Category: Types of Law

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Universal Ostrich Farms, Part 3: The Bilinski Affidavit, And Immune Biosolutions

Universal Ostrich Farms (UOF), in British Columbia, has been in the alternative media a lot lately. Specifically, the Canada Food Inspection Agency (CFIA) ordered about 400 birds to be killed after some supposedly tested positive for the H5N1 virus.

UOF filed an Application in Federal Court to challenge the order. A second Application was filed challenging the refusal to grant any sort of exemption. To date, both cases have been dismissed. Barring a successful Appeal, the culling is expected to go ahead.

See Parts 1 and 2 in the Universal Ostrich Farms series for more information.

The first two pieces have interestingly caused quite the backlash. The bulk of it is simply reading from various Court documents, including Affidavits. What people don’t seem to grasp is that when someone asks for money, it becomes public interest litigation. The have GiveSendGo and GoFundMe pages up, among other avenues, soliciting donations.

As such, their case is open to scrutiny, or at least it should be.

Now, let’s see what David Bilinski has to say.

From The Affidavit Of David Bilinski

13. One of the problems we encountered though was there was no good breeding records for ostriches. To starts a recording program, I initiated a DNA fingerprinting program for ostriches in Canada. I worked wit Dr. Kim Cheung, a director of the Avian Research Centre at the University of British Columbia, to develop this program.

14. Unfortunately, shortly after starting the program, the market for breeding ostrich collapsed, and the program was suspended.

19. The antibodies ostriches produce in response to an infection can last several years, and are found in extremely high concentrations in the yolks of their eggs. These antibodies can be used to develop neutralization anitbodies against, among other things, the H5N1 virus. I have attached as Exhibit “B” a true copy of the study published by Dr. Yasuhiro Tsukamoto, Laboratory of Veterinary Anatomy, Graduate School of Biology and Environmental Sciences, Osaka Prefecture University.

34. When the COVID-19 pandemic hit in March 2020, it essentially shut down our business. Processing plants closed, breeder sales plummeted, and farms downsized.

35. We then became familiar with the work of Dr. Tsukamoto, who was studing the IgY Immune Globin Yolk) antibodies in ostrich eggs.

36. Based on Dr. Tsukamoto’s and others’ research, we learned that ostrich eggs are uniquely situated for developing antibodies because of the size of the yolk, and the concentration of the antibodies produced.

39. As a result, we began working with [Immune] Biosolutions Inc. (“Biosolutions”) in Quebec, which was working on protocols to produce antibodies for Covid-19, due to a $13,000,000 grant from the Government of Canada.

40. In or around 2021, Biosolutions provided antigens to the UOF, which then allowed us to produce antibodies using the ostrich eggs.

42. Then, in about 2022, UOF began a venture with Struthio BioScience Inc. (“Struthio”) and entered into a contract wherein UOF must provide Struthio with ostrich eggs, failing which UOF would be in breach of contract.

43. In summary, since 2020 UOF has been entirely dedicated to the production of antibody IgY.

44. To be clear, UOF is not a commercial poultry facility, and it does not produce any ostrich meat or eggs for human consumption.

It would be nice to know more about this DNA fingerprinting program, even if it was ultimately cancelled. Perhaps a later piece can cover that.

Bilinski tries to portray to the Court there being a “contract” between Universal Ostrich Farms and Struthio BioScience Inc. This is apparently to fulfill business obligations. However, Karen Espersen is both the owner (and president) of UOF, and a co-owner of Struthio. This connection is obvious when looking at her LinkedIn page, but isn’t clear in the Court documents.

Defenders of the farm have pointed to the fact that Immune Biosolutions is the one that got the contract from the ISED, not the farm. While true, it misses the point. Espersen and Bilinski are working with them, and using their antigens, giving it to the ostriches, and creating antibodies in return.

In turn, it then raises all kinds of questions as to what exactly these birds are infected with, and what the risks are to humans. This apparently isn’t explained in any Affidavit.

Despite howls about “protecting the food supply”, Bilinski’s Affidavit makes it clear that these animals aren’t intended for any sort of human consumption. This ostrich farm really is an open-air biolab.

The irony also seems lost on these litigants. They’re challenging the findings that some of the birds are infected with a virus, claiming that these tests are unreliable. Fair enough. But then, the birds are used to generate antibodies to fight another virus. In fact, they stand to make a fortune if they’re able to sell their work.

Oh well. Live by the shady “science”, die by the shady “science”.

Now, let’s find out a little more about their partner.

Taxpayer Money Funneled Through ISED For Grants

The Government of Canada, or more specifically, Innovation, Science and Economic Development Canada, announced a few years ago various projects would be funded. Taxpayers would foot a $2.3 billion bill for 41 different grants, all across the country.

Immune Biosolutions, of Sherbrooke, Quebec, was just one company.

March 16, 2021: Up to $13.44 million to help through the Strategic Innovation Fund (SIF) to develop and advance its therapeutic candidate from pre-clinical studies up to Phase II clinical trials.

Perhaps it would be more accurate to describe groups it partners with as “subcontractors”.

Who Is Immune Biosolutions?

A partnership in antibody development
Our antibody discovery platform is available mainly to pharmaceutical and biotech companies seeking to develop custom novel antibodies against targets of interest with unmet needs. Whether the desired antibody is for therapeutic or diagnostic purposes, our avian platform opens up the accessibility to new antibody paratopes of great affinity against highly conserved mammal proteins or molecules.

Immune Biosolutions is a Quebec company that “partners” with other people or companies in their antibody development. This is the research and development end, while the others are the ones who receive and do the live testing.

