Proper Statement of Claim in VCC Lawsuit (Ontario)

06 July 2020 — PDF available here

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ONTARIO
SUPERIOR COURT OF JUSTICE

 

BETWEEN The Plaintiffs:

• Vaccine Choice Canada (VCC),
• Josee Anne McMAHON,
• Melina LEPE,
• Petronela GROZA,
• Carla SPIZZIRRI,
• Cindy CAMPBELL,
• Alysa SHEPHERD,
• Scott Daniel COOKE (by his litigation guardian Denise Adele COOKE),
• and Denis RANCOURT

( THE PLAINTIFFS )

- and -

( THE DEFENDENTS )

• Justin TRUDEAU, Prime Minister of Canada,
• Dr. Theresa TAM, Chief Medical Officer for Canada,
• Marc GARNEAU, Canadian Transport Minister,
• Doug FORD, Premier of Ontario,
• Christine ELLIOT, Minister 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. Eileen 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 Winr.sor-Essex County,
• Her Majesty the Queen in Right of Canada,
• Her Majesty the Queen in Right of Ontario,
• Attorney General of Canada,
• Attorney General of Ontario,
• The Canadian Broadcasting Corporation ("CBC"),
• Johns and James DOE, officials and employees of the above-noted Defendants

 

 

You can download the archived and searchable VCC, Rancourt et al v Ontario Lawsuit (PDF) directly from this Covfefe Bakery Cafe or just perv the historical embed mirror'd below.

This is a working transcription (OCR of the Claim that I'm proof-reading and correcting in my spare time) so there will be a lot of clean-up in the future, but the raw OCR is here for your perusal.

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STATEMENT OF CLAIM 
TO THE DEFENDANT: 

A LEGAL PROCEEDING HAS BEEN COMMENCED AGAINST YOU by the plaintiff. The claim made against you is set out in the following pages. 

IF YOU WISH TO DEFEND THIS PROCEEDING, you or an Ontario lawyer acting for you must prepare a statement of defence in Form 18A prescribed by the Rules of Civil Procedure, serve it on the plaintiffs lawyer or, where the plaintiff does not have a lawyer, serve it on the plaintiff, and file it, with proof of service, in this court office,  WITHIN TWEiNTY DAYS after this statement of claim is served on you, if you are served in Ontario. 

If you are served in another province or territory of Canada or in the United States of America, the period for serving and 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 DISMISSEiD if it has not been set down for trial or terminated by any means within five years after the action was commenced unless otherwise ordered by the court. 

Date: , 2020 Issued by: 
Address of Local Office: 
393 University 
10ith Floor Toronto, Ontario MSG 1E6 

TO:

Attorney General of Canada 
Ontario Regional Office, Department of Justice Canada 
Address: #400-120 Adelaide Street W; Toronto, Ontario M5iH 1 Tl 
Fax: (416) 954-8982 | Tel: (416) 973-0i942

AND TO:

The Attorney General for Ontario
Crown Law Office, Constitutional Law Branch
Address: 720 Bay St; Toronto, Ontario M7A2iS9
Tel: 416-326-4460 | Fax: 416i-326-401 

AND TO:

John Tory and City of Toronto,
City Solicitor's office, City of Toronto
Address: 100 Queen Street, W; Toronto, Ontario M5H2eN2 

AND TO:

Dr Wajid Ahmed, Medical Officer of Health
Windsor-Essex County Health Unit
Address: 1005 Oullette Ave Windsor ON N9A 4J8
Tel: 519-258-2146 | Fax: 519-258-6003 
Email: crd e, ,wechu.org 

AND TO:

Dr Nicola Mercer, Medical Officer of Health
WDG Health Unit
Address: 160 Chancellors Way Guelph ON NI G 0El
Phone: 519-822e-2715 Fax: 519-836-7215 
Email: info@wdgpublichealtb.ca 

CLAIM 

1. As against the Crown and Municipal Defendants the Plaintiffs claim: 
   1. A Declaration that the "COVID Measures" undertaken and orchestrated by Prime Minister Trudeau ("Trudeau")i, 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 rights through the Pre.Amble of the Constitution Act, 1867, emanating from the unwritten constitutional principles of Rule of Law, Constitutionalism and Democracy , as enunciated by the Supreme Court of Canada in, inter alia , Quebec Secession Reference; 
   2. A Declaration that:
      1. s. 7.0.1 through s.70.11 of the Emergency Management and Civil Protection Act, RSO 1990.C.e.9 (the "Act"), and in particular vesting an indefinite emergency power in the Premier and Lti-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 to 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 Democracy , as enunciated by the Supreme Court of Canada in, inter alia , Quebec Secession Reference;
      1. 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.7.0e.1(3) of that Act, and is in further contravention of s. 7.0.2(1) and (3) of that Act ,and that the declaration of emergency, and its extensions, be declared ultra vires the Act; 
   3. 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") bureaucrats, 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; 
   4. 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:
      1. "self isolation";
      2. "social distancing";
      3. the compulsory wearing of face masks;
      4. arbitrary and unjustified closure of businesses; 

• In that the Measures are not:
  1. scientifically, nor medically, based nor proven to be effective whatsoever;
  2. pose physical and psychological harm; and
  3. 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. 1 of the Charter in that they are not demonstrably justified in a free and democratic society; 

5. 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 c. E-9, infringe s. 2, 7, 8, 9, and 15 of the Charter specifically the measures of:
   In that the Measures are not:
   5. "self isolation";
   6. "social distancing";
   7. the compulsory wearing of face masks;
   8. arbitrary and unjustified closure of businesses;
   9. the closure of schools, daycares, park amenities, and playgrounds;
   10. 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; and
   11. the closing down of religious places of worship;
   12. scientifically, nor medically, based nor proven to be effective whatsoever;
   13. pose physical and psychological harm; and
   14. 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 not in accordance with the tenets of fundamental justice in their over breadth, nor are they justified under s. 1 of the Charter in that they are not demonstrably justified a in free and democratic society; 
6. A Declaration that the Municipal COVID Measures enacted by By-Law, and Orders, by the City of Toronto, and conduct of John Tory, are ultra 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 seizure), s.9 (arbitrary detention by By-Law officers), andis. 15 of the Charter, specifically the measures of:
   1. "self isolation";
   2. "social distancing";
   3. the compulsory wearing of face masks;
   4. arbitrary and unjustified closure of businesses;
   5. the closure of schools, daycares, park amenities, and playgrounds;
   6. 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;
   7. the closing down of religious places of worship;

In that the Measures are not

1. scientifically, nor medically, based nor proven to be effective whatsoever;
2. pose physical and psychological harm; and
3. 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 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 in a free and democratic society; 

7. 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; 
8. A Declaration that the concept of "social distancing" is neither scientifically, 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;
9. A Declaration that:
   1. the orders from the Medical Officers from the Counties of Wellington-Dufferin-Guelph and Winsor-E ssex, and any and all County or Municipal By- Law or Health Officers and orders, respecting mandatory wearing face-masks, is unconstitutional; and
   2. a further Declaration that the mandatory wearing of face-masks is both ineffective and poses a 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 right of liberty, to choose how to breath, as well as pose a physical and medical danger;
10. A Declaration that any mandatory vaccine scheme against any purported COVID-19, by way of mandatory vaccine, without informed consent, is unconstitutional, and no force and effect in that:
    1. It in infringes s.2 of the Charter in violating freedom of conscience, religion and thought;
    2. 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;
    3. Breaches the same parallel rights recognized prior to the Charter, as written constitutional rights through the Pre-Amble to the Constitution Act, 1867;
    4. Breaches parallel international treaty rights to no medical treatment without informed consent, and right to bodily integrity, which international treaty rights are to be read in, as a minimal s. 7 Charter protection, as enunciated by the Supreme Court of Canada in, inter alia the Hape decision;
    5. And that, under no circumstances are mandatory vaccines, nor coerced compliance to vaccines, in accordance with the tenets of fundamental justice, nor demonstrably justified under s. 1 of the Charter;

11. 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, belief, and religion in banning association, including 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 justified under s. 1 of the Charter;

12. 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;

13. 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 fide pandemic, but for other political and socio-economic reasons, motives, and measures at the behest of globalBillionaire, Corporate and Organizational Oligarchs;

14. A Declaration that prohibitions and obstacles to 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 justifiedbys.1, aswellasaviolationoftheseconstitutionalrights, recognized prior to the Charter, through the Pre-Amble to theConstitution Act, 1867 and against international treaty rights protected by s. 7 of the Charter;

15. 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:

    1. (i)  "self- isolation";

    2. (ii)  no gatherings of more than five (5) and larger than (10) persons, or any set number;

    3. (iii)  the shutting down of children's playgrounds, daycares and schools;

    4. (iv)  "social distancing";

    5. (v)  the compelled wearing of face- masks;

    6. (vi)  prohibition and curtailment of freedom of assembly, including religious assembly, and petition;

    7. (vii)  the imposition of charges and fines for the purported breach thereof;

    8. (viii)  restriction of travel on public transport without compliance to physical distancing and masking

    9. (ix)  restrictions on shopping without compliance to masking and physical distancing;

    10. (x)  restrictions on attending restaurants and other food service establishments without compliance to masking, physical distancing, and providing name/address/contact information for contact tracing purposes.

16. Constitute a violation of ss. 2,7,8, 9, and ss. 15 of the Charteri, 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 to s. 8, arbitrary detention under s. 9 of the Charteri, 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 Act, 1867 and affected by means of removing measures against the "Liberty of the Subject" by way of habeas corpus;

17. Further Declarations that:

18. 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 face-masking compulsory; 

19. 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 facto put most small businesses and activities out of business; 

20. 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-1i9, 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; 

21. A Declaration that: 

22. 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 unwritten 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 Charter; 

2. Such further and/or other Declaratory relief as counsel may advise and this Honorable Court entertain. 

3. As against the Crown and Municipal Defendants, Interim 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 Regulationi/ order thereunder, particularly measures which interfere with physical and psychological integrity without informed consent. 

4. As against the CBC: 

5. Ciost of this action on a substantial indemnity basis and such further or other relief this Ciourt deems just. 

THE PARTIES 

¥ The Plaintiffs 

6. Vaccine Choice Canada ("VCC") 1s 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 to advocate and support the statutory and constitutional rights tied to the right to vaccinate, and the right not to vaccinate, based on best science and medicine, with informed consent. Vaccine Choice Canada was originally incorporated as the Vaccination Risk Awareness Network ("VRAN") in 1982. It changed its name to Vaccine Choice Canada (VCC) in 2014i. 

7. The Plaintiff Josee Anne McMahon, 1s a resident of Ontario. Residing in Mississauga. 

8. The Plaintiff, McMAHON, is a mother to four (4i) 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, 20i20i. She has been providing telephone sessions from March to April and video sessions have started as of May. She is finding that about 50i% of the families that she would normally work with are not able to engage by telephone or by 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. McMAHON has had her own children interrupt client phone calls and video sessions in order to meet her children's needs. She would normally be able to work 7-9 hours from the office daily. But, since the shutdown, she is not able to do that but works significant reduced hours. Some of the 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.

9. McMAHON states that personally, the Covid measures have affected 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 has been yelled at and shamed in public 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; 

(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 receive services"; 

(i) She has asthma and has had lung issues over the years; 

G) 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 in a 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 out because of all of the above. 

10. McMAHON further states that she objects to face-masks based on the fact that they are ineffective with respect to respiratory viruses, further pose physical and psychological health risks, and further violate her rights under s. 2 and 7 of the Charter. 

11i. The Plaintiff , Cindy CAMiPBEiLL is a resident of Ontario, residing in Toronto. 

12. CAMPBELL has been a Registered Nurse for the past 25 years. She has a Bachelor's of Science in Nursing from the University of Victoria and a Master's degree in Health and Aging from Queens University. She is also a certified operating room nurse and holds certification in gastroenterology with The Canadian Nurses Association. 

13i. CAMPBELL has a special interest in older adults and nursing education and has published work related to both. Her pursuit of leadership in education led her to complete a prestigious Advanced Clinical Practice Fellowship with the Registered Nurses Association of Ontario for which she was awarded the 2019 nursing practice award from the downtown Toronto hospital in which she has been employed for 20 years. 

14i. During that time, CAMPBELL has worked across all areas of Peri-operative Services including the main operating room and endoscopy. Her main area of practice however is in the elective outpatient surgery unit(EOPS). This is an ambulatory unit that performs a diverse range of surgeries to treat a range of conditions, many of which are causing patients significant harm, suffering, or pain. During these procedures, important diagnostic testing may also take place to identify such things as cancers and infections. 

15i. Upon announcement of the COVID-1i9 pandemic in mid-March, 2020, EOPS was closed and converted into an annex for the Eimergency Room to manage suspected overflow. The endoscopy unit was closed to elective procedures and also was converted into an overflow area for the ICU. The Main Operating Room, which has 12 ORs, was also closed, and only emergency or high priority cases that met strict criteria were allowed. This meant a dramatic workload reduction in surgeries and for staff. Similar workload reductions would have been mirrored in units across the hospital subjected to closure mandates. 

16. At the onset of the pandemic, CAMPBELL was assured she would be used for sick calls because of COVID-19 -she was never called in. During this time the units that were converted into ER and ICU overflows sat unused-there was no overflow. She was told that she may be transferred to another setting that may be in need during the COVID crisis-she was never called in to help. As a casual RN, she had all her posted shifts canceled and was not given another shift until June 17-this meant almost 3 months without an income and pension contributions. Considering her unit remains at half capacity, she suspects shifts will remain scant until they are fully open again. 
17. As an RN, CAMiPBELL'S primary role is that of patient advocate. As a patient advocate, CAMiPBELL states, and the fact is, with respect to several consequences of the COVID-1i9 management measures namely: (a) Canceled surgeries and endoscopy procedures: This is an issue with senous consequences. CAMiPBELL states that there is no question, considering the volume of cases canceled, that this act alone resulted in significant numbers of missed diagnoses and physical harm including death as a result of conditions left untreated/undiagnosed. In addition, the physical and mental suffering of those left to manage debilitating conditions without medical intervention was unwarranted. 
(b) No visitor policies: On her last day in the OR, on March 25, 20i20i, following the implementation of no visitor policies, CAMiPBELL'S unit performed surgery on a young man who was in such a state of depression that he was near catatonic. His surgeon told CAMPBELL how this grown man cried when he heard his mother could not be there when he awoke post-surgery and could no longer visit him. CAMiPBELL states, and the fact is, that this is but one of thousands of stories across Canada. Despite hospitals' embrace of family care models that recognize the connection of family support upon positive health outcomes, families were deemed incompetent to take necessary precautions and were indefinitely shut out. This is further troubling in an era that suggests medical error is the third leading cause of death in North America. Family plays an essential role as advocates and in the prevention of medical error. This is particularly true in multicultural settings that left patients without family translators, older adults with dementia /cognitive impairments, etc. The long duration of this policy was punishing and caused significant, unnecessary suffering and harm. ( c) Mask recommendations are not based on scientific or medical evidence and pose an infection transmission risk. As an Operating room nurse, CAMPBEiLL has extensive training in masking. As such, CAMPBELL is very aware of the alarming, rampant breaches around safe and effective mask use currently happening in the community. Dr. Tam initially expressed these same concerns around mask contamination and their risk of spreading infection. Yet, Dr. Tam abandoned these valid concerns and the historic viewpoint that endured through all past epidemics and pandemics that did not recommend community mask use. Based on very low grades of evidence, she began recommending public use of cloth masks. Risks of masks equally extend to populations excluded and isolated as a result of mask use in the community such as hearing-impaired older adults. Not only does this alienate these populations but miscommunication as a result of mask use could have serious outcomes. (d) Long-term care (LTC) homes were left unprepared which resulted in unnecessary death and suffering despite ample warning. 

18. The Plaintiff, Petronela GROZA, is an Ontario resident residing m North Augusta. She recently moved there from Toronto. 

19i. On May 26it\ 2020, at around 5:30pm, Graza and her 1 0yr old child had gone to Longo' s, a supermarket at York Mills and Leslie in Toronto, for groceries, but we were stopped as they had entered the doors and an employee demanded that they wear a mask before entering. The store employee, and Manager, stipulated that they had the discretion, as a private business, as per the statements of Premier FORD, and Mayor TORY, to impose mask requirements. The Plaintiff and her daughter left the store as she refuses to wear masks because they are ineffective and dangerous to her health, and a violation of her constitutional rights. 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 but also exceeded their authority in making these statements. 

20. On June 13it\ 2020, at around noon, the Plaintiff Graza was driving on highway 401 Eastbound, and pulled into the Cambridge "OnRoute" to use the washroom and buy lunch. At the entrance there was a man with a mask that demanded the Plaintiff 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 Omoute. The Plaintiff informed him that just the day before she had stopped at an Omoute and was not forced to wear a mask. He insisted that it was the law . Groza then 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." Groza walked 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. Groza left the OnRoute without buying anything to eat. Groza then 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 and excess of authority statements made by Trudeau, Ford, Tory, and their Medical Officers, with respect to what Covid-measures have, or have not, actually put into law, and simply express the at-the-moment ill-informed views of these Defendants.21i. The Plaintiff GR OZA absolutely refuses the wearing of a face-masks. She further denies the efficacy of social distancing 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 neither measure prevent the contraction of any virus and are otherwise detrimental to her health. 

22i. The Plaintiff, Melina LEiPEi, is an Ontario Resident residing in the County of Wellington-Duff erin-Guel ph. 

23i. The Plaintiff, LEiPEi, states that when lockdown started on March 17th, 2020i, 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 13it\ 2020i. They have not left 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 emergency orders. Even meeting in a park and keeping physical distance was not allowed. As a new mother who suffered from birth trauma and is recovering from birth 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 Plaintiff in physical pain which has affected her ability to care for her family. The Plaintiffs 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 Plaintiff planned to give her daughter for her growth and development were taken away. 

24. The Plaintiff, LEPE, states that Wellington-Dufferin-Guelph County's mandatory mask order is adding insult to injury. The Plaintiff is opposed to the order for several reasons: (a) It takes away her right to bodily autonomy, which the Plaintiff takes extremely seriously, as she is firm in her conviction in medical freedom 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 easily able to find science-based articles studies showing that masks, especially cloth ones, are not effective at protecting oneself or others. In fact, they can have a negative impact on physical and mental health. The Plaintiff further states that our public health officials should have been more prudent in their research if they truly want to protect the public's health. 

( c) It has had a negative effect on her mental health. As someone who has suffered with, at times, debilitating anxiety 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 the mandatory mask order of the County's Medical Officer, Nicola Mercer. 
25i. The Plaintiff LEiPE absolutely refuses the wearing of a face-masks. She further denies the efficacy of social distancing 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 detrimental to your health. 

26i. The Plaintiff, Carla SPIZZIRRI, resides in Toronto and is a real-estate agent. 

27. The Plaintiff, SPIZZIRRI states, and fact is, that Condo Boards across the GTA are allowed to make up their own rules for each 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 ride. The Plaintiff has waited as long as 1.5 hours to get on an elevator. While this rule has been implemented for Covid-1i9, the Plaintiff states it has never been implemented for previous "pandemics" such as SARS. The Plaintiff states, and fact is that her clients are not happy with these restrictions, not to mention that many of the Plaintiff's clients are losing their incomes and livelihoods making them unable 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 stricl when properties do allow showings such as: requesting a signed contract which 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. SPIZZIRRI states 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 face-mask, and that the Covid-measures violate her rights under ss.2 and 7 of the Charter. 

29. The Plaintiff, Alysa SHEiPHEiRD, is a Doctor of Chiropractory, residing in the County of Welling-Dufferin-Guelph, Ontario. 

30i. The Plaintiff, SHEiPHEiRD, opposes the COVID-measures enacted by the government(s) as set out below. 

31i. The Plaintiffi, as a citizen, opposes these measures because : 
(a) As an individual with a history of mental health struggles 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 SHEiPHEiRD had been using and needs, in order to support her own health 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, SHEiPHEiRD was utilizing a variety of approaches to support herself and to heal these struggles, no longer available to her. 

(b) More specifically, since approximately September, 20i18 SHEiPHEiRD has been receiving regular nutritional therapy via I-V. SHEiPHEiRD was scheduled to receive her monthly I-V therapy a few days after the emergency measures were enacted, and therefore, SHEiPHEiRD did not receive them. SHEiPHEiRD had now been three (3i) 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, SHEiPHEiRD now must wear a mask to any such appointment, which she refuses to do for reasons set out below. 

(d) SHEiPHEiRD was 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, SHEiPHEiRD must mask to enter the dental clinic , which she refuses to do. 
(e) SHEiPHEiRD had also been gomg for regular craniosacral 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. SHEiPHEiRD does not feel the government has the right to take away her health care and decide what is 'essential' vs. 'non-essential' in this regard. 

(f) SHEiPHEiRD also take serious objection with the suspension of Parliament and the lack of transparent process with how her government is currently 
conducting itself. SHEiPHERD states that the measures enacted have not been congruent with the scientific and medical data, with best scientific practices, and the best evidence available. SHEPHERD has written multiple letters to elected officials which are continually ignored or to which she receives the rare tepid response. SHEPHEiRD states, and the fact is , that this has all set a precedent for this to happen every influenza season, which would be devastating for her and many.

(g) On June 13th, 2020i, SHEPHERD 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 to health and well-being. Only when SHEPHERD 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 $5i,000 fine for being unmasked if a spot.check was performed by Public Health. While SHEPHERD was inside, this all felt stressful for her. SHEiPHEiRD's family have now made the decision to take their commercial activity outside WDG, adding to 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 .. 

32i. SHEiPHEiRD, as a mother of two young children, aged five (5) (Quentin) and two and a half (2.5) (Ivy) years old, further objects to the emergency measures enacted and lock down for the following reasons:

33i. As a chiropractor, SHEiPHEiRD objects to the emergency measures and measures enacted by the various layers of government for the following reasons:

further objects to the WDG mandatory mask order because it is not aligned with best evidence and known science and creates unnecessary risk to physical health, mental health, relational and social health, as SHEiPHEiRD clearly articulated in a third letter sent to various levels of elected officials, to which SHEiPHEiRD has received no response.  
Furthermore, there is no end date on the order or even a date of reassessment as would seem prudent for an evidence-informed approach to this. No cited science was given to support this order of mandatory masking.  
34i.  The Plaintiff, Scott Daniel COOKE (by his litigation guardian Denise Adele COOKEi) resides in Hamilton, Ontario.  
3 5.  Scott Daniel Cooke is a 23 year-old male with autism diagnosis since age three  (3i).  
36i.  He is 6'3 ", weighs 220 lbs.i, 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 (4i).  
37i.  Scott Daniel Cooke has been totally, mentally, devastated by the COVID. measures, in depriving him of his routine activities and social and emotional network, without recourse. He suffers severely, from not being able to understand, nor accommodate, 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 understand and therefore cannot comply with "social distancing" or "isolation", given his severe neurological disability and his special needs. The plaintiff, 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 Scott's entire support, social, medical, and therapeutic network has been ripped away from him without any regard to his special needs. 
38i. The Plaintiff, Professor Denis RANCOURT, Ph.iD., resides in Ottawa, Ontario. 
39. Denis Rancourt, B.Sc., M.Sc., Ph.D., is a former tenured Full Professor of Physics, University of Ottawa. Full Professor is the highest academic rank. He is an expert in public health. He has taught over 2,000 university students, and supervised more than eighty (80) junior research terms or degrees at all levels from post-doctoral fellow to graduate students to NSERC undergraduate researchers. He headed a research laboratory, and attracted significant research funding for two decades. He supervised doctoral students in both physics and environmental science. He has been an invited plenary, keynote, or special session speaker at major scientific conferences nearly forty ( 40i) times. He has published over one hundred (100) research papers in leading scientific journals, in the areas of physics, chemistry, geology, materials science and environmental science, including environmental nanoparticles. He co-discovered the phenomenon of "superferromagnetism", and co-discovered the urnque meteoritic alloy "antitaenite". He has a scientific impact factor (h-index) of 39 (84i% of Nobel Prize winners in physics had h-indexes of at least 30i), and his articles have been cited more than 5,000 times in peer-reviewed scientific journals. 
40i. Presently, Dr. Rancourt is a registered mentor for physics students at the University of Toronto, and is a Researcher (volunteer position) at the Ontario Civil Liberties Association (ocla.ca). He is a frequent media commentator. His 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). 
41i. The Plaintiff, RANCOURT, in April, 2020i, 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 ( 400i, 000i) reads. 
42i. YouTube also removed three of 3 of RANCOURT's videos, which were part of his " Play List" entitled "COVID-19 with Denis Rancomt". The 3 videos were entitled: 

RANCOURT statesi. 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 concededly applied to any and all opinions that run contrary to the official WHO dogma, notwithstanding that those contrary opinions come from recognized experts in their field. 
43i. RANCOURT has written or co-authored the following published authoritative documents about COVID-19i: 

¥ "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 215 \ 2020i. 
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 expe11s who take critical or contrary view of the COVID measures executed by the Federal, Provincial, and Municipal governments at the direction and behest of the WHO. 
44i
. A CBC high-profile journalist had interviewed RANCOURT, 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. 

45i
. 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 to protect against this flagrant censorship, and as such, through omission, infringe RACOURT'S, and other Plaintiffs', right to freedom of speech, expression, and the media contrary to s.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 

COVID-Measures because they are not scientifically or medically based, rely on false and distorted data , are based on a false declaration of a pandemic, and because they violate his ss.2i, and 7 Charter rights. 
¥ The Defendants 
46i
. The Defendant, Justin Trudeau, is the current Prime Minister of Canada, and as such, a holder of a public office. 

4 
7. The Defendant, Dr. Theresa TAM, is Canada's Chief Public Health Officer and as such a holder of a public office. 

48i
. The Defendant Her Majesty the Queen in Right of Canada, is statutorily and constitutionally liable for the acts and omissions of her officials. 

49. 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 relief, including with respect constitutional declaratory relief, and required to be named as a Defendant in any action for declaratory relief. 
50i
. The Defendant Marc GARNEiAU is the Federal Minister of Transport, and as such a public office holder. 

51i
. The Defendant Her Majesty the Queen in Right of Ontario, is statutorily and constitutionally liable for the acts and omissions of her officials. 

52i
. 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, 

including with respect to its constitutionality, and required to be named as a Defendant in any action for declaratory relief. 

53i
. The Defendant Doug FORD, is the current Premier of Ontario, and as such a holder of a public office. 

54i
. The Defendant Dr. David WILLIAMS, is Ontario's Chief Medical officer, and as such a holder of a public office. 

55i
. 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. 

56i
. The Defendant Stephen Lecce, is the Minister of Education for Ontario. 

57. The Defendant, The City of Toronto, is a Municipality in the Province of Ontario and governed by, inter alia, the Municipal Act and all other applicable Provincial Acts. 
58i. The Defendant JOHN TORY, is the Mayor of the City of Toronto, and as such a holder of a public office. 
59. The Defendant Dr. Eileen De VILLA, is Toronto's Chief Medical Officer, and as such a holder of a public office. 
60i
. The Defendant County of Wellington-Dufferin-Guelph is a County in the Province of Ontario and the Defendant, Nicola MEiRCEiR is its (Chief) Public Health Officer, and as such, Nicola MEiRCEiR is a holder of public office. 

61i
. The Defendant County of Windsor-Eissex 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. 

