Whitelaw-Twining Partner Beckmann states as "unreasonable" the Offer to deactivate this website, although the only requirement is that he retract his misrepresentative letter of 07 December 2023. (The SLAPP Defendant's gesture is a conciliatory, voluntary forfeiture of his freedom of expression rights).

Antagonist Beckmann does not deny, indeed has never denied, that his letter of 07 December 2023 was defamatory in its false accusation of the SLAPP Defendant, as not being an insured of his Client INTACT; that the Defendant had submitted an insurance claim under false pretences.

The defamatory nature of Beckmann's false assertion is arrantly discredited by the Strata Property Act Section 155(b), the landmark case of Strata Plan VR 2213 v. Schappert, 2023 B.C.J. No. 2272, 2023 BCSC 2080 (decided by the Honourable Justice Coval of the BC Supreme Court), correspondence of INTACT personnel (SLAPP Plaintiffs Amanda Myers and Christa Rae Cordick), Adam Trott investigator of the BC Ombudsman Office, Bruno de Sando investigator of the GIO, Patrick Williams of renowned law firm Clark Wilson, CHOA (Condominium Homeowners Association of BC), the BCFSA, personnel of various Scheduled Insurers of the subject INTACT property liability policy, Insurance Broker Gordon Li, Property Manager Nico Barbu, Sedgwick Insurance Sr Adjuster Daphne Chan, Heather Bidnall, Compliance Officer of the Insurance Council of BC, et al.

The image to the left, albeit fictional, is of facts that will forever forge Whitelaw-Twining's antagonistic rôle, as the prima facie embodiment of the creator and perpetrator of malicious SLAPP litigation, for which the Courts (in the Supreme Court of Canada case Hansman v Neufeld, 2023 SCC 14) and Legislature (in the Protection of Public Participation Act), have expressed extreme distaste! Indeed, in light of the misguided, egregiously conflicted-of-interest acts and omissions of the Whitelaw-Twining Attorney for the INTACT SLAPP Plaintiffs (as minutely detailed and documented on this website) this case is clearly destined to become a landmark case, in Canada's emphasis upon human rights and freedom of expression. In the likely event that the Whitelaw-Twining Partner should continue on his wayward trajectory, in his scheme to exploit the resources of the BC Supreme Court as a tool for his oppressive SLAPP aspirations, then the media will begin to cover this travesty of justice, as the trial date approaches.

23 June 2025 Rule of Court 9-1 encourages extrajudicial settlements. SLAPP Defendant will ultimately present to the Court (be it by Application, Responsive Pleadings and/or Trial), the extensive paper trail of Offers made to and rejected by all SLAPP Plaintiffs. SLAPP Defendant looks forward to intensive examination of the Plaintiffs, at trial. However, in light of Rule of Court 9-1, an equitable, extrajudicial resolution is not without the realm of contemplation. Thus, if INTACT, SLAPP Plaintiffs Amanda Myers, Christa Rae Cordick or Michele Vincent should express interest in the "without prejudice" discussion of a possible discontinuance of the Counterclaim against them, it is requested of its counsel from Whitelaw-Twining that he, or anyone else with authority, broach the possibility with SLAPP Defendant. The woefully conflicted-of-interest Whitelaw-Twining Partner refuses to allow any settlement of claims between/among the parties, without inclusion of a release of claims against the Partner and Whitelaw-Twining. No Offer extended to any SLAPP Plaintiff is inclusive of a release of any claim, as against Whitelaw-Twining or its Partner!

24 June 2025 The three images to the left are an indication that the ulterior motive of the Whitelaw-Twining's Partner's SLAPP actions, expertly handcrafted for his Clients, Plaintiffs, Claims Manager Amanda Myers, Lawyer Christa Rae Cordick and Ombuds[wo]man Michele Vincent, against INTACT's Insured Defendant, was/is harassment, to bully him into the withdrawal of his Complaint of the Partner's defamatory accusation that the Named Insured had submitted his claim to INTACT under the false pretence of being an insured (as documented hereinafter). A tangential issue is the various illicit activities, committed by the Plaintiffs, and uncovered by fellow whistleblower, INTACT Privacy Officer Helen Cameron.

In the first image, the Whitelaw-Twining Partner claimed "general damages", in addition to the injunctive relief that the Insured permanently deactivate this website, relief which the Defendant had offered to the Whitelaw-Twining Partner, on three (3) occasions, prior to the filing of the SLAPPs, and on eight (8) occasions thereafter, as thoroughly documented on this website.

On each of the eleven (11) occasions, the Whitelaw-Twining Partner rejected the Offers to permanently deactivate this website, because his malicious, ulterior motivation, and that of his Clients was/is that the Insured Defendant withdraw his Complaint that the Whitelaw-Twining Partner had defamed him, by the false accusation that the Defendant was not an Insured of INTACT and that he had submitted his claim with INTACT under false pretences. A tangential issue is Defendant's request that INTACT's Customer Experience Team release their Final Business Decision letter regarding the Insured's Complaint, which was assigned to the Team investigators on 26 May 2023.

The image to the left is of the Whitelaw-Twining Partner's Plaintiffs' second SLAPP, filed just two (2) days after his first SLAPP. In the Partner's rare moment of truth, in the new SLAPP, the Partner has conspicuously deleted his claim for "general damages", leaving only the injunctive relief that the Defendant permanently deactivate this website, the exact relief that the Defendant had offered to the Partner on three (3) occasions, prior to the filing of his SLAPPs, and on eight (8) occasions thereafter, as thoroughly documented on this website.

The image to the left is of the Whitelaw-Twining Partner's NOTICE OF DISCONTINUANCE of his first SLAPP, in which he had sought "general damages".

In summary, the Whitelaw-Twining Partner originally had contemplated the additional, oppressive, malicious element of "general damages", but he ultimately abandoned such, because his illicit and malicious ulterior motivations are unsustainable, legally or even morally!

The wayward Partner continues to reject Offers of the Defendant, to permanently deactivate this website. if the Partner should imprudently represent the Plaintiffs at trial, then an enhanced dimension of the Partner's irreconcilable conflict of interest shall have arisen!

Below image from WHITELAW-TWINING's SLAPP action VLC-S-S-244484, filed on 08 July 2024

Below image from WHITELAW-TWINING's SLAPP action VLC-S-S-244577, filed on 08 July 2024

Below image of WHITELAW-TWINING's Discontinuation of SLAPP action VLC-S-S-244484, filed on 07 August 2024

20 June 2025 As minutely detailed and documented on this informational website, the Whitelaw-Twining Partner's deceitful, defamatory, spurious accusations that RB was not an insured of INTACT, and had submitted his claim under false pretences, has been entirely discredited by Strata Property Act § 155(b), which was incorporated into the recent Decision of the Honourable Justice Coval of the BC Supreme Court, case of Strata Plan VR 2213 v. Schappert, 2023 B.C.J. No. 2272, 2023 BCSC 2080], in addition to almost 40 percipient witnesses, including SLAPP Plaintiff Amanda Myers.

However, the most compelling fact of the false accusation of Whitelaw-Twining's Partner's letter of 07 December 2023, is that SLAPP Plaintiff Michele Vincent, Ombuds[wo]man] of INTACT, legally affirmed RB's status as a customer of INTACT, referring to RB as a Customer of INTACT, by acceptance of his formal Complaint (against Claims Manager Amanda Myers), with Vincent's assignment thereof to the Customer Experience Team, for an investigation and release of a Final Business Decision Letter, to RB. In light of the indisputable facts, displayed on this website, it is respectfully requested that the Whitelaw-Twining Partner donate his ill-gotten fees to a homeless shelter assistance organisation of his choice, in atonement for his malicious acts and omissions!

20 June 2025

AS PRECISELY DOCUMENTED ON THIS INFORMATIONAL WEBSITE, THE WHITELAW-TWINING PARTNER HAS FILED TWO (2) SLAPPs AGAINST HIS CLIENT'S NAMED INSURED, THUS AIDING AND ABETTING HIS CLIENT AND ITS ROGUE PERSONNEL, IN THEIR ATTEMPTS TO CONCEAL THEIR VARIOUS UNLAWFUL ACTIVITIES. AT WHITELAW-TWINING's SECOND HEARING OF ITS APPLICATION TO TEMPORARILY DEACTIVATE THIS WEBSITE, MADAME JUSTICE LAURIE CHIDED WHITELAW-TWINING's LAWYER, FOR HIS DEVIOUS SHORT-TIME HEARING ESTIMATE OF 1.5 HOURS, WHEN HE FINALLY ADMITTED THAT HE NEEDED AN ENTIRE DAY OF THE COURT'S TIME.

AT THE THIRD HEARING, THE COURT WILL BE ALERTED TO THE FACT THAT THE RELIEF THAT WHITELAW-TWINING SEEKS (THE DEACTIVATION OF THIS WEBSITE), HAD BEEN OFFERED AND REJECTED ON SEVERAL OCCASIONS, PRIOR TO THE FILINGS OF ITS SLAPPs, AS WELL AS THEREAFTER.

IN THE LIKELY EVENT THAT THE WHITELAW-TWINING PARTNER SHOULD IGNORE HIS SLAPP DEFENDANT's OFFER TO DEACTIVATE THE WEBSITE REGARDING INTACT, AT THE BEGINNING OF THE ENTIRE ONE DAY HEARING THAT THE COURT HAS SCHEDULED FOR WHITELAW-TWINING's APPLICATION, THE SLAPP DEFENDANT WILL ALERT THE COURT TO THE FACT THAT AN ENTIRE DAY OF ITS PRECIOUS TIME AND RESOURCES HAS BEEN SACRIFICED BY WHITELAW-TWINING's ABUSE OF THE JUDICIAL SYSTEM, IN A COVER-UP OF THE RESULTS OF ITS CLIENT's PRIVACY OFFICER'S INTERNAL AFFAIRS PROBE, THAT UNCOVERED THAT CLAIMS MANAGER AMANDA MYERS HAD ENGAGED IN THE ILLEGAL CLAIMS ACTIVITIES, AS DETAILED AND DOCUMENTED ON THIS WEBSITE.

WHITELAW-TWINING's LEARNED PARTNER - MALICIOUS OR MERELY TEMPORARILY CONFUSED?

According to its official website, Whitelaw-Twining, is a self-proclaimed "Best Lawyer®" Canadian law firm of 134 lawyers, among whom is Nigel Beckmann, Esq, the head of the Insurance Law and Defamation departments. With all due respect to Attorney Beckmann, how can he begin to justify his filing of two (2) SLAPPs against a statutory Named Insured of his Client INTACT Insurance, falsely and defamatorily accusing the statutory Named Insured of posing as an insured of INTACT Insurance, and thereby "deceiving any potential reader of the Post about [RB's] status and relationship with [INTACT]." It simply is not at all credible that such a self-proclaimed expert of insurance and defamation law could so conveniently conflate the legal significance between a statutory Named Insured [per Strata Property Act § 155(b), which was incorporated into the recent Decision of the Honourable Justice Coval of the BC Supreme Court, case of Strata Plan VR 2213 v. Schappert, 2023 B.C.J. No. 2272, 2023 BCSC 2080], with a contractual Named Insured, such as Strata LMS 2845, insured under INTACT Strata policy #CMW M1756. In an effort to accommodate Attorney Beckmann's legal conflations, the SLAPP Defendant had a meeting with him in Whitelaw-Twining's conference room. In an exercise of extreme deference, the Defendant explained to Mr. Beckmann that although it is arguable that the Defendant was not entitled to first party coverage, as a resident of the insured LMS 2845 Strata Property, Unit 1702, his claim, nonetheless, was obviously a third party claim for the abatement of the toxic pigeon faecal matter spore proliferation, emanating from a strata common area (which SLAPP Plaintiff lawyer Christa Rae Cordick falsely represented, in oral argument and pleadings, to Judges of the BC Provincial Court, that it was the responsibility of the SLAPP Defendant resident, NOT the Strata Corporation, to abate hazardous conditions. Combat-ready Attorney Cordick, who is approaching retirement age, is far too expert and experienced to believe her misrepresentations to the Court, that strata corporations are not responsible for the abatement of hazardous conditions upon their common, or otherwise inaccessible property!

[Note: The fraudulent, collusive acts of Claims Manager Amanda Myers, declaring that the inaccessible pigeon roost was part of the insured unit's premises, and that language exclusionary to coverage had been triggered, is yet another link of the concatenation of fraud and deceit that INTACT and its rogue employé(e)s and lawyers have perpetrated upon the SLAPP Defendant and the BC judicial system!] The only question that lingers is whether Attorney Beckmann, who yet refuses to withdraw the defamatory accusation of his letter of 07 December 2023, is: (1) Sincere in his arrantly discredited accusation that the SLAPP Defendant is not a Named Insured, or (2) Is intentionally compounding his Clients egregious bad faith conduct, in exchange for the tens of thousands of dollars of INTACT's shareholders' funds, in the fees that are showered upon Whitelaw-Twining.

17 June 2025 WHITELAW-TWINING displays on its official website the image to the right.

As detailed on this informational website, Whitelaw-Twining has compiled non-privileged personal information about the SLAPP Defendant, access to which he has sought, with five (5) formal Freedom of Information Requests, per the Freedom of Information and Protection of Privacy Act.

Privacy Officer Ryan Darby has ignored all five (5) Freedom of Information requests, and refuses to accept telephone calls, as well.

Whitelaw-Twining's unctuous statements of "lawful management of confidential information", "conflict of interest avoidance", "dispute resolution experts", "defamation expertise", "insurance law expertise", etc. may theoretically be rendered to select clients, but in the case subject of this informational website, the ethical void persists.

Perhaps the firm refers to an expertise in the resolution of legal entanglements that they create?

18 June 2025

RECOMMENDATION:

As to possible retention of any of WHITELAW-TWINING's 134 133 132 lawyers, including the featured guest Nigel Beckmann, Esq and/or Ryan Darby, Esq, any prospective client might first consider that Whitelaw-Twining's below Privacy Officer's "commitment" to protection of confidential, personal information, which it receives, has been substantially violated on several occasions, as documented on this informational website. Furthermore, the mere fact that a Partner has exposed his corporate Client to ethical, legal and regulatory entanglements, as documented herein, is not intended to signify, nor should such be interpreted as a reflexion of the Partner's expertise or customary integrity. Although this informational website is actually or constructively known by Whitelaw-Twining's lawyers and personnel, none of whom has come forward to suggest or participate in an extrajudicial resolution of Whitelaw-Twining's legal dilemma, such is not intended to suggest any bad faith motivation or intention, on the part of any.

19 June 2025 INTACT's SLAPP Defendant RB, in his relentless efforts to conserve the Court's precious time and resources, per Rule of Court 1-3, rendered an offer to Whitelaw-Twining's Partner, which could lead to the deactivation of this informational website, on the condition that Whitelaw-Twining's Client INTACT, simply conduct a standard, good faith claims investigation, to replace the falsified, fraudulent claims practice with RB's claim.

