Category: Procedural

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Boulachanis: Murderer, Trafficker And Escapee Sent To Women’s Prison

It’s bad enough that male convicts can simply game the system to ensure they’re placed with women. It seems that even being a convicted murderer, a narcotics trafficker, or having a history of escaping isn’t necessarily enough to prevent it. Nor are allegations of sexual assault while in custody. Regardless of circumstances, women simply don’t have rights to assert.

This covers John Boulachanis, who now goes by Jamie Boulachanis. He had previously been involved in drug trafficking, and murdered an accomplice he feared would turn him in.

Bagnald, Blackplume and Patterson were looked at previously.

In a convoluted decision, Justice Sébastien Grammond of the Federal Court allowed him to be transferred, at least until the issue was finally worked out. However, the Federal Court of Appeal stayed that decision.

Boulachanis Is Murderer With Previous Escape

[17] Upon her return to Canada, Ms. Boulachanis was charged with first‑degree murder and detained in provincial custody. In 2013, she managed to escape while being transported in a prison van, but was caught soon after. After going through a metal detector, she handed over saw blades, handcuff keys and part of a screwdriver hidden in her body cavities. In 2015, a search of her cell turned up a variety of objects and instruments that could be used to escape, including braided ropes, handmade handcuffs and tools. She was also convicted of obstructing justice for inducing witnesses to lie during her murder trial.

From Justice Grammond’s own reasons, Boulachanis had escaped custody previously, and had the tools to do so another time. He was still allowed to be in a women’s jail. Additionally, he had fled the country, and was only apprehended when he returned.

According to the Federal Court, Boulachanis lived under false identities in Greece, the United States, and elsewhere in Canada. Another reason to view him as a security risk.

Tortured Logic Coming From Federal Court

[30] To determine whether Ms. Boulachanis presented a strong prima facie case, it can be helpful to begin by reviewing the positions of the parties. Ms. Boulachanis’s position is straightforward: keeping her in a men’s institution is discriminatory, and in addition, this violates the interim policy. Since she is legally a woman, she has the strict right to be accommodated in a women’s institution.

[31] On the contrary, the Attorney General’s argument is based on the exception that appears in the interim policy. He argues that Ms. Boulachanis’s case, because of her high risk of escape, raises “overriding health or safety concerns which cannot be resolved.” The decision to keep Ms. Boulachanis in a men’s institution would be the result of weighing her right to equality against the objectives of the Corrections and Conditional Release Act, SC 1992, c 20 [the CCRA], namely those regarding public safety. Citing the decision in Doré v Barreau du Québec, 2012 SCC 12, [2012] 1 SCR 395 [Doré], the Attorney General argues that the outcome of this weighing exercise was reasonable.

[35] In our society, certain facilities or areas are often reserved for men or for women. Reconciling these deeply entrenched practices with the right to equality of trans people often raises challenges. Nevertheless, there is prima facie discrimination when a trans person is forced to use facilities reserved for people of their anatomical sex, when they do not correspond to their gender identity or expression: see, for example, Sheridan and Kavanagh. Such an approach is consistent with a perspective based on individual autonomy in gender identity and expression.

[36] Thus, Ms. Boulachanis was subject to prima facie discrimination because of her gender identity or expression, given that she was denied a transfer to a women’s institution, even though that is what corresponds to her current gender identity and expression and the designation of sex that now appears on her act of birth. That was also the conclusion of the Canadian Human Rights Tribunal in Kavanagh, at paragraph 141. The interim policy the Service adopted in December 2017 was also based on the idea that respecting the right to equality of trans people required that their choice to be in a men or women’s institution be respected.

[37] Ms. Boulachanis was also subject to prima facie discrimination from another perspective. While all inmates undergo a risk assessment to determine their security classification, it is only in the case of trans women inmates that the Service use this assessment to deny them the possibility of being accommodated in a women’s institution. A cisgender woman who presented just as great a risk as Ms. Boulachanis would automatically be sent to a women’s institution. That is another reason for a finding of prima facie discrimination.

[40] In this case, the Attorney General is not claiming that the simple presence of trans women in women’s institutions would cause undue hardship. It appears that the adoption of the interim policy, which clearly provides for this presence, implicitly set aside the arguments that, more than fifteen years ago, led to the Canadian Human Rights Tribunal’s finding in Kavanagh, at paragraphs 155–160.

[41] What the Attorney General is arguing is that accommodating trans women inmates in a women’s institution must be subject to an assessment of the level of risk to health and safety. To justify this condition that would be applied only to trans women inmates, the Attorney General strongly insists on the fact that men and women’s institutions do not meet the same security requirements. In particular, the evidence clearly shows that the construction standards are different and that the use of firearms to ensure safety is prohibited in all women’s institutions, whereas it is allowed in men’s institutions, depending on their security level. These differences in the design and operation of the two categories of institution apparently reflect the fact that men are, in general, more dangerous than women, that the criminal behaviour of men and women is different, and that women may benefit from a different correctional approach based on their specific needs. In this regard, the policy adopted by the Service is largely inspired by the report of Justice Louise Arbour concerning the riot that occurred at the Kingston women’s prison in 1994 (Commission of Inquiry into Certain Events at the Prison for Women in Kingston, Minister of Public Works and Government Services Canada, 1996).

[42] I have no difficulty accepting the fact that it is appropriate to separate men and women in a correctional environment and that it is appropriate to implement less strict security measures in response to the different situation of women. But that is not the issue. The real issue is to determine whether, in a context where it is justified to keep separate institutions for men and women, Ms. Boulachanis should be treated as a man or as a woman.

[45] I find it hard to believe that physical capability is so important in assessing the risk posed by an inmate that, for that reason alone, trans women inmates must be treated as men. Furthermore, I note that the assessment to determine Ms. Boulachanis’s security classification makes no mention of her physical capabilities.

[48] In the absence of a reliable scientific basis, we are reduced to speculation, which is fertile ground for discriminatory prejudice. At the hearing, the Attorney General made certain hypotheses about the physical and psychological effects of the various phases of the sex reassignment process on risk and dangerousness. I have serious doubts about the validity of such hypotheses. Moreover, we should also consider the social effects of this process, in particular on the ability to maintain relationships with potential accomplices or criminal networks.