62i
. The Defendant unknown Johns and Janes DOEi, are employees of the Crown and Municipal Defendants and as such are holders of a public office. 

63. The Defendant, The Canadian Broadcasting Cor[oration ("CBC"), is Canada's publicly-funded broadcaster and governed , inter alia, under the Federal Broadcast Act, with a public mandate as Canada's national publicly-funded broadcaster. 
THEi(FURTHER)iFACTS A/ "COVID-19i"-THE TIMELINE 
64i
. In 2000 Bill Gates steps down as Microsoft CEiO and creates the 'Gates Foundation" and (along with other partners) launches the 'Global Alliance for Vaccines and Immunization ('GAVI"). The Gates Foundation has given GAVI approximately $4i.1 Billion. Gates has further lobbied other organizations, such as the World Economic Forum ("WEiF") and governments to donate to GAVI including Canada and its current Prime Minister, Justin Trudeau, who has donated over $1 Billion dollars to Gates/GA VI. 

65i
. In 2002 Scientists engage in "gain-of-function" (GOF) research that seeks to 

generate viruses "with properties that do not exist in naturei" and to "alter a pathogen to make it more transmissible (to humans) or deadly. " 1 2 
66. 
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 Carolina (UNC) Ralph Barie announced the creation of a synthetic clone of a mouse coronavirus. 

67. 
On October 28ith, 2003 the Barie group at UNC announces a synthetic recreation of the SARS virus. 

68i. In 2005 Research demonstrates that Chloroquine is a potent inhibitor of SARS coronavirus infection and transmission. 3 
1 https://www.ncbi.nlm.nih.gov/books/NBK28SS79/ 'https://www.sciencemag.org/news/2014/10/us-halts-funding-new-risky-viru… 3 https://www.ncbi.nlm.nih.gov/pmc/articles/PMC1232869/ 
69. 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 governments around the globe following suit. 
70i
. 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 GAVI 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). 

71. In May 2010, the Rockefeller Foundation writes a Report, later leaked, unintentionally from within the organization, with a study of a future pandemic scenario, where an unknown virus escapes Wuhan, China, and a "hypothetical" scenario on what the appropriate response would be, and its core scenario entitled "how to secure global governance in a pandemic". The Plaintiffs statei, and the fact is, that the scenario scripted in this May 20i10i, Report is what has unfolded during the "COVID-1i9" so-called "pandemic". 

72. 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 
economically feasible and are predicted to delay viral spread but not impact overall morbidity. " 4  

73.  In May, 2012, the 194 Members States of the "World Health Assembly" endorse the 'Global Vaccine Action Plan (GVAP) led by the Bill and Melinda Gates Foundation in collaboration with GAVI, and the World Health Organization (WHO).  

74  In 2014 Under President Obama, the National Institute of Health (NIH) halts  
federal funding for gain-of-function (GOF) 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 transmissibility in mammals via the respiratory route." NIH later allows  
10 of the studies to resume.  
75i.  In 2015 NIAID awards a five-year, $3.7 million grant to conduct gain-of. 
function studies on the "risk of bat coronavirus emergence." Ten percent of the  
award goes to the Wuhan, China, Institute of Virology.  
76i.  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".  
77.  In 2017 Dr. Marc Lipsitch of the Harvard School of Public Health tells the New  
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  
pandemics, and yet risked creating an accidental pandemic."  

4 Social Distancing as a Pandemic Influenza Prevention Measure 
hltps://nccid .ca/wp¥conlent/uploads/siles/2/2015/04/HlNl 3 tin.l.pd f 
78i. In 2019 NIAID awards a six-year renewal grant of $3.7 million to EcoHealth Alliance and the Wuhan Institute of Virology (in China) to continue their gain.of-function studies on bat coronaviruses. 
79. At the January, 2019, World Economic Forum in Davos, Switzerland, on January 23rd, 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. 
80i. British and French researchers publish a study (May 5, 2020i) estimating that COVID-1i9 could have started as early as October 6, 2019. 
81. On October 18i1\ through 2i\ 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''. 

82. On October 18i, 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 to a hypothetical global coronavirus pandemic. 
83. In November-December, 2019, -General practitioners in northern Italy start noticing a "strange pneumonia." 

84. On December 2nd and 3rct, 2019 Vaccine scientists attending the WHO's Global Vaccine Safety summit confirm major problems with vaccine safety around the world. 

85. On December 3rd , 2019i, 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 unique position in human history where we've shifted the human population to vaccine-induced, to dependency on vaccine-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're 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." 

86. On December 1st\ 2019i, 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. 
87. On December 31i,2019 -Chinese officials inform the WHO about a cluster of "mysterious pneumonia" cases. Later, the South China Morning Post reports that it can trace the first case back to November 1 ihe, 2019i. 
88. On January i\ 2020 -Chinese authorities formally identify a "novel" corona virus. 

89. On January 11, 2020 -China records its first death attributed to the new corona virus. 

90. On January 20, 2020 -The first U.S. coronavirus case is reported in Washington State. 

91.  On January 23rd , 2020, Shi Zheng-Li releases a paper reporting that the new  
corona virus (COVID-1i9) is 96i% identical to the strain that her lab isolated from  
bats in 2013 but never publicized.  
92.  On January 30, 2020 -The WHO declares the new coronavirus a "global  
health emergency."  
93.  In January, 2020 -A study of US military personnel confirms that those who  
received an influenza vaccine had an increased susceptibility to coronavirus  
infection. 5  
94.  On February st\ 2020 -Bill and Melinda Gates announce $100 million in  
funding for coronavirus vaccine research and treatment efforts. On February  
11 t\ 2020 the WHO gives the virus its name: 'COVID-1i9".  
95.  On February 28ith, 2020 -The WHO states that most people will have mild  
symptoms from SARS-Co V-2i("COVID 19i") infection and get better without  
needing any special care.  
96.  On February 28ith, 2020 , the WHO announces that more than 20 vaccines are  
in development globally.  
97.  On February 28ith, 2020, the WHO states ."Our greatest enemy right now is  
not the virus itself. It's fear, rumors and stigma." 6  
98.  On March st\ 2020 -Dr. Peter Hotez of Baylor College told a US  
Congressional Committee that coronavirus vaccines have always had a "unique  

5 https://www .sc!encedirect.com/science/article/pii/S0264410Xl93U64 7 
6 WHO Director-General's opening remarks at the media briefing on COVID-19 -28 February 2020 
https://www.who.l11t/dg/5.eches/detail/who-director-general-s-opening-r… 
potential safety problem" -a "kind of paradoxical immune enhancement phenomenon." 7 
99. On March 11i,2020 -The WHO declares COVID-1i9 a pandemic. 

100. On March 121e\ 2020 Education Minister Stephen Lecce ordered the closing down of public schools, on the advice of Dr. Williams the co-Defendant. 

101. On March 16i1\ 2020 -Neil Ferguson ofilmperial College London, scientific advisor to the UK government, publishes his computer simulations warning that there will be over two million COVID-1i9 deaths in the U.S. unless the country adopts "intensive and socially disruptive measures." Imperial Col1cgc London receives funding from Bill and Melinda Gates Foundation. 

102. On March 16i1\ 2020 -Dr. Anthony Fauci tells Americans that they must be prepared to "take more drastic steps" and "hunker down significantly" to slow the corona virus's spread. 

103. On March 16i1\ 2020 -NIAID launches a Phase 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. 
104. On March 17th , 2020 -Prime Minister Trudeau asks for lockdown measures, under the Federal Quarantine Act, banning travel. The same date Premier Doug FORD declares an Emergency in Ontario, under ots Provincial legislation. 

105. On March 19i¥\ 2020 -The status of COVID-1i9 in the United Kingdom is downgraded. COVID-1i9 is no longer considered a high consequence infectious disease (HCID). The Advisory Committee on Dangerous Pathogens (ACDP) in 

7 https://www.c-span.org/video/?4 70035-1/ho use-science-space-technology-comm ittee-hea ring-coronavi rus&.ta rt= 1380 
the UK is also of the opinion that COVID-19 should no longer be classified as an HCID (High Consequence Infectious Disease). 8 9 

106i. On March 24th , 2020 -Global medical experts declared that efforts to contain the virus through self-isolation measures would negatively impact population immunity, maintain a high proportion of susceptible individuals in the population, prolong the outbreak putting more lives at risk, damage our economy and the mental stability and health of the more vulnerable. 10 
10i7. On March 241\ 2020 -Professor Peter Gotzche issues a statement -"The 
coronavirus mass panic is not justified. " 
108. On March 241\2020 -Bill Gates announces funding for a company that will blanket Earth with $1 billion in video surveillance satellites. 

109. On March 26i11\ 2020 Microsoft announces it is acquiring 'Affirmed Networks" focused on 5-G and "edge" computing". 

110. On March 26i1\ 2020 -Dr. Fauci publishes an editorial in the New England Journal of Medicine stating that "the overall clinical consequences of Covid-19 may ultimately be more akin to those of a severe seasonal influenza," with a case fatality rate of perhaps 0.1 %. 
8 
https:/lwww.qov.uk/topiclheallh-protection/infectious-diseases 
9 hltps://prepforthat.com/uk-officials-covid-19-no-lonqer-high-conseguence-infectious-disease/ 
10 https ://off-guardian .org/2020/03/24/12-experts-q uestion ing-the-coron avirus-pa n ic/ 
11 m.u,s://www.europereloaded.com/twenty-two-experts-question1ng-the-coronavirus-p…"11s5i/. 
111. On March 30th 2020, Dr Michael J. Ryan, Executive Director of the 
Health Emergencies Programme at the World Health Organization publicly stated, 
during a press conference that: 
"And at the moment in most parts of the world due to lock-down most of the transmission that's actually happening in many countries now is happening in the household at family level. In some senses transmission has been taken off the streets and pushed back into family units. Now we need to go and look in families to find those people who may be sick and remove them and isolate them in a safe and dignified manner". 
112. March 31, 2020, Dr. Theresa Tam states that, "it is not clear that masks actually help prevent infections, and may increase the risk for those wearing them." 
113. On April 2nd , 2020 -Bill Gates states that a coronavirus vaccine "is the only thing that will allow us to return to normal.i" 
114. In April, 2020-A review of the scientific literature conducted by Denis Rancourt, Ph.D., with regards to the use of masking, concluded there is no scientific evidence to substantiate the effectiveness of masking of the general public to prevent infection and transmission. 12 

115. On April 6th , 2020 -German epidemiologist, Knut Wittkowski, releases a statement warning that artificially suppressing the virus among low risk people like school children may "increase the number of new infectionse" as it keeps the virus circulating much longer than it normally would. 13 

116. On April 6i1\ 2020 -Dr. Anthony Fauci states, "I hope we don't have so many people infected that we actually have herd immunity." 
12 hllps:ljwww.researchgate.nel/publicatlon/34057073S Masks Don't Work A review of science relevant to COVID.19 soda! policy 
13 Stand Up for Your Rights, says Bio-Statistician Knut M. Wittkowski. American Institute for Economic Research. April 6, 2020 
h\.!P.s:llwww .. aier.org/article/stand-up-for-your-rights-says-professor-kr1-ut-m-witlkowskl/ 
117. On April 9ithe, 2020 -Canadian public health officials stated -"In a best-case scenario, Canada's total COVID-1i9 deaths can range from 11i000 ,ito 22,000i." And "In the bad scenarios, deaths go well over 300i,000i." (As of May 21i, 20i20i, the total reported deaths from COVID 19 in Canada was 6,145.) The number of deaths attributed to COVID-1i9, is in line with typical yearly seasonal viral respiratory illness deaths in Canada. However, the Covid-death numbers arc inflated based on the parameters dictated by the WHO to list a death as a Covid.death, namely anyone who has the Covid-1i9, at time of death ,regardless of whether another clear primary cause of death is evident apart from the simple presence of the covid-1i9 virus. 

118. On April 101\ 2020 -John Carpay, president of the Justice Centre for Constitutional Freedoms in Canada has stated there is reason to conclude that the government's response to the virus is deadlier than the disease itself. 14 

119. On April 1st\ 2020 -Bill Gates pledges another $150 million to coronavirus vaccine development and other measures. He states, "There are seven billion people on the planet. We are going to need to vaccinate nearly everyone." 

120. On April 1st\ 2020, US News reports corona virus tests are ineffective due to lab contamination at the EiDC and the CDC's violation of its manufacturing standards. 

121. On April 241\ 2020 -The Ontario government took the "extraordinary step" to release a database to police with a list of everyone who has tested positive for COVID-19 in the province.15 

122. On April 30t\ 2020 -Bill Gates writes that "the world will be able to go back to the way things were ... when almost every person on the planet has been vaccinated against coronavirus.i" Gates also states that "Governments will need to expedite their usual drug approval processes in order to deliver the vaccine to over 7 billion people quickly." 

14 https://www.jcd.ca/the¥cost-of-the-coronavirus-cure-.ould-be-deadller-than-the-disease/ 
123. On May st\ 2020, Neil Ferguson resigns from the UK government's Scientific Advisory Group for Emergencies (SAGEi) after flouting and breaking his own social distancing rules. On May 6t\ 2020, an anonymous soft-ware engineer (ex-Google) pronounces Neil Ferguson's COVID-1i9 computer model "unusable for scientific purposes". In fact, Ferguson's COVID-1i9 model has been laughing-stock and debacle. 

124i
. On May 11 t\ 2020, UK Chief Medical Officer Whitty states that COVID-1i9 is 'harmless' to the vast majority". 

125i
. On May 14th, 2020, Microsoft announces that it is acquiring UK-based 'Metaswitch Networks", to expand its Azure 5-G strategy. 

126i
. On May 19th, 2020 -Health Canada approves human trials of a SARS-Co V-2 (COVID-19) vaccine without clear evidence that prior animal testing to identify the potential risk of pathogenic priming (immune enhancement) has been conducted. 

12i
7. On May 21st, 2020 -Four Canadian infectious disease experts, Neil Rau, Susan Richardson, Martha Fulford and Dominik Mertz state -"the virus is unlikely to 

15 https:t/toronto .ctvnews.ca/mobile/ontarlo-ta kes-exlraord inary-slep-to-g lve-police-list-or-ail-covid-19-patients-
1.4910950?rbclld=lwAR 1 Ojfu 50Yg5BPZJKMyyqiN2P47dK wbZzFMqC8WEpFxilllEFt81 cGnfgc 
disappear from Canada or the world any time soon" and "It is unlikely that zero infections can be achieved for COVID-19." 16 
128. By May 2020 -Over six million Canadians have applied for unemployment benefits and 7.8 million Canadians required emergency income support from the Federal government, 17 because of economic shut-downs and closures dictated by Covid-measures. 
12i9. By May, 2020 -Estimates of the Federal deficit resulting from their response to SARS-CoV-2 (COVID-19) ranges up to $400 billion. 18 (This exceeds the Canada's national budget for a year). 
130. On May 20t\ 2020 -Dr. Teresa Tam, Canada's Chief Medical Officer, publicly advised the use of non-medical masks for the general public to provide an "added layer of protection" that could help prevent asymptomatic or pre.symptomatic Covid-19 patients from unknowingly infecting others. Dr. Tam's advice is not supported by scientific evidence. 19 
13i1. On May 21ist, 2020 -A letter from Mark Lysyshyn, MD, Deputy Chief Medical Health Officer with Vancouver Coastal Health states -"Although children are often at increased risk for viral respiratory illnesses, that is not the case with COVID-19. Compared to adults, children are less likely to become infected with COVID-19, less likely to develop severe illness as a result of infection and less likely to transmit the infection to others.i" Dr. Lysyshyn further states -"Non.medical masks are not needed or recommended. Personal protective equipment 
16 h ttps :/ / n atio na Ip ost. com/opinion/opinion-we-are-infect io us-disease-experts-its-ti m e-to-I ift-t h e-covid-19-lo c kd owns 17 https://www.macdonaldlaurier.ca/beyond-lockdown-canadians-can-have-both… 18 https://www.macdonaldlaurier.ca/beyond-lockdown-canadians-can-have-both… 19 https://www.politico.com/news/2020/05/20/canada-non-medical-masks-provi… 
such as medical masks and gloves are not recommended in the school environment." 20 
132. On May 22nd,2020 -Prime Minister Justin Trudeau told reporters that "contact tracing" needs to be ramped up across the county. Trudeau stated that he "strongly recommends" provinces use cell phone apps when they become available, and that this use would likely be mandated. 
133i
. On or about May 25i1\2020, the Federal government announced potential Criminal Code provisions, making it a criminal offence to publish "misinformation" about the COVID-19. "Misinformation" quickly evolves to mean as any opinion or statement, even from recognized experts, which contradicts or criticizes measures taken and/ or mandated by the WHO, to be implemented globally by national and regional governments. 

13i
4. As of June 9i1\ 2020, neither Prime Minister Trudeau, nor Premier Ford are willing and in fact refusing to disclose what medical advice, and from whom, they are acting upon. 

135i
. On June 111\ 2020 Toronto Mayor John Tory announces that mandatory face.masks will be implemented on the Toronto Transit Commission's (TTC) subways, busses and street cars, notwistanding that operations of the TTC continued as normal for the last four ( 4) months since the declared "out break" and "emergency" without neither any face-masks, nor any realistic way of reinforcing the six feet (2 meter) social distancing rule, on public transit. The Plaintiffs state, and the fact is, that face-masks, it has been scientifically and medically established, do NOTHING to prevent spread of air-borne viruses, and 

'0 http://www. vch .ca/Documents/COVI D-VCH-Schools-May-21-2020. pdf 
in fact cause other health problems. The Plaintiffs state and the fact is, that the Defendants and their officials are stepping up compulsory face-masks in order to maintain a physical and visual tool to maintain panic, fear, and to enforce compliance of their baseless measures due to increasing public resistance, and of their groundless and false basis . The masks, further act as a visual and present symbol of intimidation and show of who is in power, and do not act to medically assist but to publicly muzzle, panic, instill fear, and exert compliance to irrational and ineffective COVID measures from the Plaintiffs and others. The Plaintiff states and the fact is, that these measures were up-stepped after a Canadian survey was released that revealed, inter alia, that: ( a) 50i% of Canadians did not believe Justin Trudeau was being honest about the COVID-Measures ; (b) 16i% of the Canadians believe that the COVID-Measures are being used to effect mandatory vaccination and contract tracing and other surveillance; ( 
c) 19% of the Canadians do not believe that COVID-1i9 is no more harmful then a common flu; and 
( 
d) 7% of the Canadians believe that COVID-1i9 does not exist at all and is being mis-used as pretext for other, ulterior motives. 

136i. On or about June 11i1\ 2020: (a) Wellingtone-Dufferini-Guelph County, in Ontario, through its public health officer, Dr. Nicola Mercer, announced, ordered, that all customers and all employees, of all businesses in the County, would be required to wear face-masksi, including children under the age of 5 , and special.needs persons, who cannot and will not countenance a face-mask; (b) On June 3rd , 2020 Federal Minister of Transport, Marc Garneaui, announced that face-masks are required by all, when taking public transportation in Canada whether by plane, train, ship, or transit. 
(c) On June 11i1e\ 2020, Toronto Mayor John Tory announced the coming compulsory wearing of face-masks on the Toronto transit Commission vehicles and property. 

( d) On June 18i1\ 2020 the County of Windsor-Essex, in Ontario, through its public health officer, Dr. Wajid Ahmed, announced ordered, that all customers and all employees, of all businesses in the County, would be required to wear face-masks. 
137. 
Between April 1ist and June 15i1\ 2020 the Canadian Civil Liberties Association (CCLA) reports that approximately 10i,000 Covid related charges were laid across Canada, 2,85i3 in Ontario. 

138. 
On June 1 i\ 2020, the Toronto Hospital for Sick Children, considered the world's Premier Children's hospital completed an advisory report, publicly released days later, to the Minister of Health and Education, with respect to recommendations for the re-opening of school in September, 2020i. The report was prepared by two experts (in Virology) , upon the contribution and review of another twenty (20) experts as well as the "SickKids Family Advisory Networks". The 11-page report is resound and clear on the facts stat: 

1. (a) Children are at extremely low risk when it comes to COVID-19i;
2. (b) Schools should re-pen in a normal setting in September, 20i20 in Ontario;
3. (c) That no mask should be worn by children because of no evidence of effectiveness and in fact masks pose a health risk for children; 
4. (d) Social distancing should not be employed; and 
5. (e) That masks and social distancing pose significant physical and psychological health risks to children.21 

139i. On June 23rd , 2020, the Justice Centre for Constitutional Freedoms calls for, in a 69-page report, an end to the lock-down measures based on an analysis of the lack of medical and scientific evidence for their imposition and the infliction of unwarranted and severe Charter violations.22 
140. On June 26ith , 2020, Sweden's COVID-19 expert, Anders Tegnell, blasted the WHO'S response to COVID-19 and states that the "world went crazy" and further stingingly criticized the WHO as "mis-interpreting data" in branding Sweden as one of eleven (11) countries who are seeing a "resurgence" in COVID-19 cases. The Plaintiff state, and the fact is, that Sweden was one of the few countries in the World who did not adopt, wholesale, the WHO protocol and in fact faired much better then the countries who did, including Canada in that there was no economic shut-down in Sweden. Dr. Tegnell further stated that the lockdowns "fly in the face of what is known about handling virus 
d á 
pan em1cs. 23 
21 "COVID-19: Recommendations for School Re-opening", Toronto Hospital for Sick Children, Report dated June 17'\ 2020. 22 "Unprecedented and unjustified: a Charter Analysis of Ontario's Response to COVID-19" June 22nd , 2020. 23 "Daily Mail Online", Daily Mail.com, June 26'\ 2020 
141i.  On June 18ith , 2020 Premier Doug FORD announced  an upcoming up-step and  
acceleration of the implementation of 'contract tracing" surveillance through  
cellphones.  
14i2.  On June 28i1\  2020 The City of Toronto announces and put forward  a  
mandatory mask By-Law for all indoor public  venues  including private  
businesses.  

B/ THE COVID-19 MEASURES 
¥ Federal Measures 

143. 143. On or about March 1 ?11\ 20i20 Justin Trudeau announces a lock-down and invoked the following legislation with respect to "pandemic": 
     1. a) The Federal Quarantine Act, stipulating the lock-down of flights to Canada, and that Canadians returning to Canada, self-isolate and quarantine themselves for a 14i-day period; 
     2. b) Various prices of legislation setting out financial assistance for various persons and sectors. Trudeau further and effectively shut down Parliament. Parliament has only "convened", sparingly, to pass spending measures, with an amputated, hand.picked, selection of 25 MPs, notwithstanding that technology such as "Zoom", exists to accommodate and convene the entire Parliamentary contingency of the 338 MPs, to date it has not happened. Parliamentary Communities rested in a legislative coma until April, 20i20i, where after some sit virtually. 
144. 144. Justin Trudeau held (holds) daily press conferences to "inform" Canadians, and further issues decrees and orders, such as "stay home", which decrees and fiats have no legal effect, notwithstanding, that they were acted upon by Municipal and Provincial enforcement officers, but at that no time has the Federal Parliament invoked the Federal Emergencies Acti. 

¥ Provincial Measures 

145. 145. On or about March, 1 ?11\ 2020 Premier of Ontario. Doug Ford and his government invoked the Provincial Emergency Management and Civil Protection Act, with a declared state of emergency, last extended to July 9th, 2020i, and enacted to date, 48 Regulations thereunder with enforcement orders, which are: 

In force 

[ SPACER FOR ORDERS ]

 

146. 146. The net, summary effect, of the orders contained in the above Regulations are as follows: 
     1. a) Ordering the shut-down of all business, except for 'essential'' businesses which were tied to food, medicine, doctors, and hospitals; 
     2. b) A 'social distancing" of two (2) meters; 
     3. c) No 'public gathering" of more than five (5i) persons, who are un-related, withs 'social distancing" of two (2) meters, which was later increased to ten (10) persons; 
     4. d) Restaurant and bar shut-downs, except for take-out service; 
     5. e) The physical closure of all public and private schools, daycares, and universities; 
     6. f) The mandatory use of face-masks, mandated by the Ministry of Health, to all the Medical Regulatory Medical Services Colleges, to direct all their licensed members to impose mandatory masking of all patients, employees, and members, in their place of work; 
     7. g) The shut-down of all park amenities including all play-grounds and facilities for children; 
     8. h) The elimination of one-on-one, and all other programs for special-needs children, and those suffering from neurological and physical disabilities; 
     9. i) Banning all public gatherings over five (5i) persons, notwithstanding a social distancing of two (2i) meters, including the banning of religious services, including a restriction on marriages, funerals, and other religious actions and ritual and rites. 
     10. j) The provision for offences, laying of charges, and imposition of heavy fines for breach of the orders, with an impossibility to challenge those fines as the Provincial Offences Court is physically closed and the Provincial Offences Act tickets make it clear that the charge and fine cannot be 'mailed in" but that the person must attend, physically, at the Provincial Offences Act Court to file a defense of the charges, only to find a closed Courthouse. 
147. 147. In none of those Regulations did the Province require mandatory, community wearing of face-masking in public nor private locations. Premier Ford expressly declined to do so. 
148. 148. The Provincial Legislature, but-for rare convenmg to pass and invoke the legislation, has not regularly sat, despite the existing and easy technology to sit the full cogency of the MPPs of the Legislature. FORD has effectively dispensed with Parliament (the Provincial Legislature). 

¥ City of Toronto Municipal Measures 

149. 149. The City of Toronto , through Mayer John Tory, on March 23rd , 2020 issued a "Declaration of an Emergency" invoking the following measures: 
     1. a) "Eimergency order No.i1 -"To impose Regulations requiring physical distancing within park and public Squares"; 
     2. b) "Eimergency 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 Provincial legislation, but under the City of Toronto's own By-Law Municipal Code. It is 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. 150. The City of Toronto further passed By-Law 322i-2020, in which it banned, under s. 1, and s. 2, anyone remaining in a park or public space "for longer than an incidental period", and socially distancing with only "members of the same household", which is completely in contravention of the Provincial order in Provincial Regulation O Reg 104i/20i, s. 1(4i), passed pursuant to s, 7.0i.2(4i) of the Ontario Act. The Plaintiffs state, and the fact is, that 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 which was delegated to the Chief officer of Health, Eileen De Villa, a co-Defendant in the within claim. 
151. 151. On April 1st , 2020 a "Class Order" purportedly passed pursuant to s. 22(5.0.i1) of the Health Protection and Promotion Act, Dr. Eileen De Villa, Toronto's Medical Officer of Health, made an order, for anyone who: 
     1. a) Is identified with a diagnosis of COVID-19; 
     2. b) Has signs and symptoms of COVID-19,or have been tested and awaiting results; 
     3. c) Otherwise has reasonable grounds to believe to have COVID-19i; 
     4. d) Is in close contact with any in (a) to (c) above. 

Were ordered by De Villa to: 

1. a) Isolate and stay at home, with no visitors; 
2. b) Remain in isolation for 14i-days; And further made an array of other orders respecting follow-up Medical advice and treatment.

Exemptions to this order were made for: 

1. a) Asymptotic person who provide essential services; 
2. b) those receiving essential medical services; and 
3. c) 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". 

