Author: Ronnie

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Defamation Claim Against CSASPP And Donor Dismissed As A SLAPP

June 28, 2022, a $1.1 million defamation lawsuit was filed against the B.C. based group CSASPP, and 3 of its members. It was commenced 18 months ago, and finally thrown out by Justice Chalmers under Ontario’s anti-SLAPP laws. (See CanLII version).

For a bit of context, “SLAPP” is an acronym for a strategic lawsuit against public participation. It’s when a person or group sues another in order to silence their expression on issues of public interest.

The suit was filed by “Mr. Bad Beyond Argument” himself, who seems to put more effort into threatening and suing his critics than he does in holding tyrannical administrations to account. This site has extensively covered just how shoddy those pleadings are.

An anti-SLAPP Motion is simply a Motion to dismiss. It’s complex, and there are many steps, but really, it’s just a Motion to dismiss. Here are the basic requirements:

Tests that must be met by both sides

The Defendant(s), or Moving Part(y/ies), must convince the Judge that the expression is that of a public interest. Specifically, it must be on a topic that at least a segment of the population has a genuine interest in knowing about. By design, it’s a very low burden.

If successful, the burden shifts to the Plaintiff(s), or Respondent(s), who then must pass 3 conjunctive tests. If the Plaintiff(s) fails even 1 part, then the case must be dismissed.

(A) The Plaintiff(s) must convince the Judge that there is “substantial merit” to the allegations. That’s not to say that a win is guaranteed, but that it’s more likely than not that it could prevail at Trial.

(B) The Plaintiff(s) must convince the Judge that there are no reasonable defences that are likely available. There are many ways to overcome a defamation suit, and the Plaintiff(s) must show that there are no plausible ones.

(C) The Plaintiff(s) must convince the Judge that there is greater public interest in allowing the case to proceed to Trial than there is in protecting the expression. At the heart of it, the Plaintiff(s) must also show that the expression led to (or will lead to) serious financial and/or reputational harm. Here, the Court decides which will prevail.

Here, the CSASPP Defendants prevailed in every aspect. It wasn’t a close call, or a difficult case.

[45] The pandemic and the governments’ response affected virtually all Canadians. The actions commenced by A4C, and the Society are proposed class actions. I am of the view that segments of the public have a genuine interest in receiving information about a lawyer who is acting for plaintiffs in a proposed class action that challenges the government’s response to the pandemic.

[46] The expression relates to the differences between the actions commenced by the Plaintiff on behalf of VCC and A4C, and the action commenced by the Society. The expression also relates to the use of funds donated to be used in the litigation to challenge the government’s response to the pandemic. Those members of the public who donated money for the litigation would have a genuine interest about the quality of legal representation and how their donations are being used.

The public has a valid interest in knowing what is happening with those cases, and how the money being donated is being spent.

The Plaintiff couldn’t even meet a single branch of the test

(A) The Court found that there was no merit to the defamation claims, so the case was effectively over then. Additionally, the other “torts” such as: abuse of process; unlawful means; harassment; conspiracy, etc… were just derivatives of the defamation claims.

(B) The Court accepted all defences that were offered, including: (i) absolute privilege; (ii) qualified privilege; (iii) justification, or truth; and (iv) fair comment. Absolute privilege protects complaints to quasi-judicial bodies, and prevents retaliatory lawsuits. Qualified privilege refers to an obligation — usually professional — to speak out. Fair comment refers to the protection of people to express opinions that could honestly be held.

(C) The Court also found that there was much stronger interest in protecting the expression than allowing the case to continue. It didn’t help that while financial losses were alleged, the details of which were withheld. Nor did it help that there were many other sources of criticism, making it harder to pinpoint a source.

At its core, it was about 4 different expressions

(1) A January 2021 email to Dan Dicks of Press for Truth, inviting people to donate this case, as opposed to the Action4Canada one. At the time, there had been nothing filed, despite months of fundraising.

(2) A June 2021 change to the FAQ (frequently asked questions) which stated clearly that there was no association or affiliation between the groups, and gave reasons why. It was also largely a duplicate of the Dicks email.

(3) A January 2022 complaint to the LSO — or Law Society of Ontario — asking for information as to the whereabouts of money donated to various cases.

(4) Allegations — not properly pleaded — of a conversation where there was a desire to see the Plaintiff disbarred and criminally charged with fraud.

Interestingly, the Dicks email and the FAQ took place more than a year prior to this case being filed. It’s the LSO complaint that appears to have been the driving force.

Brief timeline of major events

January 2021: CSASPP emails Dan Dicks in order to promote their proposed suit, and to pitch it as a better investment than Action4Canada.

June 2021: CSASPP puts the section up on their FAQ, supposedly to quell constant inquiries about who they are connected to, and what there role is in other cases.

January 15, 2022: the original LSO complaint is put forward to the LSO, although it appears that it wasn’t immediately accepted.

May 19, 2022: The LSO finally forwards the complaint and demands a response.

June 28, 2022: The $1.1 million dollar suit is filed against CSASPP and its people

June 29, 2022: A letter is sent to the LSO, informing them that Donna Toews has been sued, and that the Court will effectively be deciding the issue.

July 12, 2022: The Law Society itself is sued, and the Toews complaint makes up large part of it. One can assume this was done to further thwart any investigation into the complaint. The suit demands $500,000 in damages, and is very poorly written.

July 13, 2022: There’s an appearance on a livestream with Vaccine Choice Canada, bragging about the CSASPP and LSO suits which have just been filed. It’s plausible to view this as a publicity stunt. Supposedly, neither CSASPP nor the LSO had actually been served by this point.

October 12, 2022: CSASPP and the LSO appear in Court on the same day to set down dates to throw out their respective cases. CSASPP’s Motion is based on s.137.1 of the Courts of Justice Act (anti-SLAPP). The LSO Motion is based on Rule 21 of Civil Procedure (failing to state a cause of action). Both are to be heard the next Autumn.

The next several months is a document exchange of the papers needed to carry out the anti-SLAPP Motion. The LSO documents are also attached below.

July 28, 2023: CSASPP files their Factum, or written arguments. This is a Friday, and it’s interesting to see what happens the following Monday.

July 31, 2023: The Law Society is sued for a second time, and it’s largely a rehash of the first one. Another $500,000 is sought. It’s possible this was done to “keep open” litigation against the LSO, assuming the first case is thrown out.

September 12, 2023: CSASPP’s Motion to dismiss is heard, with the ruling under reserve.

September 21, 2023: LSO’s Motion to strike is heard, the ruling under reserve.

December 11, 2023: The suit against CSASPP is dismissed as a SLAPP. The Court finds that the suit was brought for the improper purposes of stifling debate, and to intimidate people from filing LSO complaints. In essence, it’s a finding of professional misconduct.

The Law Society Complaint from Donna Toews

On June 19, 2020, I donated $1000 in my husband’s name to Vaccine Choice Canada with specific instructions to give the donation to the Legal Fund headed by Mr. Galati, who was preparing a claim seeking relief on behalf of Canadians wronged by the actions of government officials and others because of Covid-19. I also donated $1000 to Action4Canada, which was soliciting donations to fund a similar lawsuit in British Columbia. I understand that Vaccine Choice Canada,Action4Canada, and a third organization in Quebec have raised approximately $3,500,000 to finance litigation in Ontario, British Columbia and Quebec. Vaccine Choice Canada confirmed that my donation had gone to its Legal Fund to support its legal fees for the constitutional challenge to be brought by Mr. Galati.

As VCC suggested, I “added a membership to my file” so that I would be invited to members only meetings with Mr. Galati. (This email exchange is attached. I have redacted my name and other information that may identify me). Mr. Galati commenced the action on behalf of Vaccine Choice Canada and other plaintiffs on July 6, 2020.

Mr. Galati stated during a media interview that he would be sure that an interim hearing would be held before December 2020. I received no information about the progress of the litigation until almost 18 months later. I was not invited to any members only meetings with Mr. Galati in the meantime. No interim hearing has been held, and no Statements of Defence have been delivered as far as I can determine. No default proceedings have been taken. In fact, I do not know whether the defendants have even been served with the Statement of Claim.

I wrote to Vaccine Choice Canada on December 20, 2021, to ask whether anything had come of the lawsuit and whether the Court had seen it yet. Vaccine Choice Canada replied on January 2, 2022, that, “our case filed in the summer of 2020 has not had a hearing yet. The lawyer is working backstage, but he does not want to tell anything of what he is doing so he does not give an opportunity to the enemy.” (This email exchange is attached. I have redacted my name and other information that may identify me).

I do not know the relationship between Vaccine Choice Canada, or Action4Canada,and Mr. Galati, other than that Mr. Galati is representing them in the litigation. No financial statements of VCC have been filed with Corporations Canada as of December 22, 2021. I do not know much of the funds raised by these organizations have been turned over to Mr. Galati in trust, how much he has been paid, or what he expects to result from the claim he has started (but, evidently neglected to pursue).

Justice Chalmers not only ruled that the Toews complaint was protected by absolute privilege. He found that she had been sued in order to derail the complaint, and as an act of intimidation.

From the ruling

[89] With respect to the claim against Ms. Toews, I am of the view that “what is really going on” is an attempt to intimidate members of the public who may be considering making a complaint about the Plaintiff to the LSO. The effect of the action against Ms. Toews would be to obstruct the regulatory process. The harm this would cause in the LSO’s ability to receive and process complaints about lawyers is, in my view significant.

[94] I also find that there is a strong public interest in protecting the right of members of the public to make complaints to quasi-judicial bodies such as the LSO. If the public could be subject to expensive litigation for making a complaint, this would impair the ability of the LSO to regulate the profession. I find that this harm outweighs any harm that may have been suffered by the Plaintiff because of the LSO complaint.

[98] For the reasons set out above, I find that the Plaintiff brought this action for the improper purpose of stifling debate with respect to his handling of a proposed class action that is being funded by public donations. I also note that the Claim was brought one day before the Plaintiff submitted a response to the LSO with respect to Ms. Toews complaint. I find that the Claim was brought for the improper purpose of limiting the LSO investigation, and to intimidate others from making any LSO complaints about him.

This is now official: an ONSC Judge has ruled that a lawsuit was filed in order to sabotage an existing LSO complaint, and to intimidate others from making complaints. This is grounds for disbarment, and there is precedent in Ontario for revoking licences under these circumstances.

Justice Chalmers also found that criticising “Mr. Bad Beyond Argument” was justified, because his cases — particularly his anti-lockdown suits — were objectively very poor.

[74] In the e-mail to Mr. Dicks dated January 29, 2022, Mr. Gandhi supported the statement with hyperlinks to support the statements. The statements made in the FAQ are also supported by hyperlinks that provides that factual support for the statements. The statements made in the e-mail to Mr. Dicks and in the FAQ, that the Plaintiff has been criticized by the courts in other cases, is supported by the following decisions: Sivak v. Canada, at para. 55, Galati v. Harper, at para. 35, Da Silva Campos v. Canada, at para. 12, Wang v. Canada, 2016 FC 1052, at para. 31, and Al Omani v. Canada 2017 FC 786, at para. 94-95.

[75] In the e-mail to Mr. Dicks, Mr. Gandhi states that lawyers who reviewed the Ontario claim, “said it was very poorly drafted” and “will most likely get struck”. I am of the view that there is justification for this comment. The Ontario pleading is prolix and argumentative. The claim advances pseudo-legal concepts and conspiracy theories that the pandemic was pre-planned and executed by the WHO, Bill Gates, the World Economic Forum and unnamed billionaires and oligarchs. The similarly drafted A4C claim was struck by Justice Ross. In doing so, he described the pleading as “bad beyond argument”.

[87] The comment with respect to the quality of the Plaintiff’s legal services is analogous to reviews of other products and services. Courts have recognized that discussion among the consuming public of the quality of services is a matter of public interest: Canadian Thermo Windows Inc. v. Seangio, 2021 ONSC 6555, at para. 5. The Defendants argue that the stifling of reasonable public debate as to the value of a lawyer’s services, tactics or approach to litigation negatively affects public confidence in the legal system. The Defendants also argue that it would bring the legal system into disrepute if a lawyer could drag those who question the value of his or her services through expensive litigation. I agree.

[93] On the other side of the ledger, I find that there is a strong public interest in protecting the expression. The Plaintiff is advancing a public interest class action with respect to the government’s restrictions in response to the pandemic. Members of the class, and persons who have donated to the litigation have a right to information about the lawyer retained to prosecute the claims.

One very minor error: neither the VCC nor A4C cases are class actions, although they would have the large impact on the public, depending on the ruling.

Apparently an appeal is already in the works. It’s unclear what possible grounds there are for reversal, as there are no major errors in the ruling.

Should people still be donating to these lawsuits, knowing that the lawyer in charge of them could very well be disbarred for bringing this case? Keep in mind, the LSO won’t take too kindly to having to pay to defend 2 frivolous suits themselves. Perhaps it’s time to consider other options.

One final thought: successful anti-SLAPP Motions in Ontario typically lead to “full indemnity” (or 100% of costs) for the Defendant(s). Considering the volume of paperwork involved here, it could easily top $100,000 to $150,000. Many such awards have been handed out in recent years, and in fact, have gone much higher. If the case is appealed unsuccessfully, that will likely lead to full indemnity costs as well.

CSASPP/RG DOCUMENTS (June 2022)
(1) CSASPP RG Statement Of Claim
(2) CSASPP RG Moving Party Motion Record Volume 1
(3) CSASPP RG Moving Party Motion Record Volume 2
(4) CSASPP RG Moving Party Motion Record Volume 3
(5) CSASPP RG Responding Motion Record Volume 1
(6) CSASPP RG Responding Motion Record Volume 2
(7) CSASPP RG Responding Motion Record Volume 3
(8) CSASPP RG Moving Party Supplemental Motion Record
(9) CSASPP RG Moving Party Record Motion To Strike
(10) CSASPP RG Plaintiffs Responding Record Motion To Strike
(11) CSASPP RG Transcript Brief
(12) CSASPP RG Moving Party Factum (Arguments)
(13) CSASPP RG Responding Plaintiff Factum
(14) CSASPP RG Moving Parties Reply Factum
(15) CSASPP RG Reasons For Judgement
(16) CanLII Posting Of Decision

1ST LAW SOCIETY OF ONTARIO CLAIM (July 2022)
(1) Law Society Of Ontario Statement Of Claim
(2) Law Society Of Ontario Intent To Defend
(3) Law Society Of Ontario Amended Statement Of Claim
(4) Law Society Of Ontario Requisition For Amended Claim
(5) Law Society Of Ontario Motion Record, To Strike
(6) Law Society Of Ontario Moving Party Factum To Strike
(7) Law Society Of Ontario Plaintiff Responding Factum

2ND LAW SOCIETY OF ONTARIO CLAIM (July 2023)
(1) Law Society Of Ontario Second Statement Of Claim

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UNESCO Guidelines For The Governance Of Digital Platforms

Recently, UNESCO released their action plan to regulate social media platforms. The guideline is a 59 page document outlining a series of goals and steps that should be taken by Member States.

On the surface, the paper seems harmless enough. But as with most things, the devil is in the details.

Going through this, the thoughts that comes to mind are the CRTC, and Bills C-11 and C-18. There’s a strong reluctance to accept any sort of Government interference with media access.

The paper talks about the importance of having an independent media, with a diversity of perspectives. Nothing wrong with that. However, there are a few places where the idea is raised of subsidizing “independent” media, presumably with Government funds. While a viable media is important, this creates an obvious conflict of interest.

There are also several mentions of online media being used in ways to help advance the U.N. Sustainable Development Agenda, a.k.a. Agenda 2030. It’s unclear what would happen if online platforms were used in ways to undermine its implementation.

There are repeated calls to use digital platforms to respect and protect human rights. This is fine in principle, but it’s undefined, and presumably arbitrary, what those rights are.

Paragraph 38 talks about the need for there to be an ongoing relationship with digital platforms and “credible” news sources. Of course, the term credible is left undefined. It’s also unclear what, if any, voices that media who aren’t considered credible would have.

Paragraph 45 gets into the topic of “compliance mechanisms”. It’s rather chilling, as it mentions the possibility of regulators making final decisions with respect to the rules on platforms.

Paragraph 49 addresses the idea of having checks and balances. This sounds fine, until one asks what structures would have to be put in place to begin with.

Paragraph 52 covers “investing” in so-called independent media, in order to make it more sustainable. If the only way that independents can survive is by getting bailout money, then that would convert them into Government employees. No need to ban critics when they can simply be bought off.

Paragraph 54 talks about having: (a) national; (b) regional; and (c) global governance systems put in place, to safeguard freedom of expression, access to information, and other human rights. There’s also a brief mention about limiting expression to protect human rights.

Perhaps the most interesting sections are paragraphs 68-73, which outline how an “independent regulator” would work. Of course, how independent can it be when it reports to the very people it’s supposed to keep an eye on.

68. In statutory regulation, official regulatory authorities, though constituting part of the executive state apparatus, should be wholly independent of the government and be primarily accountable to legislatures for fulfilment of their mandates. This applies to existing regulatory bodies that have a legitimate interest in content on platforms (such as electoral management bodies, advertising authorities, child protection entities, data and privacy commissions, competition bodies, etc.), as well as any new dedicated or coordinating regulatory instances that may be established.

69. With regard to all statutory bodies engaging in platform regulation, either solely or jointly, periodic review should be performed by an independent body reporting directly to the legislature. Statutory interventions should also be subject to review in the courts if authorities are believed to have exceeded their powers, acted unreasonably, or acted in a biased or disproportionate manner.

70. Official regulatory authorities need to be independent and free from economic, political, or other pressures. Their power and mandate should be set out in law. They should also comply with international human rights and promote gender equality standards.

71. Official regulatory institutions must have sufficient funding and expertise to carry out their responsibilities effectively. The sources of funding must also be clear, transparent, and accessible to all, and not subject to the governmental discretion.

72. Governing officials or members of the official regulatory institutions working on the issue of content on platforms should:
a. Be appointed through a participatory, transparent, non-discriminatory, and independent merit-based process.
b. Be accountable to an independent body (which could be the legislature, judiciary, an external council, or an independent board/boards).
c. Include relevant expertise in international human rights law and the digital ecosystem.
d. Deliver an annual public report to an independent body—ideally the legislature—and be held accountable to it, including by informing the body about their reasoned opinion.
e. Make public any possible conflicts of interest and declare any gifts or incentives.
f. After completing the mandate, for a reasonable period, not be hired or provide paid services to those who have been subject to their regulation, in order to avoid the risk known as “revolving doors”.

73. The official regulatory authorities should be able to request that digital platforms provide periodic reports on the application of their terms of services, and take enforcement action against digital platforms deemed non-compliant with their own policies or failing to fulfil their responsibilities to safeguard freedom of expression and access to information and diverse cultural content. They should be able to establish a complaints process and issue public recommendations that may be binding or non-binding and be empowered to issue transparent and appropriate directives to the platforms for the promotion and respect of human rights, based on international human rights standards

In fairness, there are portions that are noble, such as 72(e) and (f) which aim to limit conflicts of interest in the forms of gifts or lobbying. Lest this be viewed as a hatchet job, there are portions of the paper that are quite good.

Paragraph 115, and its many subparagraphs, detail how due process information and human rights data should be integrated at all stages of moderation. On the surface, there’s nothing wrong with this, but who will be setting the standards?

Paragraphs 116 to 118 offer suggestions for collecting user demographic data for research purposes. While it’s supposed to be anonymized, there’s not enough specifics included as to it use.

Paragraph 143 gives brief guidelines about how platforms should conduct themselves during emergencies and armed conflicts. It suggests . Developing cooperation with trusted partners, independent media organizations, and other reliable flaggers.

These are just some of the issues that are raised. This UNESCO paper seems so harmless on the surface, but it’s really vague at times when clarity is needed.

Note: While UNESCO claims to want to prevent misinformation from spreading, it has hardly been neutral or objective. Only recently, it was telling people to only trust official sources for information on the “pandemic”.

(1) https://www.unesco.org/en/articles/online-disinformation-unesco-unveils-action-plan-regulate-social-media-platforms
(2) https://unesdoc.unesco.org/ark:/48223/pf0000387339
(3) UNESCO Guidelines To Govern Digital Platforms
(4) https://www.youtube.com/@UNESCO
(5) https://www.youtube.com/watch?v=90cIg4lv-3M

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A Little Discernment Can Go A Long Way….

Above is a photo from the International Federation of Library Associations and Institutions. This exact image is available at my local library, and probably many others across Canada as well. It’s meant as a rough guide for filtering out information.

While it presumably is targeted at books, the same guidelines are valid for podcasts, articles, videos and other content. And there are worthwhile things to ask.

  • Are there any supporting sources to make the claims?
  • Is the title “clickbait”, or does it accurately represent the content
  • Is it satire? If the claims made are overly dramatic, the author may be trying to create humourous work.
  • Who wrote it, and why? Are there any obvious conflicts of interest?
  • Who can a person check with to verify the information?
  • Will biases be an issue in judging it objectively
  • Is the information current or outdated?

No one needs to point out how badly “ask the experts” has gone lately. Nonetheless, it can be a starting point for getting information on a topic.

Note: This isn’t meant at a specific person or group. Rather, it’s a pattern that has become a lot more noticeable over the last few years.

While many people have become proficient at spotting Government deception and propaganda, they either overlook or ignore it in the alternative media spheres. Of course, the reverse is also true for the normies. And examples?

(1) Some who dismissed Government fear mongering around this so-called “pandemic” will not look carefully into topics such as microchipping vaccines, DNA modification, gain of function, lab leaks, or bioweapons. Any dramatic claims deserve skepticism, regardless of the source.

(2) On a related note: there have been some who (rightly) question whether CV tests are accurate based on current methods. However, they will just take for granted that other viruses can be tested for using that same technology. We want authors who are logically consistent.

(3) Some of the larger political alternative voices will do a great job researching candidates and parties they don’t like, while making excuses for those they support. If they have a dog in the fight, then they can never be fully trusted.

(4) In a world where views and advertising dollars matter, catching attention is important. However, that’s not always the best option if the content doesn’t warrant sensationalism.

(5) While Government plants within the media are often easy to spot, “alternative” voices come out of nowhere and instantly gain huge followings. Such individuals do so despite addressing topics that are normally censored, or while not offering anything insightful. Similarly, if the content frequently borders on, or engages in outright Fed-posting, be wary.

(6) Lack of curiosity should always be viewed as a red flag. If a piece touches on really important issues, but only at a surface level — with no follow up — one should ask why. Rabbit holes are a fun, albeit exhausting, way to shake strongly held views.

These are just a few things that have come up in the alt-media landscape, and not just the Canadian scene. All media should be scrutinized, regardless of whether it has the slant and leanings that are preferred.

A question that comes up is who should the public be following. The answer is no one. Ideally, the best populace is one that’s full of inquisitive and resourceful people. Yes, research is time consuming, but there’s no shortcut to becoming educated. The alternative is to sit back and hopefully trust the right outlet. That seems to be a poor plan.

True, there’s no way to not view published media at all, but just realize that there will be gaps in what’s presented. If nothing else, different perspectives can at least draw attention to flaws and errors.

A little discernment can go a long way….

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Court Asked To Throw Out Vaccine Choice Canada Suit As “Bad Beyond Argument”

A high profile Toronto lawsuit filed July 6, 2020 will finally be heard in Court.

To clarify, this will not be a Trial, or anything of the sort. Instead the Court will hear Motions to throw the case out as frivolous, vexatious, an abuse of process, moot (no longer relevant) and “bad beyond argument”. The Factums state that the Statement of Claim — the initial filing — is incoherent, unintelligible, lacks required facts and particulars, and fails to meet even the basics of Civil Procedure.

And they’re not wrong.

See these critiques from 2021 and 2022. These upcoming Motions parallel those predictions a lot.

It doesn’t help that this case remained inactive from July 2020 until January 2023. That’s 2 1/2 years. Makes it hard to view this as urgent.

On a side note: as of the time of publication, there appear to only be 2 Factums on file, despite there being 5 Motions to Strike. Perhaps there has been a delay in filing from other lawyers.

Also, it needs to be pointed out that this group has 2 (two) separate lawsuits. Both were written by “Mr. Bad Beyond Argument” himself, and both are a complete waste of time and money.

1. Vaccine Choice Canada’s 2019 Lawsuit Dormant

Back in October 2019, VCC filed a lawsuit against the Ontario Government challenging requirements to give injections to students. A response was filed, and the case garnered some attention.

But what these people don’t tell you is that the case has been idle for 4 years now. It hasn’t had a single Court appearance since then. There have been no hearings, evidence filed, or obvious attempts to move the case forward.

Ontario Court cases are typically dismissed for delay if they haven’t reached Trial within 5 years, if there isn’t a reasonable explanation. That will happen in October 2024, just 11 months from now.

2. Vaccine Choice Canada’s 2020 Lawsuit To Get Thrown Out

Here’s the Mercer Factum. However, the Ahmed/WEC Factum is even juicier with the following. It comes across as a lot more blunt in regards to these circumstances. When others are filed, they’ll be made available too.

(26) It has been outlined in the jurisprudence that it is fundamental to the trial process that a plaintiff plead material facts in sufficient detail to support the claim and relief sought. Opposing parties cannot be left to speculate as to how the facts support the causes of action pled. Rather, the pleading must tell the defendant who, when, where, how and what gave rise to its liability.

(28) In Adelberg v. Canada, a Statement of Claim was filed by some 600 plaintiffs who alleged they suffered harm because of a COVID-19 vaccination policy issued by the Treasury Board of Canada. The claim was almost 50 pages long, with nine pages devoted to remedies sought, some of which were not available in a civil action, including administrative declarations and injunctive relief. The claim included allegations of constitutional invalidity, criminal culpability and broad assertions of scientific knowledge. The pleading did not particularize the facts and was devoid of material facts pertaining to the personal circumstances of the plaintiffs. The Court found the pleading to be “bad beyond argument” and it was struck in its entirety. It is worthy to note that counsel for the plaintiffs in Adelberg is the same plaintiff counsel as in this matter before this Court.

