TAKE NOTICE that this motion is follow with the Motion of request presentation of trial that made by the defendants on April 7th 2003; since the plaintiff is waiting for LEGAL AID REVISION (request made on April 24th 2003) in order to get his own medical expertise for the trial, the plaintiff request this honorable court allows to start this trial with civil matter first before the medical matter (please kindly find attached support letter from our Chinese community—CHINESE FAMILY SERVICES GREAT OF MONTREAL).
This trial is based the nature of this case for the damages directly and indirectly related with Mrs. Pan (Cuiqin Ren—late wife of Zhenguo Pan), and her family, and the damages of financially, mentally and physically suffered remaining her family by follows:
For Mrs. Pan (Cuiqin Ren—late wife of Peter (Zhenguo) Pan)
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Lost emotional support since Montreal General hospital never try to reach her family even with such serious medical injury, and she lost her emotional support from her family before she went to coma. It is very important for her to fight with her injury if she realized there was her family stand beside to support her, unfortunately she never had this opportunity;
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Lost best timing to have a better chance for recovery based of negligent of unreasonable 7 hours delay for start the surgery. Since she already arrived in Montreal general hospital emergency especially for the brain damages, and Montreal General hospital already received warning by the Unbalance before she arrive to the Emergency;
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Lost her best chance to recognize the level of degree of head trauma injury based two evidences—her body no any where had injured even a little skin scratch excepted blood shows on her head with the hit area; unacceptable of the fact that Mrs. Pan had to wait three hours just to have a CT scan done especially with the case of a major head trauma injury;
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Lost her best interests for the medical treatment since the plaintiffs never respected her family requests to have a second opinion by special medical expertise based of her family provided a new medication BFGF, true story published on Chinese Overseas People’s Daily News, and with her family request to keep medical treatment in positive way even just for a miracle;
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Lost her life survive chance since on December 5th 1995, without her family permission Dr. Gordon Baltuch made an order to stop any medical treatment, remove life support to let her die, though her family had a meeting on 1995 December 4th 9:00am with hospital doctors attached witnesses from Chinese Organization Neighbourhood Youth Group President Mr. Zhen Feng Zhang to confirm all the requests made earlier with a promise made by the plaintiffs;
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Permanently lost her life survive chances based of the order made by Dr. Gordon Baltuch on Dec. 5th 1995 and though after words, the plaintiffs promised her family that all the medical treatment already reactive within one hour follow from her family request, unfortunately according the medical record, the plaintiffs never reactive the medical treatment until Mrs. Pan passed away on Dec. 28th 1995.
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Mrs. Pan was a healthy businesswoman and family supporter who was handling all kind business and family matters especially mainly for the finance matters based she was an accountant in China with 13 years experiences; and she lost her great opportunities in business field especially in account field with the fact that she was taking accountant training course with BAO HUA Inc., and she also lost a great opportunities become a good restaurant manager with her very talented of different of languages speaking and warming conversations with her clients.
For Mr. Pan (Peter (Zhenguo) Pan—husband of late wife Mrs. Pan)
The damages caused with death of Mrs. Pan is the result of her family immediately went to family crisis, mentally physically ruins her family and brought her family into financial difficulties living with a nightmare lacking no ending:
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Mr. Pan cannot accept the fact that the plaintiffs did not respected its promise made on the meeting dated of Dec. 4Dec. 4th 1995, and granted a decision by the plaintiffs to end his late wife life without Mr. Pan his permission especially Mr. Pan cannot take the words from the intensive care unit, “SHE IS JUST A VEGETABLE, SHE ISYOU’RE YOUR WIFE ANYMORE, WHY YOU STILL WANT TO SURVIVE HER?”;
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It is emotionally killing Mr. Pan day by days and year by years, and he feels guilty all the time with his late wife based of she suppose marry with a rich man but she chose Mr. Pan became her husband for true love, that she spent her life time work together with Mr. Pan to build up their dream without no day-offs, no-vacations, and Mr. Pan unable to let her hear a word from him especially to protect her when she really needs him;
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Mr. Pan his family lost income from Mrs. Pan, lost himself income because of the stress and depress, lost financial management for his family and his company especially lost his true love partner that caused his life disorder, facing with all kind problems, involved with many lawsuits no matter he wants or not, it also brought into family crisis with all kind complex issues;
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Mrs. Pan death caused Mr. Pan became a major depression patient. It made him lost control with his family, his financial and his businesses. Giving example: the way of his daughter Ruoxi Pan growing; financial lost with his family—all the cash and bank savings, nurture funds, RRSP investment and life insurance investment, child education funds especially business lost with his manufactory JIAXING LAILIN PERFUME CO. LTD in Zhejiang China, his company MAISON CHUAN YANG INC. Export-Import business and his restaurant business SAWATDEE at Old Montreal in Canada;
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Regarding mentioned above, since Mr. Pan became a major depression patient, and he also have to suffer with western medical treatment for the strong side effects, although he was luckily got controlled by Asian traditional way treatment, that he still have to suffer for western doctor un-trust for the way he cures his illness and side effects by the fact of he has to hire a lawyer to release him from mental institution;
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Mr. Pan has to suffer again for the new project OPIUM THAI CUISINE & ORIETAL INSTITUTION living with another pressure giving reason by his daughter Ruoxi Pan when she went age 18, and she released her education fund to let him find a way to cure his illness and side effects, to quite welfare support, rebuild up business and new life, unfortunately didn’t work out;
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Mr. Pan has to suffer with different of discriminations once Mrs. Pan death brought him in a deep mess without ending, living as nightmare seem never have a way to out, everyday has to facing with legal matters, family matters and non stop to seeking a way out even he already tried more than enough;
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Mr. Pan has to use his very limited financial source to deal for his family living cost, his daughter education cost especially for unbelievable legal costs to get out endless of his nightmare since him unable to reach for legal aid support.