Although not broached, woefully conflicted-of-interest Whitelaw-Twining Partner Beckmann's deceitful, defamatory, false allegation that RB was not an insured of INTACT, and had submitted his claim under false pretences, has always been an impediment to an extrajudicial resolution, albeit a cash-cow windfall from a deep pocketed Client. Beckmann's "responsive" email (to the left), is an unambiguous affirmation of his lucrative decision to continue to place Whitelaw-Twinging's legal and pecuniary interests above those of its Client. RB looks forward to an apparently necessary judicial resolution, but respectfully requests of Attorney Beckmann that he cease wasting RB's time, just to accumulate Whitelaw-Twining's billable hours!

12 June 2025 The WHITELAW-TWINING Partner remains remarkably intransigent in his refusal to retract his defamatory, false charge against his Client's Named Insured, "RB", a serious tort that underlies the complex legal entanglements in which Attorney Beckmann has embroiled his Clients. The Statute of Limitations for litigation against Attorney Beckmann and WHITELAW-TWINING would run on 06 December 2025. Thus, in the absence of a conciliatory retraction, "RB" is left with no alternative to litigation.

Just one of many examples of Whitelaw-Twining's brazen violations of good faith conduct toward its Client's Named Insured, Partner Nigel Beckmann filed the above legal pleading in his malicious SLAPP. Abundant documentary evidence on this website attests to the fact that in addition to the perjured Affidavits that Whitelaw-Twining Client, the fraudulent Claims Manager Amanda Myers filed, (1) her own letter of 30 September 2021 confirmed Defendant "RB" status as a Named Insured, and (2) according to the internal affairs probe of INTACT Privacy Officer Helen Cameron. In a woefully misguided lapse of moral clarity, Claims Manager Myers went on to become a lead Plaintiff in the malicious SLAPP against INTACT's Named Insured, and filed perjured Affidavits for INTACT's Application to curtail Defendant's right to expose the Intentional Infliction of Emotional Distress to which INTACT has subjected him.

As abundantly documented on this informational website, Whitelaw-Twining's Nigel Beckmann is the architect of the Pyramid of Lies, with his scurrilous, accusation (that he widely publicised) of his Client INTACT Insurance's Named Insured, as being a third party non-Insured, and of submission of a claim with INTACT under false pretences.

SLAPP Defendant "RB" can file a Motion to Dismiss INTACT's SLAPP litigation, OR in light of the BC Supreme Court's emphasis upon Rule 1-3, and its requirement of "proportionality" a less labour-intensive, immediate remedy would be a simple Application for an Order that INTACT's counsel Nigel Beckmann withdraw his false accusation of Defendant's wrongdoing, the cornerstone of the Pyramid of Lies, upon which the entirety of INTACT's legal entanglements lie.

Since Attorney Beckmann refuses to voluntarily withdraw the above defamatory accusation, or offer even a scintilla of legitimacy or veracity of his accusation, the above Application will compel that he provide inculpatory elements of his Affidavit, in opposition to the aforementioned Application.

"Madam Justice, this SLAPP Defendant's herculean efforts to prevent Whitelaw-Twining Partner's abuse of the Court's precious time and resources have been unsuccessful, as the Plaintiff persists in his outrageous attempts to conceal the illegal acts of a Claims Manager, as discovered by Plaintiff's Privacy Officer, as detailed in Defendant's Affidavit. Although the Defendant's case before the Human Rights Tribunal has not yet been scheduled for hearing, Whitelaw-Twining's Partner's false accusations against the Defendant are expressed in the Defendant's Affidavits, which include such authority as Strata Property Act Section 155(b) (2) the landmark case of Strata Plan VR 2213 v. Schappert, 2023 B.C.J. No. 2272, 2023 BCSC 2080 (decided by the Honourable Justice Coval of the BC Supreme Court), correspondence of INTACT personnel (SLAPP Plaintiffs Amanda Myers and Christa Rae Cordick), Adam Trott investigator of the BC Ombudsman Office, Bruno de Sando investigator of the GIO, Patrick Williams of renowned law firm Clark Wilson, CHOA (Condominium Homeowners Association of BC), the BCFSA, personnel of various Scheduled Insurers of the subject INTACT property liability policy, Insurance Broker Gordon Li, Property Manager Nico Barbu, Sedgwick Insurance Sr Adjuster Daphne Chan, Heather Bidnall, Compliance Officer of the Insurance Council of BC, et al.

Moreover,

WHISTLEBLOWER # 1 - INTACT PRIVACY OFFICER HELEN CAMERON In her public announcement of 19 January 2024, INTACT's courageous and conscientious Whistleblower, Privacy Officer Helen Cameron, confirmed the results of her independent internal affairs probe, that Alberta Claims Manager Amanda Myers had fabricated and falsified the entirety of her claims "investigation"! The Privacy Officer's revelation led to the discovery that Claims Manager Myers had engaged in other illicit claims practices, as minutely detailed and documented on this informational website. As the investigation progressed, it was also discovered that INTACT *Ombuds[wo]man Michele Vincent had wrongfully interfered with an investigation of Claims Manager Myers' unlawful activities, which Ms. Vincent, herself, had assigned to INTACT's Claims Experience Team. Ombuds[wo]man Vincent's clandestine intervention culminated in her order to the Customer Experience Team to permanently cease and desist its investigation of Myers' rogue activities. In furtherance of INTACT's egregious verbotene activities, against a Named Insured, Whitelaw-Twining (a local, boutique law firm) was retained, with the Director of its Defamation Department falsely accusing the Named Insured of submission of a claim with INTACT, under false pretences (as abundantly detailed and documented on this website). Although INTACT has not yet filed a SLAPP against Privacy Officer Helen Cameron, it the company should be so reckless, then the Administrator of this informational website pledges to devote factual coverage thereof to Ms. Cameron.

*Disclaimer: "RB" has long requested that INTACT adopt the term "Ombudswoman" for the position, which is currently occupied by such. However, INTACT, with its claims of "inclusion", is still mired in the antiquated concept of male supremacy, with its occasional usage of the wimpy term "ombuds", as if giving full credit to the phenomenal accomplishments of women were somehow a gesture of compromise!

WHISTLEBLOWER # 2 - INTACT NAMED INSURED "RB"

As abundantly detailed and documented on this informational website, in a letter of 07 December 2023 to INTACT's Named Insured "RB", Whitelaw-Twining's Defamation Department Director, Nigel Beckmann levelled the false accusation (that Beckmann widely publicised), that "RB" had submitted a claim with INTACT, under false pretences. When "RB" refused to succumb to Attorney Beckmann's wrongful attempts to intimidate "RB" into withdrawal of his claim, Beckmann filed two (2) SLAPPs against "RB", and as detailed herein, Beckmann persists upon abusing the precious time and resources of the BC Supreme Court, as if the Court were an instrument of enforcement of INTACT's campaign to conceal the facts of the unlawful activities of its rogue Claims Manager Myers and Ombuds[wo]man Vincent.

INTACT INSURANCE's DILEMMA OF TWO, INDEPENDENT WHISTLEBLOWERS

11 June 2025

WHITELAW-TWINING continues its relentless exploitation of the taxpayer-funded resources of the BC judicial system, with INTACT's SLAPP litigation, to prevent exposure of the fraudulent claims practice of its Claims Manager, Amanda Myers! WHITELAW-TWINING would be ill-advised to file a companion SLAPP against "RB's" fellow Whistleblower, Privacy Officer, Helen Cameron, whose internal affairs probe uncovered that Myers had fabricated and falsified the entirety of an important claim denial. To the right is INTACT's Whistleblower, Named Insured's Application to Dismiss INTACT's SLAPP. The stages of the Application's development will be updated. As elaborately detailed on this informational website, by way of defamatory, false charges that Whitelaw-Twining's Partner alleged against a Named Insured of the firm's Client, INTACT Insurance, INTACT is now embroiled in costly, frivolous, SLAPP litigation. Noteworthy is it that no one from WHITELAW-TWINING has come forth with a retraction of the Partner's defamatory, false accusations, which would represent a major de-escalatory measure. Could it be that at WHITELAW-TWINING, dignity has come to be an obsolete commodity?

07 June 2025

INTACT INSURANCE has squandered tens of thousands of dollars, having engaged four (4) hyper- zealous lawyers, such as Nigel Beckmann, who alleged untrue statements in an investigative report to the company. INTACT continues its aggressive campaign, to avoid the consequences of its human rights abuses, as detailed on this informational website.

There is currently pending in the BC Human Rights Tribunal, a Complaint against INTACT, for its abuses of the human rights of the whistleblower Defendant of INTACT's two (2) SLAPPs.

At the Human Rights Tribunal hearing, testimony will be elicited from fellow whistleblower INTACT PRIVACY OFFICER Helen Cameron, whose internal affairs probe exposed INTACT Claims Manager Amanda Myers' falsification of the entirety of her claims "investigation", as well as others of her illicit claims activities.

INTACT Public Entities (a subsidiary of Intact Insurance) has been faced with the dilemma of a significant increase in discrimination claims being filed against INTACT, such as the case of Shahin v. Intact Insurance Company (2024 ONSC 2059). General damages awarded by Human Rights Tribunals in Canada for injury to dignity, feelings, and self-respect, are on the increase, due to such egregious abuses, as minutely detailed on this informational website.

FORMAL LEGAL NOTICE OF INTENT AND PURPOSE*

*This website has been created and maintained by "RB", a Canadian retired, locally renowned carpet installer, and a Named Insured of INTACT Insurance.

The intent and purpose of this website is to respectfully render a plea to Whitelaw-Twining Partner, Nigel Beckmann, to withdraw his letter (to the right), wherein Mr. Beckmann falsely and defamatorily accused "RB" of not being an insured of INTACT Insurance, and thereby "deceiving any potential reader of the Post about [RB's] status and relationship with [INTACT]." Mr. Beckmann's untrue accusation, numerous legal, regulatory and eventual SLAPP litigation against "RB" ensured. , In aggravation, Mr. Beckmann's untrue letter came to suppress the results of an internal affairs probe, conducted by Privacy Officer Helen Cameron, who uncovered that Claims Manager Amanda Myers had fabricated and falsified an investigation of a property claim that "RB" had submitted, as well as others of Myers' illicit claims practices.

The overwhelming bases, in support of "RB's" respectful request of Attorney Beckmann, includes Strata Property Act § 155(b), which was incorporated into the recent Decision of the Honourable Justice Coval of the BC Supreme Court, in the landmark case of Strata Plan VR 2213 v. Schappert, 2023 B.C.J. No. 2272, 2023 BCSC 2080. Moreover, as detailed on this website, there are almost 40 independant witnesses to the fact that "RB" was a Named Insured, in contradiction of Attorney Beckmann's lone position, as expressed in the letter to the right!

Another element of this website are the two (2) oppressive, Strategic Lawsuits Against Public Participation SLAPP) actions that Whitelaw-Twining Partner Nigel Beckmann filed against Named Insured "RB".

British Columbia has protective anti-SLAPP legislation, entitled the Protection of Public Participation Act [PPPA], Section 4 of which encourages courts to cleanse the judicial system of such abusive litigation, upon a Defendant's Application for a Dismissal Order. Unable to find a lawyer who will represent "RB" for less than $20,000, he intends to file for such a Dismissal Order, as as he has sufficiently researched such a "DIY" project.

SLAPP actions, such as Whitelaw-Twining Partner Beckmann's, are universally disfavoured by Legislatures and the Courts. Indeed, the Supreme Court of Canada released its latest decision interpreting anti-SLAPP legislation in Canada. A 6-1 majority of the Court in Hansman v Neufeld, 2023 SCC 14, restored an order dismissing a plaintiff’s claim under British Columbia’s anti-SLAPP legislation.

The Supreme Court of Canada’s decision centered upon the balancing of the public interest in protecting the defendant’s impugned expression against the plaintiff’s right to protect their reputation. The Court had specific reference to Charter jurisprudence under ss. 2(b) and 15(1) in determining the level of protection that should be afforded to certain expressions. In particular, where the impugned expression is “counter-speech” intended to respond to ignorant or harmful expressions against a vulnerable group, that may weigh more heavily in the balancing exercise in favour of protecting that speech.

CONCLUSION

This website, documenting the facts of WHITELAW-TWINING's oppressive litigation against "RB's" right to freedom of expression to communicate with INTACT's managerial personnel, in a factual, albeit critical manner, does not constitute defamation!

Above image of Attorney Beckmann's letter, falsely accusing "RB" of not being an insured of INTACT.

02 June 2025

The British Columbia Supreme Court Civil Rules, such as Rule 9-1, include provisions designed to encourage litigants to seek extrajudicial remedies prior to filing formal Motions and Applications. These rules emphasise proportionality, early resolution, and case management, in order to ensure that disputes be resolved in a just, speedy, and inexpensive manner.

In violation of the proportionality of Rule of Court 1-3/Rule 9.1, INTACT's lawyer, Whitelaw-Twining Partner, Nigel Beckmann, in an email of 30 May 2025, rejected Defendant's offer to obviate the necessity of INTACT's Application for an Interlocutory Order, by offering to surrender absolute, unrestricted control of this website to the Plaintiffs, in order to enable them to remove, in their sole discretion, all content from this website that they should deem, even in bad faith, "defamatory".

Attorney Beckmann confirmed his position that every statement of this website is defamatory, including statutory authority [STRATA PROPERTY ACT § 155(b), judicial authority [THE RULING OF THE HONOURABLE JUDGE COVAL OF THE BC SUPREME COURT], regulatory authority [SECTION 80.3(1) OF THE FINANCIAL INSTITUTIONS ACT] and the documented results of INTACT PRIVACY OFFICER Helen Cameron's internal affairs probe, which uncovered that INTACT Claims Manager Amanda Myers had falsified the entirety of her alleged "claims investigation", which precipitated violations of the [PERSONAL INFORMATION PROTECTION ACT (PIPA)], S.B.C. 2003, c. 63.

Although INTACT has legions of combat ready legal professional warriors at its costly command, it remains eternally conflicted with the truth and facts, as it mercilessly exploits the precious resources of the Supreme Court, as an instrument of its malicious SLAPP litigation!

IF FREE SPEECH RIGHTS ARE TO PREVAIL, AS METICULOUSLY DOCUMENTED ON THIS WEBSITE, INTACT INSURANCE's NAMED INSURED, THE IN PRO SE DEFENDANT OF ITS TWO (2) SLAPP ACTIONS MUST SUCCESSFULLY EXPOSE THE FACT THAT HIS OPPONENT, "SLAPP PROSECUTOR", NIGEL BECKMANN (PARTNER OF LAW FIRM WHITELAW-TWINING), HAS RESORTED TO THE FILING OF DEMONSTRABLY FALSE PLEADINGS, AS WELL AS PERJURED AFFIDAVITS.

