Court Documents
Date: 26 January, 2021
Author: Plaintiff (CSASPP)
File No: S-210831 (Class proceeding for everyone)
Document Type: Pleading
Our Notice of Civil Claim is the formal process by which a suit is commenced. It explains who the parties to the litigation are, what the cause of action is (underlying legal theory that is the basis for the suit), and what we’d like a judge to do about it.
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Date: 4 March, 2021
Author: Plaintiff (CSASPP)
File No: S-210831 (Class proceeding for everyone)
Type: Application
A Request for Assignment of Judge is required for any class proceeding. All class proceedings are judicially managed in British Columbia. This means the same judge presides over all hearings, as opposed to a random one for each application. This is required under Practice Direction No 5. This has been the norm since 2010.
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Date: 31 March, 2021
Author: Defendants (Dr. Bonnie Henry & Provincial Crown)
File No: S-210831 (Class proceeding for everyone)
Type: Pleading
The Defendants’ Response to Civil Claim contains their position and why the government believes it has done nothing wrong.
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Date: 21 June, 2021
Author: Plaintiff (CSASPP)
File No: S-210831 (Class proceeding for everyone)
Type: Case Plan Proposal
Our case plan proposal outlining proposed steps and timelines for this civil proceeding. This document will be tabled before our judge at our judicial management conference currently scheduled for 10 August, 2021.
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Date: 5 July, 2021
Author: Defendants (Dr. Bonnie Henry & Provincial Crown)
File No: S-210831 (Class proceeding for everyone)
Type: Case Plan Proposal
Dr. Bonnie Henry and the Crowns’ case plan proposal outlining proposed steps and timelines for this civil proceeding. This document will be tabled before our judge at our judicial management conference currently scheduled for 10 August, 2021.
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Date: 13 August, 2021
Author: Defendants (Dr. Bonnie Henry & Provincial Crown)
File No: S-210831 (Class proceeding for everyone)
Type: Requisition
CSASPP’s requisition confirming a Judicial Management Conference to be held by consent of the parties on 1 October, 2021, at 9 AM for one hour by telephone.
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Date: 30 August, 2021
Author: Plaintiff (CSASPP)
File No: S-210831 (Class proceeding for everyone)
Type: Response to Demand for Particulars
CSASPP’s response to Dr. Bonnie Henry and the Crown’s request for additional details in relation to CSASPP’s claim.
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Date: 30 August, 2021
Author: Plaintiff (CSASPP)
File No: S-210831 (Class proceeding for everyone)
Type: Letter
CSASPP provides notice to Dr. Bonnie Henry and the Crown that it intends to seek injunctive relief against the new provincial health order announced 23 August, 2021. The order will require individuals to provide proof of injections to access a broad range of venues. It is difficult to challenge when the order has not been made public, so a copy is requested from the defendants.
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Date: 3 September, 2021
Author: Defendants (Dr. Bonnie Henry & Provincial Crown)
File No: S-210831 (Class proceeding for everyone)
Type: Letter
The defendants’ response to our letter of 30 August, 2021. We are advised that the injection passport order is not publicly available and that no timeline for its availability was provided either.
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Date: 13 September, 2021
Author: Transcriber
File No: S-219760 (Petition opposing injection passport)
Type: Transcript and reasons for judgment
Transcript of the exchange between Registrar Nielsen, Crown counsel, and CSASPP counsel. This was from our 13 September, 2021, hearing in general chambers seeking short leave to have an application heard seeking a stay of the injection passport public health order.
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Oral reasons for judgment of Registrar Nielsen of the aforementioned.
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Date: 15 September, 2021
Author: Plaintiff (CSASPP)
File No: S-210831 (Class proceeding for everyone)
Type: Amended Pleading
CSASPP Amended Notice of Civil Claim filed and served on the defendants 15 September, 2021. Text that has been underlined has been added. Text that has been struck through has been removed.
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Date: 28 September, 2021
Author: Defendants (Dr. Bonnie Henry & Provincial Crown)
File No: S-210831 (Class proceeding for everyone)
Type: Agenda for Judicial Management Conference
This document was drafted by Crown counsel in consultation with CSASPP. It outlines the agenda to be discussed with Justice Crerar at our Judicial Management Conference of 1 October, 2021.
