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Re a sealing order made by Justice Stephen Paull on October 26, 2016 (Sea led

Packaged.9//--//o~/6.f>

Order Varying Sealing Order


Pursuant to section 487 ,3(4) of the Criminal Code

As requested by Crown Fraser Kelly, the attached sealing order is varied as follows .

The term currently reads:

The Sealing Order contains an exception permitting Police Officers and Crown
Counsel to review, discuss and rely on copies of the Information to Obtain,
associated appendixes or Reports to Justice for purposes of further invesligalion
and prosecution . This exception is necessary to allow the continuation of the
investigation.

The following is hereby added:

"Further, the Crown may disclose the copied material in accordance with
R.v.Stinchcombe, S.C.C., and in the course of the prosecution."

This amendment is to be affixed to the outside of the related sealed pack~ge. The
Crown may have to a copy of th is signed variation order. All other terms of the sealiri,...
order are unchanged and remain in force.

Uated at Woodstock, Ontario on November 23, 2016

The Honourable Justice Stepli.;:; ,"auJI


Ontario Court of Justice
4
ORDER PROHIBITING DISCLOSURE OF INFORMATION
ORDONNANCE INTERDISANT LA COMMUN/CATION D 'INFO~ION
SEALING ORDER I ORDONNANCE DEMISE SOUS SCE E rl
S tion I Article 487.3
of t du Code crtminet

Packet Number _ _
Numero de paquet
J:f /J - (b - (:) 3
WHEREAS Production Ord ers p u rsu ant to Sec. 487.014 of the Crim inal Code of Canada was issued on
A TTENDU QUE (do3cribe riaturc of wa1Tant, order or aultionuation I ddcnro Jo msndot, l'0<donnanr;o, " l'autonsst;on) a ele emls(e)
Records located at t wo Ontario colleges as well
this 261h day of _o_c_t_o _b e
_ r_ __ _ _ _ , yr. 2016 relatlng to as the College of Nurses of Ontario
le - jourde an relativement a-(describe place 1r applicable I decrire l'emfrolt s9/0n te caa)

UPON THE APPLICATION OF Detective Constable T im Pi nder


SUR LA DE.MAN DE DE (name of appllcanVlnformant I nom du demandeur!deno(l(;/ateur)

of the Sout hwest Region Police Officer


de (du) "-------------~--~--~----
(region t region) (occupation I professJoni-------
AND WHEREAS an applicatron was made for an order prohibiting access to and the disclosure of any information
E T A TTENDU QUE fa demande a ete presentee d'interdire, par ordonnance, /'acces al'lnformatfon relative
relating to the said Production Orders
audit (a la dlle) - ~ITllnl
-.-Of
-d-e-
rc-r-au-th_o_
riza
--tio_n_/_m_
and
-at-.ad-o-nn-a-nce-,ou
- e-u-tori
- s-st_ion
_ l_ _ _ ains1 que la communication de cette information;

AND BEING SATISFIED THAT the ends of justice would be subverted by the disclosure of any Information, for (a) reason(s) referred to ins.
487.3(2), or that the information might be used for an improper purpose;
ET ETANT CONVAINCU(E) QUE la communication de cette information, pour l'une ou /'autre des ralsons mentionnees au par. 487.3(2).
serait prejudiciab/e aux fins de /a justice, OU que /'information pourrait efra uli/isae a des fins if/agifimes;

ANO that this (these) reason(s) outweigh(s) the importance of access to the information;
ET que cette ou ces ra1sons /'emportenl sur /'lmportanoe de /'acces a /'informal/on;

IT IS ORDERED that the access to and the disclosure of information or portions of information relating to this said warrant, order or
authorization is hereby prohibited, subject to the following terms end conditions:
a a
IL EST ORDONNE par Jes presentes que f'acces la totafite OU une partie quelconque de /'information relative audit mandat OU la dite a
ordonnance ou autorisation est fnterd/t, da meme que la communication iota/a ou partielle de fadile information, sous reserve des moda/it~s
suivantes :
(se1 out terms and condl~ons, If any I pr(:clser les moda/i/es, le cas ecl1eant)
The Sealing Order contains an exception permitt ing Po lice Officers and Crown Counsel to review, discuss and r ely on
copi es of the Infor mation t o Obtain , associ ated appen d ixes or Reports to J ustice for purposes of f urther investigation
and prosecut ion. Th is exception is necessary to allo w the continuatio n of the investigatio n.

The undersigned has placed the followi ng documents or portions thereof fi led in support of the application for the said warrant,
order or authorization In a packet and sealed the said packet immediately on determination of the application:
L a p erson ne soussignee a place la totalite OU une parlie des documents suivants, qui ont eta deposes a f'app ui de l a demande dudlt
mandat ou de la dite ordonnance ou autorisation, d ans u n paquet sur /equal el/e a mis /es sce//es des que la decision relative a cette
demande a ete p rise :

IT IS FURTHER ORDERED I.hat this said packet be kept in the custody of the court in a place to Which the public has no access (or other
place as authorized) and not be dealt with except in accordance with the terms and conditions set out above or unUI further order of the court.
IL EST EN OUTRE ORDONNE que ledil paquet soil garde par le tribunal en un lieu auquef le public n'a pas acces (ou en tout autre lieu autorise) el qu1f
ne peut en ~ dispose que conformement aux modalites fix.ees ci-dessus ou que jusqu'a nouvelle orr:Jonnance du tribunal.
Date-0 this 26th day of October . yr. 2016
Fait ce }our de an
al the City of Woodstoc~
a(au) de
in the Province of Ontario I dans fa province de /'Ontario
Judge/Justice of the Pe25/ Juga/Juga de pai><

CAO-S4 cso (05108) (posled I alfichoe 04/06/08)


!:. .,J. /a. u tI
2
INFORMATION TO OBTAIN A PRODUCTION ORDER
DENONC/ATION EN VUE D'OBTEN/R UNE ORDONNANCE DE COMMUN/
Woodstock Police Service Cbh',r
J C/ // - lfc - /53
1

0 ,
SUPERIOR/ONTARIO COURT OF JUSTICE -#:""'
GOUR SUPER/EURE DE JUS TICE/DE JUSTICE DEL 'ONTA RIO
CANADA form I Formule 5.0 04
PROVINCE OF ONTARIO Subsection I psragraphe 487.014(2), 487.01 5(2),
PROVINCE DE L'ONTARIO 487.016{2), 487.017(2) and I el 487.018(3)
of the Criminal Code I du Code crim inel
Southwest I Sud-Ouest
---- 7
(Region Region")-~~-- Case/File No. I N du caSidossiar --

This is the information of Detective Constable Tim PINDER , of The City of Woodstock
La presente constitue fa denoncialion de (name of peace officer or public: officer I de
nom de /'agent de ta paix ou dtt fonofionnaire public)
("the informant").
cl-apres appele(e) <t le denonciateur )).
The informant says that they have reasonable grounds to suspect (or, if the application is for an order under section 487. 0 14
of the Criminal Code, reasonable grounds to believe)
Le denonciateur dee/are qu'il a des motifs rafsonnab/es de soupi;onner (ou, sl la demande vise obtenir une ordonnance en a
vertu de l'artiGle 487.01 4 du Code criminel, de croire) que /es conditions suivantes sonf reunies :
(a) that an offence has been or will be committed under
a) une infraction prevue a
_c_c
__,_
s_ e...,.,
c._2,.-3_5~(~1-'-
) _
F i.,...rs
_t_D_e~g~r,..,.
e_e,.-
M_u_r_
de_r-,x 8 _a,_..
___ n_ d _C..,.C--,-S,.-
ec _._2_,_3_9~(':-
1 '-
)('-b.._)_
A_tt_e_
m....P_t e
_d_ M_u_rd_e_r_x_6 __ ,
(specify the provision of the Ctfmlnal Code or other Act of Parliament I pr9c/ser la dlsposilfoo du Code crimlnel ou de l'autre loi feoora/e) a efe OU sera comm/Se;

AND I ET
(b) (if the application is for an order under section 487.014 of the Criminaf Code) that (specify the document or data)
a
b) (si la demande vise obtenir une ordonnance en vertu de l'article 487.014 du Code criminel) (precissr1asa{)(1noes)
- J anine HOOVER, Conestoga College, 299 Doon Valley Dr., Kitchener ON
- Deb STOCKMANN, Fans hawe College, E1012, 1001 Fanshawe College Blvd., London ON
- Paul BRENNAN, The College of Nurses of Ontario, 101 Davenport Rd.1 Toronto ON

is In the possession or control of See Appendix B and will afford evidence respecting the
sont en fa possession de (name ~-
fl-
he_p_e-
rs-
on_/_n-
om_d_e_la-p-~-s-on-
n-e)_ _ _ OU sa disposition et fourniront une a
commission of the offence.
,preuve concemant la p e1petration de /'infraction.
OR / OU
(b) (If the application is for an order under section 487.015 of the Criminal Code) that the identification of a device or
a
b) (sl la demande vise obtenir une ordonnance en vertu de !'article 487_015 du Code crimfne0 l'identification de tout
person involved in the transmission of
a --~--------------~ ------~-----
dispositif ayant Servi /a transmission de (specify \Ile communlcallort / prilcfser/l'J communication)