IN VIEW OF INTACT's ABUSIVE OF PROCESS MANIPULATION OF THE JUDICIAL SYSTEM, AS A VEXATIOUS TOOL TO HARASS THE NAMED INSURED DEFENDANT, AND INFLICT UPON HIM EMOTIONAL DISTRESS, THE SITUATION WARRANTS AN APPLICATION ON DEFENDANT's PART, TO DISMISS WHITELAW-TWINING's MALICIOUS SLAPPs.

ALTHOUGH THE NAMED INSURED DEFENDANT HAS ENDEAVOURED TO LIMIT THE SCOPE OF PROPAGATION OF THIS WEBSITE, WHITELAW-TWINING's INTENTIONAL INFLICTION OF EMOTION DISTRESS UPON HIM NECESSITATES THAT HE SLIGHTLY EXPAND THIS WEBSITE's PARAMETRES, IN ORDER TO ATTRACT THE INTEREST OF A PRO BONO LAWYER, OR IF SHE SHOULD BE UNAVAILABLE, AT LEAST ONE WHO WOULD AGREE TO A SLAPP DEFENCE, FOR LESS THAN $20,000.

THUS, DEFENDANT IS ON TO AN EXTENSIVE EFFORT TO LOCATE A PRO BONO LAWYER, OR A SOCIAL INFLUENCER, ANTIPATHETIC TO WHITELAW-TWINING's RELENTLESS CRUSADE AGAINST FREE SPEECH AND FUNDAMENTAL HUMAN RIGHTS.

THE OFFICE OF THE BC ATTORNEY GENERAL IS CURRENTLY RECONSIDERING INTERVENTION IN THE INTACT SLAPPs SINCE, UNLIKE COMMON SLAPPs, INTACT's SLAPPs CONTAIN THE DUPLICITOUS ELEMENT OF WHITELAW-TWINING ATTORNEY's FABRICATION OF THE PREMISE UPON WHICH INTACT's SLAPPs ARE PREDICATED - THAT INTACT's NAMED INSURED HAD SUBMITTED AN INSURANCE CLAIM UNDER THE FALSE PRETENCE OF BEING A NAMED INSURED OF INTACT.

STATEMENT OF INTENT AND PURPOSE OF THIS METICULOUSLY DETAILED AND DOCUMENTED DAY-IN-THE-LIFE, FACTUAL PRESENTATION

FACING THE LEGAL "DILEMMA" OF THE LACK OF PRETEXT TO COMMENCE SLAPP LITIGATION AGAINST A NAMED INSURED OF HIS CLIENT, INTACT INSURANCE, "BOUTIQUE" LAW FIRM WHITELAW-TWINING's PARTNER, NIGEL BECKMANN, RENDERED THE FALSE CHARGE OF "SUBMISSION OF AN INSURANCE CLAIM, UNDER THE FALSE PRETENCE OF BEING A NAMED INSURED", AGAINST AN ACTUAL NAMED INSURED OF THE COMPANY.

CURRENTLY, DESPITE MONTHS OF WHITELAW-TWINING's INFLICTION OF EMOTIONAL DISTRESS, WANTONLY ABUSING THE PRECIOUS RESOURCES OF THE BC SUPREME COURT, ATTORNEY BECKMANN REFUSES TO RETRACT HIS MALICIOUS DISTORTION OF THE TRUTH!

The purpose of this public interest website, is the presentation of the illicit claims and administrative acts and omissions of INTACT Insurance and a select few of its rogue (among the vast majority of honest, competent and well-intentioned) personnel.

AS EXPOSED BY AN INTERNAL AFFAIRS PROBE, CONDUCTED BY INTACT INSURANCE PRIVACY OFFICER HELEN CAMERON, IN 2021 INTACT CLAIMS MANAGER AMANDA MYERS HAD FABRICATED HER INVESTIGATION, IN ADDITION TO OTHER FRAUDULENT ACTS, REGARDING A CLAIM SUBMITTED BY A NAMED INSURED OF INTACT. THE NAMED INSURED IMMEDIATELY FILED A FORMAL COMPLAINT AGAINST THE ERRANT CLAIMS MANAGER WITH INTACT's OMBUDS[WO]MAN, MICHELE VINCENT, IN ACCORDANCE WITH SECTION 80.3(1) OF THE FINANCIAL INSTITUTIONS ACT.

HOWEVER, INSTEAD OF INVESTIGATION OF THE CLAIMS MANAGER's DOCUMENTED FRAUD, INTACT ENGAGED NIGEL BECKMANN (PARTNER OF THE ERSTWHILE BOUTIQUE LAW FIRM WHITELAW-TWINING), WHO SERVED A LETTER UPON THE NAMED INSURED, THREATENING TO SUE THE NAMED INSURED FOR THE FACTUAL, DOCUMENTED INFORMATION AND DOCUMENTATION DISPLAYED ON THIS WEBSITE. WHEN THE NAMED INSURED REFUSED TO SUCCUMB TO MR. BECKMANN's DEMANDS, MR. BECKMANN FILED TWO (2) SLAPPs AGAINST THE NAMED INSURED.

ALTHOUGH THE INFORMATION AND DOCUMENTATION ON THIS WEBSITE IS UNAVOIDABLY CRITICAL OF THE ACTS AND OMISSIONS OF WHITELAW-TWINING's PARTNER, ALL STATEMENTS ARE FULLY SUPPORTED BY THE METICULOUS DOCUMENTATION OF THE FACTS.

The factual, statutory, judicial and regulatory authority in conflict with the Whitelaw-Twining Partner's assertion include:

Strata Property Act Section 155(b) (2) the landmark case of Strata Plan VR 2213 v. Schappert, 2023 B.C.J. No. 2272, 2023 BCSC 2080 (decided by the Honourable Justice Coval of the BC Supreme Court), correspondence of INTACT personnel (SLAPP Plaintiffs Amanda Myers and Christa Rae Cordick), Adam Trott investigator of the BC Ombudsman Office, Bruno de Sando investigator of the GIO, Patrick Williams of renowned law firm Clark Wilson, CHOA (Condominium Homeowners Association of BC), the BCFSA, personnel of various Scheduled Insurers of the subject INTACT property liability policy, Insurance Broker Gordon Li, Property Manager Nico Barbu, Sedgwick Insurance Sr Adjuster Daphne Chan, Heather Bidnall, Compliance Officer of the Insurance Council of BC, et al.

In a futile attempt to justify his two (2) SLAPPs against the Defendant, the Whitelaw-Twining Partner is the only person (not even his own Clients) who asserts the Defendant as not being a Named Insured of INTACT. Moreover, no other lawyer from Whitelaw-Twining has come forward to support the Partner's contrary-to-fact allegation.

Per Court filings and other misrepresentations, Whitelaw-Twining Partner has propagated the arrant falsehood that the Defendant had forfeited his Named Insured INTACT insurance coverage by occupying and using an area which is, in fact, a physically inaccessible, contaminated, narrow, cemented ornamental pigeon roost, which required a 3-person specialty crew to remediate. (see images to the left). Those percipient witnesses of Whitelaw-Twining's material false Affidavits and other fabricated accusations include:

Dr. Leo Perra, LMS 2845 Strata President, Alexandre Korecki Property Management Owner, Nico Barbu Property Manager, Scott Chen Unit 1702 Owner, Michael Bromm lawyer of Unit owner, Humane Solutions Remediation Specialist, Mike Blackall, Property Manager, Ray Nouri LMS2845 Building Superintendent.

As fully documented on this whistleblower's website, Whitelaw-Twining Partner's false filings and perjured Affidavits are only some of the malicious falsehoods that he has perpetrated upon regulatory agencies and the Supreme Court.

With its aggressive SLAPP prosecutions, replete with perjured Affidavits, Whitelaw-Twining refuses to withdraw its Partner's malicious accusation that Defendant had misrepresented himself as a Named Insured of INTACT, and that he had filed an insurance claim under the false pretence of being such.

A Partner of British-based DWF Group Whitelaw-Twining has wrongfully filed two (2) SLAPPs against a Named Insured of the firm's Client, INTACT Insurance, falsely accusing the Named Insured of submission of a claim with INTACT, under the false pretence of being an Insured.

The same Whitelaw-Twining Partner has also concealed, and continues to conceal, the investigative findings of INTACT Privacy Officer Helen Cameron, a whistleblower Privacy Officer, who conducted her own, independent internal affairs probe, which exposed that INTACT Alberta Claims Manager Amanda Myers, had fraudulently fabricated one of Myers' claims investigations, had fraudulently denied the Named Insured's claim, and committed other serious, unlawful claims practices.

Query: Has there been any violation of the following Ethical Rules of the Law Society of British Columbia?

• Rule 2.1-2 (Integrity): Lawyers must act with integrity and not engage in dishonest or misleading conduct.

• Rule 3.2-7 (Encouraging Respect for the Administration of Justice): Lawyers must not abuse legal procedures or bring proceedings that are clearly unfounded.

• Rule 3.2-9 (Threatening Criminal or Regulatory Proceedings): Lawyers cannot use legal threats to gain an improper advantage.

• Rule 5.1 (Advocacy): Lawyers must ensure that their advocacy is fair, honest, and does not mislead the court.

Whistleblower Helen Cameron, a dedicated and highly skilled professional, whose exceptional abilities, leadership, and integrity set her apart. Helen's extensive academic background, having earned both a Bachelor’s degree from Algonquin College of Applied Arts and Technology and a Bachelor of Arts from Carleton University, serves as a strong foundation for her remarkable expertise.

As INTACT’s Privacy Officer, Helen has consistently demonstrated her commitment to ethical practices and transparency. Her role demanded keen analytical skills and unwavering integrity—qualities that she exemplified when she took the initiative to conduct an internal affairs investigation into illicit activity within the company. Through her thorough and meticulous probe, Helen successfully uncovered fraudulent misconduct by Claims Manager Amanda Myers, who had fabricated a critical claims investigation. Helen's ability to detect and expose such a significant violation not only safeguarded the company’s credibility but also reinforced the importance of accountability within the organization.

Helen’s leadership extends beyond compliance and investigative responsibilities. Her approach to work is defined by efficiency, creativity, and eloquence, consistently delivering high-quality results and innovative solutions. A fast learner with a keen ability to adapt, Helen excels both in collaborative team environments and in independent roles.

Helen’s professional portfolio includes invaluable contributions to education and mentorship. She has tutored English as a Second Language (ESL) learners and provided active coaching and training to both seasoned professionals and new hires. Her dedication to professional integrity has enabled her to work seamlessly across various departments and offices, strengthening internal structures and fostering organizational growth.

In addition to her leadership and mentoring capabilities, Helen has successfully managed departmental integrations, led networking and compliance projects, and developed essential training tools and workflows from inception. Her ability to handle complex and highly regulated information has been instrumental in refining communication strategies—creating and managing internal and external communication templates, editing formal position letters, and transforming technical material into accessible consumer-facing content.

Helen’s passion for communication extends beyond her professional endeavours; she is an avid reader and writer, constantly refining her skills to develop meaningful and effective messaging. Her experience as a Communication Trainee at the Galerie d’art d’Ottawa further highlights her commitment to excellence in the field. Moreover, her multilingual capabilities—fluent in both French and Japanese (she has mastered the Japanese syllabaries katakana and hiragana, and is currently learning kanji)—demonstrate her adaptability and cultural awareness, valuable assets in today’s interconnected world.

In summary, as the epitome of INTACT CEO Brindamour's "Living Our Values" initiatives, Helen Cameron is well on her way to even higher executive positions at INTACT, or beyond!

As minutely detailed on this strictly factual, informational website, a Partner of British-based DWF Group Whitelaw-Twining has violated Section 80.3(1) of the Financial Institutions Act, by tortiously causing the injury of Intentional Infliction of Emotional Distress to a Named Insured of the firm's Client INTACT Insurance, by aiding and abetting Ombuds[wo]man Michele Vincent, who ordered the Claims Experience Team to cease and desist its investigation of Claims Manager Amanda Myers' documented fabrication of a claims investigation, and other unlawful acts.

WHITELAW-TWINING PARTNER FALSELY ACCUSED A NAMED INSURED OF HIS CLIENT INTACT OF SUBMISSION OF A CLAIM UNDER FALSE PRETENCES, AND THEN ABUSED THE JUDICIAL SYSTEM, BY MALICIOUSLY FILING TWO (2) SLAPPs FOR DEFAMATION, AGAINST THE NAMED INSURED.

Renowned legal scholar, strata law expert, and longstanding counsel for the Condominium Homeowners Association (CHOA), Patrick Williams of the premier law firm, Clark Wilson (the #1 Top Western Law Firm for 2024/25), conducted a legal analysis of the law and facts. His conclusion, which is based upon Strata Property Act § 155(b), was that the Defendant, subject of this informational website, has been a bona fide Named Insured.

How comes it that Clark Wilson's strata law expert, in addition to some other thirty three (33) experts and percipient witnesses, infra, all stand in opposition to the Whitelaw-Twining Partner's lone position that the Defendant is not a Named Insured of INTACT; that he submitted his claim under false pretences, and defamed INTACT?

*source- Whitelaw-Twining Partner, Nigel Beckmann's, herein defamatory letter of 07 December 2023

Strata Property Law (Phase Two) Project Committee The Strata Property Law (Phase Two) Project Committee was formed in fall 2013. This volunteer project committee is made up of leading experts in strata-property law and practice in British Columbia. The committee’s mandate is to assist BCLI in developing recommendations to reform strata-property law in the seven areas selected for study in this phase.

The committee unanimously concluded that Strata Property Act § 155 is protective of the legitimate interests of persons, such as the Defendant, herein, who normally occupy strata units. This conclusion was cited by the Honourable Justice Coval of the BC Supreme Court, in the landmark case of Strata Plan VR 2213 v. Schappert, 2023 B.C.J. No. 2272, 2023 BCSC 2080.

Yet, the Whitelaw-Twining Partner continues to refuse to abandon his absolutely discredited, solitary perversion of law that the Named Insured Defendant had defamed his Client INTACT Insurance, by citing the protections of Strata Property Act § 155 and the case law. Of particular legal significance is the fact that Whitelaw-Twining persists in its abuse of judicial processes of the BC Supreme Court, by their perverse SLAPP prosecutions, replete with thousands of pages of Application fodder.

Vancouver-based Whitelaw Twining claims to be a "rare law firm that is part of a publicly traded company, thanks to London, England-based DWF Group (LON:DWF) making the firm the only Canadian law firm that is part of a public company". Felicitations to British consumers!! However, back in Canada, as fully documented on this whistleblower's website, a DWF Whitelaw-Twining Partner has demonstrated the firm's expertise in "injury", with his intentional and negligent infliction of emotional distress.

