In connection with the handgun at Mork’s home, the
appellant recounted several reports from source C about having
heard about, then later seen a handgun, of a specific manufacture and model, hidden in the cushions in a sofa in the basement
of Mork’s house.
 Absent from the ITO was any mention of the origins of the
gun at Mork’s home, more specifically, that it had been planted
there by source C with the express agreement, if not the urging,
of the appellant, so that Mork could be taken out of circulation
for a significant period of time.
 In the ITO, the appellant described source C’s motivation
for informing on Mork as being that he was “sick of drug dealers
taking advantage of others”. The appellant omitted any reference to the nature of the relationship among sources A and C
and Mork. Further, the appellant made no mention of source C’s
specific animus towards Mork, his desire for revenge or his
financial motivation for providing information.
 In connection with source B, the appellant described his
motivation as a desire to eliminate Mork as competition in the
drug trafficking business. What the appellant failed to point
out was that source B’s real motive was to provide information
on those, such as Mork, who had ripped him off in prior drug
 The appellant also included in the ITO a claim that
source C had seen plastic wrap and scales at Mork’s home, items
commonplace in a drug trafficker’s tool kit. But source C said
nothing about plastic wrap, nor about scales, apart from having
left a set of his own scales behind at Mork’s home.
The execution of the warrant
 The CDSA warrant authorized police to search for and
seize cocaine and related drug paraphernalia. The warrant contained no mention of a handgun. Police found no handgun when
they executed the warrant.
The appellant’s explanation
 The appellant testified. He offered four principal explanations for the omissions and inconsistencies between the information provided by source C and what he included in the ITO.
 First, innocent error. The appellant acknowledged that as
the affiant in an ex parte application, he was required to make
full, fair and frank disclosure of all material facts. He said his
mistakes were innocent errors which he attributed to rushed
preparation and the density and complexity of the text messages
that he was required to quickly summarize in the ITO.