Court File No/N* du dossier du greffe: CV-20-00643451-0000 “torino Hn Esctony eet ena co jae ee ONTARIO SUPERIOR COURT OF JUSTICE BETWEEN! Vaceine Choice Canad: (VCO) EEE 2S Ss —————z I 2382 NCU" Plainults -and- Justin TRUDEAU, Prime Minister of Canada, Dr. Theresa TAM, Chief Medical Officer for Canada, Mare GARNEAU, Canadian Transport Minister, Doug FORD, Premier of Ontario, Christine ELLIOT er of Health and Long-Term Care for Ontario, Stephen LECCE, Minister of Education for Ontario, Dr. David WILLIAMS, Ontario Chief Medical Officer, CITY OF TORONTO, John TORY, Mayor City of Toronto, Dr. Bilcen DE VILLA, Toronto Chief Medical Officer, The County of WELLINGTON. DUFFERIN-GUELPH (“CWDG”), Nicola MERCER (Chief) Medical officer for CWDG, WINDSOR-ESSEX COUNTY, Dr. Wajid AHMED (Chief) Medical Officer for WindSor-Essex County, Her Majesty the Queen in Right of Canada, Her Majesty the Queen in Right of Ontario, Atiomey General of Canada, Attorney General of Ontario, The Canadian Broadcasting Corporation (*CBC"), Johns and James DOE, officials and ‘employees of the above-noted Defendants Defendants STATEMENT OF CLAIM TO THE DE ENDANT: A LEGAL PROCEEDING HAS BEEN COMMENC the plaintiff. The claim made against you is set out in the fallowi AGAINST YOU by 1B pages. IF YOU WISH TO DEFEND THIS PROCEEDING, you or un Ontario lawyer acting for you must prepare a statement of defence in Form |8A prescribed by the Rules of Civil Procedure, serve it on the plaintiff's lawyer or, where the plaintiff does not haveEvocton ca y ssuod / D6 v6 par vow 6ocxon quo -06-Ju-2020 Court File No/N* du dossier du greffe: CV-20-00643451-0000 a lawyer, serve it on the plaintiff, and file it, with proof of service, in this cout affice WITHIN TWENTY DAYS after this statement of claim is served on you, if you are served in Ontario. Ifyou are served in another province or territory of Canada or in the United States of America, the period for serving and filing your statement of defence is forty days. If you are served outside of Canada and the United States of America, the period is sixty days Instead of serving and filing a statement of defence, you may serve and file 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 file 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 A LOCAL LEGAL AID OFFICE. TAKE NOTICE: THIS ACTION WILL, AUTOMATICALLY BE DISMISSED if it has not been set down for trial or ferminated by any means within five years after the action ‘was commenced tinless otherwise ordered by the cour, Date: +2020 Issued by: Address of Local Office: 393 University 10" Floor Toronto, Ontario MSG 166 TO: Attorney General of Canada Department of Justice Canada Ontario Regional Office 120 Adelaide Street West Suite #400 Toronto, Ontario MSH ITI Fax: (416) 954-8982 Tel: (416) 973-0942 AND TO: The Attomey General for Ontario Crown Law office, Constitutional Law Branch 720 Bay St Toronto, Ontario M7A 289 Tel: 416-326-4460 Fax: 416-326-401E-octon ca y ssuod / D6 v6 par vo 6 econ quo -06-Ju-2020 Court File No/N* du dossier du greffe: CV-20-00643451-0000 AND TO: John Tory and City of Toronto, City Solicitor’s office, City of Toronto 100 Queen Street, W Toronto, Ontario MSH 2N2 AND TO: Dr Wajid Ahmed Medical Officer of Health Windsor- Essex County Health Unit Address: 1005 Oullette Ave Windsor ON N9A 438 Phone: 519-258-2146 Fax: 519-258-6003 Email: [email protected] AND TO: Dr Nicola Mercer Medical Officer of Health WDG Health Unit ‘Address: 160 Chancellors Way Guelph ON NIG Phone: 519-822-2715 Fax: 519-836-7215 Email: [email protected]E-octonca y ssuod / D6 w6 par vo 6 econ quo =06-Ju-2020 Court File No/N* du dossier du greffe: CV-20-00643451-0000 CLAIM 1. Asagainst the Crown and Municipal Defendants the Plaintiffs claim a) b) A Declaration that the “COVID Measures” undertaken und orchestrated by Prime Minister Trudeau (“Trudeau”) , and the Federal Crown, constitute a constitutional violation of “dispensing with Parliament, under the pretense of Royal Prerogative’, contrary to the English Bill of Rights (1689) as read into our unwritten constitutional ripbts through the Pre- Amble of the Constit mn Act,1867, emanating from the unvritten constitutional principles of Rule of Lav, Constitutionalism and Democracy , as enunciated by the Supreme Court of Canada in, inter alia , Quebec Secession Reference; A Declaration that (@s.7.0.1 through s.70.11 of the Emergency Management and Civil Protection Act, RSO 1990,C.¢.9 (the “Act ), and in particular vesting an indefinite emergeney power in the Premier and Lt.-Governor, and further that the “COVID Measures”, undertaken and orchestrated by Premier Doug FORD (“Ford”) and the Provincial Crown, constitute a constitutional violation of “dispensing with Parliament, under the pretense of Royal Prerogative”, contrary (o the English Bill of Rights (1689) as read into our unwritten constitutional rights through the Pre-Amble of ‘the Constitution Act,1867, emanating from the unwritten constitutional principles of Rule of Law, Constitutionalism andE-octon ca y ssuod / D6 w6 par vo 6ccon quo =06-Ju-2020 Court File No/N* du dossier du greffe:_CV-20-00643451-0000 sy a Democracy , as enunciated by the Supreme Court of Canada i inter alia , Quebec Sece: Reference; Gi) A further Declaration that the “emergency”, COVID-19 “pandemic” declaration issued by Ontario, did not, and does not, meet the statutory requisite criteria set out in s.7.0.1(3) of that Aet, and is in further contravention of's. 7.0.2(1) and (3) of that Act sand that the declaration of emergency, and its extensions, be declared ultra vires the Act; A Declaration that the COVID Measures taken by both Trudeau and Ford, and their respective governments, at the blind and unquestioned dictates of the World Health Organization (“WHO”) bureauerats, constitute a constitutional violation of the abdication of the duty to govern, as enunciated in, inter alia, the Re Gray and Canada (Wheat Board) v Hallett and Carey Ltd. decisions of the Supreme Court of Canada; A Declaration that the COVID Measures undertaken by Trudeau, and his officials, violate ss. 2, 7, 8, 9, and 15 of the Charter, specifically the measures: (i) “selfisolation”; (ii) “social distancing”; (iii) the compulsory wearing of face masks; (iv) arbitrary and unjustified closure of businesses;Eoctronca y ssued / D6 wo par voo 6 octron que :06-Ju-2020 Court File No/N* du dossier du greffe: CV-20-00643451-0000 Jn that the Measures are not: (i) scientifically, nor medically, based nor proven to be effective whatsoever; Gi) pose physical and psychological harm; and Gi) are extreme, unwarranted and unjustified; And that the measures violate of s.2 (right of association ) s. 7 (life, liberty, and security of person), s.8 (unlawful search and seizure), s. 9 (arbitrary detention by enforcement officers), s.15( equality before and under the law), are further not in accordance with the tenets of fundamental justice in. their overbreadth, nor are they justified under s. | of the Charter in that they are not demonstrably justified in a free and democratic society; ¢) A Declaration that the declaration of a public emergency in Ontario, and the very Legislation, Regulations and Orders enacted pursuant to the Emergency Management and Civil Protection Act, 250 1990 ¢, E-9, infringe s. 2, 7.8.8, 9, and 15 of the Charter specifically the measures of (vy) “selfisolation”, (vi) “social distancing”; (vii) the compulsory wearing of face masks; (viii) arbitrary and unjustified closure of businesses, (ix) the close of schools, daycares, park amenities, and playgrounds: 6Ecctronca y ssued / Dé we par voe @ectronque :06-Ju-2020 Court File No/N* du dossier du greffe: CV-20-00643451-0000 (x) _ the discontinuance of access to education, medical, dental, chiropractic, naturopathic, hearing, dietary, therapeutic anit other support, for the physically and mentally disabled, particularly special needs children with neurological disorders; and (x4) the closing down of religious places of worship; In that the Measures are not: (i) scientifically, nor medically, based nor proven to be effective whatsoever: (ii) pose physical and psychological harm; and (i are extreme, unwartanted and unjustified And that the measures violate of s.2 (right of association ) s. 7 (life, liberty, and security of person), s.8 (unlawful search and seizire), s. 9 (arbitrary detention by enforcement officers), s.15( eduality before and under the law), are not in accordance with the tenets of fundamental justice in. their overbreadth, nor are they justified under s. 1 of the Charter in that they are not demonstrably justified a in free and democratic society; A Declaration that the Municipal COVID Measures enacted by By-Law. and Orders, by the City of Toronto, and conduct of John Tory, are altra vires the Provincial Act and Regulations, and are further unconstitutional and are of no force and effect, for breaches of's.2 (right of association ) s 7 (life, liberty, and security of person), s. 8 (unlawful search andEoctronca y ssucd / D6 wé par voe 6 octron que :06-Ju-2020 Court File No/N* du dossier du greffe: CV-20-00643451-0000 seizure), 5.9 (atbitrary detention by By-Law officers), and s. 15 of the Charter, specifically the measures of : (i)*self isolation”; Gi)" social distancing”; (iii) the compulsory wearing of face masks; (iy)arbitrary and unjustified closure of businesses; (v)the closure of schools, dayeares, park ameniti playgrounds; (vi) the discontinuance of access to education, medical, dental, chiropractic, naturopathic, hearing, dietary, therapeutic, and other support, for the physically and mentally disabled, particularly special needs children with neurological disorders; (vii) the closing down of religious places of worship; In that the Measures are not: (_seientifically, nor medically, based nor proven to be effective whatsoever; (ii) pose physical and psychological harm; and Gil) are extreme, unwarranted and unjustified. And that the measures violate of s2 (right of association) s, 7 (life, liberty, and security of person), s,8 (unlawful search and seizure), s. 9 (arbitrary detention by enforcement officers), 5,15( equality before and under the law), are not in accordance with the tenets of fundamentalEoctronca y ssued / D6 wé parvo e 6 octon que :06-Ju-2020 Court File No/N* du dossier du greffe: CV-20-00643451-0000 8) hy justice in their overbreadth, nor are they justified under s, 1 of the Charter in that they are not demonstrably justified in a free and democratic society; A Declaration that, in the imposition of the COVID Measures, Trudeau, Ford, and Tory, and all the named Medical officer Defendants, have engaged in ultra vires and unconstitutional conduct and have acted in, abuse and excess of their authority; A Declaration that the concept of “social distancing” is neither scienlifically, nor medically based, and is an ineffective and a fictional concept, which has no scientific nor medical basis and hitherto unknown with respect to a seasonal viral respiratory illness; ‘A Declaration that: (@ the orders from the Medical Officers from the Counties of Wellington-Duilferin-Guelph and Winsor-Essex, and any and all County or Municipal By-Law or Health Officers and orders, respecting mandatory wearing face-masks, is unconstitutional: and (ji) a further Declaration that the mandatory wearing of face-masks is both ineffective and poses @ health risk, and is a violation of s. 7 of the Charter (liberty and security of the person) in violating the physical and psychological integrity, by seriously restricting a person’s primordial right to breath, as well as restricting the very tight of liberty, to choose how to breath, as well as pose a physical and medical danger;Ecectron ca y ssued / Dé wé par vo 6 ecron quo = 06 Ju-2020 Court File No/N* du dos: du greffe: CV-20-00643451-0000 3) A Declaration that any mandatory vaccine scheme against any purported COVID-19, by way of mandatory vaccine, without informed consent, is unconstitutional, and no foree and effect in that: (i) Itin infringes s, 2 of the Charter in violating freedom of conscience, religion and thought: (ii) Infringes s, 7, life, liberty, and security of the person in violating physical and psychological integrity in denying the right to choose, based on informed medical consent; (iii) Breaches the same parallel rights recognized prior to the Charter, as written constitutional rights through the Pre-Amble to the ‘Constitution Act, 1867; Gv) Breaches parallel international treaty rights to no medical treatment without informed consent, and right 1o bodi legrity, which international treaty rights are to be read in, asa minimal s. 7 Charter protection, as enunciated by the Supreme Court of Canada in, inter alia the Hape decision: (v) And that, under