. She was always early and would stay late if  
required. She had a good attitude toward her employer. She thought she had a good relationship  
with her supervisor, Ms. Levac.  
[238] Ms. Cameron left her position as the tax collector in December of 2016. When she first  
left, she thought she had a flu and would be back in the office soon. As it turned out, she had  
a blood infection that resulted in damage to her heart and required her to undergo heart surgery.  
She never returned to work. Before this, she had taken a medical leave from work when she  
took a stress leave in 2003.  
[239] Ms. Cameron testified that her health and that of her brother were stressors while she was  
employed with the Township. These were the personal issues that were referred to in her  
performance reviews. She had diabetes, which she described as “way out of hand” in her last  
few years of work. Earlier in her work as the tax collector, her brother, who is deaf, had  
significant health issues and required her assistance in getting health care because of his  
disability.  
[240] Ms. Cameron said she did not like the Vadim system when it was introduced. She found it  
difficult to learn. Compared to the software in use before, there were a lot more steps to certain  
processes. Severances, in particular, were very difficult to deal with in Vadim.  
[241] The accused denied that there was ever a time where she inputted data that she knew was  
not true or accurate. She denied she had ever produced a document she knew did not contain  
accurate information. She denied she had ever done anything in the course of her employment  
intended to benefit herself, her family, or her friends, or that she knew would cause loss to the  
Township. She said she always worked to my bestfor the Township. She said she never did  
anything she knew would cause the Township to lose money or that might cause it to suffer  
some loss.  
[242] Ms. Cameron was asked about the many receipts and reversals that were reviewed in the  
course of the trial and that were made with her username. She said she did not know why those  
would have been done. She said if she could sit at her desk and go back through the  
information, maybe there was a reason. She said she did not just turn around and do it on  
purpose.  
[243] Ms. Cameron described a number of problems she had with doing her work that were the  
result of issues with technology, whether Vadim or otherwise. For instance, sometimes when  
she was printing tax bills, the system would quit in the middle of a print job. Sometimes, she  
might forget to click a box in the program settings and would have to redo the printing. She  
thought that the tax bills found in her desk drawer after her departure involved tax bills printed  
as a result of those types of errors. Because she knew what they were, she did not label them.  
While there was a shredder in the office, she had not shredded those bills.  
[244] Ms. Cameron also testified about errors that she made. For instance, when printing tax bills,  
if she missed clicking a box, the arrears owing would not show. In those instances, she had not  
realized her mistake and did not do it on purpose.  
[245] Ms. Cameron recalled the incident in 2014 when she tendered her resignation. She  
described Ms. Levac pulling her aside and asking her about the account of Ms. Major’s uncle.  
She said “I really messed up”. Her diabetes at the time was “haywire”. She was really really  
upsetbut also had to go see her doctor that day. When she came back from that appointment,  
she tendered her resignation. She spoke with Ms. Levac again, who told her that if it was a  
mistake, they would fix it. She was aware that subsequent investigations were done of her work  
and said that she was asked by Ms. Levac to correct a few mistakes that were found as result.  
Nothing like the mistake made on the account of Ms. Major’s uncle was brought to her  
attention.  
[246] Ms. Cameron said she only ever used three passwords, and that she was aware of the  
passwords used by other employees. However, she was not aware of any other employee ever  
using her password to enter into the Vadim tax module, or logging onto her computer in her  
name. She was not aware of any significance to the username appearing in lower-case or capital  
letters. She did not think she had ever noticed that when she worked for the Township.  
[247] Tax certificates were sometimes issued by others, according to Ms. Cameron. She did not  
necessarily review all of them before they were issued. She trusted that Ms. Larocque and Ms.  
Crack were doing them properly and that the information in the system they were relying on  
to produce them was correct.  
[248] Ms. Cameron testified about “glitches” that occurred working in Vadim. One of these  
involved the disappearance of cash entries, which required staff to re-enter the transaction.  
This issue was addressed with Vadim and occurred around ten or so times.  