Immunization:

  • Spatial Peptide design and synthesis for antigen presentation
  • Chicken Immunization by vaccination (Peptides, Spatial Peptides, Proteins, Nucleic Acids, Cells, other molecules)
  • Chicken Immunization by transcutaneous electroporation (Protein expression DNA plasmid)

Screening:

  • Phage-Display Antibody Candidate Screening:
  • Chicken Single B Cell Antibody Candidate Screening
  • Avian Antibody Sequence Determination
  • Next Generation Sequencing (NGS) Antibody Library Analysis

Engineering and Production:

  • Avian Antibody Optimization & Humanization
  • Bi-Specific and Multi-Specific Antibody Engineering
  • Antibody Production & Purification
  • Stable Cell Line Development

Validation (Antibody Validation):

  • Affinity Assays
  • Functional Assays
  • Flow Cytometry
  • Biolayer Interferometry
  • Surface Plasmon Resonance
  • Static Light Scattering/Dynamic Light Scattering

Immune Biosolutions Has Lobbying Registry Profile

Application Form for COVID-19 Advancement of Vaccines and Therapeutics (SIF Program) Immune Biosolutions and collaborators are developing an immunotherapy based on newly identified antibodies to treat and possibly prevent the SARS-CoV-2 infection (COVID-19). This new accelerated discovery process, aiming at providing Canadians with a treatment for COVID-19 discovered and bio-manufactured in Canada, will be applied to future infections and other diseases, such as cancer.

It shouldn’t really surprise anyone that this company is set up to lobby members of the Federal Government for funding. Their name wasn’t picked randomly.

SOURCE OF FUNDING DATE AMOUNT
Canexport April, 2020 $22,754.38
Canexport April, 2021 $22,754.38
Canexport April, 2023 $22,754.38
Canexport April, 2024 $27,500.00
Innovation, Science and Economic Development Canada April, 2023 $5,496,072.00
Innovation, Science and Economic Development Canada April, 2024 $2,082,706.00
Innovation, Science and Economic Development Canada April, 2024 $5,496,072.00
National Research Council April, 2020 $33,108.69
National Research Council April, 2021 $33,108.69
National Research Council April, 2023 $33,108.69
National Research Council April, 2023 $212,219.00
National Research Council April, 2024 $212,219.00
National Research Council April, 2024 $222,880.00
SIF – Strategic Innovation Fund April, 2024 $5,496,072.00

Note: while there appear to be duplicate entries, the notes from the Lobbying Registry suggest that a few agencies made multiple payments in the same fiscal year.

Immune Biosolutions Received Wage Subsidies

As an aside, Immune Biosolutions received CEWS (the Canada Emergency Wage Subsidy) in 2020/2021. In fairness though, it doesn’t specify the amounts.

Now, there has been a lot of noise about how it was Immune Biosolutions that got the Government grant, not Universal Ostrich Farms itself. This misses the point. While the tech company may have gotten it directly, what was UOF using to pay its bills in the meantime?

2 scenarios are possible. Either: (a) UOF got a cut of the money directly from IBio, or; (b) UOF would make money from selling the research, thus profiting from taxpayer subsidies. While the grant went to the firm, this seems to be a distinction without a difference.

People need to be asking the hard questions.

(1) https://ised-isde.canada.ca/site/biomanufacturing/en/biomanufacturing-projects-underway
(2) https://immunebiosolutions.com/en
(3) https://immunebiosolutions.com/en/partnerships/
(4) https://lobbycanada.gc.ca/app/secure/ocl/lrs/do/vwRg?cno=368226&regId=914362#regStart
(5) https://apps.cra-arc.gc.ca/ebci/habs/cews/srch/pub/bscSrch
(6) https://unlockalberta.substack.com/p/christine-massey-david-dickson-pat

FEDERAL COURT DOCUMENTS:
(1) Ostrich Notice Of Application Certified (January, 2025)
(2) Ostrich Notice Of Application (January, 2025)
(3) Ostrich Notice Of Motion (January, 2025)
(4) Ostrich Bilinski Affidavit (January, 2025)
(5) Ostrich Espersen Affidavit (January, 2025)
(6) Ostrich Pelech Affidavit (January, 2025)
(7) Ostrich Jones Affidavit (January, 2025)
(8) Ostrich Responding Motion Record (January, 2025)
(9) Ostrich Responding Motion Record Expedited (February, 2025)
(10) Ostrich Motion Record Ex-Parte (February, 2025)
(11) Ostrich Exemption Notice Of Application (February, 2025)
(12) Ostrich Exemption Motion Record (February, 2025)
(13) Ostrich Ruling Of Justice Zinn (May, 2025)

MONEY:
(1) https://bcrising.ca/save-our-ostriches/
(2) https://www.gofundme.com/f/help-ostrich-farmers-fight-to-save-herd-from-avian-flu?attribution_id=sl%3A80e09934-7413-429b-acfb-2f7015cc19d3&lang=en_CA
(3) https://www.givesendgo.com/save-our-ostriches
(4) https://www.kinexus.ca/

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Military Veterans’ Injection Pass Case: Idiot Lawyer Sends Notice Of Appeal To Wrong Court

Just when you think a lawyer couldn’t be any dumber, you are unpleasantly surprised.

This is a follow-up on the Qualizza case, the military veterans’ injection pass lawsuit. Some 330 members and former members of the Canadian Armed Forces sued over the requirement to get the shots. The case is turning into a regular content generator, and for all the wrong reasons.

The Notice of Appeal will be explained in more detail later.

See parts 1, 2, 3 and 4 for background on the case.

Perhaps even more absurdly, the lawyer, Catherine Christensen, practiced family law for much of her career. She seems horribly out of her league here.

The case is currently before the Federal Court of Appeal. It had been struck by an Associate Judge, with a subsequent Judge refusing a request to extend time for an initial Appeal. Another Judge ordered costs over an unnecessary Motion to determine the contents of an Appeal Book. More recently, another Judge ordered costs for a Notice of Discontinuance being filed without clients’ knowledge or consent.

Now, Christensen is unhappy with the ruling that she acted in a “high handed and inappropriate” way. So, she’s set to challenge to Order, which set aside the Notice of Discontinuance.

But according to Court records, she attempted to file a Notice of Appeal. That’s right, she wants to appeal an Order of the Federal Court of Appeal, and sent the Notice …. to the same Court. She seems not to understand that you can only appeal to a higher level.

Christensen doesn’t seem to grasp the difference between:
(a) Commencing a proceeding: Claim, Application, Appeal, etc….
(b) Taking steps within the existing proceeding: typically with a Motion

Perhaps she meant to file a Motion to have that last Order reviewed, but it’s unclear. In any event, she was told that in order to appeal, she must ask for Leave (permission) from the Supreme Court of Canada.

This idiot is trying to appeal to the wrong Court.

