TURMEL: Crown wants Covid Strike Motion Timetable to July!! It's the second time the Crown forgets how Rules for S.369 motions in writing work. Notice in Michel Ethier's Appeal Motion, he filed, Crown responded in 10 days, Ethier replied in 4 days. Pursuant to the Rule 369. Case Management Judge Prothonotary Mandy Aylen asked for a timetable for the next steps in their Strike Motion. He could have answered to go by the rules but instead proposed an 87-day timeline. I objected to not following the rules. So now he proposes to not follow the rules with a 77-day timeline. Department of Justice Canada Ontario Regional Office National Litigation Sector Via E-mail to johnturmel@yahoo.com Our File Number: LEX-500040961 April 30, 2021 Dear Mr. Turmel: Re: TURMEL, John v HMQ (Court File No.: T-130-21) CR: Further to the Court's April 26, 2021, Direction in the above-noted matter, I am writing to propose the following deadlines for Canada's motion to strike and for security for costs under Rule 369: Department of Justice Canada Benjamin.Wong2 @ justice.gc.ca Via E-mail to johnturmel@yahoo.com Our File Number: LEX-500040961 May 3, 2021 Dear Mr. Turmel: Re: TURMEL, John v HMQ (Court File No.: T-130-21) I am writing in response to your letter dated May 2, 2021. To expedite the determination of this matter, Canada is willing to consent to 15 days for the service and filing of Canada's Notice of Motion and Affidavits. Canada is also willing to start the timeline for service and filing of its Motion Record from the date that you advise that you will not be filing an affidavit or participate in cross- examinations. Canada's revised proposed schedule would be as follows: - Service and filing of Canada's Notice of Motion and Affidavits: 15 days from the date that the Court implements this schedule - Service and filing of the Plaintiff's Affidavits: 15 days from the date that Canada serves its Notice of Motion and Affidavits - Cross-examinations on affidavits: 10 days from the date that the Plaintiff serves his Affidavits - Service and filing of Canada's Motion Record: 15 days from the expiration of the time for cross-examinations, or, if the Plaintiff does not intend to serve an Affidavit or conduct cross-examinations, within 15 days of Canada being advised of this - Service and filing of the Plaintiff's Responding Record: 15 days from the date that Canada serves its Motion Record - Service and filing of Canada's Reply Submissions: 7 days from the date that the Plaintiff serves his Responding Record Please let me know if this revised timetable is acceptable to you. If not, pursuant to the Court's April 26, 2021, please provide me with your availabilities for a case management conference so I can advise the Court of our joint availabilities. Sincerely, Benjamin Wong Counsel JCT: It's obvious we're not going to agree. I want to go by the Rules, he does not. But he's going to need to get an order dispensing him with following the rules. Right now, he's only got Prothonotary Aylen request for a timeline, as if she doesn't know it's in the rules. So he's pretending the timeline in the rules doesn't exist. Can't let the judge know about the rules she doesn't seem to know. I have an ace up my sleeve. Two actually. But I can't show them until the Case Management Judge makes the mistake of not following the rules, again. So tomorrow, I'll write to him that I disagree with his new 77-day timeline as I disagreed with his original 87-day timeline and suggest we both submit the timeline we want. Mine, in the rules, his, not in the rules. If she does not follow the rules, then the fireworks can commence.