REPLY INUTHE PROVINCIAL COUFT OF BRITISH COLUMIA (SUALL CLAIMS COURT) & Toacam 1D Toa couteriain Jessica Simpson _ 505 - 8840 210 ST ridges Clinic ____perennanr. fzrahi LLP an: ie Stanger ‘600-816 Fortoy Stent i ol AGREEMENT WITH THE CLAIM: 1-= sem topays COUNTERCLAIM (rou svoun oxy ALL OUT THs PART OF THE FORM F YOU WISH TOMAKE A CLAM AGANST THE CLAMANT (1S PART 16 HOT To dE USED HON RERLYNG TOA COUNTERUIMION TO ANOTCE OF Vt NESOTIONTMEUNA. CAM, WHAT HAPPENED? Eatrnd tan How MUCK? —_g na is } +FILING FEES '$ OTAL CLAIMED $ ‘curt copy,| ht 1 | No, 2170295 hi] Vancotver Ropisty It INT PaqucraL COURT OF BRITISH COLUMDTA BETWEEN: JESSICA SIMPSON PLAINTIFF AND: VANCOUVER COASTAL HEALTH AUTHORITY operating as THREE BRIDGES CLINIC DEFENDANT SCHEDULE “A” 1, In response to the whole of the Notice of Civil Claim, the defendant specifically denies that it, or any employees, servants or agents of the defendant Vancouver Coastal Health Authority ‘were negligent or in breach of any duty as alleged or at all, and further specifically denies ‘that the plaintiff has suffered the injury, loss, and damage claimed, or any loss or damage at all 2. The plaintiff attended Three Bridges Clinic between approximately February 2, 2021 and Sune 10, 2021 for care (the “Treatment Period’). 3. This defendant further says that any and all care and treatment rendered to the plaintiff by this Defendant and by any employes ofthe Health Authority during the Treatment Period ‘was rendered with rasonable skill, care and diligence, and in accordance with wecepted standards of practice 4, Inresponse tothe whole of the Notice of Civil Claim this defendant specifically denies that it or its employees, servants or agents were negligent or in breach of any duty as alleged or at all during the Treatment Period, and further specifically denies thatthe plaintif has suffered ‘the injury, loss and damage claimed, or any injury loss or damage at all, 5. Inthe alternative and in further answer to the whole of the Notice of Civil Claim, if this dofendant was negligent or in breach of duty as alleged or at all, which is not admitted but is specifically denied, then such negligence or breach did not cause or contribute to any injury, loss, damage or expense allegedly suffered by the plaintiff. 6. In the further alternative and in further answer to the whole of the Notice of Civil Claim, if the plaintiff suffered or will continue to suffer any injury, loss, damage or expense as claimed ‘or at all, then the plaintiff has failed to mitigate her losses by failing to take all reasonable steps to minimize or avoid such injury, loss, damage or expense.2 Defendant's addtess fo IL Dives, Harpo, Stanger & Mirah LLP [ Barristers and Solicitors 600 ~ 815 Homby Strct | Vancouver, B.C. V6Z.2E6 fo! Attention: Eric Stanger Fax number for service: (604-605-1414 Date: January 14, 2022 Health AuthorityCertificate of Readiness 270286 | Inthe Prins! Cour o Bah Cau a ins COT et 27-Jan-22 D Inthe case between: REGisTRL Rinmengenne — sreJessica Simpson cE CLAIMANT( Spence and SiN we Vancouver Coastal Health Authority DEFENDANTS Brigh CoIOTBE SSOUIPPSH JO B}LIINITI9D |1am claiming damages for personal injuries and am reedy to discuss settlement of my centre claim, "attach all medical reports and all records of expenses or losses incurred or expected. soe Jan 27, 2022 Jessica Simpson oe couatPatient Chart : Printed: 2022-Jan-10 Patient Demographics ———— | year adore ride 195702 ome Pont) 285-1240 et Phe 00006040 ‘20st 22nd Larges. 