Ontario Review Board
Re: Stephen Clements
ORB File No: 7490
Hearing held on: Monday July 7, 2025
Place of Hearing: Southwest Centre for Forensic Mental Health Care
Pursuant to: Sections 672.82(1) of the Criminal Code
Before:
Alternate Chairperson: Mr. R. Bigelow
Members: Dr. A. Jones
Dr. J. Cheston
Mr. D. Sandor
Ms. K. Brisson
Parties Appearing:
Accused: Stephen Clements
Counsel: Ms. A. Jervis
The Person in charge of Hospital: Counsel: Ms. J. Zamprogna
Attorney General of Ontario: Counsel: Mr. D. Rose
AMENDED REASONS FOR DISPOSITION
(Dated August 12, 2025)
Please see underlined change to original reasons made August 26, 2025: On page 1 under Parties Appearing – Accused name has been corrected to read “Stephen Clements.”
Introduction
On February 4, 2019, Stephen Clements was found not criminally responsible on charges of terrorism hoax and obstruct peace officer in the execution of his duty contrary to the Criminal Code. Mr. Clements is currently subject to a disposition of the Ontario Review Board (the Board) dated April 14, 2022, ordering his detention at the Southwest Centre for Forensic Mental Health Care (the Hospital) with privileges up to and including residence in the community of southwestern Ontario in accommodation approved by the person in charge. Several weeks after Mr. Clements’ initial hearing in April 2022 Hospital staff attempted to contact him and were advised by his prior residence that he was no longer there, had quit his job and sold his cell phone. Police were advised that Mr. Clements was in violation of his disposition and that a form 49 warrant had been issued. Hearings scheduled for June 2, 2023, September 20, 2023, and September 27, 2024, were adjourned as there had been no contact with Mr. Clements.
On April 22, 2025, Mr. Clements was apprehended by police as a result of a complaint made by staff at the Sarnia Public Library with respect to his harassing an employee. Upon apprehending Mr. Clements, police discovered that there was an outstanding warrant with respect to breach of his disposition and he was returned to hospital.
On Monday July 7, 2025, the Board convened a hearing at the Southwest Centre for Forensic Mental Health Care (the Hospital) to review Mr. Clements’ disposition pursuant to section 672.82(1) of the Criminal Code. Mr. Clements attended the hearing unrepresented although Amicus was appointed to assist the panel. The issues to be determined at the hearing were whether Mr. Clements continued to represent a significant threat to the safety of the public as defined in section 672.5401 of the Criminal Code and, if so, to determine what was the necessary and appropriate disposition that was also the least onerous and least restrictive taking into account the factors set out in 672.54 of the Criminal Code.
Initial Positions of the Parties
At the commencement of the hearing the parties were requested to provide their initial without prejudice positions with respect to the issues before the Board. Counsel for the Hospital indicated that it was the hospital’s position that Mr. Clements continued to represent a significant threat to the safety of the public and that the necessary and appropriate disposition was a continuation of the current detention order with the deletion of the current conditions 2(d) to 2(i) relating to indirectly supervised access to the community, passes into the community and residence in the community.
Counsel for the Attorney General supported the Hospital position.
Amicus indicated that he was unable to take a position at that time
Mr. Clements indicated that in his view there was no evidence to establish that he constituted a significant threat to the safety of the public and that he was accordingly entitled to be discharged absolutely.
Evidence at the hearing
- The evidence at the hearing consisted of Hospital Reports dated March 23, 2023, and June 19, 2025, the oral evidence of Dr. A. Prakash who had been Mr. Clements’ treating physician until two weeks prior to the hearing when his care was transferred to Dr. Mokhber upon his movement from the assessment to the treatment unit, and the oral evidence of Mr. Clements.
Findings:
- For the Reasons that follow, the Board finds that the evidence does not establish that Mr. Clements constitutes a significant threat to the safety of the public and that accordingly he is entitled to be discharged absolutely.
Index Offences:
- The allegations surrounding the index charges as summarized in the Hospital Report are as follows:
On December 16, 2016, Mr. Clements contacted the German Consulate in Toronto and spoke to the Acting General Consul, Michael Lauber, on the phone. Mr. Clements identified himself and Informed Mr. Lauber that a terrorist attack was going to take place in Berlin over the weekend. Mr. Clements said that he was acting as a facilitator, as he had received this information from a member of a terrorist cell who wanted out.
