MOHAWK+GRAND RIVER

Gazette No. 63 — Application for Writ of Mandamus — Affidavit of Benjamin Doolittle UE

Be it known and placed on record: That the affidavit of Benjamin Doolittle UE, Secretary-General, in support of the Application for Writ of Mandamus targeting Director Dan Petoran, Land Registry Services Branch, ServiceOntario, is hereby registered in the Gazette as Gazette No. 63.

I. The Deponent and His Standing

The deponent is Benjamin Doolittle UE, Secretary-General of the Mohawk Nation of Grand River Secretariat. He is Lower Mohawk of Grand River, Turtle Clan. He is a sixth great-grandson of Colonel Joseph Brant (Thayendanegea) UEL, Canajoharie Mohawk, as certified by the United Empire Loyalists’ Association of Canada. His matrilineal Mohawk descent runs through ten documented generations from Colonel Brant’s sister through the Turtle Clan line to the deponent’s grandmother, Jessie May Hill née Doolittle.

II. The Scope of the Affidavit

177 sworn paragraphs. 130 exhibits (A1–A20, B1–B9, C1–C70).

The affidavit establishes: (1) the deponent’s standing and lineage; (2) the Haldimand constitutional chain from the 1779 Pledge through the 1850 Proclamation (Exhibit A5-A, certified 13 March 1964); (3) the Crown knowledge chain from 1821 to 2026, comprising 14 documented instances of Crown acknowledgment without resolution in the 230-year avoidance pattern; (4) the administrative gap confirmed by Director Petoran on 1 April 2026 (Exhibit B2); (5) the BR26001881 constitutional record including the Rules of Engagement (G69), the Protocol Deficiency Notice (G70), the Crown’s Application for Summary Dismissal (Exhibit C68), the Respondent’s Written Submissions (Exhibit C69), and the Crown Prosecutor’s conflict of interest; (6) the Burgos conflation (Exhibit C70); (7) the international instruments character (Holmes and Associates, AANC-INAC, Exhibit A20).

III. The Fourteen Instances

The Crown knowledge chain documents 14 instances of Crown acknowledgment without resolution: (1) 1821 Darling Report; (2) 1827 Report; (3) 1841 Bagot Commission; (4) 1856 Pennefather Commission; (5) 1871 negotiations; (6) 1880 Spence Commission; (7) 1895 Brantford case; (8) 1897 Settled Accounts Arbitration; (9) 1909 Frank Oliver (House of Commons); (10) 1914 Frank Oliver (House of Commons); (11) 1922 Churchill (House of Commons UK); (12) 1995 MOA / Band Council Resolution No. 17; (13) 2021 Jeffrey Lem concurrent registry acknowledgment (Exhibit B1); (14) 2026 Burgos letter (Exhibit C70).

IV. The Administrative Gap

Director Dan Petoran’s letter of 1 April 2026 confirmed: no mechanism exists in Ontario’s land titles registry to record or give effect to the Haldimand Crown covenant interest. This is the unconstitutional administrative gap at the centre of the Application. The Director has the authority and the obligation to create such a mechanism. The Application seeks a court order compelling him to do so.

V. The Critical Deadline

The Application for Writ of Mandamus must be filed and heard before October 5, 2026 — the date the Six Nations v. Canada Phase 1 trial commences. The Crown is attempting to conflate this Application with that proceeding. The conflation must be defeated before October 5, 2026.