What is the defence argument in support of the House Warrant and the Wood Gundy Warrant?

The defence says that the ITOs sworn in support of each application (i.e. for the House Warrant and the Wood Gundy Warrant) did not establish the reasonable grounds required for the issuance of either search warrant, i.e. the defence attacks the ‘facial validity’ of the warrants. As well, the defence says that there were material errors in and omissions from the ITOs that if corrected and included would have negated any reasonable grounds that were shown in the ITOs put before the authorizing Judge, i.e. the defence also challenges the ‘sub-facial validity’ of the warrants. (See: R v. Sadikov, infra, at paras. 36-38).