 

152. 152. 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 that it was any way more pervasive or dangerous than any other seasonal viral respiratory illness of the past fifteen (15) years. 
153. 153. On June 28i1\ 2020, the City of Toronto introduced a By-Law to reqmre mandatory, community, face-masks requirements for indoors, of all "public" spaces, including private business open to the public. The city issued posters for store owners to post, which included the requirement of store owners to enforce masking, but NO mention of exemptions to masking. 
154. 154. On June 301\ 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. 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 to "Stay home" and "do not go out except for food and medicine", when in fact such prohibitions were nowhere to be found in the law. 

¥ Reckless and Unlawful Statements and Actions of Leaders 

156. 156. The Plaintiffs 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 cause 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: 
     1. (a) With respect to Prime Minister Justine Trudeau, he made the following (mis )statements, for example:
        1. (i) Prime Minister Justin Trudeau told Canadians: "People should be staying home, self-isolating with family."24 
        2. (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. "25
        3. (iii) Justin Trudeau has issued a stern 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 to rise. 26
        4. (iv) "To all the kids out there, who can't go on play dates or on spring break vacation .. .I know this is a big change, but we have to do this for our grandparents and for the nurses and doctors in hospitals. "27 
        5. (v) "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 we are all in this together." (24i:35) " ..i. 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 regularly." 
        6. (vi) "I know it is tough to stay home, especially as the weather gets nicer. If you have kids, it is even tougher, but to get back outside and running around the playground and park as soon as .ossible, you need to keep them inside for a little longer. (10:22i)2
        7. (vii) " ... but I can tell you that we know it is very difficult situation for Canadians. There are very challenging projections out there that will emphasize how important it is for all of us to do our part, to stay home, to keep ourselves safe, to keep our loved ones safe and get through this ... "(42:26)3¡
        8. (viii) Miore 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.3
        9. (ix) On the topic of Asymptomatic viral shed contradiction puts to questions the merit of social distancing among healthy people: A reporter asks Mr. Trudeau, after his wife had been tested positive for coronavirus, what kind of advice he had received from medical doctors. 
           "In terms of advice I 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." (15:30i)A reporter asks about the possibility of transmission to other members of the cabinet,17:02 "According to Health Officials the fact that I have expressed no symptoms means that anyone that I engaged with throughout this week has not been put at risk (1i7: 12)32
     2. (b) While Trudeau made the above-noted comments and decrees, without legal basis whatsoever, and further contradicted actual Provincial laws, Trudeau, all the while breaks social distancing Provincial Laws by:
        1. (i) On March 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 COVIDl 9."
        2. (ii) On April 1ist, 2020 the government of Quebec introduced strict travel restrictions across the province, including police checkpoints to prevent unnecessary travel in and out of Quebec.
        3. (iii) Shortly after calling on Canadians to "stay home" and "Skype that big family dinner," Trudeau crossed the provincial border from Ottawa into Quebec on Easter Weekend to visit his wife and three children who had been living at their Harrington Lake cottage since March 29i, 20i20.33
     3. (c) With respect to Premier Doug Ford: 
        1. (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 (CCLA);34
        2. (ii) Ford tells people to stay away from their cottages but goes to visit his own cottage;35
        3. (iii) 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.36
     4. (d) With respect to Toronto Mayor John Tory: 
        1. (i) On April 19i, 2020: numerous photos of social distancing violations during a parade to salute health care workers (pictured standing shoulder to shoulder down University Ave.)37 
        2. (ii) May 23i: Here is Tory violating social distancing rules and modeling counterproductive mask use at Trinity Bellwoods park , where thousands had gathered;38 
157. 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, 2020i, and who had to resign his post in the UK for breaching the Rules. Other examples of such reckless behaviour and statements include:
     1. (a) On April 25th FORD calls protestors opposing government lockdowns as "selfish" "irresponsible" "yahoos"; 
     2. (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 advice. It risks undoing the good 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.39 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 TRUDEiAU, all of whom simply follow one singular dogma from the WHO, while refusing to disclose the "science", its substance or source, 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;
     3. (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. cabinet minister Carla Qualtrough, Conservative Opposition Leader Andrew Scheer, his wife and their five children last Friday -filling all seats on the aircraft. "40
     4. (d) Dr. Bonnie Henry BC Provincial Health Officer allows gatherings of 50 and when challenged on conflicting figures from across Canada confirm "None of these are based on scientific evidence."41 
     5. (e) Dr. Yaffe:Ontario's Associate Chief Officer of Health Dr. Yaffe caught blatantly violating the social-distancing rules, just minutes after the premier said that based on public-health officials' advice we'll have to stay on lock-down for an indefinite period.i42 No such indefinite "lock-down" was mandated by any law. 
158. 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 a groundless and falsely-declared 'pandemic'', and generate fear and confusion on the ground, not only with 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, Corporate, and Organizational Oligarchs. 

Cl IGNORING AND NOT ADDRESSING THE MEDICAL EXPERTS' EVIDENCE 

¥ The Nature of Viral Respiratory Illness (or Disease) and COVID-19 

159. The Plaintiff Dr. Denis RANCOURT, Ph.D.i, and co-Plaintiffs state, and the fact is that, as is borne out by vast preponderance of medical and scientific study, that regardless of the novel viral specification ("strain"), viral strains which lead to Seasonal Viral Respiratory Illness (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 face of under-lying 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 viral strain season; 
(c) That the year-to-year winter-burden (excess) mortality in mid-latitude nations is robustly regular, with respect to Seasonal Viral Respiratory illness due to the following: 
(i) 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, "flu-
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.43 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 fluid air and fill virtually all enclosed air spaces occupied by 
43 "All-Cause Mortality during COVID-19". Denis G. RANCOURT PhD., June 2nd , 2020, and all cited scientific and medical studies therein. humans, and (2i) 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 infection is initiated.

(b) This is why the patter. 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 Northern and Southern hemispheres, irrespective of tourist and business air travel and so on.

( c) The data shows that there is a persistent and regular pattern of winter.burden mortality that is independent of the details, and that has a well constrained distribution of year to year number of excess deaths ( approximately 8i% to 11 % of the total yearly mortality, in the USA, 1972 through 19i93). Despite all the talk of epidemics and pandemics and novel viruses, the pattern is robustly constant. 
(d) 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 occurred since the unique flu pandemic of 1918 (the "Spanish Influenza"). Covid-1i9 is no exception and no more virulent than all others apart from the influenza pandemic of 1918. 
(e) Scientific studies show that the three recent epidemics assigned as pandemics, the H2N2 pandemic of 1957, the H3N2 pandemic of 1968, and the HlNl pandemic of 200i9, 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 195i1 was concluded to be more deadly, on the basis of P&I data, in England, Wales and Canada, than the pandemics of 1957 and 1968).i44 

¥ Contrary Views of the Experts to WHO protocol 

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.45 

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 fact 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. 

44 "All-Cause Mortality during COVID-19". Denis G. RANCOURT PhD., June 2nd, 2020, and all cited scientific and medical studies therein. 45 "All-Cause Mortality during COVID-19". Denis G. RANCOURT PhD., June 2nd, 2020, and all cited scientific and medical studies therein. 
163i. The Plaintiffs state that such experts include, but are not restricted to: (a) Dr Sucharit Bhakdi , a 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 200i9 he called for an inquiry into alleged conflicts of interest surrounding the EU response to the Swine Flu pandemic. 

(c) Dr Joel Kettneri, a professor of Community Health Sciences and Surgery at Manitoba University, former Chief Public Health Officer for Manitoba province and Medical Director of the International Centre for Infectious Diseases. 

(d) Dr .John Ioannidis, a Professor of Medicine, of Health Research and Policy and of Biomedical Data Science, 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 (MEiTRICS). 
(e) Dr Y oram Lass, an Israeli physician, politician and former Director General of the Health Ministry. He also worked as Associate Dean of the Tel Aviv University Medical School and during the 1980s presented the science-based television show Tatzpit. 

(f) Dr Pietro Vernazza , a Swiss physician specializing in Infectious Diseases at the Cantonal Hospital St. 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. 
(h) 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 Institut Hospitalo-universitaire Mediterranee Infection, Marseille and the Institut de Recherche pour le Developpement, Assistance Publique-I-16pitaux de Marseille, conducting a peer-reviewed study on Coronavirus mortality for the government of France under the 'Investments for the Future' programme. 
(j) 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. 
(1) Dr Peter Goetzsche , a Professor of Clinical Research Design and Analysis at the University of Copenhagen and founder of the Cochrane Medical Collaboration.46 

46 
http s :/ /www. fa rt -ru ss. co m/20 20/03 / co ro n avi ru s-s kept ic ism-the se-12 -leading-med ica I-experts-contradict-th e-offi c i a 1.gove rn ment -media-narrative/ 
And the Plaintiffs 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. 
164i. These experts have expressed, in summary, for example, the following opinions: (a) By Dr. Sucharit Bhakdi: 
"[that The government's anti-COVID19 measures] arc 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 to patients in need are reduced, operations cancelled, practices empty, hospital personnel dwindling. All this will impact profoundly on our whole society. All these measures are leading to self-destruction and collective suicide based on nothing but a spook." (b) By Dr Wolfgang Wodarg that: 
"what is missing right now is a rational way of looking at things. We should be asking questions like "How did you find out this virus was dangerous?", "How was it before?", "Didn't we have the same thing last year?", "Is it 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. It is 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 ... I 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 
https:/ /off-guardian.org/2020/03/24/12-experts-questioning-the-coronavirus.
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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 actual number of cases reported is 1 per 1000 people and the actual rate of deaths reported is 1 per 20i,000i. So maybe that would help to put things into perspective." (d) By Dr John Ioannidis that: 
"Patients who have been tested for SARS-Co V-2 arc 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-1i9 is much higher. ... Could the Covid-1i9 case fatality rate be that low? No, some say, pointing to the high rate in elderly people. However, even some so-called mild or common-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 of total deaths due to "influenza-like illness" would not seem unusual this year. At most, we might have casually noted that flu this season seems to be a bit worse than average. . . . "A fiasco in the making? As the coronavirus pandemic takes hold, we are making decisions without reliable data", Stat News, 17th March 2020i." ( e) By Dr Y oram Lass that: 
"Italy is known for its enormous morbidity in respiratory problems, more than three times any other European country. In the US about 40i,000 people die in a regular flu season. . . .In every country, more people die from regular flu compared with we all forget: the swine flu in 20i09i. 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, is a virus with public relations .... Whoever thinks that governments end viruses is wrong. -Interview in Globes, March 
22ind 2020i." (f) By Dr Pietro Vernazza that: 
"We have reliable figures from Italy and a work by epidemiologists, which has been published in the renowned science journal <Science>, which examined the spread in China. This makes it clear that around 85 percent of all infections have occurred without anyone noticing the infection. 90 percent of the deceased patients are verifiably over 70 years old, 50 percent over 
80 years ... .In Italy, one in ten people diagnosed die, according to the findings of the Science publication, that is statistically one of every 1,000 people infected. Each individual case is tragic, but often -similar to the flu season -it affects people who are at the end of their lives ..i.. If we close the schools, we will prevent the children from quickly becoming immune .i..i. We should better integrate the scientific facts into the political decisions. .Interview in St. Galler Tagblatt, 22ind March 2020 ." (g) By Frank Ulrich Montgomery that: 
"I'm not a fan of lockdown. Anyone who imposes something like this must also say when and how to pick it up again. Since we have to assume that the virus will be with us for a long time, I wonder when we will return to normal? You can't keep schools and daycare centers closed until the end of the year. Because it will take at least that long until we have a vaccine. Italy has imposed a lockdown and has the opposite effect. They quickly reached their capacity limits, but did not slow down the virus spread within the lockdown. -Interview in General Anzeiger, 18th March 2020i." (h) By Prof. Hendrik Streeck that: 
"The new pathogen is not that dangerous, it is even less dangerous than Sars-1i. The special thing is that Sars-Co V-2 replicates in the upper throat area and is therefore much more infectious because the virus jumps from throat to throat, so to speak. But that is also an advantage: Because Sars-1 replicates in the deep lungs, it is not so infectious, but it definitely gets on the lungs, which makes it more dangerous. . . . You also have to take into account that the Sars-Co V-2 deaths in Germany were exclusively old people. In Heinsberg, for example, a 78-year-old man with previous illnesses died of heart failure, and that without Sars-2 lung involvement. Since he was infected, he naturally appears in the Covid 19 statistics. But the question is whether he would not have died anyway, even without Sars-2. -Interview in Fran.fiirter Allgemeine, 16ith March 2020i". (i) By Dr Vanis Roussel et. al. that: 
"The problem of SARS-CoV-2 is probably overestimated, as 2.6 million people die of respiratory infections each year compared with less than 4000 deaths for SARS-Co V-2 at the time of writing . . . . This study compared the mortality rate of SARS-CoV-2 in OECD countries (1i.3i%) with the mortality rate of common coronaviruses identified in AP-HM patients (0i.8%) from 1 January 2013 to 2 March 2020i. Chi-squared test was performed, and the P.value was 0.11 (not significant) ... .it should be noted that systematic studies of other coronaviruses (but not yet for SARS.Co V-2i) have found that the percentage of asymptomatic carriers is equal to or even higher than the percentage of symptomatic patients. The same data for SARS-Co V-2 may soon be available, which will further reduce the relative risk associated with this specific pathology. "SARS-Co V-2i: fear versus data", International Journal of Antimicrobial Agents, 19ith March 
2020i." (i) By Dr. David Katz that: 
"I am deeply concerned that the social, economic and public health consequences of this near-total meltdown of normal life -schools and businesses closed, gatherings banned -will be long-lasting and calamitous, possibly graver than the direct toll of the virus itself. The stock market will bounce back in time, but many businesses never will. The unemployment, impoverishment and despair likely to result will be public health scourges of the first order. -"Is Our Fight Against Coronavirus Worse Than the Disease?", New York Times 20ith March 2020i." (k) By Michael T. Osterholm that: 
"Consider the effect of shutting down offices, schools, transportation systems, restaurants, hotels, stores, theaters, concert halls, sporting events and other venues indefinitely and leaving all of their workers unemployed and on the public dole. The likely result would be not just a depression but a complete economic breakdown, with countless permanently lost jobs, long before a vaccine is ready or natural immunity takes hold. . . [TJhe best alternative will probably entail letting those at low risk for serious disease continue to work, keep business and manufacturing operating, and "run" society, while at the same time advising higher-risk individuals to protect themselves through physical distancing and ramping up our health-care capacity as aggressively as possible. With this battle plan, we could gradually 
build up immunity without destroying the financial structure on which our lives are based. -"Facing covid-1i9 reality: A national lockdown is no" 
cure", Washington Post 21ist March 2020 (1) By Dr Peter Goetzsche that: 
"Our main problem is that no one will ever get in trouble for measures that are too draconian. They will only get in trouble if they do too little. So, our politicians and those working with public health do much more than they should do .... No such draconian measures were applied during the 200i9 influenza pandemic, and they obviously cannot be applied every winter, which is all year round, as it is always winter somewhere. We cannot close down the whole world permanently .... Should it turn out that the epidemic wanes before long, there will be a queue of people wanting to take credit for this. And we can be damned sure draconian measures will be applied again next time. But remember the joke about tigers. "Why do you blow the horn?" "To keep the tigers away." "But there are no tigers here." "There you see!"117 "Corona: an epidemic of mass panic", blog post on Deadly Medicines 21ist March 2020 
165i. Expert criticism has also been levelled by Canadian experts, including: (a) By Dr Denis Rancourt, Ph.D., expert in public health and Researcher, 
In stating that: 
"Federal and provincial Canadian government responses to and communications about COVID-1i9 have been irresponsible. ""The approach being followed by governments is reckless.""Justification for the early panic-response is not corroborated.""Faith in epidemic-modelling of catastrophe.scenarios and mitigation strategies is not justified. "48 (b) Dr. Richard Schabas, Ontario's former Chief Medical Officer who is of 
the opinion that: 
47 
Another 10 experts have been added to this link. Total is 22 experts. 
https;//www.europereloaded.corn/twenty¥lwo-experts¥guestio11ing¥the-coronavirus-panic-videos¥scientif1c¥common-s1>nse/ 
48 
hltp://ocla.ca/wp-colltent/uploads/2014/01/OCLA-Report-2020á1-Criticism-ol-Governml!nt-Response.to-COVID19.pdfá 
¥ "We have fundamentally over-reacted and misjudged the 
magnitude of the problem." 
¥ 
"lockdown measures are unsustainable" 

¥ 
"the virus isn't going anywhere" 

¥ 
"In no country, including Italy, has the death toll come anywhere close to what we would expect in an average influenza year."(CBC News, March 22i, 2020i)49 

( c) Based on Dr. Richard Schabas' study of SARS and quarantine50 Schabas 
states: 
"far more cases are out there than are being reported. This is because many cases have no symptoms and testing capacity has been limited. There have been about 100i,000 cases reported to date, but, if we extrapolate from the number ofrcportcd deaths and a presumed case-fatality rate of 0.5 per cent, the real number is probably closer to two million -the vast majority mild or asymptomatic." 
" the number of deaths was comparable to an average influenza season. That's not nothing, but it's not catastrophic. either, and it isn't likely to overwhelm a competent health-can. system. Not even close." "Quarantine belongs back in the Middle Ages. Save your masks for robbing banks. Stay cairn and carry 011. 
Let's not make our attempted cures worse than the disease:':i 1 (d) Dr .Joel Kettner -former Chief Public Health Officer l'<1r Manttolx1 
province; professor of Community Health Sciences and Surgery at 
Manitoba University: Medical Director of the [nternational Centre i<1r 
Infectious Diseases0 In a phone interview on CBC Radio he stated: 
"in 30 years of public health medicine I have never seen anything like this, anything anywhere near like this. I'm not talking about the pandemic, because I've seen 30 of them, one every year. It is called influenza .... But I've never seen this reaction, and I'm trying to understand why. 
49 
httpsJ/www.youtube.com/watchi'v=sm9alyH8x 
llli.P.ca. news.ya hoo.com/virus-isnt-golng-anywhere-says-1217 205 22. htm I 
50 
https:ljwww.ncbl.nlm.nlh.gov/pmc/artlcles/PMC2094974/ 
51 
ht t ps ://www, l heglo bean d ma ii, com/ op i r, ion/art iGle-strlc tly-by-the-n un, bers-t he-cor o 11 a virus-doe,-no l-(e/!!S ter-as-,1-cf rP,/ 
... the data they are getting is incomplete to really make sense of the size of the threat. We are getting very crude numbers of cases and deaths, very little information about testing rates, contagious analysis, severity rates, who is being hospitalised, who is in intensive care, who is dying, what are the definitions to decide if someone died of the coronavirus or just died with the coronavirus. There is so much important data that is very hard to get to guide the decisions on how serious a threat this is. 
The other part is we actually do not have that much good evidence for the social distancing methods. It was just a couple of review in the CDC emerging infectious disease journal, which showed that although some of them might work, we really don't know to what degree and the evidence is pretty weak. The third part is the pressure that is being put on public health doctors and public health leaders. And that pressure is coming from various places. The first place it came from was the Director-General of the World Health Organization (WHO) when he said "This is a grave threat and a public enemy number one ", I have never heard a Director-General of WHO use terms like that. "52 
166i. Other pointed criticism and opposite views include: (a) Stanford University Team-to the effect that the Evidence of Covid 19 
1. . 1 53 
morta 1ty rate 1s ow; (b) By Thomas Stavola, Rutgers University Law School Relaxation of 
Lockdown via Quarantine of Symptomatics and Digital Contact Tracing, 
Experts Agree, indicating that: 
"The latest scientific data indicates that mild and asymptomatic prevalence is much higher than previously thought, thus, the true 
52 hl.lps:Uoff-guardian.org/2020/03/17/listen-cbc-radio-cuts-ofl-eKpe.rt-when.he-guestions-covidl9.
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53 htlps://www.greenmedi11fo.com/blog/stanford-tea1,1-l'i11ds-evide11ce¥covid-.L9-mortality-rate-low-2-17-times-lower-whos.
esta?utm campaign=Daily%20Newsletter%3A%20Personal%20update%20%28VVNwqr%29&utm medium=email&utm source=Dail 
y%20Newsletter& ke=eyJrbF9IbWFpbCl6ICJgb2hu2nlvbW91dHdlc3RAZ21I1aWwuY29tliwglmrsX2NvbXBhbnlfaWQiOIAiSzJ2W FSln0 
%30 
fatality rate is closer to 0.4%, or possibly even lower. While SARS-Co V-2 can be severe in very small subset, these values indicate that the population-based severity burden is much lower than initially considered months ago. Studies indicate that asymptomatic transmission is negligibleUJ Maria Van Kerkhove, who heads the World Health Organization's emerging diseases and zoonoses unit, stated that asymptomatic cases are definitely not a major driver of transmission."54 ( c) By Knut Wittkowski -German epidemiologist. Mass Isolation 
Preventing Herd Immunity , and conluding that: 
"The lockdown prevents the normal progression of natural immunity that is key to protecting the wellbeing of the most vulnerable. The extended lockdown will increase the harm already done many fold including deaths. 
Dr. Wittkowski said we must protect and quarantine the frail, sick and very elderly 10i% of our population, while allowing the other 90i% to acquire the virus with mild to no symptoms, thereby gaining true NATURAL herd immunity. He estimated this to be a 
4 week process. 
When people are allowed to go about their daily lives in a community setting, he argued, the elderly could eventually .sooner rather than later -come into contact with the rest of the population in "about four weeks" because the virus at this point would be "vanquished." 
"With all respiratory diseases, the only thing that stops the 
disease is 'herd immunity,i"' 55 (d) By Martin Dubravec, MD -Allergist/Clinical Immunologist Allergy and 
Asthma Specialists of Cadillac Cadillac, MI, conducting that:Thc Answer 
is Herd Immunity56; 
54 https ://medium .com/@tomstavola/latest-science-on-covid-19-a nd-d igita 1-contract-tracing-f58ee55b3 b9 b 
55 https://www .a ier .org/a rticle/sta nd-u p-for-your-rights-says-professor-kn ut-m.wittkowski/?fbclid=lwAR2ZuYv6CbCsji In 2 UJ HXOk84KOjbSOWoxceTSia NZd I_ eZu had ppi25 Pn E 
hllp$://ratical.org/PerspectlvesOnPa ndem ic-11. h tm I 
56 
https://aap.online.org/coronavirus-covid-19-pubtic-health-apocatypse-or… (e) By Dr. Dubravec's whose advice on how to end this epidemic is: 
"What can be done to end this epidemic? The answer is herd immunity. Let those who will not die nor become seriously ill from the disease get infected and immune to the disease. Donát close schools -open them up! Don't close universities -reopen them! Let those under the age of 65 with no significant health problems go to work. Their risk of death is very close to zero. They become the wall that stops the virus. 
Our current strategy of isolating these healthy people from the virus: a. is not working -the virus is still spreading and b. for those who theoretically may be shielded from the virus, they wil I get exposed later. Our current strategy is actually leading to a prolonged COVlD-19 season! Herd immunity works and despite our ctment efforts to mess it up, herd immunity will be the ultimate reason the virus dies down. We should promote the concept, not try to stop it. Unlike the influenza epidemics of the past, this virus is not attacking young people. We can use herd immunity to our collective advantage." 
The bottom line is that herd immunity is what will stop the virus from spreading. Not containment. Not a vaccine. Not staying locked in our homes. It's time we had an honest conversation on how to move beyond containment. (t) By Professor Peter C. G0tzsche that: "The Coronavirus mass panic is 

not justified."57 
(g) By the Wall Street Journalin "Rethinking the Coronavirus 

Shutdown", that : 
No society can safeguard public health for long at the cost of its economic health. 58 
57 
httQ!f/J.www.deadlymedlclnes.dk/w1Honten1/uploads/G%C3%B8tzsche-The-Coroo;ivirus… 
58 
htips://www,wsj.com/anicles/rethinking-the¥coronavirus-shutdown-115M659154 (h) By the Professor Yitzhak Ben Israel of Tel Aviv University, who plotted the rates of new coronavirus infections of the U.S., U.K., Sweden, Italy, Israel, Switzerland, France, Germany, and Spain, concluding that: 
"The numbers told a shocking story: irrespective of whether the country quarantined like Israel, or went about business as usual like Sweden, coronavirus peaked and subsided in the exact same way. The professor believes this evidence -actual evidence and data, not the projections of some model -indicate that there is no need for either quarantine or economic closurcs."59 (i) By Professor Stefano Montanari that: "The Virus Vaccine is a Scam"60' á 

G) By Virologist Hendrick Streeck that: "There is no danger of infecting someone else while shopping"61; 
(k) By: (i) Sucharit Bakhdi:62 
(ii) John Ioannidis, Stanford:63 

(iii) John Lee:64 (iv) Perspectives on the Pandemic I Professor Knut Wittkowski I Episode 2.65 
59 htLps://www.afa.l\et/tl1e-stand/cullure/2020/04/shutdowns-were-polntless-aJl-atong/ll.XpnwkkhQ ZA.faceb00k 60 !illlis://europeansworldwlde.wordpress.corn/2020/04/02/the-virus-vacclne-is-a-scam/ 
61 b.!!r,is:/{www.zuercher-presse,com/vlrologe-hendrkk-s1reeck-gibt-kelne-gefahr-belm… 1zieren/?cn-reloaded4 62 https://www.youLUbe.com/warch?v=JOB9bA-gXL4&fbclid=lwARlXMZJdTEpe-9woCk… Ums loYZYLKVOR8CQICkG VjD6325SY 
63 hltps://www.voutube.com/watch?v=d6MZy.
2fcBw&fbclid=lwARlLCsQoUW3dmZzn 2Uwzl85XgfofldOtnn8iSMTMAODv5N9 Dwsi7f3K4 
64 hltps://www.spectalor.eo.uk/article/how-10-understand-and-(eport-flgures-ror-covid-l9-deaths-/c mp 65 
https://www.youtube.com/watch?11=IGC5sGdz4kg (v) "Medical Doctor Blows C Vi Rus Scamdemic Wide Open" 
Andrew Kaufman MD in (Nederlands ondertiteld);66 All indicating that the "pandemic" is not a pandemic and the modeling and measures unwarranted; (1) French researchers: in COVID FEiAR vs. DATA : 
"Under these [first world] conditions, there does not seem to be a significant difference between the mortality rate of SARS-Co V-2 in OEiCD countries and that of common coronaviruses " which are responsible for 10 to 20 percent of all respiratory infections, including colds, worldwide."67 (m) In :Coronavirus COVID-19i: Public Health Apocalypse or Panic, Hoax, and Anti-American?68; 
(n) In :Stanford doctor says Fauci doesn't have the evidence to back up his claims;69 
(o) In :Questioning Conventional Wisdom in the COVID-19 Crisis, with Dr. Jay Bhattacharya; 70 
(p) By Dr M. I. Adil, Corona Virus is a Hoax;71 
(q) In Resp therapist blowing the whistle on covid -19.72 

66 
h1tps://www.you1ube.c9m/watch ?v=S8JBg9H 725E 
67 
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68 
h l tps :// a a Q son I in e .o rg/cornoavl r us-covid-19-p u b lic-hea Ith-apocalypse-or-pa ni c-h oax-an d-an l i-ame.rlc, 11/ 69 https://www.youtube.com/watch?v=-U03Wd5urg0 
70 
https://www.yol1tube.com/watcl1?v=J04Yz11gPyU 
71 
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2 htlps://www.youtube.corn/watch?v=ROaDAM5tzWA 
¥ COVID-Measures Worse than Virus 
16i7. Another thematic point of sound scientific and medical criticism is that the COVID -measures are worse than the virus as reflected in, inter alia, the following: (a) At least one study suggests the ultimate changes in contact patterns triggered by social distancing measures could end up having a negative effect on the population and, in some cases, even worsen the outcome of 
.. 
t h e ep1 d em1c. 73 (b) Cost of Coronavirus cure could be deadlier than the disease. 74, by Carpay who is president of the Justice Centre for Constitutional Freedoms; (c) California ER Physicians: Sheltering in Place Does More Harm than Good -Lowers Our Immune System. (d) Doctors Dan Erickson and Artin Massihi of Accelerated Urgent Care in Kern County, California say the longer people stay inside, the more their immune system drops. The secondary effects, the child abuse, alcoholism, loss ofirevenue -all of these are, in our opinion, significantly more detrimental thing to society than a virus that has proven similar in nature to the seasonal flu that we have every year. 75 
73 
JR Soc Interface. 2018 Aug; 15(145): 20180296. hLtps://www.11cbl.nlm.nih.gov/pmc/a(ticles/PMC6127185/pdf/rsif20180296.pqf hltps://www.greenmedlnfo.com/blog/social-disLancing-may¥worsen-epidemic-outco;nes 
74 
https://www.jccf.ca/the-cost-of-the-coronavirus-cure-could-be-deadlier-…¡the-disease/ 
75 
https:ljvaccineimpact.com/2020/california-er-physicians-sheltering-in-p… 
https ://p repforth at.co m/kern-cou nty-ca I iforn ia-doctors-co ronavi rus-en d-s h utd own/ ( e) Economic Consequences of Lockdown: 
"Our leaders must reopen our country immediately. We will survive this virus. We will not survive this economic lockdown. "76 
168. With respect to treatment measures, the Defendants further ignored, and continue to ignore, the following expert criticism and opposition; (a) Ventilators are not working and may be increasing harm. New evidence reveals there is no 'pneumonia' nor ARDS with CV 19. Ventilators are not only the wrong solution, but high pressure intubation can actually wind up causing more damage than without. Ventilators arc not working and may be increasing harm. Over 80% of individuals put on ventilators are dying. 77 
(b) Managing the Flow. The truth for any new virus is that most people will be exposed to it. If one's goal is to NEiVEiR get COVID-19, one would pretty much need to live on lockdown for the rest of his/her life. The ONLY reason for the lockdown is to manage the flow of people through our hospitals so that those who have acute symptoms will get the care they need to hopefully not die. Is the desire to manage the flow of people through our hospitals worth shutting down our economy? Given most hospitals are operating at 50% or less of capacity, have we not over managed the flow? 

