IN THE COURT OF QUEEN'S BENCH OF ALBERTA

JUDICIAL DISTRICT OF EDMONTON

BETWEEN:

KEVIN BRADLEY GERMAN

Plaintiff/Applicant

- and -

HER MAJESTY THE QUEEN IN RIGHT OF ALBERTA; CAPT. THERESA MAE

GERMAN; CAPT. BENTLEY BARR; MAJ. STOKES (JUDGE ADVOCATE
GENERAL’S OFFICE); CST. MICHAEL POIRIER (ROYAL CANADIAN MOUNTED
POLICE #38758); DR. VIJAY SINGH AND DR. CURTIS WOODS (FACS FILE
25909); Prof. ROGER BLAND (UNIVERSITY OF ALBERTA)

Defendant/Respondent

NOTICE TO REPLY TO WRITTEN INTERROGATORIES

NOTICE OF MOTION

You are hereby required to provide to the Applicant within 30 days of service of this
Notice, answers to the following questions, in writing, under oath:

[ 1 ] The case of “German vs. German (Capital Health Authority, DND, RCMP et al)” rests
largely on the topics of “informed choice in health care” based on the 408 experience, and “adapting
to the needs of our clients” from CHA’s values. The case balances the CHAP with the AHE Report
of 22 March 2002 and events post-trial as the St. Albert Crown pressed ahead a sanction
(overlooking the “Singh Report” in the process). The appellant was, while under the attention of
each co-Defendant physician, attempting to maintain long-term employability concerns while
addressing the Court’s conflicting and contradictory demands.

Q1: The letter to Mr. Tiamiyu of Mid-November 2002 mentions two counts of breach of probation
on October 2nd, 2002 and these arose from attempts to secure POIRIER’s notes from Leo Nickerson,
dating to 6 December 2001 to prepare an appeal and speak to the credibility of the co-Defendants’
observations. As mentioned, the appellant was expecting a full day’s attention to the case to address
the Charter issues and appeal. (This appears as the “Steer Me into Pills” fax of the period.) With
this issue being the “needs” as expressed by client at the time, why was the full day scheduled for the
appellant’s issues (on appeal) reduced to one hour’s time on 1 Nov ’01 and why, if CHA focuses on
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the client’s needs, did FACS assume control of the case by asserting what the “purpose” of the
interview was to be, instead?

[ 2 ] The same letter mentions that the “mental health issue” has been the most prominent issue
from the perspective of the psychiatrists. In fact, defending against the Barr’s charges via getting
the forensic staff to notice the “Insight on What’s Happening” (and avoiding unwarranted medical
intervention) was the most prominent issue, from the perspective of the “accused”.

Q2: If the “Consent Order” and terms of probation require the services of a psychiatrist to verify
“mental health concerns” for the Courts, and the AHE Report of 22 March 2002 had already
addressed this issue with some clarity as of 22 March 2002, how did the diagnostic observations
accrued in a one-hour meeting though Leo Elwell in July 2002, or Woods on 1 Nov ’02 post-trial
and across the divorce and “Consent Order”, negate the findings of the Singh Report and the six
weeks’ worth of tests underlying those words of record (for Elwell, Woods and eventually, Bland)?

[ 3 ] The case has many Charter s. 15 and 28 issues and as stated, the Appellant was on the other
side of a divorce trial, criminal trial and “Consent Order” issue. This is why the CHAP states (under
SINGH) that the social dynamics are such that “his personal failure remains predetermined and
guaranteed by design”, now proven via the “POPIK” investigation of May 2006.

Q3: Would CHA’s medical staff not be in an inherent Conflict-of-Interest position, as they’re
drawn into the “social dynamics” via the Barrs and POIRIER, in addressing the appellant’s alleged
“health care needs” by negating or dismissing appellant’s clear objections to the meds issue and
getting their diagnostic “insight” from the ‘ex over their own client base via Breaches of Confidence
if necessary? (Restated, who’s team is my Health Care “Provider” supposed to be on anyway and
what happened to “the ability to instruct counsel” mentioned in the AHE Report of 22 March ‘02?)

