DR.JAHAGIRDAR- COURT ACTION CV20 82659
FROM: Roger Callow Plaintiff CV20 ooo 82659 oooo January 29-2020
1285 Cahill Drive #2001 Ottawa K1V 9A7 t.613-521-1739 firstname.lastname@example.org
TO: A copy of the above action is mailed to Dr. J as Defendant plus organizations listed here:
1) Ottawa and Toronto Police to seize disclosure defined herein from Dr. Jahagirdar (Dr. J.) and Ministry of Transport-Medical.
2) College of Physicians and Surgeons - ethical branch Perhaps you will do what you should have done in the first place; namely suspend Dr. J. until she hands over my complete medical file (which belongs to this patient as a matter of law).
3) Dr. Kitts whom is also asked to hand over my medical Report from Boxing Day Dec. 26-2019 when I was seized by the police for the purpose. A second copy should go to the Transport Ministry mentioned above in order to have my driver's license restored. I still await his Report on this infamous affair in which I call for the suspension of hospital donations until the truth is revealed on this debacle.
Yours truly, Roger Callow
cc selected Ottawa City Councillors
The following letter was written by Dr. J. at my insistance after a telephone call from her and does not
represent the character of her phone call. Apparently she broke patient confidentiality rules by discussing my
medical file with sons Chris and Greg whom, I submit, placed it in her mind to contact the transport ministry-
medical as opposed to directing me to a cognitive assessment which apparently she did later with the Ottawa
Hospital after i dispensed with her services on Nov.1-2019. As late as Dec. 15, the ottawa hospital was unaware
that she was no longer my doctor. i received no such communication from Dr. j. on oct. 03 regarding a cognitive
re-evaluation. no doubt she will blame Towngate staff on that accord. She does not specify which information
and from whom she received it about October 15 which caused her to invoke the suspension of my driver's
license. it is that disclosure that i have been pursuing in 19-SC-155235 (Ottawa Small Claims Court) which
towngate/Dr. j. steadfastly refuse to divulge and without which I cannot get a new doctor. The geriatric Team
she did recommend did contact me and had no idea about the license suspension. In summary, her account is one
of prevarication after prevarication. The writer C.S. Lewis summed it up best when he claimed that the greatest
evil is done by those pretending to do good.
submitted by Roger Callow - January 17-2020
Courts of Justice Act
statement of claim (general)
DOCTOR ANUSHA JAHAGIRDAR
(OF TOWNGATE FAMILY MEDICINE)
statement of claim
TO THE DEFENDANT
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.
(Where the claim made is for money only, include the following:)
IF YOU PAY THE PLAINTIFF’S CLAIM, and $ 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 plaintiff’s claim and $400 for costs and have the costs assessed by the court. THE CLAIM IS FOR $10 MILLION
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.
Date ........................................................................... Issued by ...........................................................................
court office .........................................................................
TO (Name and address of each defendant) DOCTOR ANUSHA JAHAGIRDAR (c/o TOWNGATE FAMILY MEDICINE 2446 BANK STREET
STE. 201 OTTAWA K1V 1A4) t.613-739-0998
(In an action under the simplified procedure provided in Rule 76, add:)
THIS ACTION IS BROUGHT AGAINST YOU UNDER THE SIMPLIFIED PROCEDURE PROVIDED IN RULE 76 OF THE RULES OF
CIVILPROCEDURE. ONE HOUR BEFORE A JUDGE FOR DISCLOSURE
1. The plaintiff claims: (State here the precise relief claimed.)
THAT THE DEFENDANT HAS BREACHED HER PROFESSIONAL MEDICAL PRIVACY AS
A FAMILY DOCTOR IN A MOST SIGNIFICANT MANNER WHICH LED TO THE
CANCELLATION OF THE PLAINTIFF'S DRIVER'S LICENSE IN PERPETUITY IN AN
ALLEGED CONSPIRACY WITH THE ONTARIO MINISTRY OF TRANSPORT - MEDICAL
DIVISION INCLUDING THE ROLE OF UN-NAMED FAMILY MEMBERS IN THE PURSUIT
OF THIS APPARENT FRAUD.
(Then set out in separate, consecutively numbered paragraphs each allegation of material fact relied on to substantiate the claim.)
1) The other defendants knew and participated in Doctor Jahagirdar's conduct and arguably induced her
to breach her duties to the plaintiff, whether grounded in contract or medical duty;
2) There is a strong prima facie case of unlawful interference with medical interests because the defendants made false statements to third parties with the intent to injure the plaintiff; two sons filed a committal action which led to a nine-day detention in Ottawa's secure 4-bed unit even though he successfully passed a full complement of tests after being seized by the police from his apartment on the court order request of his sons.
3) What the defendants appear prima facie to have done is to set out to unlawfully take that medical information which is not theirs through a conspiracy that included breaching the Plaintiff's medical record, bad mouthing the plaintiff, interfering in its relations with third parties such as the Ministry of Transport-Medical, using its confidential information, and hurting the defendant in a significant way interfering with his ability to live in a free and open society.
4) Moreover, allowing the defendants to succeed in their unlawful design is contrary to any conception of fairness. It is not clear that the Plaintiff can recover from the harm inflicted upon him already. However, saying to the plaintiff "Too bad; so sad; see you at trial" is unacceptable. Doing so would vindicate the defendants' surreptitious breaches of duty and intentional torts.
5) The key to the above lies in disclosure from the remaining part of the Plaintiff's medical record which Dr. Jahagirdar refuses to divulge and the Ministry of Transport-Medical to confirm undisclosed information she received on or about October 15-2019 which caused her to call for the suspension of the Plaintiff's Driver's License. That suspension was issued 4 days later raising the question as to whether the Transport Ministry first contacted Dr. Jahagirdar.
6) The trial should be two-fold: a one-hour call for disclosure by a judge in Ottawa court to be followed in a second hearing at a future date according to what this disclosure reveals.
(Where the statement of claim is to be served outside Ontario without a court order, set out the facts and the specific provisions of Rule 17 relied on in support of such service.)
(Date of issue) JANUARY 13-2020 ROGER CALLOW PLAINTIFF
1285 CAHILL DRIVE #2001 OTTAWA K1V9A7
(signed) Roger Callow t.613-521-1739