CANADA
S U P E R I O
R C O U R T
(Civil chamber)
- PROVINCE OF QUEBEC
- DISTRICT OF
ST-FRANÇOIS
- NO: 450-05-002521-983
(A translation
of a original document at my best knowledge)
SERGE BOURASSA-LACOMBE, to the elected
residence, Proteau & Associated, bailiff, 862,
Belvedere street South, Sherbrooke, province of Quebec, district of St-François, J1H
4C2;
c.
CENTRE UNIVERSITAIRE DE
SANTE DE L'ESTRIE, located at 580, rue Bowen Sud, at Sherbrooke, province of Quebec,
district of St-François, J1G 2E8;
and
LYNN GAUDREAULT,
physician, psychiatrist, practising her profession at Centre Universitaire de Sante de
l'Estrie, located at 580, rue Bowen Sud, at Sherbrooke, province of Quebec, district of
St-François, J1G 2E8;
and
JEAN-PHILIPPE BOULANGER, physician, psychiatrist, practising his profession at Centre Universitaire de Sante de
l'Estrie, located at 580, rue Bowen Sud, at Sherbrooke, province of Quebec, district of
St-François, J1G 2E8;
and
CLAUDE ARBOUR, physician,
psychiatrist, practising his profession at Centre Universitaire de Sante de l'Estrie, located at 580, rue Bowen Sud, at Sherbrooke, province of Quebec, district of
St-François, J1G 2E8;
and
PAUL MONTAMBAULT,
physician, psychiatrist, practising his profession at Centre Universitaire de Sante de
l'Estrie, located at 580, rue Bowen Sud, at Sherbrooke, province of Quebec, district of
St-François, J1G 2E8;
and
ANDRE SIMARD, m.d.,
practising his function at Centre Universitaire de Sante de l'Estrie, located at 580, rue
Bowen Sud, at Sherbrooke, province of Quebec, district of St-François, J1G 2E8;
and
MARC LEFEBVRE, physician,
practising his profession at Centre Universitaire de Sante de l'Estrie, located at 580,
rue Bowen Sud, at Sherbrooke, province of Quebec, district of St-François, J1G 2E8;
TO SUPPORT
HIS ACTION, THE PLAINTIFF EXPOSES RESPECTFULLY THE FOLLOWING :
1. The plaintiff was born at
Verdun June 20th 1957, under the name of Serge Lacombe, the name that he officially
took until July 12th 1996;
2.
On July 12th 1996, the plaintiff was
authorized by the civil state Director to use the name of Serge Bourassa-Lacombe;
3. On the date of February 11th
1995, the plaintiff did not have any psychiatric past or nor any mental disorder;
4. On the contrary, the
plaintiff had a very good past having notably studied during more than 18 years in
different schools, colleges and formation centers, obtaining at every occasion excellent
academic results the main thing like that appears on the copy of academic grade sheets to
be produce to support the present action under the mark P-1;
5. He had worked as well
since 1970, and even often during his studies, at various jobs where he offer an
excellent output, the main thing like that will be more abundantly demonstrate at the time
of the inquiry;
6. The plaintiff had mainly
worked in the Automotive field, over a period of 25 years, as a Travelling
Salesman, among others for the company Bear Automotive inc. from 1984 to 1987, and for the
company Moog Canada Ltd. From 1987 to 1990;
7. The plaintiff has obtain
excellent results, the main thing like the different correspondences from his employers
and from his clients to be produce to support the present action under the mark P-2;
8. Since September 1992, the plaintiff has studied as an Animal Health
Technician at the College of Sherbrooke
(now Cegep of Sherbrooke);
9.
Still again he has
obtain excellent academic results and he has acted even as President of his class;
10. Toward the end of the
year 1994 and
the beginning of 1995,
in spite of not much support obtain by the teaching profession of the Animal
Health Technique at College of Sherbrooke
(now Cegep of Sherbrooke), The plaintiff has
obtained that his third year training could be perform in Florida, in a Treatment
Center for the racehorses, the main thing like that appear from different correspondences
to be produce to support the present action under the mark P-3;
11. February 11th
1995, the parents of the plaintiff has visited him at his apartment;
12. Before
the
visit, as the relation between the plaintiff and his roommate was rather strained, it was
as agreed between both that the latter will not show the apartment where he live
during the visit of the plaintiff parents;
13. In spite of this
understanding, the roommate of the plaintiff went into the apartment and so as almost
inevitably a quarrel has been start between this latter and the plaintiff, in the course
of the aforementioned
had pretended that the plaintiff was no more going to the College and
was taking drugs;
14. When the conflict was at
its most intense, the plaintiff thump one's fist on the table without that
threatening or
assaulting his roommate;
15. The roommate of the
plaintiff founded this act aggressive, had decided to communicate with the Sherbrooke
Police in order to request the assistance of policemen since she claim she's been victim
of violence from the part of the plaintiff;
16. Seeing this unlikely
scenario that draw up in front of his eyes, the plaintiff had decided to not leave it
at that and to go himself to the Police Station in order to have them know his
version of the facts and to avoid the humiliation of a police intervention in his own
apartment;
17. February 11 1995 the
plaintiff was mistaken by the police of Sherbrooke for another Serge Lacombe,
been born the even dates, the same year age he was born. The police then
handcuffed him to
drive him to the Centre Hospitalier Universitaire de Sherbrooke (hereafter called «CUSE»);
18. On arriving at the
Police Station, the
police never allowed the plaintiff to give
his version of the
facts, they rather let him wait in the hall before they ask him to follow them in a
place where they let him think that he can gives his reasons;
19. He was taken in
a patrol vehicle and driven directly to the Centre Hospitalier Universitaire de Sherbrooke, located on the 12th North Avenue at Fleurimont;
20. The plaintiff was,
immediately taken in charge by the personal of the hospital who, without delay and always under the supervision of the police forces had places the plaintiff in a separate
room, number 22 of the emergency of the hospital previously mentioned;
21. All in all the plaintiff
was
kept forty eight (48) hours
at the emergency of the before mentioned hospital and was afterwards transferred
at the wing 4B without telling the plaintiff why. They told him that they were
bringing him to a
more comfortable room;
22. The
plaintiff
who has never agreed in a free manner to stay in the Hospital complex, was in this way
prisoner contrary his will for a total period of fifty-seven (57) days, so be it until
April 12th 1995
inclusively;
23. The plaintiff was totally deprived of his freedom during this period, except for three (3) conditional
outings that was being authorized for March 5th,
March 11th as well as April 11th 1995;
24. About thirty (30) hours
after his admission to the hospital, while he was still at the department of the
emergency of the hospital, the employees of the hospital had administered by force and
against the will of the plaintiff
sleeping and neuroleptic drugs;
25. The hospital as the
intervening physicians in this present file had never respected the legislative
dispositions applicable in the case of point, keeping the plaintiff against his will,
having him suffering from the cares or the treatments
without his authorization and acting
without judiciary authorization;
26.
At no time in the
case of point in the emergency, did the plaintiff present any danger for the health and the security
for himself or others, and his mental health state did not represent for
himself or others any grave peril in that time period;
27. Moreover, following
this
illegal
detention of 48 hours
at the
hospital emergency, no request for psychiatric examination was presented to
the court;
28. It was the
fundamental responsibility of the hospital to take the necessary measures to put the
plaintiff through an examination by the court;
29. During his
confinement in the hospital the plaintiff declared to the doctors and personal nurses that it
was going to sue them when he would be in a position to do it after his release;
30. After this declaration they became aggressive and do wrong towards the
plaintiff as a result of which he underwent many reprisals;
31. Furthermore
during this confinement and arbitrary detention, the plaintiff was
victim of several
cruel and inhuman treatments and that of course always against his will and without a judiciary
authorization, notably but not restrictive what is following;
32.
