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1 . 1 0!":,., ~.':, f- JUDICIAL DISTRICT OF EDMONTON ~ rr.=~ ",{~. '-eetween: US,~~'~~.~,R\E!L FAUl I t C,:';r" ::~\ss\ono::r10f Oaths.:.";.f 0.. '" _.i:;<,..-.\,: cs ~,:~ _ \11 ano ior lr,>;:.;../ "n 0 3 ~ : ;:.: ~~! \ Ia:: of A lhl-..ria edres June 15, 201 l:..!. (5)'11 Iw I"'\UJO~. 'Y' c' c: ~ l~ EARL BRODER, GEORGE BRODER, RlCHARD BRODER, MARGARET ~ r r, r v. MACPHEE, DORlS BIBAUD, LUELLA ADAM AND DORlS BIBAUD AND GEORGE c\. ~ t' BRODER, PERSONAL REPRESENT ATIVES OF THE ESTATE OF EDMUND '1 ~. RODER ALSO KNOWN AS ED BRODER DECEASED :..: This is Exhibit ~.r referred to In the 2 ;:: 6._...Clr~L:~~~.I.d~~~~..n._~ c ~: t/ If:::j f; (--~ Swom.-R7{0re me this ~.~ _ day - and - C. _ '"'; at I.!..lQ2.:C.CL A.D., r. (.)~:r ~ ~.5" ~ < 1..i... "; ~~TiNA<'t. NG CURRJE CU'\.~i,/~;~:SiO!,Jr::p. FOP O~TS"'" IN THE COURT OF QUEEN'S BENCH OF ALBERTA....~~ i~;;;;:. iot6~ i;;~oo ;~H~QrUER AND CRAIG BRODER PLAINTIFFS CbNUd In ~:'1l-<i:;r ;,,0 p,"":',-c d _~'.' ::> DEFENDANTS u:. C~ ;r.,::>:;;'" i.:;('~ ~.~.::;;;;~;/~E;.i~G!.L_ BadE?(!'" ;,-,::" :21.,ucp~.. ~,,. AMENDED AMENDED STATEMENT OF CLAIM 1. The Plaintiffs, Dons Bibaud and George Broder were appointed Personal Representatives of the Estate of Edmund Broder, also known as Ed Broder, Deceased pursy~.!:1t.t9_ an Order of this Honourable Court granted on May 24 th, 200 I and bring this action on behalf of the Deceased's Estate and for the benefit of the beneficiaries of the Deceased's Estate being the Deceased's children, Earl Broder, George Broder, Richard Broder, Margaret MacPhee, Dons Bib::lUd, Luella Adarn, deceased and the Defendant. Don Broder. The Plaintiffs and the Defendants are all resident in the Province of Alberta. 2. The Plaintiffs Earl Sroder. George Broder, Richard Broder, Margaret MacPhee, Doris n

2 J, 2 Bibaud and Luella Adam, Deceased and the Defendant Don Broder are all siblings while the Defendant Craig Broder is the son of the Defendant Don Broder. 3. The Plaintiffs, Earl Broder, George Broder, Richard Brader, Margaret MacPhee, Doris Bibaud and Luella Adam, deceased and the Defendant Don Broder's father, Edmund Brod(ff q,lso known as Ed BIoder, died intestate in Among the assets of the Edmund Broder Estate js a world record mule deer head trophy (hereinafter the "Trophy"). 4. Ed Erader died leaving no surviving spouse. pursuant to the provisions of the Intestate Succession Act, R.S.A Chapter 1-9, as amended, the said Estate shall be d;c;tribl!-,~i per stripes among the issue. namely equally between the Plaintiffs, Earl Broder, GeOfQe Brade",Richard Srader, Margaret. MacPhee, Doris Bibaud, Estate of Luella Adam, deceased and the pefendant Don Broder. 5. From the time afed Brader's death until some time in 1973 the saiq Trophy remained in the custody and safekeeping of the Plaintiff, fuchard Broder. In 1973 the Defendant Don Broder assumed custody of the Trophy and has for many years been in possession as custodian, with the knowledge and consent of the Plaintiffs, of their father's "Trophy". The Plai ntiffs say that the Defendant Don Broder's custody of the Trophy was for benefit of and on behalf of all siblings. 6. In or about the month of February 1997 the Defendant Don Broder with the assistance of the Defendant Craig Broder, and without the knowledge of the Plaintiffs exercised dominion over