Although it is believed and expected, that of Whitelaw-Twining's multitude of combat ready lawyers and personnel, some would oppose the firm's relentless abuse of the judicial processes of the BC Supreme Court, with its malicious SLAPP actions. Thus far, none has emerged.

As thoroughly documented on this informational, whistleblower's website, in addition to other tortious acts and omissions, a Partner of Whitelaw-Twining wrongfully orchestrated Client INTACT Insurance's violation of Statutory Condition 5 (Termination of Insurance), Section 16.1 of the Insurance Act of BC and the Code of Consumer Rights and Responsibilities. Query: Has there been any violation of the following Ethical Rules of the Law Society of British Columbia?

• Rule 2.1-2 (Integrity): Lawyers must act with integrity and not engage in dishonest or misleading conduct.

• Rule 3.2-7 (Encouraging Respect for the Administration of Justice): Lawyers must not abuse legal procedures or bring proceedings that are clearly unfounded.

• Rule 3.2-9 (Threatening Criminal or Regulatory Proceedings): Lawyers cannot use legal threats to gain an improper advantage.

• Rule 5.1 (Advocacy): Lawyers must ensure that their advocacy is fair, honest, and does not mislead the court.

The Whitelaw-Twining Partner, (head of the firm's Defamation and Insurance Law Department), continues to abuse the resources of the BC Supreme Court, with his frivolous SLAPP, refusing to cede to the following statutory, judicial and evidentiary authority, that the malicious accusation of his letter of 07 December 2023 (to the right) has been absolutely discredited.

The Whitelaw-Twining Partner is acutely aware that the Defendant's legal status as INTACT Named Insured, had been established by (1) Strata Property Act Section 155(b) (2) the landmark case of Strata Plan VR 2213 v. Schappert, 2023 B.C.J. No. 2272, 2023 BCSC 2080 (decided by the Honourable Justice Coval of the BC Supreme Court) (3-4) correspondence of INTACT personnel (SLAPP Plaintiffs Amanda Myers and Christa Rae Cordick) (5) Adam Trott, investigator of the BC Ombudsman Office (6) Bruno de Sando investigator of the GIO (7) Patrick Williams of renowned law firm Clark Wilson (8) CHOA (Condominium Homeowners Association of BC) (9) BCFSA (10-11) personnel of various Scheduled Insurers of the subject INTACT property liability policy (12) Insurance Broker Gordon Li (13) Property Manager Nico Barbu (14) Sedgwick Insurance Sr Adjuster Daphne Chan (15) Heather Bidnall, Compliance Officer of the Insurance Council of BC, et al.

PARTICULARLY, DURING THESE TIMES OF TARIFFS AND INTERNATIONAL CONFLICT, INTACT CEO, MONSIEUR CHARLES BRINDAMOUR, CONTINUES TO ALLOW THE COSTLY FUNDING OF THE WHITELAW-TWINING PARTNER'S DESECRATION OF INTACT's INTERNATIONAL REPUTATION 查看intactfinancial的更多内容

Although Ombuds[wo]man Michele Vincent committed perjury in her Affidavit, infra, in the letter to the left, she had accepted the Named Insured Defendant's formal Complaint of Claims Manager Myers' fraud, and had assigned the Complaint to INTACT's Customer Experience Team investigators, who were to issue a "Final Business Decision" letter. After almost two (2) years and tens of thousands of dollars in Whitelaw-Twining's fees, such a letter has not been issued!

DESPITE THE SQUANDER OF TENS OF THOUSANDS OF DOLLARS IN SLAPP PROSECUTORIAL "LEGAL" FEES, THOUSANDS OF PAGES OF LEGAL PLEADINGS, THOUSANDS OF HOURS OF INTACT PERSONNEL'S TIME AND RESOURCES, A PROJECTED TWO (2) WEEKS OF THE RESOURCES OF THE BC SUPREME COURT, INTACT'S LAWYER AT WHITELAW-TWINING REFUSES TO WITHDRAW HIS HEREIN DETAILED, MALICIOUS AND DEFAMATORY LETTER OF 07 DECEMBER 2023, THE GENESIS OF THE ENTIRE PERFECT LITIGATION STORM OF INTACT'S FALSIFICATIONS, PERJURED AFFIDAVITS AND DECAY OF INTACT'S LEGAL AND MORAL IMAGE.

WHERE IS THE CEO, CONSUMMATE ACTUARIAL, CHARLES BRINDAMOUR?

NOTICE: This fact-based informational website is replete with documentation of statements and representations, as rendered herein. The viewer is invited to familiarise herself/himself with the documented facts, prior to the formation of any opinion.

INTACT's LAWYER HAS SUBMITTED PERJURED AFFIDAVITS, WITH AN APPLICATION FOR AN INTERLOCUTORY ORDER TO (TEMPORARILY) DEACTIVATE THIS WEBSITE, IN A SCHEME TO CONCEAL THE ILLICIT LEGAL PRACTICES, AS EXPOSED ON THE INFORMATIONAL, PUBLIC INTEREST WEBSITE. OTHER PERJURED AFFIDAVITS WILL BE DISPLAYED IN THE FUTURE

Claims Manager Myers' letter of 30 September 2021, per her Affidavit Myers' perjured Affidavit

Whitelaw-Twining is a member of the DWF Group, headquartered in Manchester, England.

Claims Manager Myers' illegal claims practices are not limited to perjured Affidavits. On Page 2 of her Affidavit (image to the left) she committed claims management fraud, by falsely testifying that the Claimant had nullified his insurance coverage, for "personal use" of a balcony, that is factually an exterior, inaccessible pigeon roost (below). INTACT Privacy Officer Helen Cameron conducted an independent internal affairs probe, which confirmed that Claims Manager Myers had fabricated and falsified her claims "investigation".

24 MARCH 2025

DESPITE DEFENDANT'S REPEATED CONCESSIONAL OFFERS TO PLAINTIFFS, IN THE SPIRIT OF RULE OF COURT 1-3, INTACT's INTRANSIGENT REJECTION OF ALL OFFERS WILL BE THE SUBJECT OF THE SCHEDULED COURT HEARING.

BELOW IS THE ACTUAL OFFER MADE BY DEFENDANT, AS FILED ON 18 MARCH 2025, WHICH IS EVEN MORE CONCILIATORY THAN SEVERAL PRIOR OFFERS. ALL OF THESE CONTRACTUAL, STATUTORY, REGULATORY AND JUDICIAL ENTANGLEMENTS, MERELY BECAUSE INTACT REFUSES TO CONDUCT A SIMPLE, STANDARD CLAIMS INVESTIGATION, TO REPLACE CLAIMS MANAGER AMANDA MYERS' FRAUDULENT, FALSIFIED SHAM!

27 MARCH 2025

As evidenced by the scrupulously detailed, public interest, informational website, Plaintiff, Claims Manager Amanda Myers fabricated the investigation of a claim submitted by Defendant. Myers' fabrication was exposed by INTACT Privacy Officer, Helen Cameron, in her letter of 19 January 2024.

However, in egregious bad faith, instead of merely conducting an actual, standard investigation, Myers (aided and abetted by Plaintiffs, Counsel Christa Rae Cordick and Ombuds[wo]man Michele Vincent), has refused for more than 3 1/2 years to merely conduct an actual, good faith investigation, to replace Myers' fraudulent sham. On 07 December 2023, a Whitelaw-Twining Partner, Nigel Beckmann overzealously joined the illicit cover-up, with the herein letter, defamatory of Defendant, falsely accusing Defendant of submission of a claim (that Claims Manager Myers had accepted), under the false pretence of being an insured.

Whitelaw-Twining’s indispensable involvement in this travesty of conscience and law alike, is particularly odious, in that in order to support his defamatory allegation of the Defendant’s illicit claims submission, the Partner cannot but disavow Strata Property Act Section 155(b), and the applicable ruling in case of Strata Plan VR 2213 v. Schappert, 2023 B.C.J. No. 2272, 2023 BCSC 2080, decided by the Honourable Justice Coval of the BC Supreme Court, as well as the confirmations that the Defendant was a Named Insured, per INTACT personnel Amanda Myers, Christa Rae Cordick and Michele Vincent, all of whom had all declared the Claimant's status as a Named Insured, in legal pleadings to the BCPC, the BCFSA, as well as to various Scheduled Insurers of the subject INTACT property liability policy. Defendant's legal status as a Named Insured was additionally confirmed by Insurance Broker Gordon Li, Sedgwick Sr Adjuster Daphne Chan, and Heather Bidnall, Compliance Officer of the Insurance Council of BC.

WHITELAW-TWINING's CREATIVE SOLUTIONS TO ITS SELF-CREATED, "CREATIVE CONFLICTS OF INTEREST®"

IN THE RECENT B.C. SUPREME COURT LANDMARK CASE, THE COURT ISSUED ITS RULING THAT OCCUPANTS OF INSURED PROPERTIES ARE NAMED INSUREDS, THUS SOUNDLY REJECTING THE SOLE PREMISE OF WHITELAW-TWINING's PARTNER's MALICIOUS, DEFAMATORY LETTER OF 07 DECEMBER 2023, AND THE WRONGFUL BASIS FOR ITS SUBSEQUENT, TORTIOUS SLAPP ACTIONS.

As thoroughly documented on this informational, public interest website, despite the fact that all of the Plaintiffs, as well as various insurance brokers, regulatory representatives, and others had all confirmed the Defendant's legal status as a Named Insured, the Whitelaw-Twining Partner Nigel Beckmann nonetheless filed two (2) SLAPPs (and threatens a third) against the Defendant, for allegedly defaming INTACT Insurance, by representing himself to be a Named Insured, and submitting a claim under the false pretence of so being.

In his landmark ruling, in the case of Strata Plan VR 2213 v. Schappert (2023 BCSC 2080), the distinguished, Honourable Justice Coval, soundly rejects INTACT's premise that an occupant of an insured strata property is not a Named Insured.

In the Schappert case, Justice Coval clarified that individuals who normally occupy a strata lot, such as short-term renters, tenants and owners, are Named Insureds under the strata's property insurance policy. This interpretation aligns with Section 155 of the Strata Property Act and emphasizes the importance of recognizing the rights of occupants, authorized by the strata. The decision also highlighted the necessity for clear and precise language in insurance policies to avoid ambiguities regarding insured status. A fortiori, in this case, the SLAPP defendant was a bona fide tenant of a property insured by INTACT.

Justice Coval's decision underscores the importance of adhering to legal precedents and ensuring that accusations be grounded in a thorough understanding of insurance law. It also highlights the broader implications of disputes involving insurance claims, strata corporations, and the rights of occupants. The ruling also reflects the objectives of the Strata Property Act, Section 155(b),ensuring fairness and consistency in the treatment of occupants under strata insurance policies. This contributes to a broader understanding of legal frameworks surrounding property rights, insurance, and the evolving dynamics of short-term rental arrangements.

Justice Coval's contributions extend beyond the courtroom. He has been actively involved in pro bono work, serving as vice-president of the British Columbia Access Pro Bono Society and coordinating the Court of Appeal roster program. His efforts in promoting access to justice earned him the prestigious Harry Rankin Pro Bono Award. Additionally, he has played a significant role in mentoring young lawyers and fostering a culture of pro bono service within the legal community.

Through his judicial work, mentorship, and community service, Justice Coval has left an indelible mark on the legal profession, embodying the principles of justice and fairness that define his career. His legacy serves as an inspiration to both his peers and future generations of lawyers.

PLAINTIFFS' WHITELAW-TWINING PARTNER INSISTS UPON THE WANTON SQUANDER OF THE COURT'S PRECIOUS TIME AND RESOURCES, IN HIS APPLICATION FOR AN INTERLOCUTORY ORDER TO DEACTIVATE THE ENTIRETY OF THE SUBJECT INFORMATIONAL WEBSITE. HE DISINGENUOUSLY CLAIMS THAT "EVERY WORD AND IMAGE" [INCLUDING STRATA PROPERTY ACT § 155(B), AND JUSTICE COVAL'S LANDMARK DECISION] ARE DEFAMATORY.

PLAINTIFFS' COUNSEL NEEDS TO UNDERSTAND THAT DEFAMATION DOES NOT INCLUDE FACTS, STATUTORY AND JUDICIAL AUTHORITIES, THAT INTERDICT ILLICIT ACTIVITIES.

21 MARCH 2025-

WHY DOES the WHITELAW-TWINING PARTNER CONTEND THAT THE CITATIONS OF STRATA PROPERTY ACT SECTION 155(b) AND THE CASE OF STRATA PLAN VR 2213 V. SCHAPPERT, 2023 B.C.NO. 2272, 2023 BCSC 2080, (A RECENT DECISION OF THE HONOURABLE JUSTICE COVAL OF THE BC SUPREME COURT) DEFAME CLIENT INTACT INSURANCE?

Justice Coval's ruling was essentially that even overnight Airbnb guests, a fortiori, residential tenants of insured properties, are Named Insureds, for the purpose of first or third party claims. The Strata Property Act § 155(b), which was specifically referenced in the decision, is conclusively definitive of the legal status of tenants and owners of insured premises.

In addition to the above statutory and judicial authority, INTACT personnel Amanda Myers, Christa Rae Cordick and Michele Vincent have the SLAPP defendant to be a Named Insured. Additionally, Insurance Broker Gordon Li, Sedgwick Sr Adjuster Daphne Chan, and Heather Bidnall, Compliance Officer of the Insurance Council of BC, have confirmed the Defendant's status as a Named Insured.

Hypocrisy, however blatant, is but a moral transgression, but is there not a point, where unctuous virtual signaling transcends empty slogans?

Rather than an insincere retraction of Partner Beckmann's defamatory, false accusations of the Defendant, of having falsely represented himself as an Insured of INTACT, and submission of his claim under false pretences, Whitelaw-Twining's representative continues in his intransigent campaign of intentional infliction of emtional distress!

12 MARCH 2025-

Nigel Beckmann has provided correspondence, rejecting the Offer to permanently deactivate this website, in exchange for a simple retraction of the defamatory portions of his 07 December 2023 letter. Interestingly, he claims that it was his Client, INTACT, that instructed him to write such defamation; a reversal of the common "advice of counsel" defence.

In any event, he has provided evidence that INTACT had instructed that he write such a defamatory letter, despite INTACT's own personnel's declarations that the Claimant was a bona fide Named Insured!

