REASONS FOR RULING ON APPLICATIONS

V. Christie

Overview

[1] The Applicant, Rasha Al-Enzi, brought two applications; one requesting a stay of proceedings in relation to her outstanding criminal charges, the other for judicial interim release pending trial on those criminal charges.

[2] At the outset of the hearing, after this court expressed some concern in relation to its jurisdiction to hear a stay application in relation to criminal charges that are still before the Ontario Court of Justice, the Applicant abandoned the stay application. Therefore, the matter proceeded as a bail review only.

[3] The Applicant argued that there has been a material change in circumstances since Justice McKelvey ordered the Applicant’s detention on a bail review decided on November 2, 2020. Primarily, the Applicant argued that the Central East Correctional Centre (“CECC”) did not comply with the Order of Justice McKelvey, which was to ensure timely steps were taken toward appropriate medical care, which has resulted in significant delays in a surgery required by the Applicant. The Applicant asked this court to consider her compromised medical condition, in light of the ongoing COVID-19 pandemic. The Applicant submitted that there is evidence before this court that CECC does not have the ability to perform proper post-operative care for the Applicant. Secondarily, the Applicant presented a new plan of release, in that the proposed pledge being offered is now increased to $100,000, and electronic monitoring is now available. The Applicant submitted the plan presented should satisfy any concerns this court may have on the secondary or tertiary grounds.

[4] The Respondent submitted that there has been no material change in circumstances. It was argued that CECC has taken all appropriate steps to ensure that proper medical care is being received in a timely fashion, however, they cannot control when doctors respond to them or when appointments are scheduled. The Respondent did concede that, if this Court finds that CECC was not diligent in complying with Justice McKelvey’s order, this would amount to a material change in circumstances; however, the Respondent pointed out that there was no evidence before this court that the Applicant’s medical condition has worsened as a result of any delay. Rather the condition has remained the same. Further, if this court finds that a material change in circumstances has occurred, the Respondent submitted that the Applicant has failed to meet their onus on release, as there remains secondary and tertiary ground concerns as recognized by Justice McKelvey.

Charges and Allegations

[5] The Applicant is charged with the offences of robbery with a firearm x3, kidnapping with a firearm, and conspiracy to commit an indictable offence x2. These offences are alleged to have occurred on April 30, 2020 and June 10, 2020.

[6] The allegations in relation to April 30, 2020 are that a group of males forced their way into a home in Stouffville. The men bound the wrists of the adult occupants and assaulted the adult male occupant demanding money. One of the men was armed with a handgun. When the adult occupants told the men they had no money in the house, the men put a bag on the male occupant’s head, and taped the mouth and eyes of the female occupant. The occupants were loaded into a van and taken to a Richmond Hill residence, where they were again assaulted. The Crown alleges that the Applicant was a party to these offences, in that she rented two vehicles matching descriptions of vehicles linked to the kidnapping, and rented the Richmond Hill Airbnb residence where the victims were taken.

[7] The allegations in relation to June 10, 2020 are that four or five males forced their way into a residence in Markham. One of the men was armed with a handgun. The male occupant was bound with zip ties around his wrists and ankles. The suspects demanded cash, took his phone and fled the residence. The Crown, again, alleges that the Applicant was a party to these offences.

[8] The Applicant was arrested on July 15, 2020 and has been held in custody at CECC.

[9] Dates have been set for a preliminary inquiry for July, September and November.

[10] The Applicant is, of course, presumed innocent and the question of bail must be decided with this firmly in mind.

Previous Bail Hearings

[11] On August 14, 2020, the Applicant’s bail hearing was held in the Ontario Court of Justice. Justice N. Dwyer issued a detention order.

[12] On October 15 and 16, 2020, the Applicant’s bail review application was heard before Justice McKelvey. The basis for the bail review was a purported material change in circumstances, in that 1) a different plan of release was presented, and 2) the Applicant suggested that her medical condition had gone untreated since the initial bail hearing, and the only way to have it properly treated was for her to be released to have the surgery performed and proper post-operative care. On November 2, 2020, Justice McKelvey denied the Applicant’s bail review application, confirmed the detention order, and ordered that “the Superintendent of CECC is to ensure proper and timely steps are taken for the appropriate consultations for the accused with her attending physicians and to see the surgical specialist. The issue should be reviewed at her next court attendance on November 10, 2020 at 9 am in 201.”