Keep in mind, none of this helps any of her clients advance their case against the Federal Government. Nothing here helps overturn A.J. Coughlan’s decision to strike, or Justice Manson’s refusal to grant an extension.

But first, problems with the lawsuit shouldn’t be a surprise to Christensen.

The Neri Decision: Christensen Knew Claim Would Be Struck

An Application filed in late 2021 sought to prevent several members of the Canadian Armed Forces from facing consequences for refusing the injections. An Interlocutory Injunction was sought, with the plan to get a permanent one later. The case was tossed, because Section 29 of the National Defence Act specified a grievance scheme for members of the military to use.

The case was discontinued in January 2022.

The point is: Christensen knew in advance of filing the Qualizza case that it would very likely be struck for lack of jurisdiction. It seems doubtful that current clients were aware of this case.

Not only was Christensen aware of jurisdiction issues, but the Statute of Limitations should have been fresh in her mind as well. September 2024, she lost another case, Tondreau, in Federal Court. A major part of the ruling was her filed the Notice of Application well after the 30 day deadline.

Qualizza Case Struck Without Leave To Amend

Associate Judge Catherine Coughlan struck the case in November 2024, and without Leave to Amend. This meant there was no permission to fix and refile. While lengthy, the decision centered on 2 main issues.

First: The Statement of Claim lacked a lot of the necessary information. When making Charter Claims, it’s required to plead certain facts and details about each Plaintiff. While there was background information on each of them, nothing was pleaded about the specifics of the torts themselves.

Second: The Court refused to take jurisdiction of the case over s.29 of the National Defence Act This was the exact issue explained to Christensen in Neri. Not only was the grievance system required, but over 100 Plaintiffs either had or were actively grieving.

Because Coughlan was an Associate Judge (Prothonotary), and not a regular Judge, there’s a difference process to appeal. More importantly, there’s a much shorter time limit.

Christensen Missed Deadline For 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

The specific errors were covered extensively in a previous article. An extension was refused.

Just as with Tondreau a few months earlier, Christensen missed the deadline to file, and never really offered a convincing explanation of why that was the case.

Christensen Doesn’t Understand What’s Being Appealed

After Justice Manson refused to extend time in the Federal Court, Christensen filed Notice of Appeal in the Federal Court of Appeal. But there’s already a serious problem.

The Notice asks that the original Order of A.J. Coughlan be set aside and that the case be allowed to proceed. That may be fine as additional Relief being sought.

However, the Notice doesn’t challenge Justice Manson’s decision to refuse an extension of time. The most immediate problem is that the Plaintiffs/Appellants are time-barred into going further, unless that is overturned. In the “grounds” section, it’s shrugged off as procedural error. Again, without being challenged.

She also asks for Leave to file the Notice of Appeal. This doesn’t make any sense, as this is the Notice, and it’s already been filed. And it gets worse from here.

Determining Contents Of Appeal Book

The Federal Court of Appeal differs from its Provincial counterparts in a significant way. Specifically, it requires the Appellants to either: (a) get consent as to the contents; or (b) file a Motion to have a Judge determine it.

For a recent example of what a consent looks like, see the Payne Appeal.

Christensen chose Option “B”, while the Government responded that this was entirely unnecessary.

Justice Rennie agreed that this could have been resolved on consent.

(b) No argument is advanced by the appellants why the materials that were before the Associate Judge but not before Manson J., ought to be before this Court;

(c) Rule 343(2) requires parties to an appeal to include in an appeal book “only such documents, exhibits and transcripts as are required to dispose of the issues on appeal”. Although the Rule 343(2) test is a flexible one, a document should be included in the appeal book “only if there is a reasonable basis for concluding that it is required to dispose of an issue on appeal”

This highlights Christensen’s lack of understanding of what she’s doing. She’s appealing Justice Manson’s refusal to extend time to allow that Rule 51 Appeal. As such, only the few documents that were before him would be considered by this Court.

Christensen “Discontinued” Without Clients’ Knowledge Or Consent

Christensen’s clients were apparently unhappy with her mediocre legal services, and many refused to pay additional money to her “non-profit”. Consequently, she filed a Notice of Discontinuance of their behalf.

Procedurally though, this cannot be done.

One client, Mark Lolacher, took it upon himself to file his own Motion to set aside the Notice, and to be reinstated. He also accused Christensen of misconduct. The Government lawyer offered a suggestion allow Lolacher to remain, but as a self-represented litigant. Surprisingly, Christensen opposed the Motion.

Ultimately, Justice Locke ordered Lolacher’s reinstatement as an Appellant, and $2,000 for the “high handed” treatment he had received. The reasons were scathing, although misconduct allegations were to be deferred to the Law Society of Alberta.

The Judge also mentioned 2 practical solutions. Christensen could be replaced as counsel, under Rule 124, or she could file a Motion to withdraw as counsel, under Rule 125. Neither happened, and she apparently got her own lawyer. Keep in mind, bickering and fighting with clients doesn’t advance the vaccine passport case at all. Remember, this was supposedly the reason for the lawsuit in the first place.

As a humourous aside: Lolacher is the only Plaintiff/Appellant in this case have actually won a Motion. Christensen has racked up loss after loss, and all at her clients’ expense.

Christensen Apparently Has Her Own Counsel

The Court filings are admittedly just a small part of what’s been going on. Still, it’s fair to say that things have further deteriorated.

According to further correspondence from Mark Lolacher, Christensen isn’t following Justice Locke’s Order in good faith. She keeps misrepresenting a procedural Motion as “suing the other Appellants”. Now, she apparently has her own counsel…. while still representing all (or some?) of the clients. It’s a mess. Will clients now be billed for 2 lawyers?

Christensen is apparently unwilling to accept Justice Locke’s decision reinstating Lolacher. Instead of taking a reasonable alternative, she tries to file a Notice of Appeal…. to the same Court.

Have to wonder who came up with the idea: Christensen, or her new “counsel”? In any event, the Federal Court of Appeal refused to file the Notice, since procedurally, it would have to go to the Supreme Court of Canada. Actually, the SCC would have to agree to hear it first, with an Application for Leave. The staff at the Courts apparently know the Rules better than either of these lawyers.

Again, none of this helps any of their clients.