The Integrated National Security Enforcement Team (INSET) GTA was advised of this event, and Cpl. Brouillard contacted Mr. Clements by phone that afternoon. Mr. Clements confirmed that he was the one who had called the German consulate, and indicated that he resided at an address that was later determined to be a Starbucks coffee shop. He refused to provide more details over phone and asked to meet in person in order to provide the information. When the police officers called him again, he indicated that he had changed his mind and would only meet with police the following day. He advised that the man from the terrorist cell (the key) was already with German authorities. Mr. Clements mentioned that ''this was his job" and that he was acting a facilitator.
INSET officers contacted Mr. Clements by telephone on the morning of December 17, 2016. He agreed to meet with the police officers despite being of the opinion that there was no reason to meet. He repeatedly stated that German authorities had already resolved the matter. He went on to explain that the Germans were very happy with his work and would most likely offer him a job. He met with INSET officers later that morning in a coffee shop. The police officers asked him about two arrest warrants from British Columbia. He indicated that the warrants were related to him identifying two police officers as serial killers. The INSET officers were of the opinion that Mr. Clements "did not seem very coherent" and perceived that his affect was incongruent with the serious topic of conversation. He declined to provide any information about the alleged terrorist Hoax. He similarly refused to identify his sources of information, stating that he did not want to expose them. INSET and TPS officers placed him under arrest for Terrorist Hoax. He did not resist arrest and declined to speak to a lawyer.
When interviewed later on December 17, 2016, Mr. Clements refused to provide further information to police, though he conveyed that he was convinced that the terrorist threat was genuine. He said that he had already provided his information to the German consulate and opined that the Canadian authorities would not be helpful to the situation. He informed that he was homeless and currently residing with a friend named Peter, but refused to elaborate on his hereabouts. He informed that he had headaches and described this as "his mental issues.” indicated he had not consumed drugs, medications, or alcohol in the last 24 hours.
On December 19, 2016, while Mr. Clements was in remand custody, a terrorist attack occurred in Berlin causing 12 deaths and dozens of injuries (approx.. 50). A search of Mr. Clements phone and email account on the same day did not show any evidence of foreign communications that would indicate knowledge of the terrorist attack in Berlin.
Mr. Clements participated in a "non-jeopardy" interview on December 22, 2016. According to RCMP Cst. Abdulrahman's notes, Mr. Cements advised that a "higher power" had told him about the attacks. He endorsed hearing voices that only he could hear. Both Jesus Christ and the devil spoke to him. He heard the voices first approximately one week before he contacted the consulate. The first message that he received was about an impending attack in south Berlin. A male voice directed him to contact police on 2 to 3 occasions, but he waited until the December 16 to inform the authorities because “the devil plays funny games with him.” The voice of the devil was deeper and was “always telling him to do bad things.” Since his arrest, he had heard a voice "telling him that his future is looking bad.”
The accused was placed under arrest for Uttering a Terrorist Hoax (by advising the German Consul that there was a terrorist attack going to take place when there was not) and taken to 41 Division where he provided a caution statement. The accused was charged and held for a Show Cause hearing.
Background Information Regarding the Accused:
Information with respect to Mr. Clements’ background is rather limited largely due to his refusal to provide information. However, based on his reports it appears that he was born in Sarnia Ontario and resided in a supportive home with his parents until the age of 19. He denied experiencing traumas or exposure to substance use throughout his development. He reported having brothers and sisters but stated “I’m not involving my brothers and sisters” and denied having any family involvement in the last few years, although he reports speaking with his daughter who now lives in the United States.
Although Mr. Clements reports doing well academically in elementary and high school, he quit school when he was 16 and went to work for the Canadian Railway as a labourer. He states that he later completed his GED when he was 20 and went on to obtain a college diploma in biochemistry through Seneca College.
Mr. Clements reports that he has been self-employed for most of his life owning 30 to 40 businesses over his career. He claims to have patented a design for “anaerobic digestion mechanism to break down waste” but was unable to patent the mechanism as it is from a living organism.
Mr. Clements’ former employer at the River City Vineyard shelter in Sarnia has stated that as of August 2021 Mr. Clements had resided at the shelter for approximately three years. Shortly after arriving he began volunteering but was quickly placed into a paying position and has lived and worked at the shelter since moving in.