The medical team
and the nurse employees of the University Hospital
had prevented on several
occasions and on a continued period of
fifty-seven (57) days the fundamental rights of the plaintiff, such as the right of liberty,
the right of information, the right to accept or to refuse treatment, the right to
give his consent in a free manner, as well as his right to dignity and to
integrity, the whole matter will be more abundantly demonstrate at the time of
the inquiry;
33. Until March 13th
1995 inclusively, the medical and nurse employees of the hospital had being giving to the
plaintiff without his consent, chemicals drugs like Lithium, Haldol, Rivotril, Dalmane, Ativan,
Cogentin, Mellaril and Stelazine
in a negligent way and without the medical obligation to divulge to the
plaintiff the possible side effects of those medicine. This obligation was not respected;
34. Moreover,
it appear that
the
attending
physicians Lynn Gaudreault
and
Marc
Lefebvre has prescribed in a
continuous way during all this period, the above mentioned drugs, without
verifying their
effects on the plaintiff, and without considering the complaints of the latter to this
effects, the main thing like it will be more abundantly demonstrate at the time of the
inquiry;
35. This taking of drugs lead to extremely prejudicial consequences to the plaintiff, among
others :
-
Almost an absence of urine and no faeces during one continued
period of seven (7) days, so be it from February 13th
to 20th 1995;
-
Loss of a certain percentage of vision which lead
to no visual focus and having a blurred vision from February 12th to March 27th
1995;
-
Ache cause by this fragile state from February 12th
to April 9th 1995;
-
Convulsions and stiffness from February 12th
to March 20th 1995;
-
Fatigue, muscular weakness, ataxia, sleepiness
and trembling from February 28th to March 20th 1995;
-
Confusion, mislead, muscular spasms,
hyper-reflexibility from March 11th to 16th 1995;
-
Problems of sleep, having slept only 140 hours
for a period of fifty-six (56) days going from February 11th to April 11th
1995 inclusively;
-
Mental and physical torture of all kinds over a
period going from February 11th to April 11th 1995 inclusively;
-
Lost of sexual functions from February 12th
to April 9th 1995;
-
Lost of academic concentration from February 11th
to April 27th 1995;
36.
On March 13th
1995, the physicians Marc Lefevbre and Lynn Gaudreault, in order to try to
relieve the sides effect caused to the plaintiff by the administrated drugs to
this latter, they had asked him to cut half his daily consumption of water,
which the plaintiff had made
immediately;
37. Right the day after, so
be it March 14th 1995, the plaintiff was found
to be a
victim of a severe intoxication caused by an overdose of
drugs
that was administrated to him;
38. At the time of this chemical overdose, the
attending physician
Marc Lefevbre had informed the plaintiff that we'll have to stop the taking of Lithium,
it was done immediately;
39. Following this severe
overdose, the plaintiff had repeated firmly his intention to not take medication
of any kind;
40. Evenly, from that day,
the plaintiff had to make his own way alone and
without medical support resulting in a withdrawal which
was extremely difficult ;
41. March 15th
1995, the physician Marc Lefevbre explained finally to the plaintiff that the Lithium is
a medication which does not work for all;
42. He explain also that it
is for this reason why Stelazine does exist, a medication which work, according to him like
the Lithium with however less side effects and he attempt to convince the plaintiff to
take this medication;
43. From this
time, the
medical personnel and nurses, stop using force to administer the medication,
they continued to use different strategies like menaces, harassing and blackmail, notably they
had deprive the plaintiff, since March 14th 1995, of all liberty inside the
psychiatric wing, of all activity with the group of psychiatric patients and on certain
occasions also deprived of food, applied psychological pressures to the
plaintiff to believe that his detention will be longer if he
refuse to take the prescribed medication;
44.
This attitude was pursued until
April 5th 1995, date in which the defendants
had permit the plaintiff to go back to group activities, but always haunted by
their
psychological pressures in order to convince this latter to take the medication;
45.
