As meticulously detailed and documented on this website,

INTACT INHOUSE LAWYERS, CASEY GOODRICH and CHRISTA RAE CORDICK, IN COLLUSION WITH OUTHOUSE LAWYER NIGEL BECKMANN, ARE THE CHIEF ARCHITECTS OF INSURANCE FRAUD [per Criminal Code of Canada Section 380], VARIOUS TORTS, BREACHES OF CONTRACT, ABUSES OF PROCESS and DECEIT. THIS WEBSITE IS A DETAILED EXPOSURE OF THEIR PERPETRATIONS OF EGREGIOUS, ONGOING HUMAN RIGHTS ABUSES.

Regarded as "insurance experts" lawyers, within INTACT, Christa Rae Cordick, Casey Goodrich and Nigel Beckmann are held to an ultimate legal standard, against the backdrop of their collusive, systemic betrayal of the interests of both INTACT, Whitelaw-Twining, the Provincial and Supreme Court, as well as INTACT's policyholder Strata Corporation LMS 2845 and the named insured SLAPP Defendant.

1. Christa Rae Cordick: The Executive Architect of Deceit

Lawyer, Cordick engineered the jurisdictional fraud. By swearing an Affidavit (filed in the Supreme Court on 18 February 2025), infra, that the Strata Corporation had neither control, nor responsibility, over the de facto common property, inaccessible exterior ledge, Cordick fabricated a structural hazard. This was a calculated abandonment, designed to shift a dangerous, covered maintenance burden onto a retired Tenant, forcing him to engage in unsafe physical acts, in order to abate the hazard, infra.

2. Casey Goodrich: The Operative of Double-Betrayal

Lawyer Goodrich’s perfidy is unique: he betrayed not only the Claimant Tenant, but also his own client, Strata Corporation LMS 2845.

The Fraud: Goodrich and Cordick filed Provincial Court and Supreme Court pleadings, falsely claiming that Strata LMS 2845 had no responsibility or control over the inaccessible, exterior ledge. Cordick elevated INTACT's exposure with her perjured sworn Affidavit, which Whitelaw-Twining filed in the Supreme Court on 18 February 2025, infra.

The Unethical Deception: While ostensibly "representing" the insured, Strata LMS2845, Goodrich and Cordick lied to their Strata Client, fraudulently enabling INTACT to avoid paying for the remediation. By absurdly, falsely disavowing the Strata’s authority and control over its own property, Goodrich and Cordick deprived Strata LMS 2845 of its INTACT coverage benefits, and left the hazard unresolved, forcing the Tenant to pay for the costly remediation.

The Admission: The Myers' letter proves that INTACT had notice of the RTB eviction claim.

In Claims Manager Myers' letter of 30 September 2021, infra, she refer to the Insured Tenant's " request for legal defense at a wrongful eviction hearing". INTACT wrongfully refused the claim for defence counsel, which proximately caused the forced eviction of the Tenant.

3. Nigel Beckmann: The Instigator and Enforcer of Continuing Malice

Beckmann codified this collective deceit. His 07 December 2023 letter, infra, anchored the defamatory two (2) SLAPP actions that he filed against his Client INTACT's Insured. Even at the risk of his Clients' reputational damage, Lawyer Beckmann refuses to retract said letter. This is Continuing Malice: using a known lie to protect the "Ghost Claim" 1033684645 from exposure, infra.

Charging Allegation: The "Expert" Malice

These three lawyers replaced the Duty of Utmost Good Faith with a collusive Duty to Deceive. They targeted a retired Tenant’s vulnerability, by systematic sabotage of the insured Strata Corporation’s coverage, in an attempt to protect INTACT’s balance sheet.

4. Meera Jain: The Whitelaw-Twining Senior Associate, who assumed responsibility for this INTACT dossier several months ago, a transfer by which Partner Beckmann has achieved some deflection of responsibility for his acts and omissions. Attorney Jain may elect to clarify her position, without further ado.

13 January 2026

ASTONISHINGLY, IN A FUTILE ATTEMPT TO DISTANCE HIMSELF FROM THE FRAUDULENT (30 SEPTEMBER 2021) COVERAGE DENIAL OF HIS CLIENTS, CLAIMS MANAGER AMANDA MYERS AND CLAIMS REPRESENTATIVE BREANNA GRAY, THEIR LAWYER NIGEL BECKMANN HAS FALSELY STATED "NO ONE EVER SAID [THE SLAPP DEFENDANT CLAIMANT] OCCUPIED THE LEDGE", ALTHOUGH BECKMANN DID UNKNOWINGLY PROVIDE ADMISSIBLE EVIDENCE THAT MYERS' AND GRAY'S DENIAL WAS WRONGFUL, AS BEING DEVOID OF ANY LEGAL LEGITIMACY.

In the email of 13 January 2026, absent a "without prejudice" reservation, Attorney Beckmann has also proffered evidence that by the (30 September 2021) denial of coverage letter (as displayed on this website), Amanda Myers and Breanna Gray not only falsely accused the Claimant of "possession, occupation or use" of the physically impossible to access, exterior pigeon roost ledge (photographs of which are displayed on this website), Myers and Gray, who falsely claimed to have completed an investigation (according to the letter) explicitly invoked an exclusionary clause, fraudulently using the falsehood as a basis for their denial of coverage for claim number 4033526840.

In a futile attempt to deflect the facts, Attorney Beckmann disingenuously continues to posit that the 30 September 2021 coverage denial letter refers to both claim numbers 4033526840 and to "ghost claim" 1033684645, a falsehood that is easily exposed by examination of the letter, infra.

The legally admissible, "admission against interest" is significant because by falsely stating that no occupation of the ledge was ever asserted, INTACT’s counsel has acknowledged that the factual condition required to trigger an exclusion to coverage was never present.

VERSION JURIDIQUE FORMELLE (FRANÇAIS)

ÉTANT DONNÉ QUE LE CONSEIL D’INTACT A MAINTENANT CONFIRMÉ QU’AUCUNE « OCCUPATION » N’A JAMAIS ÉTÉ ALLÉGUÉE, LA CONDITION FACTUELLE NÉCESSAIRE À L’APPLICATION DE LA CLAUSE D’EXCLUSION CITÉE DANS LA LETTRE DE REFUS DU 30 SEPTEMBRE 2021 FAIT DÉFAUT. EN CONSÉQUENCE, L’EXCLUSION EST INAPPLICABLE ET LE REFUS DE GARANTIE SE TROUVE DÉPOURVU DE FONDEMENT OPÉRATIONNEL.

10 January 2026

FORMAL NOTICE TO INTACT INSURANCE AND WHITELAW-TWINING

WITHOUT PREJUDICE AND SUBJECT TO THE PROTECTION OF PUBLIC PARTICIPATION ACT

NOTICE OF CRIMINAL HAZARD AND INSTITUTIONAL PERJUDICIAL CONDUCT

This is a formal notice, to address a critical divergence between your current litigation strategy—the "Defamation Offense"—and the documented institutional record of your client, Intact Insurance.

Your joint legal position contradicts the written admissions of INTACT personnel, Amanda Myers, Breanna Gray, Christa Cordick, who had affirmed the SLAPP Defendant's legal status of INTACT Insured. You are attempting to manufacture a reality that places the aforementioned personnel and Whitelaw-Twining Associate Lawyer Meera Jain, in direct criminal and ethical peril.

1. The Section 136 (Criminal Code of Canada)

Be advised that any testimony offered by INTACT personnel that aligns with your "manufactured" offence—specifically the denial of the status as an INTACT Insured—will activate the "Contradictory Evidence" provisions of the Criminal Code of Canada:

• Section 136 (Contradictory Evidence): It is an indictable offense for a witness to give evidence in a judicial proceeding that is contrary to their previous evidence with intent to mislead. If any of the aforementioned personnel should testify in support of Whitelaw-Twining's current narrative, her own prior written affirmations of the insured status will serve as the primary evidence for their indictment.

• Section 13 (Canada Evidence Act) Exception: While witnesses generally enjoy protection from self-incrimination, Section 13 specifically excludes prosecutions for perjury or the giving of contradictory evidence. There is no "Charter shield" for witnesses who testify falsely to support their lawyer’s tactical misadventure.

2. Ethical Hazards and the Duty of Candour

This unethical strategy creates a profound conflict for Meera Jain, the Associate Lawyer whom you have assigned to this case. Under Rule 5.1-2 of the BC Code of Professional Conduct, an associate lawyer has an independent duty not to knowingly assist in or encourage any dishonesty or fraud. Filing documents or calling witnesses to testify in a manner that contradicts the firm’s own client files is a direct breach of the Duty of Candour owed to the court.

3. Preservation of Integrity and Good Faith

The SLAPP Defendant has made every effort to preserve the reputational interests of INTACT and Whitelaw-Twining. The offer to remove the Beckmann letter from the public record, in exchange for a factual retraction was a "safe harbour" designed to:

1. Prevent the commission of institutional perjury;

2. Protect the associate lawyer’s professional standing; and

3. Uphold the integrity of the judicial process.

Your refusal to accept a settlement based upon documented truth, in favor of one based upon a tactical lie, confirms an improper purpose and an abuse of process.

Please be governed accordingly. Any attempt to present witnesses to the court in a manner that contradicts their established written record will be met with immediate reference to Sections 131, 136, and 137 of the Criminal Code.

佛山祖廟

As documented, infra, the SLAPP Defendant and his family sustained substantial damages, including costs of the abatement of the pigeon faecal matter hazard emanating from the external ledge of unit 1702. Other damages include sanitisation of the rooms, particularly of the bedroom unit, situated above the inaccessible external ledge, and alternate housing during the sanitisation procedures.

INTACT inhouse Counsel, Christa Rae Cordick's perjured Affidavits and false and defamatory representations to the Provincial and Supreme Courts, infra, represent only a small element of her unethical and unprofessional acts and omissions. "Insurance expert" Cordick is primarily responsible for the systematic failure of INTACT Insurance to comply with the explicit terms of the BFL Canada/CapriCMW Strata Program policy CMW M1756, claims no. 4033526840 and 1033684645 (which, according to claims personnel Breanna Gray's and Don McLaughlin's file notations of 30 April 2024, is still pending, which has implications regarding the tolling of the statute of limitations).

1. Attorney Cordick’s Egregious Fiduciary and Statutory Breaches

• Summary Denial and Obstruction: Cordick acted as a "human firewall," unilaterally refusing to open a claim or address reported biohazards, despite being notified of the pigeon faecal matter and other issues, which, according to INTACT's records, were reported by INTACT personnel Sara Alkhatib and Thierry François, during August 2021.

• Perjury regarding "Control": In her Supreme Court Affidavit, Cordick falsely declared that Strata LMS2845 had "neither responsibility nor control" over the inaccessible, exterior pigeon roost ledge, infra. This contradicts Section 72 of the Strata Property Act, which mandates Strata repair of Strata property which is inaccessible by any resident of the building, and ignores the fact that Chubb Endorsement No. 18 and Zurich Z Choice Pollution Liability cover such conditions at any location insured under the policy, with no "exterior" exclusion.

• Suppression of Scheduled Insurers: Cordick ignored direct requests to notify other Scheduled Insurers, falsely claiming (1) that since the INTACT policy provided no such coverage, that Lead Insurer INTACT had no responsibility to apprise the other Scheduled Insurers of the claims, and (2) that the Strata Corporation had no such coverage.

2. The Suppression of Specialized Remediation Funds

Despite having the policy deck, INTACT, by way of its "insurance expert" Counsel Cordick failed to disclose or trigger two important, independent sources of coverage:

• Chubb Endorsement No. 18 ($100,000): This specifically covers costs to "clean up, remove, restore or replace property" due to Fungus (defined as mildew, mould, mycotoxins, or spores). The general virus/bacteria exclusion explicitly does not apply to this fungus coverage.

• Zurich Z Choice Pollution Liability: This policy provides coverage for On-Site Cleanup Costs resulting from a "pollution event" discovered during the policy period. The record of the August 2021 report of "two biohazards" constituted a discovery that INTACT was legally obligated to investigate under this policy.

3. INTACT’s Institutional Bad Faith

INTACT, as the lead Insurer, breached the Duty of Utmost Good Faith through the following documented actions:

• Willful Refusal to Respond to Emergency: On 20 August 20 2021, at 20:35, INTACT’s FNOL intake recorded the statement of the claims, affirming coverage, and that the Strata was "refusing to open a claim".

• Administrative Sabotage: At 20:46, just 11 minutes later, Intact personnel downgraded the emergency to a "regular adjuster during business hours," falsely claiming there was "no need for a restoration company" despite the reported biohazard and unlivable conditions.

• Breach of Duty to Advise: As the lead manager of the subscription, INTACT had an affirmative duty to inform the Claimant of the Chubb and Zurich coverages. Instead, they remained silent, allowing the false, "non-insured" narrative to facilitate a permanent loss of these contractual benefits.

4. Violation of the Subject Insurance Contract

• Reporting Compliance: The Claimant fulfilled the contractual requirement to report the claim "as soon as possible" via the August 2021 FNOL.

• Indemnity Deprivation: By refusing to coordinate with the other Scheduled Insurers, INTACT deprived the Claimant of valuable insurance coverage.

A testament to Attorney Cordick's antagonistic, malicious posture she compounded her own human rights oppressions by becoming a Plaintiff of two (2) malicious SLAPP actions, as detailed infra.

INTACT COMPAGNIE D’ASSURANCE

Détournement de Valeurs : L'Anatomie d'une Fraude à Double Voie

La directive « Vivre nos valeurs » de CEO Brindamour est trahie par une tromperie systémique. Le Dossier 4033526840 constitue une fraude active : un refus formel fondé sur une enquête inexistante.

Pourtant, le Dossier Fantôme 1033684645 est une infamie juridique supérieure. En maintenant ce fichier occulte et non arbitré, Intact a pratiqué une suppression administrative. Cette manœuvre a neutralisé les garanties spécialisées sans jamais émettre de refus officiel, privant l'assuré de tout recours.

C'est un sabotage contractuel prémédité—un témoignage accablant d'une perfidie institutionnalisée.

For anglophonic viewers of this public interest website, a brief introduction to the legendary Willie Lamothe would be in order.

Willie was not educated at Laval, University of Montreal Law School or Sherbrooke, but he sang to truth and the dignify of the human species

Find a comfortable, state of the art, "ergonomic relaxer" (chair) at Whitelaw-Twining's exquisite harbour view offices, and listen to the below "Ode to INTACT and its WHITELAW-TWINING COHORTS", in a rendition that only Willie could deliver!

Whitelaw-Twining Partner's Malicious Interference with Statutory Regulatory Rights

As evidenced by the Exhibit to an Affidavit, filed by Whitelaw-Twining, its Partner unethically threatened to file a (SLAPP) action against a confirmed INTACT Insured, unless the Insured should cease communications with INTACT Claims personnel, Claims Representative Breanna Gray, Claims Manager Amanda Myers, and Ombudsman Michele Vincent, who had assigned the Insured's Complaint to INTACT's Customer Experience Team, for investigation.

The lawyer also threatened litigation, unless the Insured should forfeit his right to maintain this public interest website, that documents the facts of lawyer's unethical conduct. (When the Insured refused to succumb to the Whitelaw-Twining lawyer's intimidative tactics, the lawyer filed not only one, but two (2) SLAPP actions against the Insured).

The Protected Right to Complain: Under the Financial Institutions Act § 80.3, and BCFSA regulatory protections, every insured has a "Right to Complaint Resolution." This is an independent regulatory track that exists outside of a the offence lawyer's control.

The Ethical Breach: Under the Law Society of BC Code of Professional Conduct (Rule 3.2-5), it is improper for a lawyer to "threaten to lay a charge or make a complaint to a regulatory authority in order to secure a civil advantage." Conversely, using the threat of a civil lawsuit to induce the withdrawal of a legitimate regulatory complaint is an abuse of the administration of justice.

Obstruction of Oversight: By demanding that the INTACT Insured cease pursuit of a Complaint that had been assigned to the Customer Experience Team, the lawyer unethically prevented INTACT's personnel from compliance with INTACT's internal complaint resolution protocol, infra, which led INTACT on a costly venture that has accomplished tens of thousands of dollars of offence costs, and an indelible departure from the CEO's "Living Our Values" directive.

The Whitelaw-Twining Partner also published his defamatory letter to personnel of INTACT, as he had done with his letter of 07 December 2023, infra. Such adds yet another layer of intrigue to Whitelaw-Twining's lucrative venture!

09 January 2026

As explained in precise detail on this website, Whitelaw-Twining Partner is not merely litigating; he is conducting an unethical experiment that requires the moral compromise not only of his Clients (INTACT, Amanda Myers, Breanna Gray, Christa Cordick and Michele Vincent), but of Meera Jain, the Associate Lawyer whom he assigned to this case.

The SLAPP Defendant had attempted to resolve issues extrajudicially, by removal of his counterclaim of defamation of the Whitelaw-Twining Partner's letter of 07 December 2023, infra, as well as deletion of all images and references thereto from this website.

However, the Partner has rejected the Offer, which necessitates that his Clients choose between:

(1) AssertIon of their legal and ethical rights to uphold the integrity of their own emails, Affidavits and court-filed statements of record, regarding the Defendant's legal status as an insured of INTACT. OR

(2) Commission of perjury, by support of the Whitelaw-Twining Partner's false and defamatory letter of 07 December 2023.

The Ethical Contagion of Tactical Falsehood

In Canadian law, a conflict of interest exists when there is a "substantial risk" that a lawyer’s loyalty is affected by his/her own interests (Strother v. 3464920 Canada Inc., 2007 SCC 24).

Abuse of Process - Nixon v. Cochrane, 2013 BCSC 133. Using the threat of litigation to achieve a "collateral purpose" (denial of the existence of true records) is an abuse of the court

Honest Performance - C.M. Callow Inc. v. Zollinger, 2020 SCC 45. Parties have a duty of honest performance. Manufacturing a false narrative to avoid a contractual obligation is prohibited.

Duty of Candour- R. v. Neil, 2002 SCC 70. A lawyer's "Bright Line Rule": He cannot act in a way that is adverse to the established legal/factual truth of a client's own files.