no circumstances are mandatory vaccines, nor coerced compliance to vaccines, in accordance with the tenets of fondamental justice, nor demonstrably justified under s, 1 of the Charter; k) A Declaration that social distancing, self-isolation, and limits as to the number of persons who can physically congregate, and where they can congregate, violate s, 2 Charter rights to freedom of association, thought, 0Eoctronca y ssuad / D6 wé par voo Goctron que :06-Ju 2020 Court File No/N* du dos: m) » du greffe: CV-20-00643451-0000 belief, and religion in banning association, ineluding religious gatherings, and further restricting physical and psychological liberty and security of the person rights under s.7 of the Charter, and are not in accordance with the tenets of fundamental justice, nor demonstrably justi the Charter; A Declaration that the arbitrary, irrational}, and standardless sweep of closing businesses and stores as “non-essential”, and the manner of determining and executing those closures, constitutes unreasonable search and seizure contrary to s. 8 of the Charter and not demonstrably justified under s.1 of the Charter; A Declaration that the declared rationales and motives, and execution of COVID Measures, by the WHO, are not related to a bona fide, nor an actual “pandemic”, and declaration of a bona je pandemic, but for other political and socio-economic reasons, motives, and measures at the behest of global Billionaire, Corporate and Organizational Olivarchs; ‘A Declaration that prohibitions and obstacles co protest against COVID. Measures in Ontario, and in Toronto, are a violation of the constitutional rights to freedom of expression, conscience, belief , and association, assembly, and petition, under s, 2 of the Charter, and not demonstrably justified by s. 1, as well as a violation of these constitutional rights, recognized prior to the Charter, through the Pre-Amble to the Constitution Act, 1867 and against international treaty rights protected by s.Tof the Charter;Eoctronca y ssucd / D6 w6 par voo Goctron que :06-Ju-2020 Court File No/N* du dossier du greffe: CV-20-00643451-0000 °) A Declaration that any and all COVID Measures coercively restraining and curtailing the physical and psychological integrity of the Plaintiffs, and any and all physical and psychological restraints, including but not restricted to: (i) “selfisolation”; (ii) no gatherings of more than five (5) and later ten (10)persons, or any set number; (iii) the shutting down of children’s playgrounds, daycares and schools; (iv) “social distancing”; (v) the compelled wearing of face-masks; (vi) prohibition and curtailment of freedom of assembly, including religious assembly, and petition; (vii) the imposition of charges and fines for the purported breach thereof (viii) restriction of travel on public transport without compliance to physical distancing and masking (ix) restrictions on shopping without compliance to masking and physical distancing; (X) __restrietions on attending restaurants andl other food service establishments without compliance to masking, physical distancing, and providing name/adéress/contact information for contact tracing purposesEoctronca y ssued / D6 wé par voo 6 octron que :06-Ju-2020 Court File No/N* du dossier du greffe: CV-20-00643451-0000 (p) Constitute a violation of ss. 2,7.8, 9, and ss. 15 of the Charter , to freedom of association, conscience religion, assembly, and express on under s. 2, liberty and security of the person in violating the physical and psychological integrity of the liberty and security of the person, not in accordance tenets of fundamental justice, contrary to s. 7, and further breach of the rights against unreasonable search and seizure contrary tos 8, arbitrary detention under s. 9 of the Charter , and not demonstrably Justified under s. 1, as well as breach of the unwritten parallel rights, recognized as constitutional rights, through the Pre-Amble of the Constitution Aet, 1867 and affected by means of removing measures against the “Liberty of the Subject” by way of habeas corpus; Further Declarations that: (i) the thoughtless imposition of “social distancing” and self-isolation at home breaches s. 2 of the Charter, in denying the right to freedom of association and further breachs the right 1o physical and psychological integrity, under s. 7 of the Charter (liberty) in curtailing and restricting physical movement, which measures are wholly unjustified on any scientific or medical basis, and which are not in accordanee with the tenets of fundamental justice in being vague, and suffering from overbreadth, and which cannot be justified under s, | of the Charter;Eoctronca y ssucd / D6 wo parvo o 6 octron que :06-Ju-2020 Court File NoJN* du dos: Gi) Gif) iv) (vy) du greffe: CV-20-00643451-0000 ‘That the measures themselves, and the arbitrary detention, by enforcement officers, in enforcing these vague and over-broad, and often ultra vires, and contradictory “orders”, is a violation of the right against arbitrary detention under s. 9 of the Charter and that, in the course of such “enforcement” the search and seizure of private information, including medical information, from individuals, heing charged with purported violations of such orders, constitutes a violation of ss.7 and 8 of the Charter, and that neither violation of. 7 or 8 are in accordance with the tenets of fundamental justice nor justified under s. 1 of the Charter; ‘That the use of “contuct-tracing Apps” constitutes a violation of s.8 of the Charter, and further violates ss. 7 and 8 of the Charter with respect Lo the constitutional rights to privacy, under ttl sections, and that such breaches are not in accordance with the tenets of fundamental justice, and are further not justified under s | of the Charter; ‘That the compelled use of face masks breaches, in restricting the right to breath, al the crux of life itself, and the liberty to choose how to breath, infringes s. 7 to the Charter liberty, security of the person and is not in accordance with the tenets of fundamental justice and not justified by s. 1 of the Charter; That the above-noted infringements under s. 2, 7, 8, and 9, as well as the arbitrary decisions on what businesses to close, and whichEoctronca y sued / D6 wé par voe 6 octon que :06-Ju 2020 Court File No/N* du dos: x 3) du greffe: CV-20-00643451-0000 ones to he left open, constitutes a. 15 of the Charter violation based on: (i) Conscience, belief’, and religion; Association, assembly and petition: (ili) Trade and profession; And farther that such measures are arbitrary, and discriminate before and under the law, contrary to s, 15 of the Charter (and not justified under s,1 of the Charter), and ate further a violation of the unwritten constitutional right to equality recognized before the Charter, as unwritten constitutional rights through the Pre-Amble to the Constitution Act, 1867 as emanating from the principles of Rule of Law, Constitutionalism, and Respect for Minorities as enunciated by the Supreme Court of Canada in Quebee Secession Reference; ‘A Declaration that any and/ all Municipal ‘County By-Laws and/or orders, with respect to compulsory face masks, are ultra vires the Provincial legislation in that the Province has expressly refused to make facc-masking compulsory; A Declaration that the unjustified, irrational, and arbitrary decisions of which businesses would remain open, and which would close, as being “essential”, or not, was designed and implemented to favor mega- corporations and. to de faeto put most small businesses and activities out of business;Eoctronca y ssucd / D6 wo par voo 6 acon que :06-Ju-2020 Court File No/N* du dos: du greffe: CV-20-00643451-0000 1) A Declaration that the WHO proposal, that it may be necessary to enter people's homes and remove children from parents, or separate families, ‘who are tested positive for COVID-19, is flagrantly unconstitutional in violating the s.2 rights to freedom of association (the family unit) as well as violating the parent-child relationship protected by s.7 of the Charter, as established by the Supreme Court of Canada; u) A Declaration that (i) the Defendant Federal Crown, and its agencies and officials, including but not restricted to the CR'TG, have, by glaring acts and omissions, breached the rights of the Plaintiffs to freedom of speech, expression, and the press, by not taking any action (o curtail what has been deseribed by the UK scientific community as “Stalinist censorship”, particularly the CBC in knowingly refusing to cover/or publish the valid and sound criticism of the COVID measures, by recognized experts: (ii) @ Declaration that the Federal Crown has in fact aided the suppressing and removing of“Paccbook” and “YouTube” postings, even by experts, which in any way contradict or criticize the WHO and government measures as “misinformation” “contrary to community standards”, by the federal Defendants threatening criminal sanction for such “misinformation”;Ecctronca y sued / D6 w6 par voe 6 octron que :06-Ju 2020 Court File No/N* du dossier du greffe: CV-20-00643451-0000 ‘thus violating s. 2 of the Charter by way of act, and 01 delineated and ruled by the Supreme Court of Cana juin, inter alia Vriend; v) A Declaration that the measures have a devastating impact on those with severe physical and neurological special needs, particularly children, and infringe s, 15 of the Charter, and the unwritien right to equality through the Pre-Amble to the Constitution Act, 1867, based on psychical and ‘mental disability, and age, and not justified under s. 1 of the Charters Such further and/or other Declaratory relief as counsel may advise and this Honorable Court entertain, As against the Crown and Municipal Defendants, tnterim and/or final injunctive relief, from any mandatory vaccine, or compelled use of face-mask, and against any other compelled, coercive COVID-Measures, whether by legislative provision and/or Regulation / order thereunder, particularly measures which interfere with physical and psychological integrity without informed consent. Asagainst the CBC: (@) A Declaration that: (@ the CBC, as the publicly- funded broadcaster under the Broadcast Act, owes a fiduciary duty to be fair, independent, impartial, objective, and responsible, in its news coverage and investigation of the “pandemic”, and COVID- Measures, which fiduciary duty it has flagrantly and knowingly breachedE-octronca y ssuod / D6 v6 par vo 6 econ quo -06-Ju-2020 Court File No/N* du dossier du greffe: CV-20-00643451-0000 (ii) that the CBC, owing a duty of care to the Plaintiffs as the national publicly - funded broadcaster, has been grossly negligent in its coverage and reporting on the COVID-19;and (iii) ‘That the CBC has knowingly and intentionally suppressed, censored, and unjustifiably belittled expert opinion opposed and critical of the WHO and government line on COVID, and thus propagated “misinformation” and “false news” (b) General damages in the amount of $1 Million dollars; (© Punitive damages in the amount of $10 Million dollars; (G) Such further or other injunctive relief as counsel may advise and this Honorable Court grant 5. Cost of this action on a substantial indermnity basis and such further or other relief this Court deems just.E-ecton ca y ssuod / D6 v6 par vo 6 econ quo =06-Ju-2020, Court File No/N* du dossier du greffe: CV-20-00643451-0000 THE PARTIES + The Plaintifis 6. Vaccine Choice Canada (“VCC”) is a federally registered not-for-profit educational society. VCC is committed to protecting health by informing of the existing and emerging scientific literature evaluating the risks, side effects, and potential long-term health effects of artificial immunization. VCC works to protect the right of all people to make fully informed and voluntary vaccine decisions, for themselves and their children. VCC further advocates for safe vaccines. VCC further works 10 advocate and support the statutory and constitutional rights tied (o the right to vaccinate, and the tight not to vaccinate, based on best science and medicine, with informed consent. Vaccine Choice ition Risk Awareness Network ‘Canada was originally incorporated as the Vaci (°VRAN") in 1982. [t changed its name to Vaccine Choice Canada (VCC) 2014. 