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MARILYN DOLMAGE, et al. Plaintiffs and HER MAJESTY THE QUEEN IN RIGHT OF THE PROVINCE OF ONTARIO Defendant Court File No. CV-09-367927CP00 ONTARIO SUPERIOR COURT OF JUSTICE Proceeding commenced at Toronto Proceeding under the Class Proceedings Act, 1992 NOTICE OF MOTION PLAINTIFFS PHASE I DISCOVERY MOTION (RETURNABLE FEBRUARY 8, 2013) KOSKIE MINSKY <strong>LLP</strong> 900-20 Queen Street West Toronto, ON M5H 3R3 Kirk M. Baert LSUC#:30942O Tel: (416) 595-2117 Fax: (416) 204-2889 Celeste Poltak LSUC# 46207A Tel: (416) 595-2701 Fax: (416) 204-2090 Lawyers for the Plaintiffs
Schedule “A” REFUSALS Question No. Page No. Specific question Relevance Disposition by the Court Duty of Care –Resident Abuse 1 2574 871 - 872 To advise whether it is the Crown's position that it owed a duty of care to the resident class over the full time frame to ensure that residents were not physically abused by staff or other residents. 2 2575 872 To advise if the defendant owed a duty of care over the full time frame to ensure that residents were not sexually abused by staff or other residents. 3 2580 874 To advise if it is the defendant's position that it owed a duty of care to the class over the full time frame to ensure that reports of any alleged criminal activity on the premises were reported to the Ontario Provincial Police. 2 2581 874 To advise if the Crown owed a duty of care over the full time frame to ensure that standards of conduct for employees were implemented to ensure employees would not endanger residents. 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 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 with respect to ensuring that employees would not endanger residents.
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: - 7 - November 23, 2012 KOSKIE MINS
Page 11 and 12: 9 1834 650 With respect to para. 69
Page 13 and 14: 14 2895 950 Regarding CR109385 (mar
Page 15 and 16: 26 1414 500 To identify the doc ID
Page 17 and 18: Staff training and Qualifications,
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

here. - Koskie Minsky LLP

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