IN VIEW OF THE OPPRESSIVE NATURE OF WHITELAW-TWINING DIRECTOR NIGEL BECKMANN's MALICIOUS CAMPAIGN OF DEFAMATION, ABUSIVE OF PROCESS AND INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS, THE ADMINISTRATOR OF THIS FACTUAL, INFORMATIONAL, PUBLIC INTEREST WEBSITE HAS DECIDED TO FOREGO HIS FREEDOM OF EXPRESSION RIGHTS, BY HIS HEREIN OFFER OF PERMANENT DEACTIVATION HEREOF, UPON THE TIMELY RETRACTION OF THE DEFAMATORY PORTION OF THE DIRECTOR's LETTER OF 07 DECEMBER 2023; TO WIT: THE ACCUSATION OF THE ADMINISTRATOR OF NOT BEING AN INSURED OF INTACT- SUBMISSION OF AN INSURANCE CLAIM UNDER THE FALSE PRETENCE OF BEING AN INSURED.

As thoroughly documented on this informational, public interest website, Whitelaw-Twining Partner's ongoing commission of barratry has resulted in his refusal to withdraw the above defamatory allegations, in absolute contradiction of the evidentiary documentation that his own Clients, INTACT personnel Amanda Myers, Christa Rae Cordick and Michele Vincent had all defined the Claimant's legal status as a Named Insured. Additionally, Insurance Broker Gordon Li, Sedgwick Sr. Adjuster Daphne Chan, and Heather Bidnall, Compliance Officer of the Insurance Council of BC, had confirmed the Claimant's status as a Named Insured.

Do Whitelaw-Twining's "creative solutions" refer to the unrestricted procurement of its own attorneys' fees?

07 MARCH 2025-

INTACT CHIEF LEGAL OFFICER FRÉDÉRIC COTNOIR

Mr. Cotnoir is responsible for Intact's legal, compliance, internal audit and corporate secretarial functions. Over the years, he has been debriefed as to the issues, documented on this public interest website. He can no longer afford the luxury of ignoring the following legal and regulatory entanglements, which have festered under his lax watch. The list is not exhaustive:

1. INTACT Claims Manager Amanda Myers based an important coverage denial upon a false allegation that a Named Insured had triggered certain exclusionary language of a property liability policy. As a lawyer, Mr. Cotnoir would know that a property liability policy of a Strata Corporation, is jointly funded by Owners thereof. Tenants of Owners pay for such amenities by way of rental payments. Such rental income goes toward covering the Owner's costs related to the property, which includes strata fees, mortgage payments, maintenance, and insurance premiums. INTACT's specious position that the Named Insured Tenant had never funded his status is contrary to the facts and fundamentals of insurance law, and a stark measure of INTACT's and Attorney Beckmann's relentless disingenuousness!

2. When the Named Insured Claimant created this public interest website, in order to attract the serious attention of the facts of the matter, Mr. Cotnoir received actual and constructive notice that INTACT had engaged the legal services of Whitelaw-Twining Partner Nigel Beckmann, head of the firm's Insurance Law and Defamation departments. The legal, regulatory, ethical, moral entanglements that Attorney Beckmann had created, nurtured and refuses to resolve, is adequately documented on this website, and will not be further summarised.

3. INTACT's Ombuds[wo]man Michele Vincent acknowledged the Named Insured's formal Complaint against Claim Manager Amanda Myers' fabricated "claims investigation", by assignment to INTACT's Claims Experienced Team investigators. However, as part of INTACT's elaborate cover-up, Vincent later ordered the investigators to cease and desist further enquiry and release of its findings, in violation of INTACT's internal protocol, and violation of Section 80.3(1) of the Financial Institutions Act.

In his role as Chief Legal Officer, Mr. Cotnoir is ultimately responsible for INTACT's veritable perfect legal storm. Perhaps he would step in, at this point, and practice CEO Brindamour's "Living Our Values" initiative, or at least that the initiative be renamed "Denying Our Values"!

04 MARCH 2025-

INTACT's hypocritical "Living Our Values" initiative is exposed by the reality that upper managerial elements of the company, the rogue among its personnel, and its legal counsel continue to perpetrate intimidating, bad faith, unethical, criminal, defamatory and other frauds, torts and breaches of contract, on a national scale.

As abundantly documented on this public interest website, INTACT has squandered tens of thousands of dollars of stakeholders' capital, to INTACT's lawyer at Whitelaw-Twining DWF, in a fraudulent attempt to avoid conducting a standard, legitimate claims investigation, to replace the fabricated version, contrived by Strategic Team Leader Amanda Myers, documented in her hereinbelow letter of 30 September 2021.

Special recognition is warranted of the bold efforts of INTACT's Privacy Officer, Helen Cameron, whose professionalism and devotion to INTACT's public image led her to conduct her own, independent, internal affairs probe, which exposed Amanda Myers' fraud. Privacy Officer Cameron's said findings, as announced in her letter of 19 January 2024, are displayed on this website.

28 FEBRUARY 2025- DURING SEPTEMBER 2024, THE CREATOR OF THIS PUBLIC INTEREST WEBSITE ATTENDED THE HARPER GREY LLP-SPONSORED PRO BONO LEGAL "ADVICE-A-THON", WHERE HE RECEIVED GRATUITOUS LEGAL ADVICE ON HOW TO DEFEND AGAINST THE WHITELAW-TWINING DWF PARTNER's UNETHICAL AND TORTIOUS CONDUCT, AS DETAILED HEREIN.

The deep-pocketed INTACT's rogue personnel have expended herculean efforts to simply avoid the ab initio rescission of its Strategic Team Leader's fraudulent decision, ostensibly based upon a claims investigation that INTACT Privacy Officer Helen Cameron had determined had never been conducted!

In another link in the concatenation of INTACT's bad faith measures, Whitelaw-Twining Privacy Officer, Ryan Darby has ignored the below OIPC Freedom of Information request.

The below Complaint has been served and lodged with the OIPC.

21 FEBRUARY 2025 THE PLAINTIFFS' WHITELAW-TWINING LAWYER HAS MISGUIDED HIS CLIENTS INTO YET ANOTHER EGREGIOUS CONFLICT OF INTEREST, INADVISABLY SACRIFICING ALL OF HIS CLIENTS' INTERESTS, IN AN EFFORT TO AVOID PUBLIC INTEREST CRITICISM OF HIS FIRM.

In the below email from Plaintiffs' Whitelaw-Twining Partner assures that Plaintiffs Amanda Myers, Christa Rae Cordick and Michele Vincent (none of whom has ever identified a specific instance of defamation on the website) have formally rejected the Offer to remove all traces/vestiges of their identities (names, job titles and all other identifiers) therefrom. The conflict of interest has been created by the artful conflation of his Clients' interests with those of Whitelaw-Twining. He defamatorily alleges that this website, as well as that in litigation, CLAIMMANAGERREPORT.COM (both websites) have caused damages to (1) his Clients and to (2) his firm! This "2 for 1" modus operandi will assure that the case proceed to trial, and even in such regard, the Plaintiffs' counsel has been uncooperative.

19 FEBRUARY 2025 Perhaps the Plaintiffs' Lawyer should familiarise himself with the Protection of Public Participation Act of BC.

18 FEBRUARY 2025 A point worthy of mention is the BCSC's Rule 1-3, which emphasises the importance of proportionality in legal proceedings. Thus, Court aims to ensure that the time, expense, and complexity of a case be proportionate to the matters at stake. That which is at stake in these SLAPP actions is the Plaintiffs' malicious, abusive of process insistence that this website, in its entirety, be removed from the internet (notwithstanding the fact that Defendant had offered to remove from the website the names, job titles; i.e. all information identifying the Plaintiffs, and had even offered to cede permanent, exclusive control of the website to the Plaintiffs).

As scrupulously documented on this public interest website, Whitelaw-Twining's Partner continues his relentless frustrations of the very spirit of Rule 1-3. By example, Defendant had proposed a discovery plan, which would comply with the spirit of Rule 1-3, "to promote fair and efficient resolution of disputes by balancing the resources and efforts involved in the litigation process". Defendant's proposal was to streamline discovery to simple, limited interrogatories. However, Whitelaw-Twining's Partner formally rejected the suggestion, instead insisting upon formal 'examinations for discovery', calculated to greatly maximise Defendant's expenses, for travel expenses of the Plaintiffs, as well as the attendance of a court reporter. Defendant offered to submit to an examination for discovery, at Plaintiffs' lawyer's convenience.

Although a Court Order will be required, at which costs and other sanctions will be sought by Defendant, the below are the draught Interrogatories of Plaintiffs Amanda Myers, Christa Rae Cordick and Michele Vincent.

20 FEBRUARY 2025 FOMENTING CONFLICTED-OF-INTEREST INSURANCE LITIGATION

As reflected in the below email, the Plaintiffs demand that the website, in its entirety, be removed from the internet. Although these Plaintiffs have all soundly rejected all prior Offers, Defendant remains receptive to any demand, by any Plaintiff, with the exception of the permanent deactivation of the entire site.

13 FEBRUARY 2025 - LEGAL NOTICE

As fully detailed on this public interest website, Whitelaw-Twining's Partner authored the letter of 07 December 2023, wherein the Partner defamatorily, falsely accused a Claimant of an INTACT Insurance policy, of (1) not being an Insured, and (2) submitting the property insurance claim, under false pretences.

The Whitelaw-Twining Partner published the defamatory letter to various departments of the Insurer.

The detailed history of the Partner's SLAPP lawsuits against the Claimant have been fully documented hereupon. The defamed Defendant had offered to allow Whitelaw-Twining occasion to remove all references to the Partner and the firm, per the below examples. To date, the Offer has not been accepted. It will not be repeated.

Defendant's Offer was rendered for the sole purpose of compliance with the requirements of Court Rule 1-3, with the possibility of an extrajudicial remedy of the substantial legal entanglements, past, present and future. No other motivation is intended, nor may be inferred. To emphasise, the herein Offer remains unaccepted, despite the fact that it had been amended to include Whitelaw-Twining, its Partner and all personnel, whose names appear on this website.

12 FEBRUARY 2025

By way of the below email, Whitelaw-Twining assures that Plaintiffs Amanda Myers, Christa Rae Cordick and Michele Vincent (none of whom has ever identified a specific instance of defamation on the website) have formally rejected the Offer to remove all traces/vestiges of their identities (names, job titles and all other identifiers) therefrom. Defendant proudly RSVPs this not so subtle invitation to trial, and continues to encourage that Plaintiffs' lawyer comply with Rule of Court 1-3, by stipulation to certain procedures (reasonable discovery), without the threat of Court intervention, which he relentlessly wields, unless the Defendant should summarily deactivate the entirety of the public interest website, including citation of the Strata Property Act § 155(b), as well as the ruling of the Schappert case, analysed herein.

12 FEBRUARY 2025

Whitelaw-Twining's Partner, committed a tactical error (i.e. miscalculation in the resolve of a mere civilian, in pro se Defendant) with the Partner's letter of 07 December 2023, wherein he defamatorily accused the Defendant of submission of a property claim with INTACT Insurance, under the false pretence of being an insured.

Currently, the herein Offer remains unaccepted, despite the fact that it had been amended to include Whitelaw-Twining, its Partner and all personnel, whose names appear on this website.

It would behoove Whitelaw-Twining to seriously reconsider Defendant's yet unexpired Offers.

Nigel Beckmann's letter of 07 December 2023, subsequent to his deletion of identifying information.

Nigel Beckmann's letter of 07 December 2023, prior to deletion of identifying information.

AS CONFIRMED BY THEIR ATTORNEY (IN HIS ABOVE EMAIL OF 13 FEBRUARY 2025) PLAINTIFFS AMANDA MYERS, CHRISTA RAE CORDICK AND MICHELE VINCENT HAVE ALL REJECTED THE OFFER TO REMOVE FROM THIS PUBLIC INTEREST WEBSITE, ALL TRACES OF INFORMATION THAT COULD IDENTIFY THEM.

10 FEBRUARY 2025

Counterproductive strategy: INTACT’s lawyer rejects all of Defendant’s Offers, ever-insistent that the entire website is defamatory; only deactivation of the website be acceptable. However, this website has always contained factual information, such as that highly complimentary of CEO Charles Brindamour, the consummate executive actuarial, under whose superb leadership, the company has achieved remarkable success. It is incomprehensible that Monsieur Brindamour should knowingly allow the arrant gaspillage of shareholders’ funds, in the futile pursuit of the self-destructive, moral, ethical, legal and statutory entanglements, in which the company finds itself, with no end in sight!

09 FEBRUARY 2025

An Offer to remove the names of Plaintiffs (Amanda Myers and Christa Rae Cordick) was previously rejected, although their Whitelaw-Twining lawyer had initially expressed interest therein.

In one last effort by Defendant to comply with Rule of Court 1-3, the current Offer includes Plaintiff Michele Vincent, and the removal of all job titles, as well.

UPON EXPIRY OF THIS UNACCEPTED OFFER, PER THE COUNTDOWN, IT WILL NEVER AGAIN BE RENDERED.

08 FEBRUARY 2025

In yet another effort on the part of Defendant to comply with BC Supreme Court Rule 1-3, Defendant hereby offers, subject to the above countdown, forever to remove from the website the name, as well as job title, of any Plaintiff who agrees to discontinue her role in the subject litigation against Defendant. Defendant thanks the Plaintiffs' counsel for timely conveying this Offer to each Plaintiff.

THIS OFFER IS RENDERED SOLELY TO COMPLY WITH THE SPIRIT OF COURT RULE 1-3, AND NOT AS AN ADMISSION THAT ANY ASPECT OF THE WEBSITE IS, OR EVER HAS BEEN DEFAMATORY, OR OTHERWISE UNTRUE.

Email of 02 December 2024 - Plaintiffs' lawyer's response to Defendant's Offer

Email of 02 December 2024 - Defendant's Offer to Plaintiffs Amanda Myers and Christa Rae Cordick

07 FEBRUARY 2025

Open letter to Whitelaw-Twining DWF Group, since the Partner selectively ignores important correspondence.

Per the below link to the Partner's email of 03 February 2025, he summarily states that the entirety of the subject website is defamatory, without ever citing even a single, specific examples (he has never so cited). He also threaten a Motion for Injunctive Relief, to have that entire website deactivated.

In an effort solely to comply with the spirit of Court Rule 1-3, and certainly not of intimidation, Defendant provides the below links, as labelled. The Partner's unconditional, summary threat to "shut down" or "take down" that entire cite, which includes citations of oppositional statutes and case law, such as a citation of the Strata Property Act § 155(b), as well as the ruling of the Honourable Justice Coval of the BC Supreme Court, are matters of fact, worthy of judicial notice, and by no means subject to removal from that website.

As scrupulously documented on the website, Whitelaw-Twining's Partner continues either to conflate or confuse the legal distinction between defamation and inconvenient, oppositional facts.

