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CANADA
SUPERIOR COURT
Class Actions
PROVINCE OF QUÉBEC
DISTRICT OF MONTRÉAL MICHAEL CARRIER, resident and
domiciled at Building No. 249-2, in the
No.: 500-06-000943-181 Town of Kangirsuk, District of Amos,
Province of Quebec, J0M 1A0

Plaintiff
v.

ATTORNEY GENERAL OF QUÉBEC, in


the capacity of representative of the
Director of Criminal and Penal
Prosecutions, the Minister of Justice and
the Minister of Public Security, with an
establishment at 1, rue Notre-Dame Est,
Suite 8.00, in the City of Montreal, District
of Montreal, Province of Quebec, H2Y 1B6

Defendant

AMENDED APPLICATION FOR LEAVE TO INSTITUTE A CLASS


ACTION AND TO BE DESIGNATED REPRESENTATIVE
(Section 575 CPC)

TO ONE OF THE HONOURABLE JUDGES OF THE SUPERIOR COURT, SITTING ON


AND FOR THE JUDICIAL DISTRICT OF MONTREAL, THE PLAINTIFF STATES
RESPECTFULLY AS FOLLOWS:

I. Preamble

1. Nunavik is a territory north of the 55th parallel, which covers nearly a third of the
area of the province of Quebec.

2. In 2011, the total population of Nunavik was 12,090.

3. Of this number, 10,755 were Inuit, representing almost 90% of the population, as
shown in the report by Statistics Canada titled “Inuit: Fact Sheet for Nunavik” and
dated March 29, 2016, Exhibit P-1.

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4. Anyone arrested and detained in Nunavik should be entitled to the full protection
of the Law, in the same way as all Canadian and Quebec litigants; this is not the
case.

5. The Criminal Code, the Canadian Charter of Rights and Freedoms (hereinafter the
“Canadian Charter”) and the Charter of Human Rights and Freedoms (hereinafter
the “Quebec Charter”) usually require that persons accused of a crime retain their
freedom while awaiting trial.

6. Where an accused is not released before or at the time of appearance in court, the
lawfulness of his detention can be controlled by holding what is commonly known
as a bail hearing (hereinafter the “Bail Hearing”).

7. Unless the accused renounces to it, the Bail Hearing must imperatively be held
within a period of three clear days, in order to protect his rights and to avoid any
undue extension of his detention.

8. In Nunavik, this delay is systematically violated due to the indifference and


negligence of the Defendant.

9. Dozens of people who are charged each year in this territory are illegally detained
for periods that surpass by several days, even weeks, the period of three clear
days without having the lawfulness of their detention duly examined by a justice of
the peace.

10. The members of the group defined below are entitled to compensation for the
damages they have suffered as a result of the fault of the Defendant and for
repeated violations of their fundamental rights.

II. Facts

1. The Parties

a. The Members of the group

11. The Plaintiff, Michael Carrier, wishes to institute a class action on behalf of the
natural persons included in the following group of which he is a member:

Any person who, having been charged in Nunavik with a criminal offence
after September 4, 2015, has been detained for a period exceeding three
clear days without a bail hearing being held in accordance with Article 515
of the Criminal Code, unless that person has deliberately consented to
such detention.

12. The Plaintiff reserves his right to modify and extend the period covered by this
authorization application.

b. The Defendant and her representatives

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13. The Defendant represents several government stakeholders who collectively


control the administration of justice in criminal matters in Nunavik.

14. She represents the Director of Criminal and Penal Prosecutions (hereinafter the
“DCPP”), which is responsible for directing all criminal and penal prosecutions in
Quebec on behalf of the State.

15. She also represents the Department of Justice (hereinafter the “DJQ”), which has
the duty to ensure the principle of the equality of between citizens and to ensure
respect for the rule of law in Quebec.

16. Finally, she represents the Department of Public Security (hereinafter the “DPS”)
which is responsible for the custody of detainees awaiting trial in Quebec.

2. The right to a Bail Hearing within 3 clear days

17. In a free and democratic society, the State must take all the necessary measures
to minimize the risk of unjustifiably depriving its citizens of their liberty, even if only
for one day.

