Affidavit #1 Z.

Parihar
Made November 29, 2022

No. S-210831
Vancouver Registry
IN THE SUPREME COURT OF BRITISH COLUMBIA

BETWEEN:

CANADIAN SOCIETY FOR THE ADVANCEMENT OF SCIENCE IN PUBLIC POLICY

PLAINTIFF
AND:

HER MAJESTY THE QUEEN IN RIGHT OF THE PROVINCE OF BRITISH

COLUMBIA AND DR. BONNIE HENRY IN HER CAPACITY AS PROVINCIAL HEALTH
OFFICER FOR THE PROVINCE OF BRITISH COLUMBIA

DEFENDANTS
Brought under the Class Proceedings Act, R.S.B.C. 1996, c. 50

AFFIDAVIT

I, Zubin Singh Parihar, senior systems engineer, with an address for service in
these proceedings at 1400 - 1125 Howe Street, in the City of Vancouver, in the Province
of British Columbia, MAKE OATH AND SAY THAT:

1. I am one of the directors of the plaintiff, Canadian Society for the Advancement of
Science in Public Policy (the “Society”), and as such have personal knowledge of the
facts hereinafter deposed to save and except where stated to be upon information and
belief, and where so stated, verily believe them to be true.

2. make this Affidavit in support of an application to certify this action as a class

proceeding.

am a resident of British Columbia.

am authorized to make this Affidavit by the Society.

 5. have a Bachelor of Technology in Data Communications and Network Security
from the British Columbia Institute of Technology. work in the field of
information
Technology as a senior systems engineer.

6. am also the CEO and Founder of Bubbles Software Corp. A copy of my

curriculum vitae is attached as Exhibit "A".

7. I have personally been affected in many ways by the defendants’ declaration of

emergency due to Covid-19 and subsequent orders, directives, and related policies.

8. Between March 2020 and March 2021, wanted to participate in public protests
against the defendants’ and the federal government's Covid-19 policies, but due
to Dr.
Henry's orders “Gatherings and Events” made on November 19, 2020, December 2, 9,
15 and 24, 2020, did not. would only walk by and watch from a distance but was afraid
to engage in the protests as need a clean record for my work. In December 2021,
walked by several public protests held in front of the Art Gallery in Vancouver, B.C. but
despite wanting to, did not participate because did not want to face high penalties or
jail time.

9. Because of my work, did not want to face having a criminal record for breaching
the law. If am raising capital for my business and potential investors do a background
check on me, a criminal record would negatively affect my ability to raise funding.
Travelling to the United States is also important for my work and having a criminal record
or a record of me being sent to jail could result in a denial of entry into the United States.

10. I'am 41 years old and not double vaccinated as have concerns about the efficacy
and side effects of the available vaccines against Covid-19 in British Columbia. am also
concerned that the vaccines were not properly tested compared to other vaccines. know
several people who have had serious adverse affects. For example, a close friend lost
feeling in her entire arm for approximately two weeks after the first dose of the Pfizer
vaccine.

11. Between June 16, 2021 and June 23, 2021, was very worried and stressed
because was unable to visit my Grandmother, who had suffered a stroke and was cared
for at Eagle Ridge Hospital in Coquitlam, British Columbia.

12. I felt angry, depressed, lonely and isolated from my community because was
unable to go to social gatherings like the Vancouver Canucks games at Rogers
Arena
with my vaccinated friends during the months of October 2021 to April 2022. enjoy going
to hockey games and meeting with friends there. was also unable to go to restaurants,
movie theatres, the gym and Kundalini yoga classes. Attending social gatherings and
places like these with friends is important to me because these are venues where my
friends and discuss news, politics, sports, music, art and other topics of interest. feel
connected to my community and feel that can participate freely in our society when
engaging in social activities like these.

13. am also single and have not been able to meet potential partners from March
2020 until April 2022 at the types of events described in the previous paragraphs. do
not like on-line dating and the various orders and Covid-19 policies of the defendants
have significantly affected my opportunities to meet people. have not gone on a single
date between March 2020 and April 2022 despite wanting to meet a potential long-term
life partner. In the past, have met girlfriends while at community events, like through the
yoga community. have been involved in the Metro Vancouver yoga community for the
past 11 years and have attended yoga classes, lectures, and meditation events. There
are a lot of like-minded people at yoga events, so they have always been a great place
to meet new people, either romantically orjust socially. Apart from the yoga community,
also meet people date at the gym (Steve Nash Fitnessworld), or at tech events.

14. During the months of October 2021 to April 2022, stayed mostly at home and
went out occasionally to buy groceries and for walks in the park, weather permitting. As
the weather was mostly rainy and cold, my friends preferred to go to restaurants and pubs
and other venues the unvaccinated were not allowed in.

15. obtained a doctor's exemption from wearing a mask but was still unable to go to
some grocery and other stores. For example, while the masking mandate was still
required have been denied entry to the Shoppers Drug Mart on Davie Street, in
Vancouver, book stores, clothing stores, and grocery stores. was denied entry for not
wearing a mask at The Independent and Safeway grocery stores on Davie Street in
Vancouver. Sometimes they would let me in but not always as it depended on who was
at the door.

16. For other stores that did not let me in never bothered going back. For example,
stopped going to JJ Bean, where used to get coffee and meet friends regularly, because
their staff (at the Yaletown location) refused to recognize my mask exemption and were
very rude to me.

17. While the masking mandate was on, the thought of going to the store made me
nervous, anxious and hesitant as never knew if there was going to be an issue with my
exemption and did not want to have to argue with staff.

18. Because was not vaccinated and not wearing a mask, people would shun me.
For example, in December 2021, lived in a rental building at 1155 Harwood Street in
Vancouver. would go into the elevator and other residents would not come in because
 was not wearing a mask. Once a man did come in and commented that was not
wearing a mask, said that had a mask exemption, and then he asked if
was
vaccinated. When replied that was not, he immediately pressed the elevator button for
the next floor and he got out because he said was not vaccinated.

19. Until April 2022 when the vaccination mandate was lifted, resigned myself to not
go to social events — including art events organized by my friends, which were usually
held at bars or venues serving alcohol.
Representative Plaintiff
20. am willing to personally act as a representative plaintiff in this action,
and understand my personal obligations if appointed to, amongst others:

become familiar with the issues to be decided by the Court;

review the Notice of Civil Claim and any amendments to the claim;
provide this Affidavit in support of the motion for certification;
attend, if necessary, with a lawyer for cross-examination on my Affidavit;
attend, if necessary, with a lawyer for an Examination for Discovery where
I will be asked questions relevant to this proceeding;
attend, if necessary, with a lawyer at trial to give evidence and be cross-
examined on that evidence;
receive updates on the action from time to time;
express my opinions about the lawsuit to my lawyers; and
express my opinion to my lawyers and to the Court if offers to settle the
action are made.

21. To date, have taken the following steps to fairly and adequately represent the
interests of class and subclass members as part of my duties as a director of the Society:

prepared this affidavit in support of certification;

reviewed the Amended Notice of Civil Claim and proposed further
amendments;
iii. reviewed the notice of application for certification and other court
documents:
iv. reviewed the litigation plan.

22. |, in my personal capacity, will do my best to fairly and adequately

represent the
interests of class members. will instruct Class Counsel as necessary, and will keep class
members informed of developments in the proceeding. will be available for court
processes as required.
23. If this lawsuit is certified as a class proceeding, the Court will certify issues of fact
and/or law that are common to class members. am not aware of any conflict between
the or my interests and the interests of other class members.

24. The Society will do its best to fulfill its responsibilities as a representative plaintiff.

25. have read all of the affidavits filed by the Society in this proceeding.

26. difficult to estimate the size of the class as that information is best known to
the defendants. However, after reviewing some of the affidavits of defendants, which
have the best information, my estimates are:

v. Main class is approximately 5.2 million people, being residents of British

Columbia (less those under 18 years old or the number over 18 years old);
vi. Medical subclass consists of approximately 328,000 people based on the
reduction in access to primary care in T. affidavit #1 Exhibit G
(page 35), assuming one service per person;
vii. The vaccination subclass is 376,752 people based on Dr. Emerson's
affidavit #2, paragraph 9, Exhibit A;
viii. The religious subclass is more difficult to estimate but is relatively small,
considering the high vaccination rates in British Columbia. estimate it
would be less than 376,752 people.

27. lam not aware of any fact material to the certification application that has not been
disclosed in this affidavit or in any of the affidavits previously filed by Kipling Warner and
other affidavits filed on behalf of the Society in this proceeding.

