On November 16, 1999, a legal action was started against
    our family by kidnapping our child - an apprehension to
    use the legal euphemism.

    Before we knew anything about it, Tina Berryman, an
    employee of Molly Maid who had cleaned our home once,
    made a complaint.  Our home is too large for my wife
    Linda and me to clean, so we have a maid service.  Tina
    Berryman has no statement on record, only a paraphrase
    by a social worker.  It appears the maid was appalled
    that the house needed cleaning when she arrived.

    On Tuesday November 16, around 10 am, two people showed
    up at our door wearing smiles but clearly hostile,
    inviting themselves into our home.  I refused them
    permission to enter.  There were a few words exchanged,
    in which they identified themselves as representatives
    of Children's Aid with a complaint that there was a lock
    on our child's door.  I ended the discussion by closing
    the door.

    At 6:15 pm the same day, two policemen came with a woman
    from Children's Aid, showing a warrant authorizing them
    to apprehend our son, Ken aged 3 years.  I respected the
    warrant, but declined to answer any substantive
    questions until talking to a lawyer.  After my wife
    talked to the police for an hour, one of the policemen
    told me our child would be left with us if I removed a
    broken crib from Ken's room, otherwise Ken would be
    taken to a foster home.  I retreated to my office to
    call a lawyer, but since the raid was after business
    hours, it took 15 minutes.  I removed the crib and they
    took Ken anyway.  I gave him a goodbye hug and he was
    gone.  They did not really suspect abuse, because they
    did not examine Ken before taking him.

    Linda got to visit Children's Aid on Wednesday and
    Thursday, on the second visit they even let her visit
    Ken for a while.  She took a toy and clothing for Ken
    both times and recognized when Ken was having a bowel
    movement, requiring her to leave for a clean diaper.
    These facts were misrepresented in the CAS affidavits.

    We got a lawyer, Evelyn Huber, to represent us and
    Friday morning we were informed that Children's Aid
    intended to apply for crown wardship, meaning that we
    would never see Ken again.  I am a graduate of six
    foster homes and two boarding schools, and I know from
    personal experience just what a nightmare they are.  Our
    care of Ken was heaven compared to that.

    The next Monday at 10 am we went to the Orangeville
    Courthouse with our lawyer, and she worked out a consent
    agreement with Children's Aid, under which we could get
    Ken returned in nine days provided we complied with six
    listed conditions.  As part of the consent, we were
    permitted to visit Ken for one hour each weekday.

    At 3 pm I saw Ken for the first time since his
    abduction, Linda for the second time.  We had to enter a
    building with a sign affixed to the window "Lesbian and
    Gay Positive Space", and in smaller type, "This is a
    place where human rights are respected, and where gays,
    lesbians, bisexuals, their friends and allies are
    welcomed and supported".  Every door has a locking
    mechanism, many operated by remote control.  Ken
    entered, and we were ushered to a closed room with a
    one-way mirror allowing observation from the adjacent
    room (it had open blinds on it), several surveillance
    cameras and concealed microphones.  Ken had a sad-sack
    look, more depressed than any I had ever seen before.
    It took him a half-hour to regularly smile.  When he
    realized that we were leaving, he cried intensely in a
    way that we had never seen before.

    For six more consecutive weekdays we saw Ken under the
    same conditions.  Later, Kim James filed thousands of
    words of affidavits using our visits as evidence against
    us.  On Tuesday Ken's spirits were improved.  Children's
    Aid had agreed Monday to let us take Ken for a haircut,
    but Kim James reneged.  After Wednesday's visit two
    social workers, Kim James and Nina Little, met with us.
    Kim opened the questioning by asking "How do you feel?".
    That was quite a question from a kidnapper.

    On Tuesday November 23, a reporter from the Toronto Sun,
    Jean Sonmor, visited us at home to get our side of the
    story, and on Wednesday she called Children's Aid, to
    get their side.  Also on Wednesday, our lawyer called
    with a gripe that there was material on the internet
    about our case that Children's Aid considered libelous.
    Hard to understand, because most of what I had posted
    was merely verbatim copies of their documents.  Still, I
    sent them an email offering to correct any libels (copy
    below).  They did not respond, but the next day's
    treatment may be their response.

    On Thursday we met Ken at 3:15 pm for an hour.  During
    the session I took a too-loud toy cell phone from Ken,
    ignoring his 20 second tantrum, then he climbed
    contentedly onto my lap.  Kim James and her supervisor
    Kim Evans came in after the visit and questioned us
    about the six conditions in our consent.  We were in
    compliance with all, except that the day-care
    arrangements were under way and not yet completed.  Then
    they asked questions unrelated to the consent, and after
    five minutes I suggested that Linda should stop giving
    answers outside the scope of the consent.  Switching
    from friendliness to hostility, they said they would
    find us not in compliance with the consent and announced
    that they were going to proceed with crown wardship
    taking Ken from us permanently.  When Ken cried today,
    they said, I did not comfort him.  So we had
    accomplished nothing.  Reviewing the agreement, the
    writing did not get us Ken back December first, that was
    merely their oral promise.

    That evening I had to call a suicide prevention line to
    get help for my wife, and later drove her to the
    hospital emergency room for sedatives to make it through
    the night.  To maintain family harmony, I had to end all
    efforts at exposure through the press or the internet.

    Friday we saw Ken for another hour uneventfully.  On
    Monday we saw Ken again, this time with Linda's brother
    Eric, who had flown in from Denver to lend his support
    during the family crisis.  Ken attacked the Venetian
    blinds in the CAS office, and to rebut the contention of
    Children's Aid that Ken's destructiveness was our
    illusion, I did not interfere with him as I otherwise
    would have.  In the CAS account of this event they fear
    a danger that could only occur if I sat by doing nothing
    while my son choked to death.  Tuesday's meeting with
    Ken was in the same room with the still-broken blind,
    but otherwise uneventful.

    On Wednesday, we went to the courthouse to get our son
    returned.  CAS added a blizzard of new documents to the
    case, and demanded that he be kept in custody for
    several more months.  This precluded an agreement, but
    no judge was available to hear the case, even after an
    all-day wait.  However, the next afternoon, Thursday
    December 2, 1999, a judge did hear our case and ordered
    Ken returned to our custody immediately.  Ken was freed
    at 4:30 pm.  From Ken's speech, I inferred that he was
    fed waffles in captivity.

    On December 7 we took Ken to see Dr Murphy, in
    compliance with the judge's conditions.  I took along a
    large clear plastic garbage bag filled with a quarter
    cubic meter of toys that were in the home at the time of
    the raid, though I could have taken three such bags.  We
    got there 20 minutes early, time that Ken spent
    cheerfully playing with toys.  As soon as Dr Murphy
    entered the room, Ken became sullen and uncommunicative.
    Dr Murphy asked "Where's your belly-button?", and Ken
    just cried.  It took him two minutes to respond by
    showing the doctor his stomach.  Afterwards I inquired
    why Ken's attitude was so negative, but Dr Murphy
    insisted that his previous meeting with Ken had gone
    well.

    The CAS affidavits up to this point made many
    allegations too broad to characterize as true or false,
    but eleven of the definite facts alleged by Kim James
    and eight of those by Trish Cox, even basics such as
    names and phone numbers, were false to my personal
    knowledge.  Paulette Smith denied making the statements
    attributed to her in the affidavit supporting the
    warrant.

    On January 19, 2000 a consent agreement was worked out
    at the courthouse ending the claim for crown wardship,
    but with a finding that Ken is in need of protection.  I
    would have chosen to litigate before a judge in
    preference to the consent, but that would have been too
    damaging to the family without Linda's approval.  This
    left us open to Children's Aid marching an army of
    social workers into our home (three visits a week on
    average) indefinitely.  If we object, we become repeat
    offenders, enhancing their chances of getting Ken into
    an orphanag...  oops safe home.

    The attitude of CAS, and research into the law,
    convinced me to pursue political remedies.  An exchange
    of letters starting with my elected representative in
    the provincial parliament, David Tilson, was a dead end.
    In January I found that anyone could become a member of
    Children's Aid by paying three dollars, and did so.
    Shortly thereafter, CAS sent us an intimidating letter,
    threatening to put us on the Child Abuse Registry.  From
    this, and other actions, I know CAS understands that
    they can not intimidate me, but can scare Linda.  She
    was terrified, so I had to proceed slowly.  As a member
    I requested a copy of the bylaws, finding that CAS has
    17 directors, 12 elected by the members, and 5 appointed
    by local politicians.  I addressed Mono Council on this
    subject on March 8, 2000.  As a CAS member I requested a
    membership list, finding that before I joined, there
    were just 32 members.  The bylaws give members the right
    to attend board of directors meetings, and on April 19,
    2000 I did so.  It was a chilling experience - all of
    the atrocity planners did so with unbroken smiles.
    There I learned that the annual general meeting of CAS
    was to be on June 20, 2000.  The bylaws provided for a
    cutoff date of at least 30 days before the meeting;
    only members as of that day are eligible to vote in the
    election.  In the month up to the cutoff date, still not
    using newspaper publicity, I signed up as many members
    as possible and on on May 18, 2000 I deposited papers
    with CAS nominating Lillian Brewer and me as candidates
    for director at the annual meeting.  From this point on,
    CAS workers and David Thwaites lost their smiles in
    dealing with me.  I sent out proxy solicitations to the
    32 original members, and got to the meeting with three
    members loyal to our side, and 12 proxies.  Before the
    meeting Linda suggested alerting the Orangeville Banner,
    breaking press silence.

    The president of CAS and meeting chairman, Mark Van
    Horne, treated us like adversaries in a court
    proceeding.  We found out that CAS had recruited 40 new
    members.  According to Patti Lowe, a member of our team
    who helped count the votes, they were mostly social
    workers and policemen.  The vote count appears in
    sequence below.

    The day after the meeting, CAS filed a new set of court
    motions, apparently designed to keep us in court
    forever.  They moved to compel us to attend an
    assessment at Chedoke-McMaster hospital, and scheduled a
    motion to be heard a week later extending supervision
    for another six months.  The supporting affidavits
    suggested that all of Ken's development while growing up
    was the result of successful intervention by CAS.  In
    this second round of litigation, they were much more
    brief and accurate, avoiding the petty factual errors of
    the first round.

    At the oral hearing June 28, 2000 both David Thwaites
    and Evelyn Huber spent most of their time putting
    different spins on a letter from Dr Bakht.  He did not
    agree with the paraphrase by Trish Cox.  Trish Cox had
    an assistant, Jennifer Diamond, with her before the
    lunch break.  Another lawyer, Gillian Shute, a friend of
    Evelyn Huber sat in on the hearing after the lunch
    break.

    In his opinion, Judge Allen noted that there was
    resentment of CAS by McQuaid, then he went into the
    entry onto the Child Abuse Register as a justification
    for the resentment.  He dismissed the CAS motion to
    compel the Chedoke-McMaster assessment.

    On July 5, 2000 there was another hearing, again before
    Judge Allen.  An assistant substituted for David
    Thwaites.  The subject was the motion by CAS to extend
    the supervision by six months.  The two lawyers
    explained that the business before the court was setting
    a date for the trial on the extension, probably in four
    months, with vive voce evidence.  The dispute today was
    whether the supervision would remain in force during the
    period up to the trial.  On his own initiative, Judge
    Allen requested the two parties to consent to trying the
    issue of the extension of supervision using the existing
    record.  David Thwaites might have refused, but after a
    ten minute recess, both sides agreed.  The lawyers
    commented on the record, CAS claiming the need for
    continued supervision to ensure implementation of Dr
    Bakht's recommendations.  The judge again criticized CAS
    for putting us on the Child Abuse Register, and noted
    that the parents could take care of Kenneth without help
    from CAS.  He dismissed the supervision order
    immediately.  So we did not even have to wait until July
    19 to be free.


    I welcome calls from readers in Dufferin County who have
    had experience with CAS, or who are willing to help
    reform CAS.  Call me, Robert T McQuaid, phone
    519-942-0565, or email rtmq@hurontario.net

    --------------------------------------------------------

    Document contents

    - description of our home and case discussion
      1999
    - Nov 16  warrant and supporting affidavits
              information by Kimberly James
              affidavit by Kimberly James
    - Nov 19  application for child protection
    - Nov 19  affidavit of Kim James
      A       information by Kimberly James
      B       notes by Jim Dickson.
      C       photographs
      D       assessment by Nina Little
      E       letter by Dr Ron Murphy
    - Nov 22  affidavit by R T McQuaid
    - Nov 22  consent order
    - Nov 24  email responding to libel allegation
    - Nov 26  letter to David Tilson, MPP
    - Nov 29  affidavit of Kim James
      A       (copy of Nov 22 consent, omitted)
      B       letter from foster mother
      C       Risk assessment
      D       safety assessment
    - Dec  2  affidavit of Kim James
    - Dec  1  affidavit of Linda Prosh
      A       photographs, omitted
      B       letter of Dr Stephen G Ross
    - Dec  2  affidavit of R T McQuaid
    - Dec  2  notes of Judge Allen
    - Dec 16  Ages and Stages test, Nina Little Alcorn
    - Dec 20  Brigance Pre-School Screen by Joyce Cook
    - Dec 21  affidavit of Trish Cox
    - Dec 22  Adjournment request
      2000
    - Jan 19  consent order
    - Jan 25  advertisement in Orangeville Banner
    - Feb  2  Concerned Parent in Orangeville Citizen
              comment by RTMQ
    - Feb  9  Cover letter for bylaws
    - Feb  9  letter from Minister of Community and Social
              Services
    - Feb 10  Letter from Chedoke-McMaster
    - Feb 16  Gary Putman in Orangeville Citizen
              comment by RTMQ
    - Mar 28  Entry onto Child Abuse Register
    - Jun  5  Letter soliciting proxies
    - Jun 23  Article in Orangeville Banner on CAS meeting
    - Jun 21  Cumulative Table of Contents
    - Jun 21  Application status review
    - Jun 21  Affidavit of Trish Cox
      A       May 31 Report of Nina Little Alcorn
      B       Jun 15 Report of Kindrey Rowland
    - Jun 21  Notice of Motion to compel assessment
    - Jun 21  Summary of Court Cases
    - Jun 26  Affidavit of Trish Cox
      A       Feb 10, 2000 Chedoke-McMaster letter to CAS
    - Jun 27  Answer
    - Jun 27  Affidavit of Robert McQuaid
      A       Jun 26, 00 letter of William Weiner
      B       Jun 22, 00 letter of Deborah Launspach
      C       email of January 29, 2000 RTMQ to CAS.
      D       CAS letter to Prosh on Child Abuse Registry
      E       Brigance Pre-School Screen,  Dec 20, 1999
      F       Ages and Stages test, Dec 16, 1999
    - Jun 27  Letter of Dr Bakht
    - Jul  4  Affidavit of Trish Cox
    - Jun 25  Original draft of affidavit
    - Jul 10  Letter to John Baird
    - Aug 10  Letter from Vince Tedesco
    -         Epilogue
    -         Name Index and Glossary

    --------------------------------------------------------

    Description of our home and case discussion.

    In 1999 Ken had a behavior I call a rampage.  Linda
    alluded to it with Kim James, who then misrepresented
    it.  During a rampage, Ken threw objects, hit people,
    tipped things over, knocked things out of the grasp of
    adults, and later added spitting and biting.  This
    developed from age 18 to 30 months.  Our response was to
    remove dangerous items from the area where he runs free
    and to lock him away from things not for him, such as
    computers.  The most controversial lock was the one on
    his room.  Following age two years, this lock confined
    him during periods of rampage (three uses a week was
    typical), and as he became more adept at picking outside
    locks, we locked it every night to avoid finding him
    dead in the pool in the morning.  Otherwise, Ken roamed
    through about 1000 square feet, larger than many
    apartments, with windows on three sides, he could (and
    did) get my attention at any time by opening my office
    door, or banging it if locked.  We managed to keep
    things under control everywhere except in his own room,
    where he routinely disassembled his bed, the closet
    doors, crib, carpeting and heating vents.  He pulled on
    the curtains, leaving an exposed curtain string far out
    of his reach, and there was a missing globe on his lamp,
    also far out of his reach.  Karen Bowers, of Friends at
    Hand-in-Hand daycare, gave me the cause of the problem
    (which I will not repeat) and I was able to work out a
    treatment.  Within a few weeks I stopped the biting and
    spitting, the other symptoms disappeared gradually over
    four months.  Aside from Karen Bowers and William
    Weiner, the advice and opinions of all the professionals
    involved in this case have been worthless.

    The CAS legal case started out as:
    1  we kept Ken locked in his room most of the time
    2  our home is so filthy as to be a health hazard.
    After raiding our home and making jailhouse
    observations, they added:
    3  our home is dangerous
    4  Ken suffers from developmental delays.
    Large amounts of mud-slinging were included.

    (1) The lock on his door was used as above.

    (2) We do not live with the level of filth alleged by
    CAS, instead our home is bug-free.  Neither of us are
    excessively neat, that is why we hired a maid.  I clean
    the kitchen daily, between cleanings things pile up.  On
    days the maids came, I didn't clean the kitchen at all.
    I clean all food accidents outside the kitchen
    immediately.  We have never had mold in our home except
    for spoiled food at the back of the fridge.

    (3) The safety allegations consist of calling anything
    out of place a hazard, no matter how far-fetched.  A
    missing globe on a lamp, and an exposed curtain rod,
    both out of the child's reach, were cited as hazards.
    The missing heating grates were more of a hazard to
    adults than to children.  In studying this kind of
    litigation, something I never did before the raid, it
    appears that false filth and safety allegations are
    commonplace.  Children's Aid missed for weeks the real
    hazard, from which Ken was well protected by multiple
    locks - the swimming pool.

    (4) On complete evaluations of Ken's development, he is
    at or above the average level for his age.  The
    developmental delays were alleged by reporting only
    those test items on which he failed.  CAS never noticed
    the contradiction in claiming that our home was so
    cluttered as to be a hazard, yet too bare to allow for
    development.



    Here are a few more facts about our home:

    During the raid, the police let Ken into the kitchen,
    Ken grabbed a knife, an apple from the fridge, then ate
    the apple, leaving uneaten parts around the house, all
    things we would never allow while in control of our own
    home.

    The living room lamp was broken by Ken two days before
    the raid and repaired one day after.  An earlier
    three-day loss cured him of TV molestation.

    Neither of us have ever spanked Ken.  The buttocks
    scratches noted in a report occurred most likely after
    Ken was in custody.

    In September we decided Ken needed more contact with
    other children, so we tried to enroll him in day care,
    but all day care facilities were booked up.

    In October I trimmed branches from a tree to avoid roof
    damage.  One protruded 20 cm across a 1 meter walkway,
    to a door we never use.  There is a bizarre CAS account
    of this below.

    From family history, we knew that there was an even
    chance that Ken inherited color blindness at birth.  We
    tried to detect his condition by teaching him colors
    early.  In the CAS accounts, this is a form of abuse.

    Neither Linda nor I are devoted to big ceremonies.  When
    we got married, it was before a Justice of the Peace
    with just two witnesses.  When Ken had his third
    birthday, Linda gave him two inexpensive toys, and we
    sang him happy birthday.  He is too young to understand
    what a birthday is.  Linda forgot even this under the
    stress of the police raid.

    In her affidavit Kim was shocked to find there was food
    on the table at supper time.  Even by her account Ken
    was not hungry.

    The Parent Infant Programme pamphlet referred to in the
    affidavits starts with a letter over the signature and
    picture of single-mother Rosie O'Donnell.  It refers to
    a child of unspecified gender with the pronoun she.  The
    word caregiver, not in any dictionary before the era of
    political correctness, appears in the pamphlet
    repeatedly.  Alleging a scientific fact without a
    citation is the opposite of science - the pamphlet does
    it twice.  The full text is at:
    http://www.iamyourchild.org/qualitycare/index.html

    Most of this text is verbatim transcripts of the court
    documents, primarily the Children's Aid case.  To avoid
    slanting the case I show all documents filed except the
    photographs and notes of OPP officer Jim Dickson.  I
    have typed the documents exactly, even with the
    unbalanced quotes, missing paragraph xi, and duplicate
    paragraph 4.  Computer checking shows that most of the
    errors in grammar and spelling are from the original
    documents, not the transcription.  I tediously include
    captions and jurats, because of their value to others
    litigating the same CAS, and to show that CAS got basic
    facts wrong such as McQuaid's phone or Huber's address
    and law partner.  For brevity, I start some documents
    with "CAS letterhead", or "CAS memohead";  the glossary
    contains the pre-printed wording.  Long documents have
    the name of the author and date in brackets before
    paragraphs;  these notes are not part of the court
    record.

    --------------------------------------------------------

    Ontario Court of Justice
    at 10 Louisa Street, Orangeville ON L9W 3P9

    Court File Number 180/99
    Family Law Rules, O.Reg. 114/99

    Form 33A; Warrant to Apprehend Child

    TO ALL CHILD PROTECTION WORKERS AND PEACE OFFICERS IN
    THE PROVINCE OF ONTARIO:

    On the basis of an information sworn before me under
    Part III of the Child an Family Services Act respecting
    the child named or described at the bottom of this
    warrant, I am satisfied that there are reasonable and
    probable grounds to believe:

    (a) that the child is in need of protection;  and (b)
    that a course of action less restrictive than the
    child's removal to a place of safety is not available or
    will not adequately protect the child.

    I am further satisfied, on the basis of that
    information, that the child may now be found at LOT 5
    CON 4 EHS MONO TOWNSHIP.

    I THEREFORE AUTHORIZE YOU TO BRING THIS CHILD to a
    "place of safety" within the meaning of the Child and
    Family Services Act.

    This warrant expires at 5:00 am on November 17, 1999

    /signed/ G Funston     November 16, 1999
    Justice of the peace County of Dufferin

    NOTE:  Any changes, alterations or corrections to this
    form must be initialled by the justice of the peace.  It
    is a criminal offence for any other person to change the
    wording of this warrant after it has been signed by the
    justice of the peace.

    DESCRIPTION:

    Full legal name of child to be apprehended
      KENNY McQUAID/PROSH
    Birth date   APPROX 3 YRS
    Sex  M
    Residential address  LOT 5 CON 4 EHS MONO TOWNSHIP
    Telephone number  940-9847
    Present whereabouts of child  AT RESIDENCE

    FLRO 33A (08 99)

    ........................................................

    Ontario Court of Justice
    at 10 Louisa Street, Orangeville ON L9W 3P9

    Form 33:  Information for Warrant to Apprehend Child

    My name is KIMBERLY JAMES
    I live in DUFFERIN COUNTY, ONTARIO
    and I swear/affirm that the following is true:

    1.  I am a child protection worker employed by
        DUFFERIN CHILD & FAMILY SERVICES INTAKE WORKER.

    2.  I have reasonable and probable grounds to believe
        and do believe that KENNY McQUAID/PROSH is a child
        in need of protection for the following reasons:
        Sec 37(2) (B) CFSA - CRUEL/INAPPROPRIATE TREATMENT
        - 3 YR OLD LOCKED IN ROOM PHYSICALLY CONFINED

    3.  I have reasonable and probable grounds to believe
        and do believe that a course of action less
        restrictive than the child's removal to a place of
        safety is not available or will not adequately
        protect the child, for the following reasons:
        PARENTS REFUSED ACCESS TO CHILD & HOME, NEGLECT OF
        BASIC NEEDS - HOUSEHOLD SANITATION CHILD SLEEPING
        ON TORN MATTRESS - NO BEDDING, ENCRUSTED DIRT,
        DEBRIS & FOOD WASTE.

    4.  I have reasonable and probable grounds to believe
        that the child may be found at
        LOT 5 CON 4 EHS MONO TOWNSHIP

    /signed/ Kimberly James

    Sworn/Affirmed before me at Town of Orangeville in
    Ontario on November 16, 1999

    /signed/

    IRENE BEAZLEY
    A Commissioner etc, Province of Ontario,
    for the Children's Aid Society.
    Expires September 27, 2000

    ........................................................

    Applicant
    The Children's Aid Society
    of the County of Dufferin
    50 Fourth Avenue, Unit 13
    Orangeville ON L9W 4P1
    Tel: 519-941-1530  Fax: 519-941-1525

    David Thwaites, Solicitor
    Wardlaw, Mullin, Carter, Thwaites and Ward
    235 Broadway  Orangeville ON L9W 2Z5
    Tel: 519-941-1760  Fax: 519-941-3668

    Respondents
    Robert McQuaid and Linda Prosh
    Lot 5 Con 4 EHS Mono Township

    My Name is KIMBERLY JAMES
    I live in DUFFERIN COUNTY, ONTARIO
    and I swear/affirm that the following is true:

    [James Nov 16]
    ON NOV 15, 1999 DAWN FRANKS, INTAKE WORKER RECEIVED A
    CALL FROM TINA BERRYMAN.  SHE STATED THAT SHE HAD
    CLEANED THE MCQUAID/PROSH RESIDENCE IN OCTOBER 1999 -
    DESCRIBED THE HOME AS HAVING LATCHES ON THE DOORS.  THE
    FATHER SAID HE "BETTER LET THE MONSTER OUT".  TINA SAW
    MR MCQUAID UNLOCK KENNY'S BEDROOM DOOR & LET HIM OUT.
    MR MCQUAID THEN WENT INTO HIS OFFICE.  KENNY'S ROOM WAS
    VOID OF TOYS, TORN MATTRESS ON THE FLOOR, NO BEDDING,
    BEDROOM WINDOW DOESN'T OPEN, DIRTY DIAPERS IN BATHTUB
    MOLD IN KITCHEN SINK & ON MATS, FOOD ENCRUSTED IN
    COUNTER, DIRTY DISHES, KENNY DESCRIBED AS BEING DIRTY,
    FOLLOWED TINA EVERYWHERE & HAD A TANTRUM WHEN SHE LEFT.

    [James Nov 16]
    THIS WORKER ATTENDED RESIDENCE THIS MORNING WITH POLICE
    CONST.  CRAIG ABRAHMS, SHELBURNE OPP, WE IDENTIFIED
    OURSELVES & ASKED TO COME IN, HE DENIED ACCESS.  MR
    QUAID WOULD NOT SPEAK WITH US OUTSIDE.  MR MCQUAID ASKED
    WHY WE WERE THERE.  I TOLD HIM I HAD RECEIVED
    INFORMATION THAT THERE WAS A LOCK ON HIS SON'S BEDROOM
    DOOR.  MR QUAID THEN SHUT THE DOOR AND LOCKED IT.

    [James Nov 16]
    I SPOKE WITH PAULETTE SMITH BY PHONE, PAULETTE HAS
    CLEANED THIS RESIDENCE FOR 10 YEARS, EVERY TWO WEEKS.
    PAULETTE CONFIRMED TINA BERRYMAN'S OBSERVATIONS.
    PAULETTE DESCRIBED THE HOME AS A "PIG STY", THE HOME IS
    DIRTIER SINCE KENNY WAS BORN.  PAULETTE STATED THAT
    KENNY IS LOCKED IN HIS ROOM REGULARLY & THAT THERE ARE
    HOOK & EYE LOCKS ON EVERY DOOR.  PAULETTE STATED THAT MR
    MCQUAID USUALLY LETS KENNY OUT OF HIS BEDROOM WHEN SHE
    IN THERE & MR MCQUAID GOES INTO HIS OFFICE.  KENNY
    FOLLOWS HER AROUND & DOES NOT WANT ME TO LEAVE, SHE
    BELIEVES HE IS LONELY.  PAULETTE STATED THAT THERE IS
    MOLDY FOOD SOMEWHERE IN THE HOUSE EVERY TIME SHE IS
    THERE.  I VERILY BELIEVE THE ABOVE INFORMATION TO BE
    TRUE.

    [James Nov 16]
    AS A CHILD PROTECTION WORKER & BASED ON THE INFORMATION
    PROVIDED, I HAVE REASON TO BELIEVE THAT KENNY IS A CHILD
    IN NEED OF PROTECTION.  GIVEN HIS AGE THERE IS
    SUBSTANTIAL RISK THAT HE MAY SUFFER PHYSICAL HARM CAUSED
    BY HIS PARENTS FAILURE TO CARE, PROVIDE FOR OR SUPERVISE
    HIM ADEQUATELY.  KENNY IS CONFINED TO HIS ROOM, LOCKED
    IN FOR AN UNKNOWN LENGTH OF TIME BUT ON A REGULAR BASIS.
    THE HOUSEHOLD SANITATION PRESENTS RISK OF HARM TO KENNY
    - SPOILED FOOD NOT DISCARDED, NO BEDDING, TORN MATTRESS.
    AS PER THE ELIGIBILITY SPECTRUM THE ABOVE INFORMATION IS
    CODED ABOVE THE LINE IN TWO SECTIONS AND WARRANTS AN
    INVESTIGATION UNDER THE CFSA.

    /signed/ Kimberly James

    Sworn/Affirmed before me at Town of Orangeville
    in Ontario on November 16, 199

    /signed/
    IRENE BEAZLEY
    A Commissioner etc, Province of Ontario,
    for the Children's Aid Society.
    Expires September 27, 2000

    --------------------------------------------------------

    Ontario Court of Justice
    at 10 Louisa Street, Orangeville Ontario L9W 3P9

    Form 8B:  Application for child protection.

    Applicant:
    The Children's Aid Society of the County of Dufferin
    60 Fourth Avenue, Unit 13
    Orangeville Ontario L9W 4P1 Canada
    Phone: 519-941-1530
    Fax: 519-941-1525
    email: dcafs@hurontario.net

    Wardlaw, Mullin, Carter, Thwaites and Ward
    Attention: David Thwaites 235 Broadway
    Orangeville Ontario L9W 2Z5 Canada
    Phone: 519-941-1700
    Fax: 519-941-3688
    eMail: dthwaites@wardlaw.on.ca

    Respondents:
    Robert McQuaid
    RR #5  Orangeville Ontario  L9W 2Z2, Canada
    Phone: 940-9847
    Linda Prosh
    RR #5  Orangeville Ontario  L9W 2Z2, Canada
    Phone: 940-9847

    TO THE RESPONDENTS:
    A COURT CASE HAS BEEN STARTED AGAINST YOU IN THIS COURT.
    THE DETAILS ARE SET OUT ON THE ATTACHED PAGES.  THE
    FIRST COURT DATE IS November 22, 1999 AT 10.00 am or as
    soon as possible after that time at:  10 Louisa Street,
    Orangeville, Ontario, L9W 3P9.  If you have also been
    served with a notice of motion, there may be an earlier
    court date and you or your lawyer should come to court
    for the motion.  IF YOU WANT TO OPPOSE ANY CLAIM IN THIS
    CASE, you or your lawyer must prepare an answer (Form 10
    - a blank copy should be attached), serve a copy on the
    applicant children's aid society and all other parties
    and file a copy in the court office with an affidavit of
    service (Form 6B).  YOU HAVE ONLY 30 DAYS AFTER THIS
    APPLICATION IS SERVED ON YOU (60 DAYS IF THIS
    APPLICATION IS SERVED ON YOU OUTSIDE CANADA OR THE
    UNITED STATES) TO SERVE AND FILE AN ANSWER.  IF YOU DO
    NOT, THE CASE WILL GO AHEAD WITHOUT YOU AND THE COURT
    MAY MAKE AN ORDER AND ENFORCE IT AGAINST YOU.

    The applicant children's aid society is also making a
    claim for child support.  You MUST fill out a financial
    statement (Form 13 - a blank copy attached), serve a
    copy on the society and file a copy in the court office
    with an affidavit of service even if you do not answer
    this case.

    WARNING:  This case is subject to case management, which
    means that the case runs on a timetable.  That timetable
    says that the following steps have to be finished by the
    following number of days from the start of this case:
    Temporary care & custody hearing      25 days
    Plan of care to be served and filed   33 days
    Case conference                       40 days
    Settlement conference                 80 days
    Protection hearing or status review  120 days
    You should consider getting legal advice about this case
    right away.  If you cannot afford a lawyer, you may be
    able to get help from your local Legal Aid office.  (See
    your telephone directory under LEGAL AID).

    Date of Issue Nov 19/99
    Clerk of the court
    /signed/ C Pabst

    THE CHILD
    Kenneth Darryl McQuaid
    Date of Birth: 10/16/96
    Age: 3
    Gender: Male
    Mother's Name: Linda Prosh
    Father's Name: Robert McQuaid
    Religion: Unknown
    Native Status: Unknown

    CLAIM BY APPLICANT SOCIETY

    [Taylor Nov 18]
    1.  The applicant children's aid society asks the court
    to make a finding under Part III of the Child and Family
    Services Act that the child named in this application is
    in need of protection because:

       there is a substantial risk that the child will
       suffer physical harm, inflicted by the person having
       charge of the child or caused by that person's
       failure to care and provide for or to supervise and
       protect the child adequately [clause 37(2)(b)].

       the child has suffered emotional harm that is
       demonstrated by severe anxiety, depression,
       withdrawal or self-destructive or aggressive
       behaviour, and the child's parent or the person
       having charge of the child does not provide, or
       refuses or is unavailable or unable to consent to,
       services or treatment to remedy or alleviate the
       harm [clause 37(2)(f)].

       the child suffers from a mental, emotional or
       developmental condition that, if not remedied, could
       seriously impair the child's development and the
       child's parent or the parent having charge of the
       child does not provide, or refuses or is unavailable
       or unable to consent to, treatment to remedy or
       alleviate the condition [clause 37(2)(h)].

    [Taylor Nov 18]
    2.  The applicant society therefore asks for an order,

        that the child be made a ward of the Crown and
        placed in the care of The Children's Aid Society of
        the County of Dufferin

        relating to access, the details of which are as
        follows:

        Supervised Access at the discretion of the C.A.S.

        court costs.

    [Taylor Nov 18]
    3.  To the best knowledge of the applicant society, the
    parties or the child have not been in a court case
    before relating to the supervision, wardship
    (guardianship) or custody of or access to the child.

    [Taylor Nov 18]
    4.  The parties have not made a written agreement
    dealing with any matter involved in this case.

    [Taylor Nov 18]
    5.  The following is a brief statement of the facts upon
    which the applicant society is relying in this
    application.

    The society received information on November 15, 1999
    that Kenneth McQuaid, child, was being locked in his
    room and that the house was filthy.  A warrant of
    apprehension was obtained on November 16, 1999 after
    Robert McQuaid, father, refused to co-operate with the
    Society.  Kenneth McQuaid was brought to a place of
    safety and is currently in the Society's care as there
    were immediate concerns of risk of physical harm and
    Kenneth was demonstrating developmental delays.  There
    was also concern about the lack of supervision and
    interaction that Kenneth was receiving

    /signature/
    November 18, 1999
    Debbie Taylor
    Senior Program Manager

    APPENDIX

    The terms and conditions that the applicant society
    purposes for the child's supervision are as follows:

    1) Linda Prosh and Robert McQuaids visits will be at
       the discretion of the Society and the Society will
       supervise these visits to take place at the
       Society's Office until further assessments are
       completed.

    2) Parents will participate in a parenting capacity
       assessment completed by Dr Diane Benoit as soon as
       possible.

    3) Kenneth McQuaid requires a full pediatric assessment

    4) Parents sign all necessary consents to fullfill the
       foregoing.

    --------------------------------------------------------

    Ontario Court of Justice
    at 10 Louisa Street, Orangeville Ontario L9W 3P9

    Court File Number 180-99
    Form 14A: Affidavit (General) dated November 19, 1999

    Applicant(s)
    The Children's Aid Society of the County of Dufferin
    50 Fourth Avenue Unit 13
    Orangeville Ontario L9W 4P1 Canada
    Phone: 519-941-1530
    Fax: 519-941-1525
    email: dcafs@hurontario.net

    Lawyer:
    Wardlaw, Mullin, Carter, Thwaites and Ward
    Attention: David Thwaites 235 Broadway
    Orangeville Ontario L9W 2Z5  Canada
    Phone: 519-941-1760
    Fax: 519-941-3688
    eMail: dthwaites@wardlaw.on.ca

    Respondent(s)
    Robert McQuaid
    RR #5  Orangeville, Ontario L9W 2Z2, Canada
    Phone: 940-9847

    Linda Prosh
    RR #5  Orangeville, Ontario L9W 2Z2, Canada
    Phone: 940-9847

    My name is Kim James
    I live in The Town of Orangeville, Ontario
    and I swear/affirm that the following is true:

    I, Kim James, of the Town of Orangeville in the  County
    of Dufferin, make oath and say:

    [James Nov 19]
    1.  I am employed by Dufferin Children's Aid Society as
    a Child Protection Intake Worker.

    [James Nov 19]
    2.  Linda Prosh, date of birth December 27, 1954 and
    Robert McQuaid, date of birth August 5, 1942 are the
    parents of Kenneth Darryl McQuaid, date of birth October
    16, 1996.  The reside at RR 5 Orangeville Lot 5
    Concession 4 EHS of Mono Township.  Kenneth, (Ken) was
    born in Toronto, Ontario.  I requested Ken's birth
    certificate but was informed by Linda that she was
    unable to find it.  Linda is self employed in computer
    graphics and animation.  Robert is self employed, "Quaid
    Software Limited".