76 htLps://www.facebook.corn/groups/22194S012378955/ 
77 httns://web.arcl1ive.org/web/2020040S061401/hltps://medium.com/@agaiziunas/covid-19-had-L1s-all-fooled-bul¥now¥wC'¥ rnight-have-flnally-found-its-secrel-91182385efcb (c) No Evidence Masks Work. No RCT study with verified outcome shows a benefit for HCW or community members in households to wearing a mask or respirator. There is no such study. Likewise, no study exists that shows a benefit from a broad policy to wear masks in public. Furthermore, if there were any benefit to wearing a mask, because of the blocking power against droplets and aerosol particles, then there should be more benefit from wearing a respirator (N95i) compared to a surgical mask, yet several large meta-analyses, and all the RCT, prove that there is no such relative benefit. (d) Ineffectiveness of Masks & Respirators -D. G. Rancourt.78 (e) Conflicting Advice About Face Masks to Prevent CV 19. There is currently no evidence that wearing a mask (whether medical or other types) by healthy persons in the wider community setting, including universal community masking, can prevent them from infection with respiratory viruses, including COVID-1i9. 79 (f) The surgeon general said not to wear a mask.80 
(g) Over 3 times the risk of contracting influenza like illness if cloth mask is used versus no mask at all;81 

(h) "Penetration of cloth masks by particles was almost 97% compared to medicalmaskswi th44 % "; 82 
78
https://www.researchgate.het/publlcatlon/34057073S Masks Don'l Work A review of science relevant to COVID.19 social policy?fbclid=lwAR3JC0snDOC2oRHaulk8F8 rA6CmfTvca6eZY11S BHOGRcSuHhKYPoWEmfk 
79 
ht l ps:/lt h ev accinerea ct ion .org/2020/04/1 ace-mas ks-to-p revent-covid-19 ¥con fllct in g-filcts-advice/ 11 ed ns 
80 ht1ps://ww´1,businessin.sider.com/who-110-need-for-healthy-people-to-we.r-f-.ice-masks-2020-'1 81 hLlps://www.ncbi.nlm.oih.gov/prpc/artides/PMC4420971/ (i) Report on surgical mask induced deoxygenation during major surgery"83 ; 
G) Co-Factors: Not everyone is at equal risk of dying from COVID 19i. CV 
19 has spread unevenly around the world, clustered in several hot pockets, while leaving other areas with scant outbreaks. What other factors are contributing to the COVID 19 virus mortality?; (k) Link Between Air Pollution and CV 19;84 
(1) Underlying Disease and COVID-19.85 

16i9. The Plaintiffs state, and the fact is, that the evidence is that far many, more people have died as result of the "pandemic" measures themselves, than purportedly from the "COVID-deaths", even if one takes the deaths "caused" by COVID as a given, through the following consequences of the measures: (a) Spikes in suicide rates resulting in intense clinical depression from the measures; 
(b) Spikes in drug over-dose attributable to measures; 

( c) Spikes in domestic violence and murder as a direct result of the measures; (d) Deaths resulting from the cancellation of over 170i,000 medical surgeries; ( e) Deaths from persons afraid to leave their homes to obtain medical diagnosis and treatments; and 
82 
.s://www.sciepcedailv.com/releases/2015/04/150422121724.htm 
83 
https://www.ncbi.nlm.nih-.gov/pubmed/18500410 
84 
https:ljthevaccinereact-ion.org/2020/04/study-shows¥link-between-11ne-pa-rt1cle-air¥pollut1011-and-cov1d-l9-mortality/ 
85 
h I tps :// thev accine reaction .org/20 20/04/ covid-19-hospita Ii zed-patients-a nd-u 11 d erlyi ng-chro n ic-d tsea se/ (f) Sub-space spikes in starvation, given the UN World-Food Bank warning that 130 Million additional people will be on the brink of starvation by end of 2020 due to disruption of supply chains due to COVID Measures. 
170i
. It is to be noted that the above-noted criticism was early on in the outbreak which criticism has now intensified both in volume and accuracy, that the COVOD-measures are unwarranted, extreme, and not based on science and medicine. 

1 
71. Another pointed area of disagreement and criticism, which continues, along with the above-noted, which the Defendants refuse to acknowledge, ignore, and not respond to, is the questioning of this as a "pandemic" rather than a typical seasonal viral respiratory illness, as reflected, inter alia, by the following: 

(a) California has a 0.0003% Chance of Death from Covid 19": 
"Initial models were woefully inadequate. They predicted 
millions of cases of death. Not of prevalence or incidence 
but deaths. This is not materializing. What is materializing 
in California is 12% positives ... This equates to 4.7 million 
cases in California. This is the good news .... We have seen 
1,227 deaths. California has 0.0003% chance of death from 
Covid-19. Is this enough to justify a lock-down?" 
"COVID-19 Antibody Seroprevalence in Santa Clara County, California"Conclusion: "The population prevalence of SARS-Co V-2 antibodies in Santa Clara County implies that the infection is much more widespread than indicated by the number of confirmed cases. 
P -pulation pre al nee estimates can now be used to calibrate epidemic and mortality projections." 86 
86 
https://www.medrxiv.org/content/l0,1101/2020.04.14.200624G3v1 (b) The above research, in (a) above, is ground-breaking and provides foundational support for narratives such as 
(i) the initial models were incorrect; 
(ii) conflicts of interest (Gates/Fauci/Democrats) contributed to an over-hyped response and failure to revisit despite availability of new data (confirmation bias); 

(iii) we need to be rational here as the lock-down 1s hurting normal citizens -the 99% ; (iv) no evidence exists to justify forceful solutions like mandatory Covid-19 vaccinations, community immunity passwords, contact tracing, or increased domestic surveillance: 
(v) we need to root out and remove all conflicts of interests 111 om public health institutions, both CDC and WHO; again 
(vi) Annual Influenza Deaths vs. CV 19 deaths. It is claimed that 7 to 8,000+ Canadians die from season viral respiratory illness each year. The number of Canadians who have died from Covid-19 does not stray from annual season viral respiratory illness death total, 87 notwithstanding the inflated, false " covid-deaths"; 
(c) In 2009-2010, the world experienced the swine flu pandemic (HINI). During that pandemic it is claimed that 203i,000 people were killed world.

87
b!:ws://www.worldometers.info/coron.virus/7nsukey,c8gR2B80EU.vHglRlj\z%2FFrRbGWu%28hOoChcVMEV2tc1d0%2 Fqt1 hen Kl U fJ_ 6Oevxq86h8W7SYtAC%2'FYsoVycvKvhtVZgT%2FvRExliON%2BcUTJ6uKZOsU4QDUYN0QG2n2ifAPsD1,1LBJZryuEWbYH8BsYmR4hwzTo azvCLjgZsbV0YQAANZ46gHbo7Sf%2Beyzklc3WND68j 
wide by the virus. There was not a need to shut down our entire way of life in 2009i. It is still unclear why this is the strategy being implemented today; ( d) The CDC has tracked the total number of Americans who die every week from pneumonia. For the last few weeks, that number has come in far lower than at the same moment in previous years. How could that be? It 
seems that doctors are classifying conventional pneumonia deaths as COVID-19 deaths. That would mean this epidemic is being credited for thousands of deaths that would have occurred if the virus never appeared here. (e) Number of influenza cases and deaths according to WHO every 
88 
year.i(f) Are the numbers of CV deaths accurate?89 
(g) Montana physician Dr. Annie Bukacek discusses how COVID 19 death certificates are being manipulated;90 
(h) Italy: 99i% who died from virus had other illness;91 The Key Points being thati: 

¥ The cases and deaths of this new disease COVID 19 are being described as "flu-like symptoms with pneumonia" but 
there is NO data that shows SARSCov2 is present in all of these cases/deaths. Only coronavirus of which there are many strains. 
88 
hLtp;//www.euro.who.Jnt/eo/health-topks/cornmunicable-diseases/lnlluenz./seaso…¥rnflueoza/bL1rden¥o[¥ 
influenza?lbclid=lwAROZDNTwTXKGve oJVmtZsGKFAI44JYSo6IAf4GkA47EYD8805b6FS-8Rkw 
89 h11ps://www.ctvnews.ca/health/coronavlrus/why-the-exact-death-toll-for-covid-l9… 
90 https://www.youtube.com/watch?v=Cnn.MNdlCz s 
91 h!!P.s://www,bloombern.com/news/artides/2.020-03-18/99-ofáthose¥who-died-from¥virus-had-other-illness-italy.
says?utm cam paign=pol&.utm medlum=bd &ul m source=applenews&lbclld=lwAROg N9k2 HVrnAghrK-Wrl72.J7oBoNVlvFAGY3dl.
M7GWKirK6dUeAl1Gyg 
¥ This is because the PCR test is not reliable enough to identify the new strain -laboratory testing is only identifying coronavirus. This is the flaw in the CDC/WHO theory of causality for this "new" disease "COVID 19". They haven't provided any data about the presence of this new strain (SARSCov2) in COVID 19 and it is known 
that many influenza viruses and bacteria cause "flu-like 
symptoms with pneumonia". 
¥ Until you have evidence to prove the causality of COVID19 disease as being to SARsCov2 by showing that it is present in ev ry case of the disease then there is no new disease. Koch's postulates need to be used to provide proof of causality. 
¥ Mathematical Modeling Flawed 
In March, UK epidemiologist Neil Ferguson from the Imperial College of London issued a mathematical "model" that predicted that as many as 500i,000 in the UK would die from Covid-19. On March 24ith Ferguson revised his modeling projections to read 20i,000 deaths, and "likely far fewer." On April 2nd Ferguson revised it again to read 
5,700 deaths. The problem was that many world leaders used Ferguson's original number to shut down most of the planet.i92 (i) The Canadian government implemented the lockdown on the basis of Neil 
Ferguson's Imperial College mathematical modeling that was grossly 
flawed. Ferguson has drastically backtracked on his predictions which 
begs the question why is Canada now doubling down on the lockdown that 
will not be lifted until a vaccine is ready? 
G) UK Decides CV 19 No Longer A 'High Consequence Infectious 
Disease' As of March 19, 2020, COVID-19 is no longer considered to be 
a high consequence infectious diseases (HCID) in the UK. 93 
92 
https://prepforthat.com/fear-mongerlng-covid-19áepidemiologlst-says-11e… 
93 
https://prepforthat.com/uk-officlals-covid-19-no-longer-hlgh -conseguence-lnfecllous-dlsease/ 
(k) High Consequence Infectious Disease Public Health England, have provided current information and regarding COVID-1i9 mortality rates as low. The Advisory Committee on Dangerous Pathogens (ACDP) in the UK and is also of the opinion that COVID-19 should no longer be classified as an HCID (High Consequence Infectious Disease). 94 (1) Our World in Data researchers announced this week that they had stopped relying on World Health Organization data for their models.95 (m)New Oxford study suggests millions have already built up coronavirus 
. 'ty 96 
1mmum (n) Lack of Good Data. If you are going to do something as draconian as shut down an economy, you better be right, and you better have good data. The government has neither.97 
(o) Dr Teresa Tam's incompetent virus response.98 
(p) BC health officer Dr Bonnie Henry admits They did not use science to 

. 9 
impose res t nc . t' wns. 9-
172. The measures have been also heavily criticized, on a legal basis, in Canada and abroad. Early on in the declaration, on March 26it\ 2020 the UN Commissioner 
94 
hi Lps:ljwww.goli.l.lk/topic/health-protectlon/ln fectious-d iseases 95 
hltps://fee.org/arl1cles/oxford-based-group-stops-using-who-data¥for-coronavir.1s-reporting-c1tl111!: 
errors/?fbclid=lwARlokWvqn-ge7z11bHxoUY U-4Nlqe6A8o,OVwGgw4 N3gk9TXsfs P6eEMJA 
9
6 hllps://news.yahoo.com/oxford-study-uggests-millions-people-221100162.html?soc src=hl-vlewer&soc trk:fb 
97 
https://¥vww.foxnews.Go111/opinio11/tucker-carlson-we-must-ask-the-experts-how-they-screwed-up-the-coronav1rus-models-.n.badly?fbclid=lwAROxrpFytibdvSJJLOR2fveTjvplSb23tn7Jfn2uemrXeu27GDFRpeuDLol 
98 
https://www.spencerfernando.com/2020/03/29/devastating-tlmellne-reyeals…-\fieresa-ta111s-wus¥ 
response/ 99
htrps:Uwww.youlube.com/watc:.h?v=cSV8tclCOG4c&fea1ure=youtu.be&fbtlld=lwAROBmc…! LmF¥uOKlKJbD cdKQ!ls&app=desktop 
for Human Rights, Michelle Bachelet, took an opposite view to that of Dr. 
Teresa Tam, whose view is that it is appropriate to run rough-shod over these 
rights and worry about it later, where Bachelet early declared that: 
"Lockdowns, quarantines and other such measures to contain and combat the spread of COVID-1i9 should always be carried out in strict accordance with human rights standards and in a way that is necessary and proportionate to the evaluated risk." 
173. Former UK Supreme Court Justice Lord Sumpton was an early opponent to the 
lock-down measures. In a BBC interview ofMay18th, 2020, he re-iterated and 
stated, inter alia, as follows: 
JS: because they seem to me to have no real purpose in continuing the lockdown other than to spare themselves public criticism. now one does understand why politicians don't want to be criticized but it's the mark of a statesman that you're prepared to stand up for the national interest and not simply to run away before public opinion. especially when you have in a sense created that public opinion yourself by frightening the daylights out of people over the over the last eight weeks and trying to persuade them that this is a much more virulent epidemic than it actually is. 
LS: what i'm advocating now is that the lockdown should become entirely voluntary. it is up to us, not the state, to decide what risks we are going to take with our own bodies. now, the traditional answer that people give to that is: "well, but by going out or in the streets and in shops and things you are infecting other people". but you don't have to take that risk you can voluntarily self-isolate. you don't have to go into the streets. you don't have to go to the shops. people who feel vulnerable can self-isolate, and the rest of us can then get on with our lives. 
we have never lived in a risk-free world and we're never going to live in a risk-free world. 
we are entitled to take risks with our own lives especially when basically life is only worth living if you are prepared to engage in social activities. which inevitably involve risk. that is part of life. 
174. The Plaintiffs state, and fact is, that the above-noted scientific and medical expert opinions, against and in severe criticism of the "pandemic" declaration. and its draconian and un-necessary measures, are not exhaustive, but examples. The Plaintiffs state, and fact is, that the Defendants have never acknowledged. addressed, spoken to, nor responded to these contrary expe11 views, and further state that the Defendants, including the mega-social media, such as YouTu be. Facebook, Amazon, Google, Yahoo and like, as well as CBC, have intentionally suppressed, censored, belittled and removed the publication of any such contrary views, contrary to the principles and methodology of science and medicine. with the acquiescence and actual support of the Canadian Federal government, which government threatens to add criminal sanctions to assist these media for what they irrationally, arbitrarily and unscientifically deem "misinformation"i, and further violate the Plaintiffs' rights to freedom of speech, expression, and the media, contrary to s.2 of the Charter, by the government's acts and omissions in making threats of criminalizing speech, and doing absolutely nothing, by omission, to regulate this type of "Stalinist censorship". 

DI THE SCIENCE & MEDICINE OF COVID-19 

¥ Summary (Overview) 175. The Plaintiffs state, and the fact 1s, that the World Health Organization,("WI-IO"), our federal, provincial and municipal governments, and the mainstream media, propagate that we are facing the biggest threat to humanity in our lifetime. This is false. 
176i. The fact is that, false and baseless predictions of wide-spread infection with high rates of mortality persuaded governments that unprecedented containment measures were necessary to save us from certain peril. 
177. 
The fact is that, while there is more about the SARS-CoV-2("COVID-19") coronavirus that needs to be understood, the scientific and medical evidence clearly demonstrates that the mathematical modeling used to justify extreme containment measures were invalid. Further, that the vast majority of the population is not at serious risk of complications or mortality as a result of exposure to COVID-19. 

178. The fact is that, the mass and indiscriminate containment of citizens, the restriction of access to our economy, courts, parliament and livelihoods, medical and therapeutic care, and the imposition of physical distancing and other restrictions are measures that have never before been implemented nor tested, nor have a scientific or medical basis. 

179. The fact is that, the impact of these measures on physical, emotional, psychological, and economic well-being is profoundly destructive, unwarranted, and clearly not sustainable. 

180i. The fact is that, these drastic isolation measures are not supported by scientific or medical evidence. There is considerable agreement in the scientific community that such drastic measures are not sustainable nor warranted or justified, and while these measures may delay viral spread, they are unlikely to impact overall morbidity. 
181i.  The fact is that, this over-hyped COVID-1i9 pandemic narrative 1s creating  
unnecessary panic and being used to justify systemic governmental violations of  
the rights and freedoms that form the basis of our society, including our  
constitutional rights, sovereignty, privacy, rule of law, financial security, and  
even our very democracy.  
182i.  The fact is that, it is clear that significant violations of the Plaintiffs' rights and  
freedoms are being perpetrated by the federal, provincial and municipal  
governments and health authorities.  
183i.  The fact is that, as a result of all of the above, the Plaintiffs have suffered and  
continue to suffer, severe violations of their constitutional rights which are  
justified on any measurement, including s. 1 of the Charter.  
¥ The Covid -Measures Unscientific, Non-Medical, Ineffective,  
and Extreme  
184i.  The Plaintiffs state and the fact is, that the Measures implemented lack scientific  
and medical evidence to support containment measures in that:  (a) Mass and indiscriminate lockdown of the general population has not been  
previously attempted in modern history, and has no scientific nor medical  
basis. In fact, Dr. Bonnie Hemy, BC Chief Medical Officer, has flatly  
stated that the measures are not based on science or medicine.  (b) A 201i1 review of the literature 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 economically feasible  

and are predicted to delay viral spread but not impact overall morbidity. 
JOO (c) There are no realistic and contextual studies of the negative social, family, psychological, and individual health consequences of extended general population lockdowns, nor the impact on the national economy. 
(d) The long-term impact of the broadly applied infringements of civil rights and freedoms is not known, including any permanent structural erosion of democracy itself due to increased authoritarianism and heightened regulatory or penal consequences for violating government directives. 

( e) The measures enacted by the federal, provincial and municipal governments are unprecedented. (t) The government has acted in diametrical opposition to the precautionary principle: "Government shall not act with insufficient scientific knowledge, if the action has any likelihood of causing more harm than good". (g) Justification for the early panic response has not been corroborated. 101 
(h) Faith in epidemic-modeling and the resulting mitigation strategies are not justified. 
(i) Physicians globally are expressing alarm over the exponentially growing negative health consequences of the national shutdown. 102 103 

100 Social Distancing as a Pandemic Influenza Prevention Measure 
blw.s:ljnccid.ca/wp-content/uploads/sites/2/2015/04/H1Nl 3 f1nal.pdf 
1 01 http://ocla.ca/wp-contenVuploads/201410110CLA-Report-2020-1-Criticisrn-… D1 9. pdf 
1
02 https://'Nww .scribd.com/ document/ 462319362/ A-Doctor-a-Day-Letter-Signed#from _embed 103 htt ps ://www. fo rbes. com/sites/grace ma rietu rn er /2020/05 /2 2/ 600-p hysic i an s-sa y-1 ockd owns-are-a-mass-casualty.i n ci dent/#20248e5250fa 
conta111menl. 
G) Despite the importance given to physical distancing as a containment 
measure, there is a lack of scientific evidence on the effectiveness of such . . . . I 04 105 
mtervention on t h e 1 ong-term h eait 1 h o f citizens. (k) There is no scientific evidence to substantiate the effectiveness of two meter 'physical distancing' as an intervention to reduce SARS-Co V-2 transmission and infection and to improve overall health. 106 (1) Dr. Martin Dubravec, MD, a Clinical Immunologist states: "The hot/om line is that herd immun;ty is what v,1ill stop the virus fiáom spreading. Not containment. Not a vaccine. Not staying locked in our homes. It's lime 1ve 
á 
. 
h a d an h onest conversat10n on h b d . 
ow to move 
eyon (m) A review of the scientific literature with regards to the use of masking concluded there is no scientific evidence to substantiate the effectiveness of masking of the general public to prevent viral infection and transmission. 108 
(n) Denis Rancourt, Ph.D. has identified the many unknowns regarding the potential harm from a broad public policy of masking. Rancourt concludes: "In an absence of knowledge, governments should not make policies that have a hypothetical potential to cause harm. The government 

104 Benjamin E Berkman. Mitigating pandemic influenza: the ethics of implementing a school closure policy. Journal of Public Health Management and Practice: JPHMP, 14(4):372-378, August 2008. PMID: 18552649. 
105 htlps://nccid.ca/wp-content/uploads/sites/2/2015/04/HlNl 3 Hn;il.pdf 
106 hllps://www.zuercher-presse.com/vlrologe-hendrick-slreeck-qibl-keine-qefahr-bei….
i nfiziere n/?cn-reloaded= 1 
107 htIps://aapsonline.orn/coro11avirus-covid-19-public-healIh-apocalypse-or-antl-amerlcaol 
108 hnps://www.researchgate.net/publication/340570735 Masks Don't Work A review of science relevant to COVID.
19 soclal policy 
has an onus barrier before it instigates a broad social-engineering 
. . . . . " I 09 
mtervent1on or a 11 ows corporat10ns to exp mt 1ear-1 -C b ase d sentiments. ( o) A study of cloth masks cautions against the use of cloth masks. The study concludes: "As a precautionary measure, cloth masks should not be recommended." 110 (p) According to Dr. Richard Schabas, former Chief Medical Officer for Ontario -"Quarantine belongs back in the Middle Ages. Save your masks for robbing banks. Stay calm and carry on. Leti's not make our a/tempted cures worse than the disease. " 111 (q) On May 20i, 2020i, Dr. Teresa Tam, Canada's Chief Medical Officer, publicly advised the use of non-medical masks for the general public to provide an "added layer of protectioni" that could help prevent asymptomatic or pre-symptomatic Covid-1i9 patients from unknowingly infecting others. Dr. Tam's advice is not supported by scientific evidence. 
112 (r) It would appear that any advice/requirement to use masks is for a purpose/agenda other than the prevention of viral infection and transmission. 
(s) A paper published on January 30, 2020 in The New England Journal of Medicine (NEJM) which appeared to confirm that individuals who are 

