here. - Koskie Minsky LLP

47 1832 649 To advise as to whether the defendant concedes that if the
events described in para. 66 of the Statement of Defence
(marked as Exhibit “B”) occurred, whether this would
constitute either a breach of the duty of care or a breach of the
fiduciary duty or both.
48 2583 875 To advise if the defendant owed a duty of care to the class over
the full time frame to ensure that residents were clothed and
sanitary.
49 646 - 647 233 -
235
To advise if it is Mr. Low's knowledge and understanding that
no one was ever kept at Huronia against their will.
To ascertain the
defendant’s position with
respect to the contents of
its duty of care respecting
the care and supervision of
residents.
To ascertain the
defendant’s position with
respect to the contents of
its duty of care respecting
the care of residents.
To determine whether the
defendant was in
compliance with
appropriate discharge
policies.