April 9th 1995, following different blackmail and menaces,
the plaintiff give up and resign,
weighed down by the constraint,
to take half tablet of 5mg of Stelazine, while the medical personnel ask him to take
a full tablet;
46. The effect of this administered medication
was violent for the plaintiff, who had fortunately took care to dilute the
product with some litre of water and was really very terribly ill.
47. The plaintiff was not in the physical and mental state to undertake
legal actions;
REPORTS
OF EXPERT AND JUDICIAL AUTHORIZATIONS
48.
March 21st 1995, the plaintiff received from the Centre Hospitalier Universitaire de
Sherbrooke a letter personally to him, it was in Dr Lynn Gaudreault hand
writing, advising him that following two (2) evaluations carried out March 17th 1995 and March
19th 1995, respectively Lynn Gaudreault and Jean-Philippe Boulanger, the
plaintiff was actually locked-up, the main thing like that appear of the copy of
the aforesaid letter to be produce under the mark P-4;
49.
April 7th 1995, the plaintiff
had received from the Centre Hospitalier Universitaire de Sherbrooke a letter personally
to him, it was in physicians Marc Lefevbre and Lynn Gaudreault hands writing
confirming to the plaintiff that following an evaluation carried out April 5th
1995, by the attending physician Lynn Gaudreault it was decided to pursue the
locked-up, the
main thing like that appear of the copy of the aforesaid letter to be produce under the
mark P-5;
50. Around one week before,
so be it March 31st 1995, the plaintiff was advised by Dr Lynn Gaudreault that
he was admitted to the hospital because that he had the potential to become a killer;
51.
On April 10th
1995, the plaintiff learned from Dr Claude Arbour's mouth, psychiatrist, that he will be
free
April 11th
1995 for a period of 24 hours, and if everything taking place without incidental,
the cure might come to an end April 12th 1995;
52.
Following his sojourn
without incident the day of April 11th 1995, the plaintiff returned to the
hospital on and April 12th 1995 the plaintiff
received his definate sick leave signed by Dr Marc Lefevbre and Claude Arbour, the
main thing like that appears on the copy of the document to be produce under the mark
P-6;
53.
It was on the date of
April 19th 1995, that the Honourable Judge Louis-Denis
Bouchard, of
the Court of Quebec, had given a court order to keep the plaintiff in locked-up, presented by the physician Andre Simard in the name of physician Paul Montambault,
and this precisely seven (7) days after the plaintiff have left the hospital, the main
thing like that appear on the copy aforesaid request and the court order referred to, be produce
to support this present under the mark P-7;
54. This request was never
made aware to the plaintiff, seeing that the defendants had put forward that such
signification will be injurious to the health or to the security of this latter or others;
55.
The plaintiff was never interrogated at the time of the hearing of this request, seeing that the defendants
had put forward that it was manifestly useless to interrogate the responding party in reason
of his state of health;
56. The plaintiff considered this act abusive because he was neither dangerous
for himself or for
others to receive signification of the aforesaid request and to be able to testify at the
time of the awarding, the main thing like that will be more abundantly demonstrate at the
time of the inquiry;
57. The plaintiff consider he had suffering serious harm and as result of the
request was not
presented within the prescribed time by the law, rather than seven (7) days after the end
of his institutional torture;
AFTER THE
LIBERATION
58. Since April 9th
1995, the plaintiff
has
not until this day ever taken legal or illegal drugs
to control his
mood;
now the plaintiff takes medication since March 22nd 2003 after a court order was
obtained by the defendants;
59. The 1st to
the 12th of may 1995, the plaintiff had done well in six (6) exams of the nine
(9) as planned originally in order to permit him to complete his Animal Health Technique;
60. The plaintiff however
had to put an end to this series of finals exams, not being able to concentrate
adequately following the after-effects suffered at the time of his illegal detention
in the hospital of the defendants;
61. July 18 1995, the
plaintiff goes to the
Hospital Center Angrignon to obtain care for his feet. The Dr Laurent Boisvert, doctor to the
emergency refused then care for the feet. The plaintiff rather was encircled by eight (8) armed policemen of the police force
of Montréal, he was put on drugs and attached on a stretcher all night long;
62.