It’s hard to believe that a licenced lawyer can actually be so bad at what she does. Sure, this could all be deliberate sabotage, but it’s so poorly done that it strains all belief.

It seems that Law Societies will allow anyone to practice, even a potted plant.

FEDERAL COURT/CLAIM STRUCK:
(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 Order Striking Statement Of Claim Without Leave November 2024

FEDERAL COURT/RULE 8 MOTION TO EXTEND TIME/RULE 51 APPEAL:
(1) Qualizza Plaintiffs Motion To Extend Time To Appeal December 2024
(2) Qualizza Defendants Respond To Motion To Extend Time To Appeal December 2024
(3) Qualizza Order Denying Extension Of Time January 2025
(4) Qualizza Federal Court Notes

FEDERAL COURT OF APPEAL/CONTENTS OF APPEAL BOOK:
(1) Qualizza Notice Of Appeal January 2025
(2) Qualizza Motion Record Contents Of Appeal Book February 2025
(3) Qualizza Responding Motion Record Contents Of Appeal Book March 2025
(4) Qualizza Order Contents Of Appeal Book April 2025

FEDERAL COURT OF APPEAL/MARK LOLACHER REINSTATEMENT:
(1) Qualizza Notice Of Discontinuance January 2025
(2) Qualizza Lolacher Motion Record March 2025
(3) Qualizza Lolacher A.G. Responding Motion Record March 2025
(4) Qualizza Lolacher Christensen Responding Motion Record March 2025
(5) Qualizza Lolacher Order For Reinstatement May 2025
(6) Qualizza Lolacher Reasons For Reinstatement May 2025

FEDERAL COURT OF APPEAL/VENDETTA AGAINST LOLACHER:
(1) Qualizza Lolacher Letter To Court May 2025
(2) Qualizza Federal Court Notes FCA

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WestJet Forced To Pay Over Refusal To Accommodate Religious Objection To Injection Mandate

A Calgary Court has now ruled that WestJet improperly terminated an employee over the 2021 vaccination mandates, and didn’t adequately provide alternatives.

Justice Argento awarded Duong Yee $65,587.72, or the equivalent of 11 months of her salary. After more than 11 years of employment, she was terminated in the Fall of 2021, for refusing to take the injections. She had tried — but failed — to obtain an exemption on religious grounds.

Many lawsuits in recent years have invoked religious beliefs. However, this is a rarer one that actually details what those beliefs are. The case was pursued by Jody Wells and James Kitchen.

Yee didn’t challenge the Government policy itself, but how it was implemented. While not a repudiation to the injection pass in general, this is nonetheless a nice win showing that some exemptions can be protected.

Although many have referred to this as suing WestJet, there were in fact 3 Defendants: (a) WestJet, an Alberta Partnership; and its Partners (b) Westjet Airlines; and (c) 2222304 Alberta Corp.

The lawsuit sought $100,000 for economic and other harms:

  • $66,500 for severance pay
  • $12,000 for benefits
  • $21,500 for “moral damages” or aggravated damages
  • Costs

While Yee did get an award for severance pay, and presumably the benefits lumped in, the request for damages was denied. The Judge said that none had been proven, and there was nothing overly insensitive or egregious in how the company had acted.

WestJet further argued that Yee failed to mitigate her damages (improve her own situation), but that was rejected by the Court.

Quotes From WestJet Exemption Questionnaire

Question #6. Explain why you are requesting an accommodation:

Based on sincerely held beliefs as a bible believing Christian, the vaccine is betrayal of faith to my healer, Lord and Saviour Jesus Christ.

Question #7. Describe the accommodation you are seeking:

Exemption from vaccination; from masks; from rapid testing

Question 9. Describe how you are a practicing member of this religion:

I attend online worship and sermons with my church, I have a weekly bible study with my church group to continue understanding God’s word, as well as my own daily prayer, worship and bible readings to commune with my heavenly father.

Question #10. How long have you been a practicing member of this religion?

Over 3 years

Question #11. Explain the connection between your religious belief(s), your objection to receiving a COVID-19 vaccine and the accommodation you are seeking:

Jesus is my healer, I do not cannot rely on the use of vaccinations or medicines created artificially in order to prevent sickness. Jesus speaks of seeking out a doctor when one is sick, not well. I have no need of a vaccine in order to maintain my health.

Question #19. Do you belong to any groups (social media or otherwise) protesting or denouncing or being critical of Covid-19 measures taken by health authorities and government bodies?

Yes

Question #20. Please describe the groups of which you are a member:

I have joined groups that are peacefully seeking a community to support our freedoms; ie. conscience, religion, beliefs; choice – Jesus came to set the captives free and that we are not to live in bondage. This can be include those being critical of the covid measures, but that is not my purpose for belonging to these groups

Question #21. Do you have any concerns about the safety of any Health Canada-approved Covid-19 vaccines?

Yes, many reports of adverse reactions and death in the last 4 months of covid vaccines alone compared to last 17 years of all vaccines according to VAERS. -Severe reactions include: Inability to conceive, heart attacks, miscarriages, strokes; bloodclots, paralysis of arms and legs, reproductive dysfunction.- No long term safety has been completed to ensure they are safe and effective.-mRNA is a new technology and side effects completely unknown – Never been licensed for human use when 0 long term studies have been competed [sic] to ensure they are safe and effective, they are still in phase 3 experiment that will not be completed until trial ends late 2022.

Interestingly, when WestJet asks a direct question about practical concerns people may have, this is used as “evidence” that their objection is a personal opinion, and not a protected ground.

WestJet has carefully reviewed your request for an accommodation, including the information listed above. For the reasons stated below, WestJet declines your request for an accommodation on the basis of religion:

• The information provided or obtained in reviewing your accommodation is insufficient to establish you require an accommodation. More specifically, the information you provided to WestJet casts doubt on religion being the grounds for your application. You have written in your application form that you consider the vaccine unsafe. It is therefore reasonable to consider that you are philosophically/personally opposed to mandatory vaccine, which means you are seeking accommodation for secular reasons, not religious. We respect your opinion, but personal preference is not a Protected Ground.

One has to wonder what kind of answer Yee was supposed to give. If she had no concerns about the shots, why wouldn’t she have just taken them?

