23 MARCH 2025

DESPITE DEFENDANT'S REPEATED CONCESSIONAL OFFERS TO PLAINTIFFS, IN THE SPIRIT OF RULE OF COURT 1-3, INTACT's INTRANSIGENT REJECTION OF ALL OFFERS WILL BE THE SUBJECT OF THE SCHEDULED COURT HEARING.

BELOW IS THE ACTUAL OFFER MADE BY DEFENDANT, AS FILED ON 18 MARCH 2025, WHICH IS EVEN MORE CONCILIATORY THAN SEVERAL PRIOR OFFERS. ALL OF THESE CONTRACTUAL, STATUTORY, REGULATORY AND JUDICIAL ENTANGLEMENTS, MERELY BECAUSE INTACT REFUSES TO CONDUCT A SIMPLE, STANDARD CLAIMS INVESTIGATION, TO REPLACE CLAIMS MANAGER AMANDA MYERS' FRAUDULENT, FALSIFIED SHAM!

24 MARCH 2025

As evidenced by this scrupulously detailed, public interest, informational website, Plaintiff, Claims Manager Amanda Myers fabricated the investigation of a claim submitted by Defendant. Myers' fabrication was exposed by INTACT Privacy Officer, Helen Cameron, in her letter of 19 January 2024.

However, in egregious bad faith, instead of merely conducting an actual, standard investigation, Myers (aided and abetted by Plaintiffs, Counsel Christa Rae Cordick and Ombuds[wo]man Michele Vincent), has refused for more than 3 1/2 years to merely conduct an actual, good faith investigation, to replace Myers' fraudulent substitute. On 07 December 2023, a Whitelaw-Twining Partner, Nigel Beckmann joined the illicit cover-up, with the herein letter, defamatory of Defendant, falsely accusing Defendant of submission of a claim, under the false pretence of being an insured.

27 MARCH 2025

As evidenced by this scrupulously detailed, public interest, informational website, Plaintiff, Claims Manager Amanda Myers fabricated the investigation of a claim submitted by Defendant. Myers' fabrication was exposed by INTACT Privacy Officer, Helen Cameron, in her letter of 19 January 2024.

However, in egregious bad faith, instead of merely conducting an actual, standard investigation, Myers (aided and abetted by Plaintiffs, Counsel Christa Rae Cordick and Ombuds[wo]man Michele Vincent), has refused for more than 3 1/2 years to merely conduct an actual, good faith investigation, to replace Myers' fraudulent sham. On 07 December 2023, a Whitelaw-Twining Partner, Nigel Beckmann overzealously joined the illicit cover-up, with the herein letter, defamatory of Defendant, falsely accusing Defendant of submission of a claim (that Claims Manager Myers had accepted), under the false pretence of being an insured.

Whitelaw-Twining’s indispensable involvement in this travesty of conscience and law alike, is particularly odious, in that in order to support his defamatory allegation of the Defendant’s illicit claims submission, the Partner cannot but disavow Strata Property Act Section 155(b), and the ruling regarding Named Insureds, in 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, as well as the confirmations that the Defendant was a Named Insured, per INTACT personnel Amanda Myers, Christa Rae Cordick and Michele Vincent, all of whom had all declared the Claimant's status as a Named Insured, in legal pleadings to the PBPC, the BCFSA, as well as to various Scheduled Insurers of the subject INTACT property liability policy. Defendant's legal status as a Named Insured was additionally confirmed by Insurance Broker Gordon Li, Sedgwick Sr Adjuster Daphne Chan, and Heather Bidnall, Compliance Officer of the Insurance Council of BC.

IN THE RECENT B.C. SUPREME COURT LANDMARK CASE, THE COURT ISSUED ITS RULING THAT OCCUPANTS OF INSURED PROPERTIES ARE NAMED INSUREDS, THUS SOUNDLY REJECTING THE SOLE PREMISE OF PLAINTIFFS' SLAPP ACTIONS.

As thoroughly documented on this informational website, despite the fact that all of the Plaintiffs, various insurance brokers, agents and regulatory representatives had all confirmed the Defendant's legal status as a Named Insured, INTACT nonetheless filed two (2) SLAPPs (and threatens a third) against the Defendant, for the mere act of submitting a property insurance claim with his insurer, INTACT Insurance. For some unexplained, "slapp happy" reason, the Plaintiffs allege that Defendant's presentation of the documented facts, as well as supportive statutory, judicial and regulatory authority, constitutes defamation.

In his landmark ruling, in the case of Strata Plan VR 2213 v. Schappert (2023 BCSC 2080), the distinguished, Honourable Justice Coval, soundly rejects INTACT's premise that an occupant of an insured strata property is not a Named Insured.

In the Schappert case, Justice Coval clarified that individuals who normally occupy a strata lot, such as renters, tenants and owners, are Named Insureds under the strata's property insurance policy. This interpretation aligns with Section 155 of the Strata Property Act and emphasises the importance of recognizing the rights of occupants, authorized by the strata. A fortiori, in this case, the SLAPP Defendant was a long time Tenant of a property insured by INTACT.

Justice Coval's decision underscores the importance of adhering to legal precedents and ensuring that accusations be grounded in a thorough understanding of insurance law. It also highlights the broader implications of disputes involving insurance claims, strata corporations, and the rights of occupants. The ruling also reflects the objectives of the Strata Property Act, Section 155(b),ensuring fairness and consistency in the treatment of occupants under strata insurance policies. This contributes to a broader understanding of legal frameworks surrounding property rights, insurance, and the evolving dynamics of short-term rental arrangements.

Justice Coval's contributions extend beyond the courtroom. He has been actively involved in pro bono work, serving as vice-president of the British Columbia Access Pro Bono Society and coordinating the Court of Appeal roster program. His efforts in promoting access to justice earned him the prestigious Harry Rankin Pro Bono Award. Additionally, he has played a significant role in mentoring young lawyers and fostering a culture of pro bono service within the legal community.

INTACT's TWO (2) CIVIL ACTIONS AGAINST DEFENDANT ARE PRIMA FACIE SLAPPs

As minutely detailed on this informational website, the Plaintiffs INTACT and its personnel, Amanda Myers, Christa Rae Cordick and Michele Vincent, have filed two (2) SLAPPs against the Defendant, one of two whistleblowers, who had filed a formal Complaint against Claim Manager Amanda Myers, for the falsification and fabrication of a claims investigation of Defendant's property claim. The other whistleblower, INTACT Privacy Officer, Helen Cameron, had conducted an independent internal affairs probe, which exposed the Claims Manager's fraud. The courageous Privacy Officer is not a party to this SLAPP.

The telltale indication of the nature of the SLAPPs is that no Plaintiff claims or seeks any monetary or other damages; the only relief that these SLAPP Plaintiffs seek is the exact relief that Defendant has repeatedly offered to them, months prior to the filing of the SLAPPS, and repeatedly, subsequent thereto.

In a further effort to deprive Defendant of his freedom of expression rights, by way of attrition, INTACT has recently filed an Application for a provisional, interlocutory Order to temporarily deactivate this website, an absolute, needless squander of the Court's precious time and resources, since Defendant has repeatedly invited Plaintiffs to join him in compliance with Rule of Court 1-3, with its focus upon "proportionality".

As thoroughly documented herein, the Defendant has offered (1) to voluntarily remove from this website all indications of the names, job titles and all identifying information about the Plaintiffs (2) to surrender exclusive control of the website to Plaintiffs, control to be returned to Defendant within two weeks of trial (3) to surrender exclusive control of the website to Plaintiffs, to be altered at their sole discretion, but that all references to statutory, judicial and regulatory authority remain intact, etc. Plaintiffs rejected all offers, with their counsel's below 17 March 2025, disingenuously stating that "every word" on this website is defamatory, even the ruling by the Honourable Justice Coval, supra!

As documented on this informational website, in an ongoing effort to seek Plaintiffs' compliance with Rule of Court 1-3,the Defendant has rendered the following Offers:

1. AN OFFER TO PERMANENTLY REMOVE THE PLAINTIFFS’ NAMES AND JOB TITLES FROM THE WEBSITE, AN OFFER WHICH PLAINTIFFS SUMMARILY REJECTED.

2. AN OFFER TO PERMANENTLY REMOVE SPECIFIC STATEMENTS FROM THE WEBSITE, PER A LIST TO BE PROVIDED BY PLAINTIFFS, AN OFFER PLAINTIFFS SUMMARILY REJECTED.

3. AN OFFER TO TRANSFER EXCLUSIVE CONTROL OF THE WEBSITE TO PLAINTIFFS, ON THE SOLE CONDITION THAT THEY NOT DEACTIVATE SAME, AN OFFER WHICH PLAINTIFFS SUMMARILY REJECTED.

4. AN OFFER TO SURRENDER TO THE PLAINTIFFS EXCLUSIVE CONTROL OF THE WEBSITE, WITH THE ABILITY AND AUTHORITY TO REMOVE THEREFROM ALL STATEMENTS AND IMAGES, WHICH PLAINTIFFS, IN THEIR SOLE DISCRETION, SHOULD DEEM DEFAMATORY. PLAINTIFFS SUMMARILY REJECTED THIS OFFER, AS WELL.

16 MARCH 2025-

Whitelaw-Twining's Gavin Clark is the fifth lawyer to join the litigation fray, by the filing of an Application for injunctive relief. In violation of Rule of Court 1-3, with its emphasis upon proportionality, INTACT has elected to squander the precious time and resources of an already overburdened judicial system, for the precise relief which Defendant has offered, and Plaintiffs have rejected on several occasions, as documented on this website.

For almost four (4) years, INTACT has engaged in a fraudulent campaign to deny that any coverage for biohazards existed, either under its own policy or that of any other Scheduled Insurer of the subject risk-sharing BFL master policy. Plaintiffs have all participated in the spoliation, with Christa Rae Cordick as a primary violator of the Claimant's contractual rights, with her documented refusal to report the claim of the biohazard (which had caused injury) to the Lead or other Insurers.

An examination of the Application reveals materially perjured Affidavits by Plaintiffs Amanda Myers, Christa Rae Cordick and Michele Vincent, whose illicit activities have been thoroughly documented on this public interest website.

Moreover, an examination of materials referenced in the perjured Affidavits evidences INTACT's spoliation of material evidence of INTACT's ongoing wrongdoings. Such includes INTACT's intracompany correspondence of (1) coverage for Defendant's eviction defence hearing, (2) coverage for health issues sustained by Defendant's daughter, occupant of the bedroom window above the infested pigeon roost, (3) extensive coverage accorded by numerous other Scheduled Insurers of the comprehensive, risk-sharing BLF policy, as well as (4) INTACT's bad faith refusal to apprise the lead Insurer Zurich of the numerous issues. Plaintiff Christa Rae Cordick's perjured Affidavit is of her recurrent lies that the Defendant had occupied the pigeon roost depicted on this website; that the Provincial court had dismissed the case, with a finding that the the Defendant was not a Named Insured. The court records evidence the fact that the Court dismissed the action for lack of injunctive relief jurisdiction, with no finding of that the Defendant was other than a Named Insured! Other incidents of Plaintiffs' falsehoods include the denial that each of them had declared the Defendant's legal status as a Named Insured.

The issues are far too complex to be addressed at a provisional, Injunctive Relief hearing, and in egregious violation of the spirit of Rule of Court 1-3, with its emphasis upon proportionality.

Therefore, as required by Rule 1-3, in order to assuage the Plaintiffs concerns, however ill-founded, and to avoid the wasteful expenditure of the Court's precious time and resources, Defendant hereby offers to transfer exclusive control of this website, with the ability of Plaintiffs to remove all instances of identifying information and images therefrom, pending the assignment of the first trial date, at which time control would be relinquished to Defendant, subject to the Court's ruling, upon trial.

In such event as Plaintiffs should reject Defendant's Offer, and insist upon violation of Rule 1-3, Defendant will seek costs and other punitive measures.

AN AFFRONT TO THE COURT, PLAINTIFFS INSIST UPON THE WANTON SQUANDER OF ITS PRECIOUS TIME AND RESOURCES, IN THEIR FRIVOLOUS APPLICATION FOR AN INTERLOCUTORY ORDER TO DEACTIVATE THE ENTIRETY OF THIS INFORMATIONAL WEBSITE. PLAINTIFFS DISINGENUOUSLY CLAIM THAT "EVERY WORD AND IMAGE" [INCLUDING STRATA PROPERTY ACT § 155(B), AND JUSTICE COVAL'S LANDMARK DECISION] ARE DEFAMATORY.

PLAINTIFFS NEED TO UNDERSTAND THAT DEFAMATION DOES NOT INCLUDE FACTS, STATUTORY AND JUDICIAL AUTHORITIES, THAT INTERDICT THEIR ILLICIT ACTIVITIES.

12 MARCH 2025-

The gravamen of INTACT's Complaint is that the Defendant submitted an insurance claim with INTACT, under the false pretence of being an insured. The Honourable Justice Coval of the BC Supreme Court, where INTACT's Complaint is pending ruled, in the case of Strata Plan VR 2213 v. Schappert, 2023 B.C.J. no. 2272, 2023 BCSC 2080, as well as the Strata Property Act Section 155(b), have judicially and statutorily determined Defendant's legal status is that of a Named Insured.

07 MARCH 2025-

INTACT CHIEF LEGAL OFFICER FRÉDÉRIC COTNOIR

Mr. Cotnoir is responsible for Intact's legal, compliance, internal audit and corporate secretarial functions. Over the years, he has been debriefed as to the issues, documented on this public interest website. He can no longer afford the luxury of ignoring the following legal and regulatory entanglements, which have festered under his lax watch. The list is not exhaustive:

1. INTACT Claims Manager Amanda Myers based an important coverage denial upon a false allegation that a Named Insured had triggered certain exclusionary language of a property liability policy. As a lawyer, Mr. Cotnoir would know that a property liability policy of a Strata Corporation, is jointly funded by Owners thereof. Tenants of Owners pay for such amenities by way of rental payments. Such rental income goes toward covering the Owner's costs related to the property, which includes strata fees, mortgage payments, maintenance, and insurance premiums. INTACT's specious position that the Named Insured Tenant had never funded his status is contrary to the facts and fundamentals of insurance law, and a stark measure of INTACT's and Attorney Beckmann's relentless disingenuousness!

2. When the Named Insured Claimant created this public interest website, in order to attract the serious attention of the facts of the matter, Mr. Cotnoir received actual and constructive notice that INTACT had engaged the legal services of Whitelaw-Twining Partner Nigel Beckmann, head of the firm's Insurance Law and Defamation departments. The legal, regulatory, ethical, moral entanglements that Attorney Beckmann had created, nurtured and refuses to resolve, is adequately documented on this website, and will not be further summarised.

3. INTACT's Ombuds[wo]man Michele Vincent acknowledged the Named Insured's formal Complaint against Claim Manager Amanda Myers' fabricated "claims investigation", by assignment to INTACT's Claims Experienced Team investigators. However, as part of INTACT's elaborate cover-up, Vincent later ordered the investigators to cease and desist further enquiry and release of its findings, in violation of INTACT's internal protocol, and violation of Section 80.3(1) of the Financial Institutions Act.

In his role as Chief Legal Officer, Mr. Cotnoir is ultimately responsible for INTACT's veritable perfect legal storm. Perhaps he would step in, at this point, and practice CEO Brindamour's "Living Our Values" initiative, or at least that the initiative be renamed "Denying Our Values"!

06 MARCH 2025-

ANNOUNCEMENT OF THE ESTABLISHMENT OF A BMO COMMERCIAL TRUST ACCOUNT, IN THE AMOUNT OF ONE HUNDRED THOUSAND DOLLARS ($100,000), WITH INTACT CHIEF LEGAL OFFICER FRÉDÉRIC COTNOIR, OR HIS DESIGNATED REPLACEMENT, AS TRUSTEE.

This offer is made voluntarily, with the transparent purpose of encouragement of evidence-based clarity, regarding the subject matter outlined below. The following terms and conditions apply:

1. Objective: This Offer is specifically responsive to INTACT Insurance's Claims Manager, Amanda Myers' herein posted letter of 30 September 2021, wherein she denied coverage to a Claimant, whose legal standing she had confirmed as a Named Insured of INTACT. According to her letter, the basis for the denial was her allegation that the Named Insured had "possessed", "occupied" and "used" a certain area of his residence. 2. In order to qualify for the $100,000 donation, participants must provide factual, verifiable evidence supporting INTACT's Claims Manager Amanda Myers' aforementioned statement. The $100,000 will be paid, upon the presentation of verifiable evidence that the Named Insured had ever even had physical access to the area referred to in Claims Manager Myers' letter. The Offer is extended, but not limited, to all personnel of INTACT Insurance, including Claims Manager Amanda Myers, Attorney Christa Rae Cordick and Ombuds[wo]man Michele Vincent.

3. Verification of Evidence: All evidence submitted must be lawful, factual, and verifiable. The Administrator of this website reserves the sole discretion to evaluate the validity and relevance of the evidence submitted.

4. Eligible Charities: Donations will be made exclusively to registered and legitimate public charities of the participant’s choice. The participant must provide the name and details of her/his selected charity, for verification.

5. Legality: All activities and evidence submissions must comply with applicable laws and regulations. Any unlawful or unethical conduct will result in disqualification from this offer.

6. No Liability: The Administrator is not responsible for any disputes, misunderstandings, or issues arising from this initiative. This offer does not constitute an endorsement of any particular charitable organisation.

7. Duration of Offer: This offer is valid from 06 March 2025 until 05 March 2026. In the event that no bona fide submission shall have been conveyed by the end of said period, the $100,000, plus all accrued interest, shall be refunded to the Settlor. 8. In strict transparency, all claimed evidence sought must be submitted to joint intermediaries Nigel Beckmann, Esq. Partner of Whitelaw-Twining and counsel for INTACT, at 2400 - 200 Granville Street Vancouver, BC V6C 1S4, Canada. Phone 604.682.5466, Telecopier 604.682.5217. Email: nbeckmann@wt.ca, OR Ryan Darby, Freedom of Information Privacy Officer of Whitelaw-Twining, (same address as above), Phone 604.891.7214, Telecopier 604.682.5217. Email: rdarby@wt.ca.

The Settlor of the charitable trust respectfully invites and awaits notice from Messrs Cotnoir, Beckmann and Darby, for formal confirmation of their designated roles.

04 MARCH 2025

INTACT's hypocritical "Living Our Values" initiative is exposed by the reality that upper managerial elements of the company, the rogue among its personnel, and its legal counsel continue to perpetrate intimidating, bad faith, unethical, criminal, defamatory and other frauds, torts and breaches of contract, on a national scale.

As abundantly documented on this public interest website, INTACT has squandered tens of thousands of dollars of stakeholders' capital, to INTACT's lawyer at Whitelaw-Twining DWF, in a fraudulent attempt to avoid conducting a standard, legitimate claims investigation, to replace the fabricated version, contrived by Strategic Team Leader Amanda Myers, documented in her hereinbelow letter of 30 September 2021.

Special recognition is warranted of the bold efforts of INTACT's Privacy Officer, Helen Cameron, whose professionalism and devotion to INTACT's public image led her to conduct her own, independent, internal affairs probe, which exposed Amanda Myers' fraud. Privacy Officer Cameron's said findings, as announced in her letter of 19 January 2024, are displayed on this website.

03 MARCH 2025- OTTAWA'S HOUSING CHARITY SALUS HAS FILED A $55,000,000 LAWSUIT AGAINST INTACT INSURANCE, AFTER THE COMPANY TRIED TO FORCE THE HOUSING CHARITY INTO TAKING MILLIONS LESS THAN THEY ARE RIGHTFULLY OWED, LEAVING 40 PEOPLE WITH SEVERE AND PERSISTENT MENTAL ILLNESS IN SHELTERS.

Mark MacAulay, CEO of Ottawa Salus stated:

“For nearly a year and a half, INTACT has operated in bad faith – trying to bully and force us into taking $4.3M less than we’re rightfully owed.” They don’t care that it could cripple our finances. They don’t care that it will keep 40 people in shelters and struggling on the street during a housing emergency. They don’t care at all. So we’re taking them to court. We’re going to make them pay up.”

05 MARCH 2025-

INTACT INSURANCE's ACTIONS AGAINST THE YELLOWKNIFE WOMEN'S SOCIETY

Bree Denning, Directress of the Yellowknife Women's Society has reported that Intact Insurance, insurer of the shelter provided by the Yellowknife Women's Society, had "reneged" on its coverage and gave the society 30 days to find a new insurance company. Denning said Intact didn't provide a reason but the society is currently working on getting a new insurer for the building.

