CY- H- 06 714780 -CC0O

ONTARIO
SUPERIOR COURT OF JUSTICE
DR. ASHVINDER KAUR LAMBA

and
Plaintiff
ROCCO GALATI and ROCCO GALATI LAW FIRM PROFESSIONAL CORPORATION

Defendants
INFORMATION FOR COURT USE

1, This proceeding is an: [X] action [ ] application

2. Has it been commenced under the Class Proceedings Act, 1992? [ |] yes [X] no

3. Ifthe proceeding is an action, does Rule 76 (Simplified Procedure) apply? [ ] yes [X] no
Note: Subject to the exceptions found in subrule 76.01 (1), it is MANDATORY
to proceed under Rule 76 for all cases in which the money amount claimed or
the value of real or personal property claimed is $200,000 or less.

4, The claim in this proceeding (action or application) is in respect of:

(Select the one item that best describes the nature of the main claim in the proceeding.)
Bankruptcy or insolvency law [ ] Motor vehicle accident [ |
Collection of liquidated debt [ ] Municipal law [ ]
Constitutional law L | Partnership law [ |
Construction law (other than construction lien) [ ] | Personal property security [
Construction lien [ ] Product liability [ |
Contract law [ ] Professional malpractice (other than medical) L X]
Corporate law [ ] Real property (including leases; excluding mortgage or [| |
charge)
Defamation [ ] | Tort: economic injury (other than from medical or [ |
Employment or labour law [ ] |professional malpractice)
Intellectual property law [ ] | Tort: human trafficking (Prevention of and Remedies for [ |
Human Trafficking Act, 2017)
Judicial review [ ] | Tort: personal injury (other than from motor vehicle [ ]
accident)
Medical malpractice [ |] | Trusts, fiduciary duty [ |
Mortgage or charge [ ] | Wills, estates [ |

Date: February 14, 2024

MU ff
Name of filer

RCP-E 14F (January 2, 2024)

 Cy-24- C8 TID TX6 -

Court File No. COOL

ONTARIO
SUPERIOR COURT OF JUSTICE
BETWEEN:

DR. ASHVINDER KAUR LAMBA

Plaintiff
and

ROCCO GALATI and ROCCO GALATI LAW FIRM

PROFESSIONAL CORPORATION

Defendants

STATEMENT OF CLAIM

TO THE DEFENDANTS

A LEGAL PROCEEDING HAS BEEN COMMENCED AGAINST YOU by the plaintiff. The
claim made against you is set out in the following pages.

IF YOU WISH TO DEFEND THIS PROCEEDING, you or an Ontario lawyer acting for you must
prepare a statement of defence in Form 18A prescribed by the Rules of Civil Procedure, serve it
on the plaintiff's lawyer or, where the plaintiff does not have a lawyer, serve it on the plaintiff, and
file it, with proof of service in this court office, WITHIN TWENTY DAYS after this statement of
claim is served on you, if you are served in Ontario.

If you are served in another province or territory of Canada or 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 is sixty days.

Instead of serving and filing a statement of defence, you may serve and file a notice of intent to
defend in Form 18B prescribed by the Rules of Civil Procedure. This will entitle you to ten more
days within which to serve and file your statement of defence.

IF YOU FAIL TO DEFEND THIS PROCEEDING, JUDGMENT MAY BE GIVEN AGAINST

YOU IN YOUR ABSENCE AND WITHOUT FURTHER NOTICE TO YOU. IF YOU WISH
TO DEFEND THIS PROCEEDING BUT ARE UNABLE TO PAY LEGAL FEES, LEGAL AID
MAY BE AVAILABLE TO YOU BY CONTACTING A LOCAL LEGAL AID OFFICE.
IF YOU PAY THE PLAINTIFF’S CLAIM, and $1,000.00 for costs, within the time for serving
and filing your statement of defence you may move to have this proceeding dismissed by the court.
If you believe the amount claimed for costs is excessive, you may pay the plaintiffs claim and
$400 for costs and have the costs assessed by the court.

TAKE NOTICE: THIS ACTION WILL AUTOMATICALLY BE DISMISSED if it has not been
set down for trial or terminated by any means within five years after the action was commenced
unless otherwise ordered by the court.