Mr. Clements denied having any debts or ever being on Ontario Works or the Ontario disability support program.
Substance Use History
- Mr. Clements indicates that he drinks beer occasionally but denies ever having used any other intoxicating substances and there is no information available to the Hospital contradicting his assertions.
Legal History:
- Mr. Clements criminal history as provided by the Canadian Police Information Centre (CPIC) database is as follows:
Date & Location
Charge(s)
Disposition
1995-05-19
Peel Region, ON
Criminal harassment (Sec 264(1) CC)
Dismissed and Peace Bond for 1 year
2016-04-04 Burnaby, BC
Mischief Under $5000 (Sec 430(4) CC)
Stay of Proceedings (2022-08-25)
2019-02-04 Toronto, ON
Hoax regarding terrorist activity (Sec 83.231 (1)(2) (A) CC) And, Omit to Assist Peace Officer (Sec 129 (B) CC)
NCR
2025-04-22
Harassment
Solved non-criminal (see information below)
- The Hospital Report (Exhibit 2) summarizes the circumstances surrounding the April 22, 2025 incident referred to above as follows:
On April 22, 2025, the police were called to the Sarnia Public Library in response to a harassment complaint from a senior librarian staff regarding alleged harassment by Mr. Clements of a sixteen-year-old student-employee who works at the library. The Assistant Supervisor of Library Operations informed the police that Mr. Clements was trying to offer the student-employee hockey tickets and was bothering her, and that there were five other occurrences reported on different dates by the student-employee regarding Mr. Clements.
- As of the date of Mr. Clements’ hearing, no charges have been laid stemming from these allegations and Mr. Clements has denied any form of harassment associated with what has been alleged.
Psychiatric History
- Mr. Clements denies having any contact with mental health professionals prior to the NCR assessment and there is no file or collateral information regarding any prior hospital admissions or clinical contacts related to mental health. However, there is information to suggest that Mr. Clements evidenced unusual beliefs in early 2016 which were associated with charges of mischief after he damaged property reportedly related to his perception that no one had addressed his claim that police officers were serial killers. Outside of this and the allegation coming from the Sarnia Public Library, the Hospital presented no evidence that Mr. Clements, from 2019 to the present, had any contact with the police, with other hospitals, or mental health service providers or volunteer organizations with whom Mr. Clements has been connected in the community. This is in spite of the fact that Mr. Clements has, of his own admission, been entirely non-compliant with recommended treatment, even following his initial hearing before this Board.
Current Diagnosis
- Mr. Clements’ current diagnosis is schizophrenia spectrum disorder.
Evidence of Dr. Prakash
Dr. Prakash indicated that he had been Mr. Clements’ attending psychiatrist until two weeks prior to the hearing when he was transferred to the care of Dr. Mokhber after his transfer from the assessment unit to the treatment unit. He had read and adopted the contents of the Hospital Reports. Dr. Prakash indicated that the Hospital had little clinical or psychiatric information with respect to Mr. Clements due to his having broken off contact with the Hospital shortly after his initial hearing. He noted that it is possible that Mr. Clements can do quite well in the community, and it is possible that he will be able to hold employment and be a value to the community. However, he doesn’t speak to the treatment team in any relevant way.
Dr. Prakash stated that the results of his risk assessment of Mr. Clements is contained at pages 30 to 33 of the Hospital Report and referred to his “history of violence” as well as the seriousness of the index offences. He noted that Mr. Clements “likely” suffers from a major mental disorder but the diagnosis has not yet been clarified. He advises that Mr. Clements has no insight into the need for treatment for future risk of violence although on a day-to-day basis he does well.
Dr. Prakash stated that it was possible that Mr. Clements’ living situation was appropriate but that there had been no confirmation of it as he had not consented to have the Hospital speak to anyone at the residence.
Dr. Prakash indicated that Mr. Clements continued to refuse to provide information because, in his opinion, it was all a waste of time given the absence of violence in his history. Dr. Prakash noted that in the Court of Appeal decision of Re: Mott (2019 ONCA 560) the court noted that an absence of violence in and of itself does not eliminate the risk of significant harm to the public.