PLAINTIFFS CONTINUE TO ABUSE THE BC JUDICIAL SYSTEM, IN AN ATTEMPT TO FINANCIALLY BURDEN THE DEFENDANT OF THEIR SLAPPs, WITH A FRIVOLOUS APPLICATION FOR THE PRECISE PROVISIONAL RELIEF THAT DEFENDANT HAD OFFERED ON NUMEROUS OCCASIONS.

In a recent decision from the Supreme Court of British Columbia (Mawhinney v. Stewart, 2023 BCSC 419), Justice Baker awarded full indemnity costs to the defendant, who successfully brought an application to dismiss the plaintiffs’ action for defamation under British Columbia’s anti-SLAPP (Strategic Lawsuits Against Public Participation) legislation.

If an action is dismissed under the Protection of Public Participation Act, S.B.C. 2019, c. 3 (PPPA), a successful defendant should receive costs on a full indemnity basis. That is the starting point, although the court maintains judicial discretion to make a different costs award in appropriate circumstances. In exercising this discretion, the court will consider the intention of the full indemnity starting point, which is to discourage strategic lawsuits against public participation (SLAPP suits).

Section 7 of the PPPA expands the costs options available to the court on dismissal applications brought under the act. Under British Columbia’s Supreme Court Civil Rules, the court is not authorized to make full indemnity costs awards. However, s. 7 of the PPPA states that if the court makes a dismissal order, the successful defendant is entitled to costs on a full indemnity basis unless the court considers that assessment inappropriate in the circumstances.

The Hon. D. Eby discussed this costs provision in the PPPA at the committee stage:

There’s a recognition within this bill, and generally around these kinds of lawsuits, of an imbalance of resources most typically in these kinds of lawsuits. In fact, typically, one of the defining features of these lawsuits is that imbalance of resources between the plaintiff and the defendant. So this recognizes that.

What we wanted to do with both of these provisions, subsections 7(1) and 7(2), was to give the court a presumption. The presumption is that if someone is successful in this application, they get full costs on an indemnity basis.

Conclusion

This case serves as a warning for would-be plaintiffs in actions designed to silence one’s critics. Even if the contemplated claim has substantial merit, the action may be dismissed at an early stage, and if it is, a significant adverse costs award will likely be made.

The Supreme Court of Canada released its latest decision interpreting anti-SLAPP legislation in Canada. A 6-1 majority of the Court in Hansman v Neufeld, 2023 SCC 14 restored an order dismissing a plaintiff’s claim under British Columbia’s anti-SLAPP legislation. The Court’s decision centered on the part of the analysis that calls for the balancing of the public interest in protecting the defendant’s impugned expression against the plaintiff’s right to protect their reputation. The Court had specific reference to Charter jurisprudence under ss. 2(b) and 15(1) in determining the level of protection that should be afforded to certain expressions. In particular, where the impugned expression is “counter-speech” intended to respond to ignorant or harmful expressions against a vulnerable or marginalized group, that may weigh more heavily in the balancing exercise in favour of protecting that speech.

24 FEBRUARY 2025

صبر تلخ است ولیکن بر شیرین دارد

Future public interest articles will include how Whitelaw-Twining's Partner's documented publication of correspondence to various INTACT Insurance personnel (accusing a confirmed Named Insured of INTACT of not being an Insured, and of submission of a property claim under the false pretence of being an Insured) constitutes the tort and criminal offence of defamation.

23 FEBRUARY 2025 *BEST DEFAMATORY LAWYER IN CANADA® (2024)

21 FEBRUARY 2025 THE FULL DISSERVICE WHITELAW-TWINING LAWYER HAS MISGUIDED HIS CLIENTS INTO YET ANOTHER EGREGIOUS CONFLICT OF INTEREST, INADVISABLY SACRIFICING ALL OF HIS CLIENTS' INTERESTS, IN AN EFFORT TO AVOID PUBLIC INTEREST CRITICISM OF HIS FIRM.

In the below email from Plaintiffs' Whitelaw-Twining Partner assures that Plaintiffs Amanda Myers, Christa Rae Cordick and Michele Vincent (none of whom has ever identified a specific instance of defamation on the website) have formally rejected the Offer to remove all traces/vestiges of their identities (names, job titles and all other identifiers) therefrom. The conflict of interest has been created by the artful conflation of his Clients' interests with those of Whitelaw-Twining. He defamatorily alleges that this website, as well as that in litigation, OFFENCELAWYERSREPORT.COM (both websites) have caused damages to (1) his Clients and to (2) his firm! This "2 for 1" modus operandi will assure that the case proceed to trial, and even in such regard, the Plaintiffs' counsel has been uncooperative.

The deep-pocketed INTACT's rogue personnel have expended herculean efforts to simply avoid the ab initio rescission of its Strategic Team Leader's fraudulent decision, ostensibly based upon a claims investigation that INTACT Privacy Officer Helen Cameron had determined had never been conducted!

In another link in the concatenation of INTACT's bad faith measures, Whitelaw-Twining Privacy Officer, Ryan Darby has ignored the below OIPC Freedom of Information request.

The below Complaint has been served and lodged with the OIPC.

19 FEBRUARY 2025 Perhaps the Plaintiffs' Lawyer should familiarise himself with the Protection of Public Participation Act of BC.

20 FEBRUARY 2025 AN EXTRAJUDICIAL RESOLUTION OF THE LITIGATION

As reflected in the below email, the Plaintiffs demand that the website, in its entirety, be removed from the internet. Although these Plaintiffs have all soundly rejected all prior Offers, Defendant remains receptive to any demand, by any Plaintiff, with the exception of the permanent deactivation of the entire site.

18 FEBRUARY 2025 A point worthy of mention is the BCSC's Rule 1-3, which emphasises the importance of proportionality in legal proceedings. Thus, Court aims to ensure that the time, expense, and complexity of a case be proportionate to the matters at stake. That which is at stake in these SLAPP actions is the Plaintiffs' malicious, abusive of process insistence that this website, in its entirety, be removed from the internet (notwithstanding the fact that Defendant had offered to remove from the website the names, job titles; i.e. all information identifying the Plaintiffs, and had even offered to cede permanent, exclusive control of the website to the Plaintiffs).

As scrupulously documented on this public interest website, Whitelaw-Twining's Partner continues his relentless frustrations of the very spirit of Rule 1-3. By example, Defendant had proposed a discovery plan, which would comply with the spirit of Rule 1-3, "to promote fair and efficient resolution of disputes by balancing the resources and efforts involved in the litigation process". Defendant's proposal was to streamline discovery to simple, limited interrogatories. However, Whitelaw-Twining's Partner formally rejected the suggestion, instead insisting upon formal 'examinations for discovery', calculated to greatly maximise Defendant's expenses, for travel expenses of the Plaintiffs, as well as the attendance of a court reporter. Defendant offered to submit to an examination for discovery, at Plaintiffs' lawyer's convenience.

Although a Court Order will be required, at which costs and other sanctions will be sought by Defendant, the below are the draught Interrogatories of Plaintiffs Amanda Myers, Christa Rae Cordick and Michele Vincent.

Interrogatories to INTACT in house lawyer, Christa Rae Cordick, who testified to the Court that Defendant had occupied the pigeon roost, displayed herein.

Interrogatories to "Strategic Team Leader" Amanda Myers, who sued the whistleblower Defendant for exposing her fraudulent practices.

Interrogatories to INTACT Ombudsman/Complaint Officer, who ordered INTACT's Customer Experience Team to cease and desist its ongoing probe of Amanda Myers' falsified claims investigation, as detailed herein

It is respectfully requested of Plaintiffs' lawyer that he arrange for a complimentary, five minute, pro bono consultation with another partner of Whitelaw-Twining, John Vamplew, who authored an informative article, aptly entitled "The New Supreme Court Civil Rules: Implications for Claims Handlers", which addresses the numerous abuses of process, that Plaintiffs have been aided and abetted to pursue in the two (2) SLAPP actions.

15 FEBRUARY 2025 Whitelaw-Twining's not so subtle assurance that Plaintiffs Amanda Myers, Christa Rae Cordick and Michele Vincent (none of whom has ever identified a specific instance of defamation on this website) have formally rejected the conciliatory Offer to remove all traces/vestiges of their identities (names, job titles and all other identifiers) from this website. Defendant proudly RSVPs this invitation to trial.

14 FEBRUARY 2025 The Plantiffs' lawyer from Whitelaw-Twining has written to the the Administrator of this website, a formal rejection of the Offers to remove all names, job titles, positions and other identifying information herefrom. Thus, no further attempts by Defendant, to extrajudicially resolve the issues, will be forthcoming.

In preparation for trial, the state of this public interest website, prior to this day, has permanently been locked. In the days to come, the website will focus upon a more comprehensive, factual exposure of the nature of the illicit acts and omissions of Plaintiffs Amanda Myers, Christa Rae Cordick and Michele Vincent.

AS CONFIRMED BY THEIR ATTORNEY (IN HIS ABOVE EMAIL OF 13 FEBRUARY 2025) PLAINTIFFS AMANDA MYERS, CHRISTA RAE CORDICK AND MICHELE VINCENT HAVE ALL REJECTED THE OFFER TO REMOVE FROM THIS PUBLIC INTEREST WEBSITE, ALL TRACES OF INFORMATION THAT COULD IDENTIFY THEM.

13 FEBRUARY 2025 As fully detailed on this public interest website, Whitelaw-Twining's Partner authored the letter of 07 December 2023, wherein the Partner defamatorily (1) falsely accused a Claimant of an INTACT Insurance policy of not being an insured, and (2) of submitting the property insurance claim, under false pretences.

The Whitelaw-Twining Partner published the defamatory letter to various departments of the Insurer.

The detailed history of the Partner's SLAPP lawsuits against the Claimant has been fully documented hereupon, and the defamed Defendant had offered to allow Whitelaw-Twining, its Partner and all personnel, whose names appear on this website, the option to remove such herefrom. The below examples illustrate the effect.

12 FEBRUARY 2025 Whitelaw-Twining's Partner, committed a tactical error (i.e. miscalculation in the resolve of a mere civilian, in pro se Defendant) with the Partner's letter of 07 December 2023, wherein he defamatorily accused the Defendant of (1) deceiving viewers of this website, and (2) submission of a property claim with INTACT Insurance, under the false pretence of being an insured.

Currently, the herein Offer remains unaccepted., despite its having been amended to include Whitelaw-Twining, its Partner and all personnel, whose names appear on this website.

08 FEBRUARY 2025

In yet another effort on the part of Defendant to comply with BC Supreme Court Rule 1-3, Defendant hereby offers, subject to the above countdown, forever to remove from this website the name, as well as job title, of any Plaintiff who agrees to discontinue her role in the subject litigation against Defendant. Defendant thanks the Plaintiffs' counsel for timely conveying this Offer to each Plaintiff.

THIS OFFER IS RENDERED SOLELY TO COMPLY WITH THE SPIRIT OF COURT RULE 1-3, AND NOT AS AN ADMISSION THAT ANY ASPECT OF THE WEBSITE IS, OR EVER HAS BEEN DEFAMATORY, OR OTHERWISE UNTRUE.

11 FEBRUARY 2025

Plaintiffs' lawyer, Nigel Beckmann of Whitelaw-Twining, has finally responded, however opaquely, to Defendant's yet unexpired Offer. Attorney Beckmann argues that examination, at trial, as to why none of the Plaintiffs accepted either of the Offers, will be opposed, on the basis of the privilege of "settlement discussions". Defendant respectfully disagrees with Mr. Beckmann, but in any event, the acceptance of the current, unexpired Offer, would obviate the necessity of an estimated more than ten (10) days trial, per Court Rule 103.

NO JUDGE OF THE BCSC WOULD CIRCUMVENT THE SPIRIT OF RULE 1-3, BY RULING THAT A PROTRACTED TRIAL BE PREFERABLE TO AN EXTRAJUDICIAL RESOLUTION.

If Mr. Beckmann has actually conveyed the Offers to his Clients, obviously he, or any member of Whitelaw-Twining, could easily guide each Plaintiff, to permanently resolve all issues of the gravamen of the SLAPP actions gravamen, "defamation".

Witn all due respect to Mr. Beckmann, although the prospect of an estimated ten (10) trial, with testimony of various personnel of Plaintiff, may seem a lucrative option, with a deep-pocketed Insurer Plaintiff (whose personnel have engaged in criminal acts and omissions, as documented on this public interest website) unless individual Plaintiffs are insistent upon being examined at trial, perhaps they should be notified of the Offer, as well as the legal implications of their resultant insistence of public exposure of the facts.

Although Plaintiffs' thus far absence of a response speaks for itself, , Counterproductive strategy: INTACT’s lawyer rejects all of Defendant’s Offers, ever-insistent that the entire website is defamatory; only deactivation of the website be acceptable. However, this public interest website has always contained factual information, such as that highly complimentary of CEO Charles Brindamour, the consummate executive actuarial, under whose superb leadership, the company has achieved remarkable success. It is incomprehensible that Monsieur Brindamour should knowingly allow the arrant gaspillage of shareholders’ capital, in the futile pursuit of the self-destructive, moral, ethical, legal and statutory entanglements, in which the company currently finds itself, with no end in sight!

09 FEBRUARY 2025

An Offer to remove the names of Plaintiffs (Amanda Myers and Christa Rae Cordick) was previously rejected, although their Whitelaw-Twining lawyer had initially expressed interest therein.

In one last effort by Defendant to comply with Rule of Court 1-3, the current Offer includes Plaintiff Michele Vincent, and the removal of all job titles, as well.

UPON EXPIRY OF THE BELOW UNACCEPTED OFFER, PER THE COUNTDOWN, IT WILL NEVER AGAIN BE RENDERED.

Email of 02 December 2024 - Defendant's Offer to Plaintiffs Amanda Myers and Christa Rae Cordick

Email of 02 December 2024 - Plaintiffs' lawyer's response to Offer

Page 2 of Amanda Myers' letter of 30 September 2021 -CURRENT IMAGE

Page 2 of Amanda Myers' letter of 30 September 2021 -UPON TIMELY ACCEPTANCE OF OFFER

THE BELOW 2 IMAGES REPRESENT AN EXAMPLE OF THE NATURE OF THE DELETIONS TO THIS WEBSITE. THE OFFER IS AVAILABLE TO EACH INDIVIDUAL PLAINTIFF.

07 FEBRUARY 2025

Open letter to Whitelaw-Twining DWF Group, since the Partner selectively ignores important correspondence.

Per the below link to the Partner's email of 03 February 2025, he summarily states that the entirety of the subject website is defamatory, without ever citing even one specific example (he has never so cited). He again threaten a Motion for Injunctive Relief, to have this entire website deactivated.

In an effort solely to comply with the spirit of Court Rule 1-3, and certainly not of intimidation, Defendant provides the below links, as labelled. The Partner's unconditional, summary threat to "shut down" or "take down" this entire cite, which includes citations of oppositional statutes and case law, such as a citation of the Strata Property Act § 155(b), as well as the ruling of the Honourable Justice Coval of the BC Supreme Court, matters of factual, even worthy of judicial notice, and by no means subject to removal from this website.

As scrupulously documented on the website, Whitelaw-Twining's Partner continues either to conflate or confuse the legal distinction between defamation and inconvenient, oppositional facts.

06 FEBRUARY 2025

THIS PUBLIC INTEREST, EXPOSITORY WEBSITE IS REPLETE WITH PRECISE INFORMATION AND DOCUMENTATION, REGARDING A VERITABLE PERFECT LEGAL STORM, WHICH ENSUED WHEN A WHITELAW-TWINING PARTNER, OUT HOUSE COUNSEL RETAINED BY INTACT INSURANCE, SENT THE BELOW DEFAMATORY LETTER, FALSELY ACCUSING A CLAIMANT OF INTACT OF SUBMISSION OF HIS CLAIM UNDER THE FALSE PRETENCE OF BEING AN INSURED. THE TOXIC EFFECT OF SUCH LETTER PROXIMATELY CAUSED THE BELOW-DOCUMENTED, INAUSPICIOUS CHAIN OF EVENTS, WHICH CULMINATED IN THE LAWYER'S FILING OF TWO (2) SLAPP ACTIONS AGAINST INTACT'S NAMED INSURED CLAIMANT, WITH THREE (3) OF INTACT'S DISILLUSIONED PERSONNEL AS PLAINTIFFS.

In particular, the below documented activity from 20 January 2025 to 05 February 2025, has critically distinguished INTACT's civil action (no. VLC-S-S-244577) from a common, personal insurance dispute, to a prima facie SLAPP action of significant public policy implications, which raise questions of broad legal significance.

Below is an email of 02 October 2024, from the Ministry of the Attorney General of BC. Within the past few days, there have been nascent indications that the AG's office may intervene in INTACT's SLAPP litigation, in view of broad involvement of the significant public policy implications, with issues of broad legal significance, such as statutory [INTACT’s Lawyer's acts and omissions have proximated extensive regulatory entanglements], by his refusal to comply with [Strata Property Act Section 155(b)] judicial [Plaintiffs refuse to apply the ruling 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, where INTACT's SLAPP is pending] ethical [Law Society of British Columbia Rule 2.02(5)] regulatory [Plaintiff Ombudsman Michele Vincent submitted material, false information to the BCFSA] judicial [Plaintiff Christa Rae Cordick provided false testimony to judges of the BC provincial court] criminal and administrative [Plaintiff Amanda Myers falsified an important Claims Investigation (according to INTACT's Privacy Officer, Helen Cameron]

Common sense ethics are specifically codified in Law Society Codes of Conduct, such as Rule 5.1-2(e) When acting as an advocate, a lawyer must not knowingly attempt to deceive a tribunal or influence the course of justice by offering false evidence, misstating facts or law, presenting or relying upon a false or deceptive affidavit, suppressing what ought to be disclosed or otherwise assisting in any fraud, crime or illegal conduct.

In Paulus v. Fleury, 2018 ONCA 1072, the Court of Appeal held that a factual misrepresentation by counsel in judicial proceedings could amount to deceit or civil fraud “in those circumstances where there would be no reasonable basis for the factual assertion; nor could it be said that the statement was made in good faith” (para 30).

Rule 5.1-2(a) states that a lawyer must not abuse the process of the tribunal by instituting or prosecuting proceedings which, although legal in themselves, are clearly motivated by malice on the part of the client and are brought solely for the purpose of injuring the other party.

Rule 2.01 (4) A lawyer who has unknowingly done or failed to do something that, if done or omitted knowingly, would have been in breach of this rule and who discovers it, must, subject to rule 2.03 (Confidentiality), disclose the error or omission and do all that can reasonably be done in the circumstances to rectify it. Rule 5.1-2(b) states that a lawyer must not knowingly assist or encourage any person to abuse the process of the tribunal by instituting or prosecuting proceedings which, although legal in themselves, are clearly motivated by malice on the part of the client and are brought solely for the purpose of injuring the other party.

Rule 5.1-2(c) states that a lawyer must not knowingly make a false or misleading statement to a tribunal. Rule 5.1-2(d) states that a lawyer must not knowingly present false evidence or assist in any fraud, crime, or illegal conduct.

C

Prior to Whitelaw-Twining Partner's malicious, defamatory letter, falsely accusing the Claimant of submission of the subject claim, under the false pretence of being an insured, Ombudsman Michele Vincent had confirmed the Claimant's status as an insured, by assigning his formal Complaint to the Customer Experience Team. However, in reliance upon the Whitelaw-Twining Partner's false accusations, Ombudsman Vincent not only abandoned the Claimant's Complaint, she became a Plaintiff in Whitelaw-Twining's SLAPP litigation.

Prior to Whitelaw-Twining's Partner's above letter, falsely accusing the Claimant of submission of the subject claim, under the false pretence of being an insured, in house Counsel Christa Rae Cordick had confirmed the Claimant's status as a Named Insured, in a legal pleading. However, in reliance upon the Whitelaw-Twining Partner's false accusations, Ms. Cordick not only abandoned the Claimant's Complaint, she became a Plaintiff in Whitelaw-Twining's SLAPP litigation.

Prior to Whitelaw-Twining's Partner's above letter, falsely accusing the Claimant of submission of the subject claim, under the false pretence of being an insured, Unit Claims Manager Amanda Myers and Claims Representative Breanna Gray had confirmed the Claimant's status as an Insured. However, in reliance upon the Whitelaw-Twining Partner's false accusations, Manager Amanda Myers became a Plaintiff in Whitelaw-Twining's SLAPP litigation. Representative Breanna Gray, a young lady of impeccable ethical and moral standards, refused to participate in Whitelaw-Twining' Partner's SLAPP initiative.