[awse
rm ¢ CC pf a)
Date +< by vex) VY , 2<2| Issued by |; SOL. (|
Local Registrar
Address of :
court office: Courthouse . , \
393 University Ave-=6th Floor €° i
Toronto, Ontario MSG 1E6

SUPERIOR COURT COUR SUPERIEURE

E DE JUSTICE
TO: ROCCO Galal S SUNIVERSITY AVE. 880, AVE. UNIVERSITY
1062 College Street, 8TH FLOOR 8E ETAGE
Toronto, Ontario, M6H 1A9 TORONTO, ONTARIO TORONTO, ONTARIO
M5G 1R7 M5G 1R7
AND TO: ROCCO GALATI LAW FIRM PROFESSIONAL CORPORATION
1062 College Street,
Toronto, Ontario, M6H 1A9
 CLAIM

l. The plaintiff claims:

(a) General and special damages for professional negligence, breach of fiduciary duty
and/or breach of contract in the amount of $500,000.

(b) Aggravated and/or punitive damages in the amount of $100,000.

(c) Prejudgment interest in accordance with the Courts of Justice Act, R.S.O. 1990 ¢.
C.43,

(d) Post-judgment interest in accordance with the Courts of Justice Act, supra.

(e) The costs of this action on a substantial indemnity basis.

(f) Such further and other relief as the plaintiff may advise and as this Honourable
Court may permit.

The parties

2. The plaintiff, Dr. Ashvinder Kaur Lamba (“Dr. Lamba”), is a family physician practicing

in Brampton and Toronto, Ontario. In addition to being a medical doctor, Dr. Lamba also has a

research Master’s degree in Science in Genetic Counselling, along with a clinical Master’s degree

in Biochemistry and Microbiology with her thesis focusing on human genetics. Dr. Lamba is a

former delegate of the Ontario Medical Association (“OMA”) and member of the OMA Governing

Council, and is now Secretary of the Board of Concerned Doctors of Ontario, a non-profit

organization composed of frontline physicians advocating for a patient-centered, sustainable,

accessible and quality health-care system.

3. The defendant, Rocco Galati (“Mr. Galati”), is a lawyer licensed to practice law in the

Province of Ontario, At all material times, Mr. Galati practiced law, inter alia, in the field of civil

litigation and held himself out as being an expert or competent lawyer in the field of defamation

law and civil litigation more broadly.

 _4..

4. The defendant, Rocco Galati Law Firm Professional Corporation (the “Professional

Corporation”), is Mr. Galati’s professional corporation and law firm, and the vehicle through

which he practices law and bills clients. At all material times, the Professional Corporation held

itself out as being an expert law firm in the field of defamation law and civil litigation more

broadly.

3: Collectively, Mr. Galati and the Professional Corporation shall be referred to as the “Galati

Defendants”.

The defendants’ representation of the plaintiff

6. In or about the autumn of 2020, the Galati Defendants and Dr. Lamba entered into a

solicitor-client relationship. At that time, the Galati Defendants began providing her with legal

advice and services in respect of defamatory statements that had been published about her in or

around September 2018 by two non-party physicians, hereinafter the “First Doctor” and “Second

Doctor”, whose identities are known to the Galati Defendants. At all material times, the Galati

Defendants owed Dr. Lamba a fiduciary duty, along with a duty of care and good faith.

7. As aresult of the said defamatory publications, Dr. Lamba suffered significant damage to

her reputation, both personally and as a physician, along with hateful social media messages. Her

standing in the medical community was adversely affected, and the harm was exacerbated due to

the fact that she was a female physician of colour. She also suffered personal anguish and suffering.

8. Dr. Lamba only had a meritorious claim against the First Doctor and did not have a

meritorious claim against the Second Doctor. Notwithstanding this, the Galati Defendants

expressly or impliedly advised Dr. Lamba, directly or indirectly or indirectly, that she had a

meritorious claim against the Second Doctor. They further expressly or implicitly advised and
 5.

recommended directly or indirectly that Dr. Lamba sue both physicians, which thereby exposed

her to significant costs vis-d-vis the Second Doctor.

9. At or about the same time that the parties entered into a solicitor-client relationship, the

Galati Defendants also entered into a solicitor-client relationship with the non-party, Dr. Kulvinder

Gill. The above-mentioned publications of the First Doctor and Second Doctor were also of and

concerning Dr. Gill. However, Dr. Gill was also the subject of numerous other publications

regarding her positions concerning the COVID-19 pandemic (the “COVID-19 Claims”). Due to

Mr. Galati’s strong ideological beliefs concerning the COVID-19 pandemic, the Galati Defendants

advised and recommended that Dr. Gill bring an action against approximately twenty-two separate

entities (the “Gill Defendants”) in respect of the COVID-19 Claims.

