CLAIM This Action Has Been Started by the Plaintiff(S) for the Relief Set out in Part 2 Below
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17-Aug-21 Court File No. VLC-S-S-217586 Vancouver Registry No. Vancouver Registry In the Supreme Court of British Columbia BETWEEN: Action4Canada, Kimberly Woolman, The Estate of Jaqueline Woolman, Linda Morken, Gary Morken, Jane Doe #1, Brian Edgar, Amy Muranetz, Jane Doe #2, Ilona Zink, Federico Fuoco, Fire Productions Limited, F2 Productions Incorporated, Valerie Ann Foley, Pastor Randy Beatty, Michael Martinz, Makhan S. Parhar, North Delta Real Hot Yoga Limited, Melissa Anne Neubauer, Jane Doe #3 Plaintiffs -and- Her Majesty the Queen in right British Columbia, Prime Minister Justin Trudeau, Chief Public Health Officer Theresa Tam, Dr. Bonnie Henry, Premier John Horgan, Adrian Dix, Minister of Health, Jennifer Whiteside, Minister of Education, Mable Elmore, Parliamentary Secretary for Seniors’ Services and Long- Term Care, Mike Farnworth, Minister of Public Safety and Solicitor General British Columbia Ferry Services Inc. (operating as British Columbia Ferries), Omar Alghabra, Minister of Transport, Vancouver Island Health Authority, The Royal Canadian Mounted Police (RCMP), and the Attorney General of Canada, Brittney Sylvester, Peter Kwok, Providence Health Care, Canadian Broadcasting Corporation, TransLink (British Columbia) Defendants NOTICE OF CIVIL CLAIM This action has been started by the plaintiff(s) for the relief set out in Part 2 below. If you intend to respond to this action, you or your lawyer must (a) file a response to civil claim in Form 2 in the above-named registry of this court within the time for response to civil claim described below, and (b) serve a copy of the filed response to civil claim on the plaintiff. If you intend to make a counterclaim, you or your lawyer must 1 1. (a) file a response to civil claim in Form 2 and a counterclaim in Form 3 in the above- named registry of this court within the time for response to civil claim described below, and 2. (b) serve a copy of the filed response to civil claim and counter claim on the plaintiff and on any new parties named in the counterclaim. JUDGMENT MAY BE PRONOUNCED AGAINST YOU IF YOU FAIL to file the response to civil claim within the time for response to civil claim described below. Time for response to civil claim A response to civil claim must be filed and served on the plaintiff(s), (a) if you reside anywhere in Canada, within 21 days after the date on which a copy of the filed notice of civil claim was served on you, (b) if you reside in the United States of America, within 35 days after the date on which a copy of the filed notice of civil claim was served on you, (c) if you reside elsewhere, within 49 days after the date on which a copy of the filed notice of civil claim was served on you, or (d) if the time for response to civil claim has been set by order of the court, within that time. Table of Contents of the Claim Page Part 1: Statement of Facts • The Parties……………………………………………………………………..5 • The Plaintiffs and their personal facts…………………………………………5 • The Defendants…………………………………………………………….....82 • THE FACTS………………………………………………………………………..85 A/ “COVID 19” THE TIMELINE………………………………………………...85 B/ THE COVID-19 MEASURES • Federal measures…………………………………………………………..103 • Provincial measures…………………………………………………….....104 2 Page • Orders of Provincial Health Officer Bonnie Henry…………………………105 • Ministerial Orders……………………………………………………………106 • Reckless and Unlawful Statements and Actions of Leaders………………...114 C/ IGNORING AND FAILING TO ADDRESS MEDICAL EXPERTS’ EVIDENCE • The Nature of Viral Respiratory Illness (or Disease) and COVID-19……….122 • Contrary Views of the Experts to WHO protocol……………………………125 • Covid measures worse than virus…………………………………………….148 D/ THE SCIENCE & MEDICINE OF COVID-19 • Summary (Overview)……………………………………………………...…160 • The Covid -Measures Unscientific, Non-Medical, Ineffective, and Extreme…………………………………………………..…162 E/ HYPER – INFLATED, DISTORDETED TOTAL NUMBER OF CV-19 “CASES” & “DEATHS”………………………………….180 F/ GLOBAL POLITICAL, ECONOMIC AGENDA BEHIND UNWARRANTED MEASURES • The Non-Medical measures and Aims of The Declared • Pandemic- The Global Agenda………………………………………….…...188 • Bill Gates- Vaccines, Pharmaceuticals & Technology…………………..…...211 • The WHO / Gates/ Trudeau and Dr. Teresa Tam………………………….....212 • Dr. Bonnie HENRY – Vaccines and the WHO……………………………....244 G/ CONSEQUENCES OF MEASURES TO THE PLAINTIFFS AND OTHER CITIZENS, AND VIOLATION OF CONSTITUTIONAL RIGHTS……………………………………………………247 H/ THE COVID-19 VACCINE- “WE DO NOT GET BACK TO NORMAL UNTIL WE HAVE A VACCINE”……………………......255 • Microchipping /Immunity Passports/ Social Contact Vaccine Surveillance & 5G……………………………………………….…...259 • Authorized COVID “Vaccines”…………………………………………..…...261 • Vaccines in General………………………………………………………..