Will assist in the investigation Of the Offence and t11at (specify ihe transmission data)
OU de toute personne y ayant particfpe sera utile a l 'enquete re/atJve f'fnfractfon et a (preclser/esdonneesde transmission)

that is in the possession or control of one or more persons whose identity is unknown will enable that identification .
a
sont en fa possession ou la disposition d 'une ou de ptusieurs personnes-dont ndentife n 'est pas connue- et
permettront cette identification.
ORIOU
(b)
b)

is in the possession or control of


sont en la possession de ---~e of the person I nom de 1a perronne)

the offence.
/'enquete. relative a /'infraction.
CC0-487-5.004 (rev, 04115) CSD
INFORMATION TO OBTAIN A PRODUCTION ORDER
DENONCLATION EN VUE D'OBTENIR UNE ORDONNANCE DE COMMUNICATION
Form I Formula 5.004
Subsection I paragraphe 487.014(2). 487.015(2).
487.016(2}, 487,017(2) and I el 487.018(3)
of the Criminal Code I du Code crirninel
Page 2

(b) (if the application is for an order under section 487.017 of the Crim in al Code) lhaf (specify I.tie trac~ing data)
a
b) (~j la demande vise obtenir une ordonnance en vert~ de !'article 487.017 du Code criminef) (precJserlesdonn~sda kxalisafi()()}

is in the possession or control of and will assist in the [nvestlgation of


Soni en la possession de
-----------------~
(name of lhe per:ion I nom de la personne) OU a
sa disposition et seront uti/es a
the offence.
l'enquefe relaUve a /'infraction.
(b) (if the application is for an order under section 487.018 of the Criminal Code} that (specify the data)
b) (si la demande vise a obtenir une ordonnance en vertu de !'article 487.018 du Code criminef) (pracise11esc1onn&es)

is 1n the possession or control of - - - - - - - - - - - and will assist in the investigation of


sont en la possession de - -- (~ame ofthe financlal lnstitullon, person or entily I nom de
/'Fnslitution financlere, de la personne ou de l'enl/te)
OU a
sa disposition et seront ulifes a
the offence.
l'enquefe relative a /'infraction.
:.G:PT1f IED Ju 8. ~~ .. ,, , ...
COPIE AUThEl\rTIOU!= ~;:~n~;;
T he reasonable, grounds are:
Les motifs raisonnables sont Jes suivants :
CORRECT COPY Of Tl-{E ORlvll\l 1\1..
ET CON~R~ L'ORIGINAL
See Appendix C

T he informant therefore requests


En consequence, le _denonciateur demande
(if the application is for an order under section 487.014 of the Criminal Code) that
a
(si la demande vise obtenir une ordonnance en vertu de !'article 487.014 du Code crimine~ qu'il soit ordonne a
- Janine HOOVER, Conestoga
College, 299 Doon Valley Dr..
K itchener ON
- Deb STOCKMANN, Fanshawe
College, E1012, 1001 Fanshawe
College B lvd., Lo ndon ON
- Pau l BRENNAN , The College of
Nurses of Ontario, 101
Davenport Rd., Toronto ON be ordered to produce a document that is a copy of See Appendix B
----''----'----~-~~- --~"'-"--~~--~~~~~-
(riame ol Ille person I nom de la personne) de oommUniquer Un document qui est la copie de (specify the document I indlquer/e dooument)

that is in their possession or control when they receive the order (and/or to prepare and produce a document containing (specify the data)
a
qui est en sa possession ou sa disposition au moment et) ii ou ef/e reqoit /'ordonnance (oL! d'etab/ir et de. oommuniquer un
document comportant (lndlquer tes dOllfl&esJ
Within 14 days of receiv ing the order

that is in their possession or control when they receive the order).


a
qui sont en sa possession ou sa disposition au moment oti ii ou elle reqolt /'ordonnance) .
OR/OU
(if the appllca6on is for an order under section 487.015 of the Criminal Code) that a person who is served with the order in accordance
with subsection 487 .015(4) of the Criminal Code be ordered to prepare and produce a document containing (specify the transmission data)
a
(s i la demande vise obtenlr une ordonnance en vertu de !'article 487.015 du Code crimine~ qu'i/ soit ordonne a toule
a
personne qui l'ordonnance est slgnifiee conformement au paragraphs 487.015(4) du Code crim inel d 'etablir et de
comm uniquer un document comportant (preciser /es dormees de 11ansm1ssio11J
4
CC0-487-.5.004 (rev. 04115) CSD
5
INFORMATION TO OBTAIN A PRODUCTION ORDER
DENONCIATION EN VUE O' OBTENIR UNE ORDONNANCE DE COMMUNICATION
Form I Formule 5.004
Subsection I paragraphe 487,0 14(2). 487.015(2),
487,016(2). 487,017(2) and I et 487.018(3)
of the Criminal Code I du Code criminel
Page 3

OR/OU
(if the application is for an order under section 487.016 of the Criminal Code) that
a
(sl la demande vise obtenir une ordonnance en vertu de I'article 487 .016 du Code criminel) qu'il soit ordonne a
be ordered to prepare and produce a document containing (specify the transmission data)
- -(name o i the "P""iiSOf1i nom de 1~pe~so7iiiaj- d 'etabllr et de communlquer un document comporlant (preoiser les donnees de transmission)

that is in their possession or control when they receive the order.


a
qui sont en sa possession ou sa disposition au moment ou if ou el/e regolt l'ordbnnance.

OR / OU
(if the application is for an order under sectfon 4 87.017 of the Criminal Code) that
a
(st la demande vise obtenir une ordonnance en vertu de l'artlcle 487.017 du Code criminel) qu'll soil ordonne a
------~-------- be ordered to prepare and produce a document containing (soeclfy tne tracl\lrig da1a)
(name of ll\e peson I nom de la personne) d'etabfir et de communiquer Un document comportant (preciser /es donnees de localrsallon)

that is in their possession or control w hen they receive the order.


a
qui son! en sa possession ou sa disposition au moment ou ii ou el/e regoit l'ordonnance.

OR / OU
(if the appflcation Is for an order under section 487. 018 of the Criminal Code) that
a
(si la demande vise obtenir une ordonnance en vertu de !'article 487.018 du Code criminel) qu'il so1t ordonne a
. be ordered to prepare and produce a document containing . (specify the data)
- ,-na-m_e_o_flh-e-fi-1
n-anc
-i-
al-ln_s1i_"
tu-tlo_n_,pe
,_,_
rs-on_o_
r -en- - 1n-o-m-de-1-'ln-sll-tu-t!tln_
lity _ d 'etabfir et de communiquer un document comportant " (preciser/es donneas)
fin~ncltue, da la personne ou de l'en/Jte)

that is in their possession or control when they receive the order.


a
qui sont en sa possession ou sa disposftion au moment ou II ou e//e reqoit l'ordonnance.

Sworn before me on October 261h, 2016 ,


Falt sous serment devei"nt moi ce ~te)---

at The City of Woodstock


a (au) . ---,p-la-ce-,-,,e-u-
) - - -- - - -- (Si91ature of informant I Signature du denonclateur)

(Signature o stice or judge/Commissioner of Oaths


Signature du juga de pai"X OU du juga/Commissa/re a l'assermentatlon)

Kathryn Anne Fraser, a


Commissioner, e t c., Province. of
ontae9 .Jq: W~ds}qc~E'i!icel(llf:- Al llJ
Servicfl. Effi!l,t.h.'~r~~,r'O'Ur~ti:tT IF~E\
CORRECT COPY OF THC ORIGINAL
ET CONF.O~ rv;.E ti L (lRIC:.IN/\L /

~ iilR"Aft-fii'
i-cta4/~
CfrEH'lliR~~v
ONTA.RI() COURT OF .JUST> ICE
t ,!jUtf Mr l~ltll r"t: rt) I n1vi'l"n ' 10
CC0-487-5.004 (rev . 04115) CS O
APPENDIX "A"

Tilis is Appendix "A" attached to and forming a part of the Production Order for the documents
or data referred to in Appendix "B'':

Elizabeth Tracy Mae WETTLAUFER (DOB: I OJUN67) on or about the 12'11 day of August
2007, did conunit first degree murder on the person of James Lancing SILCOX, contrary to
Section 235(1) of The Criminal Code of Canada

AND FURTHER: Elizabeth Tracy Mae WETTLAUFER (DOB: lOJUN67) on or about the
month of September 2007, did corrunit attempted murder on the person of Clotilda ADRIANO
by administering an overdose of insulin, contrary to Section 239(1)(b) of The Criminal Code of
Canada

AND FURTHER: Elizabeth Tracy Mae WETTLAUFER (DOB: I OJUN67) on or about the
month of September 2007, did commit attempted murder on the person of Albina
DEMEDEIROS by administering an overdose of insulin, contrary to Section 239( l )(b) of The
Criminal Code of Canada

AND FURTHER: Elizabeth Tracy Mae WETTLAUFER (DOB: 1OJUN67) on or about the 27th
day of October 2007, did commit first degree murder on the person of Helen Muri.el
MATHESON, contrary to Section 235(1) of The Critninal Code of Canada

M<TI FURTHER: Elizabeth Tracy Mae WETTLAUFER (DOB: l OJUN67) on or about the 23rd
day of December 2007, did commit first degree murder on the person of Maurice "Moe"
GRANAT, contrary to Section 235(1) of The Criminal Code of Canada

AND FURTHER; Elizabeth Tracy Mae WETTLAUFER (DOB: l OJUN67) on or about the
month of October 2008, did coll11Uit attempted murder on the person of Wayne HEDGES by
administering an overdose of insulin, contrary to Section 239( l)(b) ofThe Criminal Code of
Canada
AND FURTHER: Elizabeth Tracy Mae WETTLAUFER (DOB: 1OJUN67) on or about the 1sL of
Jam1ary 2009 until the 31 st of December 2009, did commit attempted murder on the person of
Michael Stephen PRlDDLE by administering an overdose of insulin , contrary to Section
239(1)(b) ofThe Criminal Code of Canada