OPEN LETTER TO PLAINTIFFS' WHITELAW-TWINING LAW FIRM PARTNER:

04 FEBRUARY 2025

Below is an exact copy of an email from Plaintiffs' lawyer to the In Pro Se Defendant of Plaintiff's SLAPP litigation.

Although the legal points will be thoroughly addressed at trial, certainly not on this public interest website, the following highlighted portions of Mr. Beckmann's email are indisputably incorrect.

In violation of Rule of Court 1-3, Plaintiffs' lawyer rejected the Offer, which was to extrajudicially grant them the right to permanent, exclusive control of this website, to remove any material that any of them should find defamatory, for whatever reason. Plaintiff INTACT has personnel who are trained to modify websites under its control.

Plaintiffs' lawyer's statement that the Court could not order or enforce the Offer is disingenuous and specious, at best, because the terms of the Offer were designed to avoid any Court enforcement, or other involvement, whatsoever. The Offer was designed to allow the Plaintiffs unrestricted, free rein over the presentation of this website. The Court not only encourages extrajudicial resolutions, it has codified this requirement in Court Rule 1-3.

With his relentless, customary hyperbolic threats to institute more and more more litigation, Plaintiffs' lawyer claims to be preparing more Motions for Court Orders for injunctive relief, unless Defendant should abandon his rights to freedom of speech, by immediate deactivation of this entire public interest website.

Defendant's reliance upon fundamental civility from Plaintiffs' lawyer, expectation of compliance with basic ethical regulations of the Law Society of British Columbia, as well as honesty and good faith, have been to no avail!

PLAINTIFFS' ACTS AND OMISSIONS CONSTITUTE A PRIMA FACIE DEFINITION OF SLAPP LITIGATION

Furthermore, BC Premier David Eby, Attorney General Niki Sharma and the legislature of BC are diametrically opposed to the nature of abusive Plaintiffs, who pursue litigation, merely to deny Defendant's of the right of freedom of expression.

WORTHY OF NOTE IS THE ABOVE EMAIL TO THE WHITELAW-TWINING PARTNER, COUNSEL FOR INTACT AND ITS PERSONNEL. IN A FINAL ATTEMPT TO RESOLVE THIS MATTER EXTRAJUDICIALLY, PER RULE OF COURT 1-3, THE DEFENDANT REINSTATED THE LAPSED OFFER, NOW DUE TO EXPIRE PER THE ABOVE COUNTDOWN.

PER THE TERMS OF THE EMAIL, THE OFFER WAS EXTENDED TO INCLUDE PLAINTIFFS' COUNSEL MAîTRE NIGEL BECKMANN. IN THE ABSENCE OF TIMELY ACCEPTANCE OF THE SUBJECT OFFER (detailed below) THE PLAINTIFFS WILL AUTOMATICALLY FORFEIT PERMANENT, EXCLUSIVE CONTROL OF THIS WEBSITE.

THEREFORE, UPON OCCURENCE OF PLAINTIFFS' FORFEITURE, THE ADMINISTRATOR OF THIS WEBSITE HAS ELECTED TO PROMOTE ANOTHER PUBLIC INTEREST INITIATIVE - FREE SPEECH IN CANADA.

IN THE EVENT OF PLAINTIFFS' FORFEITURE, THE ADMINISTRATOR RESERVES THE RIGHT TO AUGMENT, OR OTHERWISE MODIFY THIS WEBSITE'S PAST POSTS OF THE HISTORY OF THE INTACT INSURANCE DISPUTE, THE SPECIFIC UNLAWFUL CLAIMS PRACTICES OF THE ALBERTA CLAIMS TEAM, THE FALSE, DEFAMATORY ACCUSATIONS RENDERED BY ITS LEGAL COUNSEL, AND OTHER TORTS AND BREACHES OF CONTRACT, AS DOCUMENTED HEREIN, WITHOUT PRIOR NOTICE TO ANYONE.

A PROJECT OF THE CANADIAN CONSTITUTION FOUNDATION

02 FEBRUARY 2025

The impending expiry of the subject Offer represents a tacit admission that despite having filed two (2) civil actions against the herein Claimant for defamation, none of the Plaintiffs, their Whitelaw-Twining lawyer, or anyone else has been able to identify any aspect of this website that she/he considers defamatory. This tacit admission will assume legal proportions, upon examination of each Plaintiff and their percipient witness lawyer, under oath, at trial.

As fully documented on this public interest website, INTACT's Privacy Officer, whistleblower Helen Cameron had discovered that Alberta Claims Manager Amanda Myers, had falsified the investigation of a claim, which had been assigned to her. The claimant, Administrator of this website, then filed a formal Complaint with INTACT Ombudsman, Michele Vincent, who assigned the Complaint to INTACT's Customer Experience Team. However, in an illegal act to conceal the legal and regulatory consequences of the Claims Manager's fraud, the Ombudsman instructed the Customer Experience Team never to release its findings of the claim manager's unlawful claims practices. Thus, after one year, seven months, the Customer Experience Team's Complaint investigation remains in perpetual suspension. When the INTACT Named Insured Claimant created this factual website, INTACT, rather than to rectify the Claims Manager's fraud, the company engaged a Partner of a Whitelaw-Twining (DWF Group), who, in an attempt to intimidate the Claimant into withdrawing his claim, falsely and defamatorily accused the Claimant of having submitted the claim under the false pretence of being an Insured. When the Claimant refused to succumb to the Lawyer's extortive threats, the Lawyer filed two (2) lawsuits against the Claimant, who looks forward to the trial, at which the Plaintiffs and their instigator, percipient witness Lawyer will all be examined, under oath, and their illicit involvement finally be subject to judicial scrutiny and exposure!

Of particular legal significance is the fact that despite the Lawyer's fabricated defamatory accusation, the fraudulent Claims Manager, Amanda Myers (nominated as a "Strategic Team Leader"), and the derelict, conflicted of interest Ombudsman/Complaint Officer Michele Vincent, and an in house INTACT Lawyer had all confirmed the Claimant's legal status as a Named Insured. However, in retaliation for the exposure of their illicit activities, they became plaintiffs in the defamatory out house Lawyer's aforementioned scheme.

03 FEBRUARY 2025 BREAKING DEVELOPMENT

AN EMAIL (which will be posted later) FROM PLAINTIFFS' LAWYER , NIGEL BECKMANN HAS BEEN RECEIVED. RATHER THAN TO AWAIT THE COUNTDOWN OF THE EXPIRY OF THE OFFER, MR BECKMANN HAS FORMALLY REJECTED THE OFFER.

PER THE TERMS OF THE OFFER, ALL PLAINTIFFS WOULD HAVE ASSUMED EXCLUSIVE, PERMANENT CONTROL OF THIS WEBSITE, WITH THE RIGHT TO REMOVE THE NAMES OF THE PLAINTIFFS ( "INTACT", "AMANDA MYERS", "CHRISTA RAE CORDICK" and "MICHELE VINCENT"), AS WELL AS ANY OTHER MATERIAL THAT THEY SHOULD DEEM DEFAMATORY, FOR ANY REASON !

IN EGREGIOUS VIOLATION OF COURT RULE 1-3, AND IN FURTHERANCE OF PLAINTIFFS' ABUSE OF PROCESS, AND INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS, PLAINTIFFS' LAWYER DEMANDS IMMEDIATE DEACTIVATION OF THIS ENTIRE WEBSITE (which includes published decisions of the BC Supreme Court, the Strata Property Act, many articles complimentary of INTACT CEO Charles Brindamour and "Living Our Values" initiatives, etc.)

WITH HIS RELENTLESS, CUSTOMARY HYPERBOLIC THREATS TO INSTITUTE MORE AND MORE MORE LITIGATION, PLAINTIFFS' COUNSEL CLAIMS TO BE PREPARING MORE MOTIONS FOR COURT ORDERS FOR INJUNCTIVE RELIEF, UNLESS DEFENDANT SHOULD IMMEDIATELY ABANDON HIS RIGHTS TO FREEDOM OF SPEECH, BY DEACTIVATION OF THIS ENTIRE PUBLIC INTEREST WEBSITE.

24 JANUARY 2025 - THE CREATOR OF THIS WEBSITE OFFERS COMPLETE CONTROL OF THIS WEBSITE TO INTACT INSURANCE AND THE OTHER PLAINTIFFS

In an ongoing commitment to ensure that this public interest website resolve the entire gravamen of the Plaintiffs' SLAPP action (court file No. VLC-S-S-244577), and to conserve the precious time and resources of the Court, the creator of this public interest website has elected to permit INTACT Insurance and the other Plaintiffs an additional ten (10) days, within which to accept the subject Offer, to allow any Plaintiff to remove all words and phrases on this website, that she should deem defamatory.

Furthermore, in order to assure Plaintiffs that the terms of the below, subject Offer be implemented, in the Plaintiffs' sole discretion, the creator of this website has offered to the Plaintiffs complete control of this website.

At the risk of repetition, the terms of the Offer refer to "any specific words, images, sentences or representations of the website that Plaintiffs should claim to be defamatory. No reason or explanation is required . This offer does not apply to summary demands or ultimata, such as those to strip the website of all content, even that complimentary of CEO Brindamour, etc."

Content Removal Instruction Tool

In order to facilitate the Plaintiffs' attempts to locate any alleged defamatory representations, all pages prior to 24 January 2025 are now locked in the condition, as exist as of this date, subject only to any instruction for revision, by any Plaintiff, per the terms of the Offer.

The purpose of this Offer, and its extension, is to conserve the precious time and resources of the Supreme Court, by obviation of the necessity to otherwise devote several days of trial time, regarding the gravamen of the Plaintiffs' SLAPP action - the allegation of the existence of defamatory representations on this public interest website.

The creator of this website thanks all Plaintiffs for their unanticipated cooperation.

28 JANUARY 2025

Although the Offer will remain open, per the above countdown, it will not be repeated upon its expiry. In the event that the Plaintiffs should fail to timely accept the Offer, it has been decided not to file the herein Motion to Dismiss, but to allow the SLAPP action to proceed to a full trial, at which the media, both traditional and social, can serve the public interest, by the public exposure of the facts of INTACT's egregious bad faith, oppressive and fraudulent practices, as detailed on this public interest website.

The Whitelaw-Twining offence lawyer continues to ignore all correspondence regarding the offer to the right. If he actually had communicated the Offer to his Clients (Claims Manager Amanda Myers, Counsel Christa Rae Cordick and Ombudsman Michele Vincent) do they prefer to be examined under oath at trial, to provide proof of their allegations of defamation?

Are the Plaintiffs aware of the Offer? Are they aware of the requirements of Court Rule 1-3?

28 JANUARY 2025

Plaintiffs' civil action is a prima facie SLAPP.

In an extremely conciliatory gesture, per the requirements of Supreme Court Rule 1-3, the Defendant had offered to the Plaintiffs exclusive, permanent control of the website, in order to allow them absolute latitude to remove all words and phrases from the website that they should believe defamatory. The Plaintiffs' concerted refusal to exercise complete control of the website evidences their ulterior motive to stifle free speech, rather than to seek genuine remediation. Such is characteristic of a SLAPP action. By refusing the Defendant's proactive solution, the Plaintiffs clearly aim to burden the court unnecessarily, contrary to Supreme Court Rule 1-3 of the BC Supreme Court Civil Rules.

Acceptance of the Defendant’s offer would have efficiently resolved the matter, without engagement of the Court, in a trial of at least 10 days!

PURSUANT TO COURT RULE 1-3, IN DEFENDANT'S ONGOING EFFORTS TO LIMIT THE DURATION OF EXAMINATION OF THE PLAINTIFFS AT TRIAL (WHETHER OR NOT THEY EXERCISE THE OPTION TO ASSUME EXCLUSIVE CONTROL OF THIS WEBSITE), ALL POSTS PRIOR TO 20 JANUARY 2025 HAVE BEEN LOCKED, AND WILL REMAIN SUCH.

IT IS RESPECTFULLY SUGGESTED THAT THE PLAINTIFFS MAKE PERIODIC, EXACT TIME-STAMPED COPIES OF THE WEBSITE, IN ORDER TO CONSERVE TRIAL TIME.

30 JANUARY 2025

As detailed below, the Defendant of Plaintiff INTACT's and its personnel's civil actions had made the below offer to permanently surrender exclusive control of this website to the Plaintiffs, subject to the terms thereof. On 21 January 2025, Plaintiffs' lawyer from Whitelaw-Twining rejected said offer, by rendering a counteroffer, to remove everything from this website (including facts complimentary of INTACT CEO Brindamour). Plaintiffs' lawyer's counteroffer was to effectively remove this website from the internet, with the result of a blank screen page. Pursuant to Supreme Court Rule 1-3, Rule 7-1 and Part V, Defendant has reinstated the Offer, which remains valid until the expiry of the above countdown. Never again will it be reinstated!

In the absence of Plaintiffs' timely acceptance of the Offer, at trial they will each be required to identify all instances of defamation on the website that justify their filing of the two (2) civil actions against the Defendant. If they should fail to meet this solemn threshold, then a civil action for abuse of process will be pursued against them, guaranteed!

In yet another assault upon fundamental human dignity and decency, the Representative of Whitelaw-Twining and DWF Group, has inflicted another round of emotional distress upon INTACT's Named Insured and his spouse, by refusing a simple Freedom of Information Act request for unprivileged personal information. Although only tangentially relevant to the gravamen of the subject of this public interest website, Whitelaw-Twining's intransigent refusal further frustrates RB's efforts to obtain a standard Customer Experience letter from INTACT. As detailed hereinafter, after more than three (3) years of judicial and regulatory entanglements, INTACT's Ombudsman, Michele Vincent has refused to issue such a letter, claiming that RB is unknown to the company; that no records of RB exist. Whitelaw-Twining receives remuneration from INTACT, by fomenting incessant litigation, requiring that the Freedom of Information Act Requestor incur the logistics and expense to engage the Supreme Court, in a Motion to Compel INTACT's compliance with legislation. Requiring a court Order to compel compliance with the Freedom of Information Act is yet another stark indication that Whitelaw-Twining's relentless tactics are calculated to generate even more of its tainted legal fees, with the sacrifice of open defiance of Court Rules, which are designed to conserve the Court's precious time and resources! The legislature's intent is the facilitation of Freedom of Information, without counterproductive, costly litigation!

20 JANUARY 2025 As the result of INTACT's relentless malicious, vexatious two (2) SLAPP actions and other bad faith and illegal acts and omissions, the Defendant of INTACT's two (2) SLAPP actions has decided not to rely upon the possibility of litigative support of BC Attorney General Niki Sharma, or BC Premier David Eby (both of whom are ardent supporters of anti-SLAPP legislative and judicial initiatives). Thus, in the event that INTACT, et al, Plaintiffs of its two (2) SLAPP actions, should fail to timely accept the Defendant's unconditional Offer to allow them to literally strip this public interest website of all words that they should consider defamatory (per the below, formal Offer), then the final version of the below draught of a Motion to Dismiss will be filed and pursued. Once the Motion shall have been filed, it will not be withdrawn, and will proceed to hearing! Under the circumstances, enhanced Costs will be sought!

21 JANUARY 2025

As detailed on this public interest website, it was the Whitelaw-Twining (DWF) Partner, who masterminded the two (2) SLAPP actions, after sending the initial letter that falsely accused the Defendant of submitting an insurance claim under false pretenses.

This same Partner, along with the Plaintiffs of the two (2) SLAPP actions (INTACT Insurance, Claims Manager Amanda Myers, in house counsel Christa Rae Cordick and Ombudsman Michele Vincent), have continued to ignore the below detailed, conciliatory Offer to grant them the right to strip the subject website of all words that any of them should believe defamatory. Although currently subject to the above countdown, this Offer was first made (several months prior to the filing of the two (2) SLAPP actions) to, and duly ignored by the same Whitelaw-Twining Partner, who had promised to convey Offers, ongoing for more than one year.

In the ongoing, good faith effort to resolve matters extrajudicially, the Offer had again been judicially made to Plaintiffs' Whitelaw-Twining Partner, on 27 July 2024, by way of the Responsive Pleadings to the Complaint, Section 1 of which is shown below.

Although always ignored by Plaintiffs, Defendant's Offer to each of them underscores the importance of balancing defamation claims with the protection of free expression, as enshrined in the Protection of Public Participation Act, SBC 2019, c 3 (the “PPPA”), commonly known as the anti-SLAPP legislative Act.

Therefore, upon expiry of the above countdown, it will be demanded of Plaintiffs (none of whom have thus far responded to the subject Offer, or requested an extension) to withdraw their two (2) SLAPP actions, in order to avoid enhanced costs and sanctions, for the soon-to-be confirmed tacit admission that the litigation that they instituted against the Defendant was intended solely to harass the Defendant, and not to prevent the alleged defamation! In the event that the Plaintiffs should continue to ignore the Offer that they revise the website, they should expect litigation against them, for malicious prosecution, and abuse of process, etc. The Plaintiffs' actual motives for their SLAPP actions has only recently been demonstrated; their tortious conduct was not foreseeable at the time of filing of the Cross-Complaint, which either will be amended, upon Motion, or a separate civil action be filed and pursued!

18 JANUARY 2025 WITHOUT PREJUDICE/RESERVATION OF RIGHTS

On 23 December 2024, INTACT's lawyer from Whitelaw-Twining fired off an email (excerpted below), wherein he threatened to widen the conflict to even more costly litigation, in the case before the BC Supreme Court (BCSC case no. VLC-S-S-244577). It is respectfully brought to INTACT's lawyer's attention that his threatened action is highly inimical to the strict policy objectives that the Court requires; to wit:

The British Columbia Supreme Court Civil Rules, such as Rule 9-1, include provisions designed to encourage litigants to seek extrajudicial remedies prior to filing formal Motions and Applications. These rules emphasize proportionality, early resolution, and case management, in order to ensure that disputes be resolved in a just, speedy, and inexpensive manner.

In accordance with the aforementioned authority, INTACT's Named Insured (RB) hereby offers to INTACT and its personnel, the unconditional option to revise this website, by the deletion or other method, of any and all specific words that INTACT and/or its personnel should claim to be defamatory.

Thus, upon INTACT's timely submission of a list of specific words to be revised, with an indication as to the name and position in the company occupied by the Requestor, the website will be revised to reflect such instruction. There is no requirement that any Requestor provide any explanation or justification, in order to exercise this option. Furthermore, once the website is modified, according the dictates of the Plaintiffs, it will be permanently locked and remain indefinitely as so revised.

This Offer applies exclusively to this website, and does not apply to any demands or ultimata to summarily deactivate the entire website, without reference to specific words.

THE SOLE PURPOSE OF THIS OFFER IS THE JUDICIALLY REQUIRED EFFORT TO RESOLVE LITIGATION, AND IS NOT TO BE CONSTRUED OR INFERRED AS ANY OFFER TO RESOLVE DAMAGES, OR ADMISSION THAT ANY ELEMENT OF THIS WEBSITE IS, OR HAS EVER BEEN DEFAMATORY. ANY AND ALL ATTEMPS TO USE THIS OFFER, IN ANY CIRCUMSTANCE OR EVENT, MUST BE ACCOMPANIED BY THIS DISCLAIMER.

QUOTE FROM INTACT CEO BRINDAMOUR

In an interview with insurance industry analysts, INTACT CEO Brindamour, the consummate actuarial, stated:

"To outperform the industry, Intact is focusing on data segmentation, claims management and investment in distribution". He added "to bolster data segmentation, Intact has invested massively in artificial intelligence to identify new variables. In claims management, Intact uses digital technology and is boosting in-sourcing of its processes" .

The sole purpose of this public interest website is to apprise CEO Brindamour of the dire need of his attention to the fact that his entire, reasoned approach to the above and others of his stated policy objectives, have been frustrated by the toxic intervention of INTACT's out-house counsel, as detailed herein. The issues that have arisen, due to the actions of such counsel include, but not by way of limitation:

1. Financial Impact: The legal fees associated with the acts and omissions are substantial (in excess of $50,000), diverting valuable resources from INTACT's core operations.

2. Reputation Damage: The negative publicity generated by acts and omissions has occasioned a potential erosion of customer trust and investor confidence.

3. Operational Disruptions: The legal challenges have required INTACT to allocate additional internal resources to manage these issues, thereby hindering progress on core strategic initiatives.

4. Regulatory Scrutiny: The involvement of regulatory bodies due to these legal problems has exposed INTACT to potential penalties and further scrutiny.

5. Internal Morale: The ongoing Alberta Claims Team's falsifications of claims investigations, as abetted by outside counsel, have created a negative work environment, affecting employee morale and productivity.

Below is a respectful suggestion to INTACT CEO Brindamour, as to how to assure that his salutary objectives be applied, some retroactively, in order to mitigate any future damage.