[249] In addition to reviewing entries for specific tax rolls with Ms. Cameron, the Crown put to  
Ms. Cameron that the sheer number of reversals in her name suggested they were done  
deliberately. Ms. Cameron replied: “I know there was an awful lot of reversals done but I don’t  
remember these people paying or not paying. I don’t understand why they were done, I would  
have no reason to do them”. She said she would not have deliberately done a reversal “just to  
do a reversal”. She also said, “if I did it, there must have been a reason, but I don’t remember  
… it is going into the sixth year since I’ve looked at a computer screen with these types of  
documents”. Her evidence about the individual tax rolls was similar in its substance. She  
generally testified to the effect that she did not remember or have any explanation for the  
transactions identified on each account, but “there must have been a reason”.  
[250] Ms. Cameron denied that she had deliberately and intentionally worked in the test system  
and manipulated the data in this system to produce false tax certificates knowing that this  
would not show up in an audit report or client inquiry. She said she often worked in the test  
environment, particularly when working on an account with a severance, or in preparing final  
tax bills since these were more complicated. She suggested she might not have realized she  
was working in the test system when some of the documents on an account were produced by  
her.  
[251] Ms. Cameron denied the suggestion made by the Crown that she took some money and  
meant to pay it back and all this snowballed and her manipulations were meant to cover this  
up. She said she never took any money. She also denied the suggestion that she had, over the  
years, made so many errors in her work that she was deliberately manipulating the accounts to  
cover up her own ineptitude. She replied that she was not saying she did not make errors and  
stated that she was not perfect. She denied manipulating the accounts. She said she would not  
do anything on purpose.  
The legal principles  
The fundamental principles of criminal law  
[252] In our law, an accused person is presumed innocent until proven guilty. It is the Crown  
who bears the burden of proving any criminal offence charged beyond a reasonable doubt.  
That burden never shifts. An accused person is not required to prove his or her innocence. Our  
law requires that if a judge has a reasonable doubt about whether the accused committed a  
criminal offence, the accused must be acquitted.  
[253] In a case like this, where the accused has testified and presented evidence, the case of R. v.  
W.(D.), [1991] 1 S.C.R. 742 directs the court in its approach to the evidence. The W.D. test  
applies not just to an accused person’s testimony, but to any defence evidence and any  
potentially exculpatory evidence, whether led by the defence or the Crown: R. v. Smith, 2020  
ONCA 782, 69 C.R. (7th) 126, at para. 12. In short, the test tells me that if I believe the  
accused’s evidence, or it leaves me with a reasonable doubt after I have considered it in the  
context of all the evidence, the accused must be acquitted.  
[254] It is important to note, however, that in deciding a case, a judge is not simply comparing  
each account and deciding which account to believe. Trials are not credibility contests where  
the more credible witness’s account necessarily carries the day. It is also important to note that  
a judge can believe a witness but still be left with a reasonable doubt about what happened  
after considering all of the evidence. As has been noted by our Court of Appeal, “a reasonable  
doubt can survive a finding that [a] complainant is credible”: R. v. T.A., 2020 ONCA 783, at  
para. 29, citing R. v. J.W., 2014 ONCA 322, 316 O.A.C. 395, at para. 26.  
[255] Further, even if a judge disbelieves the evidence given by an accused person, or is not left  
with a reasonable doubt based on the accused’s evidence, this does not mean that the Crown  
has proved its case. A judge must always determine whether the Crown has proved each  
element of every offence charged beyond a reasonable doubt. This will only happen when there  
is evidence that the judge accepts that supports each element the Crown is required to prove.  
[256] As for what is meant by “reasonable doubt”, it is not an imaginary, far-fetched or frivolous  
doubt, and it must not be based upon sympathy or prejudice. It is based on reason and common  
sense. It is logically derived from the evidence or absence of evidence: R. v. Bryce (2001), 140  
O.A.C. 126(C.A.), at paras. 13-20. Probable or likely guilt is not sufficient to meet the standard  
in a criminal trial. But the burden of proof is also not impossibly high. The Crown is not  
required to prove its case to an absolute certainty.  
[257] If, at the end of the case, a judge concludes only that the accused is likely or probably  
guilty, the accused must be acquitted. Before an accused may be found guilty, and face the  
consequences of a conviction, a judge must be sure that the accused committed the offence  
charged (see D. Watt, Watt’s Manual of Criminal Jury Instructions, 2nd Ed., Thomson Reuters  
Canada Ltd., 2015, Final 13, “Reasonable Doubt”, at pp. 261-267; and R. v. Lifchus, [1997] 3  
S.C.R. 320, at paras. 36-40).  