AND FURTHER: Elizabeth Tracy Mae WEITLAUFER (DOB: lOJUN67) on or about the 14th
day of October 2011, did commit first degree murder on the person of Gladys MILLARD,
contrary to Section 235(1) of The C1iminal Code of Canada

AND FURTHER: Elizabeth Tracy Mae WETTLA UFF.R (DOB: 10.TUN67) on or about the
month of November 2011, did commit first degree murder on the person of Helert
ZURAWINSKI, contrary to Section 235(1) of The Criminal Code of Canada

AND FURTHER: Elizabetb Tracy Mae WETTLAUFER (DOB: LOJUN67) on or about the 14 11i
day of July 2013, did commit first degree murder on the person of Helen White] aw Marshall
YOUNG, contrary to Section 235(1) of The Criminal Code of Canada

AND FURTHER: Elizabeth Tracy Mae WETTLAUFER (DOB: l OJUN67) on or about the 2gt1i
of March 2014, did c01mnit first degree murder on the person of Maureen PICKERING (Nee:
O'NEIL), contrary to Section 235( 1) of The Criminal Code of Canada

AND FURTHER: Elizabeth Tracy Mae WETTLAUFER (DOB: 1OJ UN67) on or about the 31 st
day of August 2014, did conunit first degree murder on the person of Arpad HORVATH,
contrary to Section 23 5(1) of The Criminal Code of Canada

AND FURTHER: Elizabeth Tracy Mae WETTLAUFER (DOB: 10JUN67) on or about tbe l51 of
November 20) 5 until the 31st of March 2016, did conlllit attempted murder on t11e person of
Sandra TOWLER by administering an overdose of insulin, contrary to Section 239(1)(b) of The
Criminal Code of Canada
CERTIFIED J'O BE tl. 'rfWI- AND
COPIE AJ1 t-- l:NTIOIJC CER1 IFEE
CORRECT COPY Of THt ORIGINAl
ET C0N'0~, A L'ORIGI+
d' - va .0tZ'lc
?CLERK OF THE CO
ORGFFIEiR OF. LA co~ 1

ONTARIO rouRl OJ= JUSTACt.


l}~( lfl~I h i ' '"' " ri u IWT'\~'i\:I
AND FURTHER: Elizabeth Tracy Mae WEITLAUFER (DOB: 10JUN67) on or about the
month o f August 2016, did commit attempted murder on the person of Beverly BERTRAM by
administeriog an overdose of insulin, contrary to Section 239( l )(b) of The Criminal Code of
Canada

CERTIFIED ll 8E: A TRUI:: AN['


COPIE AUT~EN1 IOUE CERTIFEE
CORRECT COP't Of ThE ORIGIN
FT CONF9RMEJ\ L'ORIGINAl
/
APPENDIX "B"

This is Appendix "B" attached to and forming a part of the Production Order for the following
documents or data:

Conestoga College:
All student records for Elizabeth "Beth" WETTLAUFER (Nee: PARKER) located at 299 Doon
Valley Drive, Kitchener Ontario.

Fa ns hawe College:
All student records for Elizabeth "Beth" WETTLAUFER (Nee: PARK.ER) located at Office of
the Registrar, El 0 12, 1001 Fanshawe College Blvd, London Ontario.

T he Co llege of Nurses of Ontario:


All records fo r or pertaining to Elizabeth "Beth" WETTLAUFER (Nee: PARK.ER) located at
101 Davenport Road, Toronto Ontario.

CERTIFIED TO BE A TRUE AND


COPIE AUTl-<ENTIO Jc CERTIFEE
CORR ECT COPY Of THE ORIGINAL
ET CONF.ORME;.,A L'ORICll\IAL
;/' -
CLERK OF THE CO
CRF.FFIER DE: l.A CO
ONTARIO COURT OF JUSfA:F.
1:'1::'11,j~ "'" Jj.jl$jl~ll' P ~ 't:l1!11",..1TI~
APPEND lX "B"

This is Appendix "B" atlached to and foa:niog a part of the Production Order for the following
documents or data:

Conestoga College:
All student records for Elizabeth "Beth" WETTLAUFER (Nee: PARK.ER) located at 299 Doon
Valley Drive, Kitchener Ontario.

Fanshawe College:
All student records for Elizabeth "Beth" WETTLAUFER (Nee: PARKER) located at Office of
the Registrar, El012, 1001 Fanshawe College Blvd, London Ontario.

The College of Nurses of Ontario:


All records for or petiaining to Elizabeth "Beth" WEITLAUFER (Nee: PARKER) located at
101 Davenport Road, Toronto Ontario.

CERTIFIED TO BC A TRUE ANP


CQ~1E AJ i l"lEf\f'!'ttlUE CERT IFEF
CORRECT COPY Or THE ORIGINAi
ET CO['JFOR EA L'ORICINAL

CLERK OF THE= COt


CR'e1:~1ER OC L~Cb.id'
Of\lTAR IO COURT OF JUSTIC:tf-
i..it.Ji;.if.f U~ ,jO I llCI' I 0 1 1. t),.l'tf"1111 1"'
C~RTI FI ED TO BE A TRlJI:
At\ll'
rf!r
COt'>lf .. UTHEN1 IOUf CERl
CO!~REC".1 COP" OF l HE ORtGI NAL
ET CONf7M~ A;.11RtG11\JA~l
/,
- - - --4-" . ~vrJJ t~t ~ -
Cl~RK~OUR -
APPENDLX "C" Oll1:rir1E" OE U\ CO'll~
ONTA~1(1 COURl~(..OF JLJSi ICC
t:u~11Hi1 I nr11't /\r;>i('
J( / Q j , ., ,..

This is Appendix "C'' attached to and forming a part of the Production Order for the documents
referred to in Appendix ''B":

INTRODUCTION

I, T im PINDER a peace officer and a member of the Woodstock Police Service make oath and
say as follows:

I, Detective Constable (D/Cst.) Tim PINDER have been a Police officer since January 2003. I
was a former member of the Oxford Community Police Service, then became a member oftbe
Woodstock Police Service in October of 2009 when the Oxford Community Police Service
disbanded. lam currently assigned to the Ciiminal Investigation Branch of the Woodstock Police
Service and have been since January l 51, 2013 .
Unless otherwise stated all the information contained in this infonnation was obtained by myself
personally or through conversations with witnesses or police officers or from their reports or
notes all of which I have access to. I believe the infonnation provided to me to be accmate.

In this information I refer to the Niche Records Management System (RMS). This is a
computerized system, which compiles information on persons, premises or incidents and any
infom1ation that the Woodstock Police Service may receive. All of this information is cross-
referenced in the same rnanner. Most of the data in-put into this system originates with the
Ontario Provincial Police personnel, or other police services or government agencies. It includes
access to the Police Infom1ation Portal (PIP) which includes i.nfonnation and reports from other
police agencies that operate similar records management systems to Niche. I consider Niche
RMS and PIP to be credible, trustworthy and reliable sources.

In this Information I may refer to the acronym CPIC, which refers to the Canadian Police
Information Centre. The Canadian P olice Information Centre is a Dominion wide computer
database system tJ1at allows for police access to information relating to: criminal records
maintained under the authority of the Identification of Criminals Act; the names addresses and

12
13
CER'TIHEO ~t- A IRUI: Al\lt..
COPll' Ill L \J1\0UE CER,.1Ft.:
CORRECT CC',"'' llF THE ORICINAL
Fi .;0N1-l.).,IVIE ~ 1.-'0RICINAl

PERSONS AND LOCATIONS: t~ ~1,,rF1(q


THECOU
OE LI\ COLI
Ol\ITAl\'IC LOllRl OF JUSTICE
\,;OVflC m Ill Tl~ll f'JA l ONl"Wfl

Elizabeth "Beth" Tracey Mae WETTLAUFER (Nee: PARK.ER) - hereafter named Beth
vVETTLA UFER - Suspect in the murders of 8 elderly patients and the attempted murders of 6
others.

Janine HOOVER - Associate Registrar, Conestoga College, 299 Doon Valley Dr., Kitchener
Ontario, who has access to and control of the records being requested in this Infomrntiou to
Obtain a Production Order.

Deb STOCK.MANN - Student Records Team Leader, Fanshawe College Office of the Registrar,
El012, 1001 Fanshawe College Blvd, London Ontario, who has access to and control of the
records being requested in this Information to Obtain a Production Order.

Paul BRENNAN - Manager of Reports and Prosecutions, Professional Standards, the College of
Nurses of Ontario, 101 Davenport Rd., Toronto Ontario, who has access to and control ofthe
records being requested in the Info1mation to Obtain a Production Order.

James Lancing SILCOX-long term care patient at Caressant Care Woodstock, who died on
August 12th 2007.

Clotilda ADRIANO -long tenn care patient at Caressant Care Woodstock, who died on July
30th 2008.

Albina DEMEDEIROS - long tenn care patient at Caressant Care Woodstock, who died on
February 25'b 2010.

Mamice GRANAT - long tenn care patient at Caressant Care Woodstock, w110 died on
December 23ro 2007.

HeJen Muriel MATHESON - long ten11 care patient at Caressant Care Woodstock, who died on

14
October 27th 20 11

Gladys MILLARD - long term care patient at Caressant Care Woodstock, who died on October
14th 201 1.

Helen ZURAWINSKI - Jong term care patient at Caressant Care Woodstock, who died on or
about November 201 1.

Helen WIDtelaw Marshall YOUNG - long tenn care patient at Caressant Care Woodstock, who
died on July 14rh 2014.

