(January 13, 2012) - Applicant's Will-say and Supporting Documentation
- List of Exhibits
- Anticipated evidence of Mr. Michael Jack
- Exhibit 02 - Marine Technological School certificate
- Exhibit 03 - Marine College Diploma
- Exhibit 04 - Assessment certificate for soldier demobilized from regularly Israeli military service
- Exhibit 05 - Electrical Officer Second Grade certificate
- Exhibit 06 - Intel Electronics Ltd. letter
- Exhibit 07a - Trent University degrees
- Exhibit 07b - Trent University transcripts
- Exhibit 07c - Academic awards and scholarships
- Exhibit 07d - Trent University Computing & Information Systems' pamphlet
- Exhibit 08 - Anticipated evidence of witnesses
- Exhibit 09 - O.A.C.P. Certificate of Results
- Exhibit 10a - Recommendation (reference) letters
- Exhibit 10b - Curriculum Vitae of witnesses and references
- Exhibit 11a - Application to York Regional Police 2008
- Exhibit 11b - Correspondence with Chief of York Regional Police Armand La Barge
- Exhibit 12 - OPPs offer of employment
- Exhibit 13a - Ontario Police College diploma, transcripts, award certificate
- Exhibit 13b - Photograph with the Ontario Police Fitness Award
- Exhibit 13c - Provincial Police Academy diary
- Exhibit 13d - Provincial Police Academy certificate
- Exhibit 13e - Provincial Constable badge and business card
- Exhibit 14 - File 233-10 (SP09020239)
- Exhibit 15 - PCS-066P (Month 1 & 2)
- Exhibit 16 - Probationary Constable work improvement plan (Month 1 & 2)
- Exhibit 17 - PCS-066P (Month 3)
- Exhibit 18 - PCS-066P (Month 4)
- Exhibit 19 - File 233-10 (RM09096931)
- Exhibit 20a - HTA Charge - Disclosure
- Exhibit 20b - HTA Charge - Court Endorsement (12-Aug-10)
- Exhibit 20b - HTA Charge - Transcript of Proceedings (01-Apr-10)
- Exhibit 20b - HTA Charge - Transcript of Proceedings (12-Aug-10) (Page 10)
- Exhibit 20b - HTA Charge - Transcript of Proceedings (12-Aug-10)
- Exhibit 20b - HTA Charge - Transcript of Proceedings (27-May-10) (Pages 8, 21)
- Exhibit 20b - HTA Charge - Transcript of Proceedings (27-May-10)
- Exhibit 20c - OTT Legal Services re Court date
- Exhibit 21 - PCS-066P (Month 5)
- Exhibit 22 - Crown Brief Synopsis re Arrest for an impaired operation of a motor vehicle
- Exhibit 23a - File 233-10 (SP09164458)
- Exhibit 23b - File 233-10 (SP09178964)
- Exhibit 24 - PCS-066P (Month 6 & 7)
- Exhibit 25 - OPPA approval of request for legal assistance re HTA PON
- Exhibit 26a - Correspondence with Karen German and Colleen Kohen
- Exhibit 26b - Correspondence to OPPA
- Exhibit 26c - Officer notes of PC Michael Jack
- Exhibit 27 - PCS-066P (Month 8)
- Exhibit 28 - General Occurrence Report re threats call
- Exhibit 29 - Driver competency assessment
- Exhibit 30 - Syntactical and grammatical analysis of my Probationary Performance Evaluation reports
- Exhibit 31 - Peterborough clinic medial letter
- Exhibit 32 - PCS-066P (Month 9)
- Exhibit 33 - Probationary Constable work improvement plan (Month 9)
- Exhibit 34a - Re Break and Enter investigation at Young's Point Public School (Crown Brief Synopsis)
- Exhibit 34b - Re Break and Enter investigation at Young's Point Public School (correspondence with Crown Attorney Kelly Eberhard)
- Exhibit 35 - Re Large illegal drug grow op (letter of commendation from Cst. Ernie Garbutt)
- Exhibit 36 - Memorandum to Michael Jack by Michael Jack
- Exhibit 37 - PCS-066P (Month 10)
- Exhibit 38 - Probationary Constable work improvement plan (Month 10)
- Exhibit 39 - Internal complaint to Professional Standards Bureau (2545009 – 0173)
- Exhibit 40 - Investigation re Credit card fraud