06 FEBRUARY 2025

THIS PUBLIC INTEREST, EXPOSITORY WEBSITE IS REPLETE WITH PRECISE INFORMATION AND DOCUMENTATION REGARDING A VERITABLE PERFECT LEGAL STORM, WHICH ENSUED WHEN A WHITELAW-TWINING PARTNER, OUT HOUSE COUNSEL RETAINED BY INTACT INSURANCE, SENT THE BELOW DEFAMATORY LETTER, FALSELY ACCUSING A CLAIMANT OF INTACT OF SUBMISSION OF HIS CLAIM UNDER THE FALSE PRETENCE OF BEING AN INSURED. THE TOXIC EFFECT OF SUCH LETTER PROXIMATELY CAUSED THE BELOW-DOCUMENTED, INAUSPICIOUS CHAIN OF EVENTS, WHICH CULMINATED IN THE LAWYER'S FILING OF TWO (2) SLAPP ACTIONS AGAINST INTACT'S NAMED INSURED CLAIMANT, WITH THREE (3) OF INTACT'S DISILLUSIONED PERSONNEL AS PLAINTIFFS.

Common sense ethics are specifically codified in Law Society Codes of Conduct, such as Rule 5.1-2(e) When acting as an advocate, a lawyer must not knowingly attempt to deceive a tribunal or influence the course of justice by offering false evidence, misstating facts or law, presenting or relying upon a false or deceptive affidavit, suppressing what ought to be disclosed or otherwise assisting in any fraud, crime or illegal conduct.

In Paulus v. Fleury, 2018 ONCA 1072, the Court of Appeal held that a factual misrepresentation by counsel in judicial proceedings could amount to deceit or civil fraud “in those circumstances where there would be no reasonable basis for the factual assertion; nor could it be said that the statement was made in good faith” (para 30).

Rule 5.1-2(a) states that a lawyer must not abuse the process of the tribunal by instituting or prosecuting proceedings which, although legal in themselves, are clearly motivated by malice on the part of the client and are brought solely for the purpose of injuring the other party.

Rule 2.01 (4) A lawyer who has unknowingly done or failed to do something that, if done or omitted knowingly, would have been in breach of this rule and who discovers it, must, subject to rule 2.03 (Confidentiality), disclose the error or omission and do all that can reasonably be done in the circumstances to rectify it. Rule 5.1-2(b) states that a lawyer must not knowingly assist or encourage any person to abuse the process of the tribunal by instituting or prosecuting proceedings which, although legal in themselves, are clearly motivated by malice on the part of the client and are brought solely for the purpose of injuring the other party.

Rule 5.1-2(c) states that a lawyer must not knowingly make a false or misleading statement to a tribunal. Rule 5.1-2(d) states that a lawyer must not knowingly present false evidence or assist in any fraud, crime, or illegal conduct.

Prior to Whitelaw-Twining's Partner's malicious, defamatory letter, falsely accusing the Claimant of submission of the subject claim, under the false pretence of being an insured, Ombudsman Michele Vincent had confirmed the Claimant's status as an insured, by assigning his formal Complaint to the Customer Experience Team. However, in reliance upon the Whitelaw-Twining Partner's false accusations, Ombudsman Vincent not only abandoned the Claimant's Complaint, she became a Plaintiff in Whitelaw-Twining's SLAPP litigation.

Prior to Whitelaw-Twining's Partner's above letter, falsely accusing the Claimant of submission of the subject claim, under the false pretence of being an insured, in house Counsel Christa Rae Cordick had confirmed the Claimant's status as a Named Insured, in a legal pleading. However, in reliance upon the Whitelaw-Twining Partner's false accusations, Ms. Cordick not only abandoned the Claimant's Complaint, she became a Plaintiff in Whitelaw-Twining's SLAPP litigation.

Prior to Whitelaw-Twining's Partner's above letter, falsely accusing the Claimant of submission of the subject claim, under the false pretence of being an insured, Unit Claims Manager Amanda Myers and Claims Representative Breanna Gray had confirmed the Claimant's status as an Insured. However, in reliance upon the Whitelaw-Twining Partner's false accusations, Manager Amanda Myers became a Plaintiff in Whitelaw-Twining's SLAPP litigation. Representative Breanna Gray, a young lady of impeccable ethical and moral standards, refused to participate in Whitelaw-Twining' Partner's SLAPP initiative.

OPEN LETTER TO PLAINTIFFS' WHITELAW-TWINING LAW FIRM PARTNER:

05 FEBRUARY 2025

THIS PRECISELY DETAILED PUBLIC INTEREST WEBSITE HAS EXPOSED THE EGREGIOUS BAD FATH AND FRAUDULENT ACTS AND OMISSIONS OF INTACT INSURER AND ITS LEGAL COUNSEL.

In particular, the below documented activity from 20 January 2025 to 05 February 2025, has critically distinguished INTACT's civil action (no. VLC-S-S-244577) from a common, personal insurance dispute, to a prima facie SLAPP action of significant public policy implications, which raise questions of broad legal significance.

Below is an email of 02 October 2024, from the Ministry of the Attorney General of BC. Within the past few days, there have been nascent indications that the AG's office may intervene in INTACT's SLAPP litigation, in view of broad involvement of the significant public policy implications, with issues of broad legal significance, such as statutory [INTACT’s Lawyer's acts and omissions have proximated extensive regulatory entanglements], by his refusal to comply with [Strata Property Act Section 155(b)] judicial [Plaintiffs refuse to apply the ruling of Strata Plan VR 2213 v. Schappert, 2023 B.C.J. No. 2272, 2023 BCSC 2080, decided by the Honourable Justice Coval of the BC Supreme Court, where INTACT's SLAPP is pending] ethical [Law Society of British Columbia Rule 2.02(5)] regulatory [Plaintiff Ombudsman Michele Vincent submitted material, false information to the BCFSA] judicial [Plaintiff Christa Rae Cordick provided false testimony to judges of the BC provincial court] criminal and administrative [Plaintiff Amanda Myers falsified an important Claims Investigation (according to INTACT's Privacy Officer, Helen Cameron]

04 FEBRUARY 2025

Below is an exact copy of an email from Plaintiffs' lawyer, to the In Pro Se Defendant of Plaintiff's SLAPP litigation.

Although the legal points will be thoroughly addressed at trial, certainly not on this public interest website, the following highlighted portions of Mr. Beckmann's email are indisputably incorrect.

In violation of Rule of Court 1-3, Plaintiffs' lawyer rejected the Offer, which was to extrajudicially grant them the right to permanent, exclusive control of this website, to remove any material that any of them should find defamatory, for whatever reason. Plaintiff INTACT has personnel who are trained to modify websites, under its control.

Plaintiffs' lawyer's statement that the Court could not order or enforce the Offer is disingenuous and specious, at best, because the terms of the Offer were designed to avoid any Court enforcement, or other involvement, whatsoever. The Offer was designed to allow the Plaintiffs unrestricted, free rein over the presentation of this website. The Court not only encourages extrajudicial resolutions, it has codified this requirement in Court Rule 1-3.

With his relentless, customary hyperbolic threats to institute more and more more litigation, Plaintiffs' lawyer claims to be preparing more Motions for Court Orders for injunctive relief, unless Defendant should abandon his rights to freedom of speech, by immediate deactivation of this entire public interest website.

Defendant's reliance upon fundamental civility from Plaintiffs' lawyer, expectation of compliance with basic Code of Conduct regulations of the Law Society of British Columbia, as well as honesty and good faith, have been to no avail.

PLAINTIFFS' LAWYER'S ACTIONS CONSTITUTE THE PRIMA FACIE DEFINITION OF SLAPP LITIGATION

Furthermore, BC Premier David Eby, Attorney General Niki Sharma and the legislature of BC are diametrically opposed to the nature of abusive Plaintiffs, who pursue litigation, merely to deny Defendant's of the right of freedom of expression.

PURSUANT TO COURT RULE 1-3, IN DEFENDANT'S ONGOING EFFORT TO LIMIT THE DURATION OF EXAMINATION OF THE PLAINTIFFS AT TRIAL (WHETHER OR NOT THEY EXERCISE THE OPTION TO ASSUME EXCLUSIVE CONTROL OF THIS WEBSITE), ALL POSTS PRIOR TO 20 JANUARY 2025 HAVE BEEN LOCKED, AND WILL REMAIN SUCH. IT IS RESPECTFULLY SUGGESTED THAT THE PLAINTIFFS MAKE PERIODIC, EXACT TIME-STAMPED COPIES OF THE WEBSITE, IN ORDER TO CONSERVE TRIAL TIME.

30 JANUARY 2025 As detailed below, the Defendant of Plaintiff INTACT's and its personnel's civil actions had made the below offer to permanently surrender exclusive control of this website to the Plaintiffs, subject to the terms thereof. On 21 January 2025, Plaintiffs' lawyer from Whitelaw-Twining rejected said offer, by rendering a counteroffer, to remove everything from this website (including facts complimentary of INTACT CEO Brindamour). Plaintiffs' lawyer's bad faith counteroffer was to effectively remove this website from the internet, with the result of a blank screen page. Pursuant to Supreme Court Rule 1-3, Rule 7-1 and Part V, Defendant has reinstated the Offer, which remains valid until the expiry of the above countdown. Never again will it be reinstated! In the absence of Plaintiffs' timely acceptance of the Offer, at trial they will each be required to identify all instances of defamation on the website that justify their filing of the two (2) civil actions against the Defendant. If they should fail to meet this solemn threshold, then a civil action for abuse of process will be pursued against them, guaranteed! 22 JANUARY 2025 "Nulla est terminus malitiae socii Whitelaw-Twining." According to the Whitelaw-Twining Partner, his Clients, INTACT Insurance, Claims Manager Amanda Myers, Counsel Christa Rae Cordick and Ombudsman Michele Vincent have all formally rejected Defendant's herein Offer to grant them the unconditional right to strip the subject website of all words that any of them should believe defamatory, without need of reason, nor explanation. As the below email from INTACT's lawyer from Whitelaw-Twining confirms, with reference to this website, the Plaintiffs all "claim that every single word, image, sentence, and representation is defamatory". Although the Plaintiffs allege that "every single word, image, sentence, and representation is defamatory", a simple review reveals that more than 90% of its content is factual, such as correspondence authored and signed by each Plaintiff. Among the matters deemed by the Plaintiffs to be "defamatory" are facts, even worthy of judicial notice [such as Strata Property Act Section 155(b), and the case of Strata Plan VR 2213 v. Schappert, 2023 B.C.J. No. 2272, 2023 BCSC 2080, decided by the Honourable Justice Coval of the Supreme Court, where Plaintiffs filed their SLAPP actions forum of this . Other factual information on the public interest website includes citations of legislation, court filings, and even numerous, laudatory articles about Plaintiff INTACT and its CEO Brindamour and his "Living Our Values" noble initiative. Much content is complimentary, not defamatory, and certainly falls within the scope of protected free speech. The Whitelaw-Twining has proven that his intransigent, cynical approach has no limit. Thus, Defendant's Motion to dismiss the Plaintiffs' SLAPP actions has been redraughted, subject to more revisions, and filed, when appropriate and without notice to the subject offence lawyer.

02 FEBRUARY 2025

The impending expiry of the subject Offer represents a tacit admission that despite having filed two (2) civil actions against the herein Claimant for defamation, none of the Plaintiffs, their Whitelaw-Twining Lawyer, or anyone else has been able to identify any aspect of this website that she/he considers defamatory. This tacit admission will assume legal proportions, upon examination of each Plaintiff and their percipient witness Lawyer, under oath, at trial.

As fully documented on this public interest website, INTACT's Privacy Officer, whistleblower Helen Cameron had discovered that Alberta Claims Manager Amanda Myers, had falsified the investigation of a claim, which had been assigned to her. The Claimant, Administrator of this website, then filed a formal Complaint with INTACT Ombudsman, Michele Vincent, who assigned the Complaint to INTACT's Customer Experience Team. However, in an illegal act to conceal the legal and regulatory consequences of the Claims Manager's fraud, the Ombudsman instructed the Customer Experience Team never to release its findings of the Claim Manager's unlawful claims practices. Thus, after one year, seven months, the Customer Experience Team's Complaint investigation remains in perpetual suspension.

When the INTACT Named Insured Claimant created the factual website, INTACT, rather than to rectify the Claims Manager's fraud, the company engaged a Partner of a Whitelaw-Twining (DWF Group), who, in an attempt to intimidate the Claimant into withdrawing his claim, falsely and defamatorily accused the Claimant of having submitted the claim under the false pretence of being an Insured. When the Claimant refused to succumb to the Lawyer's extortive threats, the Lawyer filed two (2) lawsuits against the Claimant, who looks forward to the trial, at which the Plaintiffs and their instigator, percipient witness Lawyer will all be examined, under oath, and their illicit involvement finally be subject to judicial scrutiny and exposure!

Of particular legal significance is the fact that despite the Lawyer's fabricated defamatory accusation, the fraudulent Claims Manager, Amanda Myers (nominated as a "Strategic Team Leader"), and the derelict, conflicted of interest Ombudsman/Complaint Officer Michele Vincent, and an in house INTACT Lawyer had all confirmed the Claimant's legal status as a Named Insured. However, in retaliation for the exposure of their illicit activities, they became plaintiffs in the defamatory out house Lawyer's aforementioned scheme.

03 FEBRUARY 2025

AS THE COUNTDOWN PORTENDS THE EXPIRY OF THE UNACCEPTED OFFER, IT IS RELEVANT TO NOTE THAT NO PLAINTIFF HAS ACCEPTED EVEN THE OFFER'S RIGHT TO REMOVE THE NAMES OF THE PLAINTIFFS ( "INTACT", "AMANDA MYERS", "CHRISTA RAE CORDICK" and "MICHELE VINCENT") FROM THIS WEBSITE, AND RELATED SEARCH ENGINES.

THE DEFENDANT HAS REQUESTED, AS SOON AS POSSIBLE, THAT OFFENCE COUNSEL SELECT PRECISE DATES FOR THE DEPOSITIONS OF DEFENDANT AND PLAINTIFFS, SINCE, EVEN UPON DISMISSAL OF THE PLAINTIFFS' ACTION, THE DEFENDANT'S CROSS-COMPLAINT WILL BE PURSUED INDEPENDENTLY.