Maureen PICKERING- long term care patient at Caressant Care Woodstock, who died on
Marcb 28 1h 2014.

Arpad HORVATH - long tenn care patient at Meadow Park Centre ii1 London, who diecl on
August3l 51 201 4.

Michael Stephen PRIDDLE- long term care patient at Caressant Care Woodstock, who died iJ.1
December 2012.

Wayne HEDGES - long term care patient at Caressant Care Woodstock, who died on October
28th, 2008.

Sandra TOWLER - Jong tenn care patient at , who is still alive-


. Throughout this Information to Obtain she may be referred to as Sandra
"FOWLER", as the spelling ofher surname was incorrectly provided to police during the
original stages of this investigation.

Beverly BERTRAM-in-home care patient who lives -


and had been under the care of Beth WETTLAUFER.

15
OVER VIE\V:

1) On September l<Yh 20 16, Beth WETILAUFER, a registered nurse residing in Woodstock


Ontario, checked bersel f into the Centre for Addiction and Mental Health located at 250
College St., Toronto Ontario.
- The psychiatrist who cared for WETTLAUFER was Dr. Alan KHAN 1

2)

3)

4) At approximately 18:35 Hrs. the Toronto Police Service contacted the Woodstock Police
Service regarding the allegations, since the majority of the offences occurred in Woodstock.
The investigation was turned over to the Woodstock Police Service Criminal Investigation
Bureau for further investigation.

BACKGROUND OF INVESTIGATION:

On the basis of the forego ing paragraphs, I believe on reasonable grounds that Beth
WETTLAUFER is responsible for the Criminal Code offences under section 235 (1) and 239 (1)
(b). My grounds for belief may b e summarized as follows:
:t:RT1r11:.o 10 qr 'R JE. ~ND
COPIE AU rHHl !IOU!': CE~ flFEt:
Cl">R l(ECI \OPY OF 11 1t ORIGINAL
ET co N!=oR~ A. 10R1c 1NAL

cr,/ \dla )

1 Dr. Alan KHAN, is a psychiatrist currently employed at the Centre for Addiction and M ental Health in Toronto,

hereafter named CAMH- He was Elizabeth WETTLAUFER's doctor during her stay at CAMH.

16
5) On September 29th 2016, at 19 :40 Hrs. I was briefed by Detective Constable Karen
OVERBAUGH2 regarding a call she took from the Toronto Police Service. l learned the
following:

Beth WETTLAUFER bad checked herself into a CAMH in Toronto


WETTLAUFER was a registered nurse (RN) at Caressant Care

6) At 20:40 Hrs. 1 attended Caressant Care with D.C. OVERBAUGH and spoke with the nurse
on duty. She confinned that Beth WETTLAUFER had been employed as an RN there but
that she hadn't worked at Caressant Care for approximately 1 year

7) On September 30th 2016, at I7:30 Hrs. I spoke with Detective Pat ALBERGA3 . I learned the
following:

Detective ALBERGA had interviewed Beth WETTLAUFER

The psychiatrist was going to release her from CAMH on Wednesday October 5th 2016

1Detective Constable Karen OVERBAUGH, hereafter named D.C. OVERBAUGH, is a Detective Constable with the
Woodstock Police Service and the primary investigator in this case. Ct::RTIF1ED f0 Bf- P. NUI: ~NC
COPIE AUlHENT1QUE CERTIFEE
3
Pat ALBERGA is a det ective wi th the Toronto Police Service. CORR~~o~~g~1 1 ~~ ~~~C~~flNAI

-~OFTHE:Cco . GRl:fFlef'I nL L4'


r)NTARlO COURT JF JU lf lCE
rc-11 , ,... .,,. 11 1or1rt f1t' i..\tlll f'\I"'
8) At 19:36 Hrs. I, along with Detective Sergeant Kevi11 TALSMA4 and D.C. OVERBAUGH,
received an email from Detective ALBERGA. It oontained his report, a

I Detective Sergeant Kevin TALSMA, hereafter named D/Sgt. TALSMA, is a Detective Sergeant with the Woodstock
Police Service, is in charge of Criminal Investigations Bureau, and is designated as a Maj or Case Manager for this
investigation CERTIH t:U T<l F'IE A rRU!: ~l'l0
COPIE AUi H~!\I flOUE CERTIFF<
s CORRECT CO PY UF THE ORIGINAl
Is a personal friend of Beth WETTLAUFER :1 CONF;J.RME b, L'ORICINAL /
" --. ~
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CLFRK OF THE= COU
GREFFIER DE LACOUR~
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CERTIFIED 10 BE A TRUE AND
COPleAUTHEl\ITIOUE CERTIF!:e
CORRECT CO PY OF THE ORIGINAL
cT CONFORMi; AL ORIGINA!
,"' /

CLERK OF THE C
CREftf'l!:R DE IA
ONT A.RIO COURT OF JUS1 ICF
~Pl.I~ ~F .1Ub11-.;!P ~"' 1. g"'T""'19'
20
9) In reading the witness statement of Glen HART, which was written by HART and provided
by D etective ALBERGA, I learned the following:
CERTIFIED 1013L ,_.. ''<Ut: .,11.
COPI E AUTH!:l'J710UE Ccl?' FE"
CORRECT COPY OF THE ORIC IN \l
E'r CON.FO~i''1E A L'CR~
I G INA L

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:> CLERK OF THF. C , ,-
CREF=tt11:R cir: lA C
Of'1.TAR10 couRT c1c. JUSi 1d
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10) I began searching on-line for the names of victims


looking for death notices and/or obituaries

~ER l IHtt:J T0 BE A I r~UE: ~i\HJ


COP1E AUTHENTIQUE CERTIFEE
cor~RECT COPY OF THE ORIGINAL
James SILCOX died on August 12" 2007 FT CONFpRM~L;:'~
His death notice was in the Woodstock Sentinel Review 7fLtf'R~{f~ C~. -
. . "rd t,~EFPIER or: IJ\ COUR
MaunceGRANAT died on December 2_, 2007, at Caressant C~l\J fAF'lO COURT OF JU'--TlCf
I 01111 1h: HtnTjl" n~ I " '~I l'tltJ
Helen MATHESON died on October 27 1h 2011, at Caressant Care
I was unable to find a death notice or obituary for Mary ZERWINKSKI

22
CERTIFIED p '?l: A fRUE ANI
COl' E .:iu !\11 IOUF CERTIFE!:
1

CORR~fl ro1
~ I COM /.r:
1
u~ THE ORJC. ' f\l~I
A '}>PJGINAL

Gladys MILLARD died on October 14th 20 11, at Caressant Car.,....e--cceP.~nAntf6~


uR - -"'
d th r-1rGffr ilif> Or.: LACOUR /
Helen YOUNG <lie on July 14 2013, at Caressant Care Ot'J Tl\Rlt"r Ct) UriT OJ JU 1 (
e:t.1u1 l\r. 111c11 1r- 1 r 11: 1 ""'l"'n<'
Maureen PICKERING died on March 2811i 2014, at Caressant Care '
Arpad HORVATH died on August 31st 2014, at Victoria Hospital in London
Clotilde ADRIANO had since died on July 30th 2008, at Caressant Care
Albina DEMEDEIROS had since died on Februa1y 25th 2010, a.t Woodstock General
Hospital
DEMEDECROS was listed as being "fonnerly of Caressant Care"

11) At 21 :37 Hrs. I spoke with staff at Caressant Care. I learned that Helen CROMBEZ6 would
have the patient notes and nurses schedules that would be required by police.

12) At 11 :55 Hrs. I attended at Saint Elizabeth Health Care in Woodstock. I spoke with the
nurse in charge there and learned the following:

WETILAUFER used to work at Saint Elizabeth but quit approximately 1 month earlier
Saint Elizabeth services patients throughout the county, including Ingersoll
Tamara CONDY 7 cou1d provide police with more information such as WETTLAUFER 's
patient list so that police could find out who "Beverly'' was

13) On October 4th 2016, I was involved in a briefing on this investigation with D/Sgt.
TALSMA, D .C. OVERBAUGH, and Detective Constable Adam DICOLA8. D .C.
OVERBAUGH provided an update on the investigation and I learned the following:

- D.C. OVERBAUGH spoke with Helen CROMBEZ of Caressant Care


WETTLAUFER hadn't worked there in approximately 1 year

6 Helen CROM BEZ is a Registered Nurse and the Director of Nursing at Caressanl Care

1 Tamara CONOY is the Supervisor at Saint Elizabeth

8 Detective Constable Adam DICOLA, hereafter named D.C. DICOLA, Is a Detective Constable fn the Criminal
Investigation Bureau of the Woodstock Police Service

23
-
CROM BEZ went through the 7 patients

C ROMBEZ went through the patient notes

specifically the observation of diaphoretic patients, that a patient had


a seizure despite not being epileptic, and that a deceased patient had bulging eyes
CROMBEZ stated that these symptoms are consistent with an insulin overdose
Insulin isn't accounted for or secured at Caressant Care
Insulin would never be looked at as a cause of death

ADRIANO was found on August 27th 2007 and was clammy, sweating and di fficult to arouse
When ADRIANO was found this way WETTLAUFER was working that night and that was
the only time that ADRIANO exhibited those symptoms
D.C. OVERBAUGH also spoke with Dr. Elizabeth URBANK.E9 at Woodstock General
Hospital
Dr. URBANKE confirmed that insulin levels would never be checked at the time of death
You wouldn't be able to determine insulin levels by exhuming bodies and even if you were
looking for insulin levels during an autopsy it would be difficult to find

Dr. Alan KAHN was the psychiatrist attending to WETTLAUFER

14)

CEf(I IFILO 1 P l.3f: I~ 1 f\'Ul: AN!)


