Court File No. ONTARIO SUPERIOR COURT OF JUSTICE JULIE BILOTTA Plaintiff -and-? COVELL, JACKIE DORAZIO, DELIANE FRASER, S. GARNETT, EMMANUELLE GODIN, ROSE GYASI, ROSALIND GYASI, DOUG HORNER, JANET KAMEI, WILLIAM LAST, DIANE PILON, JENNIFER ROBINSON, JENNIFER SMILEY, CHRISTINA THOMPSON, SHERRY WALSH, STEVEN WILKES, and OTTAWA CARLETON DETENTION CENTRE CORRECTIONAL SERVICES EMPLOYEES JOHN DOE and JANE DOE Defendants STATEMENT OF CLAIM TO THE A LEGAL PROCEEDING HAS BEEN COMMENCED AGAINST YOU by the Plaintiff. The claim made against you is set out in the following pages. IF YOU WISH TO DEFEND THIS PROCEEDING, you or an Ontario lawyer acting for you must prepare a Statement of Defence in Form 18A prescribed by the Rules of Civil Procedure, serve it on the Plaintiff?s lawyer or, where the Plaintiff does not have a lawyer, serve it on the Plaintiff, and ?le it, with proof of service, in this Court of?ce, WITHIN TWENTY DAYS after this Statement of Claim is served on you, if you are served in Ontario. If you are served in another province or territory of Canada or in the United States of America, the period for serving and ?ling your Statement of Defence is forty days. If you are served outside Canada and the United States of America, the period is sixty days. Instead of serving and ?ling a Statement of Defence, you may serve and ?le a Notice of Intent to Defend in Form 18B prescribed by the Rules of Civil Procedure. This will entitle you to ten more days within which to serve and ?le your Statement of Defence. IF YOU FAIL TO DEFEND THIS PROCEEDING, JUDGMENT MAY BE GIVEN AGAINST YOU IN YOUR ABSENCE AND WITHOUT FURTHER NOTICE TO YOU. If you wish to defend this proceeding, but are unable to pay legal fees, legal aid may be available to you by contacting the local legal aid 'office. DATE: SEP 23 2011. ISSUED BY: ?44" Address of Court Of?ce: 161 Elgin Street Ottawa, ON K2P 2K1 TO: Her Majesty the Queen in Right of Ontario c/o Sandra Nishikawa Ministry of the Attorney General Crown Law Of?ce 4 Civil 720 Bay Street, 8th F100r Toronto, ON MSG 2K1 AND TO: Melanie Cochrane c/o Ottawa Carleton Detention Centre 2244 Innes Dr., Ottawa, ON 4C4 AND TO: Covell c/o Ottawa Carleton Detention Centre 2244 Innes Dr., Ottawa, ON Kl 4C4 AND TO: AND TO: AND TO: AND TO: AND TO: AND TO: AND TO: AND TO: AND TO: aekie Dorazio e/o Ottawa Carleton Detention Centre 2244 Innes D11, Ottawa, ON KIB 4C4 Deliane Fraser c/o Ottawa Carleton Detention Centre 2244 Innes D12, Ottawa, ON KIB 4C4 S. Garnett c/o Ottawa Carleton Detention Centre 2244 Innes Dr., Ottawa, ON 4C4 Emmanuelle Godin e/o Ottawa Carleton Detention Centre 2244 Innes Dr., Ottawa, ON 4C4 Rose Gyasi e/o Ottawa Carleton Detention Centre 2244 Innes Dr., Ottawa, ON 4C4 Rosalind Gyasi c/o Ottawa Carleton Detention Centre 2244 Innes D12, Ottawa, ON KIB 4C4 Doug Homer e/o Ottawa Carleton Detention Centre 2244 Innes Dr., Ottawa, ON KIB 4C4 Janet Kamei c/o Ottawa Carleton Detention Centre 2244 Innes D12, Ottawa, ON K1 4C4 William Last e/o Ottawa Carleton Detention Centre 2244 Innes Dr., Ottawa, ON K1 4C4 AND TO: Diane Pilon e/o Ottawa Carleton Detention Centre 2244 Innes Dr., Ottawa, ON 4C4 AND TO: Jennifer c/o Ottawa Carleton Detention Centre 2244 Innes Dr., Ottawa, ON 4C4 AND TO: Jennifer Smiley e/o Ottawa Carleton Detention Centre 2244 Innes Dr., Ottawa, ON 4C4 AND TO: Christine Thompson e/o Ottawa Carleton Detention Centre 2244 Innes Dr., Ottawa, ON KIB 4C4 AND TO: Sherry Walsh c/o Ottawa Carleton Detention Centre 2244 Innes Dr., Ottawa, ON KIB 404 AND TO: Steven Wilkes c/o Ottawa Carleton Detention Centre 2244 Innes Dr., Ottawa, ON 4C4 AND TO: OCDC Correctional Services Employees John Doe and Jane Doe e/o Ottawa Carleton Detention Centre 2244 Innes Ottawa, ON 4C4 l. The Plaintiff, JULIE BILOTTA, claims: General damages in the amount of $200,000; Punitive, exemplary and/or aggravated damages in the amount of $1,000,000; Damages pursuant to the provision of the Family Law Act, R.S.O. 1990, c. F. 3, as amended, related to her son, Gionni?s injuries, in the amount of $100,000; Special damages in an amount to be determined with particulars to be provided prior to trial; Out-of-pocket funeral expenses in the amount to be determined with particulars to be provided prior to trial; Pre and post judgment interest pursuant