(29) Similarly, the Court in Action4Canada v. British Columbia (Attorney General), struck the plaintiffs’ pleading in which they sought damages and other relief from various government entities and employees for harms they allegedly suffered as a result of various restrictions instituted in British Columbia due to the COVID-19 pandemic. The Court held that the pleading could not be properly answered by a responsive pleading as it described wide-ranging global conspiracies and sought rulings of the court on issues of science. The pleading was also labelled as “bad beyond argument” and could not be mended by striking portions of it. The plaintiffs counsel in Action4Canada was one in the same as the Plaintiffs’ counsel in this case and in Adelberg.

(32) Much like in the cases of Adelberg and Action4Canada, the pleading in this matter is “bad beyond argument”. It is 190 pages long, violates the rules of pleadings, improperly names defendants, is replete with lengthy diatribes and makes allegations of cover-ups and conspiracies. It leaves many of the Defendants speculating as to how the facts support the causes of action pled. The pleading is, simply put, unintelligible and lacking in clarity, and should be struck. It cannot be mended by striking portions as it would only create more confusion and result in greater expenditure by the parties and this Court.

(37) In the alternative, this Court should strike or dismiss the Plaintiffs’ pleading in its entirety on the grounds that the pleading is scandalous, frivolous, vexatious and otherwise an abuse of process as it contains many hallmarks of litigant behaviour as identified in the jurisprudence. As already indicated, the pleading is 190 pages in length, misnames defendants, contains 235 footers, includes rambling discourse, repeated misuse of legal, medical and other technical terms and makes discerning a legitimate cause of action very difficult. The pleading is unintelligible and is indicative of litigant behaviour resulting in five separate motions to strike before this Court.

(38) The courts have recognized that scarce resources should not be devoted to proceedings that are clearly frivolous and vexatious. They take away from meritorious cases and there is no benefit served in allowing them to continue. Scarce resources have already been devoted to this matter by the numerous counsel and parties involved as well as three days of valuable court time. The Plaintiffs’ pleading should be struck in its entirety with no leave to amend. The pleading cannot be partially struck or mended to fix the multiplicity of signposts of a vexatious proceeding. Any attempt to do so would only result in the consumption of more time and limited resources and result in further confusion. It is “bad beyond argument”.

Action4Canada struck as “bad beyond argument” at Paragraph 45:
https://www.canlii.org/en/bc/bcsc/doc/2022/2022bcsc1507/2022bcsc1507.html#par45

Adeberg struck as “bad beyond argument” at Paragraph 52:
https://www.canlii.org/en/ca/fct/doc/2023/2023fc252/2023fc252.html#par52

Earlier this year, the B.C. Law Society roasted the Action4Canada case, including it their training manual for new lawyers as an example of a “Wholly Inadequate Pleading”.

Where’s the lie here? Despite all of the things that various Governments have done to its citizens in recent years, these pleadings are so incomprehensible that they’ll never make it to Trial. Litigants with valid concerns will never get their day in Court. These cases aren’t thrown out on their merits, but because they’re so poorly written. At some point, one has to wonder it this was done intentionally.

Despite the Claim being nearly 200 pages long, it fails to plead details that would have established liability of the Defendants. Yes, this needs to be spelled out. Instead, the bulk of the document is almost entirely irrelevant to a CIVIL Court in Ontario.

Moreover, Klaus Schwab, the World Economic Forum, Bill Gates, GAVI, the Rockefeller Foundation, and others aren’t listed as Defendants, so the information about them is irrelevant.

The Rules of Civil Procedure for Ontario, particularly Rule 25.06, lay out the basics for how pleadings should be drafted. These aren’t optional. Cases that don’t follow them will get struck down. Hard to imagine how veteran lawyers don’t know this.

Part of the problem with suing so-called “Medical Officers of Health” is that they have immunity from civil and criminal liability unless bad faith can be established. The Statement of Claim doesn’t plead any facts that would allow that to be bypassed.

By letting so much time elapse, the Defendants can now introduce “mootness” as an escape. One has to wonder why the suit was never diligently pursued, and why it was just allowed to sit.

Vaccine Choice seems content to simply file high-profile cases with no concern as to whether they’ll ever advance in the Courts. Kuntz himself has stated that their are other ways to get results other than from what a Judge has to say. This is improper, and a clear abuse of the Court system.

The Respondent (Plaintiff) Factum is due December 8th. Most likely, it will be a rehash of earlier ones, begging and pleading for a chance to rewrite. It will say that “it’s not plain and obvious” the case has no merit. And after it is struck, expect a trip to the Court of Appeals, and requests for more donations.

And please do remember to donate!

Remember, by checking this link, anyone can SEARCH ONLINE FOR FREE to see what’s happening with various cases. Don’t accept the word of anyone here, but check it out for yourselves. Call the Court, or visit in person if that’s a feasible option.

Ontario Superior Court, Civil Branch
330 University – Toronto
330 University Ave.
Toronto ON M5G 1R7

Court file# CV-20-00643451-0000

Civil – Superior Court of Justice
tel. 416-327-5440 (front desk)

VACCINE CHOICE CANADA DOCUMENTS (2019 CLAIM):
(1) VCC – Statement Of Claim, October 2019 Lawsuit
(2) VCC – Statement Of Defence, October 2019 Lawsuit
(3) VCC – October 2019 Press Release

VACCINE CHOICE CANADA DOCUMENTS (2020 CLAIM):
(1) VCC – Statement Of Claim Unredacted
(2) VCC – Discontinuance Against CBC
(3) VCC – Discontinuance Against CBC With Cover Letter
(4) VCC – Mercer Statement Of Defense
(5) VCC – Mercer Affidavit Of Service
(6) VCC – Requisition For CPC Motion To Strike
(7) VCC – Notice Of Motion To Strike
(8) VCC – Factum WEC Wajid Ahmed
(9) VCC – Factum Nicola Mercer
(10) VCC – Factum Federal Defendants

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From 2009: WHO Guidance On IHR Implementation In National Legislation

Over the last few years, it’s been covered here how the WHO’s International Health Regulations (or IHR), have been implemented domestically via the Quarantine Act and Public Health Acts. It’s also been argued that the Public Health Agency of Canada (or PHAC), is effectively a local outpost of WHO.

To further bolster those claims, here’s a 2009 document from WHO, giving Member States advice on how to implement the 2005 version of those International Health Regulations. Interestingly, there seems to be little to no interest in any sort of democratic consultation.

