This page contains the Applicant’s Motion Record for Motion #1 in McLean v. TDHA et al, dated January 23, 2025 and filed in the Divisional Court. The Motion Record includes the Notice of Motion, Confirmation of Motion, the JRPA Application, the Applicant’s Factum, the Application Record, Affidavit #2, Affidavit #4, the Certificate of Perfection, and all supporting materials relied upon for the relief sought. Motion #1 seeks orders compelling the Licence Appeal Tribunal to forthwith file the complete Record of Proceeding under section 10 of the Judicial Review Procedure Act and section 20 of the Statutory Powers Procedure Act, prohibiting the Tribunal’s participation until compliance, and permitting costs submissions. The Motion Record outlines the Tribunal’s 69‑day non‑compliance period, the statutory duties triggered upon service of the JRPA Application, and the jurisprudential foundation for record‑integrity obligations, including Payne, Rol‑Land Farms, Reflection Productions, Endicott, Jacko, and Lachance. This page forms part of LawCap’s public‑interest archive documenting procedural fairness, statutory compliance, and judicial oversight in administrative law.