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Q.B No. 271/1994

 

IN THE COURT OF QUEEN'S BENCH FOR SASKATCHEWAN JUDICIAL CENTRE OF SASKATOON

BETWEEN:

RICHARD KLASSEN, KARI KLASSEN DENNIS KVELLO, DIANE KVELLO, SHELDON KVELLO, SHERRY KVELLO (BY HER LITIGATION GUARDIAN DIANE KVELLO), PAMELA KLASSEN, MARIE KLASSEN, JOHN KLASSEN, MYRNA KLASSEN, PETER DALE KLASSEN,

ANITA JANINE KLASSEN

PLAINTIFFS

-and-

MATHEW MIAZGA, SONIA HANSON, RICHARD QUINNEY, BRIAN DUECK, CAROL BUNKO-RUYS, OWEN MAGUIRE, SASKATOON BOARD OF POLICE COMMISSIONERS

 

DEFENDANTS

___________________________________________________________________________________

PART I. DOCUMENTS TO WHICH THERE IS NO OBJECTION TO PRODUCTION ON BEHALF OF THE PLAINTIFF (RICHARD KLASSEN);

___________________________________________________________________________________

 

 

The above named Plaintiff has in his possession or power the documents relating to the matters in question in this suit set forth in the first and second parts of the first schedule hereto.

The following documents are the documents that this plaintiff has in his possession as of the time that this plaintiff started to act for himself. The original list of documents that was prepared in 1995 by solicitor Ed Holgate remains in his possession and will remain his responsibility.

This list will begin with the enumeration 1 in a circle with a line underneath, and will include 1(a) 1(b) etc for when there is more than one page to a document, each document will be separately enumerated and described.

This is the first statement as to documents of the plaintiff Richard Klassen of Q.B. 271/1994 and is in full compliance with the order of Madam Justice Dovell, dated February 21st, 2002.

#1 One page hand written letter dated December 13th-1989 that shows on the top that it is written by MRS. Robert Vogel signed with all our love Grandpa and Grandma. This letter appears to be a letter written to the three Ross children.

#2 One page photocopied paper with a picture of Michael London Ross that appears to be a school picture.

#3 One page letter dated June 21st 1988 with a logo of WESTGATE ALLIANCE CHURCH, to Mrs. Kathy Ross and family, written by Rev. D. Keith, Senior Pastor.

#4 One page letter with the logo CANORA JUNIOR ELEMENTARY SCHOOL to Kathy Ross dated May 10th, 1988 signed by R. Hoehn, Principal.

#5 One page SASKATOON BOARD OF EDUCATION structured success program registration contract for Michael Ross dated September 3 1987 signed by Anita Grosse, Anita Klassen, Dawn Shaak, and Garnett Francis.

#6 One page document heading SASKATOON BOARD OF EDUCATION dated June 25, 1987 to Anita Klassen from Dawn Shaak, School Social Worker.

#7 One page Hand written letter dated Aug, 1988 to Anita signed yours truly Donaldon the bottom of the letter it is written to say big hello to Kathy and MichelleSmile.

#8 One page letter dated June 26th, 1987 from The Saskatoon Board of Education to Anita Klassen from Dawn Skaak.

#9 Two page hand written letter to Anita Klassen regarding Michelle Ross listed on second page as 9A, dated November 3rd, 1988Hello again, signed by Mrs. N. Evans

#10 One page handwritten letter dated December, 8th, 1988 to Anita Klassen signed Mrs. N. Evans.

#11 Two page hand written letter dated October 11, 1989 to Anita Klassen, signed by Donald Ross Page two is listed as 11A.

#12 One page hand written letter to "Anita and your husband signed by Donald Ross with no date.

#13 A binder consisting of a photo-copy of Anita,s Diary with a starting date of December 28th, 1987 to January 1st, 1989This document consists of 56 pages that is listed as 13A-A ending at 13C-D

#14 A green bound book entitled SASKATOON P.R.O.T.O.C.O.L dated September 1991 consisting of 23 pages. .

#15 3 page typed letter from MacDermid Lamarsh to Anne M. Wallace dated March 29th, 1993. This document is listed as # 15 and 15A ending with 15B.

#16 One page photocopy of a Statutory declaration of Michael London Ross dated March 9th, 1999.