Material Misrepresentation - Slotkin v. Citizens Casualty Co. A lawyer can be held personally liable for a settlement obtained through the concealment of material facts

The Associate's Peril - Under the BC Code of Professional Conduct (Rule 5.1-2), an Associate Lawyer has an independent duty not to assist in "dishonesty, fraud, or illegal conduct." If the Associate facilitates a demand that she knows contradicts the written affirmations of her Clients, INTACT’s own staff, there are legal consequences.

The purpose of citation of ethical guidelines is to remind the involved Whitelaw-Twining lawyers of their ethical obligations. The Defendant has no intention of filing a complaint to the LSBC !

THE BELOW LETTER OF 07 DECEMBER 2023, FROM THE WHITELAW-TWINING DIRECTOR OF THE FIRM'S DEFAMATION AND INSURANCE LAW DEPARTMENTS, CONTAINS NUMEROUS FALSE, DEFAMATORY ACCUSATIONS, WHICH CONSTITUTE STRATEGIC (PROFITABLE) DEFAMATION, WITH AN ATTEMPT TO REWRITE HISTORY.

THE LAWYER's SUBSEQUENT TWO (2) SLAPP ACTIONS AGAINST HIS OWN CLIENT's INSURED, NOT MERELY CONSTITUTES AN EGREGIOUS VIOLATION OF RULE OF COURT 1-3, IT UNETHICALLY SUBJECTS THE ROLE OF THE SUPREME COURT AS A COLLECTION AGENCY FOR WHITELAW-TWINING's ILL-GOTTEN GAINS.

The December 7, 2025, letter from Whitelaw-Twining Director represents a strategic and ethical "point of no return." By advising a client to deny a previously established fact (the Claimant’s status as an Insured), the lawyer has moved beyond advocacy and into the realm of active interference and defamation.

1. The Legal "Reversal of Fact"

In insurance law, once a carrier (the client) has established or confirmed that a party is an "insured," that confirmation carries legal weight.

• The Interference: For a lawyer to advise a client to un-confirm that status—despite the client’s own findings— evidences an attempt to manufacture a defence where none exists.

• Bad Faith Aggravation: This provides a clear "paper trail" showing that the denial of the claim was not based upon a genuine dispute of fact, but, rather upon a lawyer-led effort to rewrite the history of the claim.

2. Defamatory Component: "Posing as an Insured"

The accusation that the claimant was "posing" as an insured is a direct attack on integrity.

• Published Malice: Because the Whitelaw-Twining lawyer "published" this letter (sent it to third parties), the threshold for defamation is met.

• The Contradiction: Since the client had already established the Claimant's legal status as an Insured, the statement is demonstrably false. Making a false statement that harms a person's reputation while knowing the truth (or being willfully blind to it) constitutes malicious defamation.

3. Professional Misconduct: Crossing the Line

Lawyers are protected by "qualified privilege" when giving legal advice, but that privilege is not absolute.

• Advising Dishonesty: A lawyer cannot ethically advise a client to state something they know to be false. The Whitelaw-Twining lawyer's advice that claims personnel Myers and Gray were "wrong" to confirm the status—despite their joint confirmation of the insured status, is evidence of the lawyer's advice to act in bad faith.

• Direct Liability: This makes the Whitelaw-Twining lawyer a potential co-defendant in a civil suit and a subject for a Law Society complaint regarding his duty to the administration of justice.

THE BELOW LETTER OF 07 DECEMBER 2023 EVIDENCES A SCHEME TO GENERATE PROFITS, BY FALSIFYING THE TRUTH AND REWRITING THE FACTS OF INTACT's OFFICIAL RECORDS.

Each of the false, defamatory statements levelled at INTACT's Insured, is quoted, verbatim:

1. “malicious conduct in targeting its employees”

• The lawyer accuses of malice: He defamatorily imputes a malicious state of mind, despite evidence to the contrary.

• Abandonment of facts: No factual basis; so the lawyer invents motive.

• Intent to steer INTACT: Frames the Insured as a threat to staff so that INTACT would feel compelled to distance itself from its Insured — including from its own earlier recognition of Insured status.

2. “repeated and incessant emails”

• Malice: The lawyer recasts normal consumer follow‑up as harassment.

• Abandonment of facts: No quantification, no examples — pure fabrication.

• Intent to steer Intact: Creates a narrative that the Insured is unreasonable, making it easier for INTACT's Ombudsman, Michele Vincent to justify abandonment of the confirmed assignment of the Insured's Complaint to the Customer Experience Team, infra.

3. “extraordinarily harmful… defamatory of the Company and its employees”

• Malice: The lawyer asserts the Insured of intent of extraordinary harm.

• Abandonment of facts: The lawyer labels the Insured's truthful statements as defamatory without identifying a single false assertion of fact.

• Intent to steer Intact: The lawyer positions the Insured as a reputational danger, encouraging INTACT to breach its contract with the Insured individual, as well as the Strata Council LMS 2845, for whom the policy was issued, infra.

4. “significant defamatory and false statements of fact”

• Malice: The Lawyer falsely claims that the Insured spread falsehoods.

• Abandonment of facts: Because they don't exist, the lawyer never identifies any false statement.

• Intent to steer Intact: The lawyer offers INTACT a false sense of security in breaching its contract.

5. “refers to you as an insured, which is untrue… deceives any potential reader”

• Malice: The lawyer falsely accuses the Insured of intentional deception.

• Abandonment of facts: The lawyer ignores INTACT’s own prior confirmation of the insured status.

• Intent to steer Intact: This is the core deception — The lawyer attempts to nullify the Insured's status, which happens to benefit Whitelaw-Twining with tens of thousands of dollars of ill-gotten spoils. The "Impossible Dream" for this Lawyer of La Mancha, infra.

  • no duty to defend

  • no duty to indemnify

  • no regulatory exposure

  • no internal contradiction to reconcile

6. “amplifying the sting of the defamatory remarks”

• Malice: The lawyer claims that the Insured intensified harm.

• Abandonment of facts: “Sting” is rhetorical, not factual.

• Intent to steer Intact: The lawyer paints the Insured with escalating hostility, making it easier for INTACT to justify its breach of contract.

7. “obvious intent… to indelibly smear the good name of the Company and its key employees”

• Malice: The lawyer falsely asserts a destructive, permanent intent.

• Abandonment of facts: The lawyer invents motive, without evidence.

• Intent to steer Intact: If INTACT believes that the insured is defaming its “key employees,” it becomes institutionally impossible for it to maintain the Insured status.

8. “to sow distrust in the market regarding their character and competence”

• Malice: He imputes economic sabotage.

• Abandonment of facts: No evidence that the Insured attempted to influence the market.

• Intent to steer Intact: He frames the Insured as a market threat — a perfect justification for INTACT to breach its contract, severe ties and accept Whitelaw-Twining's malicious, "cash cow" narrative.

9. “should therefore be shunned as a potential provider of insurance products and services”

• Malice: The lawyer claims that the Insured is orchestrating a boycott.

• Abandonment of facts: No evidence of any such campaign.

• Intent to steer Intact: If Intact believes the Insured is trying to harm its business, they will abandon any prior recognition of insured status without hesitation.

10. “remove the Post… or legal proceedings will be taken”

• Malice: The lawyer uses litigation threats to silence the Insured's right to file a Complaint, an egregious violation of BC's Protection of Public Participation Act (PPPA), when the lawyer filed two (2) separate SLAPP actions against INTACT's Insured.

Each of the Whitelaw-Twining Partner's false, defamatory accusations serves one purpose: to cause INTACT to breach its contract, not only with the Insured individual, but also with the Strata Council LMS 2845, a named insured of the below INTACT policy, that provides the individual with Tenants’ Legal Liability – Any One Premises – $500,000, at an ill-gotten spoils allocation of tens of thousands of dollars to Whitelaw-Twining's bulging coffres!

ALTHOUGH DEFAMATION DEFENCE FIRMS ARE COMMON ACROSS CANADA, A CREATIVE PARTNER AT WHITELAW‑TWINING HAS INTRODUCED A NEW SPECIALTY - DEFAMATION OFFENCE.. AN ANTI-WHISTLEBLOWER, ANTI-FREEDOM OF SPEECH PROJECT.

IN A FUTILE ATTEMPT TO IMPLEMENT HIS UNAVAILING, NEW LEGAL THEORY, THE PARTNER HAS FAILED TO CONSIDER THAT IN BC INSURANCE LAW, INTACT IS ESTOPPED FROM TAKING A POSITION INCONSISTENT WITH ITS PREVIOUS REPRESENTATIONS, ESPECIALLY SINCE THAT CHANGE CAUSES DETRIMENTAL RELIANCE. INTACT's OWN PERSONNEL (1) INHOUSE COUNSEL CHRISTA CORDICK (2) CLAIMS MANAGER AMANDA MYERS and (3) CLAIMS REPRESENTATIVE BREANNA GRAY HAVE ALREADY CONFIRMED THE CLAIMANT's LEGAL STATUS AS AN INSURED OF INTACT, IN WRITING, A DETERMINATION UPON WHICH THE CLAIMANT WAS ENTITLED TO, AND DID RELY.

OTHER LEGAL IMPEDIMENTS TO THE WHITELAW-TWINING's PARTNER's DEFAMATION OFFENCE INVERSION OF TRADITIONAL, ESTABLISHED DEFAMATION LAW, INCLUDE THE BC PROTECTION OF PUBLIC PARTICIPATION ACT (PPPA), WHICH HAS BEEN DOCUMENTED, infra.

IF THE WHITELAW-TWINING PARTNER's MOTIVATIONS ARE TO EXPONENTIALLY EXPAND THE PARAMETRES OF DEFAMATION LAW, TO ESTABLISH CANADA AS AN INTERNATIONAL DEFAMATION LITIGATION HUB, HE MIGHT WELL RECONSIDER HIS ACTIONS.

The SLAPP Defendant looks forward to the trial of INTACT's and the other Plaintiffs' meritless SLAPP litigation.

However, as documented herein, despite the Defendant's requests and demands that Plaintiffs' Counsel Meera Jain, advance her lawsuit to trial, she continues to refuse, for reasons that anyone familiar with the case would understand.

Attorney Jain is a powerful advocate, rising star at Whitelaw-Twining, trained at a major, no nonsense law firm. Nonetheless, the documented evidence displayed on this website, presents a veritable challenge, even to such a formidable adversary. Confident that the truth and facts are absolutely incontrovertible, the SLAPP Defendant has respectfully submitted the following "Proposed Consent Order" to Attorney Jain, in an effort to present the evidentiary facts to a Judge, without Plaintiffs' further delay and dilatory tactics that have, thus far, enabled them to avoid justice.

Attorney Beckmann's inopportune 07 December 2023 letter, supra, is the source of a widening divergence between INTACT's personnel (Claims Manager Amanda Myers and Claims Representative Breanna Gray) that the SLAPP Defendant was in Insured of INTACT. Mr. Beckmann's defamatory assertion stands in isolation, unsupported by INTACT and inconsistent with the company’s operational understanding of the issues in its SLAPP litigation.

As an egregious '3 way" conflict of interest, INTACT's current Counsel Meera Jain continues to defend Mr. Beckmann's letter, thus requiring INTACT to fund a costly position that is inimical to its interests, in conflict with its own claims personnel, and that originates not from its personnel, but from Attorney Beckmann’s personal insistence upon preserving his defamatory letter. This insistence serves to temporarily maintain Mr. Beckmann’s face, rather than to advance the interests of Attorney Jain's Clients. The resulting misalignment exposes INTACT to unnecessary friction and reputational drag.

In all fairness to Attorney Jain, although her actions suggest her support of the Mr. Beckmann's defamatory letter, it is possible that her loyalties are with her Clients' interests, and not with the position advanced by Mr. Beckmann. This places her in a conflicted posture.

As a gesture of relief from the 3-way conflict, the Offer to the left should be considered with due solemnity, as it may be withdrawn, without notice.

For Attorney Meera Jain's immediate reference, it is requested that she review the case of Bent v. Platnick, 2020 SCC 23 — distinguishes between solicitor–client privilege and defamation privilege.

The "Whitelaw-Twining Effect" - How a Personal, False and Defamatory Letter Became a Corporate Liability

As abundantly documented on this website, Whitelaw-Twining Senior Partner, Director of its Defamation and Insurance Law Departments, positioned himself as an Insurance Law expert, when he provided his Client INTACT with an advisory letter, directly countervailing INTACT's own documented recognition (letters, infra, from Claims Manager Amanda Myers and Claims Representative Breanna Gray), of the SLAPP Defendant as an Insured of INTACT.

For more than two years, the Whitelaw-Twining Partner has refused to retract or clarify the false premise that he advised. His false assertion has become the pivot point around which INTACT’s perception shifted. Instead of relying upon its own evidentiary documentation, INTACT responded to the narrative that the Whitelaw-Twining Partner imposed, allowing his false claim to override INTACT's established protocol, and a posture highly inimical to INTACT CEO Brindamour's "Living Our Values" directive.

The result was a prolonged and unnecessary misalignment: the Partner’s illicit, personal assertion reshaped the trajectory of the dossier, turned INTACT against its own Insured, and drew the client into a labyrinth built upon a premise that was never grounded in the reality of its own records. This is the core of the "Whitelaw–Twining Paradox" — a situation in which a single uncorrected false statement created institutional confusion, reputational exposure, and a cascading series of consequences that INTACT could hardly have intended.

Well‑intentioned lawyers within Whitelaw-Twining have become burdened, navigating a position that they did not create, while the firm’s public image and ethical responsibilities were placed at risk by the assumption and continuation of a stance highly inimical to the interests of its Clients INTACT, Amanda Myers, Christa Rae Cordick, Michele Vincent and Breanna Gray.

NEW YEAR'S ANNOUNCEMENT

As documented on this public interest website, during years 2021 (with INTACT Claims Manager Amanda Myers' fraudulent claims practices),2022, 2023, 2024, 2025 and likely 2026, INTACT Insurance (with the guidance of their Whitelaw-Twining Lawyers Meera Jain and Nigel Beckmann) relentlessly pursue their project to alter the reality of documented facts.

To the right is an exact image of INTACT Policy 5PNGL0819, which clearly states:

“Tenants’ Legal Liability – Any One Premises – $500,000 per Named Insured.”

INTACT's refusal to apply its own written coverage, according to courts in Canada, constitute bad faith, especially where the wording is unambiguous. such as INTACT's policy page to the right.

“Tenants’ Legal Liability – Any One Premises – $500,000 per Named Insured.”

INTACT's denial of its own policy, that literally contains “Tenants’ Legal Liability” is the textbook pattern courts identify as bad‑faith claims handling, according to cases such as:

1. Whiten v. Pilot Insurance Co., 2002 SCC 18

The Supreme Court held that an insurer acts in bad faith when it “recklessly disregards the terms of its own policy” or denies coverage contrary to its own wording. INTACT’s denial fits this description precisely.

2. Fidler v. Sun Life Assurance Co., 2006 SCC 30

The Court confirmed that insurers owe a duty of good faith, breached when they ignore clear contractual obligations. INTACT's refusal to acknowledge the policy’s own “Tenants’ Legal Liability” clause is exactly that.

3. Bhasin v. Hrynew, 2014 SCC 71

The Court established a general duty of honest contractual performance. An insurer cannot pretend a clause does not exist. INTACT’s denial contradicts the unambiguous text that it draughted.

4. 702535 Ontario Inc. v. Non‑Marine Underwriters, 2000 ONCA

Bad faith found where the insurer “took a position inconsistent with the policy wording it authored.” Identical fact of INTACT's denial of coverage that appears on its own declarations page.

23 December 2025

INTACT's "creative" lawyers Meera Jain and Nigel Beckmann, from Whitelaw-Twining have been largely successful in suppression from the Supreme Court's watchful eyes, volumes of incriminating documentary evidence, such as the below email from Claims Representative Breanna Gray, wherein she admitted that the SLAPP Defendant Tenant was an insured of INTACT, but that Claims Manager Amanda Myers' had denied his claim, without any investigation of the facts, but solely upon the basis of the 18th floor Strata Plan (which indicated that the area of the 18th floor ledge was a narrow exterior pigeon roost structure, physically inaccessible from the Tenant's unit, incapable of being "occupied", "used" or "possessed" by the Tenant, as cited as the basis upon which Claims Manager Myers had fraudulently denied his coverage,.

24 December 2025

In her quest to defy reality, by disingenuous insistence that the SLAPP Defendant "occupied", "used" and "possessed" the the physically inaccessible ledge (image below), INTACT's lawyer Meera Jain ignores all evidence, such as the below email exchange from Scott, the unit Owner and Nico, the Strata Property Manager. She also ignores the email from Humane Solutions, the company that charged the SLAPP Defendant $2,541 to abate the remove the pigeon faeces, infra.

Attorney Jain has also pretended that INTACT has no way to verify the below INTACT Policy 5PNGL0819 “Tenants’ Legal Liability – Any One Premises – $500,000 per Named Insured, despite the documented fact of the policy provision in the 13 March 2025 sworn Affidavit of Plaintiff Christa Cordick, as well as other Affidavits and pleadings.

The sources, as documented, infra, confirm the INTACT policy 5PNGL0819 as stating:

16 December 2025 As documented in precise detail on this public interest website, Whitelaw-Twining lawyers Meera Jain and Nigel Beckmann, have artfully lured INTACT Insurance into numerous (lucrative to Whitelaw-Twining) abuses of the BC Supreme Court (SLAPP cases no VLC S-S-244577 and VLC S-S-244484). INTACT remains steadfast in its refusal to resolve the gravamen of its SLAPP litigation, infra, by simply allowing its Customer Experience Team to complete its 2023 investigation of a claims employée's fraudulent claims practices, infra. Under Whitelaw-Twining's "creative" guidance, INTACT continues to subvert its own obligatory, internal resolution procedure, in violation of BC Financial Institutions Act § 80.3(1), as well as numerous other provincial and federal regulatory statutes.