It’s worth pointing out that the Attorney General isn’t challenging the policy in any way. In other words, there’s no issue in principle with men being in women’s prisons. It’s only that this specific one cause security risks.

The Judge doesn’t think that just because Boulachanis is a man, that he should be treated as such.

Another noteworthy point is that there appears to be no concern for the well being of the female inmates at the prison.

Timeline Of Major Events In Case

August 9, 1997: John Boulachanis is charged with first degree murder of Robert Tanguay.

1998 to 2011: Boulachanis lives under various assumed names, and in other countries. He is eventually arrested after returning to Canada.

September 2016: Over several days, a Jordan Application is argued. The Defendant says that his rights have been violated due to the extensive delays in prosecuting him.

October 6th, 2016: The Quebec Court denies the Jordan Application to stay the case.

October 27th, 2016: Quebec Superior Court permitted the testimony of a certain witness to be admitted at Trial, but with limiting instructions to be issued when the time came.

November 29th, 2016: The Quebec Court refuses a request to get certain prosecution statements removed from the record.

December 17th, 2016: Boulachanis is convicted, receives automatic life sentence.

January 20th, 2017: Quebec Court of Appeal agrees to expedite a challenge to the sentence.

January, 2019: Now serving a life sentence, Boulachanis begins taking synthetic hormones.

April 11th, 2019: Boulachanis has a hearing Federal Court. The prison staff refused his request to be transferred to a female prison. They do however refer to him as “Jamie”.

April 15th, 2019: Federal Court orders that Boulachanis can be transferred to a women’s prison for the time being.

April 23rd, 2019: Federal Court of Appeal hears argument that Boulachanis should stay where he is, and that female prisons are not designed to hold someone like him.

April 24th, 2019: Federal Court of Appeal stays the transfer pending final determination of the original Application.

January 8th, 2020: Quebec Court of Appeal rejects an Appeal of 2016 decision that refused the Jordan Application.

January 11th 2021: Boulachanis is transferred to Joliette Women’s Institution. Despite the FCA overturning Justice Grammond’s ruling, he’s in with women. Presumably, it was settled internally.

December 16th, 2021: Supreme Court of Canada grants an extension of time to file material for an Application for Leave to Appeal, but denies the Application itself. This was over the order which refused to stay his case for delay.

September 25th, 2024: CSC conducted a reassessment of his security clearance, which was currently at a “moderate” level.

The case didn’t end in 2021. Boulachanis filed a Habeas Corpus Application, which was refused. His security classification was raised, due to an incident of him trafficking morphine within the prison. As a result, he risked being sent back to a men’s prison.

Ultimately, the Court refused to get involved in the case, stating they were not the “arbiters of the institutional day-to-day”.

In any event, he never had any business being locked up with women, regardless of the other security risks he posed.

COURT DECISIONS (TRANSFER):
(1) https://www.canlii.org/en/ca/fct/doc/2019/2019fc456/2019fc456.html
(2) https://www.canlii.org/en/ca/fca/doc/2019/2019fca100/2019fca100.html
(3) https://www.canlii.org/fr/qc/qccs/doc/2025/2025qccs1049/2025qccs1049.html

COURT DECISIONS (MURDER CASE):
(1) https://www.canlii.org/fr/qc/qccs/doc/2016/2016qccs6867/2016qccs6867.html
(2) https://www.canlii.org/fr/qc/qccs/doc/2016/2016qccs6876/2016qccs6876.html
(3) https://www.canlii.org/fr/qc/qccs/doc/2016/2016qccs6877/2016qccs6877.html
(4) https://www.canlii.org/fr/qc/qccs/doc/2016/2016qccs6879/2016qccs6879.html
(5) https://www.canlii.org/fr/qc/qcca/doc/2017/2017qcca66/2017qcca66.html
(6) https://www.canlii.org/en/qc/qcca/doc/2020/2020qcca4/2020qcca4.html
(7) https://www.canlii.org/en/ca/scc-l/doc/2021/2021canlii129761/2021canlii129761.html

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Haedyn Patterson: How This “Woman” Acted While In Custody

Let’s look at an older case that’s still applicable today. Haedyn-Khris Racquel Beaumann, (or Patterson?) whose real name is Kevin David Patterson, fled to British Columbia after committing murder back in 2014. To avoid extradition to Washington State, he filed endless legal challenges. Eventually, he resorted to playing the “transgender” card, in order to further delay.

While the case was (more broadly) covered over the years, reporting didn’t really address the specific allegations of how Patterson acted in custody. He managed to get transferred to the Alouette Correctional Centre for Women, or ACCW. It’s shocking what the staff tolerated, and how little the safety of the women trapped with him mattered.

Also see Bagnald and Blackplume for some of the other psychos that are locked up.

Female Prison To Be Staffed By Female Guards

9. As a general matter, females are housed separately from men in British Columbia’s correctional system. As is explicitly acknowledged by BC Corrections in a document entitled “Statement of Philosophy – Correctional Service for Women,” female inmates tend to have backgrounds, needs, and safety concerns that are distinct from male inmates. Notably, many female inmates have historically suffered abuse at the hands of men, and as a result of this trauma are more vulnerable and susceptible to ongoing and future trauma and abuse.

34. In accordance with the Cross Gender Staffing Policy, all front-line correctional officers at ACCW are female. These officers are responsible for supervising the inmate population on the units, doing visual safety checks of inmates in all areas of the centre, including individual cells, performing physical searches, taking escorts into the community, facilitating programs, etc. The few male staff members at ACCW are either supervisors or managers.

35. The majority of the inmates at ACCW have suffered from violence or other forms of abuse by men, tend to be marginalized, are more likely to be easily controlled or overpowered by men, and have high levels of trauma.

36. There are many challenges to managing the inmate population at ACCW. Ensuring the safety and security of staff and inmates in the context of a correctional centre is a complex balancing act. One of the biggest challenges staff face is managing the interaction among inmates to prevent or minimize tensions and conflict among them, and to protect vulnerable inmates from being taken advantage of.