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Date: 1 October, 2021
Author: Court
File No: S-210831 (Class proceeding for everyone)
Type: Orders (Judicial Management Conference)
Orders made by Justice Crerar on 1 October, 2021, following our Judicial Management Conference. These orders were entered 29 November, 2021.
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Date: 15 October, 2021
Author: Court
File No: S-210831 (Class proceeding for everyone)
Type: Orders (Judicial Management Conference)
This document contains the orders made at our Judicial Management Conference hearing of 10 August, 2021, before Justice Crerar. It was entered by the registry on 15 October, 2021.
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Date: 18 October, 2021
Author: Defendants (Dr. Bonnie Henry & Provincial Crown)
File No: S-210831 (Class proceeding for everyone)
Type: Application
Dr. Henry and the Provincial Crowns' application to seek additional details from CSASPP on the specifics of what the defendants are being sued for. Note that due to a clerical error, this copy provided by the defendants’ does not contain a registry filing stamp.
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Date: 25 October, 2021
Author: Plaintiff (CSASPP)
File No: S-210831 (Class proceeding for everyone)
Type: Application Response
CSASPP's application response to Dr. Henry and the Provincial Crowns' application. The latter seeks additional details from CSASPP on the specifics of what the defendants are being sued for.
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Date: 28 October, 2021
Author: Court
File No: S-210831 (Class proceeding for everyone)
Type: Orders (Chamber Application)
Orders made by Justice Crerar on 28 October, 2021, following Dr. Henry and the Provincial Crowns' application for further and better particulars.
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Date: 28 October, 2021
Author: Transcriber
File No: S-210831 (Class proceeding for everyone)
Type: Transcript
Transcript of the exchange between Crown counsel, CSASPP counsel, and Justice Crerar from 28 October, 2021, in respect to the application of Dr. Henry and the Provincial Crown seeking further and better particulars to CSASPP's amended pleadings of 15 September, 2021.
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Date: 28 October, 2021
Author: Court
File No: S-210831 (Class proceeding for everyone)
Type: Reasons for Judgment
Oral reasons for judgment from Justice Crerar in chambers of 28 October, 2021, in respect to the application of Dr. Henry and the Provincial Crown seeking further and better particulars to CSASPP's amended pleadings of 15 September, 2021.
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Date: 4 November, 2021
Author: Petitioner (CSASPP)
File No: S-219760 (Petition opposing injection passport)
Type: Petition
Petition seeking judicial review of the defendants’ injection passport public health orders.
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Date: 4 November, 2021
Author: Petitioner (CSASPP)
File No: S-219760 (Petition opposing injection passport)
Type: Affidavit
Executive Director’s affidavit in support of our petition seeking judicial review of the respondents’ injection passport public health orders.
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Date: 8 November, 2021
Author: Plaintiff (CSASPP)
File No: S-210831 (Class proceeding for everyone)
Type: Response to Demand for Particulars
CSASPP's Response to Demand for Particulars of Dr. Henry and the Provincial Crown, pursuant to the order of Justice Crerar in chambers of 28 October, 2021. The defendants sought further and better particulars to CSASPP's amended pleadings of 15 September, 2021.
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Date: 26 November, 2021
Author: Petitioner (CSASPP)
File No: S-2110229 (Petition for health care workers)
Type: Petition
CSASPP’s petition on behalf of all health care workers affected by an injection mandate.
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Date: 26 November, 2021
Author: Petitioner (CSASPP)
File No: S-2110229 (Petition for health care workers)
Type: Affidavit
Affidavit by CSASPP's Executive Director in support of CSASPP's petition opposing an injection mandate to all affected health care workers.
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Date: 26 November, 2021
Author: Petitioner (CSASPP)
File No: S-2110229 (Petition for health care workers)
Type: Affidavit
Affidavit by Laurie Bridge, petitioner counsel’s paralegalist, in support of CSASPP's petition opposing an injection mandate to all affected health care workers.
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Date: 10 January, 2022
Author: Plaintiff (CSASPP)
File No: S-210831 (Class proceeding for everyone)
Type: Application
The Plaintiff’s application seeking class certification.
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Date: 14 January, 2022
Author: Plaintiff (CSASPP)
File No: S-210831 (Class proceeding for everyone)
Type: Letter
A letter from the plaintiff to the Court regarding facilitating public access to hearings.