[ 4 ] The FACS record mentions a “conspiracy against men” at numerous points, passing this off
as paranoid ideations. CHA has since been sued for an actionable “Conspiracy with Intent to Injure”
as there has been no consideration of ever releasing the appellant as “fit to fly” appearing on the
record at any point since 6 Dec ’01. The “Hi & Lois” panel sparked a calling, and groups such as
“Fathers-4-Justice” lobby for shared parenting, and we see ads for divorcees now appearing in ads
for used cars. As a pilot, the appellant can’t actually even meet the terms of the Barr’s demands.
These are, after all, my stated issues and have been buried in favour of strong-arming ahead a
regimen of “care” just so the doctors can prove to themselves they’re in control of the case
progression at any direct or indirect cost to their own “patient”.

Q4: This seems to me as socially “equal” as the seats at the back of the bus were for Rosa Parks.
With so much attention paid to the issue over the years, why has there been no discussion on the
“Paradigm Conflict” exhibit, the “Power X-fer Explained” panel, POIRIER’s visit to Albrecht’s
office and the social “value systems” in the CHAP included in the AHE Report under Dr. Singh?

[ 5 ] The report of 15 Nov ’02 mentions tests “suggestive of explosive violent outbursts”, but the
CD-ROM has a “Here is the Math” e-mail dating to 28 Dec ’01 that expresses this dynamic line-by-
line as “some element of frustration on my part”; a natural part of the Human Condition. There is
also an e-mail to Ms Edwards dating to December 2001 stating “I think you might have interpreted
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the authority I can project as pending aggression as well” and further, “It’s a very precarious
position to be in”. These would speak to the “state of mind” and my own “risk assessment” issues.

Q5: As the “Here is the Math” e-mail also contains the words “someone else can pay the legal
bills as I make my point” and also, Ms Barr has taken the words “you have a big head” and
“dropping a bombshell” to be “violent”, how does the “Lily Cares” program even begin to address
Ms Barrs’ behavioral observations, the Barrs’ failure to live up to their own civic obligations (on the
record in the CHAP VIS and on receipt of the QB Action), Cst Poirier’s professional misconduct on
the attempt to appeal in ‘02, and the “Distorted Content Excerpted from the Internet” in the CHAP?

[ 6 ] The report says the behavior has been psychologically and emotionally damaging to the
victims involved” but the Barr’s behavior let to the CHAP and the “Consent Order” led to this
litigation.

Q6: Considering that the “Consent Order” issues and POPIK investigation now leaves the
appellant tagged as “a harmless ranter who lives on the street” via FACS’ “care plan”, currently
destroyed as a professional aviator and unable to see my own children without the Barrs’ asserting
“stalking” of their Cadets, and having had POIRIER in my Flight Surgeon’s office to trash my life
there, have the Barrs’, RCMP’s and FACS’ misguided efforts to-date not been a little more than
“psychologically and emotionally damaging” to the Plaintiff?

[ 7 ] The children are always caught in the middle of any divorce, but the focus has been on going
to the ‘ex for her take on the appellant’s moods and needs. Meanwhile, the appellant has a new life
partner who also wants to go out dining and dancing and FACS’ “care” has had me earning 10% of
my earnings potential and would keep this cycle going indeterminately.

Q7: As every story has two sides, why has FACS been taking their “read” from Ms Barr, and why
has nobody (in four years) once asked Ms Weiler what her take is on the “mental health (forensics)”
issue? (She knows me better than Ms Barr ever did, and would have painted a completely different
picture for the Courts, as she did at the trial on 18 Dec ’06, and this is the “Details for Damages” for
QB 0503 19251.)