# 17 One page typed letter taken from the website injusticebusters from Michelle Ross to Richard Klassen dated November, 1999.

#18 A two page typed letter dated August 13th, 2001 to the Minister of Justice Chris Axworthy from Kathy Rossthe second page of the letter is listed as 18A.

#19 Picture of Nadash McConnel, wife of Howard McConnel "Picketing.

#20 Picture of John Lucas "postering on downtown Saskatoon post.

#21 6-page hand written letter "To whom it may concern from Michael London RossThis is listed as 21, then 21A ending at 21E.

#22 3 page double sided hand written letter "To whom it may concern from Michael London Ross dated December, 1989, ending March 1990This letter is listed as 22, then 22A, ending at 22B.

#23 One page hand written letter "To whom it may concern dated December 25th, 2001 from Michael London Ross, regarding the release of information concerning himself.

#24 32 pages of transcription of the Marilyn Thompson notes transcribed by Ed Holgate on November 29th, 2001this is listed as #24 ending at 24B-E

#25 A picture drawing appears to be done by one of the three Ross children.

#26 What appears to be 6 pages of hand written notes from Marilyn Thompson dated October, 24th (no year)Listed as #26 ending at 26E.

#27 What appears to be 3 pages of hand written notes of Marilyn Thompson dated Saturday October 20th-AM (No year)Listed as #27 ending at 27B.

#28 What appears to be 7 pages of hand written notes from Marilyn Thompson dated October 26th- 4:15 (No year)Listed as #28 ending at 28F.

#29 What appears to be 5 pages of hand written notes from Marilyn Thompson dated Thursday October 25th, 1990Listed as #29 ending at 29D.

#30 What appears to be 3 pages of hand written notes from Marilyn Thompson dated October 25 (No year) on top THOTSListed as #30 ending at 30B.

#31 What appears to be 2 pages of hand written notes from Marilyn Thompson heading "Michelle,s disclosure,s from Aug, date on top is 1990Listed as #31 ending at 31A.

#32 What appears to be 4 pages of hand written notes of Marilyn Thompson with the heading Kathy, dated October/90Listed as #32 ending with 32C

#33 What appears to be 2 pages of hand written notes of Marilyn Thompson with the heading Michael, dated October/90Listed as #33 ending with 33A.

#34 What appears to be one page hand written note of Marilyn Thompson dated Sun, October 28 Michael Video.

#35 One page drawing of what appears to be from one of the three Ross children.

#36 One page hand written notes on a photocopy of a envelope that appears to be from Marilyn Thompson.

#37 One page hand written note that appears to be written by Marilyn Thompson.

#38 Two pages of hand written notes that appears to be written by Marilyn Thompson with no date Listed as #38 ending with 38A.

#39 One page letter with the heading SENTENCES that appears to be written by one of the three Ross children.

#40 One page drawing with some writing on that page that appears to be 5 stick people wearing various costumes and seems to have been drawn by one of the three Ross children.

#41 Two pages of notes with the heading Brian on the top that appears to be written by Marilyn Thompsonending with 41A.

#42 One page note that appears to be written by Marilyn Thompson that has no date, with the heading of "Michael.

#43 One page note that appears to be written by Marilyn Thompson.

#44 Two page note with the heading Brian that appears to be the same as #41-41A.

#45 One page note that appears to be written by Marilyn Thompson.

#46 Seven page notes numbered on the top one through seven that appear to be written by Marilyn ThompsonListed as #46 and ending with 46F.

#47 One page drawing of what appears to be someone tied up on a table, and appears to be drawn by one of the three Ross children.

#48 Two page note with the starting of MY NOTES that appear to be written by Marilyn ThompsonListed as #48 and ending with 48A.

#49 One page drawing that appears to be drawn by one of the three Ross children.

#50 One page drawing that appears to be drawn by one of the three Ross children.

#51 One page drawing that appears to be drawn by one of the three Ross children.

#52 Three pages of hand written notes that appear to be written by Marilyn Thompson Listed as #52 and ending with 52B.

#53 Seven pages of hand written notes with a date of Oct 11/90 in the column that appears to be written by Marilyn ThompsonListed as #53 and ending with 53F.

