here. - Koskie Minsky LLP

4 2584 875 To advise if the defendant owed a duty of care over the full
time frame to ensure that complaints of physical or sexual
abuse were pursued and investigated.
5 2591 877 To advise if it's the defendant's position that it owed a duty of
care to the resident class between 1976 and 2009 to provide for
an ombudsman function to carry out independent reviews of
abuse allegations.
Resident Abuse Policies and Procedures
6 1252 456 To provide a copy of the grievance referenced in paragraph 1
of Document CR006547 (marked as Exhibit “H”).
7 1531 528 -
529
8 1801 633 -
634
To identify the documents upon which the defendant relies to
support the portion of its Statement of Defence (marked as
Exhibit “B”) that asserts that during the class period, the
institution had appropriate policies and procedures in place
during the whole time-frame with respect to staff policies
respecting resident abuse.
With respect to para. 25 of the Statement of Defence (marked
as Exhibit “B”) regarding mistreatment or abuse, to advise as
to what facts and documents the defendant relies on to
establish that it met the appropriate standard of care or
fiduciary duty that would have been applicable during the class
period in regard to the general method or system that was used
by the defendant to (a) substantiate allegations of abuse, if the
defendant did, and (b) taking the appropriate steps, including
dismissal and reporting to authorities.
To ascertain the
defendant’s position
regarding the content of its
duty of care.
To ascertain the
defendant’s position
regarding the content of its
duty of care.
To determine whether
allegations of abuse were
dealt with appropriately by
the defendant.
To determine the basis on
which the defendant
substantiates its claim that
it met the standard of care
with respect to staff
policies respecting resident
abuse.
To determine the basis on
which the defendant
substantiates its claim that
it met the standard of care
with respect of dealing
with allegations of abuse.