- Exhibit 41 - Notice of Proposed Release from Employment
- Exhibit 42 - Performance and conduct requirements of a Recruit Constable
- Exhibit 43 - Analysis of my performance evaluations
- Exhibit 44 - PCS-066P (Month 11)
- Exhibit 45 - Probationary Constable work improvement plan (Month 11)
- Exhibit 46 - Resignation letter
- Exhibit 47 - Calls for service (reportable and non-reportable)
- Exhibit 47a - Calls for service (non-reportable)
- Exhibit 47b - Calls for service (reportable)
- Exhibit 47c - Reports re calls for service
- Exhibit 47d - Traffic reports re Motor Vehicle Collisions
- Exhibit 48 - Anticipated evidence of Mr. Harry Allen Chase
- Exhibit 49 - Anticipated evidence of Mr. Steve Ryan
- Exhibit 50 - Anticipated evidence of Dr. Derek Dotzko
- Exhibit 51 - Anticipated evidence of Dr. Vanita Lokanathan
- Exhibit 52 - Diary (Page 40)
- Exhibit 52 - Diary
- Exhibit 53 - Rebuttal to PCS-066P (Month 1 & 2)
- Exhibit 54 - Rebuttal to PCS-066P (Month 3)
- Exhibit 55 - Rebuttal to PCS-066P (Month 4)
- Exhibit 56 - Rebuttal to PCS-066P (Month 5)
- Exhibit 57 - Rebuttal to PCS-066P (Month 6 & 7)
- Exhibit 58 - Rebuttal to PCS-066P (Month 8)
- Exhibit 59 - Rebuttal to PCS-066P (Month 9)
- Exhibit 60 - Rebuttal to PCS-066P (Month 10)
- Exhibit 61 - Rebuttal to PCS-066P (Month 11)
- Exhibit 62 - Mr. Harry Allen Chase's complaint to OHRC
- Exhibit 63 - General Occurrence Report written by Cst. Lloyd Tapp for Cst. Harry Allen Chase re Domestic occurrence
- Exhibit 64 - R. vs. Stillman Crown Brief Synopsis and Cst. Lloyd Tapps examination of the R. vs. Stillmans case
- Exhibit 65 - Peterborough County OPP Detachment telephone directory
- Exhibit 66 - Peterborough OPP Duty Schedule 2009
- Exhibit 66 - Peterborough OPP Duty Schedule 2009 (MS Excel)
- Exhibit 67 - Police Services Act R.S.O. 1990, c. P.15 Ontario Regulation 123-98
- Exhibit 68 - Peterborough Fish and Game Association membership
- Exhibit 69 - Crazy Ivan
- Exhibit 70 - Anticipated evidence of Sgt. Jason Postma
- Exhibit 71a - Anticipated Evidence of Mark Greco
- Exhibit 71b - Anticipated Evidence of Rui Pacheco
- Exhibit 72 - Photographs of being in charge of cadets in the Nautical School in Israel
- Exhibit 73 - Photographs during the years of regular military service in Israel
- Exhibit 74 - Photograph with the “Undesirables” (the top one) taken in the GoodLife fitness club in August of 2003
- Exhibit 75 - Photographs at the Ontario Police College (graduation)
- Exhibit 76 - Photograph at the Provincial Police Academy's shooting range
- Exhibit 77 - Photographs at the Provincial Police Academy (graduation)
- Exhibit 78a - Certificate of Results issued by Applicant Testing Services
- Exhibit 78b - Standard First Aid issued by St. John Ambulance
- Exhibit 79 - Re Application for position of Constable with York Regional Police
- Exhibit 80 - Re Application for the position of Police Constable with Toronto Police service
- Exhibit 81 - Israeli Criminal Record Check re Application to Toronto Police Service
- Exhibit 82 - Correspondence with Ontario Power Generation
- Exhibit 83 - Correspondence with Toronto Police service
- Exhibit 84 - Correspondence with Peel Regional Police service
- Exhibit 85 - Correspondence with Halton Regional Police service
- Exhibit 86 - The Peterborough Examiner re Post-Traumatic Stress Disorder (August 5, 2010)
- Exhibit 87 - The Promise of the OPP
- Exhibit 88 - Professionalism in the OPP
- Exhibit 89 - Workplace Discrimination and Harassment Policy of the OPP
- Exhibit 90a - Framework for action, Ontario Public Service, Volume 10