In the below email of 05 November 2024, INTACT's lawyer at Whitelaw-Twining threatened even more litigation against the Defendant of his SLAPP actions, in the event that the Defendant should post any defamatory commentary on social media websites, such as LinkedIn (a website known for its focus upon issues of public interest, in the professional sphere of influence). As documented, none of the Plaintiffs, nor the Whitelaw-Twining Partner, has been able to find any defamatory word, words, phrases, or other representation that any of them considers defamatory. Thus, any posts on LinkedIn, or other social media websites, that refer to or quote any representation of this website, have been proofread by INTACT and its personnel, to be free of defamation.

Prepare to see factual comments, subject to "likes", "dislikes" or other commentary.

23 JANUARY 2025

INTACT INSURANCE AND THE OTHER PLAINTIFFS HAVE ALREADY FAILED THEIR LEGAL BURDEN OF PROOF, AN ABSOLUTE REQUIREMENT OF THEIR TWO (2) SLAPP ACTIONS !

These recent posts serve as a dry run for the Plaintiffs' burden of proof events that will unfold, at trial. After several months of Defendant's open Offer to grant Plaintiffs INTACT Insurance, Claims Manager Amanda Myers, Counsel Christa Rae Cordick and Ombudsman Michele Vincent the unconditional right to strip the subject website of all words that any of them should believe defamatory, without need for reason, nor explanation, none of these Plaintiffs was able to cite even a single representation on this website, that they (in good faith or even in bad faith) believe to be defamatory.

In the view of the transparent nature of this website, if any Plaintiff should have an explanation, rebuttal or other comment, for her inability to find any examples of defamation, then immediately will such be prominently posted on this website.

This option is to assure absolute transparency, with rebuttals posted, prior to Defendant's only immediate option for the prevalence of truth and justice - social media. Thus, it is highly recommended that Plaintiffs assume a position, whatever it may be.

22 JANUARY 2025 DEFENDANT'S TRIAL STRATEGY OPTIONS

According to the Whitelaw-Twining Partner, his Clients, INTACT Insurance, Claims Manager Amanda Myers, Counsel Christa Rae Cordick and Ombudsman Michele Vincent have all formally rejected Defendant's herein Offer to grant them the unconditional right to strip the subject website of all words that any of them should believe defamatory, without need for reason, nor explanation. As the below email from INTACT's lawyer from Whitelaw-Twining confirms, with reference to this website, the Plaintiffs all "claim that every single word, image, sentence, and representation is defamatory".

Thus, as a trial strategy, Defendant may elect to forego a Motion to Dismiss INTACT's SLAPP actions, and instead allow the litigation to proceed, and then examine Plaintiffs Amanda Myers, Christa Rae Cordick and Michele Vincent as to why they pursued the litigation to trial, rather than acceptance of Defendant's offer to agree to the gravamen of their SLAPP action, by allowing them to take control of this website, with the removal of all words that they should deem defamatory, but leaving intact examples of their own correspondence to the Defendant, Strata Property Act Section 155(b), the 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 Supreme Court where their SLAPP action will be heard), citations of legislation, court filings, and even numerous, laudatory articles about Plaintiff INTACT and its CEO Brindamour and his "Living Our Values" noble initiative. It will be interesting to observe how the Defendants deem all of the foregoing to be defamatory, and the Court will not be particularly amused. The case has the potential of considerable future citation!

Although the Plaintiffs allege that "every single word, image, sentence, and representation is defamatory", a glance of this website reveals that more than 90% of its content is factual, such as correspondence authored and signed by each Plaintiff. Some matters are even worthy of judicial notice [such as the existence of Strata Property Act Section 155(b), and the 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 Supreme Court where Whitelaw-Twining's Partner filed the subject SLAPP action]. Other factual information on this public interest website includes citations of legislation, court filings, and even numerous, laudatory articles about Plaintiff INTACT and its CEO Brindamour and his "Living Our Values" noble initiative. Such content is complimentary, not defamatory, and certainly falls within the scope of protected free speech!

Whitelaw-Twining's Head of Defamation and Insurance Department has proven that his intransigent, cynical approach has no limit. Thus, Defendant's Motion to dismiss the Plaintiffs' SLAPP actions has been redraughted, subject to more revisions, and filed, when appropriate and without notice to the subject offence lawyer.

INTACT CEO CHARLES BRINDAMOUR, A RENOWNED ACTUARIAL, SHOULD HAVE BEEN CONSULTED, PRIOR TO INTACT'S DISASTROUS DECISION TO ASSIGN THE CASE, SUBJECT OF THIS PUBLIC INTEREST WEBSITE, FROM INHOUSE COUNSEL CHRISTA RAE CORDICK, TO OUTHOUSE COUNSEL WHITELAW-TWINING.

According to a comprehensive survey conducted by Bloomberg Law, 25% of legal matters are misclassified as high-value and assigned to "top-tier" firms, leading to vastly unnecessary costs. By correction of these imprudent misallocations, insurers would save up to $150,000 per million dollars of outside counsel expenditures.

Shareholders should take note that INTACT elected to ignore the advice of its inhouse counsel, Christa Rae Cordick, who repeatedly had advised INTACT's management of the legal status of the Claimant, as a Named Insured. In fact, Attorney Cordick had even filed a legal pleading, in formal confirmation of the Claimant's such legal status. However, outhouse counsel, Whitelaw-Twining's noncertified "Insurance Law Specialist", a Partner of the firm, repudiated Attorney Ms. Cordick's confirmation, and proceeded to falsely and defamatorily accuse the Claimant of having committed the crime of submission of his insurance claim with INTACT, under the false pretence of being an Insured. Whitelaw-Twining's Partner ultimately filed two (2) SLAPP actions (with threats of even more litigation) against INTACT's Named Insured Third Party Claimant. Curiously, Whitelaw-Twining's "Insurance Law Expert" is also listed as a "Defamation Defence Expert", although his role in this legal perfect storm case is that of a "Prosecutor of Defamation"!

Insurers rarely sue their own insureds, usually whenever the insureds submit false claims.

However, as in the case, subject of this public interest website, the fraudulent act was committed by INTACT's own Claims Manager, who falsified her own claims investigation, an illicit act uncovered as the result of an internal affairs investigation, conducted by INTACT Privacy Officer Helen Cameron, as announced in her letter of 19 January 2024.

As detailed herein, in a futile attempt to justify justification for accusing the Named Insured of an unlawful claim submission, Whitelaw-Twining's Partner has caused INTACT to violate the Strata Property Act § 155(b), and to deny the documented fact (herein letter of 30 September 2021) that Claims Manager Amanda Myers had defined the legal status of the Claimant as a Named Insured.

Such unethical conduct is referred to as "litigation by attrition"; a strategy of a well-funded party (INTACT) utilising financial resources to overwhelm and exhaust the less-funded opponent, forcing him to withdraw his claim, due to the high costs and prolonged nature of the legal process. INTACT's Named Insured cannot match INTACT's financial reserves and has only the truth, the facts and the law in his favour.

In retrospect, INTACT CEO Charles Brindamour may elect to adhere to his initiative of "Living Our Values", or at least to employ his finely honed actuarial prowess, in order to determine if Whitelaw-Twining's advice has served INTACT's interests, either in retrospect or in prospect.

Below is the excerpt of an email from a 23 December 2024 email from Whitelaw-Twining, which bemoans INTACT's expenditures of "more than $50,000" into Whitelaw-Twining's unreceptive coffers.

15 JANUARY 2025

WHITELAW-TWINING'S UNJUST ENRICHMENT IS THE LEGAL BASIS FOR ITS REQUIRED DISGORGEMENT OF ITS $50,000+ ILL-GOTTEN FEES

As precisely detailed on this public interest website, the genesis of INTACT Insurance's myriad legal, moral, ethical and regulatory entanglements is its legal advisors at Whitelaw-Twining's (hereinbelow) letter of 07 December 2023, wherein the a Partner of the firm materially falsified the facts and the law, the tort which is the gravamen of this public interest website.

RB, a shareholder of Intact Financial Corporation (IFC.TO), has informal standing to demand, and hereby so demands, that Whitelaw-Twining immediately refund the $50,000+ ill-gotten legal fees, back to his insurer, INTACT Insurance. Of course, the matter may be raised at the next shareholders' meeting, and in such event as Whitelaw-Twining should refuse to disgorge its fees, that matter will be broached thereat.

09 JANUARY 2025

If anyone from INTACT Insurance is interested in the facts and the law, its counsel, Partner of Whitelaw-Twining, recently sent an email to Named Insured Third Party Claimant RB, relevant parts of which are presented below. It is inconceivable that the head of Whitelaw-Twining's 'Insurance Law Department' could still propagate the myth that the claim was of the first person, and not the obvious third person, and after more than three (3) years, the Whitelaw-Twining Partner still renders such costly, incompetent legal advice!

When the claim against the Policyholder Strata Corporation was submitted, on the basis of damages arising from its failure to maintain an infectious external, ornamental pigeon roost (detailed hereinbelow), Alberta Claims Manager "Strategic Leader®" Amanda Myers incorrectly processed such as a first party claim, rather than the appropriate third party type. Ms. Myers refuses to reconsider her bad faith decision.

Incidentally, in the below email, Whitelaw-Twining's Partner is correct to state "if you suffered harm or losses, they were at the hands of others......." Those "others" to whom the Partner referred happen to be the Strata Corporation, a policyholder and named insured of INTACT.

02 JANUARY 2025

BRIEF SUMMARY OF INTACT'S SLAPP ACTION AGAINST ITS OWN NAMED INSURED

Although the subject of this public interest website focuses upon various incidents of INTACT Insurance's unlawful claims practices, the most recent developments are the retaliatory filings of two (2) separate SLAPP actions by its legal counsel (a Partner of the law firm of Whitelaw-Twining), who falsely and defamatorily accused a confirmed Named Insured of his Client INTACT, of submission of an insurance claim with the company, under the false pretence of being an insured of INTACT.

The gravamen of Whitelaw-Twining's Partner's malicious SLAPP actions also relates to INTACT's Named Insured's public interest promotion of the consumer protective, ethical Rules and Regulations of the Law Societies of BC, Ontario, Alberta and other jurisdictions, as well as the Canadian Bar Association.

As evidenced by detailed documentation on this website, INTACT's lawyer and his firm, Whitelaw-Twining are in egregious violation of the Law Society of Ontario and other jurisdictional Rules, which protect the public against deceptive practices of listings in third party ranking systems, by the firm's false claims of rankings in ‘Best Lawyer’ and ‘Canada’s Best Lawyers' publications!

There exists an issue, apart from that of puffery; false claims of recognition and awards on the Whitelaw-Twining website. By example, the following claim is made of a certain Partner's "expertise", in a myriad of disciplines, including "defamation" and "insurance law". The firm maintains offices in Alberta, BC, Ontario and Montréal (a topic to be explored in future reports).

In the Law Society of Alberta, Code of Conduct 4.3-1, it is written:

[2] A lawyer who is not a certified specialist is not permitted to use any designation from which a person might reasonably conclude that the lawyer is a certified specialist. A claim that a lawyer is a specialist or expert, or specializes in an area of law, implies that the lawyer has met some objective standard or criteria of expertise, presumably established or recognized by a Law Society. In the absence of Law Society recognition or a certification process, an assertion by a lawyer that the lawyer is a specialist or expert is misleading and improper.

THE ABOVE VIOLATION IS BUT ONE OF NUMEROUS!

SPECIAL NEW YEAR'S REPORT

ISSUES INHERENT IN INTACT INSURANCE'S ANTICIPATED "ADVICE OF COUNSEL" DEFENCE

But for its own tortious acts and omissions, INTACT's anticipated "advice of counsel" defence could be a powerful tool, but it comes with certain conditions. For this defence to be valid, or in this case, partially valid, INTACT must demonstrate that its personnel, (the Plaintiffs in the subject SLAPP action/Cross-Defendant in the Cross-Complaint), acted in good faith based on the legal advice received from the Partner of Whitelaw-Twining, and that they disclosed all relevant facts to their counsel. If it turns out that Whitelaw-Twining misrepresented the expertise of the Partner, then INTACT's reliance upon that advice might not be considered reasonable.

In such event, if INTACT could reasonably have known about the misrepresentation, it could undermine its defence. INTACT's personnel would need to show that they had no knowledge of the counsel's lack of expertise and that they had fully disclosed all pertinent information. Although INTACT's personnel had engaged in fraudulent coverage denials, to some extent Whitelaw-Twining's Partner's false, defamatory letter of 07 December 2023, infra, creates comparative legal exposure for INTACT and Whitelaw-Twining, at the very least.

To further complicate this 'perfect legal storm', Whitelaw-Twining's Partner has set himself up to be a percipient witness at the trial hereof, and a motion to disqualify him will ensue.

As documented throughout this public interest website, Whitelaw-Twining's campaign of advertising, violative of the Law Societies of BC, Alberta, Ontario and Québec, proximately caused the damages claimed in the Cross-Complaint, as well as anticipated future litigation. Since INTACT's lawyer filed false legal pleadings in the BC Superior Court, the firm's reputation, based upon puffery, has significant relevance to the case, and is to be exposed.

INTACT's lawyer has threatened even more litigation, subject to the above countdown. Perhaps Whitelaw-Twining will abide by the countdown, and will timely cease and desist its violations of the ethical Rules and Regulations of the LAW SOCIETIES OF BC, ALBERTA and ONTARIO (chronicled by the CANADIAN BAR ASSOCIATION). Other Canadian law firms, who have been constructively damaged by Whitelaw-Twining's unfair competition tactics, would benefit from Whitelaw-Twining's compliance, voluntary or otherwise.

The below hyperlinks facilitate a search as to the truth regarding Whitelaw-Twining's claims of awards and other recognition, in Defamation (offence) and Insurance law.

27 DECEMBER 2024

Today's topic of this public interest website is the promotion of ethical standards of the advertisement of legal services, as required by the Rules and Regulations established by the Law Societies of BC, Ontario, Alberta and other jurisdictions, as well as the Canadian Bar Association, which specifically mentions Whitelaw-Twining's practice of listings in ‘Best Lawyer’ and ‘Canada’s Best Lawyers’ as being unprofessional and in contravention of the Law Society of Ontario and other jurisdictional Rules, which protect the public against deceptive practices of listings in third party ranking systems. Whitelaw-Twining has recently revealed plans to open an office, WT Montréal LLP, in Québec, joining forces with the law firm Bélanger Sauvé:

"The Montréal team comprises 16 lawyers, 9 of which [sp] are partners, and 12 business support staff. With the addition of this team, WT beefs up its partnership to 35 and boosts its expertise in insurance law and litigation." "This partnership brings together two teams with deep expertise in insurance law and litigation"

Given the fact that Whitelaw-Twining has stated its intention to use the words "deep expertise", one may assume, unlike its "experts" lack of certification in other jurisdictions, that WT Montréal will conform to the advertising regulations of the Barreau du Québec.

In protection of the public, Canadian law societies have formulated ethical rules and regulations regarding legal advertising. In Ontario, for example, commentary for Rule 4.2-1 states that lawyers must not refer to awards, rankings, and third-party endorsements that are not bona fide or are likely to be misleading. The LSO Rules specifically state that using terms like “best” contravenes this Rule.

The LSO Rule 4.3-1 states that a lawyer must not advertise that the lawyer is a specialist in a specified field unless the lawyer has been so certified by the Society. The Barreau du Québec has similar protective regulations.

As detailed herein, Whitelaw-Twining (which also maintains an office in Ontario) is in violation of both of the aforementioned Regulations.

As revealed by its extensive internet advertisements for prospective clients, Whitelaw-Twining has engaged an America-based "international" marketeer, in an attempt to add a layer of credibility to its unsubstantiated, superlative claims that its lawyers, such as a Partner, are Canada's best lawyers, as well as experts of various legal disciplines. For a subscriptive fee, these mysterious internet platforms utilise generative AI to propel subscribers to instant, algorithmic stardom! Such non-academic, purely commercial platforms, are usually operated by the same entity.

(1) Best Lawyers®

(2) Best Law Firms®

(3) The Best Lawyer®

(4) Ones to Watch®

(5) Best Lawyers in Canada®

(6) Best Lawyers: Ones to Watch in Canada®

(7) Lawyer of the Year®

(8) Law Firm of the Year®

(9) Law Firm of the Day®

The Law Societies of British Columbia and Ontario strictly enforce rules and regulations regarding "puffery". In Canadian law societies, a lawyer is prohibited from claiming to be the "best" lawyer, unless she/he can substantiate such a boisterous claim, with verifiable evidence.

Whitelaw-Twining's claims to be the best lawyers is a prima facie violation of the LSO Rule against the usage of the superlative "the best".

If Whitelaw-Twining should succeed in convincing a potential client that its lawyers are the best Canadian lawyers and/or are deep experts (albeit uncertified) in 29 legal disciplines (as claimed on its website), this American marketeer displays a self-protective disclaimer on its platforms, that its subscribers' puffery is not to be construed as a measure of quality or competency, and that any viewer must engage in her/his own research, in order to confirm if its subscribers' puffed claims of being the best might be nothing but बकवास !

"Inclusion in Best Lawyers is not a guarantee of quality or competency."

"Potential clients are encouraged to conduct their own independent research and verify the credentials and qualifications of any lawyer or law firm."

Whitelaw-Twining's type of unsubstantiated, superlative claims has been dealt with by several law societies, such as the Law Society of Ontario, which has jurisdictional authority over an office of Whitelaw-Twining. In the case of Law Society of Ontario v. Mazin (2019 ONLSTH 35), the tribunal considered the rules governing lawyer advertising. Gary Mazin, a personal injury lawyer, was reprimanded for misleading advertising. He claimed to be "Toronto's Best Personal Injury Lawyer" and used various endorsements and awards that were not verifiable or reflective of his actual performance.

The tribunal found that his marketing suggested qualitative superiority over other lawyers and included misleading references to dubious awards and third-party endorsements. As a result, Mazin was reprimanded for professional misconduct.

The following link relates to the aforementioned prohibited, misleading advertising: Whitelaw-Twining offers no excuse for its non-compliance!

Yet another concern of Law Societies of British Columbia, Ontario, Alberta, etc. is the claim that a certain lawyer is an "expert" (or "deep expert") of a given legal discipline. Specifically, the Law Society of Ontario (a jurisdiction in which Whitelaw-Twining has an office), has a Certified Specialist Programme, to assure the public that lawyers claiming to be experts, be possessed of certain qualifications. On the Law Society's website it is written:

"Becoming a Certified Specialist gives you recognition as a leader in your field. The Certified Specialist Program recognizes lawyer licensees who have met established standards of experience and knowledge requirements in one or more designated areas of law and have maintained exemplary standards of professional practice. Certification as a specialist in an area of specialization is recognized by the Law Society of Ontario with the 'CS' designation. This designation shows the public and colleagues in the legal professions that a lawyer is accomplished and has been acknowledged to be so by the Law Society of Ontario."

To the left is an image from Whitelaw-Twining's website, wherein it claims that virtually all of its lawyers are "industry leaders in 29 areas of law" experts.

Whitelaw-Twining claims that a Partner has earned the status of Best Lawyer in Canada. This Partner heads the Insurance Law and Personal Injury Litigation department, and has been assigned an expert of both disciplines. There is no indication that he has earned the status of a Certified Specialist of either discipline.

In any event, on this website are detailed facts of Defamation Best Lawyer Partner's defamatory, false accusation that a Named Insured of his Client/Insurer had submitted a property claim, under the false pretence of being an insured. At the trial of his meritless SLAPP action against the Named Insured, the Partner will have occasion to objectively substantiate the accuracy of his claim to being the best lawyer in Canada, held to the enhanced standard of an expert in defamation!

Furthermore, in Canada, in addition to the strict standards of Law Societies for the legal profession, the Competition Bureau enforces laws that prohibit misleading advertising and deceptive marketing practices, including puffery. According to the Competition Act, businesses must ensure that any claims they make are accurate and substantiated.

To the left is an image from Whitelaw-Twining's website, wherein it claims that virtually all of its lawyers are "industry leaders in 29 areas of law" experts.

To the right is another image from Whitelaw-Twining's website, wherein the firm again claims that its lawyers are possessed of expertise in "29 distinct practice areas".

To the left is a recent, humble proclamation from Whitelaw-Twining, of the "awards" bestowed (by the AI generated platforms) upon 16 of its members for "Best Lawyers® " and 6 others for "Best Lawyers: Ones to Watch® in Canada".

Perhaps Whitelaw-Twining will voluntarily abandon its deceptive American style of algorithmic advertising, by ceasing and desisting its ongoing violations of the Rules and Regulations of the Law Societies of BC, Ontario, Alberta and other jurisdictions, as well as by the Canadian Bar Association. Whitelaw-Twining's Partner has imposed a time constraint of 17h00, 08 January 2025, which is a propitious completion date and time for the firm's unconditional, full compliance with the Law Societies' Rules and Regulations!

