There seems to be something wrong with my computer program as I can't edit or delete. Well, that is what happens when you have a 20 years old computer that acts up most days. I do not know how the petition floated into my blog and I can't delete it. Oh well it is filed for public viewing in the supreme court registry so nothing is secret.
I can't get over what is happening. The lawyers for Vancouver Coastal Health are wanting me to be banned 100% because I disrupt management. What a joke. What are they saying, they do not know how to manage. All I want to do is be with Randy as he is fragile, he may die soon, and I want to make sure GPC is following is health plan. To me it is simple so why is it so difficult for them..
The idea that Kip Woodward would be upset because I sent him emails does not make sense. What do you think Chairmans get when their staff do not answer emails from the public. You are going to send them to the Chairman, the Police Commissioner, the Ministers of BC, the Prime Minister of Canada.
I want to see the emails that I sent to Kip Woodward. I am sure there might be some good ideas for management in them on how to better manage VCH. I suspect if Kip knew that he was now a public record over emails in the court house he would not be pleased with Clark Wilson.or his secretary.
As for my friend Stephanie, I am very disappointed in her, she created the incident on October 22, 2013 and then she lied about it and she further lied when she said I threatened her. Her statement on a report November 20 2013 just shows how she is. She said that I was sneaking into Randy's room to get some of his stuff to take to VGH and she had to phone security.. I wasn't sneaking it, I walked in front of everyone. No one said anything, why should they.
The next thing she did was cruel. Karen, her husband had just died, and she was distraught and I tried to comfort her and Stephanie won't let me. When Karen was at VCH with Guy, her husband, I always visited them. We were friends and we shared things like Randy's radio with Guy. We would go for a beverage together. But at GPC we were prevented from even acknowledging each other and her loss. And Stephanie reports it like she was saving Karen from the wicked witch from the west..
Stephanie is a very attractive woman, beautiful in fact, and everyone especially men nurses, fall over her. Watching them is entertaining. the power that woman has in leading a mob.
I suspect she is the one who complained of post traumatic stress and
took off two days with pay. Discrediting someone like me would
deserves a few days off with pay. Incident reports written by Paladin
mean nothing. They are trained to create situations ad make people look
bad. They are not even capable of being observant making out that Randy has an electric
wheel chair that would translate to a dangerous vehicle when in fact
Randy has a light-wight manual one. Her knowledge of patient's rights
are nil. Randy has the right to leave GPC whenever he wants.. He
cannot be imprisoned. I still haven't seem any documentation from VGH
which I have asked for that says that they can force Randy to remain
there. The only reason he is there is because I was told there is no
other facility to take him due to his injuries. If there is no where
else to go then he is imprisoned/forced there. He can come home if they would
supply nursing for him and the equipment and the meds. It can't be that
difficult for them to do. But who says VCP has commonsense or cares about its patients or families.
It always amazes me about the amount of money these health professionals make and hearing Tanu say that nothing can happen to her because she is a public servant. So she can lie and emotionally destroy people's lives. You should hear scream at her staff:: no one is going to defy me...So if anyone quits it is not because of me, it is because of her. If the stress is so great, why doesn't she quit. The rumour that the two managers of GPC prior to Ro, who is a friend of Tanu, quit because of her. So maybe Kip Woodward should contact them and find out about Tanu's treatment of staff, patients and visitors. .
The staff at GPC should let the residents live and stay out of their personal lives. Their job is to nurse not to control everything.Form 32 (Rule 8-1(4))
IN THE SUPREME COURT OF BRITISH COLUMBIA
BETWEEN:
AUDREY JANE LAFERRIERE and RANDY MICHAEL WALKER
AND:
VANCOUVER COASTAL HEALTH AUTHORITY
NOTICE OF APPLICATION
Name of Applicant: Vancouver Coastal Health Authority ("VCH")
To: Audrey Jane Laferriere and Randy Michael Walker
TAKE NOTICE that an application will be made by the Applicant to the presiding Judge at the Courthouse
at 800 Smithe St., Vancouver, BC on 8/Apr/2014 at 9:45am for the Orders set out in Part 1 below.
PART 1: ORDERS SOUGHT
1. An injunction, enjoining and restraining the Petitioner, Ms. Laferriere, by herself, or by
her agents and servants, from participating in any of the following activities:
(a) attending at any of the VCH properties, including but not limited to the George Pearson
Centre located at 757 West 57th Avenue, Vancouver, BC, except in circumstances in
which Mr. Walker’s physician deems that Mr. Walker is imminently terminal, in which
case VCH will promptly make arrangements for Ms. Laferriere to attend the George
Pearson Centre; and
(b) contacting, by email or phone, any doctors that care for Mr. Walker, or any staff,
administration, or board members of VCH, except for Richard Singleton, Director of Risk
Management for VCH and Romila Ang, Manager of the George Pearson Centre.
2. An order that any peace officer, including any officer of the Vancouver Police
Department or the R.C.M.P. having jurisdiction in the province of British Columbia, who on reasonable
and probable grounds believes that Audrey Jane Laferriere is in breach of the terms of this order may
immediately arrest that person and bring her before a judge of the Supreme Court promptly after the
arrest, to be dealt with on an inquiry to determine whether she has committed a breach of this order;
CW7 117020.1
3. Costs of this application be awarded to the defendant, VCH; and
4. Such further and other directions and orders as this Honourable Court considers just
and equitable.
PART 2: FACTUAL BASIS
Background
1. The Petitioner, Randy Michael Walker, was involved in a catastrophic injury in or about
June 2010 that left him in a state of quadriplegia. Mr. Walker uses a tracheostomy tube to assist him
with breathing.
2. Mr. Walker was first transferred to George Pearson Centre located at 757 West 57th
Avenue, Vancouver, BC ("GPC") in or about November 2010 due to the need for constant care.
3. At present, Mr. Walker is in a fragile state, but his condition has not worsened for
several months and there are no signs that suggest that there is an immediate risk of death as the
Petitioner suggests.
4. Since Mr. Walker began residing at GPC, Ms. Laferriere has been a regular visitor.
5. It is unclear what relationship Mr. Walker and Ms. Laferriere have with one another. Ms.
Laferriere has, at various times, described her relationship to Mr. Walker as one of "friend", "confidant",
"surrogate", "representative", "wife", and "advocate".
6. Mr. Walker purportedly signed a Representation Agreement pursuant to section 9 of the
Representation Agreement Act on January 31, 2013, in which Ms. Laferriere was purportedly given
authority to obtain medical records, make housing choices for Mr. Walker, and negate any "do not
resuscitate" orders pertaining to Mr. Walker.
7. VCH has abided by the Representation Agreement and has treated Ms. Laferriere as Mr.
Walker’s health care decision maker when Mr. Walker is incapable of making informed decisions about
his health care. VCH health care providers contact Ms. Laferriere by phone when health care decisions
are required, and will continue to do so as long as Ms. Laferriere is Mr. Walker’s representative.
Procedural History
8. Because of Ms. Laferriere’s behaviour (described in detail below) and in efforts to
protect the safety of all parties involved, VCH has, on multiple occasions, imposed restrictions on Ms.
Laferriere’s visitation rights. Ms. LaFerriere has repeatedly and flagrantly disregarded these restrictions.
9. As a result of Ms. Laferriere’s continued aggressive behavior towards the GPC staff and
her disregard for VCH’s restrictions of access, on January 29, 2014, Richard Singleton, the Director of
Risk Management and Client Relations at VCH, issued a Trespass Notification banning Ms. Laferriere
from attending GPC for 90 days, except for any personal medical attention.
10. Although restrictions have been placed on Ms. Laferriere’s access to GPC at various
times since Mr. Walker began residing at GPC, VCH has always been and remains committed to
CW7117020.1
providing Ms. Laferriere access to Mr. Walker outside of the GPC grounds. VCH has facilitated visits at
places such as the Oakridge Mall, at the curbside of GPC, etc.
11. Ms. Laferriere filed a Petition dated March 14, 2014 in which she sought orders for 16
different forms of relief. Ms. Laferriere also sought, and was granted, short leave to have heard one of
the orders sought: that listed in Paragraph 13 of the Petition in which Ms. Laferriere sought unrestricted
and unsupervised 24/7 access to Mr. Walker.
12. VCH filed Response materials on March 17, 2014 and the hearing of the issue outlined in
Paragraph 13 of Ms. Laferriere’s Petition took place on March 18, 2014.
13. The Public Guardian and Trustee, through its counsel, attended the hearing on March
18, 2014 and sought an adjournment of the hearing in order to consider issues related to Mr. Walker’s
interests.
14. VCH consented to an adjournment, which was eventually granted by the order of
Master MacNaughton. Specifically, Master MacNaughton ordered that the matter be heard on April 8,
2014 in front of a judge, rather than a master.
Ms. Laferriere’s Behavioural History
15. Ms. Laferriere has a long history of violent and aggressive behaviour towards staff
members at GPC, VCH in general, and even the members of the Vancouver Police Department who
attended the GPC on numerous occasions to deal with or assist with escorting Ms. Laferriere out of the
facility.
16. Ms. Laferriere’s behaviour includes violent physical conduct, harassing emails, blog post
entries alleging incompetence and illegal conduct on VCH’s part, and picketing at GPC and elsewhere.
17. One particular example of Ms. Laferriere’s violent and aggressive behaviour occurred on
October 21, 2013. On that day, Ms. Laferriere trespassed into the room of a resident other than Mr.
Walker at GPC. When asked to leave the facility, Ms. Laferriere refused, then later attempted to leave
the facility with Mr. Walker in his electric wheelchair. Staff prevented Ms. Laferriere from removing Mr.
Walker, and in response, Ms. Laferriere punched two staff members, attempted to hit staff with Mr.
Walker’s wheelchair, and bit the hand of a security guard. Ms. Laferriere later punched a police officer in
the face.
18. Ms. Laferriere has created over 200 internet blog entries associated with VCH since
March 2011. Blog entries have included professional emails and phone numbers of VCH employees and
board members.
19. Ms. Laferriere has also created pamphlets that have been posted on buses and bus
stops and that relate to VCH. In these pamphlets, Ms. Laferriere has included the email addresses and
phone numbers of VCH employees and board members.
20. Ms. Laferriere has also picketed at the Oakridge Centre Mall regarding her grievances
with VCH and the George Pearson Centre.
CW7 117020.1
21. Since the Trespass Notification was issued on January 29, 2014, Ms. Laferriere has
repeatedly attempted to access GPC contrary to the terms of the Trespass Notification. On numerous
occasions, Ms. Laferriere has violated the Trespass Notification. On each of these occasions, the
Vancouver Police have been called and have attended at GPC, typically arriving 90-120 minutes after
being called, but on no occasions have they removed Ms. Laferriere from GPC.
22. GPC is a large complex with over 50 entrances, and since the Trespass Notification was
issued, Paladin Security Officers have not been able to prevent Ms. Laferriere from entering GPC, nor
have they been able to compel her to leave.
23. Since the decision of Master MacNaughton handed down on March 18, 2014, VCH has
arranged curb-side visits between Mr. Walker and Ms. Laferriere on days that Mr. Walker is physically
capable of leaving the GPC facility.
24. Dr. James Dunne, the physician of record for Mr. Walker, determines on a day-to-day
basis if Mr. Walker is fit to leave the GPC facility to visit with Ms. Laferriere.