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Date: 21 January, 2022
Author: Respondent (Dr. Bonnie Henry)
File No: S-2110229 (Petition for health care workers)
Type: Response to Petition
Dr. Henry's response to CSASPP's petition of 26 November, 2021. The latter was brought on behalf of all health care workers affected by an injection mandate.
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Date: 21 January, 2022
Author: Court
File No: S-210831 (Class proceeding for everyone)
Type: Orders (Judicial Management Conference)
Various procedural orders made by the Hon. Justice Crerar on 21 January, 2022, and entered by the Registry 14 March, 2022. These orders grant CSASPP's request to amend its certification application by 15 February, 2022, the defendants a time extension for responding materials, and a new judicial management conference scheduled for 21 April, 2022.
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Date: 28 February, 2022
Author: Petitioner (CSASPP)
File No: S-2110229 (Petition for health care workers)
Type: Petition
CSASPP’s amended petition on behalf of all health care workers affected by an injection mandate. The original was filed and served on the respondent 26 November, 2021. This amended version was filed 28 February, 2022.
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Date: 12 April, 2022
Author: Defendants (Dr. Bonnie Henry & Provincial Crown)
File No: S-210831 (Class proceeding for everyone)
Type: Affidavit
Affidavit No 1 of Dr. Brian Emerson, Deputy Provincial Health Officer.
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Date: 3 May, 2022
Author: Plaintiff (CSASPP)
File No: S-210831 (Class proceeding for everyone)
Type: Application
CSASPP’s application to amend pleadings to insert additional representative plaintiffs and other amendments.
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Date: 4 May, 2022
Author: Court
File No: S-2110229 (Petition for health care workers)
Type: Reasons for judgment
Justice Coval in his reasons for judgment rules that CSASPP has public interest standing.
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Date: 3 June, 2022
Author: Plaintiff (CSASPP)
File No: S-210831 (Class proceeding for everyone)
Type: Application
CSASPP's application seeking certification of its proposed class proceeding. Returnable 12-16 December, 2022, before Justice Crerar. Some redactions have been applied.
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Date: 26 July, 2022
Author: Plaintiff and Defendants (Dr. Bonnie Henry & Provincial Crown)
File No: S-210831 (Class proceeding for everyone)
Type: Agenda for Judicial Management Conference
This document was drafted by both CSASPP and Crown counsel. It outlines the agenda to be discussed with Justice Crerar at our Judicial Management Conference of 28 July, 2022.
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Date: 2 August, 2022
Author: Respondent (Dr. Henry)
File No: CA48599 (Appealing Chief Justice’ ruling in S-219760)
Type: Notice of Abandonment
Justice Coval awarded CSASPP public interest standing on 4 May, 2022. Dr. Henry provided notice she wished to appeal his ruling. On 2 August, 2022, she abandoned her pursuit of an appeal.
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Date: 12 September, 2022
Author: Court
File No: S-219760 (Petition opposing injection passport)
Type: Reasons for judgment
Chief Justice Hinkson’s ruling on CSASPP’s petition opposing the injection passport.
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Date: 7 October, 2022
Author: Appellant (CSASPP)
File No: CA48599 (Appealing Chief Justice’ ruling in S-219760)
Type: Notice of Appeal
Chief Justice Hinkson issued his ruling on CSASPP’s petition opposing the injection passport on 12 September, 2022. It was dismissed on technical grounds. This document formally initiates the appeal process in the British Columbia Court of Appeal.
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Date: 12 October, 2022
Author: Respondent (Dr. Henry)
File No: CA48599 (Appealing Chief Justice’ ruling in S-219760)
Type: Notice of Appearance
Dr. Henry's formal confirmation that her counsel will participate in CSASPP's appeal Chief Justice Hinkson's ruling dismissing its injection passport petition on technical grounds.
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Date: 14 October, 2022
Author: Petitioners (counsel for third party petitioners, not us)
File No: S-2110229 (Petition for health care workers)
Type: Requisition - General
Peter Gall, a lawyer for a petition that is to be heard concurrently with CSASPP's health care workers' injection passport petition, requested a judicial management conference for the morning of 19 October, 2022, before Justice Coval, to discuss several procedural issues relating to admissible evidence.
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Date: 20 October, 2022
Author: Plaintiff (CSASPP)
File No: S-210831 (Class proceeding for everyone)
Type: Affidavit
CSASPP's Executive Director's affidavit in support of its open court application. Note that due to a minor clerical error, this affidavit should have been assigned ordinal 4 and not 3.