To the left is another false claim from Whitelaw-Twining. The Globe and Mail Statista did survey thousands of legal professionals, but Whitelaw-Twining received no special status or mention, above the other thousands.

To the right is a recent, humble proclamation from Whitelaw-Twining, as to its sacred ranking, bestowed by the AI generated platform the "Best Law Firms™ "

IN VIEW OF THE FACTS AND THE LAW, IT IS BELIEVED THAT THE DEFENDANT WILL PREVAIL AT TRIAL, AGAINST INTACT INSURANCE, MICHELE VINCENT, AMANDA MYERS AND CHRISTA RAE CORDICK,

IN SUCH EVENT, FUTURE LITIGATION AGAINST THESE PARTIES, SOUNDING IN VARIOUS CAUSES, IS ASSURED.

09 DECEMBER 2024 UPDATE: With reference to the language of the 30 September 2021 denial letter, infra, it is written:

2. EACH OF THE FOLLOWING IS ALSO AN INSURED: 2.5. Your unit or strata lot owners and any tenants, but only with respect to the conduct of the corporation for liability arising out of the common property, excluding liability arising out of the owner's or tenant's possession, occupation or use of property designated for exclusive use. Per the ruling of the Economic v Aviva case and its progeny, the policy language controls. Apart from the issues that the Whitelaw-Twining Insurer/Client failed to apprise the other Scheduled Insurers (the master policy of which offered extended, comprehensive coverage), INTACT wrongfully refused the First Party Named Insured's claim, which unambiguously involved the "conduct of the corporation for liability arising out of the common property", whether by (1) failure to maintain the ornamental pigeon roost ledge, or by (2) failure to enforce the Strata Regulations and Bylaws against the Owner of the nearby unit. These regulations are clear provisions of the Strata Property Act.

The provision of the liability of the common property is activated either by the Strata corporation's (1) failure to maintain the ornamental pigeon roost ledge, or by (2) failure to enforce the Strata Regulations and Bylaws against the Owner of the unit (who is also an Insured under the policy).

The insured Strata Corporation LMS2845 Bylaw 3.9 states: "The Strata Corporation shall maintain the common property ) and the decorating of the whole of the exterior of the building in a healthful and attractive condition".

Strata Property Act § 26 "Subject to this Act, the regulations and the bylaws, the council must exercise the powers and perform the duties of the strata corporation, including the enforcement of bylaws and rules".

Strata Property Act § 257 addresses amending a strata plan to correct a wrong designation of Limited Common Property (LCP) These steps ensure that the property is correctly classified and that the designation aligns with its actual use and accessibility. Strata Property Act § 129 "(1) To enforce a bylaw or rule the strata corporation may do one or more of the following: (a) impose a fine under section 130; (b) remedy a contravention under section 133; (c) deny access to a recreational facility under section 134"

It is difficult to fathom that none of INTACT's five (5) lawyers, neither Casey Goodrich, nor Christa Rae Cordick, nor Nigel Beckmann, nor Mathieu Grenier, nor Frédéric Cotnoir, has familiarised himself/herself with the facts and the law thereof.

06 DECEMBER 2024 UPDATE:

INTACT's offence lawyer is currently prosecuting INTACT's malicious SLAPP action against INTACT'S own Named Insured. Although INTACT CEO Charles Brindamour, Executives Mathieu Grenier and Frédéric Cotnoir may believe that the Defendant is not an Insured of the company (since his name is not listed in the insurance policy), a recent decision by Justice Coval of the BC Supreme Court (where INTACT's SLAPP action is pending), soundly rejects INTACT's assertion. Press below links for details!

Christa Rae Cordick, Intact house counsel, a Plaintiff in INTACT's SLAPP action against its own Named Insured, was instrumental in the legal, regulatory and ethical entanglements that have ensued. By example, at a Provincial Court Settlement Conference, Cordick repeated the odious lie that INTACT's Named Insured was an unstable, vexatious litigant, who visited the feral pigeons, in their roost. That absurd, scurrilous lie drew derision from the Judge, and forever poisoned the Named Insured's position in the litigation before that Court.

Michele Vincent, Intact Ombudsman, committed a litany of false representations and unlawful cover-ups. One of the more egregious was exposed by Intact's Privacy Officer, Helen Cameron. A Plaintiff in INTACT's SLAPP action against its own Named Insured, Vincent's false representations to federal and provincial regulators, and her Intentional Infliction of Emotional Distress, against the Named Insured and his wife, also a Named Insured, is detailed with documentary evidence, on this comprehensive, public interest website.

As part of her unlawful cover-up, despite letters from INTACT personnel, the authority of Strata Property Act § 155(b), and the Supreme Court ruling, Ombudsman Vincent continues, unabated in her illicit conduct. When the Named Insured requested a common Claims Experience Letter (on 16 May 2024), Ombudsman Vincent replied with a refusal, still denying his status as Named Insured. Her email of 13 June 2024 is displayed below, type enlarged for legibility and emphasised in yellow.

INTACT "Strategic Team Leader" Amanda Myers. In furtherance of her scheme to avoid investigation of the Named Insured's claim, Myers falsified the claims investigation, which was exposed, when INTACT Privacy Officer, Helen Cameron, conducted an internal affairs probe, confirming, in a release of 19 January 2024, that Myers had not only falsified her claims investigation, she had engaged in an extensive cover-up of her activities for over two (2) years. Incredibly, Myers is also Plaintiff in INTACT's SLAPP action against its own Named Insured, notwithstanding the fact that in her letter of 30 September 2021, Myers had confirmed the Defendant's status as a Named Insured!

Listen to the below song, an endearing tribute to "Strategic Team Leader" Amanda Myers.

To the right is an image of an ornamental pigeon roost ledge, situated next to a bedroom window of INTACT's Named Insured's 17th floor residential unit. As indicated in the image, the ledge was replete with large amounts of contaminated, toxic spore-producing faecal matter.

The building Strata Corporation refused to abate the health hazard, so the Named Insured occupant submitted a First Party claim with INTACT.

On this website is a letter dated 30 September 2021, from INTACT, acknowledging the status of Named Insured, and confirming the following policy language:

2. EACH OF THE FOLLOWING IS ALSO AN INSURED: 2.5. Your unit or strata lot owners and any tenants, but only with respect to the conduct of the corporation for liability arising out of the common property, excluding liability arising out of the owner's or tenant's possession, occupation or use of property designated for exclusive use.

Faced with the "dilemma" of having to process and possibly pay a claim, the INTACT Claims Manager, Amanda Myers, devised a scheme [which she has refused to renounce for more than three (3) years], that the Named Insured had physically "possessed", "occupied" and "used" the ornamental pigeon roost ledge, thus triggering the policy exclusion. The roost is physically inaccessible from the Named Insured’s high rise unit. The ledge is devoid of any means of ingress/egress. It is legally, physically and architecturally, common property; not part of any unit of the residential building.

The images to the right is of the health hazard abatement team from specialist Humane Solutions, which, in accordance with BC WorkSafe and OSHA regulations, the remediation crews were required to don protective hazmat suits, special air filtration masks, and safety tie lines, as they gained access to the ledge, by way of a work platform, anchored at the roof of the high rise building. The Named Insured paid $2,541 for the health hazard abatement service.

Christa Rae Cordick, Intact house counsel, a Plaintiff in INTACT's SLAPP action against its own Named Insured, was instrumental in the legal, regulatory and ethical entanglements that have ensued. By example, at a Provincial Court Settlement Conference, Cordick repeated the odious lie that INTACT's Named Insured was an unstable, vexatious litigant, who visited the feral pigeons, in their roost. That absurd, scurrilous lie drew derision from the Judge, and forever poisoned the Named Insured's position in the litigation before that Court.

Michele Vincent, Intact Ombudsman, committed a litany of false representations and unlawful cover-ups. One of the more egregious was exposed by Intact's Privacy Officer, Helen Cameron. A Plaintiff in INTACT's SLAPP action against its own Named Insured, Vincent's false representations to federal and provincial regulators, and her Intentional Infliction of Emotional Distress, against the Named Insured and his wife, also a Named Insured, is detailed with documentary evidence, on this comprehensive, public interest website.

As part of her unlawful cover-up, despite letters from INTACT personnel, the authority of Strata Property Act § 155(b), and the Supreme Court ruling, Ombudsman Vincent continues, unabated in her illicit conduct. When the Named Insured requested a common Claims Experience Letter (on 16 May 2024), Ombudsman Vincent replied with a refusal, still denying his status as Named Insured. Her email of 13 June 2024 is displayed below, type enlarged for legibility and emphasised in yellow.

INTACT "Strategic Team Leader" Amanda Myers. In furtherance of her scheme to avoid investigation of the Named Insured's claim, Myers falsified the claims investigation, which was exposed, when INTACT Privacy Officer, Helen Cameron, conducted an internal affairs probe, confirming, in a release of 19 January 2024, that Myers had not only falsified her claims investigation, she had engaged in an extensive cover-up of her activities for over two (2) years. Incredibly, Myers is also Plaintiff in INTACT's SLAPP action against its own Named Insured, notwithstanding the fact that in her letter of 30 September 2021, Myers had confirmed the Defendant's status as a Named Insured!

Listen to the below song, an endearing tribute to "Strategic Team Leader" Amanda Myers.

To the right is an image of an ornamental pigeon roost ledge, situated next to a bedroom window of INTACT's Named Insured's 17th floor residential unit. As indicated in the image, the ledge was replete with large amounts of contaminated, toxic spore-producing faecal matter.

The building Strata Corporation refused to abate the health hazard, so the Named Insured occupant submitted a First Party claim with INTACT.

On this website is a letter dated 30 September 2021, from INTACT, acknowledging the status of Named Insured, and confirming the following policy language:

2. EACH OF THE FOLLOWING IS ALSO AN INSURED: 2.5. Your unit or strata lot owners and any tenants, but only with respect to the conduct of the corporation for liability arising out of the common property, excluding liability arising out of the owner's or tenant's possession, occupation or use of property designated for exclusive use.

Faced with the "dilemma" of having to process and possibly pay a claim, the INTACT Claims Manager, Amanda Myers, devised a scheme [which she has refused to renounce for more than three (3) years], that the Named Insured had physically "possessed", "occupied" and "used" the ornamental pigeon roost ledge, thus triggering the policy exclusion. The roost is physically inaccessible from the Named Insured’s high rise unit. The ledge is devoid of any means of ingress/egress. It is legally, physically and architecturally, common property; not part of any unit of the residential building.

The images to the right is of the health hazard abatement team from specialist Humane Solutions, which, in accordance with BC WorkSafe and OSHA regulations, the remediation crews were required to don protective hazmat suits, special air filtration masks, and safety tie lines, as they gained access to the ledge, by way of a work platform, anchored at the roof of the high rise building. The Named Insured paid $2,541 for the health hazard abatement service.

The legal illusionist to the left is obviously fictitious, but so is INTACT FINANCIAL's lawyer's delusional claim (per his declaration and signature in legal pleadings filed with the BC Supreme Court), that RB (creator of this website), has never been an Insured of INTACT. Unless this gentleman is able to retroactively change the words of "NAMED INSURED" to "UNINSURED", in correspondence from INTACT, which was filed with various federal and provincial regulatory agencies, BCFSA, FCAC, OSFI, GIO, IBC, as well as the BBB, then he and his Clients have committed perjury to the Court, and false representations to those agencies

Whitelaw-Twining's lawyer has confirmed that INTACT has paid, to date, more than $50,000 in needless fees.

INTACT personnel Amanda Myers, Christa Rae Cordick and Michele Vincent had all declared the Claimant's status as a Named Insured. Additionally, the Insurance Broker Gordon Li, Sedgwick Sr Adjuster Daphne Chan, and Heather Bidnall, Compliance Officer of the Insurance Council of BC, also confirmed the Claimant's status as a Named Insured.

However, in perfidious defiance of all of the foregoing authorities, a Whitelaw-Twining Partner devised and conducted the highly lucrative scheme to falsely accuse RB of not being a First Party Named Insured, who submitted a claim with INTACT, under the false pretence of so being. In aggravation of his actions, this Partner proceeded to file two (2) SLAPP actions against RB in the BC Supreme Court, for highly illicit motives.

The Whitelaw-Twining Partner's disservice to his client INTACT goes beyond mere Abuse of Process and Intentional Infliction of Emotional Distress of its Named Insured, since the Partner deliberately ignored RB's repeated requests to apprise Sedgwick (the adjusting authority for all of several Scheduled Insurers, under the subject comprehensive BFL Strata Protect policy) of RB's claim, which is covered under the provisions of other Scheduled Insurers' contractual provisions.

THIS PUBLIC INTEREST WEBSITE IS OF NECESSITY, FACTUALLY CRITICAL OF CERTAIN ROGUE PERSONNEL, EMBEDDED WITHIN THE RANKS OF INTACT INSURANCE. 

FOR REASONS OF TRANSPARENCY AND FAIRNESS, THERE REMAINS THE REMOTE POSSIBILITY THAT EXECUTIVES CEO CHARLES BRINDAMOUR, SR LEGAL COUNSEL MATHIEU GRENIER AND LEGAL COMPLIANCE OFFICER FREDERIC COTNOIR BE UNAWARE OF THE EXISTENCE OF THESE ROGUE ELEMENTS, WHO CONTINUE TO EXPOSE INTACT TO THE IRONY OF INCREASINGLY COSTLY IGNOMINY.

THEREFORE, PRIOR TO THE OPTIMISATION OF THIS WEBSITE'S SEO SETTINGS AND THE INTRODUCTION OF A SOCIAL MEDIA PLATFORM, WITH BLOG ACTIVITY, IT HAS BEEN REQUESTED OF INTACT'S LEGAL COUNSEL NIGEL BECKMANN, THAT HE DETERMINE IF ANY OF THE AFOREMENTIONED GENTLEMEN IS WILLING TO INSTRUCT THAT OMBUDSMAN VINCENT PERMIT THAT THE CUSTOMER EXPERIENCE TEAM CONCLUDE THE COMPLAINT INVESTIGATION, ASSIGNED BY MS. VINCENT ON 23 MAY 2023.

The staggering administrative costs of Ombudsman Vincent's obstruction of her own Complaint investigation, in conjunction with a confirmed more than $50,000 in legal fees, to a Partner of Whitelaw-Twining, would be of concern to an actuarial, if not to a disinterested observer. With all due respect to INTACT, this website is intended to be informational, not necessarily as actuarial advice!

Perhaps the below song will accord INTACT a clew !

A COST-BENEFIT ANALYSIS (CBA) IS A SYSTEMISED APPROACH USED TO ASSESS THE ADVANTAGES (BENEFITS) AND DISADVANTAGES (COSTS) ASSOCIATED WITH A PARTICULAR DECISION, PROJECT OR POLICY.

In this case, the sum "benefit" to INTACT is the Ombudsman's (temporary) avoidance of issuance of a Final Decision Letter to a Named Insured (who has offered to pay for postage), as well as some Manager's perverse sense of accomplishment, in instructing a lawyer to file two (2) civil actions against the Named Insured Whistleblower, in retaliation for his exposure of the illegal activities of an Alberta Claims Team!

The costs are (1) administrative expenses for two house lawyers (Casey Goodrich and Christa Rae Cordick) and their staff (2) legal costs for specialty lawyer (Nigel Beckmann) and his staff (3) court filing and other fees (4) administrative expenses in warding off regulatory agencies (5) Human Rights Tribunal defence (6) reputational damage, inherent in (7) eventual regulatory compliance enforcement measures (8) employee morale (9) replacement of rogue employees, etc.

Perhaps INTACT should expedite plans to implement GENERATIVE AI !

AT WHAT COST, REPUTATIONAL IGNOMINY?

In summary, this website contains detailed, documentary evidence of the following of INTACT INSURANCE's violations of morality, ethics, regulatory and other legal standards, such as:

(1) A "Strategic Leader" Claims Team's fraudulent fabrication of a claims investigation (uncovered during an internal affairs probe, ordered by INTACT's diligent Privacy Officer)

(2) INTACT's lawyer's false charge of a Whistleblower's having committed the offence of submission of an insurance claim, under false pretences

(3) Extortionary threat by an INTACT lawyer, of litigation against a Whistleblower, unless he should renounce his Charter Rights

(4) Obstruction of justice, by INTACT's conflicted-of-interest Ombudsman/Complaint Officer, by her Order to the Customer Experience Team to cease a Complaint investigation, that she, herself had commissioned

(5) Violations of other federal and provincial insurance company regulations, plus an array of miscellaneous ethical offences

Federal and provincial regulators have refrained from enforcement measures against INTACT, in view of Ombudsman, Michele Vincent's 26 May 2023 referral of Named Insured RB's Complaint to the Customer Experience Team, for an investigation and Final Decision letter (below). However, after more than one year, six months, the Customer Experience Team's investigation has not yet been completed, thus no required Final Decision letter has been released. Ombudsman Vincent's signature 'Open-Ended, Never to be Concluded' (TM) Complaint investigations are belied by INTACT's websites, which state:

"If you have a complaint about the service you have received, you have a right to access your company's complaint resolution process. Intact will provide you with information about how you can ensure that your complaint is [sic] heard and promptly handled". Given Ombudsman Vincent's illicit Complaint Resolution modus operandi, 'promptness' equates to 'never'!

INTACT'S REGULATORY DILEMMA, AS COMPOUNDED BY ITS LAWYER'S HYPER-ZEALOUS FABRICATION OF FACTS

24 April 2023 Manal, member of INTACT's (Step-2) Customer Experience Team, acknowledged receipt of a formal Complaint, filed by RB, an INTACT Named Insured. In Manal's email, she stated that the Unit Claims Manager (the subject of the Complaint) would be notified, with an opportunity to resolve the Complaint. The Unit Claims Manager ignored the Named Insured's efforts, so in strict compliance with INTACT's Complaint Resolution Protocol, RB proceeded to Ombudsman Michele Vincent (Step 3).

26 May 2023 Ombudsman Vincent commissioned a formal inquiry into RB's Complaint to the Customer Experience Team, assuring RB that the results of the Customer Experience Team's investigation would be provided to him, in a Final Decision letter.

08 July 2024 Although 409 days had passed since the Ombudsman's assignment to the Customer Experience Team, neither case updates, nor the promised Final Decision letter had been provided. Instead of completion of compliance with regulatory protocol, in retaliation for his Complaint, Ombudsman Vincent sued the Named Insured in the BC Supreme Court File No. VLC-S-S-244484

10 July 2024 A mere two (2) days thereafter, Ombudsman Vincent filed another retaliatory lawsuit against the Named Insured, in the BC Supreme Court File No. VLC-S-S-244577

22 November 2024 INTACT's hyper-zealous lawyer Nigel Beckmann threatened even more retaliatory, extortionary litigation against RB, unless RB should unconditionally renounce his freedom of expression rights, by unconditional deactivation of this public service website.

Note: Notwithstanding the fact his INTACT personnel Clients, Amanda Myers and Christa Rae Cordick had assured INTACT's attorney, Nigel Beckmann (* a Whitelaw-Twining Partner), that RB was a Named Insured of INTACT, Beckmann perpetrated a lucrative scheme by falsely accusing RB of submission of an insurance claim with INTACT, under the false pretence of being an Insured.

* A cozy 'boutique' law firm, that represents itself to be a staunch defender of the falsely accused!

When our CEO, Charles Brindamour orders regulatory compliance, he does not countenance false, deceptive reports to regulators!

As detailed herein, on 26 May 2023, Ombudsman Michele Vincent responded to regulatory inquiries by the BCFSA and FCAC, by assignment of a Named Insured's 3-step formal Complaint to the Customer Experience Team, (Step 2 of INTACT's federally and provincially required Complaint Resolution Protocol). Ombudsman Vincent instructed that, upon completion of the Customer Experience Team's investigation, the results thereof were to be provided to the Named Insured, in a Final Decision letter, within 60 days (no later than 26 July 2023).

Unaware that Ombudsman Vincent had been engaged in an extensive cover-up, the Regulators deferred to Vincent's disingenuous representation that the Customer Experience Team's Final Decision letter would be released. However, after one year and two months of the Ombudsman's assignment to the Customer Experience Team, neither results of any investigation, nor any Final Decision letter has been provided.

Ombudsman Vincent's legal and ethical dilemma was her inability to hold the regulators at bay indefinitely, since due to some perversity, she has had no intention of statutory compliance with the regulations!

