Schedule of Unjust Enrichment — Mohawk Nation of Grand River

The Gazette of the Mohawk Nation of Grand RiverNo. G61 · 2 April 2026

Full eight-layer analysis. Total: approximately $2.96 trillion CAD.

The instrument

Gazette No. 61 — Schedule of Unjust Enrichment

Haldimand Accounting Exhibit — Formal Exhibit to the Haldimand Lands Trust Account

2 April 2026 (Date of Original Instrument) · Registered 5 April 2026

Gazette No.: GZT001-050400-000061 [now GZT001-260609-000061]

Tracking Code: TG0827-050400-000060 Status: Perfected — Registered and Published

SCHEDULE OF UNJUST ENRICHMENT

A Comprehensive Economic Accounting of Wealth Generated and Retained by the Crown from Haldimand Tract Lands

Formal exhibit to the Haldimand Lands Trust Account (GZT001-050300-000025 [now GZT001-260606-000025]) and the Haldimand Accounting Instrument (GZT001-010300-000027 [now GZT001-260609-000027]). Published in the Two Row Times, 2 April 2026. Transmitted to His Majesty King Charles III as a schedule to the Representation and Notice dated 2 April 2026. Dispatched by registered mail to Buckingham Palace.

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| :-: |
| *KEY FOUNDING FACT\The City of Brantford’s own internal report (1994) assessed the total value of lands it administers at $250 billion CAD,\and acknowledged that 90% of those lands fall within the Mohawk national land claim.\*This figure, originating from the Crown’s own municipal apparatus, is the conservative baseline for all calculations herein. |

I. PREAMBLE AND LEGAL FOUNDATION

This Schedule is prepared as an annex to the Representation and Notice to His Majesty King Charles III, asserting the continuing obligations of the Crown under the Haldimand Proclamation of 25 October 1784 and the Silver Covenant Chain covenant relationship. It constitutes a formal accounting of the economic enrichment received and retained by the Crown and its municipal, provincial, and federal instrumentalities from Haldimand Tract lands that the Crown’s own municipal apparatus — the City of Brantford — acknowledged in 1994 to be ninety percent (90%) under Mohawk national land claim.

The legal doctrine engaged is unjust enrichment, well established in both common law and equity: where one party has been enriched, another correspondingly deprived, and there exists no juristic reason for that deprivation, the enriched party bears an obligation of restitution. The Haldimand instruments constitute the juristic framework from which the Nation’s entitlement flows. The Crown’s own records confirm the deprivation. This Schedule quantifies the enrichment.

II. METHODOLOGY AND INDEXING

The 1994 report established a land valuation baseline. The Consumer Price Index, which tracks the cost of consumer goods, is an inappropriate index for land valuation and has been rejected in favour of real property appreciation ratios — the only economically honest measure for updating land values over time.

The real property appreciation ratio for the Grand River Territory is established by reference to a representative residential property benchmark: a four-bedroom dwelling in Brantford valued at $80,000 in 1994 is valued at $500,000 in 2026. This produces a multiplication factor of 6.25x — representing actual market appreciation of land and property on Haldimand Tract.

III. SCHEDULE OF UNJUST ENRICHMENT — EIGHT LAYERS

Layer 1 — Land Asset Value

| | | |
| :-: | :-: | :-: |
| *Component* | *Calculation* | *Value (CAD)* |
| 1994 baseline (City of Brantford report — full tract) | — | $250,000,000,000 |
| Real property appreciation multiplier (1994–2026) | 6.25x | — |
| Total appreciated value — full tract (2026) | $250B × 6.25 | $1,562,500,000,000 |
| *90% under Mohawk national claim* | \$1.5625T × 0.90\ | \$1,406,250,000,000\ |

Layer 1 Subtotal: $1,406,250,000,000 CAD

Layer 2 — Infrastructure Capital Installed on Claimed Lands

| | |
| :-: | :-: |
| *Infrastructure Category* | *Estimated Cumulative Investment (1994–2026)* |
| Provincial highways and roads (Hwy 403, 401 corridor, regional roads) | $35,000,000,000 |
| Municipal roads, bridges, and stormwater (39 municipalities) | $28,000,000,000 |
| Water and wastewater systems | $18,000,000,000 |
| Hospitals and health infrastructure (Hamilton Health Sciences, Grand River Hospital, etc.) | $12,000,000,000 |
| Schools, post-secondary campuses (Laurier Brantford, University of Waterloo, etc.) | $8,000,000,000 |
| Transit infrastructure (ION LRT, GO Transit, regional transit) | $6,000,000,000 |
| Government buildings, courthouses, civic infrastructure | $5,000,000,000 |
| *Layer 2 Subtotal* | \$112,000,000,000\ |

