statement of claim part 1

1
Action No. 03o IN THE COURT OF QUEEN'S BENCH OF ALBERTA JUDICIAL DISTRICT OF CALGARY BETWEEN: T. DOE, L. DOE, K. DOE and V. DOE Plaintiffs - and - ATTORNEY GENERAL OF CANADA, COMMISSIONER GUILIANO ZACCARDELLI, DEPUTY COMMISSIONER BEVERLY BUSSON, CHIEF SUPERINTENDENT PETER GERMAN, SUPERINTENDENT RICHARD BARSZCZEWSKI, SUPERINTENDENT VINCE CASEY, INSPECTOR JIM HISLOP, STAFF SERGEANT JIM DALLIN, STAFF SERGEANT PETER MARSH, STAFF SERGEANTDEBBIE CHISHOLM, SERGEANT RON GERMAN, SERGEANT DAN PAINTER, SERGEANT RANDY BURGESS, SERGEANT BARB FLEURY, SERGEANT DENNIS KRILL, SERGEANT ROBERT BLUNDELL, SERGEANT JIM MACDONALD, SERGEANT DAN MALO, CORPORAL GARY SHINKARUK and CONSTABLE HARRY INGRAM Defendants STATEMENT OF CLAIM TART I— OVERVIEW 1. In this claim, four female Royal Canadian Mounted Police ("RCMP") officers seek damages against their employer and certain of their superior officers for sexual assault and various other torts, including abuse of public office. 2. One of the Defendants, Sergeant Robert Blundell, committed sexual assault against each of the four women during various RCMP undercover criminal operations. 3. The balance of the Defendants:

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After going through the RCMP's internal discipline process, the four female officers who complained that Staff Sergeant Robert Blundell had sexually harassed and assaulted them filed a civil action. The case was eventually settled out of court. The details of the settlement are covered by a non-disclosure agreement and have never been made public

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Page 1: Statement of Claim Part 1

Action No. 03o

IN THE COURT OF QUEEN'S BENCH OF ALBERTAJUDICIAL DISTRICT OF CALGARY

BETWEEN:

T. DOE, L. DOE, K. DOE and V. DOE

Plaintiffs- and -

ATTORNEY GENERAL OF CANADA, COMMISSIONER GUILIANO ZACCARDELLI,DEPUTY COMMISSIONER BEVERLY BUSSON, CHIEF SUPERINTENDENT PETER

GERMAN, SUPERINTENDENT RICHARD BARSZCZEWSKI, SUPERINTENDENT VINCECASEY, INSPECTOR JIM HISLOP, STAFF SERGEANT JIM DALLIN, STAFF SERGEANTPETER MARSH, STAFF SERGEANTDEBBIE CHISHOLM, SERGEANT RON GERMAN,

SERGEANT DAN PAINTER, SERGEANT RANDY BURGESS, SERGEANT BARBFLEURY, SERGEANT DENNIS KRILL, SERGEANT ROBERT BLUNDELL, SERGEANT

JIM MACDONALD, SERGEANT DAN MALO, CORPORAL GARY SHINKARUK andCONSTABLE HARRY INGRAM

Defendants

STATEMENT OF CLAIM

TART I— OVERVIEW

1. In this claim, four female Royal Canadian Mounted Police ("RCMP") officers seek

damages against their employer and certain of their superior officers for sexual assault and

various other torts, including abuse of public office.

2. One of the Defendants, Sergeant Robert Blundell, committed sexual assault against each

of the four women during various RCMP undercover criminal operations.

3. The balance of the Defendants: