Discontinued: Leighton Grey Abandons Calgary Firefighters Injection Pass Case In 2023

This article is to follow up on a 2022 case that no one ever heard about again. Specifically, it involved the Calgary Fire Department being sued for their new requirement to take the clot-shots. Many covered the announcement at the time, but nothing ever came of it.

Turns out that the lawsuit was discontinued, see here and here, less than a year after it was filed. The primary reason appears to be pushback from Calgary itself. The Calgary Firefighters Association, Local 255, has a collective bargaining agreement with the City and employees.

It’s also (yet another) cautionary tale about the problems litigants can have when they sue too many parties. Here, there could have been a decent case against the Alberta Government. Instead, the lawyer decides to name the employer as well, causing new headaches.

Additionally, the pleading had other serious defects.

The genius behind this was Leighton Grey, K.C., or King’s Counsel.

Firefighters’ Collective Agreement Mandates Arbitration

24.01
(a) If any difference concerning the interpretation, application, operation or any alleged violation of this Agreement or any question as to whether any difference is arbitral arises between the parties or persons bound by the Collective Agreement, such parties or persons shall endeavour to resolve the difference utilizing informal dispute resolution meetings. Should the parties fail to resolve the difference either party may proceed through the grievance process as set out below.

Step Two
If a satisfactory settlement is not achieved at Step One the Association within fifteen (15) days of the decision rendered by the Deputy Fire Chief or designate may submit the grievance to the Fire Chief. The Fire Chief or designate shall hear the grievance within fifteen (15) days of receiving it and shall render a decision within fifteen (15) days from the date the grievance was heard. If a satisfactory settlement is not achieved the grievance may be advanced within thirty (30) days to arbitration as provided under 24.01(c). If a grievance is not advanced to arbitration within thirty (30) days of the decision in Step Two, the grievance shall be deemed abandoned.

(e) The grievance arbitration board shall hear and determine the difference and shall issue an award in writing and the decision is final and binding upon the parties and upon any Member affected by it. The decision of a majority is the award of the grievance arbitration board, but if there is no majority the decision of the Chair governs and it shall be deemed to be the award of the board;

Article 24 of that agreement spells out the grievance process. It reads:
(a) Bring grievance to Deputy Fire Chief.
(b) If no resolution, proceed to file with Fire Chief.
(c) Proceed to arbitration, if needed.

It’s also specified that if there’s no satisfactory conclusion reached with the Chief, then there’s a 30 day time limit to seek arbitration. It’s also clear that such a hearing is meant to be final.

Now, lawyers have attempted (unsuccessfully) to argue that various agreements never contemplated vaccine passports. While true, this amounts to CONSTRUCTIVE DISMISSAL, where the employer unilaterally changes a term and condition of employment. This sort of thing “is” usually covered.

Of course, had Grey only sued the Government of Alberta, the union agreement wouldn’t have come into play. Think about it, they can’t invoke a contract they’re not a party to. But by suing the Fire Department as well, Grey ensures that lack of jurisdiction will be an issue.

It’s just like an Ontario lawyer, who would be okay suing just the Ford Government. But then, he decides to sues any and all employers as well. Of course, suddenly union contracts create a jurisdiction issue.

City Of Calgary Brings Application To Strike

The City of Calgary Fire Department brought an Application to Strike. Predictably, they invoked the union agreement, which specified arbitration as the only option.

Grey could simply have sued the Alberta Government — who brought in Provincial mandates — and left it at that. After all, they can’t challenge jurisdiction based on a contract they didn’t sign. Suing the Calgary Fire Department was an idiotic move, and allowed this to happen.

Pleading Full Of Other Defects As Well

The Statement of Claim contains poison pills, ensuring that it will be struck. A Civil Court has no jurisdiction to hear criminal allegations at all.

The document also doesn’t plead any facts or particulars about any Plaintiff. The Judge would just be left guessing what the circumstances are for everyone, and which specific arguments they intend to make. This is probably since this lawsuit is largely recycled from other ones.

Timeline Of Leighton Grey’s Injection Passport Cases

See Parts 1, 2, 3, 4, 5, 6, and 7 for more information.

  1. March 16th, 2022: Grey discontinues lawsuit against University of Winnipeg.
  2. April 10th, 2023: Grey discontinues lawsuit against Purolator.
  3. April 12th, 2023: Grey discontinues lawsuit on behalf of Westjest employees.
  4. April 25th, 2023: Grey discontinues lawsuit against City of Calgary
  5. May 25th, 2023: Grey discontinues Proposed Class Action suit against Winnipeg/Manitoba.
  6. June 20th, 2023: Grey discontinues the rest of the case with CNR.
  7. January 31st, 2024: Grey discontinues Pillon lawsuit against Ducks Unlimited Canada.
  8. March 18th, 2024: Grey discontinues (Hildebrand) case with CNR.
  9. November 5th, 2024: Grey brings Motion to withdraw as counsel in Stowe/TransX case.

Then there’s the Canada Post (a.k.a. “Posties”) case to talk about. That wasn’t discontinued, but it was crashed into the ground. In order to challenge an arbitration ruling, Grey should have filed an Application for Judicial Review. Instead, he filed a Statement of Claim, and tried to get around it. Quite predictably, the case was thrown out.

Looking at Grey’s recent work — as a whole — he appears to target clients who are part of unionized workplaces. They inevitably have some sort of collective bargaining agreement, which makes Court action a total non-starter.

Shouldn’t More Be Expected From “King’s Counsel” Lawyers?

On his website, Grey brags about his success and accomplishment in the profession, including being an Adjudicator for Law Society disciplinary hearings from 2015–2020. He also mentions being the youngest to receive the King’s Counsel designation. Alberta describes members as:

Competence, including:

  • sound intellectual ability with a thorough, comprehensive, and current knowledge of law and practice in the applicant’s field
  • distinguished legal service with demanding and challenging legal work that contributes to the development of the law and practice
  • a recognized expertise in a particular area of law and practice (which may include the general practice of law)
  • an outstanding ability as a lawyer in the applicant’s field, to a standard to be expected of King’s Counsel

One has to wonder how and why so many defective cases were filed in recent years over the “vaccine passport” issue. It appears that most involved unionized employers, making them doomed to fail. Shouldn’t more be expected?

Note: To anyone who has read this far, are you aware of any other injection pass/vaccine pass cases brought by Leighton Grey? This site covered 9 that were dropped, and 1 struck, but there may very well be more. If so, please respond with the details.

COURT DOCUMENTS:
(1) Calgary Firefighters List Of Documents
(2) Calgary Firefighters Statement Of Claim (June 2022)
(3) Calgary Firefighters Application To Strike (August 2022)
(4) Calgary Firefighters Amended Statement Of Claim (September 2022)
(5) Calgary Firefighters Discontinuance (December 2022)
(6) Calgary Firefighters Discontinuance (April 2023)

COLLECTIVE BARGAINING AGREEMENT:
https://www.calgaryfirefighters.org/files/docs/IAFF_L255_2021-2023_Collective_Agreement_.pdf

Discontinued: Leighton Grey Drops (At Least) 9 Vaccine Passport Cases

This site has covered many of the terribly crafted cases filed by the “freedom lawyers” in recent years. These challenges to lockdown measures — such as injection mandates — are often comically done. The suits have procedural defects built in, which ensures that they go nowhere.

However, let’s consider another angle. Does it benefit clients, or the public as a whole, when cases are simply discontinued (dropped) long before they’re ever heard?

Worse, there’s typically no media attention when lawsuits are ended like this. Certainly, high profile rulings do get published. But there are no decisions when cases are simply dropped, making it far harder to piece together what’s really going on.

While CanLII is a great tool for searching verdicts, it’s essentially useless at helping to find out when discontinuances are filed. Reporters are left having to manually search, often without complete information.

Today, let’s look at a (somewhat) more low profile lawyer, and at some of his recent work. The results are not encouraging.

Timeline Of Leighton Grey’s Injection Passport Cases

  1. March 16th, 2022: Grey discontinues lawsuit against University of Winnipeg.
  2. April 10th, 2023: Grey discontinues lawsuit against Purolator.
  3. April 12th, 2023: Grey discontinues lawsuit on behalf of Westjest employees.
  4. April 25th, 2023: Grey discontinues lawsuit against City of Calgary
  5. May 25th, 2023: Grey discontinues Proposed Class Action suit against Winnipeg/Manitoba.
  6. June 20th, 2023: Grey discontinues the rest of the case with CNR.
  7. January 31st, 2024: Grey discontinues Pillon lawsuit against Ducks Unlimited Canada.
  8. March 18th, 2024: Grey discontinues (Hildebrand) case with CNR.
  9. November 5th, 2024: Grey brings Motion to withdraw as counsel in Stowe/TransX case.

Then there’s the Canada Post (a.k.a. “Posties”) case to talk about. That wasn’t discontinued, but it was crashed into the ground. In order to challenge an arbitration ruling, Grey should have filed an Application for Judicial Review. Instead, he filed a Statement of Claim, and tried to get around it. Quite predictably, the case was thrown out.

Now, Grey is still soliciting money for his Proposed Class Action (Burke), which was filed in Federal Court. This is supposedly on behalf of federally regulated workers, excluding the airline industry. But considering he already dropped the Winnipeg suit, why should people have confidence in this one?

It’s worth noting that this very likely isn’t the complete list.

#1: Lawsuit Against University Of Winnipeg, Brent Roussin Et Al

This case is actually a bit confusing. While it appears that the parties agreed to having the case struck, there is still a Notice of Discontinuance on file. It’s also worth noting that the Statement of Claim filed here is essentially cut-and-pasted into future claims.

Note: The Manitoba Courts have a great system, which allows members of the public to check the status of cases. Specific documents can be requested, although there’s typically a fee for doing so.

(1) Mlodzinski Statement Of Claim
(2) Mlodzinski Notice Of Motion Uncontested
(3) Mlodzinski Order Striking Case
(4) Mlodzinski Notice Of Discontinuance

#2: Lawsuit Against Purolator, Canadian Government

June 17th, 2022: Statement of Claim is filed against Purolator and Ottawa.

December 23rd, 2022: Statement of Claim is amended.

April 10th, 2023: Claim is discontinued against everyone.

Note: All of the dates listed can be confirmed by searching the respective cases on the Federal Court website. It keeps a detailed listing of all significant events.

There isn’t anything noteworthy to report in the case. After it sat idle, for nearly a year, the case was dropped. Presumably, no one got refunds.

PUROLATOR COURT DOCUMENTS:
(1) Purolator T-1267-22 Statement Of Claim
(2) Purolator T-1267-22 Amended Statement Of Claim
(3) Purolator T-1267-22 Notice Of Discontinuance

#3: Lawsuit Against Westjet, Government Of Canada

October 4th, 2022: Statement of Claim is filed.

November 17th, 2022: Defence files Notice of Intent to Respond.

November 20th, 2022: Case management is ordered.

November 21st, 2022: Amended Statement of Claim is filed.

December 5th, 2022: Plaintiffs (a) Erin Shannon; (b) Tara Mainland; (c) Jennifer Masterman all send in Notices of Discontinuance.

December 8th, 2022: Plaintiff’s lawyer (Grey) submits letter with proposed timetable.

February 28th, 2023: Court orders case management conference on March 13th, 2023.

March 13th, 2023: Conference discusses options of discontinuing overall, or setting timetable to file materials for Motion to Strike.

April 12th, 2023: Lawsuit is discontinued.

Note: All of the dates listed can be confirmed by searching the respective cases on the Federal Court website. It keeps a detailed listing of all significant events.

WESTJET COURT DOCUMENTS:
(1) Westjet Statement Of Claim October 2022
(2) Westjet Amended Statement Of Claim November 2022
(3) Westjet Order Timetable December 2022
(4) Westjet Notice Of Discontinuance April 2023

#4: Firefighters V. City Of Calgary, Case Dropped

July 7th, 2022: Statement of Claim filed.

August 9th, 2022: Application brought to strike Statement of Claim.

September 9th, 2022: Hearing (to strike suit) adjourned.

September 21st, 2022: Statement of Claim is amended.

April 25th, 2023: Notice of Discontinuance.

Note: The Alberta Courts are a bit different. The search function allows people who order a list of the documents filed. From there, specific ones can be selected.

CALGARY FIREFIGHTER COURT DOCUMENTS:
(1) Calgary Firefighters List Of Documents
(2) Calgary Firefighters Statement Of Claim (June 2022)
(3) Calgary Firefighters Application To Strike (August 2022)
(4) Calgary Firefighters Amended Statement Of Claim (September 2022)
(5) Calgary Firefighters Discontinuance (December 2022)
(6) Calgary Firefighters Discontinuance (April 2023)

#5: Peters V. Winnipeg/Manitoba Class Action

December 8th, 2022: Statement of Claim is filed in the King’s Bench Court of Manitoba

January 5th, 2023: Municipal Defendants prepare Notice of Motion to strike lawsuit.

January 6th, 2023: Manitoba Defendants prepare Notice of Motion to strike lawsuit.

February 14th, 2023: Hearing for Motion to Strike is adjourned.

February 27th, 2023: Hearing for Motion to Strike is adjourned.

April 27th, 2023: Hearing for Motion to Strike is adjourned.

May 25th, 2023: Notice of Discontinuance is filed.

Note: The Manitoba Courts have a great system, which allows members of the public to check the status of cases. Specific documents can be requested, although there’s typically a fee for doing so.

As an aside, the Notice of Discontinuance is dated April 3rd, 2023, but wasn’t filed until the end of May. Perhaps dropping the case had long been the intention.

There are so many examples of this happening.

WINNIPEG/MANITOBA COURT DOCUMENTS:
(1) Winnipeg Class Action Statement Of Claim
(2) Winnipeg Class Action Notice Of Motion Municipal Defendants
(3) Winnipeg Class Action Notice Of Motion Provincial Defendants
(4) Winnipeg Class Action Affidavit Of Service
(5) Winnipeg Class Action Notice Of Discontinuance

#6: Lawsuit Against Canadian National Railway Dropped

March 4th, 2022: Grey files the Statement of Claim against CNR and the Federal Government. Despite representing over 200 Plaintiffs, the entire document is just 14 pages long.

September 7th, 2022: case management is held to bring a Motion to Strike.

October 11th, 2022: Statement of Claim is amended.

October 28, 2022: first Notice of Discontinuance is filed. Several Plaintiffs want out.

February 1st, 2023: Statement of Claim is again amended.

February 7th, 2023: Order from the Court regarding how to proceed with the Motion to Strike the case.

May 8th, 2023: Most Plaintiffs discontinue.

May 17th, 2023: Grey files a Motion to remove himself as solicitor for the few remaining clients. This appears to be the most work he has actually performed in the case.

June 20th, 2023: Last client discontinues case.

Note: All of the dates listed can be confirmed by searching the respective cases on the Federal Court website. It keeps a detailed listing of all significant events.

So, what actually happened in this case? The Statement of Claim was amended a few times, and there was some activity on a Motion to Strike. Then the suit was dropped without anything happening. None of the Plaintiffs ever got their day in Court. But their lawyer probably got his money.

CNR COURT DOCUMENTS:
(1) CNR T-553-22 Statement Of Claim (March 4, 2022)
(2) CNR T-553-22 Case Management September 7 2022
(3) CNR T-553-22 Amended Statement Of Claim (October 11, 2022)
(4) CNR T-553-22 Notice Of Discontinuance October 28, 2022
(5) CNR T-553-22 Amended Amended Statement Of Claim (February 1, 2023)
(6) CNR T-553-22 Order Regarding Motion To Strike February 7 2023
(7) CNR T-553-22 Notice Of Discontinuance May 8, 2023
(8) CNR T-553-22 Motion For Removal Of Solicitor (May 17, 2023)
(9) CNR T-553-22 Notice Of Discontinuance June 20, 2023

#7: Pillon V. Ducks Unlimited Canada Lawsuit

October 2023, Grey files a lawsuit in Manitoba against Ducks Unlimited Canada. The case is discontinued in January 2024, before the Statement of Claim is even filed.

Note: The Manitoba Courts have a great system, which allows members of the public to check the status of cases. Specific documents can be requested, although there’s typically a fee for doing so.

(1) Pillon Statement Of Claim
(2) Pillon Notice Of Discontinuance

#8: Hildebrand V. Canadian National Railway Lawsuit

At the end of October, 2023, Grey filed a Statement of Claim on behalf of Kenton Hildebrand, against CNR in Manitoba. The case was dropped in April 2024, and had not even been served.

Note: The Manitoba Courts have a great system, which allows members of the public to check the status of cases. Specific documents can be requested, although there’s typically a fee for doing so.

HILDEBRAND COURT DOCUMENTS:
(1) CNR Hildebrand Statement Of Claim
(2) CNR Hildebrand Notice Of Discontinuance

#9: Grey Withdraws As Counsel For Stowe/TransX Case

Grey filed this suit in October 2023. For more than a year later, until November 2024, there had been no activity whatsoever. Then, Grey filed a Motion to get himself removed as counsel.

While technically Grey hasn’t discontinued this case, Stowe is essentially screwed. He’s now outside the Statute of Limitations to file a proper claim, and it seems very unlikely he can get help with the existing one. For him, the case is over.

Note: The Manitoba Courts have a great system, which allows members of the public to check the status of cases. Specific documents can be requested, although there’s typically a fee for doing so.