    [James Nov 19]
    3.  This agency received a call on November 15, 1999
    from Tina Berryman who is an employee with Molly Maid
    Cleaning Service.  Tina expressed her concerns about the
    McQuaid/Prosh residence and the welfare of Ken McQuaid.
    Tina stated that she was to their residence in October
    of this year and upon entering the home Mr McQuaid
    stated that he "better let the monster out" and
    proceeded to Ken's bedroom where Tina observed him
    unlock the door.  Mr McQuaid then proceeded to his
    office located down the hall.  Tina described the
    residence as a disgrace.  Tina stated that Ken's room
    was torn up, the mattress was on the floor, no toys, no
    dresser in his bedroom.  Tina stated that Ken was
    dressed in a diaper and a t-shirt.  There were 5 or 6
    dirty diapers in the bathtub and the bathroom was
    described as cruddy and dirty.  Tina stated that there
    was mould in the kitchen sink, food encrusted on the
    counter, dirty dishes.  Tina stated that Ken was dirty
    and barely spoke and followed her around the home while
    she cleaned.  Tina stated that she was there
    approximately an hour and a half.  During this time his
    father never came out of his office and his mother was
    not home.  Tina stated that every door in the house has
    a lock on it.  The initial information was received by
    Dawn Franks, Intake Worker with Dufferin Children's Aid
    Society.  I verily believe this to be true.

    [James Nov 19]
    4.  This worker attended the McQuaid/Prosh residence
    accompanied by P.C.  Abrams, Shelburne OPP on November
    16, 1999 at approximately 10:35 am.  We approached the
    front entrance way which was blocked by a fallen tree.
    Mr McQuaid answered the front door and we identified
    ourselves and requested to come in and speak with him.
    Mr McQuaid denied us entry, we asked him to step outside
    which he also declined.  Mr McQuaid asked why we were
    there and I informed him that we had received a call
    stating that there was a lock on their son's bedroom
    door.  Mr McQuaid the shut the door on us.

    [James Nov 19]
    5.  PC Abrams and this worker returned to the Society
    office and met with Kim Evans, Program Manager and was
    advised to make an application for a warrant to
    apprehend Ken.  This worker obtained a Warrant of
    Apprehension signed by Justice of the Peace Gwen
    Funston.  Please refer to Exhibit "A".  This worker
    contacted Shelburne OPP detachment and spoke with PC
    Dickson requesting assistance of two officers and
    informed him that I had a warrant of apprehension.  This
    worker then met PC Dickson and Sergeant Brodhagen at
    Coffee Time just south of Hockley Valley Road.  We then
    proceeded to the McQuaid/Prosh residence.  Mr McQuaid
    answered the door and was informed that we had a warrant
    of apprehension and we entered the residence at
    approximately 6 pm.

    [James Nov 19]
    6.  Ken was in the entrance way when we came into the
    home.  Mr McQuaid led us to the living room which was
    located down the hall from the front entrance.  As I
    walked down the hall I observed locks on the doors,
    there were two heating vents without grate coverings,
    there was a large cement pillar lying on its side.  Mr
    McQuaid sat down on a couch in the dark, put his feet up
    on the coffee table, folded his arms across his chest
    and stated that he was not going to answer any of our
    questions.  Mr McQuaid was asked if there was a light
    for the room and he replied "he broke them all, they
    don't work".  PC Dickson asked "who broke them?", Mr
    McQuaid responded he did, he did all of this".  We
    inquired as to Linda's whereabouts, she was downstairs
    and came upstairs asking who we were and why we were
    there.  Linda then stated that she knew who had done
    this, referring to the individual that had made the
    report to the Society.  This worker clarified to Linda
    that the referent did not make allegations of physical
    abuse but the concerns were regarding her son being
    locked in his bedroom and the dirty state of the home.
    Linda stated that the doors were locked, referring to
    this as "a rather elaborate system, there are actually
    two types of locks to keep Ken out of the rooms".  Linda
    then began to talk abut Ken being destructive and that
    she does not know how to control him.  Linda stated that
    she ends up putting Ken in his room when he is out of
    control and that is why his room is a mess.  I then
    asked to see Ken's room and was led down the hall.

    [James Nov 19]
    7.  Ken's room was not locked.  There was half of a lock
    catch located on the door but the hook had been removed
    from the door frame.  The door knob did have a key lock
    mechanism which Linda stated they did not use.  I
    entered the room and observed a twin size wooden
    bedframe with the supporting slats exposed, the mattress
    was on the floor and there was no bedding on the
    mattress.  The bifold door for the closet was folded
    underneath one end of the mattress.  The other end of
    the mattress was up against the side of a broken crib.
    There were two metal rods sticking out from the crib,
    approximately 3 inches in length.  There was an electric
    fan on the crib mattress, the heating vent was stuffed
    with shredded paper.  The closet was empty, there were
    strips of carpet laying on the floor, there were chords
    for the window dressing exposed as well as exposed light
    bulbs on the ceiling.  There was a locked trunk in the
    corner of the room.  Linda stated that Ken trashed his
    room every day.  I asked where he slept and she
    indicated in this room.  She stated that she would make
    up his bed and in the morning this is how she would find
    it.  I asked her what she does when she hears him
    trashing his room, she replied nothing.  I asked if she
    thought that her son had behavior problems, Linda
    replied that he was a very strong little boy and very
    rambunctious but never thought that he had a behaviour
    problem.  I indicated to her that this was not normal
    behaviour for a child that is being adequately
    supervised and engaged in stimulating activities.  I
    went on to indicate the safety concerns, to which Linda
    replied that she had child proof his room as much as she
    possibly could.  I then pointed out the hazards that I
    had noted as well as the exposed heating vents in the
    hall way.  Linda replied that they knew the vents were
    there and that they were cautious.  I clarified that my
    concern was regarding an active toddler running down the
    hallway and stepping into the vent could cut his leg or
    break it.

    [James Nov 19]
    8.  I asked Linda to show me the rest of the home.  All
    of the doors were locked by either the hook and eye
    mechanism or key handle locks.  The powder room bathroom
    stank of dirty diapers which were piled in a small waste
    basket.  I then enquired about toilet training.  Linda
    stated that Ken was still in diapers and that he would
    not sit on the toilet.  I asked how many times she has
    attempted to train him and she stated that she was
    really busy and had not really given it much of her
    time.  Linda began to talk about how much she and her
    husband work.  I asked where Ken was while they were
    working and she indicated that he was up stairs and that
    is why everything was locked, to deny him access.  I
    asked how long Ken would be left alone at a time, Linda
    was unable to give me an answer.  She stated that he is
    never really alone because Robert and herself are both
    working in their offices.  I indicated that Ken did not
    have direct access to them and she said that I was
    right.  I observed Mr McQuaid's office and the master
    bedroom which appeared to be adequately furnished and
    kept.  We went downstairs.  A piece of art was suspended
    above the stair well.  Linda indicated that Ken had
    knocked it off the wall.  Linda stated to myself and PC
    Dickson that Ken is not allowed downstairs unless she is
    with him.  Ken emptied a child's jigsaw on the floor of
    her office and Linda said, "see, he is always doing
    stuff like that".  I replied that was normal behaviour
    for a three year old.  I then went upstairs and viewed
    the kitchen.

    [James Nov 19]
    9.  The kitchen was also on the hook and eye lock
    system.  The kitchen was dirty.  There was a cooked tv
    dinner on the table which did not appear to be touched.
    I asked Linda when Ken last ate.  Linda stated that she
    had made him the tv dinner but that he did not eat it.
    She stated that he usually throws his food and
    dinnerware.  I again asked when his last meal was.
    Linda stated that she wasn't sure but thought Bob had
    fed him lunch but she was not sure of what.  Linda
    stated that she thought that he may have had a muffin, I
    indicated that I did see a half eaten muffin somewhere
    in the house and she replied that was Ken's.  Linda
    stated that she had given him cereal in the morning.  I
    asked if the family sits down to eat together and she
    replied sometimes.  I asked what Ken's bedtime was, she
    replied whenever they were finished working.  I asked if
    he had a bedtime routine.  Linda did not respond.  I
    asked what she did to get him ready for bed, Linda
    replied that she gave him some coco and then put him in
    his room and shut the door.  Linda stated that she likes
    to take Ken for walks on their property but that she has
    to carry him back because he won't walk.  Linda stated
    that she tries to take him to the Dufferin Resource
    Centre once a week and to the park because he likes the
    swing.

    [James Nov 19]
    10.  I then began to focus on Ken.  He was vocal and
    verbalizing words but much of the time he was mumbling.
    Ken was not able to communicate to me.  He mimicked
    everything I said and could not answer simple questions
    such as "what color is this?".  Ken was eating an apple
    and he was spitting chunks out on the floor.  He went
    into the kitchen to obtain another apple.  I had to take
    a knife away from him as he was attempting to cut it.
    Ken appeared to be healthy.  His eyes appeared a little
    sunken and dark circles were under both eyes.  I
    observed superficial scratch marks around his midriff.
    Possibly self inflicted.  There were no other visible
    marks on him.

    [James Nov 19]
    11.  I consulted with both PC Dickson and Sergeant
    Brodhagen as to their thoughts about Ken being a child
    in need of protection.  Please see Exhibit "B".  Both
    officers indicated that they would not feel comfortable
    leaving him in his home due to the lack of supervision
    and that they had never really seen anything like this
    before.  PC Dickson stated that he would like to
    photograph this home, I informed him that there was a
    camera in my car and asked if he would obtain it.  I
    asked Linda if I could use here phone and consulted with
    my Program Manager, Kim Evans.  I relayed my concerns
    for Ken's personal safety due to the hazards as well as
    it appeared as though Ken was not adequately supervised
    and that there was not much interaction between the
    family members.  Ken also appeared to present some
    developmental delays.  I was directed to bring him into
    care.  I began taking pictures of the kitchen, Ken's
    bedroom and various hazards I had observed in the home.
    Please see Exhibit "C".  I then informed Linda that I
    would be taking Ken into foster care this evening and
    requested that she pack some clothes for him as well as
    any toys or comfort objects that he may have.

    [James Nov 19]
    12.  At some point I had seen Mr McQuaid get up from the
    living room and walk to his office where he remained
    behind closed doors for a period of time.  He came out
    and began to dismantle the crib which I had instructed
    to Linda needed to be done due to the hazard.  Linda was
    obtaining items for Ken.  The whole time that we were in
    their home the parents did not interact with Ken once.
    Linda changed Ken's diaper and got him dressed in his
    coat, hat and boots.  Linda was crying at this time.
    Robert did not say goodbye to Ken.

    [James Nov 19]
    13.  Ken was placed at an approved foster home in
    Dufferin county.

    [James Nov 19]
    14.  On November 17, 1999, I requested that a Parent
    Infant worker observe Ken in the foster home and provide
    me with initial observations and assessment.  Nina
    Little Alcorn summarizes in her report that she suspects
    developmental lags and concerning social and language
    behaviours.  Ken can interact at some level, albeit
    through toys.  Please see Exhibit "D".

    [James Nov 19]
    15.  I spoke with Linda by phone in the morning.  Linda
    stated that she is prepared to do anything that the
    Society wants and that she will get Robert to cooperate
    as well.  Linda asked if she could visit with Ken.  I
    asked if she would be able to meet with me later in the
    day and to bring his health card and birth certificate.
    Appointment set for 4 pm.

    [James Nov 19]
    16.  I attended the foster home for approximately an
    hour and was left alone with Ken.  I observed him to be
    calm and playing with toys.  Ken and I attempted to
    communicate and once again he mimicked my speech.  I was
    able to redirect his attention and behaviour with ease.
    When the foster mother returned home we discussed how
    the evening was.  She stated that he was difficult to
    bath and became upset when they washed his hair.  Ken
    also stripped his bed twice, each time it was remade.
    His bed and the bedroom were intact in the morning
    except that his pillows were on the floor.  At the time
    of writing this affidavit Ken's behaviour has been
    described as well behaved.  He has not been out of
    control, destructive, aggressive, he is following
    direction and beginning to speak more clearly.  Ken is
    also taking and interest in toilet training as there are
    other toddlers in the foster home who are in the process
    of learning.

    [James Nov 19]
    17.  I passed this information on to Linda during our
    meeting.  She seemed surprised that he has not been
    destructive and she stated that it seemed that he did
    not miss them.  Linda and I talked about her personal
    history as well as her relationship with Robert and Ken.
    Linda stated that she and Robert are not very sociable
    people.  Linda stated that she believes Ken was about 16
    months when he began to crawl and she was also concerned
    about his lack of speech.  Linda took Ken to Dr Trevor
    Hunt in Alliston, paediatrician, on two separate
    occasions to discuss her concerns.  The doctor referred
    Ken to an occupational therapist for the crawling.  Ken
    was also referred for a speech assessment.  Linda claims
    that the next day after visiting the doctor, Ken began
    to crawl and the second visit he began to speak.  Linda
    did not follow up with her concerns after this.  Linda
    asked if Robert could come for the visit as well, I
    asked if he wanted to.  Linda stated that she would ask
    him if he wanted to come.  Linda informed me that she
    met Robert at a MENSA meeting.  Linda stated that both
    she and Robert wanted a child.

    [James Nov 19]
    18.  This worker has called both the family doctor and
    the pediatrician but at the time of writing the
    affidavit have not been able to speak with them.  The
    Society has made an appointment with Dr Ron Murphy for a
    complete physical and developmental assessment.  This is
    scheduled for Friday, November 19, 1999.  Please see
    Exhibit "E".

    [James Nov 19]
    19.  Linda and Ken had a scheduled visit for Thursday,
    November 18, 1999 at 1:30 pm.  I observed their visit
    for one hour at the Society office.  Linda was seated on
    the couch in the room when I brought Ken in.  Linda said
    "hi Ken" while sitting down.  Ken said "hi mom" and sat
    in a chair opposite her.  Linda asked Ken for a kiss.
    He got up, walked around the table and stood beside her.
    He leaned towards her but did not kiss her.  Linda
    stated that he has never kissed her.  Ken then said
    "that's not a kiss" and Linda kissed him saying "that's
    a kiss".  Ken did not engage his mother as a playmate.
    The level of interaction was through the toys and not
    personal.  There was distance between their interaction.
    Linda did attempt to hold him on her lap once, Ken did
    not respond but rather sat there for a very short period
    of time.  Linda left the room at one point in the visit.
    Ken followed her to the door.  When she shut the door he
    reached for the handle and made a small cry sound and
    then went for the toys.  When Linda came back into the
    room Ken was seated on the couch and he did not get up
    and greet her.  Linda took him to change his diaper and
    he went without any fuss.  Ken found markers and paper.
    Linda did not want him to have the markers and said that
    she would draw him a picture.  Ken tried to take the
    marker that Linda was using and they were engaged in a
    tug of war over the marker, Linda remarking that she was
    drawing Ken a picture.  Ken became frustrated with this
    an threw the markers at Linda.  Linda stated to me that
    she does not like Ken to have markers and I replied that
    she should take them away from him and put them away,
    Linda did so.  At the end of the visit we walked out to
    the waiting area where the foster dad was.  Ken
    approached the foster dad and was directed to say good
    bye to his mother.  Linda asked for a good bye kiss.
    Once again, Ken went over to his mother, leaned close to
    her, did not kiss her but she kissed him.  Robert did
    not attend for the visit.

    [James Nov 19]
    20.  During the visit Linda inquired as to how Ken was
    behaving at the foster home.  I told her that he was
    doing very well.  She asked how bed time was.  I
    informed her that last night he went to bed around 8:30
    pm without any problems and slept the whole night
    through, room and bed in tact.  Linda appeared to be
    surprised.  She asked if he was throwing his food and
    utensils at meal times, I said that they did not mention
    that this was happening.  Linda stated that she was
    surprised to hear this.  She then asked if there has
    been any form of disruptive behaviour I replied not that
    I am aware of.  Linda then said, maybe he thinks there
    is something wrong with us.  Linda then asked Ken if he
    wanted to go home.  Ken did not reply.  I asked Linda
    how they celebrated his 3rd birthday.  Linda stated that
    they didn't do anything.  I asked if they had a cake for
    him, she replied no and stated that they are not really
    big on "that sort of thing".  I asked Linda what they
    got him for his birthday and she said nothing because
    she buys him things all the time.  I asked what sort of
    things she buys, she replied clothes.  Linda stated that
    she would only buy toys from the dollar store for him
    because he is so destructive.  Linda stated that they
    might do something for him when he gets older.

    [James Nov 19]
    21.  I spoke with the foster mother on the morning of
    November 19, 1999 and she informed me that Ken had a
    good day with them.  He took a bath with their toddler
    and played with bath tub toys.  He was in bed by 8 pm
    without incident and slept through the night.  His bed
    and room intact.  The foster mother stated that since he
    has arrived, "he hasn't broken a single thing, not even
    dumped a cereal bowl.  He picked up the baby's soother
    this morning and said, oh, back in baby's mouth.  This
    is Ken's baby".

    [James Nov 19]
    22.  My assessment of Ken McQuaid, age 3 years is as
    follows:  Ken is a child in need of protection as there
    is substantial risk that he will suffer physical harm
    caused by his parent's failure to care and provide for
    or supervise and protect him adequately.  Ken has been
    physically confined to his room for unknown periods of
    time and his movements/access has been restricted to a
    bleak, unstimulating environment.  The area that Ken has
    access to present hazardous conditions and the household
    sanitation poses neglectful conditions and as a result
    there is a high potential for injury, harm or illness to
    Ken.  His parents excecise little supervision over him.
    They are locked in their offices and therefore may be
    unable to access Ken's play area quickly if necessary.
    Linda and Robert do not demonstrate sufficient
    qualities/abilities for child care.  Their inability to
    demonstrate bonding or nurturing characteristics are
    presenting serious risk to Ken's well-being.

    [James Nov 19]
    23.  I make these statements with no improper intent

    /signed/ Kim James

    Sworn/Affirmed before me at The Town of Orangeville
    in Ontario on November 19, 1999

    /signed/ GARY BRIAN PUTMAN, A Commissioner, etc,
    Province of Ontario, for the Children's Aid Society.
    Expires September 20th, 2000

    ........................................................

    Exhibit A  photocopy of the Information for Warrant to
               Apprehend Child, shown above.
    Exhibit B  photocopy of notes by Jim Dickson.
    Exhibit C  photographs that we have never seen.

    ........................................................

    Exhibit D

    CAS memohead (see glossary)

    Observation Summary
    Parent Infant Program

    CLIENT NAME:  Kenneth McQUAID

    DATE OF REPORT:  November 18, 1999

    DATE OF BIRTH:  October 16/96

    REFERRAL INFORMATION:
    Kim James, intake worker for Dufferin Child and Family
    Services, invited this consultant to observe Kenneth
    (Ken) in the foster home of K & F Clauser on November
    17/99.  Ken had arrived at the Clausers' home the night
    before.

    Mrs James described odd behaviors and questioned
    developmental delay.  She was interested in our
    observations and any recommendations.  Little
    developmental history was reported, other than creeping,
    I assume on all 4's, at 16 months.  Apparently the
    parents periodically expressed concerns about Ken's
    progress and/or behaviors, however, their worries would
    diminish and it seems no active investigation or ongoing
    treatment was engaged.

    HOME VISIT OBSERVATIONS NOVEMBER 17/99.
    I attended at the foster home over the noon hour with
    Dorothy McLachlan, Program Manager.  Dorothy's role was
    to observe and take notes while I interacted with Ken.
    We were greeted by Mrs Clauser, three young preschoolers
    and two friendly dogs.

    At yesterday's date Ken was 37 months and 1 day.

    * despite his very recent separation from his parents
      and placement in a busy household, seemingly disturbed
      behavior the night before, and the earlier visit by 3
      DCAF staff, Ken stayed in the (closed off) livingroom
      with us.  He did not demonstrate what would be
      understandable stress or confusion, not apparently
      alarmed, yet not initiating interaction with us.

    * Ken responded very favourably to my invitation to
      explore with me the contents of a small toy box.  His
      expression lit up with a smile and eye contact as he
      found and identified "Barney and friends" and a number
      of Sesame Street characters.  With brief breaks,
      mostly to try my keys in the two doors, Ken was easy
      to re-engage and we were able to interact for roughly
      45 minutes.

    * Ken was most interested in my keys and the Barney and
      Sesame Street figurines.  He also played for quite a
      while with small pegs and a pegboard.  The most
      striking observation was Ken's apparent disinterest in
      small toy cars, even after I demonstrated propelling
      it with the "vroom" sound.  Ken smiled and said
      "that's Ken McQuaid" to his image in a small mirror.

    * Ken's language was a mix of echolalia and spontaneous
      meaningful speech.  He repeated a great deal of what
      was said to him often without eye contact.  His speech
      also contained quite appropriate 2-3 word phrases (ie.
      "baby sleep" after I said "baby night-night").  I
      noted some sound substitutions and articulation
      errors.  Ken named a number of objects, he also named
      a number of pictures (ie.  banana, baby) and he
      pointed to several body parts on a doll.

    * Ken demonstrated considerable patience when he had
      difficulty manipulating an object, in fact he appeared
      quite gentle as he handled the various objects.  Each
      time Kenneth exhibited frustration, after reasonable
      effort, his face reddened and tensed and he uttered a
      "grrr" with other sounds.  He was not very loud, nor
      did he use his body or limbs as many preschoolers
      would to protest.  Ken did not solicit help, but did
      not reject it when I offered assistance.  He was able
      to copy a number of my demonstrations (ie.  musical
      toy button).

    * Ken tolerated my touch as I stroked his hair away from
      his eyes, fed him one cereal bit, and "crowded" his
      personal space to reach around him for a toy.  At one
      point Ken leaned on my leg very relaxed to play with
      an object.  Ken did not engage, or acknowledge,
      Dorothy's presence at all, despite my introduction of
      her and ongoing verbal exchange.  I heard no reference
      to mom or dad, or Katherine, however, we witnessed
      distress at being denied another toddler's bottle and
      during a search for a "see'n'say" toy.  This search
      occurred at the end of our visit when we also let the
      other children join us.  At this point Ken's behavior
      became more bizarre and more anxious-appearing
      (reduced eye contact, no response to our wave,
      ignoring everyone else with persistent repetition of
      "where's the honey?", a phrase from the toy that Ken
      seemed to be uttering to himself more so as a label
      for the object).

    * Ken sat in the "W" position to play.  His gait seemed
      normal, although he was unable to jump with both feet
      on the floor or from a step, and climbed the stairs
      sideways in non-reciprocal fashion holding on to the
      bannister.

    * Ken used both hands.  He placed tiny pegs in a board
      with a neat pincer hold, though he stuffed Cheerios in
      his mouth with his fist.  Ken would not try stringing
      the Cheerios on a lace, but was able to unscrew a
      plastic nut and bolt.  I was not able to observe paper
      and crayon skills.

    * Ken "lined up" a number of objects, though not
      obsessively.  He lined up wooden blocks mostly, would
      not stack more than two.  His manipulation of the toys
      was not strikingly different at today's visit except
      that he seemed most excited about "TV" characters and
      not so with the little cars or a tiny doll and the
      bottle (except to say "milk").

    SUMMARY and RECOMMENDATIONS:
    From this "snapshot" contact it is my impression that
    Kenneth presents an intriguing mix of suspected
    developmental lags and concerning social and language
    behaviors (ie.  limited eye contact, ecolalia, etc).
    The extent, permanence, and cause(s) I believe, require
    a thorough pediatric investigation before plans for
    treatment (including placement?) can be made.  His
    strengths include his engaging appearance and
    willingness to interact at some level, albeit through
    the toys, and apparent change/response to handling by
    the individuals around him over a very brief period of
    time.

    I believe accurate assessment can probably only be done
    over repeated sessions, therefore I am reluctant to
    offer a developmental estimate.  I have reported
    specific observations from my hour with Kenneth, largely
    one-on-one.  I would be happy to help again in any way I
    can.

    I have a sense of potential in this little guy.  Thank
    you for the opportunity to observe Kenneth and give you
    feedback.

    /signed/             Nov 18/99
    Nina K Little Alcorn, HBA (Psych), Cert Soc Wk
    Parent Infant Consultant
    Parent Infant Program


    /signed/             Nov 18/99
    Dorothy McLachlan
    Program Manager
    Developmental Support Services

    ........................................................

    Exhibit E

    RONALD G MURPHY MD FRCP (C)
    MEDICAL ARTS BLDG
    15 ELIZABETH STREET SUITE M 16
    ORANGEVILLE ONTARIO L9W 5X5

    PEDIATRICS        (519) 942-3501

    November 19, 1999

    Ms Jennifer Long-Moore
    Dufferin Child & Family Services
    50 Fourth Ave Unit 13  Orangeville Ont L9W 4P1

    Dear Ms Moore:

    RE:  Kenneth McQUAID
    DOB:  16/10/96

    I saw Ken in the office today accompanied by you
    regarding concerns over his development.  Ken was
    recently apprehended from his parents after concern had
    been expressed regarding the home environment.  It is my
    understanding from you that the environment was found to
    be lacking in stimulation for Ken.  I understand that
    there were very few if any toys available for Ken's use
    and that he was severely restricted in his movement
    through the family home.

    He has been placed in a Foster Home where there are
    other children ranging in age from 9 weeks to 14 years.

    In the office today Ken presented as a healthy looking
    active young boy.  He did not display any stranger
    anxiety and was not destructive or overly active in the
    room.

    Ken's general examination today revealed his weight to
    be 17.4 kg which places him at the 95th percentile,
    while his height at 100.5 cm places him at the 90th
    percentile.  His head circumference was 34 cm which is
    above the 95th percentile.  His general examination was
    normal.  There were a number of excoriations or
    scratches present on both buttocks.  There was a fading
    bruise on the anterior aspect of the left leg and two
    areas in the midline over the lower spine which appear
    to be well healed areas from previous minor trauma.  He
    was well nourished and there were no abnormalities
    detected.  Developmentally Ken tended to echo our speech
    today and had difficulty in following some simple
    commands which would be expected by his age such as
    asking him to place an object on a chair or on the
    floor.  One would expect Ken to be able to do this by 2
    1/2 years of age and many children indeed would be able
    to follow such simple instructions at an ever younger
    age.  He was unable to scribble initially when presented
    with a pencil but eventually was able to do this after
    watching me.  He could not copy a circle nor could he
    draw a vertical line.  Again these would be milestones
    expected for somebody of Ken's age.  I understand he is
    able to assist with some of his dressing.  He is not yet
    toilet trained.  He was unable to balance on one foot
    and could not jump.  He can walk without difficulty but
    I could not get him to walk backwards in the office.  I
    understand that he is able to walk up steps but he tends
    to lead with the same foot.

    The development delays which Ken in demonstrating may be
    the result of lack of stimulation.  I understand that
    his speech is already showing some signs of improvement.
    I have requested a number of investigations to rule out
    any possible underlying medical cause for his delays.
    Some of the investigations which I have undertaken may
    take as long as a couple of months before results become
    available.  If Ken does not show improvement and
    progression in the above mentioned delays then it may
    become necessary for him to become involved with the
    speech therapist, occupational therapist to assist with
    fine motor, and physiotherapist if the gross motor
    skills are not continuing to improve.

    I would be happy to clarify any of the above findings
    should you deem this necessary.

    Sincerely yours,

    /signed/

    RG Murphy MD FRCP (C)

    RGM/wl

    dictated but not read

    --------------------------------------------------------

    ONTARIO COURT OF JUSTICE
    10 LOUISA STREET, ORANGEVILLE

    Form 14A: Affidavit (General) date 180/99

    Applicant

    The Children's Aid Society of the County of Dufferin
    50 Fourth Street Unit 13
    Orangeville Ontario L9W 4P1
    (519)941-1530 phone
    (519)941-1525 fax

    Wardlaw Carter Mullin Thwaites and Ward
    David Thwaites
    235 Broadway, Orangeville ON
    941-1760 phone
    941-3688 fax

    Respondents

    Linda Prosh/Robert McQuaid
    RR #5  Orangeville ON L9W 2Z2
    940-9847

    Huber & Heersche
    Evelyn D Huber
    184 Broadway Orangeville ON L9W 1K3
    (519)940-4500 phone
    (519)940-4502 fax

    My name is Robert McQuaid
    I live in Township of Mono, County of Dufferin
    and I swear/affirm that the following is true:

    [McQuaid Nov 22]
    1.  I have had the opportunity to review the affidavit
    and attached materials of Kim James sworn November 19,
    1999.

    [McQuaid Nov 22]
    2.  I am the natural father of the child Kenneth McQuaid
    born October 16, 1999 and my wife Linda Prosh is the
    natural mother of the child.

    [McQuaid Nov 22]
    3.  Linda and I have been active and loving involved
    parents of Kenneth.  I confirm that there are locks on
    the doors in the home in order to ensure that Kenneth
    does not injure himself in any of the rooms on furniture
    etc.  Kenneth has become increasingly destructive and
    our method of dealing with this has been to restrict his
    access to some of the common areas, unless he is
    immediately supervised by my wife or me.  There is also
    a lock on his bedroom door, which we do on occasion use
    to give Kenneth a time out when he is behaving
    inappropriately.

    [McQuaid Nov 22]
    4.  Kenneth is well groomed, dressed, fed and loved.
    Kenneth's family physician, Dr Ross in Tottenham can
    attest to the fact that there has never been occasion
    when Kenneth has been treated for any injury.  He is not
    malnourished or otherwise neglected.  In fact, my
    concern until Kenneth was two years old was that he had
    never had so much as a cold and I believed he needed
    exposure to some colds in order to develop his immune
    resistance more effectively.

    [McQuaid Nov 22]
    5.  I have an involved relationship in Kenneth's life.
    I will take him for a walk daily on our property of 67
    acres.  He is deeply bonded to me and does voluntarily
    come to me for affection and attention.  I am an active
    participant in feeding him, clothing and changing him.

    [McQuaid Nov 22]
    6.  The Police allege in their notes that I was in an
    almost catatonic state.  I have a strong belief in my
    right to counsel, particularly in light of the
    allegations being laid against me by the CAS and the
    Police.  I felt it in my best interest to be
    non-communicative.  I did not believe I had any reason
    to address the allegations of the CAS because I know
    Kenneth is well cared for and loved.

    [McQuaid Nov 22]
    7.  My wife Linda does take him to the Resource Centre
    in Orangeville to give Kenneth the opportunity to
    interact with other children.  The worker there, Debbie,
    could attest to this fact.

    [McQuaid Nov 22]
    8.  The housekeeper, Tina Berryman, had been in
    attendance at our home on one occasion.  I confirm that
    our home could be cleaner, but the home does not pose a
    risk to Kenneth.

    [McQuaid Nov 22]
    9.  The cement pillars that the officer referred to had
    been the legs of a glass table.  I had removed the glass
    from the table top some months ago and stored it in a
    locked room because of my concern that Kenneth might
    hurt himself on the glass if it fell.  The cement
    pillars had been used to block him from crawling behind
    the wall unit in the living room.  I was worried that he
    would access the plugs and electrical cords.  The
    pillars were recently set on their sides because Kenneth
    had threatened to knock them over and again I was
    concerned for his safety.

    [McQuaid Nov 22]
    10.  Linda and I had decided to place Kenneth in day
    care because we believed he needs greater exposure to
    other children at this stage in his life and being in
    the country does not afford him the opportunity to play
    with many other kids.  Linda began looking in late
    summer and had difficulty finding a day care that was
    not full with the return to school coming soon.

    [McQuaid Nov 22]
    11.  I confirm that we had the diapers in the tub in the
    spare bathroom.  We keep them there at a maximum for
    three days.  We then gather them and take them to the
    barn.  I share the changing of the diapers.  I take
    Kenneth two to three times a week in to Orangeville with
    me to run errands.  I believe he should be exposed to
    other people and I am taking this opportunity.

    [McQuaid Nov 22]
    12.  We take him on weekend outings every other weekend
    to places such as the hiking area at Mono Cliffs,
    Belwood Lake, the Orangeville Conservation Area.

    [McQuaid Nov 22]
    13.  Kenneth has a huge number of Lego toys, dolls, cars
    and trucks.  We do not spend a great deal of money on
    his toys, but he does have a number of them.  They are
    not stored in his bedroom.  We like to supervise him
    when he plays.

    [McQuaid Nov 22]
    14.  When the cleaning ladies are in the home, I
    generally try to get out of their way and go into my
    work room.  Kenneth enjoys the company and I leave him
    following the cleaners around.  Paulette generally comes
    and I have known Paulette for approximately 10 years and
    I know her well enough to feel comfortable leaving
    Kenneth out with her.  I have never had any complaints
    that Kenneth interferes with their work.

    [McQuaid Nov 22]
    15.  I do call Kenneth the Ken Monster.  It is a term of
    endearment to me and if Tina Berryman took it amiss,
    then I cannot be responsible for that.  Linda and I have
    both nicknamed him that.

    /signed/  Robert T McQuaid

    Sworn/Affirmed before me at Town of Orangeville County
    of Dufferin
    Nov 22/99
    E Huber
    Commissioner for taking affidavits

    --------------------------------------------------------

    (This document is in the handwriting of David Thwaites)

    IN THE MATTER OF KENNETH McQUAID

    CONSENT

    The parties consent to an Order

    1.  That the child Kenneth McQuaid born October 16, 1996
        shall be in the temporary care of the Children's Aid
        Society with access by the parents as arranged with
        the Society.

    2.  that the proceedings be adjourned to December 1,
        1999 at 10 am to allow for the parents to address
        and implement, to the satisfaction of the Society:

        (a) arrangements for the enrollment of the child in
            a daycare programme approved by the Society.
        (b) follow through on the recommendations of Dr
            Ronald Murphy
        (c) the involvement of the Infant Parent Programme
        (d) appropriate house safety (for example removal of
            locks on interior doors)
        (e) releases of information for the child, family
            doctor and community resources
        (f) parenting courses and counselling, if
            recommended.

    dated at Orangeville the 22 day of Nov/99

          /signed/    Robert T McQuaid
                      Linda Prosh
                      Kim James, Children's Aid

    witness
    (illegible)

    --------------------------------------------------------

    (message sent by email)

    November 24, 1999

    Dufferin Child and Family Services
    dcafs@headwaters.net

    Subject:  Libel allegation

    Sirs:

    Today I received a communication from Evelyn Huber that
    you considered some of the statements I had made through
    the internet to be libelous.  Please forward your
    objections to me by E-mail, or any other form of
    communication you prefer.  I will give your objections
    the same distribution given to my own comments.

    Robert T McQuaid
    RR 5  Orangeville Ontario L9W 2Z2 Canada
    E-mail:  robert.mcquaid@hurontario.net

    --------------------------------------------------------

    November 26, 1999

    David Tilson MPP
    david_tilson@ontla.ola.org

    Subject:  Child abducted by Children's Aid

    Dear Mr Tilson:

    On November 16, without warning, in two visits
    Children's Aid removed our only child, Kenneth, age 3,
    from our home.  A few days later they moved in court
    papers to make Ken a ward of the crown, so that we would
    never see him again.

    This was an intact family with a normal healthy three
    year old, with regular medical checkups, never before
    diagnosed with any problems.

    The rest of this E-mail details the events in the
    case.  I am asking for your help:
    (a)  to get us out of our family nightmare
    (b)  to consider altering the procedures so that an
         aggrieved family can have a chance at least to
         hire legal counsel before suffering the loss of a
         child, or even to reduce the funding for
         Children's Aid to a level where they could not
         cause this kind of mayhem for intact families.

    Thank you for your consideration.

    Robert T McQuaid
    RR 5  Orangeville Ontario L9W 2Z2
    phone:   519-942-0565
    E-mail:  robert.mcquaid@hurontario.net

    (The rest of the E-mail, containing the case documents
    up to this date, is omitted.)

    --------------------------------------------------------

    Ontario Court of Justice
    at 10 Louisa Street, Orangeville Ontario L9W 3P9

    Court File Number 180/99
    Form 14A: Affidavit (general) dated November 29, 1999

    Applicant
    The Children's Aid Society of the County of Dufferin
    50 Fourth Avenue Unit 13
    Orangeville Ontario L9W 4P1 Canada
    Phone:  519-941-1530
    Fax:  519-941-1525
    email:  dcafs@hurontario.net

    Wardlaw, Mullin, Carter, Thwaites and Ward
    Attention:  David Thwaites 235 Broadway
    Orangeville Ontario L9W 2Z5  Canada
    Phone:  519-941-1760
    Fax:  519-941-3688
    eMail:  dthwaites@wardlaw.on.ca

    Respondents

    Robert McQuaid
    RR #5  Orangeville Ontario L9W 2Z2  Canada
    Phone:  940-9847

    Linda Prosh
    RR #5  Orangeville Ontario L9W 2Z2  Canada
    Phone:  940-9847

    My Name is Kim James
    I work in Orangeville Ontario
    and I swear/affirm that the following is true:

    I, Kim James, of the Town of Orangeville in the County
    of Dufferin, make oath and say:

    [James Nov 29]
    1.  I am employed by Dufferin Children's Aid Society as
    a Child Protection Intake Worker.

    [James Nov 29]
    2.  On November 18, 1999, I spoke with Audrey Campbell
    who works with Dr Trevor Hunt.  Dr Hunt met with Linda
    and Ken on September 12, 1997 due to delayed milestones.
    Dr Hunt noted that Ken would fall backwards when in a
    seated position.  Ken was approximately 11 months old at
    this time and should have been able to meet this
    milestone.  Dr Hunt had made a referral for an
    occupational therapist.  On June 22, 1999, Dr Hunt met
    with Linda and Ken due to delayed speech and a referral
    was made for a speech therapist.  I verily believe this
    to be true.

