IN THE SUPREME COURT OF THE NORTHWEST TERRITORIES BETW EEN: William Leonard George Turner Applicant -andCommissioner of the

Northwest Territories Respondent

ORIGINATING NOTICE
Pursuant to subrules 22(f) and 23(1)

TAKE NOTICE that an application will be made by the Applicant for: 1. An order declaring the Affirmative Action Policy and Directive of no force or effect pursuant to subsection 52(1) of the Constitution Act, 1982. 2. An order declaring subsection 67(2) of the Human Rights Act of no force or effect pursuant to subsection 52(1) of the Constitution Act, 1982. 3. An order of costs and disbursements, regardless of the result of this application.

AND TAKE NOTICE THAT this application is made on the following grounds: 1. This Honourable Court is the only forum in which the constitutional validity the GNWT Affirmative Action Policy and Directive (the AA Policy) can be determined. 2. The Applicant has a direct, special interest in the determination of the constitutionality of the AA Policy. The Applicant is a southern Aboriginal who regularly applies on GNWT jobs. 3. Since the AA Policy affords preference to all NWT long-time residents, regardless of race or disadvantage, the AA policy infringes the rights and freedoms guaranteed by subsection 6(2)(b) of the Canadian Charter of Rights and Freedoms (the Charter). 4. Since the rate of employment for the Northwest Territories is higher than the rate of employment for Canada, the Respondent cannot invoke subsection 6(4) of the Charter.

5. Subsection 67(2) of the HRA serves to exclude those who are adversely affected by the AA policy from HRA protection and serves no ameliorative purpose. 6. Subsection 67(2) of the HRA infringes subsection 6(2)(b) in the same manner as the AA Policy infringes subsection 6(2)(b). Additionally subsection 67(2) has no ameliorative purpose whatsoever. 7. Such further and other grounds as advanced by the Applicant and accepted by this Honourable Court Costs 8. Costs should be awarded to the Applicant since the constitutional validity of the AA Policy is a matter of vital public importance, the grounds of this application have significant merit and the Applicant is excluded from making use of the free HRA adjudication process. AND FURTHER TAKE NOTICE that this application will at 4903 49th Street, Yellowknife, Northwest Territories, on the 8th day of July, 2011 at 10:00AM or soon after that time.

AND FURTHER TAKE NOTICE that in support of the application will be read the affidavit of William Turner, copies of which are served with this Originating Notice. DATED at Yellowknife, Northwest Territories, on May 23rd, 2011 and taken.

_______________________ William Turner

ISSUED out of the office of the Clerk of the Supreme Court of the Northwest Territories, at Yellowknife, Northwest Territories, on May 23, 2011.

_______________________ Clerk of the Supreme Court

TO: The Honourable George L. Tuccaro Commissioner of the Northwest Territories P.O. Box 1320 Yellowknife, NT X1A 2L9 803 Northwest Tower Tel: (867) 873-7400 Toll Free: 1-888-270-3318 Fax: (867) 873-0223 E-Mail: commissioner@gov.nt.ca Government of the Northwest Territories Legal Division 4903 - 49th St. Box 550 Yellowknife, NT X1A 2N4 (867) 920-8760 / 873-7602 or toll free: 1-866-822-5864 Fax: 867-873-0291 Justice Canada 5919 52nd Street 2nd Floor, Nova Plaza X1A 2P5

IN THE SUPREME COURT OF THE NORTHWEST TERRITORIES BETWEEN: WILLIAM LEONARD GEORGE TURNER -andCOMMISSIONER OF THE NORTHWEST TERRITORIES

ORIGINATING NOTICE

William L. Turner 5450 52nd Street Yellowknife, NT X1A 3K1 Tel: (867) 445-1116 Email: williamturner83@hotmail.com

NOTICE TO THE RESPONDENTS: You are hereby notified that the Applicant may enter judgement in accordance with this Notice, or such judgement as the Applicant may be entitled to in accordance with the practice of the Supreme Court of the Northwest Territories, without any further notice to you unless you or your agent or solicitor appear at the place and on the date and time specified.