(1) Stowe TransX Statement Of Claim
(2) Stowe TransX Motion To Withdraw

Okay, So Why Should People Care About This?

These types of lawsuits typically make the news when they’re filed. That said, they almost never get any sort of attention when they’re dropped. The public wrongly believes that there are lawyers working hard to protect their rights.

People are free to spend their own money however they wish. With that in mind, most people like to view themselves as intelligent consumers. Many appreciate being more fully informed before making purchases or financial contributions.

The next time some Government comes to trample people’s rights, is there any reason to expect the “freedom lawyers” will defend the public?

Worth noting: Grey was recently successful in getting certification for a Proposed Class Action involving residential school students. He’s clearly capable of doing great work. But his injection pass cases have consistently been a complete dead end.

Do you actually think Liberty Talk would ever address something like this?

Class Action Malpractice Lawsuit Against Rocco Galati: New Clients Being Sought

Westpoint Law Group is now accepting applications for potential new clients. This involves a (Proposed) Class Action suit filed in Edmonton, Alberta.

“Canada’s Top Constitutional Lawyer” faces a multi-million dollar malpractice lawsuit for how he has conducted anti-lockdown litigation going back to 2020. The basic allegation is that his work falls far below any level of professionalism that should be expected. Details include:

(a) Missing critical deadlines and being time barred
(b) Having cases thrown out for lack of jurisdiction
(c) Recycling pleadings in subsequent cases
(d) Drafting cases which are too convoluted to be addressed
(e) Not following basic rules of procedure
(f) Not properly advising clients of risks involved
(g) Encouraging unionized workers not to formally grieve
(h) Undisclosed conflicts of interest
(i) Seeking relief unavailable in Civil Court (i.e. criminal remedies, Nuremberg, Helsinki, International Criminal Court, crimes against humanity, etc…)
(j) Not advancing his cases in a timely manner
(k) Not seeking Injunctions that were promised
(l) Unnecessarily driving up costs
(m) Appealing decisions when amending was available

The claim contains essentially the same allegations which have been addressed on this website for several years. Nice that something is finally being done about it.

The suit names: (1) Galati personally; (2) his law firm; and (3) the Constitutional Rights Centre. The CRC is the organization which receives donation money. There are in fact 2 separate corporations sued.

There are 2 subclasses as well. The first group is for those who were represented by Galati in any of these cases. The second is for anyone who donated, thinking these claims were legitimate.

Worth noting: Kulvinder Gill and Ashvinder Lamba, both former clients of Galati’s, filed malpractice suits of $2,000,000 and $600,000 respectively. According to the Toronto Registry, both cases are still open. Since insurance money is limited, will we see Plaintiffs fighting over the same pot of money?

125(b). an accounting and disgorgement of revenue obtained by each of the Galati Defendants to draft each Pleading and to pursue each appeal;

Paragraph 125(b) of the Statement of Claim asks for “accounting and disgorgement”. What this means is that an attempt will be made to seize all money taken in for these cases.

Tamara Ugolini of Rebel News covered this as well. (See video)

Which Are The 6 Defective Cases Being Referenced?

There have been so many bogus and defective cases brought in recent years, it may be difficult to keep track of them. For reference, these are the 6 listed in the Statement of Claim.

  1. Vaccine Choice Canada: ONSC CV-20-00643451-0000 (the “2020 Ontario Action”)
  2. Sgt. Julie Evans (Police On Guard):ONSC CV-21-00661200-0000 (“2021 Ontario Action”)
  3. Dorceus: ONSC CV-22-00685694-0000 (the “2022 Ontario Action”)
  4. Katanik: ONSC CV-23-00695518-0000 (the “2023 Ontario Action”)
  5. Action4Canada: BCSC S217586 (the “BC Action”)
  6. Adelberg: Federal Court T-1089-22 (the “Federal Court Action”)

3 of them have been dropped: (a) Vaccine Choice Canada; (b) Evans; and (c) Katanik
3 have been struck at least once: (a) Dorceus; (b) Action4Canada; and (c) Adelberg

While the ones that were struck are officially still “open” cases, let’s be realistic. None of them will ever get to Trial on the merits.

Galati Called Out For REPEATEDLY Wasting Court Resources

(1) British Columbia Supreme Court (Justice Ross)
Action4Canada v British Columbia (Attorney General), 2022 BCSC 1507 (CanLII)
https://www.canlii.org/en/bc/bcsc/doc/2022/2022bcsc1507/2022bcsc1507.html

(2) British Columbia Court of Appeal (Justices Marchand, Dickson, Voith)
Action4Canada v. British Columbia (Attorney General), 2024 BCCA 59 (CanLII)
https://www.canlii.org/en/bc/bcca/doc/2024/2024bcca59/2024bcca59.html

(3) Federal Court of Canada (Justice Fothergill)
Adelberg v. Canada, 2023 FC 252 (CanLII)
https://www.canlii.org/en/ca/fct/doc/2023/2023fc252/2023fc252.html

(4) Federal Court of Appeal (Justices Gleason, Boivin, LeBlanc)
Adelberg v. Canada, 2024 FCA 106 (CanLII)
https://www.canlii.org/en/ca/fca/doc/2024/2024fca106/2024fca106.html

(5) Ontario Superior Court of Justice (Justice Koehnen)
Dorceus v. Ontario et al., 2024 ONSC 7087 (CanLII)
https://www.canlii.org/en/on/onsc/doc/2024/2024onsc7087/2024onsc7087.html

The BCSC and BCCA rulings are the Action4Canada case.
The FC and FCA findings are Adelberg.
The ONSC decision is from Dorceus.

Of course, the comments from Justice Chalmers in the CSASPP defamation case are very telling. He was quite blunt about how he viewed the VCC and A4C pleadings.

[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”.

Dorceus and the CSASPP defamation cases were appealed. Dorceus has yet to be heard, while CSASPP is currently under reserve. It seems extremely unlikely that either will be even partially overturned.