- Exhibit 90b - Ontario's Human Rights Code - Racism & Racial Discrimination Brochure
- Exhibit 90c - Ontario's Human Rights Code - Racial Harassment Brochure
- Exhibit 90d - Insights from the Ontario Human Rights Legal Support Centre
- Exhibit 90e - Ontario Public Service WDHP Policy
- Exhibit 91a - Access or Correction Request under Freedom of Information and Protection of Privacy Act
- Exhibit 91b - Response to Access or Correction Request under Freedom of Information and Protection of Privacy Act (Request number CSCS-P-2011-00058)
- Exhibit 92 - Toronto Sun article about CHRT decision
- Exhibit 93 - Maclean's article about intimidation of employees
- Exhibit 94 - Ontario Use of Force Model
- Exhibit 95 - HRTO Cst. Tapp vs. OPP - Terms of Settlement
- Exhibit 96a - The Peterborough Examiner re Officer charged with racing
- Exhibit 96b - The Peterborough Examiner re OOP officer cleared of stunt-driving charge
- Exhibit 97 - Gym memberships
- Exhibit 98 - OPP Association Comments re Ombudsman's Investigation
- Exhibit 99a - Probationary Performance Evaluation Guidelines
- Exhibit 99b - Ontario Provincial Police Orders
- Exhibit 100 - Boiling frog syndrome
(January 12, 2012) - Respondent's Original Disclosure
- Volume 1 - Index Volume 1 to Volume 4.12
- Volume 1 - Index Volume 4.13 to Volume 7.14 & Appendix
- Volume 1 - B-38 to B-67
- Volume 1 - B-44 to B-48
- Volume 1 - B-49 to B-43
- Volume 1 - B-68 to B-98
- Volume 1 - B-75 to B-37
- Volume 1 - C to I & I-1 to I-25
- Volume 1 - I-26 to I-52
- Volume 1 - I-53
- Volume 1 - I-54 to I-75
- Volume 1 - I-76 to I-96
- Volume 1 - I-97 to I-100
- Volume 1 - I-101 to I-112
- Volume 1 - I-113 to I-114
- Volume 1 - I-115 to I-116, J & K
- Volume 2.0
- Volume 2.1
- Volume 2.2
- Volume 2.3
- Volume 2.4
- Volume 2.5 - last 2 pages
- Volume 2.5 - last 5 pages
- Volume 2.0 - Tab 12
- Volume 3.0
- Volume 3.1
- Volume 3.2
- Volume 3.3
- Volume 3.4
- Volume 3.5
- Volume 3.6
- Volume 4.0
- Volume 4.1
- Volume 4.2
- Volume 5.0
- Volume 5.1
- Volume 6.0
- Volume 6.1
- Volume 6.2
- Volume 6.3
- Volume 7.0
- Volume 7.1
(January 27, 2012) - Respondent's Additional Disclosure
(February 16, 2012) - Respondent's Additional Disclosure
- Vehicle Damage Report
- Staff Sergeant Coleen Kohen's transcribed notes
- OPP orders Chapter 6, Section 6.16 OPP Vehicles
(February 23, 2012) - Complaint to the Law Society of Upper Canada
- Complaint to LSUC Re: HRTO 2010-07633-I
- Appendix A
- Appendix B
- Exhibit 1-a - (December 13, 2010) FDH LLP - Re Application of Michael Jack to the HRTO
- Exhibit 1-b - (December 14, 2010) (HRTO 2010-07633-I) - Application under Section 34 of the Human Rights Code (Form 1)
- Exhibit 1-c - (December 14, 2010) (HRTO 2010-07633-I) - Application of Michael Jack to the HRTO, Area of Discrimination Employment (Form 1-A)
- Exhibit 1-d - (December 13, 2010) (HRTO 2010-07633-I) - Application of Michael Jack to the HRTO (Schedule A)
- Exhibit 1-e - (December 13, 2010) (HRTO 2010-07633-I) - Application of Michael Jack to the HRTO (Schedule B)
- Exhibit 1-f - (December 12, 2010) - Statutory Declaration of Michael Jack
- Exhibit 2 - (January 10 and January 18) - the two exhibits below combined for ease of reference
- Exhibit 2 - (January 10, 2011) - Correspondence from the Ministry of the Attorney General
- Exhibit 2 - (January 18, 2011) (FDH LLP) - Re Application of Michael Jack to the HRTO (File No. 2010-07633-I)
- Exhibit 3 - (July 2008) (HRTO) - Policy on Representation before the HRTO
- Exhibit 4 - (March 11, 2011) (HRTO 2010-07633-I) - Notice of Application