Then, there’s this nonsense:

“51. Transgender inmates at SPSC are welcome to wear wigs or prosthetics in accordance with their gender expression, though BC Corrections does not supply these items. All inmates at SPSC must, however, wear the same outer clothing for safety and security reasons.”

The Response to the Petition is interesting. It’s stated quite plainly that with the odd exception in management, the staff is female. This is due largely to trauma and violence inmates have suffered. And it’s all perfectly reasonable.

However, this logic completely falls by the wayside when it’s explained that male prisoners can simply call themselves women and be transferred there. Guards at least are subjected to a high level of background checks, whereas anyone can be an inmate.

Patterson got himself transferred to the Alouette Correctional Centre for Women in Surrey, B.C. But because of how he acted, he was eventually sent back. He challenged the decision.

ACCW admits that they had at least 15 transgender prisoners between 2016 and 2019. So, this isn’t a one-off, but is a regular concern. But what about the women there?

Alouette Explains Reasons For Sending Patterson Back

In response to Patterson’s Petition, the prison filed a formal reply. It outlined in detail the problems that they had with him.

59. In late 2017 (i.e. after three years in custody), while incarcerated at SPSC, the petitioner informed BC Corrections for the first time that she identifies as female. The petitioner was transferred from SPSC to ACCW on September 12, 2018.

60. Prior to her transfer to ACCW, the petitioner was required to sign a “Behavioural Expectations Contract”. These are sometimes used where an inmate has demonstrated negative behaviour and BC Corrections staff determine a behavioural expectations contract may assist in correcting that behaviour. The terms of the contract ensure inmates have a clear understanding of what is expected of them and to provide a clear behavioural plan for the inmate to follow.

64. During her stay at ACCW, Ms. Bryson worked closely with the petitioner to manage her behavioural issues and to support her compliance with the behavioural expectations at ACCW, as set out in her Behavioural Expectations Contract. Nevertheless, the petitioner’s behaviour proved extremely difficult to manage.

65. Throughout her time at ACCW, and despite Ms. Bryson’s efforts to work with the petitioner, the petitioner routinely engaged in disruptive behaviour that breached ACCW’s rules. These behaviours ranged from horseplay, prohibited intimate relationships with other inmates, disobeying staff direction, and behaving in an abusive manner toward others. By the time that she was transferred back to SPSC, there were 288 negative entries in her C-Log related to her time at ACCW.

66. In addition to these more routine examples of negative behaviour, there were four serious incidents involving the petitioner during her time at ACCW. These incidents, which took place on January 30, April 3, July 24 and August 14, 2019, demonstrated a pattern of repeated and significant misbehaviour that put the safety and security of the petitioner, ACCW staff, and other inmates at risk.

80. On August 14, 2019, Dr. Nader Sharifi, Medical Director of Correctional Health Services emailed ACCW’s Warden, Lisa Martin. Dr. Sharifi indicated that the petitioner had not been adhering to her transcare medication and that felt obligated to inform Ms. Martin of that fact as, in his view, it could endanger the safety at ACCW and its operations.

84. A Code Yellow was called and additional responding staff attended the scene. The petitioner was non-compliant and combative with staff. It eventually took eight staff members, including staff who are members of the Emergency Response Team, to restrain the petitioner with a “wrap” and move her to a harm reduction cell.

85. As a result of the petitioner’s combative behaviour on August 14, 2019, three staff members submitted Worker’s Compensation Claims for various injuries sustained during the code response including scratches, swelling, and injuries to the neck, knees, and back.

It’s difficult to believe that this went on. Prison staff knew in advance that Patterson was a serious problem. They also noted that “identifying as a woman” only set in after approximately 3 years in custody. And of course, he was wanted in the United States for first degree murder.

Not only was he transferred to ACCW, but allowed to remain there in spite of being a constant nuisance, menace, and danger to the women.

Patterson Threatened To Kill Staff, Other Inmates At ACCW

70. This incident was particularly concerning to ACCW staff. As noted above, the petitioner is facing extradition to the United States on a charge of first degree murder. One way to defeat an extradition proceeding is to be charged in Canada with a crime of equal or greater severity. Given this context, the petitioner’s comments “don’t forget I have nothing to lose” were taken very seriously.

Notwithstanding that he never should have been at ACCW to begin with, it’s mind boggling that he was allowed to remain for so long.

Timeline Of Major Events In Case

September 17th, 2014: Patterson commits murder and soon flees to Canada.

November 20th, 2014: The U.S. officially requested Patterson be extradited.

December 11th, 2014: The Minister of Justice authorized the extradition.

February 11th, 2015: British Columbia Supreme Court rejected Patterson’s application for bail. He had requested temporary release while extradition was being sorted out.

May 6th, 2015: At an extradition hearing, Justice gives oral reasons for committing Patterson into custody until the American authorities can get him.

July 20th, 2015: British Columbia Court of Appeal rejects a request to review the bail findings from earlier in the year. Patterson is to stay in custody.

October 17th, 2015: Minister of Justice orders unconditional surrender of Patterson.

February 3rd, 2017: British Columbia Court of Appeal dismissed an Appeal from the B.C. Supreme Court, which would have forced Patterson’s extradition to the U.S. The Court also refused an Application to consider new evidence.

Late 2017: Although no exact date is given, Patterson informs prison staff for the first time that he identifies as a woman.

March 15th, 2018: Supreme Court of Canada declined to hear an Appeal from the February 2017 decision of the BCCA.

September 12th, 2018: Patterson is transferred to ACCW.

December 7th, 2018: British Columbia Court of Appeal throws out Patterson’s Appeal.

July 11th, 2019: Supreme Court of Canada granted an extension of time to serve and file the Application for Leave, to challenge the December 2018 ruling. However, the Application itself was dismissed.

January 14th, 2020: British Columbia Court of Appeal rejects yet another request for interim release, pending extradition.

April 2nd, 2020: British Columbia Court of Appeal dismissed an Application by the Attorney General of Canada to have Patterson declared a “vexatious litigant”. However, it was noted that any further misuse of the Court may change their minds.