Given that many, MANY Judges have already issued scathing reviews of Galati’s work, it’s difficult to see how this can be overcome.

How Easy Would It Be To Prove The Torts Here?

This lawsuit cites a few different torts, such as breach of contract, breach of fiduciary duty, and negligence. That said, the requirements are much the same for each.

(a) Establish a contract, obligation, or duty to another person or group
(b) Prove that the contract, obligation, or duty has been breached
(c) Prove that damages have resulted from the breach

The first part of the test can be established with almost any documentation, such as a retainer agreement, or receipts showing donations.

The second part should be straightforward, given the various Court rulings cited above. Lawyers have an obligation to take on cases in a professional and diligent manner. This clearly hasn’t been happening. Plaintiffs can of course give evidence of issues not addressed elsewhere.

The third part will involve showing that any breach resulted in harm or financial loss.

When SUING Your Critics Just Isn’t Enough

Not content with simply suing (and threatening to sue) his critics, Galati has also made threats to involve the RCMP. This would be considered “swatting” by most people. The included letter is from September 2021, and addressed to the Law Society of Ontario, or LSO. While framed as “harassment”, the true purpose is to silence the very legitimate criticism of his defective cases.

And as usual, the LSO did nothing.

They don’t protect the public in any meaningful way.

COURT DOCUMENTS:
(1) Rocco Class Action Statement Of Claim February 2025

Galati’s (Other) $500,000 Case Against LSO Discontinued Last May

A $500,000 suit was filed against the Law Society of Ontario at the end of July, 2023. It was discontinued the following year, without the Plaintiff making any effort whatsoever to advance it.

For context, all of this stems from a 2022 complaint to the Law Society from a former donor named Donna Toews. She had contributed to both Action4Canada (A4C) and Vaccine Choice Canada (VCC) for their anti-lockdown cases. However, she became unhappy with the total lack of activity in pushing either case. To get her money back, she contacted the LSO.

This set off a chain of events, with A4C and VCC likely terrified that the Law Society might investigate. Potentially, it could force their books open, and lead to audits.

As a result, Kuntz and Gaw directed Galati to sue Toews in order to shut her up. It was a way to derail her complaint, at least for the foreseeable future. Gaw later remarked online that it had to be done to prevent disbarment.

It didn’t stop there. Galati sued the LSO a few weeks later, to future complicate any attempt to investigate Toews’ complaint. He then sued the LSO a second time to further keep things in limbo. This isn’t an editing mistake. He really started separate (but very repetitive) litigation.

Now, we know the fate of the last suit. It was dropped without a fight.

3 Related Lawsuits Filed To Bury Toews Complaint

(1) June 28th, 2022 v.s. Canadian Society for the Advancement of Science in Public Policy (CSASPP)

(2) July 12th, 2022 v.s. Law Society of Ontario (LSO)

(3) July 31st, 2023 v.s. Law Society of Ontario (LSO)

Anyhow, the CSASPP lawsuit was dismissed under Ontario’s anti-SLAPP laws, and an award of over $132,000 was ordered shortly afterward. It was appealed, but on very weak grounds.

The first claim against the LSO was struck for failing to state a Cause of Action, although permission was given to amend and refile. It doesn’t appear to have ever happened though. A cost award of $14,600 was handed down at the time.

The second claim was dropped last Spring.

Assuming the Appeal is dismissed against CSASPP, that pretty much ends the entire saga.

Of course, it doesn’t look good for the LSO. After all, this is supposed to be the regulatory body. If a member can sue somebody who complains — to sabotage the complaint — and then sues the LSO twice, all without consequences, what exactly is their purpose?

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

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

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

June 29th, 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 12th, 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 13th, 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 9th, 2022: An amended Statement of Claim is filed against the LSO, despite the fact the the Motion to Strike had already been initiated. This isn’t permitted.

October 12th, 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 both the anti-SLAPP Motion and LSO Motions. Both are attached below.

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

July 31st, 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 12th, 2023: CSASPP’s Motion to dismiss is heard, with the ruling under reserve.

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

October 11th, 2023: The (first) Claim against the LSO is struck in its entirety for not disclosing a reasonable cause of action, and for inadequate pleading. However, Justice Dow does allow the pleading to be rewritten, for what is presumably the last time.

December 11th, 2023: The Claim against CSASPP is dismissed under anti-SLAPP laws

February 3rd, 2024: Galati is ordered to pay $132,268.17 in costs.

March 6th, 2024: Appellant’s Factum is filed for CSASPP case.

May 13th, 2024: The second LSO suit is discontinued.

May 31st, 2024: Respondents in CSASPP Appeal file their Factum.

January 13th, 2025: CSASPP Appeal is heard, but the ruling is reserved.

However, it doesn’t look like Galati’s troubles are over yet. He still has to deal with malpractice lawsuits from Kulvinder Gill and Ashvinder Lamba. They’re valued at $2,000,000 and $600,000, respectively.

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) https://www.canlii.org/en/on/onsc/doc/2023/2023onsc7508/2023onsc7508.html
(17) https://www.canlii.org/en/on/onsc/doc/2024/2024onsc935/2024onsc935.html
(18) CSASPP RG Appellant’s Factum
(19) CSASPP RG Respondent’s Factum

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
(8) https://www.canlii.org/en/on/onsc/doc/2023/2023onsc5617/2023onsc5617.html

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

GILL PROFESSIONAL MALPRACTICE CLAIM:
(1) Gill Malpractice Notice of Action
(2) Gill Malpractice Statement Of Claim
(3) Gill Malpractice Statement Of Defence
(4) Gill Malpractice Reply To Defence

LAMBA PROFESSIONAL MALPRACTICE CLAIM:
(1) Lamba Statement Of Claim
(2) Lamba Notice Of Intent To Defend
(3) Lamba Reply To Statement Of Defence

MacKenzie/Levant Defamation Suit: $3,500 For Security Needed, No Trial Yet

Often, defamation lawsuits demand million dollar judgements, though not always.