Layer 3 — Tax Revenue Extracted from Haldimand Tract

Layer 4 — Licensing, Fees, and Resource Extraction

| | |
| :-: | :-: |
| *Category* | *Estimated Cumulative (1994–2026)* |
| Aggregate extraction royalties and licenses (Grand River valley) | $8,500,000,000 |
| Commercial water-taking permits and fees | $3,200,000,000 |
| Environmental and resource licenses (quarrying, mining, gravel) | $4,800,000,000 |
| Commercial and business licenses (municipal) | $6,400,000,000 |
| Liquor licenses, gaming licenses, other regulatory fees | $3,100,000,000 |
| Crown land leases and easements within tract boundaries | $2,600,000,000 |
| Hunting, fishing, and conservation authority fees | $1,800,000,000 |
| *Layer 4 Subtotal* | \$30,400,000,000\ |

Layer 5 — Agricultural Production and Agri-Food Revenue

Layer 6 — Trade, Commerce, and Industrial Output

Layer 7 — Intellectual Property, Patents, and Innovation

The University of Waterloo, located within the Haldimand Tract corridor, operates one of the world’s top co-operative education and intellectual property programs. University of Waterloo students retain ownership of their intellectual property — a policy that has produced a disproportionate concentration of patent activity, startup formation, and technology commercialization on Haldimand Tract lands. The Toronto-Waterloo Innovation Corridor generates 17% of Canada’s national GDP.

| | |
| :-: | :-: |
| *IP and Innovation Category* | *Estimated Cumulative (1994–2026)* |
| Patents registered by entities on Haldimand Tract (University of Waterloo, private sector) | $28,000,000,000 |
| Technology startup valuations and exit value (IPOs, acquisitions) — on-tract entities | $45,000,000,000 |
| R\&D tax credits claimed by on-tract corporations (federal SR\&ED program) | $12,000,000,000 |
| University research grants and commercialization (NSERC, CIHR, CFI) on-tract institutions | $8,400,000,000 |
| Venture capital invested and retained in on-tract tech ecosystem | $6,800,000,000 |
| Licensing revenues from on-tract IP held by Crown-funded institutions | $3,200,000,000 |
| *Layer 7 Subtotal* | \$103,400,000,000\ |

Layer 8 — Water, Environmental, and Natural Resource Value

| | |
| :-: | :-: |
| *Natural Resource Category* | *Estimated Cumulative (1994–2026)* |
| Municipal water supply value (drinking water drawn from Grand River system) | $14,200,000,000 |
| Agricultural water use (irrigation, livestock water) | $4,800,000,000 |
| Hydroelectric and power generation on river system | $2,100,000,000 |
| Timber and forestry (reforestation credits, conservation authority woodlots) | $1,600,000,000 |
| Aggregate and gravel extraction (river valley deposits) | $7,400,000,000 |
| Carbon credit and conservation offset value (GRCA-managed lands) | $2,800,000,000 |
| *Layer 8 Subtotal* | \$32,900,000,000\ |

IV. SUMMARY ACCOUNTING — TOTAL UNJUST ENRICHMENT

| | | |
| :-: | :-: | :-: |
| *Layer* | *Category* | *Value (CAD)* |
| *1* | Land Asset Value (90% of appreciated 2026 value) | $1,406,250,000,000 |
| *2* | Infrastructure Capital Installed on Claimed Lands | $112,000,000,000 |
| *3* | Tax Revenue Extracted from Haldimand Tract | $653,560,000,000 |
| *4* | Licensing, Fees, and Resource Extraction | $30,400,000,000 |
| *5* | Agricultural Production and Agri-Food Revenue | $62,600,000,000 |
| *6* | Trade, Commerce, and Industrial Output | $554,500,000,000 |
| *7* | Intellectual Property, Patents, and Innovation | $103,400,000,000 |
| *8* | Water, Environmental, and Natural Resource Value | $32,900,000,000 |
| *TOTAL — Conservative Aggregate Unjust Enrichment* | \$2,955,610,000,000\ | |

TOTAL UNJUST ENRICHMENT — CONSERVATIVE ESTIMATE$2,955,610,000,000 CAD≈ $2.96 Trillion Canadian Dollars

This figure represents a conservative floor. All eight categories apply standard economic methodologies; none involves speculation. The true figure, inclusive of compound opportunity cost, interest on the 1784 land value itself, and uncounted secondary economic multipliers, is considerably higher.

