To Johnson, Smith, and the thousands of people they represent

Mountain View

















Good news!

Lawyer Egan will speak on this case with CAFE on Thursday, November 19th, 2015. Meanwhile, allow me to wrap up this Statement of Claim.



Despite of all the violence resulted from overcrowding and bullying,

  1. There is no unit dedicated for the sick or injured at EMDC;
  2. When prisoners needed health care at night, between 11pm and 7am, they had no access to any, during 2010 – 2013.


So let’s say they saw a health professional, when they come back…


  1. e) Patients were typically not cared the way instructed by medical staffs.
  2. i) Patients with special physical or mental need were housed with others without regards to the special care they required.


  1. Again, even if they (prisoners, families and media) complain, EMDC staffs did nothing to try to improve this.


The Plaintiffs’ stories


Glenn Johnson

August 31st, 2012

Plaintiff Glenn Johnson fell in his cell block and suffered from a mild concussion. As a result, he was moved to a smaller cell to recover. However, his cellmate got another inmate onto his bed and moved Mr. Johnson to the floor. When Johnson protested, his cellmate wounded his head and mouth.


  1. Mr. Johnson didn’t get any stitches or treatment.


October 28th, 2012

  1. Mr. Johnson was beaten by a group of inmates when he refused to fight them.


Other assaults included:

  1. attacked by three inmates and stabbed by a pencil;
    soaked by urine;
    sexual harassment,
    sexual threats involving family, etc.


More examples of lack of medical treatments (59e)

  1. In August, Mr. Johnson received no ringworm treatment and
  2. In October, no antibiotics when he had a sore, itchy and infectious lump in his arm.


Example of lack of special diet (59i) and lack of actions following up complaints (70)

Despite of the knowledge of the Plaintiff’s dietary restrictions, Mr. Johnson was given food he could not eat on several occasions. As a response, the guards gave him juice, fruit cup and or nothing for a couple days in a row.


Michael Smith

July 10th, 2012

During his short stay at EMDC from July 9th to 12th of 2012, inmates dragged Plaintiff Michael Smith to the washroom and wounded his cheek. As a result, Mr. Smith was disfigured and continues to suffer from psychological trauma from the wound which required 13 stitches and plastic surgery.





  1. Besides fear and physical injuries, the Plaintiff class members also suffer in terms of trust, emotional expressivity, mental health such as depression, anxiety, post-traumatic stress disorder, education, getting a job and getting paid, ability to deal with authority, enjoying life, etc.


  1. Class members had developed psychological defence mechanisms in order to survive the abuse at EMDC, including denial, repression, dissociation and guilt.



The Statement of Claim was produced by the McKenzie Lake Lawyers LLP
Kevin Egan, Russell Raikes, and Michael Saelhof; Lawyers for the Plaintiffs