#54 Three pages of what appears to be notes written by Marilyn Thompson that starts with a drawing that appears to be drawn by one of the three Ross childrenListed as #54 and ending with #54B.

#55 One page hand written note that appears to be written by Marilyn Thompson.

#56 One page note that appears to be written by Michael Ross, that states he needs help. The date of 90 Oct 26 and the name Brian appear at the top.

#57 One page letter that appears to be written by one of the three Ross children that reads I want help

#58 Sixteen pages of handwritten notes that appear to be written by Marilyn Thompson Listed as #58 and ending with 58(O).

#59 One page letter that appears to be written by Marilyn Thompson startingMaking of a

#60 One page note that appears to be written by Marilyn Thompson with a date at the top of October 24, Michael

#61 One page with drawing that would appear is one of the three Ross children,s drawings.

#62 One page letter that appears to be written by Michael London Ross.

#63 Three pages of notes that appears to be written by Marilyn Thompson, headed Michael Oct 24, starting with #63 and ending with #63B.

#64 One page that appears to be written by Marilyn Thompson with some names, phone numbers and addresses on it. The Travelodge Hotel Logo is on the bottom right side of the page.

#65 One page that appears to be written by Marilyn Thompson starting Making of a

#66 One page note that appears to be written by one of the Ross childrenI will never kill anybody

#67 One page that appears to be a drawing by one of the Ross children, with writing on it reading Cups of Anita,s & birth moms & dads

#68 A black bound folder labeled Justification containing 97 pages. The pages alternate from one page of transcribed to one page of a fax copy of what appears to be handwritten notes of Marilyn Thompson. They are numbered from #68 to #68D-S.

#69 A white bound book containing 30 pages, labeled R. v. Lucas dated 1997: October 15; 1998: April 2. #70 Picture of john Lucas postering on Spadina Crescent in Saskatoon, Saskatchewan.

#71 Picture of a poster in a store front window reading DID SGT. DUECK

#72 Four page document labeled SASKATOON POLICE SERVICE DISCLOSURE REPORT Case number 93-43387, consisting of witness statement (s) from Brian George Dueck, Marilyn Thompson, and Carol Bunko-Ruys. Dated November 16/1993. Listed as #72 to #72D.

#73 Two page letter dated July 25, 1993 addressed to Mr. Roy Romanow from Rick Klassen, Listed as #73 to #73A.

#74 Picture of Richard Klassen putting up a picket sign on 22nd Street boulevard.

#75 Picture of Sheila Steele video taping on down town streets in Saskatoon, Saskatchewan.

#76 Five page Community Child Care Consultant report dated December 4/1989 regarding Michael London Ross. Signed by Carol Bunko-Ruys (child therapist) listed as #76-#76D.

#77 Five page Community Child Care Consultant report dated March 19/1989 regarding Michael London Ross. Signed by Carol Bunko-Ruys (child therapist) listed as #77-#77D.

#78 Seven page Community Child Care Consultant report dated November 26/1990 regarding Michael, Michelle and Kathleen Ross. Signed by Carol Bunko-Ruys (child therapist) listed as #78-#78F.

#79 Ten page Community Child Care Consultant report dated April 26/1991 regarding Michael, Michelle and Kathleen Ross. Signed by Carol Bunko-Ruys (child therapist) listed as #79-#79I.

#80 Eight page Community Child Care Consultant report dated September 3/1991 regarding Michael, Michelle and Kathleen Ross. Signed by Carol Bunko-Ruys (child therapist) listed as #80-#80G.

#81 Three page fax copy of a MEDICLINIC report on Kathleen Ross addressed to Liz Newton dated June 1/1991 signed by Dr. Joel Yelland. Listed as #81-#81B.

#82 Three page fax copy of a MEDICLINIC report on Michael London Ross addressed to Liz Newton dated June 7/1991 signed by Dr. Joel Yelland. Listed as #82-#82B.

#83 Three page fax copy of a MEDICLINIC report on Michelle Ross addressed to Liz Newton dated June 1/1991 signed by Dr. Joel Yelland. Listed as #83-#83B.

#84 Four page MacNeill Clinic Psychiatry report on Michael Ross dated September 17/1987, signed by Margaret Graham-Woloshyn. Listed as # 84-#84C.