In response to questions from amicus, Dr. Prakash agreed that the index offence occurred in December 2016, that the NCR finding was made in February 2019 and that during that period of time Mr. Clements was in the community. Dr. Prakash adopted the evidence noted in exhibit 2 at page 13. Here, the Hospital Report indicates that the Hospital had some contact with a former director and shelter manager of the River City Vineyard Church and Community Centre – an important charitable services provider in Sarnia, Ontario, that Mr. Clements has been actively involved with as a volunteer for a number of years. That individual, Ms. Audrey Kelway, advised the Hospital that Mr. Clements had been working at the shelter for about three years. She explained that, over that period of time, he lived at the shelter. Ms. Kelway explained that while Mr. Clements’ involvement was initially as a volunteer, he was quickly placed into a paid position. Ms. Kelway described no mental health or management concerns whatsoever concerning Mr. Clements. To the contrary, she described him as an “amazing worker” with a “great heart”. She said that he is a “huge help for me.” She explained his duties, which include answering calls, greeting arrivals, providing direction, washing floors and cooking. She expressed a high level of trust for him, driven by over 3 years of daily experience and observation.
According to the Hospital Report, Ms. Kelway further advised the Hospital that Mr. Clements manages frustrations well. She said that he “talks a little quieter when he’s frustrated” and she indicated an absence of any sign of perseveration on his part. Framing her comments with the descriptor “supervision response”, the Hospital Report indicates that Ms. Kelway advised that Mr. Clements fulfills obligations and is accountable. He will also “happily pick up extra shifts.” Ms. Kelway confirned that Mr. Clements does not speak about mental illness. She indicated that she has “never” heard him speak about violence or threatening people. She described him as a “puppy dog.” She explained that Mr. Clements has been stable for the entirety of the time he has been at the shelter. He has his own private room and there is no limit on how long he may occupy that room so long as he continues to help at the shelter.
Ms. Kelway provided the Hospital with information pertaining to Mr. Clements’ personal supports. She described him as pro-social and positive. She provided the Hospital with information pertaining to Mr. Clements’ finances and his ability to manage his own affairs and deal with the stresses of daily living.
Dr. Prakash offered no evidence to contradict Ms. Kelway’s information. No evidence was produced that affected the credibility or reliability of Ms. Kelway’s report. Indeed, there was harmony between Ms. Kelway’s information, contained in the Hospital Report and adopted by Dr. Prakash at the opening of his evidence, and the evidence offered by Dr. Prakash himself. Dr. Prakash agreed that, since Mr. Clements’ admission to the Hospital in April, he has been pleasant and sociable with staff and peers. His thoughts were clear and organized. Referencing page 25 of the Hospital Report, Dr. Prakash testified that Mr. Clements’ behaviour was not “obviously bizarre”. He testified, in fact, that this drew into question the propriety of Mr. Clements’ previous diagnosis – schizophrenia – and speculated that Mr. Clements may have experienced symptoms of a delusional disorder or a schizo-affective disorder in the past, based on evidence of his having received communication and directions from Jesus Christ and the devil.
In response to questions from panel members, Dr. Prakash noted that since his admission to the Hospital Mr. Clements had not displayed any observable responses to internal stimuli and did not display thought disorganization. However, he indicated that there were some signs of grandiosity and paranoia including his statements of patented inventions and refusal to engage with the treatment team. Dr. Prakash testified that while there is a great deal of diagnostic uncertainty surrounding Mr. Clements, the Hospital is really only considering a delusional disorder at this point. In this regard, Dr. Prakash noted that Mr. Clements is again, not overtly psychotic, is pro-social, maintains strong beliefs relative to the role that God plays in his life and spirituality, and displays no difficulties with the dictates of daily living. While Dr. Prakash suggested that medication could reduce the intensity of any delusional symptoms Mr. Clements may be experiencing, it was unclear in the absence of signs of overt psychosis or negative psychotic symptoms what exactly proposed medications were to treat. In response to questions from the panel, Dr. Prakash testified that when considering Mr. Clements’ history and presentation, this was not a situation in fact where the Hospital was going to “jump to medications” but that they wanted to speak with him more openly about the possibility of a treatment regime to address possible symptoms of delusion or grandiosity that neither Ms. Kelway, the Hospital, service providers in Sarnia, or the Sarnia Police had noted over the past several years, including this most recent period of time when Mr. Clements has been in the highly-structured and monitored environment of the Southwest Centre for Forensic Mental Health Care.