COPic ALi-f tNTIQUE -:umFEr;
CORREC1 COP'r OF THI'.: ORfGli\iAI
Dr. Elizabeth URBAN KE is an ER doctor at Woodstock General Hospital and also a regist~:reo ~ ~,ie~ fl.. L.~~RIOINAl
9

w Detective Kevin HAMILTON Is a Detective with t he Toronto Pollce Service CLERK OF Tl-IE CO C
CREfFl~lf ~r lJ\ c
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15) At 11 :27 Hrs. I completed an internet search for the CAMH and learned that it was located
at 250 College Street, Toronto Ontario.

16)

-
30
17)

18) At 15:58 Hrs. I spoke wi th D.C. DICOLA. I learned the following:

He weot to Meadow Park Care Centre in London


He sp oke with Nicole ROSS 11
ROSS advised that she has in her possession progress notes for the time period surrounding
Arpad HORVATH's transfer from their facility to Victoria Hospital and his subsequent
death, Medication Administration Records, WETTLAUFER's personnel file and progress
notes specifically for HORVATH
ROSS indicated that the notes were available immediately, though she would need up to 7
days to produce them in case she wasn't working at t11e time she was served with a
Product.ion Order
ROSS indicated that the notes were in her possession at Meadow Park Care Centre, 12 l 0
Southdale Rd East, London Ontario
ROSS said that e-mail or facsimile service of the Production Order would suffice and that
she could provide a copy to police via the same
ROSS provided an e-mail address o

l 9) On October 5111 2016, J was part of a briefing that included D/Sgl TALSMA, D.C.
OVERBAUGH, O.C. DICOLA and D.C. EASTLAKE. During this briefing I learned the
following:

D.C. EASTLAKE stated that she attended Telfer Place in Palis


I.n April 2016, WETTLAUFER was asked not to return to their facility due to her behavior
towards other staff members
Sandra "FOWLER" was actually named Sandra TOWLER
CER 1lf=ILD l I tlE A 1'Wl }\I If}
CC'PIE AlJ 1lc NT1!)1Jf r ERl 1F-~E:
C.QPRECT COPl OF TH>: ORIG INAi
11
Nicole ROSS is the Administrator of the Meadow Park Care Centre in London f-!T CO~RM~)-'ORI Gll\JA~
L .

~~~ ~.
Cl ERK OF THE COLJPT.
~.RC!'>=IGQ Df LJ\ C01.m
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"t.;\~ I\ ~ cs Ill~ I t le' I It:: I U)~ I \ttt }
TO\VLER went to hospital in 20 15 after becoming confused, however this was detennined to
be from a "UTI"
It was confirn1ed that WETTLAUFER would hnve cared for TOWLER while she was there
Insulin was not controlled or monitored at Telfer Place
WETTLAUFER was also employed through ''Life Guard'', but her last day was August 7th
2016. WETTLAUFER quit because she sent an e-mail to Life Guard in which she stated that
she, "Can no longer function as a Registered Nurse"
D.C. DICOLA stated that he spoke with Tamara CONDY
WETTLAUFER only worked for Saint Elizabeth for approximately 5 weeks
There wasn't any negative feedback from patients or col1eagues regarding WETTLAUFER
during that time
\VETTLAUFER resigned on September 2nd 2016, stated that she couldn't do it anymore
D.C. DICOLA spoke with Patricia MALONE 12 of Saint Elizabeth. She bad control of
WETTLAUFER's employment records, patient List, and her resignation letter
MALONE was aware that police would be requesting a Production Order for those materials
and had them prepared
MALONE could be served at 90 Allstate Parkway, Markham Ontario
D.C. OVERBAUGH stated that she'd spoken again with CROMBEZ
CROMBEZ had control of the Caressaot Care ''Death register" 13 from 2007-2014
CROMBEZ also has control ofWETTLAUFER's persollilel file as well as patient notes of
the deceased victims titled "Click to care patient records"
The files were located at her office at 81 Fyfe Avenue, Woodstock Ontario
The records were mostly prepared already and could be provided to police within 7 days
from the date of the service of a Production Order
D.C. OVERBAUGH n111her stated that CROMBEZ disclosed that WETTLAUFER was
dismissed from Caressant Care in 2014 for failing to follow insulin protocol

11 Patricia MALONE is the Corporate Integrity Officer for Saint Elizabeth Health Care

13
On 040CT16, at 16:00 Hrs, D.C. OVERBAUGH learned via conference call with D~~~~~~~~~~{~~F~~~ill
had a Death Register. It was prcictice until 2014 for a coroner t o attend on ever;yclW~~h @tPal'.e~~nqQar~ ORltilf\ AL
regardless of the circumstances. caressant Care held these records. F 1 ~F.Q~Mf~ C. 1. ~J GINAl

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20) At 09:17 Hrs. I spoke with Pat MALONE. She advised that she' d need 72 hours to produce
the required documents upon service of a Production Order, and that e-mail service to here-
mail account would suffice for service.

21 ) At 16:55 Hrs. I spoke with D .C. OVERBAUGH. I learned the following:

Legal Cooosel for CAMH was Kristin TAYLOR


TAYLOR was the person to be contacted in order to obtain the medical records of Beth
WETILAUFER from her admission at CAMH
TAYLOR' s e-mail address w

22) At 16:58 Hrs. I spoke with D.C. EASTLAKE. I learned the following:

Telfer Place in Paris is owned and operated by Revera Longterm living


Frank CERRONE is the Senior Vice President of Revera and responsible for assisting poli oe
with regards to Production Order R equests

23) At 20:44 Hrs. I received an e-mail from Chief William RENTON14 . He mentioned
information that the Toronto Police Ser vice had interviewed Dr. KHAN.

24) On October 6111 20 1 6~ at 08:05 Hrs. I was involved io a briefing regarding this investigation.

I also asked in tlUs briefing if any of the


other detectives had knowledge of a statement obtained by the Toronto Police Service from
Dr. KHAN. I learned that D.C. OVERBAUGH had been told by Detective ALBER GA thal
they'd obtained a state01ent from Dr. KHAN and that it was mentioned in their report, which

14 . . . . ' CERl IFIED TC BE I. 1~U f; ~''"


Chief Wllltam RENTON IS the Chief of Police of The Woodstock Police Service COPE All ~N.,.ICIJl CERT.FEc
.:ORRECT COPY OF THE OPll.111\lAL
isDetective Constable HERGOTT, hereafter narned D.C. HERGOTI, is a Detective ConsJJi~'1~~~-dsfc!E!CNAft-L
Police Service ..--<'.1~1. ~l~l.
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GREi-FIEl'i' DI.; I "' ~oup
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[hadn't read. I viewed the Toronto Police Service report on Niche and learned the
following:

Dr. KHAN was interviewed on September29 1b 2016

25)

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26) At 10:38 Hrs. I received an e-ma il from D.C. EASTLAKE, and I also spoke with her. I lea rned

t he fo llowing:

She had been in contact with Revera Retirement Living earlier that morning

Th e person in ch arge of providing records to police in response t o Production Ord er

requests was Melanie STEELE, of Rever a Retirement Living and Long Term Care Services, 55

Standish Court. M ississa uga Ontario,

She had access to and control of the records required

She could produce t he records within 7 days

53
27) At 14:58 Hrs. I dropped off an Information to Obtain a Production Order at Court for

records locat ed at Caressant Care, Revera Retirement Living, Meadow Park and Saint

Elizabeth. At 15:55 Hrs. I retrieved th e Production Orders that had been signed by a Judge

so that I cou ld serve thetn.

28} On October 19th 2016, I returned from a holiday and learned that I would be required to

write more production orders, including additional production orders for Caressant Care,

Meadow Park, and Saint Elizabeth.

29) At 08:05 Hrs. I met with O/Sgt. TALSMA in his office. I viewed a forwarded email from

Detective Steve SIMONE16 . I learned th at he' d spoken directly with Nicole ROSS who

advised she had in her possession a copy of the M eadow Park Death Registry, a list of

medication errors and the controlled substances record pertaining to the medication cart

accessible to Beth WETTLAUFER, and the staffing schedule for Meadow Park.

30) At 08 :31 Hrs. I spoke with D.C. OVERBAUGH. I learned the following;

On October 5th 2016, at 17:00 Hrs. she received an e-mail from Kathy FRASER17 advising. her

that there was a message from Helen CROM BEZ indicating that Helen CROM BEZ believed

that the victim "Mike" was in fact Mike PRIDDLE, and that the victim "Wayne" was in fact

Wayne HEDGES, who died on October 28th 2008.


On October 7 th 2016, at 09:42 Hrs. D.C. OVERBAUGH spoke with Helen CROM BEZ direct ly.

CROMBEZ advised that WEITLAUFER had given "glucagon" to Wayne HEDGES when he was

found with critica lly low blood sugar and that "glucagon" reverses the effects of fow blood

sugar. Mike' s full name was Michael Stephen PRIDDLE and he died in December 2012.

There was no time t hat PR IDDLE was found unresponsive but he was under the direct care

of WETTLAUFER, had Huntington's Disease, and was a patient at Caressant Care at the time

On Mon day October 10th at 2016 at 11:47 Hrs. D.C. OVERBAUGH attended at Beth

WETTLAUFER's new address at

D.C. OVERBAUGH also confirmed t hat Helen CROM BEZ is aware that the Woodstock Police

Service wilt be requesting patient records for Mike PRIDD LE and Wayne HEDGES and that

she could have those records ready within 7 days

31) At 10:17 Hrs. I spoke with Detective Constable Beth BROWN 18, and I also viewed some of

the records provided from Saint Elizabeth Health Care for th e original Production Order.

learned the following:

-
_f;/<T1HE:u r.._, u1-: ~ , raJt- A111D
COPIE AlJl LNllOUE <"Ei'<T'FEe
18
Detective Constabl e Beth BROWN, hereafter named D.C. BROWN, Is a Detectivel"i26lfsafile 1&ltlFtt-ie:lntj! ~i fi: ORrc':"iJ\J
41
Provincial Police and the lead investigator for the Oxford OPP investigation of the attem~teffif'IM2&1"EiffS~iiei<lf.NA
BERTRAM, as she resides within t heir jurisdiction 1"~uff/-
/.,
t1 CREFFlul?
E K OF THE I.OUR
DE l.J: i:Ot11-
-
0~T AR!Q ,..OJ!:T C" JU!"!i!ii lCt_
IJUl<r t" lt..!fJr- I.ff.' 1 f.'l t f t hntl"'
Beth WETTLAUFER worked for Saint Elizabeth from July 20111 2016, until August 29th 2016

32) At 10:30 Hrs. I spoke directly with Detective SIMONE. I learned the following:
He saw Nicole ROSS personally

Nicole ROSS confirmed that she had in her possession the required records which had

already been prepared

Nicole ROSS would only need one day to produce the records

33) At 10:44 Hrs. I spoke with Constable Matt LYNCH 19 . I learned the following:

It was learned through Beth WITTLAUFER' s ex-husband Dan iel WETTLAUFER that Beth

WITTLAUFER used to work at the Geraldton Regional Hospital located at 500 Hogarth

Avenue, Geraldton Ontario

Beth WETTLAUFER's maiden name was "PARKER"

An MTO check confirmed Beth WETTLAUFER had an address in Geraldton In 1995

P.C. LYNCH spoke with Dori GIGNAC20 on October 17th 2016, and GIGNAC confirmed that

Beth "PARKER 11 was previously employed at Geraldton Regional Hospita l

Pau line VIOLETTE had possession and control of the emp loyment records for Beth

WETTLAUFER (Nee: PARKER)

P.C. LYNCH included this information in an e-mail he sentto me, which I read

34) At 10:52 Hrs. I spoke with Pauline VIOLEffi. She told me th at she would need less th an 7

days to produce the employment records of Beth WETTLAUFER (Nee . PARKER) and that e-

mail service to would be sufficient for the service of the

Production Order.
CH(J II IED I t.t 131: i.\ I f<\..Jt: /~ 1 111-
COP1::: ALl"f'"iH 1T1 0ut. CE'?TIFEE
COR~EC1 J+ ~- TH: ORIC'o l\J"'
ET CC. NF l<rv';:). l t1~1?1C1NP

."":":7-:7""""1!::':~1-'.-:--!'\..l.~u~-!. t . ,
19
Constable Matt LYNCH, hereafter named P.C. LYNCH, is a police constable with th e ~ !ll f!1 H!~ f}r:J,
currently assigned to assist the Criminal Investigation Bureau with this investigati.Pfl CRE -FIH' L ~rJu /
r;1\1r11,P 1t1'CJ1J
r- II I r- 11 rf!
"'.ur.
n~ I
20
Don GIGNAC is the payroll and benefits coordinator with Geraldton Regional Hospital

56
35) At 11:05 Hrs. I spoke with Pat MALONE again. She told tne that e-mail service of the

Production Order would be suffident, that she had control of the medical records for

Beverly BERTRAM as well as employee records of th e other nurses working out of the Saint

Elizabeth Woodstock Ontario location, and that she'd need less than 7 days t o produce

these records.

36) At 11:41 Hrs. I read an e-mail from Kristin TAYLOR which had been sent to me while I was

away on vacation. I learned the following:

A Production Order for Beth WETILAUFER's medical records from CAMH shou ld be made
out to " Manager, Health Records - CAMH, 1001 Queen Street, Toronto"

The Production Order should be made out to Kristin TAYLOR via fax or e-mai l:

Kristin Taylor Is having the info rmation prepared so it's ready for the police when the

Production Order is issued

They would need 1 day to produce the records upon the service of a Production Order

37) At 11:55 Hrs. I checked the MTO site and confirmed that WETILAUFER had a surname of

PARKER in 1995

38)
39) On 200CT16, at 08:22 Hrs. I spoke with D/Sgt. TALSMA. I learned the following:

While I was away on vacation, officers went through the documents from Caressant Care,