86 anata Secondary Addaea we ee Medical History robo Mistry; TRANG-SEXIALIS, SEXIALOEATIONS AND DISORDERS, OTHER COMPLICATIONS OF ‘Retive Madestions: —_OZEMPIC 0.25.05 MG DOSE PEN, MAR AMTRPTYUNE 25 86 TABLET, tretorn of 9 OM Tae, ‘AURO-CYCLOBENZAPRINE 10 MG TAB, rretoopropatone aces ‘01mg Oct Tita ‘apatre Omg Oe! Tet buen HEL 100mg Oa nde Ras, (ante Soma Ort Tal. Ended Rose 2, {fecen dango tras econ arg 00 el (Si Subodawour sli Fe (9) ‘urgent stone Nene Recaro Know Alergos: CHALOPRAM 18 MC TABLET CiloramAnsogu (Crug ANY [eile oe: None Rzoded Fay sto Non Reset ‘yncalgi Hitons None Recor PeotMeciaitisory: fe oewng. Dates Oyen, Brin Cyt x2. bengn Pret SurgieaHouory; Meow conto Or aes, MorealbateJessica Simpson ‘Appointment Date: 2021-Mar-08 Note Provider: Vilayil, Ruth Referred By: Tancon, Scott 4lessica was seen in ofice followup. She is 2 months post op from neovaginal construction done in Montreal. She had a post operative bleed and some hypergranulation tissue as a post op ‘complication, ‘She is having significant discomfort doing vaginal dilation and has not been able to go up to the ecommended calitre of dilator since | sawher in ER, and is down to every other day treatments ‘There is vaginal bleeding for which she sees Rebecca (nurse) at 3 Bridges for thrice weekly ‘AgNoS treatments. She has urinary urgency and nocturia wich is newin the last few days, The Urinary stream seems to go off ata right angle. oF: general appearance mild distress abdomen overweight Vulva - external incisions weil healed, hypergranulation tissue on the cheeks posterior to neovaginal opening vagina - has a thin band of ? adhesion / scar tissue creating 2 openings. vaginal length reduced {rom previous, can admit length of one finger blood on glove after the exam ‘Assessment: Jessica is experiencing possible UTI symptoms, and post op hypergranulation tissue and adhesive band across the neovagina Recommendation: | vill contact her surgical team in Montreal / 3 Bridges for recommendations as she is stl fairly early in the healing process, encouraged ner to continue wit the siz baths and the vaginal dilation at the recommended frequency at as much depth as possible. Patients Jessica Simpson Appointment Date: 2021-Mar-12 Tith Note Provider: Vilayil, Ruth Referred By: None Phoned Dr Langhani and left message, no oreply yet Diw Rebecca at 3 Bridges. She has been seeing her for the hypergranulation complication. She has referred Jessica tothe vaginoplasty plastic surgeon doctor at VGH for urgent followup, has an appt there today, F: no tlu here for now Patient: Jessica Simpson ‘Appointment Date: 2021-Mar-19 hone followup ~ RV Vilayil, Ruth Referred By: None Thad a phone vist vith Jess today. As per her emai, she & having increased vaginal beeing, saturating thick pads, was seen by Rebecca at 3 bridges and she saw BREPY with speculum insertion as wel. Feeing weak/cizy, stil at work. pain is ok ‘A: post op compication from lysing the vaginal band? P: proceed to VGH ER, may nead vaginal packing temporarilyPatient: Jessica Simpson Appointment Date: 2021-May-03 Title: Phone followup - RV Provider: Vilayil, Ruth Referred By: Tancon, Scott Thad a phone vist with Jessa today at her request. Stl trugging with hypergranuation tissue, saturating pads, etc. seems tf not frank blood but brown and sticky mixed with transudate. She has seen Dr Genoway and Iva request her notes from ther interaction, Jessica & ok with that request. ‘She's requesting in person physical exem to see f anything can be done about the hypergranulston ‘at the apex of the vagna. Tam trying not to duplcate care as she seeing three brkiges and Dr Genoway, but Iwi request their notes and bring Jessica in to see me shorty Patient: Jessica Simpson ‘Appointment Date: 2021-May-14 “Tiel Office followup - RV Provider: Vial, Ruth Referred By: Tancon, Scott Jessica was seen in the offce for folownup today, by request. She & stl dlating daly bast with see #2. ‘There & daly being, BRB, not excessive amounts. Some cle decharge. She & worred about bbcation of her cltors. She has decussed the wet her surgeon in Montreal The vaginal band got incised by the drin Vancouver. ‘til granulation tssue in the neovagha, less than previous. kss bleeding cltors seen somewhat buried beneath the apex of the bla majora, spec: ableto advance fairy deep into the full length, no granulation tissue seen deep within, AgNo3 to the superficial grenubtion tissue visualzed P: reassurance, no f/u here for now. Jessica Simpson ‘Appointment Date: 2021-Jun-29 Office followup - RV Vilayil, Ruth Referred By: ‘Tancon, Scott Jessica was seen in the offce for folovaip today at her request. Ispent 45 minutes wih her and her mother today. ‘The hy pergranuistion compkcation of surgery s mproving. Amost none externaly. She has not been dibting the neovegina due to pai, she din’ sey how long she has stopped for. No mare blssaing. vulva - wel healed, mid scarring vagina - bisterl abil hypergrenubtion tésue anterior, treated wth AgNo3 wh consent spec: unable to advance the speculum beyond 4 cm internally. single digk exam - the neovagha has narrowed deeper internaly, not able to admk even 1 Angert, Thad a dificut dlscusson wth Jessa and her mother. She was vsby upset because ofthe apparentcolapse of the neovagina due to lack of dation. encouraged her to purchase the smalest vagnal diators avalable, and to commence dlation AT LEAST ONCE EVERY 24 HOURS, idealy more frequentY. There hope that the colepsad partion may slowly, gradualy, open back up. There & a very certan risk that f she does not do regubr dation, that the ~“cm portion that she does have wil cose up too. (Questions were answered to the best of my abity. No guarantees were glen or ipl. vdlintte a re-referral to Dr Genoway the reconstructive surgeon, for her expert advice i how to manage this compicaton. Patient: Jessica Simpson Appointment Date: 2024-3ul-06 Note Vilayit, Ruth Referred Bi None ‘diwher GP on the phane - there is @ referral in place to Dr Genoway, awaiting a date. emphasized that she'needs to keep dilating, even if is a smaller dato, no followup from here booked. Patient: Jessica Simpson Appointment Date: 2021-3ul-33 Titie: Note Provider: Vilayil, Ruth Referred By: Tancon, Scott Thank you for re-referting Jessica, who is @ 34 year old trans woman who has 2 complication post- gender affirming surgery. She is here wth her mother, who is hard of hearing. | orginally met her in ER at RMHin January 2021 when she had vaginal bleeding and dificaty wth the prescribed post op cation programme. She has now had a new challenge, which is stenosis of the neovagina. She had too much pain and dlifcuty withthe TID dition, and eventually stopped. She presented to ER recently with symptoms of fever and chils, and I was reconsulted again regarding her postoperative recovery Issues, ‘She has a referral in to Dr Genoway, who is a Vancouver based plastic surgeon who specializes in ‘gender affirming surgery. She has an appointment wih her in August 20211 oF: general appearance NAD abdomen overveight nneovulva - no granulation tissue noted, well healed ‘neovagina - hypergranulation tissue noted internally, pink, no smell able to admit 1 finger, about S ‘om depth. used her smallest silicon dilator, not able to use the next size up due to calbre mismatch she is visibly uncomfortable withthe examidilation & describes shooting pain Assessment ‘Jessica is a 34 year old transwoman who is 6 months post op from gender affirming surgery. She has had