In its relentless campaign of regulatory defiance, INTACT continues to exploit the Court as if the judicial system were a mere clearinghouse for INTACT's refusal to resolve Complaints administratively, without wasteful Court intervention. INTACT's relentless abuses of the Court's processes have already exacerbated the problem of overloaded dockets, significant delays, and increased reliance upon several (lucrative to Whitelaw-Twining) frivolous Applications. INTACT's violations of law represent challenges to access to justice, professional conduct, and systemic inequality. Recent high-profile decisions from across Canada demonstrate that the Courts increasingly apply a strict standard of reasonableness when reviewing the decisions of insurance and other companies. The application of the reasonableness standard means the Courts uniformly defer to the expertise and first hand knowledge of insurance companies, to manage their own affairs, administratively. As a result, particularly regarding individual rights under the Charter of Rights and Freedoms or monitoring proper business practices, the Courts require the fundamental rule of self-governance, and in the case of INTACT Insurance, the cornerstone of CEO Brindamour's tarnished "Living Our Values" unctuous directive!

The INSURANCE ACT, SECTION 12 dispute resolution process, which INTACT has ignored for more than four (4) years, was described by Justice Punnett in Westland Insurance Company Limited v. Pounden, 2020 BCSC 264 at para. 65. aff'd 2021 BCCA 156:

"The dispute resolution provisions under the Act are clearly intended to reduce the duration and expense of litigation and encourage settlement of disputes outside of court as they are a simple, cost-effective method to resolve disputes at an early stage. A party who neglects or refuses to participate in the dispute resolution process under s. 12 frustrates this purpose".

Despite INTACT's lawyers futile attempts at obfuscation, Section 12 clearly:

• Applies to disputes between an insurer and an insured “about a matter that under Statutory Condition 11… or another condition of the contract, must be determined using this dispute resolution process.”

• It’s triggered after proof of loss is delivered, and either party may demand participation.

INTACT's lawyers are incorrect, since:

• The Insured submitted a Complaint and Intact assigned it to CET — that’s conduct consistent with recognition of the Complainant as an insured.

• INTACT did not reject the Complainant's standing at the outset. Instead, they engaged procedurally, which would estop them from later denying applicability.

• If INTACT's denial hinges on coverage interpretation, that’s precisely the kind of dispute Section 12 is designed to resolve.

• INTACT is trying to have it both ways: accept the complaint for internal review, then deny the Complainant's status when it’s time to engage the statutory dispute process.

19 December 2025

BC INSURANCE ACT Section 12 — Dispute Resolution Process

• Applies to disputes under Statutory Condition 11 or other contract conditions requiring this process.

• Either party may demand dispute resolution in writing after proof of loss is delivered.

• Within 7 days, each party must appoint a dispute resolution representative.

• Within 15 days of those appointments, the two reps must appoint an umpire.

• The reps must:

  • (a) try to resolve the dispute by agreement.

  • (b) if they fail, submit the matter to the umpire.

• The written determination of any two (either both reps or one rep and the umpire) is binding.

Since INTACT is obligated by law to comply with BC Insurance Act §  12 and Financial Institutions Act § 80.3(1), its lawyers attempt to avoid compliance with sophistry. In the below email, the INTACT's attorney states "The dispute resolution process in s. 12 of the Insurance Act does not apply to our clients' claim against you.....". However, this case is not about INTACT's claim against its Insured, but rather a dispute of the Insured's claim against INTACT.

20 December 2025

INTACT’s mishandling of the claim, subject of this public information website, does not only raise issues under the Insurance Act and Financial Institutions Act.

INTACT’s conduct also creates risk with its reinsurers and co‑insurers:

• Shared risk obligations: The Schedule of Insurers shows multiple carriers (Zurich, Chubb, Wawanesa, Lloyd’s syndicates, Everest, Starr, HDI, Sovereign) sharing property and specialty lines. INTACT is required to notify and coordinate claims across these participants. The record indicates that INTACT Lawyer Christa Rae Cordick refused to act upon the Insured's request to alert the other Insurers.

• Failure to notify: INTACT's denial of coverage unilaterally obstructs statutory dispute resolution, and it risks breaching contractual duties to co‑insurers who expect timely claim disclosure.

• Reinsurance treaty standards: Reinsurers monitor claims handling for fairness and compliance. Bad faith denials or inconsistent insured status assertions can trigger treaty consequences, including refusal to indemnify, premium increases, or stricter audit terms.

• Direct exposure lines: Intact holds 100% liability under General Liability, Strata Directors & Officers Liability, and Crime coverage. In these areas, mishandling claims hits INTACT directly, without reinsurance protection.

• Reputational risk: Documented refusals to comply with statutory or coordination duties undermine INTACT’s credibility with reinsurers and co‑insurers, creating long‑term exposure beyond the immediate dispute.

20 December 2025

As documented on this public interest website, rising star Whitelaw-Twining Senior Associate Meera Jain, a consummate litigator in her own right (the seventh INTACT lawyer to work on this litigation file), has assumed primary responsibility of representation of SLAPP Plaintiffs, INTACT, Claims Manager Amanda Myers, lawyer Christa Rae Cordick and Ombudsman Michele Vincent.

A special plea to Attorney Jain, in view of the fact that her Client Amanda Myers had fabricated facts that led to her fraudulent denial of the SLAPP Defendant's claim, infra. Because Myers’ fraudulent denial created a false record of a claim being denied, and because I am legally required to be truthful on insurance applications that ask whether I have had a claim denied within the past ten years, I have been placed in an unfair and damaging position that I did nothing to cause.”

Furthermore, SLAPP Plaintiff INTACT lawyer Christa Rae Cordick, filed false Affidavits and pleadings in the BC Provincial Court, which served to propagate Myers' fraud, as fully documented on this website!

08 December 2025

The SLAPP Defendant expresses special thanks to the legal tip, a message in the contact form, written by an anonymous viewer, ostensibly a lawyer. The viewer broached the fact that INTACT has technically never refused to comply with Financial Institutions Act § 80.3(1) or Strata Property Act §  155(b); that the prior focus upon literal non-compliance was somewhat flawed, thus allowing Whitelaw-Twining an easy escape clause. The viewer suggested, instead, that the focus be redirected upon INTACT's deprioritisation of the Complaint (of the Claims Manager's fraudulent claims practices) which was formally accepted by Ombudsman Vincent, who assigned such to the Customer Experience Team more than two and one half (2 1/2) years ago. This issue of the actionable delay in the Customer Experience Team's investigation and issuance of the Final Business Decision (FBD) has been addressed in numerous cases, such as

Blencoe v. British Columbia (Human Rights Commission), 2000 SCC 44 → unreasonable administrative delay can amount to abuse of process.

Law Society of Saskatchewan v. Abrametz, 2022 SCC 29 → backlog and delay undermine fairness and efficiency, even absent outright refusal.

Strickland v. Canada (Attorney General), 2015 SCC 37: While relating to a different statutory context, the Supreme Court of Canada affirmed the principle that a long, unexplained delay in a mandatory administrative process can render the agency's action unreasonable.

Apotex Inc. v. Canada (Attorney General), 2017 FCA 247: Specifically discusses that unreasonable delay is a ground for judicial review, particularly when the delay prejudices the applicant or frustrates the purpose of the statute (like the FIA).

Gould v. Yukon Order of Pioneers, 1996 CanLII 139 (SCC): Establishes that where delay is so long that the statutory purpose is defeated, it can justify intervention.

Consumer/Insurance Acts (provincial) → require insurers to handle complaints “promptly and fairly.”

· Customer Satisfaction page (INTACT’s official website) — Intact acknowledges it has a formal Complaint Handling Protocol and notes that customers may contact them for “information on how we process complaints, how to file a complaint or inquiry on the status of a complaint.” The very fact that INTACT intimates backlog and status inquiries suggests that delays are a recognised issue.

· Trustpilot reviews — INTACT Insurance has a very low TrustScore (1.2/5 from nearly 200 reviews). Many reviewers complain about poor service, difficulty reaching adjusters, and long waits for resolution.

· ComplaintsBoard — Lists multiple unresolved complaints, including policyholders reporting claims and complaints dragging on without timely resolution. The site shows Intact rated poorly (1.3/5) with repeated mentions of delays.

RevDex consumer complaints — Customers describe repeated attempts to contact Intact without response, brokers not returning calls, and matters left unresolved for long periods.

In light of the SLAPP Defendant's new and improved legal strategy, the Application to Compel INTACT to comply with Financial Institutions Act § 80.3(1) has been modified to an Application to Compel INTACT to comply with the statute's and case authorities' requirement that compliance be within a reasonable period of time; and that Rule 1-3 strictly requires that such timely resolution obviate the sanctionable burden upon the Supreme Court!

The anonymous tip also advised a focus upon the incriminating Affidavit of INTACT Claims Manager Amanda Myers, sworn on 18 February 2025, wherein she admitted the status of each of the two (2) property claims, submitted to INTACT, both of which, according to the letter of Ombudsman Michele Vincent, attached to the Affidavit, were assigned to INTACT's Customer Experience Team for investigation.

To the left is Exhibit B, the attachment to the Affidavit of Claims Manager Myers, supra. Note the Exhibit refers to claim no. 1033684645, and as of 04 July 2023, the claim was still open.

Since Whitelaw-Twining Associate Meera Jain has forbidden the SLAPP Defendant from direct communications with INTACT, his only extrajudicial manner to ascertain the current status of claim no. 1033684645 is to withstand her repeated refusals to cooperate to any degree, whatsoever.

To the left is Exhibit C, the attachment to the Affidavit of Claims Manager Myers, supra. Note the Exhibit refers to claim no. 1033684645, and as of 30 April 2024, the claim was still open.

As stated above, since Counsel Meera Jain has forbidden the SLAPP Defendant from direct communications with INTACT, his only extrajudicial manner to ascertain the current status of claim no. 1033684645 is to withstand her repeated refusals to cooperate to any degree, whatsoever.

08 December 2025

As an indication that the INTACT insists upon its refusal to comply with Financial Institutions Act § 80.3(1) and Rule of Court 1-3, in response to the below email, with a copy to Whitelaw-Twining Counsel Meera Jain, the response was the predictable systematic disinformation and outright distortion of law and facts, claiming the falsity that the BC Provincial Court has injunctive relief jurisdiction, and that the Provincial Court (which has no injunctive relief jurisdiction), had ordered that INTACT be immune from compliance with Financial Institutions Act § 80.3(1) and Strata Property Act §  155(b).

Curiously, with all this posturing, Attorney Jain still hasn't filed her oft-threatened Application for Summary Judgement, infra, which is nothing but a prohibited Application to have Justice Elwood's Order of 13 August 2025 (which rejected her Application permanent or even interlocutory deactivation of this, or any other, website), reviewed by a different Justice. Her attempt is clearly a futile attempt to "judge shop"

Up until 08 December 2025, all of the conflicts of this SLAPP litigation have been focused upon only one of the two (2) claims accepted by INTACT's Ombudsman, claim no. 4033526840. However, the Customer Experience Team has not yet informed the Claimant of the status of the other claim, no. 1033684645, although as evidenced below, INTACT's intercompany correspondence indicates that the claim was active and assigned to claims adjustors on 29 March 2022, 04 July 2023 and 30 April 2024, to Breanna Gray, the Claims Representative who co-authored another claims representative's provocative letter of 30 September 2021, infra.

The issue of the active status of the second claim, adds a new, expansive window of inquiry to the "tempête juridique parfaite" that Whitelaw-Twining has tailor-made, according to INTACT's bad faith specifications!

To the left is Exhibit C, the attachment to the Affidavit of Claims Manager Myers, supra. Note that the letter refers to both of the claims that the SLAPP Defendant submitted to the Ombudsman. The first claim (no. 4033526840) is currently with the Customer Experience Team's investigators, awaiting completion after more than two and one half (2 1/2) years, supra.

According to the letter, the second claim (no. 1033684645) "will be dealt with through Intact's operational representatives and the court", an unambiguous statement that Ombudsman Vincent seeks the Supreme Court's involvement, rather than the simple administrative remedy, as required by Financial Institutions Act § 80.3(1) and Rule of Court 1-3, supra.

03 December 2025

The SLAPP Defendant hereby admits defeat in his repeated, naïve appeals to INTACT Senior Legal Counsel Mathieu Grenier and Legal Compliance Officer Frédéric Cotnoir, to disengage Whitelaw‑Twining’s oppressive tactics, which sully INTACT’s reputation, that CEO Brindamour has long endeavoured to preserve.

Until now, the SLAPP Defendant has successfully warded off Whitelaw-Twining "creative solutions" offence specialists' numerous SLAPP Applications, with more in process. Therefore, since INTACT has chosen to allow Whitelaw-Twining to continue to override CEO Brindamour's "Living Our Values" Directive, the SLAPP Defendant's heretofore passive efforts to limit propagation of this website require amplification.

Accordingly, some of the following propagation steps will be undertaken, without further notice:

• Search Engine Indexing:

  • Submit the site to Google Search Console and Bing Webmaster Tools for full indexing.

  • Generate and maintain XML sitemaps to ensure all pages be crawled.

  • Apply structured metadata (Open Graph, Twitter Cards, schema.org) to maximise visibility in search results.

• Social Media Engagement:

  • Establish official accounts on Twitter/X, LinkedIn, Facebook, and YouTube.

  • Deploy scheduled posts linking to site content, using hashtags relevant to insurance, litigation, and corporate accountability.

  • Integrate share buttons on each page to encourage organic propagation.

• Content Syndication:

  • Republish key articles on Medium, Substack, and LinkedIn Articles to reach professional audiences.

  • Create short summaries and infographics for Instagram and TikTok to broaden reach.

• Email and Newsletter Distribution:

  • Build a mailing list via opt‑in forms on the site.

  • Circulate regular updates highlighting new documents, case developments, and commentary.

• Technical Amplification:

  • Implement RSS feeds for automatic syndication.

  • Use analytics (Google Analytics, Matomo) to monitor reach and adjust propagation strategy.

  • Optimize site speed and mobile responsiveness to ensure accessibility across devices.

    The SLAPP Defendant appreciates all of the helpful assistance rendered by viewers of this site.

04 December 2025

If INTACT's Counsel Meera Jain should elect to defy Court Rule 1-3, by pursuit of the threatened Application for Summary Judgement, then the SLAPP Defendant will present the following oral argument at the hearing:

"My Lady/Lord, [TAB 1 of my Book of Authorities] - Rule 1‑3 requires that every proceeding be determined justly, speedily, and inexpensively on its merits. [TAB 2]- the Supreme Court of Canada in Harelkin v. University of Regina confirmed that administrative remedies must be exhausted before judicial intervention.

[TAB 3] is the BC Financial Institutions Act § 80.3(1), which requires administrative resolution of complaints. Per my Affidavit, INTACT has already commissioned its Customer Experience Team to investigate and administratively resolve the very issues that it has decided to foist upon the judicial resources of this Court, an act which constitutes an unambiguous abuse of the Court's processes, as outlined in the Harelkin case. Furthermore, in my Affidavit I have attested to the fact that in November 2025 I had suggested to Plaintiffs' Counsel to stipulate to a Consent Order to suspend all court activity, pending INTACT's administrative resolution. Counsel summarily rejected my suggestion to comply with Rule 1-3.

INTACT's refusal to engage administratively, and its attempt to proceed directly by Application, is contrary to both Rule 1‑3 and the aforementioned binding precedent, and is an egregious waste of the precious resources of this Court!

Accordingly, this Application, brought without first completing the statutory administrative resolution is not only premature, but obstructive. I ask that the Court dismiss this Application and direct INTACT to fulfill its statutory duty before returning here, with special costs to the SLAPP Defendant.

INTACT's lawyers from Whitelaw-Twining's repeated, circumventions of standard protocol include, but not by way of limitation (1) Tortious Abuses of the Supreme Court's processes , (2) Res Judicata, (3) Issue Estoppel, (4) Duplicative proceedings· Rule 1‑3 (efficiency mandate), etc.

05 December 2025

To the left is the SLAPP Defendant's Application for an Order that INTACT comply with BC Financial Institutions Act § 80.3(1), by the simple completion of the Customer Experience Team's suspended investigation of Claim Manager Amanda Myers' fraudulent claims practices, infra. INTACT's administrative procedure will obviate the necessity of further judicial involvement, so the Court, that perpetually struggles with logistical support for ever-expanding workloads, would welcome this Application!

The sole reason why the SLAPP Defendant has elected not to file the Application yet is that he wants to avoid the "piranha effect" with the Whitelaw-Twining lawyers, filling their coffres at the expense of his and his wife's emotional stress!

07 December 2025

As has her predecessor, INTACT Counsel Meera Jain has rejected the SLAPP Defendant's offers to resolve all issues, extrajudicially. Less than two months ago the SLAPP Defendant had notified INTACT lawyer Meera Jain that he intended to file the below Application, in order to compel INTACT's compliance with regulatory BC Financial Institutions Act § 80.3(1). In detrimental reliance upon Attorney Jain's statement that the Application "is not something that the court order on an application....", the SLAPP Defendant forwent the pursuit thereof.

Furthermore, in the below email, Attorney Jain responded to the SLAPP Defendant's request for a few days extension to file his Responsive pleading, by stating "We do not agree to extend the time for you to file your Response to the Amended NOCC". How unprofessional to deny a customary, brief extension of time, to opposing party (self-represented SLAPP Defendant), who has now come to learn all the tricks of this 'word merchant' (méchant) trade!

In a recent response to this website's contact form, he was anonymoustly advised that Attorney Jain's below admonition was incorrect, if not purposely misleading.

On 05 December 2025, the SLAPP Defendant sent an email to INTACT's Counsel Jain, requesting that she recommend to INTACT to voluntarily allow the Customer Experience Team to conclude its investigation into Claims Manager Amanda Myers' fraudulent claims practices.

The response was a terse "No. Your Application is improper".

"Improper" in Whitelaw-Twiningese, means "INTACT cannot comply with the regulations, because if the Customer Experience Team concluded its investigation, Claims Manager Myers' fraudulent claims practice would be exposed!"

On the biennial of Whitelaw-Twining's defamatory letter of 07 December 2023, infra, and in the spirit of ਚਮਕੌਰ ਦੀ ਗੜੀ ਦੀ ਜੰਗ, نوروز , Natalis Domini, प्रायश्चित्त or પ્રાયશ્ચિત્ત , 佛成道日, عاشوراء , as well as other guiding lights of benevolence, perhaps the antagonists among INTACT's and Whitelaw-Twining's noble personnel, will reflect, not only upon statutory law, but upon the universality of benevolence toward each other. We all could do better!