- Exhibit 5 - (March 30, 2011) (HRTO 2010-07633-I) - Request for time extension by Counsel for Respondent
- Exhibit 6 - (April 7, 2011) (HRTO 2010-07633-I) - Re Request for time extension by Counsel for Respondent
- Exhibit 7 - (May 4, 2011) (HRTO 2010-07633-I) - Response to Application
- Exhibit 8 - (November 28, 2011) (HRTO 2010-07633-I) - Request for time extension by Counsel for Respondent
- Exhibit 9 - Copies of inculpatory statements in e-mails between respondents with respect to Exhibit 1-d
- Exhibit 10 - Copies of inculpatory statements in e-mails between the respondents with excerpts of denials from Counsel's response to the Application
- Exhibit 11 - (December 22, 2011) (HRTO 2010-07633-I) - Notification from Counsel Re Assuming Representation of the Respondent
- Exhibit 12 - The Law Society of Upper Canada, Rules of Professional Conduct
- Exhibit 13 - Ontario Public Service, Guide to Public Service Ethics and Conduct
- Letter of Authorization from Michael Jack for LSUC
- Letter from LSUC closing the complaint until the disposition of HRTO case
(March 2, 2012) - Respondent's Additional Disclosure
(March 9, 2012) - Respondent's Additional Disclosure
- Cover letter, PC Bruce Hanna's notebook entries
- Cover letter, Staff Sergeant Colleen Kohen's schedule of evaluations
- PC Michael Jack's notes 1
- PC Michael Jack's notes 2
- Staff Sergeant Ron Campbell's transcribed notes
(March 20, 2012) - Counsel's Request (Form 10) for an Order During Proceedings
- Counsel's Request for a Case Management Conference
- Main pages and first pages of exhibits being objected to in Form 10
- Highlights of Counsel's objections to Applicant's statement
- Case Law - Cover page
- Case Law - 1
- Case Law - 2
- Case Law - 3
(March 23, 2012) - Respondent's Additional Disclosure
(April 2, 2012) - Respondent's Additional Disclosure
- Cover letter and refusal to comply with section 17 of the Application
- a, g
- b 1
- b 2
- b 3
- e
- f, g, i
- g
- g 2
- l, m, n, p
- o 1
- o 2
- q, o
(April 4, 2012) - Applicant's Response (Form 11) to Counsel's Request (Form 10) for an Order During Proceedings
(April 4, 2012) - Applicant's Case Law in Support of the Application
- List of Case Law Documents
- CHRC - ALI TAHMOURPOUR vs RCMP (April 2008)
- FCA - ALI TAHMOURPOUR vs CANADA (July, 2010)
- BCSC - NANCY SULZ vs RCMP (January 2006)
- BCCA - NANCY SULZ vs RCMP (December 2006)
- CHRC - DONNA MOWAT vs CANADIAN ARMED FORCES (2008)
- CHRC - FIONA ANN JOHNSTONE vs CANADA BORDER SERVICES (2010)
- OHRT - YOUSOUFI vs TPS (2009)
- CHRC - BARBARA TANZOS vs AZ BUS TOURS INC (2007)
- CHRC - Speaking to the Media
- OCCPS - Constable Brandon Wilson vs OPP (2006)
- OCCPS - Sergeant Shawn Hewlett vs OPP (2007)
(April 4, 2012) - Respondent's Additional Disclosure
(April 5, 2012) - Respondent's Additional Disclosure
- Volume 1, Cover letter, Index and Items 1 - 2
- Volume 1, 2 - 3
- Volume 1, 4 - 5
- Volume 1, 7 - 16
- Volume 1, 16 A
- Volume 1, 16 B
- Volume 1, Witness list and anticipated evidence
- Volume 2, 6 - 7
- Volume 2, 6 - 7, 16
- Volume 2, 17 - 55
- Volume 2, 56 - 91
- Volume 2, 91 - 108
- Volume 2, 109 - 132
- Volume 3, 133 - 150
- Volume 3, 150 - 163
- Volume 3, 164 - 180
- Volume 3, 180 - 185
- Volume 3, 185 - 191
- Volume 4, 192 - 210
- Volume 4, 211 - 215
- Volume 4, 216 - 227
- Volume 4, 227 - 236
- Volume 5, 5 - 239
- Volume 5, 237 - 238
- Volume 5, 238 - 239
- Volume 5, 239 - 240
- Volume 5, 240 - 242
(April 9, 2012) - Applicant's Analysis of Respondent's Disclosure
(CONSOLIDATED, ORGANIZED, PERTINENT AND COHERENT INFORMATION!!!)