109 ht1ps://www.researc:hgate.net/publlcalio11/340570735 Mmks Don't Work A review of science relevant to COVID.
19 social policy 
110 https://www.ncbl.nlm.nih.gov/pmc/arlic:les/PMC4420971/ 
111 
h tlps:/lwww. lheqlobea ndma rl.comlop,n ,on/art icle-strlclly-by-the-numbers-the-coranavirjJ"' <lcw . :n.01-1 f.!fl!';; '.L "-..:_,. 
112 https://www.politico.com/news/2020/05/20/canada-non-medical-masks-provi… 
asymptomatic can transmit SARS-Co V-2 to others has subsequently . . 
proven to contam maJor fl aws an d errors. 113 (t) The imposition of mass and indiscriminate self-isolation measures 
prevents the development of natural immunity necessary to secure herd . . . 114 
1mmumty an d en d t h e ep1 "d em1c. (u) On April 6, 2020, German epidemiologist, Knut Wittkowski, released a statement warning that artificially suppressing the virus among low risk people like school children may "increase the number of new infectionsi" as it keeps the virus circulating much longer than it normally would. 115 
(v) On March 24i, 2020 global medical experts declared that efforts to contain the virus through self-isolation measures would negatively impact population immunity, maintain a high proportion of susceptible individuals in the population, prolong the outbreak putting more lives at risk, damage our economy and the mental stability and health of the more vulnerable. (w) A review of recent literature pertaining to social distancing measures conducted by David Roth and Dr. Bonnie Henry of the BC Centre for Disease Control concluded the following: a) widespread proactive school closures are likely not an effective prevention measure during an influenza 
113 https://www.sciencemag.org/news/2020/02/paper-non-symptomatic-patient-t… 
114 https:/lwww.aier.org/article/herd-immunlly-is-misleadinq/ 
115 Stand TJp for Your Rights, says Bio-Statistician Knut M. Wiltkowski. American Institute for Economic Research. April 6, 2020 
ht1ps://www.aler.org/article/st.and-up-for-your-rlghts-says-professor-knut-m-wi… 
116 https://off-guardian.org/2020/03/24/12-experts-questioning-the-coronavi… 
117 ht1ps://www.europereloaded.com/1wenty-wo-experts-guestioning-1he-coronavirus-pa…[ 
pandemic; b) stringent travel restrictions and border control may briefiy delay imminent pandemics, these approaches are neither economically nor socially feasible; and c) there is no recent evidence outlining the effectiveness of the prohibition of mass gatherings. 118 (x) According to a public statement issued by the BC Ministry of Health: a) COVID-19 virus has a very low infection rate in children and youth; b) In 
BC, less than 1 % of children and youth tested have been COVID-19 positive; c) There is no conclusive evidence that children who are asymptomatic pose a risk to other children or to adults, and d) Schools and childcare facility closures have significant negative mental health and socioeconomic impacts on vulnerable children and youth. 1 19 (y) According to a May 21, 2020 letter from Dr. Mark Lysyshyn, MD, Deputy Chief Medical Health Officer with Vancouver Coastal Health: "Although children are often at increased risk for viral respiratory illnesses, that is not the case with COVID-19. Compared to adults, children are less likely to become infected with COVID-19, less likely to develop severe illness as a result of infection and less likely to transmit the infection to others. " Dr. Lysyshyn further states: "Non-medical masks are not needed or recommended. Personal protective equipment such as medical masks and 
. ,, 120 
l d d zn t . h e sc h oo l environment. 
g aves are not recommen e (z) On May 21, 2020, British Columbia's Chief Health Officer, Dr. Bonnie Henry stated: "We 're encouraging people [to wear masks] as a mark of 
116 11ltps://nccid.ca/wp-contenUuploads/sites/2/2015104/H1 Nj 3 final.pelf 
119 https://www2.gov. be.ca/assets/ gov /hea Ith/a bout-bc-s-hea Ith-care-system/ office-of-the-provi ncia 1-hea Ith-officer/ covid-19/ covid.
19-pho-gu ida nce-k-12-schools. pdf 
120 http://www. vch .ca/Docu ments/COVI D-VCH-Schools-May-21-2020. pdf 
respect, as a mark of politeness, and paying attention to the welfare al others.i" The recommendation to mask no longer is on the basis of . . d. . . 121 
e f1ectlveness :c b ut mstea 1s b emg promote d as a socia I grace. (aa) British Columbia's Chief Health Officer, Dr. Bonnie Henry, when addressing a question regarding the inconsistency among the provinces of Canada on COVID-1i9 restrictions placed on Canadians stated: "None of this is based on science. " 122 (bb) The reported number of deaths attributed to SARS-CoV-2 1s demonstrably unreliable given the inclusion of "presumptive" deaths, and the failure of the medical establishment to differentiate between individuals dying from COVID 19 and those with co.
123 124 
morbidities dying with COVID 19i. (cc) The failure to differentiate between individuals dying.from COVID 
19 and those with co-morbidities dying with COVID 19 inflates the risk of mortality from SARS-Co V-2 and undermines confidence in any response strategy based on mortality statistics. 125 ( dd) Doctors globally are being pressured to issue death certificates that identify COVID 19 as the cause of death even when other co.morbidity issues are the more likely cause of death. 
121 https:/fwww .stralg hi .comlcovtd -1c9-pa ndem iclmay-21c-coronavirus-update-bc-resistance-heallh-measu res-remonal.rest ricl ions-qe nde r-d iffere nces-second-wave 
'122 
111tps:l/www.youtube.comlwatch?v=SY8fclCOG4c&feature=youtu.be&fbclid=lwAROBmcUm4… vHJVM6HLmF-uOKiKJbD cdKQlls&app=desktop 
12 Why the exact death toll for COVID-19 may never be known. CTV News, April 3, 2020 htlps://www.c1vnews.ca/hP.allh/coronavlrusMY.-rhe-exac1-deaLh-toll-for-covld-l9… 124 https:1/www.cpsbc.ca/for-physicians1c0Jlege-connector/2020-V08-02/04 
125 https://www.bloomberg.com/news/articles/2020-03-18/99-of-those-who-died… ( ee) The presentation of mortality data, expressed as a percentage of' deaths of tested and confirmed cases, is distorting the risk and creating undue panic. This data fails to include a significant percentage of the population who contracted the virus but were not tested nor confirmed and who recovered without medical intervention. (ff) To date, the number of reported deaths attributed to SARS-Co V-2 is not out of "normal" range when compared to the annual mortality from influenza and pneumonia (seasonal viral respiratory illness) recorded through the last decade. 126 127 128 (gg) According to Dr. Richard Schabas, former Chief Medical Officer of Ontario, strictly by the numbers, the coronavirus does not register as a dire global crisis. (hh) No data has been provided by the Government of Canada nor Ontario to indicate that the total mortality in Canada has increased substantially from previous years. (ii) Mortality modeling by the World Health Organization, Imperial College of London, and the US Institute for Health Metrics and 
126 Strictly by the numbers, the coronavirus does not register as a dire global crisis. Richard. Schabas. The Globe and Mail. March 9, 2020 
tiµps:f/www.the.gtobeandmail.com/op1nionlarl1cle-slr1ctly-by lhe-1tumbers-1he-corq_n.fil!!1JLS-ilom: not I r:,,1i ,t ,, _ils 12 New Data Suggest !he Coronavlrus Isn't as Deadly as We Thought. WDJ/Opinion. April 17, 2020 
l1t1ps:ljwww.gree11111edinfo.com/blog/stantord-team¥ á,nds-evidence-covid-19-mortality-rate-low¥2¥17¥t1mes¥lower-whos-est. https://www.medrxlv.org/content/10.1101/2020.Q4.l4.20062463v2 128 https://www.ncbLnlm.nih.gov/pmclarticles/PMC71c02597J?.fbclid=lwAR29vpT…á 
xoVzVRbuAgVhil1 k0DcZkGgyYsak6IC-OByjZcBRP6cyjc 
Evaluation have all been drastically "downgraded". Strategies and . . . . 1 29 1 30 
measures b ase d on t h ese ongma l pre d" 1ctlons are mva 1 1.d . 
Gj) As of March 19i, 2020i, the status of COVII?.19 in the United Kingdom was downgraded. COVID-1i9 is no longer considered a high consequence infectious disease (HCID). The Advisory Committee on Dangerous Pathogens (ACDP) in the UK is also of the opinion that COVID-1i9 should no longer be classified as an 
1 31 1 32 
HCID (High Consequence Infectious Disease). (kk) On March 26, 2020, Dr. Anthony Fauci published an editorial in the New England Journal of Medicine stating that "the overall clinical consequences of Covid-19 may ultimately be more akin to those of a severe seasonal influenza with a case fatality rate of' 
1 33 
perhaps 0.i1%.i" (11) On April 9, 2020i, Canadian public health officials stated: "In a best-case scenario, Canada's total COVID-1i9 deaths can range from 11i,000 to 22i,000i." And "In the bad scenarios, deaths go well over 300i,000i." As of May 21i, 2020i, the total reported deaths from COVID 19 in Canada was 6,145i. As of July 2, 2020i, the total deaths attributed to COVID 19 in Canada was 8,642i. In 2018, the mortality rate of the 2018 influenza/pneumonia in Canada which 
129 How One Model Simulated 2.2 Million U.S. Deaths from COVID-19. Cato Institute. April 21, 2020 
https;//www.cato.org/bloti/how-one-model-simulated-22-mlllion-us-deaths-covid¥ 9 
130 
hllps:/lprep'forthal.comtfear-monqering-covid-19-epidemiologist-says-he-was-wrong/ 
131 
htlps:J/www.qov.uk/topic/heallh-proteclion/infectious-diseases 
132 
hltps://prepforthat.com/uk-officlals-covid-1e9-no-Ionger-high-consequence-infectious-disease/ 
133 https://www. ncbi.n Im. nih .gov /pmc/a rticles/PMC7121221/ 
was 23 per 100,000. 1e34 In a population of 3 7. 7 M, this equates to approximately 8,671 deaths. This is the mortality even though a vaccine exists for both influenza and pneumonia and there is a high uptake rate in the senior population. (mm) The World Health Organization knew as early as February 28, 2020 that most people will have mild illness from SARS-Co V-2 infection and get better without needing any special care. 135 (nn) The Canadian government has implemented a re-start strategy that continues to maintain the unsubstantiated narrative that the SARS-Co V-2 virus is extra-ordinarily dangerous and requires extra.ordinary social distancing measures never before implemented. ( oo) The re-start strategy recommended by the federal and various provincial governments is based on 'sector' rather than 'risk'. There is no evidence that a re-start based on sector has scientific merit. (pp) According to a number of infectious disease experts, hospital capacity, rather than the number of infections should be the metric . . . . 136 
o f c h mce .c 1or re 1 axmg restnct10ns. ( qq) There is no evidence that harms caused by the mass and indiscriminate containment of citizens was calculated and 
134 
https ://www.statista.com/ statistics/ 434445/ d eath-rate-for-i nfl u enza-a nd-pn eu m on ia-i n-ca n ad a/ 
135 WHO Director-General's opening remarks at the media briefing on COVID-19 -28 February 2020 
https://wv,w.who.lnt/dg/speeches/det-ail/wtá10-director-general-s¥opening-remarks-at-the-n1edla-brieflng-on-covic,l-l9---28 
february-2'J20 
136 https://nationalpost.com/opinion/opinion-we-are-infectious-disease-expe… 
considered in the modeling and strategic planning response to 
137 
SARS-CoV-2i. (rr) SARS (2003), Swine Flu/HlNl (2009), and MERS (2012) were all considered pandemics by the World Health Organization. Each of these pandemics were effectively contained without lockdowns, economic ruin, violations of privacy, and the indefinite loss of the right to work and personal freedoms. SARS and MEiRS dissipated on their own naturally without any vaccine intervention. 138 (ss) Academic studies of media coverage during the 2003 Canadian SARS outbreak concluded that the media coverage was excessive, sensationalist, and sometimes inaccurate. Government health agencies were criticized for lacking a unified message and communications strategy, resulting in confusion and panic about 
139 
the disease. These same criticisms hold even more true for media and government response to SARS-Co V-2i. (tt) The suspension of our civil liberties is not justified by the known risk posed by SARS-Co V-2i. (uu) In a statement released on March 24i, 2020i, professor Peter Gotzche states: "The coronavirus mass panic is notjust(fied. " The suspension of our right to liberty, to work, to travel, and to conduct 
137 
Rethinking the Coronavirus Shutdown. WSJ/Opinion. March 19, 2020 
https://www.wsj.com/artlcles/rethinklng.the-coronavirus-shutdown-115846… 
138 https://www. ncbi.nlm. nih .gov /pmc/articles/P MC209497 4/ 
139 https://www.thecanadianencyclopedia.ca/en/article/sars-severe-acute-res… 
commerce is not justified by the known risk posed by SARS-Co V.2_ 140 (vv) There is no independent human rights oversight committee to track human rights violations associated with SARS-Co V-2 response measures in Canada. 
(ww) Communications about SARS-Co V-2 by the Government of Canada and mainstream media have been exaggerated, distorted, irresponsible, and appear to have been purposely designed to evoke fear and panic. The fear is out of proportion to the actual risk of mortality. 
(xx) Governments and media have repeatedly failed to properly distinguish between the 'risk of infection' and 'the risk of mortality'. For the vast majority of the population the risk of mortality is extremely low. 

(yy) Prevalence of SARS-CoV-2 in the entire Canadian population is very low. Extreme social controls should never be used in low prevalence epidemics. (zz) As presented by PHAC, the modelling techniques used to establish probabilities of the epidemic trends and thus "inform" policy decisions have no basis in evidence, are completely inflated, and essentially amount to statistical chicanery. 
140 The Coronavirus mass panic is not justified. Professor Peter C. G0tzsche24 March 2020 
ht tps://www.deadlymedici1,es.dk/wp-con tent/uploads/G.G%B8tzsche-The-Coronavirus-1na,s-p;ipic-1 -no\-justffied,pdl (aaa) Using total case numbers as though they represent the risk of being infected with SARS-Co V-2 is perception management. While these numbers may be of interest for epidemiological study, they have little bearing on the true risk facing citizens. (bbb) Severity of SARS-Co V-2 is estimated by infection fatality rates. Infection fatality rates cannot be established until the total number of cases, both symptomatic and asymptomatic, in the entire population can be estimated. ( ccc) The Canadian government failed to perform a national random sample test to establish a SARS-Co V-2 baseline across the entire population to justify the restrictions and violations of rights and freedoms. (ddd) Exaggerated claims and distorted messages have contributed to an atmosphere of fear and uncertainty that is destructive to the well.being of Canadians. It would appear that the real epidemic is an epidemic of fear. ( eee) The evoked fear and pamc 1s so entrenched amongst a large proportion of Canadians that it is extremely difficult to reverse that message even when the scientific data does not support such panic. (fff) As recent as May 22, 2020 Prime Minister Justin Trudeau told reporters that contact tracing needs to be ramped up across the county. Trudeau stated that he "strongly recommends" provinces use cell phone apps when they become available, and that this use 
would likely be mandated. Use of surveillance technologies to monitor citizens constitutes a clear violation of our right to pnvacy. (ggg) As of May 24i, 2020i, the Prime Minister of Canada has not invoked the Emergencies Act. Therefore, emergency measures announced by the Prime Minister and his public statements to Canadians to "just stay home" have no legal basis or authority, are an abuse of power, and is resulting in confusing, dangerous and unlawful messagmg. (hhh) The Prime Minister of Canada and Ontario Premier Doug ford have repeatedly stated that "life will not return to normal until a vaccine is found". It is irresponsible to base a return to normal upon a vaccine when there is no guarantee that an effective and safe vaccine can be developed. (iii) There are significant risks to both individuals and to confidence in the health care system by accelerating the development of a SARS.Co V-2 vaccine by relaxing normal and prudent safety testing measures. (jjj) Health Canada has approved human trials of a SARS-Co V-2 vaccine (May 19, 2020) without clear evidence that prior animal testing to identify the potential risk of pathogenic priming (immune enhancement) has been conducted. Pathogenic priming has prevented the development of an effective and safe coronavirus vaccine to date. (kkk) Dr. Peter Hotez of Baylor College (who has previously tried to develop a SARS vaccine) told a US Congressional Committee on March 5, 2020 that coronavirus vaccines have always had a "unique potential safety problem" -a "kind of paradoxical immune enhancement phenomenon." 141 (lll) To impose through influence, mandate, or coerc10n an inadequately tested SARS-Co V-2 vaccme product upon all Canadians when 99% of the population 1s not at risk of mortality is reckless, irresponsible and immoral. (mmm) A SARS-Co V-2 vaccine ought to be targeted at the less than 1 % of the population that is at risk of mortality, rather than the more than 99% that is not at risk. (nnn) There is no moral, medical or ethical justification to ignore prudent safety protocols and to suggest that the use of this yet to be developed medical product is necessary for life to return to normal. (ooo) Dr. Allan S. Cunningham, a retired pediatrician, has raised the possibility that a potential contributor to the current coronavirus outbreak is the seasonal influenza vaccine. A randomized placebo.controlled trial in children showed that the influenza vaccine 
14 1 https://www.c-span.org/video/?470035-1/house-science-space-technology-c… 
increased fivefold the risk of acute respiratory infections caused by . . . . 142 143 
a group o f non m fl uenza viruses, me l u d' mg coronav1ruses. (ppp) A study of US military personnel confirms that those who received an influenza vaccine had an increased susceptibility to coronavirus infection. 144 (qqq) EU numbers show correlation between influenza vaccme and coronav1rus deaths. The countries with highest death rates (Belgium, Spain, Italy, UK, France, Netherlands, Sweden, Ireland and USA) had all vaccinated at least half of their elderly 
1 á á á fl 145 
popu at10n agamst m uenza. (rrr) Canada continues to be one of only two 020 Nations which fails to compensate citizens who are injured and killed by government approved and recommended vaccine products. The other is Russia. (sss) The unwillingness of the Government of Canada to provide compensation for vaccine injury, while at the same time imposing vaccine products upon its citizens, is unconscionable. (ttt) To rely on a vaccine as the required strategy to returning life to normal is reckless, irresponsible and unwarranted. (uuu) Jonathan Kimmelman, director of McGill University's biomedical ethics unit stated: "Outbreaks and national emergencies often 
142 https://www.bm[.com/contenU368/bmj.m81 O/rr-O 
14 3 https://www.ncbi.nlm.nih.gov/pmc/articles/PMC3404712/ 
144 https://www.sciencedlrect.cem/sclence/artlcle/pil/S0264410X19313647 
145 hllps:/lwww,theqatewaypundlt.com/2O2O/05/njall-mccrae-david-kurten-eu-numbers-show-correlation-flu-vaccine.
coronavirus-deaths/ 
create pressure to suspend rights, standards and/or normal rules of ethical conduct. Often our decision to do so seems unwise in 
retrospect." (vvv) On June 8ith , 2020 the WHO publicly announced that the risk of symptomatic spreading of the virus was "very rare". This statement removed by Facebook as "fake News", given its very early, prior contrary assessment, the WHO, the next day partially retroacted this this June gt\ 2020 statement by qualifying without details or explanation that modeling suggested Asymptomatic transmission is possibly as high as 40%: NO evidence or study was provided, nor the basis of the previous day's release. On July 4it\ 2020 the WHO re-re paddled back to its original June gt\ 2020 position. 
185i. The Plaintiff, VCC, had posted on its website, a CNBC report announcing the June gt\ 2020 WHO release, on Facebook, with respect that Asymptomatic transmission was very rare, which was immediately removed by Facebook as "Fake News" for, contradicting earlier WHO releases. 
El HYPER -INFLATED, DISTORDETED TOTAL NUMBER OF CV-1i9 "CASES" & "DEATHS" 
186i
. The Plaintiffs state that the total number of Covid-19 cases rs the basis for almost all of the Covid-19 data including deaths in those cases, recovery from those cases, hospitalizations and ICU admissions of those cases and total active cases.i146 Total case numbers are also used for other epidemiological metrics 
( e.g.i, virulence and transmission rates of Covid-19i). 

18i
7. Yet the total case numbers are inflated by both RT-PRC testing and WHO coding definitions. 

188. 
The Plaintiffs state that the WHO coding of cases allows 'virus not identified', i.e., probable cases to be counted as Covid-19 cases.i147 WHO coding also inflates death data numbers by requiring all cases where Covid-19 is "probable or confirmed" to be certified as a death due to Covid-19 regardless of comorbidities. Admonishing physicians to "always apply these instructions, whether they can be considered medically correct or not."148 

189. 
RT-PCR was never intended as a diagnostic tool149 and is not an antigen test 150. 

190i. The Plaintiffs state that the PCR tests are based on an arbitrary cycling number (Ct) that is not consistent among testing laboratories.i151 "Cycling too much 
146 
Public Health Agency of Canada, https://www.canada.ca/en/public-health/services/diseases/2019-novel-cor…"Confirmed:A person with laboratory confirmation of infection with the virus that causes COVID-19 performed at a community, hospital or reference laboratory (NML or a provincial public health 
laboratory) running a validated assay. This consists of detection of at least one specific gene target by a NAAT assay (e.g. real-time PCR or nucleic acid sequencing). 147 
WHO ICD-10 Coding https://www.who.int/classifications/icd/COVID-19-coding-icd10.pdf?ua=1a] 148 
WHO Cause of Death Guidelines https://www.who.int/classifications/icd/Guidelines_Cause_of_Death_COVID….
EN.pdf?ua=l 149 
Dr. Judy Mi kowitz https:// articles. me rcola. com/ sites/a rt ides/ arch ive/2020/05/03/is-th e-new-co ron aviru s-created-i n-il-la b.aspx "Epidemiology is not done with PCR. In fact, Kary Mullis who invented PCR, Nobel Laureate, and others, said PCR was never intended for diagnostic testing." 
150 
Not an Antigen Test: Prof Eleanor Riley, Professor of Immunology and Infectious Disease, University of Edinburgh and Dr Colin Butter, Associate Professor and Programme Leader in Bioveterinary Science, University of Lincoln https://www .sciencem edia centre .o rg/ expert-com ment-on-d ifferent-types-of-testing-fo r-covid-19/ 
could result in false positives as background fluorescence builds up in the PCR  
reaction."  Tests can show positive for minute amounts of RNA that are not  
causing illness and for non-infectious fragments of RNA. 152 RT-PCR tests  
cannot prove the pathogenic nature of the RNA.  
191.  RT-PCR tests have a specificity of 80i-85i%. 153 This means 15i-20i% of the time a  
positive test does not indicate the presence of RNA of SARS-Co V-2, but of  
some other RNA  source.  RT-PCR testing is  not reliable for SARS-CoV-2  
testing. 154  
192.  RT-PCR tests are more likely to be false positive than false negative.i155  In low  
prevalence countries like Canada: "Such [false positive] rates would have large  
impacts on test data when prevalence is low. Inclusion of such rates significantly  
alters four published analyses of population prevalence and asymptomatic ratio.  
The high false discovery rate that results, when prevalence is low, from false  
positive rates typical of RT-PCR assays of RNA viruses raises questions about  
the usefulness of mass testing ... " 10  
193.  The Plaintiffs state that the implications of false positive tests include the  
following:  "There  are  myriad clinical and  case  management implications.  
Failure  to  appreciate  the  potential frequency  of  false  positives  and  the  

151 
Issues with the RT-PCR Coronavirus Test, David Crowe and Dr. Stephen Bustin, April 23, 2020 https ://thEmfectiousmyth .com/ coronavirus/RT-PCR _ Test_lssues. ph p ] 
152 https://www.independent.co.uk/news/wor1d/asia/coronavirus-south-korea-p… 
153 RT-PCR Test 80-85% specificity per Dr. James Gill, Warwick Medical School, England https://www.sciencemediacentre.org/expert-comment-on-different-types-of…] 
154 
Stability Issues of RT-PCR Testing of SARS-CoV-2, March 10, 2020 Abstract: https://pubmed.ncbi.nlm.nih.gov/32219885/ 
Full text: https://onlinelibrary.wiley.com/doi/full/10.1002/jmv.25786 "In our study, we found a potentially high false negative rate of RT-PCR testing for SARS-CoV-2 in hospitalized patients in Wuhan clinically diagnosed with COVID-19. Furthermore, the RT-PCR results showed a fluctuating trend. These may be caused by insufficient viral material in the specimen, laboratory error during sampling, or restrictions on sample transportation."a] 
155 
. 10 False positives in reverse transcription PCR testing for SARS-CoV-2 https://www.medrxiv.org/content/10.ll01/2020.04.26.20080911vl.full.pdfa] 
consequent unreliability of positive test results across a range of scenarios could unnecessarily remove critical workers from service, expose uninfected individuals to greater risk of infection, delay or impede appropriate medical treatment, lead to inappropriate treatment, degrade patient care, waste personal protective equipment, waste human resources in unnecessary contact tracing, hinder the development of clinical improvements, and weaken clinical trials."1a56 
194. 
A Chinese study157 found, "In the close contacts of COVID-1i9 patients, nearly half or even more of the 'asymptomatic infected individuals' reported in the active nucleic acid test screening might be false positives." 1a58 

195. 
The Public Health Agency of Canada reports more than 1.4 million people have had PCR tests.159 Considering the false positive rate, especially for contact tracing, this is not a good use of our resources (both dollars and testing staff). 

196. 
As of June 15it\ 2020 the COVID "statistics" are as follows: 
(a) Population of Canada 2020i---37,742,154i; 
(b) Total number of confirmed or probable cases as of June 15ith --99,14i7; 

( c ) Therefore, 0.0026i% of Canadians are testing positive; 
156 
https://www.medrxiv.org/content/10.1101/2020.04. 26.20080911 v2 
<https://www. medrxiv.orq/content/10.1101/2020.04.26.20080911 v2> ____ _ 
157 
Potential false-positive rate among the 'asymptomatic infected individuals' in close contacts of COVID-19 patients, March 23, 
2020 
http://html.rhhz.net/zhlxbx/017 .htm Full translation: https://theinfectiousmyth.com/articles/ZhuangFalsePositives.pdf 
158 
https://www.reddit.com/r/COVID19/comments/fik54b/false positives among asymQ 
tomatlc/ < https ://www. reddlt.corn/r/COVIDl 9/comments/fik54b/false positives among a._y 
mptomatic/> 
159 PHAC Da'ily Update, May 25: 1,454,966 total people tested 
https :/ /www. can ad a. ca/ content/dam/ p ha c-a s pc/documents/ services/ d isea ses/2019-n ove I-corona vi ru s-i nfect ion/ s u rv-cov id 19-e pi.
u pd ate-en g. p df (d) 0.00021% of Canadians are dying "with" or "ofCOVID" (there is no current differentiation between death " with" or "from" COVID statistically speaking). As of June 15i,2020 the national death count from covid stands at 8,175, a completely inflated and distorted number, due to levels of gross mismanagement of patient care in institutions where outbreaks are reported, and death certificate mislabelling of dying ''with'i' covid, as opposed to dying "from" covid. Meanwhile, the statistics (2018) for other causes of death, according to statistics Canada, in Canada were as follows: (i) Suicides---3,811i; (ii) influenza and pneumonia (seasonal viral respiratory illness) --.8,511 *; (iii) accidents (unintentional injuries) ---13i,2i90i; (iv) medical error (including medications)---28,000; (v) heart disease---53i,134i; (vi) cancer---79,536i. 
197. The Plaintiffs state, and fact is that the US, UK, and Italy, through their public health officials have publicly admitted that a COVID death is tallied as such, simply where the COVID virus is found, albeit inactive, and regardless of whether the patient died from another primary cause of death, such as from cancer in palliative care. Thus a senior US Health official, on April 19i!11,20i20i, Dr. Ezike, Director of Public Health, put it this way: 
That means, that if you were in hospice and had already be given a few weeks to live, and then you also were found to have COVID, that would be counted as a COVID death. 
''Iet means technically if you died of a clear alternate cause but you had COVID at the same time, its still listed as a COVID death. 
Everyone who is listed as a COVID death doesn't mean that was the cause of the death, but they had COVID at the time of death. The Plaintiffs state, and the fact is, that Canada uses the same system, mandated by the WHO, because the WHO collapsed three different ways of certifying and dassifying death into one, in order to grossly inflate the number of deaths "attributable" to covid-19. 
198. This includes someone like George Floyd who was killed (murdered) by four (4) Minneapolis police officers, who have been charged with murder, in that the official autopsy report stipulated that he had tested positive for COVID months earlier. (Why George would be tested for COVID, in the circumstances, is beyond baffling). 

199. The Plaintiffs state, and the fact is, that in many jurisdictions, such as New York City, a hospital is paid much more to deal with a "COVID-death", than a non-COVID death. 