25. Also since March 18, 2014, Ms. Laferriere has continued to attempt to access Mr.
Walker at GPC on days which Dr. Dunne deems Mr. Walker unfit to leave the GPC facility.
26. In addition, Ms. Laferriere has continued to create internet blog posts in which specific
GPC and VCH staff members are identified and their contact information provided. Ms. Laferriere has
also created and distributed flyers with contact information of specific VCH board members.
The Effect of Ms. Laferriere’s Behaviour on Staff at VCH
27. As a result of the incident on October 21, 2013, VCH brought in Dr. Georgia Nemetz, a
psychologist in private practice, to conduct two critical incident debriefing sessions with the GPC
employees. Approximately 25 workers from GPC and VCH attended these two sessions.
28. Dr. Nemetz was extremely concerned about the cumulative impact of Ms. Laferriere’s
behaviour on the staff of GPC and VCH. Dr. Nemetz identified two employees who have had indications
of Post-Traumatic Stress Disorder (PTSD) associated to ongoing interactions with Ms. Laferriere.
29. As a result of the October 21, 2013 incident, VCH commissioned a Workplace Violence
Assessment of Ms. Laferriere (the "Assessment") by Kevin Calder, a Workplace Violence Specialist with
VCH, which report was finalized in January 2014.
30. In preparing the Assessment, Mr. Calder spoke to numerous employees at VCH and GPC
who have had interactions with Ms. Laferriere, and reviewed numerous reports prepared by the VCH’s
security officers and Paladin Security.
31. The Paladin Security Reports show that Ms. Laferriere repeatedly failed to follow
behavioural and access restrictions imposed on her by VCH, attempted to take Mr. Walker away from
GPC without permission on numerous occasions, and regularly verbally abused and acted aggressively
towards GPC staff.
CW7 117020.1
32. The Assessment concluded that Ms. Laferriere poses a high risk of demonstrating
affective (emotionally-based and unplanned) violence, and that her behaviour constitutes bullying and
harassment of GPC and the VCH staff.
33. Ms. Laferriere’s behaviour has led to significant issues amongst the staff at GPC. Many
staff members have been physically assaulted by Ms. Laferriere, and many fear that they will be singled
out and harassed by Ms. Laferriere. Ms. Laferriere poses a significant threat to staff, residents, and
visitors at George Pearson Centre.
34. Because of the above actions of Ms. Laferriere, staff and board members of VCH feel
threatened and are reluctant to interact with Ms. Laferriere out of fear that they will be singled out and
their personal information made public.
35. Certain staff members have also refused to escort Mr. Walker out of GPC to visit with
Ms. Laferriere because these interactions have been filmed, presumably at the direction of Ms.
Laferriere.
36. Ms. Laferriere’s actions negatively affect the care that Mr. Walker receives.
Police Involvement
37. The Vancouver Police Department has been called on numerous occasions in situations
where Ms. Laferriere has become threatening or violent or has accessed GPC contrary to restrictions
placed byVCH.
38. At present, when Ms. Laferriere attempts to access GPC contrary to the Trespass
Notification, staff at GPC call the Vancouver Police, who arrive, typically between 90-120 minutes after
being called. The Vancouver Police do not detain Ms. Laferriere and do not forcibly remove her from the
GPC premises. The typical response from the Vancouver Police is that the situation with Ms. Laferriere is
a civil matter and they will not involve themselves without a court order.
PART 3: LEGAL BASIS
1. VCH relies on the following legal bases:
(a) rule 10-4 of the Supreme Court Civil Rules, which provides for the ability of a party to
seek an injunction by order of the Court;
(b) rule 14-1 of the Supreme Court Civil Rules, which provides the framework for the
assessment of costs of applications;
(c) section 39 of the Law and Equity Act, R.S.B.C. 1996, c. 253, which provides for the
court’s ability to enjoin a party where it appears just or convenient to do so; and
(d) the inherent jurisdiction of the court.
2. The test for permanent injunctions is laid out in the case of Qureshi v. Gooch, 2005
B.C.S.C. 1584, in which the seminal case of Cadbury Schweppes Inc. v. FBI Foods Ltd., [1999] 1 S.C.R. 142
is cited.
CW7 117020.1
3. The issuance of a permanent injunction is a discretionary order and in deciding whether
to grant such an injunction, the court is to look at the nature of the rights that the injunction will
protect, the surrounding circumstances, and the balance of equities between the parties.
Cadbury Schweppes Inc. v. FBI Foods Ltd., [1999] 1 S.C.R. 142
4. Courts have considered a number of factors when determining if a permanent
injunction is appropriate including:
(a) whether an enforceable right and a threat/violation of that right exists;
Delta Hotels v. Okabe Canada Investments Co., (1991), 81 Alta L.R. (2d) 338 (OB)
(b) whether the applicant will suffer demonstrable harm should the injunction not be
granted;
Steeves Dairy Ltd. v. Twin City Co-operative Milk Producers Assn., [1926] 1 W.W.R. 25
(c) the hardship that would be caused to the party enjoined if the injunction were granted
compared to the hardship to the party seeking the injunction were the injunction not
granted;
Cadbury Schweppes Inc. v. FBI Foods Ltd., [1999] 1S.C.R. 142
(d) the conduct of the parties; and
(e) the effectiveness of an injunction.
Consideration of the Above Factors Favours the Granting of an Inlunction
5. VCH, and its staff and board members, would suffer demonstrable harm if an injunction
against Ms. Laferriere is not granted.
6. Ms. Laferriere’s attendance at GPC harms the ability of GPC’s staff to care for all of the
residents of GPC. As long as Ms. Laferriere continues to be able to attend GPC, the ability of VCH staff to
do their jobs is made more difficult.
7. Ms. Laferriere’s continued attendance at GPC also causes disruption to all those around
her, including other residents at GPC and their loved ones.
8. In addition, it is likely that if Ms. Laferriere continues to attend GPC, staff members at
GPC may quit or transfer to other departments. If staff members were to leave GPC, those departures
would be detrimental to the ability of staff at GHP to care for the residents of GPC.
9. The interests at issue in this proceeding are not simply the interests of Ms. Laferriere in
accessing Mr. Walker, they are the interests of all parties involved, including Mr. Walker, other residents
at GPC, staff at GPC, and visitors of other residents at GPC. Considering the detrimental impact that Ms.
CW7 117020.1
Laferriere’s behaviour has on all of the parties involved, the balance of convenience favours the granting
of an injunction preventing her access to GPC.
10. The opinion of Kevin Calder, Workplace Violence Specialist, is that nothing short of a
permanent ban of Ms. Laferriere will be effective in protecting the staff and visitors at GPC
PART 4: MATERIAL TO BE RELIED ON
1. Those materials filed by VCH on March 17, 2014.
2. Affidavit #1 of Tanvirezohra Batlawala, made,LApr/2014.
3. Affidavit #1 of Louise Kokotailo, made 64Apr/2014.
The Applicant estimates that the application will take 60 minutes.
D This matter is within the jurisdiction of a Master.
This matter is not within the jurisdiction of a Master.
TO THE PERSONS RECEIVING THIS NOTICE OF APPLICATION: If you wish to respond to this Notice of
Application, you must, within 5 business days after service of this Notice of Application or, if this
application is brought under Rule 9-7, within 8 business days after service of this Notice of Application:
(a) file an Application Response in Form 33;
(b) file the original of every Affidavit, and of every other document, that:
(i) you intend to refer to at the hearing of this application, and
(ii) has not already been filed in the proceeding; and
(c) serve on the Applicant 2 copies of the following, and on every other party of record one
copy of the following:
(i) a copy of filed Application Response;
(ii) a copy of each of the filed Affidavits and other documents that you intend to
refer to at the hearing of this application and that has not already been served
on that person;
(iii) if this application is brought under Rule 9-7, any notice that you are required to
give under Rule 9-7(9).
CW7 117020.1
Date: __JApr/2014
This NOTICE OF APPLICATION is prepared by Jordan Watson of the firm of Clark Wilson LLP whose place of
business is 900-885 West Georgia Street, Vancouver, British Columbia, V6C 3H1 (Direct #: 604-891-7703, Fax #:
604.687.6314, Email: jjw@cwilson.com) (File #: 37794).
To be completed by the court only:
Order made
El in the terms requested in paragraphs of Part 1 of this Notice of Application
o with the following variations and additional terms:
Date:
[dd/mmm/yyyy] Signature of 0 Judge 0 Master
CW7 117020.1
APPENDIX
[The following information is provided for data collection purposes only and is of no legal effect.]
THIS APPLICATION INVOLVES THE FOLLOWING:
D discovery: comply with demand for documents
o discovery: production of additional documents
o other matters concerning document discoveryForm 32 (Rule 8-1(4))
IN THE SUPREME COURT OF BRITISH COLUMBIA
BETWEEN:
AUDREY JANE LAFERRIERE and RANDY MICHAEL WALKER
AND:
VANCOUVER COASTAL HEALTH AUTHORITY
NOTICE OF APPLICATION
Name of Applicant: Vancouver Coastal Health Authority ("VCH")
To: Audrey Jane Laferriere and Randy Michael Walker
TAKE NOTICE that an application will be made by the Applicant to the presiding Judge at the Courthouse
at 800 Smithe St., Vancouver, BC on 8/Apr/2014 at 9:45am for the Orders set out in Part 1 below.
PART 1: ORDERS SOUGHT
1. An injunction, enjoining and restraining the Petitioner, Ms. Laferriere, by herself, or by
her agents and servants, from participating in any of the following activities:
(a) attending at any of the VCH properties, including but not limited to the George Pearson
Centre located at 757 West 57th Avenue, Vancouver, BC, except in circumstances in
which Mr. Walker’s physician deems that Mr. Walker is imminently terminal, in which
case VCH will promptly make arrangements for Ms. Laferriere to attend the George
Pearson Centre; and
(b) contacting, by email or phone, any doctors that care for Mr. Walker, or any staff,
administration, or board members of VCH, except for Richard Singleton, Director of Risk
Management for VCH and Romila Ang, Manager of the George Pearson Centre.
2. An order that any peace officer, including any officer of the Vancouver Police
Department or the R.C.M.P. having jurisdiction in the province of British Columbia, who on reasonable
and probable grounds believes that Audrey Jane Laferriere is in breach of the terms of this order may
immediately arrest that person and bring her before a judge of the Supreme Court promptly after the
arrest, to be dealt with on an inquiry to determine whether she has committed a breach of this order;
CW7 117020.1
3. Costs of this application be awarded to the defendant, VCH; and
4. Such further and other directions and orders as this Honourable Court considers just
and equitable.
PART 2: FACTUAL BASIS
Background
1. The Petitioner, Randy Michael Walker, was involved in a catastrophic injury in or about
June 2010 that left him in a state of quadriplegia. Mr. Walker uses a tracheostomy tube to assist him
with breathing.
2. Mr. Walker was first transferred to George Pearson Centre located at 757 West 57th
Avenue, Vancouver, BC ("GPC") in or about November 2010 due to the need for constant care.
3. At present, Mr. Walker is in a fragile state, but his condition has not worsened for
several months and there are no signs that suggest that there is an immediate risk of death as the
Petitioner suggests.