to sections 128 and 129 of the Courts of Justice Act, R.S.O. 1990, 0. C43, as amended; The costs of this action, plus applicable taxes; and Such further and other relief as this Honourable Court may deem just. Introduction 2. On September 29, 2012, the Plaintiff, JULIE BILOTTA (?Ms Bilotta?), gave birth to her son in a cell at the Ottawa Carleton Detention Centre . For many hours leading up to the birth, Ms. Bilotta had been screaming in pain and pleading to be taken to the hospital. Instead of helping her, the guards at the OCDC punished her for being disruptive and moved her into a solitary cell where her moans would not bother the other inmates. . The Defendant, ROSE GYASI (?Nurse Gyasi?), an OCDC registered nurse, came to assess. Ms. Bilotta multiple times. Ms. Gyasi failed to recognize that Ms. Bilotta was in labour and that both Ms. Bilotta and her unborn baby were in need of immediate medical assistance. Nurse Gyasi failed to consult with a doctor. Nurse Gyasi failed to call an ambulance. Nurse Gyasi failed to act to provide the necessary and emergency medical assistance that Ms. Bilotta and her baby needed. Ms. Bilotta suffered a traumatic birth leading to serious injury. Baby Gionni was born in immediate distress. Prior to his birth, there were obvious medical indications that the baby was in danger. When he was ?nally taken to hOSpital he was in critical condition. He never fully recovered from the dif?cult birth. In his short life he suffered permanent respiratory problems. He passed away just after his ?rst birthday due to those injuries. 8. The Defendants had complete care and control over Ms. Bilotta and her baby. But for the Defendant?s malicious and/or negligent actions, the shocking injuries suffered by Ms. Bilotta and Gionni would not have occurred. The Parties 9. At all material times, Ms. Bilotta, was an inmate at the OCDC located at 2244 Jones Rd., in the City of Ottawa, in the Province of Ontario. 10. The Defendant, HER MAJESTY THE QUEEN IN RIGHT OF ONTARIO (?Her Majesty?), is named pursuant to the provisions of the Proceedings Against the Crown Act, R.S.O., 1990, c.P.27., as amended: 21. On behalf of the Crown; b. On behalf of the Attorney General of Ontario; c. On behalf of the Ministry of Commonity Safety and Correctional Services; (1. On behalf of their agents, servants, of?cers, employees, those named in this proceeding; and e. On behalf of all others who may have come into contact with the Plaintiff and were responsible for Ms. Bilotta and Gionni on September 29, 2012, the identities of whom are unknown to the Plaintiff. 11. 12. 13. In addition, Her Majesty, by virtue of the Ministry QfCorrectz'cnaZ Services Act, R.S.O. 1990, c. and the regulations thereto, is responsible for the maintenance, operation and administration of the OCDC, including the supervision and detention of inmates there, training of correctional staff, establishing standards of employee conduct and the provision of health care services within the OCDC. The Defendants, DELIANE FRASER, ROSE GYASI, ROSALIND GYASI, JANET KAMEI, and CHRISTINA THOMPSON (collectively, the Nurses?) were at all material times employed as registered nurses at the OCDC at the time of Ms. Bilotta?s labour and delivery. As such, they had supervision, care, custody and control over Ms. Bilotta?s medical care and that of Gionni. The wrongful actions and/or negligence of the OCDC Nurses, in failing to recognize and respond to Ms. Bilotta?s emergency medical situation, resulted in injuries to Ms. Bilotta and Gionni, and led, eventually, to baby Gionni?s death. The Defendants, MELANIE COCHRANE, COVELL, JACKIE DORAZIO, S. GARNETT, EMMANUELLE GODIN, DOUG HORNER, DIANE PILON, JENNIFER ROBINSON, JENNIFER SMILEY, SHERRY WALSH, and STEVEN WILKES, (collectively, the Guards?) were at all material times employees of the OCDC at the time of Ms. Bilotta?s labour and delivery, in their capacity as a guards, supervisors and/or managers. As such, they had supervision, care, custody and control over Ms. Bilotta and Gionni. The wrongful actions and/0r negligence of the OCDC Guards individually and/or collectively, in failing to respond to Ms. Bilotta?s labour and 14. 