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Date: 26 October, 2022
Author: Plaintiff (CSASPP)
File No: S-210831 (Class proceeding for everyone)
Type: Notice of Application
CSASPP's application for allowing offline video recording and archival of the certification hearing. It does this by refining the constitutionally protected definition of an open court in a contemporary context. This application was returnable, at the time of filing, 7 November, 2022, before Justice Crerar.
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Date: 27 October, 2022
Author: Petitioners (CSASPP)
File No: S-2110229 (Petition for health care workers)
Type: Letter
Cover letter for CSASPP's further amended petition for health care workers'. This letter was served on Dr. Henry with the accompanying revised petition of the same date.
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Date: 27 October, 2022
Author: Petitioners (CSASPP)
File No: S-2110229 (Petition for health care workers)
Type: Petition
CSASPP’s third revision of its health care workers’ petition. It makes several amendments necessary to address Dr. Henry’s 12 September, 2022, public health order.
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Date: 28 October, 2022
Author: Petitioners (CSASPP)
File No: S-2110229 (Petition for health care workers)
Type: Letter
CSASPP’s letter to Dr. Henry requesting she provide the scientific basis for her orders.
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Date: 28 October, 2022
Author: Petitioners (CSASPP)
File No: S-2110229 (Petition for health care workers)
Type: Letter
CSASPP requests Dr. Henry re-assess the underlying circumstance which gave rise to her 12 September, 2022, public health order which affected health care workers in hospitals. This is for CSASPP's health care workers' petition. The request is made under s. 45 of the Public Health Act, SBC 2008, c. 28.
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Date: 1 November 2022
Author: Respondent (paralegalist for Dr. Henry)
File No: S-210831 (Class proceeding for everyone)
Type: Affidavit
This document forms part of the materials provided by Dr. Henry's counsel in opposition to CSASPP's application to webcast the certification hearing in our class proceeding. It is an affidavit provided by a para legalist in the Legal Services Branch of the BC AG. Some good faith redactions have been performed on our part to protect their identity.
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Date: 2 November 2022
Author: Respondent (Attorney General of British Columbia)
File No: S-210831 (Class proceeding for everyone)
Type: Application Response
This document forms part of the materials provided by Dr. Henry's counsel in opposition to CSASPP's application to webcast the certification hearing in our class proceeding. It sets out the basis for why the Attorney General opposed our application.
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Date: 2 November 2022
Author: Respondent (Dr. Henry & Provincial Crown)
File No: S-210831 (Class proceeding for everyone)
Type: Application Response
This document forms part of the materials provided by Dr. Henry's counsel in opposition to CSASPP's application to webcast the certification hearing in our class proceeding. It sets out the basis for why Dr. Henry and the Provincial Crown opposed our application.
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Date: 7 November, 2022
Author: Court
File No: S-210831 (Class proceeding for everyone)
Type: Reasons for judgment
Justice Crerar’s reasons for judgment in respect to our application to webcast our certification hearing.
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Date: 15 November, 2022
Author: Respondent
File No: S-2110229 (Petition for health care workers)
Type: Requisition - General
Dr. Henry’s requisition to set down a case planning conference for 16 November, 2022, before Justice Coval.
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Date: 23 November, 2022
Author: Respondent
File No: S-2110229 (Petition for health care workers)
Type: Application (unfiled)
Dr. Henry’s application to strike various affidavits.
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Date: 29 November 2022
Author: Plaintiff (CSASPP)
File No: S-210831 (Class proceeding for everyone)
Type: Affidavit
Affidavit of Zubin Parihar in support of CSASPP’s application seeking class certification.
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Date: 30 November, 2022
Author: Petitioner
File No: S-2110229 (Petition for health care workers)
Type: Application Response
CSASPP’s response to Dr. Henry’s application to strike various affidavits.
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Date: 13 January, 2023
Author: Defendants (Dr. Bonnie Henry & Provincial Crown)
File No: S-210831 (Class proceeding for everyone)
Type: Requisition
Dr. Henry and the Provincial Crown's requisition to set down a continuation of the class proceeding's certification hearing set to resume 24 April, 2023, for five days. This follows the previous five days that began on 12 December, 2022. Both sets of dates were mutually agreed upon by the parties.