Circumstantial evidence  
[258] Counsel agree that the case for the Crown is based entirely on circumstantial evidence.  
This means that for every offence charged, the Crown must prove beyond a reasonable doubt  
that the accused’s guilt is the only reasonable conclusion that can be drawn from the whole of  
the evidence.  
[259] A trier of fact must guard against the risk of “filling in the blanks” by too quickly  
overlooking reasonable alternative inferences and be vigilant about the path of reasoning  
involved in drawing inferences from circumstantial evidence. An inference of guilt drawn from  
circumstantial evidence must be the only reasonable inference that such evidence permits. The  
inferences that may be drawn from any set of facts must be considered in light of all the  
evidence and the absence of evidence, assessed logically, and in light of human experience and  
common sense: R. v. Villaroman, 2016 SCC 33, [2016] 1 S.C.R. 1000, at para. 30.  
[260] It is important to confirm that in assessing circumstantial evidence, inferences consistent  
with innocence do not have to arise from proven facts. To hold otherwise would reverse the  
burden of proof. As explained in Villaroman, “[t]he issue with respect to circumstantial  
evidence is the range of reasonable inferences that can be drawn from it. If there are reasonable  
inferences other than guilt, the Crown’s evidence does not meet the standard of proof beyond  
a reasonable doubt”: para. 35. Accordingly, an alternative theory to guilt is not “speculative”  
only because it arises from a lack of evidence: Villaroman, at para. 36, R. v. S.B.1., 2018 ONCA  
807, 143 O.R. (3d) 81, at para. 131.  
[261] As further directed in Villaroman at paras. 37-38  
When assessing circumstantial evidence, the trier of fact should consider “other  
plausible theor[ies]” and “other reasonable possibilities” which are inconsistent  
with guilt … I agree with the appellant that the Crown thus may need to negative  
these reasonable possibilities, but certainly does not need to “negative every  
possible conjecture, no matter how irrational or fanciful, which might be consistent  
with the innocence of the accused” … “Other plausible theories” or “other  
reasonable possibilities” must be based on logic and experience applied to the  
evidence or the absence of evidence, not on speculation.  
Of course, the line between a “plausible theory” and “speculation” is not always  
easy to draw. But the basic question is whether the circumstantial evidence, viewed  
logically and in light of human experience, is reasonably capable of supporting an  
inference other than that the accused is guilty. [citations omitted, emphasis in  
original.]  
[262] Ultimately, circumstantial evidence does not have to “totally exclude other conceivable  
inferences”: Villaroman, at para. 42, S.B.1., at para. 153. Further, alternative inferences must  
be reasonable, not just possible: Villaroman, at para. 42.  
Analysis  
Findings of fact  
[263] As I have said, the Crown must prove every element of the offences charged beyond a  
reasonable doubt.  
[264] The scenario presented by the Crown involves, at its core, an allegation that the accused  
manipulated data in the Vadim system and issued documents containing information she knew  
to be false. The Crown accepts that it is unable to show why the accused did this, and that there  
is no evidence the accused in any way benefited from her alleged conduct.  
