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here. - Koskie Minsky LLP

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Schedule “B”<br />

DEFICIENT UNDERTAKINGS<br />

Question<br />

No.<br />

Page<br />

No.<br />

Specific undertaking Crown’s Response Deficiency Disposition by<br />

the Court<br />

Defendant’s Compliance with Standard of Care<br />

1 1178 426 Advise as to which of the<br />

specific recommendations<br />

set out in the Willard<br />

report (marked as Exhibit<br />

“DD”) were not complied<br />

with by the Crown.<br />

Willard was appointed pursuant to section<br />

6 of the Ministry of Community and Social<br />

Services Act. Section 6 authorizes the<br />

appointment but does not oblige the<br />

Minister in any way as it relates to the<br />

recommendations or report that may issue<br />

as a result. However, all 69<br />

recommendations from the Willard report<br />

were considered and responded to. The<br />

intent of each recommendation was<br />

considered as specific decisions were<br />

made. The recommendations were just<br />

that, recommendations for consideration,<br />

not directives that were required to be<br />

followed exactly.<br />

This answer is not<br />

responsive to the<br />

undertaking. The<br />

answer should set<br />

out how each<br />

recommendation<br />

was specifically<br />

complied with, or<br />

not. Documents<br />

CR146351<br />

CR192119 not<br />

produced.<br />

See documents CR006627, CR007077,<br />

CR007100 (which will be provided under<br />

separate cover), CR007105, CR030990,<br />

CR032764, CR034753 (which will be<br />

provided under separate cover),<br />

CR034755 (which will be provided under<br />

separate cover), CR034770, CR044136,<br />

CR051312, CR051313, CR051584,<br />

CR051585, CR052584, CR071336,

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