April 30th, 2020: British Columbia Court of Appeal dismisses Patterson’s Appeal of the January 24th, 2019 decision.

After exhausting all legal options in B.C., Patterson was eventually extradited. He was found guilty of murder.

One has to assume that the prison staff don’t want to put up with people like this. Patterson wasn’t even delusional, he was just gaming the system to avoid extradition for murder. To play devil’s advocate, perhaps the guards were trying to put together an extensive paper trail.

This sort of policy puts staff and prisoners alike in danger. Even if male inmates don’t injure or kill anyone, it’s still an intrusion that no one wants.

It’s apparently common practice to supply prisoners with synthetic hormones while they’re locked up. Not only to women have to contend with male prisoners, but they’re drugged up at the same time. It’s just asking for trouble.

There’s also the issue of all the expenses involved here. Patterson racked up huge legal bills, which taxpayers are presumably on the hook for.

COURT DOCUMENTS:
(1) Patterson Petition
(2) Patterson Response To Petition
(3) Patterson Notice Of Hearing

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Katherine Ethyl Bagnald: Transferred To Women’s Prison Despite Sexual Assault Allegation

Something that largely went ignored by the media is the case of an inmate named Katherine Ethyl Bagnald. He is a 22 year old man who was sentenced to prison time for multiple robberies, and wants to be sent to a women’s jail.

Despite his age, Bagnald already has a serious criminal record. When Corrections Canada refused to put Bagnald in with women — at least for the time being — he sued the Federal Government.

His intake assessment is disturbing, to put it mildly.

  • His first arrest (at 16) was for pulling a knife on his mother’s boyfriend.
  • He was arrested for threatening to kill his (then) girlfriend’s father.
  • He was previously in a fight at the CNSCF.
  • He was on probation when he committed these 3 robberies.
  • He claimed to have a knife when robbing these 3 gas stations.
  • He was heavily into drugs and alcohol as a minor (so he claims).
  • He was involved in prostitution as a minor (so he claims).

It’s baffling to think that putting this mentally ill biological male with female inmates wouldn’t lead to serious problems. What’s more unsettling is that the responding lawyers don’t cite this danger as the primary reason to refuse him.

Thanks to Ottawa’s new rules on “diverse gender offenders“, men can simply declare that they are women, and are allowed to be transferred. There’s little (if any) consideration for the safety and comfort of the women involved.

Bagnald Accused Of Sexually Assaulting FEMALE Inmate

Now we get to the uglier part. It’s more than just the issue of putting a male inmate in a female prison. Bagnald is also under investigation for sexual assault of another inmate. Although some details are included in these papers, they won’t be published here.

One of the reasons Bagnald cites in being allowed to go to a women’s prison is that the incident had only led to an internal investigations by the jail, and not formal criminal charges. Of course, that may very well change. He also claims the encounter was consensual.

While Bagnald is suing to force the jail to put him at a women’s federal penitentiary, it turns out that was unnecessary. He was later voluntarily transferred, despite the ongoing complaint. Corrections couldn’t be bothered to at least fight the case.

Correction: He was in fact later charged with sexual assault under section 271 of the criminal code. It occurred on September 12th, 2024. However, he wasn’t charged until May 2025.

***Author’s note: because of the publication ban of portions of the evidence, and on identifying the victim, the actual documents will not be published.***

Bagnald Objected To Portions Of Confidentiality Request

As is common in cases of sexual assault, and internal investigative matters, confidentiality requests are made. Bagnald opposed it, however, including sealing information that would have protected the identity of his victim.

Ultimately, the Court did agree to restrict some information.

Timeline Of Major Events In Case

September 12th, 2025: Bagnald, while in custody on robbery charges, sexually assaults a female inmate at the Central Nova Scotia Correctional Facility. However, he would not be charged with this for several months.

January 3rd, 2025: Bagnald receives a Federal (over 2 year) sentence for 3 counts of robbery and breach of probation. He is incarcerated with men, given that he is one.

January 10th, 2025: Bagnald is notified that he would be sent to the Regional Reception Centre (RRC) at Springhill Institution, which is a men’s prison. This is the order that he tries to have set aside, and there is just 30 days to commence proceedings. That would be February 9th.

January 14th, 2025: Bagnald is transferred to the RRC.

February 25th, 2025: Bagnald files a Motion for an extension of Time in Federal Court. As the deadline to challenge the order has lapsed, he needs to convince the Court that he should be allowed to argue it anyway.

February 28th, 2025: Bagnald brings another Motion, this one for an order to compel Corrections Canada to transfer him to a women’s prison.

March 3rd, 2025: The Attorney General responds, objecting to the Motion to compel Bagnald’s transfer to a women’s prison. However, it’s based primarily on procedural grounds, i.e. Statute of Limitations, and not the fact that he would be a danger to the women locked up.

March 3rd, 2025: The Attorney General also responds to the Motion for the extension of time.

March 18th, 2025: The Attorney General brings a Motion to seek (or protect) certain information from being made publicly available. While the assessment was still ongoing, it’s alleged that Bagnald sexually assaulted a female inmate, a real woman. Although no criminal charges had been filed yet, the jail still had to investigate it. There is a PUBLIC version available with redactions, but only the Court has access to the full version.

March 20th, 2025: Bagnald formally objected to most of the redactions sought by the government.

March 20th, 2025: Bagnald files reply submissions in support of getting transferred.

March 24th, 2025: Federal Court agreed to withhold portions of the evidence from public view, citing the need for privacy.

March 25th, 2025: Bagnald files an Application for Judicial Review, trying to force Corrections Canada to let him be transferred to a women’s prison.

April 9th, 2025: Bagnald files an amended Application.

May 14th, 2025: Bagnald is finally charged with sexual assault. The Crown elects to proceed “by indictment”, the more serious option. By this time, he’s already at the Nova Institute for Women, a federal penitentiary.

June 17th, 2025: A publication ban is ordered to protect the sexual assault victim, and witnesses who may be involved in the case.

June 19th, 2025: The Government brings forward a Motion to Strike for the Federal case. The basis is that by now, Bagnald has already been transferred to a women’s prison, and hence, the Application is moot.