Background of Medical Issue

[13] On June 5, 2020, prior to her arrest, the Applicant saw Dr. Mohammed Elahi for breast pain and deformity. A letter from Dr. Elahi dated July 21, 2020 states as follows:

This 38 year old female was seen by me on June 5, 2020 status post prior breast surgery by another surgeon many years ago. She was complaining of severe pain and deformity in the bilateral breasts. My diagnosis was capsular contracture and I have recommended that the only way to deal with the pain and deformity is to perform another operation that would involve bilateral breast capsulectomy (removal of the scar tissue and the implants).

The pain is quite severe for her and I have told her that the only way to manage this would be surgery…

[14] The original date set for the Applicant’s surgery was August 20, 2020, however, prior to this date, the Applicant was arrested.

[15] On August 6, 2020, prior to the first bail hearing, Dr. Brent MacMillan, attending physician at CECC, sent a Health Care Consultation Note to the Applicant’s counsel indicating as follows:

Rasha Al-Enzi is currently an inmate @ Central East Correctional Centre in Lindsay ONT. She has a plastic surgery appointment with Dr. M. Elhani on [date omitted]. Our facility is not appropriate for mid September post-op care of this nature. I would support her release on medical grounds to facilitate the above.

Dr. MacMillan provided no support for his position. Dr. MacMillan has not been called as a witness at this bail review.

[16] On August 12, 2020, again prior to the first bail hearing, the Crown reached out to CECC for clarification on Dr. MacMillan’s letter and for clarification on whether the Applicant could still attend her surgery while detained. Marissa Wheal of CECC responded as follows:

I have spoken with Dr. MacMillan regarding his letter of support for the client in question. He *** that the surgery is not urgent, but is one that is not provided locally, and does required a significant amount of follow up post-surgery. It was booked prior to the clients incarceration.

[17] After further follow up by the Crown, Judy Santos, Deputy Superintendent of Programs at CECC (now Deputy Superintendent – Security Compliance) indicated that the CECC did not support the Applicant’s release and would find the Applicant an infirmary bed post-surgery. She stated:

Her appointment will be rescheduled and then we would be responsible to watch her in the hospital or get her to an infirmary within an institution.

She would still get the medical attention she needs but would not be made aware of the date of time of the appointment as that would be a breach of security.

[18] With the benefit of this information, the bail hearing proceeded on August 14, 2020. As previously stated, the Applicant was detained.

[19] According to Cathy Goard, Healthcare Manager at CECC, on September 16, 2020, persons at CECC spoke to Dr. Elahi’s office and were told that the Applicant required an ultrasound.

[20] On September 22, 2020, the CECC faxed a referral to Dr. Elahi’s office. This was a request for a pre-operative appointment with the specialist to review the MRI that she was to have and suggest whether surgery was needed or not.

[21] On October 15 and 16, 2020, the Applicant’s bail review was heard.

[22] On October 29, 2020, the Nurse Practitioner completed a review of the Applicant’s file and noted that the Applicant’s information had been faxed to the MRI department at Ross Memorial Hospital in Lindsay. An MRI was booked for December 24, 2020.

[23] On November 2, 2020, the bail review was denied.

[24] On November 9, 2020, Ms. Santos wrote a letter to the Crown, indicating as follows:

I understand that one of the issues raised at the bail review was that Ms. AI-Enzi had been scheduled for surgery in August to address a painful condition. This surgery was booked prior to her arrest and because of her detention, she was not able to attend the surgery. Since incarcerations the following has transpired in respect to Ms. AI-Enzi's medical condition:

The client is being followed by our Nurse Practitioner, Sylvia Arsenault. The Nurse Practitioner has been in contact with Dr.Elahi, who was going to complete the surgery on the client prior to her incarceration. Dr.Elahi ordered some testing to be completed prior to any surgical intervention. When that referral was sent over to the local hospital (Ross Memorial Hospital), the radiology department indicated that different testing would be required and sent the referral back to CECC. The Nurse Practitioner contacted Dr.Elahi, and had Dr. MacMillan, institutional doctor, to assist with ordering the necessary testing as indicated by the radiology department. The testing is booked for ***/20. This date cannot be shared with the client due to security reasons. Once the results of the test are known, Dr.Elahi will then proceed with a surgical date if necessary. The client will continue to be followed by our Nurse Practitioner as required as well as the rest of the Healthcare team.