[ 8 ] The appellant filed the definition of “enabler” once the “Lily Cares” program had attempted
to address POIRIER’s “off meds” stunt -- as he was given everything he needed on 30 Dec ’01 to
address the charges in his report. TC would call this “Officially Induced Error” (on the initial arrest
and 3rd breach) and “Professional Misconduct” (on the attempt to appeal).

Q8: As the words are “avoiding the consequences of their behavior” and FACS’ job is to address
the Court’s report for “state of mind at the time of the alleged offense”, why did these words not
“register” as a red flag for pending litigation?

Q9: What percentage of your client base would you estimate are on medications?

Q10: Have you ever had the opportunity to address the employability concerns of a professional
pilot, or had any specialized training in this regard?
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[ 11 ] The CD-ROM has numerous articles and media clipping regarding “inhumane treatment for
inmates in the ERC”, “police stomping on homeless men in the streets”, “the price of justice out of
reach for many litigants”, and “Retuning to Sanity Must Begin with the Church”. Altogether, these
media clippings paint a bleak picture of the “Justice” and “mental health” systems in Alberta, and
the police services often come off as brutal and repressive as well. The appellant has been on the
record clearly as trying to run a bit of a social crusade on the “Mrs. Doubtfire Issue” and using the
Court’s attention to the Barrs’ suspect allegations to pull the CHAP and “Hi & Lois” before the
FACS Staff; judicial bias, systemic incompetence, socio-economic hypocrisy and willful blindness
being the key issues.

Q11: At every milestone, the psychiatric community has actually reinforced these ingrained biases
and the Barrs have even gone on to say “his meds were helping” as if the ‘ex (post-divorce and post-
“grounding”) has the right to assume Power of Attorney over her adult children and the appellant’s
career needs. In the process, every line of CHA’s, CIC’s and AARN’s core values have been
inverted or violated to bury the CHAP and attempt to justify events past.

The definition of “Police State” reads as “a political unit characterized by repressive governmental
control, usually as an arbitrary exercise in power”. Does this definition not meet word-for-word
with the terms of the Barrs’ “Consent Order” demands, “House Arrest” and for FACS, the forced
conscription into the “Lily Cares” program as “proof” of compliance?

If you object to answering any of these questions, you must serve on the Applicant,
an objection to answering the disputed questions, setting out the reasons for the objection, within 14
days of service of this combined Notice and Notice of Motion.

DATED at _________________, on the _________ day of ___________________, 200__

____________________________________
Applicant
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Notice
_____________________________________
If you fail to respond to the questions posed or
to state that you object to answering the
questions and the reasons therefore, you are to
appear before the presiding Justice in
Chambers at the Court House in the City of
Edmonton in the Province of Alberta at
10:00 a.m. on Wednesday, the 15th day of
August, 2007, at which time the Court may:
a) order that the questions be answered
before a date to be specified in the order;
b) find you in contempt of court;
c) grant the applicant any other remedy
requested;
d) grant costs for failing to answer.
Action No. 0503 19251
_____________________________________
IN THE COURT OF QUEEN' BENCH
OF ALBERTA
JUDICIAL DISTRICT OF EDMONTON
_____________________________________
BETWEEN:
KEVIN BRADLEY GERMAN
Plaintiff/Applicant
- and -
HER MAJESTY THE QUEEN IN RIGHT OF
ALBERTA; CAPT. THERESA MAE
GERMAN; CAPT. BENTLEY BARR; MAJ.
STOKES (JUDGE ADVOCATE GENERAL’S
OFFICE); CST. MICHAEL POIRIER (ROYAL
CANADIAN MOUNTED POLICE #38758);
DR. VIJAY SINGH AND DR. CURTIS
WOODS (FACS FILE 25909); Prof. ROGER
BLAND (UNIVERSITY OF ALBERTA)
Defendant/Respondent
_____________________________________
NOTICE TO REPLY TO
WRITTEN INTERROGATORIES
NOTICE OF MOTION
Kevin Bradley GERMAN
10116 105 Ave
Edmonton, Alberta
T5H 0K2
_____________________________________