In yet another assault upon fundamental human dignity and decency, Whitelaw-Twining/DWF Group's Partner has inflicted yet another round of emotional distress upon his Insurer Client's Named Insured and his spouse, by refusing a simple Freedom of Information Act request for unprivileged personal information. Although only tangentially relevant to the gravamen of the subject of this public interest website, Whitelaw-Twining's intransigent refusal further frustrates RB's efforts obtain a standard Customer Experience letter from the Insurer. According to Whitelaw-Twining's website, under its 2022 acquisition by the DWP Group, its Privacy Officer is a T. Ryan Darby https://wt.ca/privacy-policy who, despite an unctuous "Commitment to Privacy" vacuous assurance of compliance with the BC Office of Information and Privacy Commissioner (OIPC) ease of access to personal information, Mr. Darby ignores all requests and other correspondence. Has the Whitelaw-Twining Partner's intransigent stance countermanded Privacy Officer Darby's statutory obligations? Since Whitelaw-Twining (DWF) has opened offices in several provinces, including Québec, thus constructively maintaining RB's personal information in each, its BC office's cooperation would obviate the necessity of Requests for Information in the other provinces. Even more so than the OIPC of BC, its counterpart, the Privacy Commissioner of Ontario enforces Freedom of Information requests aggressively. Requiring a court Order to compel compliance with the Freedom of Information Act is yet another stark reminder that Whitelaw-Twining's relentless tactics are calculated to generate even more tainted legal fees, with the open defiance of Court Rules, designed to conserve the Court's precious time and resources! The legislature's intent is the facilitation of Freedom of Information, without counterproductive, frivolous, albeit costly Orders for pretrial injunctive relief! On a separate note, due to an oversight, the Complaints specified herein, were not sent to the Law Societies of BC, Alberta or Ontario. Thus, in the event that Whitelaw-Twining should reconsider voluntary compliance with the subject of said Complaints, then a Representative of the firm should contact RB, without further ado.

20 JANUARY 2025 As the result of Whitelaw-Twining's relentless malicious, vexatious two (2) SLAPP actions and other unethical acts and omissions, the Defendant of the firm's SLAPP actions has decided not to rely upon the possibility of litigative support of BC Attorney General Niki Sharma, or BC Premier David Eby (both of whom are ardent supporters of anti-SLAPP legislative and judicial initiatives). Thus, in the event that Whitelaw-Twining's Insurer Clients, Plaintiffs of its two (2) SLAPP actions, should fail to timely accept the Defendant's unconditional offer to literally strip the public interest website of all words that they should consider defamatory (per the below, formal offer), then the final version of the below draughted Motion to Dismiss will be filed and pursued. Once the Motion shall have been filed, it will not be withdrawn, and will proceed to hearing! Under the circumstances, enhanced Costs will be sought!

19 JANUARY 2025 WITHOUT PREJUDICE/RESERVATION OF RIGHTS On 23 December 2024, a Partner of Whitelaw-Twining fired off an email (excerpted below), wherein he threatened to widen the already contentious, costly litigation of the subject case before the BC Supreme Court (BCSC case no. VLC-S-S-244577). It is respectfully brought to Whitelaw-Twining's attention that this threatened action is highly inimical to the strict policy objectives that the Court requires; to wit: The British Columbia Supreme Court Civil Rules, such as Rule 9-1, include provisions designed to encourage litigants to seek extrajudicial remedies prior to filing formal Motions and Applications. These rules emphasise proportionality, early resolution, and case management, in order to ensure that disputes be resolved in a just, speedy, and inexpensive manner. Thus, In accordance with the aforementioned authority, the creator of this public interest website, a Named Insured of Whitelaw-Twining's Insurer Client, offers to Whitelaw-Twining, its Insurer Client and its personnel, the unconditional option to revise the website, subject of the aforementioned litigation, by the deletion or other method, of any and all specific words that Whitelaw-Twining, its Insurer Client and/or its personnel should claim to be defamatory. Upon Whitelaw-Twining's timely submission of a list of specific words to be deleted or otherwise revised, with an indication as to the name and position in the company occupied by the Requestor, the website will be revised to reflect such instruction. There is no requirement that any Requestor provide any explanation or justification, in order to exercise this option. Furthermore, once the website is modified, according the dictates of the Plaintiffs, it will be permanently locked and remain indefinitely in such modified state. This offer does not apply to this website, or to any demands or ultimata to summarily deactivate the other website in its entirety, without reference to specific words. THE SOLE PURPOSE OF THIS OFFER IS THE JUDICIALLY REQUIRED EFFORT TO RESOLVE LITIGATION, AND IS NOT TO BE CONSTRUED OR INFERRED AS ANY OFFER TO RESOLVE DAMAGES, OR ADMISSION THAT ANY ELEMENT OF THIS WEBSITE IS, OR HAS EVER BEEN DEFAMATORY. ANY AND ALL ATTEMPS TO USE THIS OFFER, IN ANY CIRCUMSTANCE OR EVENT, MUST BE ACCOMPANIED BY THIS DISCLAIMER.

WHITELAW-TWINING IS A RECENT ADDITION TO THE WORLD-RENOWNED DWF GROUP

At the heart of DWF's success is its commitment to "Disrupt to Progress", a motto which encapsulates the firm's dedication to challenging traditional legal practices and embracing new ways of delivering legal services. By leveraging cutting-edge technology and fostering a culture of continuous improvement, DWF strives to ensure that its clients receive the highest quality legal advice and support.

As detailed on this public interest website, in view of the perfect legal storm that Whitelaw-Twining has created and periodically nurtured for its Insurer Client, a refund of its attorneys' fees to the Insurer Client would be entirely consistent with DWF's noble commitments to serve clients, by at least, not fomenting frivolous litigation, which has Whitelaw-Twining's Insurer Client with myriad costly legal and regulatory entanglements.

18 JANUARY 2025

15 JANUARY 2025 (LIMITED OFFER TO WHITELAW-TWINING)

Although Whitelaw-Twining's website is a prime example of advertising practices that are prohibited by all Law Societies in Canada (as detailed herein), since its "Defamation" and "Insurance Law" Departments are head by a certain Partner, he would be aware of a major element of this website; that the truth and the facts of the case serve as an absolute defence to Whitelaw-Twining's charges of defamation, in its two (2) SLAPP actions against its Insurer/Client's Named Insured.

As justice would have it, in the case of Casses et al. v. Canadian Broadcasting Corp. et al., 2013 BCCA 200, when he practiced defamation defence, Whitelaw-Twining's Partner prevailed, in reliance upon the legal doctrine that the truth and facts are an absolute defence to the charge of defamation.

However, in the two (2) SLAPP actions, subject of this website, that same Whitelaw-Twining defamation expert Partner, now practices defamation prosecution (as detailed, hereinbelow), defamatorily charging a Named Insured of Whitelaw-Twining's Insurer/Client, with submission of a claim with the Insurer, under the false pretence of being an Insured!

In view of the fact that Whitelaw-Twinging's toxic, wrongful advice to its Insurer/Client was the proximate cause of the Insurer's legal, moral, ethical and regulatory entanglements that have ensued, the creator of this public interest website has written to Whitelaw-Twining, with a request that it refund the (more than $50,000) ill-gotten legal fees back to its Insurer/Client. Whitelaw-Twining would be aware of the legal doctrines of "Unjust Enrichment", "Disgorgement of Improperly Obtained Fees", "Abuse of Process" and "Malicious Prosecution".

WHITELAW-TWINING'S HYPERZEALOUS PROSECUTION OF TWO (2) MALICIOUS, DEFAMATORY SLAPP ACTIONS HAS BEEN LUCRATIVE TO THE FIRM, HOWEVER INIMICAL TO THE PUBLIC INTEREST OF JUSTICE AND FAIR PLAY.

Below is a redacted excerpt from Whitelaw-Twining's Partner's 23 December 2024 email, with a to-be-expected Christmas greeting and assurance of more oppressive litigation in 2025!

10 JANUARY 2025

If anyone from Whitelaw-Twining or its Insurer/Client is interested in the facts and the law, its counsel, Partner of Whitelaw-Twining, recently sent an email to Named Insured Third Party Claimant RB, relevant parts of which are presented below. It is inconceivable that the head of Whitelaw-Twining's 'Insurance Law Department' could still propagate the myth that the claim was of the first person, and not the obvious third person, and after more than three (3) years, the Whitelaw-Twining Partner still renders such costly, incompetent legal advice!

When the claim against the Policyholder Strata Corporation was submitted, on the basis of damages arising from its failure to maintain an infectious external, ornamental pigeon roost (detailed hereinbelow), Alberta Claims Manager "Strategic Leader®" Amanda Myers incorrectly processed such as a first party claim, rather than the appropriate third party type. Ms. Myers refuses to reconsider her bad faith decision.

Incidentally, in the below email, Whitelaw-Twining's Partner is correct to state "if you suffered harm or losses, they were at the hands of others......." Those "others" to whom the Partner referred happen to be the Strata Corporation, a policyholder and named insured of his Insurer Client.

COMPETITION ACT OF CANADA Bill C-59, ENACTED 20 JUNE 2024

Whitelaw-Twining's ongoing deceptive advertising modus operandi, as detailed herein, constitutes egregious violations of the ethical Rules and Regulations of the LAW SOCIETIES OF BC, ALBERTA and ONTARIO (chronicled by the CANADIAN BAR ASSOCIATION)

Recently enacted provisions of C-59 of the Competition Act, enable the Competition Commissioner enhanced enforcement authority over violators, such as Whitehall-Twining, on the basis of unfair Competition.

23 DECEMBER 2024 UPDATE:

The Whitelaw-Twining Partner, Nigel Beckmann, continues in his futile efforts to confuse the law as it applies to the facts of the case, and the facts as they apply to the law. As documented hereinbelow, he continues to attempt to bind Whitelaw-Twining's Insurer/Client, with his own defamatory letter of 07 December 2023, wherein he maliciously and defamatorily accused the Insurer/Client's Named Insured of the submission of an insurance claim under the false pretence of being an Insured.

09 DECEMBER 2024 UPDATE:

It is difficult to contemplate that a Partner of Whitelaw-Twining, a law firm that appears to have staff members of various specialties, filed two (2) SLAPP actions against a Client/Insurer's Named Insured. Nonetheless, the damages occasioned by a malicious chain of events that could possibly still be mitigated, by Whitelaw-Twining's familiarity with Strata Property Act, Section 155(b), and how it applies.

With reference to the language of the 31 September 2021 denial letter, infra, it is written:

2. EACH OF THE FOLLOWING IS ALSO AN INSURED: 2.5. Your unit or strata lot owners and any tenants, but only with respect to the conduct of the corporation for liability arising out of the common property, excluding liability arising out of the owner's or tenant's possession, occupation or use of property designated for exclusive use. Per the ruling of the Economic v Aviva case and its progeny, the policy language controls. Apart from the issues that the Whitelaw-Twining Insurer/Client failed to apprise the other Scheduled Insurers (the master policy of which offered extended, comprehensive coverage), the Whitelaw-Twining Partner's Insurer/Client refused the First Party Named Insured's claim, which unambiguously involved the "conduct of the corporation for liability arising out

of the common property."

The provision of the liability of the common property is activated either by the Strata corporation's (1) failure to maintain the ornamental pigeon roost ledge, or by (2) failure to enforce the Strata Regulations and Bylaws against the Owner of the unit (who is also an Insured under the policy).

The insured Strata Corporation LMS2845 Bylaw 3.9 states: "The Strata Corporation shall maintain the common property ) and the decorating of the whole of the exterior of the building in a healthful and attractive condition".

Strata Property Act § 26 "Subject to this Act, the regulations and the bylaws, the council must exercise the powers and perform the duties of the strata corporation, including the enforcement of bylaws and rules".

Strata Property Act § 257 addresses amending a strata plan to correct a wrong designation of Limited Common Property (LCP) These steps ensure that the property is correctly classified and that the designation aligns with its actual use and accessibility. Strata Property Act § 129 "(1) To enforce a bylaw or rule the strata corporation may do one or more of the following: (a) impose a fine under section 130; (b) remedy a contravention under section 133; (c) deny access to a recreational facility under section 134"

06 DECEMBER 2024 UPDATE: The Whitelaw-Twining Partner continues to refuse to address the solemn ethical and legal issues raised on the public interest, strictly factual website, the publication of which has intentionally been devoid of social media, and otherwise expanded scope. Could it be that efforts to achieve extrajudicial resolutions (such as retraction, apology, compliance with LSBC Rules of the Code of Conduct)are not included in the firm's professional services?

Perhaps one of the firm's insurance coverage specialists could advise the Partner as to the exposure that his SLAPP action and other conduct continues to occasion.

Here is a summary of the illicit activities Whitelaw-Twining's Partner's Claims Manager Client, in the case against an Insured of his Insurer/Client's Named Insured. To the right is an image of an ornamental pigeon roost ledge, situated next to a window of the Partner's Client's Named Insured's 17th floor residential unit. As indicated in the image, the ledge was laden with large amounts of contaminated, toxic spore-producing pigeon faecal matter. The building Strata Corporation (also an Insured of the Whitelaw-Twining Partner's Insurer/Client) refused to abate the health hazard, so the Named Insured occupant submitted a First Party claim with Whitelaw-Twinging's Insurer Client.

A Claims Manager of the Partner's Client wrote a letter dated 30 September 2021, to a Defendant in the Partner's SLAPP action. On 01 May 2024, the Partner requested and was provided with a copy thereof. The letter acknowledged the status of Named Insured, and confirming the following policy language:

2. EACH OF THE FOLLOWING IS ALSO AN INSURED: 2.5. Your unit or strata lot owners and any tenants, but only with respect to the conduct of the corporation for liability arising out of the common property, excluding liability arising out of the owner's or tenant's possession, occupation or use of property designated for exclusive use.

Faced with the "dilemma" of having to process and possibly pay a claim, the Partner's Insurer/Client's Claims Manager devised a scheme [which she has refused to renounce for more than three (3) years], that the Named Insured had physically "possessed", "occupied" and "used" the ornamental pigeon roost ledge, thus triggering the policy exclusion. The roost is physically inaccessible from the Named Insured’s high rise unit. The ledge is devoid of any means of ingress/egress. It is legally, physically and architecturally, common property; not part of any unit of the residential building.

The image to the right is of the health hazard abatement team from specialist Humane Solutions, which, in accordance with BC WorkSafe and OSHA regulations, the remediation crews were required to don protective hazmat suits, special air filtration masks, and safety tie lines, as they gained access to the ledge, by way of a work platform, anchored at the roof of the high rise building. The Named Insured paid $2,541 for the health hazard abatement service.

08 DECEMBER 2024 UPDATE: No one has ever notified the creator of this website, that any specific representation or image hereupon, is in any manner untruthful or contrary to fact. Since the truth is an absolute defence to the charge of defamation (at least in the real world), the Myth of "DEFAMATORY FACTS AND TRUTHS" may be a newly developed, revolutionary cause of action, which guides the Whitelaw-Twining Partner in his two (2) SLAPP actions against Whitelaw-Twining's Insurer/Client's Named Insured, and threatens even more.

As detailed, herein, there is no legal basis to support the SLAPP actions. Curiously the referenced Partner happens to be the firm's foremost expert on defamation, with the ironic statement on his web page segment:

"We have experience in mediations and other alternate dispute resolutions. We also counsel our clients on the damage control measures unique to defamation law, like clarifications, retractions and apologies."