#85 Two page MacNeill Clinic Psychiatry report on Michael Ross dated October 6/1987, not signed but the psychiatrist named is P. Reebye, M.D. Listed as # 85-#85A.

#86 Three page INFORMATION document # 1774644, occ # 46066/90 on the members of the Klassen/Kvello families, signed by Brian Dueck, dated July 6/1991. Listed as #86-#86B.

#87 Three page INFORMATION document # 3054840 on some members of the Klassen family, dated November 27/1991. Listed as # 87-#87B.

#88 One page letter dated November 17, 1994 signed by David Macknak addressed to Mr. Robert Vogel.

#89 One page letter dated October 29, 1993 signed by John D. Hillson addressed to Richard A. Klassen.

#90 One page letter dated November 1, 1993 signed by John D. Lucas addressed to John D. Hillson.

#91 One page letter dated November 1, 1993 signed by John D. Lucas addressed to Mr. Dave Yanko (Star Phoenix).

#92 One page letter dated October 21, 1993 signed by Pamela Freyd, Ph. D. Executive Director of the FMS Foundation, addressed to Jack Christopher.

#93 One page letter dated October 27, 1993 signed by Richard Klassen addressed to John D. Hillson.

#94 One page letter dated October 6, 1993 signed by Janice Mann (City Clerk) addressed to Richard Klassen.

#95 One page letter dated November 4, 1993 signed by Richard Klassen addressed to Robert W. Mitchell, Q.C.

#96 Two page letter dated March 29, 1993 signed by Donald A. MacPherson addressed to Anne M. Wallace. Listed as #96-96A.

#97 Two page letter dated October 19, 1993 signed by John D. Lucas regarding June 17, 1993 meeting. Listed as #97-97A.

#98 One page letter dated September 1, 1994 signed by John D. Lucas regarding Political Asylum.

#99 Seven page draft affidavit not signed or dated by Richard A. Klassen styled in the Court of Queens Bench Saskatoon, Saskatchewan. Listed as #99-99E.

#100 Three page letter dated September 1993 signature is blacked out but the writing on the top of the page states that this story was written by Pamela Klassen to the Star Phoenix. Listed as #100-100B.

#101 One page letter signed by John D. Lucas. 1994.

#102 Thirty-six page bound transcript dated January 12, 1994 speaking to an adjournment concerning charges against John David Lucas.

#103 Four page "Foster Talk Newsletter dated November 27, 1989. Listed as #103-103C.

#104 Three page draft affidavit of Peter Klassen dated February 15, 1994 but not signed. Listed as #104-104B.

#105 Ten page document labeled Helen Ross Argument December 14, 1992. Defence Lawyer Jack Hillson addressing the court. Listed as #105-105I.

#106 Two page letter dated October 15, 1993 signed by Robert W. Mitchell, Q.C. addressed to Richard Klassen. Listed as #106-106A.

#107 One page letter dated Sunday May 2, signed by Michael London Ross addressed Dear Mom & Dad.

#108 One page poster of "Children,s Group dated November 7 December 19, 1988 by Margaret Graham-Woloshyn and Ruthanne Bell.

#109 One page letter dated July 3, 1987 signed by Vonda Jorgenson addressed to Anita Klassen.

#110 One page newspaper advertisement dated November 18, 1989 by the Department of Social Services addressed to prospective foster parents.

#111 Two page undated letter signed by Vogel,s and Bohn,s addressed to Court of Queen,s Bench and Minister of Social Services. Listed as # 111-111A.

#112 One page Case Review regarding Stephen Mayes, dated February 4, 1991 signed by Judi Hjertaas.

#113 One page Case Review regarding Stephen Mayes, dated November 20, 1991 signed by Judi Hjertaas.

#114 Twelve pages of handwritten notes possibly from Judi Hjertaas, dated October 31, 1990. Listed as # 114-114K.

#115 Three pages of a partially typewritten transcript of notes prepared by Judi Hjertaas, dated October 1990. Listed as #115-115B.

#116 One page document entitled Criminal Information # 1 of ANY HONEST SASKATOON POLICE OFFICER. Signed by Star Chamber Publications.

#117 One page document entitled Criminal Information # 2 of ANY HONEST SASKATOON POLICE OFFICER. Signed by Star Chamber Publications.