On July 18th
1995, the plaintiff attempt to have his feet cure in different hospitals of Montreal he
saw himself refuse to be cure at several times when the medical personal of those hospital
consulted the file of Mister Bourassa-Lacombe;
63.
The plaintiff
ended
up under contention at Verdun Hospital
therefore a physician of the
hospital asked to transfer
this latter to Saint-Mary Hospital Center;
64. The
Saint-Mary Hospital
Center had communicated with the Centre Hospitalier Universitaire de Sherbrooke
on
July 19th 1995, in order to obtain some information of the plaintiff, the main
thing like it appear of the copy from the medical report to be produce to support this
present under the mark P-8;
65. The
Saint-Mary Hospital
Center had in all likelihood receive from the
physician Lynn Gaudreault,
some information to the effect that the
plaintiff had being admitted and locked-up for notably a problem of bipolarity disorder with
paranoid schizophrenia episodes, the main thing like it appear and produce under the mark
P-8;
66. The plaintiff consider, that the existence of the medical file like it was put together but the
defendants, is the direct cause of his restraint at Verdun Hospital and of all the related
troubles including his detention during more than eight (8) hours at Saint-Mary Hospital;
67. Persuaded that there was a link between the reaction of the Hospital
Center Angrignon of Verdun and his medical file of the CUSE where he unfairly is
described as a: fussy, depressive, paranoiac, schizophrenic, narcissic,
mystical and religious delirium, and of the potential to be dangerous and to
become a mass killer;
68. The plaintiff fled to the United States in the fear against reprisals,
and the plaintiff came back to Canada November 29 1996 and to Quebec December 24 of
the same year;
69.
On September 15th
1995, the plaintiff who had already asked in vain at several times during his
hospitalization, the access of his medical file, addressed to the Centre Hospitalier
Universitaire de Sherbrooke by writing in order to obtain the aforesaid medical file;
70. December 5th
1995, the plaintiff had received a negative answer from the hospital at the motive that
such transmission of the integral file will be prejudicial for him;
71. On arriving from the United States the plaintiff was arrested and committed to the Philip Pinel
Institute of Montréal under
an accusation of criminal harassment. The accusations were withdrawn even before that the
plaintiff recorded a plea;
72. All these events reinforced the fear of the plaintiff for his security
if he executed his declared intention to start proceedings against the CUSE;
73.
On
March 27th 1997,
the plaintiff had made a complaint at the Centre Hospitalier Universitaire de
Sherbrooke, which became at this time the Centre Universitaire de Santé de l'Estrie, relatively
to the events making the object of the present lawsuit, the main thing like it appear of
the copy of the complaint to be produce under the mark P-9;
74. In answer to this
complaint, the plaintiff had received, on April 17th 1997 a letter
issued from the Centre Universitaire de Sante de l'Estrie and signed by the hand of
Mister Normand Legault at the effect that the Center will not be considering the
complaint because the treatments that have being lavished by the defendants had been
authorized by the court, the main thing like it appear from the copy aforesaid letter to
be produce under the mark P-10;
75.
