MOTION FOR A STAY

RELIEF SOUGHT

— with your refinements

//// “Until this Court determines whether s. 53 is constitutional, the Supreme Court should not be issuing advisory opinions, and the federal government should not be invoking that process — especially in matters affecting Quebec and Alberta.” ////

An order staying the legal force, effect, use, and reliance upon any advisory opinions issued under section 53 of the Supreme Court Act, including but not limited to the opinion in Reference re Secession of Quebec, [1998] 2 S.C.R. 217, pending the final determination of this Application for Judicial Review.

An order staying the legal force, effect, use, and reliance upon, by or on behalf of the Respondent or any federal authority, of any advisory opinion issued under section 53 of the Supreme Court Act, as a basis for:

(a) encouraging, authorizing, legitimizing, or facilitating any referendum, process, negotiation, legislative initiative, or other measure relating to the independence, secession, or constitutional rupture of any province or territory of Canada; or

(b) encouraging, authorizing, legitimizing, or facilitating the substitution of, or negotiation for, any form of government for Canada other than that established by the British North America Act, 1867 (U.K.), 30 & 31 Vict., c. 3.

An order staying any federal recognition, endorsement, support, or reliance upon any provincial or territorial advisory opinion, reference, or proceeding that purports to authorize, justify, or legitimize measures of the kind described in paragraph 2(a) and (b), pending the final determination of this Application.

Such further and other relief as this Honourable Court may deem just.

Costs of this motion, if applicable, or in the alternative, no order as to costs.