4. Since Mr. Walker began residing at GPC, Ms. Laferriere has been a regular visitor.
5. It is unclear what relationship Mr. Walker and Ms. Laferriere have with one another. Ms.
Laferriere has, at various times, described her relationship to Mr. Walker as one of "friend", "confidant",
"surrogate", "representative", "wife", and "advocate".
6. Mr. Walker purportedly signed a Representation Agreement pursuant to section 9 of the
Representation Agreement Act on January 31, 2013, in which Ms. Laferriere was purportedly given
authority to obtain medical records, make housing choices for Mr. Walker, and negate any "do not
resuscitate" orders pertaining to Mr. Walker.
7. VCH has abided by the Representation Agreement and has treated Ms. Laferriere as Mr.
Walker’s health care decision maker when Mr. Walker is incapable of making informed decisions about
his health care. VCH health care providers contact Ms. Laferriere by phone when health care decisions
are required, and will continue to do so as long as Ms. Laferriere is Mr. Walker’s representative.
Procedural History
8. Because of Ms. Laferriere’s behaviour (described in detail below) and in efforts to
protect the safety of all parties involved, VCH has, on multiple occasions, imposed restrictions on Ms.
Laferriere’s visitation rights. Ms. LaFerriere has repeatedly and flagrantly disregarded these restrictions.
9. As a result of Ms. Laferriere’s continued aggressive behavior towards the GPC staff and
her disregard for VCH’s restrictions of access, on January 29, 2014, Richard Singleton, the Director of
Risk Management and Client Relations at VCH, issued a Trespass Notification banning Ms. Laferriere
from attending GPC for 90 days, except for any personal medical attention.
10. Although restrictions have been placed on Ms. Laferriere’s access to GPC at various
times since Mr. Walker began residing at GPC, VCH has always been and remains committed to
CW7117020.1
providing Ms. Laferriere access to Mr. Walker outside of the GPC grounds. VCH has facilitated visits at
places such as the Oakridge Mall, at the curbside of GPC, etc.
11. Ms. Laferriere filed a Petition dated March 14, 2014 in which she sought orders for 16
different forms of relief. Ms. Laferriere also sought, and was granted, short leave to have heard one of
the orders sought: that listed in Paragraph 13 of the Petition in which Ms. Laferriere sought unrestricted
and unsupervised 24/7 access to Mr. Walker.
12. VCH filed Response materials on March 17, 2014 and the hearing of the issue outlined in
Paragraph 13 of Ms. Laferriere’s Petition took place on March 18, 2014.
13. The Public Guardian and Trustee, through its counsel, attended the hearing on March
18, 2014 and sought an adjournment of the hearing in order to consider issues related to Mr. Walker’s
interests.
14. VCH consented to an adjournment, which was eventually granted by the order of
Master MacNaughton. Specifically, Master MacNaughton ordered that the matter be heard on April 8,
2014 in front of a judge, rather than a master.
Ms. Laferriere’s Behavioural History
15. Ms. Laferriere has a long history of violent and aggressive behaviour towards staff
members at GPC, VCH in general, and even the members of the Vancouver Police Department who
attended the GPC on numerous occasions to deal with or assist with escorting Ms. Laferriere out of the
facility.
16. Ms. Laferriere’s behaviour includes violent physical conduct, harassing emails, blog post
entries alleging incompetence and illegal conduct on VCH’s part, and picketing at GPC and elsewhere.
17. One particular example of Ms. Laferriere’s violent and aggressive behaviour occurred on
October 21, 2013. On that day, Ms. Laferriere trespassed into the room of a resident other than Mr.
Walker at GPC. When asked to leave the facility, Ms. Laferriere refused, then later attempted to leave
the facility with Mr. Walker in his electric wheelchair. Staff prevented Ms. Laferriere from removing Mr.
Walker, and in response, Ms. Laferriere punched two staff members, attempted to hit staff with Mr.
Walker’s wheelchair, and bit the hand of a security guard. Ms. Laferriere later punched a police officer in
the face.
18. Ms. Laferriere has created over 200 internet blog entries associated with VCH since
March 2011. Blog entries have included professional emails and phone numbers of VCH employees and
board members.
19. Ms. Laferriere has also created pamphlets that have been posted on buses and bus
stops and that relate to VCH. In these pamphlets, Ms. Laferriere has included the email addresses and
phone numbers of VCH employees and board members.
20. Ms. Laferriere has also picketed at the Oakridge Centre Mall regarding her grievances
with VCH and the George Pearson Centre.
CW7 117020.1
21. Since the Trespass Notification was issued on January 29, 2014, Ms. Laferriere has
repeatedly attempted to access GPC contrary to the terms of the Trespass Notification. On numerous
occasions, Ms. Laferriere has violated the Trespass Notification. On each of these occasions, the
Vancouver Police have been called and have attended at GPC, typically arriving 90-120 minutes after
being called, but on no occasions have they removed Ms. Laferriere from GPC.
22. GPC is a large complex with over 50 entrances, and since the Trespass Notification was
issued, Paladin Security Officers have not been able to prevent Ms. Laferriere from entering GPC, nor
have they been able to compel her to leave.
23. Since the decision of Master MacNaughton handed down on March 18, 2014, VCH has
arranged curb-side visits between Mr. Walker and Ms. Laferriere on days that Mr. Walker is physically
capable of leaving the GPC facility.
24. Dr. James Dunne, the physician of record for Mr. Walker, determines on a day-to-day
basis if Mr. Walker is fit to leave the GPC facility to visit with Ms. Laferriere.
25. Also since March 18, 2014, Ms. Laferriere has continued to attempt to access Mr.
Walker at GPC on days which Dr. Dunne deems Mr. Walker unfit to leave the GPC facility.
26. In addition, Ms. Laferriere has continued to create internet blog posts in which specific
GPC and VCH staff members are identified and their contact information provided. Ms. Laferriere has
also created and distributed flyers with contact information of specific VCH board members.
The Effect of Ms. Laferriere’s Behaviour on Staff at VCH
27. As a result of the incident on October 21, 2013, VCH brought in Dr. Georgia Nemetz, a
psychologist in private practice, to conduct two critical incident debriefing sessions with the GPC
employees. Approximately 25 workers from GPC and VCH attended these two sessions.
28. Dr. Nemetz was extremely concerned about the cumulative impact of Ms. Laferriere’s
behaviour on the staff of GPC and VCH. Dr. Nemetz identified two employees who have had indications
of Post-Traumatic Stress Disorder (PTSD) associated to ongoing interactions with Ms. Laferriere.
29. As a result of the October 21, 2013 incident, VCH commissioned a Workplace Violence
Assessment of Ms. Laferriere (the "Assessment") by Kevin Calder, a Workplace Violence Specialist with
VCH, which report was finalized in January 2014.
30. In preparing the Assessment, Mr. Calder spoke to numerous employees at VCH and GPC
who have had interactions with Ms. Laferriere, and reviewed numerous reports prepared by the VCH’s
security officers and Paladin Security.
31. The Paladin Security Reports show that Ms. Laferriere repeatedly failed to follow
behavioural and access restrictions imposed on her by VCH, attempted to take Mr. Walker away from
GPC without permission on numerous occasions, and regularly verbally abused and acted aggressively
towards GPC staff.
CW7 117020.1
32. The Assessment concluded that Ms. Laferriere poses a high risk of demonstrating
affective (emotionally-based and unplanned) violence, and that her behaviour constitutes bullying and
harassment of GPC and the VCH staff.
33. Ms. Laferriere’s behaviour has led to significant issues amongst the staff at GPC. Many
staff members have been physically assaulted by Ms. Laferriere, and many fear that they will be singled
out and harassed by Ms. Laferriere. Ms. Laferriere poses a significant threat to staff, residents, and
visitors at George Pearson Centre.
34. Because of the above actions of Ms. Laferriere, staff and board members of VCH feel
threatened and are reluctant to interact with Ms. Laferriere out of fear that they will be singled out and
their personal information made public.
35. Certain staff members have also refused to escort Mr. Walker out of GPC to visit with
Ms. Laferriere because these interactions have been filmed, presumably at the direction of Ms.
Laferriere.
36. Ms. Laferriere’s actions negatively affect the care that Mr. Walker receives.
Police Involvement
37. The Vancouver Police Department has been called on numerous occasions in situations
where Ms. Laferriere has become threatening or violent or has accessed GPC contrary to restrictions
placed byVCH.
38. At present, when Ms. Laferriere attempts to access GPC contrary to the Trespass
Notification, staff at GPC call the Vancouver Police, who arrive, typically between 90-120 minutes after
being called. The Vancouver Police do not detain Ms. Laferriere and do not forcibly remove her from the
GPC premises. The typical response from the Vancouver Police is that the situation with Ms. Laferriere is
a civil matter and they will not involve themselves without a court order.
PART 3: LEGAL BASIS
1. VCH relies on the following legal bases:
(a) rule 10-4 of the Supreme Court Civil Rules, which provides for the ability of a party to
seek an injunction by order of the Court;
(b) rule 14-1 of the Supreme Court Civil Rules, which provides the framework for the
assessment of costs of applications;
(c) section 39 of the Law and Equity Act, R.S.B.C. 1996, c. 253, which provides for the
court’s ability to enjoin a party where it appears just or convenient to do so; and
(d) the inherent jurisdiction of the court.
2. The test for permanent injunctions is laid out in the case of Qureshi v. Gooch, 2005
B.C.S.C. 1584, in which the seminal case of Cadbury Schweppes Inc. v. FBI Foods Ltd., [1999] 1 S.C.R. 142
is cited.
CW7 117020.1
3. The issuance of a permanent injunction is a discretionary order and in deciding whether
to grant such an injunction, the court is to look at the nature of the rights that the injunction will
protect, the surrounding circumstances, and the balance of equities between the parties.
Cadbury Schweppes Inc. v. FBI Foods Ltd., [1999] 1 S.C.R. 142
4. Courts have considered a number of factors when determining if a permanent
injunction is appropriate including:
(a) whether an enforceable right and a threat/violation of that right exists;
Delta Hotels v. Okabe Canada Investments Co., (1991), 81 Alta L.R. (2d) 338 (OB)
(b) whether the applicant will suffer demonstrable harm should the injunction not be
granted;
Steeves Dairy Ltd. v. Twin City Co-operative Milk Producers Assn., [1926] 1 W.W.R. 25
(c) the hardship that would be caused to the party enjoined if the injunction were granted
compared to the hardship to the party seeking the injunction were the injunction not
granted;
Cadbury Schweppes Inc. v. FBI Foods Ltd., [1999] 1S.C.R. 142
(d) the conduct of the parties; and
(e) the effectiveness of an injunction.
Consideration of the Above Factors Favours the Granting of an Inlunction
5. VCH, and its staff and board members, would suffer demonstrable harm if an injunction
against Ms. Laferriere is not granted.
6. Ms. Laferriere’s attendance at GPC harms the ability of GPC’s staff to care for all of the
residents of GPC. As long as Ms. Laferriere continues to be able to attend GPC, the ability of VCH staff to
do their jobs is made more difficult.
7. Ms. Laferriere’s continued attendance at GPC also causes disruption to all those around
her, including other residents at GPC and their loved ones.
8. In addition, it is likely that if Ms. Laferriere continues to attend GPC, staff members at
GPC may quit or transfer to other departments. If staff members were to leave GPC, those departures
would be detrimental to the ability of staff at GHP to care for the residents of GPC.