Considering that the only judicial authorization was knock down April 19th 1995, the plaintiff
consider that the University Center had done so illegally and deliberately acted
with the intention to lead the plaintiff in error, notably in tempting to let
him believe that the events had been done there between the month of February and April 1995, had been
done in the most completely proper manner;
76. The CUSE held hidden the medical file of
the plaintiff CHUS 398 068 for 34 consecutive months causing harm to the
plaintiff, who was then incapable to seize the content of his medical file and
by then the plaintiff knew that without the achievement of his file,
he would be unable to file an action against the defendants;
77. It has followed a serial
of steps which ended on November 20th 1997 in a decision of the Commission of
Social affairs giving order to the defendant Hospital Center to give to the plaintiff an
integral copy of his medical file, the main thing like it appear of aforesaid decision of
the Commission of Social affairs to be produce to support the present under the mark P-11;
78. What is more the medical file asked since the
summer 1995 and necessary to present his request was granted only following a
decision of Me Lina Bisson Jolin to the Commission of the Social Matters
No: SS-10369 return November 20 1997;
79. December 16th
1997, the plaintiff received a copy of his medical file which will be produce to support
the present under the mark P-12;
80. In taking knowledge of
his medical file which was transmitted to him the plaintiff had found out several falsities
and omissions, the main thing like it will be abundantly demonstrate in the time of the
inquiry;
81. Still fearful but taking his courage
in hand the plaintiff deposited his motion to institute a proceeding on
Mondays April 14 1998;
82. It also appear that
during the year 1996, when the plaintiff was in United-States, that the Dr Lynn Gaudreault
had revealed certain information relative to the medical file of the plaintiff to the
Police of Atlanta also the Royal Canadian Mounted Police;
83. The plaintiff had
suffered and still suffers the grave side effects and serious damages following all the
events aforementioned in non-exhaustive way;
84. The plaintiff considered that the Centre Hospitalier Universitaire de Sherbrooke existing now under
the name of Centre Universitaire de Santé de l'Estrie, should take responsibility notably
as the employer of the nurses and medical personal having acted illegally and having caused
serious damages to the plaintiff;
85. Since all those events,
the plaintiff is still without job;
86. While waiting to be questioned by the defendants, the plaintiff
decided to travel 4 150 km in the Maritime on his bicycle, going through the
North Coast and leaving Sherbrooke August 1st to
October 14th;
87. The plaintiff was questioned by the defendants on November 25th and 30th
1998 as well as December 9th the same year;
88. André Prévost, Attorney - McCarthy Tétrault and Éliane-Marie Gaulin,
Attorney -
Langlois Gaudreau met on May seven (7) 1999 the various ones intervening implied
in defence in this civil pursuit NO: 450-05-002521-983 in front of the Superior
Court and this, so at the level of the doctors and also the personal nurses. A
global assessment of the file was carried out, in the interest of all the
parties involved;
89. Impossibility in fact to act – the Article 2904 C. C. Q. enunciates that «the
prescription does not run against the persons that in the impossibility in fact to act be by themselves be while doing to represent itself by of others».
This is the rule contra non-valentem agere non-currit praescriptio. [I
underline]
Gauthier c. Beaumont [
1998] R. C. S. 3
90. «The prescription delays of the action in nullity of a contract runs to
count knowledge of the cause of nullity by the one that the invokes, or has to
count suspension of the violence or fear.» 1991, c. 64, has. 2927 (1994-01-01)
C. C. Q.;
91. The plaintiff has not been able presented his
request earlier because it was in the fear of reprisals, which fear seemed to
him justified after reprisals undergoes to the hospital when it talked about
eventual pursuits and after its misadventures after his gone out that it
associated with his intention to start pursuits;
92. Considering the bad
faith, the deliberately undermine to the fundamentals rights as the malicious damages from
the defendants, the plaintiff is in right to call them jointly and severally for exemplary
and punitive damages;
93. The
defendants having act illegally and deliberately with
the intention to harm and considering the abuse of rights whose he was victim, the
plaintiff is in right to call to the defendants, jointly and severally the total amount of
EIGHT MILLION
EIGHT HUNDRED EIGHTY EIGHT THOUSAND DOLLARS ($8, 888, 000.00) for damages and interests, distribute like following : [back]
[forward]
-
Pains, physicals suffering:
A
-
Mental damage and
humiliation:
A
-
Undermine to the
fundamental rights:
A
-
Troubles and inconvenience:
A
-
Exemplary
damages:
|
$2, 000,000.00
$2, 000,000.00
$2, 000,000.00
$2, 000,000.00
$ 888,000.00 |
94. Also, the plaintiff
consider that the existence of such medical file as seen it been put
together by the defendants and consist of notably, a diagnosis of bipolar disorder with
paranoid schizophrenia episodes, hallucinatory, delusions of grandeur, etc., harm greatly
to the existence of the plaintiff attribute to him among other, stick a label extremely
prejudicial of "mental illness";
95. In consequence, the
plaintiff is in right to ask that his medical file, such as is being constituted at the
Centre Universitaire de Sante de l'Estrie be destroy as quickly as possible and that the
Centre Universitaire de Sante de l'Estrie, as all the members of personal as working, and
including the attendants physicians stop immediately to circulate no matter how that
it be, all information which can undermine his dignity and reputation notably the
allegations concluding to a mental disorder of this latter;
96. The present action is
well founded in facts and in right.