- 1 - June 2008
- 2 - July 2008
- 3 - August 2008
- 4 - September 2008
- 5 - October 2008
- 6 - November 2008
- 7 - December 2008
- 8 - January 2009
- 9 - February 2009
- 10 - March 2009
- 11 - April 2009
- 12 - May 2009
- 13 - June 2009
- 14 - July 2009
- 15 - August 2009
- 16 - September 2009
- 17 - October 2009
- 18 - November 2009
- 19 - December 2009
- 20 - Missing calls for service
- 21 - Sgt. Flindall and PC Payne special relationship
- 22 - Coaching by PC Nie
- 23 - Conclusion
- 24 - January 2011
(April 9, 2012) - Documentation in Support of Applicant's Analysis of Respondent's Disclosure
- Exhibit 101 - Israel and firearms
- Exhibit 102 - Oath of Canadian citizenship (November 10, 2004)
- Exhibit 103 - Statement of earnings & deductions (January 29, 2010)
- Exhibit 104 - Dental records and receipts (January and February 2009)
- Exhibit 105 - Traffic incident driver's report form (2009)
- Exhibit 106 - Break and Enter at Selwyn Outreach Centre (January 26, 2009)
- Exhibit 107 - Guidelines prepared by PC Jack (2009)
- Exhibit 108 - Domestic dispute (February, 2009)
- Exhibit 109 - PC Payne's occurrences (July 18, 2009)
- Exhibit 110 - PTA OIC Undertaking - Williamson (July 24, 2009)
- Exhibit 111 - Retired firefighter sues OPP (March 10, 2012)
- Exhibit 112 - Occurrences re Richard Kaulback (September 9, 2009)
- Exhibit 113 - Cheaper by the Dozen 2 (July 2005)
- Exhibit 114 - GOR re Jessup and Couch (October 12, 2009)
- Exhibit 115 - Logon sheet Platoon D Night Shift (October 17, 2009)
- Exhibit 116 - Workplace Discrimination and Harassment Prevention Policy (WDHP)
- Exhibit 117 - OPP Orders on Member Note Taking
- Exhibit 119 - OPP Orders on Code of Conduct
- Exhibit 120 - Proof of OPP violating officer's rights to confidentiality
- Exhibit 121 - Threatening e-mail by Sgt. Dennis
- Exhibit 122 - Copies of inculpatory statements by the respondents with excerpts of denials from the Counsel's response to the Application
- Exhibit 123 - REFUSED
(April 9, 2012) - Applicant's Request (Form 10) for an Order During Proceedings
- Form 10
- Schedule A
- Schedule B
- Exhibit 1 - (December 12, 2010) - Statutory Declaration
- Exhibit 1 - (December 13, 2010) (FDH LLP) - Re Application to the Human Rights Tribunal of Ontario of Michael Jack
- Exhibit 1 - (December 13, 2010) (HRTO 2010-07633-I) - Application to the Human Rights Tribunal of Ontario of Michael Jack (Schedule A)
- Exhibit 1 - (December 13, 2010) (HRTO 2010-07633-I) - Application to the Human Rights Tribunal of Ontario of Michael Jack (Schedule B)
- Exhibit 1 - (December 14, 2010) (HRTO 2010-07633-I) - Application to the Human Rights Tribunal of Ontario Area of Discrimination Employment (Form 1-A)
- Exhibit 1 - (December 14, 2010) (HRTO 2010-07633-I) - Application under Section 34 of the Human Rights Code (Form 1)
- Exhibit 1 - (December 14, 2010) (HRTO 2010-07633-I) - Application under Section 34 of the Human Rights Code (Form 1, Page 11)
- Exhibit 2 - (May 4, 2011) (HRTO 2010-07633-I) - Respondent's response to the Application
- Exhibit 3a - (January 10, 2011) - Correspondence from the Ministry of the Attorney General Re Application
- Exhibit 3b - (January 18, 2011) (FDH LLP) - Correspondence from FDH LLP to HRTO Re HRTO File No. 2010-07633-I
- Exhibit 4 - (Januray 7, 2011) - Date the Respondent became aware of the Application via their Counsel
- Exhibit 5 - (March 30, 2011) - Correspondence re Respondent's request for an extension of time
- Exhibit 6 - (April 7, 2011) - Correspondence re Respondent's request for an extension of time
- Exhibit 7 - (November 22, 28, 30, 2011) (HRTO 2010-07633-I) - Notice of confirmation of hearing + Respondent's request for an extension of time
- Exhibit 8 - (December 14, 2010) - Section 17 and Section 18 of the Application
- Exhibit 9 - (March 13, 2012) - Correspondence from Mr. Tapp to Counsel Lynette D'Souza
- Exhibit 10 - (April 2, 2012) - Counsel's cover letter for additional disclosure and refusal to comply with Section 17 of the Application
- Exhibit 11 - Date stamp of production dates of e-mails in the Counsel's disclosure
- Exhibit 12a - (2004 - 2006) - Applicant's University degrees
- Exhibit 12b - (2004 - 2006) - Applicant's University transcripts
(April 17, 2012) - Respondent's Additional Disclosure
(April 20, 2012) - Counsel's Response (Form 11) to Applicant's Request (Form 10) for an Order During Proceedings and Counsel's Request (Form 10) for an Order During proceedings
(April 27, 2012) - Respondent's Additional Disclosure
(May 4, 2012) - Applicant's Response (Form 11) to Counsel's Request (Form 10) for an Order During Proceedings
- Form 11
- Schedule A
- Appendix A
- Appendix B
- BCSC - NANCY SULZ vs RCMP (January 2006)
- OHRT - YOUSOUFI vs TPS (2009)
- Exhibit 07d - Trent University Computing & Information Systems' pamphlet
- Exhibit 39 - Internal complaint to Professional Standards Bureau (2545009 – 0173)
- Exhibit 69 - Crazy Ivan
- Exhibit 70 - Anticipated evidence of Sgt. Jason Postma
- Exhibit 74 - Photograph with the “Undesirables” (the top one) taken in the GoodLife fitness club in August of 2003
- Exhibit 90b - Ontario's Human Rights Code - Racism & Racial Discrimination Brochure
- Exhibit 90c - Ontario's Human Rights Code - Racial Harassment Brochure
- List of arguably relevant documents - AMENDED
- Witness list - AMENDED
- Anticipated evidence of witnesses - AMENDED
(May 8, 2012) - HRTO Case Assessment Direction
- HRTO Case Assessment Direction
- Mirco Dabic v. Windsor Police Service
- Pellerin v. Conseil scolaire de district catholique Centre-Sud
(May 14, 2012) - Respondent's Additional Disclosure
(February 10, 2016) - Respondent's Additional Disclosure
Correspondence
- E-mail Correspondence - Volume 1
- E-mail Correspondence - Volume 2
- (December 12, 2010) - Statutory Declaration of Michael Jack
- (December 13, 2010) (FDH LLP) - Re Application to the Human Rights Tribunal of Ontario of Michael Jack
- (December 14, 2010) (HRTO 2010-07633-I) - Form 1 - Application under Section 34 of the Human Rights Code)
- (December 14, 2010) (HRTO 2010-07633-I) - Form 1, Page 11 - Application under Section 34 of the Human Rights Code
- (December 14, 2010) (HRTO 2010-07633-I) - Form 1-A - Application to the Human Rights Tribunal of Ontario Area of Discrimination Employment
- (December 13, 2010) (HRTO 2010-07633-I) - Application to the Human Rights Tribunal of Ontario of Michael Jack (Schedule A)
- (December 13, 2010) (HRTO 2010-07633-I) - Application to the Human Rights Tribunal of Ontario of Michael Jack (Schedule B)
- (January 10, 2011) - Correspondence from the Ministry of the Attorney General Re Application
- (January 18, 2011) (FDH LLP) - Re Human Rights Tribunal of Ontario File No. 2010-07633-I - Michael Jack
- (February 11, 2011) (FDH LLP) - File Pickup Receipt
- (January 20, 2011) (MCSCS) - Subject Request Number CSCS-P-2011-00058
- (March 11, 2011) (HRTO 2010-07633-I) - Envelope to the Office of the Independent Police Review
- (March 11, 2011) (HRTO 2010-07633-I) - Notice of Application
- (May 4, 2011) (HRTO 2010-07633-I) - Respondent's Response to the Application
- (May 12, 2011) (HRTO 2010-07633-I) - Form 23 - Applicant's Reply to the Respondent's Response to the Application
- (May 13, 2011) (HRTO 2010-07633-I) - Applicant's Statement of Delivery
- (May 30, 2011)(HRTO 2010-07633-I) - Request for an Extension of Time by Counsel for the Respondent
- (November 22, 2011) (HRTO 2010-07633-I) - HRTO Notice of Confirmation of Hearing
- (January 13, 2012) (HRTO 2010-07633-I) - Cover letter from Counsel for the Respondent Re disclosure of all arguable documents - (rec'd January 16, 2012)
- (January 13, 2012) (HRTO 2010-07633-I) - Form 23 - Applicant's Statement of Delivery
- (January 16, 2012) (HRTO 2010-07633-I) - Form 23 - Applicant's Statement of Delivery
- (February 2, 2012) (HRTO 2010-07633-I) - Letter from Counsel Lynette D'Souza to Lloyd Tapp re Michael Jack vs HMQ
- (February 2, 2012) (HRTO 2010-07633-I) - Response from Lloyd Tapp to letter from Counsel Lynette D'Souza