[265] In considering the evidence as a whole, including the evidence of Ms. Cameron, I am able  
to arrive at the following conclusions beyond a reasonable doubt:  
a. An unusually high number of payments and reversals were made in the Vadim  
system using the accused’s username. There is no compelling evidence that anyone  
other than the accused was the person who made the entries;  
b. A number of payments and reversals coincided with correspondence from a  
taxpayer or their lawyer about the status of the account, and about what taxes  
remained owing. Entries were made by the accused that allowed for the issuance of  
a tax certificate indicating nothing was owing. For instance, in respect of tax roll  
#7, a payment was noted in the system by Ms. Cameron that had the effect of  
reducing the amount payable to zero on the same day she issued the tax certificate  
showing nothing was owing. Just over a week later, a subsequent reversal of that  
payment was made by the accused that had the effect of returning the account to its  
balance prior to the request for a tax certificate (see the summary regarding Tax  
Roll #7 as given in the evidence of Ms. Lancaster);  
c. In 2014, the accused was made aware of a circumstance in which the funds paid by  
the uncle of Sylvie Major had not been properly directed to his account. The  
accused offered to resign as a result. Further investigation was done at that time to  
see if there were any other accounts with similar issues. A few errors were located,  
but no wrongdoing was suggested by anyone at the Township as a result of their  
review of their records at that time;  
d. A number of tax certificates were issued in the test system by Ms. Cameron,  
including a number after the year 2014 (see again Tax Roll #7);  
e. There is no evidence that the accused has benefitted in any way from the conduct  
alleged by the Crown. There is no evidence that suggests she had any change to her  
lifestyle. There are no banking records that show any anomalies that suggest a  
financial benefit to her from anything she did while employed with the Township;  
f. There is no evidence that the accused knew any of the taxpayers involved in the  
unusual transactions and no basis to conclude that she was seeking to benefit or  
target any particular taxpayer. Indeed, the only taxpayer to whom she had a personal  
connection, her nephew Corey Cameron, had a payment made by him misallocated  
by Ms. Cameron, and also received a payment misallocated from another taxpayer;  
g. At the time that many of the originating issues with the taxpayer accounts arose  
(e.g. between 2006 and 2008), employees in the Township were beginning to  
transition from one software program to Vadim. This transition was not an easy one  
by all accounts. It is an easy conclusion that this was a time where errors in Vadim  
would have been more likely than in later years when the Township’s employees  
had more experience with the system. For instance, Ms. Lancaster confirmed that  
the default setting in Vadim was such that when printing tax bills, the bill would  
not show amounts past due. It was necessary to click a box and save it to ensure  
any bill printed also showed amounts past due. There is no way of knowing if this  
was an error that was made at the time of the originating problems or not;  
h. This is because there are no records available to show what information was or was  
not provided to taxpayers from the time of the originating problems. It seems that  
all of the originating problems in the tax accounts highlighted by the Crown were  
because of a missed payment by a taxpayer. However, there are no records available  
to show whether the taxpayer was notified of the taxes owing at the time they were  
first owed. The only records regarding payments made have come from taxpayers  
who have retained their receipts for over a decade;  
i. At the time of the originating problems, Ms. Cameron was the assistant tax  
collector, and the responsibilities of the tax collector were held by Ms. McLeod.  
Ms. McLeod was not interviewed by investigators and has not provided evidence  
in this trial. There is insufficient evidence to conclude that whatever the originating  
problem was for various tax files, Ms. Cameron was the person responsible. There  
is no basis to conclude that she would have been in a position to even identify those  
taxpayer accounts that had been affected by any errors or other irregularities;  
j. It is not clear where and how the Township may have lost money as a result of these  
originating problems given the lack of records from that time period and the  
remaining state of the evidence, which includes evidence that at least some  
taxpayers did in fact pay tax installments and were not credited for doing so in the  
Vadim system. The Crown has not proved any loss in this case beyond a reasonable  
doubt;  
k. While some of the entries made by Ms. Cameron correspond to other events in the  
tax file (such as a request for a tax certificate), not all of them do.  
The analysis on each count charged  
[266] While the indictment includes five different charges, the Crown no longer seeks a  
conviction on count 3 since it does not seem intended to capture circumstances of the kind  
alleged here. The accused will be found not guilty on this count.  
[267] My analysis therefore will focus on whether the Crown has met its onus on the remaining  
four counts.  
Counts 1, 4, and 5  
[268] The issues in counts 1, 4, and 5 all rise and fall on whether the Crown has proved beyond  
a reasonable doubt that the accused engaged in manipulations of the tax data in Vadim for  
reasons other than the performance of her obligations as the tax collector.  
The positions of the parties  
[269] The Crown argues that the sheer number of payments and reversals made in unusual  
circumstances, including dates that were proximate to the issuance of tax certificates or tax  
bills, shows that the accused was engaged in a scheme to manipulate the tax data. While it is  
unable to say why she was doing this (which is an issue it does not have to prove in any case),  
the Crown says that it cannot be a coincidence that on so many occasions, the entries made by  
the accused reduced the amounts payable by taxpayers to zero, or reduced their arrears owing,  
and that these entries were so often very close to the issuance of tax certificates or tax bills.  