a complicated post op course with post op bleeding, hypergranulaton tissue, multiple ER visite, and now stonotie of the necvagina, likely due to lack of dlation during the post op time frame. Recommendation:! have encourages her to dilate with the smallest dilator as much as she ean tolerate, and to gradually increase to the nest size up. | believe she has been in touch with her original surgeon who would be the best ono to advice on this complication. l epont 45 minutos with them today. She has an appointment vith the Vancouver based specialist ne month.if there is a need for general gynecology surveillance in future, Lam happy to see her again. Ihave requested to be copied on notes from Or Genaway.Pan SIMPSON. JESGCA SERE Home Phone (212HTBOOSIRY Work Phone ‘ne sex F Patent | | Ceres YLATILRUTH ARN Rapone By: TRANS co EI use ur ae Consultation Note (Final)fade folded over and put into a condom wich could then be placed and aecaced in ‘proceed with vaginal AiLetion es prescribed in the Postoperative tine foane, 2 phontoed sowvrasce tat tiie patient da commasted with the Maree ReiSgee Inopital and these were bot? medics) grade products (Qecvioce, estice and her wther vece satisiied ant aie was ehay to proceed itn the Lonerting tho makowite vaginal atest. caked ove of the energemey ‘ooeinel pa and folded it over and put a Tad one snte the cendon a8 Sdoquste. f wan then able to successfully place that as a mieshife packing ‘noe srisnd the evening to try t6 loot it An place. This seemed eatiefeceary t2 ioecnton fm hor ania scomtrvston ute Tha Munna {he gender ssryery cliais a. VES, ve tave agrecd on the plan 0© Teeping the ‘Shoop ov Saturday, Sunsaey 20, 2021, and ny colleague, Or- ianpea, vill Be on ‘coe kind cf surglon? Coblowipr hich iaeally would be at the Tee Bridges Dieeding closely. If sbe his to change a pad every bout for 2-3 houte ox 3 she fe be/02/202} 16:38:43 1E sigantase June does aot contain electronic signature statea, the report batOnsred ay: YLAYILRUTHARN Rapti TRANSFHA Dat Geno: 200128 evened: 202140 ty RVleyt cc [URGRA HESIA, 7ERRICO HCMUARD, VILAML RUTH ANN Upson: 2024 Aup 187A. Consultation Note (Final) ‘care team in guebes by vartaal mesneSndnedy:— GENOWAY HSA egos By ransvens Dateof Serves: 2021Aup18 even rae 15by Fay Repatt Date 2021-91350 oe SENONRY WIA, MEE CNEL M, AGEA REA, VANCOUVER GENERAL HELM RECORDS, LAY, RTH Upctegon —202-Aup 1872154 Outpatient Clinic Consutation Note (Final) At thie point, T do aot think any zevision surgery is needed for Jeseice. SheDocument Nor 33 years Sex: F Patient 1D: jun 12 1987 Duteot service: Hr 12001 tee: vet sac Raporedn Hor 13201 05:8 Reported by: \eecsever cont Dictating Ordering Dr:SENOMAY Dr KRISTA Exrecttin (64 96 Reported to: GENOVIAY Dr. KRISTA , NATARAJAN Dr. ANITA , ° PROGRAM GENDER SURGERY , TOWNSEND Oy MARRIA, \YANCOUVER GENERAL HEALTH RECORDS. TTA RT WaNcOUVER GENERAL HOSPETAL Patient Location: ssc toro ater iii 8 5 bate of Birth — Onte of consultation 1273/2001 Consulting service: Piastie Surzery Jessica Simpson is a pleasant 33-year-old transgender woman wo wis seen in the clinic in tonsultation after wndergeing © vaganaplasty ot Sts Montreal to Oh January 26th, she noticed significant vaginal bleeding aod this resulted in her undergoing resteent st Haple Ridge Wossital, she Fes Deen followed by Or, Ruth Vilayil, in Maple Ridge fren Synecslogy” She has beer having ‘itleulty ity dilation and reached out to GRE Montreal. Tt mas mowed Via potee that she hat > etin Bridge fhve wat prasencing fer dilating, she feached out to her core providers ane she wos referred to the Ste propren for OF note, the patient has recently been Involved in a