June 30th, 2025: Bagnald responds to the Motion to Strike. While he as already been moved, he wants to proceed anyway, in order to create a precedent that can be used later.

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’s nothing “progressive” or “enlightened” about implementing these sorts of policies. Supporters simply hate women, and are indifferent (at best) to the harm that they cause.

MOTION REQUESTING EXTENSION OF TIME (25-T-23):
(1) Bagnald Risk Assessment Corrections Canada (January, 2025)
(2) Bagnald Gender Diverse Inmate Directives
(3) Bagnald Motion Record To Extend Time (February, 2025)
(4) Bagnald Letter To Court Requesting Urgency (February, 2025)
(5) Bagnald Motion Record Requiring Transfer (February, 2025)
(6) Bagnald Responding Motion Record Extension Of Time (March, 2025)
(7) Bagnald PUBLIC Responding Motion Record Transfer (March, 2025)
(8) Bagnald Written Submissions Transfer (March, 2025)
(9) Bagnald Cost Agreement (March, 2025)
(10) Bagnald – Decision Granting Extension Of Time To File Application (March, 2025)

APPLICATION TO REVIEW DECISION (T-982-25):
(1) Bagnald Notice Of Application (March, 2025)
(2) Bagnald Amended Notice Of Application (April, 2025)
(3) Bagnald Motion Record To Strike (June, 2025)
(4) Bagnald Responding Motion Record To Strike (June, 2025)

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“Posties” Get Screwed Over Again By Incompetent Counsel, Part 1

Last Spring, this site covered how hundreds of employees at Canada Post (a.k.a. The “Posties“) had been taken for a ride by their counsel. In the Fall of 2024, documents were filed indicating that at least some of them would be attempting to appeal.

For context, in the Fall of 2021, the workplace implemented the “vaccine mandates”. This required everyone to get multiple injections, or face the loss of their employment.

Being a unionized employer, the collective bargaining agreement specified a remedy: file a grievance. If things couldn’t get resolved, then the matter would go to arbitration, and that would be considered final. If the process was unfair or corrupted, then requesting a review may be an option.

Here, the Arbitration Panel sided with Canada Post, ruling that the mandates were a reasonable safety matter. Now, filing an Application for Judicial Review may could have worked, if they took that path.

However, the Posties retained a lawyer, Leighton Grey, who filed a Statement of Claim instead. Rather than challenging the fairness of the Arbitration, he commenced an Action. This was doomed to fail, at least with the company, as the union agreement explicitly prohibited it.

As for the Government of Canada, the Court said that there was enough of a separation between the Federal Government and Canada Post, a Crown Corporation, to hold them liable.

Furthermore, the Statement of Claim was lacking in the necessary information. As is common with Grey, he doesn’t plead the necessary facts (Rule 174) for each Plaintiff, which is required. Despite having nearly 300 Plaintiffs, the Claim was just 18 pages in length. The case was struck without an opportunity to refile.

It turns out that dozens of Plaintiffs wanted to appeal, but Leighton missed the deadline. Clients seemed to be under the impression that a challenge was coming, when none was. If the transcripts are to be believed, they were strung along for months.

In September of 2024, they get a new lawyer, Jason Gratl. While he could have brought a malpractice complaint against Grey — which would get clients some justice — he tries halfheartedly to salvage the lost cause of a case.

One would assume that Gratl would act urgently, given the nature of missing a deadline. However, he sits on a file for nearly 2 months, before bringing a Motion to extend time. It’s dismissed by Associate Justice John Cotter. He then brings another Motion, challenging the refusal.

Timeline Of Events In Arbitration

***It’s important to remember that this didn’t start with a lawsuit. It began with grievances and then arbitration. This matters as it relates to the lack of jurisdiction of the Federal Court.

September 2021: Canada Post announces that it will change the “vaccination” policy, requiring that all employees (and new hires) take the shots in order to be employed. It’s to take effect on November 26th, 2021.

October 26th, 2021 mandatory injection policy is formally approved.

November 15th, 2021: CUPW, Canadian Union of Postal Workers, files grievance against Canada Post’s new policy of requiring the injections in order to stay employed.

January 18th, 2022: Arbitration hearing is held over Canada Post’s policy requiring the injections of all employees. There would be several sessions over the coming months.

January 24th, 2022: Canada Post’s lawyer serves some 700 pages of material related to the arbitration hearings.

February 12th, 2022: Hearing date for arbitration related to Canada Post. Colin Furness, who works for the University of Toronto, testifies.

March 21st, 2022: Hearing date for arbitration related to Canada Post.

March 22nd, 2022: Hearing date for arbitration related to Canada Post.

April 5th, 2022: Final arguments were to be held for arbitration process.

April 27th, 2022: Arbitrator dismisses the grievance against Canada Post, saying that the injection requirement is “reasonable”.

Timeline Of Events In Federal Court Lawsuit

July 12th, 2022: Statement of Claim is filed with the Federal Court. It names: (a) Canada Post Corporation; (b) Her Majesty the Queen, as Elizabeth was Queen at the time; and (c) Attorney General of Canada.

July 18th, 2022: A Notice of Intention to Respond is filed.

November 3rd, 2022: Defendants send correspondence asking for case management, and to suspend normal timelines to file a Defence.

November 23rd, 2022: Associate Judge Catherine A. Coughlan is assigned to manage the case.

January 16th, 2023: Plaintiffs provide letter for dates for case management conference.

April 6th, 2023: Case conference is delayed until May 31st.

May 31st, 2023: Plaintiffs directed to file Amended Statement of Claim by June 15th.

June 19th, 2023: Plaintiffs file Amended Statement of Claim.

July 7th, 2023: Dates are set down for Defendants’ Motions to Strike (throw out the case), and the following deadlines were established. Worth mentioning, these kinds of Motions are done in many steps.