If the surgery is necessary and is to take place while Ms. AI-Enzi is in custody, Central East Correctional Centre would be responsible to make sure she got the surgery and would look for an infirmary bed for her to recuperate. I can assure you that we are committed to treating inmates in a responsible, just and humane manner recognizing medical issues in a timely manner.

This letter was provided to counsel for the Applicant.

[25] On December 1, 2020, counsel for the Applicant wrote to the Superintendent of CECC requesting an update on the steps taken to comply with Justice McKelvey’s endorsement of November 2, 2020.

[26] On December 5, 2020, the Applicant complained of pain and was given an appointment with the Nurse Practitioner on December 10, 2020.

[27] On December 10, 2020, the Applicant was assessed by the Nurse Practitioner and informed that an MRI was booked but the date could not be shared with her.

[28] On December 24, 2020, the Applicant was taken for an MRI at Ross Memorial Hospital. The MRI report was reviewed by the physician and nurse practitioner at the CECC.

[29] On January 18, 2021, counsel for the Applicant wrote to the Superintendent of the CECC requesting (1) that the Applicant be transferred back to general population; and (2) an update on the steps taken to comply with Justice McKelvey’s November 2, 2020 order. On that date, an office administrator contacted the office of the specialist and left a voicemail to contact CECC, as the referral to the specialist had been faxed on September 22, 2020. The CECC responded to the request from Applicant’s counsel indicating that a referral to the specialist had been sent, and the CECC was awaiting an appointment for the Applicant.

[30] On March 5, 2021, Crown counsel requested an update from Ms. Santos. Ms. Santos indicated that (1) Dr. Elahi had not contacted the CECC with an appointment for the Applicant; (2) an office administrator was assigned to follow up with Dr. Elahi to see if an appointment had been booked; (3) the Healthcare Manager at CECC, Cathy Goard, booked the applicant to be seen March 9 to review the file to see if another surgeon would accept her as a patient.

[31] Later that same day, March 5, 2021, Ms. Santos spoke to Ms. Goard who stated that they had sent another fax to the specialist and followed up by voice message with no response. Further, Ms. Goard confirmed that she had just called the specialist again. This time, Ms. Goard spoke with the specialist, who stated he recommended surgery. Ms. Goard asked for the earliest date. A preoperative appointment was then booked for March 9, 2021 and an appointment for surgery on March 25, 2021. The specialist indicated that the Applicant needed to bring $4000 on March 9 to pay for implants.

[32] According to email correspondence provided, Ms. Santos and Ms. Goard spoke to Ms. Al-Enzi on March 8, 2021 in regard to her pre-op and surgery. She was advised that $4000 was to be paid by her to her surgeon.

[33] On March 9, 2021, the Applicant attended her preoperative appointment in Toronto. It was determined that the surgery would be day surgery in a hospital. The Applicant returned with information about post operative recovery. The instructions were no heavy lifting, no straining, dressing changes, wearing a supportive garment, antibiotics, pain medication and single accommodation. Ms. Goard confirmed that all of these things could be accommodated by the institution. Ms. Goard confirmed that they have a nurse practitioner and doctor. They have a full pharmacy. Dr. MacMillian would review the instructions from the hospital after surgery and develop a care plan. Ms. Goard stated that the Ross Memorial Hospital is approximately 7-10 minutes away if needed. Ms. Goard also confirmed that, at the institution, Ms. Al-Enzi has access to medical treatment 24 hours a day.

[34] The surgery scheduled for March 25 was never confirmed appropriately, therefore, it is no longer scheduled. Ms. Goard believed that on March 5 she had confirmed both the pre-op and the surgery, but when she followed up with Dr. Elahi’s office today, it was indicated that the surgery had never been confirmed and would not go ahead.

[35] The surgery is now scheduled for April 6. Ms. Santos assures this court that the surgery will go ahead, despite the fact that Ms. Al-Enzi is aware of the date.

Applicant and Sureties Proposed

[36] The Applicant is a 38-year-old Canadian citizen. She does have a criminal record. Apart from the charges subject to this bail review, she has no other outstanding charges at this time. The Applicant stated in her affidavit:

I have not seen a surgical specialist as ordered by Justice M. McKelvey on November 2, 2020;

The inability to have required surgery in a timely manner has caused and continues to cause me severe physical pain and emotional distress. I am fearful that my medical situation could dramatically worsen at any time due to inattention and become life-threatening. I am also extremely anxious that I will catch COVID-19 while in custody and that it will negatively impact my medical situation in unknown and life-threatening ways.