FOR THESE
REASONS, MAY IT PLEASE THE COURT:
WELCOME
the presents
action;
CONDEMN
the defendants
to pour jointly and united to the plaintiff the sum of EIGHT MILLION
EIGHT HUNDRED EIGHTY EIGHT THOUSAND DOLLARS ($8,888,000.00 ) more
the additional compensation as well as the anatocism;
THE whole
taking interest in the lawful rate as from the deposit date;
ORDER
to the
University Center of Health of the Estrie to destroy immediately the entirety of
the file of the plaintiff carrying the number 398068;
ORDER
to the
defendants as well as to the whole personnel working or already having worked
for the University Center of Health of the Estrie, of not to do to circulate in
any case the news being able to attain the reputation of the plaintiff included
all the news originating file number 398068, and of all event having taken birth
between February 11 1995 and April 12 1995
and between March 22nd, 2003 and May 13th, 2003;
CONDEMN
the defendants
to the entire expense;
Montréal, this
November 11th 2003
Serge Joseph Adrien
Bourassa-Lacombe
plaintiff
SOLEMN DECLARATION
I, undersigned
Serge Joseph Adrien BOURASSA-LACOMBE, without residence, declares
solemnly this that follows:
1- I am the plaintiff;
2- All the alleged facts in
this amended declaration are true;
IN FAITH OF WHAT, I SIGNED
At MONTRÉAL
THIS 11th DAY OF NOVEMBER
2003
Serge Joseph Adrien Bourassa-Lacombe, plaintiff
SOLEMN DECLARATION IN FRONT
OF ME
At MONTRÉAL
THIS 11th DAY OF NOVEMBER
20003
Germaine Corbeil
Commissioner to the
assermentation
DEPOSITION ADVISE
To : |
Me Chantal C. Tremblay
McCarty Tétrault
Has is RESIDENCE
ELECTED:
Proteau & Associés, bailiff
862, rue Belvédère Sud
Sherbrooke (Québec)
J1H 4C2
Prosecutors of the defendants
Dr Lynn Gaudreault
Dr Claude Arbour |
Me Philippe Tremblay
Heenan Blaikie
1250, boul. René-Lévesque Ouest
Bureau 2500
Montréal (Québec)
H3 B 4Y1
Prosecutors of the defendants
The University Center of Health of
the estrie, Drs Paul A.
Montambault,
André Simard and Marc Lefebvre |
TAKE OPINIONS that the presents amended
declaration will be deposited to the Transplant of the Superior Court, in and
for the St-François district, to the justice Palace of Sherbrooke, situated
to the 375, street King West, Sherbrooke (Quebec), on Fridays November 14 2003.
WANT TO ACT CONSEQUENTLY.
Montréal, this Tuesday November 11 2003
Serge Joseph Adrien Bourassa-Lacombe
Plaintiff
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.ME DAVID II StigmatisEUR/sTIGMATISOR pour/FOR/ PARA FONDATION SERGE BOURASSA-LACOMBE Foundation
14-08-2012 19:40:26 |
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