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COURT FILE NUMBER
Q.B.G. NO. 644 OF 2009
COURT OF QUEEN'S BENCH FOR SASKATCHEWAN
JUDICIAL CENTRE
REGINA
REPRESENTATIVE
PLAINTIFF
KATHLEEN THORPE
DEFENDANT
HONDA CANADA INC.
AFFIDAVIT
AFFIDA VII OF CHRISTOPHER PERREIRA
I, CHRISTOPHER PERREIRA, of the City of Toronto, in the Province of
Ontario, MAKE OATH AND SAY THAT:
1.
I am the Supervisor of Customer Relations Marketing at Honda Canada Inc.
("Honda Canada"). I have held this position throughout the period relevant to this affidavit.
2.
As Supervisor of Customer Relations Marketing, I, along with Alvin Cheung
(Engineering Analyst, Campaign Safety & Collision, of the Engineering Development
department) was responsible for distribution of the Notices described in the Settlement
Agreement.
..,
.).
As the first step in distributing the Notices, I assembled a list ofthe names and
postal addresses of all present and former owners and lessees of settlement class vehicles.
This list was assembled using the same methodology that Honda Canada uses to deliver
notices of safety recalls to consumers, as described in the Affidavit of Kenneth Dick sworn
May 22, 2014 which was filed in support of the application for preliminary approval of the
settlement.
4.
In the result, Honda Canada generated a mailing list using multiple inputs: (i)
its database of Vehicle Identification Numbers ("VINs") sold; (ii) a database of its
customers; (iii) dealer data on customers whose vehicles they service; and (iv) further
-2enhancements effected by an outside service provider, Retention Marketing Systems Inc.
("Retention
Marketing")
using publicly available records
and proprietary address
enhancement software (the "Mailing Database").
5.
I believe that the Mailing Database contains a comprehensive list of all names
associated with each settlement class vehicle VIN and the best reasonably available address
information for all names in that database.
6.
The names and corresponding addresses associated with all settlement class
vehicle VINs from the Mailing Database was delivered to Retention Marketing.
7.
I am advised by Alvin Cheung and John Bishop at Retention Marketing and
verily believe, that 187,636 envelopes containing the Notice and Claim form described in the
Settlement Agreement (the "Notice Materials") and addressed to all known settlement class
members from the Mailing Database were provided to Canada Post for mailing between July
7, 2014 and July 30, 2014.
8.
As evidenced by the three invoices attached as Exhibit "A", the 187,636
envelopes were delivered to Canada Post for delivery by Canada Post to the addresses
indicated.
9.
As of September 17, 2014, 15,537 ofthese envelopes were returned to Honda
Canada as undeliverable.
10.
Although not required under the Settlement Agreement, Honda Canada had
the Notice Materials translated into the French language. Copies of the Notice Materials in
French were delivered to addresses of settlement class members located in the province of
Quebec or if a customer has expressed that their preferred language of communication is
French.
-3-
11.
I make this affidavit to at1est to Honda Canada's compliance with its obligations
under the Settlement Agreement, and in support of an application for final approval of the
·settlement.
SWORN BEFORE ME at the City
of Markham, in the Province of
Ontario, this I() day of
October, 2014.
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CHRISTOPHER PERREIRA
~~A=~~0~~~.
7h7,_*~n:~L-IC_i_n_an_d_fu_r_t~-----~
Province of Ontario.
1
1
My Commission expires:.---t/'--f-f/7..:.74-~----
0r Being a Solicitor
CONTACT INFORMATION AND ADDRESS FOR SERVICE
KANUKA THURINGER LLP
Barristers and Solicitors
1400- 2500 Victoria Avenue
Regina, Saskatchewan
S4P 3X2
Address for Service: Same as above
Telephone: (306) 525-7200
Fax:. (306) 359-0590
Lawyer in Charge of File:
James S. Ehmann, Q.C./Keith D. Kilback
29513·0002/kl
DM II 10039 v3
[Retention]
MARKETING
Honda Canada Inc.
180 Honda Boulevard
Markham, Ontario
L6C OH9
Attention:
Mr. Alvin Cheung
DATE: Tuly 81h, 2014
Re:
INVOICE #: 1Tht1S 2696-01
Civic Class Action Mailing- HL81 Part 1
Receive all relevant data and run a full data cleanse
Remove any non-applicable records (Honda Canada Inc, Honda Dealers,
etc.).