[270] The Crown argues that the fact that these entries were made by the accused leads to the  
inescapable inference that she must have had a dishonest or criminal intent when making the  
entries. This is the only reasonable inference that can be drawn on the whole of the evidence.  
[271] The Crown agrees that an inescapable feature of its theory is that the accused must have  
been keeping track of all these accounts and adjusting them on a schedule or prompt of some  
kind. While the Crown acknowledges that there is no other evidence to support the existence  
of such a scheme, it says that the court can infer it from the remaining evidence.  
[272] The defence argues that the accused should be believed when she says she never made an  
entry for a dishonest purpose and would never have done anything to harm the Township. At  
a minimum, her evidence, considered as part of the whole of the evidence, should leave the  
court with a reasonable doubt about whether the Crown has proved any of counts 1, 4 and 5.  
[273] The defence emphasizes certain circumstances and gaps in the evidence. First, there is no  
evidence that provides a coherent motive for the conduct alleged. The transactions start in 2007  
and there are hundreds or thousands after that until 2016. It is inconceivable that the accused,  
who was law abiding and a dedicated civil servant, spent the better part of a decade “ripping  
off the township”.  
[274] A second related point is that there is no proof of any benefit to the accused. There is no  
evidence the accused had anything other than a frugal lifestyle. There is no evidence of  
unexplained deposits in her bank account. There is no evidence anyone ever saw her taking  
money. There is no evidence she materially benefitted from any of these transactions.  
[275] Third, if the accused were carrying out a years-long ongoing fraud affecting hundreds of  
taxpayers and involving hundreds or thousands of transactions, this would require tremendous  
organization to ensure that things balanced, and to keep track of when to reverse something or  
indicate a payment was made. In contrast, the evidence on the trial is to the effect that the  
accused was a disorganized person whose problems with organization skills were routinely  
highlighted in her performance appraisals. The defence says there is no evidence the accused  
was covering up anything just that she was a disorganized person doing her best.  
[276] Finally, the defence emphasizes that throughout the years she was allegedly committing  
these offences, the accused was being supervised. Initially she was supervised by Ms. McLeod  
when she was the tax collector. At all times, she was supervised by Ms. Levac, the treasurer.  
In addition to this, an accounting firm conducted audits twice yearly, and would randomly  
select certain files to examine as part of its work. At no time were any issues with the accused’s  
performance brought to her attention, save for the incident in 2014 that prompted further  
examination of her work with no resulting concerns being expressed. In all the circumstances,  
including the accused’s evidence denying any wrongdoing, the defence submits that the Crown  
cannot prove its case beyond a reasonable doubt.  
Analysis  
Count 1  
[277] I begin by considering the issues as they relate to count 1, which alleges a breach of trust  
in connection with the accused’s duties of her office as an official tax collector. She is alleged  
to have committed this offence by manipulating data, issuing false tax bills and tax  
certificates.  
[278] The elements that must be proved in proving the offence of breach of trust were considered  
by the Supreme Court in R. v. Boulanger, 2006 SCC 32, [2006] 2 S.C.R. 49. Only one of the  
issues in the five-part test is raised here that is whether or not the Crown has proved beyond  
a reasonable doubt that the accused acted with the intention to use his or her public office for  
a purpose other than the public good, for example, for a dishonest partial, corrupt, or oppressive  
purpose”: Boulanger, at para. 58.  
[279] The defence concedes that if I am satisfied beyond a reasonable doubt that the accused  
manipulated data for some purpose other than to correct mistakes and that she did so to cover  
something up or help herself in some way, this would satisfy the elements of this offence.  
However, the defence says that in this instance, at best, there is speculation as to what the “non-  
public good purpose” might be.  
[280] The Crown says that if the accused is found to have falsified tax certificates and tax bills  
and manipulated data, given the implications for the tax system, this can only be characterized  
as a non-public good purpose. It also says that if the accused was making these entries to  
address other problems that she was aware occurred with Vadim’s accounting, then she had an  
obligation to bring this issue to the attention of her supervisors and her ongoing manipulations  
were a non-public good purpose. The Crown argues that the weight of the evidence contradicts  
the accused’s evidence and it should be rejected, or not give rise to a reasonable doubt.  
