Proceedings

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IN THE MATTER OF
THE SECURITIES ACT, RSO 1990, c S.5

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IN THE MATTER OF
MICHAEL PATRICK LATHIGEE, EARLE DOUGLAS PASQUILL,
FIC REAL ESTATE PROJECTS LTD., FIC FORECLOSURE FUND LTD.
and WBIC CANADA LTD.

STATEMENT OF ALLEGATIONS
OF STAFF OF THE ONTARIO SECURITIES COMMISSION