Plaintiffs can also ask for much less. A broadcast from July 2023 has resulted in a $35,000 lawsuit from Jeremy MacKenzie in Toronto Small Claims Court. That’s the most allowed in Ontario.

Specifically, MacKenzie is suing: (a) Ezra Levant personally; (b) Rebel Media Holdings Inc.; and (c) Rebel News Network Ltd.

Worth noting, Small Claims Courts in general are a very simplified way of resolving disputes over small amounts of money. Cost awards are typically capped as well.This can be a welcome relief to the amount of paperwork that happens in Superior Court cases. The typical steps are involved:

  1. File Plaintiff’s Claim (a.k.a. Statement of Claim)
  2. File Defence (a.k.a. Statement of Defence)
  3. Attend Settlement Conference
  4. Book Trial (if no Settlement reached)
  5. Have the Trial

Steps #1 through #3 are complete, and a Trial needs to be booked.

Since no agreement was reached at the Settlement Conference, MacKenzie is free to request a Trial.

A complication arose, when Levant filed a Motion for Security for Costs. Essentially, he wanted MacKenzie to have to pay a deposit to the Court pending the outcome of the case. part of the issue was that MacKenzie is a Nova Scotia resident, and presumably had no assets in Ontario. An agreement was reached in the amount of $3,500.

At the time of writing this, it doesn’t appear that MacKenzie has either: (a) paid the deposit; or (b) booked a Trial date.

What Is The Nature Of The Defamation Allegations?

The lawsuit seems to focus around a July 25th, 2023 of the Ezra Levant Show. MacKenzie is suing over claims that he was slandered as follows:

a. That Mr. MacKenzie founded an explicitly racist organization;
b. That Mr. MacKenzie is a government agent;
c. That Mr. MacKenzie concocted a social movement to entrap the Coutts Four in a criminal offence.

In fairness, Levant has walked a tightrope before as to whether his comments cross into defamation. We’ll have to see what happens here.

Levant Claims Statements Taken Out Of Context

Levant claims that it’s obvious, or should be obvious, that a lot of what he covers is opinion, or commentary, and shouldn’t be taken as fact. Essentially, he’s setting up a “Fair Comment” Defence.

From page 10 in the Defence: “On the contrary, Levant clearly states during the July 25 Podcast that the Plaintiff started Diagolon as a joke or a prank, and that the Coutts 4 got into trouble because they took the joke seriously and went too far with their role playing.”

Page 9, paragraph 18, Levant says he genuinely believes that Diagolon was set up as an explicitly racist organization, but qualifies it as “I think it was done as a joke”.

From the Exhibits filed, it seems MacKenzie had his social media accounts scoured for evidence. While some was probably trolling, it may not sit well with the Court.

Should the case ever get to Trial, a Judge can make those determinations.

Government Agent (Or “Fed”) Allegations Appear True

In his Defence, Levant filed MacKenzie’s POEC testimony as an Exhibit. This was the infamous time in 2022 when he admitted under oath that he reported “extremist” behaviour, and was willing to have a “continuous relationship” with law enforcement in identifying threats to public safety.

While this may not be enough to prove MacKenzie is a “fed”, it shows, at a minimum, that he was willing to work with them. His “informing” did lead to the arrest of Landon Preik, of the group, Liberate Your Neighbourhood.

It’s also unclear what damages MacKenzie suffered from the “fed” allegations. He’s been labelled one for several years, so it’s hardly new.

Timeline Of Major Events In This Case

October 17th, 2023: MacKenzie files the Plaintiff’s Claim (a.k.a. Statement of Claim) through his lawyer, Frank Wu. The Claim demands $35,000 (the most allowed in Ontario Small Claims), and seeks the maximum costs allowed.

November 20th, 2023: Levant files a Defence, which includes MacKenzie’s testimony before the POEC Committee, and screenshots of some of his comments.

April 22nd, 2024: Levant submits his witness list for the upcoming Settlement Conference, which is just himself.

May 3rd, 2024: Wu submits Affidavits from witnesses Jason Lavigne and Kira Decoste.

May 8th, 2024: Deputy Judge Wong certifies that there was no agreement at the Settlement Conference. Defendants are also permitted to bring a Motion for Security for Costs.

August 7th, 2024: The Defence requested the scheduling of a hearing to determine Security for Costs, and whether MacKenzie would need to post before Trial.

November 8th, 2024: Defence files Motion Record for Security for Costs. MacKenzie being an out-of-Province litigant weighed against him.

November 18th, 2024: On consent, it’s agreed MacKenzie must pay $3,500.

The deposit hasn’t yet been paid, and it’s unclear if it ever will be. But should the case ever go to Trial, transcripts will likely be published on Levant’s show.

(1) MacKenzie Plaintiffs Claim October 2023
(2) MacKenzie Defence November 2023
(3) MacKenzie Defence Affidavit Of Service November 2023
(4) MacKenzie Defence List Of Proposed Witnesses April 2024
(5) MacKenzie Defence Witnesses Affidavit Of Service April 2024
(6) MacKenzie Affidavit Of Jason Lavigne May 2024
(7) MacKenzie Affidavit Of Kira Decoste 2024
(8) MacKenzie Endorsement Of No Settlement May 2024
(9) MacKenzie Defence Request To Clerk August 2024
(10) MacKenzie Defence Motion For Security For Costs November 2024
(11) MacKenzie Defence Motion Record Affidavit Of Service November 2024
(12) MacKenzie Endorsement For Security For Costs November 2024

Military Injection Pass Case: Catherine Christensen And The “Missing” Motion Record

Late last month, counsel for hundreds of military veterans appeared on the Talk Truth podcast to talk about her case, among other things. This is, of course, a notorious and high profile injection passport case that was thrown out in late 2024.

See parts 1, 2 and 3 for background on the case.