15. emergency medical situation, resulted in the injuries to Ms. Bilotta and Gionni, and led, eventually, to baby Gionni?s death. The Defendant, OTTAWA CARLETON DETENTION CENTRE SUPERINTENDANT WILLIAM LAST, was at all material times employed as the Primary Executive of the OCDC at the time of Ms. Bilotta?s labour and delivery. As such, he had supervision, care, custody and control over Ms. Bilotta and Gionni. He was also the supervisor of all those employees who were in direct contact with Ms. Bilotta. The wrongful actions and/0r negligence of William Last, in failing to properly manage, train, supervise and/or provide directions to the employees who came into contact with Ms. Bilotta, resulted in the injuries to Ms. Bilotta and Gionni, and led, eventually, to baby Gionni?s death. The Defendants, OTTAWA CARLETON DETENTION CENTRE CORRECTIONAL SERVICES EMPLOYEES JOHN DOE and JANE DOE (collectively ?Other OCDC Staff?), were at all material times employees of the OCDC at the time of Ms. Bilotta?s labour and delivery, in their capacity as guards, supervisors, managers and medical staff. As such, they had supervision, care, custody and control over Ms. Bilotta and Gionni. The wrongful actions and/or negligence of the Other OCDC Staff individually and/or collectively, in failing to respond to Ms. Bilotta?s labour and emergency medical situation, resulted in the injuries to Ms. Bilotta and Gionni, and led, eventually, to baby Gionni?s death. The identities of the Other OCDC staff are unknown to the Plaintiff and are within the unique knowledge of the Defendants. The Facts 16September 25, 2012, Ms. Bilotta was remanded into custody. The OCDC knew, at the time, that Ms. Bilotta was 36 weeks pregnant with her ?rst child. On September 29, 2012 commencing on or about 10:00 am, Ms. Bilotta, told correctional and health staff at the OCDC that she was not feeling well. At approximately 11:45 am, the Defendant, MELANIE COCHRANE (?Guard Cochrane?), noticed that Ms. Bilotta had not eaten her lunch. At approximately 12:15 pm, Guard Cochrane and the Defendant, STEVEN WILKES (?Guard Wilkes?), brought Ms. Bilotta to the Health Care unit to be assessed. There Defendant, JANET KAMEI (?Nurse Kamei?) used a Doppler to attempt to listen to the baby?s heartbeat. At ?rst no heartbeat could be found in the lower part of Ms. Bilotta?s abdomen. When the Doppler was applied to the upper portion of her abdomen the heartbeat was located. The Defendant CHRISTINE THOMPSON (?Nurse Thompson?) was also in attendance at the assessment. At the end of the examination Ms. Bilotta was given an antacid. It is unknown whether a doctor was consulted. As Ms. Bilotta was being escorted back to her cell, the Defendant, JENNIFER ROBINSON (?Guard Robinson?), observed Ms. Bilotta and noted that she was walking slowly, was obviously feeling ill, and that her skin colour had turned grey. Guard Robinson took no action. At approximately 3:30 pm, the Defendant, DELIANE FRASER (?Nurse Fraser?), received a call at the OCDC nurses? station requesting that Ms. Bilotta be reassessed by a nurse. Nurse Fraser instructed Nurse Gyasi on how to assess Ms. Bilotta. 23Shortly thereafter, Nurse Gyasi came to see Ms. Bilotta and felt her abdomen while Ms. Bilotta was standing outside her cell. Nurse Gyasi did not report back to or consult with Nurse Fraser following the assessment. It is unknown whether Nurse Gyasi consulted with a doctor. At approximately 4:00 pm, Ms. Bilotta complained to the Defendant DIANE PILON (?Guard Pilon?) and Other OCDC Staff that she was experiencing cramps and lower abdominal pain, including a sharp pain that was recurring every 2 minutes. No action was taken. At approximately 5:30 pm, Guard Cochrane and Guard Pilon moved Ms. Bilotta into a cell by herself. Guard Pilon told Ms. Bilotta that her-moans were disruptive and the other inmates were tired of hearing her complaining about the pain. At approximately 6:25 pm, Ms. Bilotta, who had been in constant pain now for hours, was screaming that she was in extreme pain and was begging for transport to the hospital. She could not stand and she could not eat. Once again, Nurse Gyasi attended to Ms. Bilotta. This time she provided Ms. Bilotta with a Tylenol. It is unknown whether Nurse Gyasi consulted with any other nurses regarding Ms. Bilotta?s condition. It is unknown whether Nurse Gyasi consulted with a doctor as she promised Ms. Bilotta