200e. The Plaintiff states, and the facts is, that the false and faulty manner and method of determining a ''COVID-death' ', is wholly and exclusively dictated by WHO guidelines and parroted by Chief Medical Officers in Canada, in furtherance of the WHO's false "pandemic", to instill baseless fears, in the WHO's non.medical agenda, at the control and instigation of Billionaire, Corporate, and Organizational Oligarchs, who actually control the agenda of the WHO, to effect their plan to install a New World (Economic) Order by means of 
economic shut-down and mandatory vaccinations and surveillance of the planet's population. 
F/ GLOBAL POLITICAL, ECONOMIC AGENDA BEHIND UNWARRANTED MEASURES 
¥ The Non-Medical measures and Aims of The Declared Pandemic-The Global Agenda 
201i. The Plaintiffs state, and the fact is that the WHO is not, nor ever has been, an objective, independent medical body, but is riddled with over-reaching socio.economic and political dictates of its funders who, inexplicably over and above the nation-states who fund-it, is heavily funded, and directed, through its "WHO Foundation", and GAVI, by international Billionaire Oligarchs, and Oligarch organizations such as Bill Gates, GAVI, the World Economic Forum ("WEF"). The Plaintiff states, and the fact is, that WHO vaccination programs, funded by the Bill Gates and Melinda Foundation, have been accused, by the governments of various sub-Saharan African countries, as well as Nicaragua, India, Mexico and Pakistan, the Philippines, of conducting unsafe, damaging vaccine experiments on their children. In India, the Courts are investigating these vaccination experiments on children. The WHO has recently, in the context of the COVID-1i9, been expelled from various countries for lack of confidence, corruption, and attempted bribery of their officials, up to, and including, head(s) of state. The Plaintiffs further state, and fact is: (a) There is a declared agenda to impose global mandatory vaccination, ID chipping, testing and immunity certification on all citizens. This global agenda has been in the works for decades. 160 
(b) Bill Gates, through his Foundation and Organization(s), 1s the largest private funder to the World Health Organization, is a leading proponent of keeping the economy locked down until a vaccine is developed. Gates is also a major advocate behind the contact tracing initiative. 161 Gates is a major investor in developing a SARS-Co V-2(COVID-19) vaccine and in tracking technology. Gates has a clear financial conflict of interest in advocating for a vaccine and contact tracing. 

( c) Bill Gates has no medical or scientific training or credentials and holds no elected office. He should not be determining the fate of mankind. 162 (d) The Gates Foundation (along with other partners) helped launch the Global Alliance for Vaccines and Immunization (GAV!). The foundation has given $4i.1 billion to GA VI over the past 20 years; 163 ( e) These self-propelling agenda personally benefit Gates and other 
Billionaires, Corporations, and Organizations, particularly vaccines and computer and wireless technology, in his pharmaceutical (vaccine ) holdings and agenda, as well as IT and internet holdings and concerns in that, overnight , a vast majority of socio-economic activity has been dislocated to a "virtual", "new normal" whereby everything from 
160 https://childrenshealthdefense.org/news/a-timeline-pandemic-and-erosion… 161 https://www.lifesitenews.com/news/bill-gates-life-wont-go-back-to-norma… 
162 https://childrensheallhdefense.org/news/government-corruption/qatescglo…¥pharma.and-mandatory-vacclnationl 
163 htt ps :/ / www. vox. co m/f utu re-perfect/202 0/ 4 / 14/212155 9 2/b i I I-gates-co ran av i ru s-va cci n es-t re a tm en ts-bi 11 ion a ires 
commerce, schools, Parliament, Courts, are converting to "virtual'', not to mention the electronic surveillance through cellphone applications for contract tracing; (f) The Gates Foundation project to develop at-home testing evolved from a two-year-old research project from the University of Washington that was intended to track the spread of diseases like influenza. All told, the Gates Foundation has poured about $20 Million into the effort. A project funded by the Gates Foundation will soon begin issuing at-home specimen collection kits for the novel coronavirus, COVID-19i, according to a report 
. 164 
1 T. 
mt h e S eatt e 1mes. (g) Dr. Joel Kettner, former Chief Medical Officer revealed that pressure is being put on public health doctors and public health leaders by the Director-General of the World Health Organization (WHO) when he said, 
"i
"This is a grave threat and a public enemy number onei. Kettner states "I have never heard a Director-General of WHO use terms like that." 165 (h) While these initiatives are presented as measures to address health, they significantly increase control by governments over their citizens, violate privacy, and are part of an agenda to impose vaccination by mandates and other forms of coercion. 
(i) Contact tracing applications are being installed in cell phone software upgrades without the express knowledge or permission of consumers; 

164 
https: //www. seattletimes. com/seattle-news/health/gates-f u nd ed-p rog ra m-wi 11.soon-offer-home-testing-kits-for-new-coronavirus/ 
165 https :// off-guardian .org/2020/03/17 /listen-cbc-rad io-cuts-off-expert-whe n-he-q uestions-covid 19-na rrative/ 
G) The Centre for Disease Control in the United States is actively lobbying for increased masking and physical distancing measures, without substantive evidence to justify these measures., while in Canada compulsory masking has also emerged; (k) Alan Dershowitz, a Harvard Law school professor has declared: "ff a safe vaccine is to be developed for Covid-19, I hope it's mandated, and 1 will defend it, and wei'll argue that in the Supreme Court of the United States. " 
166 (1) Social media platforms such as Facebook, Pinterest, Instagram, Twitter, Y ouTube and others, under the direction of governments, are actively censonng information that challenges the SARS-Co V-2(COVID-19) pandemic narrative. Public debate on this topic is not being permitted, where Canada is no exception, and even worse, with the Canadian government threatening to enact Criminal Code provisions for those who utter or publish "misinformation" on COVID-1i9, including expert opm10n; (m)The voices of highly credentialed and respected scientists and medical doctors have been censored by the government and media, preventing them from providing critical information from their decades long experience in dealing with infectious diseases and epidemics. Even our own public health experts' experience and advice, gathered over many decades has been ignored. This includes Dr. Joel Kettner, former Chief 
166 htt ps :/ /www. fo rbes. com/sites/ ch ri sto ph e rri m/20 20 /05/20/ mo re-than-st i mu I us-ch e c ks-h ow-cov id-19-re Ii ef-m ight -in cl u de.m and a ted-va cci n es/?fbcl id= lw A R2 n rvg0W DT d v _Kw j L _ we dTN W Be3 px bq QeQAvQI K4m 8OfSct LG F hA U 9 rGY E #ld 19b0d57992 
Medical Officer of Manitoba and Dr. Richard Schabas, former Chief Medical Officer of Ontario. (n) Scientists have been involved in "gain-of-function" (GOF) research since 
2002 that seeks to generate viruses "with properties that do not exist in naturei" and to "alter a pathogen to make it more transmissible (to humans) or deadly. " 167 168 ( o) Rather than instruct people on how to improve their overall health or boost their immunity with healthy foods, quality supplements, and physical activity, governments are telling citizens that the only way to survive the coronavirus crisis is to rush the development of a vaccine and then inject all seven billion humans on the planet. (p) Many scientists and doctors have expressed confidence in high dose Vitamin C, Vitamin D supplementation, and other generic, inexpensive, and readily available medications and treatments to assist recovery. To state that there is no cure to SARS-Co V-2 (COVID-19) is dishonest. ( q) The "no cure" agenda devolves directly from the pharmaceutical industry, which is receiving billions of dollars from governments to develop expensive and, so far, unproven as safe and effective "cures". Yet safe, effective and inexpensive remedies that help with recovery from Covid-19 already exist. 
167 https://www.ncbi.nlm.nih.gov/books/NBK285579/ 168 https://www.sciencemag.org/news/2014/10/us-halts-funding-new-risky-viru… (r) Research in 2005 demonstrated that Chloroquine is a potent inhibitor of SARS coronavirus infection and spread, thus negating the urgent need for a vaccine. 169 
(s) Some governments are actively restricting access to treatments that have been proven to alleviate the symptoms of SARS-Co V-2(COVID-l 9) including VITAMIN C and D, zinc, HCQ, GTH precursors, and oxygen treatments, including hyperbaric chambers. 
(t) The decision by governments globally to institute social controls and severe containment measures will prolong the epidemic and guarantee successive waves of infection. As social controls are lifted, susceptible individuals previously cocooned from infection will become exposed. Successive waves of infection is a certainty as a result of severe containment measures that prevented the development of natural immunity. 
(u) Prime Minister Trudeau and Ontario Premier Ford have stated that "life will not return to normal until we have a vaccine", parroting Bill Gates and Gates' agenda, and has failed to take "mandatory vaccination" off the table as a potential action of the government. 170 It would appear that the Prime Minister and Premier are not considering any alternative plan to ending this lockdown. 
(v) The Government of Canada has not assumed legal and financial liability for any injury or death resulting from containment measures or the use of any vaccme. 
(w) When a government uses its power to force ordinary citizens to give up their freedoms, that nation is in great danger of moral and economic collapse. 171 

169 https ://www. ncbi. n Im. n i h .gov /pmc/a rticles/PMC 1232869/ 170 https ://nationa I post.com/news/ ca nada/ coronavi rus-live-u pdates-covid-19-covid 19 
202. The Plaintiffs state, and the fact is, that the non-medical aims and objectives to declare the "pandemic", for something it is not beyond one of many annual seasonal viral respiratory illnesses, was to, inter alia, effect the following non.medical agendas, by using the COVID-19i" as a cover and a pretext: (a) To effect a massive bank and stock market bail-out needed because the banking system was poised to again collapse since the last collapse of 
2008 in that the World debt had gone from $14i7 Trillion dollars in 2008 to $321 Trillion dollars in January, 2020 and that; (i) With 10 days of the declared pandemic European and North American banks were given $2i.3 Trillion dollars and further amounts to hold up stuck markets and corporations, for a total of approximately $5 Trillion dollars, largely going un-noticed in the face of the "pandemic", with this number progressively climbingi; 
(ii) The shutting of virtually all , small independent businesses, with the bizarre, but intended consequence that a local, street-level clothing-store, or hardware store, or any store not selling food or medicine, is forced shut down but a Walmart or Costco could sell 

171 https://www.chp.ca/commentary/free-injections-or-mandatory-vaccinations 
anything and everything in its stores because one section of the store sold food ( an essential service); (iii) Other stores unable to sell , had to close with the consequence that all small hardware shops, and the like, were closed but the large corporations such as Home Depot, and the like, were equipped to take o-line orders and have drive-by pick up; (b) The fact is that the pandemic pretense is there to establish a "new normal"; of the New (Economic) World Order, with a concurrent neutering of the Democratic and Judicial institutions and an increase and dominance of the police state; ( c) A massive and concentrated push for mandatory vaccines of every human on the planet earth with concurrent electronic surveillance by means of proposed:

(i) Vaccine "chips", bracelets", and "immunity passports"; 
(ii) Contract-tracing via cell-phones; 

(iii) Surveillance with the increased 5G capacity; ( 
d) The elimination of cash-currency and the installation of strictly digital currency to better-effect surveillance; 
(e) The near-complete revamping of the educational system through "virtual" learning and closure of schools, particularly at the University levels. 

203. The Plaintiffs state, and the fact is, that the benefactors of these goals and agendas are the global oligarchs who control and profit from vaccines and the technical infrastructure of information and communication such as Bill Gates, 
and his compames and Organizations, who pursues global vaccination and profits from a global shift to "virtual economy" along with the other corporate oligarchs and their "on-line" sale and distribution infrastructure of globalization, and by-passing of effective national governance of nation-states under their own respective Constitutions, including Canada. 
204e. The Plaintiffs state, and the facts is, that this agenda is well on its way to "virtualizing", "corporatizing", and "isolating" even Parliament and the Courts to an embarrassing and debilitating degree as reflected by: (a) Virtual Parliamentary Committers and sittings become the "new normal" because a declared "pandemic", is available every year, with projected 
(b) The Supreme Court of Canada, on June 3erd,2020 announced virtual, "Zoom" hearing of its appeals with its first virtual appeal hearing on or about June 101\ 2020e; 
(c) The Chief Justice of the Ontario Superior Court, Justice Justice Geoffrey Morawetz, embarrassingly declared, on May 29t\ 2020 that "there is no real return to full-scale, what I will call normal operations, to pre-March operations, until such time that 

there's a vaccine available". Whether the Chief Justice is aware, or not aware, that he was echoing a mantra originated by Bill Gates, and an agenda Gates has been pursuing for decades, which serves Bill Gates and his associates, is unknown. 
205. The Plaintiffs further state, and the fact is, that this agenda executed under the pretext of the COVID-1i9 has been long in the planning and making, as reflected and borne out by, inter alia the following facts and documents:

(a)

(i) "decade of vaccines" declared by Bill Gates, and its funding with the full support of the Canadian government, under a Memorandum of Understanding in 2020 up to including PM Trudeau, and further, on or about May 18it\ 2020, gifting Bill Gates another $8i00 Million dollars of Canadian Taxpayer dollars in addition to prior millions already gifted; 
(ii) The public statements made by Bill Gates and others for mandatory vaccination of the globe, with vaccine-chips, chip.bracelets, smart-phone tracing, covid-testing, and surveillance of everyone; 

(iii) The criminal vaccine experiments causing horrific damage to innocent children in India, Pakistan, Africa and other developing countries; (b) The Rockefeller Foundation Report, issued on May 2010, and leaked, in which report a hypothetical scenario and hypothetical is laid out with the effect of " how to obtain global governance during a pandemic", and which report, posits an unknown virus escaping Wuhan, China; 
(c) The 2010 Canadian Film Board documentary in which Dr. Theresa Tam, an ex-WHO committee member, is featured and quoted to have stated, with respect to a potential pandemic; Transcript ( of Film Documentary): 1 
:25 -1 :32 -"Large epidemics and pandemics occur on a regular basis through-out history, and it will occur again. It definitely will." 
57:00 -58:00 -"If there are people who are non-compliant, there are definitely laws and public health powers that can quarantine people in mandatory settings." 
"It's potential you could track people, put bracelets on their arms, have Police and other set-ups to ensure quarantine is undertaken." 
"It is better to be pre-emptive and pre-cautionary and take the heat of people thinking you might be overreacting, get ahead of the curve, and then think about whether you've over-reacted later. It's such a serious situation that I think decisive early action is the key." 
Narrator Colm Feore states: "Police checkpoints are set up on all the bridges and everyone leaving the city is required to show proof of vaccination. Those who refuse to cooperate are taken away to temporary detention centers." 
1 :22 -"What is certain is an epidemic or pandemic is coming." 172 
(d) Gates, through the Bill and Melinda Gates Foundation, between 2003 and 201i7,vaccine program killing thousands of children and severely injuring 486,000-plus in India, Pakistan, and Africa in administrating vaccines, as exposed by Robert Kennedy Junior and his Defense of Children Foundation, and others, and the fact that in India the Courts are investigating this conduct, and an unsuccessful motion brought in the Italian Parliament to have 
172 NFB Website: http:/Jonf-nfb.gc.ca/en/our-collection/?idfilm=S5974 
Toronto Sun article: htlps://rorontosu11.com/r\ews/nationaJ/warminglo1Ham-talked-of-tracki11g-llracelets¥in-20lO-epldPmic¥flln, 
Gates indicted and extradited for crimes against humanity , and further that developing nation states declaring that they have been "guinea pigs", mostly children, in furtherance of global vaccination; ( e) A study by Dr. Peter Aaby in Africa, DTP Vaccine Increases Mortality 5-Fold, In Study Without Healthy User Bias concluded: "DTP was associated with 5-fold higher mortality than being unvaccinated. No prospective study has shown beneficial survival effects of DTP. All currently available evidence suggests that DTP vaccine may kill more children from other causes than it saves from diphtheria, tetanus or pertussis."1 7 3 DTP while discontinued North America is still administered in the developing World.

(f) All the facts pleaded, in the above statement of claim with respect to Bill Gates, the Gates Foundation, GAVI, the WEF, Gates'entrenchment in vaccinating, mandatorily the entire planet, and his vaccine-chip pursuits with smart-phone surveillance, covid-testing, acquisition of 5G companies for maximum contact tracing and surveillance, his relationship with the WHO and its funding; 
(g) A UN report, commissioned and released, in September, 20i19, prepared by the "Global Preparedness Ministry Board", in which an "Apotyliptic Pandemic" is predicted killing as many as 80 million people; (h) "Eivent 20 l ", an exercise, simulating a pandemic, prior to October l 8t\ 201i9, organized by Gates, GA VI, which included the "World Economic Forum", on invitation only; 
(i) The Government of Canada's, minutely detailed 67-page Report, entitled" Government of Canada Response Plan COVID-19i", final version 3 .1 ", with previous versions unavailable, which could not have been researched and written a mere couple of weeks prior to the declaration of lock-downs and emergency in Canada; 

j) The heavily censored UK "Sage Report" of late-May, 2020; 
(k) The International Lobby, spear-headed by Bill Gates and others as set out in the within Statement of Claim; 
(1) The Suppressed German government 93-page, May, 2020, report which was eventually and recently leaked, which clearly and conclusively determined that the "pandemic" and measures are unjustified. The salient summary of which reads: cs. KM4 -51000i/29#2 

KM 4 Analysis of Crisis Management (Brief Version) Remarks: It is the task and aim of crisis management groups and any crisis management to recognize extraordinary threats and to fight them until the normal state is re-established/regained. A normal state cannot therefore be a crisis. 
ummat:y of tbc 1áesults of th_is analysis 

1. 1. In the past the crisis management did not (unfortunately against better institutional knowledge) build up adequate instruments for danger analysis. The situational reports, in which all information relevant for decision-making should be summarized in the continuing/current crisis, today still only cover a small excerpt of the looming spectrum of danger. An assessment of danger is in principle not possible on the basis of incomplete and inappropriate information. Without a correctly carried out assessment of danger, no appropriate and effective planning of measures is possible. The deficient methodology has an effect on a higher plane with each transformation; politics so far has had a strongly reduced chance to make factually correct decisions. 
2. 2. The observable effects of COVID-19 do not provide sufficient evidence that there is -in relation to the health consequences of all of society -any more than a false alarm. At no point in time, it is suspected, was there a danger as a result of this new virus for the population ( comparison is the usual death rate in Germany). Those who die of corona are essentially those who statistically die this year, because they have arrived at the end of their lives and their weakened bodies cannot any longer fight coincidental everyday challenges (including the approximately 150 circulating viruses). The danger of COVID-19 was overestimated. (In a quarter of a year worldwide no more than 250,000 deaths with COVID-19, as opposed to 1.5 million deaths during the 2017 /18 influenza season). The danger is obviously no larger than that of many other viruses. We arc dealing with a global fal e ala1ám which has been unrecognized over a longer period of time. -This analysis was reviewed by KM4 for scientific plausibility and does not fundamentally oppose the data and risk assessments provided by the RKI [Robert Koch Institute]. 
3. 3. A fundamental reason for not discovering the suspected false alarm is that the existing policies for the actions of the crisis management group and the crisis management during a pandemic do not contain appropriate instruments for detection which would automatically triger an alarm and the immediate cancellation/abandonment of measures, as soon as either a pandemic proves to be a false alarm or it is foreseeable that the collateral damage -and among these especially the parts that destroy human lives -threatens to become larger than the health effects of and especially the deadly potential of the illness under consideration. 
4. 4. In the meantime, the collateral damage is higher than the recognizable benefit. The basis of this assessment is not a comparison of material damages with damage to persons (human lives). Alone a comparison of deaths o far due to the virus with deatl1s due to the measures decreed by the state (both without certain data). Attached below is an overview.type summary of collateral health damages (incl. Deaths), reviewed by scientists as to plausibility. 
5. 5. The ( completely useless) collateral damage of the corona crisis is, in the meantime, gigantic. A large part of this damage will only manifest in the nearer and more distant future. This cannot be avoided anymore, only minimized. 
6. 6. Critical infrastructures are the lifelines necessary for the survival of modern societies. As a result of the protective measures, the current security of supply is no longer a given as it usually is (so far gradual reduction of the basic security of supply, which could result in a fallout in future challenging situations). The resilience of the highly complex and strongly interdependent complete system of critical infrastructure has been reduced. Our society lives, from now on, with increased vulnerability and a higher risk of failure of infrastructures necessary for life. This can have fatal consequences, if on the in the meantime reduced level of resilience of KRITIS a truly dangerous pandemic or other danger should occur. 
   Four weeks ago, UN-general Secretary Antonio Guterres of a fundamental risk. Guterres said ( according to a report in the Tagesschau on April 4, 2020i): "The weaknesses and insufficient preparation which are becoming apparent through this pandemic give insight into how a bioterrorist attack could look -and these weaknesses possibly increase a risk thereof." According to our analysis, in Germany a grave deficiency is the lack of an adequate system for the analysis and assessment of danger. 
7. 7. the protective measures decreed by the state, as well as the manifold societal activities and initiatives which, as initial protective measures cause the collateral damage, but have in the meantime lost any purpose, are largely still in effect. It is urgently recommended to abolish these immediately, to avert damage to the population -especially unnecessary additional deaths -, and to stabilize the situation around critical infrastructure, which is possibly becoming precarious. 
8. 8. The deficits and failures in crisis management consequently lead to communication of information that was not well.founded. (A reproach could be: The state showed itself to be one of the biggest fake-news-producers in the corona crisis). 

From these insights it follow : 

1. a) The proportionality of interference with the rights of cg. Citizens is currently not given, since the state did not carry out an appropriate consideration with the consequences. The German constitutional court demands an appropriate balancing of measures with negative consequences. (PSPP judgement of May 5, 2020). 
2. b) The situational reports of the crisis management group BMI-BMG and the communications from the state to the provinces regarding the situation must there fore henceforth -conduct an appropriate analysis and assessment of dangerous -contain an additional section with meaningful, sound data regarding collateral damage (see remarks in the long version) -be freed of irrelevant data and information which are not required for the assessment of danger, because they make it difficult to see what is going on -an index should be formed and added at the beginning 
3. c) An appropriate analysis and assessment of danger is to be performed immediately. Otherwise the state could be liable for damages that have arisen.174 

206. The Plaintiffs further state, and fact is, that in a study issued by Stefan Homburg, Christof Kuhbandner, at the Leibniz University Hannover, Germany, post-.June 81'\ 2020, these authors soundly concluded in their study that the lock-down measures as modelled and executed were Not effective, globally comparing countries following the WHO protocols and countries that did not.175 

207. The Plaintiffs state, and the fact is, that this agenda includes the "World Economic 
Forum ("WEF")". The Plaintiffs state and fact is that the WEF; 

1. (a) Consistently promotes a "New Economic World .rder" ,which is a vision in the process of being rolled out under the auspices of the World Economic Forum, of which one of the main sponsors is The Bill & Melinda Gates Foundation. 
2. (b) The World Economic Forum is the International Organization for Public-Private Cooperation. The Forum engages the foremost politica], business, cultural and other leaders of society to shape global, regional and industry agendas. 
3. (c) The World Economic Forum is committed "to the launch of the Great Reset -a project to bring the world's best minds together to seek a better, fairer, greener, healthier planet as we rebuild from the pandemic." "The COVID-1i9 crisis has shown us that our old systems are not fit any more for the 21ist century," said World Economic Forum Executive Chairman Klaus Schwab. "In short, we need a great reset." 176 
4. (d) Since its launch on March 11i1\ 2020i, the Forum's COVID Action Platform has brought together 1,667 stakeholders from 1,10i6 businesses and organizations to mitigate the risk and impact of the unprecedented global health emergency that is COVID-1i9. The platform is created with the support of the World Health 0 rgamza 10n. , t' 177  The WEF sponsors have big plans:" ... the world must act jointly and swiftly to revamp all aspects of our societies and economies, from education to social contracts and working conditions. Every country, from the United States to China, must participate, and every industry, from oil and gas to tech, must be transformed. In short, we need a "Great Reset" of capitalism." "The World Economic Forum is launching a new Davos Manifesto, which states that companies should pay their fair share not taxes, show zero tolerance for corruption, uphold human rights throughout their global supply chains, and advocate for a competitive, level playing field." Klaus Schwab, Founder and Executive Chairman, World Economic Forum.i178 (f) In 201i7 Germany, India, Japan, Norway, the Bill & Melinda Gates Foundation, the Welcome Trust and the World Economic Forum founded the Coalition for Epidemic Preparedness Innovations (CEPI) to facilitate focused support for vaccine development to combat major health epidemic/pandemic threats. As an organization, the Forum has a track record of supporting efforts to contain epidemics. In 2017, at the Annual Meeting, the C'oaliticrn for Epidemic Preparedness Innovations (CEPI) was launchedi.bringing together experts from government, business, health, academia and civil society to accelerate the development of vaccines. CEPI is currently supporting the race to develop a . . . 179 vaccme agamst t h' 1s stran d o f t h e coronavuus. (g) Event 20i1, the pandemic exercise in October 20i19i, was co.sponsored by the World Economic Forum and the Gates Foundation. 180 

208. Further with respect to global vaccination, in the context of Covid, the WEiF has stated: (a) Thati: 
"The COVID-19 crisis is affecting every facet of people's lives in every corner of the world. But tragedy need not be its only legacy. On the contrary, the pandemic represents a rare but narrow window of opportunity to reflect, reimagine, and reset our world to create .a healthier, more equitable, and more prosperous future. Interactive diagram." 181 (b) And that: 
"The changes that are underway today are not isolated to a particular country, industry, or issue. They are universal, and thus require a global response. Failing to adopt a new cooperative approach would be a tragedy for humankind. 
To draft a blueprint for a shared global-governance architecture, we must avoid becoming mired in the current moment of crisis management. 
Specifically, this task will require two things of the international community: wider engagement and heightened imagination. The engagement of all stakeholders in sustained dialogue will be crucial, as will the imagination to think systemically, and beyond one's own short-term institutional and national considerations." 182 
179https://cepi.net/about/whoweare/ https://apps. who.int/gpmb/assets/annual_report/GPM B _ annualreport_ 2019 .pdf pg 19 
1811 https://www.centerforhealthsecurity.org/event20 I/ 
181 https://www.weforum.org/agenda/2020/06/now-is-the-time-for-a-great-reset 
182 
https://intel I igence. weforum.org/top ics/al GOX0000060 Lei U AG ?tab=publ ications 
hltps:/f\V1v,.v áfor 1111.nr , ncJlil,i,'20 L 11/ lohnli1.ntion:¥G.\'.!JUL-ciq9i;:!t-111c,l!.l.Q}:l'::H:.1vill::bcne::OJ:_cy1c:l'Y,ll!l£( 
209. In early July, 2020i, Trudeau announced the massive expenditure of post.COVID-19 infrastructure spending to re-align the economy, in concert with the WEiF agenda, in tandem with private sector partnership whereby the anticipated privatization of public assets is a given. 

210. The Plaintiffs state, and the fact is, that: 

1. (a) This agenda, conspiracy, is spear-headed by Bill Gates, and other Billionaire, Corporate, and Organizational Oligarchs, include vaccine, Pharmaceutical, and Techn0logy Oligarchs, through the WHO, GA VI, and the WEiF, whom they fund and effectively direct and control; 
2. (b) National and Regional Leaders who are simply, knowingly and/ or unknowingly, as duped c-conspirators, partaking in this conspiracy by simply declaring a "pandemic", "emergency", and delegating decisions to their Chief medical officers who are simply following the dictates and guidelines without question nor concern for the world expert opinions against such measures, of the WHO; 
3. ( c) In effect there are less than a hand-full of people dictating the virtual fate of the planet whereby sovereign Parliaments, Courts, and Constitutions are by-passed; (d) The "social media", such as Google, Facebook, YouTube, Amazon owned and operated by the likes of Bill Gates, Mark Zukerberg, and, in Canada, the CBC,funded and controlled by the Federal Government, are knowingly playing in concert with this over-arching conspuacy, and in fact over.lapping conspiracies. 