Justice Argento Accepts Argument Termination Unnecessary

[101] First, the Plaintiff’s conduct was not insubordination or disobedience of a type where the employment relationship could not continue and the misconduct was irreconcilable with continued employment. The Plaintiff continued working after her accommodation request was denied on October 4, 2021 until she was placed on unpaid leave on November 1, 2021. She continued to meet deadlines and her manager described her performance as “professional” leading up to November 1, 2021. There was no evidence that her non-compliance with the Vaccination Policy negatively impacted the workplace, other employees or the Defendant’s trust in her ability to do her job.

[102] The Plaintiff’s refusal to comply with the Vaccination Policy did not impact her job performance. It did not endanger the Defendant’s employees or the public as the Plaintiff was working from home. While a future, partial return to work was anticipated, that was not yet implemented. The issue of cause must be assessed based on what was known and understood at the time of dismissal.

[104] Next, in balancing the competing interests of the parties, it is significant that dismissal was not the only option available to the Defendant. Even though the Defendant’s Vaccination Policy stipulated that anyone failing to comply would be subject to discipline up to and including termination for cause, the Defendant did not have to proceed in this fashion.

Aside from pleading the exemption issue, the Plaintiff pointed out that she had already been working remotely for several months. This presumably could continue.

Justice Argento comments that the decision to dismiss Yee was likely unnecessary in any event. This wasn’t the sort of conduct that would destroy an employment relationship, nor was it one that would result in a lost of trust.

And most importantly, it wouldn’t endanger anyone since Yee was working from home.

WestJet Plays Games With Issue Of Jurisdiction

11. While the Plaintiff references the words “wrongful dismissal” or “wrongful termination” the substance of her claim is entirely that of a human rights complaint based on allegations of discrimination; the concept of wrongful termination itself is tied to WestJet’s failure to accommodate the Plaintiff. The duty to accommodate is an obligation of employers enshrined in human rights legislation, and WestJet’s purported failure to accommodate the Plaintiff is squarely in the purview of a human rights commission. The Civil Claim even seeks general damages for the duration of the reasonable notice period, which is a remedy only available to a human rights commission as compensation for the pain and suffering caused by discrimination.

24. The Plaintiff further claims that WestJet ceded jurisdiction of this action to this Court. With all due respect, this is inaccurate. In response to the Plaintiff’s Canadian Human Rights Complaint, and prior to the Civil Claim being filed, WestJet made a preliminary objection to the complaint on the basis that it would more appropriately be addressed under the Canada Labour Code by the Canadian Industrial Relations Board (“CIRB”). At no point has WestJet stated that this Court, or any civil court for that matter, has, or ought to have jurisdiction of a claim entirely based on an allegation of discrimination.

These passages are from the Defendants’ written submissions. For context, it’s important to realize the Yee filed a human rights complaint before suing anyone. WestJet objected, saying it would be better placed before the Industrial Relations Board (CIRB) for Arbitration. The complaint was dropped.

WestJet now complains that this lawsuit should have been filed with the Human Rights Tribunal, raising a jurisdictional issue.

While the submissions say that the preferred venue is the CIRB, this is a bit of a red herring. WestJet initially objected to jurisdiction of the Human Rights Tribunal, so they can’t really claim that it should be there after all.

The Defendants tried to argue that at its core, this wasn’t a case about breach of contract or wrongful termination. It was about discrimination and failure to accommodate. It was unsuccessful.

Note: While WestJet is a unionized employer, not all employees and contractors are covered. Mrs. Yee wasn’t, and hence, there was no duty to grieve and seek arbitration.

Timeline Of Major Events In Case

May 17th, 2010: Yee begins her employment with WestJet. At the time, she was working part time as a sales agent.

May, 2021: Yee comes back from maternity leave, and begins working remotely.

September 8th, 2021: WestJet announces their vaccination requirements.

September 20th, 2021: Yee requests a vaccine exemption.

October 4th, 2021: The request for an exemption is refused.

October 30th, 2021: The deadline imposed by WestJet for vaccination.

November 1st, 2021: Yee is placed on a month long unpaid suspension.

December 1st, 2021: Yee’s employment is terminated by WestJet, and they claim it is “with cause”.

August 15th, 2023: Yee sues WestJet in the Calgary Branch of the Alberta Court of Justice.

February 24th, 2025: Trial begins.

May 13th, 2025: Judgement is issued.

The Court declined to make an immediate decision on costs, allowing the parties the opportunity to settle them first. This may very well happen.

COURT DOCUMENTS:
(1) Yee WestJet Statement Of Claim
(2) Yee WestJet Plaintiffs Written Submissions
(3) Yee WestJet Defendants Written Submissions
(4) Yee WestJet Reasons For Decision
(5) https://www.canlii.org/en/ab/abcj/doc/2025/2025abcj87/2025abcj87.html

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The Payne Appeal: What This s.2(d) Challenge Will Look Like

The Federal Government is appealing a shocking ruling from January which allowed a Proposed Class Action to proceed. Despite expectations to the contrary, Justice Richard Southcott (mostly) dismissed a Motion to Strike.

The challenge was organized by the group, Feds For Freedom. It’s comprised of 3 Representative Plaintiffs, all from different areas of the public sector.

  • Department of National Defence (Stacey Helena Payne)
  • Correctional Services Canada (John Harvey)
  • Federal Economic Development Agency for Southern Ontario (Lucas Diaz Molaro)

They had their employment threatened in late 2021 with the introduction of the vaccine passport. Unlike earlier challenges, this one survived, due to the innovative arguments raised.

This lawsuit challenged not the mandates themselves, but the manner in which they were implemented. The case argued that there effectively were no grievance options because of this.

It’s not being hyperbolic to say this will impact employment rights at the Federal level. Either freedom of association is a valid ground to challenge such mandates, or there may not be any option at all.

What Happened With Justice Southcott’s Decision

Right of employee
208 (1) Subject to subsections (2) to (7), an employee is entitled to present an individual grievance if he or she feels aggrieved
.
(a) by the interpretation or application, in respect of the employee, of
(i) a provision of a statute or regulation, or of a direction or other instrument made or issued by the employer, that deals with terms and conditions of employment, or
(ii) a provision of a collective agreement or an arbitral award; or
(b) as a result of any occurrence or matter affecting his or her terms and conditions of employment.

