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Dr. Jean Dodds Responding Exp. Report (plaintiff)

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Nina Penteado v. Rosedale Animal Hospital. Toronto, Court File: SC-11-126218 Toronto veterinary malpractice lawsuit. Dr. Jean Dodds' responding expert report for plaintiff, marked as exhibit No. 4 on February 1st, 2013.
  In the Toronto Small Claims Court Cour des petites creances Toronto , Cl . N _ _ ;::8:::_· .=C_-__:_IL_-_.:_1..: ~~J-_l_l:{_- 0...:......;::0;._;;:0 -- U-· _ a~m o _ No de la demande This is Exhibit ~ - Plaintiff Voici a piece justificative . t Introduced y the ·_·· ;--; ____: Deposee par This 0 f -~of i;;; R~ Yr.:J-D I§ : Le L_~~ ~ an ~f:;.. ~L~ ~Cl erK/Greffier Dr. Jean Dodd s Response to Defendant Expert Opinion Report prepared by Dr. Dana Gray Allen 11-126218 Nina Penteado v Rosedale Animal Hospital Ontario Veterinary Group (2004) Inc. Greater Toronto Veterinary Professional Corporation Toronto Small Claims Court/Sheppard -Clerk: Please file with materials filed by Plaintiff i · ·.J ' ~ ~ 8ti lt -; · l ___ - ... ·.~~: :=; ~. i.) ·. - -. ã .C -.-:,_·I ã ã ~ >c·-    2 3 4 5 6  January 7, 2013 Mr. Frank Caruso Kerzner, MacDermid, McKillop 200 University A venue, Suite 1000 Toronto, ON M5H 3C6 Fax:416-628-8118 Tel: 416-628-8100 VIA FAX and MAIL Dear Mr. Caruso: Re: Rosedale Animal Hospital, Ontario Veterinary Group (2004) Inc., Greater Toronto Veterinary Professional Corporation (GTVPC) Your file: 86792 Court File: 11-126218 I contacted your previous Bay Street address today at Tel: 416-628'-8100 to confirm your new phone and fax numbers. Bay Street office staff indicated that even though you have moved to 200 University Avenue since December 19th/12 you have the same phone and fax nun.lbers. I have attempted to fax Dr. Dodd s response to Dr. Allen's expert opinion report several times, and will continue to do so. Dr. Jean Dodd's Rebuttal Report: Attache< fmd a copy of Dr. Jean Dodd's rebuttal report dated January 7th 2013 to Dr. Dana Gray Allen's report you mailed to me November 29th 2012. This report was available since October 25th 2012, yet it appears you waited over a month to serve it on me. I was out of he country until December 26th 2012, and did not have the opportunity to prepare a response prior to this date. t should be noted that Dr. Dodd's also resides in California, and reaching her to prepare a response invol~s as you can ppreciate~ time consuming. \~»>PW I am therefore relying on Rule 3.02(1) and 2.02 of he Rules of Small Claims Court in order to serve the attached documents on you via fax and mail, and Will file an affidavit of service accordingly. Plaintiff- Additional Documents' and 'Plaintiff Book of Authorities': You were personally served with the following documents on December 28th 2012 Plaintiff- Additional Documents' and 'Plaintiff Book of Authorities' at your new office address at 200 University Avenue pursuant to Rule 18.02(1) and 8.03(5). n affidavit of service was filed with Small Claims Court with a signature from staff at 365 Bay Street confirming you moved office locations as of December 19th 2012 to 200 University A venue, and that Michelle Goodman (receptionist) would be able to accept service since you were away on holidays. 1  I also spoke with you on the 28th of December and you indicated Michelle Goodman would be able to accept the documents in question. Finally, Michelle Goodman endorsed service of he materials at your 200 University A venue office address confirming receipt in writing. It should be noted that you did not advise me or the courts of your address change as is required under Rule 8.09(1) of he Rules of Small Claims Court. Your offices were well aware that was going to be away until December 26th 2012. The following documents have been previously filed and served on you, but am serving them on you again via fax today. These documents were attached to Dr. Jean Dodds expert opinion report dated May 5th 2012 which was served on you April 17th 2012 i) 'W. Jean Dodds' ii) AAHA Vaccination Protocols for Dogs Predisposed to Vaccine Reactions' You were also served with the AAHA 2011 Canine Vaccination Guidelines, which was served February 7th 2012, and on April 17th, 2012. am not faxing this document to you again. Please see Black Binder Tab 12 and Expert Opinion Medical Report (Dr. Jean Dodds, DVM). Documents and Reports received by you: Finally, note that the following documents were served on me to date: i) . ii) iii) iv) v) vi) vii) Dec 7th/ll Statement of Defence with attached revised Rosedale Animal Hospital Patient Chart dated December 6th/11 · April13th/12 an Affidavit of Service and 9A defence form for the GTVPC (later deemed to be an insufficient defence on an April 17th/12 Motion Hearing April 17th/12 a revised Veterinary Emergency Clinic Patient History Report dated November 28th/11 never served previously or seen by Dr. Judy Au my subsequent veterinarian (you were given an additional extension to file a defence for the GTVPC at the April 17th/11 Motion Hearing). May 14th/12 a letter stating you had no intentions of filing a defence for the GTVPC May 16th/12 a letter stating the GTVPC operates under Rosedale, which is false May 24th/12 a fresh as amended defence served on me at May 24th/12 at end of Motion Hearing after you were once again ordered to file a defence for the GTVPC by May 31 st/12 The fresh as amended defence contained another set of changes to Rosedale's Patient Chart November 29th/12 you mailed Dr. Dana Gray Allen's expert opinion report You have not filed any other documents including any additional VEC documents, and therefore expect you will be relying on documents which have been previously filed and served on me between December 7th/11 and November 29th/12. I have ftled and served all VEC and Rosedale al pita Charts inclu ther documents, which have been made available to me- which includes set of 12 VEC X Ray images o my dog Colombo (on CD disc). Regards, Nina Penteado cc: Clerk/ Small Claims Court- Toronto
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