Apotex - contamination     www.apotexholocaust.com            www.pharmaholocaust.com
I live like a walking death in twilight zone / some where in between death and a life being deprived of all Human Rights and Constitutional / Law 
protection by habitual offenders. I was assessed by three (3) independent psychiatrists to eliminate offender's speculations about my insanity 
prompting "delusions" etc. All psychiatrists stated clearly, that I am sane /I do NOT have/had any mental illness. No family history of any.
O.H.R.T. PATENTLY WRONG / CRIMINAL Decision 
ACCESSORY/ACCOMPLICE TO CRIMES AGAINST HUMANITY​
HUMAN RIGHTS COMMISSION/ TRIBUNAL OF ONTARIO FACILITATED AND PERPETUATED ON BEHALF OF APOTEX / OFFENDER GROSS ACTS OF DISCRIMINATION, RETRIBUTION, HERRASSMENT, DENILE OF CONSTITUTIONAL / LAW PROTECTION, DENILE OF MEDICAL HELP, DENILE OF ANY EMPLOYMENT, CRIMINAL CONSPIRACY, TORTURE, UNLAWFUL IMPRISONMENT OF A DISABLED / VERY SICK PERSON AND MUCH MORE. 
IT DID ALLOW HABITUAL OFFENDER -APOTEX TO PURGE VICTIMS FILE OFF ALL EVIDENCE AND IT DID MAKE PATENTLY WRONG / CRIMINAL DECISION BY INCOMPETENT MEMBER IN CONFLICT OF INTEREST.

HOLD DR. BERNARD SHERMAN (CEO APOTEX),Jack Kay (Apotex's President) and accomplices PERSONALLY, CRIMINALLY AND SEVERLY RESPONSIBLE / LIABLE FOR ALL MY SUFFERS, TORTURES, DISABILITIES, UNLAWFUL IMPRIZONMENT AND ALL OF WHAT I ALLEAGE! (Bill - 107, Bill - 45, Bill - 168, Bill -133, C-27, etc. ......:)
“Torture is the act of deliberately inflicting severe physical or psychological pain and possibly injury to a person usually to one who is physically restrained or otherwise under the torturer's control or custody and unable to defend against what is being done to them. Reasons for torture can include punishment, revenge, deterrence, interrogation or coercion of the victim, or simply the sadistic gratification of those carrying out or observing the torture.”
Dangerous Offender, habitual offender, long term offender - provisions of the Criminal Code of Canada.

LOOK AT: 
http://www.pharmaholocaust.com/OHRT-March-14--2010.html
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http://www.pharmaholocaust.com/Dr--Bernard-Sherman-tortures-me.html
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http://www.pharmaholocaust.com/Apotex-with-its-Counsel--Carl-Peterson--Filion-Wakely-Thorup-Angelletti--and-a-gang-of-criminal-accomplices.html
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http://www.pharmaholocaust.com/Please-PREVENT-Mr--Carl-Peterson--Filion-Wakely-Thorup-Angeletti-LLP--and-.html
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http://www.pharmaholocaust.com/APOTEX-S-CRIMINAL-TESTIMONY.html
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http://www.pharmaholocaust.com/Dr-Barry-Sherman.html
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http://www.pharmaholocaust.com/My-former-Doctor-does-keep-patients-medical-info--data-and-.html
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http://www.pharmaholocaust.com/characteristics-of-malpractice.html
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http://www.pharmaholocaust.com/WSiB-SUBJECTS--I-W--TO-TREMENDOUS-PHARMACOLOGICAL---SURGICAL-ABUSE---TORTURE.html
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Look for more info in index.

Orlowski v. Apotex, 2010 HRTO 527 
2010-03-11 
HUMAN RIGHTS TRIBUNAL OF ONTARIO


______________________________________________________________________


B E T W E E N:

Andrzej Orlowski
Applicant
-and-

Apotex Inc.
Respondent

______________________________________________________________________

Decision
______________________________________________________________________

Adjudicator: Caroline Rowan

Date: March 11, 2010

File Number: TR-0170-09

Citation: 2010 HRTO 527

Indexed as: Orlowski v. Apotex 
______________________________________________________________________


WRITTEN SUBMISSIONS BY




  )  
Andrzej Orlowski, Applicant ) On his own behalf 
  )  


  )  
Apotex Inc., Respondent ) Carl Peterson, Counsel
  ) 


[1] This is an Application filed pursuant to section 53(5) of Part IV of the Human Rights Code, R.S.O. 1990, c. H.19 as amended (the “Code”) on April 22, 2009. Mr. Andrzej Orlowski filed the underlying human rights complaint with the Ontario Human Rights Commission (the “Commission”) on January 21, 2008.  
[2] In his Application, the applicant alleges that the respondent, Apotex Inc. (“Apotex”), discriminated against him in employment contrary to section 5 of the Code on the grounds of age, disability, ethnic origin, place of origin. He also alleges a breach of settlement and that he had been subject to a reprisal by the respondent, Apotex. The applicant’s complaint against the respondent arises out of his employment with Apotex and/or its predecessor over a period of approximately six and a half years ending on or about January 7, 2004.
[3] In his complaint, the applicant contends that he was subject to discriminatory treatment during the course of his employment by various individuals employed at Apotex (including individuals he refers to as “Taliban employees”), because he raised safety, product quality, and conflict of interest issues in the workplace. His allegations include that he was exposed to active products as punishment for raising these issues and that his employment with Apotex was terminated on January 7, 2004 for the same reason. He also alleges that he was tortured psychologically and picked on during the course of his employment due to his ethnic origin and language accent. More specifically, the applicant provides particulars of his claim in that regard in his submissions filed with the Tribunal, in which he contends that he was attacked physically and verbally by Taliban employees of Apotex due to the fact that he was the only white non-Taliban on shift and because he questions his health and safety.  
[4] In its response to the Application, the respondent requests that the Application be dismissed summarily for any one of the following reasons:
• The Application is covered by a full and final signed Release between the parties in accordance with Rule 13.3 of the Tribunal’s Rules of Practice; 

• The applicant’s extreme delay of approximately four (4) years in filing the underlying human rights complaint with the Commission; 

• The allegations, even if accepted as true, do not disclose a prima facie case of a breach of the Code.  
[5] A hearing was originally scheduled in this matter to address the preliminary issues raised by the respondent. However, at the request of the applicant, and with the consent of the respondent, the hearing was cancelled since both parties waived their right to make oral submissions and agreed that the Tribunal should deal with the preliminary issues on the basis of the written submissions filed.  
[6] By way of background to the preliminary issues, I note that the alleged events giving rise to the applicant’s complaint of discrimination in employment date back to the six and a half year period of his employment with Apotex and/or its predecessor and the termination of his employment on January 7, 2004.  
[7] There is no dispute that, at the time of his discharge from employment, the applicant was offered and accepted a severance package in exchange for a full and final release. Even though the applicant acknowledges having signed the release in question, he contends that Apotex breached/invalidated the release by, among other things, ruining his health and preventing him from obtaining alternate work. He also contends that he was disabled and under financial duress at the time he signed the release.  
[8] It appears from a review of the applicant’s submissions that he claims to have become disabled as a result of his alleged exposure over the six and a half year period of his employment at Apotex to dangerous substances used and/or produced by his former employer. These allegations are also the subject matter of a pending Workplace Safety & Insurance Board (“WSIB”) proceeding and were the subject of a health and safety reprisal complaint filed on July 4, 2006 with the Ontario Labour Relations Board (“OLRB”) under section 50 of the Occupational Health and Safety Act (“OHSA”). The OHSA application was dismissed by the OLRB on March 13, 2007 on the ground of the applicant’s excessive delay in filing it.  
DECISION
[9] Having carefully reviewed the written submissions and supporting documents filed by the parties in respect of the preliminary issues, and for the reasons that follow, I am satisfied that the Application should be dismissed due to the applicant’s excessive delay. I am satisfied that the events giving rise to the applicant’s complaint of discrimination in employment occurred in excess of four years before the applicant’s complaint was filed with the Commission and that the applicant has not provided a reasonable explanation for such a lengthy period of delay and as such that the delay was not incurred in good faith.  
[10] In the circumstances, it is unnecessary to address the other preliminary issues raised by the respondent.
Delay
[11] The alleged discrimination in employment allegedly occurred during the course of the applicant’s six and a half years of employment with Apotex and culminated in his termination in January 2004. His human rights complaint was not however filed with the Commission until approximately four years later. 
[12] The applicant contends that, after the termination of his employment by Apotex, he contacted the Commission in 2004. According to the applicant, Commission staff referred him to other government agencies such as the WSIB and the OLRB. He also contacted the OLRB and many lawyers. He also notes that he did not have a knowledgeable representative to assist him, such as any union representation.  
[13] The applicant explains in his submissions that the reason he did not file his human rights complaint in 2004 or 2005 was both because he was sick and under the influence as a result of the adverse effects of psychiatric/antidepressant and narcotics and because he relied on the guidance from the Commission and other government agencies concerning the proper avenue to proceed with his complaint against Apotex.  
[14] The respondent contends that it is prejudiced by the four year delay in this case in that memories have faded, documents such as notes have no been maintained and there are a number of potential witnesses that are no longer with Apotex. In the circumstances, the respondent submits that it is prejudiced in its ability to mount a defence to the Application at this point in time.
[15] Section 34 of the Code permits a person who believes that any of his or her rights under the Code have been infringed to make an application to the Tribunal alleging an infringement within one year after the incident to which the application relates. Even though the applicant’s original complaint to the Commission was filed when the old section 34 of the Code was in force, the Tribunal has found that the current section 34 provisions are applicable to applications, such as this one, filed under the transition provisions of the Code. See Boncori v. TRW Canada, 2009 HRTO 564 , 2009 HRTO 564 ; Marchand v. St. Michael’s Hospital, 2009 HRTO 566 , 2009 HRTO 566 ; Chinatman v. Toronto District School Board, 2009 HRTO 1225 , 2009 HRTO 1225 . 
[16] An application alleging an infringement of a person’s rights under Part I of the Code must therefore generally be made within a one year period after the alleged discriminatory incident (or after the last alleged discriminatory incident if there is a series of incidents). Section 34(2) of the Code however permits a person to make an application alleging an infringement of the Code more than one year after the alleged incident took place (or after the last incident if there was a series of incidents) only if the Tribunal is satisfied that the delay in filing the application was incurred in good faith and that no substantial prejudice would result to any person affected by the delay if the application were to proceed. The relevant provisions of section 34 of the Code provide as follows:

34. (1) If a person believes that any of his or her rights under Part I have been infringed, the person may apply to the Tribunal for an order under section 45.2,

(a)within one year after the incident to which the application relates; or 

(b)if there was a series of incidents, within one year after the last incident in the series.

(2) A person may apply under subsection (1) after the expiry of the time limit under that subsection if the Tribunal is satisfied that the delay was incurred in good faith and no substantial prejudice will result to any person affected by the delay.
[17] In the present case, the alleged discrimination in employment to which the application relates occurred at unspecified times during the course of the applicant’s six and a half years of employment with Apotex which ended in January 2004. The applicant also alleges that the termination of his employment with Apotex in January 2004 contravened the Code. The applicant’s human rights complaint was not however filed with the Commission until approximately four years after that last alleged incident of discrimination in employment contrary to section 5 of the Code. 
Good Faith
[18] In addressing the timeliness issue, the first question to be determined is whether the applicant’s delay of approximately four years in filing his complaint with the Commission was incurred in good faith. As noted in Corrigan v. Peterborough Victoria Northumberland and Clarington Catholic District School Board, 2008 HRTO 424 , 2008 HRTO 424 , in order to find that a delay in pursuing one’s complaint was incurred in good faith, the applicant must provide a reasonable explanation for why he or she did not pursue his or her rights under the Code in a timely manner.  
[19] In the present case, the applicant explains his delay by noting that, after the termination of his employment by Apotex, he contacted the Commission in 2004. He also indicates that he contacted the OLRB and many lawyers in the period after the termination of his employment. He states that Commission staff referred him to other government agencies, such as the WSIB and the OLRB. The applicant explains that the reason he did not file his human rights complaint in 2004 and 2005 was both because he was sick and “under the influence” as a result of the adverse effects of psychiatric/antidepressant and narcotics and because he relied on the guidance from the Commission and other government agencies to select the proper avenue to proceed with his complaint against Apotex. He also notes that he did not have a knowledgeable representative to assist him, such as a union representative.  
[20] Given that much of what the applicant complains about in his human rights complaint concerns reprisals for raising health and safety issues and also concerns having become disabled as a result of his exposure to chemicals at work, it is not surprising that Commission staff may have provided the applicant with information concerning these other agencies. However, the mere fact that the applicant was alerted to these other possible avenues of recourse does not adequately explain such a lengthy delay in pursuing his discrimination complaint against Apotex.  
[21] It is apparent from the applicant’s submissions that he was aware of the process for filing a human rights complaint at the Commission back in 2004, shortly after his employment with Apotex was terminated. It is also apparent that he knew that his discrimination complaint was not going to be addressed at the OLRB since he explains that he did not include his allegations of discrimination in his OLRB application because the OLRB had advised him that those issues were not within its jurisdiction.  
[22] The applicant therefore knew in July 2006, at the time he filed his application at the OLRB, that his human rights issues would not be addressed by that body. He nonetheless waited a further year and a half to file his human rights complaint at the Commission.  
[23] The applicant’s alternate explanation for his delay in pursuing his human rights complaint at the Commission is that he was too disabled to file his complaint in the period after the termination of his employment. He refers in particular to withdrawal symptoms he experienced apparently from the fact that he was no longer exposed to the various drugs produced by Apotex, to which he claims to have been exposed during the course of his employment.  
[24] In support of his position that he was suffering from various disabling conditions, the applicant submitted a number of letters from physicians which refer to the applicant’s various medical conditions.  
[25] A review of the medical certificates confirms that the applicant has a number of medical issues. However, none of the medical certificates on which the applicant relies indicates that his medical conditions prevented him from being able to file a human rights complaint with the Commission in the period after the termination of his employment in January 2004. There is therefore insufficient evidence before the Tribunal on which to conclude that the applicant had medical restrictions which prevented him from pursuing his human rights claim in a timely way.  
[26] It is also apparent from the material filed by the applicant that he was able to file a number of other applications with other government agencies concerning the same events which gave rise to his human rights complaint years before filing the present Application. For example, as noted, he filed a health and safety reprisal complaint in July 2006 and yet waited another year and a half before filing his human rights complaint at the Commission.  
[27] In all of the circumstances, I am not persuaded that the applicant has provided a reasonable explanation for his lengthy delay of approximately four years since the termination of his employment with Apotex before filing the present complaint alleging discrimination in employment. I therefore find that the applicant has not satisfied his burden of demonstrating that the delay in filing this application was “incurred in good faith” as required under section 34(2) of the Code. 
[28] In the circumstances, it is unnecessary to determine whether the respondent has demonstrated prejudice as a result of the delay. It is also unnecessary to address the other preliminary issues raised by the respondent.
Order 
[29] This Application is dismissed for delay.
Dated at Toronto, this 11th day of March, 2010.


“Signed by”
_____________________________
Caroline Rowan
Member
​==================================================================================================

CLARIFICATION:  
Statement by O.H.R.T. MEMBER THAT I REFERED TO A GROUP OF EMPLOYEES AS “TALIBAN” “(including individuals he refers to as “Taliban employees”)” is out of context! THESE GROUP OF EMPLOYEES DID REFER TO THEM SELFE AS “TALIBAN” AND I DID QUOTE THEM AS SUCH IN REFERENCE TO SOME ISSUES. 
 Apotex/ employer as well did recognize them as such unique group and created exclusively for them in facility pray / religious Rooms.

MORE OF CRIME:

​WSIAT decision Apr /2014`

WSIAT Ontario – artistry in fraud / crimes, misrepresentation, misinterpretation, criminal conspiracy, ,purge of legal files, falsification of Doctor’s notes, recruitment/ solicitation of fraudulent witnesses, accomplice / assistance of criminal offenders , accomplice into crimes, tempering with evidence, insertion of false evidence, facilitation of “illegality defence” by offender and list can go on and on.
 All information used by vice-chair to adjudicate my Case is not representative of truths including my work history, positions held, etc.
Doctor’s notes /info supporting my case is not taken in to consideration / is misinterpreted not included etc.

WSIAT COMMITS CRIMES IN DAY LIGHT!

​MORE OF CRIME LOOK AT: http://www.pharmaholocaust.com/APOTEX-S-CRIMINAL-TESTIMONY.html

AND AT:  
​http://www.pharmaholocaust.com/WSIAT-Ontario---artistry-in-fraud---crimes.html

AND AT THE INDEX




Toxicologist Mitchell W. Souerhoff- Souerhoff & Associates works on his own for 15 years and has no clue what side effects are of new and old chemicals.