Therefore, perhaps Claims Manager Amanda Myers will set aside time from her busy schedule as Strategic Team Leader to reconsider her fabrication of investigative findings and the sustained refusal over a four‑year period to retract those findings despite her admissions in Notices to Admit, which align with the elements described in section 380 of the Canada Criminal Code, which defines fraud as deceit, falsehood, or other fraudulent means resulting in deprivation or risk of loss. Furthermore, to the extent that written reports or investigative documents were created or maintained to record the fabrications, such conduct parallels the definition in section 366 of the Criminal Code, which describes forgery as the making of a false document, knowing it to be false, with intent that it be acted upon as genuine to another’s prejudice. INTACT Privacy Officer Helen Cameron might reflect upon her letter, infra, to OIPC, falsely claiming that INTACT had not compiled any information about the SLAPP Defendant Claimant, despite more than two years of voluminous letters and emails, including formal Complaint to Ombudsman Vincent, who assigned an investigation of Myers' fraudulent claims practice to the Customer Experience Team, etc.

Perhaps Whitelaw-Twining's Meera Jain and Nigel Beckmann will kindly review LSBC (Law Society of BC) Professional Conduct Rules:

• Rule 3.2‑7: A lawyer must not knowingly assist or encourage any dishonesty, fraud, crime, or illegal conduct.

• Rule 5.1‑2: A lawyer must not act in a manner that is prejudicial to the administration of justice.

• Rule 7.1‑3: A lawyer must not engage in conduct that brings the profession into disrepute.

Counsels' refusal to stipulate, coupled with the systematic cover-up of fraudulent activities committed by INTACT's Claims Manager, parallels the prohibition in LSBC Rule 3.2‑7, which provides that a lawyer must not knowingly assist or encourage any dishonesty, fraud, crime, or illegal conduct. The absence of formal criminal charges against the Claims Manager does not alter the professional duty imposed by the LSBC rules. Moreover, Attorney Jain's characterisation of the SLAPP Defendant's Application as “improper” and Attorney Beckmann's defamatory accusation of the Claimant of false pretences, rather than addressing the admitted fabrication, the Whitelaw-Twining lawyers' conduct is documented as assisting in the perpetuation of ongoing fraud, contrary to the professional obligations set out in the LSBC Code of Professional Conduct, supra.

To the extent that INTACT's Senior Legal Executives, including Cotnoir and Grenier, are responsible for oversight of counsel, their failure to prevent or correct conduct that parallels LSBC Rule 3.2‑7 constitutes systemic perpetuation of fraud. The absence of criminal charges does not diminish the professional duty to ensure compliance with law society rules.

The SLAPP Defendant has, on this website, documented conduct that parallels LSBC Rule 3.2‑7, prohibiting lawyers from assisting in fraud. These parallels are noted for the record, only. The SLAPP Defendant expressly pledges not to alert the Law Society of British Columbia, at this time. This restraint underscores that the purpose of the record is deterrence and judicial efficiency, not disciplinary escalation.

BC courts have applied this principle to insurers under the FIA, holding that Complainants must first pursue remedies through the BCFSA (formerly the Financial Institutions Commission (FICOM).

Maxxam Insurance Services (Burnaby) Ltd. and Dewar v. Insurance Council of British Columbia (FST-FIA-21-A001, July 21, 2022)

Stephen Craig Hill v. Insurance Council of British Columbia (FST-FIA-22-A001, July 7, 2023)

Xiaomei (May) Zou v. Insurance Council of British Columbia (FST-FIA-20-A001, Dec. 24, 2020)

Amarpal Singh Atwal v. Insurance Council of British Columbia (FST-FIA-21-A001, Mar. 3, 2021)

Note: “SLAPP litigation” refers to Strategic Lawsuits Against Public Participation — lawsuits brought not to win on the merits, but to silence critics by burdening them with costly, exhausting litigation. Such suits are disfavoured because they undermine freedom of expression and public participation in matters of public interest.

Anti‑SLAPP legislation exists to protect free expression, ensure disputes of public interest be aired, and prevent courts from being misused as tools of intimidation.

How did each of the above ladies contribute to the "Living Our Values" legacy? As documented herein:

1. INTACT employée fabricated an investigation of the SLAPP Defendant's insurance claim, and other illicit activities.

2. INTACT employée committed perjury in legal proceedings at the Provincial Court, and filed misleading Affidavits in the Supreme Court.

3. Ombudsman Vincent assigned the SLAPP Defendant's Complaint to the Customer Experience Team, but prevented their investigation of Claim Manager Myers' illicit claims activities.

4. Whitelaw-Twining Counsel Meera Jain has engaged in numerous abuses of the Supreme Court, such as ongoing violations of Rule 1-3.

WHITELAW-TWINING CONTINUES TO VIOLATE INTACT CEO BRINDAMOUR'S "LIVING OUR VALUES" DIRECTIVE

The purpose of this website is the ongoing attempt to apprise INTACT Financial CEO Charles Brindamour of Whitelaw-Twining's and rogue INTACT personnel whose acts and omissions represent an ongoing challenge to his standard of honest conduct, as embodied in his "Living Our Values" directive.

Although these rogue personnel have maliciously created difficulties for Claimant RB, the conflict between the rogue elements and CEO Brindamour is far more costly, in terms monetary and reputational.

Origin of INTACT Insurance’s Costly Misadventure

As documented on this website, a letter of 07 December 2023, from Whitelaw‑Twining law firm's Principal Partner marked the beginning of INTACT's costly misadventure. Faced with a formal Complaint from a Claimant, whose property claim had been fraudulently denied by an INTACT “Strategic Team Leader” Claims Manager Amanda Myers, INTACT had contacted Whitelaw-Twining for legal advice as to a solution to its legal and ethical conundrum. INTACT had been presented with a mandatory course of action, as required by the Living Our Values directive: investigate and re‑examine the claim, by compliance with its statutory duty under the Financial Institutions Act § 80.3(1).

However, in a lucrative (to Whitelaw-Twining) plan, the Partner devised a "creative solution", which did not merely contravene Financial Institutions Act § 80.3(1), it also stood in stark opposition to CEO Charles Brindamour’s “Living Our Values” directive, which commits INTACT to integrity, accountability, and customer trust. By weaponising litigation to suppress exposure of misconduct, Whitelaw‑Twining placed INTACT in conflict with its own professed values, eroding credibility and escalating reputational risk. Whitelaw-Twining disobeyed the statute and pursue litigation against the Claimant for posting evidence of Claims Manager Myers’ coverage denial (which is available, infra). This manoeuvre inverted the very purpose of Financial Institutions Act § 80.3(1), which was enacted to require insurers to resolve disputes through administrative remedies rather than burdening the courts. By weaponising litigation to silence exposure of fraudulent misconduct, INTACT imprudently (temporarily) avoided accountability and set in motion a process that has proven both costly and reputationally damaging.

The underlying denial itself was not the product of a genuine investigation. Because Claims Manager Myers fabricated her claims report, she had miscalculated an area of the Claimant's residential unit, treating what was in fact an exterior pigeon roost ledge as though it were part of the insured unit’s interior. (the unit was insured under the Strata Corporation's INTACT policy. Myers' letter and photographs of the pigeon roost ledge are posted, infra) This false representation became the basis for the wrongful denial of coverage. Whether viewed as deliberate or reckless, such fabrication undermines INTACT’s duty of good faith and fair dealing. A denial grounded in false facts is not a mere error; it is a breach of trust that erodes confidence in INTACT's claims process.

The episode stands as a cautionary tale: when insurers choose litigation over statutory compliance, and when fabricated investigations are used to justify denials, they not only undermine legislative intent but also risk escalating disputes into public controversies. The genesis of this misadventure lies not in the claimant’s complaint, but in INTACT’s refusal to investigate and resolve it, as the law requires.

To the left is a statistic from INTACT's lawyers, Whitelaw-Twining's website.

The "bewildered" self-represented, retired tradesman, SLAPP Defendant finds encouragement in the fact that despite the veritable legion of lawyers and other support personnel at their disposal, Meera Jain and Nigel Beckmann choose to rely upon irreconcilably conflicting legal pleadings, as documented on this public interest website, infra.

If INTACT's SLAPP actions had any palpable merit at all, why must its Whitelaw-Twining lawyers Jain and Beckmann always deviate from the truth and the facts?

(1) HOW MANY ANGELS CAN DANCE ON THE HEAD OF A PIN?

(2) HOW MANY INTACT AND WHITELAW-TWINING LAWYERS, PARALEGALS, SECRETARIES, INTACT SENIOR LEGAL COUNSEL, INTACT LEGAL COMPLIANCE OFFICERS, INTACT OMBUDSWOMEN, INTACT CUSTOMER EXPERIENCE TEAM MEMBERS, INTACT "STRATEGIC TEAM LEADER" CLAIMS MANAGERS, INTACT CLAIMS REPRESENTATIVES, INTACT INTERNAL AUDITORS, INTACT AND WHITELAW-TWINING EXTENDED SUPPORT PERSONNEL, VIOLATIONS OF FINANCIAL INSTITUTIONS ACT § 80.3(1), VIOLATIONS OF PIPA § 56(1), VIOLATIONS OF THE PROTECTION OF PUBLIC PARTICIPATION ACT, VIOLATIONS OF INTACT's INTERNAL COMPLAINT RESOLUTION PROTOCOL, VIOLATIONS OF PROVINCIAL AND SUPREME COURT RULES, SUCH AS 1-3, VIOLATIONS OF LSBC GUIDELINES, VIOLATIONS OF THE BC HUMAN RIGHTS CODE, VIOLATIONS OF FUNDAMENTAL STANDARDS OF HUMAN DIGNITY AND FREE SPEECH DOES IT TAKE TO AVOID THE TRUTH AND THE FACTS OF INTACT'S ILLICIT HANDLING OF CLAIM 4033526840?

The environmental costs alone (the lawyers frequent trips to and from the Provincial and Supreme courthouses), and soon to the Human Rights Tribunal, alone, are more than symbolic!

INTACT FINANCIAL's LAWYERS TACTICS IN REAL TIME

As abundantly documented on this public interest website, on 26 May 2023, Ombudswoman Michele Vincent acknowledged receipt of insured's formal Complaint of a Claims Manager's illicit denial of a property claim that he had filed with INTACT. Ms. Vincent confirmed that she had assigned the Complaint to the Customer Experience Team for investigation, upon completion of which the Customer Experience Team would provide the insured with a Final Business Decision (FBD) letter.

In an email of 24 April 2023, Manal, a Customer Experience Team member acknowledged receipt of the Complaint, and confirmed the initiation of a claims investigation.

In a letter of 07 December 2023, a Partner of INTACT's counsel, Whitelaw-Twining defamatorily accused the insured of wrongfully submitting his claim, under the false pretence of being an insured. The Partner admits to having published his defamatory letter with various claims personnel of INTACT.

As of 24 November 2025, the FBD letter has not been issued, and despite INTACT's expenditure of an estimated $72,500 dollars in Whitelaw-Twining's fees, INTACT and three (3) of its personnel are embroiled in costly SLAPP litigation, which presents an ethical dilemma, apparently not envisioned by INTACT's executives, in their "living our values" directive, which ironically has become a yet salvageable symbol of a destructive policy, under the pretence of a noble objective.

Let the viewers of this website decide!

As abundantly documented on this informational, public interest website, the Whitelaw-Twining Partner, whose defamatory letter of 07 December 2023, infra, was the proximate cause of INTACT's regulatory and ethical perfect storm, has appointed Associate Lawyer Meera Jain, who continues to perpetrate the lucrative masquerade that the Defendant had submitted his insurance claim with INTACT under the false pretence of being an insured of the company.

The statutory, case and witness authority that the Defendant was an insured of INTACT include:

Strata Property Act Section 155(b) (2) the landmark case of Strata Plan VR 2213 v. Schappert, 2023 B.C.J. No. 2272, 2023 BCSC 2080 (decided by the Honourable Justice Coval of the BC Supreme Court), correspondence of INTACT Claims Manager Amanda Myers, INTACT lawyer Christa Rae Cordick, Adam Trott investigator of the BC Ombudsman Office, Bruno de Sando investigator of the GIO, Patrick Williams of renowned law firm Clark Wilson, CHOA (Condominium Homeowners Association of BC), the BCFSA, personnel of various Scheduled Insurers of the subject INTACT property liability policy, Insurance Broker Gordon Li, Property Manager Nico Barbu, Sedgwick Insurance Sr Adjuster Daphne Chan, Heather Bidnall, Compliance Officer of the Insurance Council of BC, Dr. Leo Perra, LMS 2845 Strata President, Alexandre Korecki Property Management Owner, Nico Barbu Property Manager, Scott Chen Unit 1702 Owner, Humane Solutions Remediation Specialist, Mike Blackall, Property Manager, Ray Nouri LMS2845 Building Superintendent, and others.

IF INTACT'S AND THE OTHER SLAPP PLAINTIFFS' ACTION HAD ANY LEGITIMACY, WHY DOES THEIR LAWYER, MEERA JAIN, REBUFF ALL OF THE SLAPP DEFENDANT'S EFFORTS TO BRING THE CASE TO TRIAL?

IN YET ANOTHER EFFORT TO BRING THE LAWSUIT TO TRIAL, THE SLAPP DEFENDANT HAS PREPARED AND OFFERED TO ATTORNEY JAIN THE BELOW CONSENT ORDER, TO COMMENCE THE PROCEDURAL STEPS TO ADVANCE THE PLAINTIFFS' MERITLESS SLAPP ACTION TO TRIAL.

29 November 2025

As documented on this website, INTACT's Whitelaw-Twining lawyers' assorted abuses of human rights, as well as of the judicial system are relentlessly lucrative to the firm.

THE "BEWILDERED", SLAPP DEFENDANT AND HIS WIFE HAVE GROWN WEARY OF THE FIRM'S RELENTLESS, INTIMIDATIVE, UNSAVOURY PRACTICES. THUS, SINCE THE DEFENDANT'S SUPPLICATIONS FOR RELIEF HAVE BEEN MISINTERPRETED AS A SIGN OF CAPITULATION, THE SLAPP DEFENDANT HAS ABANDONED HIS PASSIVE APPROACH, BY PREPARATION OF THE ABOVE RESPONSE TO INTACT's APPLICATION FOR AN ABUSIVE OF COURT RE-EXAMINATION OF JUSTICE ELWOOD'S DENIAL OF THEIR APPLICATION OF 13 OCTOBER 2025, infra.

The SLAPP Defendant will respond to the any and all Applications, however numerous, including those for the permanent or interlocutory deactivation of this website. Such relief is unavailable, as it was not sought in INTACT's Amended Notice of Civil Claim.

INTACT should be aware of BC Supreme Court Civil Rule 8-3, which provides that INTACT and the other SLAPP Plaintiffs are limited to relief that was claimed in the Amended Notice of Civil Claim.

28 November 2025

Even more predictable than the rising of the sun, INTACT's and the other Plaintiffs' Whitelaw-Twining lawyer's response to the Defendant's proposal for a Consent Order (below) was a spontaneous refusal even to consider the SLAPP Defendant's effort to bring INTACT's and the other Plaintiffs' SLAPP action to trial.

In an absurd, yet hardly surprising cut and paste announcement, the Plaintiffs' lawyer resurrected and re-threatened an intention to file a Rule 9-6 or 9-7 Application (for a rehearing, by a different Justice) of an Order issued against Attorney Jain on 13 August 2025, by the Honourable Justice Elwood of the BC Supreme Court.

As attorney Jain would know, if she had been unhappy about Justice Elwood's denial of her Application for the permanent deactivation of this website, then her recourse had been an appeal, not a rehearing of the same subject matter, before a different Supreme Court Justice! This blatant attempt to subvert the judicial system, by way of "justice shopping", instead of requiring SLAPP Plaintiff, Ombudsman Michele Vincent to allow the Customer Experience Team to complete its investigation, constitutes offences that exceed the purview of Rule 1-3!

01 December 2025

The "Self-Righteous Four" (INTACT, Amanda Myers, Christa Rae Cordick and Michele Vincent) are already in violation of a myriad judicial, regulatory, legal, moral, ethical and fundamental human rights standards.

Their Counsel Meera Jain's recent announcement of her intention to file yet another "Application for Summary Trial or Summary Judgement " presents yet another layer of hardship for the retired tradesman SLAPP Defendant and his wife.

The below draughted Responsive Pleading is somewhat incomplete, as it lacks the exposure of yet another solemn issue - that Attorney Jain’s announced Application is, in substance, an attempt to re‑litigate relief that has already been denied by Justice Elwood, in his Order of 13 August 2025. Ms. Jain's apparent dissatisfaction with that ruling should have been pursued by way of appeal to the Court of Appeal under § 13 of the Court of Appeal Act.

The announced renewed Application, before a different Supreme Court Justice, constitutes a back‑door appeal, contrary to Rule 1‑3 of the Supreme Court Civil Rules and the doctrine of abuse of process. The announced Application therefore undermines the finality of judicial determinations and must be dismissed with costs.

The SLAPP Defendant thanks the SLAPP Plaintiffs and their Counsel for their collective patience, as he augments his below responsive pleading.

20 November 2025

To add to the list of INTACT's protection of the public, regulatory evasions is that of BC Personal Information Protection Act (PIPA), § 56(1).

This violation was memorialised in the below letter of 19 January 2024, wherein Privacy Officer Helen Cameron falsely represented to OIPC Investigator Ryan Graves that INTACT possessed no personal information of OIPC Requestor RB. Cameron's denial is patently false, in view of the fact that from September 2021 until 2024, INTACT had compiled voluminous documentation of the Requestor's personal information, such as the 30 September 2021 letter from Claims Manager Amanda Myers, infra.

Privacy Officer Cameron's false statements to the OIPC investigator, constitutes a prima facie violation of the BC Personal Information Protection Act (PIPA), § 56(1):

Subject to subsection (2), an organisation or person commits an offence if the organisation or person

(c) obstructs the commissioner or an authorized delegate of the commissioner in the performance of his or her duties or powers under this Act,

(d) knowingly makes a false statement to the commissioner, or knowingly misleads or attempts to mislead the commissioner, in the course of the commissioner's performance of his or her duties or powers under this Act.