AFFIRMED BEFORE ME at Vancouver,

British Columbia, day of
November, 2022,

Barrister & Solicitor

1400-11256 Howe Street
VANCOUVER B.C. V6Z 2K#8
778-946-9980
 Zubin Parihar 001
Suite 1806 — 1155 Harwood St, Vancouver, BC, VOE 1S1
Tel: 604-767-7900 Email: zparihar@gmail com

Expertise:
«Strong Technology Skills * Puppet Configuration Management
Leadership Ability Apache Web Server Administration
Linux Systems Administration (Red Hat/CentOS/Ubuntu) * Network Administration Services
Developing and Automating Processes * Systems and Network Security
KVM and Xen Virtualization Network Application Troubleshooting
«Server Scaling Practices » Bash Shell Scripting
High-Availability * Technical Documentation

Skills:

Technical:
Scripting and Programming Languages: Shell Scripting, Awk. Ansible
«Databases: MySQL, Percona, PostgreSQL
Opcrating Systems: Red Hat, CentOS, Fedora, Ubuntu, Debian, OpenSuse, Free-BSD. Solaris, Windows
7/XP/2003/2008/2012
«Networking Applications: Apache, Nginx, BIND DNS, NFS, RSYNC. Kickstart, Preseed, Samba, Snort, SSH,
IPTABLES, DHCPD, CVS, Subversion, Mercurial, Git, LVS, Squid, HAProxy. NTP,
Heartbeat, DRBD, SMTP, MRTG, Nagios, Icinga, Cacti, Munin, Asterisk. Bacula.
OpenVPN, Memcached. Repeached, Redis. Awstats, PXE,
GlusterFS, iSCSI, FreelPA, Katello, Satellite
Configuration Management: Puppet, Saltstack, Red Hat Satellite. Cobbler, Func, DSH, Landscape
eSecurity Applications: Nessus, Snort, NMap, Tripwire
. Virtualization Applications: VMWare, KVM, Xen, VirtualBox,
* Containers Technologies OpenVZ, LXC, LXD. Docker, Kubernetes
* Cloud Technologies AWS, Softlayer, Terratorm

Interpersonal:
* Motivated and Hard working * Comprehensive Teacher * Natural Leader
* Composed in I'ace of Disaster Self-Starter Excellent Oral and Written Skills.
* (Creativeand Innovative * Can Work Independently * Attention to Detail
* Flexible and Intuitive * Enjoy Working in Teams * Patient

Work Experience:

March 2017 — Present: Bubbles Software Corp. — IT Automation and Deployment Consultant
Vancouver, BC — https://bubbles.io

About the Organization: Bubbles provides an infrastructure automation solutions to help organizations build their DevOps
platform and workflow to accelerate infrastructure and code delivery while utilizing the organizations existing IT
infrastructure.

About the Role:

+ Bubbles product design and programming - https://www.bubbles.io/bubbles-run-through
«Product customization and on-site implementation Lins IS A "referred to inthe
«Product integration with existing client infrastructure of 2. Pa
sworn befpre me at
Role Overview:
+
Client consultation and solution design
«Dev and Test environment design and implementation
day 9
rs200
Bash Scripting for taking Affidavits
+ Ansible + Puppet Configuration Management
Columbia
Auguest 2015 — March 2017: Global Relay — Sr. Systems Administrators
Vancouver, BC — https://www.globalrclay.com

About the Organization: Global Relay is a SaaS technology services company providing email archiving, instant message
archiving, social media archiving, compliance and supervision solutions in highly regulated industries mostly in the finance
sector. Global Relay is a significant player in the cloud-based messaging and archiving industries with a client base that
include 22 of the world's 25 biggest banks. Their Data Centers which are located in North Vancouver and Toronto consists
of 2400+ Servers
About the Role:
Configuration Management Implementation
VDI Project Implementation
Solaris Zones to CentOS Linux Container Migration
Ubuntu Linux Desktops Management
Staff Training
Technical Documentation

Role Overview:
+ Automated VDI Deployment Process * Landscape Management for Ubuntu Desktops
* Solaris to CentOS Linux Migration Katello Management and Deployment
+ Implemented Solaris Zones to OpenVZ Containers * FreelPA Management
Implemented ZFS on Linux
Configuration Management
* Kickstart to Puppet Module conversion

ly 2014 — December 2014: BAMSAS — IT Consultant — Project Contract

Vancouver, BC — hitp://www.bamsas.com/

About the Organization: BAMSAS is a software and services company that develop and support a full-featured software
platform for wagering and competitive games offered for the web and mobile land-based markets. BAMSAS has extensive
experience in the U.S. gaming industry which successfully navigates through the complexities of offering interactive real
money betting and sports games. The Data Center is located in North Carolina and consists of 100+ Servers

About the Role:

Project Planning
Configuration Management Planning + Implementation
Automation Project Planning + Implementation
Retrofitted 60 Linux Servers
Staff Training
Technical Documentation

Role Overview:
» Configuration Management Project * Automation Project
¢
Built Puppet Master Server + Replicate production infrastructure
+ Built Puppet Modules for various Application Services «Automatically register VM's to IP, MAC Address, DNS
Existing Servers to be Puppet Agents * Technical Documentation