  • August 18th: Defendants serve (but not file) Notice of Motion, and any Affidavit evidence
  • September 15th: Plaintiffs serve (but not file) any Affidavit evidence
  • October 27th: Any cross-examinations on Affidavits is to have finished. This is similar to a Court setting, where a person gets asked about evidence that they submit. Failure to attend means evidence won’t be considered.
  • November 17th: Moving Party Defendants are to submit their Motion Records, which is a collection of documents. In Federal Court, it also includes the written arguments, or submissions
  • December 8th: Responding Plaintiffs to serve and file their Motion Record(s)
  • January 23rd-25th, 2024: Court to hear the Motions

July 10th, 2023: Lawyer for Canada Post contacts the Court and advises a lack of availability for the week in January when the hearing is to take place.

September 5, 2023: Even more Plaintiffs discontinue, or voluntarily leave the case. It worth mentioning that the Court history is filled with various Plaintiffs discontinuing. This is especially prevalent after the Motion to Strike is set out. Seems they realize that their case will go nowhere.

March 4th, 2024: Motions are eventually heard.

March 13th, 2024: Court releases reasons for striking the case.

March 13th, 2024: Order striking case is officially issued.

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.

Timeline Of VERY Late Motion For Appeal Extension

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

Associate Justice Coughlan (a.k.a. a Prothonotary) is the one who struck the case. The 10 day time limit applies, meaning something would have to be filed by March 23rd, 2024.

7. The adverse order and reasons for judgment were issued by Associate Judge Coughlin on March 13, 2024 (the “Decision”). The Decision was provided to the plaintiffs by GWS LLP on March 14, 2024. The plaintiffs then immediately, on March 14, 2024, requested legal advice from GWS LLP on the merits of an appeal.

10. As of April 10, 2024, we believed that the deadline for appealing was 30 days from the date of the decision. Although I had suspected that the deadline might be 10 days from the date of decision in late March of 2024, our legal counsel first advised me in late April of 2024 that the deadline was 1O days from the date of decision.

11. On May 13, 2024, I requested an update from GWS LLP on how the appeal was proceeding. On June 6, 2024, I again requested an update from GWS LLP. On June 19, 2024, I again requested an update from GWS LLP. I am advised by Kim Priest that she repeatedly telephoned GWS LLP to ask for updates on the progress of the appeal and to urge GWS LLP to file the application to extend the deadline.

12. On July 4, 2024, I was advised by Mr. Farquhar, an associate lawyer at GWS LLP, that Ms. Trignani, another associate lawyer at GWS LLP, was no longer working at GWS LLP and she had been working on the appeal. Mr. Farquhar assured me on July 4, 2024, that he, Mr. Farquhar, was now personally working on the application to extend the deadline for the appeal and that it would be prepared shortly.

13. On July 17, 2024, I received application materials, and on July 22, 2024, I provided comments and again instructed GWS LLP to file the application. On July 26, 2024, Mr. Grey of GWS LLP advised that he would no longer be supervising the work on the appeal and that Mr. Farquhar of GWS LLP would be working on the file alone.

14. On September 4, 2024, Mr. Grey advised that Mr. Farquhar was no longer working at GWS LLP, and that Mr. Hershey, the lawyer at GWS LLP who was initially supposed to be working on the appeal under Mr. Grey’s supervision, no longer worked at GWS LLP and that no one else at GWS LLP was able to take on the appeal.

16. We found Grall & Company, a Vancouver-based law firm, in late September of 2024. We agreed in principle to retain Grall & Company to give advice on this appeal on September 22, 2024.

In paragraph 7 of her Affidavit, page 17 in the Motion Record, Karine Solakian states that many Plaintiffs sought advice immediately on the merits of an Appeal. She also states that she found out from Grey for the first time about the 10 day deadline well after it had lapsed.

***Neither Grey nor his assistants ever filed for an extension. Nor does it seem they ever notified the Defendants that an Appeal was in the works.

November 15th, 2024: Gratl files a Notice of Change of Solicitor. It’s unclear why he waited nearly 2 months to do anything.

November 15th, 2024: Gratl files a Notice of Motion, indicating Plaintiffs will be seeking an extension of time to appeal the March ruling. It’s been a full 8 months at this point. Given that it was an Associate Justice who struck the case, the deadline is a mere 10 days.

February 14th, 2025: Gratl files the Motion Record for clients.

February 27th, 2025: The Federal Government files their Responding Motion Record.

February 28th, 2025: Canada Post files their Responding Motion Record.

May 2nd, 2025: Associate Justice Cotter refuses the extension of time.

May 12th, 2025: Gratl brings another Motion, to challenge the refusal to grant an extension of time. This time, the 10 day time limit is met.

June 4th, 2025: The Attorney General of Canada files their Responding Motion Record.

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.

The main concern for this latest Motion is whether or not the previous Motion (an extension of time) should have been refused. The Order cited a few major concerns: (a) lack of explanation for the delay; and (b) the length of the delay was “significant and prejudicial”. The delay was 234 days, over 7 months, of which 53 days were while Gratl was retained.

Interesting, it seems that Grey doesn’t actually do the legal work himself, he just farms it out to the hired help. More coming up in Part 2.

ARBITRATION:
(1) https://www.cupw.ca/sites/default/files/urb-ja-31-2022-ca-en.pdf
(2) Canada Post Collective Bargaining Agreement 2022
(3) Canada Post Arbitration update, February 2022 (removed)
(4) Wayback Machine Archive
(5) CUPW On Some Updates On Arbitration
(6) Wayback Machine Archive On Arbitration Updates
(7) https://www.cupw.ca/en/last-days-arbitration-vaccination-practice-grievance
(8) Wayback Machine Archive Of April 1st, 2022 Update
(9) https://www.cupw.ca/en/arbitrator-dismisses-grievance-against-canada-post%E2%80%99s-mandatory-vaccination-practice
(10) Arbitration Decision (Removed)
(11) Canada Post Arbitration Ruling Redacted
(12) Wayback Machine Archive Of Arbitration Decision
(13) https://www.fct-cf.gc.ca/en/court-files-and-decisions/court-files#cont

LITIGATION (CASE STRUCK):
(1) Canada Post Statement Of Claim (July, 2022)
(2) Canada Post Amended Statement Of Claim (June 7, 2023)
(3) Canada Post Order Timetable (July, 2023)
(4) Canada Post Defendants Motion Record (October, 2023)
(5) Canada Post Plaintiff Responding Motion Record (January, 2024)
(6) Canada Post Plaintiff Responding Motion Record CP (February, 2024)
(7) Canada Post Further Amended Statement Of Claim (February, 2024)
(8) Canada Post Decision Striking Amended Pleading (March, 2024)