18. In criminal law, this fundamental liberty of the citizen concerned is generally
reflected in the right to the presumption of innocence and as a corollary, the right
not to be unfairly deprived of one’s liberty while awaiting trial.

19. Thus, any delay in releasing an accused person from custody necessarily
undermines the presumption of innocence.

20. When the State nevertheless still detains an accused person while awaiting trial,
the Criminal Code provides that a Bail Hearing must be held by a judge so that the
lawfulness of that detention is subject to judicial review.

21. The accused’s freedom being at stake, this Bail Hearing must be held within three
clear days.

22. Only the accused can legally waive this deadline.

a. The situation in Nunavik

23. When an offender is arrested in Nunavik, he is usually taken by the police to a


justice of the peace in order to appear before him, most of the time by telephone.

24. If, during the appearance, the Public prosecutor does not oppose his release, the
accused is then released, with or without conditions.

25. If, however, the Public prosecutor opposes his release, the accused is placed in
pretrial detention and a warrant of remand is issued pending his Bail Hearing.

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26. Since there is no detention facility in Nunavik, the accused’s Bail Hearing cannot
be held in this territory.

27. Because of this constraint, the accused must be transported to the Amos
courthouse, also located in the judicial district of Abitibi, so that the lawfulness of
his detention can be verified.

28. This transportation lasts almost systematically for several days, as it appears in
the report of the Québec Ombudsman titled “Detention conditions administration
of justice and crime prevention in Nunavik” and dated February 18, 2016,
Exhibit P-2.

29. The accused’s journey usually starts in shackles and chains aboard a commercial
aircraft to Montreal, a flight requiring up to 7 stops.

30. From Montreal, he is then transported shackled and chained to the Saint-Jérôme
detention facility, where he remains imprisoned for a few hours, even days.

31. The accused is strip searched twice, first during his admission and then again
when he leaves the Saint-Jérôme detention facility.

32. From Saint-Jérôme, the accused is then transported shackled and chained by land
to the detention facility in Amos, where his Bail Hearing can finally begin.

33. The accused is strip searched a third time during his admission and then a fourth
time upon his departure from the Amos detention facility.

34. Thus, in Nunavik, the delay between the appearance of the accused and the
beginning of his Bail Hearing can vary from one day to two weeks.1

35. In addition, when the Bail Hearing is held by videoconference, which is common in
order to allow the accused’s counsel to appear remotely, the parties usually have
only 45 minutes to complete evidence and submissions.

36. This additional constraint forces the accused and his attorney, who did not have
access to his client during his transport, to act hastily, on pain of seeing the Bail
Hearing continued and the “pretrial” detention extended.

37. The consequences of this constraint are further magnified when the proceedings
are held in Inuktitut and the presence of an interpreter is required.

38. When the accused is finally released at the end of his Bail Hearing, he must repeat
the circuit in the opposite direction to return to Nunavik, a “perilous” trip which, for
all intents and purposes, prolongs his deprivation of liberty, as evidenced by the

1 Exhibit P-2, p.50

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sworn testimony of Ms. Lyne Saint-Louis, Justice Officer of Makivik Corporation,


dated June 5, 2018, Exhibit P-10.

39. Between January 1, 2015, and October 9, 2018, the average length of pretrial
detention of Quebec Inuits exceeded that of the total prison population by nearly
50%, as it appears in statistics obtained from the DPS through the Act respecting
Access to documents held by public bodies and the Protection of personal
information, Exhibit P-11.

b. The particular case of the Plaintiff

40. The Plaintiff is Inuit.

41. He was born on May 10, 1990, and currently resides in the northern village of
Kangirsuk, Nunavik.

42. He is the father of two children aged 1 and 2, and works full time.

43. On July 5, 2018, he was arrested in the northern village of Kangirsuk.

44. He appeared the same day from the Kangirsuk Police Station.

45. At the time of his appearance, the public prosecutor opposed his release and a
warrant of remand was issued, as it appears in the warrant of remand, dated July 5,
2018, Exhibit P-3.

46. As the Public prosecutor’s Office was unable to offer any availabilities for the
conduct of a Bail Hearing, the file was postponed to July 10, 2018.

47. From Kangirsuk, he was transferred to Kuujjuaq.

48. On or about July 7, 2018, he was transported from Kuujjuaq to Montreal and then
from Montreal to the Saint-Jérôme detention facility.