V. LEGAL FRAMING — UNJUST ENRICHMENT

The doctrine of unjust enrichment requires three elements: (1) enrichment of the defendant; (2) corresponding deprivation of the plaintiff; and (3) absence of juristic reason for the enrichment. All three elements are clearly established on the face of the record.

Enrichment of the Crown: The figures in this Schedule document $2.96 trillion in land value, tax revenue, resource extraction, commercial output, and infrastructure value received and retained by the Crown from Haldimand Tract lands over 32 years alone.

Corresponding deprivation of the Nation: The Mohawk Nation of Grand River has been excluded from governance, revenue, and benefit from its own treaty territory since the Haldimand Proclamation, a deprivation extending not 32 but 240 years.

Absence of juristic reason: No valid legal instrument has extinguished Mohawk title to the claimed lands. The Haldimand Proclamation of 1784 constitutes the founding instrument. The Crown has never provided consideration adequate to extinguish it. The City of Brantford’s own 1994 acknowledgment that 90% of its lands remain under Mohawk claim confirms that no resolution has been achieved.

This Schedule is tendered not as a litigation demand but as a statement of account — a record, placed before His Majesty, of the magnitude of the obligation that accumulates with each year the Crown delays honoring the Haldimand instruments.

VI. NOTES ON SOURCES AND CONSERVATISM

Land value baseline: City of Brantford internal report, 1994. Secretary-General holds reference. Source is the Crown’s own municipal instrumentality.

Real property appreciation ratio: Brantford four-bedroom residential benchmark: $80,000 (1994) to $500,000 (2026) = 6.25x. Conservative regional average; commercial and industrial land appreciation has been higher.

CPI data: Statistics Canada, cumulative 1994–2026 inflation approximately 93% (multiplier 1.93x). Applied for reference only; real property ratio governs land valuation.

Population figures: Grand River Conservation Authority Watershed Report 2020 — approximately one million persons in the watershed.

Agricultural data: Ontario Ministry of Agriculture, Food and Agribusiness county profiles; Statistics Canada Census of Agriculture 2021; Grand River watershed — approximately 5,641 farms, 70% of land area in agriculture.

Technology/innovation data: Region of Waterloo economic indicators; Toronto-Waterloo Innovation Corridor — ranked 16th global startup ecosystem, representing 17% of Canadian national GDP.

Manufacturing data: Waterloo Region manufacturing sector — fourth largest in Canada, annual revenues exceeding $6 billion, 57,000 employees.

Double-counting: All estimates are independent of one another. No double-counting has occurred between layers. Overlap risk is lowest between Layers 1 (asset value), 3 (tax flows), and 6 (commercial output), which represent distinct economic phenomena.

VII. ATTESTATION

This Schedule is entered into the Register of the Mohawk Nation of Grand River Secretariat under Gazette No. 61 and published in the Two Row Times as a matter of Mohawk national record. It is transmitted to His Majesty King Charles III as a schedule to the Representation and Notice dated 2 April 2026, dispatched by registered mail to Buckingham Palace, London, England.

Benjamin Doolittle UE, Secretary-General

Date

CERTIFICATION OF THE REGISTRAR GENERAL

I certify that this instrument has been duly received, examined, and entered in the Register of the Nation of the Mohawk Nation of Grand River Secretariat.

Gazette No.: GZT001-050400-000061 [now GZT001-260609-000061]

Original Date: 2 April 2026

Cross-References: GZT001-050300-000025 [now GZT001-260606-000025] (Haldimand Lands Trust Account); GZT001-010300-000027 [now GZT001-260609-000027] (Haldimand Accounting Instrument); GZT001-050400-000035 [now GZT001-260211-000035] (Representation to His Majesty the King)

Jesse Butler UE, Registrar General

Date of Registration

This instrument forms part of the permanent record of the Secretariat.

Mohawk Nation of Grand River · Grand River Territory

Published in the Two Row Times — Publication of Record

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