she would. Ms. Bilotta continued to scream and moan in pain, beg for pain medication and ask continually to be taken to a hospital. Nothing was forthcoming. She was left to suffer alone in her cell. 29. At approximately 8:00 pm, Ms. Bilotta yelled to an OCDC Guard that she could feel a foot in her vagina. She also told an OCDC Guard that she thought she had had an accident in her pants. Her underwear and pants were soaking wet. 30. Nurse Gyasi, Guard Cochrane and the Defendant, JACKIE DORAZIO (?Guard Dorazio?) came together to see to Ms. Bilotta in her cell. Each could see a white object in her vagina. Nurse Gyasi, after conducting some sort of rudimentary examination, stated that she did not think it was a foot but might perhaps be a mucous plug. Guard Cochrane stated it looked like tissue paper or cauli?ower. Guard Cochrane asked Ms. Bilotta whether she was hiding any contraband in her vagina. No further action was taken regarding the visible foot. 3 1. Nurse Gyasi was about to leave the area when Guard Cochrane requested she come back and inspect Ms. Bilotta?s underwear. Nurse Gyasi looked at the underwear and sanitary pad and noted that they were wet and stained green. Nurse Gyasi apparently had no idea what she was looking at. Guard Cochrane suggested that the green ?uid could be meconiurn. Nurse Gyasi stated that she would call a doctor and left the cell. Guard Cochrane and Guard Dorazio left the cell and continued their regular duties. 32. It is unknown whether a doctor was called. Certainly no ambulance was called. 33. At approximately 8:15 pm, Guard Cochrane and Guard Dorazio found Ms. Bilotta in distress on the toilet. Now not only was the foot visible but so was the leg of the baby. 34. It was only at this point that Guard Cochrane made two medical emergency pages within the OCDC. 35. OCDC Staff assisted Ms. Bilotta to her mattress. 36. 37. 38. 39. 40. 41. 42. 43. 44. 45. The mattress had no sheets on it. Someone grabbed a towel and placed it under Ms. Bilotta. At approximately 8:25 pm, OCDC Nurses J. Schultheis, D. Longmuir, Nurse Gyasi and the Defendant, ROSALIND GYASI (?Nurse Rosalind Gyasi?), responded to the emergency page. Other OCDC Staff responded as well, including the Defendants, EMMANUELLE GODIN (?Guard Godin?), SHERRY WALSH (?Guard Walsh?), and COVELL (?Guard Covell?). Ms. Bilotta now had two feet visible at the vaginal opening. Ms. Bilotta was given oxygen. No pain management medication was available or provided. Somebody ?nally called an ambulance. Paramedics arrived at approximately 8:50 pm. The Defendant S. GARNETT (?Guard Garnett?) assigned an escort to take the paramedics to Ms. Bilotta?s cell. With the paramedics? assistance, baby Gionni was delivered shortly thereafter with the umbilical cord wrapped around his neck. He had also inhaled meconium into his lungs and had to be suctioned. Ms. Bilotta and baby Gionni were transported to the hospital by ambulance. Ms. Bilotta was accompanied in the ambulance by Guards Smiley and Dorazio. Guard Garnett followed the ambulance in a van. On arrival at the hospital, Ms. Bilotta and Gionni were separated. 46. 47. 4s 49. 50 51. 52. 53. 54. ?14? At approximately 11:00 pm, Ms. Bilotta was taken in for surgery to remove a retained placenta. She also suffered from signi?cant post?partum hemorrhage complicated by anemia. She required two blood transfusions. After the surgery, Ms. Bilotta was moved to a private room. Once there she was shackled to the hospital bed by Guards Smiley and Dorazio on the orders of Guard Garnett. . Baby Gionni was assessed in critical condition. He was placed on a ventilator, had seizures, was intubated and had to be fed through a catheter. Gionni stayed at the hospital until October 7, 2012. . Ms. Bilotta was returned to the OCDC on October 2, 2012. She was released from OCDC on October 18, 2012 and placed in a half-way house. On November 9, 2012, Ms. Bilotta attended a walk-in clinic for a painful bump on the back of her thigh. She was immediately sent back to the hospital where she was treated for a Methicillin-resistant Staphylococcus Aureus infection. As a result of the infection, contracted at the OCDC, Ms. Bilotta underwent numerous visits from a nurse to clean the wound and now has a large 20?crn scar on her thigh. Baby Gionni