    [James Nov 29]
    3.  On November 22, 1999, The Society, Robert McQuaid
    and Linda Prosh agreed to adjourn the matter of Kenneth
    McQuaid until December 1, 1999 as the parents agreed to
    work with the Society.  During the interim, Kenneth
    remained in the temporary care and custody of the
    Society.  The parents were to address and implement, to
    the satisfaction of the Society six conditions.  Please
    see Exhibit "A".  It was my understanding that if the
    conditions were met to the satisfaction of the Society
    that a "least intrusive measure" would be sought by the
    agency in working with this family.  Arrangements were
    made for the parents to have one hour daily supervised
    visits with Ken at the Society office.  This worker
    would continue with the investigation and gathering
    information.

    [James Nov 29]
    4.  This worker had opportunity to observe the visits
    between Ken and his parents on four separate occasions.
    Upon reuniting with his father after a six day
    separation and four days for his mother there was no
    form of affection shown immediately.  Ken went straight
    for the blocks that his parents had brought him.  Ken
    continued to focus his time and attention on the toys
    rather than his parents.  Bob finally invited Ken over
    to read a story book to him.  Ken appeared content and
    relaxed on his father's lap.  The parents present more
    as teachers than playmates with Ken.  Their conversation
    was a question answer format.  When it was time to say
    good bye Ken cried a little but stopped as soon as he
    saw his foster mother.  This worker also received a
    voice mail message from Nina Little Alcorn with the
    Parent Infant Program stating that Bob McQuaid had
    called her as he was complying with the conditions
    agreed upon between himself and the Society.  I verily
    believe this to be true.  Nina met Linda and Bob after
    this visit and gave them a pamphlet outlining the Parent
    Infant Program and spoke with them briefly about their
    services.  Nina had asked them to read the pamphlet.

    [James Nov 29]
    5.  On November 23, 1999, this worker spoke with Debbie
    Holmes, an employee at Community first.  Debbie verified
    that she has seen Linda and Ken at the resource centre
    but was unsure of the frequency.  Debbie stated that
    Linda has had a membership with them for over a year.  I
    verily believe this to be true.  The visit on this day
    was similar to the previous day.  Once again the
    greeting was not affectionate.  Bob immediately began
    reading to Ken.  Linda interrupted this on two
    occasions.  Linda showed Ken the toys that they had
    bought him and gave him chocolates.  Ken attempted to
    engage his father in play by giving him a car.  Bob held
    it, said "my car Ken", then gave the car back to Ken.
    They displayed the teacher role once again.  Linda would
    say, "yellow duckie, yellow block, blue jacket, blue
    block," This was repeated over and over with the other
    colours.  At one point Linda stated, "you are far more
    important to him that I am".  I believe this is due to
    the fact that Ken attempted to interact more with his
    father.  Linda asked Ken if he wanted to go on the swing
    and then told him he could not.  It is my understanding
    from Linda that she would take Ken to the park after
    their visits to Community First and Ken enjoyed the
    swing.  Bob had Ken on his lap and they were counting,
    Ken did not appear interested and Bob responded by
    saying, "were playing counting now, pay attention
    child".  Linda asked if he wanted to sit on her lap, Ken
    got up but only stayed there for approximately 10
    seconds.  By 3:45 pm there was no interaction between
    the parents and Ken.  Ken was playing with the empty
    boxes that his toys came in and the parents were having
    a conversation.  Ken left the visit without hugs and
    kisses from his parents.  This worker also made note
    that the parents were concerned that they were being
    audio or video taped as their visits take place in our
    interview room.  The interview room has a two way
    mirror, two video cameras mounted on the wall and two
    wall microphones.

    [James Nov 29]
    6.  On November 24, 1999, I met with the foster mother
    at her home.  She informed me that Ken does need a nap
    in the afternoon otherwise he is extremely cranky in the
    evening.  Ken has also progressed from diapers to pull
    ups and is showing an interest in toilet training of the
    other toddlers in the home.  Ken is both giving and
    asking for hugs.  Ken has broken three chain locks on
    their external back door as he is wanting to go outside
    and play on the swing.  When he has broken the locks he
    says, "bad boy Ken, you broke it Ken, you can't go in
    there in Ken".  During my visit Ken appeared to be happy
    as he was playing with the toys and sat on my lap for a
    period of time while we drew a stick figure of Ken.
    Later in the morning of this day, Reverend Lou Potter
    called me and stated that she had just met with the
    McQuaids and that they had given her verbal permission
    to speak with me.  Lou stated that they appeared to be
    having difficulty understanding the concerns regarding
    the locked doors.  Lou stated that they had told her
    that Ken would be confined to his room for a period of
    an hour when he was bad.  Lou stated that it was her
    opinion that they did care for their son but had very
    little practical parenting knowledge.  Lou stated that
    she advised them that a child three years of age should
    only receive a two to three minute time out for bad
    behaviour not an hour.  Lou suggested that they pick up
    a book on child development and one on parenting.

    [James Nov 29]
    7.  The visit on November 24, 1999, was scheduled
    between 4-5 pm.  I met Ken in the foyer at the office.
    When I told him it was time to see his mom and dad he
    stood motionless with a void look on his face and would
    not respond.  Hereafter this behaviour will be referred
    to as freezing.  I took this time to address their
    concerns about being audio and video taped.  I showed
    them the monitors located in the back kitchen that are
    hooked up to the video cameras in their room and
    explained that I was watching them on the monitors and
    making notes.  I explained to them the purpose of the
    set up of the room.  Ken was given a new stuffed toy and
    more chocolate.  Bob made something out of the blocks
    but did not invite Ken to interact with him.  Linda
    asked Ken if he wanted to go home, yes or no.  Ken did
    not respond.  She asked him again, Ken went and picked
    up his coat.  Ken unzipped the hood from the jacket and
    said, "bad boy Ken".  Linda offered to fix it.  Linda
    then asked again if he wanted to go home.  Ken made a
    whining noise this time and Bob invited Ken onto his lap
    and patted his back.  Ken got down and went over to the
    blocks.  He threw two of them.  Both parents responded
    by saying, "Don't throw blocks Ken, bad boy, pick them
    up Ken".  Ken then cleared the blocks from the table.
    His parents told him to pick them up, he did not.  Bob
    stated, bad boy Ken and then invited him onto his lap
    and read him a book.  Linda interrupted by asking Ken if
    he was mad at her.  Linda then asked Ken how he was.  No
    response.  Bob then asked Ken to pick up the blocks, Ken
    did so.  Linda then picked Ken up and sat him on her
    lap.  Ken struggled to get free.  The visit ended once
    again with no affectionate interaction.  Nina Little
    Alcorn and myself came into the room.  Ken did the
    "freezing" behaviour again when we had entered the room.

    [James Nov 29]
    8.  After the visit Nina Little Alcorn and myself met
    with Linda and Bob.  Nina had asked Linda and Bob how
    they were doing.  Linda responded that both she and Bob
    were not eating or sleeping very much.  Linda then
    stated that she was concerned about the long term
    affects and motioned toward Bob who was sitting beside
    her.  Linda then mouthed the words, "especially about
    him".  I gave feedback to the parents of my observations
    and suggested how they may interact with Ken during
    their visits.  I told Bob that I saw some good
    interaction between them when he was reading the books
    to Ken.  I suggested that when they bring the blocks,
    instead of them talking about the colours or the parents
    building something for Ken that they invite Ken to build
    something with them.  Nina had suggested that they get
    down to Ken's level and play.  Nina asked if they had
    read the pamphlet that she gave them.  They stated that
    they had not.  A discussion took place regarding day
    care centres and Nina gave them another handout on how
    to look for a day care provider and booked an
    appointment with them.

    [James Nov 29]
    9.  On November 25, 1999, this worker met Ken in the
    foyer again and asked if he was ready to go see mom and
    dad.  Ken gave this worker a hug and asked if I wanted
    to go to Kelsey's.  I told Ken no and said that he was
    going to visit mom and dad.  Ken displayed the
    'freezing' behaviour once again.  I called his name and
    rubbed his cheek and he snapped out of it.  When I took
    him to see his parents he greeted them happily but once
    again, no form of physical affection exchanged.  This
    visit was difficult to watch as the parents displayed
    inappropriate responses to Ken's attempts for consoling.
    This occurred when Bob and Linda began by asking Ken if
    he wanted to go home, if he wanted to go on the swing,
    over and over.  Ken went and got his coat, repeating
    what they were saying and went to put it on.  They then
    stated that they were not going.  Ken became upset by
    this and began to cry.  He went to his father for
    consoling.  Bob sat outstretched in his chair, his arms
    crossed in front of himself and did not move.  Ken
    attempted to prod at his father's hands, directly
    looking for physical contact, no response.  Not so much
    as a word was uttered by either parent to console Ken.
    Bob and Linda had bought Ken a toy cell phone.  Ken was
    happy to receive it and began to play with it
    immediately.  Ken was told by Linda not to break it, Bob
    took it away from him and put it in his pocket.  Ken
    became upset by this.  Bob redirected Ken's attention by
    picking him up onto his lap and read him a book.  Ken
    asked about the phone and Bob replied that it was too
    loud.  Ken got down and retrieved the blocks.  No one
    interacted with him.  Ken went to his father and asked
    about the phone again, no response.  Ken then went to
    his mother and pointed out a truck in the magazine that
    she was reading.  Linda repeated his words.  Ken went
    back to his dad and asked to get up, Bob responded and
    they began to read the book again.  Bob asked Ken where
    the clock was, referring to the clock in the book.  Ken
    looked at the clock on the wall.  Linda points to the
    clock on the wall and says, "what time is it Ken?".  Bob
    responds to Ken's answers by saying brilliant, vary
    smart.  Ken points to a broom in the book and Bob
    responds, "that's for cleaning up after you Ken, that's
    a broom".  Linda asks Ken if he is sleepy.  As soon as
    the book was finished Bob told Ken to go and bug his
    mom.  Linda sat forward and picked up her magazine.
    Linda then asked Ken how he was feeling and finally
    picked Ken up.  Ken sat on her lap a total of 30
    seconds.  This is when Bob and Linda began to question
    Ken about going home, going on the swing and Ken getting
    upset.  Once Ken calmed down on his own he went to the
    plastic birds that his parents had bought him.  Ken
    brings the birds to his father, no interaction engaged.
    Ken starts to throw the birds.  Linda and Bob tell Ken
    not to do this.  Linda says, "we don't like that bratty
    behaviour".  Ken echo's this.  Linda then says, "that's
    the cell door and that's the espionage window,"
    referring to the two way mirror.  Ken opens the door and
    says, "good boy, want to say good bye".  Bob asks Ken if
    he wants to go.  At 3:55 pm Bob gets the blocks and
    says, "I'm going to start and lets see if you can put
    some on".  Bob begins and then Ken puts the rest of the
    blocks on and Bob sits back on his chair, no longer
    engaged.  Bob says, "that's a good construction", Linda
    says, "that makes it stable".  Bob says to Linda that
    Ken does not understand and then laughs.  Linda returns
    to looking at her magazine.  Ken continues to build with
    the blocks.  Linda then places one of the birds on the
    blocks and says that they should have built a bird
    house.  Linda then asks Ken if he wants to go home, yes
    or no?  Ken responds by saying.  "do you want to go to
    Kelsey's?".  Linda says, "I think you'd be okay now, you
    wouldn't take a royal fit".  Bob says, "we will
    celebrate your release".  Ken puts a bird on the blocks
    and says make them fly and knocks them off the blocks.
    No response by parents.  Ken then asks, "want to take
    shoes off?".  No response.  Linda then asks Ken where
    his "furbee" is, Ken does not respond.  Ken goes over to
    the garbage pail and pulls out the toy wrapper and
    repeats five times, "that's a wrapper".  Bob then asks
    Ken for the wrapper.  They begin to point out letters of
    the alphabet.  Linda says, "I'd take you to Kelsey's
    now, I don't think you'd be as bad now".  Ken opens the
    door and says, "want to go to Kelsey's?" and shuts the
    door.  Linda replies, "don't slam the door Ken".

    [James Nov 29]
    10.  I enter the room at this point and Ken greets me
    and says, "want to go see mom and dad".  I attempt to
    redirect Ken by asking about his new toys.  I begin to
    play with the birds, pretending that they are flying.
    Ken begins to throw the birds.  Linda and Bob both say,
    "see that's what he always does".  Linda adds that it is
    usually his food and utensils that he throws.  I
    continue to show Ken how to make birds fly and
    redirecting him.  Ken asks again, "want to go see mom
    and dad" and moves toward the door.  Ken then leaves the
    room and goes to the foyer and greets his foster mom
    with "you want a hug?"

    [James Nov 29]
    11.  After this visit I met with Linda and Bob along
    with Kim Evans, Program Manager of Child Protection.
    This visit was prearranged in order to discuss the
    conditions of the agreement.  The first condition
    regarding day care was discussed.  Linda indicated that
    she had been to see a couple of them and that two of
    them were available December 1, 1999.  Linda stated that
    she had begun looking in September but that Bob didn't
    like the idea.  Linda would prefer to have Ken attend
    every day, Bob feels that every other day is good enough
    because he wants Ken at home with him.  Bob also stated
    that three days was enough exposure to other children
    and that they have great facilities around their own
    home, referring to the 67 acres that Ken can romp
    around.

    [James Nov 29]
    12.  The second condition is in reference to following
    through with Dr Murphy's recommendations.  They have an
    appointment to meet with Dr Murphy on December 21, 1999.
    Linda is wanting to ask the doctor about Ken's blood,
    they do not have an agenda set for discussion with Dr
    Murphy.

    [James Nov 29]
    13.  The third condition is following through with the
    Parent Infant Program.  They have a visit scheduled with
    Nina for December 7, 1999.  I asked if they have read
    the pamphlet Nina gave them, they said no.  I asked how
    they felt about the Parent Infant Program and whether
    they thought that it was an appropriate service in
    regard to Ken's needs.  They both stated that they did
    not know, that they would not know what the
    service/program was until Nina came to their home.

    [James Nov 29]
    14.  The fourth condition is in reference to the safety
    issues at home.  Bob replied that they have removed the
    lock from Ken's door, the light fixture was fixed and
    that they were painting his room.  Bob stated that I had
    not pointed out any other concerns and therefore in his
    opinion this condition had been complied to.

    [James Nov 29]
    15.  The fifth condition outlines releases of
    information from their doctors.  Bob stated that Dr Ross
    had informed him that the Society needs to initiate the
    forms.  I stated to Bob that I would get the appropriate
    forms for them to sign.

    [James Nov 29]
    16.  The sixth condition states parenting courses and
    counselling if recommended.  Bob stated that they have
    not done anything regarding this as it only states if
    recommended.  I informed Bob that I am recommending that
    counselling and a parenting capacity assessment be
    sought for the both of them.  I told them that they
    could call Toronto Hospital for Sick Children or
    McMaster Chedoke Hospital and request names to complete
    the parenting capacity assessment.

    [James Nov 29]
    17.  I then asked Linda about her comment yesterday with
    regard to her concerns about the long term affects on
    Bob.  Linda said she really didn't want to say anything
    in front of Bob.  I replied that she brought it up
    yesterday in front of Bob and that it was concerning me.
    Linda began to talk about their lawyer, Bob cautioned
    Linda that this was not information to share with us.
    Linda then stated that she felt that Bob was, "taking
    this thing too far.  He is wanting to move and I don't
    want to move".  Bob interrupted at this time and asked
    me if I was trying to drive them apart.  I replied that
    what I was trying to do was assess the current situation
    at home and to complete my investigation.  Bob replied
    that they did not have to answer any of my questions.  I
    informed him that it was my understanding from his
    lawyer that they were willing to cooperate with the
    Society.  Bob stated that he was cooperating and would
    only comply to the conditions set out in the agreement.
    I asked Bob if he was saying that he would not cooperate
    and answer my questions, he stated again that he would
    only comply with the conditions and would not discuss
    anything other than those conditions with me.  I then
    stated that based on my observations of their visits
    with Ken that I had great concerns regarding their
    parenting capacity.  I told them that even after making
    suggestions about increasing interaction they made
    little to no effort.  They had not shown an interest in
    the Parent Infant Program nor did I get the sense that
    they felt that it was applicable to them.  I then stated
    that it was very concerning that they made no effort to
    console Ken today when he became upset.  Linda stated
    that I was lying.  I stated that what I observed was Ken
    getting upset after they continued to ask him if he
    wanted to go home, on the swing, etc, Ken got his coat
    and they said that he could not go.  Ken became upset
    and went to Bob who sat there and I physically copied
    Bob's body posture.  I informed them that neither one of
    them so much as said a word to comfort Ken.  Again Linda
    stated that Ken did not get upset during their visit and
    that I was fabricating this because I was upset with
    them about what they had done.  I informed Linda that
    this was not personal on any level and that I was not
    the only one who had observed this visit.  I informed
    them that Kim Evans had also observed this session and
    Kim nodded her head in agreement.  They asked if Ken was
    going to be returned home on December 1, 1999.  I
    informed them that the Society would continue with the
    original application and request for Crown Wardship at
    this time.  The rational behind this is that there is
    concern about their parenting capacity and the cause of
    Ken's developmental delays is unknown at this time and
    now there is added concern of risk of flight if Ken is
    returned home.  I further stated that it is also
    concerning that Bob is not willing to cooperate, that
    they appear not to have an understanding or a concern
    regarding Ken's developmental needs.  The meeting ended
    by Linda stating that she was very angry, that this was
    not democratic, that this was a police state and that
    they had a right to a public forum and that they would
    use the public forum.  Linda further stated that I was
    upset with them because of the "e mail".  I informed
    Linda that she was entitled to her thoughts and
    opinions.  Bob stated that we had an agreement and could
    not arbitrarily change those conditions at any time.  I
    asked if they had any questions and they asked if they
    still had their visit with Ken.  I replied that they had
    scheduled supervised visits for tomorrow and next Monday
    and Tuesday.

    [James Nov 29]
    18.  I have had the opportunity to review the affidavit
    of Bob McQuaid sworn November 22, 1999.  In response to
    paragraph '3' it is concerning that Bob identifies Ken's
    behaviour as increasingly destructive but they have not
    sought professional help to date to help them deal with
    Ken's behaviour.  Linda has stated that she does not
    believe that Ken has a behaviour problem and yet both
    parents have demonstrated that they are unable to
    redirect Ken's behaviour and respond to his behaviour by
    confining him to his room.  In paragraph '5' Bob
    indicates that he is an active participant in feeding,
    clothing and changing Ken.  Linda has stated to this
    worker that she has been wanting to go and visit her
    brother in Denver but has not been able to do so because
    she would need to find someone to care for Ken.  Linda
    said that she would not feel comfortable leaving Ken
    alone in Bob's care as he does not do everything he
    should.  Linda further stated that Bob is good in
    helping change Ken's diapers and that is about it.  This
    information was shared the evening of November 16th and
    during her office visit with Ken on the 18th of
    November, 1999.  In paragraph '9', Bob states that he
    took the glass table apart and put it away, Linda
    indicated to myself on November 16th, that Ken had
    destroyed it.  In paragraph 10, Bob states that he is in
    support of Ken attending day care.  Linda has stated
    twice to me that Bob has been opposed to her wanting to
    put Ken into day care.  In paragraph 13, Bob states that
    Ken does not have free access to his toys.  A child this
    age should have access to toys for purpose of
    stimulating their development through pretend play.  A
    child at this age of development also spends a great
    deal of their time in what is known as solo play in
    order to learn to manipulate their environment.  It is
    also concerning that Bob stated that they supervise him
    and that they are not interacting with him.  In
    paragraph 14 Bob states that he gets out of the way of
    the cleaning ladies but leaves his toddler to follow the
    cleaning ladies around.  I thas been my experience that
    a toddler would get in the way of someone attempting to
    get something completed.  In paragraph 15, Bob states
    that the "Ken Monster" is a term of endearment to him
    and Linda.  I have observed this family interact for a
    total of four hours and have not once heard either one
    of them refer to Ken as the "Ken Monster".

    [James Nov 29]
    19.  I spoke with Catherine, the foster mother on
    November 29, 1999 inquiring as to how Ken was doing.
    She stated that since Friday, November 26, 1999, Ken has
    been laying on the living room floor in fetal position
    and sucking his thumb.  He remains in this position fro
    approximately 20 to 30 minutes at a time and then will
    get up and wander around the house aimlessly.  Catherine
    stated that while in this position he does not respond
    to their attempts to arouse him.  This continued until
    this morning.  Catherine stated that he has had a low
    grade fever as well and was wondering if this is normal
    behavior for Ken when he is not feeling well.  Overall,
    Catherine stated that she believes that Ken's behavior
    while in her home has been typical behavior of a
    toddler.  She has noticed signs of improvement in his
    speech, in socialization, affection, sense of humor,
    bath and bed time and eating - he is no longer spitting
    food out nor demonstrating throwing food or utensils as
    Linda indicates that Ken does at home.  Catherine stated
    that the only time that she has had difficulty with Ken
    was the afternoon of November 25th and the following
    morning.  I verily believe this to be true.  Please
    refer to Catherine's notes, attached as Exhibit "B".

    [James Nov 29]
    20.  My assessment of the matters of Ken McQuaid are as
    follows:  There is a substantial risk that Ken will
    suffer emotional harm if he is returned to the primary
    care and custody of Linda Prosh and Bob McQuaid.  I have
    observed Ken's parents interact with Ken.  There is
    concern regarding the level and type of attachment that
    they have with their son.  Little to no forms of
    physical affection or consoling, negative verbal
    messages.  Ken is demonstrating concerning 'freezing'
    behaviour and the parents have demonstrated a reluctance
    to work cooperatively and take an interest in the
    concerns that have been brought to their attention about
    their son's developmental delays.  A risk assessment has
    been completed with input from myself, Jennifer Moore
    and Kim Evans.  Jennifer Moore is a co-worker who has
    also had an opportunity to observe Ken interact with his
    parents.  The risk assessment is a tool designed to
    assist child protection workers in making a decision as
    to the risk of future harm to a child.  The outcome of
    the risk assessment is high and clearly indicates the
    identified areas of concern.  Please refer to Exhibit
    "C".  I have also attached a copy of the Safety
    Assessment which is a tool used to assess the immediate
    safety of children.  Please refer to Exhibit "D".
    Without information from Dr Murphy regarding the cause
    of Ken's developmental delays there is room to speculate
    that the delays may be due to lack of adequate care and
    environment.  A parent capacity assessment would address
    the concerns regarding quality and type of attachment
    and the ability of the parents to meet the needs of Ken.
    The Society has concern that if Ken is returned to his
    parents at this time that there is a risk of flight and
    more importantly the parents will increase the risk of
    developmental delays due to their lack of acknowledging
    the concerns and their lack of ability to change their
    parenting attitudes and styles in regard to Ken's
    present needs.

    [James Nov 29]
    21.  I make these statements with no improper intent.

    /signed/ Kim James

    Sworn/Affirmed before me at Town of Orangeville in
    Ontario on November 29, 1999.

    /signed/
    IRENE BEAZLEY
    A Commissioner, etc, Province of Ontario,
    for the Children's Aid Society.
    Expires September 27, 2000

    ........................................................

    Exhibit A  (Consent filed November 22, shown above)

    ........................................................

    Exhibit B

    (This document is handwritten)

    [Clauser] Nov 16, 99
    When Kim left Ken had to be restrained from hitting his
    head against the floor and the door.  He took a swing a
    (illegible) in franco's arms.  During a bath, (hair very
    dirty) he had to be restrained to stay in tub - wouldn't
    stand up and gripping side of tub.  Bed was the same
    procedure - had to restrain him and let him scream until
    he was exhausted.  His only communication is parroting,
    screaming and tantrums.

    [Clauser] Nov 17, 99
    Ken woke up at 9:00 am and I told him it was breakfast.
    He walked away so I picked him up and sat him at the
    table with no problems.  He was like a whole new kid
    today, no throwing food, no spitting food down the front
    of himself;  I think I can handle this.  He has
    compulsive behaviour turning lights on and off and
    closing doors.  Played with toys, but not with children.
    When he got tired, he started throwing toys and needed a
    time out.  When in T.O.  pulled a tantrum and was
    violent towards me.  Had a bath and went to bed with no
    problems.

    [Clauser] Nov 18, 99
    Good day today!  Only had to be reminded once not to
    throw toys.  He was giving Noah back his soother.  Still
    just mimmicking, but using the things he's heard to
    communicate.  ie "Want some breakfast, Ken?  Played in
    the bathtub.  Went to bed with no problem.

    [Clauser] Nov 19, 99
    Actually coming to me for a hug when he's upset.
    Follows me around mimmicking everything he's heard and
    is following simple directions;  time to eat please come
    sit at the table, please open the door.  Still in his
    own world, but sometimes sharing toys with the other
    kids.

    [Clauser] Nov 20, 99
    Good day!  No tantrums.  Woke up really early so he fill
    asleep during dinner.

    [Clauser] Nov 21, 99
    Wants hugs and kisses from me.  Good day!  Played in
    bathtub with other kids.  Only threw toys once and sat
    down for short T.O.  with no tantrum.  Drew a
    picture-scribbles, but first time he's picked up pencil
    without the "bad boy, don't touch that, Ken's a bad boy,
    don't break that" litany.

    [Clauser] Nov 22, 99
    Had a very bad morning, tantrum while changing diaper,
    tantrum because I wouldn't let him have a broken toy;
    he launched himself at me with feet and fists while
    holding Noah;  throwing toys, pushing other kids.  Had a
    nap, gave me a hard time, had to put him down twice, but
    woke up in a much better mood.  Went for visit with Mom
    & Dad and hugged me when he came out.  Wanted lots of
    hugs and kisses all right even from company we had.
    Played in the tub with Rachel and didn't hang on to the
    sides at all.  No problem putting to bed.

    [Clauser] Nov 23, 99
    As he interacts more with the children, he is pushing
    and hitting from lack of social skills.  Starting to
    share.  We went for a hair cut today and he was asking
    all the hairdressers for hugs.  Brenda was here and he
    wanted hugs and kisses from her and myself.  Had a
    temper tantrum during dinner because I wouldn't let him
    just drink juice so he refused to eat supper.  Played
    with everyone in the bathtub.  Went to bed with no
    problem.

    [Clauser] Nov 24, 99
    Good morning - lots of hugs.  Just before lunch he hit
    Hannah with a play bat in the head hard enough to bruise
    and welt.  Really inquisitive - playing with water in
    the sink and pouring it on the floor - normal kid stuff.
    Good evening.  Bath, bed no problems.

    [Clauser] Nov 25, 99
    Welcome to our world, Ken!!  Didn't "zone out" at all
    today, just tried to test the limits and see if temper
    tantrums work;  they didn't so he'd stop and go back to
    playing with the other kids.  When I woke him up from
    his nap, I asked him if he wanted to go see Mon & Dad -
    he lost it - held his breath till his lips turned blue
    and threw himself to the ground and started screaming.
    He went limp so I couldn't dress him and kept screaming
    until I got him in the car.  During supper started
    screaming and wouldn't stop;  I think it was a
    combination of finished his juice and wanted more, tired
    and continuation of tantrum from visit.  Whenever I have
    not been in eye sight of him he screamed and came to
    find me.  Like I stated before, I think he's coming into
    this world.  (When I T.O.  him today, he's say "want a
    hug" to deal his way out of T.O.) When he went to bed
    last night, he took all the movies in the headboard out
    of their cases and ripped out one tape and several
    covers.  This is the first time he has done anything
    destructive.

    ........................................................

    Exhibit C

    (The date on this document, Nov 20 1999, is a mistake,
    since that is a Saturday, and the document refers to
    events during visitation that started on Nov 22.  Nov 29
    is likely.  The Safety Assessment following also has an
    erroneous date.  The numbers 5478 are printed by the
    same machine printing our names.  I attribute the
    document to Kim Evans on the basis of the signature,
    though the first person references are from Kim James.
    -RTMQ)


    Dufferin Child and Family Services
    50 Fourth Ave, Unit #13
    Orangeville Ontario L0N 1N0

    McQuaid/Prosh, Robert and Linda
    5478

    Case Status:  Open
    Case Worker:  Kim James
    Classification:  Protection

    Risk Assessment

    Completed for Social Worker:  Kim James

    Reason for Report - Initial - within 21 days

    Caregiver's Name            Relationship
    Prosh, Linda                Mother
    McQuaid, Robert             Father

    Remarks:
    The information provided is based on conversations with
    Linda and Bob, and observations made during their daily
    visits with Ken.  This assessment was completed jointly
    with input from Jennifer Moore and Kim Evans as well as
    myself.

    Child's Name     McQuaid, Kenneth Darryl
    Child's D.O.B.   16/10/96

    --------------------------------------------------------
    CAREGIVER INFLUENCE
    --------------------------------------------------------

    CG1.  Abuse/Neglect of Caregiver

    4.  Severe abuse/neglect as a child.
    3.  Recurrent but not severe abuse/neglect as a child.
    2.  Episodes of abuse/neglect as a child.
    1.  Perceived abuse/neglect as a child with no specific
        incidents.
    0.  No perceived abuse/neglect as a child.
    9.  Insufficient information to make a rating.

        [Evans Nov 20]
    0   Prosh, Linda
    4   McQuaid, Robert

    Mr McQuaid was abandoned by his father and raised in
    foster care in the US.  Linda stated that he was
    severely abused while in care.  No specific details
    provided.

    --------------------------------------------------------

    CG2.  Alcohol or Drug Use

    4.  Substance use with severe social/behavioural
        consequences.
    3.  Substance use with serious social/behavioural
        consequences.
    2.  Occasional substance use with negative effects on
        behaviour.
    1.  Occasional substance use.
    0.  No misuse of alcohol or use of drugs.
    9.  Insufficient information to make a rating.

        [Evans Nov 20]
    0   Prosh, Linda
    0   McQuaid, Robert

    No evidence at this time.

    --------------------------------------------------------

    CG3.  Caregiver's Expectations of Child

    4.  Unrealistic expectations with violent punishment.
    3.  Unrealistic expectations with angry conflicts.
    2.  Inconsistent expectations leading to confusion.
    1.  Realistic expectations with minimal support.
    0.  Realistic expectations with strong support.
    9.  Insufficient information to make a rating.

        [Evans Nov 20]
    3   Prosh, Linda
    3   MaQuaid, Robert

    This worker is basing this variable on observations of
    the home environment, Ken's delays and the fact that the
    parents state that Ken is confined to his room.  Linda
    made several comments that when Ken is out of control
    she puts him in his room.  She had indicated that she
    does not know how to control his behavior and therefore
    there is probably some level of angry conflict.

    --------------------------------------------------------

    CG4.  Caregiver's Acceptance of Child

    4.  Rejects and is hostile to child.
    3.  Disapproves of and resents child.
    2.  Indifferent and aloof to child.
    1.  Limited acceptance of child.
    0.  Very accepting of child.
    9.  Insufficient information to make a rating.

        [Evans Nov 20]
    3   Prosh, Linda
    3   McQuaid, Robert

    Linda and Robert both indicated that Ken had destroyed
    their home and that is why they need to lock everything
    away from him.  There does not appear to be a bond
    between parents and child.  Initial contact, the parents
    did not acknowledge Ken at all.

    --------------------------------------------------------

    CG5.  Physical Capacity to Care for Child

    4.  Incapacitated due to chronic illness or disability
        resulting in inability to care for child.
    3.  Physical impairment or illness which seriously
        impairs child caring capacity.
    2.  Moderate physical impairment or illnesses resulting
        in only limited impact on child caring capacity.
    1.  Very limited physical impairment or illness with
        virtually no impact on child caring capacity.
    0.  Healthy with no identifiable risk to child caring
        capacity.
    9.  Insufficient information to make a rating.

        [Evans Nov 20]
    0   Prosh, Linda
    0   McQuaid, Robert

    --------------------------------------------------------

    CG6.  Mental/Emotional/Intellectual Capacity to Care
          for Child

    4.  Incapacitated due to mental/emotional disturbance
        or developmental disability resulting in inability
        to care for child.
    3.  Serious mental/emotional disturbance or
        developmental disability with seriously impairs
        child caring capacity.
    2.  Moderate mental/emotional disturbance or
        developmental disability with limited impairment of
        child caring capacity.
    1.  Symptoms of mental/emotional disturbance or
        developmental disability with no impact on child
        caring capacity.
    0.  No identifiable mental/emotional disturbance.
    9.  Insufficient information to make a rating.

        [Evans Nov 20]
    9   Prosh, Linda
    9   McQuaid, Robert

    Although both parents are high functioning and
    intelligent, it would appear as though intellectual
    capacity impairs their ability to care for their son
    adequately as they put their needs before his and do not
    understand Ken's need for interaction and a stimulating
    environment.

    --------------------------------------------------------
    CHILD INFLUENCE
    --------------------------------------------------------

    4.  Child younger than 2 years old, or older child with
        special needs.
    3.  Child older than 2 years old, not regularly visible
        in the community.
    2.  Child is under 12 years old, attends school, day
        care, or early childhood development program.
    1.  Child is over 12 years old, and younger than 16
        years old.
    0.  Child is 16 years old or older, with adequate
        self-sufficiency skills.
    9.  Insufficient information to make a rating.

        [Evans Nov 20]
    3   McQuaid, Kenneth Darryl

    Ken is chronologically 3 years of age but is
    developmentally delayed in speech and motor development,
    also in social development.

    --------------------------------------------------------

    C2.  Child's Response to Caregiver

    4.  Extremely anxious with uncontrolled fear,
        withdrawal, or passivity.
    3.  Very anxious with negative, disruptive, and
        possibly violent interaction.
    2.  Moderately anxious with apprehension and suspicion
        toward caregiver.
    1.  Marginally anxious with some hesitance toward
        caregiver.
    0.  Child trust and responds to caregiver in
        age-appropriate way.
    9.  Insufficient information to make a rating.

        [Evans Nov 20]
    4   McQuaid, Kenneth Darryl

    There is little to no interaction with parents.  Ken
    presents as passive, withdrawn and aloof to his parents
    presence.  There is minimal eye contact and his physical
    response to his mother was rigid or non-existent.  Ken
    has never kissed his mother.  These statements are based
    on observation between Ken and his mother.

    --------------------------------------------------------

    C3.  Child's Behaviour

    4.  Dangerous behaviour problems.
    3.  Serious behaviour problems.
    2.  Moderate but pervasive behaviour problems.
    1.  Minor behaviour problems.
    0.  No significant behaviour problems.
    9.  Insufficient information to make a rating.

        [Evans Nov 20]
    3   McQuaid, Kenneth Darryl

    Within his home, Ken has exhibited destructive behavior
    of objects and possessions.  He has been isolated from
    his parents and lacks socialization opportunities.  It
    should be noted that these behaviors have not been
    exhibited while in foster care.

    --------------------------------------------------------

    C4.  Child's Mental Health and Development

    4.  Incapacitated due to mental/emotional disturbance
        or developmental delay and unable to function
        independently.
    3.  Serious mental/emotional disturbance or
        developmental delay impairs ability to function in
        most daily activities.
    2.  Moderate mental/emotional disturbance or
        developmental delay impairs ability to perform some
        daily activities.
    1.  Symptoms of mental/emotional disturbance with
        minimal impact on daily activities.
    0.  No identifiable mental/emotional disturbance.
    9.  Insufficient information to make a rating.

        [Evans Nov 20]
    3   McQuaid, Kenneth Darryl

    Dr Murphy's preliminary assessment of Ken is that he has
    global developmental delays.  According to Ken's parents
    he displays symptoms of mental/emotional disturbances,
    such as inability to communicate and destructive
    behaviors to the extent that they have had to respond by
    confining him and isolating him from family interactions
    and sections of the home.

    --------------------------------------------------------

    C5.  Child's Physical Health and Development

    4.  Severe physical illness, disability, or lack of
        physical development;  requires medical care.
    3.  Serious physical illness, disability, or lack of
        physical development;  restricts activities without
        special care.
    2.  Moderate physical illness, disability, or lack of
        physical development;  restricts activities
        somewhat but overcome with special care.
    1.  Mild physical illness, disability, or lack of
        physical development;  does not restrict
        activities.
    0.  Healthy and no obvious physical illness,
        disability, or lack of physical development.
    9.  Insufficient information to make a rating.

        [Evans Nov 20]
    0   McQuaid, Kenneth Darryl

    According to Dr Murphy Ken is a healthy Child

    --------------------------------------------------------
    FAMILY INFLUENCE
    --------------------------------------------------------

    F1.  Family Violence

    4.  Repeated or serious physical violence or
        substantial risk of serious physical violence in
        family.
    3.  Incidents of physical violence in family;
        imbalance of power and control.
    2.  Isolation and intimidation;  threats of harm.
    1.  Verbal aggression.
    0.  Mutual tolerance.
    9.  Insufficient information to make a rating.

        [Evans Nov 20]
    3   Family Situation.

    Linda states the following about her relationship with
    Robert, "there is no physical violence.  There is a lack
    of cooperation between myself and Robert.  He doesn't
    help me do anything, he expects me to do all of the
    housework and attend to Ken.  He is self sufficient,
    everything is in his name.  He doesn't really discuss
    things with me".  Linda did not state that she was being
    emotionally abused but the above information may
    indicate that she is being emotionally abused.