[37] The proposed sureties are Kevin Permaul and Neelawatie Permaul. Kevin Permaul is the ex-husband of the Applicant. He resides in a condo in Thornhill with his children and there is space for the Applicant to reside. He is an autobody specialist, but not currently employed; therefore, he could supervise the Applicant as required. Neelawatie Permaul is the ex-mother-in-law of the Applicant. She resides in Woodbridge with her husband. She is retired. The sureties are willing to pledge a total of $100,000 for this bail. Both sureties were questioned extensively before Justice McKelvey at the earlier bail review. Neither have testified on this review.

[38] The proposed plan of release would include conditions as follows:

a. Reside with surety and abide by the rules and discipline of the household;

b. Remain in residence at all times except for personal medical emergencies which require an ambulance or unless in the direct and continuous presence of a surety;

c. Accused shall at her own expense be subject to GPS monitoring by Recovery Science Corporation (RSC).

d. Do not contact or communicate directly or indirectly by any physical, electronic or other means, with Daron THOMPSON, Jaamar TAYLOR, Nicholas DUNKLEY and Floyd MORGAN except in the presence of legal counsel for the purpose of preparing a defence or during scheduled court appearances;

e. Do not possess any controlled drugs or substances except pursuant to a valid prescription from a physician;

f. Do not possess any weapons as defined by the Criminal Code of Canada; and

g. Do not possess or apply for any Firearms Acquisition Certificate and/or Firearms License

[39] The Applicant purports to have a good relationship with the sureties and promises to obey all conditions of a recognizance.

Material Change in Circumstances

[40] As to what amounts to a material change in circumstances, the categories are not closed and depend upon the specific circumstances of the case. In R. v. Daniels (1997), 1997 CanLII 3670 (ON CA), 35 O.R. (3d) 737 (C.A.), a bail pending appeal case, the purported material change consisted of more comprehensive legal arguments, including a new ground of appeal. Doherty J. held that these arguments will “seldom” amount to a material change in circumstances, however, it was sufficient in that case. The Court stated:

[43] Usually, subsequent applications based on an alleged change in circumstances depend upon some event which occurred between the initial application and the subsequent application. On occasion, subsequent applications are brought when a part of the trial record becomes available and adds significant weight to the merits of the appeal. Here, the alleged change in circumstances rested in large measure on the restatement in a more comprehensive form of legal arguments made on the first application. In addition, one new argument was put before Laskin J.A. I agree with Laskin J.A. that these kinds of arguments will seldom amount to a material change in circumstances justifying release. I would not, however, interfere with the conclusion of Laskin J.A. that this was one of those rare cases where a rearticulation of arguments previously made supplemented by a new ground of appeal amounted to a material change in circumstances which affected the outcome of the public interest inquiry required under s. 679(3)(c).

These comments by the Court of Appeal would suggest that the types of things that will amount to a material change in circumstances are fairly broad.

[41] A number of years after Daniels was decided, the Court of Appeal offered some further guidance, and held that the changes must address the considerations that underpinned the original bail judge's decision. In R. v. Whyte, the court held as follows:

[25] Courts have recognized that a material change in circumstances will warrant judicial interim release where, for example, in the bail pending appeal context, additional sureties become available, R. v. Baltovich (2000), 2000 CanLII 5680 (ON CA), 47 O.R. (3d) 761 (Ont. C.A. [In Chambers]), or where the applicant offers a new legal argument and rearticulates existing arguments in a more comprehensive form, Daniels, supra.

[26] In my view, the assessment of whether a material change in circumstances exists in a particular case depends on the actual considerations that underpinned the first bail judge's refusal of bail. In other words, the issue is whether the change in circumstances is relevantly material.

See also R. v. C. (A.A.), 2015 ONCA 483 at para. 56

[42] It is the view of this court that no material change in circumstances has occurred.

[43] It was this court’s impression that Ms. Goard attempted to downplay the lack of follow-up on the part of the institution. Clearly steps taken in January and March were triggered by counsel and the Crown. Having said that, steps were taken.

