This page contains the Applicant’s Written Submissions for Motion #1 in McLean v. TDHA et al, filed and served January 30, 2025 in the Divisional Court. The submissions outline the Applicant’s position that the Licence Appeal Tribunal has failed to comply with its statutory duties under section 10 of the Judicial Review Procedure Act and section 20 of the Statutory Powers Procedure Act by not forthwith filing the Record of Proceeding from December 24, 2023 to September 12, 2024. The Applicant seeks orders compelling the Tribunal to file the complete record, prohibiting its participation until compliance, and permitting ancillary relief if the Tribunal remains non‑compliant. The submissions rely on leading authorities including Payne, Rol‑Land Farms, Reflection Productions, Jacko, and Lachance, emphasizing the Divisional Court’s inherent jurisdiction to insist upon a full and accurate record. This page forms part of LawCap’s public‑interest archive documenting record‑integrity obligations, procedural fairness, and judicial oversight in administrative law.