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Date: 13 January, 2023
Author: Court of Appeal Registrar
File No: CA48599 (Appealing Chief Justice’ ruling in S-219760)
Type: Letter
BC Court of Appeal Registrar rejects Dr. Henry's request for a preliminary mootness application in CSASPP's appeal of Chief Justice Hinkson's dismissal of the petition challenging the injection passport.
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Date: 16 January, 2023
Author: Defendants (Dr. Bonnie Henry & Provincial Crown)
File No: S-210831 (Class proceeding for everyone)
Type: Affidavit
Affidavit No 3 of Dr. Brian Emerson, Deputy Provincial Health Officer, in response to CSASPP's request for particulars of 21 December, 2022. Dr. Emerson claims that the BCCDC is not a party to this proceeding because it is a program of the Provincial Health Services Authority. The defendants intend to rely upon this affidavit at the certification continuation scheduled to resume 24 April, 2023.
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Date: 16 January, 2023
Author: Appellant (CSASPP)
File No: CA48599 (Appealing Chief Justice’ ruling in S-219760)
Type: Factum
CSASPP's factum in its appeal of Chief Justice Hinkson's ruling of 12 September, 2022, dismissing the plaintiffs' constitutional challenge. The latter sought judicial review of the injection passport public health orders of Dr. Bonnie Henry. The original reasons for judgement are indexed as Canadian Society for the Advancement of Science in Public Policy v. British Columbia, 2022 BCSC 1606.
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Date: 28 February, 2023
Author: Court
File No: S-2110229 (Petition for health care workers)
Type: Reasons for judgment
Justice Coval's reasons for judgment of 28 February, 2023, dismissing the petitioners' applications to augment the evidentiary record that was before Dr. Henry at the time she issued her orders mandating injections for health care workers.
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Date: 7 March, 2023
Author: Petitioners (CSASPP et al.)
File No: S-2110229 (Petition for health care workers)
Type: Letter
CSASPP and other petitioners request a corrigendum of Justice Coval's ruling of 28 February, 2023. The ruling dismissed an application seeking to augment the record in our health care workers' petition.
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Date: 9 March, 2023
Author: Court
File No: S-2110229 (Petition for health care workers)
Type: Letter
Justice Coval acknowledges petitioners' letter of 7 March, 2023, and accepts need for corrections of his ruling of 28 February, 2023. The ruling dismissed an application seeking to augment the record in our health care workers' petition.
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Date: 30 March, 2023
Author: Court
File No: S-2110229 (Petition for health care workers)
Type: Letter
Justice Coval particularizes the corrections he made to his previous ruling of 28 February, 2023, at which time he dismissed Peter Gall's application to augment the evidentiary record.
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Date: 30 March 2023
Author: Court
File No: S-2110229 (Petition for health care workers)
Type: Corrected reasons for judgment
Justice Coval's corrected reasons for judgment of 28 February, 2023, dismissing the petitioners' applications to augment the evidentiary record that was before Dr. Henry at the time she issued her orders mandating injections for health care workers.
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Date: 24 May, 2023
Author: Plaintiff (CSASPP)
File No: S-210831 (Class proceeding for everyone)
Type: Proposed further amended notice of civil claim
Proposed further amended notice of civil claim in our class proceeding. This is a clean copy.
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Date: 5 June, 2023
Author: Plaintiff (CSASPP)
File No: S-210831 (Class proceeding for everyone)
Type: Highlighted proposed further amended notice of civil claim
Proposed further amended notice of civil claim in our class proceeding. This is a marked up copy with proposed changes colour coded.
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Date: 5 June, 2023
Author: Plaintiff (CSASPP)
File No: S-210831 (Class proceeding for everyone)
Type: Letter
Letter to Justice Crerar pursuant to his direction of 28 April, 2023, to address any issues still outstanding following the conclusion of our certification hearing.
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Date: 6 June, 2023
Author: Plaintiff (CSASPP)
File No: S-2110229 (Petition for health care workers)
Type: Discontinuance
Discontinuance of our health care workers' petition.
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Date: 13 June, 2023
Author: Plaintiff (CSASPP)
File No: S-210831 (Class proceeding for everyone)
Type: Requisition
Requisition to set a Judicial Management Conference in our class proceeding before Justice Crerar for 28 August, 2023, at 0900 for one hour. The hearing was requested by Dr. Henry as discussed in our letter to Justice Crerar of 5 June, 2023.