49. He was the subject of a first strip search when he arrived in Saint-Jérôme.

50. On or about Monday, July 9, he was transported from the Saint-Jerome detention
facility to the one in Amos.

51. He was subjected to a second strip search when he left Saint-Jérôme and a third
strip search when he arrived in Amos.

52. On July 10, 2018, he was finally able to appear from the Amos detention facility
and to set the date of his Bail Hearing on the first date offered by the Public
prosecutor, on July 13, 2018.

53. A new warrant of remand was issued, as it appears in the warrant of remand dated
July 10, 2018, Exhibit P-4.

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54. On July 13, 2018, the date chosen for his Bail Hearing, the Public prosecutor finally
changed his position and consented to his release on an undertaking, as it appears
from the undertaking dated the same day, Exhibit P-5.

55. He was therefore detained on July 5, 6, 7, 8, 9, 10, 11, 12 and 13 pending a Bail
Hearing that never took place.

56. After being subjected to a fourth strip search, he was released in Amos, . . .and
had to make the trip back to Kangirsuk.

57. It was not until July 15, 2018, that he was finally able to return to his home and to
his children, 10 days after his arrest.

3. Fault

58. By not allowing the members of the group to obtain their Bail Hearing within the
period required by the Law, the Defendant unjustly deprived them of their liberty.

59. In doing so, the Defendant violated their right to liberty and security, protected by
section 7 of the Canadian Charter and section 1 of the Quebec Charter.

60. She also violated their right not to be deprived of reasonable bail without just
cause, a right guaranteed under paragraph 11(e) of the Canadian Charter and by
section 31 of the Quebec Charter.

61. She violated their right to the presumption of innocence, a right guaranteed by
paragraph 11(d) of the Canadian Charter and by section 33 of the Quebec Charter.

62. She also violated their right to be protected against arbitrary detentions, a right
guaranteed by section 9 of the Canadian Charter and by section 24 of the Quebec
Charter.

63. In addition, she violated their right to protection from cruel and unusual treatment,
a right guaranteed by section 12 of the Canadian Charter and by section 25 of the
Quebec Charter.

64. Finally, she violated their right to the full and equal recognition and exercise of their
human rights and freedoms, a right guaranteed by section 15 of the Canadian
Charter and by section 10 of the Quebec Charter.

65. In so doing, the Defendant acted in full knowledge of the immediate and natural
consequences of her conduct on the rights of the members of the group.

a. The James Bay and Northern Quebec Agreement

66. As early as 1975, the Government of Quebec was aware of the problems relating
to the lack of a detention facility in Nunavik and was committed to correcting the
situation to allow Inuit to be detained on their territory:

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20.0.25 As quickly as possible... the appropriate detention institutions shall be


established within the judicial district of Abitibi so that lnuit should not be, unless
circumstances so require, detained, imprisoned or confined in any institution
below the 49th parallel.

as it appears in the “James Bay and Northern Quebec Agreement and


Supplementary Agreements”, Exhibit P-6.

67. In 2002, the Quebec government renewed its promise and pledged to build a
detention facility in Nunavik, this time before December 31, 2005, as it appears in
the document titled “Partnership Agreement on Economic and Community
Development in Nunavik” dated 2002, Exhibit P-7.

68. These promises have remained dead letters.

b. The Québec Ombudsman’s investigation

69. In its devastating 2016 report, the Québec Ombudsman paints a dark portrait of
the detention conditions and the administration of justice in Nunavik, specifically
noting the almost systematic violation on its territory of the right to obtain a Bail
Hearing within the timeframe provided for by law:2

The Criminal Code stipulates that a bail hearing for someone awaiting trial must
take place within three days of the arrest unless the accused consents to a
longer time frame. However, since bail hearings occur in Abitibi-
Témiscamingue, the remand warrant’s three-day deadline has in most cases
already expired by the time the accused faces the judge. This is in violation of
the Criminal Code.

