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;

                                                                                             Plaintiff

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;

                                              Defendants


 [Español]      AMENDED DECLARATION      [Français]


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

Why Such Signing ?

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

Why Such Signing ?
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

Why Such Signing ?

Serge Joseph Adrien Bourassa-Lacombe Plaintiff

Click on the judge in order to discover the contents of the criminal medical records CHUS 398068 !


 

2006/10/25

Pour la Gloire de Dieu et le Salut du Monde !


Serge Bourassa-Lacombe
c.
TEACHING HOSPITALS and al
hearing in the bottom of reason
C.S. ST-François: 450-05-002521-983
will be heard in sherbrooke
JANUARY 8th - 10th, 2007
THREE DAYS SHOULD BE ENOUGH.

 

Pour la Gloire de Dieu et le Salut du Monde !

2005/08/24

Pour la Gloire de Dieu et le Salut du Monde !


Serge Bourassa-Lacombe
c.
Jeans-Philippes bOULANGER (CHUS) and al
audience in the bottom of reason
C.S. ST-François: 450-05-002521-983
will be heard in sherbrooke
for a length of 10 days
September 18th - 29th, 2006
and if necessary, on October 2nd and 3rd, 2006

 

Pour la Gloire de Dieu et le Salut du Monde !
2004/06/21 Pour la Gloire de Dieu et le Salut du Monde !

Pour la Gloire de Dieu et le Salut du Monde !

 

complaints DEPOSITED BY
bourassa-lacombe serge joseph adrien
 IN SECONDARY SCHOOL OF THE DOCTORS OF QUEBEC
&
NATIONAL SECURITY office OF the RCmp

against
 
the PSYCHIATRIST mario roy of douglas hospital of verdun
 +
2 AMBULANCE DRIVERS OF THE AMBULANCES OF ESTRIE
+
5 PSYCHIATRISTS OF «CHUS - HÔTEL-DIEU»
+
3 DOCTORS OF «CHUS - HÔTEL-DIEU»

+
2 DOCTORS OF «CH DE VERDUN» IN FORMER DAYS «CH ANGRIGNON»
+
9 PSYCHIATRISTS OF «CHUS - FLEURIMONT»
+
3 DOCTORS O
F «CHUS - FLEURIMONT»


 

Pour la Gloire de Dieu et le Salut du Monde !

Pour la Gloire de Dieu et le Salut du Monde !

2004/06


Report Of evaluation of serge bourassa-lacombe
FROM the Dr ROY, PSYCHIATRIST AT

the psychiatric hospital douglas of Verdun

 

2004/05/18

report Of evaluation of serge bourassa-lacombe
FROM the dr ********* ********, emergency physician AT

the psychiatric douglas hospital of Verdun

2004/05/17


CS 450-17-001129-049
Prescription of treatment pronounced

by the honorable judge raynald fréchette
against serge bourassa-lacombe

 

2004/05/17

Pour la Gloire de Dieu et le Salut du Monde !


CS 450-17-001117-044
REQUEST in permanent injunction against it «CHUS»
faced up Serge Bourassa-Lacombe a problem of
«hypoglycaemia»
 in front of THE seduction exercised by

me cheryl gilbert of heenan blaikie
on the honorable judges raynald fréchette

 

Pour la Gloire de Dieu et le Salut du Monde !

2004/05/06

Pour la Gloire de Dieu et le Salut du Monde !

CS 450-17-001129-049
NOTICES OF DENUNCIATION OF

the DEFENDANT SERGE BOURASSA-LACOMBE

declinatory WAYS AND OF NON-ADMISSIBILITY

Pour la Gloire de Dieu et le Salut du Monde !

2004/04/26

2004/04/21

CS 450-17-001129-049
Medical report of the Expert Witness Dr William Semaan

of April 21st 2004 to obtain the prescription of treatment

2004/04/14

Pour la Gloire de Dieu et le Salut du Monde !

CS 450-17-001117-044
request in interlocutory injunction order
Serge Bourassa-Lacombe c. CHUS

Pour la Gloire de Dieu et le Salut du Monde !

2004/01/12

Pour la Gloire de Dieu et le Salut du Monde !

CS450-05-002521-983
Commitments of precision

of the prosecutor Serge Bourassa-Lacombe
further to the interrogation of December 9th, 2003
of the defendants Drs Lynn Gaudreault and Claude Arbour

Pour la Gloire de Dieu et le Salut du Monde !

2003/12/16

Pour la Gloire de Dieu et le Salut du Monde !

CS450-05-002521-983
Declaration Of inscription on cause list
of SERGE Bourassa-Lacombe

Pour la Gloire de Dieu et le Salut du Monde !
24/03/2003
TO
16/05/2003

Diverse COURT ORDER obtained in 2003
by use of forgeries of THE CHUS
against SERGE BOURASSA-LACOMBE...


 
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.ME DAVID II 
StigmatisEUR/sTIGMATISOR
pour/FOR/ PARA
FONDATION
SERGE BOURASSA-LACOMBE
Foundation

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14-08-2012 19:40:26

FONDATION SERGE BOURASSA-LACOMBE FOUNDATION
DEPUIS/SINCE/ DESPUÉS
12/02/1995

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 AFIN DE CONSTRUIRE UN PAYS SANS CORRUPTION !

 
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IN ORDER TO BUILD A COUNTRY WITHOUT CORRUPTION!

 
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