Citadel law corporation Philip J.

Dougan
1400-1125 Howe street Silvano S. Todesco
Vancouver BC v6z 2k8 Polina H. Furtula*•
PH: 778-945-9990

_____________________________________________________________________________________

File No. 1502-1

November 8, 2021

VIA FAX & EMAIL (Emily.Lapper@gov.bc.ca; Jacqueline.Hughes@gov.bc.ca)

Ministry of Attorney General

Legal Services Branch
1301 - 865 Hornby Street
Vancouver, B.C. V6Z 2G3

Attention: Emily Hopper

Dear Sirs/Mesdames:

Re: Canadian Society for the Advancement of Science in Public Policy v. Her
Majesty the Queen in Right of the Province of British Columbia et al,
SCBC Vancouver Registry File No. S210831

Please find enclosed for service upon you the Response to Demand for Particulars dated
November 8, 2021.

Yours very truly,

CITADEL LAW CORPORATION

POLINA H. FURTULA

-----------------------------------------------------------------------------------------------------------------------
CITADEL LAW CORPORATION
*Denotes Law Corporation 1400-1125 Howe Street, Vancouver, BC V6Z 2K8
•Associate Counsel 120-256 Wallace Street, Nanaimo, BC V9R 5B3

Polina Furtula 778-945-9990 pfurtula@citadellawyers.ca

 No. S210831
Vancouver Registry

IN THE SUPREME COURT OF BRITISH COLUMBIA

BETWEEN

CANADIAN SOCIETY FOR THE ADVANCEMENT

OF SCIENCE IN PUBLIC POLICY
PLAINTIFF
AND
HER MAJESTY THE QUEEN IN RIGHT
OF THE PROVINCE OF BRITISH COLUMBIA
AND
DR. BONNIE HENRY IN HER CAPACITY AS PROVINCIAL HEALTH
OFFICER FOR THE PROVINCE OF BRITISH COLUMBIA

DEFENDANTS

Brought under the Class Proceedings Act, R.S.B.C. 1996, c. 50

RESPONSE TO DEMAND FOR PARTICULARS

TO: The Defendants

In response to the Defendants’ Demand for Particulars dated September 27, 2021
(the “Demand”) the Plaintiff says:

1. In response to paragraph 1(b) of the Demand, and with respect to Part 1,

paragraph 44 of the Amended Notice of Civil Claim, the agents of the
Province who are alleged to have obstructed or discouraged licensed
physicians and other treatment providers licensed under the Health
Professions Act, R.S.B.C. 1996, c. 183, from advocating modalities or
therapies with respect to the clinical approach in treating COVID-19 and
related diseases, include the following:

a. Ministry of Health;

b. Office of the Provincial Health Officer;

c. BC Centre for Disease Control;

d. such further particulars as may be advised.

 2

2. In response to paragraph 1(c) of the Demand, and with respect to Part 1,

paragraph 44 of the Amended Notice of Civil Claim, the acts, statements or
other conduct includes the following written statements:

a. June 2, 2020 – Clinical Reference Group Recommendations:

Therapies for Covid-19 - BC Centre for Disease Control;

b. Undated - Valid contraindications and deferrals to Covid-19

vaccination - Office of the Provincial Health Officer;

c. October 1, 2021 – Joint message about ivermectin in the prevention

and treatment of COVID-19 - Office of the Provincial Health Officer;

d. October 19, 2021 - Clinical Reference Group Recommendations:

Therapies for Covid-19 - BC Centre for Disease Control;

e. such further particulars as may be advised.

Dated: November 8, 2021

________________________________
Signature of lawyer for the Plaintiff,
Polina H. Furtula