70. Following the tabling of this report in the National Assembly, the Minister of
Immigration, Diversity and Inclusion and Government House Leader for the
Government of Quebec, Simon Jolin-Barette, then spokesman for the Second
Opposition Group in the matters of justice, recognized that accused from Nunavik
are treated as [TRANSLATION] “second-class citizens “ would be treated in a “Gulag”,
as it appears from the transcript of Minister Simon Jolin-Barette’s briefing, dated
February 18, 2016, Exhibit P-12.

71. Minister Jolin-Barette severely criticized the DPS, noting in passing that these
inhuman displacements could easily be avoided by the use of videoconferencing.

72. This solution has been advocated since at least 2009 by the Working Group on
Justice in Nunavik, the whole as it appears from the report of the Task Force on
Justice in Nunavik for 2008-2009, Exhibit P -13.

73. Questioned by the Québec Ombudsman, the DPS and the DJQ committed to
[TRANSLATION] “make every effort in the coming months to implement major projects

Exhibit P-2, p. 49.

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that will provide solutions”, as it appears from the letter of commitment DPS and
DJQ dated May 31, 2016, Exhibit P-14.

74. Once again, this commitment was not respected.

c. The Commission Viens

75. On December 21, 2016, a Commission of Inquiry (Hereinafter the “Commission


Viens”) was set up to investigate, among other things, the discrimination endured
by Aboriginal people in Quebec with respect to access to justice.

76. The testimony heard in the context of this commission confirmed the Defendant’s
inaction and total indifference to the violations suffered by the members of the
group.

77. Representatives of the judiciary explained that the Courts have been asking in
vain, and for more than 10 years, that the Bail Hearings be held from Nunavik so
that the rights of the accused are respected, the whole as it appears from the
testimony of the Honourable Lucille Chabot, Coordinating Judge for the Regions
of Abitibi-Témiscamingue and Nord-du-Québec, and the Honourable Danielle
Côté, J.c.Q, dated December 10, 2018, Exhibit P-15.

78. The judiciary suggests some simple solutions, including the use of
videoconferencing.

79. The problem was also decried by the Barreau d’Abitibi-Témiscamingue-Nord-du-


Québec, which suggests the same solutions, including the use of
videoconferencing, as it appears from the testimony of the Honourable Nathalie
Pelletier, J.S.C., then president of the Barreau d’Abitibi-Témiscamingue-Nord-du-
Québec, dated April 19, 2018, Exhibit P-16.

80. The sworn testimony of the Director and Chief Public Security Officer of the Kativik
General Administration (hereinafter the “ARK”), Jean-Pierre Larose, reveals that
the rights of the accused are continually violated and describes the treatment as
[TRANSLATION] “inhuman” and “unacceptable”, as it appears from the sworn
testimony of Jean-Pierre Larose dated November 22, 2018, Exhibit P-17.

81. The President of the ARK herself, Ms. Jennifer Munick, lamented the “cruelty” and
“inhuman” nature of the displacement of the accused who consume 10% of the
Kativik Regional Police Force’s annual budget, as it appears in the sworn testimony
of Jennifer Munick dated November 19, 2018, Exhibit P-18.

82. Another Nunavik citizen, Lucy Grey, who acted as liaison officer for the
Commission Viens, described the horror experienced by members of the group
during their transfer to the “south” and the impact of those trips on their
communities, as evidenced by Ms. Lucy Grey’s sworn testimony dated November
23, 2018, Exhibit P-19.

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83. A representative of the DCPP even admitted to denouncing, apparently without


being heard, the problem for “a long time”, the whole as it appears from the
testimony of Ms. Marie-Chantal Brassard, chief prosecutor of the DCPP on
November 13, 2018, piece P-20.

84. Just recently, the Québec Bar also insisted on the urgency and the need to act
quickly to ensure the protection of the fundamental rights of Nunavik residents:
[TRANSLATION]

Currently, the lack of resources in Nord-du-Québec, including the lack of


videoconferencing facilities, the lack of suitable places for detention and
the absence of aerial links between certain cities, compromises the
fundamental rights of persons accused or convicted in criminal matters.

as it appears in the Quebec Bar’s brief titled “Le système de justice et les peuples
autochtones du Québec : des réformes urgentes et nécessaires”, dated April 19,
2018, Exhibit P-8.