#118 One page document entitled Criminal Information # 3 of ANY HONEST SASKATOON POLICE OFFICER. Signed by Star Chamber Publications.

#119 One page document entitled Criminal Information # 4 of ANY HONEST SASKATOON POLICE OFFICER. Signed by Star Chamber Publications.

#120 One page document entitled Criminal Information # 5 of ANY HONEST SASKATOON POLICE OFFICER. Signed by Star Chamber Publications.

#121 One page document entitled Criminal Information # 6 of ANY HONEST SASKATOON POLICE OFFICER. Signed by Star Chamber Publications.

#122 Five page letter dated September 28, 1993 signed by Johanna Erna Lucas addressed to The Saskatchewan Provincial Court Judge. Listed as #122-122D.

#123 Five page document entitled MALICIOUS PROSECUTION by The Province of Saskatchewan, and the City of Saskatoon. Undated, unsigned. Listed as # 123-123D.

#124 One page document entitled STAR CHAMBER PUBLICATIONS beginning, I RICHARD ALLEN KLASSEN

#125 Two page letter dated September 20, 1993 from Richard Klassen addressed to City Council, City of Saskatoon. Listed as # 125-125A.

#126 One page sworn statement of Richard Klassen, dated November 2, 1993, regarding THE SASKATCHEWAN QUEEN,S BENCH TRIAL OF DONALD ROSS, HELEN ROSS

& DONALD WHITE.

#127 One page documents entitled STAR CHAMBER TRIALS beginning "Secret tapes produced by the Saskatoon City Police

#128 One page document entitled STAR CHAMBER TRIALS beginning "If restitution for the innocent

#129 Two page document entitled THE THOMPSON PERJURY beginning "A local area foster mother testified Listed as #129-129A.

#130 Two page document (both sides) entitled PUBLICATION BAN CAN BE DAMNED. Addressed to Mr. Chris Axworthy, M.P. Undated and Unsigned. Listed as #130-130C.

#131 One page document entitled STAR CHAMBER PUBLICATIONS beginning "The false allegation cover-up by Miazga & Hansen.

#132 One page document entitled STAR CHAMBER PUBLICATIONS beginning "A judicial inquiry into the foster children trials.

#133 One page document entitled STAR CHAMBER PUBLICATIONS beginning "I RICHARD ALLEN KLASSEN Signed by Richard Allen Klassen.

#134 One page document entitled STAR CHAMBER PUBLICATIONS beginning "I RICHARD ALLEN KLASSEN (Richard Klassen picture appears on top right hand side.) Signed by Richard Allen Klassen.

#135 One page document entitled STAR CHAMBER PUBLICATIONS beginning "I RICHARD ALLEN KLASSEN signed by Richard Allen Klassen.

#136 One page document entitled STAR CHAMBER PUBLICATIONS beginning, "Star chamber publications is releasing into the community of Warmen, Saskatchewan dated December 7, 1993.

#137 One page document entitled STAR CHAMBER PUBLICATIONS beginning, "JUDICIAL MISCONDUCT.

#138 Five page handwritten document entitled, Mary: for Court against "Cory. Signed by Mary Grunow, listed as # 138-138D.

#139 One page document entitled MANUFACTURED DEFAMATORY LIBEL.

#140 Videotape of Michelle Ross interview done by Brian George Dueck and Carol Bunk-Ruys, dated Oct 1, Oct 28, Nov 15/1990. Counter takes you to 10.45.46.

#141 Second videotape of interview of Michelle Ross from 10.46.01 to end. Dated November 15/1990. Second part of this tape is of the Kathleen Jessica Ross interview done by Brian George Dueck and Carol Bunko-Ruys.

#142 Videotape of Michael London Ross interview conducted by Brian George Dueck and Carol Bunko-Ruys.

#143 Videotape of the November 29/2000 airing of the CBC,s The Fifth Estate "The Scandal of The Century dated December 1, 2000.

#144 Videotape of the January 2001 airing of the CBC,s The Fifth Estate "The Scandal of The Century with update.

#145 Videotape of the January 23, 2002 airing of the CBC,s The Fifth Estate "The Scandal of The Century with further update.

#146 Videotape of the local CBC, dated February 1, 2002 of Richard Klassen.

