2022-10-27 - Petitioners' Cover Letter For Further Amended Petition

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Citadel law corporation Philip J.

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

_____________________________________________________________________________________

File No. 1502-2

October 27, 2022

VIA MAIL & E-MAIL

Ministry of Attorney General of BC


Legal Services Branch
PO Box 9280 Stn Prov Govt
1001 Douglas Street
Victoria, BC V8W 9J7

Attention: Julie Gibson & Alexander Bjornson

Dear Sirs/Mesdames:

Re: Canadian Society for the Advancement of Science in Public Policy et al v. Dr.
Bonnie Henry, in her capacity as Provincial Health Officer for the Province of B.C.
SCBC Vancouver Registry File No. S-2110229

Since the direction of Justice Coval at the August 15, 2022 CMC, your client has issued updates
to the orders challenged in the above noted petition as particularized in our letter dated August
16, 2022.

Accordingly, we write to further particularize the orders being challenged (changes to the list
provided on August 16, 2022 are underlined for your ease of reference):

Order Date of Order


Residential Care Covid-19 Preventative Measures October 21, 2021
Order
(“Residential Care Order”);
Covid-19 Vaccination Status Information and Preventative September 9, 2021
Measures Order” (“Vaccination Status Order”);
Vaccination Status Order September 27, 2021
Residential Care COVID-19 Vaccination Status Information October 6, 2021
Order
(Replaces Vaccination Status Order)
Residential Care COVID-19 Vaccination Status Information February 28, 2022
Order
(replaces previous order above)

-----------------------------------------------------------------------------------------------------------------------
*Denotes Law Corporation CITADEL LAW CORPORATION
•Associate Counsel 1400-1125 Howe Street, Vancouver, BC V6Z 2K8

Polina Furtula pfurtula@citadellawyers.ca 778-945-9990 ext. 106


Citadel law corporation
1400-1125 Howe Street, Vancouver, BC V6Z 2K8
_____________________________________________________________________________________

Hospital and Community (Health Care and other Services) October 21, 2021
Covid-19 Vaccination Status Information and Preventative
Measures” (“Hospital Order”);
Hospital Order November 9, 2021
Hospital Order November 18, 2021
Hospital Order September 12, 2022

We also enclose for service upon you the filed Further Amended Petition, based on your written
consent dated October 19, 2022.

Yours very truly,

CITADEL LAW CORPORATION

POLINA H. FURTULA

PF/

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