No Right of Action
Marginal note: Disputes relating to employment
.
236 (1) The right of an employee to seek redress by way of grievance for any dispute relating to his or her terms or conditions of employment is in lieu of any right of action that the employee may have in relation to any act or omission giving rise to the dispute.

The initial Motion to Strike was based on s.208 and s.236 of the FPSLRA, or the Public Sector Labour Relations Act. In short, employees have the right to grieve, but not to sue. This is similar to how unionized workplaces function in general.

The Statement of Claim revolved around 2 torts:

  1. Section 2(d) of the Charter, freedom of association, and
  2. Malfeasance of Public Office

First, the s.2(d) argument was that the injection pass was implemented in a heavy handed manner, without due process or meaningful consultation. As such, it circumvented any legitimate grievance process. The result is that it deprived workers of their right to freedom of association, within the context of voluntary employment.

Second, the way in which this was implemented amounted to an abuse of process and malfeasance of office by the politicians involved.

Justice Southcott accepted the first argument, that this was potentially a s.2(d) breach. However, he ruled that malfeasance was an issue that could be grieved. There was one caveat though: because there would likely be more Plaintiffs in this Class Action, it’s possible that one could be found who didn’t have that grievance right, such as a summer student.

The s.2(d) tort was allowed to proceed, while the malfeasance was struck, with Leave to Amend.

The implications are far reaching. If the s.2(d) argument was left standing, there would be precedent to prevent any such future infringements on employee rights. Unsurprisingly, the Crown appealed.

Ottawa Claims Southcott Should Have Refused Jurisdiction

28. The motion judge erred by taking jurisdiction over any aspect of the plaintiffs’ claim. First, he erred in law by failing to apply the correct legal test. Instead of assessing whether the dispute related to a matter that could be grieved under the FPSLRA, he relied on the fact that a similar issue could not be grieved under the labour relations regime that was at issue in Morin. Had the motion judge rendered his decision based on the language of s. 208, he would have found it plain and obvious that the matter could be grieved regardless of whether it was characterized as a dispute over the terms and conditions of employment or a dispute over the process by which terms and conditions were changed.

29. Second, and in any event, the motion judge committed palpable and overriding errors in accepting that the essential nature of the plaintiffs’ s. 2(d) claim related only to process. He wrongly assumed that the essential character of the dispute would be different for each of the two causes of action pled. This approach was contrary to consistent appellate authority holding that a court’s characterization of the essential nature of a dispute must be based on the facts giving rise to the dispute, and not by the legal characterization of the wrong. Since none of the material facts pled related to the process by which the Vaccination Policy was adopted, it was a palpable and overriding error to conclude that that was the essential character of the dispute.

In their filings, the Government lawyers argue that the nature of the case involves changes to the terms and conditions of employment. Section 208 FPSLRA gives everyone grievance rights, so logically, implementing the vaccine mandates should be covered.

Respondents Say Justice Southcott Made No Errors

39. Southcott J. did not err by allowing the plaintiffs’ Charter claim to survive the motion to strike.
Next, Southcott J. did not commit palpable and overriding error in his consideration of the plaintiffs’ Charter claim. Indeed, he did not engage in any such analysis because the sufficiency of the plaintiffs’ s. 2(d) claim was not even challenged by the appellant. The appellant’s motion materials include several references to the insufficiency of the plaintiffs’ misfeasance claim, but includes no such reference to the plaintiffs’ s. 2(d) claim

40. There is a “stringent” test for allowing new arguments on appeal: a new issue should only be considered “where [the Court] is able to do so without procedural prejudice to the opposing party and where the refusal to do so would risk an injustice.” The appellant has failed to identify any “exceptional circumstances” permitting it to challenge this cause of action for the first time on appeal. Nor has it explained how Southcott J. committed palpable and overriding error by not considering an argument that the appellant itself did not raise.

41. Further, any such arguments would have failed as the plaintiffs’ have pled an arguable Charter claim. The appellant here takes an unduly narrow view of the Claim contrary to the holistic and generous approach required in interpreting pleadings on a motion to strike.

47. As written by Southcott J., the plaintiffs alleged “that the Treasury Board acted with reckless indifference or willful blindness in issuing the Policy in that… it had no basis in fact to justify the Policy as a measure to prevent transmission of the virus.” Specifically, the Claim states that the Treasury Board mandated vaccination for the stated purpose of preventing transmission of COVID-19 but, in so doing, ignored the potential inefficacy of the vaccines, the potentially serious adverse effects, and the significant detriment that could have been suffered by the plaintiffs, among others. The incongruity between the Treasury Board’s knowledge and its stated intention is demonstrative of bad faith and/or dishonesty. Similar pleadings have been found to meet the standard of reasonable pleadings on a motion to strike.

50. Lastly, the appellant argues that leave to amend should not have been and cannot be granted in this case. Once again, the appellant reiterates its argument at the motion stage: the Claim ought to have been grieved. Southcott J. considered and rejected this argument. He found that it was plausible that the Federal Court had jurisdiction, at least over the Charter allegations, such that the Claim could survive this preliminary motion.

The Respondents take the position that Justice Southcott made no major errors with the ruling, and that the case ought to proceed.

Interestingly, the Appellants (Government) are now questioning whether or not the s.2(d) was pleaded with sufficient detail, an argument they didn’t raise at the initial hearing.

Keep in mind, this was just a Motion to Strike. It’s a look at the pleadings themselves. This isn’t meant to be a deep dive into the facts or the evidence.

Brief Timeline Of Major Events In Case

October 6th, 2023: Statement of Claim is filed on behalf of 3 Representative Plaintiffs.

November 9th, 2023: Government responds with their Notice of Intent.

May 31st, 2024: Government sends notice that it intends to bring Motion to have the case struck (thrown out) in its entirety.

June 6th, 2024: Prothonotary Ring gives directions that there be case management.

June 10th, 2024: Chief Justice Crampton directs (a) Justice Southcott and (b) Prothonotary Ring to be assigned manage the proceeding.

July 1st, 2024: Prothonotary Ring issues schedule for documents to be served for Motion to Strike.

August 19th, 2024: Government brings its Motion to Strike.