LITIGATION (EXTENDING TIME TO APPEAL):
(1) Canada Post Notice Of Change Of Solicitor (November, 2024)
(2) Canada Post Affidavit of Karine Solakian (November, 2024)
(3) Canada Post Notice Of Motion (November 2024)
(4) Canada Post Applicants Motion Record Extension Of Time (February, 2025)
(5) Canada Post Motion Record Extension Of Time (February, 2025)
(6) Canada Post HMTK Motion Record Extension Of Time (February, 2025)
(7) Canada Post Order Refusing Extension Of Time To Appeal (May, 2025)

LITIGATION (APPEAL OF REFUSAL TO EXTEND TIME TO APPEAL):
(1) Canada Post Motion Record Appeal Refusal To Extend Time (May, 2025)
(2) Canada Post HMTK Written Submissions Appeal Time Extension (June, 2025)

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The Pham Case: NGOs Pushed For Foreign Criminals Having More Rights Than Canadians

A disturbing trend has been in the news lately. Recently, a series of cases were published where foreigners received unusually low sentences for criminal convictions, in order to avoid deportation. Since the 2013 Supreme Court ruling in Pham, there has been a requirement to view “immigration consequences” when handing down punishment.

What’s even more unsettling is how this came to happen. A foreign drug trafficker received a 2 year sentence on a Joint Submission (agreement), but seemed to have realized after the fact that it would mean deportation.

For context: under the rules at the time, non-citizens who received a jail sentence of 2 years (or more) were excluded from many appeal options to avoid deportation. Removal was pretty much automatic. However, those convicted and receiving lesser punishment still had more prospects of staying. This was later reduced to a 6 month limit.

Hoang Anh Pham was sentenced to 2 years in prison for drug possession, for the purposes of trafficking. On Appeal, he asked that it be reduced by a day, to avoid deportation. The Court of Appeal, in a split decision, rejected it. However, the Supreme Court of Canada granted Leave (permission) to hear the case, and then did allow it.

What likely tipped the scales was that several Intervenors (interested parties) made submissions to the Supreme Court of Canada. These were:

  • British Columbia Civil Liberties Association (Charity Page)
  • Canadian Association of Refugee Lawyers
  • Canadian Civil Liberties Association (Charity Page)
  • Canadian Council for Refugees (Charity Page)
  • Criminal Lawyers’ Association of Ontario

Various groups weighed in, asking the the Supreme Court require that Judges take immigration consequences into account when imposing sentences. How does this benefit actual Canadians? How does special consideration for foreign criminals create a better society?

Hoang Anh Pham Previously Convicted For Drug Trafficking

[2] The facts as disclosed at trial were that the appellant was involved in a three-stage marijuana grow operation consisting of 591 plants at various stages of growth. It was estimated that the value of this crop ranged from $461,718 (if sold by the pound) to $738,750 (if sold by the ounce). An additional 28 grams of marijuana was found in two freezer bags in the freezer compartment to the refrigerator on the main floor.

[3] At the subsequent sentencing hearing, the appellant’s prior criminal record was entered as an exhibit. It disclosed that on December 12, 2000 the appellant had been convicted of one count of failing to attend court (section 145(2)(a) of the Criminal Code), one count of trafficking in a scheduled substance (section 5(1) of the CDSA) and one charge of possession of a scheduled substance for the purpose of trafficking (section 5(2) of the CDSA). At that time, the appellant had received a sentence of one day in gaol on the first count and a three month conditional sentence order, concurrent, on each of the other two charges.

[4] At the sentencing hearing in this case, the appellant’s then counsel and Crown counsel urged upon the sentencing judge, by way of joint submission, a sentence of imprisonment for two years. The Crown cited as aggravating factors that the appellant had benefitted financially and that he had not learned his lesson from his previous encounter with the criminal justice system.

From the Alberta Court of Appeal, we can see that Pham was already a convicted drug trafficker when this sentence was handed down.

Prosecutors Complicit With Sentence Reduction

[32] Returning to the case at bar, the appellant has previously been convicted of three offences. In 2000, he was convicted of failing to attend court, trafficking in a scheduled substance, and possession of a scheduled substance for the purposing of trafficking. For the first offence, he was sentenced to one day in jail; he received a three month conditional sentence for the other two charges. Now there is the more recent drug- related conviction, which resulted in the two year prison term he asks us to reduce. Illegal drugs are a tremendous scourge on our society. The appellant’s repeated contribution to the problem, albeit modest in the large scale of things, would normally disqualify him from leniency. However, as the prosecution has consented to this appeal, I would agree to allow it with the caveat that in future cases, this relief will not be there simply for the asking.

In a dissenting opinion with the ABCA, Justice Martin mentioned that the prosecution had consented to the appeal, which would have reduced the sentence. So, even though he was argued that he “clearly hadn’t learned his lesson”, the Crown is still okay with reducing the sentence to help prevent deportation.

1. B.C. Civil Liberties Association

2. The BCCLA submits that failure to consider the immigration consequences of a sentence would deprive the court of information required to properly consider the relevant sentencing factors, and may result in a sentence which unjustly infringes an offender’s rights and freedoms.

3. Immigration consequences must be taken into account by a sentencing judge in order to ensure that the offender is not punished more than necessary. A permanent resident convicted in Canada and sentenced to two years or more is almost certain to face deportation. For many permanent residents, deportation will be the most punitive impact of their sentence. In order to ensure that sentences are consistent with the principles of proportionality and restraint, the BCCLA submits that immigration consequences are relevant personal circumstances which should be taken into account as part of the individualized sentencing assessment.