    --------------------------------------------------------

    F2.  Ability to Cope With Stress

    4.  Chronic crisis with limited coping.
    3.  Prolonged crisis strains coping skills.
    2.  Stabilized after period of crisis.
    1.  Resolution without adverse effect.
    0.  Free from stress influence.
    9.  Insufficient information to make a rating.

        [Evans Nov 20]
    9   Family Situation.

    At this time this worker does not know this family very
    well.  Linda has indicated that she attempted suicide
    when she was 21 years old.  It appears as though Mr
    McQuaid becomes reclusive.

    --------------------------------------------------------

    F3  Availability of Social Supports

    4.  Effectively isolated.
    3.  Some support, but unreliable.
    2.  Some reliable support, but limited usefulness.
    1.  Some reliable and useful support.
    0.  Multiple sources of reliable and useful support.
    9.  Insufficient information to make a rating.

        [Evans Nov 20]
    4   Family Situation.

    This family is socially isolated as a choice.  They
    definitely have the means and capacity to access
    supports if need be but they choose to be reclusive.

    --------------------------------------------------------

    F4.  Living Conditions

    4.  Extremely unsafe;  multiple hazardous conditions
        that are dangerous to children and have caused
        physical injury or illness.
    3.  Very unsafe;  multiple hazardous conditions that
        are dangerous to children.
    2.  Unsafe;  one hazardous condition that is dangerous
        to children.
    1.  Fairly safe;  one possibly hazardous condition that
        may harm children.
    0.  Safe;  no hazardous conditions apparent.
    9.  Insufficient information to make a rating.

        [Evans Nov 20]
    3   Family Situation.

    Initial observations of home are that there were
    multiple hazardous conditions that pose physical danger
    to Ken.  Also household sanitation is a factor.  This is
    more disturbing factoring in that Molly Maid cleans the
    home every two weeks.

    --------------------------------------------------------

    F5.  Family Identity and Interactions

    4.  Negative family interactions.
    3.  Family interactions generally indifferent.
    2.  Inconsistent family interactions.
    1.  Family interaction usually positive.
    0.  Family interactions typically supportive.
    9.  Insufficient information to make a rating.

        [Evans Nov 20]
    4   Family Situation.

    The parents do not have consistent caring interaction
    with their son.  They do not provide a nurturing or
    stimulating environment for him.  Linda stated that she
    did not know when his last meal was, she thought that
    Robert may have fed him lunch but she was not sure and
    did not know what he had.

    --------------------------------------------------------
    INTERVENTION INFLUENCE
    --------------------------------------------------------

    I1

    4.  No motivation to meet child's needs.
    3.  Very little motivation to meet child's needs.
    2.  Motivated to meet child's needs, but caregiver has
        multiple impediments to solving problems.
    1.  Motivated to meet child's needs, but caregiver has
        some impediments to solving problems.
    0.  Motivated to meet child's needs, and caregiver has
        not impediments to solving problems.
    9.  Insufficient information to make a rating.

        [Evans Nov 20]
    3   Prosh, Linda
    3   McQuaid, Robert

    --------------------------------------------------------

    I2.  Caregiver's Cooperation with Intervention

    4.  Refuses to cooperate.
    3.  Cooperates minimally, but resists intervention.
    2.  Cooperates, but poor response to interventions.
    1.  Cooperates, with generally appropriate response to
        intervention.
    0.  Cooperates with intervention.
    9.  Insufficient information to make a rating.

        [Evans Nov 20]
    0   Prosh, Linda
    3   McQuaid, Robert

    Robert has stated that he will "comply" with the
    agreement reached until the next court date.  He has not
    been forthcoming with information to assist in the
    investigation.

    --------------------------------------------------------
    ABUSE/NEGLECT INFLUENCE
    --------------------------------------------------------

    A1. Access to Child by Perpetrator

    4.  Open access with no adult supervision.
    3.  Open access with ineffective adult supervision.
    2.  Open access with effective adult supervision.
    1.  Limited access with effective adult supervision.
    0.  No access to child.
    9.  Insufficient information to make a rating.

        [Evans Nov 20]
    4   Prosh, Linda
    4   McQuaid, Robert

    In this case, the parents have committed an act of
    omission.  Should Ken be returned to his home, there is
    no indication that his needs would be met, thus acts of
    omission would continue.

    --------------------------------------------------------

    A2.  Intent and Acknowledgement of Responsibility

    4.  Deliberate or premeditated abuse or neglect.
    3.  Hides or denies responsibility for abuse/neglect.
    2.  Rationalizes abuse/neglect or doesn't understand
        role.
    1.  Understands role in abuse/neglect; accepts
        responsibility.
    0.  Abuse is accidental or neglect is not deliberate.
    9.  Insufficient information to make a rating.

        [Evans Nov 20]
    4   Prosh, Linda
    4   McQuaid, Robert

    Linda has admitted that they limit Ken's access and
    leave him unattended for periods of time.

    --------------------------------------------------------

    A3.  Severity of Abuse/Neglect

    4.  Extreme harm or substantial danger of extreme harm.
    3.  Serious harm of substantial danger of serious harm.
    2.  Moderate harm or substantial danger of moderate
        harm.
    1.  Minor harm or substantial danger of minor harm.
    0.  No harm or substantial danger of harm.
    9.  Insufficient information to make a rating.

        [Evans Nov 20]
    3   Prosh, Linda
    3   McQuaid, Robert

    Parents have created substantial risk of physical injury
    through lack of supervision of their son.  They have
    failed to meet his needs of emotional care through lack
    of interaction and an environment void of nurturance or
    stimulation.

    --------------------------------------------------------

    A4.  History of Abuse/Neglect Committed by Present
         Caregivers

    4.  Severe or escalating pattern of past abuse/neglect.
    3.  Serious recent incident or a pattern of
        abuse/neglect.
    2.  Previous abuse/neglect.
    1.  Abuse/neglect concerns.
    0.  No history of abuse/neglect.
    9.  Insufficient information to make a rating.

        [Evans Nov 20]
    0   Prosh, Linda
    0   McQuaid, Robert

    No internal record of police records

    --------------------------------------------------------
    RISK ANALYSIS WORKSHEET
    --------------------------------------------------------

    A.  List, in point form, all risk factors which received
    a rating of 3 or 4 and any other risk factors that
    should be considered:

          [Evans Nov 20]
    CG1.  Abuse/Neglect of Caregiver - 4
    C2.   Child's Response to Caregiver - 4
    F3.   Availability of Social Supports - 4
    F5.   Family Identity and Interactions - 4
    I2.   Caregiver's Cooperation with Intervention - 4
    A1.   Access to Child by Perpetrator - 4
    A2.   Intent and Acknowledgement of Responsibility - 4

    CG3.  Caregiver's Expectations of Child - 3
    CG4.  Caregiver's Acceptance of Child - 3
    CG6.  Mental/Emotional/Intellectual Capacity to Care
          for Child - 3
    C1.   Child's Vulnerability - 3
    C3.   Child's Behavior - 3
    F1.   Family Violence - 3
    F4.   Living Conditions - 3
    I1.   Caregiver's Motivation - 3
    A3.   Severity of Abuse/Neglect - 3

    F2.   Ability to Cope with Stress - 9

    B.  Describe the significance and interaction of the
    risk factors which contribute to an overall risk rating
    and should be considered in Plan of Service:

    [Evans Nov 20]
    The greatest significance is that all of these risk
    factors increase due to Ken's age.  Parents have failed
    to provide a safe, secure, nurturing and stimulating
    environment for their son through confinement and lack
    of supervision.  There is little to no interaction with
    their child and there is a possibility that Ken has not
    met his developmental milestones due to lack of a
    positive environment.

    C.  Describe significant family or individual strengths
    which have been identified and may be used as part of
    the service plan to reduce future risk:

    [Evans Nov 20]
    Parents have the mental capacity to learn appropriate
    child care.

    D.  Describe how relevant family members view the
    identified risk elements and any other areas of family
    functioning identified in C, above:

    [Evans Nov 20]
    Linda stated that she would do anything to have her son
    back, however her insight into the problems is not
    accurate.  For example, she focused on her lack of
    housekeeping as being a large issue as opposed to the
    very apparent safety and developmental issues that
    directly impact on Ken.

    E.  Give rating or overall risk for family

    [Evans Nov 20]
    High Risk             (This item checked)
    Moderately High Risk
    Intermediate Risk
    Moderately Low Risk
    No/Low Risk

    F.  Identify the key risk factors and the expected
    outcomes which should be addressed in this family's Plan
    of Service:

    [Evans Nov 20]
    CG1, C2, F3 & 5, I2, A1 & 2, CG3, 4 & 6, C1 & 3, F1 &
    4, I1, A3 & F2

    --------------------------------------------------------
    SEND FOR APPROVAL
    --------------------------------------------------------

    Supervisor:  Kim Evans

    Date Risk Assessment Completed:  20/11/99

    --------------------------------------------------------
    APPROVAL SECTION
    --------------------------------------------------------

    Approved Document:  Yes No  (neither checked)
    Approved By:   (not filled in)
    Changes Required:  (option checked)

    ........................................................

    Exhibit D

    Dufferin Child and Family Services
    50 Fourth Ave, Unit #13
    Orangeville Ontario L0N 1N0

    McQuaid/Prosh, Robert and Linda
    5478

    Case Status:  Open
    Case Worker:  Kim James
    Classification:  Protection

    Safety Assessment

    Completed for Social Worker:  Kim James

    Caregiver's Name            Relationship
    Prosh, Linda                Mother
    McQuaid, Robert             Father

    Child's Name     McQuaid, Kenneth Darryl
    Child's D.O.B.   16/10/96

    Safety Factors

    1.  Caregiver's behaviour is violent or out of control

    Not Known

    At this time is does not appear that the parents
    behavior has been violent or out of control, but given
    that Ken is unable to communicate, this may never be
    known.

    2.  Caregiver describes or acts toward child in
    predominantly negative terms or has extremely
    unrealistic expectations.

    Yes

    The parents have left Ken unattended for an undetermined
    length of time and they do not understand why he would
    destroy their home.  They are not able to redirect him
    or control his behavior.  Linda stated that when she
    takes him for walks she does not understand why she has
    to carry him back.  Also neither parent picked up on his
    developmental milestone delays quickly.

    3.  Caregiver caused, or has made a plausible threat
    that has or would result in, serious physical harm to
    the child.

    Not Known

    This is unknown as Ken is unable to communicate.

    4.  Child's whereabouts cannot be ascertained and/or
    there is reason to believe that the family is about to
    flee or refuse access to the child

    No

    Not an issue.

    5.  Caregiver has not, or will not, provide sufficient
    supervision to protect the child from potentially
    serious harm.

    Yes

    This is the main reason for our involvement.  They have
    left Ken unattended for an unknown amount of time.  He
    has basically been confined within his own home and
    locked out of many rooms.

    6.  Caregiver has not, or is unable, to meet the child's
    immediate needs for food, clothing, shelter, and/or
    medical care.

    No

    Ken appears to be a healthy boy and he has had all of
    his immunization shots.

    7.  Caregiver has previously harmed a child and the
    severity of the harm, or the caregiver's prior response
    to the incident, suggests that child safety may be an
    immediate concern.

    No

    There is no prior internal record, or police record.

    8.  Child is fearful of people living in or frequenting
    the home.

    Not Known

    Ken is unable to communicate this to us.  My
    observations are that Ken appears to be indifferent to
    his parents.

    9.  The child's physical living conditions are hazardous
    and may cause serious harm to the child.

    Yes

    This is another reason for our involvement.  Ken's
    bedroom had many hazardous conditions in it as well as
    unprotected heating vents that Ken could fall into and
    cut or break his leg.

    10.  Child sexual abuse is suspected and circumstances
    suggest that child safety may be an immediate concern.

    No

    Not at this time.

    11.  Caregiver's drug or alcohol use seriously affects
    his/her ability to supervise, protect, or care for each
    child.

    No

    There is no indication at this time that this is a
    factor.

    12.  Other (specify):

    No

    SAFETY DECISION
    Child to be apprehended and brought to a place of
    safety.

    SAFE No children considered to be in immediate danger
    of serious harm.
    UNSAFE Child considered to be unsafe without a
    protection intervention.
    (UNSAFE option checked)

    IMMEDIATE SAFETY PLAN:
    Apprehend and bring to a place of safety

    OTHER INTERVENTIONS/ACTIONS REQUIRED:
    No additional interventions/actions
    Risk assessment has been initiated
    (Risk assessment checked)
    Full medical to determine whether Ken's delays are
    genetic or environmental

    Date of Completion:  16/11/99



    APPROVAL SECTION
    Approved Document:  Yes No  (neither checked)
    Approved By:   (not filled in)
    Changes Required:  (option checked)

    --------------------------------------------------------

    Ontario Court of Justice
    at 10 Louisa Street, Orangeville, Ontario L9W 3P9

    Court File Number 180/99

    Form 14A: Affidavit (General) dated December 2, 1999

    Applicant

    The Children's Aid Society of the County of Dufferin
    50 Fourth Avenue, Unit 13
    Orangeville Ontario L9W 4P1 Canada
    Phone:  519-941-1530
    Fax:  519-941-1562
    email:  dcafs@hurontario.net

    Wardlaw, Mullin, Carter, Thwaites and Ward
    Attention:  David Thwaites 235 Broadway
    Orangeville Ontario L9W 2Z5 Canada
    Phone:  519-941-1760
    Fax:  519-941-3688
    eMail:  dthwaites@wardlaw.on.ca

    Respondents

    Robert McQuaid
    RR #5  Orangeville Ontario L9W 2Z2 Canada
    Phone:  940-9847

    Linda Prosh
    RR #5  Orangeville Ontario L9W 2Z2 Canada
    Phone:  940-9847

    My name is Kim James
    I live in Orangeville Ontario
    and I swear/affirm that the following is true:

    I, Kim James, of the Town of Orangeville in the County
    of Dufferin, make oath and say:

    [James Dec 2]
    1.  I am a employed with Dufferin Children's Aid Society
    as a Child Protection Intake Worker.

    [James Dec 2]
    2.  On November 26, 1999, Jennifer Moore, a co-worker of
    mine, supervised the visit of Ken McQuaid and his
    parents.  Linda Prosh and Bob McQuaid.  Jennifer
    observed much of the same interaction that had taken
    place in the previous four visits.  A notable and
    positive change is that Ken kissed his mother today for
    the first time ever.  Ken kisses his mother a few more
    times during the visit when asked by his mother to give
    her a kiss.  Near the end of the visit Bob states that
    he never kisses him, only hugs him.  It has been a
    regular occurrence that the parents ask Ken over and
    over if he wants to go home, if he loves them, if he
    wants to go in the truck, if he remembers their dog and
    cat.  Ken responds to this by retrieving his coat and
    then parents say no that he can't go.  This confuses and
    upsets Ken.  Another pattern that has been prominent
    during the visits is the negative self messages that
    they give Ken.  "Ken you broke it, bad boy Ken".  During
    this visit Ken was playing with the blinds in the room.
    The parents made no attempts to redirect Ken and he
    eventually broke the blinds.  Bob gave Ken permission to
    wreck them "that's okay let him wreck them".  Ken said,
    "I'm not a bad boy".  Mom responded by saying, "Ken
    wrecked it I think".  The blind cord was fully extended
    and a potential choking hazard by now.  Bob responds by
    saying, "they're the ones who say he's never
    destructive".  Mom replies with, "Ken you can hang
    yourself on that, then we can sue them for having unsafe
    things".  Bob and Linda continue to allow Ken to play
    with the blinds and Linda says to Ken, "I didn't break
    them, you're the one playing with them".  This single
    event causes great concern.  The parents once again
    demonstrate that they do not redirect his misbehaviour.
    Not only that but during their care and supervision they
    have allowed Ken to place himself in a potentially
    dangerous situation, indirectly coaching him along with
    it.  Instead of putting Ken's safety needs first they
    allow him to continue to meet their needs and goals
    which at this time is to demonstrate to the Society that
    Ken is destructive and the opportunity to sue the
    Society for harm to their son.  I understand that the
    parents are upset with the Society at this time but they
    have not demonstrated adequate parenting.  There were
    two other negative references to Ken, he broke a Mickey
    Mouse watch and the time that he took Linda's wallet and
    threw it out.  This information is based on Jennifer
    Moore's case notes and I verily believe them to be true.

    [James Dec 2]
    3.  It is after this visit that Ken began to demonstrate
    extremely concerning behaviours at the foster home.  Ken
    assumed the fetal position on the floor sucking his
    thumb.  He would maintain this position for
    approximately 20 to 30 minute intervals.  No matter what
    the foster parents attempted to arouse Ken from this
    state, Ken would not respond.  This behaviour continued
    over the weekend and after his visits on November 29 and
    30.  Originally the foster mother thought that Ken's
    behaviour may have been due to the fact that he had a
    low grade fever during the weekend.  Ken did not have a
    fever on November 29 and 30.

    [James Dec 2]
    4.  On December 1, Ken did not have a visit with his
    parents and the foster mother reports that Ken's
    behaviour was very good.  No headbanging, screaming,
    freezing or fetal position.

    [James Dec 2]
    5.  I observed the visits on November 29 and 30 and
    noted some areas of improvement.  On Monday, Ken's
    maternal uncle accompanied Linda and Bob to visit with
    Ken.  His uncle demonstrated interactive play with Ken
    while playing with the blocks and the wooden puzzle Ken
    kissed his mother again upon request.  There continued
    to be negative self messages.  The parents also made a
    greater attempt to redirect Ken's behaviour.  Linda was
    able to successfully redirect Ken on three occasions by
    engaging him another appropriate activity.  Although
    there was notable improvement, much of the hour was
    spent in a teaching capacity and parents observing Ken
    playing with toys.  Ken did throw the blocks again in
    the visit on Tuesday.  Parents continued to set Ken up
    for disappointment by asking him about going home, etc.
    Bob did make attempts on Tuesday to console Ken.  Ken
    fell and hit his head on the floor and Bob picked him
    up, held him, and rocked him in his lap and gave him
    comforting words.

    [James Dec 2]
    6.  I attended the parents home along with Trish Cox on
    November 30 to complete a home safety.  Trish Cox will
    be their Family Service Worker when the file is
    transferred.  The house was very clean and it was
    evident that Linda and Bob had made great efforts to
    respond to the potentially hazardous conditions that I
    had identified earlier.  We noted some hazards to the
    parents such as putting alcohol, prescription and
    nonprescription medication up or under lock, as well as
    makeup.  The locks had been removed from Ken's bedroom,
    the two bathrooms, a hall closet and the kitchen.  Their
    master bedroom, Bob's two offices and the basement and
    laundry room doors remain locked.  This is acceptable to
    the Society.  The greatest improvement was Ken's
    bedroom.  It has been painted, the potentially hazardous
    conditions have been addressed, his toys and dresser
    have been returned to his room.  It is pleasant and
    child focussed.  We also advised them to put approved
    child safety locks on the cabinet doors in the kitchen
    and bathrooms as well as child safety plugs in the
    electrical outlets that were still exposed.  Linda and
    Bob informed us that Ken cannot get outside and is not
    outside unless he is with one of them.  We did note that
    they do have a pool that is surrounded by the house on
    three sides but there is no fence restricting access to
    a potentially hazardous situation, whether the pool is
    filled with water or not.  There is also a balcony off
    the living room which has a large enough space between
    the cement floor and the railing that would allow Ken to
    fall two stories.

    [James Dec 2]
    7.  Linda and Bob have made reasonable efforts to comply
    with the conditions in the agreement with the Society.
    The conditions set out in the agreement was not an
    exhaustive list of our concerns as we had stated that
    this is preliminary action that needs to occur in order
    to consider possibly returning Ken home and when.  There
    are outstanding concerns that still remain.  Linda and
    Bob have stated that the reason for the locks on the
    doors was their response to keeping Ken safe.  The
    concern that now arises is how will they address the
    safety of Ken now that the locks have been removed from
    some of the doors?  What were there safety concerns
    prior to our involvement that they felt they needed to
    lock Ken out?  They have not demonstrated an ability to
    redirect Ken's behaviour on a regular basis and they
    have not received any from of parenting regarding
    managing children's misbehaviour.  Therefore the concern
    remains that we have removed their means of child
    management and it has not been adequately replaced to
    address Ken's behaviour or his needs.  The other
    condition that has not been satisfactorily met to the
    Society's standard is in regard to the Parent Infant
    Program.  Linda and Bob have met Nina, who will be the
    Parent Infant Worker and have arranged a home visit with
    her.  What is not satisfactory at this time is neither
    Linda Nor Bob appear to be interested in the program,
    they have not taken the time to read the information
    about the service.  They have not understood or
    recognized the reason for service being to help
    stimulate Ken due to his developmental delays and that
    they will be required to be active participants in
    learning how to interact with him.  Nina has informed
    them that she has rearranged her scheduled appointments
    to accomodate them at this time and has taken them onto
    her full caseload although there is an existing wait
    list for service.  This program is designed to assist
    families that require and want the help.  Nina has
    stated to Linda, Bob and myself that it will not suffice
    to provide service to this family if the only reason why
    they are involved is due to compliance with the
    agreement as it is extremely important that the parents
    recognize and identify that their child is requiring
    support services.  The Parent Infant Program is a family
    centered-relationship based intervention.

    [James Dec 2]
    8.  The Society has contacted Diane Benoit, Child
    Psychiatrist affiliated with Toronto Sick Children's
    Hospital, and inquired as to whether she would be able
    to complete a parenting capacity assessment and the
    earliest availability.  Diane informed this Society that
    she would be able to accomodate this as early as the
    week between Christmas and New Years and have a report
    ready by mid January.  A general inquiry was made with
    regard to Ken's fetal position behaviour and Diane
    responded that this is very concerning.

    [James Dec 2]
    9.  At the time that the Society entered into the
    agreement with Linda and Bob, some concerns were
    identified such as;  the conditions within the home, the
    apparent lack of stimulation to Ken, developmental
    delays of Ken and the lack of parenting knowledge and
    the parenting capacity.  The conditions outlined were to
    address those identified areas, recognizing that
    compliance was not necessarily going to result in
    returning Ken on December 1, as there were other
    concerns.  Since signing the agreement the Society has
    had an opportunity to observe the parents interact with
    Ken which has resulted in very concerning inadequacies
    with parenting, interaction, and attachment.  Ken has
    also demonstrated concerning behaviours that may be
    related to his visitations with his parents.  It is with
    this new information that the Society does not believe
    that it would be in Ken's best interests at this time to
    return home to his parents care and custody.  Without
    the parents demonstrating that they can effectively
    manage Ken's behaviour and meet his developmental needs,
    Ken is at risk of further harm.

    [James Dec 2]
    10.  On November 30, I presented this case to our Child
    Abuse Review Team.  It is expected that every Society
    have a review team that includes persons who are
    professionally qualified to perform medical,
    psychological, developmental, educational or social
    assessments and at least one legally qualified medical
    practitioner.  This is a standard under the Child and
    Family Services Act.  On this day a medical
    practitioner, a Principal, the Executive Director of
    Family Transition Place, a Program Manager of Children's
    Mental Health and Child Protection, as well as myself
    were present.  The case was reviewed and it was the
    Review Teams decision and recommendation that Linda
    Prosh and Bob McQuaid be placed immediately on the Child
    Abuse Registry due to Severe Emotional Abuse to Ken.

    [James Dec 2]
    11.  I make there statements with no improper intent.

    /signed/  Kim James

    Sworn/Affirmed before me at The Town of Orangeville
    in Ontario on December 2, 1999.

    /signed/

    IRENE BEAZLEY
    A Commissioner etc, Province of Ontario
    for the Children's Aid Society
    Expires September 27, 2000

    --------------------------------------------------------

    ONTARIO COURT OF JUSTICE
    10 LOUISA STREET, ORANGEVILLE

    Court File Number 180/99

    Form 14A: Affidavit (General)
    date December 1, 1999

    Applicant

    The Children's Aid Society of the County of Dufferin
    50 Fourth Street Unit 13
    Orangeville Ontario L9W 4P1
    (519)941-1530 phone
    (519)941-1525 fax

    Wardlaw Carter Mullin Thwaites and Ward
    David Thwaites
    235 Broadway, Orangeville ON
    941-1760 phone
    941-3688 fax

    Respondents

    Linda Prosh/Robert McQuaid
    RR #5 Orangeville ON L9W 2Z2
    940-9847

    Huber & Heersche
    Evelyn D Huber
    184 Broadway Orangeville ON L9W 1K3
    (519)940-4500 phone
    (519)940-4502 fax

    My name is Linda Prosh
    I live in Township of Mono, County of Dufferin
    and I swear/affirm that the following is true:

    [Prosh Dec 1]
    1.  I am the Respondent in this matter and therefore
    have knowledge of the issues before the court.

    [Prosh Dec 1]
    2.  Shown to me now and attached as Exhibit "A" are
    photographs of our home taken after November 22, 1999.
    They show the changes made to the home and particularly
    to Ken's room.  We have addressed the concerns raised by
    the CAS in their visit on November 22, 1999 to our home.

    [Prosh Dec 1]
    3.  Shown to me now and attached as Exhibit "B" is a
    copy of a letter from our family physician, Dr Stephen
    Ross dated November 30, 1999.

    [Prosh Dec 1]
    4.  I make this affidavit in support of my Application
    to have my child returned.

    /signed/ Linda Prosh

    SWORN before me at the Town of
    Orangeville, in the County of Dufferin
    this 1st day of December, 1999

    /signed/

    A Commissioner etc.

    ........................................................

    Exhibit B

    Tottenham Medical Centre
    Tottenham Professional Building

    BOX 2000, 119 QUEEN ST NORTH
    TOTTENHAM ONTARIO L0G 1W0

    TOTTENHAM OFFICE:  (905) 936-4211-2-3
    FAX:  (905) 938-3493

    MICHAEL RODSON MB ChB
    ALAN WARD MD
    WILLIAM R MILLIGAN MD
    STEPHEN G ROSS, M Ec MD CCFP
    DENISE D'ADDARIO MD
    M GLINSKI-COMEN PhD MD
    DONINIQUE LUSSIER MD
    R A NISHIKAWA MD CCFP

    Evelyn Huber
    184 Broadway Ave
    Orangeville Ontario
    L9W 1K3

    Re:  Kenneth McQuaid

    Dear Ms Huber,           November 30, 1999

       It has come to my attention that Kenneth McQuaid is
    now under Childrens Aid Society protection.

       Previously I have identified some concerns with this
    child's development and the parents responses.  I have
    previously referred the child for Pediatrics and
    Occupational Therapy Assistance.

       At no point did I feel that the child was the subject
    of abuse nor did I feel that either parent would be
    hurtful to this child.  I would hope that Kenneth could
    again return to his parents, and that they could receive
    some assistance in parenting.

    Sincerely,

    /signed/

    Dr Stephen Ross

    --------------------------------------------------------

    ONTARIO COURT OF JUSTICE
    10 LOUISA STREET, ORANGEVILLE

    Court File Number 180/99

    Form 14A: Affidavit (General)
    date December 2, 1999

    Applicant

    The Children's Aid Society of the County of Dufferin
    50 Fourth Street Unit 13
    Orangeville Ontario L9W 4P1
    (519)941-1530 phone
    (519)941-1525 fax

    Wardlaw Carter Mullin Thwaites and Ward
    David Thwaites
    235 Broadway, Orangeville ON
    941-1760 phone
    941-3688 fax

    Respondents

    Linda Prosh/Robert McQuaid
    RR #5 Orangeville ON L9W 2Z2
    940-9847

    Huber & Heersche
    Evelyn D Huber
    184 Broadway Orangeville ON L9W 1K3
    (519)940-4500 phone
    (519)940-4502 fax

    My name is Robert McQuaid
    I live in Township of Mono, County of Dufferin
    and I swear/affirm that the following is true:

    [McQuaid Dec 2]
    1.  I am the Respondent in this matter and therefore
    have knowledge of the issues before the court.

    [McQuaid Dec 2]
    2.  I have had the opportunity to review the most recent
    affidavits of Kim James dated November 29, 1999 and
    December 2, 1999.

    [McQuaid Dec 2]
    3.  I have grave concerns at the behaviour Ken is
    currently exhibiting in his Foster environment.  There
    is certain behaviour that is being described that I have
    never seen him exhibit when in our care.

    [McQuaid Dec 2]
    4.  Specifically, Ken has never "frozen" as Ms James
    describes in her November 29, 1999 affidavit.  I have
    never seen him go into a fetal position as described by
    Ms James.  My wife, Linda Prosh advises me, that she has
    never witnessed the child exhibit either of these
    behaviours either.

    [McQuaid Dec 2]
    5.  I believe that Ken is feeling frightened and
    disorientated with the current situation and is acting
    in an unusual fashion.

    [McQuaid Dec 2]
    6.  The CAS had made in issue with us that Ken had not
    been behaving destructively in Foster care, initially
    anyway.  When Ken started to become destructive at the
    CAS office during one of our visits, I did not
    intervene, as I would ordinarily have, in order that the
    CAS might witness some of the behaviour we had described
    to him.  I am concerned that Ken tried to play on the
    swings at the Foster home that are in the back yard and
    that is the reason for his having broken the lock there.
    It is very much a part of Linda's routine with Ken to
    play on the swings with him.

    [McQuaid Dec 2]
    7.  I wish to reiterate that the environment at the CAS
    office is entirely unnatural and not conducive to any
    normal interaction with Ken.  Ken is feeling distraught
    at the separation and needs to come home.  We have lined
    up a number of professionals who are going to assist us
    in dealing more effectively with Ken.  We only ask the
    opportunity to effect those changes.  In order to do so,
    Ken must be returned home.  Ken is very loved by Linda
    and me.  We are both very private with our feelings in a
    public environment.  We look forward to entering into a
    meaningful relationship with a counsellor in order to
    assist us.  We have made contact with William Weiner, a
    counsellor in Orangeville.  We met with Will on November
    30, 1999 and discussed with him our situation, the CAS
    involvement and our desire to retain him to assist us in
    parenting.  We have another visit set up on December 7,
    1999 with Ken so that he might observe us.  We have
    provided our consent to allow Will to discuss this
    matter with the CAS.  We believe that this type of
    counselling would be significantly more productive than
    a generic parenting course.

    [McQuaid Dec 2]
    8.  The CAS has mentioned to us that they may wish a
    parenting capacity assessment to be conducted by
    Hospital for Sick Children or Chedoke McMaster in
    Hamilton.  They have not provided us with a referral or
    any further information regarding this issue.

    [McQuaid Dec 2]
    9.  I make this affidavit in support of my Application
    to have my child returned.

    /signed/  Robert T McQuaid

    SWORN before me at the Town of
    Orangeville in the County of Dufferin
    this 2nd day of December, 1999.

    /signed/

    A Commissioner etc.

    --------------------------------------------------------

    (from a photocopy of the judge's notes)

    Nov 22

    - on consent child is placed in temporary care &
      custody of CAS with access by parents as arranged by
      it.

    - adjd to Dec 1/99 at 10am & on the terms & conditions
      outlined in the consent filed.  /signature illegible/

    Dec 1/99  Mr Thwaites
              Ms Huber & Parents
    about 1 to 1 1/2 hour required, to consider whether
    child can be returned to Parents & if so, the
    conditions which should apply.  5 40 pm unable to deal
    with this urgent matter.

    Matter is adjourned;  if parents can demonstrate a
    compelling case for the return of the child & if it can
    be demonstrated that CAS have been wilfully
    unreasonable in delaying the return of the child,
    presiding justice to consider whether costs on CAS
    should be awarded.

    Dec 8/99 10 AM to be given priority Justice Allen to be
    approached to determine whether this motion may be
    heard on an earlier date.

                           /signed/

    Dec 2/99: Mr Thwaites & Ms Huber
    - Parents present
    Submissions by counsel.
    for oral reasons, the child shall be returned to the
    care & custody of the parents subject to the Society's
    supervision & on these terms & conditions
    1) child to be enrolled forthwith in "Friends" (Mon to
       Fri Daycare Program).
    2) Parents to work with Dr Ron Murphy of Orangeville &
       follow his Recommendations & Referrals as to
       possible assessments
    3) continue re 2 (c) of the earlier consent filed and
       2(d) & (e) and (f) plus (as to (e)) " & such other
       persons providing the services described in par
       2(a)(b)(c) & (f)
    - adjourned to Dec 22/99 at 10 am.
                             /signed/

    --------------------------------------------------------

    Ages and Stages test, December 16, 1999

    Ages & Stages Questionnaires:  A Parent-Completed, Child
    Monitoring System By Diane Bricker, Jane Squires, and
    Linda Mounts with assistance from LaWanda Potter, Robert
    Nickel, and Jane Farrell Copyright (c) 1995 by Paul H
    Brookes Publishing Co

    36 Month Questionnaire

    Child's name:  Ken McQUAID
    Child's date of birth:  Oct 16/96
    Who is filling out this questionnaire?  NKLA
    What is your relationship to the child?  PiP consultant
    Your telephone:
    Your mailing address:
    City:
    State:
    zip code:
    List people assisting in questionnaire completion:
    parents
    Today's date:  Dec 16/99
    Administering program or provider:  PIP/DSS//DCAF

    COMMUNICATION

    1.  When you ask her to point to her nose, then her
    eyes, hair, feet, ears, tummy and so forth, does your
    child point to at least seven body parts correctly?
    (She can point to parts of herself, you, or a doll).

    [Little Dec 16] YES

    2.  Does your child make sentences that are three or
    four words long?

    [Little Dec 16] YES   No, it doesn't go pop.

    3.  Without giving him help by pointing or using
    gestures, ask your child to "Put the shoe on the table"
    and "Put the book under the chair".  Does your child
    carry out both of these directions correctly?

    [Little Dec 16] YES

    4.  When looking at a picturebook, does your child tell
    you what is happening or what action is taking place in
    the picture?  (For example, "Barking", "Running",
    "Eating", and "Crying").  You may ask, "What is the dog
    (or boy) doing?".

    [Little Dec 16] SOMETIMES

    5.  Show your child how a zipper on a coat moves up and
    down, and say, "See, this goes up and down".  Put the
    zipper to the middle and ask your child to move the
    zipper down.  Return the zipper to the middle and ask
    the child to move the zipper up.  Do this several times,
    placing the zipper in the middle before asking the child
    to move it up or down.  Does your child consistently
    move the zipper up when you say "up" and down when you
    say "down"?

    [Little Dec 16] SOMETIMES

    6.  When you ask, "What is your name?" does your child
    say both her first and last name?

    [Little Dec 16] SOMETIMES


    GROSS MOTOR

    1.  Without holding onto anything for support, does your
    child kick a ball by swinging his leg forward?

    [Little Dec 16] YES

    2.  Does your child jump with both feet leaving the
    floor at the same time?

    [Little Dec 16] NO

    3.  Does your child walk up stairs, using only one foot
    on each stair?  The left foot on one step and the right
    foot on the next.  She may hold onto the railing or
    wall.  (You can look for this at a store, on a
    playground, or at home).

    [Little Dec 16] NO

    4.  Does your child stand on one foot for about 1 second
    without holding onto anything?

    [Little Dec 16] SOMETIMES

    5.  While standing, does your child throw a ball
    overhand by raising his arm to shoulder height and
    throwing the ball forward?  (Dropping the ball or
    throwing the ball underhand does not count).

    [Little Dec 16] YES

    6.  Does your child jump forward at least 6 inches with
    both feet leaving the ground at the same time?

    [Little Dec 16] NO


    FINE MOTOR

    1.  After she watches you draw a line from the top of
    the paper to the bottom with a pencil, crayon, or pen,
    ask your child to make a line like yours.  Do not let
    your child trace your line.  Does your child copy you by
    drawing a single line in a vertical direction?

    [Little Dec 16] YES

    2.  Does your child thread a shoelace through a bead or
    an eyelet of a shoe?

    [Little Dec 16] YES

    3.  After he watches you draw a single circle ask your
    child to make a circle like yours.  Do not let her trace
    your circle.  Does your child copy you by drawing a
    circle?

    [Little Dec 16] YES

    4.  After she watches you draw a line from one side of
    the paper to the other side, ask your child to make a
    line like yours.  Do not let your child trace your line.
    Does your child copy you by drawing a single line in a
    horizontal direction?

    [Little Dec 16] YES

    5.  Does your child try to cut paper with child-safe
    scissors?  He does not need to cut the paper but must
    get the blades to open and close while holding the paper
    with the other hand.  (You may show your child how to
    use scissors).

    [Little Dec 16] NO

    6.  When drawing, does your child hold a pencil, crayon,
    or pen between her fingers and thumb like an adult does?

    [Little Dec 16] NO


    PROBLEM SOLVING

    1.  While your child watches, line up four objects like
    blocks or cars in a row.  Does your child copy you or
    imitate and line up four objects in a row?  (You can
    also use spools or thread, small boxes, or other toys).

    [Little Dec 16] YES

    2.  If your child wants something he cannot reach, does
    he go and find something like a chair or box to stand on
    to reach it?

    [Little Dec 16] to check

    3.  When you point to the figure and ask your child,
    "What is this?" does your child say a word that means a
    person?  Responses like "snowman", "boy", "man", "girl",
    and "Daddy" are correct.  Please write your child's
    response here:

    [Little Dec 16] NO  apple

    4.  When you say, "Say seven three", does your child
    repeat just the two numbers in the correct order?  Do
    not repeat the numbers, If necessary, try another pair
    of numbers and say, "Say eight two".  Your child must
    repeat just one series of two numbers for you to answer
    "yes" to this question.