- (February 3, 2012) (HRTO 2010-07633-I) - Form 23 - Applicant's Statement of Delivery and a Cover letter
- (February 3, 2012) (HRTO 2010-07633-I) - Form 23 - Applicant's Statement of Delivery
- (February 17, 2012) (HRTO 2010-07633-I) - Form 23 - Counsel's Statement of Delivery - (rec'd February 17, 2012, but dated February 18, 2012)
- (February 20, 2012) - Correspondence with Tatiana Tkatch (Legal Assistant at the Ministry of the Attorney General)
- (February 24, 2012) - Confirmation of receipt of complaint from LUSC
- (March 20, 2012) (HRTO 2010-07633-I) - Form 10 - Counsel's Request for an Order During Proceedings
- (March 23, 2012) (HRTO 2010-07633-I) - Counsel's Request for Mediation
- (March 26, 2012) (HRTO 2010-07633-I) - Form 23 - Applicant's Statement of Delivery
- (April 4, 2012) (HRTO 2010-07633-I) - Form 11 - Applicant's Response to Counsel's Request for a Order During Proceedings (Form 10)
- (April 4, 2012) (HRTO 2010-07633-I) - Form 23 - Applicant's Statement of Delivery
- (April 9, 2012) (HRTO 2010-07633-I) - Form 10 - Applicant's Request for an Order During Proceedings
- (April 10, 2012) (HRTO 2010-07633-I) - Form 23 - Applicant's Statement of Delivery 1
- (April 10, 2012) (HRTO 2010-07633-I) - Form 23 - Applicant's Statement of Delivery 2
- (April 12, 2012) - LSUC Complainant Process Survey
- (April 23, 2012) (HRTO 2010-07633-I) - Case Assessment Direction of the HRTO
- (April 25, 2012) (2010-07633-I) - Notice of Case Management Conference Call (email)
- (April 25, 2012) (HRTO 2010-07633-I) - Letter of Authorization from Michael Jack for HRTO
- (April 30, 2012) (HRTO 2010-07633-I) - Notice of Case Management Conference Call (snail mail)
- (May 4, 2012) (HRTO 2010-07633-I) - Form 11 - Applicant's Response to the Request for a Order During Proceedings (Form 10)
- (May 4, 2012) (HRTO 2010-07633-I) - Form 23 - Applicant's Statement of Delivery
Various pertinent documents
- The New Ontario Human Rights System - Practice Tips and Case Update (2009)
- Best Practices for Paralegals Appearing Before the Human Rights Tribunal of Ontario (2010)
Audio recordings
- (October 30, 2009) - OPP's Professional Standards Bureau Interview of Contable Michael Jack
- (April 25, 2012) - Constable Kevin Duignan Re: Michael Jack
- (May 2, 2012) - Case Assesment Conference Call (1 of 6)
- (May 2, 2012) - Case Assesment Conference Call (2 of 6)
- (May 2, 2012) - Case Assesment Conference Call (3 of 6)
- (May 2, 2012) - Case Assesment Conference Call (4 of 6)
- (May 2, 2012) - Case Assesment Conference Call (5 of 6)
- (May 2, 2012) - Case Assesment Conference Call (6 of 6)
Transcripts of the Hearing
- September 22, 2015
- February 8, 2016
- February 9, 2016
- February 10, 2016
- February 11, 2016
- February 12, 2016
- September 7, 2016
- September 8, 2016
- September 9, 2016
- September 12, 2016
- September 13 ,2016
- September 14, 2016
- September 15 ,2016
Tendered Exhibits
- List of 228 tendered exhibits
- Exhibit 92 - Anticipated evidence of Michael Jack
- Exhibit 93 - Emails from Rathbun and Johnston (August 5, 2008)
- Exhibit 99 - Emails from Campbell to Johnston (August 18-21, 2009)
- Exhibit 102 - Emails Re: running a plate (September 22-23, 2009)
- Exhibit 136 - Follow up on Background Investigation (August 2008)
- Exhibit 155 - Email from Campbell to Johnston (August 21, 2009)
- Exhibit 192 - Emails Re: running a plate (September, 2009)
Submissions
- (October 2, 2015) - SUBMISSIONS OF THE APPLICANT ON REASONABLE PROSPECT OF SUCCESS
- SUBMISSIONS
- Index
- Title page
- References
- Applicant's Submissions on Reasonable Prospect of Success
- Proof of service
- BOOK OF AUTHORITIES
- Ont. Human Rights Comm. v. Simpsons-Sears, [1985] SCR 536, 1985 CanLII 18 (SCC)
- Dhanjal v. Canada (Human Rights Commission), 1997, 139 FTR 37
- Pellerin v. Conseil scolaire de district catholique Centre-Sud. 20112 HRTO 1777
- Mirco Dabic v. Windsor Police Service, 2010 HRTO 1994
- Jacqueline Nassiah v. Peel (Regional Municipality) Services Board, 2007 HRTO 14
- SCHEDULE A
- Jack vs OPP, Schedule A
- HUMAN RIGHTS CODE, R.S.O. 1990, C. H. 19.