208. The Plaintiffs further state that through their conduct, communication, agreement, and functions of their intertwined respective public and private offices, the Defendants, knowingly and unknowingly, intentionally and unintentionally, as outlined, inter alia, by the Supreme Court of Canada in the test set out in Hunt v. Carey and jurisprudence cited therein, have and to continue to:

1. (a) engage in an agreement for the use of lawful and unlawful means, and conduct, the predominant purpose of which is to cause injury to the Plaintiffs, through the declaration of a false pandemic and implementation of coercive and damaging measures including the infliction of a violation of their constitutional rights as set out above in the within statement of claim; and/or 
2. (b) to engage, in an agreement, to use unlawful means and conduct, whose predominant purpose and conduct directed at the Plaintiffs, is to cause injury to the Plaintiffs, through the declaration of a false pandemic and implementation of coercive and damaging measures including the infliction of a violation of their constitutional rights as set out above in the within statement of claim, that Defendants and officials and employees, should know, in the circumstances, that injury to the Plaintiffs , is likely to, and does result. 

211. The Plaintiffs state, and the fact is, that Canada'si, and Trudeau's, connection to Gates, Gates' foundation, and various companies , and the global vaccine industry, is inter alia, as follows:

1. (a) PM Trudeau has echoed Bill Gates' sentiments that mass mandatory vaccination of people is necessary for any sense of normalcy to return. 
2. (b) Gates uses proxies to successfully lobby the Canadian Government. 
3. (c) The Gates Foundation founded GAVI, the Global Vaccine Alliance in 19i99 with $750 million and continues to run it and fund it. The Global Vaccine Alliance, is an organization devoted to pushing vaccinations on the public all across the world. 
4. (d) GAVI hired a lobbying firm called Crestview Strategy, a public affairs agency. Their Mission Statement is: "We make, change, & mobilize opinion.i" 
5. (e) Canada has gifted Bill Gates, and his related Foundation and companies well over $1 Billion dollars in pursuit of his agenda, $800 Million recently by Justin Trudeau; 
6. (f) Crestview has lobbied the Canadian Government on at least 19 occasions since2018 on various "health" matters, all on behalf of GA VI. 

¥ Bill Gates-Vaccines, Pharmaceuticals & Technology 

212. 212. The Plaintiffs state, and the fact is, as set out in the within Statement of Claim, that Bill Gate's companies, and associates, manifest a clear agenda, for himself and his associates in the vaccine, pharmaceutical and technology, industries, through the de facto control of the WHO, influencing and dictating its agenda, to:
     1. (a) Effect a mandatory, global, vaccine policy and laws, which would net an approximately $1i.3 Trillion per year, in which vaccine industry he is major proponent and investor; 
     2. (b) To effect surveillance, through his vaccination agenda, as outlined in their public statement, and the MIT developed smart-phone application to embed nannocrystal beneath the skin which can be read by a smart-phone through smart-phones, and 5-G capacity, in which industries Gates 1s a major stake-holder and investor; 
     3. (c) Using the above to "virtualize" and globalize the World economyi, in which virtual and global New World (Eiconomic) Order in which Gates further sits in the centre, along with the other Billionaire and corporate oligarchs; 
     4. (d) All of which is being effected and accelerated through the false pronouncement of a COVID-1i9 'pandemic", and implementation of baseless and false, draconian measures. 
213. 213. The Plaintiffs state, and the fact is, that Bill Gates' statements, and conduct, in the above-noted facts, has been documented, as reflected in the within Statement of Claim, namely at paragraphs 63i, 68, 69, 72, 75, 78, 81i, 85, 93i, 100, 107, 112, 118, 121, 124,199,200,201i,202,203i,205, of the within Statement of Claim, with respect to his agenda and conspiracy with others, including the Defandants. 

¥ The WHOi/ Gates/ Trudeau and Dr. Teresa Tam 

214. 214. The Plaintiffs state and fact is, that the connection and common agreement between Gates-Trudeau-Tam, in addition to their statements and actions m furthermore of that agreement as outlined above m the within Statement of Claim, is further manifested by the following:
     1. (a) On April 9, 2020 just before Easter, Trudeau announced that: 
        "We will not be coming back to ourfrJrmer normal situation; we can 'f do that until H'e have developed a vaccine and that could take 12 to 18 months ..... [and] .... This will be the nev1, normal until a vaccine is developed. "183
     2. (b) Trudeau's statement is a script lifted straight from Bill Gatesá cchoi11g almost word for word. the message Gates has been pushing smcc the coronavuus in North America earlier this winter. The April 9th Highwire video clip at 2:07 captures Gates stating: 
        "Things woná t go back to truly normal un Li I ,Ne have a vaccine that we've gotten out basically to the entire world.''184
     3. ( c) Instead of following the recommendations of leading scientists. doctors and epidemiologists, Trudeau is foisting the Gates/WlTO/ Gi\ VI/ \\'l T globalist agenda which he knows or ought to know, will result in l'inanci,1I ruin for millions of Canadians including the Plaintiffs.
     4. (d) Despite the prevailing global consensus on natural herd imrnunily. Bill Gates 1s determined however, to prevent natural immunity so he can mandate his new vaccine(s) for everyone. Noted scientist and journalist. Rosemary Frei, shows Bill Gates does not áwant people lo acqull'c immunity to COVID-19. Rather, Bill Gates prefers that \Ye sulTer the 'economic pain' ofelockdown in order to prevent us from acquiring naturnl immunity as Gates has stated: 
        ''We doná t want to have a lot of recovered people I ... I ro be clear, we're tryinge-through the shut-dovvn in the United States -to not get to one percent oC the populatio11 infected. We're well below that today, but with exponentiation, you could get past that three rndlion [people or approximately one percent of the U.S. population being infected with COVID-19 and the vast rnajorit r covering]. I believe wee,. ill be able to avoid that with having this economic pain."185 (e) In her latest compelling article, Covid-19 Meltdown and Pharmas' Big Money Win, Barbara Loe Fisher delves into the many disturbing angles ol this epic viral/political war unleashed on humanity. the havoc caused b\ the Gates & Fauci lockdown policy and the economic spinoJTs spawnccl by the pandemic. 186 185 Did Bill Gates Just Reveal the Reason for the Lockdowns: By Rosemary Frei, Off-Guardian, April 4, 2020 https://off.guardian.org/2020/04/04/did-bill-gates-just-reveal-the-reas… =8a3 I c96b7b83 lb06c663 ld2d800e39e274fdb4c5-l 593827339-0AbbQnElw4gYMqoe 14KtV.9sVWpJ8_1O6ZguVbep6dVylwrKGMbqfHkxidxl_3uCK08Nlmuk8B5fJzKB4cL3viTl qQYvV8722SeZLNTHOWUovzpclftZQcDi Ix vg3QQ6jPmp ZkNGtNlwGs874a0MhuR Y9 _t7yNj8TyeXmeBXidqKFHOtCmuLJEmS9ZGcLDsNGb5 WKidfn HO7DSzlQ 11 0eNBgH MLXerbj Pr Ks ESdGlhwd3 Ljo Y6FiHbJ u4UI bTEJMbsKQFlq5XIIOtoLGY2e7ffhzjnbUBrcjpv76AL5aOYmAQAI ICC3ttqOt_ k2 I mLMgHN Fa tl2g WSlla4a2S UAI8IzoKXLcbkuTr0!pvKrbjkF8B4ij3p8MdQOK0DZHcW 186Covid-l 9 Meltdown and Pharma's Big Money Win: https://thevaccinereaction.org/2020/04/covid 19-meltdown-and-pharmas-big.money-win/ (f) Covid-19 has sparked the hottest new market in town -vc1cc111c development. A staggering number of coronavirus vaccrncs me utidcr development right novv with astronomical piles of money being thrnwn at it. Gates is in the thick of it along with Tony Fauci. director ol' lhc National Institute for Allergy and Infectious Diseases (NIAID). Both me on record stating they don't want people developing natural immunity, 111 stating: 

"Now, I hope we don't have so many people in fcctcd that we actually have that herd immunity, but I think it would have to be different than it is right now", says 1-'auci, ix7 
(g) Natural immunity would disrupt Bi II Gates expressed intension to "vaccinate everything that moves". In a video interview Gates says: 
"Eventually, what we'll have to have is certificates of who is a recovered person. who's a vaccinated person, because you don át want people mm ing around the ,vorld vvhere you'll have some countries that . ¥¥IR8 won't . I 1ave 1t un d er contro I ... ,, (h) The Gates foundation has invested tens of $billions in vacc111c development which includes a decades long v1c1ous propagand,1 war against anyone questioning vaccme safety. Gates' 'decade of mccines á from 20 I 0-20 captured the global media and social media giants that h,wc dernonized and ruthlessly censored the 'vaccine risk aware' movement comprised mostly of vaccine injured families trying to protect their children and the basic human right to informed consent and exemption 
187 Covid-19 Meltdown and Pharma's Big Money Win: https://thevaccinereaction.org/2020/04/covid19.meltdown-and-pharmas-big… 188 6 How we must respond to the coronavirus epidemic, Youtube video March 25, 2020:https ://www. youtu be .com/watch ?v=Xe8fljxi coo#t=33 m45s 
rights. This has been documented by various publications, which explore the massive influence and control with which the C1atesá einp1 n.: manipulates global health and vaccine policies. 189 (i) In one article Canadian medical journalist. Celeste McGovern invcslil,'-alcs the upcoming vaccine and microchip technologies Gates is runding. l()li 

G) In another, Robert F. Kennedy Jr. exposes the C1ates/WI-IO agenda leisti11g their deadly vaccine experiments in the developing world. Kc1111cch explains: 

"In 2010. when Gates committed $10 billeion lo lhe WI 10. he said "We must make this the decade o['vacci11cs.áá 1\ month later. Gates said in a TED Talk that new \'accines "could reduce population." And, four years lalcr. in 20 I 0I. Kenya's Catholic Doctors Association accused the \VI IO or ch 111ically sterilizing mill inns or umvileling Kenyan \\ 01nc11 191 with l.1 "tetanus" vaccine campail!n. (k) Another expose is that of Vera Sharav. a Holocaust sunáivor and i<)t111dcr of the Alliance for Human Research Protection. She examines hm\ Cialc.'sá table top 'Event 201' pandemic exercise in October, 2019. set the stage for how the coronavirus pandemic would be handled. lt predicted lhe pandemic would end ONLY after an effective vaccine had been brought lo market. It is no coincidence that the coronavirus pandemic \Vas unlc,1shcd just weeks after Gates' pandemic áwar games rehearsal and i.s; 110\\ 
189
B ill Gates search-Covide-19 Global Pandemic, Vaccine Impact News: https://vaccineimpactecom/?find=bill+gales 1911 Bill Gates and Intellectual Ventures Funds Microchip Implant Technology, By Celeste McGovern, April 14, 2020: https://www.greenmedinfo.com/blog/bill-gates-and-intellectual-ventures-… technology I ?utm _ campaign=Dai ly%20News letter%3A %20B i 11%20Gates%20and%20 Intel I ectual%20 Ventur es%20Funds%20Microchip%20Implant%20Vaccine%20Technology%20%28TCCz3V%29&utm_medium=e mail&utm _source=Dai ly%20Newsletter& _ ke=eyJrbF91b WFpbCl6ICJj Lm ljZ292ZXJ uQGhvdG 1 ha Wwu Y29Lli wglmtsX2NvbXBhbnlfaWQi0iAiSzJ2WEFSln0%3D 
191 
Bill Gates' Globalist Agenda: A Win-Win for Pharma and Mandatory Vaccination by Robert F Kennedy Jr. April 9, 2020, Children's Health Defense:https ://chi ldrenshealthdefense.org/news/governmentcorruption/gates-global ist-vacci ne-agenda-a-wi 11-wi 11.for-pharma-and-mandatory-vaccination/ 
playing out, as lock down scenano threatens to continue until the nc\\ vaccine arrives?'92 (1) Sharm1 also delves into Gates' vast business ventures related to enhancing pharmaceutical products and vaccines. His 1D2020 is a digital ID progrnm aimed at identifying 1 billion + people lacking identity documents. /\lso i 11 development are several ID devices that people could be forced lo h.l\ c implanted into their body to identify their vaccine and hirth-conlrnl 
status. 193 
215. With respect to the Defendants Trudeau and Tam, the Plaintiffs state, and the 
fact is that: (a) Theresa Tarn, Canada's chief public health officer and longtime loyal servant of the WHO, serves on multiple international committees and related organizations that dictate global health policies. Her main job is to make sure that Trudeau follows the WHO/Gates lockdown policy until the new Covid-1i9 vaccine arrives in 18 months. 
192Bill Gates & Intellectual Ventures Funds Microchip Implant Vaccine Technology by Celetes McGovern, April 14, 2020: https://www.greenmedinfo.com/blog/bill-gates-and-intellectual-ventures-… ?utm_campaign=Daily%20Newsletter%3A%20Bill%20Gates%20and%20Intellectual%20Ventur es%20Funds%20Microchip%20Implant%20Vaccine%20Technology%20%28TCCz3V%29&ut111_111ediu111=e mail&utm _source=Daily%20Newsletter& _ ke=eyJrbF91b WFpbCI61CJjLm ljZ292ZXJuQGhvdG I ha Wwu Y29tli wglmtsX2NvbXBhbnlfaWQiOiAiSzJ2WEF5In0%3D 19 Coronavirus provides dictators and oligarchs with a dream come true, By Vera Sharav, Alliance for Human Research Protection, 
J 
March 26, 2020: https://ahrp .org/coronavirus-provides-ol igarchs-with-adream-come-true/ (b) Molly Chan, author ofa probing analysis of Dr. Tamás career thinks it's 
evident from her background that: 
''Theresa Tam works with the workr s most powcrl'ul globalist entities that have tremendous say in how the world deals with disease and immunization. This power enables them to have a grip on the entire planet. and to decide which measures are put into place to control lhc behaviour ofpeople in any event they choose to cause a panic over. With COVID-19, we have a perfect example or how the decisions of this small group of people can lead to global hysteria and unprecedented societal cbangcs.''191 ( c) Molly Chan asks important questions on Tam's career and cxtensi vc influence: 
"Does this make Theresa Tarn a puppet or master? I low is it possible to not follow WHO recommendations. when you're the one making them? She is on pO\verful committees!" (d) Considering the multiple numerous high-level positions Dr. Tam holds on the international stage, Tam's first loyalty is not to the áwellbeing or Canadians , or the Plaintiffs, but to the globalist policies so generously funded by Gates and Big Pharma. 
194 Dr. Theresa Tam, Queen of the Vaccine by Molly Chan, Civilian Intelligence Network, March 31, 2020: https://civilianintelligencenetwork.ca/2020/03/30/dr-teresa-tam-queen-o… (e) Chan dubs Tam as the 'Queen of Vaccineiá and explains: 

"convened public health leaders and parents to collaborate on the effort to shut dovvn any hint of anti-vaccine thought. Governments. including Canada and the U.S. arc also working with social media companies to remove vaccine misinformation and promote scientific literacy. She \, ants to make sure that people are not allcnvcd to publicly say anything against vaccinations, and establish them as just a normal part of life, no questions asked."19. 
(t) While flexing her expansive influences, it seems a 'no brainer" 

Theresa Tarn has been instrumental in controlling the CBC s narrati vc 
about the need to snuff out 'vaccine hesitancyi' which includes the ruthless 
censorship of any voices that would question vaccine safety in mainstream 
media. (g) Tam is accused of "total incompetence" in having botched the Canadian 
response to the COVID-1i9 pandemic: 
"Tam has failed miserably. putting political correctness. 
and virtue-signalling lecturing ahead of doing her job. She 
couldn't grasp the situation in time, and when she grasped 
. f. . --I% 
t 1 1e seriousness o 1t was 1á ar too 1 ate to stop 1t. á (h) The Toronto Sun's cutting review of Theresa Tam's incompetence says: 
"Our country is now run by 'healthcrats'. Dr. Theresa Tam is the Healthcrat who nms the federal government. Her 
.. 191 
d on b . . l 
recor emg wrong 1s spot ess. (i) In a recent interview in Chatelaine magazine, Tam bashes vaccine 
resistors and accuses them of causing measles outbreaks. I !er cryptic 
195 Dr. Theresa Tam, Queen of the Vaccine by Molly Chan, Civilian Intelligence Network, March 31, 2020: 
https://civilianintelligencenetwork.ca/2020/03/30/dr-teresa-tam-queen-o… 
1 96 Devastati11g timeline reveals complete incompetence of Theresa Tam's Virus Response 
https://spe11cerfernando.com/2020/03/29/devastating-timeline-reveals-to… 197 The healthcrats cure is proving worse than the disease, Toronto Sun, April 10, 2020: 
https://torontosun.com/opinion/columnists/snobelen-the-healthcrats-cure… 
statement, "/ always think we do a really good job, H1he11 no one k11mv\ what we're doing", reveals the federal health agency's lack of' transparency and inability to provide crucial epidemiological data during this crisis. 

GI CONSEQUENCES OF MEASURES TO THE PLAINTIFFS AND OTHER CITIZENS, AND VIOLATION OF CONSTITUTIONAL RIGHTS 

216. 216. The Plaintiffs state, and the facts is, that the impact of containment measures to Plaintiffs is, inter alia that:
     1. (a) Mass containment measures negatively impacts the development of herd immunity, artificially prolongs the epidemic, extends the period of confinement, and contributes to maintaining a high proportion of susceptible individuals in the population.
     2. (b) California emergency room physicians stated that "sheltering in place does more harm than good and lowers our immune system." 198
     3. (c) The measures employed to achieve the objective of "flattening the curvei" so as not to overwhelm the health care system were disproportionate to the objective. Our health care system has consistently operated at 40 -50% below capacity since the introduction of these measures.
     4. (d) The suspensions of rights to participate in community and in commerce has caused substantial and irreparable harm to the economy, livelihoods, communities, families, and the physical and psychological well-being of Canadians and the Plaintiffs. These include: 198 hltps:l/vacclneimpact.com/2020/californla-er-ohysicians-sheltering-ln-place-does-more-harm-than-good-lowers-our.immune-system/
        1. (i) A dramatic increase in reports of domestic violence (30i%). 
        2. (ii) Over six million Canadians have applied for unemployment benefits and 7.8 million Canadians required emergency income support from the Federal government (as of May 2020i). 199 
        3. (iii) The deepest and most rapid loss of jobs, savings and income in the history of Canada. 200
        4. (iv) Numerous citizens have been forced into unemployment and poverty, the loss of their business, and bankruptcy. 
        5. (v) Estimates of the Federal deficit resulting from their response to SARS-CoV-2 ranges up to $400 billion (May 2020). 201 
        6. (vi) Leading Economic Indicators show the Canadian economy is now in ''free/all". 202 
        7. (vii) Illnesses and conditions not related to SARS-Co V-2 have gone untreated and undiagnosed.
        8. (viii) Dramatic increase in number of individuals dying at home due to lack of medical care and for fear of visiting emergency wards despite the fact that most hospitals have capacity.
        9. (ix) Denial of access to health care professionals including doctors, dentists, chiropractors, physiotherapists, naturopaths, homeopaths, physiotherapists, massage therapists, optometrist, and osteopaths. 199 https://www.macdonaldlaurier.ca/beyond-lockdown-canadians-can-have-both… 200 https://www.macdonaldlaurier.ca/beyond-lockdown-canadians-can-have-both… 201 https://www.macdonaldlaurier.ca/beyond-lockdown-canadians-can-have-both… 202 https://www.macdonaldlaurier.ca/beyond-lockdown-canadians-can-have-both…
        10. (x)  Denial of access to health care services including cancer  treatments, elective surgeries, testing, diagnosing, and treatment.
        11. (xi)  Regulated health care practitioners, including chiropractors,  Naturopaths, and Homeopaths have been directed to refrain from  providing health care knowledge to individuals concerned about  SARS-Co V-2i. This is an unwarranted infringement on the right to therapeutic choice.
        12. (xii)  Dramatic Increase in mental health challenges including suicide.
        13. (xiii)  The significant potential for the traumatizing children due to the  disproportionate fear of contracting a virus for which the risk of  death is virtually zero.
        14. (xiv)  Significant increase in alcohol consumption and drug use.
        15. (xv)  Denial of access to healthy recreation including parks, beaches,  camping, cottages, and activities as golf, tennis, swimming, etc.
        16. (xvi)  Denial of a public education for children.
        17. (xvii)  Denial of access to consumer goods and services.
        18. (xviii)  Individuals dying alone in hospital and extended care facilities  without the support of family and friends. 203
        19. (xix)  Fathers denied access to be present for the birth of their child.
        20. (xx)  Elderly parents in supportive care are denied access to the support  of their family and friends.  203 https://globalnews.ca/news/6866586/bc-woman-disa.bility-dies-covid-19/
        21. (xxi) The effective closure of Courts of Law is unprecedented, illegal, unconstitutional, undemocratic, unnecessary, and impedes the ability of Canadians to hold our governments accountable.
        22. (xxii) The effective closure of Parliaments is unprecedented, illegal, unconstitutional, undemocratic, unnecessary, and impedes the ability of Canadians, including the Plaintiffs, to hold governments accountable. 
217. 217. The Plaintiffs further state, and fact is, that:
     1. (a) To combat COVID-19, "Canada's federal government has committed to measures totaling around $400 billion, of which about two-fifths constitutes direct spending." Currently, the deficit for 2019-2020 is expected to be well over $180-$200 Billion. This is seven times larger than the previous year's deficit. It is expected the interest alone, even at the very low current interest rates will cost $1 B each year. 204 
     2. (b) There is no evidence that the impact of these negative consequences were calculated, much less fully considered in the government's response to SARS-Co V-2i. 
     3. (c) John Carpay, president of the Justice Centre for Constitutional Freedoms in Canada has stated there is reason to conclude that the government's response to the virus is deadlier than the disease itself. 205 204 https://www.huffingtonpost.ca/ entry/ ca nada-budget-deficit-covid 19 ca Se85f6bcc5 b60bbd735085f4 205 htlps://w'!:f:t!.jccf.ca/the-cost-of-1he-coronavirus-cure-could-be-deadtter-.han-the-dlse11seL ( 
     4. d) The cost of combatting SARS-Co V-2 is placed disproportionately on the young and blue collar and service workers who cannot work from home, as opposed to white collar workers who often can. 
     5. (e) The results from Sweden, and other countries that did not engage in mass and indiscriminate lockdowns, demonstrates that other more limited measures were equally effective in preventing the overwhelming of the health care system, and much more effective in avoiding severe economic and individual health consequences. 
     6. (f) The Ontario government took the "extraordinary step" to release a database to police with a list of everyone who has tested.positive for COVID-1i9 in the province. 206 
218. 218. Furthermore, while upon the declaration of the pandemic, based on a totally erroneous modeling, postulated that, as opposed to regular 650i, 000 deaths every year form seasonal viral respiratory illness , world-wide, that 3 .5 Million may or would die, the erroneous COVID implemented measures have proven to be more devastating than the "pandemic" at its posited worse in that:
     1. (a) In Canada, as elsewhere, 170,000i+ medical, surgical, operations are canceled, with the numbers climbing, as well as closure of other medical services at hospital, which have caused deaths; 
     2. (b) With the fear of lock-downs and self-isolation, patients have not accessed their doctor for diagnosis of medical problems; 
     3. (c) Documented spikes of domestic violence and suicides have been recorded; 
     4. (d) Inordinate spike in alcoholism, drug use, and clinical depression; 
        
        206 hltps:1/toronto.ctvnews.calmobile/ontario-takes--extraordlnary-step-to-give-police-list-of-all-covid-9-patlents.1.4910950?fbclld=lwAR1 Ojfu 5OYq5BPZJKMyyqiN2P47dK wbZzFMqC8WEpFxilhEF!81cGnfru; (e) Moreover, and most-shocking, the UN through an official of the World Food Bank, on April 22ind,2i020, had published a document stating that, because of COVID-19 (measures )and the disruption of supply chain, it estimates that 130 Million "additional people" "on the planet could be on the brink of starvation by end of year 2020 which, begs the question: why is it justifiable to add 130 Million deaths to purportedly save 3.5 Million? 
219. 219. The Plaintiffs state, and the facts is, that the purported, and false, goals of the WHO measures and its purveyors, such as the Defendants, are a perpetual moving target, and purposely shift to an unattainable goals, in that:
     1. (a) The initial rationale for the mass lockdown of Canadian society was to "flatten the curve" to avoid overwhelming health care services. It was never about preventing the coronavirus from spreading altogether, but rather to render its spread manageable.
     2. (b) It appears now that the goal has changed. Government appears to have shifted the goal to preventing the virus from infecting any and all Canadians. If so, this ought to be made clear, as should the justification for the change. 207
     3. (c) Y oram Lass, the former director-general of Israel's Ministry of Health is of the opinion that "lockdown cannot change the final number of infected people. It can only change the rate of infection." 208 '07 https://nationalpost.com/opinion/raymond-j-de-souza-on-covid-19-a-lockd… 0/'/' htt ps :/ /www. spiked-on Ii n e. com/ 2020/05/2 2/ nothing-can-ju st ify-th is-d est ru ct i o n-of-pe op I es-I ives/ #. Xsgq i N 6 DOu Q. face book
     4. (d) There are warnings of an imminent "second wave." But if the "first wave" has been flattened, planked or buried to the extent that in vast areas of the country very few people have been exposed to the virus at all, then the "second wave" is not really a second wave at all, but a delayed first wave. 
     5. ( e) Minimizing the total spread of the coronavirus until a vaccine is available will be the most expensive goal in the history of human governance. 
     6. (f) There is no scientific evidence to substantiate that the elimination of the virus through self-isolation and physical distancing is achievable or medically indicated. 
     7. (g) According to four Canadian infectious disease experts, Neil Rau, Susan Richardson, Martha Fulford and Dominik Mertz -"The virus is unlikely to disappear from Canada or the world any time sooni" and "It is unlikely " 209 that zero infections can be achieved/or COVID-19.i
     8. (h) There is no compelling reason to conclude that the general-population lockdown measures (first requested by the Trudeau government on 17 March) had a detectable effect in Canada. The lockdown measures may have been implemented after "peak prevalence" of actual infections, which renders mitigation measures entirely without effect. 
     9. (i) The Government of Canada has been slow to endorse the re-opening of the economy even as hospitals remain well below capacity -the metric that was initially used to justify the restrictions. 