10. After entering into a solicitor-client relationship with Dr. Lamba, the Galati Defendants

had very sparse communication with her and dealt almost exclusively with Dr. Gill. Dr. Lamba

never provided consent or authorization for Dr. Gill to act as her agent. As a result, Dr. Lamba was

kept out of the loop on numerous important issues and decisions and was not able to provide

informed consent or instructions on matters related to her claim.

The Action

11. The substance of Dr, Lamba’s claim had nothing whatsoever to do with the substance of

the COVID-19 Claims, aside from the fact that Dr. Gill was the subject of the publications in both

claims. There was also an overlap in one defendant — being the Second Doctor — however, as

noted above, Dr. Lamba did not have a meritorious claim against the Second Doctor. Moreover,

the COVID-19 Claims concerned approximately 22 defendants on an issue of immense public

 fi.

interest, being issues related to the COVID-19 pandemic. As such, the COVID Claims invited anti-

SLAPP motions that were almost certain to be successful.

12. Notwithstanding the extremely strong reasons for keeping the claims separate, the Galati

Defendants advised and recommended that Dr. Lamba’s claim be brought in the same action as

Dr. Gill’s COVID-19 Claims against the Gill Defendants. They further misrepresented to Dr.

Lamba that joining her narrow claim to the COVID-19 Claims was proper and was in her best

interests. As such, these two claims proceeded together in a single action (the “Action”).

13. The Galati Defendants prepared and then issued a lengthy Statement of Claim on behalf of

Drs. Lamba and Gill (the “Statement of Claim”). The Statement of Claim was grossly deficient in

numerous respects. These include, but are not limited to, the following:

(a) The Statement of Claim improperly brought Dr. Lamba’s claim together with the
COVID-19 Claims and failed to clearly separate the narrow claim of Dr. Lamba
from Dr, Gill’s extensive and broad COVID-19 Claims;

(b) The Statement of Claim improperly named the Second Doctor as a defendant in
respect of Dr. Lamba’s claim despite the fact that Dr. Lamba lacked a meritorious
claim against the Second Doctor;

(c) The Statement of Claim improperly stated that Dr. Lamba was seeking aggravated
and punitive damages against all defendants, including the Gill Defendants, on a
joint and several basis;

(d) The Statement of Claim improperly alleged that all defendants were jointly and
severally liable to both plaintiffs for the torts of defamation, negligence, conspiracy
and breach of professional obligations, notwithstanding that 21 of the defendants
had nothing whatsoever to do with Dr. Lamba, that Dr. Lamba had no desire or
intention of suing those defendants, and that Dr. Lamba’s only meritorious claim
was in defamation as against the First Doctor;

(e) The Statement of Claim failed to plead proper defamatory meanings, improperly
focused on Dr, Maciver’s insults rather than the defamatory sting of his
 a7

publications, and otherwise failed to plead sufficient particulars of Dr. Lamba’s

defamation claim; and

(f) The Statement of Claim advanced numerous exaggerated or false allegations and
claims, along with excessive damages,

14. The Galati Defendants did not alert Dr, Lamba to the serious problems with the Statement

of Claim, as noted above and the grossly deficient way in which her claim was being articulated

and advanced.

15. On or about January 28, 2021, the Galati Defendants entered into a written retainer

agreement with Dr. Lamba, notwithstanding they had already provided legal advice and services

to her and had prepared and issued a claim on her behalf.

The Anti-SLAPP Motions

16. After the Statement of Claim had been issued and served, all of the defendants in the Action

brought motions pursuant to s.137.1 of the Courts of Justice Act, supra (the “Anti-SLAPP

Motions”). Due to the significant deficiencies in the Statement of Claim set out above, and

especially the fact that Dr. Lamba’s claim against the First Doctor had been comingled and

conflated with Dr, Gill’s numerous COVID-19 Claims, the First Doctor also brought an Anti-

SLAPP Motion,

17. Indefending the Anti-SLAPP Motions brought by the First Doctor and Second Doctor, the

Galati Defendants committed numerous errors and breaches of the duties owed to their client, Dr.