9. The interests at issue in this proceeding are not simply the interests of Ms. Laferriere in
accessing Mr. Walker, they are the interests of all parties involved, including Mr. Walker, other residents
at GPC, staff at GPC, and visitors of other residents at GPC. Considering the detrimental impact that Ms.
CW7 117020.1
Laferriere’s behaviour has on all of the parties involved, the balance of convenience favours the granting
of an injunction preventing her access to GPC.
10. The opinion of Kevin Calder, Workplace Violence Specialist, is that nothing short of a
permanent ban of Ms. Laferriere will be effective in protecting the staff and visitors at GPC
PART 4: MATERIAL TO BE RELIED ON
1. Those materials filed by VCH on March 17, 2014.
2. Affidavit #1 of Tanvirezohra Batlawala, made,LApr/2014.
3. Affidavit #1 of Louise Kokotailo, made 64Apr/2014.
The Applicant estimates that the application will take 60 minutes.
D This matter is within the jurisdiction of a Master.
This matter is not within the jurisdiction of a Master.
TO THE PERSONS RECEIVING THIS NOTICE OF APPLICATION: If you wish to respond to this Notice of
Application, you must, within 5 business days after service of this Notice of Application or, if this
application is brought under Rule 9-7, within 8 business days after service of this Notice of Application:
(a) file an Application Response in Form 33;
(b) file the original of every Affidavit, and of every other document, that:
(i) you intend to refer to at the hearing of this application, and
(ii) has not already been filed in the proceeding; and
(c) serve on the Applicant 2 copies of the following, and on every other party of record one
copy of the following:
(i) a copy of filed Application Response;
(ii) a copy of each of the filed Affidavits and other documents that you intend to
refer to at the hearing of this application and that has not already been served
on that person;
(iii) if this application is brought under Rule 9-7, any notice that you are required to
give under Rule 9-7(9).
CW7 117020.1
Date: __JApr/2014
This NOTICE OF APPLICATION is prepared by Jordan Watson of the firm of Clark Wilson LLP whose place of
business is 900-885 West Georgia Street, Vancouver, British Columbia, V6C 3H1 (Direct #: 604-891-7703, Fax #:
604.687.6314, Email: jjw@cwilson.com) (File #: 37794).
To be completed by the court only:
Order made
El in the terms requested in paragraphs of Part 1 of this Notice of Application
o with the following variations and additional terms:
Date:
[dd/mmm/yyyy] Signature of 0 Judge 0 Master
CW7 117020.1
APPENDIX
[The following information is provided for data collection purposes only and is of no legal effect.]
THIS APPLICATION INVOLVES THE FOLLOWING:
D discovery: comply with demand for documents
o discovery: production of additional documents
o other matters concerning document discoveryForm 32 (Rule 8-1(4))
IN THE SUPREME COURT OF BRITISH COLUMBIA
BETWEEN:
AUDREY JANE LAFERRIERE and RANDY MICHAEL WALKER
AND:
VANCOUVER COASTAL HEALTH AUTHORITY
NOTICE OF APPLICATION
Name of Applicant: Vancouver Coastal Health Authority ("VCH")
To: Audrey Jane Laferriere and Randy Michael Walker
TAKE NOTICE that an application will be made by the Applicant to the presiding Judge at the Courthouse
at 800 Smithe St., Vancouver, BC on 8/Apr/2014 at 9:45am for the Orders set out in Part 1 below.
PART 1: ORDERS SOUGHT
1. An injunction, enjoining and restraining the Petitioner, Ms. Laferriere, by herself, or by
her agents and servants, from participating in any of the following activities:
(a) attending at any of the VCH properties, including but not limited to the George Pearson
Centre located at 757 West 57th Avenue, Vancouver, BC, except in circumstances in
which Mr. Walker’s physician deems that Mr. Walker is imminently terminal, in which
case VCH will promptly make arrangements for Ms. Laferriere to attend the George
Pearson Centre; and
(b) contacting, by email or phone, any doctors that care for Mr. Walker, or any staff,
administration, or board members of VCH, except for Richard Singleton, Director of Risk
Management for VCH and Romila Ang, Manager of the George Pearson Centre.
2. An order that any peace officer, including any officer of the Vancouver Police
Department or the R.C.M.P. having jurisdiction in the province of British Columbia, who on reasonable
and probable grounds believes that Audrey Jane Laferriere is in breach of the terms of this order may
immediately arrest that person and bring her before a judge of the Supreme Court promptly after the
arrest, to be dealt with on an inquiry to determine whether she has committed a breach of this order;
CW7 117020.1
3. Costs of this application be awarded to the defendant, VCH; and
4. Such further and other directions and orders as this Honourable Court considers just
and equitable.
PART 2: FACTUAL BASIS
Background
1. The Petitioner, Randy Michael Walker, was involved in a catastrophic injury in or about
June 2010 that left him in a state of quadriplegia. Mr. Walker uses a tracheostomy tube to assist him
with breathing.
2. Mr. Walker was first transferred to George Pearson Centre located at 757 West 57th
Avenue, Vancouver, BC ("GPC") in or about November 2010 due to the need for constant care.
3. At present, Mr. Walker is in a fragile state, but his condition has not worsened for
several months and there are no signs that suggest that there is an immediate risk of death as the
Petitioner suggests.
4. Since Mr. Walker began residing at GPC, Ms. Laferriere has been a regular visitor.
5. It is unclear what relationship Mr. Walker and Ms. Laferriere have with one another. Ms.
Laferriere has, at various times, described her relationship to Mr. Walker as one of "friend", "confidant",
"surrogate", "representative", "wife", and "advocate".
6. Mr. Walker purportedly signed a Representation Agreement pursuant to section 9 of the
Representation Agreement Act on January 31, 2013, in which Ms. Laferriere was purportedly given
authority to obtain medical records, make housing choices for Mr. Walker, and negate any "do not
resuscitate" orders pertaining to Mr. Walker.
7. VCH has abided by the Representation Agreement and has treated Ms. Laferriere as Mr.
Walker’s health care decision maker when Mr. Walker is incapable of making informed decisions about
his health care. VCH health care providers contact Ms. Laferriere by phone when health care decisions
are required, and will continue to do so as long as Ms. Laferriere is Mr. Walker’s representative.
Procedural History
8. Because of Ms. Laferriere’s behaviour (described in detail below) and in efforts to
protect the safety of all parties involved, VCH has, on multiple occasions, imposed restrictions on Ms.
Laferriere’s visitation rights. Ms. LaFerriere has repeatedly and flagrantly disregarded these restrictions.
9. As a result of Ms. Laferriere’s continued aggressive behavior towards the GPC staff and
her disregard for VCH’s restrictions of access, on January 29, 2014, Richard Singleton, the Director of
Risk Management and Client Relations at VCH, issued a Trespass Notification banning Ms. Laferriere
from attending GPC for 90 days, except for any personal medical attention.
10. Although restrictions have been placed on Ms. Laferriere’s access to GPC at various
times since Mr. Walker began residing at GPC, VCH has always been and remains committed to
CW7117020.1
providing Ms. Laferriere access to Mr. Walker outside of the GPC grounds. VCH has facilitated visits at
places such as the Oakridge Mall, at the curbside of GPC, etc.
11. Ms. Laferriere filed a Petition dated March 14, 2014 in which she sought orders for 16
different forms of relief. Ms. Laferriere also sought, and was granted, short leave to have heard one of
the orders sought: that listed in Paragraph 13 of the Petition in which Ms. Laferriere sought unrestricted
and unsupervised 24/7 access to Mr. Walker.
12. VCH filed Response materials on March 17, 2014 and the hearing of the issue outlined in
Paragraph 13 of Ms. Laferriere’s Petition took place on March 18, 2014.
13. The Public Guardian and Trustee, through its counsel, attended the hearing on March
18, 2014 and sought an adjournment of the hearing in order to consider issues related to Mr. Walker’s
interests.
14. VCH consented to an adjournment, which was eventually granted by the order of
Master MacNaughton. Specifically, Master MacNaughton ordered that the matter be heard on April 8,
2014 in front of a judge, rather than a master.
Ms. Laferriere’s Behavioural History
15. Ms. Laferriere has a long history of violent and aggressive behaviour towards staff
members at GPC, VCH in general, and even the members of the Vancouver Police Department who
attended the GPC on numerous occasions to deal with or assist with escorting Ms. Laferriere out of the
facility.
16. Ms. Laferriere’s behaviour includes violent physical conduct, harassing emails, blog post
entries alleging incompetence and illegal conduct on VCH’s part, and picketing at GPC and elsewhere.
17. One particular example of Ms. Laferriere’s violent and aggressive behaviour occurred on
October 21, 2013. On that day, Ms. Laferriere trespassed into the room of a resident other than Mr.
Walker at GPC. When asked to leave the facility, Ms. Laferriere refused, then later attempted to leave
the facility with Mr. Walker in his electric wheelchair. Staff prevented Ms. Laferriere from removing Mr.
Walker, and in response, Ms. Laferriere punched two staff members, attempted to hit staff with Mr.
Walker’s wheelchair, and bit the hand of a security guard. Ms. Laferriere later punched a police officer in
the face.
18. Ms. Laferriere has created over 200 internet blog entries associated with VCH since
March 2011. Blog entries have included professional emails and phone numbers of VCH employees and
board members.
19. Ms. Laferriere has also created pamphlets that have been posted on buses and bus
stops and that relate to VCH. In these pamphlets, Ms. Laferriere has included the email addresses and
phone numbers of VCH employees and board members.
20. Ms. Laferriere has also picketed at the Oakridge Centre Mall regarding her grievances
with VCH and the George Pearson Centre.
CW7 117020.1
21. Since the Trespass Notification was issued on January 29, 2014, Ms. Laferriere has
repeatedly attempted to access GPC contrary to the terms of the Trespass Notification. On numerous
occasions, Ms. Laferriere has violated the Trespass Notification. On each of these occasions, the
Vancouver Police have been called and have attended at GPC, typically arriving 90-120 minutes after
being called, but on no occasions have they removed Ms. Laferriere from GPC.
22. GPC is a large complex with over 50 entrances, and since the Trespass Notification was
issued, Paladin Security Officers have not been able to prevent Ms. Laferriere from entering GPC, nor
have they been able to compel her to leave.
23. Since the decision of Master MacNaughton handed down on March 18, 2014, VCH has
arranged curb-side visits between Mr. Walker and Ms. Laferriere on days that Mr. Walker is physically
capable of leaving the GPC facility.
24. Dr. James Dunne, the physician of record for Mr. Walker, determines on a day-to-day
basis if Mr. Walker is fit to leave the GPC facility to visit with Ms. Laferriere.
25. Also since March 18, 2014, Ms. Laferriere has continued to attempt to access Mr.
Walker at GPC on days which Dr. Dunne deems Mr. Walker unfit to leave the GPC facility.
26. In addition, Ms. Laferriere has continued to create internet blog posts in which specific
GPC and VCH staff members are identified and their contact information provided. Ms. Laferriere has
also created and distributed flyers with contact information of specific VCH board members.
The Effect of Ms. Laferriere’s Behaviour on Staff at VCH
27. As a result of the incident on October 21, 2013, VCH brought in Dr. Georgia Nemetz, a
psychologist in private practice, to conduct two critical incident debriefing sessions with the GPC
employees. Approximately 25 workers from GPC and VCH attended these two sessions.