[281] As I have already outlined, this is a circumstantial case. To be sure, circumstantial evidence  
is not a lesser form of evidence, and cases based on circumstantial evidence run the gamut as  
to their strength.  
[282] In this instance, the case is far from coherent. When I consider the whole of the evidence,  
it is clear that there were a number of irregularities in how the tax department functioned during  
the years that were the focus of the evidence. It is clear, for instance, that some taxpayers made  
payments that were not reflected in the Township’s records. It is clear that employees made  
mistakes from time to time that needed to be corrected. It is clear that a practice developed  
where certain employees used the cash box for personal purposes. It is clear that the record  
keeping by the Township had significant gaps that make reconstructing many events difficult.  
None of this is the result of anything done by Ms. Cameron.  
[283] It is also clear that Ms. Cameron was the subject of supervision, and her work would have  
been reviewed in various audits. Engaging in the scheme alleged in these circumstances would  
certainly have been risky. Nothing in the audit process raised any red flags over the years, and  
Ms. Cameron routinely received positive performance appraisals, including assessments of her  
respect for public resources.  
[284] Further, it is clear that Ms. Cameron had significant problems with her organizational skills  
and that, as the defence suggested, this was a recurring theme in her performance appraisals.  
Other evidence called in the trial also highlighted her disorganization. In particular, the  
evidence about the stacks of documents found in her desk after she departed, which were  
documents that were never related to any of the tax files examined in this trial, tends to show  
that the accused was not a model of organization.  
[285] The evidence about engaging other staff to white out amounts due on tax bills for people  
on pre-authorized payment plans also shows that the accused had an approach to her job that  
was not as careful as many would hope given her responsibility for taxpayer funds. All the  
same, this conduct occurred with the participation of other township employees. Ms. Cameron  
clearly saw no problem with it and was not trying to hide it she enlisted another employee to  
assist her with it. This appears not to have been raised as an issue by the other employees, or  
Ms. Cameron’s supervisor, even though it appears this process took two days and was  
conducted in a visible location within the Township’s office.  
[286] Along with this evidence, I consider Ms. Cameron’s denials. Ms. Cameron presented in a  
credible way when she testified. I agree with counsel’s characterization of her as having  
answered questions spontaneously, directly, and completely. She was not evasive or  
argumentative. To the extent that she had no memory of much of what she was asked about, in  
the circumstances, this is understandable. A lot of time has passed since these events occurred  
and the types of transactions she was asked about could not be expected to stand out in a  
person’s memory so long after the events.  
[287] I also consider the evidence of Ms. Crack about bringing her concerns about a number of  
adjustments on accounts to the attention of Ms. Levac shortly after they occurred. It appears  
nothing came of that concern. While the evidence about what Ms. Levac told Ms. Crack is  
hearsay, there was nothing in the evidence of Ms. Levac that suggested that she had cause for  
concern because of anything other than what was reported to her by Ms. Major about her  
uncle’s account.  
[288] There is no doubt that in addition to the number of entries made by Ms. Cameron, the most  
compelling aspect of the Crown’s case is the timing and circumstances in which some of the  
entries are made. An inference that the accused must have made these entries with a dishonest,  
deceitful or criminal intent is certainly available based on that evidence. However, I have a  
reasonable doubt that this is the only reasonable inference that arises on the whole of the  
evidence.  
[289] When I consider all the evidence, I find it difficult to believe that the accused would have  
been able to keep a complex scheme of payments and reversals afloat. I find it easy to believe  
that she made many mistakes and was disorganized, and that her approach to her duties left  
genuine questions about how well suited she was to have this important position.  
[290] My confidence that Ms. Cameron was running an elaborate scheme to make false entries  
for some non-public good purpose is further eroded because, on the evidence presented during  
the trial, there is no reason for her to have been doing so. I want to be clear that I am aware  
that the Crown need not prove the accused’s motive, or that she benefited in any way from her  
conduct in proving any of the offences charged. In the circumstances of this case, however, the  
absence of evidence of motive contributes to my lack of certainty about what the accused’s  
state of mind was when she made the various entries.  