In my Case the situation vividly illustrates fundamental problems regarding Public safety in matters of health care. 
My case indicates that problems it illustrates have not yet been satisfactorily resolved across the Country or else ware.
However it has useful role in raising Public awareness of adverse corporate influence on Society and relevant Government Agencies.
It will have useful role as a catalyst to stimulate progress on improving measures to protect the safety of the Public at the local, National and International levels.
For this is necessary to commission an independent inquiry.
New significant steps need to be taken to ensure that individual or institutional conflict of interest would be promptly identified and managed.
Production / profit driven Culture? developed factors leading to corrupt practices entering in to some scientific / manufacturing endeavours, with not merely unfortunate , but tragic consequences.
The information provided by SOUERHOFF & Associates is false, inaccurate or otherwise misleading/fraudulent.
In materials provided by me I did address in depth/with support of hard evidence all what I do allege.
Grave actions were taken by Apotex against me.
Mitchell W. Souerhoff is NOT a Medical Doctor and he provided dishonest analyses in connection with my Case.
He supposes to be rejected as a witness for provision of favourable to Apotex statements which are not supported by any scientific material / Clinical Trial.
Sourhof & Associates did not have access to raw data of my Case.
Dr. Souerhoff was impeded by contractual / monetary compensation Agreement with Apotex. 
Governments must improve defence of Public interest in such cases. 
Apotex describing itself as a major Generic/Brand Company has NO regard to my and Public safety.
This is very disturbing situation.
Souerhoff & Associates / Dr. Souerhoff IS NOT an expert QUALIFIED TO TESTIFY IN MY CASE!
Either Mitchell W. Souerhoff nor his Firm Souerhoff & Associates are equipped; do not have any independent expertise or authority to provide any opinions or conclusions in regard to aggravating side effects of any chemicals / compounds, especially about chemicals / actives used in pharmaceutical industry TODAY.
Either Mitchell Souerhoff nor his Firm DO HAVE PERMITS /CAPACITIES TO CONDUCT ANY EXPERIMENTS / Clinical Trials either on animals or human subjects to have any independent Data/ Expertise in pharmaceutical field. 
Mitchell Souerhoff has his fingers every were where he can make a buck or associate himself with for self promotion.
He utilizes selected/manipulated Data available in Public domain which originates from designed, controlled , purged , suppressed and / or strictly controlled Clinical Trials conducted almost exclusively by Pharmaceutical Companies themselves (please look into data included in my Files).
Usually info about aggravating / lethal side effects is suppressed / concealed by party / Pharmaceutical Companies ordering / conducting / interpreting the Clinical Trial.
Dr. Souerhoff opinionated my Case not being qualified to do so and he did this based on bias information provided to him by Apotex / Counsel Carl Peterson (LLP).
There are no standard speciality tests available / developed to determine any at all impacts of chemicals / actives on human body.
There is absence of objective tests!
Additionally despite request, that in accordance with WSIAT Practice Direction if evidence includes a Report of a Doctor or other Expert that has been specifically prepared for Appeal one must submit a copy of the CURRICULUM VITEA (QUALIFICATIONS) OF THE DOCTOR/EXPERT AND A COPY OF A Letter send to the Doctor / Expert requesting the Report / Testimony as well as address /location of a Doctor / Expert.
Counsel Carl Peterson did not / does not provide any of those.
Mitchell W. Souerhoff and his Firm Souerhoff & Associates are providing Testimonials INCOGNITO not reviling own locations / addresses.
The fact is that BESIDE VISIBLE EXTERNAL DAMMAGE TO THE SKIN / HUMAN BODY, ONLY POSTMORTEM FORENSIC TOXICOLOGY CAN (AND does it IN very LIMITED MANNER) DETERMINE SOME INTERNAL DAMAGE TO THE CNN / HUMAN BODY AS RESULT OF TOXIC EXPOSURE. 
No data can be obtained about adverse effects on physiology or metabolism of individual cells / systems etc.
For example, the toxicity of centrally acting drugs /actives leading to accumulation of toxic concentrations and exerting complex vasoactive effect on the vascular smooth muscles can and does result in immediate or delayed death etc, etc, etc.
There are many different types of chemical injury, including chemical burns, chemical poisoning and allergies arising from chemical exposure, along with a huge range of possible symptoms. The length / severity of exposure to the toxic chemical will also affect the type of chemical injury sustained by the victim. Those are some of my injuries.
All of I allege I did substantiate by hard evidence, Doctor's diagnoses, witness statements, Government Agencies investigations and all what Apotex's Counsel states I did successfully repelled with my submissions contained in my Case Records and Addendums.
Apotex / Counsel / Witness Toxicologist are purposely omitting critical information, misinterpreting, disseminating other, ignoring my previous submissions etc.
Apotex /Counsel / Toxicologist (DEFENDANT- OFENDER) DO SELLECT SENTENCES from Doctors statements OUT OF CONTEXT IN SUPPORT OF OWN CRIMINAL AGENDA.
Counsel/Toxicologist in criminal manner takes / copies sentences from multiple documents / Doctor's statements and assembles them in to one paragraph misleading WSIAT.
Counsel Carl Peterson (LLP) pretends that such false comment / diagnoses were made by a Doctor.
Example of such fabrication is in Counsel's Letter to WSIAT dated Jan 31/2012 on top of Page 3.
Carl Peterson pretends that those are raw quotas of Dr.XXXX's correspondences etc.
In general all info contained in Counsel's submissions on Jan 31/2012 is criminally compromised / manipulated / falsified to the point of not submissability / acceptance for consideration.
Also Carl Peterson lies / misleads WSIAT in his Letter dated Feb 15 /2012 about relevant Regulations / Law as about every thing else he did in my case during almost 9 years of Apotex's / his reign of terror against me a disabled Ontarian.