Briefly, the case was struck by Associate Judge Coughlan in November 2024 for: (a) not properly being pleaded; and (b) lack of the Federal Court’s jurisdiction, due to the military’s grievance system taking priority. After missing the deadline to appeal, and a comedy of errors, Justice Manson refused an extension of time. A Notice of Appeal has now been filed in the Federal Court of Appeal.

The full interview is available on Rumble, and most on Twitter.

Catherine Christensen, counsel for the Plaintiffs, talks about her Motion Record being deleted, an allegation that makes no sense at all. She suggested that it was done prior to AJ Coughlan’s ruling, implying that the Court is corrupt.

Worth noting: Christensen doesn’t understand the argument of why Payne succeeded. It wasn’t that “Charter Rights violations cannot be addressed in the grievance system”. It was that unilaterally imposing changes on employment contracts without meaningful consultation circumvents the grievance process.

Hopefully, she isn’t able to get a negative precedent set.

Motion Records Filed, Available To The Public

Anyone can search the case notes on Federal Court cases. It’s freely available. For the Motion to Strike, the Plaintiffs’ Motion Record was Item #68 and #70. Yes, it’s 2 volumes. As for the Motion to extend time, it’s Item #77.

The first volume of the Plaintiffs’ Motion Record contains dozens of Affidavits, and is 6,908 pages in size. It’s full of photographs, and takes up over 1 GB in data. However, a significant portion is irrelevant.

The second volume of the Plaintiff’s Motion Record contains the written submissions, and hundreds of pages of “secondary sources” and “appendices”. It’s 613 pages in length.

Now, it’s possible that she had to send (at least the first volume) more than once, given its size. But she’s implying there’s some conspiracy to rig the case. In reality, the Motion Record was so poorly crafted that it went largely ignored by AJ Coughlan.

For context, what was the Motion to Strike about?
(a) Pleadings not being drafted in a way that can be responded to
(b) Lack of jurisdiction for the Court, given the grievance system in place

To address the lack of jurisdiction, the Plaintiffs needed to focus on providing evidence that the grievance option was corrupted, or otherwise unworkable. There are parts of the evidence that addressed exemptions and grievances, but that should have been the entirety.

At the time of hearing the Motion to Strike, over 100 of the Plaintiffs had filed grievances, and they were in various stages. In fairness to AJ Coughlan, it put her in the awkward spot of being asked to confer jurisdiction to the Court. As for ongoing grievances, it would effectively hijack them.

[67] Indeed, it is noteworthy that over 100 of the Plaintiffs have filed grievances arising from the Directives. At least one grievance was allowed by the MGERC though not supported by the FA. This Court has consistently upheld the CAF grievance system and declined to exercise its exceptional jurisdiction: Veltri v Department of National Defence Canada, dated January 4, 2018, at paras 11-17 (Federal Court file no. T-1400-17); Sandiford v Canada, 2007 FC 225 at para 28‑29; Graham v Canada, 2007 FC 210 at paras 22-23. In the present circumstances, I see no basis upon which I ought to exercise my residual jurisdiction to permit this action to continue.

For reference, Christensen was told back in late 2021 not to try to circumvent the grievance system by going to Federal Court. That was also a vaccine mandate case.

To give Plaintiffs credit, there were sections of the evidence that were quite appropriate. But with these decisions in mind, it was an uphill battle getting any Court to take the case.

***Due to the large amounts of private (and irrelevant) information that was filed, the Motion Record won’t be shared. It would cross into doxing.

Contents Of Motion Record Largely Irrelevant Or Redundant

The first volume of the Motion Record consists of 34 Affidavits, and is 6,908 pages long.

The content which shows various Plaintiffs attempting to seek some alternative or exemption is great. Many refer to grievance systems in place. That’s helpful in trying to establish whether or not there were any alternatives.

There’s a lot of duplication and redundancy in the evidence. Documents such as: (a) CDS Directive 001; (b) Layered Risk Management System; and (c) Government of Canada Policy on Mandatory Vaccination appear in each Affidavit.

The Affidavits also include significant sections of personal information that seem unnecessary to hearing such a Motion.

Part of the problem of having hundreds of Plaintiffs is that filing anything becomes a tedious process. Approximately, just 10% of them gave any evidence at all, and the Motion Record was thousands of pages. A far better option would be a Class Action, something Christensen does actually suggest later.

Some Affidavits Sworn Out BEFORE Proceedings Commence

[17] The Plaintiffs filed 34 affidavits of individual Plaintiffs with their motion materials. Some of these affidavits pre-date the filing of the initial Statement of Claim yet bear the style of cause and action number of the proceeding. Further, not all of the additional affidavits were referenced in the Plaintiffs’ written representations.

There’s a principle in law that evidence cannot be changed once it’s sworn out, but that appears to have happened here. AJ Coughlan mentions that some Affidavits were completed prior to the case being filed, yet have the the number of them. Prior to the Statement of Claim being filed — here it’s June 20th, 2023 — there would be no case number at all.

And that ties back in to the earlier problem. This was just a Motion to Strike, and the focus should have been on asking the Court to “take Jurisdiction”, as there was no effective grievance option. Instead, Christensen seems to have just reused Affidavits compiled earlier. She didn’t create new ones.

Written Submissions Only Reference “Some” Affidavits

[16] The form of motion materials is precisely prescribed by the Rules. Rule 363 provides that any facts to be relied upon by a party on motion should be set out in an affidavit. Rule 365(2) provides that appropriate sources may be referenced, attached to the affidavit, and included as part of the motion record. However, only affidavits and sources that are referred to in written submissions are to be included in the motion record.

[17] The Plaintiffs filed 34 affidavits of individual Plaintiffs with their motion materials. Some of these affidavits pre-date the filing of the initial Statement of Claim yet bear the style of cause and action number of the proceeding. Further, not all of the additional affidavits were referenced in the Plaintiffs’ written representations.

This is pretty straightforward. If you want to rely on Affidavit Evidence, it needs to be referenced in the written arguments. However, only some of them were.

