3 CLAIM 1.
The plaintiff claims: a.
a declaration that his rights under s. 7 of the
Canadian Charter of Rights and Freedoms
have been infringed by some, all, or some combination of the employees of Her Majesty in right of Ontario referred to below; b.
general and special damages in the amount of $1 million from all defendants; c.
aggravated, punitive and penal damages in the amount of $100,000.00 from each of the defendants; d.
damages in the amount of $100,000.00 pursuant to s. 24(1) of the
Charter of Rights and Freedoms
for the breach of his right to life, liberty and security of the person from Her Majesty in right of Ontario; e.
pre-judgment interest in accordance with the
Courts of Justice Act
, RSO 1990, c-43, as amended; f.
the costs of this action on a substantial indemnity basis; and g.
such further and other relief as the circumstances as the circumstances of the case requires and the court deems just. 2.
The plaintiff lives in the City of Toronto in the Province of Ontario. 3.
The defendants Robert Ford ("Ford"), Payman Aboodowleh ("Aboodowleh") and Aedan Petros ("Petros") live in the City of Toronto in the Province of Ontario. 4.
Metro West Detention Centre ("MWDC") is a correctional facility established and operated pursuant to the
Ministry of Correctional Services Act