notor vehicle tejury in Septerber, wnich nas resulted in ber requiring a nip brace. sne ras Been regularly allowing vp with Three Oriages for ongoing tremtoers oF Iypergranulation tissue Today. on examination, she uae s0un vich » nonmal eliters) comalex ond Tobia {nae the patiove potrtea uae the sret of Pain and linitstion far ctlation Internaliy, she hed tignificane hypargrtniietton tissue; beth ae the teptnal introitus” a5 well a8 the veginal cavity.” The majority Gf the vaginal cavity proceouRe bridge was divided. This was dane without complication. A Uhis tine, Jessice was sean for management of the skin bridge st the vaginal opening that hos been Linstiag fer dilation. This wae released sthout covolicatien. she will contsnue to follon op with Threw Bradpes for ‘ngaing teentaint of hypergranilstion tissue, uring the exouination, T noted that she was ite tense in the perineum and we nerked on relotation techniques, 18 well a= proper dilation techniaues ach ner having a recent motor vekicle Snjury ane struggling with elation, 1i 2 id eaked the patent 1¢ she woule be confortable with me faitiating this feferral and she was. Our program will initiate a raferra to the pelvic fone physiotheraoy tean to help her with strength training, euscle’relaraticn and dilation. "Np formal followup use arranged. She dows have orgoing Foltowap with Three Seiagee 2 has teen a pleasure being Snvolved Sn her care Dictated By: nists cenouiy, WD syn xe & De 1ayes/ee20 48'98:28 Te s3ye/agas 05.24.10 ce nesta Genoway, Health Records Paresa Townsend, 9 Gander Surgery Program 1 signature Line does not contain electcanie signature status, the report has tat teen reviewed by author prior to distribution. A corrected report will be a esren (Gat Ft: Panoprtiveconeisrcons msl macho seu: A case same and reve of 111 ses - Pu Mi cma P| Fwd: Perioperative considerations in adult mitochondrial disease: A case series and a review of 111 cases - PubMed Miran Yani Date: June 20, 2024 ot 6:20:66 PR) POT Te: Mcam Yaniv Subject: Perioperative consicerstions in adult mitochondrial disease: A cose setles and a roviaw of Ht eases = Pubied tps:Ipubmed.nebi rim nin gow2680" lacknowledge my place of work is within the ancestral, traditional and unceded, traditional, and ancestral territories of the Katzlo (giéay), Kwantlen (aw'é:lt'e), Matsqui (Mathxwi), and Semiahmoo (semi'a:mu:) Coast Salish Peoples, xvma8kwayam (Musqueam), Skwxwd7mesh (Squamish), and Tsleil- waututh Nations,— wv | Bape. frserhal | Se reeiee nel | Sera FAX REFERRAL FROM RCH EMERGENCY on = DEPARTMENT F CAG {AOA | | pate Tale S72 | Consultant” - YG FAX#. (Bsc Cyma._ROH- ER Physician - i MSP #. Priority to be seen: (please ) Gi Urgent (Less than 1 week) Ci} Semi-Urcent (Less than 1 month) Routine (Greater than } mont) “"EP should sp92k to conultart fr all urgent referrals" | ‘Reason for referral: | has apat PDE Vogiel Cantructia Sen 202 iy 13 ~ DiQecltres moshfarmy veal opeoty. | . Repysttye local ean poovale* Ptr. Planes Patlont Nam Aa ee OM oF Pationt's Contact Phone #_ 777-49 “7G. | Patlent’s GP or Clinic ttre any prober wth his traramis the acdreveee aa may sais n sor rotted rat any destination dwttoue Pisaeeneiy cea Ploave cata the cence. This 1 pvilged information. Ifyou "ping ofthe massagels po ‘hone niombar blow and estoy the commaniaton, Royal Columbian Emergency Department 330 East Columbia Street New Westminster, 8C Vat aw7 (Tel 604-820-4000 (Fax) 604-520-4722EMERGENCY/ AMBULATORY GARE CLINICAL RECORD SIMPSON JESSICA SERENITY | anncvat,0 5321202 1 (8) (504) 254-5554 O51 20214 und9e?, 34 ap haara,Feahia [pavsigian ores’ ‘Atos: Baclofen, Citalopram*WORE™ 7 | ae Viigtt Bak sn [RE — aD