FORM 10 [RULE 3.25] COURT FILE NUMBER 1903-(| FO| COURT COURT OF QUEEN'S BENCH OF ALBERTA JUDICIAL CENTRE Edmonton PLAINTIFF(S) IAN HAGUE, Executor of the Estate of Tim Ha x (Deceased), and the ESTATE OF TIM HAGUE (Deceased) DEFENDANT(S) THE CITY OF EDMONTON, EDMONTON COMBATIVE SPORTS COMMISSION, EDMONTON ECONOMIC DEVELOPMENT CORPORATION, PAT REID, LEN KOIVISTO, SHELBY KARPMAN, SHIRDI NULLIAH, DAVID AITKEN, 1259754 ALBERTA LTD., 1248345 ALBERTA LTD., and K.0. BOXING CANADA. DOCUMENT STATEMENT OF CLAIM ADDRESS FOR SERVICE _Assiff Law Office AND CONTACT Suite 300, 10612 — 124 Street INFORMATION OF PARTY Edmonton, AB TSN 184 FILING THIS DOCUMENT phone: (687) 524-3000 / Fax: (587) 524-3001 Lawyer: N.A. (Norm) Assiff / Ari J. Schacter File No. 17791.NA/AJS NOTICE TO DEFENDANT You have been sued. You are a Defendant Go to the end of this document to see what you can do and when you must do it ‘Statement of facts relied on: Pai 1. The Plaintiff, lan Hague, is the Executor of the Estate of Tim Hague (the "Deceased’), deceased, pursuant to a Grant of Administration issued by the Court of Queen's Bench of Alberta on February 10, 2019. lan Hague resides in the county of Athabasca, in the province of AlbertaAt all times material hereto, the Deceased resided in the town of Beaumont, in the Province of Alberta The Defendant, the City of Edmonton (the ‘City’), is a municipality incorporated pursuant to the provisions of the Municipal Government Act, RSA 2000, ¢ M-26 (the (/MGA’). ‘The Defendant, the Edmonton Combative Sports Commission (the “ECSC’), is a civic agency created pursuant to Bylaw 15638 issued under the MGA. The ECSC is a Council Committee composed of up to 7 volunteer citizen members. The ECSC supplements the regulatory provisions of the City of Edmonton Bylaws 15638 (‘Bylaw 15638") and 15594 (Bylaw 18594"), both issued under the MGA (the “Bylaws’), through further regulations ‘on combative sports matters such as fighter safety, licensing, conduct, qualifications and contests. The Defendant, the Edmonton Economic Development Corporation (the “EEDC’), is a not-for-profit corporation incorporated pursuant to the provisions of the Companies Act, RSA 2000, ¢ C-21. The EEDC is believed by the Plaintiffs to be responsible for the management of the Shaw Conference Centre, a convention centre. ‘The Defendant, Pat Reid (‘Reid’), is an individual resident at all times material hereto in the City of Edmonton, in the Province of Alberta, At all times material hereto, Reid was the Executive Director and City Manager of the ECSC and is believed to be an employee of the City. Reid was primarily responsible for, including but not limited to (a) the supervising of all combative sports competitions; (b) licensing and permitting decisions for the ECSC with respect to combative sports events and fighter participation; and, (c) making appropriate investigations and taking necessary steps to ensure compliance with, and enforcement of, the provisions of the Bylaws Reid is believed to presently reside out of Alberta in St. Catharines, Ontario, A real and substantial connection is established between this within claim against Reid and the province of Alberta on the basis that the claim relates to a tort committed in Alberta and ‘would be governed by the laws of AlbertarT 4 12. 13. 14, The Defendant, Len Koivisto ("Koivisto’), is an individual resident at all times material hereto in the City of Edmonton, in the Province of Alberta. Koivisto was the referee for the boxing match that occurred between the Deceased and Adam Braidwood on June 16, 2017, which ultimately resulted in the death of the Deceased (the “Braidwood Fight’). The Defendant, Dr. Shelby Karpman (‘Karpman’), is a medical doctor resident at all times material hereto, in the City of Edmonton, in the Province of Alberta. The Plaintiffs believe that Karpman was a ringside physician employed by the ECSC for the Braidwood Fight, but also the chief medical officer retained by Reid in his capacity as Executive Director of the ECSC. The Defendant, Dr. Shirdi Nulliah (‘Nulliah’), is a medical doctor resident at all times material hereto, in the City of Edmonton, in the Province of Alberta. The Plaintiffs believe that Nulliah was one of the ringside physicians employed by the ECSC for the Braidwood Fight. The Defendant, David Aitken (‘Aitken’), is an individual resident at all times material hereto in the City of Edmonton, in the Province of Alberta. Aitken is an employee of the City and is believed by the Plaintiffs to be employed by the City in the capacity of Branch Manager of Community Standards and Neighborhoods. Aitken is believed to have either been responsible, or alternatively, played a key role in the hiring and retention of Reid as an employee of the City. The Defendant, 1259754 Allberta Ltd. is a corporation incorporated pursuant to the laws of the Province of Alberta. ‘The Defendant, 1248345 Alberta Lid. is a corporation incorporated pursuant to the laws of the Province of Alberta The Defendant, K.0. Boxing Canada (°K.0. Canada’) between 1259754 Alberta Ltd. and 1248345 Alberta Ltd. under the laws of the Province is a general partnership formed of Alberta and is believed to operate business in the area of combative sports promotion. At all times material hereto, the Defendants each owed a duty of care to the Deceased to exercise a reasonable standard of care, skill, diligence, and ensure that the Deceased