- Ontario’s Human Rights Code - Racism & Racial Discrimination Brochure
- Ontario’s Human Rights Code - Racial Harassment Brochure
- Policy_on_discrimination_and_language, OHRC 2009
- SCHEDULE B
- Jack vs OPP, Schedule B
- (October 5, 2015) - SUBMISSIONS OF THE RESPONDENT TO DISMISS THE APPLICATION
- SUBMISSIONS
- JACK v OPP REPLY (9 OCT 2015)
- Appendix A - Chart RE DNM requirements for PERs 6 to 11 (FINAL)
- Marshall Appendix B
- (December 5, 2016) - CLOSING SUBMISSIONS OF THE APPLICANT
- SUBMISSIONS
- APPLICATION PARTICULARS
- TABLE OF CONTENTS
- TENDERED EXHIBITS
- CLOSING SUBMISSIONS
- SCHEDULE A
- SCHEDULE 'A'
- HUMAN RIGHTS CODE, R.S.O. 1990, C. H. 19
- Policy on discrimination and language, OHRC 2009
- Ontario’s Human Rights Code - Racism & Racial Discrimination Brochure
- Ontario’s Human Rights Code - Racial Harassment Brochure
- BOOK OF AUTHORITIES
- TITLE PAGE
- R v. BARROS, 2011 SCC 51
- R. v. DAVIS, [1999] 3 SCR 759, 1999 CanLII 638 (SCC)
- (February 6, 2017) - CLOSING SUBMISSIONS OF THE RESPONDENT
- Cover letter
- CLOSING SUBMISSION
- Beldjehem_v._University_of_Ottawa_(Telfer_Sc
- F.H._v._McDougall,_[2008]_3_S.C.R._41
- General_Motors_of_Canada_Limited_v._Johnson_
- McGill_University_Health_Centre_(Montreal_Ge
- Morin_v._Canada_(Attorney_General),_[2005]_C
- Toronto_(City)_Police_Service_v._Phipps,_[20
- Whale_v._Keele_North_Recycling_Inc.,_[2011]_
- (March 5, 2017) - APPLICANT'S REPLY TO CLOSING SUBMISSIONS OF THE RESPONDENT
- TITLE PAGE FOR REPLY
- SCHEDULE 'A'
- Reply to Counsel objections
- Applicant's Reply to Counsel's Submissions
- September 11, 2009 Email from Flindall to Johnston Re Jack
- Probationary Recruit Performance Evaluation Report Guidelines.
- Email from Blutstein Re Brockley Willsay sent on February 10, 2016
- Brockley's second Will-say sent on February 10, 2016
- Email Re Issues to be addressed at February 25, 2016, CMTC (February 24, 2016)
- BOOK OF AUTHORITIES
- TITLE PAGE FOR BOOK OF AUTHORITIES
- R. v. Romeo, [1991] 1 SCR 86
- Beldjehem_v._University_of_Ottawa_(Telfer_Sc
(February 5, 2018) - HRTO Decision
(March 1, 2018) - Request for Reconsideration
- TITLE PAGE
- TABLE OF CONTENTS
- Request for Reconsideration – Rule 26 Form 20
- (HRTO 2010-07633-I) - Form 23
- Request for Reconsideration (docx)
- Request for Reconsideration (pdf)
- Audmax Inc. v. Ontario Human Rights Tribunal, 2011 ONSC 315
- British Columbia (Public Service Employee Relations Commission) v. BCGSEU, [1999] 3 SCR 3, 1999
- Thwaites v. Canadian Armed Forces, 1993 342 (CHRT)
- Shaw v. Phipps, 2012 ONCA 155
(April 12, 2018) - Response
Press Releases
- The Peterborough Examiner - Former Peterborough County OPP probationary officer files human rights complaint over treatment at detachment
- Peterborough This Week - Former OPP employee to taking racism allegations to Human Rights Tribunal
- Peterborough This Week - Former OPP employee to taking racism allegations to Human Rights Tribunal - Scanned Newspaper Article
- Former OPP officer says racial discrimination led to firing