BC's Information and Privacy Commissioner has recently accepted a request to reopen the OIPC investigation of 2024, by way of the authority of §§ 50 and 52 of the Personal Information Protection Act (PIPA), which authorises reopening or reassessment of a Complaint, when an organisation’s denial is contradicted by the documented facts. Statutory monetary sanctions against INTACT have been sought, as a result of its violation of Section 56(1), supra.

Privacy Officer Cameron's oppressive insistence that the Requestor has no right to access and correction of the subject personal information, was demonstrably intentional, since the PIPA Act does not require special authorisation, in order to access and correct false information and documentation in INTACT's actual or constructive possession!

INTACT's Counsel, Meera Jain ignores all requests that INTACT allow lawful access to the records.

21 November 2025

The "bewildered" self-represented SLAPP Defendant has gained invaluable experience in countering Whitelaw-Twining Prosecutorial Team's incessant pettifogging and other deviations from good faith legal manoeuvres.

To the left is a sample of a recent Form 26 Rule 7-7(1) Notice to Admit statements and documents, propounded upon INTACT.

The documents to which reference is made are available for examination on this strictly informational, public interest website.

An illegitimate practice, which has been the source of repeated disruption of the Supreme Court's processes, with constant violation of Rule 1-3, INTACT's lawyer blatantly contradicts his own Client, Claims Manager Amanda Myers, who in her below letter had announced the completion of INTACT's claim investigation. The lawyer's awkward attempts to deflect INTACT's bad faith exposure, is an exercise in lucrative futility - the unavailing assertion that the investigation had been completed in 2021, but four (4) years later, in the 2025 pleading, the investigation had 'disappeared'!

Below is a copy of a section of INTACT's 21 November 2025 pleading, in response to the Counterclaim against INTACT and the other SLAPP Plaintiffs.

In addition to the contradiction of INTACT's lawyer's false assertion that there had been no claims investigation, the above letter also establishes the SLAPP Defendant's status as an insured of INTACT. However, in the below letter, the same INTACT lawyer, a self-styled expert in defamation law, falsely accuses the SLAPP Defendant of lying about being an insured of INTACT (i.e. of submission of his claim under the false pretence of being an insured), while the lawyer admits to publication of the defamatory letter to his "clients". Thus represents yet another, clear abuse of the judicial process, in an attempt to gain a tactical advantage. Such is a misrepresentation of a fact, essential to the claims process and policy compliance, which warrants the Court’s sanction.

ONE AWARD-WINNING MASTER CARPET INSTALLER, EXPERT IN 內家拳 and

POSSESSED OF THE TRUTH, THE FACTS AND THE LAW

VS

A PLATOON OF INTACT's SEVEN (7) COMBAT-READY RETAIL WORD MERCHANTS (LAWYERS).

The INSURANCE ACT, SECTION 12 dispute resolution process, which INTACT has ignored for more than four (4) years, was described by Justice Punnett in Westland Insurance Company Limited v. Pounden, 2020 BCSC 264 at para. 65. aff'd 2021 BCCA 156:

"The dispute resolution provisions under the Act are clearly intended to reduce the duration and expense of litigation and encourage settlement of disputes outside of court as they are a simple, cost-effective method to resolve disputes at an early stage. A party who neglects or refuses to participate in the dispute resolution process under s. 12 frustrates this purpose".

INTACT's Ombudsman Michele Vincent has wrongfully violated the purpose of the INTACT's Complaint Resolution function, not merely by refusal to complete the Defendant's formal Complaint, which she assigned to the Customer Experience Team, she also has filed three (3) SLAPPs against an insured of INTACT, who had created this website, for the purpose of alerting upper management of the acts and omissions of her SLAPP co-Plaintiffs Amanda Myers and Christa Rae Cordick, which thwarted the statutory requiremen to reduce, not augment, the duration and expense of litigation and encourage settlement of disputes outside of Court; the simple, cost-effective method to resolve disputes at an early stage, imposed by Rule 1-3.

How many statutes and case law will INTACT violate, before it changes course, and begins to recognise Canada's solemn regulatory infrastructure?

VS

The Corporate Contradiction: INTACT Fighting Itself

The core of INTACT's not so cleverly disguised ploy is the direct conflict between INTACT's unctuous, published promises of compliance vs the conflicting measures of Ombudsman Michele Vincent, who is the company's highest internal officer for regulatory dispute resolution.

This conflict perfectly illustrates the metaphor of the "dog chasing its own tail," where the company expends vast resources to maintain the illusion of compliance, while simultaneously destroying its own compliance mechanism.

The Costly Illusion of Compliance

Intact spends millions to create and publish documents like "Section 30 - Corporate governance and compliance program," which guarantees to all stakeholders (investors, regulators, and the public) that:

"sound corporate governance and compliance monitoring related to legal and regulatory requirements are paramount... [and that risk] arises from non-compliance with the laws, regulations or guidelines applicable to us..."

This establishes a high, public standard. It is INTACT's contractual promise to its market that it will handle legal and regulatory matters internally and correctly, using the Dispute Resolution Process (DRP) as the final, mandatory safeguard.

The Ombudsman/Complaint Officer Michele Vincent's Violation (The Self-Sabotage)

The Ombudsman/Complaint Officer Vincent, is the highest-ranking human agent responsible for enforcement of this corporate commitment for consumer complaints. She sits at the final, required stage of the DRP.

Her refusal to allow the DRP to conclude the investigation that she assigned on 26 May 2023, is not an error—it is the deliberate destruction of the compliance program at its most critical point.

Instead of complying with regulatory requirements (like the BC Financial Institutions Act § 80.3(1) and the Insurance Act § 12) and their own published DRP, INTACT’s "legal" team filed three (3) SLAPP actions against a Named Insured whistleblower. The SLAPPs are not about defamation; but rather as a tool to prevent regulatory compliance.

Note: Although a tangential issue, the administrator of this website has long requested, then demanded of INTACT that it immediately replace the sexist job title "ombudsman", with "ombudswoman", since Michele Vincent is not a man. Risible terms such as "ombuds", or even "ombudsperson" represent no more than a meaningless, token substitute of full recognition of the vast contributions of women (and girls) to INTACT and beyond!

WHY DO INTACT's ACTIVIST PERSONNEL REMAIN SILENT, IN THE FACE OF THIS ABHORRENT PRACTICE?

This informational website represents a compendium of INTACT's egregious bad faith violations of various regulatory and other statutes.

Yet another illicit act, committed by INTACT Privacy Officer Helen Cameron, regarding her response to INTACT's Named Insured's Freedom of Information Request to access and correct defamatory, false information compiled by INTACT.

In Privacy Officer Cameron's below letter of 19 January 2024, she falsely claimed that INTACT had not compiled any information or documentation, in response to the request to the Named Insured's PIPA request to access and correct such information as Claims Manager Amanda Myers' letter of 30 September 2021, infra, wherein Myers illicitly denied the Named Insured's insurance claim, by fabrication of her investigation of claims 4033526840 and 1033684645.

Privacy Officer Cameron absurdly contradicts herself, by stating (1) the lie that INTACT had not compiled any information about the Named Insured, and (2) that such information was in INTACT's possession, but that the Named Insured had no right to access and correct the "nonexistent information", ostensibly because he was a Named Insured, not a policyholder.

In the last paragraph of Cameron's duplicitous letter she conjures yet another obstacle to the Named Insured's good faith efforts to access and correct his information, by stating that he was not a "customer" of INTACT, thus compelling him to seek access to his personal information, by way of a Complaint to the BC Privacy Commissioner (OIPC). In reliance upon Cameron's misrepresentation that INTACT had no personal information about the Named Insured, the OIPC concluded that there was nothing for the Complainant to correct, and closed its case dossier!

Privacy Officer Cameron concluded her below letter by announcing closure of the Named Insured's request to correct his personal information. As documented on this website, the rogue INTACT personnel, Claims Manager Amanda Myers, Counsel Christa Rae Cordick, Ombudsman Vincent and Privacy Officer Helen Cameron have committed tortious acts and omissions, which are easily exposed by a simple examination of the facts!

As with INTACT's refusal to comply with BC Financial Institutions Act § 80.3(1), the compliance with the BC Freedom of Information Act is not optional.

INTACT's RELENTLESS NON-COMPLIANCE WITH CONSUMER PROTECTION LAWS NECESSITATES EXISTING AND FUTURE COMPLAINTS WITH REGULATORY AGENCIES.

INTACT must comply with, inter alia, the Insurance Companies Act, which is central to market conduct regulatory compliance in Canada, supervised by the OSFI and FCAC. All of these regulations require insurers (including INTACT) to establish and follow a formal Consumer Complaint Process to resolve disputes prior to external action. In practice, compliance means aligning operations, governance, and consumer practices with the ICA’s framework, in order to ensure market conduct protection of the public consumers of insurance products.

INTACT has recently filed an Amended SLAPP lawsuit against its statutory Named Insured, alleging that the posting of precise images from INTACT's official website and Sections of the BC Financial Institutions Act § 80.3(1) is an act of defamation.

INTACT's alleged "Whistleblower Hotline", does not accept allegations of fraudulent acts and omissions on the part of certain rogue elements, in the ranks of its personnel.

The malicious SLAPP action was the "response" of INTACT's "Legal and Compliance Department" to the request that INTACT comply with Financial Institutions Act § 80.3(1)

10 November 2025

In an email of this date, INTACT's Whitelaw-Twining lawyers formally rejected the Defendant's Rule 1-3 proposal, to conserve the precious resources of the taxpayer-funded judicial system, by INTACT's shirking of the legal responsibility to resolve matters administratively, by issuance of a Final Business Decision (FBD), as required by the Financial Institutions Act § 80.3(1) .

An FBD must contain the reasons and rationale for INTACT's final decision. Thus, an FBD cannot be issued without INTACT's completion of an internal investigation and legal assessment.

INTACT's refusal to issue an FBD is evidence that it has not conducted an investigation of the facts.

As the below email from the BC Attorney General indicates, the issue of INTACT's SLAPP litigation was of general interest.

However, the separate issue of INTACT's egregious abuse of the taxpayer-funded judicial process of the Supreme Court clearly necessitates the legislative mandate of the AG's intervention, since INTACT's refusal to issue a simple Final Business Decision (FBD) is the quintessence of what the AG's office stated - ".....the matter at hand has significant public policy implications or questions of broader legal importance that extend beyond the interests of the immediate parties involved."

The Attorney General has been notified of this current matter, as has the Finance Minister of the BCFSA.

PUBLIC DISCLOSURE OF DOCUMENTED FACT:

THE DETAILED DOCUMENTATION DISPLAYED ON THIS WEBSITE IS IN THE PROCESS OF COMPILATION FOR TRIAL, AS IT EVIDENCES THE MALICE, TORTIOUS CONDUCT AND BAD FAITH, ON THE PART OF THE SLAPP PLAINTIFFS INTACT, AMANDA MYERS, CHRISTA RAE CORDICK and MICHELE VINCENT, as well as THEIR WHITELAW-TWINING COUNSEL, NIGEL BECKMANN AND MEERA JAIN.

SUFFICE IT TO NOTE THAT HAD INTACT ORIGINALLY COMPLIED WITH FINANCIAL INSTITUTIONS ACT § 80.3(1), INSTEAD OF BURDENING THE PROVINCIAL AND SUPREME COURTS, WITH A TRAIL OF RELENTLESS, MERITLESS LITIGATION, THEN ALL OF THE COSTLY (albeit lucrative to Whitelaw-Twining) LITIGATION WOULD HAVE BEEN AVOIDED, WITH A SAVINGS OF CONSIDERABLE TAXPAYER-FUNDED COSTS TO THE JUDICIAL SYSTEM!

The Financial Institutions Act provides a comprehensive framework for regulation and enforcement by the BCFSA to ensure compliance within the financial sector in British Columbia. Given the documented fact that INTACT has willfully refused to comply with the Act for more than four (4) years, the company could face significant penalties, which may include administrative penalties and court-imposed fines, and given the egregious nature of the subject case, the suspension or revocation of its business authorisation.

Administrative Penalties: The Superintendent of Financial Institutions (or the BC Financial Services Authority, BCFSA) can impose administrative penalties for contraventions of prescribed provisions of the Act or regulations. The amount varies depending on the specific contravention but can be up to $50,000 for a corporation per contravention, or other amounts as specified in the Administrative Penalties Regulation.

Court-Imposed Fines for Offences: If the non-compliance is treated as an offence under the general penalty provisions of the Act, a corporation is liable:

o On a first conviction, to a fine of up to $500,000.

o On each subsequent conviction, to a fine of up to $1,000,000.

Other Actions: The Superintendent has broad powers to enforce compliance, which may include:

o Issuing orders to the financial institution to cease certain activities or take specific actions.

o Suspending or revoking the insurer's business authorization.

o In extreme cases, applying to the Supreme Court for an order to liquidate and dissolve the company.

Furthermore, officers or directors of the corporation who authorized, permitted, or acquiesced in the contravention may also be subject to penalties, even if the corporation is held liable.

Additionally, the BC Financial Institutions Act § 80.3(1) requires that parties resolve disputes administratively and that INTACT issue a Final Business Decision (FBD). Insurers must participate in good faith. If they obstruct or delay the issuance of a FBD, then they risk judicial criticism, cost penalties, or adverse rulings.

In the matter, subject of this website, since INTACT's SLAPP actions are in general disfavour with the legislature (PPPA) and the courts, in view of the fact that (1) INTACT has refused to comply with the regulatory statutes. Then the Supreme Court can either dismiss INTACT's litigation, or

Stay INTACT's lawsuit until it has complied with Financial Institutions Act § 80.3(1)

The SLAPP Defendant has never accused INTACT counsel Christa Rae Cordick of incompetence.

In fact, the SLAPP Defendant readily notes Attorney Cordick's expertise in insurance matters. Therefore, with reference to the portion of her Affidavit of 19 May 2023, she not only admitted to her knowledge and awareness of the Insurance Act and Strata Property Act, she even pleaded such in a document which she filed with the Court.

Thus, how comes it that with her obvious expertise of the Insurance Act, that she should fail to comply with Insurance Act § 12, regarding the mandatory dispute resolution process (DRP)?

The SLAPP Defendant has accused INTACT Ombudsman/Complaints Officer Michele Vincent of dereliction of her solemn mandate, but never of incompetence.

In fact, in her conflicted-of-interest dual capacity as Ombudsman/Complaints Officer, SLAPP Plaintiff Vincent acknowledged receipt of the SLAPP Defendant Complainant's several letters, requesting that she comply with Financial Institutions Act § 80.3(1)

The key to the Ombudsman's duplicity is her statement that "it would not be appropriate for the Ombudsman's Office to become involved in this matter....." The truth of the matter is quite the opposite; i.e. it would not be appropriate for the Ombudsman's Office to refuse to become involved in this matter...

With undue respect, Ombudsman Vincent, compliance with Financial Institutions Act § 80.3(1) is not optional, and her attempt to ultimately avoid responsibility, by filing three SLAPP actions against the whistleblower, will be addressed at trial!

10 November 2025

On INTACT's lawyers' website is the following advertisement, that the firm has an entire team devoted to regulatory compliance: https://wt.ca/expertise/regulatory-insurance-policy-group/

"We have the broad experience and deep insight to assist you with complex insurance matters including contract and policy drafting and regulatory compliance."

Since INTACT continues to ignore the Financial Institutions Act § 80.3(1) requirement to issue a Final Business Decision (FBD), its management might arrange for a complimentary consultation with one of Whitelaw-Twining's regulatory experts. Or it might save a few tens of thousands of dollars in needless offence costs, by a review and implementation of the BCFSA's Claim Dispute Guide, to the left.

INTACT Insurance's heretofore successful evasion of its regulatory duty to comply with fundamental federal and provincial, protection of the public legislation, continues to illicitly weigh upon the precious resources of the BC Supreme Court. The following is a letter sent to BC Minister of Finance, Brenda Bailey and Attorney General Niki Sharma.

Per her own admission, Ombudsman Vincent has documented the numerous emails that the SLAPP Defendant had sent her, in desperation over his damages, as documented on this website.

In egregious bad faith, she alleges the absurdity that the history of the SLAPP Defendant's claim with INTACT (to which this entire website is devoted) is available from a different insurer.

Vincent also evidences INTACT's relentless evasion of compliance with the Financial Institutions Act § 80.3(1) and the Insurance Act § 12, both statutes of which reflect the legislative intent that insurance disputes be resolved administratively, not judicially, a prohibition against INTACT's ongoing, oppressive SLAPP litigation!

m) report to regulatory or industry entities consistent with prudent and legally required insurance industry practices, including claims history.

[emphasis added]

INTACT Insurance's tens of thousands of dollars investment into non-compliance of federal and provincial regulations has been established. Since its SLAPP actions continue, unabated, the below Form 26 Notice to Admit, will concretise the germane issues for trial of the meritless Amended SLAPP action, as well as the meritorious Amended Counterclaim.

INTACT: The Compliance Failure That Forged a Series of Abuses of Process

The next feature of this public interest website will be a chronology of abundantly documented events, commencing with Whitelaw-Twining Partner's violation of STRATA PROPERTY ACT § 155(b), by instead of assuring INTACT's non-compliance with federal and provincial regulations, such as FINANCIAL INSTITUTIONS ACT § 80.3(1) and INSURANCE ACT § 12, he instead misguided INTACT, into a self-destructive entanglement of acts and omissions, which have culminated in a plethora of costly regulatory, legal, judicial, ethical and moral complications.

As an attempted subterfuge, the Partner and his Associate Lawyer, Meera Jain, have conflated the legal status of "third party insured" with "first party insured". As the below centre Exhibit 2 evidences, the SLAPP Defendant is a first party, not third party insured, because that section of the INTACT policy provides for payment of monies to a potential third party insured claimant, for damages to the insured property that the first party insured might cause. The Director of Whitelaw-Twining's Insurance (and Defamation) Departments and his Associate would know enough about insurance law, to avoid the needless expenditure of tens of thousands of dollars of INTACT Financial's shareholder funds, for such a fundamental error! Where is Maude Choquette!