7 ‘The Plaintiff ME is a resident of Onlario. Residing in Mississauga, 8 The Plaintif?, ANNs a mother to four (4) children and also a children's Mental Health Therapist, She works in an essential service and has found herself to be working from home since covid- 19 closed the province in March, 2020. She has been providing telephone sessions from March to April and video sessions have started as of May. She is finding that about 50% of the families that she would normally work with are not able to engage by telephone or byE-octon ca y ssuod / D6 w6 par vo 6ocron quo =06-Ju-2020 Court File No/N* du dos: du greffe: CV-20-00643451-0000 video due to many barriers. She has found it challenging to work from home considering she now have four (4) small children. at home who are also doing school virtually and need adult assistance. Covid measures have made it impossible to find childcare. HE has had her own children interrupt client phone calls and video sessions in order to meet her etildren’s needs. She would normally be able to work 7-9 hours from the office daily. But, since the shutdown, she is not able (o do that but works significant reduced hours. Some ofthe families and youth and families that she has talked with are reporting an increase in anxiety/depression and suicidal ideation. Children are feeling extremely disconnected, I 12s that personally, the Covid measures have affeered her as follows: (a) She has some significant allergies to corn and wheat and all of the hand sanitizer products contain alcohol made mostly from these two (2) products: (b) She bas been yelled at and shamed in publie places for not using the sanitizer when it’s a health issue for her; (c) Her son also has the same reaction when he uses hand sanitizer; (d)_ She has been told she cannot enter some stores or receive some services without using hand sanitizer first; (e) Some of the stores that she would normally frequent have signs up saying that everyone has to wear masks; 20E-ctronca y ssued D6 v6 par woe Gactron quo: 06-Ju-2020 Court File NoJN° du dossier du greffe: CV-20-00643451-0000 10. (f) She cannot do groceries as she would normally in Wellington County because of the mandatory mask order: (g) Local grocery shopping is pricier for her due to rural pricing (h) If she declines wearing a mask, she is told she “can’t go into stores or reecive services”; (i) She has asthma and has had Jung issues over the years (j) She also has experienced trauma where a mask was held forcibly over her face to prevent her from screaming while she was being sexually and physically assaulted ina past crime; (k) She now has to disclose personal health information in order to enter stores with which she disagrees, and is otherwise denied service; (1) She no longer feels safe going ut because of all of the above ER further siates that she objects to face-masks based on the fact that they are ineffective with respect to respiratory viruses, further pose physical and psycholo ical health ris , and further violate her tights under s. 2 and 7 of the Charter,E-ctronca y ssued / D6 wé par woe Gactron quo: 06-Ju-2020 Court File No/N" du dossier du greffe: CV-20-00643451-0000 16Evctronca y ssued / 06 v6 par vo. 6 acon quo :06-Ju-2020 Court File No/N" du dossier du greffe: CV-20-00643451-0000 (b)E-ctronca y ssued / 06 v6 par vo. 6 acton quo :06-Ju-2020 Court File No/N" du dossier du greffe: CV-20-00643451-0000 ©)E-octon ca y ssuod / D6 w6 par woo 6ocion quo -06-Ju-2020 Court File No/N* du dossier du greffe:_CV-20-00643451-0000 19. 20. (d) The Plainti{!, VMN is on Ontario resident residing in North Augusta, She recently moved there from Toronto, On) y 26", 2020, at around 5:30pm,MlMand her 10yr old child had gone to Longo’s, a supermarket at York Mills and Leslie in Toronto, for groceries. but we w re stopped as they had entered the doors and an employee demanded t they wear a mask betore entering The store employee, arid Manager, stipulated that they had the dis cretion, as a private business, as per the statements of Premier FORD, and Mayor TORY, to impose mask requirements. The Plaintil and her daughter left the store as she refuses to wear masks because they a ineffective and dangerous to her health, and a violation of her constitutional ts. The Plaintiff'and her daughter were forced to leave the store. The Plaintiff states, and fact is, that there were no Regulations or Orders requiring the wearing of masks to enter businesses that were deemed “essential”, The Plaintiff states that public statements made by Ford and ‘Tory had individuals enacting their own, arbitrary, and irrational laws with respect to “essential” services such as food, and further that Ford and Tory were not only reckless bu also exceeded their authority in making these statements, On June 13”, 2020, at around noon, the Plainti fT EI was driving on highway 401 bound, and pulled into the Cambridge “OnRonte” to use the washroomEcctronca y ssucd / D6 w6 par vo o Goctron que :06-Ju-2020 Court File No/N* du dossier du greffe: CV-20-00643451-0000 and buy lunch, At the entrance there was @ man with a mask that demanded the Plaintif?’ wear a mask. The Plaintiff informed him that she does not wear a mask and he informed the Plaintiff that it was “the law” to wear a mask if she wanted to enter the Onroute, The Plaintiff informed him that just the day before she had stopped at an Onroute and was not forced to wear a mask. Ie insisted that it was the law -IMilthen asked him to show her the law. He pointed in the general direction of the door and said it was written on the door. He stated: “you can go see it on the door.” IINEEMvalked to the door, did not see anything that would stand out, and since she desperately needed to use the washroom she proceeded to walk to the washroom and used the facilities. INN eft the OnRoute without buying anything to eat, IE hen drove on to the OnRoute in Trenton, where she entered without a mask, and no one stopped her from using the facilities and purchasing her late lunch. The Plaintiff states, and the fact is, that such confusion, and consequent hardship and damage, is the result of the reckless aud excess of authority statements made by Trudeau, Ford, Tory, and their Medical Officers, with respect to what Covid-measnres have, or have not, actually put into law, and simply express the at-the-moment ilLinformed views of these Defendants, 21 ‘The Plaintiff INEM bsolutely refuses the wearing of a face-masks. She further denies the efficacy of social distancing and sees both as a violation of ber s.2.and 7 Charter rights, as well as the fact that the indisputable science is that neither measure prevent the contraction of any virus and are otherwise detrimental to her health,E-octon ca y ssuod / D6 v6 par wo 6 econ quo = 06 Ju-2020 Court File No/N* du dos: 22, 23. du greffe: CV-20-00643451-0000 The Plaintitf, EM is an Ontario Resident residing in the County of Wellington-Dutferin-Guelph. ‘The Plaintiff, MJ states that when lockdown started on March 17th, 2020, she was a new mother with a 6 -month old baby. ‘The Plaintiff and child were just starting to get out into the world going to local infant events provided by the city and local businesses, going grocery shopping, meeting with friends for lunch, and other routine social activities. ‘The Plaintiff states that the last day they went out was March 13", 2020. They have not lett the house except to go for walks since that day: no socializing, no music classes, no story readings, and no swim lessons- all cancelled or closed due to the emergeney orders, Even meeting in a park and keeping physical distance was not allowed. As new mother who suffered {rom birth trauma and is recovering from bitth related PTSD, the Plaintiff’ states that being cut off from her new community has been ‘traumatizing and psychologically and socially unhealthy. This had a negative effect on her mental health which she already had a history with prior to her daughter's birth. The Plaintiff was unable to continue with her health care services that were deemed “non-essential” by the provincial government, but to someone recovering from major surgery, they are extremely essential, This has left the Plaintif? in physical pain which has affected her ability to care for her family, The Plaintiff's daughter was also unable to continue with health services that she had previously, as they were also deemed non-essential by the provincial government. The early life experiences the Plaintit?’ planned to give her daughter for her growth and development were taken awayEoctronca y ssued / D6 wr par voe Goctron que :06-Ju-2020 Court File No/N* du dos: du greffe: CV-20-00643451-0000 24, The Plaintiff, MEE states that Wellington- Dutterin- Guelph County’s mandatory mask order is adding insull to injury. The Plaintiff is opposed to the order for several reasons: (a) Ti takes away her right to bodily autonomy, which the Plaintiff takes firm in her conviction in medical freedom extremely seriously, as she i and her right to choose what goes in and on her body. She finds it very scary to have that right taken away. (b) It is not backed by scientific evidence. The Plaintiff was casily able to find science-based articles studies showing that masks, especially cloth ones, are not effective at protecting oneself or others. In fact, they ean have a negative impact on physical and mental health. The Plaintiff further states that our public health officials should have been nore pudent in their research if they truly want to protect the publie's health, (c) It has had a negative effect on her mental health. As someone who has suffered with, at times, debilitating anxicty that gives the sensation of not being able to breathe, wearing a mask is a huge trigger for the Plaintiff. Knowing that if she goes out without one, and claims medical exemption, the Plaintiff will be faced with questioning and perhaps even refusal of entry, which is also is also anxiety- inducing. The Plaintiff is then left with little options, Despite the fact that her County has been moved to “Phase 2° the Plaintiff states that her life has changed very little as she is still housebound and unable to attempt to return to some sense of normalcy dueE-octon ca y ssuod / D6 v6 par vo 6 econ quo =06-Ju-2020 Court File No/N* du dos: du greffe: CV-20-00643451-0000 the mandatory mask order of the County’s Medical Officer, Nicola Mercer, ‘The Plainti(fMEEEMbbsolutely refuses the wearing of a face. masks. She further denies the efficacy of social tancing and sees both as a violation of her s. 2 and 7 Charter rights, as well as the fact that the indisputable science is that they do not prevent the contraction of any air-borne virus and are otherwise detti ental to your health, 26, The Plaintiff, IE resides in Toronto and is a real-estate agent. 27. The Plaintiff, MINNMMBtates, and fact is, that Condo Boards across the GA are allowed to make up their own rules for cach individual building and quite a few are opting to have a “no showing” rule for condos listed for sale. Some allow showings only after a conditional offer is received. This is unfair to the owners of these units and it makes it very difficult to sell these units, sight unseen. Also, all condo buildings only allow two people per elevator tide. The Plainti Phas waited as long as 1.5 hours to get on an elevator, While this rule has been implemented for Covid-I9. the Plaintiff states it has never been implemented for previous “pandemics” such as SARS. The Plaintiff’ states, and fuet is that her clients are not happy with these restrictions, not to mention that many of the Plaintiffs clients are losing their incomes and livelihoods making them umable to buy and sell. The Plaintiff further states and fact is, that the uncertainty of the market, as a result of the Covid-measures, is also impacting purchases and sale prices greatly. The Plaintiff states that, despite real estate being deemed an “essential service, that showing procedures are very strictE-octon ca y ssuod / D6 v6 par vo 6 econ quo = 06 Ju-2020 Court File No/N* du dos: du greffe: CV-20-00643451-0000 when properties do allow showings such as: requesting a signed contract winich enforces wearing masks and gloves, not using the toilet, only allowing one (1) client at a time in the property, and in most cases they are unable to touch anything inside the property 28. BEE tates that it has made it next-to-impossible to work under these conditions and that her income has dropped drastically, ‘The Plaintiff further states that she refuses to wear a fave-mask, and that the Covid-measures violate her rights under ss.2 and 7 of the Charter. 29, ‘The Plaintif?, I is 2 Doctor of Chiropractory, residing in the County of Welling-Dufferin-Guelph, Ontario, 30. The Plaintiff, ENE opposes the COVID-measures enacied by the government(S) as set out below. 