conclusory statements about the affiant’s subjective response to
Mr. Bracken: “Mr. Bracken is loud, overbearing and very intimi-
dating. I did not approach him on my own and would not do
so because I am not sure how he will react. I am very afraid
 This affidavit does not explain what Mr. Bracken did on
that day or any other that caused Ms. Schultz to be fearful. On
cross-examination, she admitted that he had never threatened
her and had never acted violently towards her. The basis of her
fear, she said, “I think it’s just your whole demeanour and your
voice and just your body language in general that’s a little intim-
idating.” When questioned, she also mentioned his interaction
with her at the service counter on a previous day in which he
was “getting very loud”, and her discussions with colleagues
about his You Tube videos.
 Ms. Hansen’s affidavit was ten paragraphs. In it, she
states that she was concerned that Mr. Bracken’s “erratic behaviour would intimidate those trying to get into the meeting” that
was scheduled to begin an hour later. She was concerned “to
make sure staff on the first floor were safe and secure” and instituted a lockdown procedure to ensure the safety of the staff.
(On the evidence in the record, the “lockdown” consisted of locking an internal door between the council chamber and the
administrative offices.) She stated that she remains concerned
about her safety and the safety of others around Mr. Bracken.
 As with Ms. Schultz’s affidavit, Ms. Hansen’s affidavit
chronicles no acts of violence or threatened violence during
Mr. Bracken’s protest, or of Mr. Bracken preventing or attempting to prevent anyone from entering Town Hall.
 Ms. Hansen’s attitude to public protest, and the fragility
of her safety concerns, emerged on cross-examination:
171. Q: You’re not aware if protesting is allowed on Town property?
A: I’m not.
172. Q: Have you ever seen a protest on Town property?
. . . . .
179. Q: have I ever been verbally violent or physically violent with
A: I’ve never had a conversation with you before.
. . . . .
251. Q: is it normal for someone who has never had a conversation with somebody — has never spoken a word with somebody, who’s never interacted with