October 1st, 2024: Plaintiffs file responding arguments as to why case shouldn’t be struck.

December 13th, 2024: Motion to Strike is argued before Justice Southcott.

January 1st, 2025: Justice Southcott partially grants the Motion to Strike. The tort of Malfeasance of Public Office is struck, but with Leave if eligible Plaintiffs are identified. The Section 2(d) claims are allowed to proceed.

January 13th, 2025: Notice of Appeal is filed.

January 21st, 2025: Notice of Appearance is filed.

February 12th, 2025: Parties file their agreement as to what the contents of the Appeal Book will be. This is a requirement unique to the Federal Court of Appeal.

March 14th, 2025: The Appeal Book is filed.

April 14th, 2025: Appellants file their written arguments.

May 14th, 2025: Respondents file their written arguments.

Payne Part Of Series Of s.2(d) Challenges In Canada

CASE NAMES PAYNE/BCPSEF HILL/UHCWBC/UHCWO
Government Workers? Yes No
Filed Federally? Payne Hill
Filed in B.C.? BCPSEF UHCWBC
Filed in Ontario.? n/a UHCWO
Wrongful Termination by Gov’t? Yes No
Inducement to Breach Contract? No Yes
Breach s.2(d) Charter Rights? Yes Yes
Malfeasance of Public Office? Yes Yes

See parts 1, 2, 3, 4, 5 and 6 in this series.

All 5 of these cases (from Ontario, B.C. and the Federal Courts) involve the Section 2(d) tort in some way. How it applies differs somewhat between them.

Payne involves employees of the Federal Government, whereas Hill involves employees of Federally regulated industries, specifically, the airlines. While unionized, WestJet and Air Canada aren’t part of the Government. The airlines don’t use the FPSLRA, and the Government lacks standing to invoke the collective bargaining agreement of other people.

These subtle, but important differences explain why Payne was appealed, but Hill wasn’t.

There’s a similar distinction between the B.C. Government employees case and the health care workers one. Likewise in Ontario, Plaintiffs aren’t directly employed by Government there either.

We’ll have to see how Payne plays out, but this case could easily end up before the Supreme Court. It’s not an exaggeration to say that there will be long lasting implications on employment rights, at least at the Federal level.

PAYNE APPEAL DOCUMENTS:
(1) Payne Notice Of Appeal January 2025
(2) Payne Notice Of Appearance January 2025
(3) Payne Agreement To Contents Of Appeal Book February 2025
(4) Payne Joint Appeal Book March 2025
(5) Payne Appellants Memorandum Of Fact And Law April 2025
(6) Payne Respondents Memorandum Of Fact And Law May 2025

PAYNE FEDERAL COURT DOCUMENTS:
(1) Payne Statement Of Claim October 2023
(2) Payne Notice Of Intent To Defend November 2023
(3) Payne Letter Intent To Strike May 2024
(4) Payne Defendant Motion Record To Strike August 2024
(5) Payne Plaintiff Responding Motion Record October 2024
(6) Payne Transcript Of Southcott Hearing December 2024
(7) https://www.canlii.org/en/ca/fct/doc/2025/2025fc5/2025fc5.pdf
(8) https://www.canlii.org/en/ca/fct/doc/2025/2025fc5/2025fc5.html

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Discontinued: Client Forced To Abandon Injection Pass Case After Leighton Withdraws

A former employee at Canadian Natural Resources Limited (or CNRL) dropped his lawsuit, which had been filed in Calgary. Bradley Miles did so as a self-representing litigant, despite previously having counsel.

At least the Notice of Discontinuance was done on a “without cost” basis. That means that he won’t have to pay the lawyers for CNRL. He’s still out whatever fees he paid to his own lawyer, and the money he lost from being terminated, or at least, suspended without pay.

This brings to 10 (and counting) vaccine passport cases Grey has commenced, only to have dropped or abandoned. The search results are still coming in

CNRL Claims Miles Was Offered His Job Back

In the Statement of Claim, the Plaintiff states that he should be entitled to return to work in the same position he was previously in.

12. On December 2, 2021, Canadian Natural sent the Plaintiff a letter warning him that he was non-compliant with the Vaccination Policy and that, effective December 1, 2021, his site access was suspended with pay. The Plaintiff was warned that if he failed to provide proof that he had received a second dose of an approved COVID-19 vaccine by December 21, 2021, he would continue to be non-compliant with the Vaccination Policy and would be suspended without pay.

13. On December 22, 2021, the Plaintiff was suspended without pay due to his continued non-compliance with the Vaccination Policy.

14. On or around March 15, 2022, in response to the reduced number of COVID-19 cases in Alberta, and the Alberta government’s easing or removing public health protocols in respect of COVID-19, Canadian Natural sent a letter to employees on unpaid suspension for non-compliance with the Vaccination Policy, including the Plaintiff, advising that Canadian Natural was ending certain COVID-19 measures effective April 4, 2022, including the requirement that Workers be fully vaccinated. The Plaintiff was notified that his unpaid suspension would end effective April 4, 2022, and that he was required to return to his work location and role at Canadian Natural on that date.

15. In that letter, Canadian Natural asked employees to indicate whether they intended to return to work at Canadian Natural. Canadian Natural did not receive a response from the Plaintiff regarding his intention, or lack thereof, to return to work. Rather than return to work, the Plaintiff commenced his claim against Canadian Natural.

16. As of April 4, 2022, employees previously suspended without pay for non-compliance with the Vaccination Policy were returned to work by Canadian Natural to their same position.

In their Statement of Defence, CNRL claims that Miles was offered his position back in April 2022, but he didn’t respond. Instead, he sued the company in September 2022. But since the case was dropped, we won’t know for sure what the full truth is.

“Poison Pills” Slipped Into Statement Of Claim

E. Criminal Assault
44. Forcing a medical intervention on employees under threat of loss of livelihood is a clear violation of the Criminal Code of Canada (“CCC”) which states in part:

265(1) A person commits an assault when
(a) Without consent of another person he applies force intentionally to the person directly or indirectly..
265(3) For the purposes of this Section, no consent is obtained where the complainant submits or does not resist by reason of…
(d) The exercise of authority. [emphasis added]

45. Forcing employees to be vaccinated under threat of loss of livelihood is a violation of the CCC. Every member of the CNRL Board who supports the Policy supports the criminal assault of his or her fellow employees and coworkers.