Motion Record Contains “Secondary Sources” And “Appendices”

[18] The Plaintiffs also attached secondary sources to their motion record. The secondary sources were styled as “Appendices” and were not attached to affidavits. Again, only some of the secondary sources included in the motion record were referenced in argument. At the hearing of this matter, Plaintiffs’ counsel conceded that this is unacceptable under Rules 363 and 365.

[19] Because of the breach of Rules 363 and 365, I conclude that the affidavits and secondary sources were not properly before the Court on this motion. Accordingly, I did not consider them in my analysis.

AJ Coughlan clearly had (and read) the Motion Record prior to making a ruling. But the Rules of Civil Procedure were flaunted to such a degree that she refused to consider the evidence within.

Keep in mind, this is just a Motion to Strike. Again, the only evidence that really mattered was evidence that showed the grievance process was unworkable.

Despite suggesting the Judge was corrupt (or at least Court officials), the Motion Record was disregarded since Christensen couldn’t be bothered to follow the Federal Court Rules. This is an ongoing problem.

Christensen Sought To Convert Into Class Action, Or Individual Cases

Interestingly, in trying to ward off a Motion to Strike, Christensen proposed that AJ Coughlan allow the case to be refiled as a Class Action, or on an individual basis.

Of course, one has to wonder why it wasn’t in the first place. She laments the burden and hassle of having to contact and consult with over 300 clients. By contrast, a Proposed Class Action could have been initiated with a few (or even a single) Representative Plaintiff.

Christensen Screwed Up First Appeal (Rule 51)

The case was originally struck by Associate Justice Coughlan. Christensen filed a Motion under Federal Court Rule 51 to have it reviewed. Or at least, she was supposed to. She missed the deadline by nearly 3 weeks, and bungled an attempt to ask for an extension of time. And to clarify:

APPEAL RULING FROM PROTHONOTARY JUDGE
Appeal Goes Where Federal Court Federal Court Of Appeal
Appeal Ruling To Single Judge (FC) Panel of Justices (FCA)
Rules of Procedure Rule 51 Rules 335 to 357
Time Limit For Notice 10 Days 30 Days
Initial Document Notice Of Motion Notice Of Appeal
Procedure Motion Appeal
New Evidence Allowed? No With Leave, Rule 351

Because an Associate Judge (Prothonotary) struck the case initially, it could be reviewed by filing a Motion. Challenging a Judge’s decision would have required going to the Federal Court of Appeal. But Christensen screwed up the Appeal big time. Not only was she late, but:

  • The reason for prolonged inaction wasn’t really convincing
  • Christensen invoked the wrong Rule (51, instead of 8) asking for extension
  • Christensen asked for a Motion “in writing” but cited a Rule that applied to the Federal Court of Appeal
  • Christensen asked for “Leave” to appeal when it wasn’t required
  • Christensen improperly swore out her own Affidavit (breaks Rule 82)
  • Christensen didn’t clarify Plaintiffs “always intended” to appeal
  • Christensen didn’t explain how an Appeal may be successful

That Appeal was addressed in detail here and here.

Christensen Appears To Have Already Screwed Up Second Appeal

Christensen missed the deadline to appeal the first time around, and then botched a Motion to extend time. She then files a Notice of Appeal with the Federal Court of Appeal. Already, it’s obvious that she has no idea what she’s doing.

First, Leave (permission) to Appeal to this Court is not required for a Final Order.

Second, Christensen asks for Leave “to file the Notice of Appeal”. Problem is, that “is” the Notice of Appeal. It’s already filed, and can’t be unfiled. It would have made far more sense to bring a Motion asking to file the Notice of Appeal. And again, Leave isn’t required.

Third, she doesn’t seem to be challenging the Decision of Justice Manson not to extend time to file the Rule 51 Appeal. She says that it was an error…. but doesn’t ask that it be reversed.

Fourth, she requested permission to convert the lawsuit into a Class Action when the Motion to Strike was heard, and that would have solved a lot of logistical problems. However, there’s no mention of it here.

Fifth, on a lesser note, she requests costs on a full indemnity basis, which would be 100% of the costs. Outside of successful anti-SLAPP Motions for defamation suits, it’s almost unheard of. The Federal Courts have their own scales for lawyers to use.

Could such an Appeal eventually succeed?

Perhaps, but it’s been a gong show so far.

COURT DOCUMENTS:
(1) Qualizza Statement Of Claim June 2023
(2) Qualizza Amended Statement Of Claim July 2023
(3) Qualizza Statement Of Defence September 2023
(4) Qualizza Reply To Statement Of Defence September 2023
(5) Qualizza Defendants Motion To Dismiss Claim July 2024
(6) Qualizza Plaintiff Motion To Strike Written Submissions August 2024
(7) Qualizza Plaintiffs Motion To Extend Time To Appeal December 2024
(8) Qualizza Defendants Respond To Motion To Extend Time To Appeal December 2024
(9) Qualizza Order Denying Extension Of Time January 2025
(10) Qualizza Federal Court Notes
(11) Qualizza Notice Of Appeal January 2025
(12) Qualizza Motion Record Contents Of Appeal Book February 2025

OTHER:
(1) https://www.laws-lois.justice.gc.ca/eng/acts/n-5/
(2) https://www.laws-lois.justice.gc.ca/eng/acts/n-5/page-3.html#h-374837
(3) https://www.fct-cf.gc.ca/en/court-files-and-decisions/court-files#cont
(4) https://www.canlii.org/en/ca/fct/doc/2021/2021fc1443/2021fc1443.html
(5) https://www.canlii.org/en/ca/fct/doc/2024/2024fc1801/2024fc1801.html
(6) https://nationalpost.com/news/canada/hundreds-of-military-part-of-lawsuit-over-mandatory-covid-vaccine
(7) https://valourlegalactioncentre.org/
(8) https://www.youtube.com/watch?v=hifDPBW4r0w