here. - Koskie Minsky LLP

Funding Decisions
50 1852 658 -
659
With respect to para. 61 of the Statement of Defence (marked
as Exhibit “B”), to produce all documentation which would
establish that the decisions referred to in this paragraph were
made at the highest levels of government, including any
cabinet minutes or documents that would be in existence for
the relevant time period. The plaintiff takes the position that to
the extent that any cabinet privilege would apply to those
minutes or documents, either the privilege no longer attaches
because of (a) the passage of time under the applicable statute,
or (b) the defendant has waived the privilege by pleading this
defence and putting the Crown's state of mind in issue with
respect to those at the highest levels of government, which the
plaintiff presumes would include the premier and members of
the executive council. The undertaking includes production of
all cabinet documents from any time after 1945 up until 2009
which in any way relate to decisions about the funding of HRC
as outlined in para. 61.
To determine the basis for
the assertion that
inadequacies at Huronia
were the result of funding
decisions made the
government.
Duty of Care - Residential Facilities
51 2577 873 To advise if it's the Crown's position that the defendant owed a
duty of care over the full time frame to ensure that the resident
population did not exceed the approved bed capacity.
52 2579 873 -
874
To advise if it's the Crown's position that it owed a duty of care
to the class over the full time frame to ensure that the physical
facility didn't present fire hazards to the residents.
To ascertain the
defendant’s position with
respect to the contents of
its duty of care respecting
population levels.
To ascertain the
defendant’s position with
respect to the contents of
its duty of care respecting
to fire hazards.