#147 Videotape of interview with Michelle Mimi Ross and Richard Allen Klassen dated February 3, 2000.

#148 Transcript consisting of 225 pages of the videotaped interviews of Michael London Ross dated 10/20/90, 10/28/90, and 11/16/90.

#149 Transcript consisting of 164 pages of the videotaped interviews of Michelle Mimi Ross dated 10/21/90, 10/28/90, and 11/15/90.

#150 Transcript consisting of 181 pages of the videotaped interviews of Kathleen Jessica Ross dated 10/28/90, 11/15/90, 10/21/90, and 11/29/90.

#151 Bound transcript consisting of 95 pages of proceeding of Preliminary Inquiry for Peter Klassen dated December 6, 1989.

#152 Bound transcript entitled Volume 1 Ross, Ross, & White Preliminary Hearing dated November 21, 1991. Consisting of pages 1-170.

#153 Bound transcript entitled Volume 2 Ross, Ross, & White Preliminary Hearing dated November 25, 1990. Consisting of pages 183-365.

#154 Bound transcript entitled Volume 5 Ross, Ross, & White Preliminary Hearing dated November 28, 1991. Consisting of pages 715-940.

#155 Bound transcript entitled Volume 6 Ross, Ross, & White Preliminary Hearing dated December 2, 1991. Consisting of pages 941-989.

#156 Transcript consisting of 156 pages of a Preliminary Inquiry for Richard Allen Klassen and Sheila Rose Steele dated February 1,2 & 8, 1995.

#157 Transcript of the Klassen/Kvello Preliminary Hearing dated December 2, 1991 consisting of pages 1-176. Volume I.

#158 Transcript of the Klassen/Kvello Preliminary Hearing dated December 3, 1991 consisting of pages 177-323. Volume II.

#159 Transcript of the Klassen/Kvello Preliminary Hearing dated December 4, 1991 consisting of pages 324-498. Volume III.

#160 Transcript of the Klassen/Kvello Preliminary Hearing dated December 5, 1991 consisting of pages 499-644. Volume IV.

#161 Transcript of the Klassen/Kvello Preliminary Hearing dated December 9, 1991 consisting of pages 645-831. Volume V.

#162 Transcript of the Klassen/Kvello Preliminary Hearing dated December 11, 1991 consisting of pages 1000-1111. Volume VII.

#163 Transcript of the Klassen/Kvello Preliminary Hearing dated December 12, 1991 consisting of pages 1112-1199. Volume IIX.

#164 Transcript of the Klassen/Kvello Preliminary Hearing dated January 6, 1992 consisting of pages 1200-1317. Volume IX.

#165 Transcript of the Klassen/Kvello Preliminary Hearing dated January 7, 1992 consisting of pages 1318-1474. Volume X.

#166 Transcript of the Klassen/Kvello Preliminary Hearing dated January 8, 1992 consisting of pages 1475-1583. Volume XI.

#167 Transcript of the Klassen/Kvello Preliminary Hearing dated January 9, 1992 consisting of pages 1584-1703. Volume XII.

#168 Transcript of the Klassen/Kvello Preliminary Hearing dated January 10, 1992 consisting of pages 1704-1776. Volume XIII.

#169 Transcript of the Klassen/Kvello Preliminary Hearing dated January 13, 1992 consisting of pages 1777-1897. Volume XIV.

#170 Transcript of the Klassen/Kvello Preliminary Hearing dated January 14, 1992 consisting of pages 1898-2001. Volume XV.

#171 Videotaped interview of Richard Allen Klassen conducted by Brian Dueck.

#172 Videotaped interview of Kari Klassen conducted by Brian Dueck.

#173 Videotaped interview of Peter Dale Klassen conducted by Brian Dueck.

#174 Videotaped interview of Anita Janine Klassen conducted by Brian Dueck.

 

PART 11. DOCUMENTS WHICH HAVE BEEN BUT ARE NOT NOW IN POSSESSION OR CONTROL:

 

1. Original email letter sent to Richard Klassen by Michelle Mimi Ross.

PART 111. DOCUMENTS FOR WHICH PRIVILEGE FROM PRODUCTION IS CLAIMED[State grounds of privilege]:

1. Memoranda and communications prepared for the purpose of this litigation.

2. Communications between the plaintiff and his former Solicitor.

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