Evidence of Mr. Clements
Mr. Clements indicated that although he believes in God, he does not get directions from God or speak directly to him. However, his faith includes a belief in things which he cannot see. The church he belongs to is connected to the shelter where he was residing prior to the NCR finding as well as prior to his apprehension in April. His desire is to return to his life at the shelter where he is able to provide valuable assistance to individuals in need. He referred to the evidence of the former Director who confirmed his employment at the shelter and his contribution to the work of the shelter. He also indicated that the current director wants him to return to work there.
Mr. Clements indicated that the mischief charge from British Columbia in 2016 related to his being angry because he was owed $3000 for work performed and acted out causing some damage. The suggestion that it had anything to do with the police being serial killers was absurd.
With respect to the incident alleged to have occurred at the Sarnia Library, Mr. Clements stated that he had did not know who the individual allegedly making the complaint was and did not understand the basis of the allegation.
In response to questions about why he was not engaging with the treatment team he indicated that his counsel had instructed him not to participate due to a contemplated appeal of his NCR finding.
Mr. Clements indicated that since no one contacted him after the Board hearing in April 2022 he thought the matter was concluded and agreed that he had made an assumption that the matter was concluded. Shortly thereafter he left to go to Halifax to look into a new business involving the anaerobic digestion of waste products. He returned to the Sarnia area after a little more than a year and returned to the shelter. Mr. Clements described his feelings associated with his work there. He described positive spirituality and prosocial associations both in terms of support that he received and the support that he provides and is paid to provide. He said that at the church he feels the love to the people there and the presence of God. He denied repeatedly that he had ever told anyone that he had received commands or command promptings from Jesus or the devil and clarified the circumstances that informed the index offences. He described having a series of dreams in close proximity one to another, three in total, that, after consideration, moved him to making the call to report the upcoming terrorist attack. He denied, however, that he was commanded to make the call or that he hears messages from the devil. He confirmed that he did not make a series of calls or engage in harassment or perseveration directed to the victim of the index offence – an individual in a position of authority that, one would presume, would not be subject to significant psychological harm as a result of a religiously-motivated individual’s call to report suspicion of a pending terrorist attack that, ultimately, does take place.
Mr. Clements focused his evidence on the issue of whether he represented a significant threat to the safety of the public. He highlighted that he has lived in the community for nine years, did not have any incidents of violence over the course of that time, worked, volunteered, and maintained pro-social relationships organized around his church, belief-system, and the supports he provided for others. He confirmed that he does not believe that he has a mental health issue and expressed appreciation for Dr. Prakash’s role, noting nonetheless that, in the context of an appeal of his NCR finding, Mr. Clements is following instruction from unidentified counsel in terms of exercising his right to remain silent in the forensic setting of the Ontario Review Board.
Analysis and Conclusion, Significant Threat:
We should note initially that we do not accept significant portions of the evidence of Mr. Clements. In particular, we do not accept his evidence that he was unaware of the decision of the board directing his detention. The Hospital Report indicates that shortly after the disposition was issued a series of intake meetings were scheduled with Mr. Clements and the Forensic Outreach Team and when the team attempted to complete the first of those meetings Mr. Clements was uncooperative indicating “I don’t even know why I am involved with you” and shortly thereafter he left his residence and changed his phone number. The only reasonable inference to be drawn is that Mr. Clements was aware of the disposition but was refusing to be bound by it.
We also do not accept his evidence with respect to his denial that he received directions from Jesus Christ and the devil with respect to the index offence. The Hospital Report notes:
According to Mr. Clements’ NCR report, he also told officers that “a higher power had told him about a potential terrorist attack and endorsed hearing voices. He said that a male voice, whom he alluded to as being the devil, directed him to contact police”. In the same report he also mentioned he “had conversations with Jesus, who had directed him to contact the German consulate or embassy.”
According to Mr. Clements’ self-report in his NCR report, he said the information about the terrorist attack “comes from my faith”. He said he had been a Christian for 50 years. He went on to state “I have a personal relationship with Jesus. He had a conversation with me. Jesus told me that I have to make this warning and make the call”.
- The Criminal Code defines significant threat to the safety of the public as follows:
For the purposes of section 672.54, a significant threat to the safety of the public means a risk of serious physical or psychological harm to the public - including any victim of or witness to the offence, or any person under the age of 18 years - resulting from conduct that is criminal in nature but not necessarily violent.