2. Canadian Council For Refugees

4. Given that a non-citizen who has been convicted of a criminal offence may face removal from Canada, it is the CCR’s submission that the judge imposing the sentence must take into account the impact that the sentence will have on the availability of remedies for the retention of status in Canada. This is based on the following reasoning:

9. Non-citizens whose human rights will be infringed by removal are entitled to have their interests considered by a competent, independent and impartial decision maker prior to removal. A scheme was created for consideration of such interests under the Immigration and Refugee Protection Act (IRPA). Relevant to this appeal, this obligation is met in the equitable appeal which is available to permanent residents and Convention refugees who face removal because of a criminal conviction but who have received a sentence of less than two years.

17. It is submitted therefore that a judge, exercising a judicial discretion in relation to the imposition of an appropriate sentence for a crime committed, ought to take into account the impact that the sentence will have on the availability to a non-citizen of a hearing which is fully in compliance with the principles of fundamental justice under s. 7 of the Charter in relation to that person’s status in Canada.

Of course, these aren’t anywhere near all of the filed documents. However, they do illustrate what the main concerns being raised are.

The Supreme Court also has the video of the hearing posted on its website, even years later. It’s worth a watch.

51:30: Canadian Association of Refugee Lawyers begins, and brings up the possible ineffective assistance of counsel argument.
1:02:00: Criminal Lawyers Association of Ontario begins.
1:08:00: British Columbia Civil Liberties Association begins.
1:13:41: Canadian Council for Refugees begins.
1:19:15: Canadian Civil Liberties Association begins.
1:38:30: Respondent (Government) begins.

While the Government (initially) asked that the case be remitted back to the Court of Appeal, at the hearing, they simply consented to the Appeal being allowed.

This should make Canadians’ blood boil. Registered “charities” are getting significant tax breaks while they try to implement caselaw to give preferential treatment to foreign criminals.

Conservative Bill A Trojan Horse?

At the risk of jumping to conclusions, consider a recent video from Michelle Rempel-Garner. She proposes a Private Member’s Bill to amended the Criminal Code. In her words, Judges “should not” be able to take immigration status into account. It’s at the 2:00 mark.

Should not?

How about cannot? Or must not? Or are prohibited from?

While this may come across as pedantic, this choice of wording would allow Judges to retain discretion as to whether or not they consider immigration status. There would merely be a recommendation against doing so, not an outright ban.

Does she not realize that every lawyer with a foreign convicted criminal for a client will be arguing that their case is exceptional?

We’ll have to see what happens.

COURT RULINGS:
(1) https://www.canlii.org/en/ab/abca/doc/2012/2012abca203/2012abca203.html
(2) https://www.canlii.org/en/ca/scc-l/doc/2012/2012canlii68768/2012canlii68768.html
(3) https://www.canlii.org/en/ca/scc/doc/2013/2013scc15/2013scc15.html

SUPREME COURT OF CANADA:
(1) https://www.scc-csc.ca/cases-dossiers/search-recherche/34897/
(2) Pham Factum Appellants Factum
(3) Pham Factum Respondents
(4) Pham Factum Appellants Reply
(5) Pham Factum BC Civil Liberties Association
(6) Pham Factum Canadian Association Of Refugee Lawyers
(7) Pham Factum Canadian Civil Liberties Association
(8) Pham Factum Canadian Council For Refugees
(9) Pham Factum Criminal Lawyers Association Of Ontario

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Anti-SLAPP Ruling Upheld: When “Recycling” Your Defamation Cases Goes Horribly Wrong

A long awaited Court of Appeal decision has finally been handed down. Justices Zarnett, Young and Favreau have upheld a December 2023 ruling from Justice Chalmers of the Ontario Superior Court. That initial verdict saw a $1.1 million defamation case against CSASPP thrown out under anti-SLAPP laws, with $132,000 in costs awarded. Another $10,000 in costs was ordered in this subsequent ruling.

CSASPP is of course the Canadian Society for the Advancement of Science in Public Policy. In January 2021, it began a Proposed Class Action against Bonnie Henry and the Government of British Columbia. This has been covered elsewhere on this site.

See here, here and here for background information.

That said, a hilarious detail seems to have been overlooked. The case against CSASPP was almost entirely borrowed from an earlier defamation case…. against this website. To clarify, there were 2 separate actions, with overlapping allegations.

[1] This website was sued in September 2021 for detailed criticism of various anti-lockdown cases.

[2] CSASPP and its staff were sued in June 2022 over much, MUCH more mild criticism, and to silence a fomer donor from complaining to the Law Society of Ontario.

Given that this there were 2 different lawsuits, with very different circumstances, one would expect that 2 very different cases would have been prepared. Instead, it seems that the documentation for the first case was simply repackaged and reused for the second case. From the ruling:

[86] …. Finally, because of evidence in the appellant’s own materials of other extremely vitriolic and sustained criticisms of him by others, including the publication “Canuck Law”, he found that if there was damage to the appellant’s reputation, it was not shown to have been caused by the respondents, as opposed to other sources.

[91] The difficulty with the appellant’s submission is the motion judge’s causation finding. The motion judge referred to the evidence from the appellant of a concerted campaign against him by a group known as “Canuck Law” who was not a party to his action. The motion judge stated: “the [appellant] references the group extensively in the material filed on this motion. In articles posted on the Canuck website, the [appellant] was the subject of disparaging and racist comments”. Referring to that and some judicial criticism, he concluded that there was no evidence that any damage to the appellant’s reputation was caused by the respondents, as opposed to other sources.

As an aside, the “racist comments” referred to in the CSASPP case actually came from a site called Overdue Revolutions. It was just misrepresented that they originated here.

Not only are anti-lockdown cases being recycled, but defamation ones are as well. By filing evidence that someone else may have engaged in character assassination, it completely undermines the claims that CSASPP had been responsible.

Whatever happened to taking pride in one’s work?

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

CSASPP/RG APPEAL DOCUMENTS (2024)
(1) CSASPP Defamation Appellant Factum
(2) CSASPP Defamation Respondent Factum
(3) https://www.covidconstitutionalchallengebc.ca/status-updates
(4) https://www.scribd.com/document/768627727/2024-09-12-Notice-of-Merit-Hearing-13-January-2025
(5) https://www.scribd.com/document/758138683/2024-08-06-Defendant-Respondents-Motion-Record-to-Dismiss-for-Delay

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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