See both the original posting, and the marked version.

[Page 2]
The International Health Regulations (2005) – Toolkit for implementation in national legislation: The National IHR Focal Point was developed by the Secretariat of the World Health Organization (WHO) in response to requests for guidance on legislative implementation of the requirements concerning the designation or establishment and functioning of the National IHR Focal Point (NFP) under the International Health Regulations (2005) (“IHR (2005)” or “Regulations”). This toolkit complements other related legal guidance on the role and assessment of national legislation for IHR (2005) implementation, including the legislative reference and assessment tool and compilation of examples of legislation. The International Health Regulations (2005): Areas of work for implementation and other guidance developed by the WHO Secretariat assist States Parties with the IHR (2005) implementation process.

[Page 7]
1.2. What is a National IHR Focal Point (NFP)?
The designation or establishment of an NFP and its proper functioning are among the key obligations of each State Party under the IHR (2005). An effectively functioning NFP network is essential to the successful implementation of the Regulations.
The NFP is a national centre, established or designated by each State Party. The NFP must be accessible at all times (7 days a week, 24 hours a day and 365 days a year) for IHR (2005)-related communications with WHO IHR Contact Points. WHO has identified such a Contact Point at each of its six regional offices, available at all times for IHR communications. To date, 193 States Parties have designated an NFP.

[Page 10]
1.3 Why are national legislation, regulations and other instruments relevant for NFP designation or establishment and functioning?
.
The IHR (2005) are legally binding on virtually all (i.e. 194) States worldwide, and impact governmental functions and responsibilities across many ministries, sectors and governmental levels. The Regulations also involve very specific operational functions, such as those of the NFP. While the IHR (2005) mandate that the NFP be designated or established, and that it function properly, how these requirements are to be implemented is up to each State Party in light of its own legislation, governmental structures and policies. The effective implementation of these obligations, however, requires that an adequate legal framework is in place.
.
In some States, giving effect to the IHR (2005) within domestic jurisdiction and national law generally requires that the relevant authorities adopt implementing legislation. However, even where new or revised legislation, regulations or other instruments may not be explicitly required under the State Party’s legal system, they may still be considered by the country in order to facilitate performance of IHR activities in a more efficient, effective or otherwise beneficial manner — including those relating to the NFP.

The World Health Organization provides specific wording templates to use in upcoming legislation. In other words, these guidelines are being provided, and all that’s needed is to fill in the blanks.

[Page 16]
A. Minimum mandatory NFP functions
The following functions printed in bold are derived directly from the IHR (2005) and can be considered mandatory components of terms of reference for NFPs:
1) Remaining accessible at all times for communications with WHO IHR Contact Points (via e-mail, telephone and/or fax): In order to ensure coverage of the post around the clock, it is envisioned that NFPs will be offices rather than individuals, including potentially a designated government position supported by a functional structure. It is critical that the NFP be available at all times, and it will not be possible for a single individual to carry out this function. Functional and reliable telephone, e-mail and fax lines are essential. The NFP should be contactable by direct telephone or fax and via a generic institutional email address, preferably one indicating its affiliation with the IHR.

[Page 16]
2) On behalf of the State Party concerned, sending to WHO IHR Contact Points urgent communications arising from IHR (2005) implementation, in particular under Articles 6-12 of IHR (2005): In summary, Articles 6-12 cover the following communications:
(i) Notification (Article 6): Notifying WHO of all events which may constitute a public health emergency of international concern within a State Party’s territory in accordance with the Annex 2;
(ii) Information-sharing during unexpected or unusual public health events (Article 7): Providing all relevant public health information if there is evidence of an unexpected or unusual public health event within a State Party’s territory which may constitute a public health emergency of international concern;
(iii) Consultation (Article 8): If the State Party so chooses, keeping WHO advised on events occurring within a State Party’s territory which do not require notification, and consulting with WHO on appropriate health measures;

and so on….

The document also uses legislation from countries around the world to give as examples for how to implement. But don’t worry, it’s not a global conspiracy or anything.

And a serious question to ask: did anyone ever vote for this? Was this on any official Federal or Provincial platform? Was there a public referendum to examine if the citizens wanted this?

(1) https://cdn.who.int/media/docs/default-source/documents/emergencies/ihr-toolkit-for-implementation-in-national-legislation3cceba0c-4580-48a4-9d4e-2b17a2146b66.pdf?sfvrsn=60aea14d_1&download=true
(2) IHR Toolkit For Implementation In National Legislation
(3) Wayback Machine Archive

LINKS TO ARTICLES WITH BACKGROUND INFORMATION

WHO Constitution in 1946: Canada signs on to the WHO Constitution, a provision within states that adopting this document is a requirement to being a member. This was nearly 100 years ago that this was adopted.

https://canucklaw.ca/world-health-organization-constitution-have-you-actually-read-it/

Int’l Pandemic Treaty a red herring: Why the high profile “amendments” to the International Health Regulations are largely irrelevant. The short answer is that countries are already bound to their dictates. Yes, this just makes it more of a formality

https://canucklaw.ca/who-constitution-why-the-global-pandemic-treaty-is-largely-irrelevant/

IHR are legally binding: The International Health Regulations aren’t just “recommendations” as many might think. Member-states are legally required to implement these rules, although it’s unclear how disobedience might be punished in practice.

https://canucklaw.ca/who-legally-binding-international-health-regulations-ihr/

2005 Quarantine Act is 3rd Ed WHO-IHR: Bill C-12 was introduced in the House of Commons in late 2004. Supposedly”, this was in response to SARS a few years earlier. While the explanations sounded benevolent, the reality is that it laid the path for a lot of the martial law measures that happened 2020-2023. It was also explicitly admitted during the hearings that the QA was designed in anticipation of new changes to WHO-IHR. (The 3rd Edition IHR eventually came out in 2005)

https://canucklaw.ca/the-2005-quarantine-act-bill-c-12-was-actually-written-by-who/

PHAC created at instigation of WHO: The Public Health Agency of Canada was created out of nothing in June 2004, at the instigation of the WHO. The 133rd Session took place in January 2004, and required member-states to “develop a focal point” to respond to future health crises. That turned out to be PHAC. Several Orders-In-Council later, and it was embedded with other legislation. Once Harper took power in early 2006, he introduced the “PHAC Act, to give the new agency its own powers.

https://canucklaw.ca/public-health-agency-of-canada-created-as-branch-of-who/

Health Canada pop’n control: PHAC isn’t the only problem that we’ve have to deal with. Health Canada (formerly the Department of Health) was created by Bill 37 back in 1919. The supposed reason was public health after WWI. HC has undergone transformations over the years, and a lot of its old functions are now covered by PHAC.

https://canucklaw.ca/health-canada-initially-created-for-population-control-measures/

Provincial Health Acts are QA derivatives: a quick look through shows that they are written almost identically. They were all put in around 2007-2010, following the passage of the 2005 Quarantine Act. Political parties aside, they serve the same masters.