March June 2014: Emberlight Technologies — Operations Manager

Vancouver, BC — ht ww.emberlight.ca/

About the Organization: Emberlight Technologies is a small data mining and data analysis company that specializes in
online gaming data, in particular poker data. Emberlight has developed highly innovative methods and software to watch
every Poker game being played online thereby capturing each and every statistic played in real-time where it then stores it
in a central database (100+TB — Big Data). These statistics are made available instantly online and is used to provide
business intelligence results to prominent clients in the industry from operators to software providers. The reports are for
player analysis behavior, market trend analysis, security reports such as bot-detection and collusion. The Data Center is
located in Austin, Texas and consists of 100+ Servers
About the Role:
Designed Infrastructure
Took over failing infrastructure from previous company
Report Directly to Company Owner/Director
Project Planning
Capacity Planning
High-Availability Planning
Disaster Recovery Planning
Network Architect
Systems Administrator
Database Administrator
Network and Systems Performance Tuning
Worked closely to support and guide internal and outsourced development teams
Maintained 100+ Servers, 800+ VM's across multiple Data Centers, Cloud Providers and VPS providers
Setup Development, Staging and Production Environments
Technical Documentation
Vendor Management — Dell, IBM
On-Call Responsibilities — 24 x 7

Role Overview:
Re-Architcet Operations after company buy-out Database Migration Project
Build Structure. Consistency with Automation Process = Reduce 100TB of Data to 35TB of Data
* Redesign to be ligh-Availability, I‘ault Tolerant and Reduce from 22 Node Cluster to 6 Node Cluster
Redundant - 2 years = Migrate from MySQL to PerconaDB
Optimize Resource allocation a Improve Speed Performance
* Virtualization Project Improved SLA from 99% to 99.95% - 2 years
= Virtualize Servers to KVM Instances Hardware Purchasing
Redundancy Project Contact in with outsourced consultants
= Active/Passive fail-over using DRBD * Monitoring
= MySQL Replication Database
Monitoring Project * Networking
= Monitoring with Munin and lcinga: * Systems
* OS Monitoring Automation
+ Application Monitori *»
Boot
«Hardware Monitoring Kickstart
Backup Project * Preseed
= BYOD 105TB NAS Storage Server + Custom Install Scripts
High-Availability Project Technical documentation
= HAProxy for DB Availability Remote Management via SSH
= LVS for Load Balancing and HTTPD
Availability

November 2013 —unne 2014: ICBC — IT Consultant — Project Contract

Vancouver, BC —
About the Organization: ICBC is a provincial crown corporation in British Columbia. Their purpose is to provide
universal public auto insurance in BC. Locatedin North Vancouver, ICBC's large array of insurance application services run
on its 2,200 servers.

About the Role:

Project Planning
Capacity Planning
Configuration Management Planning + Implementation
Automation Planning + Implementation
Retrofitted 200+ Linux Servers
Technical Documentation

Role Overview:
+ Configuration Management Project Automation Project
Built Puppet Master Server Re-Architected Red Had Satellite Implementation
Puppet for various Application Services Implemented Cobbler for Automated installs
+ Converted Existing Kickstarts to Puppet Module Technical Documentation
Retrofitted Existing Servers to be Puppet Agents
September 2013 — May 2014: Dyrand Systems — Linux Consultant
Vancouver, BC ww.dyran

About the Organization: Dyrand Systems is an IT Service provider that allow businesses to outsource their IT Department.
Dyrand provides support and network security for small businesses.

About the Role:

Project Planning
Capacity Planning
Networking Architect
Backup and Data Recovery Planning
Networking Implementation
Configuration Management Planning + Implementation
Setup Development, Staging and Production Environments
Technical Documentation

Role Overview:
* Designed Network [Layout
* Production Environment Designed Backup and Data Recovery Process
* Testing Environment BDR Site in AWS
Development Environment Created Kickstart Installation Scripts for each server
Interface with clients on requirements Implemented Salt Configuration Management
Technical Documentation

July 2010 — March 2011: Electronic Arts — Systems Engineer

Burnaby, BC —

About the Organization: Electronic Arts Sports World Online is the social networking aspect of its console games where
all its’ console users can post video replays, self-created 3D avatars, game statistics and comments. The online platform
integrates seamlessly with its web presence and its console interface with a large community of users world wide. The
office is stationed in Burnaby with a total of 1600 employees. The operations team that I am working with consist of 8
Systems Administrators.