Like many of Leighton’s cases, he includes content that makes explicitly criminal allegations. He knows — or ought to know — that this cannot be adjudicated in a CIVIL proceeding. In fact, the Statement of Claim would have been struck for this alone.

The claim also goes on to argue what would better be described as “expert evidence”. This doesn’t belong in the initial pleadings, and would come later.

Shouldn’t a King’s Counsel/Queen’s Counsel lawyer know better?

Timeline Of This CNRL Case

September 2022: Statement of Claim is filed in Calgary.

March 2023: Statement of Defence is filed.

November 2024: The case is discontinued.

According to the information provided by the Alberta Courts, there doesn’t seem to have been any real urgency to move the case along. It never got past the initial pleadings.

Timeline Of Leighton Grey’s Injection Passport Cases

See Parts 1, 2, 3, 4, 5, 6, 7, and 8 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.
  10. November 29th, 2024: Grey’s former client (Bradley Miles) discontinues his 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. This specific case doesn’t invoke an arbitration requirement as a defence, but most do.

Strange, isn’t it? The “alternative” media will announce all kinds of new lawsuits being filed. However, they very rarely will report on how they end.

COURT DOCUMENTS:
(1) Miles Statement Of Claim September 2022
(2) Miles Statement Of Defence March 2023
(3) Miles Notice Of Discontinuance November 2024

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CSASPP Class Action Certification Application Still Under Reserve 2 Years Later

It has been a full 2 years since the Certification hearings concluded between CSASPP (the Canadian Society for the Advancement of Science in Public Policy), the British Columbia Government, and Provincial Health Officer, Bonnie Henry. No ruling has been made yet.

The Government is also asking the Court to strike the case altogether. While surviving such Applications is usually straightforward, a class proceeding complicates things.

The stakes are very high. If certified, the case would potentially create millions of Plaintiffs.

The hearings began in December of 2022, and were expected to conclude in a single week. That didn’t happen, so a week in April 2023 was needed to finish them off. Then, the decision was deferred.

Unfortunately, there’s no way to make any progress until this is settled once and for all.

In fairness to Justice Crerar, he has a big workload to deal with.

That being said, people do need an answer as to whether or not this case will be certified. 2 years is a long time to make a decision, even with an undertaking of this size. Hopefully, one will come soon.

Timeline Of Major Events In Case

January, 2021: The case was initially filed in January 2021 as a Proposed Class Action.

March, 2021: The B.C. Government responds to the lawsuit.

June, 2021: Plaintiffs bring their proposal for case management.

July, 2021: Defendants bring their own proposal to manage the case.

September, 2021: Notice of Civil Claim is amended.

December, 2022: Certification hearings start, but take longer than originally anticipated. They were intended to be completed over a single week.

April 2023: Certification hearings resume, taking up another week. The decision is under reserve, meaning it will be issued later. However, Justice Crerar would still make several subsequent requests for submissions based on related cases happening elsewhere.

July, 2023: Ingram, the disaster of a ruling, is brought to Justice Crerar’s attention. This is the Alberta ruling that struck down orders on a technicality (Cabinet interference), but otherwise okayed them in principle.

September, 2023: Bonnie Henry’s lawyer objects to CSASPP filing a Petition against the vaccine passport for health care workers, claiming the existing litigation amounts to a duplication, and hence, abuse of process.

April, 2024: Justice Crerar sends notice that he will likely be issuing a decision on the Certification Application within a month or so. As a result, CSASPP forwards several recent rulings on related issues. But, the ruling is further delayed.

May, 2024: Bonnie Henry’s lawyers are invited to make further written submissions.

April, 2025: Randy Hillier’s win at the Ontario Court of Appeal is forwarded.

So, When Will The Decision Be Made?

There’s no way to answer this.

Justice Crerar has since released decisions in other cases, although, they’re much simpler in scope. The ruling he issues — whatever it is — will impact millions of people. The various requests for submissions suggest that he’s trying to ward off any possibility of an appeal.

For what it’s worth, the overall quality of the filings has been very high. This is night and day different from another case in Vancouver.

It’s a game of hurry-up-and-wait.

LINKS TO REVIEW:
(1) https://justice.gov.bc.ca/cso/index.do
(2) https://www.covidconstitutionalchallengebc.ca/court-documents
(3) https://www.covidconstitutionalchallengebc.ca/status-updates
(4) https://www.covidconstitutionalchallengebc.ca/faq
(5) https://www.covidconstitutionalchallengebc.ca/transparency
(6) https://www.covidconstitutionalchallengebc.ca/hearing-videos
(7) https://www.canlii.org/en/bc/bcsc/doc/2022/2022bcsc2108/2022bcsc2108.html

DOCUMENTS AVAILABLE FROM CASE
(A) CSASPP 20210126 Notice of Civil Claim
(B) CSASPP 20210321 Request for Assignment of Judge
(C) CSASPP 20210331 Response to Civil Claim
(D) CSASPP 20210531 Cease and Desist Letter to Regulators
(E) CSASPP 20210621 CSASPPs Case Plan Proposal
(F) CSASPP 20210621 Dr Bonnie Henrys availability requested
(G) CSASPP 20210731 Defendants Case Plan Proposal
(H) CSASPP 20210813 Requisition for JMC for 1 October 2021
(I) CSASPP 20210817 Demand for Particulars
(J) CSASPP 20210821 Plaintiffs Response to Demand for Particulars
(K) CSASPP 20210913 Oral Reasons for Judgment Short Leave Application Seeking Stay
(L) CSASPP 20210915 Amended Notice of Civil Claim
(M) CSASPP 20211025 Affidavit No 2 of CSASPP Executive Director
(N) CSASPP 20211028 Proceedings in Chambers Defendants Application for Further Particulars
(O) CSASPP 20221101 Affidavit No 3 of Redacted Deponent Redacted
(P) CSASPP 20221102 Dr Henry and HMTKs Application Response for Webcast Application
(Q) CSASPP 20221115 Respondents Requisition Seeking 16 Nov 2022 CPC to Be Held by MS Teams


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