Thus, Ombudsman Vincent devised a scheme to sue the Named Insured, in the extortionary expectation that the financial stress would compel him to withdraw his Complaint. In furtherance of her scheme, she agreed to assume the rôle of lead Plaintiff, in a civil action against the Named Insured, as devised by a Whitelaw-Twining Partner, who filed such a civil action on 08 July 2024. When the Named Insured refused to withdraw his Complaint, lead Plaintiff Vincent instructed a second, duplicate civil action against the Named Insured, filed on 10 July 2024.

In all likelihood, CEO Brindamour does not condone such deceptions, in lieu of good faith compliance,

although he has yet to intercede in Ombudsman Vincent's reign of deception. The regulators have recently been notified of INTACT's eternal statutory violations, and have indicated renewed interest in enforcement.

Even at the otherwise evitable damage to INTACT Insurance reputation, Ombudsman Michele Vincent continues her deceptive, dilatory practice of Perpetually Unfinished Complaint Investigations. A case in point, on 26 May 2023, Ombudsman Vincent assigned the subject Complaint to INTACT's Step-2 Customer Experience Team, for investigation into an Alberta Claims Team's documented, unlawful activities. As of 12 November 2024 (536 days later) the statutorily required Final Decision Letter has not been released.

The song to the right has been written in Ombudsman

Michele Vincent's enduring tribute.

INTACT FINANCIAL CORPORATION Annual Financial Report (a Compendium of Unattained Objectives)

In the Annual Financial Report, to the left, INTACT states a woefully unattained, risk management objective:

"To mitigate these risks, we have established escalation procedures to help ensure that our customers have multiple channels to express any dissatisfaction. This includes a Customer Experience Team and an Ombudsman’s Office which both offer the opportunity for customer dissatisfaction to be resolved."

The unadulterated facts expose INTACT's systemic, de facto "Regulatory Authorities Deception Initiative Ongoing [RADIO].

On 26 May 2023 (upon a Named Insured's formal Complaint) in accordance with INTACT Complaint Resolution Protocol, Ombudsman Michele Vincent commissioned the Step-2 Customer Experience Team to investigate an illegal coverage denial. Per INTACT's regulations, the results of the investigation must be provided to the Named Insured, in a Final Decision letter, within 60 days (no later than 26 July 2023).

However, when faced with the daunting prospect of honesty, Ombudsman Vincent suddenly turned rogue, and has artfully eluded federal and provincial regulatory authorities, with a subterfuge, claiming that the Customer Experience Team hasn't completed its investigation. After one year and four months, the Final Decision Letter has not been released, nor has its statutory corollary, the Claims Experience Letter!

In the annual Financial Report, to the right, it is written: "The SVP, Corporate and Legal services reports to the Board of Directions, and its committees on such matters, including with respect to privacy and Ombudsman complaints."

INTACT omits in this Financial Report its deliberate suppression of the investigative discovery of Privacy Officer Helen Cameron.

Under the independent, administrative authority of the Privacy Office, Ms. Cameron conducted her own internal affairs probe, which culminated in the 19 January 2024 announcement that the Alberta Claims Team's alleged "claims investigation" had been an arrant fabrication.

Moreover, it was uncovered that Ombudsman Vincent's refusal to release the Customer Experience Team's findings is part of her elaborate cover-up, to prevent the Alberta Claims Team's fraudulent claims activity from regulatory enforcement exposure!

In collusion with the Ombudsman's illicit acts and omissions, a certain rogue managerial element has nullified CEO Brindamour's enduring conservative fiscal measures, by the funding of an estimated (to date) more than $50,000 in legal fees, to a Partner of the Whitelaw-Twining law firm, a consummate antagonist that filed two (2) SLAPP lawsuits against the aforementioned Complainant/Whistleblower, naming the wayward Ombudsman Vincent as lead Plaintiff!

In classic irony, at a staggering cost to INTACT's shareholders, Whitelaw-Twining's reckless acts and omissions greatly increase the risks of federal and provincial regulatory intervention against INTACT.

(specific details on this website)

INTACT Insurance could well benefit from the creation of the position of Regulatory Compliance Troubleshooter [RCT], responsible for identifying, analysing, and resolving regulatory compliance issues, to ensure that INTACT's operations adhere to all relevant laws and regulations.

The RCT would work closely with and monitor various departments, such as that of the Ombudsman, to eliminate untoward legal expenses, that serve only to tarnish INTACT's reputation and credibility. The RCT would address and resolve other general compliance challenges, thus fostering a culture of accountability and regulatory excellence.

The Financial Institutions Act (FIA) of British Columbia, specifically Sections 94.1, 158, 189, and 192 require insurers to adopt and comply with the BCFSA Code of Market Conduct. This code ensures fair treatment of customers, including proper handling of complaints and claims.

This code incorporates the principles from the Canadian Council of Insurance Regulators' (CCIR) Fair Treatment of Customers (FTC) guidance. It includes 12 expected outcomes that ensure insurers treat customers fairly throughout the product lifecycle.

The BC Financial Services Authority (BCFSA) requires insurance companies in British Columbia to have a complaint resolution protocol. This protocol ensures that insurers handle complaints in a fair, transparent, and timely manner. The guidelines include:

1. Managerial Oversight: Insurers must have managerial oversight to review and monitor operations, ensuring compliance with established laws and policies.

2. Claims and Complaints Handling Policies and Procedures: Insurers need to have clear policies and procedures for handling claims and complaints.

3. Claims and Complaints File Maintenance: Insurers must maintain detailed records of all correspondence, documents, and interactions related to claims and complaints

AS FULLY DETAILED ON THIS WEBSITE, FOR 538 DAYS INTACT INSURANCE OMBUDSMAN, MICHELE VINCENT, HAD TEMPORARILY SUCCEEDED IN DELAYING [FIA SECTION 80.3] ENFORCEMENT PROCEEDINGS, BY FEDERAL AND PROVINCIAL INSURANCE REGULATORS, BY THE ASSIGNMENT OF THE COMPLAINT TO INTACT'S CUSTOMER EXPERIENCE TEAM [STEP-2 OF THE COMPLAINT RESOLUTION PROTOCOL] HOWEVER, IN A FUTILE ATTEMPT TO HOLD REGULATORS AT PAY FOREVER, SHE LATER ILLICITLY RIGGED THE SYSTEM, BY ARRANGING THAT THE STEP-2 CUSTOMER EXPERIENCE INVESTIGATION BE ABORTED; THUS PREVENTING THAT THE OBLIGATORY STEP-2 FINAL DECISION LETTER EVER BE CREATED/RELEASED.

UPON EXPOSURE OF OMBUDSMAN VINCENT'S UNLAWFUL RUSE, BY WHISTLEBLOWERS RB AND PRIVACY OFFICER HELEN CAMERON, VINCENT ORDERED HER ATTORNEY TO SUE RB TWICE, WITHIN 2 DAYS!

Has the Partner of law firm Whitelaw-Twining committed the tort of Barratry? This tort Involves Meddling In the Affairs of Others and Encouraging Others to Use Legal Processes As a Means to Inflict Stress and Strife Rather than to Use Legal Processes for the Legitimate Purpose thereof.

SAINT CIBOIRE !

INTACT has spent tens of thousands of shareholders' capital, and will spend tens of thousands more, just to temporarily avoid having to issue a Claims Experience letter to RB, a person whom they have declared to be a Named Insured!

Intact Financial Corporation's Operating Committee members have been notified of INTACT's wanton subsidization of a law firm that continues to violate CEO Brindamour's "Living our Values" Directive, infra.

• Louis Gagnon, Chief Executive Officer, Canada

• Patrick Barbeau, Executive Vice President & Chief Operating Officer

• Ken Anderson, Executive Vice President, Corporate Development & Investor Relations

• Frederic Cotnoir, Executive Vice President & Chief Legal Officer

• Anne Fortin, Executive Vice President, Direct Distribution and Chief Marketing and Communications Officer (reports to Louis Gagnon)

• Louis Marcotte, Executive Vice President & Chief Financial Officer

• Benoit Morissette, Executive Vice President, Chief Risk & Actuarial Officer

• Werner Muehlemann, Executive Vice President & Managing Director, Intact Investment Management Inc.

Monsieur Charles Brindamour has been the CEO of Intact Financial Corporation since 2008. Originally established in 1809 under the name Halifax Fire Insurance Association, Intact has grown to become the largest insurance provider in Canada. During CEO Brindamour’s 15-plus year stewardship of the firm, he has been much-lauded for his efforts promoting fiscal restraint, sustainability and innovation within the company. He is also a member of the board directors with Intact, as well as the Geneva Association, the Canadian Imperial Bank of Commerce, and the Business Council of Canada.

1. Public Statements: CEO Brindamour has publicly addressed the issue of inflated legal costs in the insurance industry.

2. Industry Reports: Reports from industry organisations, such as the Insurance Bureau of Canada, have echoed CEO Brindamour's concerns about the impact of inflated legal costs upon the insurance industry.

3. Earnings Calls: During Intact Financial Corporation's earnings calls, CEO Brindamour has discussed how the company has been pricing for inflationary pressures, including legal costs, since 2016.

4. Comparative Analysis: CEO Brindamour's actuarial expertise has been recognised in the industry for addressing and reducing legal costs.

Risk Management Expertise: CEO Brindamour's formation as an actuary enables his expertise to assess and manage financial risks, which is invaluable for INTACT's strategic planning and decision-making.

1. Data-Driven Decisions: As an actuary, CEO Brindamour excels at analysing data and using it to make informed predictions and recommendations, helping INTACT to make more accurate and effective business decisions.

2. Cost Efficiency: With his expertise in evaluating financial outcomes, CEO Brindamour has been essential to identify cost- saving opportunities and optimise INTACT's financial performance.

3. Regulatory Compliance: CEO Brindamour is well-versed in regulatory requirements, especially in industries like insurance and finance, ensuring that INTACT stays compliant with relevant laws and regulations.

4. Long-Term Planning: CEO Brindamour is highly skilled in long-term financial planning, which assures that INTACT be prepared for future challenges and opportunities.

Fiscal conservative, INTACT Insurance Company's CEO, Monsieur Charles Brindamour's actuarial prowess has earned the company kudos throughout the insurance industry, for his indispensable ability to rein in frivolous legal costs, a fortiori, reputational legal costs, such as those squandered in the ongoing litigation, predicated upon a malicious, defamatory lie, that has resulted in tens of thousands of dollars of stakeholders' funds, being paid into the bulging coffers of Whitehall-Twining law firm (details on this public interest website).

If CEO Brindamour's inexcusably imperceptive subordinates were to permit that he be aware of the fiscal, ethical and legal travesty that the topic of this website engenders, then he would immediately order the cessation of INTACT's expenditures of a confirmed (to date) more than $50,000 in legal fees, to Whitelaw-Twining, an antagonist that relentlessly stands in lucrative opposition to CEO Brindamour's directive, to "stand up for what is right"! In addition to other improper pursuits, this antagonist falsely accused an INTACT Named Insured of the criminality of submission of a claim with INTACT, under the false pretence of being an insured. Whitelaw-Twining's Partner then filed two (2) malicious SLAPP actions against the INTACT Named Insured, based upon the allegation that the Partner, himself, had contrived!

(specific details on this website)

Here is a brief summary of the important, documented events that led to the creation and maintenance of this website. Each and every representation made in this summary and throughout the site, is true and factual, scrupulously evidenced by hundred of documents.

This summary is of the evidence that RB, creator of this site, will present to the BC Supreme Court, at trial, under oath. As always, any representation of this site, with which Defence Counsel from Whitelaw-Twining, or anyone else, should legitimately believe to be inaccurate, any such rebuttal shall be immediately posted hereupon.

CHRONOLOGY

30 September 2021 INTACT Alberta Claims Team Manager Amanda Myers sent a letter to RB, in which they she confirmed RB's status as a Named Insured of INTACT. For some reason, although she claimed to have conducted a claims investigation, she negligently assumed that a cemented, ornamental narrow pigeon roost ledge, outside and below RB's 18th floor unit had been a bedroom, within the unit, and based upon that grossly negligent miscalculation, the Claims Team declared that RB had triggered an exclusion to coverage.

02 October 2021 ~ RB contacted the Alberta Claims Team on numerous occasions for several months, repeatedly reminding the Team of their obvious error, inviting the Team to dispatch a claims investigator to his unit, in order to inspect the premises, and confirm that the Claims Team's coverage denial had been based upon the false calculation that the pigeon roost ledge was located within RB's 18th floor bedroom.

26 May 2023 Finally, in response to a formal Complaint, in accordance with INTACT 3-step Complaint Resolution Protocol, INTACT Ombudsman Michele Vincent commissioned a formal inquiry into the coverage denial, to be conducted by the Step-2 Customer Experience Team, with the results of their investigation to be stated in an INTACT Final Decision letter.

26 May 2023 ~07 December 2023 Inexplicably, Ombudsman Michele Vincent reneged on her assignment of RB's Complaint to the Customer Experience Team, ordering the Team to cease and desist its ongoing investigation.

07 December 2023 Whitelaw-Twining Partner, Nigel Beckmann sent a letter to RB, threatening to sue RB for submission of RB's insurance claim with INTACT, under the false pretence of being an Insured of the company. At the time, Mr. Beckmann was aware of the fact that the Alberta Claims Team, INTACT house counsel Christa Rae Cordick, the Strata Property Act Section 155(b), and the BC Supreme Court, in the cased of Strata Plan VR 2213 v. Schappert, 2023 BCSC 2080, had defined RB's legal status as a Named Insured of INTACT!

19 January 2024 At RB's request, and in his support, INTACT's Privacy Officer, Helen Cameron, launched her own internal affairs probe, declaring that the Alberta Claims Team's alleged "claims investigation" had been a complete fabrication! 08 July 2024 Finding that RB refused to succumb to Whitelaw-Twining Partner, Nigel Beckmann's false and defamatory accusations, Attorney Beckmann filed a SLAPP action against RB, BC Supreme Court File No. VLC-S-S-244484

10 July 2024 A mere two (2) days thereafter, when RB stood resolute against Attorney Beckmann's false and defamatory accusations, Mr. Beckmann filed another, duplicate SLAPP action against RB, court File No. VLC-S-S-244577

In a stunning example of Attorney Beckmann's relentless, irreconcilable, overlapping solemn conflicts of interest, he even solicited Alberta Claims Team Manager Amanda Myers and Ombudsman Michele Vincent as his Clients, Plaintiffs in the two (2) SLAPP actions against RB! Upon assignment of a trial date, such will be posted on this site, with an invitation to the justice-seeking public, as well as one major and one minor media organisations, to attend.

Monsieur Charles Brindamour has been the CEO of Intact Financial Corporation since 2008. Originally established in 1809 under the name Halifax Fire Insurance Association, Intact has grown to become the largest insurance provider in Canada. During CEO Brindamour’s 15-plus year stewardship of the firm, he has been much-lauded for his efforts promoting fiscal restraint, sustainability and innovation within the company. He is also a member of the board directors with Intact, as well as the Geneva Association, the Canadian Imperial Bank of Commerce, and the Business Council of Canada.

1. Public Statements: CEO Brindamour has publicly addressed the issue of inflated legal costs in the insurance industry.

2. Industry Reports: Reports from industry organisations, such as the Insurance Bureau of Canada, have echoed CEO Brindamour's concerns about the impact of inflated legal costs upon the insurance industry.

3. Earnings Calls: During Intact Financial Corporation's earnings calls, CEO Brindamour has discussed how the company has been pricing for inflationary pressures, including legal costs, since 2016.

4. Comparative Analysis: CEO Brindamour's actuarial expertise has been recognised in the industry for addressing and reducing legal costs.

Risk Management Expertise: CEO Brindamour's formation as an actuary enables his expertise to assess and manage financial risks, which is invaluable for INTACT's strategic planning and decision-making.

1. Data-Driven Decisions: As an actuary, CEO Brindamour excels at analysing data and using it to make informed predictions and recommendations, helping INTACT to make more accurate and effective business decisions.

2. Cost Efficiency: With his expertise in evaluating financial outcomes, CEO Brindamour has been essential to identify cost- saving opportunities and optimise INTACT's financial performance.

3. Regulatory Compliance: CEO Brindamour is well-versed in regulatory requirements, especially in industries like insurance and finance, ensuring that INTACT stays compliant with relevant laws and regulations.

4. Long-Term Planning: CEO Brindamour is highly skilled in long-term financial planning, which assures that INTACT be prepared for future challenges and opportunities.

Fiscal conservative, INTACT Insurance Company's CEO, Monsieur Charles Brindamour's actuarial prowess has earned the company kudos throughout the insurance industry, for his indispensable ability to rein in frivolous legal costs, a fortiori, reputational legal costs, such as those squandered in the ongoing litigation, predicated upon a malicious, defamatory lie, that has resulted in tens of thousands of dollars of stakeholders' funds, being paid into the bulging coffers of Whitehall-Twining law firm (details on this public interest website).

If CEO Brindamour's inexcusably imperceptive subordinates were to permit that he be aware of the fiscal, ethical and legal travesty that the topic of this website engenders, then he would immediately order the cessation of INTACT's expenditures of a confirmed (to date) more than $50,000 in legal fees, to Whitelaw-Twining, an antagonist that relentlessly stands in lucrative opposition to CEO Brindamour's directive, to "stand up for what is right"! In addition to other improper pursuits, this antagonist falsely accused an INTACT Named Insured of the criminality of submission of a claim with INTACT, under the false pretence of being an insured. Whitelaw-Twining's Partner then filed two (2) malicious SLAPP actions against the INTACT Named Insured, based upon the allegation that the Partner, himself, had contrived!

(specific details on this website)

Here is a brief summary of the important, documented events that led to the creation and maintenance of this website. Each and every representation made in this summary and throughout the site, is true and factual, scrupulously evidenced by hundred of documents.

This summary is of the evidence that RB, creator of this site, will present to the BC Supreme Court, at trial, under oath. As always, any representation of this site, with which Defence Counsel from Whitelaw-Twining, or anyone else, should legitimately believe to be inaccurate, any such rebuttal shall be immediately posted hereupon.

CHRONOLOGY

30 September 2021 INTACT Alberta Claims Team Manager Amanda Myers sent a letter to RB, in which they she confirmed RB's status as a Named Insured of INTACT. For some reason, although she claimed to have conducted a claims investigation, she negligently assumed that a cemented, ornamental narrow pigeon roost ledge, outside and below RB's 18th floor unit had been a bedroom, within the unit, and based upon that grossly negligent miscalculation, the Claims Team declared that RB had triggered an exclusion to coverage.

02 October 2021 ~ RB contacted the Alberta Claims Team on numerous occasions for several months, repeatedly reminding the Team of their obvious error, inviting the Team to dispatch a claims investigator to his unit, in order to inspect the premises, and confirm that the Claims Team's coverage denial had been based upon the false calculation that the pigeon roost ledge was located within RB's 18th floor bedroom.

26 May 2023 Finally, in response to a formal Complaint, in accordance with INTACT 3-step Complaint Resolution Protocol, INTACT Ombudsman Michele Vincent commissioned a formal inquiry into the coverage denial, to be conducted by the Step-2 Customer Experience Team, with the results of their investigation to be stated in an INTACT Final Decision letter.

26 May 2023 ~07 December 2023 Inexplicably, Ombudsman Michele Vincent reneged on her assignment of RB's Complaint to the Customer Experience Team, ordering the Team to cease and desist its ongoing investigation.

07 December 2023 Whitelaw-Twining Partner, Nigel Beckmann sent a letter to RB, threatening to sue RB for submission of RB's insurance claim with INTACT, under the false pretence of being an Insured of the company. At the time, Mr. Beckmann was aware of the fact that the Alberta Claims Team, INTACT house counsel Christa Rae Cordick, the Strata Property Act Section 155(b), and the BC Supreme Court, in the cased of Strata Plan VR 2213 v. Schappert, 2023 BCSC 2080, had defined RB's legal status as a Named Insured of INTACT!

19 January 2024 At RB's request, and in his support, INTACT's Privacy Officer, Helen Cameron, launched her own internal affairs probe, declaring that the Alberta Claims Team's alleged "claims investigation" had been a complete fabrication! 08 July 2024 Finding that RB refused to succumb to Whitelaw-Twining Partner, Nigel Beckmann's false and defamatory accusations, Attorney Beckmann filed a SLAPP action against RB, BC Supreme Court File No. VLC-S-S-244484

10 July 2024 A mere two (2) days thereafter, when RB stood resolute against Attorney Beckmann's false and defamatory accusations, Mr. Beckmann filed another, duplicate SLAPP action against RB, court File No. VLC-S-S-244577

In a stunning example of Attorney Beckmann's relentless, irreconcilable, overlapping solemn conflicts of interest, he even solicited Alberta Claims Team Manager Amanda Myers and Ombudsman Michele Vincent as his Clients, Plaintiffs in the two (2) SLAPP actions against RB! Upon assignment of a trial date, such will be posted on this site, with an invitation to the justice-seeking public, as well as one major and one minor media organisations, to attend.

