Court File No. 4- 1039-19 FEDERAL COURT BETWEEN BUEAI 20ers JOHN DOE #1, JANE DOE #1, JOHN DOE # JOHN DOE #3 and JANE DOE #2 ~and- = a. HER MAJESTY THE QUEEN IN RIGHT OF CANADA | Defendant 4 | STATEMENT OF CLAIM 7 TO THE DEFENDANTS | A LEGAL PROCEEDING HAS BEEN COMMENCED AGAINST YOU by the Plaintiffs. The claim made against you is set out in the following pages. IF YOU WISH TO DEFEND THIS PROCEEDING, you or a solicitor acting for you are required to prepare a statement of defence in Form 171B prescribed by the Federal Courts Rules serve it on the plaintiffs’ solicitor or, where the plaintiffs do not have a solicitor, serve it on the plaintiffs, and file it, with proof of service, at a local office of this Court, WITHIN 30 DAYS after this statement of claim is served on you, if you are served within Canada | Ifyou are served in the United States of America, the period for serving and filing your statement of defence is forty days, If you are served outside Canada and the United States of America, the period for serving and filing your statement of defence is sixty days cu Copies of the Federal Court Rules information concerning the local offices of the Court and other necessary information may be obtained on request to the Administrator of this Court at Ottawa (telephone 613-992-4238) or at any local office. oo IF YOU FAIL TO DEFEND THIS PROCEEDING, judgment may be given against you in your absence and without further notice to you. wall ULL UE LLLWo lu Sa lulu 4 oi vom Date’ Issued by: JUL 15 207 ' 2017 MICHELLE GAUVIN as REGISTRY OFFICER AGENT DU GREFFE (Registry Officer) Address of local office: TO: 180 Queen Street West Suite 200 Toronto, Ontario MSV 3L6 HER MAJESTY THE QUEEN IN RIGHT OF CANADA (ON BEHALF OF THE CANADIAN SECURITY INTELLIGENCE SERVICE) Department of Justice Canada Ontario Regional Office ‘The Exchange Tower 130 King Street West, Suite 3400, Box 36 Toronto, Ontario MSX 1K6Uo ma 1 Ub Lu li 1 RELIEF SoucnT 1. The Plaintifi’s, John Doe #1 (“Alex”), Jane Doe #1 (“Bahira”), John Doe #2 (“Cemal”’), John Doe #3 (“Emran”) and Jane Doe #2 (“Dina”) (collectively, the “Employees”), claim @ ) © @ © 9) @® (n) @ oO a Declaration that the Defendant, referred to as the Canadian Security Intelligence Service or “CSIS”, owed and was in breach of contractual, constitutional, statutory and common law duties to the Plaintiffs; a Declaration that CSIS has breached the Employees’ rights under the Canadian Charter of Rights and Freedoms, (“Charter”) Part 1 of the Constitution Act, 1982, being Schedule B to the Canada Act 1982 (U.K.), 1982, ¢. 11, specifically with respect to ss, 2(a) and 15 of the Charter, a Declaration that CSIS is liable to the Plaintiffs for the damages caused by its breach of contractual, constitutional, statutory and common law duties; non-pecuniary general damages arising from CSIS’s breach of contractual, constitutional, statutory and common law duties in the amount of $15,000,000; pecuniary damages arising from CSIS’s breach of contractual, constitution, statutory and common law duties, including for loss of income relating to loss of promotional opportunities, promotions, overtime, educational opportunities, and Joss of pension value in the amount of $15,000,000; special damages in an amount to be determined, including future and anticipated medical and out of pocket expenses; aggravated, exemplary and punitive damages, and damages pursuant to s.24(1) of the Charter in the amount of $5,000,000; prejudgment and post-judgment interest; the costs of this action, including HST and other taxes as applicable, on a substantial indemnity basis, and such further and other relief as this Honourable Court may deem just.