209 https://nationalpost.com/opinion/opinion-we-are-infectious-disease-expe… 

HI THE PROPOSED COVID-19 VACCINE-"WE DO NOT GET BACK TO NORMAL UNTIL WE HA VE AV ACCINE" 

220. 220. The Plaintiffs state, and the fact is, that the narrative and mantra created and propagated by Bill Gates that "we do not get back to normal until we have a vaccine" has been accelerated by a falsely declared "pandemic" to what has been a persistent push for mandatory vaccination of every human being on the planet, along with "global governance" as propagated by Bill Gates, Henry Kissinger, the Rockefeller Foundation, GAVI, the WEiF, and their likes. 
221. 221. With respect to (mandatory) vaccines and the COVID-19i, the áDefendants, in addition to pushing the ultimate aim of mandatory vaccines, spear-headed by Bill Gates, and others, have also ignored and refuse to address the issues in the context of COVID-19i, let alone vaccines at large, as reflected in, inter alia, the following:
     1. (a) Intention to Create Vaccine Dependency:Is it ethical to deny children, young people and most of the population who are at low risk of mortality the opportunity to develop natural immunity when we know natural immunity is lifelong in most cases? Are we going to create another condition where we become 'vaccine dependent' or will we recognize the value of natural herd immunity? Advocates of the natural herd immunity model are of the opinion that rather than the mass isolation of billions of people, only the most at-risk people and their close associates should be isolated. The forced mass quarantine of an entire, mostly low-risk population is disproportionate and unnecessary. This is the position being utilized by Sweden.210
     2. (b) Will A COVID 19 Vaccine Be Safe?
        1. (i) Dr. Anthony Fauci -is the director of the National Institute of Allergy and Infectious Diseases in the United States. Fauci has stated: "We need at least around a year and a half to make sure any new vaccine is safe and effective. " ill
        2. (ii) Dr. Paul Offit -Offit warns, "Right now you could probably get everyone in this country to get this (CV) vaccine because they are so scared of this virus. I think we should keep remembering that most people who would be getting this vaccine are very unlikely to be killed by this virus. "
        3. (iii) Dr. Peter Hotez -dean of the National School of Tropical Medicine at Baylor College of Medicine, told Reuters, "I understand the importance of accelerating timelines for vaccines in general, but from everything I know, this is not the vaccine to be doing it with. " (. . . . 211 1v ) p a th ogemc p nmmg ; 210 https;ljvaccinechoicecanada.com/in-the-news/will¥a¥covid-19-vaccine-save-us/ 211 hllps;ljwww.sctencedirect.com/science/article/pii/52589909020300186?via%3Dihub=…"l
     3. (c) Jonathan Kimmelman, a biomedical ethics professor at McGill University in Montreal, 1s watching how both scientific and ethical standards are maintained while the pandemic vaccme trials progress at breakneck speed. "My concern is that, in the fear and in the haste to develop a vaccine, we may be tempted to tolerate less than optimal science," Kimmelman said. "That to me seems unacceptable. The stakes are just as high right now in a pandemic as they are in non-pandemic settings. "To show how long the process can take, Kimmelman points to the example of the ongoing search for an effective HIV vaccine that began in the 19i90is. Before healthy people worldwide receive a vaccine against SARS-Co V-2, the risk/benefit balance needs to tip in favor of the vaccine's efficacy in offering protection over the potential risks, he said. The balance still exists even in the face of a virus wreaking an incalculable toll on human health and society." 212
     4. (d) CBC News March 24i, 20i20 reported by Amina Zafar;213
     5. (e) Moderna's vaccine uses genetic material from the virus m the form of nucleic acid. That tells the human body how to make proteins that mimic viral proteins and this should provoke an immune response. Denis Leclerc, an infectious diseases researcher at Laval University in Quebec City, said the advantage of nucleic acid vaccines like Moderna's is that they're much faster to produce than other types. While relatively safe, nucleic acid vaccines are generally not the preferred strategy, Leclerc said, because they don't have the same safety record as the traditional approach. 212 hittps://www.cbc.ca/news/canada/coronavirus-covidl9-aprill6-canada-world-l.55340… 213 https://www .cbc.ca/news/health/covid-19-vacci n e-resea rch-1.5497697
     6. (f) Will a COVID 19 vaccine be effective?Ian Frazer -Immunologist Ian Frazer has downplayed the role of a vaccine in overcoming the coronavirus pandemic, saying it may "not stop the spread of the virus in the community". That's if a vaccine can be developed at all. Frazer, a University of Queensland scientist who was recognized as Australian of the Year in 2006 for his contribution to developing HPV vaccines, said a COVID-1i9 vaccine may not be the end-all to the current crisis. 214 
     7. (g) Role of Influenza Vaccination to Current Outbreak -Allan S. Cunningham, Retired pediatrician The possibility that seasonal flu shots are potential contributors to the current outbreak. A randomized placebo-controlled trial in children showed that flu shots increased fivefold the risk of acute respiratory infections caused by a group of non influenza viruses, including coronaviruses.215 
     8. (h) Mandatory Vaccination
     9. (i) Diane Doucet -Message to New Brunswick Committee on Law Amendments"Mandatory vaccination may soon be imposed on the entire population. Eventually, every person will have to decide between attending school, keeping their job, their home and their ability to participate in society and their so-called freedom to choose. People will also be at risk of losing their jobs if they speak out against mandatory vaccinations. 

We are not talking about quarantining individuals infected by a disease. We are talking about the segregation of healthy children and adults from participating in society. Their crime is that they do not consent to handing over their bodies to the tyrannical will of a vaccine cartel which is accountable to no one. 
214 https://7news.corn.au/lifestyle/health-wellbeing/coronavirus-australia-…¥of vaccine-in-pandemic-c-983647 
215 flllps-.//www.bmj.com/conLenl/368/bmj.m810/rr-O 
The policy makers look down upon the citizenry with arrogance. We live in a system that views the common people as being too ignorant to decide what's best for themselves and their children. When corporations, health agencies and government institutions treat people like chattel and punish those who do not submit, you have slavery. If an institution can take it upon itself and do what it wants to people's bodies against their will, then you live in a slave system. We find ourselves here today, wondering how we managed to slip this low." 

¥ Microchipping  /Immunity  Passports/  Social  Contact  Vaccine  Surveillance & SG  

222. 222.  The Plaintiffs state that, and fact is, this global vaccination scheme which is being propelled and pushed by the Defendants, is with the concurrent aim of total and absolute surveillance of the Plaintiffs and all citizens.  
223. 223.  In  addition  to  the  facts, pleaded  with  respect  to Gates'  vaccine-chip,  nannocrystal "app" already developed, in late June, 2020i, cell-phone companies,  at  the  request  of  Justin  Trudeau  that the 30i-Miillion  eligible  Canadians  "voluntarily" load up "contract-tracing apps" now available from the phone-tech  giants. These companies began dumping the apps on to customers without  informed consent.  
224. 224.  On June 30it1\ 2020i, Canada announced that it was participating, to be included,  as one of an initial fifteen (15) countries, to require "immunity passport", a cell. phone application disclosing medical vaccination history.216 Canada is one of an  initial fifteen (15) countries to enter into  a  contract to deploy "immunity  216https ://www. mintpressnews.com/mass-tracki nq-covi-pass-i m mu nity-passports.slated-roll-15-cou ntries/269006/ passport" technology. The technology would utilize a cell-phone application to disclose medical vaccination history. 217 
225. 225. The Plaintiffs further state, and the fact is, that above and beyond what is set out above in the within Statement of Claim, mandatory vaccination, for any disease, let alone a virus, is a flagrant violation of the Plaintiffs' Charteri, and written constitutional rights, under s. 2 and 7 of the Charter, to freedom of belief, conscience, religion, and life liberty and security of the person as a violation of physical and psychological integrity, where informed medical consent is absent in a mandatory scheme. 

¥ Vaccines in General 

226. 226. The Plaintiffs state, and the fact is that: 
     1. (a) it is undisputed that vaccines cause severe, permanent injury up to and including death in a certain percentage of those who are vaccinated, including physical, neurological, speech, and other disabilities; 
     2. (b) that, as a result of this reality, risk, and severe injury, certain North American jurisdictions, such as the USA, and Quebec, as well as all G.7 countries except Canada, have established compensation schemes for those injured and killed by vaccines;
     3. (c) that Ontario has no such compensation scheme; 
     4. (d) that there is no individual pre-screening, to attempt to pre-determine, which individual may have a propensity to be so injured, even in cases where older siblings, in the same family have been injured, no 
     5. ( e) the Plaintiffs state, and the fact is, that while peanuts and other nuts, as an absolute proposition, do not injure or kill, they do injure or kill those who are allergic to them. While schools have taken saturated and heightened steps to make their spaces "nut-free", the risks of vaccines to children, particularly those who are pre.disposed to injury and death from them, are completely ignored. 
        
        217 https://www.mintpressnews.com/mass-tracking-covi-pass-immunity-passport… 
        investigation is undertaken or weighed with respect to the risks of their younger siblings being vaccinated;
         
227. 227. The individual, biological Plaintiffs state that they further rely on the facts set out below under the Plaintiff heading "Vaccine Choice Canada (VCC)". 
228. 228. The individual, biological Plaintiffs state that the compulsory vaccinationi, and or testing, schemes violates their rights, by act and omission. Mandatory vaccination removes the right to weigh the "risks" of vaccinating or not vaccinating, to allow for informed choice, in that vaccines can cause injury or death, is a violation of their rights as follows: 
     1. (a) an in limine compulsory vaccination scheme violates s.2(a) and (b) of the  Charter in infringing the rights to freedom of conscience, religion, thought and  belief, as well as infringing the rights to liberty and security of the person, in interfering with the physical and psychological integrity of the person and the  right to make choices as to that integrity and autonomy, pursuant to s.7 of the  Charter;
     2. (c) that the failure and omissions of the Defendants, their officials and delegees, in the vaccination scheme, to transparently and honestly present the risks of vaccination, pro and con, and the failure and omissions to make individual assessments to pre-determine and pre-screen those children who may have a propensity and pre-disposed to being vaccine injured, constitutes a violation of the same Charter cited above, in depriving the right to an informed consent before medical treatment through vaccine is compulsorily administered, by way of omission as set out by the Supreme Court of Canada in, inter alia, Vriend in unnecessarily exposing children and adults, to injury up to and including death, by an overly-broad, untailored, indiscriminate and blind vaccination scheme, notwithstanding the dire and pointed warnings in the manufacturers' own very inserts and warnings as to the risks. 
229. 229. The Plaintiffs state that the violations of their ss. 2(a) and (b) Charter rights are not justified under s.1 of the Charter and puts the Defendants to their onus of justifying the violations. The Plaintiffs further state that the violations of their s. 7 Charter rights, as set out above in the statement of claim, are not in accordance with the tenets of fundamental justice in that the scheme and provisions suffer from overbreadth and that the protection of overbreadth in legislation has been recognized, by the Supreme Court of Canada, as a tenet of fundamental justice, and that further they cannot be saved under s.1 of the Charter, the onus of which lies with Defendants. 

¥ Vaccine Choice Canada (VCC)

230. 230. Vaccine Choice Canada is a federally registered not-for-profit educational society. VCC is committed to protecting children's health by informing parents 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. Vaccine Choice Canada was originally incorporated as the Vaccination Risk Awareness Network (VRAN) in 1982i. It changed its name to Vaccine Choice Canada(VCC) in 20i14i. 
231. 231. In the 3 8 years that Vaccine Choice Canada, and its predecessor organization, has been involved in reviewing the vaccine safety literature, supporting families in their vaccine decisions, and developing educational materials related to vaccine safety, efficacy and necessity, so that individuals can make responsible and informed decisions, VCC has noted, uncovered, and researched certain established facts as set out below. 
232. 232. VCC states that, with respect to facts pertinent to product safety testing, the facts and medical literature sets out that: 
     1. (a) Vaccines do not undergo the same level of safety testing as is required for all other drugs and medical products. 
     2. (b) None of the vaccines licensed for use in Canada have been tested for safety using long-term, double blind, placebo-controlled studies. 
     3. (c) Vaccine products licensed for use in Canada are not evaluated for safety using a neutral placebo, 218 a requirement for all other pharmaceutical products. 
     4. (d) Vaccines are an invasive medical intervention whose safety is determined primarily by the amount of injury or death reported after vaccination. 
     5. (e) Pre-licensing safety monitoring of childhood vaccines, prior to the vaccines being administered, is not long enough to reveal whether vaccmes cause autoimmune, neurological or developmental disorders. 219 
     6. (f) Studies designed to examine the long-term effects of the cumulative number of vaccines or other aspects of the vaccination schedule have not been conducted. 220 
     7. (g) There are too few scientifically sound studies published in the medical literature to determine how many serious brain and immune system problems ¥ 221 are or are not cause db y vaccmes.
     8. (h) The design and reporting of safety outcomes in MMR vaccine studies, both . .. 222 pre-an d k 1 1 d post-mar etmg, 1s arge y ma equate.
     9. (i) Vaccines have not been tested for carcinogenicity, toxicity, genotoxicity, mutagenicity, ability to impair fertility, or for long-term adverse reactions. 
     10. (j) Health Canada does not conduct its own independent clinical trials to determine vaccine safety and efficacy and instead relies on the data provided by the vaccine manufacturers. 
     11. (k) Studies comparing the overall health of vaccinated and unvaccinated children reveal that vaccinated children are significantly more likely to have neuro.developmental disorders and chronic illness. 
     12. (l) There is evidence that vaccines are contaminated with unintended ingredients and that the health impact of injecting these ingredients is unknown. 224 
     13. (m) Canada is the only G7 Nation without a national program to compensate those injured or killed by vaccination, and one(l) of two(2) G-20 Nations without a vaccine injury compensation program. The other nation being Russia. 
     14. (n) The United States Vaccine Injury Compensation Program has awarded more than $4e.1 billion in compensation since 1989. 
     15. (o) The published medical literature recognizes that vaccines can cause permanent injury including death.
     16. (p) The US government has acknowledged that vaccination can cause brain damage resulting in symptoms of autism in genetically susceptible children. 
     17. 225 ( q) The US Centre for Disease Control (CDC )has acknowledged that every domestic case of polio that occurred after 1979 was caused by the vaccine . 226 stram o f po 1á 10. 
     18. (r) Vaccines include ingredients that are classified as poisons, carcinogens, toxins, neurotoxins, immune-and-nervous-system disruptors, allergens, fertility inhibitors, and sterilizing agents. 
     19. (s) Health Canada exposed children to cumulative levels of mercury and aluminum, in the incubation of the vaccines that exceeded the US FDA's safety guidelines. 

233. VCC states that, with respect to the facts pertinent to screening for susceptibility to vaccine injury, that: 

1. (a) Pre-screening to identify individuals who may be at increased susceptibility to vaccine injury and death does not occur in Canada. 
2. (b) Health Canada has not committed resources to identify those individuals who may have increased susceptibility to experience vaccine injury or death. 
3. (c) Policies to administer vaccines to "Mature Minors", often without the knowledge and consent of the parents and without the informed consent of the "Mature Minor",, in schools and medical settings without the knowledge or consent of the parents has inadequate safety protocols to fully consider the personal and family medical history prior to vaccination. 
4. ( d) This failure to fully consider personal and family medical history puts these youth at increased risk of vaccine injury. 

234. VCC states that, with respect to the facts pertinent to monitoring of adverse effects of vaccination, that: 

1. (a) Doctors and health care workers are not trained to recognize and diagnose vaccine lllJury. 
2. (b) There are no legal consequences when medical professionals fail to report vaccine mJury. 
3. (c) Parents' observations of health and behavioral changes following vaccination are routinely ignored and denied by doctors and rarely captured in adverse events reporting systems. 
4. (d) It is recognized that fewer than 1 % of vaccine adverse reactions are reported. 227 (e) Ontario's AEiFI reporting system has lower reporting rates than other provinces. 
5. (f) The medical industry has failed to fully consider the combined toxicology of vaccine ingredients and the synergistic effect of combining vaccine ingredients. 

228 
230. VCC states that, with respect to the facts pertinent to safeguarding policy over patient health, that:

1. (a) The primary metric used by Health Canada to measure the success of the vaccine program appears to be how many vaccines are delivered. 
2. (b) The goal of public health vaccine policy is to persuade parents to comply with the full vaccine schedule. 229 
3. (c) The pursuit of the goal of persuading parents to comply with vaccination recommendations is incompatible with the goal of allowing parents to possess the knowledge they need to exercise their right to informed consent, and act in their child's best interests. 
4. d) The right to informed consent has been recognized as one of the most fundamental ethics in medicine. 
5. (e) Public health professionals routinely fail to inform citizens of their legal right to personal, religious and medical exemptions where they exist. 
6. (f) Health Canada, with respect to vaccmes, places public policy over individual health considerations. 
7. (g) Government policy makers have refused to consider the fact that the risks of the target diseases are not the same for every child and that some children are at greater risk of being harmed by vaccines due to genetic or environmentally caused predispositions. 
8. (h) Government policymakers ignore that the fact that for informed consent to happen, the risk-benefit analysis must be conducted for each vaccine and individually for each child. 
9. (i) Antibody titre testing is rarely conducted in an effort to avoid unnecessary vaccination. 
10. j) An increasing number of parents are choosing not to vaccinate because they recognize that public health vaccine policy poses a serious threat to both their health and liberty. 

235. VCC states that, with respect to the facts pertinent to lack of accountability for vaccine Injury, that:

1. (a) Vaccine manufacturers and medical professionals are not held legally and financially accountable when vaccine injury and death occurs. 
2. (b) A consequence of this legal immunity is that there is no legal or financial incentive for the vaccine industry to make their products safer, even when there is clear evidence that vaccines can be made safer. 
3. (c) Systemic corruption within the medical establishment is well recognized within ¥ ¥ 230a23a1 t h e sc1ent1 'fi 1c commumty. 
4. (d) Conflicts of interest in biomedical. research are "very common". 232 

236. VCC states that, with respect to the facts pertinent to informed consent, that Consumers are rarely informed that:

1. (a) vaccines do not confer life-long immunity; 
2. (b) not all vaccines eliminate susceptibility to infection; 
3. (c) not all vaccines are designed to prevent the transmission of infection; 
4. (d) most vaccines do not alter the safety of public spaces; 233 
5. (e) Health Canada has acknowledged that vaccines are voluntary in Canada and cannot be made mandatory due to the Canadian Charter of Rights and Freedoms; 
6. (f) there is no scientific evidence that herd immunity can be achieved using vaccines due to the temporary nature of the immunity offered nor that vaccine herd immunity is more effective that natural herd immunity; 
7. (g) vaccine can and do cause permanent injury and death; 
8. (h) there is no scientific evidence that vaccines are primarily responsible for reduced mortality over the last century as is often claimed; 
9. (i) the human body has an innate capability to fight off infections and heal  itselfi;
10. (j) the pharmaceutical companies that produce almost all vaccines have been found guilty and paid billions of dollars in criminal penalties for research fraud, faking drug safety studies, failing to report safety problems, bribery,  kickbacks and false advertising 234;
11. (k) Canadian children are among the most vaccinated children in the world
12. (l) there is no compensation available in Canada, except for Quebec, should  vaccination result in injury or death;
13. (m)only two provinces in Canada (Ontario and New Brunswick) reqmre  exemptions to decline vaccination;
14. (n) recommended/required vaccmes vary by provmce, by state, and by country.  

237.  Consumers are rarely provided with the product monograph (product information insert) by health care providers. Vaccines monographs warn of limitations to vaccine safety testing as well as recognized adverse events following vaccination which include severe and permanent injury and death.  

238. Vaccine mandates violate the medical and legal ethic of informed consent.  

239. Vaccine mandates violate 'The Universal Declaration of Bioethics and Human  Rightsi', the Nuremberg Code, professional codes of ethics, and all provincial  health Acts.  

240. A review of the transcripts of the vaccine education materials produced by the Ontario government reveal that the risk of vaccine injury is discussed superficially, and that consumers are given insufficient information to make an informed decision. 
241. A review of Public Health Agency of Canada recommended curriculum for school children reveals that education on the risk of vaccine injury is absent, as is education on the right to informed consent. 235 
242. The vaccine risk information provided to consumers varies by health region. 
243. Vaccines are routinely administered to youth in medical clinics and school settings without the knowledge or consent of their parents. 

244. Youth vaccinated in school-based clinics routinely report being intimidated into vaccination and being threatened with expulsion if they refuse vaccination. 

245. Public health presents as if all vaccines carry the exact same risk/benefit assessment for all individuals. 
246. Individual benefit versus individual risk of vaccination is rarely considered. 

247. Indigenous people are required to receive vaccines other than those required for non-Indigenous people based on assumed risk, not upon medical evidence of risk. 

248. VCC states that, with respect to the facts pertinent to the Immunization of School Pupils Act (ISP A), that:

1. ( a) Only school children are mandated to provide their medical records under ISP A. Adults are not required and are less likely to be 'up to date' with their vaccinations. 
   235 https :/ /kidsboostimmunity .com/sites/default/files/reusable_ files/kbi_ be pdf 
2. (b) The forced disclosure of private medical records puts a child's medical privacy at risk.
3. (c) This disclosure often results in the child being ostracized by school staff and peers. 
4. (d) The ISP A does not give the medical officer of health authority to suspend a student. Only a principal can suspend a student from school. The Education Act does not have any section that allows a principal to suspend for lack of medical records. Yet this is routinely done for those who do not, or refuse, to comply with the mandatory scheme. 
5. (e) Parents who do not comply with unlawful suspension are threatened with child protection services. 
6. (f) Children who are under vaccinated or without exemptions are intimidated, held in the office, and incorrectly told by school officials that they need to get their shots or they cannot come to school. 
7. (g) The HSARB (Health Service Appeal and Review Board), which deals with appeals of suspensions, registration and expulsions, cannot rule on Charter challenge cases, as the enabling legislation specifically bars jurisdiction to adjudicate Charter issues. 
8. (h) There is zero accountability for violations of rights by the medical officer of health. This has resulted in many cases of the Medical Officer of Health unlawfully suspending young children for 60 to 90 school days, contrary to the 20 days suspension as set out in the ISP A. 

I/iTHE MEDIA 

249. 249. The Plaintiff states that the Defendant CBC, and other mainstream media, is purposely suppressing valid, sound, and sober criticism of recognized experts with respect to the measures that amount to censorship and violation of freedom of speech, expression and the media. 
250. 250. The Plaintiffs state, and the fact is, that CBC, a completely publicly-funded news service, and national broadcaster, paid for by Canadian taxpayers, has been to the Trudeau government, and acted as, PRAVDA was and acted for the Soviet Union in the cold-war, with respect to coverage of the COVID."pandemic", "emergency", and its draconian measures. 
251. 251. The Plaintiffs state that CBC, as the nationally and publicly-funded broadcaster under the public broadcasting policy for the Canadian public, under the Broadcast Act, owes: 
     1. (a) a Fiduciary duty to the Plaintiffs and all citizens; and 
     2. (b) a duty in Negligence (negligent investigation) to the Plaintiffs and all citizens; To be independent, fair, balanced, and objective in its coverage of the "pandemic", declared "emergency", and the measures undertaken, which duties it has breached causing damages to the Plaintiffs. 

¥ Negligence 

252. 252. The Plaintiff states that the Defendant, CBC, as a publicly-funded mandate to publicly broadcast on behalf of Canadians, owes a common-law, and statutory duty of care to the Plaintiffs, to fairly, independently, objectively report, and engage in responsible journalism, on the news and current affairs, and the Plaintiffs further state that:
     1. (a) the CBC breached that duty of care; and 
     2. (b) as a result of the breach of that duty of care, the Plaintiffs suffered damages. 
253. 253. The Plaintiff states and the fact is, this duty was breached by the CBC's negligent acts and omissions, including inter alia, the following:
     1. (a) The daily broadcasting of Trudeau's press-conferences, with absolutely no questions about the scientific and medical evidence behind the measures, and their source; 
     2. (b) Whether contrary expert views exist, to the secret advice being followed; 
     3. (c) If opposite, expert opinion exist, what is the government's response to it?; 
     4. (d) The CBC further dumps, on a daily basis, the government numbers on COVID-positive rates, and death rates, without any investigation or scrutiny as to the basis of compiling those numbers, and who and how the parameters are determined in complying those numbers nor any contextual analysis as to what they mean; 
     5. (e) The CBC has done no independent investigation, nor asked any questions, on the scientific or medical basis of the COVID-measures but simply parrots the government line, and has not investigated, exposed, nor published the avalanche of Canadian and World experts who firmly hold an opposite view, and severe criticism of the measures, nor put those criticism to the Federal Defendants for response. 

254. In short, the Plaintiffs state, and the fact is, that CBC has breached its duty of care to the Plaintiffs, and has not acted in a fair, independent, objective, and responsible manner, but has acted in a manner more akin to a propagandistic state news agency serving a dictatorial regime. 

255. The Plaintiffs state, and the fact is, that CBC has actually gone far beyond the above in that, in the rare instance CBC pretends to tackle an opposite view, CBC irresponsibly belittles, and in fact intentionally misleads, the Plaintiffs and viewers. For example, in a story published May 215 \ 2020e, written by CBC's Andrea Bellemere, Katie Nicholson and Jason Ho entitled "How a debunked COVID-19 video kept spreading after Faeebook and YouTube took it down", these "reporters" falsely and intentionally distort with respect to the video in question entitled "Plandemic". In the story they refer, with a picture, to a person CBC describes as: "featuring controversial virologist Judy Mikovitz". In the story, these three "reporters" choose to: 
(a) Delete the fact that it is Dr. Judy Mikovitz, Ph. D., is a recognized expert in virology who worked at the Centre for Disease Control (CDC) with Anthony Fauci, with whom she had serious disagreement which she documented in her book entitled "Plague Corruption"; 
(b) That she continues to work in, and be recognized as an expert in virology; 

( c) The "reporters" do not give a hint as to by whom, when, on what medical basis her expert views were "debunked";

(d) Nor do the "reporters" investigate, nor pose any questions, about why it is appropriate to remove from Face book, or Y ouTube, the views of a recognized, working World expert, of virology, with respect to issues of COVID-1i9. This conduct by these "reporters" and CBC, is intentional at worst, and depraved and gross negligence at best. 

¥ Fiduciary Duty 

256. 256. The Plaintiffs further state that the CBC further has a fiduciary relationship, and owed a corresponding fiduciary duty, to the Plaintiffs, as the national publicly.funded broadcaster to fairly, independently, objectively report, and engage in responsible journalism, on the news and current affairs for the following reasons: 
257. 257. The Plaintiffs state that the Defendants breached this fiduciary duty as set out above in this Statement of Claim. 
258. 258. The Plaintiffs state, and the fact is, that CBC, Facebook, YouTube , Google, and other social media are viciously censoring, and removing any and all content that criticizes or takes issue with the WHO, and governments that follow WHO guidelines, with respect to covid-1i9i, as purported "misinformation" contrary to "community standards" even when that content is posted by a recognized expert. 
259. 259. The Plaintiffs further state, and the fact is, that the Defendant Federal Crown is by way of act and omission, under inter alia, the Broadcast Act , and its Agencies such the CRTC, legislatively and administratively violating the Plaintiffs' rights under s. 2 of the Charter, to freedom of expression and the press in doing nothing to halt what has been described by members of the scientific community as " Stalinist censorship", by government, along with media the likes of CBC, Facebook, and YouTube. In fact, the Federal Crown goes further, in following suit with these social media censors, to propose criminal sanctions for posting such deemed and anointed "misinformation" by all, including experts. 
260. 260. On or about end of May, 2020 the UK " Scientific Advisory Group for Emergency (SAGEi) -COVID-19 Response, in response to the unwarranted measures of redaction, and removing, all criticism in respect of COVID.Measures, from the Report, of this government advisory body, the body responsible for their SAGE report referred to the government redaction as "Stalinist Censorship". 
261. 261. The Plaintiffs state, and the fact is, that CBC, Facebook, and Y ouTube, and other major social media, in their coverage of the COVID-19i, have acted in the same fashion, by knowingly and intentionally suppressing and removing expert opinion not in line with the official dogma of the WHO, which is being blindly and deafly parroted and incanted by the Defendant governments (leaders) and their officials, to the detriment of the Plaintiffs and citizens at large, in violation of their constitutional rights. 

JI SUMMARY 

262. 262. In summary, the Plaintiffs state that the COVID -19 Legislation, and Regulations By-Laws, and orders, violate, as follows, the Plaintiffs' statutory and constitutional rights in: 
263. 263. The Plaintiffs rely on: 
264. 264.  The Plaintiffs therefore request:
265. 265.  The Plaintiff proposes that this action be tried in Toronto.