This song suggests immediate action by INTACT CEO Charles Brindamour, if he is to purge the company of rogue elements, who continue to besmirch our reputation.

The below song is provided for purposes of instruction.

INTACT CEO CHARLES BRINDAMOUR'S "LIVING OUR VALUES" DIRECTIVE WARRANTS DISCIPLINARY PROCEEDINGS AGAINST ANY ROGUE ELEMENTS THAT CONTINUE TO VIOLATE THE CARDINAL RULE OF "STAND UP FOR WHAT IS RIGHT"!

In his INTACT Clients' court pleadings, Whitelaw-Twining's Nigel Beckmann has inculpated himself and his Clients with the perjured falsehoods (1) that RB has never been a Named Insured of INTACT and (2) that INTACT conducted a "review or investigation".

In Paulus v. Fleury, 2018 ONCA 1072, the Court of Appeal held that a factual misrepresentation by counsel in judicial proceedings could amount to deceit or civil fraud “in those circumstances where there would be no reasonable basis for the factual assertion; nor could it be said that the statement was made in good faith” (para 30).

Rule 5.1-2(e) of the Law Society states that a lawyer must not knowingly attempt to deceive a tribunal by offering false evidence, misstating facts, presenting or relying upon a false or deceptive affidavit, suppressing what ought to be disclosed, or otherwise assisting in any fraud, crime, or illegal conduct

Rule 5.1-2(a) states that a lawyer must not abuse the process of the tribunal by instituting or prosecuting proceedings which, although legal in themselves, are clearly motivated by malice on the part of the client and are brought solely for the purpose of injuring the other party.

Rule 5.1-2(b) states that a lawyer must not knowingly assist or encourage any person to abuse the process of the tribunal by instituting or prosecuting proceedings which, although legal in themselves, are clearly motivated by malice on the part of the client and are brought solely for the purpose of injuring the other party.

Rule 5.1-2(c) states that a lawyer must not knowingly make a false or misleading statement to a tribunal.

Rule 5.1-2(d) states that a lawyer must not knowingly present false evidence or assist in any fraud, crime, or illegal conduct.

In this INTACT case, Lawyer Beckmann has the requisite element of scienter; i.e. he intentionally created, filed and served the aforementioned pleadings, with the material false representations, with the Court. Thus, said false representations were not and are not matters of Mr. Beckmann's discretionary opinion!

Mr. Beckmann's pleadings (1) that RB has never been an Insured of INTACT, and (2) that his Clients, INTACT's personnel, had conducted a "review or investigation", constitute intentional false representations, in view of his Clients' letter of 30 September 2021, citing Strata Property Act Section 155(b), in confirmation of RB's status as a Named Insured. Furthermore, in her herein letter of 19 January 2024, Privacy Officer Helen Cameron declared that the "review or investigation" that Mr. Beckmann swears was conducted, never occurred!

The documentary evidence of NB's false representations to the court are detailed, herein. The issue is that his Clients will be examined, at trial, and if they fail to denounce the false representations, attributed to them by their lawyer, Mr. Beckmann, then they will be subjected to charges of criminal perjury! Mr. Beckmann has further subjected his Clients to contradict themselves and each other, at trial.

As further detailed herein, Mr. Beckmann will be personally examined at trial, since it was his scurrilous, defamatory letter of 07 December 2023, falsely accusing RB of having submitted a claim with INTACT, under the false pretence of being a (Named) Insured, that mutated into the remunerative (to Whitelaw-Twining), costly (to INTACT) morass of numerous conflicts of interest, illicit claims practices, moral, ethical and legal entanglements of this cause celebre before the BC Supreme Court.

Lawyer Beckmann has elected to become an indispensable witness to his own false, defamatory charges, which necessitates that he be examined under oath, at trial, or RB may elect to file a Motion to Disqualify Mr. Beckmann.

Law Society Regulation

SECTION 5.2-1 THE LAWYER AS WITNESS

A lawyer should not express personal opinions or beliefs or assert as a fact anything that is properly subject to legal proof, cross-examination, or challenge. The lawyer should not in effect appear as an unsworn witness or put the lawyer's own credibility in issue. The lawyer who is a necessary witness should testify and entrust the conduct of the case to another lawyer.

A law firm can be held liable for the acts of its partners, especially in a general partnership where each partner is jointly and severally liable for the actions of the other partners. This means that the firm itself, as well as the individual partners, can be held responsible for any wrongful acts committed by a partner in the course of the firm's business

The document to the left, signed by Mr. Beckmann's Client, Amanda Myers, confirming RB's status as a Named Insured, is evidence that Mr. Beckmann's above representation to the court (#1) is false!

The document to the right, a letter from Privacy Officer Helen Cameron, that no investigation was conducted, is evidence that Mr. Beckmann's above representation to the Court (#2) is equally false!

As a Named Insured, RB's numerous requests for a direly-needed Customer Experience letter constitutes the exercise of a most fundamental, non-pecuniary, contractual right of an Insured. Since INTACT had denied his claim, based upon a fabricated "investigation", such a letter is essential for the underwriters of prospective insurers, in order to enable them to assess the facts, in their determination of RB's insurability, exposure and rates.

Lawyer Beckmann's injudicious advice that his Client, INTACT's Ombudsman, refuse to issue the Customer Experience letter, constitutes the solemn tort of Intentional Interference with the Contractual Relations between INTACT and RB, and represents an impermissible transgression of CEO Charles Brindamour's "Living Our Values" Directive, infra.

Whitelaw-Twining Partner, Mr. Nigel Beckmann, Esq. is the source and propagator of the defamatory falsity that RB had never been an INTACT Named Insured; that he submitted his claim, no. 4033526840, under the false pretence of being an Insured. The impetus behind these false accusations, Mr. Beckmann will be examined, under oath, at trial. Thus, Law Society of British Columbia Rules 5.2-1 and 2.1-3 specifically require that since he will be subjected to examination, at trial, he is obligated to entrust the conduct of the case to other counsel.

The falsely accused Defendant has an absolute right to examine trial counsel Beckmann, given the precedent of cases such as R v. Stinchcombe (1991), R v. Quesnelle (2014) R v. Rose (1998) wherein the Supreme Court of Canada ruled that the accused has the right to full disclosure of information that could be used to challenge the credibility of a witness, including records of prior dishonesty.

PROUD INTRODUCTION OF MONSIEUR CHARLES BRINDAMOUR, THE HONOURABLE CEO OF INTACT FINANCIAL, WHOSE DEVOTION TO INTACT'S CREDO OF HONESTY AND GOOD FAITH IS OF LEGEND. THUS THE HEREIN EXPOSÉ OF THE ALBERTA CLAIMS TEAM'S FABRICATION OF A CLAIMS INVESTIGATION, AND OTHER ILLICIT ACTIVITY, AS CONFIRMED BY INTACT PRIVACY OFFICER, HELEN CAMERON, WOULD BE OF URGENT INTEREST TO CEO BRINDAMOUR.

WITH AN ABUNDANCE OF RESPECT FOR CEO BRINDAMOUR, IN VIEW OF THE DOCUMENTED FACTS, THE ROGUE ELEMENTS OF THE ALBERTA CLAIMS TEAM, AS WELL AS THEIR POLEMICIST AT WHITELAW-TWINING LAW FIRM, ARE IN DIRE NEED OF PROFESSIONAL REMEDIATION!

Quite the consummate fiscal conservative, in the oft-cited, televised chat of 14 May 2024, with CIBC Capital Market Analyst Paul Holden, CEO Charles Brindamour lamented a root cause of insurers’ rising claims costs — inflated legal fees.

As to legal fees, if CEO Brindamour's subordinates were to permit that he be aware of the fiscal, ethical and legal travesty that this matter engenders, then he would immediately order the cessation of INTACT's expenditures of a confirmed (to date) more than $50,000 in needless legal fees, to Whitelaw-Twining, an antagonist that relentlessly stands in opposition to Mr. Brindamour's directive, to "stand up for what is right"! This antagonist, a fortiori, had falsely accused a Named Insured of the criminality of submission of a claim with INTACT, under fraudulent pretences, as detailed, herein.

Charles Brindamour, has been the CEO of Intact Financial Corporation since 2008. He has shown a strong commitment to maintaining the company's integrity and addressing issues like fraud. He has been vocal about the importance of ethical practices and ensuring that the company operate with transparency and accountability. For more than two years, INTACT's Sr Legal Counsel Mathieu Grenier and Legal Compliance Officer Frédéric Cotnoir have abandoned INTACT's core interests, by artfully distancing themselves from this festering liability. However, given CEO Brindamour's commitment to honesty and good faith, it is essential that he be notified of the ethical, moral and legal entanglements, caused by an Alberta Team's unlawful claims activities, as well as INTACT's offence counsel's scurrillous accusation of a Named Insured having submitted claim no. 4033526840 under the false pretence of being an Insured.

CEO Brindamour appointed Michele Vincent as OMBUDSMAN. As documented herein, Ombudsman Vincent is licensed by the Ontario government as INTACT's COMPLAINT OFFICER.

As COMPLAINT OFFICER, Ms. Vincent commissioned Intact's Step-2, Customer Experience Team to investigate a formal Complaint (made by Named Insured "RB", of illegal claims practices. However, as part of an illicit cover-up, and egregious violation of the Ontario Insurance Act, just as the Customer Experience Team was about to issue its Decision letter, Ms. Vincent, as OMBUDSMAN, ordered the Customer Experience Team to cease and desist the investigation that she, herself, had ordered as COMPLAINT OFFICER. At that point, justice advocate, Whistleblower Helen Cameron, the conscientious Intact Privacy Officer, intervened, with her own internal affairs probe, confirming the validity of RB's Complaint; that his claim had been subjected to a fraudulent scheme by an Alberta Claims Team.

Given CEO Brindamour's enduring commitment to the sanctity of INTACT's public image of honesty and good faith, it is respectfully requested that he immediately intervene in this legal travesty, which has already cost the company tens of thousands of dollars in Whitelaw-Twining's attorneys' offence fees, as well as INTACT's related internal administrative costs.

A significant damage control step in the reestablishment of INTACT's reputation would be that CEO Brindamour Order a legitimate, good faith investigation of claim 4033526840, to replace the sham version, as fabricated by the Alberta Claims Team.

INSURANCE ACT OF ONTARIO

Insurance Ombudsman

5.1 (1) The Chief Executive Officer shall appoint an employee of the Authority as Insurance Ombudsman. (2) The Insurance Ombudsman shall inquire into complaints about insurers’ business practices.

(3) A person may submit a written complaint about an insurer’s business practices to the Insurance Ombudsman if the person has submitted the complaint to the insurer and the complaint has not been resolved within a reasonable time. (4) The Insurance Ombudsman shall give the insurer an opportunity to respond to any complaint submitted under subsection (5) After considering the complaint and any response, the Insurance Ombudsman may attempt to resolve the complaint or may recommend to the Chief Executive Officer that the Chief Executive Officer inquire into the complaint.

PLAINTIFF INTACT'S MERITLESS LEGAL POSITION

1. Not only has Mr. Beckmann contradicted all of his Clients, in their confirmations that RB was a Named Insured of INTACT, Beckmann filed two (2) duplicate civil actions against RB, in retaliation for RB's creation of this informative public interest website. 2. In a letter of 07 December 2023, Mr. Beckmann accused RB of the crime of submission of a claim with INTACT, under the false pretence of being an Insured of the company.

3.Mr Beckmann supports INTACT's position that RB nullified his insurance coverage, by residing in the residential building's 18th floor ledge inaccessible, pigeon roost ledge (as depicted in the hereinbelow images).

4.As required by the Supreme Court, the parties to the civil action must submit a list of documents, intended to be used at trial. Mr. Beckmann has failed to adequately identify the documents that INTACT would introduce, in order to accommodate a requisite exchange of documents.

5.Through Mr. Beckmann, INTACT has ignored RB's offer to dismiss one of the Cross-Defendants.

6.Through Mr. Beckmann, INTACT refuses to respond to an OIPC Freedom of Information request, as part and parcel of INTACT's elaborate and costly legal cover-up

THE FACTS (as documented on this website)

1.(a) In a letter of 30 September 2021, INTACT's Claims Manager, Amanda Myers defined RB's status as a Named Insured.

(b) In a legal filing of 19 May 2023, INTACT's Senior Legal Counsel, Christa Rae Cordick declared RB's status as a Named Insured. (c) Per the BC Strata Property Act, Section 155(b), RB has been a Named Insured of INTACT. (d) In the case of Strata Plan VR 2213 v. Schappert, 2023 BCSC 2080, the BC Supreme Court reaffirmed that all persons situated as RB, are Named Insureds of policies.

2. As a Named Insured of INTACT, RB's submission of the subject claim was acknowledged and accepted as legitimate by INTACT's aforementioned Claims Team, in addition to the other authorities.

3. As a gentleman, Mr. Beckmann should abandon INTACT's reprehensible narrative of a human being cohabitating with a flock of feral pigeons, upon a physically inaccessible, ornamental pigeon roost ledge. If he should persist in such a delusion, at trial, his strategy will easily backfire!

4. RB has identified all documents to be used at trial, and has attempted to establish the conditions for an appropriate exchange of documents.

5. RB has even offered a covenant not to execute any judgement against a certain of Mr. Beckmann's Clients.

The news organisations contacted by RB have declined covering this cause celebre, public interest case, until trial. INTACT's lawyer, although now assured of the opportunity to litigate INTACT's meritless position, remains uncooperative in the advancement of requisite pre-trial hearings. Perhaps the ultimate consequences of the filing of two (2) frivolous, identical civil actions has its legal shortcomings?????

The creator of this website, RB, is a retired expert, award-winning carpet installer, committed to the protection of his similarly situated, fellow INTACT insureds. His efforts have required that he single handedly hold at bay a billion dollar insurer, with its legal apologists, minimally diverse, Whitelaw-Twining, teeming with 66 lawyers, some multilingual. RB continues in his public interest quest, armed only of the facts and truth, in addition to literacy and conversancy of more languages than the entirety of Whitelaw-Twining's lawyers. For more than three (3) years RB has unsuccessfully attempted to attract the interest of INTACT INSURANCE'S SR LEGAL COUNSEL MATHIEU GRENIER or LEGAL COMPLIANCE OFFICER FREDERIC COTNOIR, of specific fraudulent practices, committed by an INTACT Alberta Claims Team, as detailed herein. Thus, RB has decided to greatly expand the heretofore limited scope of promulgation of this strictly factual, public interest website, and is researching the utilisation of social media influencer networks, and other public interest methods.

RB extends his gratitude to INTACT fellow Whistleblower, the courageous Privacy Officer Helen Cameron, who commissioned her own internal affairs investigation, that resulted in the exposure of INTACT's fraudulent claims practices, as detailed herein.

Another conscientious INTACT employée, who courageously refuses to promote the false narrative, is Senior INTACT Attorney Christa Rae Cordick, who supports the facts and the truth, by repudiating lead counsel, Nigel Beckmann, in his false, defamatory accusations, as detailed herein.

INTACT INSURANCE HAS SQUANDERED TENS OF THOUSANDS OF DOLLARS OF ITS SHAREHOLDERS' FUNDS, PROMOTING THE FARCICAL, CONFLICTED-OF-INTEREST PRETENCE THAT MICHELE VINCENT, AS INTACT'S COMPLAINT OFFICER, WOULD DISCIPLINE HERSELF, AS INTACT'S OMBUDSMAN

In her rôle as INTACT's COMPLAINT OFFICER, Michele Vincent is licensed by the Financial Services Regulatory Authority of Ontario (FSRA). In strict conformity with the requirements of her licensure, as Complaint Officer, Ms. Vincent has consistently conducted herself and her office in an exemplary good faith, courteous and professional manner. To her credit, as COMPLAINT OFFICER, upon her receipt of a Named Insured, RB's formal Complaint of fraudulent claims practices on the part of an Alberta Claims Team (detailed herein), on 26 May 2023 Ms. Vincent assigned the Complaint to INTACT's Step-2 Customer Experience Team, for an investigation, and a Final Decision letter to RB, upon conclusion thereof. COMPLAINT OFFICER Vincent even exceeded expectations, by meticulously providing the Alberta Claims Team with a copy of the Step-2 Complaint, and her assignment thereof to the Customer Experience Team Investigators. In her rôle as COMPLAINT OFFICER, Ms. Vincent has well complied with the requirements of her licensing authority, FSRA, regarding the Step-2 Complaint:

"In Ontario, a Complaint Officer typically works within an organisation to handle and resolve complaints from the public or internal stakeholders before they escalate. Their role includes:

Receiving Complaints: They are the first point of contact for individuals who have grievances or issues with the organization's services or conduct.

Investigating Issues: They gather information, review the circumstances, and investigate the validity of the complaints.

Resolving Complaints: They aim to address and resolve issues at an early stage, providing solutions or explanations to the complainant.

Escalating When Necessary: If a complaint cannot be resolved internally, the Complaint Officer may refer it to higher authorities or an external body, such as an Ombudsman."

SUMMARY OF THE MERITS OF MICHELE VINCENT, COMPLAINT OFFICER 1. Chronicled RB's status as an INTACT Named Insured. 2. Commissioned the Customer Experience Team to commence a Step-2 Investigation of RB's formal Complaint. 3. Complied with Strata Property Act Section 155(b), which guarantees RB's legal status as a Named Insured of INTACT. 4. In view of Privacy Officer Helen Cameron's discovery that the Alberta Claims Team had fabricated their claims "investigation", sought to replace the fraud with a legitimate claims investigation. 5. Disavowed the Alberta Claims Team's absurd accusation that RB had resided upon an ornamental pigeon roost ledge, with a flock of feral pigeons and their faecal matter. 6. Opposed the filing of any civil action, in her capacity as Complaint Officer. 7. Had no authority, as Complaint Officer, to issue a Claims Experience letter to RB.

In her surreal, Kafkaesque, alter ego rôle as INTACT's OMBUDSMAN, Michele Vincent, who is not licensed as Ombudsman by any regulatory authority, has pugnaciously defied herself and her own directives, such as her Order to the Customer Experience Team to cease and desist the Step-2 investigation of RB's formal Complaint, that Vincent, herself, had commissioned, in her rôle as a licensed Complaint Officer.

Michele Vincent is the quintessential example of an individual, conflicted of interest with and of herself. As Complaint Officer, she was a prosecutress of the Alberta Claim Teams' fraudulent activities. However, in her alter ego rôle as Ombudsman, she became a staunch apologist for the Claim Team's illegalities!

For obvious reasons, Vincent intentionally limited her alter ego rôle to Ombudsman, in her filings of duplicate, carbon copy SLAPP actions of 08 and 10 July 2024, against Whistleblower, INTACT Named Insured RB, in retaliation for his accurate exposure of her illicit Ombudsman activities.

Vincent's false statements to federal and provincial regulatory agencies, include the BC Financial Services Authority, GIO, BBB, FAC, etc.

Vincent, as Ombudsman, has thus far escaped regulatory intervention, since in Canada, Ombuds personnel are not licensed, thus are not held to the same stringent standards as required by licensing authorities, such as the FSRA. In commercial situations, Ombuds personnel are arbitrarily appointed by company administrators. Since there is no requirement of licensure, Ombuds personnel are merely "expected" to be truthful, but not subject to enforceable extra-company, governmental oversight.

SUMMARY OF THE DEMERITS OF MICHELE VINCENT, OMBUDSMAN 1. Not only refused to recognise RB as a First Party, INTACT Named Insured, Ombudsman Vincent misrepresented RB's legal status to the BCFSA, BCPC, OIPC and other governmental agencies. 2. Ordered that the Customer Experience Team cease and desist its Step-2 Investigation, that she, as Complaint Officer had commissioned. 3. Willfully violated Strata Property Act Section 155(b), which guarantees RB's legal status as a first part Named Insured of INTACT. 4. Suppressed Privacy Officer Helen Cameron's discovery that the Alberta Claims Team had fabricated their "investigation". 5. Zealously promoted as factual the Alberta Claims Team's defamatory accusation that RB had resided upon an ornamental pigeon roost ledge, with a large flock of feral pigeons and their faecal matter. 6. Became lead Plaintiff in two (2) duplicate civil actions against RB, in retaliation for his exposure of her criminality. 7. Refuses to issue a Claims Experience letter to RB, on the falsity that INTACT has no records of any such person.