Meadow Park, Saint Elizabeth and Revera Retirement Living that were obtained from the

Production Orders already issued

It was confirmed that Beth WEDLAUFER had direct care of each of the victims mentioned in

the Productions Orders at, or just prior to, the time of their deaths

40) At 11:40 Hrs. D/Sgt. TALSMA told me that in addition to patient notes, we would also

require all medical records from all victims at Caressant Care and Meadow Park, including

their death certificates and initial triage notes

41) At 11:50 Hrs. I spoke with Helen CROM BEZ. I learned the following :

She has control of all medical records of the 11 victims from Caressant Care

She cou ld produce these records within 7 days

These record s include copies of t he death certific:otes of the victims

These records include the initial admission records of the victims

42) At 14:59 Hrs. I spoke with D.C. HERGOTT and I learned the following:
CE R rI Fl(: [J 11 ) 81 .:.\ 1 <u l Ht\IL.
COPtE .t-U THEN flCJIJ~ r.ERl IFCF
CORRECT COPY Of- rHE OR ICIN.A
ET cayoRM~ ~ I 'ORIGINAW-t
. a 1 \fL&<:li
fiRFF'Ftt;~ cnlJl'f!e
CLERK 01 ~IC \.OlJ
7
I'll ll'
Ol'VT/\RIO rourn er- JlJ~,TIC l-
ctj1..H l'r ,i L1 1o I I r "'" " 11" 1r
58
Beth WETTLAUFER's family doctor ls Dr. JonnyTAM 21

Beth WETTLAUFER told him this directly

On October 12th 2016, at 10:20 Hrs., he spoke with Sandy HOLTBY22 who confirmed that

Beth WETTLAUFER was Dr. TAM's patient

Sandy HOLTBY stated that if a Production Order was required all records were held by Dr.

Jonny TAM who would be required to be served in person

The records are held at , Woodstock Ontario

43) At 15:15 Hrs. I spoke with Nicole ROSS . I learned that she still had control of all of Arpad

HORVATH's medical records including his admission summary and that she could produce

these records within 7 days.

44) At 15:19 Hrs. I spoke with Constable Mike ROUTLY 23 and learned the following:

At 15:04 Hrs. he spoke with Sharon GROENEVELD24 of Superior Greenstone for Community

Living (formerly Geraldton and District Association for Community Uving) and confirmed

that Beth PARKER was employed there in the mid 1990's

Sharon GROENEVELD has access to and control of the employment records

Sharon GROENEVELD could be served a Production Order via e-mail to

The records are located at Superior Greenstone for Community Living (formerly Geraldton

and District Association for Community Living), 206 Hogarth West, Geraldton Ontario
CER rt Fld> I._. 0 f "' 11~u t:: A1\J1
COPlf: ti.u -"~1:1\ u1.E CE'11 IF~E
CORRECT COPY lh THE Jq1C I.-\
E"'COf\lr-l*Mfr L(JR I Gll'\J~AI

A/iaa~cn -1
11 Dr. Jonny TAM, is a fa mily physician wi th an officer in Woodstock Ontario. > ffl#l( t')F fHf' <T1rn?'
CREr:l!1r: ' "'f I ( L6,/
12 Sandy HOLTBY is a nurse employed at Dr. Jonny TAM's office.
01\ff/\Ritl
c;1o1t1 r r
COllkT
r r 'I
Of Ju;;-,. F-
,,_, nto.n .,
11 11 11 111

13Constable Mike ROUTLY, hereafter named P.C. ROUTLY, is a constable with the Woodstock Police Service
assigned to assist th e Criminal Investigat ion Bureau with this investigation .

.IA\ Sharon GROENEVELD is the manager of Superior Greenstone Association for Community Living

59
At 15;10 Hrs. P.C. ROUTLY spoke with Yolanda AKHTAR 25 of Christians Horizons

AK HTAR believed that Beth WETILAUFER worked for them, but she stated she'd confirm

that and let P.C. ROUTLY know

45) At 15:30 Hrs. I spoke with P.C. LYNCH. I learned th e following:

At 15:26 Hrs. he spoke with Janine HOOVER of Conestoga College

She has control of all student records including t hose from students who attended the now

closed Stratford Ontario campus

The records are located at Conestoga College, 299 Doon Valley Drive, Kitchener Ont ario

Janine HOOVER could be served via e-mail t

She would require 2 weeks to produce the records

46) At 15:36 Hrs. I viewed Beth WETILAUFER's resume that had been obtained from a

previous Production Order for records from Caressant Care . The resume indicated the

following:

Beth WETILAUFER obtained a Registered Nurse Diploma from Conestoga College, Stratford

Ontario, during the time period of September 1992 -Apri l 1995

Beth WETILAUFER worked as a Staff Nurse at Victoria Rest Home, 265 Victo ria St . N,

Woodstock Ontario, from March 1996 until October 1996

Beth WETILAUFER worke d for Ch rist ian Horizons, 289 Graham Street, Woodstock Ontario,

starting in June 1996, and had a ref erence letter from them dated June 11th, 2007

47) At 11:47 Hrs. I spoke with P.C. ROUTLY. I learned the following:

25
Yolanda AKHTAR is the Program Manager at Christian Horizons
He spoke again with Yolanda AKHTAR, who confirmed that WETTLAUFER was previously

employed with Christian Horizons

AKHTAR advised th at M arc GORAL, Human Resources Manager, Chri stian Horizons, 4278

King Street East, Kitchener Ontario, had control of the employment records for Beth

WETTLAUFER an d th at t hose records were located at the above add ress

E-mail service to M arch GORAL at was sufficient for service

of the Production Order

48) On October 241h, 2016, at 08:57 Hrs. I was present for a briefing on th is investigatio n that

included representatives from the OPP, Londo n PS and Woodstock PS. I learn ed the

following:

Det. SIMONE had received the records from Meadow Park for the first Production Ord er

issued

Records showed that HORVATH was found unresponsive with very low blood sugar

HORVATH was given glucagen to raise his blood sugar and he was transported to Victoria

Hosp ital

After HORVATH's blood sugar was stabilized from the glucagen, it crashed and became very

low again shortly thereafter as the long acting insulin kicked in

49) At 09:33 Hrs. I read th e medical notes from HORVATH's medlcal records that were

provided to me by Det. SIMONE. I learned the following:

There were t hree instances where HORVATH was found with low blood sugar. Those

instances were on June 28th 2014, July 12th 2014 and August 3 rd 2014.

In each of these incid ents, Beth WETTLAUFER was the nurse taking ~E!r,ernf1 tlQRVAlfl:.l \ : 11
COPIE PUT, E~' IClul e.., ,;
CDRREC-1 coPv ai= 1H . or 1- , H
ET CONc<,~ME A L:C>?1rlf'JAI

,,~~ori:?~
c~rc.-F1r ~ "ef~~, )1
1

ONTA~IO ri , '1 '61


t';IJ!_lj;flJt ..... , ~ ....
On August 24th 2014, at 06:21 Hrs. HORVATH was found unresponsive, diaphoretlc, cold and

clammy, with a very low Blood Sugar of 3.1 mmol

The nurses gave HORVATH glucagon to get his blood sugar raised

Middlesex-London EMS transported HORVATH t o Victoria Hospital

At 06:31 Hrs. EMS checked WETTLAUFER.'s blood sugar and it was at 1.4 mmol

En rout e to hospital, the blood sugar went up to 10.4 mmol

At 07:05 Hrs. HORVATH's blood sugar was at 9.5 mmol

At 09:20 Hrs. HORVATH's blood sugar dipped back down to 2.2 mmol

50) At 09:42 Hrs. I re ad WETTLAUFER's resume from the Production Order for employment

r ecords from Saint Elliabeth. I lea rn ed t he following:

WETILAUFER received a " Nursing Foot Care" certificate from Fanshawe College, London

Ontario.

WETTLAU FER got her nursing dip loma from Conestoga College, Stratford Ontario

WETTLAUFER had a Bachelor of Religious Education from London Baptist Bible College,

London Ontario

51) At 10: 12 Hrs. I wrote an e-mail to Fanshawe College requesting information on who had
control of student r ecords and where those records would be located.

52) At 12:24 Hrs. I read a letter of dismissal issued by Brenda Van Quaethem 26 to Beth

Wm-LAUFER, and dated March 3pr, 2014. This letter was obt ained t hrough a Production

Order for Beth WETTLAUFER's employment records from Caressant Care. Th e letter

indicated th e reasons for WETTLAUFER's dismissal, which included the following quotes:

"On March 26, 2014, I became aware of a serious situation involving a resident (H .D). Upon

investigation it became apparent that you had administered the wree~l111~~iHEJl')tp ,!'('i~tdi ~ ,
11 11
COPIE AU 11 l:NTJOt..t:' P.tlFEE
CORR~fl COPY or- TH~ 0'(11 tr~
:: ... 0~ 1 UtlM I; L'Clf<IGll\IAI
h / .
26
Brenda Van Quaethem is the Adminlstrator of Caressant Care 4
;,r kj~:(LrsJf
:::> CLERK Or- THF C ~
CR!:r-m . n~ 11 1 i..
O~J~I J~l-,~~~ l~T . ~~'-..~~z. ;,,~.J:
DOIDGE; instead of giving her the medication that had been prescribed for her, you gave

her medication that was prescribed for another resident. This then r esult ed that in her

being incorrectly medicated and over-medicated as well. The resident experienced distress

as a result of this.''

''At our meeting you acknowledged that this was an error on your part and explained that it

was inadvertent. Bethe although you have acknowledged t his latest error, this is another

incident in a pattern of behaviou rs that are placing residents at risk. You have an extensive

disciplinary reco rd for medication-related errors which includes numerous warnings as well

as 11 3 and two 5 day suspensions."

"As a result of this most recent occurrence, the t ermination of you r employmen t is

warranted. Please be advised t hat your employment is terminated effective immediately.''

53) At 13:16 Hrs. I received an e-mail from Deb STOCKMANN. I learned the following:

STOCl<MANN was the Student Records Team Leader of Fanshawe College Office of the

Regist rar, E1012, 1001 Fanshawe College Blvd., London Ontario.

STOCKMANN had possession and control of the student records of former students at

Fanshawe College

She could be served a Production Order via a scanned e-mall copy t o

nd would need less than a week to produce the records

If the police needed any information regarding potential counselllng records they' d need to
contact Suzanne BOOK in Counselling and Accessibility Services a

54) On October 25th, 2016, I spoke with Paul BRENNAN. I Jeamed the following:

He is the Manager of Reports and Prosecution - Professional Standards, at The College of


Nurses of Ontario, 101 Davenport Road, Toronto Ontario
He has access to and control of all records for or pertaining to Beth WETILAUFER (Nee:
PARKER) 1..E.RllFIEfJ IL '.li ~ \' _ it
COIJIE AU 11-1E \ITIQ lJtO Lir.'i ~ E~
. C.ORRECT COP., OF TI IE OR1 f
He would requue less than 2 weeks to produce those records for pouoe n ~FO~t= A 1 c~ i1~1r1NA

_A~a;~ -
CLER!\ OF THF
r:RfFS:IF.e !11-c I I\ : { .
ONTAi\'ICll)L.r:Tl ~J. I l
r ,11t111r!t: ' ' '"lTtr-c " .,
A scamwd copy of a Production Order e-inailed to would be
sufficient for service of a Production Order

REASONABLE GROUNDS TO BELIEVE AN OFFENCE HAS BEEN COl\'1.MITTED:

55) Section 235 (1) of the Criminal Code of Canada states: E veryone who commits first degree
murder or second degree murder is guilty of an indictable offence and shall be sentenced to
imp1isonment for life

56) Through the investigation to date and based on the aforementioned paragraphs, I believe that
there are reasonable grounds to believe that the offence of murder as described in Appendix
"A" of this information bas been committed by Beth WETTLAUFER against the victims
James SILCOX, Maurice GRANAT, Helen MATHESON, Mary ZERWINSK1, Gladys
M ILLARD, Helen YOUNG, Maureen PtCKERfNG and A.rpadHORVATH

57) Section 239 (1) (b) of the Criminal Code of Canada states: Every person who attempts by
any means to co nunit murder is guilty of an iudictab le offence and liable to imprisonment for
life

58) Through the investigation to date and based on the aforementioned, I believe that there are