31. The Plaintiff’, as a ci en, opposes these measures because (a) As an individual with a history of mental health strggles the emergency measures, including but not limited to: limitations in visiting people, physical and social distancing (i.e. not touching people or visits in groups larger than 5), threats of fines for non-compliance, disruptions in health care services that MMM bad been using and needs, in order to support er chia Iiealth and well-being, have imposed stress and strain on her mental and physical health and well-being, Prior to the declaration of emergency measures and lockdown, EIN was utilizing a variely of approaches to support herself and to heal these struggles, no longer available to her. 30E-octon ca y ssuod / D6 v6 par woo 6 ccron quo = 06 Ju-2020 Court File No/N* du dos: du greffe: CV-20-00643451-0000 (b) More specifically, since approximately September, 2()| 8 IIE s vio -V, I yo; been receiving regular nutritional thera scheduled to receive her monthly I-V therapy a few days aller the emergency measures were enacted, and therelore, SIIB did not receive them, KIM had now been three (3) months without this nutritional support and is feeling the negative effects in her body (c) Further to this, in order to obtain this service, as a resident of Wellington Dufferin-Guelph County, EEE ow must wear a mask to any such appointment, which she refuses to do for reasons set out below (d) MME 2; also in the process of scheduling necessary and non- routine dental work (amalgam extraction and replacement), immediately prior to the pandemic, and this service again, became inaccessible to her. Again, because of Ministry of Health (“MOH”) guidelines for dentistry, GER 1st mask to enter the dental clinic , which she refuses to do, (¢) MMMM ied also. been going for regular eraniosacral therapy appointments to support her health and well-being. which also, were cancelled and she has not had access to since the start of the emergency measures, SEE does not feel the government has the right to tke away her health care and decide what is ‘essential’ vs. ‘non-essential’ in this regard. (9) SEE aso take serious objection with the suspension of Parliament and the lack of transparent process with how her government is currentlyE-octonca y ssuod / D6 w6 par vo 6 econ quo =06-Ju-2020 Court File No/N* du dos: du greffe: CV-20-00643451-0000 conducting itself, INN states that the measures enacted haye not been congruent with the scientific and medical data, with best scientific practices, and the best evidence available, MIE has written multiple letters to elected of ls which are continually ignored or (0 which she receives the rare tepid response. MEE states, and the fact is , that this has all set a precedent for this to happen every influenza season, which would be devastating for ber and many. (g) On June 13", 2020, KIN went to the Dollar Store on Stone Road in Guelph, to buy supplies for her children, and at first was denied entrance as she was not masked, despite clear exemption criteria allowing one to enter stores without a mask, if masking creates an issue with breathing or with parameters related (o health and well-being. Only when GR pushed back against the store manager that this was discrimination and illegal was she allowed to enter, “at her own peril” risking personally taking on the $5,000 fine for being unmasked if a spot check was performed by Public Health. While [EEE was inside, decision to take their commercial activity outside WDG, adding to the this al] felt stressful for hei family have now made the already high level of strain in her family due to the heightened time which errands will now take, having to drive out of the County for all their needs.E-octon ca y ssuod / D6 w6 par vo 6octon quo = 06 Ju-2020, Court File No/N* du dos: du greffe: CV-20-00643451-0000 32, MEI. as a mother of two young cbildren, aged five (5) IB and two and a half (2.5) [vears old, further objects to the emergency measures ‘enacted and lock down for the following reasons: (a) Loss of childcare, Both her children attended Star Seedlings, a licensed. childewre centre in Guelph, at the time the emergency measures were declared and the centre was freed to close. As a working mother, this has placed an undue level of strain and stress on her life, she struggled to jugele her own entrepreneurial business and supporting patients clinically, while her husband worked, and her two children were at home without childcare, Her children cannot go back at this time, as the plan had been to switch them to part- time at the end of June, and only full-time children are allowed back in this ‘phase’ of the Covid-19. () Further to this, I objects based on the stress caused to her children, specifically her five (5) year old, who has asked near daily from the beginning about the closure of the childcare cemie, when he can see his friends again, when he can see his teachers again, and when they ean go out for things he enjoys such as bubble tea, to play in parks, and to have play dates at friends’ houses, Her son turned five (5) on May 5, 2020 and was not able to have a birthday party as he wished, and J was left to deal with his disappointment and sadness over this (c) Furthermore, SEE bas witnessed clear regression of her five (5) year-old, during the emergency, into tantrums and increased aggressive behaviour towards his ster, neither of which were occurring prior toEoctronca y ssued / Dé wé par voe 6 octron que :06-Ju-2020 Court File No/N* du dos: du greffe: CV-20-00643451-0000 lockdown. Both her children have experienced sleep regressions since lockdown began. III has specifically observed I sucking his thumb, which he has never done, even as an infant. (d) With many stores not allowing children to come inside, as well as the overtly fearful messaging and bizarre policies and procedures enacted within (physical distancing, wearing of PPE), all errands haye heen conducted by either [EEE or her husband without their children, which is atypical for their home and has imposed further stress and strain on their Family. zz! emergency measures, notwithstanding that they could keep the number of 's children also only saw their grandparents once during the people within the allowed limit of five (5), their grandfather was worried about the potential of a fine, and did not want to risk seeing the grand- children in person zz, ov also lost access to health care which was necessary for him and his development. Being four or five (4-5) years old during this time, virtual appointments are a poor option for him, as he will not reliably interact through one, and screen use is something they attempt to minimize. Specifically, he lost his speech therapy as well as craniosacral therapy appointments. (g) MEE further objects to the WDG mandatory mask order for citizens under the age of five (5) as this is not congruent with best science, and what is known regarding masking, nor is it mentally or socially 4E-octon.ca y ssuod / D6 w6 par woe 6 ocion quo =06-Ju-2020 Court File No/N* du dossier du greffe:_CV-20-00643451-0000 healthy for children to see this or wear a mask. As her son is five (5). the onder would stipulate he wear a mask, Her son has only seen people masked in person once und he reacted with extreme fear. He hid between his mother’s legs, would not speak above a whisper, and only in her eat and behaved in a highly atypical fashion for him, He later told GR that the masks were scary (bh) EE s son may also lose his Senior Kindergarten year of schoo) this coming September, 2020, depending on what is ‘allowed’ and ‘required’ at that point in time. (MMs husband has stated “(ERs basically in prison. I don't blame him for being squirrely.” 33. As a chiropractor, NEM objects to the emergency measures and measures enacted by the various layers of government for the following reasons (a) When restrictions were lifted on the practice of chiropractic, her college followed mandates set forth by the Minister of Health (“MOH”) that RB 8s & practitioner, wear a medical-grade mask when unable to maintain a two-meter distance from her patients (i.e. during the treatment portion of the visit). This mandate occurred after she had written and sent two letters to government officials (one of these letters directly (0 Joel Friedman of CCO), detailing the lack of effieacy and benefit as well as the numerous risks to those wearing a mask or those they interact with MEE ststcs that this is not only a violation of her right to bodily integrity and right to choose, but also has had detrimental effects on botltE-octon.ca y ssuod / D6 w6 par vo 6 econ quo =06-Ju-2020 Court File No/N* du dos: du greffe: CV-20-00643451-0000 her physical and mental health. There were no exemption criteria given for this mandate for chiropractors. (b) Speci cally, MINI ios found that mask-wearing causes her to Feel sleepy, mentally dull, and causes headaches. Furthermore, the mandate to mask served to activate previous personal trauma for her, and has been detrimental to her mental health in this regard, (©) Forced reduction in activity has had a negative impact on her livelihood and her income, while she remained accountable for her expens Furthermore, some patients who cancelled their appointments, or have been without care, and who otherwise would have had in-person follow up, have experienced exacerbations to pre-existing conditions, without those visits (a) Apparent harm to patient trust and rapport, with children being aftaid to come near after stating they cannot breathe, on her freshily disinfected table, As of June 18", 2020, ED can specific: reporting having gone on anxiety medication specifically due to pandemic for treatment and adults choosing to wear a mask ly cite one (1) patient anxiety ; one (1) mother of'a female child reporting her child screaming in fear prior to her appointment; one (1) mother of a three (3) year old reporting screaming of her child when seeing masks; one (1) new patient rating his health and wellbeing a 3/10 since lockdown, where prior to that he rated it as a 7-8/10 ; numerous conversations with patients about stress related to covid and the measures enacted - stress of working without 36E-octon ca y ssuod / D6 w6 par vo 6ocon quo -06-Ju-2020 Court File No/N* du dos: du greffe: CV-20-00643451-0000 childcare, stress of lost job and financial uncertainty, stress of poor ergonomics working trom home ; numerous conversations with other parents about how their children have been affected - including sleep problems, speech regressions, behavioral issues; numerous patients have spoken of stress around wearing a mask, and the negative effects they [cel when wearing one (which was mandated by WDG region when entering, commercial enterprises). (e) MEE firrther states, and fact is, that at the outset of the emergency measures, messaging was delivered, by the Ministry of Health, to Ontario- based chiropractors, not fo talk about or share how they can help improve resiliency and fortify immunity, on threat of receiving a professional complaint with no certainty as to how that complaint would be decided. This is not in alignment with the oath swom upon entering practice to “first dono harm’, nor is it congruent with the right to freedom of expression (f) When (EE discussed this with the lawyer for the Chiropractor College of Ontario (*CCO") , Mr. Joel Friedman, the message was that if MB speaks about anything, that she does so at her own professional peril. However Mr. Friedman was clear that CCO would fully support MEE dissemination of the narrative coming from the MOH and government, but to speak against the MOH ot government ‘would be at her own risk, even if in alignment with published science and best available medical evidence. 37E-octon ca y ssuod / D6 v6 par vo 6 econ quo = 06 Ju-2020 Court File No/N* du dos: du greffe: CV-20-00643451-0000 (zg) As a health careworker, with a background in research, further objects to the WDG mandatory mask order because il is not aligned with best evidence and known science and creates unnecessary risk to physical health, mental health, relational and social health, as GE clearly articulated in a third letter sent to various levels of elected officials, to which IEE has received no response Furthermore, there is no end date on the order or even a date of te asses ment as Would seem prudent for un evidence-informed approach to this. No cited science was given to support this order of mandatory masking 6 he ini, cc HE "esices in Hamilton, Ontario, 35. I's © 23 yecr-old mate with autism diagnosis since aye three @). 36, He is 6°3"", weighs 220 Ibs., and has been assessed by a Philologist functioning at the level of a four (4) year-old Although he has speech, and can read some, his emotional and functional age is four (4). 