1st article: BC, AB, SK, MB, ON
2nd article: QC, NS, NB, PEI, NFLD
https://canucklaw.ca/provincial-health-acts-are-really-just-who-ihr-domestically-implemented/
https://canucklaw.ca/the-other-provincial-health-acts-written-by-who-ihr/

This was slipped into a Budget Bill, Bill C-97, back in 2019. It removes the requirement for parliamentary consultations when invoking Quarantine Act, of Human Pathogens and Toxins Act. Considering the timing, it’s hard to argue this wasn’t pre-planned.

https://canucklaw.ca/oversight-for-human-pathogens-and-toxins

This hasn’t been updated in a long time, but the WHO-IHR statements are essentially guidelines for national and regional politicians to follow

https://canucklaw.ca/canadas-actions-were-dictated-by-whos-legally-binding-ihr

The WHO-IHR are far from the only agreements that attack our freedom. Another is the Sendai Framework, which serves to trip away many of the same rights: mobility, association, earning a livelihood, etc…. These same measures can be present in different forms.

https://canucklaw.ca/2-sides-of-the-same-coin-sendai/

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2 Sides Of The Same Coin: Sendai Framework And International Health Regulations

This topic isn’t revolutionary. However, it’s interesting how different pieces of legislation (supposedly brought for completely different areas of life) can serve much the same purpose. Laws that seemingly have no connection to each other can end up having very similar results.

Let’s look at a few of them.

For emergency and disaster management:
-U.N. Sustainable Development Agenda (Agenda 21) signed in 1992
–Yokohama Strategy for a Safer World signed in 1994
–Hyogo Framework for Action signed, goes from 2005 to 2015
-U.N. Sustainable Development Agenda (Agenda 2030) signed in 2015
–Sendai Framework signed, goes from 2015 to 2030.

For public health management:
–W.H.O. Constitution signed in 1946
-W.H.O. International Sanitary Regulations signed in 1951
-W.H.O. International Health Regulations (First Edition) signed in 1969
-W.H.O. International Health Regulations (Second Edition) signed in 1995
–W.H.O. International Health Regulations (Third Edition) signed in 2005

Now, what can these things have in common? Quite simply, they are pretexts for removing rights and property from people, under the cloak of being an emergency. True, the nature of it will vary, but the results are the same.

1. Parallels Between Sendai Framework And WHO-IHR

While not identical, there are many connections and similarities between enacting emergency management laws, and the public health laws. Using B.C. as an example:

(a) Bill 31 was derived from the Sendai Framework, which itself is part of the United Nations Sustainable Development Agenda. There are many aspects to this ideology

(b) The Provincial Public Health Acts are the result of the 2005 Quarantine Act, which itself is derived from the 3rd Edition of the WHO’s International Health Regulations. Also, the WHO’s Constitution is well worth a read, as it dates back to the 1940s.

While laws are being enacted that greatly impact the lives of Canadians, the reality is that these — and many laws — are derived from international agreements that the public has no say in.

(a) Bill 31 is framed as “disaster reduction measures”, which presumably means natural disasters. As for speculation about “climate lockdowns”, this type of legislation is laying the ground work.

(b) Provincial Health Acts are framed as “preventing communicable diseases”, and we saw plenty of that in the last few years.

And reading through both, it’s clear that both are intended — among other things — to strip away large parts of individual rights, including property rights. These things are presented as necessary for the greater good.

Additionally, both sets of laws allows near dictatorial powers when it comes to issuing orders. A Cabinet Minister could do it for the Emergency & Disaster Management Act. A Minister, or Public Health Officer, can give orders concerning regulations within the Public Health Act

2. B.C. Bill 31, Emergency & Disaster Management Act

This is still going through the Legislature, but parts of it are certainly worth looking at. They’re ripe for abuse in the wrong hands.

Essential matters
75 (1) The minister may, by order, do one or more of the following:
(a) identify supplies, equipment or other items, services, property or facilities, or a class of any of these, as essential;
(b) for things identified under paragraph (a) as essential,
(i) establish or restrain increases in prices or rents for them,
(ii) ration or otherwise provide for their distribution or use,
(iii) provide for their restoration, and
(iv) prohibit or limit seizures of them or evictions from them;
(c) authorize a person to provide a service or give assistance of a type that the person is qualified to provide or give;
(d) require a person to provide a service or give assistance of a type that the person is qualified to provide or give;
(e) provide for, maintain and coordinate the provision and maintenance of necessities.
(2) Subsection (1) (b) (i) and (iv) applies despite any enactment governing tenancies or the recovery of property.
(3) Subsection (1) (c) and (d) applies despite any contract, including a collective agreement.

Land and other property
76 (1) The minister may, by order, do one or more of the following:
(a) appropriate, use or control the use of any personal property;
(b) use or control the use of any land;
(c) authorize the entry without warrant into any structure or onto any land by any person for the purpose of taking emergency measures;
(d) prohibit the entry into any structure or onto any land by any person;
(e) authorize or require the alteration, removal or demolition of any trees, crops, structures or landscapes;
(f) authorize or require the construction, alteration, removal or demolition of works;
(g) require the owner of a structure to
(i) have any damage to the structure assessed, and
(ii) give the results of the assessment to the minister or a person in a class of persons specified by the minister.
(2) The power under subsection (1) (b) to use or control the use of land does not apply to specified land.

General restrictions
78 (1) The minister may, by order, control or prohibit one or more of the following:
(a) travel to or from any area;
(b) the carrying on of a business or a type of business;
(c) an event or a type of event.
(2) The minister may, by order, do one or more of the following:
(a) require a person to stop doing an activity, including an activity that a person is licensed, permitted or otherwise authorized to do under an enactment;
(b) put limits or conditions on doing an activity, including limits or conditions that have the effect of modifying a licence, permit or other authorization issued under an enactment.

Clearly, the Bill is much longer than this. But what do these sections include?

  • Establish price controls of “essential goods”
  • Establish rationing of “essential goods”
  • Require (force) people to provide certain services
  • Appropriate or control someone’s private land
  • Allow warrantless searches
  • Prohibit people from entering their property
  • Prevent travel
  • Prohibit certain types of businesses
  • Prohibit or restrict activities

Sound familiar? It should. These things were implemented throughout British Columbia through 2020 to 2022, but under the pretense of “disease prevention”. All that’s missing are the injection passports and the mask mandates.