continued to suffer from respiratory problems and other health issues. He was required to go to hospital for regular check?ups. In early October 2013, he was admitted to hospital for overnight observation due to further respiratory problems. On the morning of October 13, 2013, Gionni was found without vital signs and was shortly thereafter pronounced dead. Breaches of Law and Policy 55. The Defendants, individually and/or collectively, committed numerous violations of law and policy during Ms. Bilotta?s labour and delivery. A. Failure to provide competent and reasonable health care 56. The Plaintiff pleads and relies on the following as setting out the law and policy in respect of the Defendants? obligations to provide reasonable and competent health care: a. Sections 5 and 24 of the Ministry QfCorrect'z?onaZ Services Act; and b. Sub?section ?Health Care Services for Women: Prenatal and Obstetrical Care? of the Ministry of Community Safety and Correctional Services Health Care Services Policy and Procedure Manual. 57. The Plaintiff pleads that the above law and policy was breached by, inter alia,: a. Failing to provide necessary and essential health care to Ms. Bilotta and Gionni; b. Failing to provide health care that conformed to professionally accepted standards, including adequate documentation; 0. Failing to take into consideration Ms. Bilotta?s health, health care needs and pregnancy in making decisions to place her in segregation; d. Failing to respond to a medical emergency in circumstances in which there was a duty to act; and e. Failing to provide the necessities of life to Gionni. m. B. Negligence towards Ms. Bilotta 58. S9. 60. The Plaintiff states that the Defendants owed a duty of care to Ms. Bilotta to take reasonable care for her health and the health of her baby as a person in the custody of the 0CDC. MS. Bilotta?s complicated labour and the medical crisis was the result of the negligence and/or reckless indifference and/or maliciousness of the Defendants. The negligent and/or reckless and/or malicious actions or inactions of the Defendants individually and/or collectively caused injury and suffering to Ms. Bilotta. Such consequences were known or ought to have been known by the Defendants. Some of the particulars of the negligent, reckless, and/or malicious conduct of the Defendants are as follows: a. Failing to ensure that OCDC employees were adequately trained in the laws, regulations and rules pertaining to the health, safety and care of pregnant inmates; b. Failing to know and follow the law and policy; c. Failing to exercise the standard of care required by their positions of employment; (1. Failure to recognize that Ms. Bilotta was in premature labour; e. Failure to recognize that the baby was in a dangerous breach position; f. Failure to recognize that Ms. Bilotta?s water had broken and there were signs of meccnium; g. Failure to recognize that Ms. Bilotta was in need of medical attention; h. Failure to ensure that Ms. Bilotta received adequate medical attention during her labour and delivery; -17 m. i. Failure to treat Ms. Bilotta with decency and respect during her labour and delivery; j. Moving Ms. Bilotta into segregation and keeping her there during her labour and delivery; k. Failure to transfer Ms. Bilotta, in a timely manner, to the care of a competent health professional and/or hospital during her labour and delivery; 1. Failing to provide adequate medical care for Gionni; and m. Failing to provide the necessities of life for Gionni. 61. The damages suffered by the Plaintiff are all consequences that were reasonably foreseeable as a result of the negligent and/or reckless and/or malicious conduct of the Defendants. C. Negligence towards Gionni 62. The Plaintiff states that the Defendants owed a duty of care to Gionni to take reasonable care for his health as a baby born in the custody of the OCDC. 63. The negligence and/or reckless indifference and/or maliciousness of the Defendants towards Gionni?s pregnant mother caused injury and suffering during the labour and delivery leading directly to the injuries suffered by Gionni. Such consequences were known or ought to have been known by the Defendants. 