37, EE bs been totally, mentally, devastated by the COVID- measures, in depriving him of his rouline activities and social and emotional network, without recourse, He suffers severely, from not being able to understand, nor uccommodate, under the Covid-measures, why he cannot play where he has played, or anywhere else, why he cannot do the other physical and social activities he did. He will not countenance wearing a mask , does not 8Eoctronca y ssucd | D6 wé par voe 6 octron que :06-Ju-2020 Court File No/N* du dos: du greffe: CV-20-00643451-0000 understand and therefore cannot comply with “social distancing” or “isolation”, tiven his severe neurological disability and his special needs. The plaiutitt, through his litigation guardian, states that Scott’s ss.2 and 7 Charter are being violated, and given his disability, his s.15 Charter, through the acts and omissions of the Covid-measures, are also being: violated in that NO regard, thought, nor measures, whatsoever. were enacted or executed to mitigate the utterly devastating damage to the mentally and physically disabled as a result of the Covid-measures. The fact is that [fs entire support, social, medical, and therapeutic network has been ripped away from him without any regard to his special needs. 38. The Plaintiff, Professor Denis RANCOURT, Ph. D., resides in Ottawa, Ontario. 39. Denis Rancourt, B.Sc. M.Sc., Ph.D., is a former tenured Full Professor of Physies, University of Ottawa, Pull Professor is the highest academic rank, He is an expert int public health, He has taught over 2,000 university students, and supervised more than eighty: (0) jumior rescurch terms or degrees at all levels from post-doctoral fellow to graduaie students’ to NSERC undergraduate researchers. He headed a research laboratory, and attracted significant research funding tor two decades, He supervised doctoral students in both physics and environmental science. He lias been an invited plenary, keynote, or special session speaker at major seientific conferences nearly forty (40) times. He has published over one hundred (100) research papers in leading scientific journa in the areas of physics, chemistry, geology, materials science and environmental science, including environmental nanoparticles. He co-discovered the 8Ecctronca y ssued / Dé we par voe @ectronque :06-Ju-2020 Court File No/N* du dossier du greffe: CV-20-00643451-0000 phenomenon of “superferromagnetism”, and co-discovered the unique meteoritic alloy “antitaenite”, He has a scientific impact factor (h-index) of 39 (84% of Nobel Prize winners in physies had h-indexes of at least 30), and his anticles have been cited more than 5,000 times in peer-reviewed scientific journals, 40, Presently, Dr. Rancourt is a registered mentor for physics students at the University of Toronto, and is a Researcher (volunteer position) at the Ontario ci ql iberties Association (ocla.ca). He is a frequent media commentator. [lis articles and interviews are published in many media venues. His recent video interviews and reporting videos about the science of the COVID-19 epidemic and the science of masks for preventing viral respiratory diseases have already been viewed more than 0.5 million times. He is scheduled to be an invited opening speaker at the October, 2020 ‘Fifth International Public Conference on Vaccination’, organized by the National Vaccine Information Center (NVIC) (USA). AL The Plaintiff, RANCOURT, in April, 2020, published an article entitled “Masks Don’t Work: A review of science relevant to COVID-19 social policy”. This was carried on the “Research Gate” website. Subsequently, “Research Gate” removed the article Rancourt’s article after the article had received some four hundred thousand (400, 000) reads. 40E-octon ca y ssuod / D6 w6 par vo 6 econ quo =06-Ju-2020 Court File No/N* du dossier du greffe: CV-20-00643451-0000 42. 43. ‘YouTube also removed three of 3 of RANCOUR'T’s videos, which were part of his * PlayList* entitled “COVID-19 with Denis Rancourt", The 3 videos were entitled: * “Masks don't work against COVID-19 article by Denis Rancourt” “Jane Scharf advocate for vulnerable persons reacts to COVID-19 policy” * “Denis Rancourt- Why COVID-19 is global mass hysteria” RANCOURT states . and the fact is, that Youtube removed the videos in accordance with its publicly- stated policy to remove any “misinformation” contrary to its “community standards”, with respect to covid-measures, which is coneadedly applied to any and all opinions that ran contrary to the official WHO dogma, notwithstanding that those contrary opinions come from recognized experts in their field. RANCOURT has written or co-authored the following published authoritative documents about COVID-19: * “Masks Don’t Work: a Review of Science Relevant to Covid-19 Social Policy”, first published und widely distributed on 11 April 2020. “Cy icism of Government Response to COVID-19 in Canada”, Report for the Ontario Civil Liberties Association (OCLA), first published and sent to governments and media on 18 April 2020, » “All-cause mort ity during COVID-19: No plague and a likely signature of mass homicide by government response”, first published and widely distributed on 2 Sune 2020, DOL: 10.13140/RG.2.2.24350.77125 alE-octon ca y ssuod / D6 w6 par woo 6 econ quo = 06 Ju-2020 44, 45. * “OCLA Asks WHO to Retract Recommendation Advising Use of Face Masks in General Population”, 9-page letter, co-authored with OCLA Executive Director Dr. Joseph Hickey, sent to the WHO Director General. all MPs, all Premiers, all Ontario MPPs, and the media on June 21", 2020. Despite this timely and authoritative body of work, noted by the scientific community, and covered in the international media, the CBC has refused to make any mention of these works, and has not provided these perspectives and this, scientific information to the Canadian public, RANCOURT further states that CBC has chosen to not cover any other experts who take eritical or contrary view of the COVID measures executed by the Federal, Provincial, and Municipal governments at the direction and behest of the WHO. A CBC high-profile journalist had interviewed RANCOUR', at length, about face masks, said the content would be on the evening news, on his blog, and on the radio, and then the content was never used. RANCOURT states, and the fact is, that the Federal Crown, and respective Ministries and agencies charged with Broadcasting, and freedom of speech, expression, and the media, have chosen not (0 protect against this flagrant censorship, and as such, through omission, inltinge RACOURT’S, and other Plaintiff®’, right to freedom of speech, expression, and the media contraty to 5.2 of the Charter. in fact the federal Crown further supports these violations by its threat to criminalize, under the Criminal Code, the same contrary opinions now being censored, as “misinformation”, even where those opinions come from recognized experts. RANCOURT further states that he opposes all current a Court File No/N* du dossier du greffe: CV-20-00643451-0000Eocton ca y ssucd / D6 wé par voo Goctron que :06-Ju-2020 46, 47. 48. 49. 50. 52, COVID-Measures because they ate not scientifically or medically bused, rely on false and distorted data , are based on a false declaration of a pandemic, and because they vivlute his ss.2, and 7 Charter rights, «= The Defendants The Defendant, Justin Trudeau, is the current Prime Minister of Canada, and as such, a holder of a public office. ‘The Defendant, Dr. Theresa TAM, is Canada’s Chief Public Health Officer and as such a holder of a public office. The Defendant Her Majesty the Queen in Right of Canada, is statutorily and constitutionally liable for the acts and omissions of her officials ‘The Defendant Attorney General of Canada is, constitutionally, the Chief Legal Officer, responsible for and defending the integrity of all legislation, as well as responding to declaratory reliof, including with respect constitutional declaratory relief, and required to be named as a Defendant in any aetion for declaratory relief, The Defendant Mare GARNEAU is the Federal Minister of Transport, and as. such a public office holder. ‘The Defendant Her Majesty the Queen in Right of Ontario, is statutorily ancl constitutionally liable for the acts and omissions of her officials. ‘The Defendant Attorney General of Ontario, is, constitutionally, the Chief Legal Officer for Ontario, responsible for and defending the integrity of all legislation, as well as responding to declaratory relief with respect to legislation, eB Court File No/N* du dossier du greffe: CV-20-00643451-0000Eoctronca y ssuod / D6 w6 parvo e 6 octon que :06-Ju 2020 Court File No/N* du dossier du greffe: CV-20-00643451-0000 including with respect to its constitutionality, and required to be named as & Defendant in any action for declaratory relief. 53. The Defendant Doug FORD, is the eurreat Premier of Ontario, and as holder of a public office. 54. The Defendant Dr, David WILLIAMS, is Ontario's Chief Medical officer, and as such a holder of a public office. 58. ‘The Defendant, Christine ELLIOT, is the current Minister of Health and Long- Term Care for the Province of Ontario and as such a holder of a public office and Long-Term Care. 56. The Defendant Stephen Lecce, is the Minister of Education for Ontario. 57. The Defendam, The City of Toronto, is 2 Municipality in the Province of Ontario and governed by, inter alia, the Municipal Act and all other applicable Provincial Acts. 58. The Defendant JOHN TORY, is the Mayor of the City of Toronto, and as such a holder of a public office, 39. The Defendant Dr. Bileen De VILLA, is Toronto’s Chief Medical Officer, and as such a holder of a publie office. 60. The Defendant County of Wellington- Dufierin- Guelph is a County in the Province of Ontario and the Defendant, Nicola MERCER is its (Chief) Public Health Officer, and as such, Nicola MERCER is a holder of public office 61. The Defendant County of Windsor-Essex is a County in the Province of Ontario and the Defendant, Wajid Ahmed is its (Chief) Public Health Officer, and as such, Wajid Ahmed is a holder of public office.Eoctronca y ssuod / D6 w6 par voo éoctron que :06-Ju-2020 Court File No/N* du dossier du greffe: CV-20-00643451-0000 62, ‘The Defendant unknown Johns and Janes DOE, are employees of the Crown and Municipal Defendants and as such are holders of a public office. 63. ‘The Defendant, The Canadian Broadcasting Corforation (“CBC”), is Canada’s publicly-funded broadcaster and governed , inter alia, under the Federal Broadeast Act, with a public mandate as Canada’s national publicly-{unded broadcaster. 45Eoctronca y ssund / D6 w6 par voo 6 octon que :06-Ju 2020 Court File No/N* du dossier du greffe: CV-20-00643451-0000 THE (FURTHER) FACTS 64, 65. 66. 67, 68. A/“COVID- 19”- THE TIMELINE In 2000 Bill Gates steps down as Microsoft CEO and creates the ‘Gates Foundation’® and (along with other partners) launches the ‘Global Alliance for Vaccines and Immunization (‘GAVI’’). The Gates Foundation has given GAVL approximately $4.1 Billion. Gates has further lobbied other organizations, such as the World Economie Forum (“WEI”) and governments to donate to GAVI including Canada and its current Prime Minister, Justin Trudeau, who has donated over $1 Billion dollars to Gates/GAVI In 2002 Scientists engage in “gain-of-function” (GOF) research that seeks to generate vituses “with properties that do not exist in nature” and to “alter a pathogen to make it more transmissible (to humans) ar deadly." '” In November, 2002, China’s Guangdong province reports the first case of “atypical Pneumonia’, later labeled as SARS, In. the same month at. the University of North Curolina (UNC) Ralph Baric announced the creation of a synthetic clone of a mouse coronavirus. On October 28", 2003 the Baric group at UNC announces a synth recreation of the SARS virus, Tn 2005 Research demonstrates that Chloroquine is a potent inhibitor of SARS. coronavirus infection and transmission. * > exis eb nim nb gav/books/NBK285579/ * np slencomag.or/aews20.4/10/5 halls funding: ew nsky- es sles call wolumary moratorium “hata nebinim.t gov/pme/artcle/PMC252969/ 46Eoctronca y ssucd / Dd w6 par voe 6 octron que :06-Ju 2020 Court File No/N* du dossier du greffe: CV-20-00643451-0000 69, 10. 