You will have seen various versions of the Affidavit sworn by Ian Walter Cambridge on 19 September, 1996 in matter 2082/96 in the Australian Industrial Relations Court.

Now I think for the first time you will see all the exhibits to the Affidavit.

I'll post them here in this post, it will grow over the next day or so.

The First download contains Cambridge's Exhibits IWC 1, 2 and 3, all about union rules

Download Cambridge Affidavit Exhibits re Union Rules  

Exhibit IC 4 is referred to on Page 9 of the Affidavit, "Attached hereto and marked IWC 4 are the Application forms and Rules of the Association.   I do not know what process Ian Cambridge and his solicitors used to gain access to these papers.   Presumably they were returned under subpoena from the AIRC to the WA Corporate Affairs Commissioner.   Whether the return of the subpoenas included other correspondence (particularly the letter of comfort from Ms Gillard vouching for the Association's bona fides and other correspondence) or not is unknown to me.   I don't know whether Mr Cambridge had the letters and didn't exhibit them or not.  

Download Cambridge Affidavit Exhibit re AWU Workplace Reform Association Application Form and Rules  

These next few exhibits describe a few payin slips for the AWU-WRA - a $46,550 cheque to set up the Construction Industry Fund (once Wilson knew he'd be running the National Construction Branch) - note the chutzpah here, the initial address for the account is a PO Box in Fitzroy Melbourne, then they move it to Ralph's home address in Perth after they get the flick - but they continue to operate the account and to invoice Thiess.   Is this the action of a person or persons who believe that the law or their former employer is seriously pursuing them?   Or was the fix in even then?   Just remember the dates that Wilson was sprung and got the redundancy money and left - 17 August, 1995 it was all over.   Check out the dates that Construction Industry Fund continues to operate and receive money (from Thiess) - right up to early 1996.     Gillard knew about AWU-WRA and apparently said nothing.   There are statements for the WA Election Fund, again operated out of Blewitt's home address.   Finally there are pay-in slips for a large amount of money coming from Thiess, John Holland, Philips Fox, Chambers Consulting, Fluor Daniel etc.   About $170,000 came into Member's Welfare Account NO 1 (3008 10000 9028) during a few weeks.   It seems to be the case that this was the "event" that brought Wilson unstuck.

Download Cambridge Affidavit Exhibits re a few AWU-WRA pay-in slips, Construction Industry Fund, WA Election Fund, pay-in AWU Member's Welfare Assn No1 ACCNt

 The last exhibits showed quite a flurry of fund-raising by Wilson and those close to him.   Notwithstanding the union rules, about $170,000 raised from construction companies (God knows on what basis) was paid into the AWU Members Welfare Association NO 1 Account in a few weeks over June/July 1995.   Wilson was sprung in July 1995.   The money paid to the union in that period (but deposited into a slush fund - read the paying slips carefully, many just say AWU) was returned to the companies as part of Wilson's departure deal.   Maurice Blackburn represented Bob Smith (the incoming Victorian Branch head), and Slater and Gordon represented Wilson.   This next exhibit is the Affidavit of Brian Kilmartin, a partner in Con Sciacca's law firm, representing Bill Ludwig.   Basically the affidavit tells the court about the willingness of the companies that paid the money, had the money returned to them and will now be asked to send that money back once again to the union.  I'll post the letters from the companies soon.   Some declare that the payments represented Union Dues, or members money.    It's one of the most peculiar elements of the whole saga, Wilson got the money in, it went into a slush fund, he was sprung, under legal advice the  money was returned to the companies (Detective Sergeant TURNLEY of the Victoria Police Fraud Squad who wrote off the matter said that action was to Wilson's credit, one would imagine that the Detective had been spoken to by lawyers involved in the matter).   So this affidavit tells you how the money will come back into the union.

One last thing.   Money back from the companies.   No money back from Wilson.

Download Cambridge Affidavit Exhibiting Brian Kilmartin Affidavit re return of money to large construction firms