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Date: 29 June, 2023
Author: Plaintiff (CSASPP)
File No: S-210831 (Class proceeding for everyone)
Type: Letter
CSASPP requests details on reasons for Dr. Henry having requested a Judicial Management Conference 28 August, 2023.
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Date: 15 August, 2023
Author: Plaintiff (CSASPP)
File No: S-210831 (Class proceeding for everyone)
Type: Letter
CSASPP provides a mutually proposed schedule for further submissions in respect to our certification application and its accompanying proposed amended pleading.
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Date: 16 August, 2023
Author: Court
File No: S-210831 (Class proceeding for everyone)
Type: Letter
Justice Crerar approves of the schedule proposed in our letter to the Court of 15 August, 2023.
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Date: 29 August, 2023
Author: Respondent (Dr. Henry)
File No: CA48599 (Appealing Chief Justice’ ruling in S-219760)
Type: Factum
Dr. Henry's argument for her application to dismiss CSASPP's injection passport appeal on grounds of mootness. The appeal was brought by CSASPP in respect of Chief Justice Hinkson's ruling striking its petition seeking judicial review of various injection passport related PHOs of Dr. Henry.
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Date: 30 August, 2023
Author: Defendants (Dr. Bonnie Henry & Provincial Crown)
File No: S-210831 (Class proceeding for everyone)
Type: Letter
Crown counsel's cover letter to their supplemental submissions in our class proceeding in respect to our certification application and our recently proposed amended pleading.
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Date: 30 August, 2023
Author: Defendants (Dr. Bonnie Henry & Provincial Crown)
File No: S-210831 (Class proceeding for everyone)
Type: Written submissions
Crown counsel's supplemental submissions in our class proceeding in respect to our certification application and our recently proposed amended pleading.
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Date: 15 September, 2023
Author: Plaintiff (CSASPP)
File No: S-210831 (Class proceeding for everyone)
Type: Letter with written submissions
CSASPP's supplemental submissions in respect to Dr. Henry's of 30 August, 2023. These submissions are in support of our application for leave to amend our pleading as part of our certification application.
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Date: 21 September, 2023
Author: Defendants (Dr. Bonnie Henry & Provincial Crown)
File No: S-210831 (Class proceeding for everyone)
Type: Letter with written submissions
Dr. Henry's supplemental reply submissions in respect to CSASPP's of 15 September, 2023. These submissions oppose CSASPP's application for leave to amend its pleading as part of its application for certification.
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Date: 6 October, 2023
Author: Court
File No: CA48599 (Appealing Chief Justice’ ruling in S-219760)
Type: Reasons for Judgment
Oral reasons for judgment from Justices Groberman, Abrioux, and Skolrood issued 6 October, 2023, and published 12 October, 2023. The judgment is in respect of the respondent’s application to declare the appellants’ appeals as moot. The Court determined that the appeals are moot, but opted to exercise its discretion nevertheless to hear several of them.
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Date: 11 December, 2023
Author: Court
File No: CV-22-00683322-0000 (Galati’s defamation claim)
Type: Reasons for Judgment
Justice Chalmers’ reasons for judgment in the Ontario Superior Court of Justice dismissing Rocco Galati’s claim that was brought in defamation against CSASPP. More information available here.
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Date: 7 February, 2024
Author: Defendants (CSASPP)
File No: CV-22-00683322-0000 (Galati’s defamation claim)
Type: Order
Entered order with the Ontario Superior Court of Justice registry dismissing Galati’s claim and awarding costs on a full indemnity basis to CSASPP in the amount of $132,268.17. More information available here.
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Date: 2 April, 2024
Author: Court
File No: S-210831 (Class proceeding for everyone)
Type: Memorandum to Counsel / Parties
Justice Crerar advises CSASPP and Dr. Henry that he anticipates his ruling on our class action's certification application to be released at some point in April or May 2024.
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Date: 12 April, 2024
Author: Plaintiff (CSASPP)
File No: S-210831 (Class proceeding for everyone)
Type: Letter
CSASPP's letter to Justice Crerar in response to his own of 2 April, 2024. At that time Justice Crerar had requested additional authorities decided since our submissions ended on 29 September, 2023, that bear upon the issues raised in our certification application. We have provided a list of ten authorities with a summary of each.