EXHIBIT 1:

The below letter is from the Whitelaw-Twining Partner, who chose to ignore the following EXHIBITS 2, 3 and 4, which clearly established the Claimant's legal status as a Named Insured of INTACT.

EXHIBIT 4:

The below letter, is the letter from INTACT Strategic Leader Claims Manager Amanda Myers' letter of 30 September 2021, to the SLAPP Defendant, wherein Myers confirms his legal status as a Named Insured, under the subject INTACT policy. However, in said letter, Myers made two (2) material, documented false allegations: (1) that an investigation of the subject claim had ever been conducted, and

(2) that the Claimant had "possessed", "occupied" or "used" a portion of the residential high rise, that is factually an physically inaccessible, cemented, ornamental narrow ledge, upon which feral pigeons and their faeces had accumulated, thus constituting a health hazard. The pigeon faecal matter removal had been covered by Chubb Insurance of Canada, a co-insurer, under the comprehensive BFL master policy.

However, although the Master policy contractually obligated Scheduled Insurer INTACT to apprise the other Scheduled Insurers of relevant claims, INTACT Counsel Christa Rae Cordick, blocked all of the Named Insured's attempts to directly make for abatement coverage. Cordick's, breach of covenant with the other Scheduled Insurers and others of her obstructionist tactics are documented, infra.

The common property ledge, as depicted in the below image was ultimately abated, by a Humane Solutions, specialty crew, as depicted, at a cost to the SLAPP Defendant.

STATEMENT OF PURPOSE: As the name of this fully documented, fact-based website implies, this is a compendium of examples of the various ways by which insurance companies run afoul of regulators and the courts, by refusal to comply with such statutes as INSURANCE ACT § 12, and FINANCIAL INSTITUTIONS ACT § 80.3(1), which protect the interests of the public, by requirement that

80.3 (1) An insurer

(a) establish procedures for dealing with complaints made to the insurer by persons who have requested or received in British Columbia products or services from the insurer,

(b) designate an officer or employee who is responsible for implementing those procedures, and

(c) designate one or more officers or employees who are responsible for receiving and dealing with those complaints.

As Justice Punnett in Westland Insurance Company Limited v. Pounden, 2021 BCCA 156 stated:

"The dispute resolution provisions under this legislation are intended to reduce the duration and expense of litigation and encourage settlement of disputes outside of court as they are a simple, cost-effective method to resolve disputes at an early stage. A party who neglects or refuses to participate in the dispute resolution process under s. 12 frustrates this purpose".

The first case of statutory non-compliance, is the case of INTACT Insurance, whose Ombudsman Michele Vincent, continues to violate the purpose of the INTACT's Complaint Resolution function, by refusal to ensure that INTACT's Customer Experience Team investigators (to whom she had assigned a formal Complaint) complete an investigation that was assigned in 2023.

This case is extraordinary, in that other upper level of INTACT's personnel, Strategic Leader Albert Claims Manager Amanda Myers and counsel Christa Rae Cordick each contributed to INTACT's ongoing refusal to comply with laws that reflect the Legislature's intent to protect the insurance consuming public.

The second case of insurer failure to protect the public is that of [K.M.] v. Aviva Insurance Canada, 2023 ONLAT 22-000554/AABS.

INTACT IS A MERCHANT - IT SELLS INSURANCE PRODUCTS. ITS LAWYERS ARE RETAIL MERCHANTS - THEY SELL WORDS FOR A PROFIT. OTHER MEMBERS OF SOCIETY, AS WELL, ARE CAPABLE OF USING WORDS. IN INTACT's MALICIOUS SLAPP ACTIONS, THE SUBJECT OF THIS PUBLIC INTEREST WEBSITE, THE SLAPP SELF-REPRESENTED DEFENDANT USES WORDS, IN ORDER TO DEFEND THE FACTS AND THE TRUTH, AND INCREASINGLY SO, THE VERY PROCEDURAL RULES OF THE SUPREME COURT.

WHITELAW-TWINING LAWYER MEERA JAIN IS THE COUNSEL FOR INTACT INSURANCE AND THE THREE (3) HUMAN SLAPP PLAINTIFFS. AS CONFIRMED BY THE BELOW EMAIL, ATTORNEY JAIN HAS NOTIFIED THE SLAPP DEFENDANT OF HER INTENTION FILE A RULE 9-6 or 9-7 APPLICATION (FOR A REHEARING, BY A DIFFERENT JUSTICE) OF AN ORDER ISSUED TO HER ON 13 AUGUST 2025, BY THE HONOURABLE JUSTICE ELWOOD OF THE BC SUPREME COURT.

AS ATTORNEY JAIN WOULD KNOW, IF SHE IS UNHAPPY ABOUT JUSTICE ELWOOD's DENIAL OF HER APPLICATION FOR PERMANENT DEACTIVATION OF ANY WEBSITE, THEN HER RECOURSE IS AN APPEAL, NOT REHEARING OF THE SAME SUBJECT MATTER, BEFORE A DIFFERENT SUPREME COURT JUSTICE!

08 November 2025

As the three (3) self-righteous SLAPP Plaintiffs self-righteously savour their 'signature' Nabob Organic Gourmet blend coffee, their attorney Meera Jain, from Whitelaw-Twining, persists in her highly lucrative campaign to frustrate the SLAPP Defendant's efforts to alert provincial and federal regulators and the Supreme Court of the Plaintiffs' relentless violations of the subject statutes and Rule of Court 1-3.

05 November 2025

INTACT's insistence upon abdication of its solemn, statutory obligations to the public has resulted in Ombudsman Vincent's, Claims Manager Myers' and Counsel Cordick's filing and prosecution of litigation, in contravention of the Protection of Public Participation Act, a law enacted in 2019 that protects individuals from strategic lawsuits against public participation. This statute provides a way for wronged whistleblowers to achieve dismissal of lawsuits, like those for defamation, that are intended to silence people from speaking out on matters of public interest.

During INTACT's costly SLAPP prosecution, its counsel, Meera Jain (of a boutique style firm known as Whitelaw-Twining), continue to defy the herein documented Order of the Honourable Justice Elwood's Order, which denied INTACT's Application for permanent, or even interlocutory deactivation of this website.

In defence of INTACT's spurious allegations of defamation, the whistleblower has taken the initiative to file and serve the Amended Counterclaim (to the left), in order to unplug Whitelaw-Twining's cash cow and relieve the Supreme Court of the relentless abuses of judicial processes, infra, of which the INTACT and its personnel refuse to cease and desist!

07 November 2025

INTACT has long taken advantage of the SLAPP Defendant's passive approach. Perhaps the Regulatory Complaint (to the left) will awaken INTACT to the realities of regulatory oversight, that its lawyers have encourage it to disregard.

ONE AWARD-WINNING MASTER CARPET INSTALLER, EXPERT IN 內家拳 and

POSSESSED OF THE TRUTH, THE FACTS AND THE LAW

VS

A PLATOON OF INTACT's SEVEN (7) COMBAT-READY RETAIL WORD MERCHANTS (LAWYERS).

The INSURANCE ACT, SECTION 12 dispute resolution process, which INTACT has ignored for more than four (4) years, was described by Justice Punnett in Westland Insurance Company Limited v. Pounden, 2020 BCSC 264 at para. 65. aff'd 2021 BCCA 156:

"The dispute resolution provisions under the Act are clearly intended to reduce the duration and expense of litigation and encourage settlement of disputes outside of court as they are a simple, cost-effective method to resolve disputes at an early stage. A party who neglects or refuses to participate in the dispute resolution process under s. 12 frustrates this purpose".

INTACT's Ombudsman Michele Vincent has wrongfully violated the purpose of the INTACT's Complaint Resolution function, not merely by refusal to complete the Defendant's formal Complaint, which she assigned to the Customer Experience Team, she also has filed three (3) SLAPPs against an insured of INTACT, who had created this website, for the purpose of alerting upper management of the acts and omissions of her SLAPP co-Plaintiffs Amanda Myers and Christa Rae Cordick, which thwarted the statutory requiremen to reduce, not augment, the duration and expense of litigation and encourage settlement of disputes outside of Court; the simple, cost-effective method to resolve disputes at an early stage, imposed by Rule 1-3.

How many statutes and case law will INTACT violate, before it changes course, and begins to recognise Canada's solemn regulatory infrastructure?

VS

INTACT's OMBUDSMAN MICHELE VINCENT's ONGOING REFUSAL TO COMPLY WITH FINANCIAL INSTITUTIONS ACT § 80.3(1) WAS THE ROOT CAUSE OF INTACT's SQUANDER OF TENS OF THOUSANDS OF DOLLARS OF LITIGATION, WITH NO END IN SIGHT!

INTACT's lawyer Meera Jain, has skillfully avoided any semblance of an extrajudicial resolution, with emails such as that of 27 October 2025, infra, wherein she misstated facts and law, by misrepresenting to INTACT's Claimant that the Supreme Court cannot order INTACT to comply with the BC Financial Institutions Act § 80.3(1). She even preemptively sabotaged any possibility of an extrajudicial resolution by defiantly stating that INTACT will not issue a Claims Experience Letter under any circumstances, infra.

The Claimant had not sought to dictate the wording of the letter, nor had he requested any admission of liability or wrongdoing. Rather, he merely had sought a factual statement, confirming that the denial of coverage was based upon internal conflicts or procedural issues within INTACT, over which he had no control, and not of any act, omission attributable to him. This reasonable request had been made, in order to resolve the matter efficiently and without further litigation, as required by Rule of Supreme Court 1-3.

If Attorney Jain is so certain of the Supreme Court's impotence to enforce the Financial Institutions Act § 80.3(1), why does she undertake no action to advance the case to trial?

OPEN LETTER TO THE FOLLOWING PERSONNEL OF INTACT FINANCIAL:

(1) Senior Legal Counsel Mathieu Grenier (2) Legal Compliance Officer Frédéric Cotnoir (3) Senior Vice President & Group Chief Internal Auditor Maude Choquette.

This website initially was created for the limited purpose of alerting INTACT senior management of the Ombudsman’s violation of BC Financial Institutions Act § 80.3(1), infra.

Shortly after Ombudsman Michele Vincent had assigned RB's Complaint to the Customer Experience Team, Whitelaw-Twining Counsel Nigel Beckmann penned his fee generating letter of 07 December 2023, which added the unnecessary, counterproductive SLAPP litigation element, infra.

It is not the intention of RB to dictate the manner in which INTACT Financial elects to squander tens of thousands of dollars of shareholder funds, with its investment in Whitelaw-Twining. However, its Counsel have thwarted RB's attempts to resolve all issues, with the conciliatory gesture of deactivation of this website (and a voluntary forfeiture of precious freedom of express rights). INTACT's wanton abuse of the resources of the BC Supreme Court has been without any palpable merit, because the BC Financial Institutions Act § 80.3(1) requires the cost effective, Ombudsman's administrative mechanism for claims disputes!

RB's conciliatory gestures should not be interpreted as a lack of resolve!

To the left is an email from Whitelaw-Twining's Meera Jain.

It is not claimed that she would intentionally attempt to mislead the SLAPP Defendant into believing that the Supreme Court lacks Interlocutory relief jurisdiction.

However, as any first-year law student knows, the type of relief sought in the Notice of Application obviously does not require the court to adjudicate coverage. The Application merely seeks an Interlocutory Order that the Ombudsman complete an investigation regarding a Complaint about Claims Manager Amanda Myers' fabricated investigation, and other illicit claims practices, infra. The Ombudsman had already accepted and assigned the SLAPP Defendant's Complaint to the Customer Experience Team, but refuses to ensure that the Team conclude its investigation, in violation of § 80.3(1) of the BC Financial Institutions Act.

Whitelaw-Twining Counsel Meera Jain has proven herself to be as intransigent and courtesy-averse as Attorney Nigel Beckmann!

In her email of 27 October 2025, she:

1. Refused the SLAPP Defendant the courtesy of a slight extension, within which to file his Response to her Amended NOCC, and the his Amended Counterclaim.

2. Ms. Jain also announced that INTACT would never extrajudicially allow the Customer Experience Team to complete the investigation assigned by Ombudsman Vincent on 26 May 2023, infra.

3. Ms. Jain also assured the SLAPP Defendant that she would add voluminous (unrelated, past Affidavits) to her pleadings in response to the SLAPP Defendant's Application for an Interlocutory Order, thus virtually assuring that a simple 30 minute perfunctory hearing be extended to at least 90 minutes, assuring that the Application be "bumped" or adjourned, due to Court calendar congestion.

4. Ms. Jain also refused to respond, in good faith, to the SLAPP Defendant's simplified Demand for Particulars.

   IN VIEW OF THE FACT THAT THE SLAPP DEFENDANT's EFFORTS HAVE HAD THE UNINTENDED EFFECT OF THE IMPETUS FOR TENS OF THOUSANDS OF DOLLARS IN REVENUE FOR WHITELAW-TWINING, HE HAS DECIDED TO UNPLUG THE FIRM'S CASH COW, BY PASSIVELY FOREGOING LABORIOUS APPLICATIONS, DEFERRING THE ENTIRETY OF INTACT's MYRIAD VIOLATIONS AND ABUSES UNTIL TRIAL!

   AS FOR ATTORNEY JAIN's REFUSAL TO EXTEND THE COURTESY OF A SLIGHT EXTENSION - NOT NEEDED, BUT DON'T ASK FOR LIKE COURTESIES IN THE FUTURE!

To the left are two images that encapsulate the cruel, egregious, illicit conduct of the Plaintiffs and their Whitelaw-Twining Prosecutors, Nigel Beckmann and Meera Jain. This is the narrative of an administrative dispute that was carefully orchestrated to become abusive SLAPP lawsuit, all while the self-righteous Plaintiffs maintain an air of high legal seriousness, as if their positions had any merit, at all!

The entire matter began with the Plaintiffs Ombudsman Michele Vincent's refusal to complete her mandatory statutory duty under the Financial Institutions Act § 80.3(1). When the Defendant attempted the proportionate, internal step of alerting senior management to this administrative failure, the Plaintiffs, rather than completing their legal obligation, chose to launch a costly, high-stakes lawsuit, with the all too cooperative duo from Whitelaw-Twining.

The sheer absurdity of the Plaintiffs' position is best captured by their Counsel Nigel Beckmann, who, published to numerous claims personnel, that the SLAPP Defendant had presented a claim with INTACT under false pretences.

More recently, after receiving confirmation that the Defendant had already disabled this website—the very core relief they purportedly sought—Attorney Beckmann responded with a disingenuous mix of acknowledgments and punitive demands:

First, INTACT accepted the deactivation, but then immediately minimized its significance by stating the relief was merely "interlocutory and not final." This is a remarkable admission that they are suing over a non-final matter, demonstrating the litigation was procedurally abusive from the outset.

Second, in the very next breath, Attorney Beckmann absurdly demanded a letter of apology/regret signed by the SLAPP Defendant, belittling instruction for a groveling, punitive pre-condition—explicitly advertised on Whitelaw-Twining's own website as a "damage control measure"—exposes the Plaintiffs' true intent: not to enforce law, but to coerce compliance and extract a concession, proving this entire legal exercise is a calculated, bad faith litigation tactic, used as a punitive measure, to conceal the Ombudsman's bad faith dereliction of her own solemn mandate.

With the guidance of Whitelaw-Twining's Nigel Beckmann and Meera Jain, the Plaintiffs have brought a Supreme Court action to compel the Defendant to apologise for exposing the Plaintiffs' own breach of regulatory requirements, all while the Plaintiffs themselves refuse to follow the fundamental law that would well have obviated the necessity of the three (3) SLAPP actions that they have filed. The Supreme Court is asked to expend judicial resources on an INTACT internal matter that is required by statute, to be resolved extrajudicially, with the Customer Experience Team's cost effective, administrative function!

31 October 2025 PUBLIC ANNOUNCEMENT - IN A MAJOR EFFORT TO EXCEED THE SCOPE OF COMPLIANCE WITH THE HONOURABLE JUSTICE ELWOOD's INTERLOCUTORY ORDER OF 13 AUGUST 2025, THE SLAPP DEFENDANT HAS PERMANENTLY DELETED MORE THAN 60% OF ENTIRE PAGES FROM THIS WEBSITE THAT, ALTHOUGH NOT DEFAMATORY, REPRESENTED MATTERS OF CRITICAL OPINION. THIS ONGOING PURGE OF THE WEBSITE REPRESENTS THE SLAPP DEFENDANT's OBJECTIVE TO SIMPLIFY THE ISSUES FOR TRIAL, AND IS NOT INTENDED TO MEAN, NOR SHOULD IT BE INTERPETED AS AN INDICATION THAT ANY OF SUCH PAGES HAD BEEN DEFAMATORY. ALTHOUGH NOT OBLIGATORY, PLAINTIFFS' COUNSEL, WHITELAW-TWINING's MEERA JAIN's PERIODIC REVIEW OF THE SLAPP DEFENDANT's PROGRESS WOULD BE SALUTARY.

25 October 2025

Open Letter to the Charles Brindamour, CEO of INTACT Financial

SUBJECT: Demand for Immediate Withdrawal of Abuse of Process (VLC-S-S-244577) and Good-Faith Resolution of Underlying Claim

This letter addresses the ongoing and entirely unjustified three (3) SLAPP actions initiated by INTACT, currently expending corporate resources to suppress legitimate public statements, regarding bad faith conduct and human rights violations in the handling of my insurance claims.

The premise of INTACT's SLAPPS—that the Defendant's statements of human rights violations are false and defamatory, has been arrantly discredited, by way of voluminous, documented facts, as displayed on this public interest website.

Formal Complaint Filed with the BC Human Rights Tribunal

Although the waiting period for hearing is substantial, the SLAPP Defendant has filed a formal, independent complaint with the BC Human Rights Tribunal (BCHRT), based upon the well-documented premise that INTACT engaged in discrimination based on the protected ground of Age and Right to Human dignity.

This discrimination is evidenced by both the oppressive litigation tactics and the specific bad faith denial of services in the SLAPP Defendant’s underlying claims:

1. Discriminatory Litigation: The Plaintiffs—including INTACT personnel Amanda Myers, Christa Cordick, and Michele Vincent—have employed the wrongful legal stratagem of falsely depicting the Counterclaimant as an "unstable, vexatious litigant" and a "psychological deviant" in oral argument, emails and court filings, using this portrayal as a core strategy to deny insured coverage.