It should be noted that there is neither a burden of proof on the accused nor a presumption of dangerousness. Winko 1999 CanLII 694 (SCC), [1999 2 SCR 625]
In Mott our Court of Appeal has indicated that in determining the issue of significant threat, the Board must conduct a broad inquiry including myriad factors. In that case the court upheld a finding of significant threat and noted that:
In particular, the Board examined the appellant’s serious history of mental health and substance abuse issues, his lengthy criminal record, including assault, break and enter, and failures to comply, his paranoid and aggressive behaviour while in detention at the respondent facility, his resistance to treatment, including medications, his moderate to high risk scores on risk assessment tests, his breach of hospital rules, including attempting to abscond, and his lack of insight into the index offence, his condition and his need for treatment. The Board accepted the opinion of the appellant’s treating psychiatrist that the appellant posed a significant threat to public safety based on these factors.
We do not accept the appellant’s submission that the absence of violent behaviour on his part eliminates the risk of significant harm to the public.
One of the main factors relied upon by the treatment team in coming to the conclusion that Mr. Clements represents a significant threat to the safety of the public is their opinion with respect to his “history of violence” and in support of this conclusion they rely on his criminal history, the seriousness of the index offence and the recent allegations with respect to incidents at the Sarnia Library. We have serious concerns with respect to a conclusion that he has such a history.
Firstly, with respect to Mr. Clements’ criminal history, we note that although he was charged with criminal harassment in 1995, that charge was dismissed, and a peace bond was directed. Given that the court dismissed the charge, there is no evidence of criminal behaviour. In 2016 Mr. Clements was charged with mischief under $5000 but the charge was noted stayed in 2022. The allegations there involved solely damage to property and there is no information before the panel with respect to any serious physical and/or psychological harm to anyone.
With respect to the incidence from April 2025 at the Sarnia Library, it is noted on CIPIC that the matter had been “solved non-criminal” and there is no evidence of serious physical and/or psychological harm to any individual.
Although there is no doubt that the index offence was extremely serious with a potential for at a minimum serious psychological harm to individuals, there is little outside of that to support a finding that Mr. Clements has a “history of violence” which significantly undermines the opinion of the Hospital with respect to significant threat.
Although the absence of a significant or recent history of violence by itself is not determinative of whether an NCR accused poses a significant threat to the safety of the public is clearly relevant factor. Re: Carrick 2018 ONCA 752
It has been 8½ years since the Commission of the index offence and, although Mr. Clements has been continuously in the community since that time without any form of treatment for his possible schizophrenia spectrum disorder, there is no evidence of his involvement in any criminal behaviour resulting in serious physical or psychological harm to a member of the public.
Unlike the situation in Mott, Mr. Clements does not have a lengthy criminal record, history of aggressive behaviour while in detention, and breach of hospital rules including attempting to abscond or a history of substance abuse which could result in decompensation and problematic conduct.
In the Winko decision of the Supreme Court of Canada indicated at paragraph 57:
Section 672.54 provides that an NCR accused shall be discharged absolutely if he or she is not a quote “significant threat to the safety of the public”. To engage these provisions of the criminal code, the threat posed must be more than speculative in nature; it must be supported by evidence: D.H. v. British Columbia (Attorney General), [1994] B.C.J. No. 2011 (QL) (C.A.), at para 21. The threat must also be “significant”, both in the sense that there must be a real risk of physical or psychological harm occurring to individuals in the community and in the sense that this potential harm must be serious. A minuscule risk of a grave harm will not suffice. Similarly, a high risk of trivial harm will not meet the threshold. Finally, the conduct or activity creating the harm must be criminal in nature: Chambers v. British Columbia (Attorney General) (1997), 1997 CanLII 2978 (BC CA), 116 C.C.C. (3d) 406 (B.C.C.A.), at p. 413.
In our view the evidence is at best speculative with respect to a potential for serious harm as a result of conduct criminal in nature.
The Board finds that the evidence does not support a conclusion that Mr. Clements represents a significant threat to the safety of the public and accordingly is entitled to be discharged absolutely. Although it may well be in Mr. Clements’ best interest to engage with mental health professionals to clarify a potential mental health diagnosis, that is not the test we are required to apply.
DATED this 12^th^ day of August 2025, at the City of Toronto, in the Toronto Region.
Robert Bigelow
Alternate Chairperson
____________________________
Office of the Registrar
Ontario Review Board