reasonable grounds to believe that the offence of attempted murder as described in Appendix
"A'' of this Infom1ation has been committed by Beth WETTLAUFER against the victims
Wayne HEDGES, Michael PRIDDLE, Clotilda ADRIANO, Albina DEMEDEIROS, Sandra
TOWLER and Beverly BERTRAM

59) My grounds for my belief are as follows:


- - "
- I
.
-
R EASONABLE GROUNnS TO BELIEVE THE DOCUMENT OR DATA IS INTHE
PERSON'S P OSSESSION OR C ONTR OL AND WILL AFFORD EVIDENCE:

60) My grounds for belief are as follows:

As indicated in paragraphs 45, 46 and 50, two resumes submitted by Beth WETTLAUFER
indicated that she obtained ber Registered Nurse Diploma at Conestoga College, Stratford
Ontario. P.C. LYNCH spoke directly to Janine HOOVER of Conestoga College who told
him that she had control of the records at 299 Doon Valley Drive, Kitchener Ontario.

As indicated in paragraphs 50 and 53, Beth WETTLAUFER's resume indicated that she
attended Fanshawe College, and Deb STOCK.MANN of Fanshawe College confirmed that
she had control of student records at 1001 Fanshawe College Boulevard, London Ontario

As indicated in paragraph 54, l spoke directly with Paul BRENNAN. He stated that he was
the M anager of Reports and Prosecutions - Professional Standards1 for The College of Nurses
of Ontario, and that he Jmd access to and control of all records pertaining to Beth
WETTLAUFER, and that those records were located at 10 l Davenpo.rt Road, Toronto
Ontario.

These records will show that Beth WETTLAUFER was educated in the adm.inistration of
medications, including insulin, as well as the effects these medications would have on
patients

These records may show comments or concerns from professors regarding B eth
WETILAUFER's behaviour or work performance CERTIFIE:D Tl') .:t. d "''it.:
COPI E AU'THEN TI0 11 E ~;::o- FEE
CORl~ECT COPY OF- Th2 O~IGtNt.11
ET CONF9RME. iJ. :.. ORlt.INfll
- -f
.dZ J ~~ "'
7
CLERK OF THE C
CFIEf'tFI HR DF l l\ C:C
ONT;. lilO COURT Qr .16fe'S I C
iZ'-1ut; ~~ ..-w-..~.. .,11; '~-, ""I"'' .. , ,..,
These records wi ll show that Beth WETTLAUFERl1:.id previous compl aints nnd/or
disciplinary action against her regarding her behaviour ot actions

CONCLUSION:

As a result ofthe information and belief described in paragraphs I to 60 the Informant has
reasonable grouods to believe and does believe that an offence against an Act of Parliament has
been committed, and that documents or data will afford evidence ofthe commission of the said
offences, and that Janine HOOVER - Associate Registrar, Conestoga College, 299 Doon Valley
Dr., Kitchetler Ontario, Deb STOCK.MANN - Student Records Team Leader, Fanshawe College
Office of the Registrar, El 012, 1001 Fanshawe College Blvd, London Ontario, and Paul
BRENNAN - Manager of Reports and Prosecutions, The College of Nurses ofOntado, 10 1
D avenpo1t Rd.. Toronto Ontario. have possession or control of tlle documents or data.

The In.formant believes that all the facts and matters set forth in this Information to Obtain are
true, notwithstanding any omission on tile Infom1a.n.t's part to specifically so state in any one or
more of the grounds or elsewhere in the Information.

To the best of the Infonnant's knowledge, information and belief, Conestoga College, Fanshawe
College, and The College of Nurses of Ontaiio are not under investigation for an offence
described ins. 487.0 14(2).

This fnformation is sworn for the purpose of obtaining a production order pursuant to section
487.014 of the Criminal Code.

,...ERTIF1lO I J E>t. ~~UE: 11 1 U


... COPH: A J r L 'J l(Jl,IF' i;.,..;0 f:
~ORRECT COPV Cll-IHt ,1Rll 1 .1 1
ET CONF-O l~~A L' Oi;>IGINAL

, I -;)c:
SEALING ORDER REQUEST!

f am seeking an order under s. 487.3 of the Criminal Code prohibiting access to and tbe
disclosure of any infonnation relating to the production orders sought in this application. I
believe that the ends of justice wouJd be subverted by disclosure of this info1111ation, or that the
informatjon mig4t be used for an improper purpose, My reasons for this belief are as follows:

I believe that the disclosure of information relating to the production orders sought in this
application will compromise the nature and ex.tent of an ongoing police investigation.
Disclosure of the methods used by police in this ongoing investigation would seriously
impede investigator in cornpleting the investigation, and thereby amount to the subversion of
the ends of justice.

This will likely be a high profile case within the community of Woodstock and Oxford
County that is likely to garner Canada-wide media attention, as it involves the murder and
attempted murder of mulliple helpless victims by someone entrusted to care for them.

Police are still identifying persons as potential witnesses in this investigation. Persons who
know the suspect may be reluctant to speak to police or come forward if they believe their
involvement with her will be made public.

I am also concerned about the possibility that the public disclosure of this information could
compromise the fair tri al interests of the suspect and/or unnecessarily complicate any trial
proceedings. There is a distinct possibility that release of the details of the investigation to
the public could contaminate potential jury pools and affect a potential change of venue
application prior to trial. A sealing order is in the interests of justice because it wlll ensure
that potential jury members will not be exposed to possible contamination from media
sources through the release of this infonnation.
Accordingly, I bel ieve a sealing order prohibiting access to the said information should be in

effect until a court of competent jurisdiction authorizes the release.

D/Cst. Tim Pinder Commissioner of Oaths, Provlnce of Ontario

Woodstock Police Service

Kathryn Anne Fraser a


Commissioner, etc., Province of
Ontario, for Woodstock Police
e,
Service. Expires f;)ecomt>or 2017.

Sworn before me at the City of Woodstock

In the Southwest Region

This 261h day of October, 2016


APPENDIX "D"

I. Janine HOOVER - Associate Registrar, Conestoga College, 299 Doon VnUey Dr.,
IGtchener Ontarjo, Deb STOCKMANN - Student Records Team Leader, Fanshawe
College Office of the Registi-ar, E1012, 1001 Fanshawe College Bhd, London
Ontario, and Paul BRENNAN - Manager of Reports and Prosecutions, The College
of Nurses of Ontario, 101 Davenport Rd., Toronto Ontario: shall produce the above
described documents and/or data to Detective Constable Tim Pinder, a peace officer, !at
The Woodstock Police Service 615 Dundas St, Woodstock ON, N4S lEl as soon as
reasonably possible but in any event no later than 14 days from the date of this order;

2. Any data required to be produced by this order may be produced in elecnonic form
recorded on machine readable electronic storage media or recorded in documents that
contain true copies of the data;

3. Any documents required to be produced shall be produced in the fonn of copies of the
said documents certified by affidavit to be true copies;

4. That the Order be executed at Conestoga College, 299 Doon Valley Dr., Kitchener
Ontario, Fanshawe College Office of the Registrar, E1012, 1001 Fanshawe College
Blvd, London Ontario, and The College of Nurses of Ontario, 101 Davenport Rd.,
Toronto Ontario, and that the order be picked up at that location by Detective
Constable Tim Pinder or a designate, OR be forwarded through their internal mailing
process to Detective Constable Tim Pinder, Woodstock Police Service 615 Dundas
St., Woodstock ON, N4S 1E1, OR be sent via facsimile to Detective Constable Tim
Pinder, Woodstock Police Service, 519-533-5155, OR be sent via electronic mail to
the e-mail address of Detective Constable Tim Pinder: in
order that the conditions of the Order be complied with. Cl:Ri lfli::LJ 1'J r;:; : '"' , , .. " ,
COPIE /~UT' 1!::11 TIOl.. 1: C U~l t -C
CORREC-1 L'UPY uF 1 H~ QJ.<lr,
-l C"Ot FO~tV\t.A L O"ICit U 1
SUBJECT TO the following terms and conditions: . ~ ~
~ae_~
_
CLERK OF THF COU
CReFF1b11 x L 'I coli ,
7-
S. Janine HOOVER-Associate Registrar, Conestoga CoUeg~\1io&f fl!6bn~a'.llevIDr. t '"
ttJ(lt,-r.Jt. if"' ~J.- 1i q
Jt j I t ! I

70
Kitchene1 Ontario, Deb STO CKMANN - Student Records Team Leader, Fanshawe
College Office of the Registrar, El012, 1001 Fanshawe College Blvd, London
Ontario, and Paul BRENNAN - Manager of Reports and Prosecutions, The College
of Nurses of Ontario, 101 Davenpol't Rd., Toronto Ontario: shall produce all copies,
photocopies, duplicates or certified copies of documents or data in a legible, readable or
otherwise accessible and usable form;

6. Conestoga College, 299 Doon Valley Dr., Kitchene r Ontario, Fanshawe College
Office. of th e R egist.-a.r , El012, l 001 Fanshawe College Blvd, London Ontario, and
The College of Nurses of Ontario, 101 Davenport Rd., Toronto Ontario: shall not
destroy or alter any original document or data copied or duplicated and produced unless
permitted by order of a Court of competent jurisdiction or until ad vised by Detective
Constable Tim Pinder or a peace officer acting wider the auth01ity or direction of that
peace officer or acting in good faith in. aid thereo~ that the investigation of the offences is
concluded and that any charges resulting there from have been :finally disposed of
including all appeals;

7. Janine HOOVER - Associate Registrar, Conestoga College, 299 Doon VaUey Dr.,
Kitchener Ontario, Deb STOCKMANN - Student R ecords Team L eader, Fanshawe
College Office of the Registrar, El012, 1001 Fanshawe College Blvd, London
Ontario, and Paul BRENNAN - Manager of Reports and Prosecutions, The College
of Nurses of Ontario, 101 Davenport Rd., Toronto Ontario: shall, upon request and
where it is reasonably possible to do so, disclose and provide copies of all or any prut of
the contents of any document or data required to be produced by this order to Detective
Constable Tim Pinder prior to certification and production as otherwise required by this
order;

8. Janine HOOVER - Associate Registrar, Conestoga College, 299 Doon Valley Dr.,
Kitchener Ontario, Deb STOCKMANN - Student R ecords Team Leader, Fansh.awe
College Office of the Registrar, El012, 1001 Fanshawe C6lle~l.i<I ILoHdon!l<lll P11 1
Ci~fPlf AU ~ EN'fllJUF CER rHh
Ontario, and Paul BRENNAN - Manager of Reports anJ.>P'f'c~fr . fR.~,J~~:~i~fdNAi

~ CLER; Qr 'fffFc:~
ClR'"J:r.1t;f~ 11' ~ /{}/1'~ _.
01 AR1r.. 1. Ri o 1Ls r1L _
1 i
w.r
( lJff4 I IJ"l J1Jo11e:t ~ Ir
of Nurses of Ontario, 101 Davenport Rd., Toronto Ontario, and any employee,
servant or agent shall not directly or indirectly disclose or p ermit disclosure of the
content, existence or operation of this order, in any manner, or to any person except as
may be necessary for the purposes of compliance with its terms or obtaining tbe advice or
assistance of legal counsel unless otherwise ordered by a Court of competent jurisdiction;

9. Nothing in this order shall be so construed as to require the production of any data or
documents which are subject to solicitor client privilege;

10. Nothing in this order shall be so construed as to require the production of mail unless or
until it is delivered or deemed by law to have been delivered to the addressee;

CERTIHE:O 1lJ F.I A ~Ul: Al\'U


COPlc AJ1" JC:NliO!.Jt.i r :RTIFl:E
COR l~ECT ,~OPY OF 1 HE ORIC.11\J' 1
H CONFORM~ A L 01< ICINAI

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