    [Little Dec 16] YES

    5.  Show your child how to make a bridge with blocks,
    boxes, or cans, like the example.  does your child copy
    you by making one like it?

    [Little Dec 16] to check

    6.  When you say "Say five eight three", does your child
    repeat just the three numbers in the correct order?  Do
    not repeat these numbers.  If necessary, try another
    series of numbers and say, "Say six nine two".  Your
    child must repeat just one series of three numbers for
    you to answer "yes" to this question.

    [Little Dec 16] YES


    PERSONAL-SOCIAL

    1.  Does your child use a spoon to feed herself with
    little spilling?

    [Little Dec 16] SOMETIMES

    2.  Does your child push a little shopping cart,
    stroller, or wagon, steering around objects and backing
    out of corners if he cannot turn?

    [Little Dec 16] to check

    3.  When she is looking in a mirror and you ask, "Who is
    in the mirror?", does your child say either "Me" or her
    own name?

    [Little Dec 16] YES

    4.  Can your child put on a coat, jacket, or shirt by
    himself?

    [Little Dec 16] NO

    5.  Using these exact words, ask your child, "Are you a
    girl or a boy?".  Does your child answer correctly?

    [Little Dec 16] NO

    6.  Does your child take turns by waiting while another
    child or adult takes a turn?

    [Little Dec 16] SOMETIMES


    OVERALL

    1.  Do you think your child hears well?

    [Little Dec 16] YES

    2.  Do you think your child talks like other children
    her age?  If no, explain.

    [Little Dec 16] NO  echolalia

    3.  Can you understand most of what your child says?

    [Little Dec 16] YES

    4.  Do you think your child walks, runs, and climbs like
    other children his age?  If no, explain.

    [Little Dec 16] NO

    5.  Does either parent have any family history of
    childhood deafness or hearing impairment?  If yes,
    explain:

    [Little Dec 16] to check

    6.  Has your child had any medical problems in the last
    several months?  If yes, explain:

    [Little Dec 16] to check

    7.  Does anything about your child worry you?  If yes,
    explain:

    [Little Dec 16] to check


    36 Month ASQ Information Summary

    Child's Name:  Ken McQUAID
    Date of Birth:  Oct 16/96
    Who is filling out the ASQ?  N K Little Alcorn
    Relationship to child:  home visitor (PiP)
    Mailing address:
    City:
    Telephone:
    Assisting in ASQ completion:
    Date:  Dec 16/99

    OVERALL

    Please transfer the answers in the Overall section of
    the questionnaire by circling "yes" or "no" and
    reporting any parents' comments.

    1.  Hears well?                            YES
    2.  Talks like other children?             NO
    3.  Understand child?                      YES
    4.  Walks, runs, and climbs like others?   NO
    5.  Family history of hearing impairment?  to check
    6.  Recent medical problems?               to check
    7.  Other concerns?                        to check

    SCORING THE QUESTIONNAIRE

    1.  Be sure each question has been answered.  If a
    question cannot be answered, refer to the ratio scoring
    procedure in The ASQ User's Guide.

    2.  Score each item on the questionnaire by writing the
    appropriate number on the line by each item answer.  YES
    = 10, SOMETIMES = 5, NOT YET = 0.

    3.  Add up the item scores for each area and record
    these totals in the space provided for area totals.

    4.  Indicate the child's total score for each area by
    filling in the appropriate circle on the chart below.
    For example, if the total score for the Communication
    area was 50, fill in the circle below 50 in the first
    row.

    (I had to make a few wording changes because this text
    can not include the graph from the original document.
    The values in parentheses are the thresholds for
    acceptance - RTMQ).

    Communication   (40)  50  with echolalia
    Gross motor     (40)  25
    Fine motor      (30)  40
    Problem solving (40)  30
    personal-social (40)  20

    Examine the blackened circles for each area in the chart
    above.

    5.  If the child's total score falls at or above the
    threshold the child appears to be doing well in this
    area at this time.

    6.  If the child's total falls below the threshold, talk
    with a professional.  The child may need further
    evaluation.

    OPTIONAL:  The specific answers to each item on the
    questionnaire can be recorded below in the summary
    chart.  (not done)

    --------------------------------------------------------

    Brigance Pre-School Screen,  Dec 20, 1999

    (The following document was prepared by a professional
    not associated with Children's Aid, who was retained by
    Friends at Hand-in-Hand day care to deal with Ken's
    rampage behavior.  She found he was not eligible for
    help, because his score on the test was above the
    threshold of 60.  The test without this note is filed in
    court.  - RTMQ)

    THREE-YEAR-OLD-CHILD DATA SHEET for the
    BRIGANCE (R) PRESCHOOL SCREEN FOR THREE- AND
    FOUR-YEAR-OLD CHILDREN

    A. CHILD DATA
    Child's Name:  Kenneth
    Date of Screening: Dec 20, 99
    School/Program:  Hand in Hand
    Birthdate: Oct 16, 96
    Teacher:  Karen
    Age:  3 years 2 months 4 days
    Assessor:  Joyce Cook

    B. SCREENING ASSESSMENTS                     C. SCORING
    Page/No  Skill
    3    1A  Personal Data Response:  Orally gives:
             1 first name  2 last name  3 age
                                                          0
    3    2A  Identifies Body Parts:  Points to or touches:
             1 ears  2 head  3 legs  4 arms  5 fingers
             6 thumbs  7 toes  8 neck  9 stomach
                                               1245678    7
    4    3A  Gross Motor Skills:
             1 Stands on one foot one second
             2 Walks tiptoe three steps
             3 Walks forward heel-and-toe three steps
                                               12         6
    5     4  Identifies Objects:  Points to picture of:
             1 stove  2 coat  3 car
                                               123        9
    6    5A  Repeats Sentences:  Repeats sentences of:
             1 three syllables
             2 four syllables
             3 five syllables
                                               123        9
    7    6A  Visual Motor Skills:  Copies:
             1 circle
             2 horizontal line
             3 vertical line
                                               23         6
    8    7A  Number Concepts:  Demonstrated by giving:
             1 one  2 one more  3 two
                                               13         6
    9    8A  Builds Tower with Blocks:
             Builds a tower with:
             1 3 blocks  2 4 blocks  3 5 blocks
             4 6 blocks  5 7 blocks
                                               12345     10
    10    9  Matches Colors:  Matches:
             1 red  2 blue  3 green
             4 yellow  5 orange
                                               12345     10
    11  10A  Picture Vocabulary:  Names:
             1 tree  2 bird  3 apple
             4 pencil  5 sock
                                               1234       8
    12   11  Plural s and -ing:  Adds
             1 plural s  2 -ing to verbs
                                               1          5


    Total Score:                                     76/100

    D.  OBSERVATIONS
    1. Handedness  Left
    2. Pencil Grasp:  Loose
    3. Speech:  Understandable
    4. Other:
       He imitates a lot of speech when he doesn't
       understand the question.

    E.  SUMMARY
       (Complete only if child is screened with group)

    F. RECOMMENDATIONS
       To be referred to a behavioural therapist.

    (c) 1985  Curriculum Associates Inc

    --------------------------------------------------------

    Ontario Court of Justice
    at 10 Louisa Street, Orangeville Ontario L9W 3P9

    Court File Number 180/99
    Form 14A:  Affidavit (General) dated December 21, 1999

    Applicant
    The Children's Aid Society of the County of Dufferin
    50 Fourth Avenue, Unit 13
    Orangeville, Ontario L9W 4P1  Canada
    Phone:  519-941-1530
    Fax:  519-941-1525
    email:  dcafs@hurontario.net

    Wardlaw, Mullin, Carter, Thwaites and Ward
    Attention:  David Thwaites 235 Broadway
    Orangeville Ontario L9W 2Z5  Canada
    Phone:  519-941-1760
    Fax:  519-941-3688
    eMail:  dthwaites@wardlaw.on.ca

    Respondents
    Robert McQuaid
    RR #5  Orangeville Ontario L9W 2Z2  Canada
    Phone:  940-9847

    Linda Prosh
    RR #5  Orangeville Ontario L9W 2Z2  Canada
    Phone:  940-9847

    My name is Trish Cox
    I live in Orangeville, Ontario
    and I swear/affirm that the following is true:

    I, Trish Cox, of the Town or Orangeville in the County
    of Dufferin, make oath and say:

    [Cox Dec 21]
    1.  I am a Child Protection and Family Services Worker
    with The Children's Aid Society of the County of
    Dufferin.  I am also a Registered Nurse with the College
    of Nurses of Ontario with a B.Sc.N.  I have worked
    extensively with children in clinical and community
    settings and at one time coordinated and supervised the
    School Health Support Services for the Dufferin and
    Dufferin-Peel Boards of Education.  I was involved daily
    in the assessment of the physical, developmental,
    emotional and social needs of children.  I was required
    to have a comprehensive knowledge of the role,
    responsibilities and interventions of Occupational
    Therapists, Physical Therapists, Speech Therapists,
    Dieticians and Nurses as they worked with children in
    home and school environments.

    [Cox Dec 21]
    2.  On December 14th, 1999 I met with Mr McQuaid and Ms
    Prosh.  Ken's room was bright and cheerful.  The bedding
    was clean and fresh.  The bed was age appropriate.  Age
    appropriate toys were in evidence in the room.  The
    closets contained season appropriate clothing.  There
    was no lock on his door.  The other areas of the house
    which I saw were stark and lacked warmth but were clean
    and free of safety concerns.

    [Cox Dec 21]
    3.  Mr McQuaid and Ms Prosh, during this visit described
    concerns related to Ken:  1.  head banging on their
    bodies.  Mrs Prosh showed me a 3 inch fading bruise on
    her groin where Ken had hit her while she was lying in
    bed.  The parents report that Ken does the same on their
    legs in sensitive areas and that this has been happening
    as often as everyday or every other day and that this
    has been occuring for some time.  The parents stated
    that he does not head bang on anything but themselves.
    2.  spitting at the parents which they report only
    started in the past two weeks.  The parents expressed
    interest in the visit about how to deal with these
    behaviours.  The parents are presently using different
    approaches.  Mr McQuaid will deal with them with time
    outs or telling him to stop.  Ms Prosh stated that she
    screamed the last time Ken banged his head on her groin.
    She sometimes says "no".  Advice was given and
    acknowledged.  During the meeting Ken was very busy.  He
    would pull and hang on the curtains, hit his parents and
    myself, handle objects off limits to him.  Mr McQuaid
    firmly and gently held Ken once when Ken was involved
    with the curtains.  However, neither parent responded to
    Ken hitting them.  During the visit the parents asked
    questions about toilet training.  This was discussed
    briefly.

    [Cox Dec 21]
    4.  The parents reported in this visit that the
    pre-school had asked Ken to be assessed by the Dufferin
    Association for Community Living, Pre-School Resource
    Programme as the pre-school felt that there were
    developmental delays.  Mr McQuaid and Ms Prosh reported
    that the pre-school found Ken to be aggressive with
    other children (hitting, spitting and throwing objects
    at them).  The parents were surprised that the
    pre-school felt that there were developmental delays and
    spent some time highlighting what Ken could do and
    related this to their own milestones as children.

    [Cox Dec 21]
    5.  During this visit I observed that Ken communication
    was mainly in the form of echolalia, a compulsive
    repetition of what is spoken by another person.  His
    speech was clear.  He responded to simple one step
    commands.  However, during the end of the interview, as
    consents were being obtained and the word "CAS" was
    used, Ken would respond each time with the word "evil".

    [Cox Dec 21]
    6.  On December 16th, 1999 I met with Lee Rivoire,
    Teacher and Karen Bowers, Supervisor of Hand-in-Hand
    Pre-School.  They stated that Ken has been attending
    each day since enrollment with the usual length of stay
    of 8:30 am to 5:30 pm.  The staff are concerned as Ken
    speaks with echolalia, does not interact with the other
    children, rarely participates in circle time.  They
    report that he does not know how to play with toys
    except cause and effect toys.  The staff have found over
    the last two weeks that Ken has difficulty with
    transitions (going to the washroom, cleaning up, going
    to circle time) and will scream and tantrum when asked
    to do these things.  The staff state that the parents
    have told them that they use plastic utensils with Ken
    as he throws things and they are afraid of being stabbed
    by him.  Ken consistently throws objects at the
    pre-school and the staff are worried about the safety of
    the other children.  Ken hits the children and spits on
    them and the staff.  The staff is concerned as Ken says
    "bad boy" with his behaviours and the mother has told
    the staff she calls him that.  The staff report that Ken
    does not have self-help skills ie.  toilet trained, uses
    a sippy cup.  They have noticed that he bangs his head,
    front and back, on the door, wall, chair and will say to
    himself "not funny" and laugh, or "that's a bad habit".
    The staff state that at nap time, Ken does not sleep and
    will suck his thumb, hit his head with his fist and
    laugh and rock.  He has also gotten up and thrown toys
    around at other children.  The supervisor reports that
    they had no indication from his parents of any problems
    with Ken at registration and feel he needs 1:1
    supervision.  The staff state that Ken leaves his
    parents easily and is happy to see both of them when
    they return.  Ms Rivoire reports one time that another
    mother with blonde hair was leaving and Ken attempted to
    go with her.  The staff state that the parents are happy
    to see Ken on pick up and are interested in how he is
    doing.  Mr McQuaid picks up Ken the majority of the
    time.  They report that Ken has a good appetite, is
    appropriately dressed, clean and tidy.  They also noted
    that regarding his echolalia, with one exception Ken
    demonstrated the ability to engage, ask a question and
    indicate a process with communication.  Ken was told
    that "Tara will bring you that toy".  When the girl
    brought him the toy, Ken asked, "Are you Tara?".  I
    verily believe this to be true.

    [Cox Dec 21]
    7.  On December 17th, 1999 I met with Nina Little,
    Infant Development Worker with Dufferin Child and Family
    Services.  She noted that Mr McQuaid was more relaxed
    with her but that both parents were mainly spectators
    throughout the visit.  She did observe that Mr McQuaid
    engaged Ken a little with some turntaking.  The father,
    however, asked Ken for his Barney figure and when given
    it, kept it even though Ken wanted it back.  Later when
    Ken was asked for another toy by his father, Ken would
    not bring it over.  During her assessment visit Ken was
    playing in the curtains.  Mr McQuaid dealt with this by
    holding Ken on his lap while vigorously patting his
    back, saying to Ms Little that they are now using zero
    tolerance.  The intervention did not calm Ken or reduce
    his activity.  Ms Little was informed by the parents
    that Ken was spitting, throwing things at the pre-school
    and the parents stated that Ken wouldn't be able to stay
    if the behaviour continues.  They reported that Ken had
    been referred to the Dufferin Association for Community
    Living by the pre-school staff.  Ms Little also
    suggested a referral to a Speech and Language Therapist
    for the echolalia.  Ms Little noted the following about
    Ken:  1.  Ken remembered activities that he was involved
    in with her from three weeks ago and was capable of
    representational play (ie.  would feed a baby doll with
    a bottle).  He was also capable of focussing for a
    significant period of time on a variety of play tasks.
    2.  when Ken looked into a mirror he would say Ken good
    boy, or Ken evil and laugh.  The parents laughed when he
    said this.  3.  when Ken was shown a crocodile whose
    mouth opened, his father said to Ken:  "look it eats
    little boys;  4.  Ken has limited ability to self care
    ie.  dress and feed himself.  The parents state they
    even load his fork with food and Ken will often eat with
    his fingers;  5.  the developmental assessment (Ages and
    Stages) indicates that Ken has poor gross motor, problem
    solving and personal and social skills.  Ken's fine
    motor skills were appropriate.  Communication could not
    be accurately assessed with this tool.  Ms Little was
    very concerned with the severity and number of concerns
    that she observed and the contrast in ability.  She
    stated that Ken would benefit from and assessment by a
    child psychiatrist.

    [Cox Dec 21]
    8.  Information from Dr R Murphy, paediatrician and Wil
    Weiner, therapist was not available at this time.  Their
    input is necessary to clarify and define aspects of the
    above observations.  Ken McQuaid can present, in
    isolated and/or controlled circumstances to function
    within acceptable developmental limits.  For example,
    form a question without prompting which initiates a
    relationship and relates to his external environment.
    He is also able to remember past processes and use
    representational play.  Ken, however, for the most part
    is below in many of his developmental milestones and
    demonstrates severe aggressive hehaviours.  He also
    demonstrates self-soothing and self-stiming behaviours.
    As well, the parents inconsistencies in parenting and
    unusual interactions with Ken is concerning to the
    Society.  A parenting capacity assessment is still seen
    as necessary because of the latter and the fact that no
    interventions were put in place prior to the involvement
    of the Society.

    [Cox Dec 21]
    9.  I make this statement with no improper intent.

    /signed/ Trish Cox

    Sworn/Affirmed before me at The Town or Orangeville in
    Ontario on December 21, 1999

    /signed/ GARY BRIAN PUTMAN, A Commissioner,
    etc, Province of Ontario, for the Children's
    Aid Society.
    Expires September 20th, 2000

    --------------------------------------------------------

    Court File # 180/99

    CONSENT ADJOURNMENT REQUEST
    ONTARIO COURT (PROVINCIAL DIVISION - FAMILY)
    10 Louisa St, Orangeville Ont, L9W 3P9

    Applicant         CHILDREN'S AID SOCIETY
    Counsel           DAVID THWAITES
    Respondents       MCQUAID / PROSH
    Counsel           EVELYN HUBER
    Parties Present:  Applicant Counsel Respondent Counsel

    Reason for adjournment
      to allow for Developmental Assessment of Child

    All parties consent to adjourn this matter from Dec
    22/99 to January 19, 2000 at 10 AM in courtroom # ___
    Status quo to continue

    Applicant signature   (blank)
    Counsel's signature   /signed/ David Thwaites
    Respondent signature  /signed/ Robert T McQuaid
    Counsel's signature   /signed/ Evelyn Huber

    Dated at the Town of Orangeville this 22 day of
    December, 1999

    Consent Adjournment Requirements:  If all parties agree
    to an adjournment, this Consent Adjournment Request must
    be properly completed and delivered to the court clerk.
    The parties may be released once the clerk has approved
    the adjournment date as available unless there still
    remains a matter in dispute which needs to be addressed
    by the judge.  The onus is on the party requesting the
    adjournment to contact all other parties not present and
    inform them of the next court appearance date and time.

    --------------------------------------------------------

    IN THE MATTER OF KENNETH DARRYL McQUAID
    born OCTOBER 16, 1996

    CONSENT

    THE PARTIES HERETO CONSENT TO AN ORDER
    on the following terms and conditions:

    1.  that the child Kenneth Darryl McQuaid, born October
        16, 1996 shall be found in need of protection.

    2.  that the child, Kenneth Darryl McQuaid shall be in
        the care and custody of ROBERT McQUAID and LINDA
        PROSH subject to the supervision of the CHILDREN'S
        AID SOCIETY OF THE COUNTY OF DUFFERIN for a period
        of 6 months on the following terms and conditions:

        (a)  LINDA PROSH and ROBERT McQUAID shall continue
             to attend and follow the recommendations of Dr
             Ron Murphy and such other persons as directed
             or referred by Dr Ron Murphy

        (b)  LINDA PROSH and ROBERT McQUAID shall continue
             to cooperate and follow the recommendations of
             the Infant-Parent Program, the Family Therapist
             (WILL WEINER), Dufferin Association Community
             Living and Family services worker.

        (c)  LINDA PROSH and ROBERT McQUAID shall sign
             Consents to Release Information as necessary to
             facilitate the terms of supervision

        (d)  LINDA PROSH and ROBERT McQUAID agree to "drop
             by" visits by representatives of the Children's
             Aid Society

        (e)  LINDA PROSH and ROBERT McQUAID shall
             participate and have a child psychiatrist
             conduct and assessment of the family to obtain
             the assessment and recommendations for
             parenting of Kenneth.  The parents shall
             cooperate and follow through with the
             recommendations.

    Dated this 19th day of January 2000
    at the Town of Orangeville.

    /signed/ Linda Prosh
    /signed/ Robert McQuaid
    /signed/ Trish Cox CAS for Dufferin

    --------------------------------------------------------

    The Banner Extra
    Vol 3 No 95  Tuesday January 25, 2000

    (advertisement)

    DUFFERIN
    Child and Family Services
    (Incorporated as The Children's Aid Society of the
    County of Dufferin)

    Dufferin Child and Family Services is a not-for-profit
    social service agency which strives to advocate for and
    provide co-ordinated quality services for children,
    families and individuals in Dufferin County.  Our
    primary service focus is on children most in need of
    counselling, support and protection from abuse and
    neglect, while supporting families in their central role
    of caring for and nurturing children.

    WE NEED FOSTER PARENTS IN
    DUFFERIN COUNTY!

    Dufferin Child and Family Services regular foster care
    program is currently seeking 4 homes for school age
    children and adolescents and 2 homes for infant and
    pre-school children.

    If you are interested in learning more about being a
    foster parent for children of your community, plan on
    attending an

    INFORMATION SESSION
    WEDNESDAY, FEBRUARY 9, 2000 7:00-9:00 PM

    Dufferin Child and Family Services
    50 Fourth Avenue, Unit 13 (Zehrs Plaza)
    Orangeville Ontario
    (519)941-1530
    (Call Diane Maloney ext 237 if you plan on attending)

    There will be a presentation that will help to answer
    any questions you may have regarding fostering, and to
    explain the approval process for foster homes in
    Dufferin County.

    --------------------------------------------------------

    The Orangeville Citizen
    February 2, 2000

    Concerns with CAS

    For the last few weeks there has been an advertisement
    in the classified section asking if anyone has had
    problems with the Dufferin County CAS (Children's Aid
    Society).  A number of responses have been received,
    even though most people are reluctant to step forward.

    Those who have stepped forward have some valid concerns
    and problems with this agency.  Over the weekend a
    number of those people gathered for a meeting near the
    Orangeville area to voice their concerns.

    In most cases the major complaint is the
    heavy-handedness of this agency and the way it operates
    by being confrontational in its approach, by not
    informing parents of their rights in these matters and
    an abuse of power by removing children from their homes
    without warrants on the basis of flimsy evidence.

    Also of concern are direct lies told the parents by some
    workers eventually leading the the destruction of the
    family unit.

    According to spokesperson Catharine Cote of the Voices
    for Children Alliance (VOCA), a group set up to combat
    this abuse of power, "these types of problems should be
    sounding alarm bells off as they are not only happening
    in Dufferin County, but seem to be systemic throughout
    the province.

    "There is nothing new about these cases.  These
    practices have been going on for some time now.  My
    experience with the CAS has been that fly swatters are
    used where an elephant gun is needed and an elephant gun
    used where a fly swatter is needed".

    In one case discussed over the weekend, the children
    were removed from school without the parents being
    notified.  The parents found out only when the children
    did not return home after school and the police were
    notified of their absence.  Then they were told that the
    children had in fact been removed by the CAS.  The major
    reason for there removal was simply "poor housekeeping
    practices".

    Among the prime targets for the CAS are single parents
    with children under the age of six.

    In targeting single, economically deprived parents,
    these agencies know that their resources for legal
    representation are limited and these cases are easily
    won as there parents soon run out of money.

    As a result of parents being encouraged to stay at home
    and raise their children there is now a shortage of
    children available for adoption while the numbers of
    people wanting to adopt have risen.

    In effect this gives the government a potential reign of
    terror over these families.

    In one of the cases discussed the children were
    apprehended and placed for adoption before the parent
    was even brought to trial and in this case the reason
    for apprehension was financial deprivation.

    What's ironic in this case is the fact that the parent
    had called the CAS asking for help.

    Let's take a look at who benefits from this industry,
    and it is certainly not the families involved.

    - A Concerned Parent

    --------------------------------------------------------

    I placed an ad in the Orangeville Banner asking for CAS
    experiences, and I have spoken to the Concerned Parent
    author and most of the CAS victims alluded to in the
    article.  Every person responding to my ad was reluctant
    to leave his name.  In most cases the bullying they
    described by CAS was worse than stated in the article.
    All of the children who were targets of crown wardship
    applications were free of physical defects.  In two
    cases from anonymous callers, crown wardship
    applications were withdrawn when hidden physical defects
    were found.  - RTMQ.

    --------------------------------------------------------

    This cover letter came in response to a phone inquiry
    from me to Irene Beazley for a copy of the bylaws.
    -RTMQ

    CAS letterhead (see glossary)

    February 9, 2000

    Robert T McQuaid
    RR #5  Orangeville ON  L9W 2Z2

    Dear Mr McQuaid,

    I am forwarding a copy of our by-laws as promised.

    I recently spoke with you when you paid the $3.00 CAS
    membership fee.  We are presently in the process of
    renewing memberships and I will be contacting the
    Secretary-Treasurer of our Board of Directors to sign
    membership cards for the 200-01 year.  Once this has
    been done a membership card will be sent to you.

    Thank you for your interest in our agency.

    Yours sincerely,

    /signed/ Irene Beazley, Senior Administrative Assistant

    /ib
    Encl

    --------------------------------------------------------

    John Baird letterhead (see Glossary)

    February 9, 2000

    Mr Robert T McQuaid
    RR 5  Orangeville, Ontario L9W 2Z2

    Dear Mr McQuaid:

    David Tilson, the Member of Provincial Parliament for
    Dufferin-Peel-Wellington-Grey, has forwarded me a copy
    of your letter concerning the Children's Aid Society.  I
    apologize for the unacceptable delay in my response.

    I appreciate the time you have taken to write about this
    matter and your comments have been noted.  Please
    understand that as the issue you raise is currently
    before the courts, it would be inappropriate for me to
    comment on this matter.

    Thank you for writing.

    Sincerely,
    /signed/
    John Baird, MPP
    Minister

    cc:  Vince Tedesco, Director, Central West Region
         David Tilson, MPP Dufferin-Peel-Wellington-Grey

    --------------------------------------------------------

    ( This letter bears the stamp:
          RECEIVED
          FEB 18 2000
          DUFFERIN CHILD AND FAMILY SERVICES
      Children's Aid kept it a secret until May 31, 2000
      when Trish Cox handed a copy to Linda Prosh as a fait
      accompli.  It is the centerpiece of the next steps in
      litigation.)


    Children's Hospital

    PO Box 2000  Hamilton, Ontario L8N 3Z5
    (905) 521-2100

    FAX: (905) 522-7982
    DEPARTMENT OF PEDIATRICS
    HSC-3G39, 521-2100, EXT 73268/73687
    CHILD ADVOCACY & ASSESSMENT PROGRAM
    @ HAMILTON HEALTH SCIENCES CENTRE (MCMASTER SITE)

    February 10, 2000

    Ms Trish Cox
    Dufferin Child & Family Services
    13-50 Forest Avenue
    Orangeville ON L9W 4P1

    Dear Ms Cox:

    RE:  McQuaid-Prosh Family CAAP Assessment

    Thank you for your referral of the above-named family to
    the Child Advocacy & Assessment Program.  The referral
    has been accepted and the following appointments have
    been scheduled.  Please advise the family of the
    following appointments:

    Robert McQuaid, Linda Prosh and Kenneth McQuaid

    Wednesday, June 28 @ 11:00 am
    Friday, July 7 @ 10:45 am
    Friday July 14 @ 9:30 am
    Friday, July 21 @ 10:45 am (Observation Session with
        Kenneth)
    Friday, August 11 @ 10:45 am (Feedback Session for
        Robert & Linda)

    Trish Cox and Nina Little

    Wednesday, July 12 @ 10:00 am

    All appointments are in the 3F clinic (third floor,
    colour red) at Chedoke-McMaster Hospitals, 1200 Main
    Street West, Hamilton.  Upon your arrival, the
    receptionist should be advised that you have an
    appointment with CAAP.

    Sincerely,

    Linda Harris
    Program Assistant
    Child Advocacy & Assessment Program

    /ljh

    HAMILTON HEALTH SCIENCES Corporation

    Children's Hospital at Hamilton Health Sciences
    Corporation is affiliated with the Faculty of Health
    Sciences, McMaster University

    --------------------------------------------------------

    The Orangeville Citizen
    February 16, 2000

    Children's Aid responds to Feb 2 letter

    [Putman Feb 16]
    We are responding to the letter published in your
    February 2nd edition by "A Concerned Parent".  Child
    protection is a difficult undertaking, filled with much
    emotion by all parties involved.  As child protection
    workers we represent children who are most often left
    without a voice to express their experiences and who are
    unable to take actions to protect themselves from
    neglect and abuse.

    [Putman Feb 16]
    Our staff work with a large number of families every
    year.  The majority of our work does not involved
    bringing children into our care.  In fact, there are
    many families who work with the Society on a voluntary
    basis.  The nature of our work, however, can result in
    our involvement with parents in an involuntary and
    intrusive manner.

    [Putman Feb 16]
    As a result, we are not surprised, and in fact might
    expect, that some parents would be less than pleased
    with our interventions on behalf of their children.  The
    article published in the February edition tries to set
    out some concerns about our agency which are not
    unfamiliar to us, as most have already been heard and
    attempts at resolution have been made.

    [Putman Feb 16]
    However, since the complaints have now been raised in a
    public forum, we feel an obligation to respond in order
    to accurately inform our community.

    [Putman Feb 16]
    Children's Aid Societies are subject to many checks and
    balances on our legislated powers to intervene into
    peoples lives.  Children's Aid Societies are able to
    investigate allegations and even to remove children from
    their parents, with or without a warrant, when there are
    reasonable grounds to believe they are at risk of
    neglect or abuse or immediate harm.

    [Putman Feb 16]
    Where children are involuntarily removed or
    "apprehended", Societies must seek a court order within
    five days to maintain those children in its care and as
    such are subject to judicial review of all their
    actions.

    [Putman Feb 16]
    One example given in the recent article stated that
    children had been apprehended because of "poor
    housekeeping practices".  Children are not apprehended
    because of a lower than average standard of
    housekeeping, which the author of the article would lead
    readers to believe.  Children are apprehended because of
    feces on the floor, spoiled food on the counters,
    mattresses with urine that children are made to sleep in
    over and over.

    [Putman Feb 16]
    Essentially, the standard of living needs to be such
    that a child's medical health is at risk before they
    would be apprehended.  In fact, in one very long term
    situation of this nature, the Society spent thousands of
    dollars to provide housekeeping and support services to
    try and maintain a group of siblings with their parents
    rather than remove them.

    [Putman Feb 16]
    Another case cited in the article states that children
    were put up for adoption before a trial occurred.
    Children cannot be adopted before they have been made a
    crown ward by the courts or with the parents written
    consents.  To suggest that child protection workers
    target certain sectors of our community or remove
    children solely to place them for adoption is grossly
    inaccurate and certainly could not be supported by the
    records of the family court in this jurisdiction.

    [Putman Feb 16]
    The Society works with a wide variety of people.  These
    are single parent families and there are two parent
    families, there are low income and very high income
    families.  The Society does not choose who it will
    become involved with.  Neighbours, professionals,
    children and spouses make reports to us and the Society
    is responsible to act upon those reports.

    [Putman Feb 16]
    We do that with highly educated social work staff
    supported by senior supervisory staff with many years
    experience.  When the Society initiates court action,
    Ontario Legal Aid guarantees representation for low
    income parents in child welfare hearings.  it is always
    our goal in court actions to minimize court time and
    cost by trying to reach agreement between all parties
    while not jeopardizing the safety of the children
    involved.  The legitimate access by parents to proper
    legal representation in child welfare hearings is
    closely guarded by the family courts and supported by
    our staff.

    [Putman Feb 16]
    In addition to judicial reviews, Children's Aid
    Societies are legally subject to the supervision of the
    Ministry of Community and Social Services through three
    annual case audits, annual foster care licensing reviews
    and supervision by Ministry staff.

    [Putman Feb 16]
    Societies are also required by law to have local
    mechanisms to allow parents or children to voice their
    concerns and to reach a resolution of the concerns
    through a progressive process involving agency staff,
    the voluntary community Board and finally the Ministry
    of Community and Social Services.

    [Putman Feb 16]
    Any client of Dufferin Child and Family Services is made
    aware of this during service or upon request either
    verbally or through a pamphlet which clearly outlines
    the process.  Naturally, as a public agency it is not
    uncommon for us to also be publically accountable to our
    community through media reports such as this.  Despite
    these many avenues of accountability, some individuals
    will always be unsatisfied.

    [Putman Feb 16]
    There are many families involved with the Society who
    are simply going through some challenges in their lives
    and require some assistance.  There are also families
    who are harmful to their children, and whose children
    require protection.

    [Putman Feb 16]
    We fundamentally believe that children should be raised
    by their own families.  However, if a child is being
    harmed physically, sexually, emotionally or otherwise
    neglected their needs and rights will be paramount in
    our actions.

    [Putman Feb 16]
    We recognize that some individuals will always be
    critical.  Despite that, we believe they have a right to
    express legitimate concerns and complaints and we will
    continue to go the extra mile to attempt a resolution.

    [Putman Feb 16]
    Those individuals who recently met to share their
    concerns about our agency are most welcome to again
    address them directly to me, jointly with the President
    of our Board of Directors.  You may call me at 941-1530
    Ext 224, to arrange a convenient meeting time and/or you
    may wish to provide your views in writing for our
    review.

    Gary Putman
    Executive Director

    --------------------------------------------------------

    Since Linda would consent only to internet publicity,
    not print journalism, I was unable to send the following
    response, even after a day of discussion.  - RTMQ


    On February 2, 2000 you published a letter relating to
    Children's Aid signed by "A Concerned Parent", followed
    on February 16 by a rebuttal from Gary Putman, Executive
    Director of Dufferin Children's Aid.

    I am one of the people attacked by Mr Putman's
    organization.  On November 16, 1999 an action was
    initiated against us by taking our child with the aid of
    a warrant and two OPP officers.  We then had to plead
    for conditions to have our child returned, events
    meeting the dictionary definition of kidnapping.  I was
    astonished to find that such a legal procedure existed.

    In the intervening three months I have undertaken a
    crash education in this area.  The law is titled "The
    Child and Family Services Act" (1984), enacted at a time
    of hysteria about child-molesters.  In thousands of
    words, there are no provisions protective of parents.
    The law allows Children's Aid Societies to take children
    from their parents and place them in foster homes under
    the doctrine of "the best interests of the child".  With
    this doctrine, some Canadian Indian bands suffered half
    of their children adopted out to white families.  Indian
    objections to slow genocide led to protections from the
    law, but only for Indians.  In 1999 amendments, every
    revision makes it easier for Children's Aid to remove
    children from their natural parents.

    There is a pervasive fear among all persons having
    contact with Children's Aid, extending even to those not
    yet involved but subject to denunciation.  I have
    personally spoken to most of the people mentioned by A
    Concerned Parent.  It was difficult to get any of them
    to give a name or phone number, out of fear of
    retaliation by Children's Aid.

    As Mr Putman states, some clients come to Children's Aid
    voluntarily, but all I have spoken to regret their
    decision to do so.

    As for "poor housekeeping practices", Mr Putman says
    removal only occurs for such abuses as feces on the
    floor (did you ever drop something during a diaper
    change?), spoiled food on the counters (ever have
    spoilage in your kitchen?) or mattresses with urine.  He
    neglects to mention that Children's Aid routinely makes
    these allegations regardless of the facts.

    I have the names of a mother and the adoptive family
    that took her children before her trial.  Only paper
    formalities remained for the aftermath.  The law grants
    Children's Aid a club called crown wardship, ending
    parental rights so they can never see their own children
    again.  By law, the same agency that takes children from
    their natural parents supplies them to adoptive parents.
    The law provides for crown wardship when "there is a
    substantial risk that the child will suffer physical
    harm, inflicted by the person having charge of the child
    or caused by that person's failure to care and provide
    for or to supervise and protect the child adequately".
    This provision could strip children from Mother Teresa.

    The legal aid touted by Mr Putman is no doubt available,
    but is useless in the face of laws that give all power
    to Children's Aid.  Children's Aid workers have immunity
    from all legal actions.  As for appeal through the
    agency itself or the ministry, the minister will ignore
    any case before the courts.

    Mr Putman continues " ...  could not be supported by the
    records of the family court in this jurisdiction".  This
    is true because the court records are secret.  I was
    turned down in a request to see the files, and I could
    not even count Children's Aid cases.  I challenge Mr
    Putman to open his records to research so a scientist
    can count children protected from abuse as well as false
    allegations of abuse.

    --------------------------------------------------------

    Ministry of Community and Social Services
    Ontario

    Child Abuse Register
    2 Bloor St W 24th Fl  Toronto Ont M7A 1E9
    (416)327-4660

    March 28, 2000  (postmarked April 11, 2000)

    Robert McQuaid
    Linda Prosh  (one copy mailed to each)
    RR 5
    Orangeville ON L9W 2Z2

    Dear Mr McQuaid:

    This letter is to inform you that you were reported to
    the Family and Children's Services County of Dufferin as
    allegedly having abused Kenneth McQuaid.  Following
    their investigation, the Society is now satisfied that
    the information is verified and reportable abuse
    occurred.  The Society is required by law, Child and
    Family Services Act (CFSA) Section 75(3), to send a
    report on this matter to the Child Abuse Register, held
    in Toronto by the Ministry of Community and Social
    Services.