Lamba. These include but are not limited to the following:

(a) They failed to articulate the defamatory sting or meanings of the First Doctor’s and
Second Doctor’s publications.
 -8-

(b) They effectively ignored the First Doctor’s actual defamatory statements and
focused instead on the insulting words the First Doctor had employed in his
publications, notwithstanding the Galati Defendants knew or ought to have known
that mere insults are not actionable;

(c) They failed to adduce any evidence from Dr. Lamba regarding the harm she had
suffered as a result of the First Doctor’s and Second Docter’s publications. The
only evidence of harm was adduced by Dr. Gill and it simply referred back to
boilerplate allegations in the Statement of Claim. This, despite the fact that the
Galati Defendants knew or ought to have known that the harm a plaintiff has likely
suffered is one of the key issues and determinations to be made on an anti-SLAPP
motion and that by not adducing evidence of harm the Galati Defendants were
dooming Dr. Lamba’s claim;

(d) The failed to adduce any evidence from Dr. Lamba and thereby caused the court to
view Dr. Lamba’s claim as frivolous, unmeritorious, or, at best, nominal;

(c) They failed to clarify at an early stage, or at all, that Dr. Lamba was not advancing
a claim or seeking any relief against the defendants save and except for the First
Doctor and Second Doctor;

(f) They focused on the motions brought against Dr. Gill regarding the COVID-19
Claims and paid insufficient attention to the Anti-SLAPP Motions brought against
Dr. Lamba;

(g) They failed to competently articulate and advance Dr. Lamba’s case against the
First Doctor, or, alternatively, failed to negotiate a settlement of the claim against
the First Doctor to reduce or mitigate Dr. Lamba’s costs exposure;

(h) They failed to recommend that Dr. Lamba drop the claim against the Second Doctor
and/or negotiate a discontinuance of that claim to reduce or mitigate her costs
exposure;

(i) Due to the number of defendants the Galati Defendants had named in the Statement
of Claim, they lost credibility with the Court;

() They passed off important work to a junior lawyer(s) or staff and failed to vet the
said work when they knew or ought to have known that this individual or
individuals lacked the requisite competency, skills, and/or training for the work
they were undertaking.

(k) They put their own political ideology and beliefs, especially regarding the COVID-
19 pandemic, above the interests of Dr. Lamba; and
 _9.

(1) They did not consult with Dr. Lamba regarding the proper strategy to be employed
on the Anti-SLAPP Motions and did not take instructions from her regarding same.

18. The motions were argued over a three-day period on September 27, 28 and 29, 2021. The

Galati Defendants failed to recommend that Dr. Lamba attend court for the motions and, as a result,

she did not attend, which further adversely affected the optics of her claim.

19. On February 24, 2022, the Court released its decision (the “Motion Decision”), It granted

all of the Anti-SLAPP Motions, including the motions of the First Doctor and Second Doctor

against Dr. Lamba. With respect to the First Doctor’s motion in particular, the motion judge noted

that Dr. Lamba, through the Galati Defendants, had focused primarily on insulting words, which

are not actionable. The motion judge further took a dim view of the absence of any affidavit

evidence from Dr. Lamba and found that the harm she had suffered was not sufficiently serious

such that the public interest in allowing the claim to proceed outweighed the public interest in

protecting the First Doctor’s expression.

20. Dr. Lamba pleads and relies upon the Motion Decision.

The Appeal and Cost Submissions

21. The Galati Defendants failed to provide Dr. Lamba with a copy of the Motion Decision.

Instead, she learned of the decision from Dr. Gill.

22. The Galati Defendants served and filed a Notice of Appeal on behalf of Drs. Lamba and

Gill. The Galati Defendants failed to communicate with Dr. Lamba regarding the merits of the

appeal or the strategy to be employed thereon. They also failed to obtain Dr. Lamba’s instructions

regarding which parties to appeal against and the grounds for appeal. Instead, the Galati
 -10-

Defendants advised Dr, Lamba that they did not require her to review the Notice of Appeal before

it was served and filed.

23. The Notice of Appeal was deficient in setting out the grounds of appeal and it compounded

the error of suing the Second Doctor by appealing the Motion Decision vis-d-vis the Second

Doctor.

24. The Galati Defendants also delivered boilerplate and deficient cost submissions, which left

Dr. Lamba potentially jointly and severally liable for the full indemnity costs of all defendants,

including the Gill Defendants whom she had never intended to sue.

25. The defendants delivered cost submissions, in which all or some of the Gill Defendants

asserted that Dr. Lamba was jointly and severally liable for the costs of the Gill Defendants due to

the way in which her claim had been pleaded in the Statement of Claim and the absence of any or

sufficient clarification by the Galati Defendants in the course of the Anti-SLAPP Motions,

26. After serving and filing a deficient Notice of Appeal and deficient cost submissions, the

Galati Defendants moved to get off the record and left Dr. Lamba in the lurch, They did not provide

her with names of alternative counsel with competency or expertise in defamation law, and, as a

result, she was forced to scramble to obtain new counsel.

