Statement of Allegations: David Nunn et al.

IN THE MATTER OF THE SECURITIES ACT
R.S.O. 1990, c. S.5, AS AMENDED

AND

IN THE MATTER OF
DAVID NUNN, MICHAEL M. REDDY,
LORNE J. GELLENY AND BARRY J. RACIPPO

STATEMENT OF ALLEGATIONS OF STAFF
OF THE ONTARIO SECURITIES COMMISSION

Staff of the Ontario Securities Commission make the following allegations:

1. Kingscross Communities Incorporated ("Kingscross") is incorporated under the lawsof Canada. Kingscross is a reporting issuer in Ontario.

2. Each of David Nunn, Michael M. Reddy, Lorne J. Gelleny and Barry J. Racippo(individually, a "Respondent" and collectively, the "Respondents") is, or was duringthe financial year of Kingscross ended December 31, 1999, a director, officer,significant shareholder (beneficial ownership of 10% or more of the voting rights ofKingscross) or individual that has, or may have, access to material undisclosedinformation.

3. Kingscross failed to file annual financial statements for its financial year endedDecember 31, 1999 on or before May 19, 2000, contrary to subsection 78(1) of theSecurities Act (Ontario).

4. By virtue of his/her/its relationship, each Respondent has, or may have, access toinformation regarding the affairs of Kingscross that has not been generallydisclosed.

5. It would be prejudicial to the public interest to allow the Respondents to trade in thesecurities of Kingscross until such time as all disclosure required by Ontariosecurities law has been made by Kingscross.

6. It is therefore in the public interest for the Commission to order that all trading,whether direct or indirect, in the securities of Kingscross by the Respondents ceaseuntil such time as Kingscross has made all filings it is required to make underOntario securities law.