3. B.C. Public Health Act (2009), Derivative Of WHO-IHR

People will no doubt remember the years of endless (and seemingly arbitrary) dictates from BCPHO Bonnie Henry, and Health Minister Adrian Dix. But what allowed them to do this?

General powers respecting health hazards and contraventions
31 (1)If the circumstances described in section 30 [when orders respecting health hazards and contraventions may be made] apply, a health officer may order a person to do anything that the health officer reasonably believes is necessary for any of the following purposes:
(a) to determine whether a health hazard exists;
(b) to prevent or stop a health hazard, or mitigate the harm or prevent further harm from a health hazard;
(c) to bring the person into compliance with the Act or a regulation made under it;
(d) to bring the person into compliance with a term or condition of a licence or permit held by that person under this Act.
(2) A health officer may issue an order under subsection (1) to any of the following persons:
(a) a person whose action or omission
(i) is causing or has caused a health hazard, or
(ii) is not in compliance with the Act or a regulation made under it, or a term or condition of the person’s licence or permit;
(b) a person who has custody or control of a thing, or control of a condition, that
(i) is a health hazard or is causing or has caused a health hazard, or
(ii) is not in compliance with the Act or a regulation made under it, or a term or condition of the person’s licence or permit;
(c) the owner or occupier of a place where
(i) a health hazard is located, or
(ii) an activity is occurring that is not in compliance with the Act or a regulation made under it, or a term or condition of the licence or permit of the person doing the activity.

Specific powers respecting health hazards and contraventions
32(1) An order may be made under this section only
(a) if the circumstances described in section 30 [when orders respecting health hazards and contraventions may be made] apply, and
(b) for the purposes set out in section 31 (1) [general powers respecting health hazards and contraventions].

32(2) Without limiting section 31, a health officer may order a person to do one or more of the following:
(a) have a thing examined, disinfected, decontaminated, altered or destroyed, including
(i) by a specified person, or under the supervision or instructions of a specified person,
(ii) moving the thing to a specified place, and
(iii) taking samples of the thing, or permitting samples of the thing to be taken;
(b) in respect of a place,
(i) leave the place,
(ii) not enter the place,
(iii) do specific work, including removing or altering things found in the place, and altering or locking the place to restrict or prevent entry to the place,
(iv) neither deal with a thing in or on the place nor dispose of a thing from the place, or deal with or dispose of the thing only in accordance with a specified procedure, and
(v) if the person has control of the place, assist in evacuating the place or examining persons found in the place, or taking preventive measures in respect of the place or persons found in the place;
(c) stop operating, or not operate, a thing;
(d) keep a thing in a specified place or in accordance with a specified procedure;
(e) prevent persons from accessing a thing;
(f) not dispose of, alter or destroy a thing, or dispose of, alter or destroy a thing only in accordance with a specified procedure;
(g) provide to the health officer or a specified person information, records, samples or other matters relevant to a thing’s possible infection with an infectious agent or contamination with a hazardous agent, including information respecting persons who may have been exposed to an infectious agent or hazardous agent by the thing;
(h) wear a type of clothing or personal protective equipment, or change, remove or alter clothing or personal protective equipment, to protect the health and safety of persons;
(i) use a type of equipment or implement a process, or remove equipment or alter equipment or processes, to protect the health and safety of persons;
(j) provide evidence of complying with the order, including
(i) getting a certificate of compliance from a medical practitioner, nurse practitioner or specified person, and
(ii) providing to a health officer any relevant record;
(k) take a prescribed action.
(3) If a health officer orders a thing to be destroyed, the health officer must give the person having custody or control of the thing reasonable time to request reconsideration and review of the order under sections 43 and 44 unless
(a) the person consents in writing to the destruction of the thing, or
(b) Part 5 [Emergency Powers] applies.

While not identical, the B.C. Public Health Act provides many of the same restrictions that Bill 31 would (if enacted). Primarily, property and personal rights can be suspended in an open ended manner, under the excuse of an emergency.

It’s also worth mentioning the the “Public Officials” involved in issuing orders are exempt from legal liability, and cannot be sued. It’s written right into the legislation.

SENDAI FRAMEWORK, B.C. BILL 31
(1) https://www.leg.bc.ca/parliamentary-business/legislation-debates-proceedings/42nd-parliament/4th-session/bills/bills-with-hansard-debate
(2) https://www.leg.bc.ca/documents-data/debate-transcripts/42nd-parliament/4th-session/20231003am-Hansard-n331#bill31-1R
(3) https://www.preventionweb.net/publication/sendai-framework-disaster-risk-reduction-2015-2030
(4) https://www.preventionweb.net/files/43291_sendaiframeworkfordrren.pdf
(5) https://www.preventionweb.net/files/44983_sendaiframeworkchart.pdf
(6) Sendai Framework 2015 Full Text English
(7) https://en.wikipedia.org/wiki/World_Conference_on_Disaster_Risk_Reduction
(8) https://www.unisdr.org/files/8241_doc6841contenido1.pdf
(9) https://www.unisdr.org/2005/wcdr/intergover/official-doc/L-docs/Hyogo-framework-for-action-english.pdf

WHO TREATIES, INTERNATIONAL HEALTH REGULATIONS
(1) https://canucklaw.ca/wp-content/uploads/WHO-Constitution-Full-Document.pdf
(2) https://www.who.int/about/governance/constitution
(3) https://apps.who.int/gb/bd/
(4) https://apps.who.int/gb/bd/pdf_files/BD_49th-en.pdf#page=6
(5) https://www.treaty-accord.gc.ca/
(6) https://www.treaty-accord.gc.ca/index.aspx
(7) https://www.treaty-accord.gc.ca/details.aspx?lang=eng&id=103984&t=637793587893732877
(8) https://www.treaty-accord.gc.ca/details.aspx?lang=eng&id=103986&t=637862410289812632
(9) https://www.treaty-accord.gc.ca/details.aspx?lang=eng&id=103990&t=637793587893576566
(10) https://www.treaty-accord.gc.ca/details.aspx?lang=eng&id=103994&t=637862410289656362
(11) https://www.treaty-accord.gc.ca/details.aspx?lang=eng&id=103997&t=637793622744842730
(12) https://www.treaty-accord.gc.ca/details.aspx?lang=eng&id=105025&t=637793622744842730
(13) https://canucklaw.ca/provincial-health-acts-are-really-just-who-ihr-domestically-implemented/
(14) https://canucklaw.ca/the-other-provincial-health-acts-written-by-who-ihr/
(15) WHO International Health Regulations, 3rd Edition 2005