7 72. From 2009 to the present. the “Bill and Melinda Gates Foundation” donates millions to the ‘Imperial College of London’ (ICL), and further funded the debunked modeling, by Neil Ferguson, at the ICL, that set the COVID-19 “pandemic” declaration in Motion and acceleration, through the WHO and ic govemments around the globe following suit In January 2010 Bill Gates pledges $10 billion in funding for the World Health Organization (* WHO”) and announces “the Decade of Vaccines.” In fact, Bill Gates and GAVT are the second and third largest funders of the WHO after the US government. Currently, the USA, through its President, has cut off funding’s to WHO for loss of confidence in it. (Various other countries have also expelled the WHO on allegations of corruption, attempted bribery of its officials, and lack of confidence) In May 2010, the Rockefeller Foundation writes a Report, later leaked, unintentionally from within the organization, with a study of a future panclemic scenario, where an unknown virus escapes Wuban, China, and a “hypothetical” scenario on what the appropriate response would be, aind its core scenario entitled “how to secure global governance in a pandemic”. The Plaintiffs state and the fact is, that the scenario scripted in this May 2010, Report is what has unfolded during the “COVID-19” so-called “pandemic” In 2011 a review of the literature by the British Columbia Centre for Disease Control to evaluate the effectiveness of social distancing measures such as school closures, travel restrictions, and restrictions on mass gatherings to address an influenza pandemic concluded that “such drastic restrictions are not a7Ecctronca y ssund / Dd w6 par voo Goctron que :06-Ju2020 Court File No/N* du dossier du greffe: CV-20-00643451-0000 B. 74. 75. 16. 71. economically feasible and are predicted to delay viral spread but not impact overall morbidity.” * In May, 2012, the 194 Members States of the "World Health Assembly” endorse the ‘Global Vaceine Action Plan (GVAP) led by the Bill and Melinda Gates Foundation in collaboration with GAVI, and the World Health Organization (WHO) In 2014 Under President Obama, the National Institute of Health (NIH) halts federal funding for gain-of-function (GOP) research. The funding hiatus applies to 21 studies “reasonably anticipated to confer attributes to influenza, MERS, or SARS viruses such that the virus would have enhanced pathogenicity and/or teansmissibility in mammals via the respiratory route.” NIH later allows 10 of the studies to resume. In 2015 NIAID awards a five-year, $3,7 million grant to conduct gain-of- function studies on the “risk of hat coronavirus emergence.” ‘Ten percent of the award goes to the Wuhan, China, Instiwute of Virology. In January, 2015 at a public appearance, Bill Gates states: “* We are taking things that are genetically modified organisms and we are injecting them into little kids* arms; we just shoot them right into the vein’ In 2017 Dr. Mare Lipsiteh of the Harvard School of Public Health tells the Ney York Times that the type of gain-of-function experiments endorsed by Dr. Fauci's NIAID have “done almost nothing to improve our preparedness for pandemies, and yet risked creating an accidental pandemic.” * Social Distancing as a Pandemic Intuenza Prevention Measure ipa free enfwp.comtent/uplsds/sies/2/2055/03/HIN1_ 3 iad 48Eccton ca y ssucd / Dd w6 par vo 0 Goctron que :06-Ju 2020 Court File No/N* du dossier du greffe: CV-20-00643451-0000 8. 79. 80. a1 82. In 2019 NIAID awards a six-year renewal grant of $3.7 million to Ecol lealth Alliance and the Wuhan Insiitute of Virology (in China) to continue their gai of-function studies on bat coronaviruses. At the January, 2019, World Reonomic Forum in Davos, Switzerland, on January 23", 2019, on a CNBC interview Bill Gates boasts that he expects to have a “twenty-fold” return on his $10 Billion vaccine investment with the next few decades. British and French researchers publish 2 study (May 5, 2020) estimating that COVID-19 could have started as early as October 6, 2019. ‘On October 18", through 27", 2019 Wuhan, China hosts the Military World Games, held every four years, where more than 9,000 athletes, from 100 countries complete. ‘The telecom systems for the Athletes’ Village are powered with 5-G technology “showcasing its infrastructure and technological prowess” On October 18, 2019 - The Bill & Melinda Gates Foundation, the World Economic Forum and the Johns Hopkins Center for Health Security convene an invitation-only “tabletop exercise” called Event 201 to map out the response 10 a hypothetical global coronavirus pandemic. In November-December, 2019, - General practitioners in northern Italy start noticing a “strange pneumonia.” On December 2" and 3'°, 2019 Vaccine scientists attending the WHO's Global Vaceine Safety summit confirm major problems with vaccine safety around the warld, 49E-octon ca y ssuod / D6 wé par vo 6 econ quo = 06 Ju-2020 Court File No/N* du dossier du greffe: CV-20-00643451-0000 85 86. 87. 88 89. 90. On December 3", 2019, At the Global Vaccine Safety Summit in Geneva Switzerland, Prof Heide Larson, MA PhD, Director of the “Vaccine Safety Project”, stated: “I think that one of our biggest challenges is, as Bob said this morning, or yesterday, we're in a unigue position in human history where we’ ve shifted the human population to vaccine-induced., to dependency on ‘yaecine-induced immunity and that’s on the great assumption that populations would cooperate. And for many years, people lined up the six vaccines, people were there; they saw the reason. We'te in a very fragile state now. We have developed a world that is dependent on vaccinations, We don’t have a choice, but to make that effort.” On December 18", 2019, researchers at the Massachusetts Institute of ‘Technology (MIT) report the development of a novel way to record a patient's vaccination history, by using smart-phone readable nano-crystals called “quantum dots’’, embedded in the skin using micro-needles. In short, a vaccine chip embedded in the body. This work and research are funded by the Bill and Melinda Gates Foundation. ‘On December 31,2019 - Chinese officials inform the WHO about a cluster of “mysterious pneumonia’ ases, Later, the South China Morning Post reports that it can trace the first case back to November 17" , 2019, On January 7, 2020 - Chinese authorities formally identify a “novel” coronavirus. On January 11, 2020 - China records its first death attributed to the new coronavirus, On January 20, 2020 - The first U. oronavirus ease is reported in Washington State 30Eoctronca y ssusd / D6 w6 parvo 0 6 ectron que :06-Ju 2020 Court File No/N* du dossier du greffe: CV-20-00643451-0000 oO 98 94, 95. 96. 97, 98. On January 23", 2020, Shi Zheng-Li releases a paper reporting that the new corona virus (COVID-19) is 96% identical to the strain that her lab isolated from bats in 2013 but never publicized. On Jannary 30, 2020 ~The WHO declares the new coronavirus a “global health emergency.” In January, 2020 - A study of US military personnel confirms that those who received an influenza vaccine had an increased susceptibility to coronavirus infection, * On February 5", 2020 - Bill and Melinda Gates announce $100 million in finding for coronavirus vaccine research and treatment efforts. On February 11", 2020 the WHO gives the virus its name: *COVID-19"* On February 28", 2020 - ‘The WHO states that most people will have mild symptoms from SARS-CoV-2(*COVID19") infection and get better without needing any special care, On February 28", 2020 , the WHO announces that more than 20 vaccines are in development globally. On February 28", 2020, the WHO staies ~ “Our greatest enemy right now is not the virus itself! It’s fear, rumors and stigma.” © On March 5", 2020 - Dr. Peter Hote of Baylor College told a US Congressional Committee that coronavirus vaccines have always had a“ c.com/sconce/arele/oa/s026as 10H 9213647 fale opening remarks at Une media being on COVID-19 - 28 Fabruary 2020 ho n/de/specehes/ cal whe decor general open fmarka he mty-brcing-on cova 31Eoctronca y ssucd / Dd wo par voo 6 oetron que :06-Ju-2020 Court File No/N* du dossier du greffe: CV-20-00643451-0000 99. 100, 101 102, 103. 104. 105 potential safety problem” — a “kind of paradoxical immune enhancement phenomenon.” 7 On Mareh 11,2020 - The WHO declares COVID-19 a pandemic, On March 12", 2020 Education Minister Stephen Lecce ordered the closing. down of public schools, on the advice of Dr. Williams the co-Defendant On Mareh 16", 2020 - Neil Ferguson of Imperial College London, scientific advisor to the UK government, publishes his computer simulations warning that there will be over two million COVID-19 deaths in the U.S. unless the country adopts “intensive and socially disruptive measures.” Imperial Ci lege London receives funding from Bill and Melinda Gates Foundation. (On Mareh 16", 2020 - Dr. Anthony Fauci tells Americans that they must be prepared to “take more drastie steps” and “hunker down significantly" to siow the coronavirus’s spread, ‘On Mareh 16", 2020 - NIAID launches a Pt 1 trial in 45 healthy adults of the mRNA-1273 (COVID-19) coronavirus vaccine co-developed by NIAID and Moderna, Inc. The trial skips the customary step of testing the vaccine in animal models prior to proceeding to human trials. ‘On Mareh 17", 2020 — Prime Minister Trudeau asks for lockdown measures, ‘under the Federal Quarantine Aet, banning travel. The same date Premier Doug FORD declares an Emergency in Ontario, under ots Provincial legislation. ‘On Mareh 19", 2020 - The status of COVID-19 in the United Kingdom is downgraded. COVID-19 is no longer considered a high consequence infectious disease (HCID). The Advisory Committee on Dangerous Pathogens (ACDP) in hitps/ fw span ore vieo/787003S-1/housestencs-space-echdiog-commtteeshearins-) “Emergency No. 2 -To impose physical distancing within Nathan Phillip Square in the same manner as other Public Squares” It is to be noted that these two orders were NOT passed, pursuant to Provineial legislation, but under the City of Toronto’s own By-Law Municipal Code. It is 67Eoctronca y ssucd / Dd w6 par voo Goctron que :06-Ju-2020 Court File No/N* du dossier du greffe: CV-20-00643451-0000 further to be noted that the Municipal Measures in fact contradicted, and were more restrictive than the Provincial Measures and are therefore illegal and ultra vires, notwithstanding that Municipal enforcement offices then detained and charged persons under the Provincial Offences Act, for engaging in activities in compliance with Provincial law, covering the same matters(s) and activities 150. The City of Toronto further passed By-Law 322- 2020, in which it banned, under s, 1, and s, 2, anyone remaining in a_park or public space “for longer than aan incidental period”, and socially distancing with only “members of the same household”, which is completely in contravemion of the Provincial order in Provincial Regulation © Reg 104/20, s. 1(4), passed pursuant to s, 7.0.2(4) of the Ontario Aet. The Plaintiffs state, and the fact is, thal not only were these measures which were enforced, ultra vires the Provincial legislation, but further violated ss.2, 7,8, and 9 of the Charter. This By-Law further provides for the delegation of the By-Law provisions whieh was delegated to the Chief officer of Health, Eileen De Villa, a co-Defendant in the within claim. 151. On April 1, 2020 a “Class Order” purportedly passed pursuant 10 s. 22(5.0.1) of the Health Protection and Promotion Aet, Dr, Eileen De Villa, Toronto’s Medical Officer of Health, made an order, for anyone who: a) Is identified with a diagnosis of COVID-19; b) Has signs and symptoms of COVID-19.0r have been tested and awaiting results; ©) Otherwise has reasonable grounds to believe to have COVID-19; d) Is inclose contact with any in (a) to (c) above, 68Eoctronca y ssuod / Dd w6 par voe Goctron que :06-Ju-2020 Court File No/N* du dos: 152, 153, Were ordered by De Villa to: a) Isolate and stay at home, with no visitors, b) Remain in isolation for 14-days; And further made an array of other orders respecting follow-up Medical advice and treatment. Exemptions to this order were made for: a) Asymptotic person who provide essential services: b) those receiving essential medical services; and ©) anyone who in the opinion of Toronto public health would not be in the public interest, ‘The enunciated rationale for this “class order was” on the grounds that, inter alia, COVID-19 was a communicable “disease”. ‘The Plaintiffs state, and the fact is, that De Villa's orders were neither scientifically nor medically grounded, were statutorily ultra vires . and violate s. 2, 7, 8, and 9, and 15 of the Charter. The Plaintiffs further state that there was no evidence, scientific or medical, to have reasonable and probable grounds thal it was any way more pervasive or dangerous than any other seasonal viral respiratory illness of the past fifteen (15) years. On June 28", 2020, the City of Toronto introduced a By-Law to require mandatory, community, face-masks requirements for indoors, of all “publie™ spaces, including private business open to the public, The city issued posters tor store owners to post, which included the requirement of store owners to enforce masking, but NO mention of exemptions to masking 69 du greffe: CV-20-00643451-0000Eocton ca y ssucd | Dé w6 parvo o Goctronque :06-Ju-2020 Court File No/N* du dossier du greffe:_CV-20-00643451-0000 154. On June 30", 2020, the Canadian Civil Liberties Association called for the extraordinary step, calling on the public to engage in “civil disobedience” of the ‘Toronto masking By-Law. based on the overwhelming scientific and medical evidence, that masks are ineffective and pose heath risks. 