28. Dr. Nemetz was extremely concerned about the cumulative impact of Ms. Laferriere’s
behaviour on the staff of GPC and VCH. Dr. Nemetz identified two employees who have had indications
of Post-Traumatic Stress Disorder (PTSD) associated to ongoing interactions with Ms. Laferriere.
29. As a result of the October 21, 2013 incident, VCH commissioned a Workplace Violence
Assessment of Ms. Laferriere (the "Assessment") by Kevin Calder, a Workplace Violence Specialist with
VCH, which report was finalized in January 2014.
30. In preparing the Assessment, Mr. Calder spoke to numerous employees at VCH and GPC
who have had interactions with Ms. Laferriere, and reviewed numerous reports prepared by the VCH’s
security officers and Paladin Security.
31. The Paladin Security Reports show that Ms. Laferriere repeatedly failed to follow
behavioural and access restrictions imposed on her by VCH, attempted to take Mr. Walker away from
GPC without permission on numerous occasions, and regularly verbally abused and acted aggressively
towards GPC staff.
CW7 117020.1
32. The Assessment concluded that Ms. Laferriere poses a high risk of demonstrating
affective (emotionally-based and unplanned) violence, and that her behaviour constitutes bullying and
harassment of GPC and the VCH staff.
33. Ms. Laferriere’s behaviour has led to significant issues amongst the staff at GPC. Many
staff members have been physically assaulted by Ms. Laferriere, and many fear that they will be singled
out and harassed by Ms. Laferriere. Ms. Laferriere poses a significant threat to staff, residents, and
visitors at George Pearson Centre.
34. Because of the above actions of Ms. Laferriere, staff and board members of VCH feel
threatened and are reluctant to interact with Ms. Laferriere out of fear that they will be singled out and
their personal information made public.
35. Certain staff members have also refused to escort Mr. Walker out of GPC to visit with
Ms. Laferriere because these interactions have been filmed, presumably at the direction of Ms.
Laferriere.
36. Ms. Laferriere’s actions negatively affect the care that Mr. Walker receives.
Police Involvement
37. The Vancouver Police Department has been called on numerous occasions in situations
where Ms. Laferriere has become threatening or violent or has accessed GPC contrary to restrictions
placed byVCH.
38. At present, when Ms. Laferriere attempts to access GPC contrary to the Trespass
Notification, staff at GPC call the Vancouver Police, who arrive, typically between 90-120 minutes after
being called. The Vancouver Police do not detain Ms. Laferriere and do not forcibly remove her from the
GPC premises. The typical response from the Vancouver Police is that the situation with Ms. Laferriere is
a civil matter and they will not involve themselves without a court order.
PART 3: LEGAL BASIS
1. VCH relies on the following legal bases:
(a) rule 10-4 of the Supreme Court Civil Rules, which provides for the ability of a party to
seek an injunction by order of the Court;
(b) rule 14-1 of the Supreme Court Civil Rules, which provides the framework for the
assessment of costs of applications;
(c) section 39 of the Law and Equity Act, R.S.B.C. 1996, c. 253, which provides for the
court’s ability to enjoin a party where it appears just or convenient to do so; and
(d) the inherent jurisdiction of the court.
2. The test for permanent injunctions is laid out in the case of Qureshi v. Gooch, 2005
B.C.S.C. 1584, in which the seminal case of Cadbury Schweppes Inc. v. FBI Foods Ltd., [1999] 1 S.C.R. 142
is cited.
CW7 117020.1
3. The issuance of a permanent injunction is a discretionary order and in deciding whether
to grant such an injunction, the court is to look at the nature of the rights that the injunction will
protect, the surrounding circumstances, and the balance of equities between the parties.
Cadbury Schweppes Inc. v. FBI Foods Ltd., [1999] 1 S.C.R. 142
4. Courts have considered a number of factors when determining if a permanent
injunction is appropriate including:
(a) whether an enforceable right and a threat/violation of that right exists;
Delta Hotels v. Okabe Canada Investments Co., (1991), 81 Alta L.R. (2d) 338 (OB)
(b) whether the applicant will suffer demonstrable harm should the injunction not be
granted;
Steeves Dairy Ltd. v. Twin City Co-operative Milk Producers Assn., [1926] 1 W.W.R. 25
(c) the hardship that would be caused to the party enjoined if the injunction were granted
compared to the hardship to the party seeking the injunction were the injunction not
granted;
Cadbury Schweppes Inc. v. FBI Foods Ltd., [1999] 1S.C.R. 142
(d) the conduct of the parties; and
(e) the effectiveness of an injunction.
Consideration of the Above Factors Favours the Granting of an Inlunction
5. VCH, and its staff and board members, would suffer demonstrable harm if an injunction
against Ms. Laferriere is not granted.
6. Ms. Laferriere’s attendance at GPC harms the ability of GPC’s staff to care for all of the
residents of GPC. As long as Ms. Laferriere continues to be able to attend GPC, the ability of VCH staff to
do their jobs is made more difficult.
7. Ms. Laferriere’s continued attendance at GPC also causes disruption to all those around
her, including other residents at GPC and their loved ones.
8. In addition, it is likely that if Ms. Laferriere continues to attend GPC, staff members at
GPC may quit or transfer to other departments. If staff members were to leave GPC, those departures
would be detrimental to the ability of staff at GHP to care for the residents of GPC.
9. The interests at issue in this proceeding are not simply the interests of Ms. Laferriere in
accessing Mr. Walker, they are the interests of all parties involved, including Mr. Walker, other residents
at GPC, staff at GPC, and visitors of other residents at GPC. Considering the detrimental impact that Ms.
CW7 117020.1
Laferriere’s behaviour has on all of the parties involved, the balance of convenience favours the granting
of an injunction preventing her access to GPC.
10. The opinion of Kevin Calder, Workplace Violence Specialist, is that nothing short of a
permanent ban of Ms. Laferriere will be effective in protecting the staff and visitors at GPC
PART 4: MATERIAL TO BE RELIED ON
1. Those materials filed by VCH on March 17, 2014.
2. Affidavit #1 of Tanvirezohra Batlawala, made,LApr/2014.
3. Affidavit #1 of Louise Kokotailo, made 64Apr/2014.
The Applicant estimates that the application will take 60 minutes.
D This matter is within the jurisdiction of a Master.
This matter is not within the jurisdiction of a Master.
TO THE PERSONS RECEIVING THIS NOTICE OF APPLICATION: If you wish to respond to this Notice of
Application, you must, within 5 business days after service of this Notice of Application or, if this
application is brought under Rule 9-7, within 8 business days after service of this Notice of Application:
(a) file an Application Response in Form 33;
(b) file the original of every Affidavit, and of every other document, that:
(i) you intend to refer to at the hearing of this application, and
(ii) has not already been filed in the proceeding; and
(c) serve on the Applicant 2 copies of the following, and on every other party of record one
copy of the following:
(i) a copy of filed Application Response;
(ii) a copy of each of the filed Affidavits and other documents that you intend to
refer to at the hearing of this application and that has not already been served
on that person;
(iii) if this application is brought under Rule 9-7, any notice that you are required to
give under Rule 9-7(9).
CW7 117020.1
Date: __JApr/2014
This NOTICE OF APPLICATION is prepared by Jordan Watson of the firm of Clark Wilson LLP whose place of
business is 900-885 West Georgia Street, Vancouver, British Columbia, V6C 3H1 (Direct #: 604-891-7703, Fax #:
604.687.6314, Email: jjw@cwilson.com) (File #: 37794).
To be completed by the court only:
Order made
El in the terms requested in paragraphs of Part 1 of this Notice of Application
o with the following variations and additional terms:
Date:
[dd/mmm/yyyy] Signature of 0 Judge 0 Master
CW7 117020.1
APPENDIX
[The following information is provided for data collection purposes only and is of no legal effect.]
THIS APPLICATION INVOLVES THE FOLLOWING:
D discovery: comply with demand for documents
o discovery: production of additional documents
o other matters concerning document discoveryForm 32 (Rule 8-1(4))
IN THE SUPREME COURT OF BRITISH COLUMBIA
BETWEEN:
AUDREY JANE LAFERRIERE and RANDY MICHAEL WALKER
AND:
VANCOUVER COASTAL HEALTH AUTHORITY
NOTICE OF APPLICATION
Name of Applicant: Vancouver Coastal Health Authority ("VCH")
To: Audrey Jane Laferriere and Randy Michael Walker
TAKE NOTICE that an application will be made by the Applicant to the presiding Judge at the Courthouse
at 800 Smithe St., Vancouver, BC on 8/Apr/2014 at 9:45am for the Orders set out in Part 1 below.
PART 1: ORDERS SOUGHT
1. An injunction, enjoining and restraining the Petitioner, Ms. Laferriere, by herself, or by
her agents and servants, from participating in any of the following activities:
(a) attending at any of the VCH properties, including but not limited to the George Pearson
Centre located at 757 West 57th Avenue, Vancouver, BC, except in circumstances in
which Mr. Walker’s physician deems that Mr. Walker is imminently terminal, in which
case VCH will promptly make arrangements for Ms. Laferriere to attend the George
Pearson Centre; and
(b) contacting, by email or phone, any doctors that care for Mr. Walker, or any staff,
administration, or board members of VCH, except for Richard Singleton, Director of Risk
Management for VCH and Romila Ang, Manager of the George Pearson Centre.
2. An order that any peace officer, including any officer of the Vancouver Police
Department or the R.C.M.P. having jurisdiction in the province of British Columbia, who on reasonable
and probable grounds believes that Audrey Jane Laferriere is in breach of the terms of this order may
immediately arrest that person and bring her before a judge of the Supreme Court promptly after the
arrest, to be dealt with on an inquiry to determine whether she has committed a breach of this order;
CW7 117020.1
3. Costs of this application be awarded to the defendant, VCH; and
4. Such further and other directions and orders as this Honourable Court considers just
and equitable.
PART 2: FACTUAL BASIS
Background
1. The Petitioner, Randy Michael Walker, was involved in a catastrophic injury in or about
June 2010 that left him in a state of quadriplegia. Mr. Walker uses a tracheostomy tube to assist him
with breathing.
2. Mr. Walker was first transferred to George Pearson Centre located at 757 West 57th
Avenue, Vancouver, BC ("GPC") in or about November 2010 due to the need for constant care.
3. At present, Mr. Walker is in a fragile state, but his condition has not worsened for
several months and there are no signs that suggest that there is an immediate risk of death as the
Petitioner suggests.
4. Since Mr. Walker began residing at GPC, Ms. Laferriere has been a regular visitor.
5. It is unclear what relationship Mr. Walker and Ms. Laferriere have with one another. Ms.
Laferriere has, at various times, described her relationship to Mr. Walker as one of "friend", "confidant",
"surrogate", "representative", "wife", and "advocate".
6. Mr. Walker purportedly signed a Representation Agreement pursuant to section 9 of the
Representation Agreement Act on January 31, 2013, in which Ms. Laferriere was purportedly given
authority to obtain medical records, make housing choices for Mr. Walker, and negate any "do not
resuscitate" orders pertaining to Mr. Walker.