    The Child Abuse Register is maintained by the Ministry
    of Community and Social Services pursuant to Section
    75(5) of the CFSA.  The Register is used as a tool in
    the overall effort to protect children and in the
    prevention of child abuse.  More specifically,
    information maintained on it provides a general register
    check for child abuse investigations conducted by
    Children's Aid Societies.  Statistical data is also
    drawn from information on the Register.

    If any further report of abuse by you is received by and
    Children's Aid Society, the fact that you are on the
    Register may be made known to that Society.

    The law states that you or your representative may
    examine the Register.  You may request that your name be
    removed or that the Register be otherwise amended.

    As a result of this request, the Director may at that
    stage decide to remove your name from the Register.
    Before he can refuse your request, you are entitled to a
    hearing by the Director or his designate.

    For further details, see the attached excerpt from the
    CFSA, 1984.

    If you have any questions about the collection of this
    information or if you wish to examine your information
    or seek an expunction, call or write to Sandra MacAulay
    at the above phone number or address.

    Yours truly,

    /signed/
    MR Seymour
    Director

    Encl.  (CFSA sections 75-76 were enclosed)
    cc:  Children's Aid Society
         Orangeville Ontario

         File No:  2000-00154


    THE CHILD ABUSE REGISTER

    The Child and Family Services Act requires that the
    local Children's Aid Society (CAS) investigate all
    reports of suspected child abuse.  After its
    investigation, the staff of the CAS then decide whether
    the information verifies that there was an incident of
    abuse.  The CAS also decides what action to take to
    protect the abused child.  If the CAS decides, on the
    basis of their review, that abuse has occurred, a report
    must then be sent to the Child Abuse Register at the
    head office of the Ministry of Community and Social
    Services.

    The purpose of the Register is to enable Children's Aid
    Societies to find out quickly whether a child or an
    alleged abuser has been involved in any previous case.
    This information will help them in deciding what the
    proper protection for the child should be.  The Register
    serves to record the name of the abused child, the name
    of the alleged abuser and a few details such as the date
    of the incident, the child's age and the name of the CAS
    that made the report.  All the information in the
    Register is carefully protected under the law and
    remains highly confidential.

    If however, a child is repeatedly abused, or an adult
    continues to abuse children, the Children's Aid Society
    has access to this information which may help them
    arrive at better decisions for helping the abuser and
    protecting the child.

    Director for the Child Abuse Register

    --------------------------------------------------------

    [Before our organizing, Children's Aid had 32 members.
    I sent each of them this letter, getting two proxies in
    return.  The letter may have come to the judge's
    attention indirectly.  -RTMQ]



                     Help Fix Children's Aid!

    The Dufferin Children's Aid Society has switched from
    protecting children to attacking families.  Specific
    policies are permanent removal of children from intact
    families, long-term removal of children for trifling
    abuses, failure to provide in-family assistance for
    families with serious problems, undermining parental
    authority in families with teen-aged children, and
    avoidance of serious child-abuse cases by turning
    against the accusers.

    The best interest of the child is in keeping his
    parents.  Children's Aid should apply its resources to
    protect children by assisting and preserving families,
    not attacking them.

    Specific policies we advocate are:

    - Children should not be removed from homes until the
      parents have had an opportunity to respond to the
      complaints against them.

    - Since the most abusive homes are broken homes, foster
      homes and group homes, children should be removed from
      families only when the families provide a level of
      care worse than foster homes.

    - Children's Aid workers should stop omitting facts
      favorable to families in court filings.

    - Children's Aid should abide by its agreements with
      parents.

    We are asking for your proxy to cast your vote at the
    annual general meeting of Children's Aid.  These proxies
    will be used to vote for two directors
    
    - Lillian Brewer.  Lillian has two children and two
      grandchildren.  She is employed as a factory worker.

    - Robert T McQuaid.  Robert has one child.  He has been
      the president of Quaid Software Limited since 1983.

    The terms of the directors end in June of 2003.  Neither
    of these candidates has previously served as an officer
    or director of Children's Aid, and neither has any
    financial obligation to Childrens's Aid, nor anticipates
    any financial loss or gain as a result of this election.
    Directors serve without compensation.  You are free to
    revoke this proxy later by signing another one, or by
    attending the meeting in person.

    If you want to help fix Children's Aid, please date and
    sign the enclosed proxy form, and return it in the
    envelope provided.  Feel free to call with any
    questions.

    June 5, 2000

    /signed/
    Robert T McQuaid   RR 5   Orangeville Ontario L9W 2Z2
    phone:  519-942-0565

    --------------------------------------------------------

    THE BANNER, Orangeville, FRIDAY, June 23, 2000

    Disgruntled residents unsuccessful in bid to join DCFS
    board

    Robert McQuaid and Lillian Brewer want to see some
    changes at local agency

    by  ELIZABETH JACKMAN
    For the Banner

    A bit of controversy surrounded this year's annual
    general meeting of Dufferin Child and Family Services
    held Tuesday evening at the Monora Park Pavilion.

    Two local people decided to run against the four
    incumbents on the 12-member board of directors.

    According to Gary Putman, Executive Director, every year
    four vacancies come up on the board.

    Candidates are usually chosen by a nominating committee
    however, the bylaw does allow for any two members of the
    society to nominate two people.

    This year, the new members, Robert McQuaid and Lillian
    Brewer, who have become disgruntled with the Child and
    Family Services, decided to take advantage of the bylaw
    and run.

    "In my 22 years experience, it has always been the
    nominating committee choosing four candidates.  This
    year there were six individuals running for four spots",
    said Putman.

    Although McQuaid and Brewer were unsuccessful in their
    bid to gain a seat on the board, McQuaid says he is not
    going to give up his attempts to try to bring about
    reforms to the service.

    "Children's Aid has become a group that is distinctly
    anti-family.  Quite a few families have been
    relentlessly attacked by Children's Aid, and even when
    they find out no child abuse has occurred, (they)
    continue the attack", said McQuaid.

    McQuaid is a Mono resident who has had personal dealings
    with the DCFS.

    The other candidate, Lillian Brewer, says she ran for
    the position because she wanted to see if she could help
    families stay together, which doesn't seem to be what is
    happening now.

    "They are pulling children out of the home instead of
    finding ways to keep them there", said Brewer.  "No one
    I have talked to that have had anything to do with Child
    and Family Services hasn't had a problem, but they won't
    speak up because they are afraid of them.  You are just
    one phone call away from losing your children because
    you are automatically guilty until proven innocent".

    "I would like to see them focus more on the family
    unit", said Brewer.  "People have asked for help and
    then they turned it against them and took their young
    kids.  It should be a place for children to be safe and
    taken care of".

    Brewer, who like McQuaid has had personal dealings with
    the agency, said she ran to make a point, that she
    doesn't believe in what they are doing.

    Putman would not comment on either case, other than to
    say, "the issues raised by the two candidates were
    individual issues to their particular situation and they
    do not reflect the philosophy of this organization or
    the Child and Family Services Act.  We do have clients
    on our board, our membership simply chose not to elect
    these two individuals".

    Both McQuaid and Brewer said that when Child and Family
    Services realized what was going on they signed on about
    40 new members, including many policemen to prevent them
    from being elected.

    McQuaid says he feels something has to be done, or the
    problems will continue on a larger scale.  "They have to
    realize, that breaking up a family is not going to
    accomplish anything", said McQuaid.

    --------------------------------------------------------

    Ontario Court of Justice
    at 10 Louisa Street, Orangeville ON L9W 3P9

    180/99

    Cumulative Table of Contents
    (continuing record)

    Volume 2

    Applicant

    The Children's Aid Society of the County of Dufferin
    50 Fourth Avenue, Unit 13  Orangeville ON L9W 4P1
    Tel:  519-941-1530  Fax:  519-941-1525
    Email:  dcafs@hurontario.net

    David Thwaites, Solicitor
    Wardlaw, Mullin, Carter and Thwaites
    235 Broadway  Orangeville ON L9W 2Z5
    Email:  dthwaites@wardlaw.on.ca

    Respondents

    ROBERT T MCQUAID
    RR 5, ORANGEVILLE ON L9W 2Z2
    LINDA PROSH
    RR 5, ORANGEVILLE ON L9W 2Z2
    EVELYN HUBER
    267 BROADWAY
    ORANGEVILLE, ON L9W 2Z2

    Document                           date        tab/page

    STATUS REVIEW APPLICATION      A   JUNE 21/00   110-114
    GENERAL AFFIDAVIT OF
      PATRICIA L COX               A   JUNE 21/00   115-127
    NOTICE OF MOTION               A   JUNE 21/00   128-143
    SUMMARY OF COURT CASES         A   JUNE 21/00   144-145

    For the second column the alternatives are:
    A = Filed by applicant
    R = Filed by respondent

    --------------------------------------------------------

    Ontario Court of Justice
    at 10 LOUISA ST  ORANGEVILLE

    Court File Number 180/99
    Cumulative Table of Contents
    (continuing record)

    Applicant

    THE CHILDREN'S AID SOCIETY OF COUNTY OF DUFFERIN
    50 FOURTH AVE #13 ORANGEVILLE ONT L9W 4P1
    WARDLAW MULLIN CARTER THWAITES
    235 BROADWAY
    ORANGEVILLE L9W 2Z5
    PH 519-941-1760 FAX 940-3688
    ATTN: DAVID THWAITES

    ROBERT McQUAID AND LINDA PROSH
    RR # 5  ORANGEVILLE
    ONTARIO L9W 2Z2
    519-940-9847

    Document                     date      filed   Tab/Page
    FORM 80 - APPLICATION     A  19/11/99  19/11/99     1-5
    FORM 14 NOTICE OF MOTION  A  19/11/99  19/11/99     6-7
    FORM 14A AFFIDAVIT
      (GENERAL)               A  19/11/99  19/11/99    8-46
    EXHIBIT 'E' TO AFFIDAVIT  A  19/11/99  25/11/99   47-48
    (illegible) OF SERVICE    A  19/11/99  25/11/99   49-52
    CONSENT                   A  22/11/99  22/11/99      53
    AFFIDAVIT GENERAL         A  29/11/99  30/11/99   54-84
    AFFIDAVIT OF SERVICE      A  30/11/99  30/11/99   85-86
    Affidavit of Service      R  30/11/99  30/11/99   87-99
    ANSWER                    R  30/11/90  30/11/99   91-94
    Affidavit General         R  30/11/99  30/11/99   95-99
    AFFIDAVIT                 A  02/12/99  02/12/99 100-104
    AFFIDAVIT                 A  21/11/99  23/12/99 105-109

    For the second column the alternatives are:
    A = Filed by applicant
    R = Filed by respondent

    --------------------------------------------------------

    Ontario Court of Justice
    10 Louisa Street, Orangeville, Ontario, L9W 3P9

    Court File Number 180/99
    Form 8B: Application status review

    Applicant
    The Children's Aid Society of the County of Dufferin
    50 Fourth Avenue, Unit 13
    Orangeville, Ontario L9W 4P1 Canada
    Phone:  519-941-1530
    Fax:  519-941-1525
    email:  dcafs@hurontario.net

    Wardlaw, Mullin Carter, Thwaites and Ward
    Attention: David Thwaites
    235 Broadway
    Orangeville, Ontario L9W 2Z5 Canada
    Phone:  519-941-1760
    Fax:  519-941-3688
    eMail:  dthwaites@wardlaw.on.ca

    Respondents
    Robert McQuaid
    RR #5  Orangeville, Ontario L9W 2Z2, Canada
    Phone:  940-9847
    Linda Prosh
    RR #5  Orangeville, Ontario L9W 2Z2, Canada
    Phone:  940-9847

    TO THE RESPONDENTS:
    A COURT CASE HAS BEEN STARTED AGAINST YOU IN THIS COURT.
    THE DETAILS ARE SET OUT ON THE ATTACHED PAGES.  THE
    FIRST COURT DATE IS July 5, 2000 AT 11:00 am or as soon
    as possible after that time, at:  10 Louisa Street,
    Orangeville, Ontario, L9W 3P9

    If you have also been served with a notice of motion,
    there may be an earlier court date and you or your
    lawyer should come to court for the motion.

    IF YOU WANT TO OPPOSE ANY CLAIM IN THIS CASE, you or
    your lawyer must prepare an answer (Form 10 - a blank
    copy should be attached), serve a copy on the applicant
    children's aid society and all other parties and file a
    copy in the court office with an affidavit of service
    (Form 6B).  YOU HAVE ONLY 30 DAYS AFTER THIS APPLICATION
    IS SERVED ON YOU (60 DAYS IF THIS APPLICATION IS SERVED
    ON YOU OUTSIDE CANADA OR THE UNITED STATES) TO SERVE AND
    FILE AN ANSWER.  IF YOU DO NOT, THE CASE WILL GO AHEAD
    WITHOUT YOU AND THE COURT MAY MAKE AN ORDER AND ENFORCE
    IT AGAINST YOU.

    WARNING:  This case is subject to case management, which
    means that the case runs on a timetable.  That timetable
    says that the following steps have to be finished by the
    following number of days from the start of this case:

    Temporary care & custody hearing     25 days
    Plan of care to be served & filed    33 days
    Case conference                      40 days
    Settlement conference                80 days
    Protection hearing or status review 120 days

    You should consider getting legal advice about this case
    right away.  If you cannot afford a lawyer, you may be
    able to get help from your local Legal Aid office.  (See
    your telephone directory under LEGAL AID).

    June 21, 2000
    /signed/  C Wale  Clerk of the court

    THE CHILD
    Kenneth Darryl McQuaid
    Date of Birth:  10/16/96
    Age: 3
    Gender:  Male
    Mother's Name:  Linda Prosh
    Father's Name:  Robert McQuaid
    Religion:  Unknown
    Native Status:  Unknown

    CLAIM BY APPLICANT SOCIETY

    [Taylor Jun 21]
    1.  The applicant children's aid society asks the court
    to make a finding under Part III of the Child and Family
    Services Act that the child named in this application
    continues to be in need of protection because:

    the child Ken McQuaid has suffered emotional harm that
    is demonstrated by severe anxiety, depression,
    withdrawal or self-destructive or aggressive behaviour,
    and the child's parent or the person having charge of
    the child does not provide, or refuses or is unavailable
    or unable to consent to, services or treatment to remedy
    or alleviate the harm [clause 37(2)(f)].

    there is a substantial risk that the child Ken McQuaid
    will suffer emotional harm that is demonstrated by
    severe anxiety, depression, withdrawal or
    self-destructive or aggressive behaviour, and the
    child's parent or the person having charge of the child
    does not provide, or refuses or is unavailable or unable
    to consent to, services or treatment to prevent the harm
    [clause 37(2)(g)].

    the child suffers from a mental, emotional or
    developmental condition that, if not remedied, could
    seriously impair the child's development and the child's
    parent or the parent having charge of the child does not
    provide, or refuses or is unavailable or unable to
    consent to, treatment to remedy or alleviate the
    condition [clause 37(2)(h)].

    [Taylor Jun 21]
    2.  The applicant society therefore asks for an order,

    that the child Ken McQuaid be placed with Robert McQuaid
    and Linda Prosh, parents subject to the supervision of
    The Children's Aid Society of the County of Dufferin for
    a period of 6 months, on the terms and conditions set
    out in the Appendix at the end of this Application form.

    [Taylor Jun 21]
    3.  To the best knowledge of the applicant society, the
    parties or the child have been in a court case before
    relating to the supervision, wardship (guardianship) or
    custody of or access to the child.  (attach a summary of
    court cases - Form 8E)

    [Taylor Jun 21]
    4.   The  parties  have not  made  a  written  agreement
    dealing with any matter involved in this case.

    [Taylor Jun 21]
    5.  The following is a brief statement of the facts upon
    which the applicant society is relying in the
    application.

      1.  Although Ken McQuaid has made improvements in
      language and social development, there are still
      significant areas of concern.

      2.  Dr Bakht, child and adolescent psychiatrist, has
      provided a diagnosis of parental neglect with social
      and language developmental delay secondary to parental
      neglect.

      3.  Ms Prosh and Mr McQuaid, though compliant with
      recommendations, have demonstrated behaviours which
      indicate difficulties in emotionally extending
      themselves to their son.

    /signed/  Debbie Taylor   June 21/2000
    Sr Program manager Child Protection Services

    APPENDIX

    The terms and conditions that the applicant society
    purposes for the child's supervision are as follows:

    (this page is left blank)

    --------------------------------------------------------

    Ontario Court of Justice
    at 10 Louisa Street, Orangeville, Ontario L9W 3P9

    Court File Number 180/99
    Form 14A: Affidavit (General) dated June 19, 2000

    Applicant
    The Children's Aid Society of the County of Dufferin
    50 Fourth Avenue, Unit 13
    Orangeville, Ontario L9W 4P1 Canada
    Phone:  519-941-1530
    Fax:  519-941-1525
    email:  dcafs@hurontario.net

    Wardlaw, Mullin Carter, Thwaites and Ward
    Attention: David Thwaites
    235 Broadway
    Orangeville, Ontario L9W 2Z5 Canada
    Phone:  519-941-1760
    Fax:  519-941-3688
    eMail:  dthwaites@wardlaw.on.ca

    Respondents
    Robert McQuaid
    RR #5  Orangeville, Ontario L9W 2Z2, Canada
    Phone:  940-9847
    Linda Prosh
    RR #5  Orangeville, Ontario L9W 2Z2, Canada
    Phone:  940-9847
    Evelyn Huber
    267 Broadway  Orangeville, Ontario L9W 1K8, Canada
    Phone:  940-4500

    My name is Patricia Louise Cox
    I work in Orangeville, Ontario
    and I swear/affirm that the following is true:

    [Cox Jun 21]
    1.  I have now been involved with this family for a
    period of 7 months.  During this time, I have obtained
    the following information about Mr McQuaid, Ms Prosh and
    their son, Ken McQuaid:

    [Cox Jun 21]
    i) On January 6, 2000 I spoke to Wil Weiner, behaviour
    therapist, who reported that the parents were very
    interested in being parents and were slowly learning
    what it takes to be a parent.  He stated they did not
    have a lot of support around how to deal with parenting
    concerns.  Mr Weiner stated that the mother had more
    difficulty with younger children and believed that both
    parents would do better when Ken is older.  He described
    Ken as an internal child and that this was the result of
    not a lot of parent/child interaction.  Mr Weiner stated
    that the parents needed a lot of teaching and support
    related to parenting advice around emotional, social and
    play development.  On January 14, 2000, at a case
    conference regarding Ken, Mr Weiner stated that Ken had
    difficulty with emotional regulation.  Mr Weiner
    described Ken as able to engage in play and wanting to
    involve his parents.  He stated that Ken was a strong
    child and could do significant damage and be difficult
    to control.  On April 27, 2000 Mr Weiner reported that
    the parents were progressing;  more attentive and
    involved and more aware of Ken's needs.  Mr Weiner
    stated that the mother's attentiveness was a working
    issue and that the parents needed to be "pushed to do
    rather than talk".  He stated that Ken's play was more
    abstract, speech clearer and talking more.  Mr Weiner's
    goals were to focus on parenting and behaviour concerns,
    toilet training and how to handle disagreements.  On May
    5, 2000, Mr Weiner provided a verbal report for a case
    conference.  He stated that he sees the parents and Ken
    every two weeks and had seen a positive change with
    Ken's language ie chatty, singing, saying yes now,
    acknowledging himself and another.  Mr Weiner states he
    had been encouraging pretend play by the parents with
    Ken and now there was elaborate and interactional
    pretend play.  He noticed that the parents are enjoying
    being parents.  They are taking Ken to the park,
    playland at MacDonald's, reading.  Mr Weiner planned to
    stay involved for the next 6 months until the parents
    and Ken accomplished toiletting and later, the
    transition from day care to school.  Mr Weiner's
    intervention has varied from weekly to biweekly
    involvement with the family.  I verily believe this to
    be true.

    [Cox Jun 21]
    ii) On January 7, 2000 I spoke with Karen Bowers,
    Supervisor of Hand-in-Hand Day Care who stated that Ken
    had been removed by them from the day care until further
    notice as a result of his severe behavioural problems
    and the effect on the other children and staff.  Ms
    Bowers expressed concern about remarks and comments by
    Ken's mother about Ken.  Ms Bowers reported that the
    mother had said to Ken "you pest", "bad boy", and "look
    at you Ken, Why can't you be like the other children.
    You were such a nice baby - What happened to you?".  Ms
    Bowers stated that she has only seen this kind of
    behaviour in children who have suffered mental abuse.  I
    verily believe this to be true.

    [Cox Jun 21]
    iii) Ken presently attends the Women's Resource Centre
    three times a week and has been since February 1, 2000.
    Jill Cutter, a worker at the centre, states that when he
    first appeared there were difficult days.  However, his
    behaviour and speech have improved as he interacts more
    with other children.  However, Ms Cutter reported
    concern with Ms Prosh in a number of areas:  limited
    interest in Ken's accomplishments at the centre ie when
    Ms Prosh comes to get Ken she doesn't go with him to see
    his craft.  She asks if he has a craft and then leaves.
    Ms Cutter also reported an incident where she notice
    that Ken smelled of perfume and also as if he had had a
    bowel movement.  The staff asked Ms Prosh about this and
    Ms Prosh stated that she wondered if Ken had soiled
    himself earlier and so had put perfume on him.  Note:
    it is the expectation of the centre that mother's with
    children over the age of 2 change their children's
    diapers.  Another worker Ms Mary Lynn Richardson
    reported that at one point Ken had a Band-Aid on that
    was loose and noticed underneath a substantial cut.  She
    stated that it looked like a slice or piece of skin was
    missing.  Ms Richardson changed the Band-Aid and then
    ten minutes later, Ms Prosh came into the room and was
    informed of the Band-Aid change.  Ms Prosh said there
    wasn't a cut and that he just wanted a bandaid.  Ms
    Richardson stated that Ms Prosh just disregarded the
    whole thing, leaving the staff to be confused.  Ms
    Richardson also reported that at times when Ms Prosh
    enters the room Ken tantrums.  She reports that she has
    observed Ms Prosh yelling at Ken and that Ms Prosh needs
    to learn to redirect and be positive with him.  Ms
    Richardson also states that one day Ken was sick with
    green discharge from his nose and he was coughing.  Ms
    Prosh responded to the centre's concern and the centre's
    request to leave by asking Ken if he wanted to go.  Ms
    Richardson stated that it took twenty minutes before Ken
    and Ms Prosh left and that it was a struggle for the
    staff to get her to go home.  Ms Richardson also noted
    that Ms Prosh wanted Ken to colour Ms Prosh's pictures
    when Ken wanted to do otherwise.  Ms Richardson stated
    she feels that Ken's delays are the result of lack of
    socialization.  Ms Richardson, on April 19, 2000,
    reported that they still saw some echolalia.  Ken would
    do some crafts but did not interact with other children.
    Ken moved around the room and played with toys.  She
    reported that the longer he's in the setting and with a
    increasing number of children, the more frustration
    there is in Ken.  The centre staff have suggested that
    Ms Prosh help on Wednesdays and stay in the room to
    obtain parenting ideas from the teachers.  I verily
    believe this to be true.

    [Cox Jun 21]
    iv) On May 23, 2000 I spoke with Debbie Launspach,
    Supervisor with Sand Box Tech, a nursery school that Ken
    has attended for the last three months.  Ms Launspach
    stated that she has had some concerns regarding Ken and
    his parents.  For example, approximately six weeks
    prior, Mr McQuaid, in front of Ken and the other
    parents, asked Ms Launspach "How's my retarded son
    doing?".  Ms Launspach stated that the school staff had
    been working with the mother and child on emotional
    interactions ie Ken giving his mother a kiss.  Ms
    Launspach reported that Ms Prosh appeared reluctant with
    this, as if she was not sure she was going to receive
    one.  Ms Launspach stated that Ken was sitting more at
    circle and participated more with activities.  She
    noted, however, that he "freaks out with toiletting;
    tantrums".  They have not noticed head banging or self
    stimulating behaviour.  There is aggression with other
    children which they treat with timeouts.  On May 31,
    2000 during a case conference, Ms Launspach stated that
    despite progress in behaviour the following concerns
    exist:  after speaking a sentence or two he goes back
    into himself;  he is still different from his peers
    though is responding to what his peers have engaged him
    in;  and toiletting is a problem, he lands on the floor,
    yelling and screaming.  I verily believe this to be
    true.

    [Cox Jun 21]
    v) Parent Infant Consultant with the Parent Infant
    Program, Nina Little Alcorn has continued to be involved
    with the family for the last seven months with visits
    averaging once or twice monthly.  On April 20, 2000 Ms
    Little Alcorn reported that the parents have been
    present for each visit with good follow through with
    appointments and phone calls.  Ms Little Alcorn was
    concerned about unnecessary qualifying comments by the
    mother.  She stated that she observed Ken referring to
    himself as a brat.  Ms Little Alcorn stated that she had
    given Ms Prosh activities to encourage nurturing;
    permitting a kid to be a kid and the parent to be a
    parent in a safe setting, encouraging memory building
    activities.  During this discussion Ms Little Alcorn
    also described an incident on March 17, 2000 in the
    speech pathologist's office where Ms Little Alcorn was
    doing a joint visit with Kindrey Rowlands, SLP.  The
    session generally went well for Ken although Ms Little
    Alcorn reported that there were odd comments and raised
    voice from the mother.  The mother was not feeling well
    and on antibiotics.  However, at one point, Ms Little
    Alcorn reported that Ken climbed onto a chair and was on
    his knees on the chair when the chair fell backwards and
    crashed.  Ken hit his head and cried.  Ms Prosh, who was
    writing a cheque, stayed in her seat, barely looked up
    and yelled "stop crying, that's what you get for acting
    up.  Ken it's not that bad".  Ken sought comfort from
    his mother but received it from Ms Little Alcorn and
    Kindrey Rowlands.  At one point, with her back to Ken,
    still writing the cheque, Ms Prosh patted Ken's back and
    said, "It's not that bad sweetie".  There was no hug,
    kiss or eye contact.  Ms Little Alcorn reports also that
    Ms Prosh stated that she still had problems controlling
    him in the mall, at Burger King and at the airport.  Ms
    Little Alcorn wondered at that time how much could be
    taught and felt that the parents needed support in child
    management especially limit setting, discipline, rules
    and boundaries, compliance and especially how to deal
    with emotional needs.  On May 31, 2000 Ms Little Alcorn
    stated that the latest test showed delays in speech and
    language and possible marginal delays in gross motor but
    that this was not a concern now.  Ms Little Alcorn was
    concerned with Ken's fit with his peers.  Ms Alcorn
    Little reported on June 16, 2000 that Ken's higher level
    of thinking was improving as well as his mood and
    emotional regulatory abilities.  She reported that
    effort had been noticed with Ms Prosh in particular,
    however, Mr McQuaid relationship with Ken was more
    difficult to assess.  Ms Little Alcorn was not sure how
    Ken would continue to progress and states an assessment
    by the Child Advocacy and Assessment Program would be
    very helpful.  Ms Alcorn Little states that she will
    continue to be involved with the family only for
    approximately another four months until Ken reaches the
    age of four.  (see report attached Exhibit A).  I verily
    believe this to be true.

    [Cox Jun 21]
    vi) Kindrey Rowlands, Speech and Language Pathologist
    has been involved with Ken in weekly speech and language
    intervention sessions from February 18, 2000 to June 8,
    2000 for a total of 14 sessions.  Ms Rowlands reports
    that Ms Prosh has actively participated in sessions and
    that Ken was also accompanied by his father on occasion.
    She reports that both parents followed through with home
    practice suggestions and provided regular verbal reports
    of Ken's progress with therapy goals in everyday
    situations at home.  Although he has demonstrated steady
    and marked progress in the relatively short time since
    he was initially assessed, Ken's speech development and
    his expressive and receptive language skills continue to
    fall Below Average for his age.  Ms Rowlands recommends
    that Ken continue to receive speech and language
    intervention focused primarily on developing his social
    and his conversation skills;  continued participation in
    a program that facilitates Ken's interaction with other
    children and that Ken's speech and language development
    be re-assessed in the fall of 2000 (see Exhibit B).  I
    verily believe this to be true.

    [Cox Jun 21]
    vii) On April 12, 2000 Debbie Taylor, Senior Program
    Manager, with the Society received a phone call from
    Alice Veenman, Mono Township Council Member and Carl
    Ross, Director of Social Services.  They reported to Ms
    Taylor that Mr McQuaid had spoken to council about "the
    kid" (his son) being taken by the Society without an
    appropriate complaint.  Ms Veenman and Mr Ross stated
    that Mr McQuaid then described the messiness in his
    home, the gratings out of the floor, the the blind cords
    dangling, and the broken crib.  He continued to refer to
    his son throughout the presentation as "the kid" and
    indicated that he felt that the Society was
    inappropriately involved with his family.  I verily
    believe this to be true.

    [Cox Jun 21]
    viii) This worker met with Mr McQuaid and Ms Prosh a
    number of times.  It was observed that on each visit Ken
    was improving in speech and language and social skills
    though not at par with his peers.  Information regarding
    the Easter Seals diaper program and the Parent Relief
    Program was given to Mr McQuaid during a drop by visit.
    Parents reported some destructive behaviour such a
    destroying videos, throwing toys and frustration with
    toilet training.  However, at the case conference of May
    31, 2000 Ms Prosh indicated that Ken was much easier to
    handle and that they did not need to be on top on Ken as
    much.  Ms Prosh stated that Ken was more attached to her
    now and only bangs his head on her when he is
    frustrated.  During the visits there was evidence of
    toys, appropriate bedding and clothing.  There was no
    lock on his door and the drawers were still out of the
    dresser.  I verily believe this to be true.

    [Cox Jun 21]
    ix) I spoke with Dr Bakht, child and adolescent
    psychiatrist, on March 3, 2000 and later met with him
    June 6, 2000.  Dr Bakht stated that, initially Ken, on
    referral was 3, and at a local day care for three weeks.
    He reported that the father was fairly bitter and angry
    with the Children's Aid Society but that the mother was
    composed and gave fairly honest information and admitted
    her responsibility in not being an acceptable mother.
    Dr Bakht stated that Ms Prosh had been most helpful as
    the peacemaker with her husband and his anger at the
    system.  Dr Bakht stated that the father has trouble
    with trusting.  Dr Bakht reported that the parents
    described Ken at that time as going into a rampage when
    tired/bored resulting in hitting, biting, destructive
    behaviour at home and at the day care.  The psychiatrist
    reported that Ken was not on medication and that his
    physical health was fine.  Dr Bakht stated that both
    parents are intellectually superior but lacking the
    social skills to take care of themselves and their
    child.  Dr Bakht reported that he originally saw Ken
    with difficulties with speech and restless/hyperactive
    behaviour.  Dr Bakht stated that when children are not
    stimulated or kept contained, they become more hyper.
    Dr Bakht states that Ken was more lively and able to
    have a rapport with the psychiatrist with some bright
    feelings of happiness.  Dr Bakht stated that the
    interaction between Ms Prosh and Ken and Mr McQuaid and
    Ken in his setting is okay.  Initially, Dr Bakht's
    provisional diagnosis was neglect of the child or ADD.
    However, as Ken's behaviour and abilities have improved,
    his final diagnosis was parental neglect of the child
    with developmental (social and language) delays
    secondary to neglect.  He stated that the parents love
    Ken and the neglect was not intentional but with their
    emotional and financial difficulties and isolation, they
    became emotionally and physically distanced from their
    child.  Dr Bakht stated he has provided the parents with
    reassurance, psychoeducational information regarding
    child rearing, good parenting, responding to cues and
    presently sees the family monthly.  The Society's
    concerns regarding the parent's ability to apply their
    knowledge at an emotional level was described to the Dr
    Bakht An assessment of Ken by the Child Advocacy
    Assessment Program at Chedoke McMaster Hospital was
    discussed.  Dr Bakht supported the decision as it would
    provide a thorough and comprehensive assessment and
    identify the degree of the delay and implications for
    the future and provide recommendations for Ken, his
    family and the professionals involved with them.

    [Cox Jun 21]
    x) On June 20, 2000, following a call from Dr Bakht to
    this writer, I spoke with Dr Bakht.  Dr Bakht reports
    that Mr McQuaid and Ms Prosh had indicated through their
    lawyer that they did not want to participate in an
    assessment with the Child Advocacy Assessment Program.
    Dr Bakht states that he supports completely the
    assessment as the assessments locally have been
    scattered and a comprehensive assessment would be
    instrumental in identifying the degree of the delay and
    implications for the future and provide recommendations
    for Ken, his family and the professional involved with
    them.  Dr Bakht reported that he will meet with Mr
    McQuaid and Ms Prosh and indicate his continued support
    of the assessment.

    [Cox Jun 21]
    xii) Ken is clearly moving positively towards being able
    to master his age appropriate developmental milestones.
    However, he is still below average despite significant
    intervention by many professionals.  Mr McQuaid and Ms
    Prosh have complied with all requests and followed
    through on all interventions.  However, statements and
    behaviours by them indicate difficulty in applying these
    on a day to day basis.  Ken McQuaid was found to have
    significant developmental delays secondary to parental
    neglect.  The concerns raised by the professionals
    continue to demonstrate to the Society that Ken still at
    risk of neglect.  Mr McQuaid's statement to the Township
    Council indicates an inability to recognize his role in
    neglect with his child.  The Society feels that there is
    a continued need to be involved to ensure the continued
    work with Ken and to monitor his progress.  The Society
    would like the assessment with the Child Advocacy
    Assessment Program to proceed to provide a thorough and
    comprehensive assessment and to identify the degree of
    the delay and the implications for the future and
    provide recommendations for Ken, his family and
    professionals involved with them.

    [Cox Jun 21]
    xiii) I make this statement with no improper intent.

    /signed/  Patricia L Cox

    Sworn/Affirmed before me at Orangeville
    in Ontario
    on June 21, 2000

    /signed/  Irene Beazley
    A Commissioner, etc, Province of Ontario,
    for the Children's Aid Society.
    Expires September 27, 2003

    ........................................................

    Exhibit A

    CAS memohead

    PERSONAL LIFE PLAN (Short)/ SERVICE UPDATE

    PARENT INFANT PROGRAM

    CLIENT NAME:  Ken McQUAID

    DATE OF BIRTH:  16 October 1996

    DATE PLAN COMPLETED:  May 31, 2000

    PLANNING PARTICIPANTS:  Nina K Little Alcorn/ L Prosh/ R
    McQuaid (and service providers/conference participants)

    PERSONAL INTRODUCTION:

    [Little Jun 1]
    Ken (Kenneth) is the 43 month old only child of Linda
    Prosh and Bob (Robert) McQuaid.  Ken is an attractive,
    interesting, and engaging preschooler.

    [Little Jun 1]
    I do not have a complete early medical/developmental
    history, however, it is my understanding that Ken was
    born at term and of average size.  I also believe that
    he has enjoyed relatively good health, but that there
    were fluctuating concerns early on about delayed motor
    milestones and speech and language development.

    [Little Jun 1]
    Ken was initially referred to our service by a child
    welfare intake worker, requesting my impressions about
    Ken's developmental status.  As our contact continued I
    engaged with Ken's parents to provide developmental
    monitoring, information, suggestions, and support.

    Current Services and Supports.

    [Little Jun 1]
    This worker has made 8 home visits, 3 office visits and
    attended one speech and language therapy appointment.  I
    have also participated in 2 case conferences, including
    today's, and, joined with Ken's parents at a "theraplay"
    session.  Referrals were made by this worker to CCAC,
    the Preschool Resource Program, and Wee Talk.
    Literature was provided about securing quality childcare
    and other private services.

    [Little Jun 1]
    Visits average once or twice monthly, typically
    revolving around a play-and-chat session in the family
    home with Ken and both of his parents.  We have reviewed
    the Ages and Stages Questionnaire for 36 months and the
    mental subtest of the Bayley Scales of Infant
    Development.

    [Little Jun 1]
    To the best of my knowledge the other paid, or unpaid,
    supports to Ken and his parents include Ken's speech and
    language pathologist, family counsellor, family service
    worker, doctor (as needed), a maternal uncle, Ken's
    preschool setting, and the "women's centre".  CCAC found
    Ken to be ineligible for service and the Preschool
    Resource Program were involved only briefly.

    PERSONAL PLAN AND GOALS:  Wishes, Dreams and
    Aspirations:

    Future Directions:

    [Little Jun 1]
    It is my sense that Bob and Linda wish to keep their
    family intact and continue to parent Ken together.  They
    hope for his optimal, healthy development and readiness
    for successful entry to elementary school.  Linda and
    Bob have appeared receptive to my partnership with them,
    following up on concrete suggestions regarding services,
    equipment, etc.  They have kept appointments and
    permitted me to reschedule when necessary.  I feel a
    dedication to trying to follow through on ideas, such as
    the speech ideas, purchasing different toys, etc.

    Current Goals:

    [Little Jun 1]
    I continue to feel uncertainty about Ken's developmental
    profile.  Although he has made remarkable gains,
    particularly in his speech, I'm unsure about the larger
    repertoire of higher level skills, comprehension,
    representational and imaginary play, mood and emotional
    regulatory abilities, etc.  I am not able to make a
    clear statement regarding Ken's attachment
    relationships.  I did witness one episode of injury
    followed by a reluctant response from his mom, which we
    addressed by way of conversation about that incident in
    particular and at length more generally about the
    emotional needs of young children.