[291] Despite the compelling features of the Crown’s case, I find myself with a reasonable doubt  
that when the accused made the entries in Vadim that are said to constitute data manipulation,  
or when she issued tax certificates and tax bills, that she was doing so with a non-public good  
purpose.  
[292] Inherent in this conclusion is a finding that that the Crown has not met its burden on counts  
3 and 4. To be clear, I am not satisfied beyond a reasonable doubt that the accused committed  
mischief in relation to data (count 4), or that she knowingly caused forged documents to be  
issued (count 5). This is because the evidence does not permit me to conclude beyond a  
reasonable doubt that the accused had the necessary criminal state of mind for each of these  
offences when she made the entries or documents at issue.  
Count 2 - Fraud  
[293] With respect to count 2, there are additional problems of proof that lead me to a finding of  
not guilty on this count.  
[294] Count 2 alleges that Ms. Cameron defrauded the Township of North Glengarry and its  
taxpayers “of monies”.  
The positions of the parties  
[295] The defence says this charge fails because there is no evidence of loss or risk of loss. The  
defence says that the Crown’s position is essentially that “we can’t prove it, but we’re guessing  
there must have been a loss and this is why reversals are being done and false tax bills are  
being created”. This does not amount to proof beyond a reasonable doubt, particularly where  
the evidence showed over and over that taxpayers had proof of payment for taxes that the  
Township said had been unpaid, and for which it had charged penalties and interest. The  
defence says that even setting aside the accused’s evidence that she did not do anything  
dishonest, the court should have a reasonable doubt based on the evidence led by the Crown.  
[296] In response, the Crown’s theory of the accused’s liability on this count appears to have  
shifted. It does not advance the position that the loss or risk of loss arises from the Township  
writing off certain sums it says it was owed but did not collect because of Ms. Cameron’s  
actions. The Crown now takes the position that after the accused became the tax collector in  
2008, a series of manipulations to tax accounts continued or began. As the tax collector, the  
accused had an obligation to determine why these reversals were all necessary and to get to the  
heart of the problem at an early stage so that the Township was not put to the expense of hiring  
forensic accountants to try to make some sense of all of these tax files. This, the Crown says,  
is the deprivation that the Crown has proved beyond a reasonable doubt.  
[297] In reply, the defence argues that the Crown’s view of “deprivation” is far too broad.  
Deprivation must be a direct consequence of the accused’s conduct, not the collateral  
consequence. Otherwise, any time a criminal defendant causes an investigation to be  
undertaken (which would cause the expenditure of public funds), they would be guilty of fraud.  
The defence also emphasizes the absence of any evidence about any cost associated with the  
work done by the forensic accountants.  
The law  
[298] To prove the offence of fraud, the Crown must prove the following essential elements  
beyond a reasonable doubt (see Watt’s Manual of Criminal Jury Instructions, Final 380,  
Fraud, at pp. 1000-1003):  
i. That the accused deprived each named complainant of something of value;  
ii. That the accused’s deceit, falsehood or other fraudulent means caused the  
deprivation;  
iii. That the accused intended to defraud the named complainant; and  
iv. That the value of the property exceeded $5,000.  
[299] R. v. Zlatic, [1993] 2. S.C.R. 29 and its companion case R. v. Théroux, [1993] 2. S.C.R. 5  
confirm that the actus reus of fraud will be established by proof of:  
1. the prohibited act, be it an act of deceit, a falsehood or some other  
fraudulent means; and  
2. deprivation caused by the prohibited act, which may consist in  
actual loss or the placing of the victim’s pecuniary interests at risk  
(see Zlatic, at p. 43, Théroux, at para. 20).  
[300] “Deprivation” does not require evidence that the complainant suffered an actual economic  
loss. The complainant’s economic or financial interests must be proved to have been at risk,  
however: Zlatic, at p. 48, Théroux, at p. 16.  
Analysis  
[301] In my view, the issue in this case is whether or not the Crown has proved the actus reus of  
the offence.  