3 3 the Trophy asserting the Defendant Craig Broder and/or the Defendant Don Broder were the sole owners thereof by displaying the Trophy in a trade show and receiving media coverage as owners, and against the rights and interests of the Plaintiffs. L On or about March 6, 1997 the Plaintiffs Earl Broder, George Broder, Richard Broder, Margaret MacPhee, Doris Bibaud and Luella Adarn made demand upon the Defendant Craig Broder for the return of the Trophy and have made continued demand for the return of the Trophy from the Defendants, but the Defendants have refused to return the Trophy. The Plaintiffs claim that the Defendants have received monies for the display of the Trophy in or about February 1997 and on prior occasions, particulars of which are unknown to the Plaintiffs but within the knowledge of the Defendants. The Defendants have refused to account to the Plaintiffs for any monies received. The Plaintiffs propose the trial of this action be held at the Law Courts Building, in the City of Edmonton. in the Province of Alberta. WHEREFORE THE PLAINTIFFS CLAIM: (a) Replevin of the Trophy; (b) A declaration that the Trophy is jointly owned by the Plaintiffs and the Defendant Don Broder or altematively by the Estate of Edmund Broder, also known as Eq Broder, Deceased; (c) An accounting from the Defendants for all monies had or received and derived from their use or possession of the trophy;

4 (d) An interim Injunction restraining the Defendants from displaying the Trophy or "otherwise dealing with the Trophy (including selling/leasing, reproducing by cast or otherwise) without the Plaintiffs' written consent; (e) An Interim Order for Replevin returning the Trophy to the Plaintiffs or to a storage facility; (f) Damages as this Court deems meet; (g) Such specials as shall be proven at the trial of this action; (h) Prejudgment Interest onany monies had and received and due to the Plaintiffs and on any other damages; (i) Costs on a solicitor and their own client basis; DATED at the City of Edmonton, in the Province of Alberta, tills 8th day of July, AD. 1997, and FILED and DELIVERED by MESSRS. WEIR BOWEN, Barristers and Solicitors Canada Trust Tower, Edmonton, Alberta, T5J OHS, Solicitors for the Plaintiff herein whose address for service is in care of the said Solicitors and Amended on the 1t h day 0 f March, 2001 and Amended Amended on the 21Sf day of September, ISSUED out of the office of the Clerk of the Court of Queen's Bench of Alberta, Judicial District of Edmonton, in the City of Edmonton, in the Province of Alberta, this 8th day of July, A.D

5 ,~ \ TO THE DEFENDANTS: You have been sued. You are the Defendant. You have only 15 days to file and serve a Statement of Defence or Demand of Notice. You or your lawyer must file your Statement of Defence or Demand of Notice in the office of the clerk of the Court of Queen's Bench in Edmonton, Alberta. You or your lawyer must also leave a copy of your Statement of Defence or Demand of Notice at the address for service for the Plaintiff named in this Statement of Claim. Warning: If you do not do both things within 15 days, you may automatically lose the law suit. The Plaintiff may get a Court Judgment against you if you do not file, or do not give a copy to the Plaintiff, or do either thing late. DON BRODER SCR~ fj A ~x.. 'Y"t. c..o.~<.2,. NO J 2949 DATED: day of,a.d.200j IN THE COURT OF QUEEN'S BENCH. OF ALBERTA JUDICIAL orstrlct OF EDMONTON ======= BETWEEN EARL BRODER, GEORGE BRODER, RICHARD BRODER, MARGARET MACPHEE, DORIS BrBAUD, LUELLA ADAM AND DOmS BIBAUP AND GEORGE BRODER, PERSONAL REPRESENTATIVES OF THE ESTATE OF EDMUND BRODER ALSO.' WN AS ED BRODER, DECEASED and CRAIG DRODER PLAINTIFFS DEFENDANTS ==/====-=--=============== AMENDED STATEMENT OF CLAIM ======~============================== THIS A ENDED AMENDED STATEMENT OF CLAIM i~issued by: I, Weir Bowen Barristers & Solicitors 1600 Canada Trust Tower Avenue Edmonton, Alberta ISJ OH8 ELIZABETI1 M. MacfNNlS..Phone: Solicitors for the Plaintiffs who reside at Edmonton J Alberta, Calgary, Alberta and Rimbev, Alberta respectively And whose address for service is in care of the said Solicitors. And is addressed to the Defendants whose residence so far as is known to the Plaintiffs is Sundry, Alberta and St. Albert, Alberta respectively file: 7839 EMM

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