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30 2578 873 To advise if it's the defendant's position that it did not owe a duty of care to the class for the full time frame, to ensure that prevailing standards regarding staff to patient ratios were ad<strong>here</strong>d to. 31 2585 875 To advise if the defendant owed a duty of care to the residents between 1945 and 2009 to ensure that the employees were qualified and subjected to appropriate criminal and other background checks. 32 2593 878 To advise as to what the defendant's position is on whether it owed a duty of care to the residents between 1976 and 2009, to increase the level of evening supervision over residents generally. 33 2594 878 To advise as to what the defendant's position is on whether it owed a duty of care to the residents between 1976 and 2009, to provide employees with training courses to ensure their proper understanding of residents' rights, discipline and policies. 34 2595 878 To advise as to what the defendant's position is on whether it owed a duty of care to the residents between 1976 and 2009 to designate certain units as "psychiatric" for residents with serious behavioural problems. 35 2596 879 To advise as to what the defendant's position is on whether it owed a duty of care to the class between 1976 and 2009 to ensure that staff-to-resident ratios were raised to the 1971 AAMD Standards. To ascertain the defendant’s position with respect to the contents of its duty of care respecting staff to patient ratios. To ascertain the defendant’s position regarding the content of its duty of care respecting the hiring of employees. To ascertain the defendant’s position with respect to the contents of its duty of care respecting supervision of residents. To ascertain the defendant’s position regarding the content of its duty of care with respect to training employees. To ascertain the defendant’s position with respect to the contents of its duty of care respecting the care of residents. To ascertain the defendant’s position with respect to the contents of its duty of care respecting staff to patient ratios.
Staff training and Qualifications, Policies and Procedures 36 1792 629 - 630 To advise as to what specific material facts and documents the defendant relies on in support of para. 24 of the Statement of Defence (marked as Exhibit “B”) for the entire class period. In particular, to advise of any facts or documents the defendant relies on that deal with when t<strong>here</strong> was a material change in the method that the defendant used to adequately and appropriately train and supervise employees of Her Majesty who worked at HRC. Defendant’s Compliance with Standard of Care 37 1803 - 1806 635 - 638 To advise as to what facts or documents the defendant relies on in support of the plea set out in the Statement of Defence (marked as Exhibit “B”) regarding whether the acts of Ontario were, in the entire class period, consistent with the approach of other provinces of Canada with respect to the standard of care. In addition, to advise as to what efforts Ontario might have made during that time period to determine whether other provinces were doing more or less than what the Ontario facilities were doing. In particular, to determine if HRC was consistent or better than what other provinces were doing. To determine the basis on which the defendant substantiates its claim that it met the standard of care with respect to training and supervision of employees. To determine the basis on which the defendant substantiates its claim that it met the standard of care with respect to the operation of HRC.
Page 1 and 2: ONTARIO SUPERIOR COURT OF JUSTICE C
Page 3 and 4: - 3 - m) the costs of this motion o
Page 5 and 6: - 5 - o) On July 8, 2012 Justice Ho
Page 7 and 8: - 7 - November 23, 2012 KOSKIE MINS
Page 9 and 10: Schedule “A” REFUSALS Question
Page 11 and 12: 9 1834 650 With respect to para. 69
Page 13 and 14: 14 2895 950 Regarding CR109385 (mar
Page 15: 26 1414 500 To identify the doc ID
Page 19 and 20: 42 2571 869 - 870 With respect to t
Page 21 and 22: Funding Decisions 50 1852 658 - 659
Page 23 and 24: Staffing Levels 57 3273 1065 - 1066
Page 25 and 26: CR084103, CR084134, CR084135, CR136
Page 27 and 28: 3 3350 - 3353 1087 - 1089 Regarding
Page 29 and 30: 6 1845 654 Advise if there are any
Page 31 and 32: 5 2323 798 Advise as to the outcome
Page 33 and 34: 13 3122 1020 Regarding CR044315 (ma
Page 35 and 36: Class Membership Information 7 1241
Page 37 and 38: 8 3271 1064 To identify the sex of
Page 39 and 40: 14 1270 460 - 461 Advise whether th
Page 41 and 42: etc. The allocation of the surplus
Page 43 and 44: 21 2330 800 Regarding CR198356, if
Page 45 and 46: 44 3314 1018 Regarding CR083963 (pa

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