[44] While this court accepts that the steps taken by CECC were somewhat less than perfect, that is not the standard they should be held to. CECC was Ordered by Justice McKelvey to “ensure proper and timely steps are taken for the appropriate consultations for the accused with her attending physicians and to see the surgical specialist.” Since Justice McKelvey’s decision, the following steps have been taken:

a. The Applicant has continued to be followed by Nurse Practitioner, Sylvia Arsenault, and Dr. MacMillan.

b. On December 5, 2020, the Applicant complained of pain and was given an appointment with the Nurse Practitioner on December 10, 2020.

c. On December 10, 2020, the Applicant was assessed by the Nurse Practitioner and informed that an MRI was booked but the date could not be shared with her.

d. On December 24, 2020, the Applicant was taken for an MRI at Ross Memorial Hospital. The MRI report was reviewed by the physician and nurse practitioner at the CECC.

e. On January 18, 2021, counsel for the Applicant wrote to the Superintendent of the CECC requesting an update on the steps taken to comply with Justice McKelvey’s November 2, 2020 order. On that date, an officer administrator contacted the office of the specialist and left a voicemail to contact CECC as the referral to the specialist had been faxed on September 22, 2020. The CECC responded to the request from Applicant’s counsel indicating that a referral to specialist had been sent, and the CECC was awaiting an appointment for the Applicant.

f. On March 5, 2021, Crown counsel requested an update from Ms. Santos. Ms. Santos indicated that (1) Dr. Elahi had not contacted the CECC with an appointment for the Applicant; (2) an office administrator was assigned to follow up with Dr. Elahi to see if an appointment had been booked; (3) the Healthcare Manager, Cathy Goard, booked the Applicant to be seen March 9 to review the file to see if another surgeon would accept her as a patient.

g. Later that same day, March 5, 2021, Ms. Santos spoke to Ms. Goard who stated that they had sent another fax to the specialist and followed up by voice message with no response. Ms. Goard then confirmed that she had just called the specialist again and spoke with the specialist who booked a preoperative appointment for March 9, 2021 and an appointment for surgery on March 25, 2021. The specialist indicated that the Applicant needed to bring $4000 on March 9 to pay for implants.

h. Ms. Santos and Ms. Goard spoke to Ms. Al-Enzi on March 8, 2021 in regard to her pre op and surgery. She was advised of the cost of $4000.

i. On March 9, 2021, the Applicant attended her preoperative appointment in Toronto.

j. The surgery is scheduled for April 6, 2021. Ms. Santos assures this court that the surgery will go ahead, despite the fact that Ms. Al-Enzi is aware of the date.

[45] This court agrees that the institution could have been more proactive about following up with Dr. Elahi following the MRI on December 24, 2020. Further, it appears that the follow-up on January 18, 2021 was only triggered by a request from counsel for the Applicant. Regardless of the triggering event, CECC did follow up when contacted by counsel for the Applicant. CECC then received no response from Dr. Elahi. This court agrees that the institution could have been more proactive about following up with Dr. Elahi following January 18, 2021. However, it was only when the Crown reached out to CECC on March 5, 2021 that steps were taken by CECC to follow up on the earlier request. These follow-ups have resulted in a pre-op appointment being held and a scheduled surgery which is coming up in about two weeks.

[46] There is no evidence that the Applicant’s medical condition has worsened in the intervening time period. In submissions, counsel for the Applicant stated that there has been a continued decline in her health as a result of the failure to receive medical treatment as ordered. However, this is simply not the evidence before this court. While the Applicant does express some concerns in her affidavit, she does not state that her medical condition has worsened.

[47] As for the Applicant being able to have surgery and get appropriate post-operative care while at CECC, these issues were all before Justice McKelvey. Apart from some delays, nothing has changed. If anything, the situation has improved. An MRI was scheduled and conducted. A pre-op appointment was completed. A surgery is scheduled for April 6, 2021.

[48] As for post-operative care, this court is confident that the Applicant can receive appropriate care at the institution. The only thing to suggest otherwise is a note from Dr. MacMillan in August 2020, however, that note does not say that the Applicant cannot receive appropriate post-op care at the institution. The note states, “Our facility is not appropriate for mid September post-op care of this nature.” It seems to be focused on the timing of the events as opposed to some inadequacy on the part of the institution. Surprisingly, Dr. MacMillian was not called to provide clarification of his note or his current position. All other evidence on this application suggests that the Applicant will get complete post-operative care.