Mitigating Dr. Lamba’s Damages

27. After Dr. Lamba retained new counsel, she sought to mitigate the extensive damages

caused by the Galati Defendants and the potential for even more significant damages. She incurred

significant legal costs in this respect.

 -l1-

28. Dr. Lamba delivered supplementary cost submissions, which, for the first time, argued

plainly that she should not be jointly and severally liable for the costs of the Gill Defendants. The

supplementary submissions also argued that the First Doctor’s and Second Doctor’s entitlement to

costs should be reduced. These supplementary submissions were necessary to mitigate the

damages the Galati Defendants had caused, but they forced Dr. Lamba to incur significant

additional legal costs.

29. On October 31, 2022, the Court delivered its cost ruling the (“Costs Decision”). Due to the

supplementary submissions Dr. Lamba had delivered, the Court found in favour of Dr. Lamba on

the issue of joint and several liability for the costs of the Gill Defendants. The Court also agreed

that certain discounts should be applied to the full indemnity costs of the First Doctor. However,

the Court found that Dr. Lamba was jointly and severally liable for the full indemnity costs of the

First Doctor and Second Doctor.

30. By Order dated July 19, 2023, the Court ordered that Dr. Lamba was jointly and severally

liable for the First Doctor’s costs in the amount of $88,247.24 and for the Second Doctor’s costs

in the amount of $73,176.71.

31. | Dr. Lamba delivered a Fresh as Amended Notice of Appeal, which cured the significant

defects in the Notice of Appeal filed by the Galati Defendants. She also abandoned the appeal of

the Motion Decision against the Second Doctor, after learning that she never had a meritorious

claim against the Second Doctor. She maintained an appeal against the Second Doctor only with

respect to the Costs Decision.

 -12-

32. Dr. Lamba was able to mitigate the damages caused by the Costs Decision. However, she

was required to incur significant legal fees to do so. She entered into confidential settlements with

the First Doctor and Second Doctor and abandoned her appeals against both prior to the hearing.

Liability of the Galati Defendants

33. The Galati Defendants are liable for the torts of breach of fiduciary duty and professional

negligence. By virtue of their solicitor-client relationship with Dr. Lamba, the Galati Defendants

had a fiduciary relationship with Dr. Lamba and owed Dr. Lamba fiduciary duties and a duty of

care, They committed flagrant breaches of their duties. Without limiting the generality of the

foregoing, the Galati Defendants directly or indirectly committed the following breaches:

(a) They improperly commenced a claim against the Second Doctor.

(b) They failed to advise Dr. Lamba of the risks in commencing a defamation action in
the Province of Ontario, including the very real potential for an adverse full
indemnity costs award and further reputational damage.

(c) They failed to pursue a genuine apology from the First and Second Doctors, which
would have mitigated damages and potentially rendered an action unnecessary.

(d) They failed to properly and competently articulate, advance, and argue a
meritorious claim against the First Doctor.

(e) They joined Dr. Lamba’s claim to Dr, Gill’s COVID-19 Claims, when they knew
or ought to have known that this would taint Dr. Lamba’s claims or adversely
affected the optics of Dr. Lamba’s claim, and would also the reputation of Dr.
Lamba and cause her to be viewed with disrespect, hatred or contempt by members
of her profession and members of the public.

(f) They caused Dr. Lamba to be potentially liable for the costs of the Gill Defendants
on a joint and several basis, which required significant additional legal costs to
remedy,

(g) They employed and/or relied upon junior lawyers, staff, and other employees who
lacked sufficient competency, skills, and training for the tasks they were
undertaking.
 -13-

(h) They held themselves out as experts in the field of defamation law, when the knew
or ought to have known that they, in fact, lacked any such expertise.

(i) They failed to provide Dr. Lamba with competent advice and recommendations.

() They failed to communicate with Dr. Lamba in a regular, open, and clear manner.

(k) They failed to take instructions or informed consent from Dr. Lamba on important
steps in the litigation.

(1) They placed their own interests, beliefs, and/or ideology above the interests of their
client, Dr. Lamba.

(m) They acted for Dr. Lamba when they knew or ought to have known that they were
in a conflict of interest due to their own beliefs and activism on the issue of the
COVID-19 Pandemic.