7. VCH has abided by the Representation Agreement and has treated Ms. Laferriere as Mr.
Walker’s health care decision maker when Mr. Walker is incapable of making informed decisions about
his health care. VCH health care providers contact Ms. Laferriere by phone when health care decisions
are required, and will continue to do so as long as Ms. Laferriere is Mr. Walker’s representative.
Procedural History
8. Because of Ms. Laferriere’s behaviour (described in detail below) and in efforts to
protect the safety of all parties involved, VCH has, on multiple occasions, imposed restrictions on Ms.
Laferriere’s visitation rights. Ms. LaFerriere has repeatedly and flagrantly disregarded these restrictions.
9. As a result of Ms. Laferriere’s continued aggressive behavior towards the GPC staff and
her disregard for VCH’s restrictions of access, on January 29, 2014, Richard Singleton, the Director of
Risk Management and Client Relations at VCH, issued a Trespass Notification banning Ms. Laferriere
from attending GPC for 90 days, except for any personal medical attention.
10. Although restrictions have been placed on Ms. Laferriere’s access to GPC at various
times since Mr. Walker began residing at GPC, VCH has always been and remains committed to
CW7117020.1
providing Ms. Laferriere access to Mr. Walker outside of the GPC grounds. VCH has facilitated visits at
places such as the Oakridge Mall, at the curbside of GPC, etc.
11. Ms. Laferriere filed a Petition dated March 14, 2014 in which she sought orders for 16
different forms of relief. Ms. Laferriere also sought, and was granted, short leave to have heard one of
the orders sought: that listed in Paragraph 13 of the Petition in which Ms. Laferriere sought unrestricted
and unsupervised 24/7 access to Mr. Walker.
12. VCH filed Response materials on March 17, 2014 and the hearing of the issue outlined in
Paragraph 13 of Ms. Laferriere’s Petition took place on March 18, 2014.
13. The Public Guardian and Trustee, through its counsel, attended the hearing on March
18, 2014 and sought an adjournment of the hearing in order to consider issues related to Mr. Walker’s
interests.
14. VCH consented to an adjournment, which was eventually granted by the order of
Master MacNaughton. Specifically, Master MacNaughton ordered that the matter be heard on April 8,
2014 in front of a judge, rather than a master.
Ms. Laferriere’s Behavioural History
15. Ms. Laferriere has a long history of violent and aggressive behaviour towards staff
members at GPC, VCH in general, and even the members of the Vancouver Police Department who
attended the GPC on numerous occasions to deal with or assist with escorting Ms. Laferriere out of the
facility.
16. Ms. Laferriere’s behaviour includes violent physical conduct, harassing emails, blog post
entries alleging incompetence and illegal conduct on VCH’s part, and picketing at GPC and elsewhere.
17. One particular example of Ms. Laferriere’s violent and aggressive behaviour occurred on
October 21, 2013. On that day, Ms. Laferriere trespassed into the room of a resident other than Mr.
Walker at GPC. When asked to leave the facility, Ms. Laferriere refused, then later attempted to leave
the facility with Mr. Walker in his electric wheelchair. Staff prevented Ms. Laferriere from removing Mr.
Walker, and in response, Ms. Laferriere punched two staff members, attempted to hit staff with Mr.
Walker’s wheelchair, and bit the hand of a security guard. Ms. Laferriere later punched a police officer in
the face.
18. Ms. Laferriere has created over 200 internet blog entries associated with VCH since
March 2011. Blog entries have included professional emails and phone numbers of VCH employees and
board members.
19. Ms. Laferriere has also created pamphlets that have been posted on buses and bus
stops and that relate to VCH. In these pamphlets, Ms. Laferriere has included the email addresses and
phone numbers of VCH employees and board members.
20. Ms. Laferriere has also picketed at the Oakridge Centre Mall regarding her grievances
with VCH and the George Pearson Centre.
CW7 117020.1
21. Since the Trespass Notification was issued on January 29, 2014, Ms. Laferriere has
repeatedly attempted to access GPC contrary to the terms of the Trespass Notification. On numerous
occasions, Ms. Laferriere has violated the Trespass Notification. On each of these occasions, the
Vancouver Police have been called and have attended at GPC, typically arriving 90-120 minutes after
being called, but on no occasions have they removed Ms. Laferriere from GPC.
22. GPC is a large complex with over 50 entrances, and since the Trespass Notification was
issued, Paladin Security Officers have not been able to prevent Ms. Laferriere from entering GPC, nor
have they been able to compel her to leave.
23. Since the decision of Master MacNaughton handed down on March 18, 2014, VCH has
arranged curb-side visits between Mr. Walker and Ms. Laferriere on days that Mr. Walker is physically
capable of leaving the GPC facility.
24. Dr. James Dunne, the physician of record for Mr. Walker, determines on a day-to-day
basis if Mr. Walker is fit to leave the GPC facility to visit with Ms. Laferriere.
25. Also since March 18, 2014, Ms. Laferriere has continued to attempt to access Mr.
Walker at GPC on days which Dr. Dunne deems Mr. Walker unfit to leave the GPC facility.
26. In addition, Ms. Laferriere has continued to create internet blog posts in which specific
GPC and VCH staff members are identified and their contact information provided. Ms. Laferriere has
also created and distributed flyers with contact information of specific VCH board members.
The Effect of Ms. Laferriere’s Behaviour on Staff at VCH
27. As a result of the incident on October 21, 2013, VCH brought in Dr. Georgia Nemetz, a
psychologist in private practice, to conduct two critical incident debriefing sessions with the GPC
employees. Approximately 25 workers from GPC and VCH attended these two sessions.
28. Dr. Nemetz was extremely concerned about the cumulative impact of Ms. Laferriere’s
behaviour on the staff of GPC and VCH. Dr. Nemetz identified two employees who have had indications
of Post-Traumatic Stress Disorder (PTSD) associated to ongoing interactions with Ms. Laferriere.
29. As a result of the October 21, 2013 incident, VCH commissioned a Workplace Violence
Assessment of Ms. Laferriere (the "Assessment") by Kevin Calder, a Workplace Violence Specialist with
VCH, which report was finalized in January 2014.
30. In preparing the Assessment, Mr. Calder spoke to numerous employees at VCH and GPC
who have had interactions with Ms. Laferriere, and reviewed numerous reports prepared by the VCH’s
security officers and Paladin Security.
31. The Paladin Security Reports show that Ms. Laferriere repeatedly failed to follow
behavioural and access restrictions imposed on her by VCH, attempted to take Mr. Walker away from
GPC without permission on numerous occasions, and regularly verbally abused and acted aggressively
towards GPC staff.
CW7 117020.1
32. The Assessment concluded that Ms. Laferriere poses a high risk of demonstrating
affective (emotionally-based and unplanned) violence, and that her behaviour constitutes bullying and
harassment of GPC and the VCH staff.
33. Ms. Laferriere’s behaviour has led to significant issues amongst the staff at GPC. Many
staff members have been physically assaulted by Ms. Laferriere, and many fear that they will be singled
out and harassed by Ms. Laferriere. Ms. Laferriere poses a significant threat to staff, residents, and
visitors at George Pearson Centre.
34. Because of the above actions of Ms. Laferriere, staff and board members of VCH feel
threatened and are reluctant to interact with Ms. Laferriere out of fear that they will be singled out and
their personal information made public.
35. Certain staff members have also refused to escort Mr. Walker out of GPC to visit with
Ms. Laferriere because these interactions have been filmed, presumably at the direction of Ms.
Laferriere.
36. Ms. Laferriere’s actions negatively affect the care that Mr. Walker receives.
Police Involvement
37. The Vancouver Police Department has been called on numerous occasions in situations
where Ms. Laferriere has become threatening or violent or has accessed GPC contrary to restrictions
placed byVCH.
38. At present, when Ms. Laferriere attempts to access GPC contrary to the Trespass
Notification, staff at GPC call the Vancouver Police, who arrive, typically between 90-120 minutes after
being called. The Vancouver Police do not detain Ms. Laferriere and do not forcibly remove her from the
GPC premises. The typical response from the Vancouver Police is that the situation with Ms. Laferriere is
a civil matter and they will not involve themselves without a court order.
PART 3: LEGAL BASIS
1. VCH relies on the following legal bases:
(a) rule 10-4 of the Supreme Court Civil Rules, which provides for the ability of a party to
seek an injunction by order of the Court;
(b) rule 14-1 of the Supreme Court Civil Rules, which provides the framework for the
assessment of costs of applications;
(c) section 39 of the Law and Equity Act, R.S.B.C. 1996, c. 253, which provides for the
court’s ability to enjoin a party where it appears just or convenient to do so; and
(d) the inherent jurisdiction of the court.
2. The test for permanent injunctions is laid out in the case of Qureshi v. Gooch, 2005
B.C.S.C. 1584, in which the seminal case of Cadbury Schweppes Inc. v. FBI Foods Ltd., [1999] 1 S.C.R. 142
is cited.
CW7 117020.1
3. The issuance of a permanent injunction is a discretionary order and in deciding whether
to grant such an injunction, the court is to look at the nature of the rights that the injunction will
protect, the surrounding circumstances, and the balance of equities between the parties.
Cadbury Schweppes Inc. v. FBI Foods Ltd., [1999] 1 S.C.R. 142
4. Courts have considered a number of factors when determining if a permanent
injunction is appropriate including:
(a) whether an enforceable right and a threat/violation of that right exists;
Delta Hotels v. Okabe Canada Investments Co., (1991), 81 Alta L.R. (2d) 338 (OB)
(b) whether the applicant will suffer demonstrable harm should the injunction not be
granted;
Steeves Dairy Ltd. v. Twin City Co-operative Milk Producers Assn., [1926] 1 W.W.R. 25
(c) the hardship that would be caused to the party enjoined if the injunction were granted
compared to the hardship to the party seeking the injunction were the injunction not
granted;
Cadbury Schweppes Inc. v. FBI Foods Ltd., [1999] 1S.C.R. 142
(d) the conduct of the parties; and
(e) the effectiveness of an injunction.
Consideration of the Above Factors Favours the Granting of an Inlunction
5. VCH, and its staff and board members, would suffer demonstrable harm if an injunction
against Ms. Laferriere is not granted.
6. Ms. Laferriere’s attendance at GPC harms the ability of GPC’s staff to care for all of the
residents of GPC. As long as Ms. Laferriere continues to be able to attend GPC, the ability of VCH staff to
do their jobs is made more difficult.
7. Ms. Laferriere’s continued attendance at GPC also causes disruption to all those around
her, including other residents at GPC and their loved ones.
8. In addition, it is likely that if Ms. Laferriere continues to attend GPC, staff members at
GPC may quit or transfer to other departments. If staff members were to leave GPC, those departures
would be detrimental to the ability of staff at GHP to care for the residents of GPC.
9. The interests at issue in this proceeding are not simply the interests of Ms. Laferriere in
accessing Mr. Walker, they are the interests of all parties involved, including Mr. Walker, other residents
at GPC, staff at GPC, and visitors of other residents at GPC. Considering the detrimental impact that Ms.
CW7 117020.1
Laferriere’s behaviour has on all of the parties involved, the balance of convenience favours the granting
of an injunction preventing her access to GPC.