[49] This court has also been provided with a “Response to COVID-19 Information Note” dated March 17, 2021. As of that date, with respect to the inmate population, CECC reported 2 positive cases, 12 resolved in custody (in that the inmate was no longer considered positive), and 6 positive cases released from custody. The Information Note sets out various protective measures which are in place at institutions such as CECC. As for the staff, CECC reported no ongoing cases and 4 resolved cases. There has been no suggestion that Ms. Al-Enzi’s medical condition places her at an increased risk of contracting the virus. COVID-19 is certainly not a material change in circumstances in this case, as the pandemic had been ongoing for some time before the first bail hearing and certainly by the time of the bail review.

[50] As for the new plan of release, these options were all available to the Applicant at the first bail review. In fact, electronic monitoring was even mentioned. This is not a material change.

[51] For all of the foregoing reasons, this court is not satisfied that a material change in circumstances has occurred. As previously stated, while the efforts of CECC could have been better, this court must assess the circumstances in light of the situation as it stands today. It is the view of this court that Ms. Al-Enzi is in a better position today than she was at the time of her bail review, as far as having her medical issues resolved. Surely, this cannot be a change in circumstances which is relevantly material to the question of bail justifying a review of the detention.

Grounds for Detention

[52] Even if a material change in circumstances existed, this court would still not grant bail in this case.

[53] With respect to the secondary ground concerns, Justice McKelvey expressed some concerns with the sureties’ ability to supervise, but his main concern appeared to be related to the criminal record. he stated as follows:

[38] A very serious issue in this case is the accused’s criminal record. It is lengthy and concerning. It dates back to 2003 and runs until 2017. She has been convicted of numerous criminal charges. Many of these involve crimes of dishonesty. For example, in January of 2007, the accused was arrested for fraud and was brought to the police station. At the time of her arrest, the accused was in possession of various pieces of personal identification in the name of her sister. She claimed to be the person on the identification papers. On the following day she attended bail court and was released on a recognizance with conditions. The name on the recognizance was her sister’s name as the accused continued to claim this as her name.

[39] Her past convictions are spread over a lengthy time period. There were convictions for multiple offences in 2003, 2005, 2006, 2007, 2012, 2014, and 2017.

[41] It is significant that two of the bail breaches occurred when the accused was under house arrest conditions…

[42] While the evidence of the two proposed sureties does provide an enhanced plan for supervision, this does not satisfy me that the accused has satisfied her onus on the secondary ground. Having suitable sureties is only part of the consideration for this Court. The other part is whether the person being released on bail is willing to comply with the conditions. In her evidence at the review hearing, the accused testified that the seriousness of the charges and the authority of the proposed sureties as well as her current medical condition and the current COVID-19 pandemic, together with the time she has been detained would motivate her to strictly adhere to a recognizance of bail. However, in my view the accused’s past history is a more reliable indicator of the risks associated with her release…

[54] Justice McKelvey referred to the fact that, during the course of the hearing, one of the sureties suggested that she was prepared to pay for electronic monitoring. However, given that this option had not been originally presented or fully explored, Justice McKelvey did not consider this as an option.

[55] In the present bail review, electronic monitoring has been now formally offered as a proposed condition of release. Electronic monitoring is not foolproof. The system itself can fail or be tricked. Further, electronic monitoring does not prevent a breach of a condition and is really an after-the-fact, reactive system, rather than a proactive one. This court is not convinced that electronic monitoring would have any deterrent effect on Ms. Al-Enzi.

[56] As for tertiary grounds, absolutely nothing has changed since Justice McKelvey’s decision, as conceded by the Applicant. At paragraph 52 of his decision, Justice McKelvey described the circumstances of the offences as “extremely serious and include the alleged kidnapping and confinement of an entire family including three children at gun point. The evidence of the accused participation is circumstantial, but very strong. The circumstances of the charges involve the use of firearms and if convicted the Criminal Code provides for a sentence of up to life imprisonment.” These circumstances remain.

Conclusion

[57] For all of the foregoing reasons, bail is denied.

Justice V. Christie

Released: March 24, 2021

R. v. Al-Enzi, 2021 ONSC 2224

Case Summary

REASONS FOR RULING ON APPLICATIONS

Overview

Charges and Allegations

Previous Bail Hearings

Background of Medical Issue

Applicant and Sureties Proposed

Material Change in Circumstances

Grounds for Detention

Conclusion

Judge

Counsel

Parties

Areas of Law

Fact Patterns

Issues

Legislation 1