Even after the filing of two (2) duplicative, carbon-copy lawsuits against the Insured, in retaliation for exposing INTACT's fraudulent claims practices (as detailed hereinbelow), INTACT's Claims Team of Amanda Myers persist in their falsifications of two (2) separate, essential issues. Offence lawyer Nigel Beckmann asserts his own brand of false allegations, in a futile attempt to cover-up the factual realities of INTACT's illegalities.

LIE NO 1 INTACT's Claims Team swear that they had jointly conducted and completed an investigation of claim no. 4033526840 (1033684645). However, in rebuttal, INTACT Privacy Officer Helen Cameron conducted her own internal affairs enquiry of the facts, and has confirmed that no investigation has ever been conducted of either claim.

LIE NO 2 The Claims Team swears that the Insured "RB" had forfeited the entirety of his INTACT coverage, by having physically "possessed", "occupied" and "used" an infected and infectious, faecal matter-laden, ornamental, pigeon roost ledge, which is physically inaccessible from the Insured’s high rise unit. The ledge is devoid of any means of ingress/egress. It is legally, physically and architecturally, common property; not part of any unit of the residential building. The below image is of the pigeon roost ledge and the hazard abatement specialist team member.

LIE NO 3 It has been more than three (3) years since INTACT designated "RB" as a Named Insured, but despite INTACT's ongoing federal and provincial regulatory and civil legal entanglements, in response to the Insured's Freedom of Information access request, Ombuds[wo]man Michele Vincent lies that INTACT has no records about the Insured.

For more than three (3) years, INTACT has refused to withdraw its fraudulent coverage denial (below), based upon INTACT's false, defamatory conclusion that "RB" had resided in the common property, ornamental pigeon roost ledge. "RB's" damages include his inability to procure property- liability insurance coverage. Although INTACT's coverage denial was based upon a fabricated "investigation" and fraudulent premise, no insurance company underwriter will approve the application of an Applicant that is deemed to have resided with feral pigeons, as INTACT continues to defamatorily assert. Even if INTACT has not reported the coverage denial to any interinsurance database, it is factual that INTACT denied coverage within the past 5 years. Since "RB" is bound to state all coverage denials on insurance applications, INTACT's fraudulent coverage decision continues to deprive "RB" of his right to a truthful and accurate insurance profile! INTACT even ignores its Whistleblower, Privacy Officer Helen Cameron's commitment to the truth, when she confirmed that Claims Manager Amanda Myers had fabricated her claims "investigation".

INTACT Insurance's ongoing, fraudulent claims practices constitute the tort of Intentional Infliction of Emotional Distress

A mere six (6) days prior to the letter (to the right), INTACT's lawyer Nigel Beckmann had threatened litigation against INTACT's Insured, unless he should remove from this factual, public interest website, citation of Strata Property Act Section 155(b) and INTACT's letter of 30 September 2021, defining him as a Named Insured.

When the Insured refused to succumb to Beckmann's extortionary threats, Beckmann fired off the letter (to the right), wherein he revokes the option to modify this website to conform with INTACT's censorship, now demanding the deactivation of the entire website, irrespective of its content!

Since Beckmann was/is unable to specify any instance of false representation of this website, he no longer insists upon INTACT's censorship of statements that it finds uncomplimentary, however factual.

Beckmann instead, doubles down on his extortionary threat of litigation, unless the Insured should summarily renounce all of his sacred rights to free speech expression, by summary and permanent removal of the entire website from the internet.

THREAT OF SLAPP LITIGATION

On 02 October 2024 the Justice Services Branch of BC Attorney General Niki Sharma responded to the Whistleblower's request for intervention. Although the AG generally refrains from intervention in individual cases, there are exceptions, whenever the issues of individual cases have broad public interest ramifications, such as in this case. Although the AG hasn't yet made any commitment of intervention, she has invited further submissions, assuring that the Court will apply the provisions of the Protection of Public Participation Act, infra.

Sr Legal Counsel MATHIEU GRENIER and Legal Compliance Officer FREDERIC COTNOIR

are aware of this case, currently before the BC Human Rights Tribunal, INTACT had instructed its legal counsel, Nigel Beckmann, to subject an elderly, INTACT insured couple to the ignominy of the loss of their dignity, honour and reputation, by defamatorily accusing them of the criminal act of submission of an insurance claim, under the false pretence of being Insureds of INTACT.

Interestingly, according to his internet advertisements, Lawyer Beckmann's specialty is defamation/abuse of process defence, which legally holds him to an enhanced professional standard, particularly in view of his new role as a defamation "prosecutor" and purveyor of INTACT's wanton display of abuse of the Supreme Court's processes, in order to maliciously prosecute an INTACT Named Insured, as minutely detailed herein.

In aggravation of Mr. Beckmann's initial offence, he threatened and finally did sue the Insured, for the defamatory, false charge that Mr. Beckmann, himself, had fabricated! 

    Particularly, in view of his specialty, Mr. Beckmann is aware of the falsity of his scurrilous, defamatory charges, because INTACT Lawyer Christa Rae Cordick had repudiated Mr. Beckmann's defamatory charges, when she filed a legal pleading, in support of the Claimant; that the claim was NOT submitted under false pretences, as RB was a Named Insured under the INTACT policy!   Despite Lawyer Cordick's repudiation of Mr. Beckmann's fabricated, defamatory accusation, he refuses to retract same, even after his examination of a letter from INTACT, admitting that the Insured was a Named Insured under the policy. Despite his knowledge of the factual truth, Mr. Beckmann nonetheless engaged in the malicious prosecution of the Named Insured, by pursuit of two (2) arrantly conflicted of interest lawsuits against the Named Insured, on behalf of INTACT's rogue elements, Amanda Myers and Michele Vincent!

INTACT's violation of Human Rights began when the INTACT Named Insured (RB) filed an insurance claim in 2021, which was assigned to Claims Manager Amanda Myers. In contravention of legitimate claims practices, without even permitting that the Claimant submit a claims form, or even state the nature of his claim, Myers preemptively, summarily and arbitrarily nullified the entirety of the Insured's coverage, based upon a claims "investigation, which they falsely allege having conducted. To the right (redacted of confidential information) is the letter of 30 September 2021 that Myers sent to the Insured, falsely alleging the completion of a claims "investigation".

Since the coverage nullification had been based upon a spurious, fabricated claims "investigation", RB contacted Myers, with photographs and other evidence that the coverage nullification was based upon a falsity, but his pleas were ignored.

Thus, RB filed a complaint, pursuant to INTACT's 3-stage Claims Resolution protocol, which was acknowledged by INTACT's Ombuds[wo]man Michele Vincent. In said email (below) Vincent confirmed that she had assigned the Complaint to the Customer Experience Team (stage-2), for investigation and notification with a "Final Business Decision" letter.

Finally, several months later, the Insured received the notice of the result of INTACT's internal affairs investigation, the coveted Final Business Decision Letter, confirming that Myers had lied; that the allegation of a claims "investigation" was a complete fabrication!

In light of INTACT's confirmation that Myers and had fraudulently fabricated their "investigation", the Insured requested of Management's Frédéric Cotnoir and Mathieu Grenier that they assign the claim to one of the numerous, honest Claims Managers, in order to conduct an actual, standard good faith investigation. However, instead of rectifying the basis for the Claims Manager's fraudulent coverage denial, INTACT engaged lawyer Nigel Beckmann, who maliciously filed the two (2) separate civil actions against the Insured.

Although the Ombuds[wo]man denies that the Insured's Complaint had ever been assigned to the (Step 2) Customer Relations Team, the below email dispels yet another episode of her litany of lies:

Canada Criminal Code Sections 372(1), 137, 366(1), 380(1) were enacted to prevent this type of fraud, as committed by claims representatives!

However, instead of "remediating" the noxious rogue elements, INTACT's Corporate Managers have elected to allow the fraud to continue, by squandering thousands of dollars in fees for three (3) attorneys, plus administrative costs. The most recent waste of shareholder funding was INTACT's filing of two (2) civil actions against its whistleblower Insured, who had sought to protect INTACT's promise to the public as being "the most trusted Auto and Home insurance brand in Canada".

Indeed, well prior to the creation of the website, the Insured had repeatedly requested (1) that INTACT conduct a legitimate claims investigation, to replace the fabricated claims "investigation" by which (according to Privacy Officer Helen Cameron), Claims personnel Amanda Myers had fraudulently nullified the entirety of the Insured's coverage, and (2) that INTACT issue a Claims Experience letter to the Insured.

The Insured, RB, had always offered to permanently deactivate the website, in exchange for INTACT's agreement to the above two (2) compelling requests.

However, instead of agreeing to simply conduct a standard, good faith claims investigation, INTACT intransigently elected to sacrifice and abuse the judicial system, by the malicious filing of two (2) cloned, duplicate civil actions against the whistleblower Insured, which doubly compound the malicious derogation of the Insured's heretofore stellar credit rating!

As irrefutable evidence of INTACT's, Amanda Myers' and Michele Vincent's vexatious, malicious intent, none of them claims or seeks any monetary or other damages from the Insured, since they inflicted, not sustained any damage or injury. The only relief that these litigants seek is injunctive; i.e. that the Court order the Insured to permanently deactivate this website, the precise relief that the Insured had repeatedly, extrajudicially offered to INTACT for several months prior to the filing of their two (2) retaliatory civil actions. Thus, these vexatious Plaintiffs have committed a prima facie tort of abuse of process.

As to the requisite elements of a cause of action for the tort of abuse of process, in Oei v. Hui the B.C. Court of Appeal clarified that the tort has the three (3) elements, that are in abundance in the instant civil action: (i) a collateral and improper purpose; (ii) an overt act in furtherance of the collateral and improper purpose; and (iii) resulting loss. Stay tuned, as the cases wind their way to trial, at which Amanda Myers and Michele Vincent will be examined, under oath!

In measured response to INTACT's malicious expansion of the scope of its fraud, the Insured will continue to disclose, in an absolutely transparent, truthful and factual manner, a running account of INTACT's wrongful activities. As detailed herein, INTACT Privacy Officer Helen Cameron conducted a comprehensive, internal affairs inquest, which revealed that Claims personnel Myers had engaged in a fraudulent coverage rescission, based upon an "investigation" that they had jointly fabricated!

At a great personal financial and emotional expense, the Insured has filed responsive legal pleadings and a Cross-Complaint against INTACT and its rogue elements. It is urged that INTACT abandon any impulse to undertake punitive measures against the courageous Privacy Officer, whistleblower Helen Cameron!

INTACT's two (2) cloned, duplicate civil actions against its whistleblower Insured constitute yet another instance of INTACT's relentless, disgraceful, malicious crusade to punish its Insured, for the exercise of his Charter rights to freedom of speech and expression.

INTACT Claims Manager Amanda Myers, by way of criminal fraud, arbitrarily, capriciously and summarily rescinded a Named Insured’s coverage, on the false, fabricated basis that as the result of her claims “investigation”, the Insured had physically "possessed", "occupied" and "used" an infected and infectious, faecal matter-laden, ornamental, pigeon roost ledge (as depicted above) which is physically inaccessible from the Insured’s high rise unit. The ledge is devoid of any means of ingress/egress. It is legally, physically and architecturally, common property; not part of any unit of the residential building.

The below centre image is of the ornamental pigeon roost ledge, that the discredited Amanda Myers had accused the Insured of having inhabited. The images to the left and right are of the health hazard abatement team from specialist Humane Solutions, which, in accordance with BC WorkSafe and OSHA regulations, the remediation crews were required to don protective hazmat suits, special air filtration masks, and safety tie lines, as they gained access to the ledge, by way of a work platform, anchored at the roof of the high rise building. The Named Insured paid $2,541 for the abatement service.

In the letter to the left, Claims Manager Amanda Myers notified the Named Insured of their arbitrary, capricious, summary nullification of the entirety of his INTACT property insurance coverage, per the findings of a joint claims investigation that they alleged to have conducted and completed.

When the Named Insured filed a formal Step-2 Complaint with the Customer Experience Team, Unit Claims Manager Donna McKernon fired off the below email, confirming her opinion of the validity of Myers' coverage nullification, and that the Insured's only option would be litigation.

In the letter to the right, INTACT's conscientious Privacy Officer Helen Cameron announced the results of her internal affairs investigation, exposing Amanda Myers' fraudulent nullification of the Named Insured's coverage. According to Privacy Officer Cameron's probe, Myers' averment of having conducted and completed the claims investigation had been an arrant fabrication!

INTACT'S WHISTLEBLOWERS' COMPLAINT INVESTIGATORS

(Ein allgemein bekanntes Symbol für Täuschung sind die drei Affen, die nichts Böses sehen, hören oder sagen.)

INTACT INSURANCE AND ITS INCREASINGLY COSTLY BAD FAITH CAMPAIGN

In a resounding rebuke of Attorney Nigel Beckmann's position that Strata Property Act Section 155(b) does not exist, the BC Supreme Court recently not only reaffirmed the scope and purview of Section 155(b), it ruled, a fortiori, that even Airbrn overnight guests are insured under a strata corporation’s property insurance policy. [Citation: Strata Plan VR 2213 v. Schappert, 2023 BCSC 2080].

INTACT INSURANCE CO v R.B. (VLC-S-S-244484 and VLC-S-S-244577)

SLAPPs are Strategic Lawsuits Against Public Participation. These malicious lawsuits chill free speech and stifle the whistleblower's prerogative, indeed moral imperative, to duly report fraud and other criminalities. SLAPPs are used to curtail free speech and harass whistleblowers by necessitating that they expend personal financial resources, in defence of meritless and malicious SLAPPs. The two (2) duplicate SLAPP civil actions that INTACT has prosecuted against its own Insured is a stark case in point, and it is urged that INTACT refrain from filing a similar SLAPP against its own Privacy Officer, Helen Cameron, who had reported to the OIPC the findings of her internal affairs investigation, which confirmed that an INTACT Claims Manager and her subordinate had engaged in fraudulent claims practices! As detailed herein, by the filing of two (2) duplicate, arrantly meritless SLAPP actions against its Insured, INTACT has doubly exploited and doubly abused the judicial system, in its costly crusade to curtail the freedom of speech rights of the Insured whistleblower, who had filed a fact-based, formal complaint against INTACT with the BC Human Rights Tribunal, regarding INTACT's fraudulent, discriminatory claims practices. The purpose of INTACT's SLAPP litigation is to exhaust the Insured's personal financial resources, such as to compel him to withdraw his whistleblower complaint. As it is essential public policy to protect whistleblowers' rights to report fraudulent activity from the chilling effect of a SLAPP, the province of British Columbia has enacted legislation that provides a process for courts to identify a claim as a SLAPP and summarily dismiss it.

Listen to a song about INTACT's verbotene business practices, of filing duplicate, clone SLAPP actions against a whistleblower who had exposed wrongful activities, on the part of certain rogue claims personnel

When Plaintiff, Claims Manager Amanda Myers testifies at trial, she will be tasked to justify her fraudulent claims "investigation", as well as other discrepant claims practices!

The CBC's "Go Public" staff has expressed an interest in this extraordinary story. However, the Insured has refrained from presenting the details to the CBC, in the naïve expectation that while INTACT's lawyer, Nigel Beckmann, considers compliance with Court Rule 7-1(1), that he recommend to his Client that it timely cease its cover-up of fraud.

Section 346 (1) Every one commits extortion who, without reasonable justification or excuse and with intent to obtain anything, by threats, accusations, menaces or violence induces or attempts to induce any person, whether or not he is the person threatened, accused or menaced or to whom violence is shown, to do anything or cause anything to be done.

Section 372 (1) Everyone commits an offence who, with intent to injure or alarm a person, conveys information that they know is false, or causes such information to be conveyed by letter or any means of telecommunication.

Section 137 Every one who, with intent to mislead, fabricates anything with intent that it shall be used as evidence in a judicial proceeding, existing or proposed, by any means other than perjury or incitement to perjury is guilty of an indictable offence and liable to imprisonment for a term not exceeding fourteen years.

Section 366(1) Every one commits forgery who makes a false document knowing it to be false, with intent (a) that it should in any way be used or acted on as genuine, to the prejudice of any one whether within Canada or not; or (b) that a person should be induced, by the belief that it is genuine, to do or to refrain from doing anything, whether within Canada or not.

Section 380(1) Every one who, by deceit, falsehood or other fraudulent means, whether or not it is a false pretence within the meaning of this Act, defrauds the public or any person, whether ascertained or not, of any property, money or valuable security or any service (a) is guilty of an indictable offence.

This public interest website is dedicated to INTACT's alleged pursuit of good faith claims management practices

WITHOUT PREJUDICE/RESERVATION OF RIGHTS

Exemplary of INTACT's aversion to the truth and the facts, and commitment to extraorindarily egregious bad faith, Ombudsman Michele Vincent falsely denies that this matter had been assigned to the 2nd step Customer Experience Team, in response to the Named Insured's formal Complaint. In yet another measure of Vincent's malicious approach, she refuses to provide the Insured with a common insurance industry-wide Claims Experience letter, as he had requested!

Another instance of Ombuds[wo]man Vincent's contempt for the facts, she refuses to issue a Claims Experience letter (request to the right), pretending, after almost three (3) years of INTACT's exploitation and abuse of the Insured, provincial and federal insurance regulators, OIPC, as well as the Courts, that INTACT has no records of the Named Insured!

As indicated by the letter to the left, and the below legal pleading, INTACT had confirmed that RB was a Named Insured of the policy. However, as indicated by his letter to the right, INTACT Lawyer Nigel Beckmann contradicted INTACT's confirmations of RB's status, by fabrication of a false charge, defamatorily and falsely accusing RB of submission of the insurance claim under the false pretence of being an insured (letter to the right). In aggravation of the initial offence, Beckmann pugnaciously committed the tort of abuse of process, by filing two (2) duplicate civil actions against RB, for the exposure of Beckmann's wrongdoings, as well as the fraud of his clients.

Curiously, Lawyer Beckmann recently filed a legal pleading, by which he contradicts his own Clients, who admit that RB is a Named Insured. If Mr. Beckmann has access to an internet connexion, then it is respectfully requested that he press the below link to Strata Property Act Section 155(b).

In a bizarre twist to this cause celebre case, on 13 August 2024, Attorney Beckmann filed a legal pleading, wherein he finally admitted that Claims Manager Amanda Myers had falsified her claims "investigation", but Mr. Beckmann blames the Insured for being so naïve as to believe that an investigation had been conducted, since no investigator had ever come to the pigeon roost ledge to inspect, supra!

Monsieur Charles Brindamour has been the CEO of Intact Financial Corporation since 2008. Originally established in 1809 under the name Halifax Fire Insurance Association, Intact has grown to become the largest insurance provider in Canada. During CEO Brindamour’s 15-plus year stewardship of the firm, he has been much-lauded for his efforts promoting fiscal restraint, sustainability and innovation within the company. He is also a member of the board directors with Intact, as well as the Geneva Association, the Canadian Imperial Bank of Commerce, and the Business Council of Canada.

1. Public Statements: CEO Brindamour has publicly addressed the issue of inflated legal costs in the insurance industry.

2. Industry Reports: Reports from industry organisations, such as the Insurance Bureau of Canada, have echoed CEO Brindamour's concerns about the impact of inflated legal costs upon the insurance industry. The overwhelming consensus of statistical input demonstrates that assignment of a matter to OUT HOUSE COUNSEL is contraindicated, whenever IN HOUSE COUNSEL is available, and sufficiently competent not to occasion undue regulatory and legal entanglements, that often arise, whenever OUT HOUSE COUNSEL is permitted to commandeer a dossier.

3. Earnings Calls: During Intact Financial Corporation's earnings calls, CEO Brindamour has discussed how the company has been pricing for inflationary pressures, including legal costs, since 2016.

4. Comparative Analysis: CEO Brindamour's actuarial expertise has been recognised in the industry for addressing and reducing legal costs.

Risk Management Expertise: CEO Brindamour's formation as an actuary enables his expertise to assess and manage financial risks, which is invaluable for INTACT's strategic planning and decision-making.

1. Data-Driven Decisions: As an actuary, CEO Brindamour excels at analysing data and using it to make informed predictions and recommendations, helping INTACT to make more accurate and effective business decisions.

2. Cost Efficiency: With his expertise in evaluating financial outcomes, CEO Brindamour has been essential to identify cost- saving opportunities and optimise INTACT's financial performance.

3. Regulatory Compliance: CEO Brindamour is well-versed in regulatory requirements, especially in industries like insurance and finance, ensuring that INTACT stays compliant with relevant laws and regulations.

4. Long-Term Planning: CEO Brindamour is highly skilled in long-term financial planning, which assures that INTACT be prepared for future challenges and opportunities.