    [Little Jun 1]
    My role will be to attempt to offer additional knowledge
    and support to achieve more of that understanding,
    review Ken's development with screens we have, and offer
    general resource and support around parenting this 2-1/2
    to 4 year old.  My service will conclude at Ken's 4th
    birthday.

    [Little Jun 1]
    I encourage Linda and Bob's attendance at relevant
    workshops/groups, Ken's participation at preschool, and,
    if possible, a more comprehensive assessment.

    /signed/ Nina K Little Alcorn
    Parent Infant Program Consultant
    May 31, 2000

    /signed/ Dorothy McLachlan
    Program Manager, Clinical Services
    June 1/00

    cc: R McQuaid/L Prosh
        T Cox

    kmcquaidlifeplan.wpd

    ........................................................

    Exhibit B

    ORANGEVILLE SPEECH & LANGUAGE CLINIC

    PROGRESS REPORT
    SPEECH-LANGUAGE PATHOLOGY

    Name:           Kenneth McQuaid
    Date of Birth:  October 16, 1996
    Report Date:    June 15, 2000
    Age:            3 years, 8 months

    PROGRESS SUMMARY

    Ken participated in weekly speech and language
    intervention sessions from February 18, 2000 to June 8,
    2000 for a total of 14 sessions.  Ken's mother actively
    participated in sessions and Ken was also accompanied by
    his father on occasion.  Both Mr McQuaid and Mrs Prosh
    followed through with home-practice suggestions and
    provided regular verbal reports of Ken's progress with
    therapy goals in everyday situations at home.
    Intervention to date has focused on the following areas:

    [Rowland Jun 15]
    1.  Developing Pretend Play Skills

    Ken has demonstrated marked improvement in this area.
    At the time of his initial assessment, Ken generally
    played with toys appropriately (eg, beating a drum,
    completing puzzles, stacking blocks).  However, his
    pretend play skills were an area of weakness.  For
    example, Ken appropriately named and placed furniture
    and people in a doll hose, however, he did not act out
    routines or involve the people in pretend conversations.
    This lack of pretend play was observed across a variety
    of toys.

    Intervention focused on modelling pretend play in a
    variety of activities.  (eg, pretending to eat and drink
    at a picnic and acting out familiar routines with a doll
    house).  Modelling pretend play was a powerful technique
    and Ken quickly joined in when he observed his mother
    engaging in pretend play activities.  Mrs Prosh reported
    that she purchases a variety of toys to facilitate Ken's
    pretend play skills at home.  Ken will now engage in
    pretend play activities without a model with a variety
    of toys both at home and at the clinic (eg, using a dish
    set, fire station, and a farm).  It was recommended that
    Ken's parents continue to get on the floor with Ken and
    engage in pretend play activities [eg, acting out
    familiar routines, putting on puppet shows, using one
    object to represent many objects (eg, a box might be an
    airplane and then a train)].  I have not observed Ken's
    play skills with his peers to date.  However, this will
    be an area of investigation in the near future.

    [Rowland Jun 15]
    2.  Developing Ken's Ability to Answer Questions
    Appropriately

    At the time of initial assessment, Ken was able to
    answer some simple "wh" questions appropriately.  In
    particular, he typically responded with the correct
    label when asked "What's this?".  When asked simple
    yes/no or forced choice questions, Ken typically echoed
    the question, and occasionally answered appropriately if
    given further processing time.

    Intervention focused on increasing Ken's ability to
    appropriately answer a variety of question types while
    reducing echolalia.  Ken has demonstrated good progress
    in this area.  He is now able to answer concrete
    forced-choice questions consistently (eg, Do you want
    milk or juice?, do you want the bubbles or the stamps?).
    Typically, these objects no longer have to be visible.
    He continues to have difficulty answering abstract
    forced-choice questions (eg, an echolalic response would
    be likely if asked about events that will occur in
    future or have occurred in the past).

    Intervention has also focused on answering yes/no
    questions.  Ken will now consistently answer short,
    simple and concrete yes/no questions (eg, Do you like
    broccoli?, Do want to play with the house?, Do you have
    the ball?).

    Future intervention will focus on developing Ken's
    ability to talk about more abstract topics.

    [Rowland Jun 15]
    3.  Developing Use of the Pronouns "My" and "Your" in
    Turn-taking Activities.

    Due to Ken's tendency to repeat verbatim was is said,
    pronoun confusions are common.  For example, when Ken is
    told "It's your turn Ken", he will respond "It's your
    turn" while taking his own turn in a game.  Intervention
    initially focused on developing turn-taking skills while
    using proper names (eg, "Mom's turn", "Kindrey's turn")
    to minimize pronoun confusions.  Ken developed his
    turn-taking skills quickly in structured activities and
    shared turns easily with other adults.

    Recently Ken has begun to say "my turn" and "your turn"
    appropriately in structured activities.  Intervention
    focusing on reducing pronoun confusions will continue.

    [Rowland Jun 15]
    4.  Developing an Appropriate Greeting

    This has been a recent target of intervention.
    Currently, when an individual says "Hi Ken" he will
    respond "Hi Ken".  Intervention is focusing on
    developing his ability to appropriately respond with the
    individual's name (eg, "Hi Mom").

    SUMMARY AND RECOMMENDATIONS

    Ken's speech development and his expressive and
    receptive language skills continue to fall Below Average
    for his age.  However, he has demonstrated steady and
    marked progress in the relatively short time since he
    was initially assessed.  Intervention to date has
    focused primarily on developing his pretend play, his
    conversational skills, and reducing echolalia.  Ken has
    demonstrated progress in his ability to talk about and
    answer questions about simple, concrete topics in the
    here and now.  However, his ability to talk about more
    abstract topics (eg, sharing stories about past events,
    talking about the future, answering more complex
    questions) continues to be a significant weakness for
    his age.  His pretend play skills have developed well.
    His interactive play skills with peers will be a future
    target of intervention.  Importantly, he has
    demonstrated an ability to generalize skills learned in
    intervention sessions across a variety of settings and
    situations.

    The following recommendations were made.

    [Rowland Jun 15]
    1.  It was recommended that Ken continue to receive
    speech and language intervention focused primarily on
    developing his social and his conversations skills,
    particularly for more abstract topics.

    In addition to weaknesses in these priority areas, Ken
    continues to demonstrate needs in his expressive and
    receptive vacabulary, in his understanding and use of a
    variety of concepts, in his auditory comprehension of
    longer and more complex instructions, and in his
    oral-motor development.  These areas will also be
    addressed in future sessions.

    [Rowland Jun 15]
    2.  Ken is currently attending a pre-school program.
    Continued participation in a program that facilitates
    Ken's interaction with other children is strongly
    recommended.

    [Rowland Jun 15]
    3.  It was recommended that Ken's speech and language
    development be re-assessed in the fall of 2000.

    Please call 519-941-1314 if I can provide any further
    information.

    Sincerely,

    /signed/  Kindrey Rowland, M SC, S-LP(C), Reg CASLPO
    Date June 15, 2000

    cc:  Mrs L Prosh, and Mr R McQuaid RR #5, Orangeville,
             ON, L9W 2Z2
         Dr Murphy, 15 Elizabeth St, Orangeville, ON, L9W
             3X3
         Dr S Ross, Tottenham Medical Centre, 119 Queen St
             N, Tottenham, ON, L0G 1W0
         N Little Alcorn, Dufferin Child & Family Services,
             50 Fourth Ave, Unit #13, Orangeville, ON, L9W
             4P1

    Kindrey Rowland
    M Sc  S-LP(C) Reg CASLPO, Speech-Language Pathologist

    15 Elizabeth Street, Suite M-15, Orangeville, Ontario
    L9W 3Z3  Phone/Fax 519-941-1314

    --------------------------------------------------------

    Ontario Court of Justice
    at 10 Louisa Street, Orangeville, Ontario, L9W 3P9

    Court File Number 180/99
    Form 14:  Notice of Motion

    Applicant
    The Children's Aid Society of the County of Dufferin
    50 Fourth Avenue, Unit 13
    Orangeville, Ontario L9W 4P1 Canada
    Phone:  519-941-1530
    Fax:  519-941-1525
    email:  dcafs@hurontario.net

    Wardlaw, Mullin Carter, Thwaites and Ward
    Attention: David Thwaites
    235 Broadway  Orangeville, Ontario L9W 2Z5 Canada
    Phone:  519-941-1760
    Fax:  519-941-3688
    eMail:  dthwaites@wardlaw.on.ca

    Respondents
    Robert McQuaid
    RR #5  Orangeville, Ontario L9W 2Z2, Canada
    Phone:  940-9847
    Linda Prosh
    RR #5  Orangeville, Ontario L9W 2Z2, Canada
    Phone:  940-9847

    TO THE PARTIES:
    THE COURT WILL HEAR A MOTION on June 28, 2000 at 11:00
    am, or as soon as possible after that time at 10 Louisa
    Street, Orangeville, Ontario, L9W 3P9

    This motion will be made by The Children's Aid Society
    of the County of Dufferin who will be asking the court
    for an order for the item listed at the end of this
    notice.  A copy of the affidavit in support of this
    motion is served with this notice.  If this material is
    missing, you should talk to the court office
    immediately.

    The person making this motion is also relying on the
    following documents in the continuing record:

    past affidavits

    If you want to oppose this motion or to give your own
    views, you should talk to your own lawyer and prepare
    your own affidavit, serve it on all other parties not
    later than 4 days before the date above and file it at
    the court office not later than 2 days before that date.
    Only written and affidavit evidence will be allowed at a
    motion unless the court gives permission for oral
    testimony.  You may bring your lawyer to the motion.

    IF YOU DO NOT COME TO THE MOTION, THE COURT MAY MAKE AN
    ORDER WITHOUT YOU AND ENFORCE IT AGAINST YOU.

    June 21/00
    /signed/ Debbie Taylor

    Wardlaw, Mullin, Carter, Thwaites and Ward
    Attention:  David Thwaites 235 Broadway
    Orangeville, Ontario L9W 2Z5  Canada
    Phone:  519-941-1760
    Fax:  519-941-3688
    eMail:  dthwaites@wardlaw.on.ca

    State the order or orders requested on this motion.

    An order for an assessment of Ken McQuaid by the Child
    Advocacy and Assessment Program at Chedoke McMaster
    Hospital, Department of Paediatrics pursuant to section
    54 of the Child and Family Services Act.

    ........................................................

    At this point there is a copy of the letter from
    Children's Hospital, or Chedoke-McMaster, dated February
    10, 2000, but withheld until May 31.

    ........................................................

    The affidavit of Trish Cox dated June 21, 2000 with two
    attachments is duplicated here in the court papers

    --------------------------------------------------------

    Ontario Court of Justice
    at 10 Louisa Street, Orangeville, Ontario, L9W 3P9

    Court File Number 180/99
    Form 8E:  Summary of Court Cases


    Applicant
    The Children's Aid Society of the County of Dufferin
    50 Fourth Avenue, Unit 13
    Orangeville, Ontario L9W 4P1 Canada
    Phone:  519-941-1530
    Fax:  519-941-1525
    email:  dcafs@hurontario.net

    Wardlaw, Mullin Carter, Thwaites and Ward
    Attention: David Thwaites
    235 Broadway  Orangeville, Ontario L9W 2Z5 Canada
    Phone:  519-941-1760
    Fax:  519-941-3688
    eMail:  dthwaites@wardlaw.on.ca

    Respondents
    Robert McQuaid
    RR #5  Orangeville, Ontario L9W 2Z2, Canada
    Phone:  940-9847
    Linda Prosh
    RR #5  Orangeville, Ontario L9W 2Z2, Canada
    Phone:  940-9847

    My name is Patricia Louise Cox

    The attached is a diary of all the steps in this case
    and any other relevant court cases involving:
    (a)  any of the parties; or
    (b)  a child who is part of this case or whose
         interests are part of this case.

    /signed/ Patricia L Cox
    June 21.00.

    ........................................................

    Form 8E:  Summary of Court Cases

    Nov 22/99  Protection application
               heard Nov 22/99 by Judge JB Allen
               ordered Dec 9/99 Adjourned to Dec 1/99
               Temporary care of CAS w/access

    Dec 2/99   Protection Application
               heard Dec 2/99 by Judge JB Allen
               ordered Dec 2/99 Adjourned to Dec 22/99
               Supervision Order (Interim)

    Dec 22/99  Protection Application
               heard Dec 22/99 by Judge Karswick
               ordered Dec 22/99 Adjourned to Jan 19/2000

    Jan 19/00  Protection Application
               heard Jan 19/2000 by Judge JB Allen
               ordered Jan 19/2000 Supervision Order 6
               months with terms and conditions

    June 28/00 Status Review Application
               heard June 28/2000


    --------------------------------------------------------

    Ontario Court of Justice
    at 10 Louisa Street, Orangeville Ontario L9W 3P9

    Court File Number 180/99
    Form 14A:  Affidavit (General) dated June 24, 2000

    Applicant
    The Children's Aid Society of the County of Dufferin
    50 Fourth Avenue, Unit 13
    Orangeville, Ontario L9W 4P1 Canada
    Phone:  519-941-1530
    Fax:  519-941-1525

    Wardlaw, Mullin, Carter, Thwaites and Ward
    Attention:  David Thwaites
    235 Broadway  Orangeville, Ontario L9W 2Z5  Canada
    Phone:  519-941-1760
    Fax:  519-941-3688
    eMail:  dthwaites@wardlaw.on.ca

    Respondents
    Robert McQuaid
    RR #5  Orangeville Ontario L9W 2Z2 Canada
    Linda Prosh
    RR #5  Orangeville Ontario L9W 2Z2 Canada

    Evelyn Huber
    Huber & Hersche
    Barristers and Solicitors
    Orangeville Ontario L9W 1K3 Canada
    Phone 519-940-4502

    My name is Patricia Louise Cox
    I work in Orangeville, Ontario
    and I swear/affirm that the following is true:

    [Cox Jun 26]
    1.  I am a child protection and family services worker
    with the Children's Aid Society of the County of
    Dufferin.  I have been involved with this family for
    seven months.

    [Cox Jun 26]
    2.  Ken McQuaid has been assessed by a number of
    professionals in the community for the significant
    delays that he presented when first brought to the
    attention of the Society.  These professionals have also
    provided interventions which have allowed Ken to move
    positively towards reaching his developmental
    milestones, especially in the areas of speech and
    social/emotional development.  However, Ken still
    presents with delays and was found to be below average
    in speech and language development by his Speech and
    Language Pathologist, Kindrey Rowlands.  Nina Little
    Alcorn has expressed concern regarding his development
    socially and emotionally.  The nursery school staff have
    identified that Ken is different.  Dr Bakht, child and
    adolescent psychiatrist, has diagnosed Ken as having
    developmental delays (language and social/emotional)
    secondary to parent neglect.  He stated to this worker
    that a comprehensive assessment of Ken would be useful
    as the assessments done to date have been scattered and
    therefore he supports a comprehensive and thorough
    assessment of Ken to identify the degree of the delay
    and implications for the future and to provide
    recommendations for Ken, his family and professionals
    involved with them.  Ms Rowlands, Ms Little Alcorn and
    Ms Launspach with the nursery school also stated that
    they felt that this assessment would be useful for them
    in their work with Ken.  I verily believe this to be
    true.

    [Cox Jun 26]
    3.  Ms Prosh, at a case conference of May 31, 2000,
    stated that she did not have any objection to this
    assessment but expressed concern regarding her husband's
    response to the suggestion.  Ms Prosh was advised at the
    case conference that the referral to the Child Advocacy
    and Assessment Program had been initiated in February by
    this writer as it was not known at that time how Ken
    would progress and this writer knew that it typically
    took four to six months at referral time to receive an
    assessment date.  At the time that the Child Advocacy
    and Assessment Program referral was initiated it was
    also not known to this writer that the parents had found
    a psychiatrist that could provide a diagnosis.

    [Cox Jun 26]
    4.  The Child Advocacy and Assessment Program assessment
    (see Exhibit A) was to begin June 28, 2000.  I spoke
    with Ms Linda Harris with the program on June 23, 2000
    and they have agreed to delay the first meeting date to
    July 7, 2000 to facilitate this court matter with this
    motion.  They will add an additional date to the
    assessment at the end of the assessment period.

    [Cox Jun 26]
    5.  I spoke with Dr Bakht June 23, 2000.  Dr Bakht
    states that the parents reported to him at a recent
    meeting that they will participate in the assessment as
    long as the information obtained will not be used
    against them.  I stated to Dr Bakht that I had a
    responsibility to the child under legislation to act on
    any information that might effect the well-being of the
    child.  I verily believe this to be true.

    [Cox Jun 26]
    6.  The Society has seen improvement in Ken but despite
    significant intervention by many providers Ken still is
    below average in his speech and language and social and
    emotional development.  Dr Bakht has diagnosed him as
    having developmental delays secondary to parent neglect.
    The Child Advocacy and Assessment Program will assist
    Ken, the parents, the professionals and the Society in
    determining the degree of delay, implications for the
    future and to provide recommendations.  Ken will be four
    years old in October.  The assessment will be completed
    just prior to that birth date.  The information received
    will help Ken, for the following year, to prepare for
    school where he will be introduced to very complex
    social interactions and require complex speech to
    effectively communicate his needs and to learn.  The
    assessment will be useful also, in providing information
    relating to the parents and their relationship with Ken
    and this information will therefore also help the
    professionals assist the parents to provide for the
    social and emotional needs of the child.

    /signed/ Patricia L Cox

    Sworn/Affirmed before me at Orangeville
    in Ontario
    on June 26, 2000
    /signed/ Irene Beazley
    A Commissioner etc Province of Ontario,
    for the Children's Aid Society.
    Expires September 27, 2003.

    ........................................................

    (Exhibit A is a photocopy of the letter from
    Chedoke-McMaster to Trish Cox dated February 10, 2000,
    shown above chronologically.)

    --------------------------------------------------------

    ONTARIO COURT OF JUSTICE
    at 10 Louisa Street, Orangeville, Ontario, L9W 3P9

    Court File Number 180/99
    Form 10: Answer

    Applicant
    THE CHILDREN'S AID SOCIETY FOR THE COUNTY OF DUFFERIN
    50 Fourth Street  Unit 13  Orangeville Ontario L9W 4P1
    (519) 941-1530
    (519) 941-1525 - fax

    WARDLAW, MULLIN, CARTER, THWAITES & WARD
    Barristers & Solicitors
    235 Broadway  Orangeville, Ontario L9W 2Z5
    David G Thwaites
    (519) 941-1760
    (519) 941-3688 - fax

    Respondents
    LINDA PROSH/ROBERT McQUAID
    RR #5  Orangeville, Ontario L9W 2Z2
    (519) 940-9847

    HUBER & HEERSCHE
    Barristers & Solicitors
    184 Broadway  Orangeville, Ontario L9W 1K3
    (519) 940-4500
    (519) 940-4502 - fax

    TO THE APPLICANT:

    1.  I agree with the following claims made by the
        applicant:  3 and 4.

    2.  I do not agree with the following claims made by
        the applicant:  1, 2 and 5.

    3.  (not applicable)

    4.  I am making a claim of my own.

    5.  The FAMILY HISTORY, as set out in the application,
        is correct.

    6.  The important facts that form the legal basis for
        my position in paragraph 2 is as follows:

    1.  Linda Prosh and I are the natural parents of the
        child, Kenneth McQuaid born October 16, 1996.  We
        have been active and involved parents of Kenneth.
    2.  A six month supervision Order was made on January
        19, 2000.  The terms of the supervision Order
        required that the Respondent's take certain steps to
        help deal with some potential developmental issues
        concerning Kenneth.  The respondent's have
        diligently followed through with all of these
        recommendations.  All of the professionals involved
        in Kenneth's life agree that he is making remarkable
        strides, and that the parents are committed to
        helping Kenneth in making those strides.
    3.  There is no risk of harm to the child.  The parents
        have taken all appropriate, required and many
        voluntary steps in helping Kenneth overcome some
        minor developmental delays.
    4.  All previous concerns with the cleanliness of the
        home, and the condition of the home have been
        rectified and the home is appropriate, clean and
        filled with toys for the child.
    5.  The circumstances do not warrant a further
        supervision Order to the CAS.

    --------------------------------------------------------

    ONTARIO COURT OF JUSTICE
    AT 10 LOUISA STREET, ORANGEVILLE

    Court File Number 180/99
    Form 14A: Affidavit (general) dated June 27, 2000

    Applicant
    The Children's Aid Society for the County of Dufferin
    50 Fourth Street  Unit 13  Orangeville Ontario L9W 4P1
    (519) 941-1530
    (519) 941-1525 - fax

    Wardlaw, Mullin, Carter, Thwaites & Ward
    David G Thwaites
    235 Broadway  Orangeville, ON
    (519) 941-1760 phone
    (519) 941-3688 fax

    Respondents
    Linda Prosh/Robert McQuaid
    RR #5  Orangeville, ON L9W 2Z2
    940-9847

    Huber & Heersche
    Evelyn D Huber
    184 Broadway  Orangeville, ON L9W 1K3
    (519) 940-4500 phone
    (519) 940-4502 fax


    My name is Robert McQuaid
    I live in Township of Mono, County of Dufferin
    and I swear/affirm that the following is true:

    [McQuaid Jun 27]
    1.  On January 19, 2000 a consent was executed in which
    we allowed the Children's Aid Society (CAS) to supervise
    Ken for six months.  We entered into this agreement as
    the quid pro quo in response to crown wardship
    application.  I assume that further discussion of events
    leading up to that consent is out of order.  This
    affidavit gives the facts I believe the court should
    consider in response to efforts by CAS to extend its
    supervision of Kenneth McQuaid and to force attendance
    at the Child Advocacy and Assessment Program.  We
    initially agreed to retain the services of the
    professionals currently involved in Ken's life, so as to
    have some control and direction in the services and the
    professionals involved.  It was my understanding that
    agreeing to retain all of these professionals was to be
    seen as an option instead of going through a CAAP
    assessment.  My concern with the CAAP assessment or
    similar assessment centres is that the referral comes
    from the CAS and there is a strong potential for
    prejudgment.

    [McQuaid Jun 27]
    3.  Further, after our last court attendance, Linda and
    I were advised after the Order was consented to that the
    CAS has recommended that we be placed on the Child Abuse
    Registry.  No mention of this intent was ever made
    leading upto the execution of the consent.  These
    actions by the CAS strike me as being covert and
    excessive in the circumstances.  We were having some
    difficulty dealing with Ken.  We are now seeking the
    appropriate professional intervention to address these
    issues.  Linda and I are committed to helping Ken and
    ourselves however we can.  We are not merely jumping
    through hoops, as the CAS insinuates, in order to comply
    with the Order.  We are doing what is in Ken's best
    interest and are committed to continuing to do so.  We
    have learned a considerable amount about the resources
    available to parents in our community and we are taking
    advantage of them and will continue to do so.

    [McQuaid Jun 27]
    4.  We have strictly complied with the consent.

    (a) We have taken Ken to Dr Murphy and followed his
        recommendations.

    (b) We allowed Nina Little Alcorn of the Infant-Parent
        Program to visit Ken in our home whenever she
        wished.

    (c) We have employed William Weiner who is a behavioural
        therapist to assist us in understanding Kenneth and
        responding appropriately to some of his behavioural
        concerns.

    (d) The Dufferin Association for Community Living
        refused to treat Ken initially, because his
        development was too advanced, later they did attend
        him a few times.

    (e) We have been attending a Speech Therapist who has
        been providing Ken with help in his language and
        communication.

    (f) We signed all consents requested by CAS.

    (g) We cooperated with TrishCox who has performed
        drop-by visits.

    (h) We attended child psychiatrist Dr Bakht at Peel
        Memorial Hospital monthly starting in February 2000.
        Until this motion, he never criticized our family,
        or referred us to any other treatment.

    (i) We have arranged for additional day care services
        not required by the consent, keeping him in some
        form of daycare regularly since December, 1999.

    [McQuaid Jun 27]
    4.  CAS now requests that we engage in the Child
    Advocacy and Assessment Program.  This program is an
    abuse screening program that is designed to ascertain
    whether any abuse has occurred to a child.  It is
    designed to screen and assess the parents and their
    parenting capacity.  It is akin to the SCAN program at
    Toronto Hospital for Sick Children.  The CAS was
    notified of these appointments by way of letter dated
    February 10, 2000, received in their offices on February
    18, 2000.  The CAS knew of these appointments but waited
    over three months to advise Linda or myself of these
    appointments.  When Linda was first advised of these
    appointments, she initially indicated she might be
    willing to attend.  She was led to believe that this
    facility was a treatment facility.  She was unaware
    until Will Weiner inquired into the nature of the
    program, that it was a facility intended to screen for
    abuse.  I verily believe that we need to focus on
    providing Ken with help, not trying to finger point.  I
    am advised by Evelyn Huber and believe it to be true
    that she spoke with Linda Harris of the CAAP program on
    June 27, 2000 and that Linda Harris confirmed to her
    that the question asked of them by the CAS was whether
    Linda and I are able to parent Kenneth.  Different
    professionals would see Kenneth that would meet with
    Linda or I.  The report and recommendations would be
    sent to the CAS.  There are no speech therapist or
    occupational therapists.  When Linda Harris was asked
    what the difference between what their program offers
    from the help currently being provided to my family she
    advised Evelyn Huber was that they were specifically
    geared towards a parenting capacity assessment.

    [McQuaid Jun 27]
    5.  Our family has been working very closely with Will
    Weiner since the end of November, 1999.  Mr Weiner has
    been invaluable in providing Linda and me with parenting
    insight.  Shown to me now and attached as Exhibit "A" is
    a true copy of a report written by Will Weiner, who was
    provided with the CAS material that is currently before
    the Court.  I am advised by Evelyn Huber and believe it
    to be true that she discussed the current Court
    proceedings with Will Weiner and provided him with the
    material.  This report does not support a need for a
    parenting capacity assessment.

    [McQuaid Jun 27]
    6.  A report from Debbie Launspach is attached as
    Exhibit B.  She does not agree with the dire prognosis
    attributed to her by Trish Cox.  I do not recall using
    the word "retarded" attributed to me but if such a
    remark was made by myself it certainly was not made in
    the context Trish Cox and the CAS now elect to place it
    for the purposes of this motion.  I love my son dearly
    and know him to be a bright, interesting and happy child
    as confirmed by Will Weiner.  I am advised by Evelyn
    Huber and believe it to be true that she discussed the
    current situation with Ms Launspach on Friday June 23,
    2000.  Ms Launspach advised Evelyn Huber, that had Trish
    Cox not contacted her, none of her or her staff members
    would have suspected CAS involvement.  Ms Launspach has
    been in the child care business for over 15 years and
    has considerable experience in dealing with all sorts of
    children and their families.  Debbie Launspach advised
    Evelyn Huber and I believe it to be true that she sees
    it as a positive sign that Ken is sometimes reluctant to
    come to the Day Care centre as it indicates his
    happiness at staying with his parents, which whom
    apppears to be very attached and bonded.  Ms Launspach
    has never indicated that she is concerned that Linda and
    I are not involved enough with Ken, or that we are
    unwilling to help, listen or learn.

    [McQuaid Jun 27]
    7.  Here and elsewhere, Trish Cox notes Ken repeating
    self-deprecating comments.  She omits the true fact that
    one of Ken's most common utterances in public is "Ken's
    a smart boy".  Trish Cox and Nina Little note an
    incident in which Ken fell in Kindrey Rowlands' office.
    This was not significant enough for Kindrey Rowlands to
    mention in her own report, attached to the affidavit of
    Trish Cox.

    [McQuaid Jun 27]
    8.  Nothing in Kindrey Rowland's report suggests that
    the parents are unwilling or unqualified to promote
    Ken's speech development.  Neither Will Weiner or Debbie
    Launspach indicates any concern that Linda and I are not
    committed to parenting Kenneth and providing him with
    any and all assistance possible.

    [McQuaid Jun 27]
    9.  Dr Bakht has never made the diagnoses to us reported
    by Trish Cox.  Evelyn Huber advises me and I believe it
    to be true that she has had a number of discussions with
    Dr Bakht and that when she inquired whether he had made
    a specific diagnosis of parental neglect, he denied
    that.  He indicated that it was impossible to make a
    firm diagnosis and that one of his considerations at the
    outset, before spending any time with the family, had to
    be whether developmental delays were as a result of
    parental neglect.  He advised that in the context of his
    treatment at his office and not having had more contact
    with the family in different settings than a clinic one,
    it was impossible for him to make any diagnosis as to
    whether or not there had been neglect.

    [McQuaid Jun 27]
    10.  Trish Cox misrepresents a report to Mono Council.
    One of the topics of my talk was false allegations by
    CAS.  Kid is a friendly colloquialism for child.  The
    complete verbatim transcript from the published minutes
    of Mono Council is:

      "Mr Robert McQuaid attended on Council to express his
      concerns with the actions of the Dufferin Children's
      Aid Society and to ask Council to use its influence
      with regard to the appointment of the Society's board
      of directors and its executive committee.  Mayor
      Creelman confirmed that it is County Council which
      appoints CAS board members, and that this matter would
      be brought up at the next County Council meeting by
      the Mayor and Deputy-Mayor Veenman, that they would
      check out the facts and advise Mr McQuaid of their
      findings".

    [McQuaid Jun 27]
    11.  Trish Cox criticizes me for addressing Mono
    Council, and by implication, the other political
    remedies I have and will continue to seek.  Exercising
    one's rights as a citizen is not to be condemned, and is
    not a form of child-abuse.  Since my experience in this
    action, I have been astounded at and continue to
    experience the vast sweeping powers of the CAS and the
    community members involved in the CAS.  As the CAS is
    currently involved with our family I will inform myself
    and become a more active member of the community and the
    CAS.  I strongly believe that if you feel strongly about
    something, you should follow through with action as
    Linda, Ken and I have done in response to the concerns
    raised by the CAS.  My level of commitment should
    indicate my general level of commitment to becoming
    involved and informing myself.  This characteristic is
    certainly influencing Linda any my current involvement
    level in helping Ken.

    [McQuaid Jun 27]
    12.  On November 29, 1999 CAS filed documents in this
    case moving to place the parents, Linda Prosh and me, on
    the Child Abuse Register.  Three days later, following a
    contested hearing, Judge Allen returned custody of Ken
    to us.  Notwithstanding this order, CAS followed though
    and did place us on the Child Abuse Register.  I believe
    it was inconsistent with the court's finding and
    premature in that no final determination had been made.
    Linda and I are now on the Registry.

    [McQuaid Jun 27]
    13.  The chronology of events surrounding the report to
    the Child Abuse Register and the Child Advocacy &
    Assessment Program follows:
    Jan 29, 00  Robert McQuaid applies for CAS membership
                by email a true copy of which is attached
                as Exhibit "C".
    Feb 1, 00   CAS types letter to Robert McQuaid and
                Linda Prosh reporting them to the Child
                Abuse Register a true copy of which is
                attached as Exhibit "D".
    Feb 3, 00   Robert McQuaid pays $3 in cash to Irene
                Beazley for CAS membership
    Feb 9, 00   Irene Beazley sends bylaws to Robert
                McQuaid following phone request.
    Feb 10, 00  Chedoke-McMaster sends letter to CAS
                confirming appointment dates.
    Feb 18, 00  CAS receives above letter from McMaster but
                withholds it from McQuaid and Prosh for
                over three months.
    I am concerned that my attempts to become involved with
    the CAS as a member, and my subsequently running for a
    Directorship has prompted significant personal animosity
    towards me by the CAS.

    [McQuaid Jun 27]
    14.  Shown to me now and attached hereto as Exhibit "E"
    is a true copy of the Brigance Pre-School Screen of Ken
    administered by Joyce Cook on December 20, 1999.  DACL
    refused to assist Ken because his score of 76 was above
    their development threshold of 60.

    [McQuaid Jun 27]
    15.  Shown to me now and attached as Exhibit "F" is a
    true copy of the Ages and Stages test of Ken
    administered by N K Little Alcorn on December 16, 1999.
    Ken's score was below the threshold on 3 categories,
    while his total score of 165 was just below the combined
    minimal scores of 170.  However, when I completed the
    items scored by Nina Little as "to check" with my own
    knowledge of Ken, he scored well within the normal
    overall score, above the threshold on all categories but
    personal-social.

    [McQuaid Jun 27]
    16.  I have conducted extensive research into the CAS
    Court cases and court findings in relation to this
    administrative body and believe that reform is necessary
    for a body with such sweeping powers at first instance
    that all but a few people have the financial resources
    to respond to.  Therefore, I pursued and will continue
    to pursue political remedies through the Mono Council
    appeal, and by becoming a member of the CAS, along with
    many other similarly situated parents.  At the annual
    general meeting of CAS held on June 20, 2000, the vote
    for directors was:
        Cathy Chmilnitzky  69 votes
        Marianne Breadner  67 votes
        Janice Jordan      67 votes
        John Christie      66 votes
        Lillian Brewer     17 votes
        Robert T McQuaid   16 votes

    [McQuaid Jun 27]
    17.  It is my intention to continue to exercise my
    political rights and freedoms in demanding legislative
    reform in this area.  That fact has nothing to do with
    the current situation with my family.  We are thriving.
    The professionals who know us best, being Debbie
    Launspach, Will Weiner and Dr Bakht are nothing if not
    positive about our progress, commitment and interest.

    [McQuaid Jun 27]
    18.  We have exceeded all requirements and suggestions
    made to us but that is not the point.  We have done
    everything possible to meet Ken's best interest and that
    is the point.  We are not only going through the motions
    of attending at the offices of various professionals
    that we have retained, but we have thrown ourselves
    wholeheartedly into the various treatment programs we
    have participated in:  the professionals agree.  There
    is no protection issue.

    [McQuaid Jun 27]
    19.  At this juncture Ken's best interest would not be
    served in subjecting him to yet another batter of
    professionals whose intention is to find a reason for
    some of Ken's delays and not provide constructive
    assistance in addressing some of those issues.  We are
    will beyond the finger pointing stage.

    [McQuaid Jun 27]
    20.  I make this affidavit in response to the current
    motion and application before the Court.

    /signed/ Robert McQuaid

    SWORN before me at the Town of
    Orangeville, in the County of Dufferin
    this 27th day of June, 2000

    /signed/ Evelyn Huber

    A Commissioner etc.

    ........................................................

    Exhibit A

    WILLIAM WEINER, MA
    162 BROADWAY  SUITE 5  ORANGEVILLE ONTARIO L9W 2Y8
    519-942-0566  wweiner@sympatico.ca

    Evelyn Huber
    267 Broadway
    Orangeville, Ontario L9W 1K8

    June 26, 2000

    Re:  Ken McQuaid

    Dear Ms Huber,

    [Weiner Jun 26]
    I am a child and Family Counsellor with 20 years of
    Clinical Experience and a Master of Arts Degree in
    Counselling Psychology.

    [Weiner Jun 26]
    I have been involved with the McQuaid Family since
    November 30, 1999.  We met for sessions twice a week,
    for the first few weeks, then weekly and now we meet
    every two weeks.

    [Weiner Jun 26]
    My sessions with the family have been with Ken and his
    parents.  I also observed Ken at Sandbox Tech Daycare
    and consulted with his teachers there.

    [Weiner Jun 26]
    I am very pleased to report that Ken has continued to
    make great strides in the areas of language, imaginative
    play, and behavior.  The parents have also grown in
    their ability to meet Ken's emotional, physical, and
    developmental needs ant in their understanding of how to
    work together to be good parents for Ken.

    [Weiner Jun 26]
    Ken's language now includes being chatty, laughing,
    spontaneous singing, answering yes or no to questions
    asked of him, verbally asserting himself when he wants
    something, asking funny and interesting question, and
    saying accurately fun and interesting comments in a
    conversation.  I have seen Ken's language move forward
    at an excellent rate of progress.

    [Weiner Jun 26]
    Ken's play has moved from static repetition to
    imaginative and elaborate pretend play.  Ken will
    include the activities that his parents have taken him
    on such as the park, hardware stores, fire station,
    grocery stores, Dairy Queen and other restaurants, as
    well as other everyday activities that are a fascination
    to a young child.  Ken's play has been enhanced by his
    parents' willingness to learn to play with him.  This
    has added to the fun for the whole family, highlighted
    Ken's interests and abilities for his parents and
    contributed toward stronger relationships.  Ken and his
    parents have developed a closer more intimate bond
    during the last seven months.  They obviously get so
    much enjoyment from parenting Ken.

    [Weiner Jun 26]
    Ken's behavior has also improved in the last seven
    months.  He is able to play alongside other children
    without being destructive or intrusive on the other
    children's play.  He can be trusted to go unsupervised
    to his room for something and return with the item in a
    responsible and prompt fashion.  He is less destructive
    of his toys.  Ken has moved from tantrum behavior to
    short bursts of tears and language of frustration and
    protest.  This is a significant step in that he
    demonstrates to his parents, other caregivers, and
    himself that he has grown emotionally enough to handle
    frustration without it becoming an overwhelming
    experience that requires a huge tantrum response.