10. The opinion of Kevin Calder, Workplace Violence Specialist, is that nothing short of a
permanent ban of Ms. Laferriere will be effective in protecting the staff and visitors at GPC
PART 4: MATERIAL TO BE RELIED ON
1. Those materials filed by VCH on March 17, 2014.
2. Affidavit #1 of Tanvirezohra Batlawala, made,LApr/2014.
3. Affidavit #1 of Louise Kokotailo, made 64Apr/2014.
The Applicant estimates that the application will take 60 minutes.
D This matter is within the jurisdiction of a Master.
This matter is not within the jurisdiction of a Master.
TO THE PERSONS RECEIVING THIS NOTICE OF APPLICATION: If you wish to respond to this Notice of
Application, you must, within 5 business days after service of this Notice of Application or, if this
application is brought under Rule 9-7, within 8 business days after service of this Notice of Application:
(a) file an Application Response in Form 33;
(b) file the original of every Affidavit, and of every other document, that:
(i) you intend to refer to at the hearing of this application, and
(ii) has not already been filed in the proceeding; and
(c) serve on the Applicant 2 copies of the following, and on every other party of record one
copy of the following:
(i) a copy of filed Application Response;
(ii) a copy of each of the filed Affidavits and other documents that you intend to
refer to at the hearing of this application and that has not already been served
on that person;
(iii) if this application is brought under Rule 9-7, any notice that you are required to
give under Rule 9-7(9).
CW7 117020.1
Date: __JApr/2014
This NOTICE OF APPLICATION is prepared by Jordan Watson of the firm of Clark Wilson LLP whose place of
business is 900-885 West Georgia Street, Vancouver, British Columbia, V6C 3H1 (Direct #: 604-891-7703, Fax #:
604.687.6314, Email: jjw@cwilson.com) (File #: 37794).
To be completed by the court only:
Order made
El in the terms requested in paragraphs of Part 1 of this Notice of Application
o with the following variations and additional terms:
Date:
[dd/mmm/yyyy] Signature of 0 Judge 0 Master
CW7 117020.1
APPENDIX
[The following information is provided for data collection purposes only and is of no legal effect.]
THIS APPLICATION INVOLVES THE FOLLOWING:
D discovery: comply with demand for documents
o discovery: production of additional documents
o other matters concerning document discoveryng.
Wednesday, April 2, 2014
Health authorities and how to deal with the public
I came across this in June of 2011. It was from YouTube: CIVIL RIGHTS NOW How to Effectively Communicate with the Public.
This is the mandate VCH instructed to all its managers:
1. Delay
2. Deny
3. Divide (divide patient/resident from family support network). All a visitor has to do is inquire as to process or talk to another visitor or resident and you will be banned.
4. Discredit
5. Demoralize.
This is the mandate VCH instructed to all its managers:
1. Delay
2. Deny
3. Divide (divide patient/resident from family support network). All a visitor has to do is inquire as to process or talk to another visitor or resident and you will be banned.
4. Discredit
5. Demoralize.
Monday, March 31, 2014
My poor Randy
Poor Randy. It has been two months since he was imprisoned at GPC because of my disrespectful conduct. What has my conduct got to do with him wanting to visit me. He has the right to see me but VCH is acting cruelly and harshly. Why are they punishing Randy when he can't move or even talk. I am sure he must be very depressed not knowing what is really going on.
I will tell you how mean VCH is: From October 15 2013 to January 29 2014 Randy was in a private room in which I was able to visit him for two hour intervals. Then they moved him to an open ward so those phantoms that are afraid of me are there and I can't see Randy.
It is the staff that is violent not me. Because they belong to the medical profession they get away with bullying and violence everyday because they are believed and the victims are not. And there is no lawyer or doctor who will aid you because VCH will make sure that they are discredited. No one.
On October 22 2013 the staff at GPC attacked me because I was trying to take Randy out of GPC. They lied and said that Randy was in need of medical attention; he didn't.
Stephanie created the mob hysteria and everyone followed her. She must have known that Randy did not want a DNR as it was in Randy's medical records and she did nothing to save him. but was willing to save him on October 22. No one did anything to save him.
I still am haunted with him begging me to save his life when he was scheduled to die by GPC on November 18 2013. No one was there; he was alone in an isolated room with no one to help him. No nurses; no security; no one. Dr. Dunne and others decided that Randy would never get any better -- he was chronic, and it was time for him to die.
How can all of GPC be party to this. And then what do they do with Randy, they ban me from seeing him. I saved his life after GPC tried to hasten his death and I am charged with the crime of disrespectful conduct. What bizarre logic does these highly trained medical professionals possess. They should all be charged with conspiracy to commit murder.
If Randy is chronic and was actively dying in November and December, it would be logical that I should have access to him 24/7 as it is just a matter of time before he dies. How insensitive and stupid is VCH.
438,858
I will tell you how mean VCH is: From October 15 2013 to January 29 2014 Randy was in a private room in which I was able to visit him for two hour intervals. Then they moved him to an open ward so those phantoms that are afraid of me are there and I can't see Randy.
It is the staff that is violent not me. Because they belong to the medical profession they get away with bullying and violence everyday because they are believed and the victims are not. And there is no lawyer or doctor who will aid you because VCH will make sure that they are discredited. No one.
On October 22 2013 the staff at GPC attacked me because I was trying to take Randy out of GPC. They lied and said that Randy was in need of medical attention; he didn't.
Stephanie created the mob hysteria and everyone followed her. She must have known that Randy did not want a DNR as it was in Randy's medical records and she did nothing to save him. but was willing to save him on October 22. No one did anything to save him.
I still am haunted with him begging me to save his life when he was scheduled to die by GPC on November 18 2013. No one was there; he was alone in an isolated room with no one to help him. No nurses; no security; no one. Dr. Dunne and others decided that Randy would never get any better -- he was chronic, and it was time for him to die.
How can all of GPC be party to this. And then what do they do with Randy, they ban me from seeing him. I saved his life after GPC tried to hasten his death and I am charged with the crime of disrespectful conduct. What bizarre logic does these highly trained medical professionals possess. They should all be charged with conspiracy to commit murder.
If Randy is chronic and was actively dying in November and December, it would be logical that I should have access to him 24/7 as it is just a matter of time before he dies. How insensitive and stupid is VCH.
438,858
Saturday, March 29, 2014
If you want to hasten your life do not agree to DNRs.
On Janaury 29 2014 I received a letter from VCH saying that I can't visit Randy who is a quad and can't talk for three months because of my disrespectful conduct. What is MY disrespectful conduct and what has that got to do with seeing Randy. I am his only advocate and friend and VCH has this idea to punish him like in a third world so I do not say anything. GPC is suppose to be a residential community it is not acute care or intensive care so disrespectful conduct would have a different meaning. For example, what your behavior is in your church is different than your behavior in your home. At GPC the method of living is the Eden principle where it is a home-like atmosphere based on being spontaneous and showing emotion.
From October 14 2013 Randy was in a private room with me having very very little access to anyone as a security guard was posted outside and I was not allowed to talk to anyone. So why didn't they leave me there with Randy. Why did they move him to a Ward where the phantoms that are afraid of me are stationed. There is more to this than just my questionable disrespectful conduct. During the time from October 14 2013 to January 29 2014 I know of no incident that would be described as disrespectful or any mention as such..
The truth is VCH does not want me to talk to anyone and tell them of my experiences of what really VCH is doing. Think about it. Having mostly all residents of GPC agree to a Do Not Transfer Order so that if they need acute care they in all probability will die at GPC as GPC is not equipped to handle acute emergencies. I thought Do Not Resuscitate Orders were bad enough but coupled with Do Not Transfer it means certain death. That is what they really mean by disrespectful behavior. The want visitors classified as employees and everything I see or hear is suppose to be confidential and away from the public ear and eye. There is in my mind no other reason for it.Most of the residents at GPC do not even know what a DNR or a DNT means.
Like Ro the manager told me most residents know they are going to die and they have accepted it. I do not believe her. Ro reminds me of an angel with the keys to purgatory as that is what Dr. Tam told me GPC was.
It has been eight months since the first Full Code intervention in August 2013 stopped Randy's imminent death and Randy may live many more months or years if a DNR/DNT Orders are not forced on him without him knowing. I was told by a lawyer who deals with health care at the Bentley court case and he said that unconsented to DNRs are common in the medical community. A nurse at that hearing also told me that. It doesn't matter how old you are if you are going to cost the medical system you will be convinced that you have no quality of life so you might as well be dead. And if you won't agree they will find a way to do it anyways; they will get your relatives to agree At GPC they isolate you until you give up and die..
There has to be a public inquiry into GPC and VGH as to DNRs and resultant deaths. There has to be stats available. If public policy is to kill the chronic ill then we the public should know about it.
I reported this to the Public Guardian and Trustee and the Ministry of Health and nothing came of it. They must know what is going on.
438515
From October 14 2013 Randy was in a private room with me having very very little access to anyone as a security guard was posted outside and I was not allowed to talk to anyone. So why didn't they leave me there with Randy. Why did they move him to a Ward where the phantoms that are afraid of me are stationed. There is more to this than just my questionable disrespectful conduct. During the time from October 14 2013 to January 29 2014 I know of no incident that would be described as disrespectful or any mention as such..
The truth is VCH does not want me to talk to anyone and tell them of my experiences of what really VCH is doing. Think about it. Having mostly all residents of GPC agree to a Do Not Transfer Order so that if they need acute care they in all probability will die at GPC as GPC is not equipped to handle acute emergencies. I thought Do Not Resuscitate Orders were bad enough but coupled with Do Not Transfer it means certain death. That is what they really mean by disrespectful behavior. The want visitors classified as employees and everything I see or hear is suppose to be confidential and away from the public ear and eye. There is in my mind no other reason for it.Most of the residents at GPC do not even know what a DNR or a DNT means.
Like Ro the manager told me most residents know they are going to die and they have accepted it. I do not believe her. Ro reminds me of an angel with the keys to purgatory as that is what Dr. Tam told me GPC was.
It has been eight months since the first Full Code intervention in August 2013 stopped Randy's imminent death and Randy may live many more months or years if a DNR/DNT Orders are not forced on him without him knowing. I was told by a lawyer who deals with health care at the Bentley court case and he said that unconsented to DNRs are common in the medical community. A nurse at that hearing also told me that. It doesn't matter how old you are if you are going to cost the medical system you will be convinced that you have no quality of life so you might as well be dead. And if you won't agree they will find a way to do it anyways; they will get your relatives to agree At GPC they isolate you until you give up and die..
There has to be a public inquiry into GPC and VGH as to DNRs and resultant deaths. There has to be stats available. If public policy is to kill the chronic ill then we the public should know about it.
I reported this to the Public Guardian and Trustee and the Ministry of Health and nothing came of it. They must know what is going on.
438515
Friday, March 28, 2014
Criminal Profiling by VCH
I haven't got over the criminal profiling that VCH did on me; it is the lowest sickest thing they could have done. David Ostrow and Kip Woodward should resign over this indignation.
And what about the psychologist Dr. Georgia Nemetz: saying
15. I have been further informed by Dr. Nemetz, Romilda Ang, Tenvirezohra Batlawala, and believe to be true that, as a result of Mrs. Laferriere's actions at GPC over the last year, numerous staff at GPC are intimidated by, and scared of, Mrs. Laferriere. Over the past year Randy spent most of it at VGH so how many days did it take for these people to become afraid of me. Management isn't afraid of me so who are. I wonder if the staff is even aware that they are being used to separate me and Randy. I am sure they did not have a vote.