Common sense ethics are specifically codified in Law Society Codes of Conduct, such as Rule 5.1-2(e) When acting as an advocate, a lawyer must not knowingly attempt to deceive a tribunal or influence the course of justice by offering false evidence, misstating facts or law, presenting or relying upon a false or deceptive affidavit, suppressing what ought to be disclosed or otherwise assisting in any fraud, crime or illegal conduct

In Paulus v. Fleury, 2018 ONCA 1072, the Court of Appeal held that a factual misrepresentation by counsel in judicial proceedings could amount to deceit or civil fraud “in those circumstances where there would be no reasonable basis for the factual assertion; nor could it be said that the statement was made in good faith” (para 30).

Rule 5.1-2(a) states that a lawyer must not abuse the process of the tribunal by instituting or prosecuting proceedings which, although legal in themselves, are clearly motivated by malice on the part of the client and are brought solely for the purpose of injuring the other party. Rule .01 (4) A lawyer who has unknowingly done or failed to do something that, if done or omitted knowingly, would have been in breach of this rule and who discovers it, must, subject to rule 2.03 (Confidentiality), disclose the error or omission and do all that can reasonably be done in the circumstances to rectify it. Rule 5.1-2(b) states that a lawyer must not knowingly assist or encourage any person to abuse the process of the tribunal by instituting or prosecuting proceedings which, although legal in themselves, are clearly motivated by malice on the part of the client and are brought solely for the purpose of injuring the other party.

Rule 5.1-2(c) states that a lawyer must not knowingly make a false or misleading statement to a tribunal. Rule 5.1-2(d) states that a lawyer must not knowingly present false evidence or assist in any fraud, crime, or illegal conduct.

This public interest website is dedicated to those who are prosecuted by their own Insurer's "defence" lawyers. Here is an explanation of the complexity of the tripartite relationship that exists among three parties: the Insurer, the Named Insured, and Whitelaw-Twining, compensated by the Insurer to prosecute its Named Insured. The sensitivity of the ethical and legal implications is heightened by the fact that, in the case subject of this website, Whitelaw-Twining's Partner has filed two (2) SLAPP actions against a First Party Named Insured of Whitelaw-Twining's Insurer/Client.

To add to the ethical and legal labyrinth, the Whitelaw-Twining Partner tortiously disavowed the sacred Insurer-Insured fiduciary relationship, by falsely accusing the Named Insured of submission of a claim with the Insurer, under the false pretence of being an Insured.

In further abandonment of ethical and legal responsibilities, the Whitelaw-Twining Partner ignored the Named Insured's repeated requests to notify the other Scheduled Insurers (of the customised BFL Strata Protect Insurance Program policy) of the Named Insured's claim. These ethical and legal lapses of fiduciary and other obligations is particularly germane, since the coverage accorded by the sum total of the wide array of Scheduled Insurers would have applied not only to the original claim, but to defence against the two (2) civil actions, which the Whitelaw-Twining Partner has filed against his Insurer/Client's Named Insured!

Tomorrow we shall focus upon another Whitelaw-Twining Partner, Privacy Officer Ryan Darby, and his ongoing violations of the BC Personal Information Protection Act (PIPA), pursuant to which individuals have the right to access their own personal information held by private entities. Despite the Named Insured's repeated requests for non-privileged information, regarding the claim with his Insurer, Privacy Officer Darby refuses to comply with the law, without so much as an acknowledgement.

THIS PUBLIC SERVICE WEBSITE EXPOSES THE HYPOCRITICAL WORLD OF DE FACTO OFFENCE LAWYERS, WHO CLAIM TO DEFEND THE OPPRESSED - DEFENDERS PROSECUTORS OF HUMAN RIGHTS (TM)

*Defenders Offenders of Fundamental Human Rights and Dignity

05 DECEMBER 2024 UPDATE:

A Whitelaw-Twining Partner is currently prosecuting a frivolous SLAPP action, in which he asserts that "Named Insured", means "Uninsured". A recent decision by Justice Coval of the BC Supreme Court, soundly rejects that risible assertion. In that case, Strata Plan VR 2213 v Schappert 2023 BCSC 2080, the Court defined the scope of Strata Property Act § 155(b), as being applicable to persons "who normally occupy strata lots", which well qualifies the Defendant prosecuted by Whitelaw-Twining's Partner, as well as his entire, resident family!

Whitelaw-Twining's toxic involvement in the subject SLAPP action (prosecuted by a Partner, against a Named Insured of the firm's Insurer/Client), began with the firm's (below) letter of 07 December 2023, wherein it is written:

"The Post (Named Insured's website) in question contains significant defamatory and false statements of fact about the Company and its employees. Since the Post also refers to you as an insured, which is untrue, it further deceives any potential reader of the Post about your status and your relationship with the Company, thereby amplifying the sting of the defamatory remarks contained therein." The Partner admits to having published the defamatory letter to personnel of the Named Insured's Insurer. Recently, when the Named Insured (SLAPP Defendant) informed the Whitelaw-Twining Partner that his wife (also a Named Insured) had been extremely distressed by the litigation and other bad faith aspects of the case, the Whitelaw-Twining Partner replied: "If your wife is upset about the litigation, and you would like to put a stop to it, the solution is simple. You take down your website and cease defaming my clients in other ways, and we will discontinue the lawsuit."

The defamation expert Partner defines "defaming [his] clients" as the Named Insured's refusal to succumb to the extortionary demands that he deactivate the public interest website, and renounce his position of being a Named Insured.

According to Whitelaw-Twining's official website, Partner Nigel Beckmann leads the Defamation and Abuse Litigation groups. It was Partner Beckmann who authored the letter to the right, wherein he knowingly, wrongfully and defamatorily accused an Insured of Whitelaw-Twinings' Insurer/Client, of the submission of an insurance claim, under the false pretence of being an Insured. The fact, as confirmed by several representatives of the Insurer/Client, is that the wrongfully accused was a First Party Named Insured, merely exercising his legal and contractual rights to submit a claim with his Insurer, Client of Whitelaw-Twining.

The Whitelaw-Twining Partner proceeded with his cash cow 'project', despite his awareness that (1) an Alberta Claims Team, (2) house counsel Christa Rae Cordick, (3) the Strata Property Act Section 155(b), and (4) the BC Supreme Court, in the case of Strata Plan VR 2213 v. Schappert, 2023 BCSC 2080, had defined the Defendant's legal status as a First Party Named Insured.

Although his own Clients, Ombudsman Vincent, house counsel Cordick, Claims Team Manager Myers and Claims Representative Gray had notified, in writing, that the Defendant had been a Named Insured, under the insurance policy, the Whitelaw-Twining Partner filed two (2) SLAPP actions against the Named Insured (threatening a third), on the fraudulent basis that the Defendant had lied about being an insured, and that he had submitted the insurance claim under the false pretence of being an Insured.

In aggravation, the Whitelaw-Twining Partner set up for perjury all four (4) of his Clients, who have sued the Defendant, on the basis that he has never been an Insured. Under most zealous examination at trial, all of these Plaintiffs must either commit perjury, by disavowal of their own confirmations (that the Defendant had been a Named Insured), or Without perjury, they shall have proved that the lawsuit that they have pursued against their company's Named Insured, constitutes abuse of process, malicious prosecution and intentional infliction of emotional distress.

In either event, the Whitelaw-Twining Partner has positioned these employés of the firm's Insurer/Client, as candidates for future judicial redress.

Whitelaw-Twining has insurance coverage experts, who would advise notification of this situation to the firm's E&O insurer, per the terms of the policy.

To this day, instead of attempting to mitigate the damages caused by his wrongful acts, or even to offer an extremely insincere apology, the Whitelaw-Twining Partner threatens even more repressive litigation!

CODE OF CONDUCT OF THE LAW SOCIETY OF BRITISH COLUMBIA Disclosure of error or omission 5.1-4 A lawyer who has unknowingly done or failed to do something that, if done or omitted knowingly, would have been in breach of this rule and who discovers it, must, subject to section 3.3 (Confidentiality), disclose the error or omission and do all that can reasonably be done in the circumstances to rectify it.

Threatening criminal or regulatory proceedings 3.2-5 A lawyer must not, in an attempt to gain a benefit for a client, threaten, or advise a client to threaten: (a) to initiate or proceed with a criminal or quasi-criminal charge; or (b) to make a complaint to a regulatory authority.

Listen to a song, dedicated to the Whitelaw-Twining Prosecutor of the Human Rights of the firm's Insurer/Client's Named Insured.

To the left is a (redacted for confidentiality) section of a legal pleading filed by Nigel Beckmann, in his SLAPP action against the Insured of a Whitelaw-Twining's Insurer/Client. The statement denying the Insured's status of the Insurer/Client is simply false, according to Partner Beckmann's own Plaintiffs Clients!

To the right is a (redacted for confidentiality) section of a legal pleading filed by Nigel Beckmann, in his SLAPP action against the Insured of a Whitelaw-Twining's Insurer/Client. The statement denying the insured's status of the Insurer/Client is simply false, according to Partner Beckmann's own Plaintiffs Clients!

PUBLICATION OF THE DEFAMATORY LETTER

Whitelaw-Twining Partner Beckmann published his above defamatory letter to several persons, including insurance personnel, managerial and other agents of the First Party Insured's Insurer(Client of Whitelaw-Twining), such as the Claims Manager of the Insured's property insurance claim. Partner Beckmann's Intentional Interference with the Insured's contract with the Insurer was instrumental in the myriad ethical and legal, regulatory and civil entanglements that ensued, and fester to this day!

All Four (4) Of Whitelaw-Twining Partner's own Clients had Confirmed the Defendant's legal Status as a First Party Named Insured of the Claim with Whitelaw-Twining's Insurer/Client. Thus, the Defamatory, False Allegations in Whitelaw-Twining Partner's Court Filings were Malicious and Deliberate, Not Matters of Opinion, Nor Reasonable Error.

A recently published decision from the Ontario Court of Appeal clarifies the crucial difference between a lawyer’s fair and zealous advocacy for her/his client and the liability for civil fraud, for deception of the Court. In the case of Paulus v. Fleury, 2018 ONCA 1072, the Court cited another recently released Supreme Court of Canada decision in Groia v. Law Society of Upper Canada, 2018 SCC 27, to conclude that a lawyer does not engage in misconduct for inadvertent errors, but only if she or he acts in good faith. In the Whitelaw-Twining case, the Partner had acknowledged that (1) his own Plaintiff Clients, an Alberta Claims Team, (2) house counsel Christa Rae Cordick, (3) the Strata Property Act Section 155(b), and (4) the BC Supreme Court, in the case of Strata Plan VR 2213 v. Schappert, 2023 BCSC 2080, had defined the Defendant's legal status as a First Party Named Insured of Whitelaw-Twining's Insurer/Client.

The motions judge relied on the test for civil fraud as set out by the Supreme Court of Canada in Hryniak v. Maudlin 2014 SCC 7 at para. 87, and held that if one choses to make a statement, it must be an honest statement “it is obvious that counsel have a duty not to lie or make knowingly misleading factual statements” and that this duty is owed to both the Court and to opposing counsel (paras 58 to 59).

The Court of Appeal noted that a lawyer’s duty of resolute advocacy has limits. As Rule 5.1-2(e) of the Law Society of Ontario’s Rules of Professional Conduct indicates, when a lawyer is acting as an advocate, he or she shall not “knowingly attempt to deceive a tribunal by offering false evidence, misstating facts, presenting or relying upon a false or deceptive affidavit, suppressing what ought to be disclosed, or otherwise assisting in any fraud, crime, or illegal conduct.”

In the Paulus v. Fleury decision the Court of Appeal’s commented that mistakes by lawyers are a “frequent occurrence”. Counsel may lose credibility with the Court and their colleagues if they are not scrupulously careful about factual assertions, or if they advance arguments with no reasonable foundation, but these should not amount to civil fraud in this context unless there is neither a reasonable basis for the statements nor a good faith belief in their accuracy (para 29).

Whitelaw-Twining takes deserved pride in defence litigation, including defence of persons wrongfully sued in SLAPP actions. In fact, the below button links to an interesting article, written by Jordanna Cytrynbaum, *Directress at the firm. Partner Nigel Beckmann is prosecuting a SLAPP action against an Insured of his Insurer/Client. Perhaps he should contact specialist Cytrynbaum for a consultation! In Whitelaw-Twining's article it is written:

"Given the resource intensive nature of defamation suits, and the length of litigation generally, the Act could provide useful relief for those embroiled in defamation suits. Pursuant to section 4 of the Act, defendants in defamation actions may now apply to have the action against them dismissed. Once an application is filed, the defamation action is effectively stayed until the application has been resolved (section 5). If the applicant is successful, the Act provides for costs (section 7), or, an award for damages if the court determines the plaintiff brought the proceeding in bad faith (section 8)."

*Whitelaw-Twining yet uses the outdated, sexist term "Director" in lieu of "Directress".

As indicated by the letter to the right, INTACT had confirmed the Claimant's status as a Named Insured of the company. owever, as indicated by his letter to the left, Whitelaw-Twining's Partner contradicted INTACT's confirmations of the Claimant's status, by fabrication of a false charge, defamatorily and falsely accusing the Claimant of submission of the insurance claim under the false pretence of being an insured. Below is a legal pleading of an INTACT lawyer, confirming the Claimant's legal status as a Named Insured.

[from Whitelaw-Twining's website]

No reference to the firm's Prosecutorial Arm re: human rights and dignity.

Defamation is a sensitive and complex area of law. Every case is unique and we explore both traditional and creative approaches to resolve defamation claims as quickly and cost-effectively as possible. The complexity of facts and the strong personalities involved in defamation cases make them costly and time consuming—and the costs are not just financial but also personal and professional.

Our clients include businesses, news and trade organizations, institutions that handle and distribute information, and private individuals. With the prevalence of social media, defamation is more common than ever and potential exposures can run the spectrum from minor to massive. We know this area of law is unlike any other, and that there are no cookie cutter solutions.

We have experience in mediations and other alternate dispute resolutions. We also counsel our clients on the damage control measures unique to defamation law, like clarifications, retractions and apologies.

Services

• Risk identification

• Risk management

• Avoidance

Defamation Lawyer Nigel Beckmann

Associate

LEGAL DISCLAIMER

This factual and informative public interest website refers to certain activities of a Partner of Whitelaw-Twining. It is not contended, nor should any reviewer of this site conclude that Partner Beckmann's herein stated acts and omissions apply to others of his cases, or that the conduct of any other lawyer of the firm might be wrongful or unethical.

To the left is a mission statement, prominently displayed on the internet website of law firm Whitelaw-Twining. Based upon this "goal to eliminate any [sic] litigation", one could conclude that a Partner who masterminds frivolous, defamatory litigation, particularly against the Insured of a Whitelaw-Twining Insurer/Client, acts contrary to the firm's stated objectives.