2. Underlying Claim Mismanagement: The discriminatory denial extends to the wrongful, illicit acts and omissions of Amanda Myers in denying the Strata Corporation coverage necessary to remediate contamination (pigeon feces removal from the unit's ledge). This denial effectively prejudiced the Claimant’s rights by denying a claim that would have directly benefited him, the elderly named insured, even as a third-party claimant.

Abuse of Process and Judicial Burden

The continuation of this defamation lawsuit is a demonstrable Abuse of Process and a Strategic Lawsuit Against Public Participation. This bad faith is clearly established by the following:

Malicious Contradiction by Counsel: Of many of INTACT's lawyers, Whitelaw-Twining Partner Nigel Beckmann engaged in further actionable defamation in a letter dated 07 December 2023, by explicitly accusing the SLAPP Defendant of filing the claim "under the pretence of being an insured." This accusation was made despite Plaintiffs Amanda Myers and counsel Christa Cordick having already confirmed the Defendant's official status as a Named Insured. This internal contradiction demonstrates deliberate malice and an attempt to intimidate and force a claim withdrawal based on a known falsehood.

Circumvention of Administrative Justice: The Plaintiffs are circumventing the administrative adjudication process intended by the Financial Institutions Act Section 80.3(1)—an intent that the Ombudsman/Complaint Officer Vincent is legally mandated to uphold. Instead of resolving the underlying bad faith insurance matter administratively, INTACT has wrongfully burdened the Supreme Court with an aggressive, retaliatory lawsuits and Applications, aimed solely at suppressing evidence of its own discriminatory conduct.

The continuation of this lawsuit exposes INTACT to significant aggravated and punitive damages through the SLAPP Defendant's soon to be filed Amended Counterclaim, which creates an unnecessary and severe reputational risk by actively suing an elderly customer who is pursuing a legitimate, documented claim of age discrimination and corporate fraud.

By pursuing this matter in the Supreme Court, Intact Insurance is acting contrary to legislative intent:

• The Plaintiffs are circumventing the administrative adjudication process intended by the Financial Institutions Act Section 80.3(1)—an intent that the Ombudsman was established to uphold.

• Instead of resolving the underlying bad faith insurance matter administratively, INTACT has purposefully burdened the Supreme Court with an aggressive, retaliatory lawsuit aimed solely at intimidating and suppressing evidence of its own discriminatory conduct.

DEMAND:

That INTACT immediately instruct its counsel to withdraw the SLAPP litigation and engage directly and in good faith to resolve the underlying insurance claim and the pending BCHRT complaint.

27 October 2025 As documented in the images to the left, on 26 May 2023, Ombudsman Michele Vincent accepted the Claimant's formal Complaint regarding Claims Manager Amanda Myers' fabricated claims investigation.

However, a mere 55 days thereafter, Ombudsman Vincent sabotaged her own Financial Institutions Act § 80.3(1) imperative, by reneging on her promised Final Business Decision letter, admitting that INTACT had decided to abandon its cost-effective administrative mandate.

The Ombudsman's decision to invoke the precious resources of the taxpayer-funded BC Supreme Court, as a subterfuge for INTACT's dereliction of its statutory mandate (as well as the squander of tens of thousands of dollars in Whitelaw-Twining's malicious SLAPP prosecution fees) is a veritable testament to the institutional dysfunctional rot that has come to replace CEO Brindamour's noble "living our values" directive.

Message from the blue collar tradesman SLAPP Defendant to the Retail Merchants of Words Whitelaw-Twining prosecutorial team:

The entirety of yours and your Clients' unconscionable legal, statutory and unethical abuses, particularly INTACT's ongoing violation of the administrative, cost effective BC Financial Institutions Act § 80.3(1) (thus wantonly squandering the precious resources of the Supreme Court) is precisely documented on this website, and will be addressed in all Affidavits for future Court filings, including the Reply to INTACT's Amended NOCC, Amended Counterclaim, future Applications and Responses thereto.

The SLAPP Defendant assures you and your INTACT Clients that the Supreme Court's nascent awareness of your myriad abuses of the judicial system is but a tip of the abuses of process iceberg!

28 October 2025

All notions of Politesse are wasted on these self-righteous SLAPP Plaintiffs and their enablers at Whitelaw-Twining!

After more than four (4) years of INTACT's intentional infliction of emotional distress, the SLAPP Defendant and his wife have decided to assume a more aggressive legal posture, with the Application for Interlocutory Relief, to the left.

The 14 November 2025 Application, set by the parties, will address Plaintiff Ombudsman Michele Vincent's egregious dereliction of her solemn mandate, with the resultant abuse of the resources of the Supreme Court.

As extensively documented on this extensive website, the self-righteous SLAPP Plaintiffs, INTACT Lawyer Christa Rae Cordick, INTACT Strategic Team Leader Claims Manager Amanda Myers, and INTACT Ombudsman and Complaints Officer Michele Vincent, have all engaged in acts and omissions at INTACT, which are illegitimate.

These three INTACT employées have all been Plaintiffs in three (3) SLAPP actions against an INTACT Insured Defendant.

These three INTACT employées have all been Plaintiffs in three (3) SLAPP actions, none of whom seeks any monetary damages.

These three INTACT employées, in their SLAPP actions, have all sought interlocutory (temporary) removal of material on this and another website, infra, that is defamatory of them. The SLAPP Defendant has removed all such arguably defamatory material from this website, pursuant to an Order of the Honourable Justice Elwood, dated 13 August 2025.

Over the course of several months, these three INTACT employées, had all rejected various offers of the SLAPP Defendant, ranging from removing their names and positions from this website, surrender of control of this website for their removal, in their sole discretion, etc.

These three INTACT employées, in their most recent SLAPP action, filed on 15 September 2025, do not seek the permanent or even interlocutory (temporary) deactivation of this website. Prima facie SLAPP spite litigation!

In a stark indication that the three INTACT employées have refused any semblance of settlement of their SLAPP litigation:

1. INTACT Claims Manager Myers refuses to reconsider her denial of the SLAPP Defendant's claim, notwithstanding the documented fact that she had fabricated her claims investigation, and had apparently negligently calculated the SLAPP Defendant's residential unit to have included a physically inaccessible, narrow ornamental exterior ledge infested with feral pigeons, whose faeces which the SLAPP Defendant had to pay hundreds of dollars to a specialty nuisance abatement company to remove.

2. INTACT Lawyer Christa Rae Cordick refuses to retract her factually untrue Affidavits, filed in the Supreme Court, which misstate material facts, circumstances, the Strata plan and statutory authority. Her defamatory material misrepresentations to Judges of the Provincial Court are documented, infra.

3. The conflicted of interest INTACT Ombudsman/Complaint Officer Michele Vincent refuses to cease and desist her ongoing violation of BC Financial Institutions Act § 80.3(1), which requires that she permit that INTACT's Customer Experience Team conclude its investigation of Claims Manager Amanda Myers, and issue its Business Decision Letter, infra.

After four (4) years, one would expect that these three INTACT employées finally cease their intentional infliction of emotional distress and act in a responsible, conciliatory manner, to be a credit to INTACT, rather than such a legal and reputational liability!

25 October 2025

INTACT's Whitelaw-Twining lawyer Nigel Beckmann has suggested an approach to resolve all outstanding issues. The following commentary is of responses to statements that he has made in the below email:

"Since my client does not consider you an insured for this CGL policy in question, I do not believe they can in good faith produce a Claims Experience Letter."

Response: As documented on this website, infra, Mr. Beckmann hasn't any client who does not consider the SLAPP Defendant as an insured of INTACT. In fact, his Client Amanda Myers defined the Defendant's status as a named insured under the INTACT policy, in her letter of 30 September 2021, infra. Another of his Clients, Christa Rae Cordick, filed pleadings in the Provincial Court, by which she conceded the Defendant's status as a named insured. In fact, as detailed on this website, Nigel Beckmann is the only person on the planet who has stated that the Defendant is not an insured of INTACT.

"Based on this premise, if you are faced with a question on an insurance application form “Have you ever had a claim denied?”, it would be appropriate for you to say “No.” The reason that it was not a denial is because you were not entitled to coverage under that insurance policy in the first place."

Response: Perhaps only a lawyer could comprehend the possible connexion between the premise and the conclusion, nonetheless the SLAPP Defendant cannot, and will not conceal the fact that INTACT has denied his claim, particularly since Mr. Beckmann has prefaced his email with the admonition that the claim had been and remains denied!

"If you do not accept that proposal, let's consider your position. You say that you were an insured. One of the proposals that you have made in the past is for an investigation, which must surely include the possibility of a determination that your claim is not allowed. If that were the outcome I do not see how you would be any better off. You would have to tell the insurance company you are applying to that you had a claim denied and that could disqualify you from coverage."

Response: Finally, Mr. Beckmann has joined INTACT Privacy Officer Helen Cameron, in confirmation that INTACT has never investigated the SLAPP Defendant's claims, in contradiction of Claims Manager Amanda Myers' false statement that she had conducted a claims investigation (source: her letter of 30 September 2021, infra.)

In an event, the SLAPP Defendant has requested such an investigation for more than four (4) years. An investigation had been assigned by SLAPP Plaintiff Ombudsman Vincent, to INTACT's Customer Experience Team, which has not yet released a Final Business Decision letter. An investigation is the injunctive relief sought in the SLAPP Defendant's soon to be filed Amended Counterclaim Court Rule 1-3 would require that the extrajudicial approach be utilised. Yes, Mr. Beckmann and Ms. Jain, the SLAPP Defendant accepts your offer of an investigation.

"What I suggest doing is considering an alternative solution to this problem. If Intact could produce a letter for you to use in the course of insurance applications which explained the situation and confirmed you were never denied a claim as a rightful insured, would that not be beneficial to your situation?"

Response: Yes, please!

As specifically detailed and documented on this website, since the SLAPP Defendant direly needs full coverage property insurance, he has requested, even begged Whitelaw-Twining's lawyer to provide him with a truthful, factual Claims Experience Letter, which explains that although INTACT denied his claim within the past seven years, that the denial was based upon Claims Manager Amanda Myers' fabrication of facts.

INTACT lawyer Nigel Beckmann sent the SLAPP Defendant the below email, on 24 October 2025.

Not being an expert in insurance matters, the SLAPP Defendant showed the email to the following property insurance brokers: Western Coast Insurance Services Ltd, London Drugs Insurance Services and Square One Insurance Services, with queries as to the propriety of Attorney Beckmann's suggestion of a Claims Experience Letter that would state that the Applicant "was never denied a claim as a rightful insured"

Although none of the agents could comprehend what "never denied a claim as a rightful insured" means, all confirmed that irrespective of the ambiguity of the "rightful insured" wording, insurance applications strictly require the disclosure of denied claims history. Applications must be answered honesty, even if a denial were wrongful, based upon falsifications (as is the case with INTACT's claims denial of 30 September 2021).

INTACT's lawyer, (the Director of Whitelaw-Twining's Insurance Department, no less ) has stated that the SLAPP Defendant was "never denied a claim as a rightful insured’— which is ambiguous and evasive. It does not negate the fact that coverage was denied, nor does it relieve the applicant of the duty to disclose that denial. This Director of Whitelaw-Twining's Insurance Department is held to an enhanced legal standard, as an insurance expert. Even more so than the highly knowledgeable team member Meera Jain, Attorney Beckmann knows that insurance applications require clear, factual disclosure of past denials. Substituting vague or rhetorical language for truthfulness undermines the integrity of the application and exposes the applicant to potential misrepresentation.

As for INTACT's offer to provide a Customer Experience Letter, which requires dishonesty, in exchange for permanent, or even interlocutory deactivation of any website, with or without a consent order, is unreasonable.

Tenant's Contractual Status as an Insured Party

The document reveals that the INTACT Policy provides coverage that extends the definition of an Insured to include the tenant in specific circumstances, fundamentally changing the relationship between INTACT and the SLAPP Defendant from adversarial to fiduciary.

1. Factual Basis: Explicit Coverage for the Tenant

The documents establish two key coverage categories relevant to a tenant on the premises:

• Coverage is explicitly provided for "Tenants' Legal Liability - with a limit of $500,000 and a $1,000 deductible.

  • Legal Impact: This coverage exists to protect the tenant (the Defendant) from claims of damage that he may cause to the strata property. By providing this coverage, the tenant is converted from a mere third-party visitor into an Insured Party under the policy, for this specific risk.

• Medical Payments – Each Person" at $50,000.

  • Legal Impact: Medical payments coverage is non-fault-based and extends to parties on the premises who sustain injury, further blurring the line between a traditional third-party and a covered person. This coverage indicates the policy intends to provide benefits directly related to tenants residing at the property.

2. The Legal Shift: Breach of Fiduciary Duty

Once the tenant is established as an Insured Party under the policy, INTACT's relationship shifts from a simple contractual one to a fiduciary relationship.

• Fiduciary Duty: In Canadian insurance law, the insurer owes a duty of utmost good faith to its insureds. This duty requires the insurer to:

  • Act honestly and promptly.

  • Give the insured's interests equal consideration to its own.

  • Properly investigate and process claims fairly.

• The Breach: INTACT's refusal to recognise the Defendant's status as an Insured Party, by virtue of the Tenants' Legal Liability coverage, and its subsequent three (3) SLAPP actions against him—rather than providing a Customer Experience letter—constitutes an egregious Breach of Fiduciary Duty.

Summary of Evidence: Intact's Institutional Contradiction and Aggravated Bad Faith

INTACT's corporate functions repeatedly confirmed the Claimant's status as a formal "Customer" entitled to a good-faith review, while the litigation department (Christa Rae Cordick and the Whitelaw-Twining Ensemble) simultaneously and falsely denied such status, in Affidavits and other court filings.

This contradiction establishes the necessary threshold for an independent, actionable wrong, justifying an award of punitive damages under Canadian common law.

The internal communications, supra, confirm that INTACT formally recognized and processed the Claimant as a party to whom they owed a corporate duty of care, directly contradicting their legal defense:

Customer Experience Email

The team explicitly refers to the claimant as a "Customer" and commits to providing "exceptional service" and a "comprehensive review of concerns."

This admission of a "Customer" relationship voids INTACT's defence that the Claimant is merely an unprotected third party with no recognised standing.

INTACT Ombudsman's Email

The Ombudsman, SLAPP Plaintiff Michele Vincent confirms that the complaint was formally assigned to "Step 2 of the Complaint Handling Protocol", a binding, regulated process committing INTACT to "investigate if needed."

INTACT triggered its own internal, multi-level duty of diligence. The subsequent failure to meet this duty transforms an initial error into a breach of corporate protocol.

Privacy Officer Admission

INTACT Privacy Officer, Helen Cameron, later confirmed there were "no documents to provide as an investigation had not been completed."

This proves that the Ombudsman's and Customer Experience Team's commitments to a comprehensive, two-step review were an institutional sham; the protocol was triggered, but the essential investigative duty was deliberately ignored.

INTACT's Whitelaw-Twining legal counsel asserted that the company "deny[s] that RB (Mr. B) is or was a Named Insured."

This is the final, dispositive contradiction: INTACT's left hand (legal defense) denies the claimant's status entirely, while its right hand (Customer Experience Team) actively processes and formalises the claimant as a "Customer" within a specific, mandatory internal protocol.

INTACT's institutional contradiction and subsequent breach of its own internal protocol meets the stringent test for bad faith conduct, justifying an award of punitive damages, as established by the Supreme Court of Canada.

The seminal case of Whiten v. Pilot Insurance Co., 2002 SCC 18, confirms that an insurer's contractual duty to act in good faith is an independent contractual obligation. A breach of this duty qualifies as an independent actionable wrong upon which punitive damages may be founded.

1. Creation of Duty: INTACT created an institutional duty by classifying the claimant as a "Customer" and initiating its formal "Complaint Handling Protocol."

2. Breach of Duty: INTACT then breached that duty by failing to conduct the promised investigation and simultaneously advancing a defence in litigation that directly refuted the claimant's internal status, demonstrating a calculated strategy to exploit its position.

• By engaging the claimant in a formal, multi-step "Complaint Protocol" that promises a comprehensive review, while internally deciding to perform no investigation and legally denying their very status, INTACT demonstrates a malicious and arbitrary pattern of conduct.

• The effect of this institutional deception was to subject a formally recognised "Customer" to the time, expense, and stress of prolonged SLAPP litigation, all while breaching the company's own documented standard of care. This manipulation of corporate regulatory process to advance a litigation strategy is the hallmark of aggravated bad faith.

Conclusion: The documentary evidence establishes that INTACT's denial of the claim was compounded by a willful, institutional contradiction, calculated to frustrate the Claimant's pursuit of justice, thereby fulfilling the requirements for a significant punitive damages award.

22 October 2025 INTACT's inhouse and outhouse lawyers have positioned INTACT for substantial punitive damage exposure!

23 October 2025

CEO Brindamour's "Living Our Values" mantra queries WHOSE VALUES ARE WE LIVING?

While CEO Brindamour vows that Intact is 'Living Our Values,' the result, in quantifiable, pecuniary terms, is a transfer of tens of thousands of dollars of shareholder funds directly into Whitelaw-Twining's coffers, in its relentless, SLAPP prosecution of a Whistleblower, who had brought to the attention of Senior Legal Counsel Mathieu Grenier and Legal Compliance Officer Frédéric Cotnoir, the reputational damage caused by certain of INTACT's rogue elements

Continuation of letters to INTACT's attorney, Meera Jain

The defense strategy, including the specific arguments presented in INTACT's Response to the Original Counterclaim, serves to reinforce the gravity of its misconduct.

1. THE EVIDENCE OF A FABRICATED DENIAL

INTACT's tort of bad faith was completed the moment the denial was issued, based on a non-existent corporate rationale. The following documents establish this as an undeniable fact:

Action 1: The Denial - INTACT's Claims Manager Amanda Myers' initial denial of coverage, asserts that her decision was based upon a completed coverage review/investigation and a clear policy finding.

Action 2: The Admission - Intact's Privacy Office Response to Access Request., formally confirms that there are “no documents to provide as an investigation had not been completed” for this file.