About the Role:

Maintained 400+ Servers in our data center across four data centers
Installed Development and Production Environments
Deploy software builds to Dev, Stage and Production Environments
Worked closely with internal and outsourced development teams
Troubleshooting with the development team
Wrote and maintained technical documentation
On-Call Responsibilities

Role Overview:
KVM Virtualization Administration Create and Optimize Processes
Setup Monitoring using Zabbix and Monit DNS Maintenance
Apache Administration Memcached Maintenance
Load Balancing Servers Developer Application Troubleshooting
Backup Strategy and Implementation with RSYNC Technical Documentation
BASH Scripting File Sharing
Compile, Install and Build RPM Packages Remote Management via SSH
Optimize Architecture On-Call Duties
May 2009 — February 2010: DES Games IT Consultant / Systems Administrator
—

Vancouver, BC - http://www.desgames.com/

About the Organization: DES Game is a casual and social gaming company. The majority of their games are played
through Facebook and MySpace with their largest community residing on Facebook. The games are developed rapidly, are
all programmed in flash and/or PHP and is linked in with an online virtual currency. The office is located in Gastown with
over 20 staff including 2 Systems Administrators.

About the Role:

Designed and implemented scalable network architecture from scratch
Built production servers
Built developer environment
Built virtual testing environment with Xen on the Centos Linux distribution
Developed staging and launching scripts and procedures
Assisted and advised development team
Wrote and maintained technical documentation
On-Call Responsibilities

Role Overview:
* Administration and Replication Backup Strategy and Implementation with RSYNC
¢
Xen Virtualization Administration Amazon Cloud Management
* Setup Monitoring using Cacti and Nagios BASH Scripting
* Production Systems Optimization SmartFoxServer Pro
* Kernel and Networking optimization DNS Maintenance
PHP Optimization: APC Developer Application Troubleshooting
* MySQL Optimization: Memcached, my.cnf Technical Documentation
Subversion Implementation and Maintenance File sharing
Apache Administration Backup Maintenance and Restoration
LAMP Installation Remote Management via SSH
Load Balancing Servers Office Network/Systems Administration - MAC OS X
Squid Caching On-Call Duties

January 2006 — January 2009: AirG Inc — Network/Systems Administrator

Vancouver, BC — http://corp.airg.com/

About the Organization: AirG is a mobile social networking and gaming company. Their mobile community has more
than 20 million users that are interconnected to each other online via their mobile carriers globally. AirG’s services are all
offered through their WAP browser interface. Services offered are multi-player games, chat rooms, dating services, video
uploads and downloads, picture uploads and downloads, ring tone downloads and more. The head office is located in
Downtown Vancouver with 100+ staff including 8 Network, Systems and IT Administrators.

About the Role:

Installed and maintained 400+ production systems in our data center
Designed, developed, installed and maintained development and test environments
Platform Unification Project
CVS to Subversion migration project
Led Virtualization Project
Consolidated existing development environments and deployed over 150 OS's across 6 Xen virtual host machines
Provided developers with troubleshooting in their application development and technical support
Unified application platform and automated installation process
Responsible for over 100 system installations
Technical documentation for Disaster Recover Project
On-Call responsibilities for 24x7 mission critical production machines
 006
Role Overview:
Subversion Implementation and Maintenance Data Center Rack, Server and Wire Installations
MySQI. Administration VPN Administration
Apache Administration Setup Monitoring
LAMP Installation File sharing
Xen Virtualization Administration Backup Maintenance and Restoration
DNS Maintenance Benchmarking Different Hardware
Disaster Recovery Plan Maintenance Network Vulnerability Assessment
Developer Application Troubleshooting Network Intrusion Detection
Automation Using Bash Shell Scripting Host Intrusion Detection
Load Balancing Servers Remote Management via SSH
Help Desk Requests Peer Training
Technical Documentation Hard Drive Recovery
SMS Gateway Installation and Maintenance CVS Repository Maintenance

ebruary 2005 — December 2005: Providence Healt h Care — Project Coordinator

Vancouver, BC -

August 2004 — October 2004: Wizard IT — Junior Network and Systems Administrator
Vancouver, BC -

February 2004 — July 2004: Stepup Technologies — Junior Systems Administrator

Vancouver, BC

January 2003 — December 2010: British Columbia Institute of Technology — Part-Time

Bachelor of Computer Systems Technology Program
o Major in Network Security and Administration
o Minor in Data Communication

September 2000 — December 2002: British Columbia Institute of Technology — Full-Time

Computer Systems Technology Program
o Diploma Major - Linux Administration & Information Systems

References:
« Available upon request