155. Moreover, the Plaintiffs state, and fact is, that the enforcement officers were, on the ground, stopping, detaining and charging individuals, under the Provincial Offences Act, such as a single person sitting by herself on a park bench with no- one around, or a child bicycle riding through a park with a parent based on the media reports of Trudeau, Ford , and Tory, and their respective Chief Medical Officers, illegally declaring 10 “Stay home” and “do not go out except for food and medicine”, when in fact such prohibitions were nowhere ta be found in the Jaw. + Reckless and Unlawful Statements and Actions of Leaders 156. The Plainti fs state, and the fact is, that Trudeau, Ford, and Tory were (and continue to be) reckless in their groundless, ignorant, and arrogant dictates, Without legal basis, so as to eause and instill a general atmosphere of fear, panic and confusion. Such decrees by Trudeau, Ford, and Tory include, but are not restricted to the following: (a) With respect to Prime Minister Justine Trudeau, he made the following (mis )statements, for example: (i) Prime Minister Justin Trudeau told Canadi staying home, self-isolating with famil ians: “People should be a upsyfortawsciwen com/neuslocaknews/eou 18c00hined. snows and omnocovsopmantt i 0Eoctronca y ssusd / Dé wr parvo o 6 octon que :06-Ju 2020 Court File No/N* du dossier du greffe: CV-20-00643451-0000 (ii) “We've all seen the pictures of people online who seem to think. they’re invincible,” Trudeau said. “Well, they’re not. Go home and stay home.”*> (i) Justin Trudeau has issued a stem warning to Canadians who ignore social distancing advice, telling citizens to “go home and stay home!” — and leaving open the possibility his government could take more extreme measures as the number of confirmed coronavirus cases continues Lo rise.” (iv) “To all the kids out there, whe can't go on play dates or on spring break vacation...1 know this is a big change, but we have to do this for our grandparents and for the nurses and doctors. in hospitals," () “So, to everyone, stay at home, and no matter what stay 2 meters apart, if you do have to go out, When it gets hard let’s remember wwe ate all in this together.” (24:35) *...how important it is not just for ourselves, but for our loved ones and health care workers, for our seniors, that we stay home, that we stay 2 meters apart, as much as we can and that we continue to wash our hands repularly.* 430212)" (vy “I know it is tough to stay home, especially as the weather gers nicer, If you have kids, it is even tougher, but to get back outside and running around the playground and park as soon us possible, you need to keep them inside for a little longer. (10:22)" (i) “...but T can tell you that we know it is very difficult sitnation for Canadians, There are very challenging projections out there that will emphasize how important it is for all of us 10 do our part, to stay home, to keep ourselves safe, to keep our loved ones safe and get through this. ."(42:26)"° (viii) More and more Canadians are avoiding public spaces. If your friends or family members are still going to parks and playgrounds, they are risking lives, Tell them to stop. (ix) On the topic of Asymptomatic viral shed contradiction puts to questions the merit of social distancing among healthy people: A patreved a: hipsi/aown vee com/en.a/arie/aSengenronavews updates cana ott pst ee sh ie-peogle ia teepthen-Fome oronavicy say hae peteved at: Hse, heguanan con fon) 23vsn-vudi. " gps dw tehinod- new com/met rap lodges cov S8ocown pe ve HW aw, tbe con atch =ToMAB TAOS * Retrieved at \itos/ sw youtube com /watch?v=ASGDKEUH¥SA * peunever at btps,// maw. yautube com witchvamlASOMLINS 1.14103554 utos/spbsswime.com/mens/evto mune yabR NR 7E-octon ca y ssuod / D6 v6 par wo 6octon quo =06-Ju-2020 Court File No/N* du dossier du greffe: CV-20-00643451-0000 reporter asks Mr, Trudeau, after his wife had been (ested positive for coronavirus, what kind of advice he had received from medical doctors “In terms of advice [have gotten from medical professionals, it was explained to me that as long as I do not show any symptoms at all, there is no value in having me tested,” (15:30)A reporter asks about the possibility of transmission to other members of the cabinet,17:02 “According to Health Officials the fact that Ihave expressed no symptoms means that anyone that L engaged with throughout this week has not been put at risk (17:12) (6) While Trudeau made the above-noted comments and decrees, without legal basis whatsoever, and further contradicted actual Provincial Jaws, Trudeau, all the while breaks social distancing Provincial Laws by: : (i) On Mareh 29, 2020 ; Dr. Theresa Tam, the Chief Public Health Officer of Canada’ “Urban dwellers/Cottagers should RESIST THE URGE: to head to the cottage and rural properties as these ‘communities have less capacity to manage COVIDI9, (i) On April 1*, 2020 the government of Quebec introduced strict travel restrietions actoss the province, including police checkpoints to prevent unnecessary travel in and out of Quebec (ii) Shortly afier calling on Canadians to “stay home” and kype that big family dinner,” ‘Trudeau crossed the provincial border from Ottawa into Quebec on Easter privet Mpe// wow youl com watch SERIA nEoctronca y ssund / D6 wo parvo o Goctron que :06-Ju-2020 Court File No/N* du dossier du greffe: CV-20-00643451-0000 Weekend to visit his wife and three children who had been living at their Harrington Lake cottage since March 29 , 2020." (©) With respect to Premier Doug Ford: (i) Premier Ford tells business they can refuse customers that will not ‘wear a mask, "Any business has the right to refuse anyone. ‘That's their business," Ford said on a teleconference last week. Despite the fact that no mandatory masks order was in place, and contrary to the legal opinion of the Canadian Civil Liberties Association (CLA); (ii) Ford tells people to stay away from their cottages but goes to visit his own cottage:"* ii) Doug Ford has over his two daughters, and family, who each live in different households for a total of 6 ~ violating 5 person maximum orders." (@) With respect to Toronto Mayor John Tory: (i) On April 19, 202 jumerous photos of social distancing violations during a parade to salute health care workers (pictured standing shoulder to shoulder down University Ave.)"" Retrieved a itga/ lobes 3 /n/ 681 5536/co,onavus usm tradgay- andrew schsr-aste av os ven brates ca [news tor /9954798-dous ora buinnssn-consause anyose nak wens mash ba sighns watehdonsevenet sas Pibclé=iarz ba 4adansheaiomGtmhwdihvallmacacv 703i nos/ mr inbremon.com/n-maskne-seric: businesses havethe-rghttozequie-mas3-01- slomes7IbcbSsNAR UMC \IXLASH {aut 7 MIDSGECSSTACPAIF BMD 7e * https //toronto.citynews.ca/2020/05/08;/tord-cottage-corunayirus/ > huts: fornia /eencanaca/torentaforephystabditancing davstiene) 5368756 * pateved rom: ipa’ nw cba ca/nevs/cinida/Lorntaftronig ste hell nEoctronca y sued / D6 w6 par vo e 6 octon que :06-Ju-2020 Court File No/N* du dossier du greffe: CV-20-00643451-0000 (ii) May 23: Here is Tory violating social distancing rules and modeling counterproductive mask use at Trinity Bellwoods park , where thousands had gathered;"* 157. ‘The Plaintiffs state, and the fact is, that the various leaders are fast and loose with ignoring their own rules, contrary to law, and ignoring the actual rules implemented, because they know the measures are false and ineffective and that the virus is no more dangerous than a seasonal viral respiratory illness. This further holds true for Neil Ferguson who put out the false modeling early on, in March, 2020, and who had to resign his post in the UK for breaching the Rules. ‘Other examples of such reckless behaviour and statements include: (a) On April 25th FORD ealls protestors opposing government lockdowns as “selfish” “irresponsible” “yahoos”; (b) Mayor John Tory agreed with Ford, saying the quickest way to end the shutdown is for people to stay home. "Gathering in a large group is to thumb your nose at well accepted science and professional health adviee, It risks undoing the yood we have all sacrificed to achieve together. In fact it runs the risk of making the shutdown longer," Tory said in a statement on Saturday.” The Plaintiff states, and fact is, that TORY has no clue, and is wholly unqualified, and has not, assessed the “well accepted science” and “advice”, and same holds for FORD and TRUDEAU, all of whom simply follow one singular dogma from the WHO, while refusing to disclose the “science”, its substance or source, * reid a: tntps//ewra:cp28.com(viceoehpla=1 673 * Retrieved at: httpsi//wwww.cb¢.ca/news/canada/toronto/ontario-shutdown grotesters-queens atk vyahoos-1.5545253 4Ecctronca y ssued / Dé we par voe @ectronque :06-Ju-2020 Court File No/N* du dossier du greffe: CV-20-00643451-0000 and what “advice” is being given by whom to them all-the-while ignore vast pool of experts who state that the measures are NOT warranted, (c) Andrew Scheer and family, Elizabeth May, and Liberal Cabinet Minister ignore social distancing orders: “Parliamentarians packed onto a small nine-seat government jet last week — ignoring pandemic health guidelines to maintain a distance of two meters from others — in their haste to reach Ottawa for a vote on federal emergency economic legislation that passed on Saturday. Green Party Leader Elizabeth May, who lives in B.C, boarded the Challenger jet along with Liberal B.C. cabinct minister Carla Qualtrough, Conservative Opposition Leader Andrew Seheer, his wife and their live children last Friday — filling all seats on the zirerali"* (@) Dr, Bonnie HenryBC Provineial Health Officer allows gatherings of 50 and when challenged on conificting figures from across Canada confirm “None of these are based on scientific evidence **! (e) Dr, Yatfe:Ontario's Associate Chief Officer of Health Dr. Yafle caught blatantly violating the social-distancing rules, just minutes fier the premier suid that based on public-health officials’ advice we'll have to stay ‘on lock-down for an indefinite period.” No such indefinite “lock-down” ‘was mandated by any law. 158, ‘The Plaintiffs state, and the fact is, that the illegal actions, and decrees issued by Trudeau, Ford, Tory, and other public officials were done. in abuse and excess of their offices, knowingly to propagate @ groundless and falsely-declared ‘pandemic"’, and generate fear and confusion on the ground, not only with “ potived tom pe //aura.cbeca/nows/goliies/hatlenger ‘ita scheorqualeoueh 15530507 “foteved at MDs. eee 2/2020/04/0/9-08-uodging-on 5 poison mi-esticoon * gssircom/RonenaryFeiTO/ sti 125450827322003513, 1BEccton ca y ssucd / D6 w6 parvo o Goctron que :06-Ju-2020 Court File No/N* du dossier du greffe: CV-20-00643451-0000 citizens, but further, and moreover, with enforcement officials who are pursuing, detaining, ticketing for perfectly legal conduct, because of the contradictory laws, and conduct of these public officials. All the while, their own personal conduct clearly manifests a knowledge that the ‘pandemic™ is false, and the measures phony, designed and implemented for improper and ulterior purposes, at the behest of the WHO, controlled and directed by Billionaire, Sorporate, and Organizational Oligarchs. C/ IGNORING AND NOT ADDRESSING THE MEDICAL EXPERTS’ EVIDENCE * The Nature of Viral Respiratory Lllness (or Disease) and COVID-19 159. The Plaintiff Dr. Denis RANCOURT, Ph.D., and co-Plaintiffs state, and the fact is that, as is borne aut by vast preponderance of medical and scientific study, that regardless of the novel viral specification (“strain”), viral strains which lead to Seasonal Viral Respiratory IlIness (Diseases) annually follow the same pattern, namely: (a) That classifying causes of death by “influenza” or “influenza-related”, or “pneumonia” is unhelpful and unreliable in the fave of underlying chronic diseases, particularly in the elderly (co-morbidity”); (b) That what is of more and central relevance is simply the total number of excess deaths during a ral strain season; 6cto ca y ssucd / Dd w6 par vo o Goctron que :06-Ju-2020 Court File No/N* du dossier du greffe: CV-20-00643451-0000 (c) That the year-to-year winter-burden (excess) mortality in mid- latitude nations is robustly regular, with respect (0 Seasonal Viral Respiratory illness due to the following, (The absolute humidity which directly controls the impact of the transmission of airborne, pathogen-laden aerosol particle droplets; (ii) In mid-latitude countries, on