Format and prepare data for Mailing File 1.-62,517 Records to be mailed on
July Th, 2014. To include randomly selected Canadian Records and all US
Records
Print and prepare sufficient 4 part Notices and 2 part Claim Forms in both
English and French
Provide plain #10 envelopes to be Ink Jetted with: Honda Canada Return
address; UID Bar Code and Numerals; Postage Indicia; and outgoing Name
and Address.
Conduct letter shop based on using the language code found in the Honda
file and insert language specific inserts into each envelope, seal and deliver to
Canada Post
$53,452.04
62,517 Records@ $0.855
Deliver to Canada Post on July 71h, 2014
HST@13%
Total
Terms: Payable on Receipt
HST # 87891 9638
We thank you for yo/.lr business
RETE:--.110:-; lvi.>.RKETT:.:G 5'tTE:".IS ]XC.
82 B~rkd~y Stre~t
Studio Number 20l
Toronto, Ontario, Canada, M5A 2W7
Tel: -H6-J68-2660 • Fax: ·H6-Jn8-5824
~,948.77
$ 60,400.81
(RetentionJ1V1. ,\KETlNG
Honda Canada Inc.
180 Honda Boulevard
Markham, Ontario
L6COH9
Attention:
DATE:
Re:
i'vfr. Alvin Cheung
Tulv 23cd, 2014
INVOICE#: R.lv1S 2696-02
Civic Class Action Mailing- HL81 Part 2
Receive all relevant data and nm a full data cleanse
Remove any non-applicable records (Honda Ca11.ada Inc, Honda Dealers,
etc.).
Format and prepare data for Mailing File 2. - 62,583 Records to be mailed on
July 18th, 2014. To include randomly selected Canadian Records
Print and prepare sufficient 4 part Notices and 2 part Claim Forms in both
English and French
Provide plain #10 envelopes to be Ink Jetted with: Honda Canada Return
address; UID Bar Code and Numerals; Postage Indicia; and outgoing Name
and Address.
Conduct letter shop based on using the language code found in the Honda
file and insert language specific inserts into each envelope, seal and deliver to
Canada Post
62,583 Records @ $0.855
Deliver to Canada Post on July 18th, 2014
HST@ 13%
Total
Terms: Payable on Receipt
HST # 87891 9638
We thank you for your business
RETE:-..IIOC\i "-l..>.RKET!~G SHE:\ IS (>:C.
82 Bt!rkeley Street
Studio Number 201
Toronto, Ontario, Canada, !1-15.-\ 2~V7
Tel: ·116-368-2660 • Fax: -!16-368-582-l
6,956.10
$ 60,464.57
[Retention}
MARKETING
Honda Canada Inc.
180 Honda Boulevard
Markham, Ontario
L6C OH9
Attention:
Mr. Alvin Cheung
DATE: Tulv_ 31st. 2014
Re:
INVOICE #: RivlS 2696-03
Civic Class Action Mailing- HL81 Part 3
Receive aU relevant data and nm a full data cleanse
Remove any non-applicable records (Honda Canada Tnc, Honda Dealers,
etc.).
Format and prepare data for Mailing File 3- Final File- 62,536 Records to be
mailed on July 30th, 2014. To include the balance of all Canadian Records
Print and prepare sufficient 4 part Notices and 2 part Claim Forms in both
English and French
Provide plain #10 envelopes to be Ink Jetted with: Honda Canada Reh1m
address; UID Bar Code and Numerals; Postage Indicia; and outgoing Name
and Address.
Conduct letter shop based on using the language code found in the Honda
file and insert language specific inserts into each envelope, seal and deliver to
Canada Post
62,536 Records - Balance of the file - @ $0.855
$53,468.28
Deliver to Canada Post on July 301h, 2014
HST®13%
Total
Terms: Payable on Receipt
HST # 87891 9638
We tlzank you for your business
RETE><"TID~'< 1vi.\RKETt;-.;c S"YTE~Is r~c.
82 Berkeley Street
Studio Numbt!r 201
Toronto, Ontario, Canada, tvl5.-\ 2W7
Tel: Ho-368-2660 • Fax: ·Ho-368-582-!
6,950.88
$ 60,419.16