Litigation Plan
Marihuana Medical Access Program Privacy Breach
as at December 3, 2021


  1. "Action" means the proposed class proceeding commenced on November 25, 2013 in the Court bearing action number T-1931-13,
  2. "Administrator" means the person appointed by the Court to carry out the functions described in this Plan,
  3. "Administrator's Decision" means the Administrator's written decision on a Claimant's eligibility or entitlement in this Action,
  4. "Arbitrator" means a person appointed by the Court to review and adjudicate any appeals made of the Administrator's Decisions pursuant to this Plan,
  5. "Claimant" means a person that alleges he/she is a member of the Class and provides a completed Claim Form to the Administrator in the manner stipulated in this Plan,
  6. "Claim Form" means a claim form, in a form approved by the Court, to be completed by Claimants and submitted to the Administrator in order to determine Claimants' eligibility to participate in the procedure described herein,
  7. "Claims Deadline" means the date by which each Claimant must file Claim Form to be eligible for a remedy granted or approved by the Court,
  8. "Class" or "Class Members" means all persons who were sent a letter from Health Canada in November 2013 that had the phrase Marihuana Medical Access Program or similar French phrase visible on the front of the envelope,
  9. "Class Counsel" means the law firms of Branch MacMaster LLP, McInnes Cooper, Strosberg Sasso Sutts LLP, and Charney Lawyers PC,
  10. "Class Counsel Fees" means the fees, disbursements and taxes payable to Class Counsel as ordered by the Court,
  11. "Class Counsel Representative" means a person to represent the interests of the Class with respect to issues of general application relating to the damages assessment process,
  12. "Court" means the Federal Court of Canada,
  13. "Health Canada List" means Health Canada's list of Class Members whose Personal Information was disclosed as alleged in the Action, which list will be delivered to Class Counsel,
  14. "Notice" means notice to the Class of the certification of the Action as a class proceeding in the form set out in Appendix I to this Litigation Plan, proceeding in the form set out in Appendix I to this Litigation Plan,
  15. "Notice of Appeal" means written notice that a Claimant, the Defendant, or Class Counsel is appealing the Administrator's Decision,
  16. "Notice Plan" means the method of distributing the Notice described in paragraph 27(c) of this Plan,
  17. "Paper Claimant" means a Claimant that is granted permission by the Administrator to communicate with the Administrator by non-electronic means including, but not limited to, submitting a hard copy of his/her Claim Form to the Administrator,
  18. "Personal Information" means Class Members' name, address, health condition and association with Health Canada's Marihuana Medical Access Program,
  19. "Plan" means this litigation plan,
  20. "Reply" means a Claimant's concise statement of material facts provided in reply to the Defendant's Statement of Opposition,
  21. "Resolution Notice" means the notice of resolution of the common issues and further directions about the claims process,
  22. "Statement of Opposition" means a Defendant's concise statement of material facts provided in response to a Claim Form,
  23. "Website" means the website developed and maintained by Class Counsel at, and
  24. "Website Claimant" means a Claimant that submits a Claim Form through the secure section of the Website.