Legal Conclusion: Your client INTACT's internal records explicitly prove that the Claims Department issued a coverage denial, a definitive legal action, while possessing zero completed work product to justify that decision. The denial was, therefore, not a good-faith mistake, but an arbitrary, high-handed, and willful fabrication of corporate due diligence.

2. DISMANTLING THE "ACTUAL NOTICE" DEFENSE

The absurdity that the Claimant was on "actual notice" because he would have noticed the absence of a claims examiner. this defence is legally meritless as it attempts to shift responsibility for the insurer's corporate fraud onto the injured party.

• The Nature of the fabrication: INTACT's bad faith resides not in the absence of evidence of Claims Manager Myers' investigation, but, rather in the Myers' documented falsehood that the file contained a completed investigation. Whether the Claimant saw a claims examiner or not is irrelevant to the Claims Manager's legal and professional duty to base her decision upon an actual, completed process.

• Aggravating Factor: The Claimant's awareness that no physical inspection occurred only makes the Claims Manager’s subsequent reliance on a fictional "investigation" more reckless and egregious. The Claims Manager issued a denial based on literally nothing other than a pre-determined decision to deny, proving the decision was arbitrary and malicious.

3. Institutional Misconduct and Extracontractual Harm

The insurer’s subsequent actions constitute ongoing abuse, warranting maximum punitive sanction:

• Weaponized Obstruction: The Ombudsman’s Office (M. Vincent) used the non-existent "Not Insured" finding to refuse the Claims Experience Letter . This was a deliberate act that actively damaged the claimant’s economic status and insurability, proving a systemic indifference to the Claimant's rights.

• Irrelevance of Contractual Defense: INTACT’s belated reliance on the inaccessible "pigeon roost" exclusion is irrelevant. The cause of action is not about the policy wording; it is about the tortious act of denying the claim under a false premise—an act of corporate misconduct already completed and documented by Intact's own records.

Attorney Jain, there remains a substantial amount of factual, documented evidence that has not yet been posted on this website.

How do you propose that I allow you full access to such documentation, without the need for full discovery!

21 October 2025

Per the below email, of 10 December 2024, INTACT's lawyer promised to persuade INTACT to provide a (limited) Claims Experience letter, yet after ten (10) months, no letter has been provided.

As explained, infra, a Claims Experience letter, however limited, would better enable the SLAPP Defendant to procure direly needed adequate property insurance, by explaining the circumstances under which Claims Manager Amanda Myers denied coverage for his claim, as documented on this website.

EVEN INTACT's LAWYER HAS AGREED TO A LIMITED CLAIMS EXPERIENCE LETTER. WHY HASN'T IT BEEN ISSUED?

18 October 2025

Open letter to Meera Jain, Esqs

Dear Attorney Jain:

In view of the fact that your professional, longitudinal examination of the INTACT dossier requires many hours of review, I should like to assist your endeavours, as best I can, by providing relevant documentation.

Among the most important documents for your review is the below letter of 19 January 2025, from INTACT Privacy Officer Helen Cameron, in response to my Freedom of Information Request to correct notations in my case dossier regarding Claims Manager Amanda Myers' letter of 30 September 2021, wherein she falsely claimed to have investigated my claims (4033526840 and 1033684645). As you come to complete your comprehensive review, please note the conclusive evidence that the initial denial of coverage for the Strata Master Policy (Commercial General Liability policy 5PNGL0819) was based upon a fabricated pretext, justifying a significant claim for punitive damages against INTACT and the other Plaintiffs.

INTACT’s conduct, beginning with the initial denial and continuing through the Ombudsman’s refusal to provide documentation, constitutes aggravated bad faith and abuse of process under the criteria established in Whiten v. Pilot Insurance Co.

1. The Internal Contradiction: Proof of a Fabricated Investigation

INTACT’s own documentary evidence, the letter of 19 January 2014,, obtained through an access request, establishes that the initial rationale for the denial was false.

• The Denial Pretext (Claims Department): The Claimant was initially led to believe the denial was justified by the findings of an "investigation" (referenced in Claims Manager Myers' letter of 30 September 2021) or the findings of Claims Manager Amanda Myers) which allegedly confirmed the loss was not covered.

• The Corporate Admission (Privacy Office): In direct contradiction, Intact’s Privacy Office formally advised the claimant on 19 July 2023, that there were "no documents to provide as an investigation had not been completed" for the claims.

The legal consequence of this internal contradiction is simple: INTACT’s Claims Department relied upon an investigation that its Privacy Officer admits never existed, as it was never completed.

This is not a mistake in policy interpretation; it is irrefutable, official corporate proof that the initial basis for the denial was arbitrary, dishonest, and designed solely to defeat the claim. This establishes the element of malice at the time the tort was committed.

2. The Irrelevance of the Contractual Defense

Your client, Claims Manager Myers, contractual defense—relying on the absurd "possession", "occupation" and "use", of an area that is in fact an external pigeon roost" was nothing but a sham, although ironically Myers did confirm the claimant's status as a Named Insured.

The denial was tortious at the time it was made because it was not based on any completed, good-faith reading of the policy, but on a false factual premise. The insurer's subsequent attempt to substitute a technical policy defense proves a persistent, bad-faith effort to avoid liability.

3. The Guarantee of Punitive Damages

The ongoing conduct of the INTACT and Amanda Myers, Christa Rae Cordick amplifies this initial act of fraud:

• Systemic Obstruction: The Ombudsman’s office actively perpetuated the harm by using the flawed "Not Insured" finding to refuse the Claims Experience Letter which directly damaged the claimant’s ability to secure other than assigned risk property insurance.

• Abuse of Process: By forcing the claimant to litigate to expose a false representatoin that was documented in their own corporate records, INTACT has engaged in egregious abuse of the judicial process.

I look forward to your review of this clear evidence of institutional fraud and misconduct. Absent immediate and meaningful settlement discussions that fully compensate the claimant for the extracontractual damages (damages related to loss of insurability) and a substantial amount for punitive damages to denounce this reprehensible conduct, we will be using these documents to pursue the maximum possible punitive award at trial.

17 October 2025

POTENTIAL FOR AN EXTRAJUDICIAL RESOLUTION TO THE SLAPP LITIGATION

The SLAPP Plaintiffs' lawyer, Meera Jain, Esqs.

Ms. Jain's predecessor had created a defence for the Plaintiffs, predicated exclusively upon the strategy that the SLAPP Defendant's burden is to obtain a judicial determination of his legal status as an insured, or named insured of INTACT.

However, Attorney Jain's SLAPP Defendant faces no such burden, since his legal rights arise from acceptance of his claims submission, by Plaintiff Amanda Myers, processed by Plaintiff Michele Vincent, and presented to the Provincial court by Plaintiff Christa Rae Cordick, irrespective of any judicial determination of his status as an insured, or named insured!

The bases for the SLAPP Plaintiff's damages will be specified in the soon to be filed and served Amended Counterclaim to INTACT's Amended NOCC,

18 October 2025

The SLAPP Defendant has had a personal meeting with Attorney Meera Jain, during which this case was discussed in depth. It is obvious that lack of courtesy is an effective approach. Legal Memorandum: Aggravated Bad Faith and Punitive Damages Establishing the Evidentiary Threshold for Corporate Misconduct Introduction: The Aggravated Breach and Punitive Liability INTACT's conduct transcends a mere breach of contract, amounting to aggravated bad faith and an independent tortious act. This course of action has inadvertently guaranteed liability for punitive damages, fulfilling the stringent criteria set by the Supreme Court of Canada in Whiten v. Pilot Insurance Co., [2002] 1 S.C.R. 595. The evidence proves INTACT acted with the required "high-handed, malicious, arbitrary, or highly reprehensible" intent. I. The Insurer’s "Worst of Both Worlds" Dilemma

The strength of this claim rests on the fact that INTACT is liable for substantial damages, regardless of the outcome of the underlying contractual dispute; i.e. insured (named insured) or non-insured but a recognised claimant.

A. Scenario 1: The judicial determination that the Claimant WAS an Insured

This finding establishes a contractual relationship, leading to liability for Breach of the Duty of Good Faith.

• Governing Authority: INTACT has a contractual duty to deal with its named insured's claim fairly and in good faith (Fidler v. Sun Life Assurance Co. of Canada, [2006] 2 S.C.R. 3).

• Application: By coupling the claim denial (Contractual Breach) with the active post-claim sabotage (Tortious Act) of the Insured's economic standing, the insurer's conduct is escalated to a malicious and arbitrary breach of the highest duty. This triggers extracontractual damages, including compensation for mental distress and, crucially, Punitive Damages under the Whiten standard to punish and deter such conduct.

B. Scenario 2: The judicial determination Claimant WAS NOT an Insured

If the claimant is determined to be a third party, INTACT's actions exposes itself and the other SLAPP Plaintiffs to liability for an independent tort, such as Unlawful Interference with Economic Relations.

• Governing Authority: Canadian tort law prohibits intentional, unprivileged interference with a party's economic interests. INTACT, wielding its corporate power, intentionally used the "Not Insured" finding—a self-serving, disputed classification—to inflict tangible, long-term harm on the claimant's insurability.

• Application: This unprivileged action, taken with clear knowledge of the potential harm, is inherently arbitrary and malicious. Since there is no underlying contract to limit damages, the tortious conduct is independently compensable, demanding a major award of Punitive Damages to denounce INTACT's corporate abuse of power.

II. Proof of High-Handed and Arbitrary Conduct The factual pillars of the case directly map to the egregious conduct required to justify a punitive award under Whiten: A. The Fabrication of Justification

The initial claim denial, based upon a fabricated internal justification, proves that Claims Manager Amanda Myers did not merely make an error in judgment. Instead, she has engaged in a calculated, dishonest course of action to deny a benefit. This constitutes malice at the investigative stage .

B. Active Sabotage and Extracontractual Harm (Vincent's Letter)

The refusal by INTACT (by way of Ombudsman Michele Vincent's emial (above) to issue the claims experience letter is the undisputed proof of INTACT's high-handed conduct. The email, which explicitly states the documentation cannot be issued because the claimant was deemed "not insured," is a deliberate act of using the disputed finding to inflict harm on the claimant’s future economic viability (insurability). This is the definition of oppression and arbitrary conduct that the Whiten decision sought to deter.

C. Systemic Codification (The Ombudsman Refusal)

The final act is the systemic entrenchment of this malicious finding. The Ombudsman's refusal to issue an exculpating letter, based on the insurer's original and self-serving "Not Insured" designation, is critical evidence that:

1. The malice is not an isolated error, but a systemic corporate policy (Whiten factors often focus on corporate conduct over individual error).

2. INTACT continues to endorse and extend the harm, demonstrating a persistent indifference to the claimant's rights, justifying a substantial punitive damage award.

Conclusion

The combined evidence of internal fabrication, the active, documented sabotage confirmed by Vincent’s Letter, and the systemic enforcement confirmed by the Ombudsman’s refusal demonstrates that INTACT's conduct is "so malicious and outrageous that it is deserving of punishment" (Whiten). Counsel can confidently assert that the evidentiary threshold for a significant award of Punitive Damages has been overwhelmingly satisfied.

Active Sabotage and Extracontractual Harm (Ombudsman Vincent's email)

The refusal by INTACT (by way of Ombudsman, SLAPP Plaintiff Michele Vincent's above email) to issue the claims experience letter, which the SLAPP Defendant has direly needed, (in order to prove to prospective property insurers, that Claims Manager Amanda Myers' claims denial was a sham) is the undisputed proof of INTACT's high-handed conduct. The email, which explicitly states the documentation cannot be issued because the claimant was deemed "not insured," is a deliberate act of using the disputed finding to inflict harm on the claimant’s future economic viability (insurability). This is the definition of oppression and arbitrary conduct that the Whiten decision sought to deter.

Systemic Codification (The Ombudsman's Refusal)

The final act is the systemic entrenchment of this malicious finding. The Ombudsman's refusal to issue an exculpating letter, based on INTACT's original and self-serving "not insured" designation, is critical evidence that:

1. The malice is not an isolated error, but a systemic corporate policy (Whiten factors often focus on corporate conduct over individual error).

2. The insurer continues to endorse and extend the harm, demonstrating a persistent indifference to the Claimant's rights, justifying the largest punitive awards.

3. The Ombudsman's email converts a simple refusal into an act of active obstruction. This fortifies the bad faith claim because it shows INTACT is not merely mistaken or passive; INTACT is dedicating institutional resources to prolonging the SLAPP Defendant's distress and interfering with his right to seek property coverage with any insurer.

09 October 2025

Subject: Prohibited Procedural Discrepancies in Relief Sought by INTACT - Case No. S-244577

Dear Mr. Beckmann and Ms. Jain

INTACT's Amended Notice of Civil Claim is procedurally incongruous with your stated intent to seek a Final Order/Summary Judgment on this matter.

1. The Amended NOCC (Paragraph 1(b)) formally requests an order for the permanent removal of the Post and Post2.

2. However, your recent correspondence threatens an Application in which you seek permanent deactivation of the entire website.

Your serious attention is requested to BC Supreme Court Civil Rule 8-3, which provides that a plaintiff is limited to relief that is claimed in the Notice of Civil Claim. INTACT's Amended NoCC, as drafted, does not contain a request for the deactivation of any entire Website.

With all due respect, Mr. Beckmann and Ms. Jain, your path of non-compliance with Rules of Court has created a trail of confusion, and a needless waste of the Court's precious resources!

If you are to comply with the Rules of Court, your options are limited:

1. Proceed with your current Amended NOCC and confirm that your upcoming Application will be strictly limited to the removal of the specific posts (1b) and will not include the closure or deactivation of this entire Website, OR

2. Seek leave of the Court to file a Second Amended Notice of Civil Claim to formally incorporate the request for Website Deactivation.

This open letter notification has been necessitated by your custom of misapplication or non-compliance with Rules of Court, as documented, in specific detail, on this and the other website.

The Court would thank you for discontinuation of your incessant posturing, as exemplified by your threatened Summary Judgment Application seeking unpleaded remedies, which are prohibited by Rule 8-3.

Sincerely,

RB, SLAPP Defendant

INTACT IS A MERCHANT - IT SELLS INSURANCE PRODUCTS. ITS LAWYERS ARE RETAIL MERCHANTS - THEY SELL WORDS FOR A PROFIT. OTHER MEMBERS OF SOCIETY, AS WELL, ARE CAPABLE OF USING WORDS. IN INTACT's MALICIOUS SLAPP ACTIONS, THE SUBJECT OF THIS PUBLIC INTEREST WEBSITE, THE SLAPP SELF-REPRESENTED DEFENDANT USES WORDS, IN ORDER TO DEFEND THE TRUTH, AND INCREASINGLY SO, THE VERY PROCEDURAL PROCESSES OF THE SUPREME COURT.

AS DOCUMENTED HEREIN, ATTORNEY JAIN HAS NOTIFIED THE SLAPP DEFENDANT OF HER INTENTION FILE A RULE 9-6 or 9-7 APPLICATION (FOR A REHEARING, BY A DIFFERENT JUSTICE) OF AN ORDER ISSUED TO HER ON 13 AUGUST 2025, BY THE HONOURABLE JUSTICE ELWOOD OF THE BC SUPREME COURT.

HOWEVER, AFTER SEVERAL WEEKS, ATTORNEY JAIN HAS FAILED TO FILE HER APPLICATION!

07 October 2025

At today's Application before the Honourable Associate Judge John Bilawich, Attorney Meera Jain easily frustrated the awkward efforts of the bewildered, blue-collar SLAPP Defendant. Ms. Jain was able to avert the focus of the Application away from the fact that she and firm Partner Nigel Beckmann had attempted an illicit back door approach to Justice Elwood's Order of 13 August 2025, which flatly denied INTACT's Application to permanently deactivate this website, as detailed herein.

Since Attorney Jain hasn't notified the SLAPP Defendant of any vestige, whatsoever, of defamation that could conceivably have remained on this website (due to the SLAPP Defendant's compliance with Justice Elwood's Order), she and the firm's Partner resorted to deceptive back door tactics!

Meera Jain's email expressly confirms that INTACT's illegitimate objective is not to protect a reputation from specific statements, but rather to misuse the legal process, to silence legitimate criticism and commentary entirely.

ABUSE OF PROCESS: Attempt to Nullify a Standing Order

Instead of complying with Justice Elwood's binding directive, Meera Jain and her Associate Nigel Beckmann have confirmed their intention to file a new, collateral application before a different Justice. This action is a textbook example of Judge Shopping and an Abuse of Process, designed solely to circumvent or nullify Justice Elwood's existing Order.

In absolute defence of the sanctity of the Honourable Justice Elwood's Order of 13 August 2025, the SLAPP Defendant resolutely challenges INTACT's lawyers' instances of non-compliance, particularly the wrongful procedural evasion. The SLAPP Defendant is insistent upon upholding Justice Elwood's Order and will vigorously oppose any Application that attempts to subvert such.

NOTICE: This fact-based informational website is replete with documentation of statements and representations, as rendered herein. The viewer is invited to familiarise herself/himself with the documented facts, prior to the formation of any opinion.

IN FURTHERANCE OF ITS SLAPPs AGAINST ITS NAMED INSURED, INTACT HAS SUBMITTED PERJURED AFFIDAVITS, WITH AN APPLICATION FOR AN INTERLOCUTORY ORDER TO (TEMPORARILY) DEACTIVATE THIS WEBSITE, IN A SCHEME TO CONCEAL ITS UNLAWFUL CLAIMS PRACTICES. OTHER PERJURED AFFIDAVITS WILL BE DISPLAYED IN THE FUTURE.

Myers' perjured Affidavit

Claims Manager Myers' illegal claims practices are not limited to perjured Affidavits. On Page 2 of her Affidavit (image to the left) she committed claims management prohibited acts, by falsely testifying that the Claimant had nullified his insurance coverage, for "personal use" of a balcony, that is factually an exterior, inaccessible pigeon roost (below). INTACT Privacy Officer Helen Cameron conducted an independent internal affairs probe, which confirmed that Claims Manager Myers had invented her false narrative of having completed a claims investigation!

Myers' letter of 30 September 2021, per her Affidavit