either side of the Equator, season” emerges in the late fall-winter months, owing to the dry, humidity-free, air which allows the pathogen-laden aerosol particles to travel freely and effectively to infect and be transmitted from person to person which phenomenon occurs on both sides of the Equator, at different times on the calendar year, given the reversal of the seasons on the opposite sides of the Equator; (iii) As the temperature rises, and humidity content in the air increases, the incident. of transmission is reduced. In tropical year-round hot climates this phenomenon is not generally in play. Nor is it at play in extreme cold climates towards both North and South Poles 160. The Plaintiffs further state, and the fact is, as reflected in the scientific and medical literature that (a) The above means that all the viral respiratory diseases that seasonally plague temporal-climate populations every year are extremely contagious for two reasons (1) they are transmitted by small aerosol particles that are part of the Quid air and fill virtually all enclosed air spaces occupied by " *ai-Cause Mortaty during COVIO-19 Denis G. RANCOURT PhD, June 2% 2020, ond a uted Scenic and medical studies nEocton ca y ssucd / Dé w6 par yoo Gocton que :06-Ju 2020 Court File No/N* du dossier du greffe: CV-20-00643451-0000 humans, and (2) a single such aerosol particle carries the minimal infective dose (MID} sufficient to cause infection in a person, if breathed into the lungs, where the ittfection is initiated. (b) This is why the pattern of all-cause mortality is so robustly stable and distributed globally, if we admit that the majority of the burden is induced by viral respiratory diseases, while being relatively insensitive to the particular seasonal viral ecology for this operational class of viruses. This also explains why the pattern is inverted between the Northerit and Southern hemispheres, irrespective of tourist and business air travel and so on (©) The data shows that there is a persistent and regular pattern of winter- burden mortality that is independent of the details, and that has 4 well constrained distribution of year to year number of excess deaths (approximately 8% to 11% of the total yearly mortality, in the USA, 1972 through 1993), Despite all the talk of epidemics and pandemies and novel viruses, the pattern is robustly constant, (a) An anomaly worthy of panic, and of harmful global socio-economic engineering, would need to consist of a naturally caused yearly winter- burden mortality that is statistically greater than the norm, ‘That has not oceurted since the unique flu pandemic of 1918 (the “Spanish Influenza”), Covid-19 is no exception and no more virulent than all others apart from the influenza pandemic of 1918, 78Eoctron ca y ssucd / D6 w6 par vo 0-6 octron que :06-Ju-2020 Court File No/N* du dossier du greffe: CV-20-00643451-0000 (e) Scientific studies show that the three recent epidemics assigned as pandemics, the 12N2 pandemic of 1957, the H3N2 pandemic of 1968, and the HIN1 pandemic of 2009, were not more virulent (in terms of yearly ‘winter-burden mortality) than the regular seasonal epidemics . In fact, scientific studies further show that the epidemic of 1951 was concluded to be more deadly, on the basis of P&I data, in England, Wales and Canada, than the pandemies of 1957 and 1968)."* © — Contrary Views of the Experts to WHO protocal 161. ‘The Plaintiffs further state that the COVID-19 measures have in fact accelerated, and caused more than would be normal deaths, and in the elderly population, which has accounted for 81% of the deaths with respect to COVID-19, mostly in Long-Term Care facilities.** 162. The Plaintiffs state and fact is that these Defendants, while purportedly relying on “advice” from their medical officers, are not transparent as to what the advice was, nor the scientific! medical basis was, and in fisct suppressing it. In fact, to date, they refuse to disclose where they are ultimately getting this “advice, and from whom, based on what medical evidence. The fact is that they are simply parroting the “advice” and dictates of the WHO without any scrutiny whatsoever, and without ever addressing nor recognizing Canadian and international experts who took, and continue to take, a contrary view and criticism of those directives from the WHO. sa cause Mortality during COVID 19, Den. RANCOURT PhO, Juna2™, 2020, aya ted selene and mesial stusee therein ‘sa cause Mortality during COVIO-19°, Dens. RANCOURT PRO, June 2, 2020, andl td Siac and medial stusos there, 0Eoctronca y ssucd / Dd w6 par voe 6 octron que :06-Ju 2020 Court File No/N* du dossier du greffe: CV-20-00643451-0000 163. ‘The Plaintiffs state that such experts include, but are not restricted to: (a) Dr Sucharit Bhakdi , 2 specialist in microbiology, He was a professor at the Johannes Gutenberg University in Mainz, Germany, and head of the Institute for Medical Microbiology and Hygiene and one of the most cited research scientists in German history. (b) Dr Wolfgang Wodarg, a German physician specializing in Pulmonology, politician and former chairman of the Parliamentary Assembly of the Council of Europe, In 2009 he called for an inquiry into alleged conflicts of interest surrounding the EU response to the Swine Flu pandemic. (©) Dr Joel Kettner , a professor of Community Health Sciences and Surgery al Manitoba University, former Chief Public Health Officer for Manitoba province and Medical Director of the {International Centre for Infectious Diseases, (d) Dr John foannidis, a Professor of Medicine, of Health Research and Policy and of Biomedical Data Seience, at Stanford University School of Medicine and a Professor of Statistics at Stanford University School of Humanities and Sciences. He is director of the Stanford Prevention Research Center, and co-director of the Meta-Research Innovation Center at Stanford (METRICS). (©) Dr Yoram Lass, an Israeli pliysician, politician and former Director General of the Health Ministry. He also worked as Associate Dean of the Tel Aviv Us fetsity Medical School and duting the 1980s presented the science-based television shaw Tatzpit 0Eoctronca y ssued | D6 wo par vo 6 octron que :06-Ju-2020 Court File No/N* du dossier du greffe: CV-20-00643451-0000 () Dr Pietro Vernazea , a Swiss physician specializing in Infectious Diseases at the Cantonal Hospital Si. Gallen and Professor of Health Policy, (g) Frank Ulrich Montgomery ,a German radiologist, former President of the German Medical Association and Deputy Chairman of the World Medical Association, (hb) Prof. Hendrik Streeck, a German HIV researcher, epidemiologist and clinical trialist, He is professor of virology, and the director of the Institute of Virology and HIV Research, at Bonn University. (i) Dr Yanis Roussel et. al. ~ A team of researchers from the Lastitut Hospitalo-universitaire Méditerranée Infection, Marseille and the Institut de Recherche pour le Développement, Assistance Publique-Hopitaux de Marseille, conducting a peer-reviewed study on Coronavirus mortality for the government of France under the ‘Investments for the Future’ programme, (i) Dr. David Katz , an American physician and founding director of the Yale University Prevention Research Center. (k) Michael T, Osterholm, a regents professor and director of the Center for Infectious Disease Research and Policy at the University of Minnesota. () Dr Peter Goetzsche , a Professor of Clinical Research Design and Analysis at the University of Copenhagen and founder of the Cochrane Medical Collaboration.” * psp ort-uss com 2020/03 coronavirus shoptickm these. 12 leading. media bape conrad she afte government media narrative? 81Eoctronca y ssund | D6 wé par vo e ¢octron que :06-Ju 2020 Court File No/N* du dossier du greffe: CV-20-00643451-0000 And the Plaintifis state, and fact is, that the above-noted experts are not alone in their contrary views and criticisms, but merely examples of a much bigger body of experts who take the same views, which contradict and criticize the WHO and current measures adopted by Canada, Ontario and Toronto, 164, These experts have expressed, in sunumary, for example, the following opinions: (a) By Dr. Sucharit Bhakdi “[that The government’s antiCOVIDI9 measures] are grotesque, absurd and very dangerous (...| The life expectancy of millions is being shortened, The horrifying impact on the world economy threatens the existence of countless people ‘The consequences on medical care are profound, Already services {o patients in need are reduced, operations cancelled, practices empty, hospital personnel dwindling, Alt this will impact profoundly on our whole society, All these measures are leading to self-destruction and collective suicide based on nothing but s spook.” (b) By Dr Wolfgang Wodarg that what is missing right now is a rational way of looking at thing We should be asking questions like “How did you find out this vvirus was dangerous?”, “How was it belore?”, “Didn't we have the sane thing last year?” “Is if even something new?” That's missing.” (c) By Dr Joel Kettner that: “I have never seen anything like this. I’m not talking about the pandemic, because I've seen 30 of them, one every year. Itis called influenza. And other respiratory illness viruses, we don't always know what they are. But I've never seen this reaction, and I'm trying to understand why. . . | worry about the message to the public, about the fear of coming into contact with people, being in the same space as people, shaking their hands, having meetings hips guaran ora/2020/02/24/32 oxpers questioning the coronas oh jh k_=397LLLad6idod902b2Abte099(528s¢8See4bSl-2SASHRAZRD 0 UgbhvhlVaWWktmnkmDgio3t#peAzOMNS\3KMeaI_LtVTeyMHRigmO _vOnsPEulAs 2Ahs akasihclOsscaW vals sete igomv st 2SnT ist WZUN6VUdehenudpa2aWw 7DaboCcEhSKANG OS HOZOFPrwphsP7OIRIeNNSSTINAAFTADICNNGO, lbpiBKAHaeeCaStPIAEOER XSUWUG BMA) SHINGO 12pUARKCOACES Fg amhowADADF LOOK LEVLEyaREBY AW per CHPSEMOAZOEIe Ho II5I4 ‘ov egeumowsRfboclid=IwAROZWy2bg8, Hiogtu)-SxuOPB2KS-ds?-OgPxNLIMAr2VibwwEhrkimunka 2Eoctronca y ssucd | Dé wé par voo Goeton que :06-Ju 2020 Court File No/N* du dossier du greffe: CV-20-00643451-0000 with people. I worry about many, many consequences related to that... In Hubei, in the province of Hubei, where there has been the most cases and deaths by far, the aclual_ number of cases reported is 1 per 1000 people and the actual rate of deaths reported is | per 20,000. So maybe that would help to put things into perspective.” (@) By Dr John foannidis that: “Patients who have been tested for SARS-CoV-2 are disproportionately those with severe symptoms and bad outcomes ‘As most health systems have limited testing capacity, selection bias may even worsen in the near future... The one situation where an entire, closed population was tested was the Diamond Princess cruise ship and its quarantine passengers, The case fatality rate there was 1.0%, but this was a largely elderly population, in which the death rate from Covid-19 is much higher . . Could the Covid-19 case fatality rate be that low? No, some say, pointing to the high rate in elderly people. However, even some so-called mild or eommon-cold-type coronaviruses that have been known for decades can have case fatality rates as high as 8% ‘when they infect elderly people in nursing homes. If we had not known about a new virus out there, and had not checked individuals with PCR tests, the number ef (oti! deaths duc to “influenza-like illness” would not seem unusual this year. AL most, we might have casually noted that flu this season seems to be a bit worse than average, . . “A fiaseo in the making? As the coronavirus pandemic takes hold, we are making decisions without reliable data”, Stat News, 17th March 2020.” (©) By Dr Yoram Lass that: “ttaly is known for its enormous morbidity in respiratory problems, more than three times any other European country. In the US about 40,000 people die in a regular fu season... In every country, more people die from regular flu compared with well forget: the swine flu in 2009. That was a virus that reached the world from Mexico and until today there is no vaccination against it. But what? At that time there was no Facebook or there maybe was but it was still in its infancy. The coronavirus, in contrast, isa virus with public relations. ... Whoever thinks that governments end viruses is wrong, ~ Interview in Globes, March 22nd 2020.” 2Evocton ca y ssuod / D6 v6 par vo 6ccxon quo = 06 Ju-2020 Court File No/N* du dossier du greffe:_CV-20-00643451-0000 (0. By Dr Pietro Vernazea that: “We have reliable figures from Italy and a work by epidemiologists, which has been published in the renowned nce journal

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