So who are these, those that are afraid of me -- they must be phantoms .
18. Based on my investigation, I concluded in that Mrs.. Laferriere poses a hgh risk of demonstrating affective (emotionall-based and unplanned) violence. I further believe that her behavior constitutes bully and harassment of GPC and Vancouver Coastal Health staff. ...increases the risk that Mrs. Laferriere will hurt someone at GPC in the future. Really.
What are they imagining. Who is this idiot lawyer who wrote the affidavit for, Kevin Calder, and who is the idiot lawyer Jordan J. Watson who decided these assumptions/assessment//lies were relevant.with no proof. So much for Clark Wilson the law firm for Vancouver Coastal Health. How low can they get.
What did I do. All I wanted was to see my husband. Even a child would not agree to their stupid guidelines. They would just run and see their parents. No one would stop them; they would find a away.. But I am prevented by Amazon security bullies and staff and the law that protects us all.
VGH knows how to discredit anyone they target. Mention the word "violent" and you are quilty of everything. Everyone I hear of who has been banned have been accused of being violent to the point of the police charging them. No one ever got convicted but it was a means to shut up the visitor. As for me I was never charged. It was I who wanted to charge VCH and their employees and security. It is as if VCH has a menu on how to get rid of visitors. Have staff say he was physically touched ever so lightly and you are a violent person; no due process, just the word of an overworked dissatisfied scared-for-his job employee or some employee wanting to get on the good side of management.
And to think that Randy is near death and VCH has done this to me and Randy. He was imminent for death in August 2013, November 18, 2013, and December 26, 2013. And what do they do they ban me and I am criminally profiled. WorkSafe BC (Jackie Dulac) couldn't have agreed to this but then maybe she did.
What about Randy's quality of life. It means nothing to VCH VCH will stick him in a corner and ignore him until he dies. Since Randy is immobile and can't talk or even use a call bell he can be discarded at will. They even got him hidden behind curtains. Dr. Dunne told me that a resident's privacy (the woman next to Randy who can talk and call and for help needs her privacy and her husband seems to be there making sure she si attended to all the time) is more important than Randy's safety.
Do Not Resuscitate Directives and Do Not Transfer Orders can be placed on him by Dr. Dunne which he has done in the past without Randy's knowledge and try to prove it after Randy is dead. A doctor's word against a dead man's word. I still do not think it was a coincidence that Dr. Dunne was at Randy's bedside hours before he should have died. on November 18th or December 26th. Dunne is never there is in the afternoons or early evenings. Why was he there...just to make sure Randy was on his way.
And the hospital criminal profiling section of VCH is monitoring every single word I write to determine if I am violent or not. And they are going to sue me for harassment employees of VCH via my blog.. VGH made my life hell for going on four years and now they are going to sue me. I hope they have real evidence and no made-up hearsay. And the court case is done face-to-face in a real courtroom where everyone can be cross examined rather than by affidavit.
438,493
.
And what about the psychologist Dr. Georgia Nemetz: saying
15. I have been further informed by Dr. Nemetz, Romilda Ang, Tenvirezohra Batlawala, and believe to be true that, as a result of Mrs. Laferriere's actions at GPC over the last year, numerous staff at GPC are intimidated by, and scared of, Mrs. Laferriere. Over the past year Randy spent most of it at VGH so how many days did it take for these people to become afraid of me. Management isn't afraid of me so who are. I wonder if the staff is even aware that they are being used to separate me and Randy. I am sure they did not have a vote.
So who are these, those that are afraid of me -- they must be phantoms .
18. Based on my investigation, I concluded in that Mrs.. Laferriere poses a hgh risk of demonstrating affective (emotionall-based and unplanned) violence. I further believe that her behavior constitutes bully and harassment of GPC and Vancouver Coastal Health staff. ...increases the risk that Mrs. Laferriere will hurt someone at GPC in the future. Really.
What are they imagining. Who is this idiot lawyer who wrote the affidavit for, Kevin Calder, and who is the idiot lawyer Jordan J. Watson who decided these assumptions/assessment//lies were relevant.with no proof. So much for Clark Wilson the law firm for Vancouver Coastal Health. How low can they get.
What did I do. All I wanted was to see my husband. Even a child would not agree to their stupid guidelines. They would just run and see their parents. No one would stop them; they would find a away.. But I am prevented by Amazon security bullies and staff and the law that protects us all.
VGH knows how to discredit anyone they target. Mention the word "violent" and you are quilty of everything. Everyone I hear of who has been banned have been accused of being violent to the point of the police charging them. No one ever got convicted but it was a means to shut up the visitor. As for me I was never charged. It was I who wanted to charge VCH and their employees and security. It is as if VCH has a menu on how to get rid of visitors. Have staff say he was physically touched ever so lightly and you are a violent person; no due process, just the word of an overworked dissatisfied scared-for-his job employee or some employee wanting to get on the good side of management.
And to think that Randy is near death and VCH has done this to me and Randy. He was imminent for death in August 2013, November 18, 2013, and December 26, 2013. And what do they do they ban me and I am criminally profiled. WorkSafe BC (Jackie Dulac) couldn't have agreed to this but then maybe she did.
What about Randy's quality of life. It means nothing to VCH VCH will stick him in a corner and ignore him until he dies. Since Randy is immobile and can't talk or even use a call bell he can be discarded at will. They even got him hidden behind curtains. Dr. Dunne told me that a resident's privacy (the woman next to Randy who can talk and call and for help needs her privacy and her husband seems to be there making sure she si attended to all the time) is more important than Randy's safety.
Do Not Resuscitate Directives and Do Not Transfer Orders can be placed on him by Dr. Dunne which he has done in the past without Randy's knowledge and try to prove it after Randy is dead. A doctor's word against a dead man's word. I still do not think it was a coincidence that Dr. Dunne was at Randy's bedside hours before he should have died. on November 18th or December 26th. Dunne is never there is in the afternoons or early evenings. Why was he there...just to make sure Randy was on his way.
And the hospital criminal profiling section of VCH is monitoring every single word I write to determine if I am violent or not. And they are going to sue me for harassment employees of VCH via my blog.. VGH made my life hell for going on four years and now they are going to sue me. I hope they have real evidence and no made-up hearsay. And the court case is done face-to-face in a real courtroom where everyone can be cross examined rather than by affidavit.
438,493
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Thursday, March 27, 2014
Criminal Profile
It takes me a long long time to get angry. And this time I am angry. The idea that Vancouver Coastal Health would have its employee do a criminal profile on me for deviating against illogical stupid guidelines based on irational stupidity is ridiculous. Rather than do what VCH should have done in 2010 when the bullying and cruely started by VCH, the best they can do is now result to criminal profile an old woman.
I am going to post Gavin's report on the internet as a public service. I want all of you to know what VCH is doing. You can read it and ask so what if she didn't follow the ridulous innocuous guidelines which were not written in stone; guidelines she never agreed to in the first place. She was trespassing on government owned property to see her husband. This is crazy. Whose idea was it. WorkSafe BC would never agree to this. A undercover hospital police state targeting an innocent to make sure they have something something to justify their work. Create a situation by tragetting an individual who only wanted to be with her husband and to make friends with the other lonely residents. Residents that no one cares to see except for their memorial service. Security companies do it all the time and managers do it as well to cement their positions. You are taught this is university: Business 101 how to survive a job and get promoted create a situation and make yourself look good. But I never thought it would happen in a hospital. VCH stating that I would be further danger to staff and everyone else on all its properties.
I was told WorkSafe BC told VCH to do it. Really. VCH is suppose to be in the health care business not in criminal profiling of its visitors, staff, contract workers, and children.. So who is next, the underpaid janitor who steals toilet paper. Or maybe Napolean Ostrow and where he gets his organs for transplants. A new industry. BIG BROTHER HOSPITAL who isn't the government. But then they might be working together.
I would be afraid of me too not physically but because I told them I would be reporting them to the college of registered nurses for their dishnourable behavioir and acts of physical/psychological violence against me and Randy.. That should cause some form of post traumatic stress. In my mother's day it would be called GUILT. Since reporting nurses to management does not work, then the next step is report it to the college of registered nurses and their union for disciplinary action.
As for Dr. Dunne I have registered five complaints against him and he won't be able to wiggle out of any of them. No wonder he can't concentrate in his job. Thank god he isn't Randy's physician's anymore. Or is he.
When I was a child we would play the "mother may I pass the red chalk line" and now at 60 years later VCH has reinvented it again. They are trying to reeducation me to be a robot who sees no evil, hears no evil, and is mute.
My husband is dying and I want access to him 24/7. VCH already took two years of our lives from us and they are intent on stealing more. There is a legal remedy for alienation of affection and it is very tempting to start another action against VCH.
Rich people hire nurse companions for patients 24/7 so that should also extend to family members to be with a patient 24/7 as well. otherwise it is discrimination. Nurse companions are there to alert the nursing staff should their patient need attention. And considering the understaffing of hospital personnel 24/7 criteria should be for everyone.
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I am going to post Gavin's report on the internet as a public service. I want all of you to know what VCH is doing. You can read it and ask so what if she didn't follow the ridulous innocuous guidelines which were not written in stone; guidelines she never agreed to in the first place. She was trespassing on government owned property to see her husband. This is crazy. Whose idea was it. WorkSafe BC would never agree to this. A undercover hospital police state targeting an innocent to make sure they have something something to justify their work. Create a situation by tragetting an individual who only wanted to be with her husband and to make friends with the other lonely residents. Residents that no one cares to see except for their memorial service. Security companies do it all the time and managers do it as well to cement their positions. You are taught this is university: Business 101 how to survive a job and get promoted create a situation and make yourself look good. But I never thought it would happen in a hospital. VCH stating that I would be further danger to staff and everyone else on all its properties.
I was told WorkSafe BC told VCH to do it. Really. VCH is suppose to be in the health care business not in criminal profiling of its visitors, staff, contract workers, and children.. So who is next, the underpaid janitor who steals toilet paper. Or maybe Napolean Ostrow and where he gets his organs for transplants. A new industry. BIG BROTHER HOSPITAL who isn't the government. But then they might be working together.
I would be afraid of me too not physically but because I told them I would be reporting them to the college of registered nurses for their dishnourable behavioir and acts of physical/psychological violence against me and Randy.. That should cause some form of post traumatic stress. In my mother's day it would be called GUILT. Since reporting nurses to management does not work, then the next step is report it to the college of registered nurses and their union for disciplinary action.
As for Dr. Dunne I have registered five complaints against him and he won't be able to wiggle out of any of them. No wonder he can't concentrate in his job. Thank god he isn't Randy's physician's anymore. Or is he.
When I was a child we would play the "mother may I pass the red chalk line" and now at 60 years later VCH has reinvented it again. They are trying to reeducation me to be a robot who sees no evil, hears no evil, and is mute.
My husband is dying and I want access to him 24/7. VCH already took two years of our lives from us and they are intent on stealing more. There is a legal remedy for alienation of affection and it is very tempting to start another action against VCH.
Rich people hire nurse companions for patients 24/7 so that should also extend to family members to be with a patient 24/7 as well. otherwise it is discrimination. Nurse companions are there to alert the nursing staff should their patient need attention. And considering the understaffing of hospital personnel 24/7 criteria should be for everyone.
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