64. Some of the particulars of the negligent, reckless, and/or malicious conduct of the Defendants are as follows: j. k. Failing to ensure that OCDC employees were adequately trained in the laws, regulations and rules pertaining to the health, safety and care of pregnant inmates; Failing to know and follow the law and policy; Failing to exercise the standard of care required by their positions of employment; Failure to recognize that Ms. Bilotta was in premature labour; Failure to recognize that the baby was in a dangerous breach position; Failure to recognize that Ms. Bilotta?s water had broken and there were signs of meconium; Failure to ensure that Ms. Bilotta and Gionni received adequate medical attention during labour and delivery; Failure to transfer Ms. Bilotta, in a timely manner, to the care of a competent health professional and/or hospital during her labour and delivery; Failure to treat Gionni with decency and respect during his delivery and birth; Failing to provide adequate medical care for Gionni; and Failing to provide the necessities of life for Gionni. 65. The damages suffered by Gionni, and claimed on his behalf by his mother Ms. Bilotta, were all consequences that were reasonably foreseeable as a result of the negligent and/or reckless and/or malicious conduct of the Defendants. ?19? D. Breach of Fiduciary Duty 66. By Virtue of the fact that Ms. Bilotta was in the custody of the 0CDC, the Defendants were in a position to unilaterally exercise power over the Plaintiff. As such the Defendants owed the Plaintiff and Gionni a fiduciary duty to ensure health care needs were met. 67. The Defendants breached the ?duciary duties they owed to Ms. Bilotta and Gionni, thereby causing the damages claimed. Damages 68. As a result of the negligent, reckless and/or malicious behaviour of the Defendants, Ms. Bilotta suffered physical, emotional and damage. As a result, Ms. Bilotta claims general damages for pain, suffering and a loss of enjoyment of life. Some of the particulars of the damage caused include: a. b. Extreme pain and suffering; Extreme emotional distress during labour and delivery; Signi?cant loss of blood and hemorrhaging; Physical damage related to the recovery from the traumatic delivery of Gionni; MSRA infection of her leg and subsequent scarring; Emotional and trauma related to the birth experience; and _20_ g. Emotional and trauma related to the loss of her child. 69. As a result of the injuries and death sustained by Gionni, Ms. Bilotta has suffered a loss of care, guidance and companionship that she would have received from her son, pursuant to the provisions of the Family Law A cl, R.S.O. 1990, c. F. 3, as amended. 70. As a result of the negligent, reckless and/or malicious behaviour of the Defendants, Gionni suffered physical, emotional and damage. As a result, Ms. Bilotta claims on his behalf for pain and suffering and loss of enjoyment of life. Some of the particulars of the damage caused include: a. Serious, permanent and/or life?threatening respiratory damage; b. Intubation; c. Seizures; d. Insertion of and feeding via catheter; and e. Developmental damage. 71. As a result of the injuries suffered, the Plaintiff has incurred special and out-of-pocket expenses including funeral expenses, the details of which will be provided prior to trial. 72. By reason of the high?handed, shocking and contemptuous conduct of the Defendants, the Plaintiff claims exemplary and/or aggravated and/or punitive damages. 73. The Plaintiff pleads and relies upon the following: a. Proceedings Against the Crown Act, R.S.O. 1990, c.F.3, as amended; 1). Ministry of Correctional! Services Act, R.S.O. 1990, c. M22, as amended; and -21_ c. Negligence Act, R.S.O. 1990, e. as amended; and (1. Family Law Act, R.S.O. 1990, c. F. 3, as amended 74. The Plaintiff proposes that this action be tried at Ottawa, Ontario. Dated September 23, 2014 GREENSPON, BROWN ASSOCIATES Barristers Solicitors 331 Somerset St. W. Ottawa, ON K2P 0J8 Tel: (613) 288?2890 Fax: (613) 288-2896 Lawrence Greenspon (LSUC 20301 D) Marisa Victor 52065 B) Counsel to the Plaintiff adr?w marquis? .. BE - mm? z?umm?m? HEM Odwwz :4 A,me Om 3. gamma, Umm??mam \thM m. NE: 5% 2o." 025339 Oog? Ow Ema.?an Emma Wang"; m?k??mgmza Om, Qw?gimwOH/Hg WWOEZ meoo. wmwwoaanm? madam 58% 03mg? 02 ?w aw ?Hor 35V max" 8me wow Em 03253: Fme ~33 251mm. Some?. Fmd? 025%? m2. 593::