….290 I/ THE MEDIA……………………………………………………………………….303 • Negligence…………………………………………………………………….304 3 Page J/SUMMARY………………………………………………………………………309 Part 2: Relief Sought………………………………………………………………..312 Part 3: Legal Basis…………………………………………………………………..356 4 CLAIM OF THE PLAINTIFF(S) Part 1: STATEMENT OF FACTS • THE PARTIES • The Plaintiffs and their personal facts 1. The Plaintiff “Action4Canada”, is a grassroots organization centred in British Columbia, whose facts, in support of its claim for relief, are as follows: (a) Action4Canada was co-founded in August of 2019; (b) The activities of Action4Canada are in direct response to government legislation that undermines Canada’s Constitution, the Charter, and Canadian democratic values. (c) At the onset of 2020, Action4Canada took note of the ongoing emergency measures that were being enacted in response to the Covid-19 pandemic. Many concerned citizens reached out to Action4Canada, to voice the hardships they faced due to these measures such as loss of job/income, business closures, school closures, and the re-scheduling of emergency surgeries. Action4Canada stepped up to advocate for those concerned citizens, and has continued to listen to their pleas, and find ways to take action for them. (d) Action4Canada advocates, educates and takes action in pursuit of upholding the Rule of Law, the Constitution and democratic governance in accordance with Canada’s constitutional order and the Rule of Law. 5 2. The Plaintiffs Kimberly Woolman (“Kimberly”), The Estate of Jaqueline Woolman (“Jaqueline”) are residents of British Columbia, whose facts, in support of their claim for relief, and who have suffered actionable damages directly as a result of the Covid measures imposed and enforced by, and on behalf of the named Defendants, are as follows: (a) Kimberly is the adult daughter of Jaqueline Woolman, who passed away on January 30th, 2021. Jaqueline’s eldest daughter passed away in August 2005, and her husband passed away in July 2011. Kimberly moved to British Columbia from Ontario to help take care of their mother, who had developed dementia in or about 2018. (b) Jaqueline’s remaining three (3) grown children, Sheldon, Kimberly and Michelle all lived within a few blocks of Jacqueline’s Long-term care residences: New Horizons (Discovery Harbour), and eventually Yucalta Lodge both located in Campbell River, British Columbia. (c) Once diagnosed with dementia, a decision was made in April 2019 to have her placed in a private long-term care, at New Horizons (Discovery Harbour) on 850 14th Avenue, in Campbell River, British Columbia. The decision came after Jaqueline had experienced two (2) falls, and two (2) hip surgeries on both hips, the first fall and surgery took place in December 2017, and in January 2018 she has her second fall, while in the New Horizons care home, and her surgery was also in January of 2018. 6 (d) Kimberly and Michelle had many issues with New Horizons for advocating for their mother’s health, and on April 4th, 2019 they were banned without explanation from visiting Jacqueline. (e) After multiple complaints filed against New Horizons care home by Kimberly and her siblings with regards to Jaqueline’s care, punitive restrictions were put in place by the home. As a result of those restrictions, the children had Jacqueline transferred to a different care home, Yucalta Lodge, which operates as a public (publicly-funded) under the Vancouver Island Health Authority at 555 2nd Ave, Campbell River, British Columbia in early 2019. Jacqueline’s transfer to the Yucalta Lodge facility was completed in May 2019, with Michelle’s assistance through her work connections as the scheduler at a social work office. (f) In May 2019, upon completion of Jaqueline’s transfer, Jae Yon Jones, the manager at Yucalta Lodge, constantly changed the rules, contradicted herself and outright lied about many issues brought forth by Kimberly and her siblings in relation to their mother. Kimberly and her siblings tried to resolve these issues in many meetings, to no avail. These issues went on to persist, and only became amplified by the Covid-19 restrictions put in place in 2020. (g) Sometime in 2019, Jaqueline’s doctor approved allowable alcohol shots to manage her pain. By March 2020, Nursing staff were not offering Jaqueline any alcohol, without any medical reason as to why. A decision 7 was made after the Covid-19 pandemic began, to put Jaqueline on fentanyl, which was later increased from 25mcg to 37.5mcg. however Jaqueline was no longer asking for any alcohol at that point because she would become too sedated. Similarly, also in March of 2020, the staff at Yucalta Lodge forced Jaqueline to quit smoking, a habit that helped her remain calm, by administering a nicotine patch for Jaqueline, without the consent of Michelle and Kimberly. (h) Jaqueline was left to waste away in bed, obtaining bed sores as a result of staff removing her access to her wheelchair, which in turn resulted in muscle atrophy. (i) On April 24th, 2020 Kimberly visited the Yucalta Lodge to take her mother supplies as she had done on numerous occasions. Kimberly was stopped at the door by staff who informed her that she could not enter due to newly implemented Covid-19 restrictions. Kimberly pulled up documentation on her phone that stated she could enter, as she did not understand what the security measures were about. The Director, Jae Yon Jones took the phone from Kimberly’s hand, informing her that she could not come in.