85. In August 2018, this Honourable Court in turn ordered the Department of Public
Security to set up adequate facilities in Nunavik [TRANSLATION] “. . .so that Inuit and
other residents of this region have the same detention rights as other Canadian
citizens,” as it appears from the judgment of the Superior Court dated August 28,
2018, Exhibit P-9.

86. Despite renewed warnings from the Québec Ombudsman, the Quebec Bar and
the Courts, the Defendant insists on disregarding the rights of members of the
group.

87. Such unlawful, intentional and malicious conduct towards them must be
sanctioned by the award of punitive damages.

4. Damages

88. The forced displacement over thousands of kilometers in inhuman conditions of


detention, the language barrier and the distance from family and community are all
factors that increase the feeling of abandonment, loneliness, helplessness, anxiety
and desperation related to the illegal detention suffered by the Plaintiff and
members of the group.

89. The Plaintiff is entitled to claim, for himself and for each of the members of the
group, compensation of $10,000.00 per day of illegal detention for the violation of
their fundamental rights.

90. In view of the failings and unlawful, intentional and malicious acts of the Defendant,
the Plaintiff is also entitled to claim, for himself and for each of the members of the
group, punitive damages in the amount of $50,000.00.

III. The composition of the group

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91. The composition of the group renders difficult or impractical the application of the
rules on the mandate to take legal action on behalf of others or on the joinder of
proceedings.

92. It is indeed impossible for the Plaintiff to contact all the members of the group and,
even more, to obtain a mandate from them, since this action is likely to target
several. . . hundreds, even. . . thousands of people, the whole as it appears from
statistics contained in a report presented by the Court of Québec to the
Commission Viens, Exhibit P-21.

93. In addition, the members of the group live for the most part in precarious conditions
and must endure on a daily basis the particularly unfair treatment that the State
still reserves today for the Inuit of Quebec.

94. For this particularly vulnerable group, therefore, class action is the best way to go
to the Courts and seek justice.

IV. Preliminary Issue

95. The identical, similar or related issues of fact and law that bind each member of
the group to the Defendant and that the Plaintiff seeks to have decided by class
action are:

1. Did the Defendant infringe the rights of the members of the group
protected by sections 7, 9, 11, 12 and 15 of the Canadian Charter of Rights
and Freedoms by not allowing the holding of a bail hearing within the
period prescribed by the Law?

2. If so, are members of the group entitled to damages as a just and proper
remedy under subsection 24(1) of the Canadian Charter of Rights and
Freedoms?

3. Did the Defendant infringe the rights of the members of the group
protected by sections 1, 10, 24, 25, 31 and 33 of the Charter of Human
Rights and Freedoms by not allowing the holding of a bail hearing within
the period prescribed by the Law?

4. If so, are members of the group entitled to compensation as a just and


proper remedy under the first paragraph of section 49 of the Charter of
Human Rights and Freedoms?

5. Did the Defendant unlawfully and intentionally violate the rights of


members of the group protected by the Charter of Human Rights and
Freedoms by not allowing a bail hearing to be held within the period
prescribed by the Law?

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6. If so, are members of the group entitled to punitive damages as a just and
proper remedy under the second paragraph of section 49 of the Charter
of Human Rights and Freedoms?

7. Did the Defendant commit a civil fault against the members of the group
by not allowing a bail hearing to be held within the period prescribed by
the Law?

8. If so, is the Defendant obliged to compensate the Plaintiff and the


members of the group for the damages thus caused?

V. The relief sought

96. The Plaintiff identifies the relief sought by the class action as follows:

ALLOW the action of the Plaintiff on behalf of all members of the group;

CONDEMN the Defendant to pay the Plaintiff and each member of the group an
amount of . . .$10,000.00 per day spent in illegal detention for the infringement of
their fundamental rights, all with interest at the legal rate plus the additional
indemnity since the filing of the application for leave to institute a class action;

CONDEMN the Defendant to pay the Plaintiff and each of the members $50,000.00
in punitive damages;

ORDER that the claims of the members be the subject of a collective recovery;

RECONVENE the parties within 30 days of the final judgment to determine the
distribution measures of the amounts collectively recovered;

ALL with costs, including the costs of all experts, notices and expenses of the
administrator, if any.

VI. The adequate representation

97. The Plaintiff is a member of the group and has a good knowledge of the file.

98. Being himself Inuit and resident of Nunavik, he is able to understand and well
represent the group.

99. He is willing to invest the resources and time necessary to complete all formalities
and tasks related to the exercise of this class action and is committed to working
fully with his lawyers.

100. He acts in good faith for the sole purpose of obtaining justice for himself and for
each member of the group.

101. For these reasons, the Plaintiff is able to ensure adequate representation of the
members of the group he intends to represent.

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VII. The judicial district

102. The Plaintiff requests that the class action be brought before the Superior Court in
the District of Montreal since it is where the Defendant has one of her principal
places of business.

FOR THESE REASONS, THE COURT:

ALLOWS the application for leave to institute a class action and to be designated
as a representative;

AUTHORIZES the class action for compensatory and punitive damages against
the Defendant;

ALLOCATES to Mr. Michael Carrier the status of representative for the following
members of the group:

Any person who, having been charged in Nunavik with a criminal offence
after September 4, 2015, has been detained for a period exceeding three
clear days without a bail hearing being held in accordance with section
515 of the Criminal Code, unless that person has deliberately consented
to such detention.

IDENTIFIES as follows the main issues of fact or law that will be dealt with
collectively:

1. Did the Defendant infringe on the rights of the members of the group
protected by sections 7, 9, 11, 12, and 15 of the Canadian Charter of
Rights and Freedom by not allowing the holding of a bail hearing within
the period prescribed by the Law?

2. If so, are members of the group entitled to damages as a just and proper
remedy under subsection 24(1) of the Canadian Charter of Rights and
Freedoms?

3. Did the Defendant infringe the rights of the members of the group
protected by sections 1, 10, 24, 25, 31 and 33 of the Charter of Human
Rights and Freedoms by not allowing the holding of a bail hearing within
the period prescribed by the Law?

4. If so, are members of the group entitled to compensation as a just and


proper remedy under the first paragraph of section 49 of the Charter of
Human Rights and Freedoms?

5. Did the Defendant unlawfully and intentionally violate the rights of


members of the group protected by the Charter of Human Rights and
Freedoms by not allowing a bail hearing to be held within the period
prescribed by the Law?

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6. If so, are members of the group entitled to punitive damages as a just and
proper remedy under the second paragraph of section 49 of the Charter
of Human Rights and Freedoms?

7. Did the Defendant commit a civil fault against the members of the group
by not allowing a bail hearing to be held within the period prescribed by
the Law?

8. If so, is the Defendant obliged to compensate the Plaintiff and the


members of the group for the damages thus caused?

IDENTIFIES the relief sought as follows:

ALLOWS the action of the Plaintiff on behalf of all members of the group;

CONDEMNS the Defendant to pay the Plaintiff and each member of the
group an amount of . . .$10,000.00 per day spent in illegal detention for the
infringement of their fundamental rights, all with interest at the legal rate plus
the additional indemnity since the filing of the application for leave to institute
a class action;

CONDEMNS the Defendant to pay the Plaintiff and each of the members
$50,000.00 in punitive damages;

ORDERS that the claims of the members be the subject of a collective


recovery;

RECONVENES the parties within 30 days of the final judgment in order to


determine the distribution measures of the amounts collectively recovered;

ALL with costs, including the costs of all experts, notices and expenses of
the Administrator, if any.

DECLARES that unless excluded, the members of the group will be bound by any
judgment to intervene on the class action in the manner provided by law;

SETS the exclusion period to sixty (60) days after the date of the notice to the
members, at which time the members of the group who have not availed
themselves of the means of exclusion will be bound by any judgment to intervene;

ORDERS the publication of a notice to members in the manner to be determined


by the court;

REFERS the file to the Chief Judge for the determination of the district in which
the class action is to be taken and the designation of the judge to hear it;

ALL WITH COSTS OF JUSTICE, including the expenses of opinion.

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Montréal, Friday, January 11, 2019

(S) Coupal Chauvelot, S.a.


COUPAL CHAUVELOT, S.A.
Solicitors of the Plaintiff

Victor Chauvelot
victor@coupalchauvelot.com
1065, av. Pratt
Montréal QC H2V 2V5
Tel. 514.903-3390
Fax 514.843.8529

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