(n) They committed flagrant breaches of their duties owed to Dr. Lamba pursuant to
the Rules of Professional Conduct.

(0) They drafted, prepared, and issued a highly deficient Statement of Claim, for the
reasons set out above.

(p) They committed numerous errors and breaches in defendants the Anti-SLAPP
Motions, for the reasons set out above. |

(q) They failed to provide Dr. Lamba with a copy of the Motion Decision in a timely
manner.

(r) They prepared and delivered deficient cost submissions for the reasons set out
above.

(s) They prepared and delivered a deficient Notice of Appeal, for the reasons set out
above.

(t) They abandoned Dr. Lamba’s case at a critical time.

(u) They generally acted as incompetent legal counsel in advancing and protecting Dr.
Lamba’s interests.

(v) Such further particulars as counsel for the plaintiff will advise.
 _|4-

34. In addition or in the alternative, the Galati Defendants are liable for breach of contract. The

conduct set out above also constitutes a breach of express or implied terms of the retainer

agreement entered into between Dr. Lamba and the Galati Defendants,

35. The Galati Defendants knew or ought to have known that their flagrant breaches and

conduct set out above would cause Dr. Lamba damages.

Damages

36. Asa result of the breaches and conduct of the Galati Defendants described above, Dr.

Lamba suffered damages and losses, the particulars of which will be provided in advance of the

trial of this action.

37. Dr. Lamba’s damages, include, but are not limited to:

(a) Pain and suffering;

(b) The loss of the damages or settlement she would have recovered from the First
Doctor had the Galati Defendants not committed the breaches set out above;

(c) Significant legal costs to mitigate the potentially astronomical costs/damages

caused by the Galati Defendants and the Costs Decision;

(d) Loss of professional and personal reputation, being tarnished as an “anti vax” or
“anti public health” physician, being the victim of disrespect, hatred and contempt,
and experiencing feelings of shame, embarrassment and humiliation, all directly as
a result of the Galati Defendants combining and conflating her claim with Dr. Gill’s
numerous and unrelated COVID-19 Claims;

(e) The loss of financial, employment and professional opportunities as a direct result
of the Galati Defendants combining and conflating her claim with Dr. Gill’s
numerous and unrelated COVID-19 Claims; and
 oi Sa

(f) Damages, interest and costs that Dr. Gill may be awarded in a claim she intends to
bring for contribution and indemnity against Dr. Lamba in respect of the Costs
Decision.

38. Dr. Lamba has taken all reasonable steps to mitigate her damages.

39. The conduct of the Galati Defendants has been high-handed and egregious and justifies

awards of aggravated, Without limiting the generality of the foregoing, the Galati Defendants:

(a) Ensured that Dr. Lamba’s claims would fail, for the reasons set out above.

(b) Exposed Dr, Lamba to a seven-figure costs award, and did so for no benefit and
without advising Dr. Lamba of this significant risk.

(c) Knew or ought to have known that by combining or conflating Dr. Lamba’s claim
with Dr, Gill’s numerous COVID-19 Claims, she would be exposed to hatred and
contempt, and suffer a loss of reputation and earning capacity for being labelled an
“anti-vax” or “anti-public health” physician.

(d) Took significant actions without Dr. Lamba’s instructions or informed consent.

(e) Knowingly placed their own desires and interests above those of Dr. Lamba, and
knowingly represented Dr. Lamba while in a conflict of interest.

Statutes, Misc,

40. | Dr. Lamba pleads and relies upon the Courts of Justice Act, supra, the Negligence Act,

R.S.O. 1990, c. N.1, and the Rules of Professional Conduct.

41. Dr. Lamba proposes that this claim be tried in the City of Toronto.
16>

JORDAN HONICKMAN BARRISTERS

90 Adelaide Street West
Suite 200
Toronto ON MSH 3V9

Asher G. Honickman
LSO #60469W
Tel: 416.238.7511
Fax: 416-238-5261

E-mail: ahonickman(@)jhbarristers.com

Lawyers for the Plaintiff

DR. ASHVINDER KAUR LAMBA -and- ROCCO GALATI and ROCCO GALATI LAW FIRM
PROFESSIONAL CORPORATION
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Defendants
Court File No. ZO
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Suite 200
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Asher G. Honickman
LSO #60469W
Tel: 416.238.7511
Fax: 416-238-5261
E-mail: ahonickman(@jhbarristers.com