[302] I have already indicated, in effect, that I have a reasonable doubt that the Crown has proved  
the “prohibited act”. I also have a reasonable doubt is has proved “deprivation”.  
[303] The evidentiary record for this case is such that it is impossible to conclude what money  
was and was not owed to the Township in the tax files examined in this case over the years at  
issue, and what, if any, penalties and interest were properly applied given the clear  
irregularities that occurred in the period between 2006-2008. There is insufficient evidence to  
conclude what, if any, responsibility Ms. Cameron would have had for those irregularities.  
[304] The Crown appears to have accepted this state of affairs and now argues that the  
deprivation in this case was causing the Township to have to expend funds for forensic  
accounting. I agree with the position of Mr. Hale on this issue. There is no evidence whatsoever  
that allows me to know what the costs of accounting services were. More critically, I also agree  
that the new Crown theory of deprivation is too remote I do not believe this type of collateral  
consequence fits within the meaning of “deprivation”.  
[305] Since the Crown cannot prove either the “prohibited act” or “deprivation” beyond a  
reasonable doubt, this count fails, and the accused will be found not guilty.  
Conclusion  
[306] At bottom, I have a reasonable doubt that the accused had the required criminal state of  
mind when she made these entries and issued these documents. As was acknowledged by  
counsel for the defence, there are certainly reasons here to be suspicious about what was going  
on. It may be that a civil court would conclude that Ms. Cameron probably engaged in data  
manipulation and deliberately issued inaccurate tax certificates and tax bills. But my task here  
is to consider whether the evidence presented meets the very high threshold of proof beyond a  
reasonable doubt on every element of every offence charged.  
[307] There are simply too many problems with this case for me to be so satisfied. As I have said,  
our law ensures that a person is not made to face the consequences of a criminal conviction,  
including being labeled a criminal, unless the trier of fact is sure they have committed the  
offence charged. I cannot reach that level of certainty here, where there are so many gaps in  
the documentary evidence, where there are so many problems with the reliability of the  
information about various taxpayer accounts (apart from anything Ms. Cameron was alleged  
to have caused), where there is no motive or benefit to the accused that has been proven, and  
where the accused has testified credibly denying the allegations. I am not sure enough of what  
happened here to find the accused committed any criminal offence.  
[308] Accordingly, I find the accused not guilty on all counts.  
The Honourable Justice Laurie Lacelle  
Released: July 15, 2022  
CITATION: R. v. Cameron, 2022 ONSC 4138  
COURT FILE NO.: 20-47  
DATE: 2022/07/15  
ONTARIO  
SUPERIOR COURT OF JUSTICE  
HER MAJESTY THE QUEEN  
and –  
Sandra Cameron  
REASONS FOR JUDGMENT  
The Honourable Justice Laurie Lacelle  
Released: July 15, 2022  
1

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Wong v. Pretium Resources Inc. | Jul 22, 2022
Labourers' International Union of North America, Local 183, Union v Mulmer Services Ltd. | Aug 5, 2022
City of Mississauga v. Hung | Sep 22, 2022
Secretary of the Ministry of Health v The New South Wales Nurses and Midwives' Association (28 September 2022)
Orewa Community Church v Minister for Covid-19 Response (16 August 2022)
Yeshiva College Bondi Limited v NSW Education Standards Authority (15 August 2022)
Moreland Planning Scheme Amendment C208more | Heritage Nominations Study | Panel Report | 15 July 2022
New Zealand Tegel Growers Association Incorporated | 2 August 2022
Farrow-Smith and Comcare (Compensation) | 26 September 2022
Evolution Fleet Services Pty Ltd v Allroads Plant Pty Ltd | 14 September 2022
656621 B.C. Ltd. v David Moerman Painting Ltd. | Sep 27, 2022
Fraser Valley Packers Inc. v Raiwal Holdings Ltd | Sep 26, 2022
Parmar v Tribe Management Inc. | Sep 26, 2022
DES Studio inc. c. Shuchat | Sep 26, 2022
Van-Kam Freightways Ltd. v Teamsters Local Union No. 31 | Sep 28, 2022
Rogers Communication Inc. v British Columbia | Sep 28, 2022
Alderbridge Way GP Ltd. | Sep 28, 2022

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