    [Weiner Jun 26]
    Ken and parents face more challenges, as Ken now needs
    to learn to use the toilet rather than a diaper.  This
    will foster even more feelings of success, confidence,
    and competence.  I would like to see Ken utilize play
    mediums such as water, clay, scissors, glue, markers,
    ball play, and a tricycle to continue the progress he
    has made.  I would like to see him continue in a
    daycare/nursery school setting to encourage more
    interactive play.  Ken's parents will need to continue
    learning how to stand up to Ken, as he becomes even more
    verbally and physically demanding of his environment and
    caregivers.

    [Weiner Jun 26]
    Both parents have demonstrated to me that they are
    capable of comforting, nurturing, being good audience
    participants, being playful and being passionately and
    actively interested in their son's development and life.
    I think that Ken's parents' have learned to utilize
    their own skills and those of other people in the
    community such a Counsellors, Speech Therapists, Daycare
    Teachers, and other Parents to meet the constant
    challenges of Parenting.

    [Weiner Jun 26]
    As you know the Children's Aid Society of the County of
    Dufferin has stipulated that certain conditions be met
    by Linda Prosh and Robert McQuaid.  It is my opinion
    that they have actively met and surpassed those
    conditions.

    [Weiner Jun 26]
    Please contact me if you require further information.

    Yours truly,

    /signed/  William Weiner, MA

    ........................................................

    Exhibit B

    Sandbox Tech Child Care
    RR #8 Mono Mills
    Orangeville, Ontario L9W 3T5

    June 22, 2000

    To Whom this may Concern:

    Child's name:  Kenneth Daryl McQuaid

    [Launspach Jun 22]
    I received a phone call from Ken's Mom Linda Prosh back
    at the beginning of Feb to see if Ken could attend
    Sandbox Tech.  She told me of Ken and his hitting etc.
    He was kicked out of two child care centres.  We were in
    the middle of a move and that she would have to wait.  I
    was impressed that Mom was so honest with me.

    [Launspach Jun 22]
    March 7, 2000 was Ken's first day at Sandbox Tech Child
    Care.  When Mom left he was not upset.  Ken joined the
    other children and was introduced to the other staff
    members.  Went outside to play for about 45 min.  Ken
    was not verbal.  Came in for circle with the other
    children.  Sat but wanted to hit his head on the floor.
    He was not upset, he just wanted to do this.  We said no
    Ken and he stopped.  He sat at circle, not really
    listening or communicating with others, but he was happy
    to be at circle.  Would not cross his legs and would
    shout out off and on at circle.  When it was his turn to
    share, he came up and sat on my knee and shared himself.
    We asked him his name, age, which colour did he like
    best, what was his favourite animal, food, etc.  We
    received no answers.  Then I asked him the questions
    again and answers then for him, Ken would parrot every
    thing that I said.  The other children giggled.  So did
    Ken.  Sometimes he would stare off into space.  I
    thought that maybe Ken might be PDD, or something also
    that line.  He enjoyed playing in our class, painting,
    playing with lego, cars, pegs, etc.  He did not want to
    talk or play with the other children.  He did not want
    to play in the water or with play doh.  No at attempt
    was made by him, but remember this was his first day.
    Ken was happy when Mom came to pick him up.

    [Launspach Jun 22]
    After about a week or two, Ken would come in and greet
    us, take off his outside shoes, and put on his slippers,
    Hang up his coat and join us in the class.  He would
    play on the carpet and watch the children as he was
    playing.  He would answer questions for other children
    that were playing near him.  Once and awhile Ken would
    hit himself on his head on the floor, carpet, shake his
    head and not listen.  He would scream at times.  But for
    only a few seconds.  The other children were a little
    afraid to play with him because of these out bursts.
    Ken would at times just hit a child on the back, head,
    face, quite hard.  Then stop.  So the children were very
    careful if Ken would come around to play near them.  Ken
    is always happy to see his Mom and Dad at pick up time.
    He greets them with a smile and a hug.

    [Launspach Jun 22]
    April:  Ken is quite different.  He said goodbye to
    Mommy and Daddy.  "Have a nice Day'.  Gives kiss or hugs
    at times.  He enters to class.  The younger children say
    hi to Ken and Ken will reply to that child with a
    greeting of hi.  He is communicating more now.  He
    listens at circle most of the time, sits with his legs
    crossed and does not always parrot us.  He is using his
    own language most of the time, when he wants to talk..
    He speaks very well.  Does not hit his head or lay on
    the floor or through himself about.  He talks about his
    sharing.  He sings songs with the children.  He smiles
    and is happy.  He loves to be outside with the toys.  At
    times he still will hit a child.  But not any one child
    or for any reason that we can tell.  Our approach to
    this behaviour is KEN NO we do not hit.  It is not nice.
    Then he must give that child a hug and say that he is
    sorry.  Ken once had a time out.  We put him on the
    chair.  He did sit on the chair and was not to upset.
    But he did voice his NO.  He did not want to set on the
    chair.

    [Launspach Jun 22]
    Ken is learning more each day.  He is taking his turn to
    hand out snack and MUST say the child's name when giving
    out the snack.  Ken is a great eater.  He enjoys food.
    At times he will talk with the children about what ever
    the other children are talking about.

    [Launspach Jun 22]
    I give Ken space and let him play with anything he
    chooses in the centre for about 15 minutes before I ask
    him to do something.  He then can focus on what I am
    asking of him.  This also gives him time to listen to
    the other children and lots of time for him to approach
    them to play.  At times a children will go over to talk
    or play with Ken and Ken does not often attempt to
    participate.  If he does it is for a very short time.

    [Launspach Jun 22]
    Ken is a bright little man.  He knows his colours and
    shapes.  He is quite good with numbers.  Ken is learning
    some sounds of the letters and some of the actions for
    them.  He knows the alphabet.  We want to work with Ken
    on toilet training him.  He does not want us to change
    him, or even place him on the toilet, let alone in the
    wash room.  He is very upset.  Asks for Mom or Dad to
    change him.  We can not change him.  Ken will go out of
    control if we even attempt to do this.  We did attempt
    this once and wow what a time.  We were not successful
    at all.  Then after being in the washroom I had to be
    very firm with him to get Ken to wash his hands.  But
    once he washed his hands, he really enjoyed it.

    [Launspach Jun 22]
    June:  Ken had come in twice not wanting to come to
    Sandbox Tech.  He was sort of upset one afternoon when
    Mom brought him in.  So Mom took him with her.  About 35
    mins later Dad came in with Ken.  Ken was happy that he
    came back.  I feel that Robert did the right thing.
    About a week later Ken's Dad brought him in.  Ken really
    did not want to go to Sandbox Tech.  Dad had to take him
    from the car and give him to me.  Ken was not a happy
    camper.  He wanted to go home.  This was not like Ken at
    all.  He always enjoyed his visits with us.  Dad left
    and Ken was fine after about 3 mins.

    [Launspach Jun 22]
    My staff and I can talk well with Ken and he can carry
    on a conversation and be very verbal with us.  I find
    Ken a very bright child.  Ken is a loveable little guy
    with so much to give.  He listens and follows directions
    very well.  I feel that in time Ken will communicate
    with the other children and will enjoy playing at the
    water and play doh centres, with the other children.  I
    feel that Ken has come a long way in a very short period
    of time.  Ken's parents are concerned with Ken and want
    his needs met.  Ken's parents are interested in having
    Ken join us for 3 full days starting this July.  I will
    be able to help them out at that time.

    [Launspach Jun 22]
    If you have any questions or concerns I would be more
    then happy to meet with you.

    Sincerely

    /signed/ Deborah Launspach

    1-519-902-0462 8-5
    1-519-941-6926 after 7pm

    ........................................................

    Exhibit C   email of January 29, 2000 RTMQ to CAS.

    January 29, 2000

    The Children's Aid Society of the County of Dufferin
    50 Fourth Avenue Unit 13
    Orangeville Ontario L9W 4P1
    dcafs@headwaters.com

    Dear Sirs/Madams:

    I wish to become a member of the Children's Aid Society
    of the County of Dufferin.  As I understand from your
    notice in the Orangeville Banner, persons over age 18
    years residing in Dufferin County are eligible on
    payment of the three dollar annual fee.

    Please indicate by return E-mail where I can pay the
    three dollars.


    Robert T McQuaid
    RR 5  Orangeville Ontario L9W 2Z2
    phone:   519-942-0565

    ........................................................

    Exhibit D   Letter from CAS to Prosh on Child Abuse
    Registry

    (Not getting any response to the foregoing email, I
    visited the office of Children's Aid on February 3,
    2000, with the three dollar membership fee.  I handed it
    personally to Irene Beazley.  Two letters arrived in our
    mail on February 7, 2000, one addressed to Robert
    McQuaid, the other to Linda Prosh, but otherwise
    identical.  Both letters were dated February 1, 2000,
    but stamped through the Children's Aid postage meter on
    February 3, 2000.  This note is not part of the court
    file.  - RTMQ)

    CAS letterhead

    February 1, 2000

    Ms Linda Prosh
    RR 5  Orangeville Ontario L9W 2Z2

    Dear Ms Prosh:

    RE:  REPORT TO CHILD ABUSE REGISTER

    This letter is to advise you that your name is being
    forwarded to the Ministry of Community and Social
    Services Central Abuse Register.  Our investigation
    supports the initial referral information received in
    November 1999, alleging that you had put your child at
    risk of physical harm as defined in section 37.2(B),
    that your son demonstrated developmental concerns as
    defined in section 37.2(H) and your son has suffered
    emotional harm as defined in section 37.2(F) of the
    Child and Family Services Act, Revised Statutes of
    Ontario, 1990, Chapter 11 as amended.

    The Central Abuse Register is a file for the Province of
    Ontario and persons who have been found to have abused a
    child can find their names placed on this list.  When
    your name has been received by the register you will be
    notified by letter and have the opportunity to appeal
    the decision and request that your name be withdrawn.

    Thank You

    /signed/ Kim James  Intake Worker
    /signed/ Kimberley Evans  Program Manager of Child
    Protection Services

    ........................................................

    Exhibit E  photocopy of Brigance Pre-School Screen by
               Joyce Cook, Dec 20, 1999, shown above.

    ........................................................

    Exhibit F  photocopy of Ages and Stages test by Nina
               Little Alcorn, December 16, 1999, shown
               above.

    --------------------------------------------------------

    (The following letter from Dr Bakht was introduced into
    evidence through an affidavit not in my possession.
    -RTMQ)

    WILLIAM OSLER HEALTH CENTRE

    Etobicoke Hospital Campus
    Brampton Memorial Hospital Campus
    Georgetown Hospital Campus
    www.williamoslerhc.on.ca

    Brampton Memorial Hospital Campus
    20 Lynch Street
    Brampton, Ontario L6W 2Z8
    Telephone 905.451.1710
    Facsimile 905.451.2690

    27 June, 2000

    Psychiatric Assessment

    Re:  MCQUAID, Kenneth
    DOB 16th October 1996

    [Bakht Jun 27]
    I have first seen Kenneth with both his parents for
    psychiatric assessment on February 16th 2000.  He was
    referred by Dr Murphy, pediatrician.

    [Bakht Jun 27]
    Kenneth was a 3 year old, male child who lived with his
    parents.  He had been attending a local day care in
    Orangeville.

    [Bakht Jun 27]
    Kenneth's father stated that Kenneth was "kidnapped" by
    Children's Aid Society on 16th November and was placed
    in a foster home until December 2nd 1999.  Father was
    extremely hostile throughout the interview against the
    Children's Aid Society for "kidnapping" his child.  At
    times he became quite agitated, however, Kenneth's
    mother was more rational and cooperative.  She
    elaborated that Children's Aid Society apprehended
    Kenneth due to what they had noted, as there was a
    safety hazard, emotional hazard and neglect for Kenneth
    at home.  During the time when Kenneth was in a foster
    home, parents had supervised visit.  Eventually he was
    released to his parents' care on supervision order and
    asked to fulfill certain criteria laid out by the
    Children's Aid Society.  Mother described such condition
    include psychiatric consultation for Kenneth, assessment
    by behavior interventionist, participating infant/parent
    program as well as attending Dufferin area community
    living program.  Dr Murphy examined him and completed a
    baseline laboratory blood workup.

    [Bakht Jun 27]
    On further questioning, Kenneth's father stated that
    Kenneth goes into "rampage" particularly when he is
    tired and bored.  He describes the rampage as throwing
    things, spitting, biting others and becoming
    hyperactive.  Mother added that even at the day care
    Centre he was physically quite aggressive to other kids.
    Both parents added that Kenneth could be quite
    disruptive and active at times if his demands were not
    fulfilled and other times he was fairly calm and quiet.

    [Bakht Jun 27]
    Parents stated that Kenneth was generally a happy child.
    He ate and slept well.  He did not cry for any reason
    and he was pretty contented but at times he showed mood
    swings when he was tired and bored.  Mother stated that
    Kenneth sucked his thumb at times.

    [Bakht Jun 27]
    Kenneth was not on any medication.  His physical health
    was good and had no allergy and had no serious illnesses
    in the past.

    [Bakht Jun 27]
    Kenneth's parents stated that they had been living
    together for eight years and got married in 1996 just
    before Kenneth was born.  Father was a 57 years old man
    from the United States and spoke little about his early
    life.  He studied math at MIT but did not finish his
    course.  He worked as a computer programmer and reported
    that he was "resting" at home for the last five years.
    His wife described him as a loner and had poor social
    contact.  Kenneth's mother was a 45 years old woman.
    She said that she was a high achiever in school and
    stood within the first 20 in the high school diploma
    throughout Quebec.  She worked as a computer graphics
    designer but lately had been working as a freelance
    graphic designer for the video and worked part time at
    Wal-Mart.  She described it was a "crappy job".
    Kenneth's mother stated that they had poor social
    contact and honestly stated that they were quite
    "disorganized" and had a lack of resources although
    stated that "financially" they were "well off".

    [Bakht Jun 27]
    Mother stated that pregnancy and delivery with Kenneth
    was a normal one.  He was a chubby child and started to
    crawl at 13 months and walked at 17 months.  His speech
    was delayed.  He has been receiving speech therapy.

    [Bakht Jun 27]
    On mental status examination, Kenneth, an average built,
    Caucasian, male, preschool child presented in casual
    dress.  His personal hygiene and grooming was fairly
    normal.  He had a small bluish spot on his forehead.  He
    was quite active during the interview and did not sit
    quietly in the chair.  At times he wanted to open the
    door and other times he walked around.  While seated he
    was rocking his head back and forth a few times.  The
    parents stated that he also banged his head quite often
    resulting that he had bruises on the forehead.  He
    maintained good eye contact.  His speech was fairly
    distinct.  His affect was pleasant.  Mood was euthymic.
    His thought form and thought content appeared to be
    normal.  Cognitively, he appeared to be average for his
    age as he was able to identify the name of a few things
    such as watch, pen and appeared to be quite well aware
    of what was going on in the interview room.

    [Bakht Jun 27]
    The initial impression was this three years old, male
    child had recently been taken under the custody of
    Children's Aid Society due to possible neglect by the
    parents as claimed by Children's Aid Society although
    parents were very bitter and hostile towards Children's
    Aid Society with their handling of Kenneth.  Father was
    showing extreme frustration and anger towards them
    although mother appeared to be quite cooperative and
    open to accept any help for their son.  There were no
    positive family history of mental illnesses or behavior
    problem and the pregnancy and birth of Kenneth appeared
    to be fairly normal although he had some developmental
    delay including speech and social skills and showed self
    stimulating behavior of possible emotional neglect as
    well as somehow being hyperactive and restless during
    the interview which may be features of Attention Deficit
    Hyperactivity Disorder which needed to be further
    explored.  Many professionals were involved directed by
    the Children's Aid Society for identifying Kenneth and
    family's need for help as well as his parents were
    cooperative under the supervision of Children's Aid
    Society.

    [Bakht Jun 27]
    Following the initial assessment I have asked the
    parents and Day Care Worker to complete the Vanderbilt
    Behavior checklist and arranged regular follow up on a
    monthly basis.  The bahavior checklist and follow up
    visit with me did not reveal any evidence of Attention
    Deficit Hyperactivity Disorder.

    [Bakht Jun 27]
    Parents remained very compliant and receptive to each
    follow up visit.  They were also very honest with
    expressing their feelings towards Children's Aid
    Society's involvement.  Parents claimed that they
    participated in all programs arranged by Children's Aid
    Society for them.  Kenneth's hyperactivity, aggression
    and demanding behavior greatly decreased.  His social
    skill and speech continued to improve with parental
    positive involvement increased social contact, speech
    therapy and professional intervention.

    [Bakht Jun 27]
    My current impression is that Kenneth is delayed in some
    areas of development such a language and social skill
    which may be the result of unintentional neglect by
    parent due to their lack of ability to identify
    emotional need for their child or they were "socially
    isolated" and "disorganized".  However, following
    Children's Aid Society's intervention and multi agencies
    involvement Kenneth has been showing continuing
    improvement in areas of development including emotional,
    social and language skill.

    [Bakht Jun 27]
    He is happy and contented living with parents.  They are
    very involved and committed to improve Kenneth's growth,
    development and gaining parental skills.

    [Bakht Jun 27]
    Children's Aid Society worker Ms Trish Cox has arranged
    an assessment for McQuaid family by child advocacy
    program at Chedoke McMaster hospital.  Although I have
    supported this assessment as a compliment Kenneth's case
    and discussed with Ms Cox, Kenneth's parents and their
    lawyer Evelyn D Huber, I am not sure whether assessment
    recommendation would be any different than what Kenneth
    and his family is receiving now.  Kenneth's parents are
    refusing this assessment fearing that the outcome of the
    assessment may be used against them that will prolong
    Children's Aid Society involvement with the family.
    However, for the well being of Kenneth I recommend as
    follow:

    1)  Kenneth should continue to receive speech therapy to
        improve his language skills.
    2)  A behavior interventionist should remain involved
        with Kenneth to reinforce positive and acceptable
        behavior.
    3)  He should continue to be exposed in stimulating
        environment to improve social skills.
    4)  Parents should continue to receive parental
        counseling through the local family-counseling
        agency for improving parental skills.
    5)  Kenneth should be periodically seen by a
        developmental pediatrician for assessing his growth
        and development.
    6)  A child psychiatrist should regularly monitor his
        emotional growth and provide support and
        encouragement to the parent for maintaining their
        cooperation with various professionals helping
        Kenneth.

    [Bakht Jun 27]
    This multidisciplinary team approach would greatly help
    to improve Kenneth's physical and emotional growth.

    [Bakht Jun 27]
    I hope this information is helpful.

    /signed/

    Dr M Bakht
    MBBS, DCH, Dip Ch Psych(C) FRCP(C)
    Child & Adolescent Psychiatrist

    MB/ns

    --------------------------------------------------------

    Ontario Court of Justice
    at 10 Louisa Street, Orangeville Ontario L9W 3P9

    Court File Number 180/99
    Form 14A:  Affidavit (General) dated July 4, 2000

    Applicant
    The Children's Aid Society of the County of Dufferin
    50 Fourth Avenue, Unit 13
    Orangeville, Ontario L9W 4P1 Canada
    Phone:  519-941-1530
    Fax:  519-941-1525

    Wardlaw, Mullin, Carter, Thwaites and Ward
    Attention:  David Thwaites
    235 Broadway  Orangeville, Ontario L9W 2Z5  Canada
    Phone:  519-941-1760
    Fax:  519-941-3688
    eMail:  dthwaites@wardlaw.on.ca

    Respondents
    Robert McQuaid
    RR #5  Orangeville Ontario L9W 2Z2 Canada
    Phone 940-9847
    Linda Prosh
    RR #5  Orangeville Ontario L9W 2Z2 Canada
    Phone 940-9847

    Evelyn Huber
    Huber & Hersche
    Barristers and Solicitors
    Orangeville Ontario L9W 1K3 Canada
    Phone 519-940-4502

    My name is Patricia Louise Cox
    I work in Orangeville, Ontario
    and I swear/affirm that the following is true:

    [Cox July 4]
    1.  The Children's Aid Society of Dufferin County has
    been involved with Mr McQuaid, Ms Prosh and their son
    Kenneth for approximately 10 months.  As a result of our
    intervention and recommendations in the original
    supervision order, Ken has made strides.  Had the
    Society not identified concerns related to Ken's social,
    emotional and speech development, and determined the
    need for professional assistance for Kenneth and his
    parents, we wonder what Ken would look like today.  As
    it is, as identified in the reports of Nina Little
    Alcorn and Kindry Rowlands, Ken still presents with
    developmental delays.  We note that Dr Bakht, child and
    adolescent psychiatrist recommends the following:

    i)    Kenneth should continue to receive speech therapy
          to improve his language skills.

    ii)   A behaviour interventionist should remain involved
          with Kenneth to reinforce positive and acceptable
          behaviour.

    iii)  He should continue to be exposed in stimulating
          environment to improve social skills.

    iv)   Parents should continue to receive parental
          conseling through the local family-counseling
          agency for improving parental skills.

    v)    Kenneth should be periodically seen by a
          developmental pediatrician for assessing his
          growth and development.

    vi)   A child psychiatrist should regularly monitor his
          emotional growth and provide support and
          encouragement to the parent for maintaining their
          cooperation with various professionals helping
          Kenneth.

          This multidisciplinary team approach would greatly
          help to improve Kenneth's physical and emotional
          growth.

    Given the fact that Kenneth continues to present with
    delays and along with Dr Bakht recommendations and the
    positive role that the Society has had in assisting Ken
    to move forward to date, the Society feels the need to
    maintain a presence that will monitor and provide
    positive direction.

    [Cox July 4]
    2.  I make this statement with no improper intent.

    /signed/ Trish Cox

    Sworn/Affirmed before me at DUFFERIN
    in ONTARIO CANADA
    on July 4, 2000

    /signed/
    ORRAL MAE PATRICIA MORRISON
    A Commissioner etc, Province of Ontario,
    for the Children's Aid Society.
    Expires April 5, 2002

    --------------------------------------------------------

    My affidavit of June 27, 2000 got the job done, but was
    frustrating to read.  Evelyn Huber cleaned up my version
    for the court.  In expurgating comments such as the
    "Trojan Horse" as insufficiently dignified for the
    court, Evelyn Huber translated many of my comments into
    ungrammatical language, and a few platitudes.  This is
    the linguistic counterpart of going to court in grubby
    clothes.  The version I submitted to Evelyn Huber is
    below.  In my version, sub-paragraph numbers match the
    numbers of the document referenced.

    The statement about court procedures is not strictly
    correct, since courts will allow live testimony with
    cross-examination, but only after the family has been
    nearly destroyed by pre-trial maneuvering.  In practice,
    it is rare, even in crown-wardship cases.

    My paragraph 5.4 is a statistical proof of bias by CAS.
    I would like to hear from any reader with better
    knowledge of statistics who can devise a better test.

    In paragraph 9, deleted entirely in court, I show the
    deleterious effect of CAS surveillance.  Building a
    network to support Ken in homeschooling was impossible
    as long as CAS investigators alienated everyone we made
    contact with.


    [McQuaid Jun]
    1.  On January 19, 2000 a consent was executed in which
    we allowed the Children's Aid Society (CAS) to supervise
    Ken for six months.  We entered into this agreement as
    the quid pro quo to avoid crown wardship.  I assume that
    further discussion of events leading up to that consent
    is out of order.  This affidavit gives the facts I
    believe the court should consider in response to efforts
    by CAS to extend its supervision of Kenneth McQuaid and
    to force attendance at the Child Advocacy and Assessment
    Program.

    [McQuaid Jun]
    2.  We have strictly complied with the consent.
    (a) We have taken Ken to Dr Murphy and followed his
        recommendations.
    (b) We allowed Nina Little Alcorn of the Infant-Parent
        Program to visit Ken in our home whenever she
        wished.  We have employed William Weiner to play
        with Ken about 20 times.  The Dufferin Association
        for Community Living refused to treat Ken
        initially, because his development was too
        advanced, later they did attend him a few times.
    (c) We signed all consents requested by CAS.
    (d) We allowed Trish Cox to do drop-by visits.
    (e) We attended child psychiatrist Dr Bakht at Peel
        Memorial Hospital monthly starting in February
        2000.  Until this motion, he never criticized our
        family, or referred us to any other treatment.
    We have arranged for additional day care services not
    required by the consent, keeping him in some form of
    daycare regularly since December, 1999.

    [McQuaid Jun]
    3.  CAS now requests that we engage in the Child
    Advocacy and Assessment Program.  The program is
    unnecessary, because we have already complied with all
    terms of the consent.  CAS scheduled this program to
    extend beyond the supervision period, then concealed it
    from us for over three months, evidencing bad faith.
    Trish Cox misrepresented the assessment to Linda Prosh,
    making her initially willing to participate.  But when
    we found the true nature of the program, we declined.

    [McQuaid Jun]
    4.  The procedures of this court do not allow for
    cross-examination or discovery, making it impossible to
    compel a witness to answer a question, and permitting
    CAS to engage in deception by omission.  The affidavit
    of Trish Cox in support of extension of supervision
    contains many instances.

    [McQuaid Jun]
    4.i.  William Weiner's actual statement appears as
    Exhibit G.  It is not in accord with the paraphrase by
    Trish Cox.

    [McQuaid Jun]
    4.ii.  We find it impractical to get a statement from
    Karen Bowers, because the events described by Trish Cox
    are too far in the past for accurate recollection.

    [McQuaid Jun]
    4.iv.  A letter from Debbie Launspach is attached as
    Exhibit A.  She does not agree with the dire prognosis
    attributed to her by Trish Cox.  I do not recall the
    "retarded" remark attributed to me, but in informal
    circumstances I frequently use hyperbole.  CAS does not
    understand hyperbole or chooses to misrepresent it.

    [McQuaid Jun]
    4.v.  Here and elsewhere, Trish Cox notes Ken repeating
    self-deprecating comments.  She omits the true fact that
    one of Ken's most common utterances in public is "Ken's
    a smart boy".  Trish Cox and Nina Little note an
    incident in which Ken fell in Kindrey Rowland's office.
    This was not significant enough for Kindrey Rowland to
    mention in her own report, attached to the affidavit of
    Trish Cox.  Trish Cox is grasping for trifles.

    [McQuaid Jun]
    5.vi.  Nothing in Kindrey Rowland's report suggests that
    the parents are unwilling or unqualified to promote
    Ken's speech development.

    [McQuaid Jun]
    5.vii.  Trish Cox misrepresents a report to Mono
    Council.  One of the topics of my talk was false
    allegations by CAS.  Kid is a friendly colloquialism for
    child.  The complete verbatim transcript from the
    published minutes of Mono Council is:

      Mr Robert McQuaid attended on Council to express his
      concerns with the actions of the Dufferin Children's
      Aid Society and to ask Council to use its influence
      with regard to the appointment of the Society's board
      of directors and its executive committee.  Mayor
      Creelman confirmed that it is County Council which
      appoints CAS board members, and that this matter
      would be brought up at the next County Council
      meeting by the Mayor and Deputy-Mayor Veenman, that
      they would check out the facts and advise Mr McQuaid
      of their findings.

    [McQuaid Jun]
    4.viii.  We have treated gift offers from CAS as a
    Trojan Horse.

    [McQuaid Jun]
    4.ix.  Dr Bakht has never made the diagnoses to us
    reported by Trish Cox.  The correct opinion of Dr Bakht
    is in Exhibit H.  I stand by any of my statements inside
    or outside this proceeding that removal of children from
    intact families that have caused them no harm is an
    outrage.

    [McQuaid Jun]
    4.xii.  Trish Cox criticizes me for addressing Mono
    Council, and by implication, the other political
    remedies I have sought.  Exercising one's rights as a
    citizen is not a disease, and is not a form of
    child-abuse.

    [McQuaid Jun]
    5.  On November 29, 1999 CAS filed documents in this
    case moving to place the parents, Linda Prosh and me, on
    the Child Abuse Register.  Three days later, following a
    contested hearing, Judge Allen returned custody of Ken
    to his parents.  Notwithstanding this order, CAS
    followed though and did place us on the Child Abuse
    Register.  While this action is not under jurisdiction
    of this court under the CFSA, it is inconsistent with
    the court's opinion.

    [McQuaid Jun]
    5.1.  As justification for the Child Abuse Register
    report CAS attached a document titled "Risk Assessment"
    by Kim Evans.  This form is junk science both in its
    design and use.

    [McQuaid Jun]
    5.2.  test design:  Most of the questions are vague.
    The scientifically interesting question of abuse of the
    caregiver is offensive judicially because it harms one
    person for the wrongdoing of another, or in social
    worker terms, deprives a child of his parents on account
    of faults of his grandparents.  Question F3 on social
    supports treats every farm family as abusers.  Question
    A1 rates any unrestricted parental care as abuse.

    [McQuaid Jun]
    5.3.  test use:  In giving a bad score of 3 for the
    physical violence question, F1, Kim Evans supports it
    with the quote:  "There is no physical violence".  At
    the time of the investigation, a crown wardship motion
    was pending, which we resisted with all available means,
    leading to demerits on question I2 for failure to
    cooperate with the intervention.

    [McQuaid Jun]
    5.4.  This technical paragraph subjects the work of Kim
    Evans to the same technique used to expose scientific
    fakery.  Her numerical evaluations are:
        Rating 0  Excellent  9 times
        Rating 1  Good       none
        Rating 2  Medium     none
        Rating 3  Bad        14 times
        Rating 4  Very Bad   8 times
        Rating 9  Unknown    3 times
    Discard the nines, Unknown, and assume unrealistically
    that the five remaining ratings are equally likely.  A
    standard statistical test gives chi squared of 24 with
    four degrees of freedom.  In an unbiased evaluation, the
    likelihood of a result as bad as Kim Evans' is .00008,
    less than one in ten thousand.  This far exceeds any
    standard hurdles such as 95% confidence or beyond a
    reasonable doubt.  The assumption of normal distribution
    is more realistic, but must produce an even worse
    likelihood, since Kim Evans distribution is U shaped
    rather than bell shaped.  For this analysis I relied on
    "Introduction to Mathematical Statistics" by Paul G Hoel
    and "A Handbook of Mathematical Functions" by Milton
    Abramowitz and Irene A Stegun.

    [McQuaid Jun]
    5.5.  In non-technical language, Kim Evans has taken the
    faults that we all share and exaggerated each to the
    extreme.  That should have been apparent to any reader
    even without statistics.

    [McQuaid Jun]
    5.6.  The chronology of events surrounding the report to
    the Child Abuse Register and the Child Advocacy &
    Assessment Program follows:
    Nov 30, 99  Child Abuse Review Team of CAS recommends
                reporting McQuaid and Prosh to Child Abuse
                Register.
    Dec  2, 99  Judge Allen returns custody of Ken
                to parents.
    Jan 29, 00  Robert McQuaid applies for CAS membership
                by email (Exhibit B)
    Feb 1, 00   CAS types letter to Robert McQuaid and
                Linda Prosh reporting them to the Child
                Abuse Register (Exhibit C)
    Feb 3, 00   Robert McQuaid pays $3 in cash to Irene
                Beazley for CAS membership
    Feb 3, 00   Postage meter imprint on above letter.
    Feb 9, 00   Irene Beazley sends bylaws to Robert
                McQuaid following phone request.  (Exhibit
                D)
    Feb 10, 00  Chedoke-McMaster sends letter to CAS
                confirming appointment dates.
    Feb 18, 00  CAS receives above letter from McMaster but
                withholds it from McQuaid and Prosh for
                over three months.
    The timing suggests that the Child Abuse Register report
    and the Child Advocacy & Assessment Program may be a
    form of retaliation or intimidation for the membership
    application.

    [McQuaid Jun]
    6.  Exhibit E attached is the Brigance Pre-School Screen
    of Ken administered by Joyce Cook on December 20, 1999.
    DACL refused to assist Ken because his score of 76 was
    above their development threshold of 60.  Exhibit F is
    the Ages and Stages test of Ken administered by N K
    Little Alcorn on December 16, 1999.  Ken's score was
    below the threshold on 3 categories, while his total
    score of 165 was just below the combined minimal scores
    of 170.  However, when I completed the items scored by
    Nina Little as "to check" with my own knowledge of Ken,
    he scored well within the normal overall score, above
    the threshold on all categories but personal-social.
    Ken suffers from no more developmental problems than the
    normal variation between individuals, most notably late
    talking.

    [McQuaid Jun]
    7.  Examination of the law and the attitude of CAS
    workers convinced me that serious reform was necessary.
    Therefore, I pursued political remedies, through the
    Mono Council appeal, and by becoming a member of the
    CAS, along with many other similarly situated parents.
    At the annual general meeting of CAS held on June 20,
    2000, the vote for directors was:
        Cathy Chmilnitzky  69 votes
        Marianne Breadner  67 votes
        Janice Jordan      67 votes
        John Christie      66 votes
        Lillian Brewer     17 votes
        Robert T McQuaid   16 votes
    CAS brought this motion to court the following day.

    [McQuaid Jun]
    8.  The CFSA is vague about many terms such as abuse or
    neglect.  In other areas suffering from vague laws a
    body of cases becomes a guide both for future judicial
    decisions and for laymen to know their rights and
    obligations.  CAS cases are secret, preventing laymen
    from learning the law either directly at the courthouse,
    or indirectly through accounts of legal journalists.
    There is only a tiny public window in the form of
    published appellate decisions.  Disregarding Young
    Offenders and Adoptions, the law librarian at York
    University was able to show me 96 published cases
    dealing with the CFSA.  None of them define issues in
    dispute in this case, such as when it is proper to put
    locks on doors, and of course, none deal with the silly
    factor of eye contact, mentioned six times by CAS in
    this case.  As long as almost all CAS cases are secret,
    it is simply impossible for a layman to be in compliance
    with the law.  This court ought to recognize the same
    principle that parents lobbying CAS have made
    politically - the best interest of the child is served
    by keeping his parents.

    [McQuaid Jun]
    9.  The requirement to execute disclosure agreements
    with CAS has been harmful to Ken.  CAS routinely
    approaches persons involved in Ken's care with
    misrepresentations requiring us to terminate
    relationships with them.  The first letter of Dr Murphy,
    attached as Exhibit D to the affidavit of Kim James
    filed November 19, 1999, falsely reports that Ken has no
    toys.  I took Dr Murphy a clear plastic bag filled with
    200 liters of toys in the house at the time of the raid,
    though I could have filled three such bags.  On all
    visits Ken's mood has changed from cheerful to taciturn
    immediately on meeting Dr Murphy.  Linda Prosh, acting
    without the requirement of CAS took Ken to the Community
    First Centre, and later to the Women's Centre, but can
    now use neither because of the hostility resulting from
    contact with CAS.  Friends at Hand-in-Hand daycare is
    unavailable to us for similar reasons.  We also
    encountered a child psychologist who refused to help us
    because she will not get involved in litigation.

    [McQuaid Jun]
    10.  By moving to extend supervision, under
    circumstances where it can be extended yet again, CAS
    apparently intends to extend the supervision as long as
    possible.  When Ken reaches college age, I will be 72
    years old, making it likely that his higher education
    will be financed from savings rather than income.  The
    unbounded drain of twenty thousand dollars a year for
    legal costs unrelated to his care and development could
    imperil his education.

    [McQuaid Jun]
    11.  During the original raid, CAS promised to leave our
    child in our home if we removed a crib from his room,
    but apprehended him anyway after we complied.  In the
    courthouse negotiation for the consent of November 22,
    1999, they promised to return Ken at the end of a two
    week observation period, but reneged by filing 36 pages
    of motion documents to retain custody.  At the
    negotiation for the consent of January 19, 2000, they
    promised that the supervision would end six months from
    the apprehension on May 16, 2000 - time served was the
    operative phrase.  Trish Cox in her own handwriting put
    May 16 as the expiry date on many of our consent forms.
    Still, CAS later insisted on July 19, 2000, a date that
    they now ask to extend.  We have scrupulously complied
    with our consent agreements, while they have defied
    their agreements, both formal and informal, and acted
    contrary to the opinion of the court on the Child Abuse
    Register.  We are requesting that the court for once
    compel CAS to respect their own agreement.

    Exhibit A   Letter by Debbie Launspach
    Exhibit B   application for membership
    Exhibit C   Letter regarding Child Abuse Register
    Exhibit D   Transmittal letter for bylaws
    Exhibit E   Brigance Pre-School Screen
    Exhibit F   Ages and Stages test
    Exhibit G   William Weiner letter
    Exhibit H   Dr Bakht letter

    --------------------------------------------------------

    July 10, 2000

    John Baird
    Ministry of Community and Social Services
    Office of the Minister
    Hepburn Block  Queens Park  Toronto ON M7A 1E9

    Dear Mr Baird:

    This letter is in response to your letter of February 9,
    2000 in which you declined to answer any questions about
    a matter before the courts.  To help you find your own
    records, I enclose the first page of the email that I
    sent to David Tilson on November 26, 1999 while our
    child was still in custody, and your response.

    Our son was seized by Children's Aid on November 16,
    1999.  On July 5, 2000 judge Allen dismissed the entire
    action, ending the court case.  The damage has been
    severe because we have been compelled to incur legal
    expenses unrelated to our son's care of about $15,000,
    Can you now answer the questions raised in my original
    letter to David Tilson?


    /signed/
    Robert T McQuaid
    RR 5
    Orangeville Ontario L9W 2Z2
    phone:  519-942-0565
    email:  robert.mcquaid@hurontario.net

    --------------------------------------------------------

    July 10, 2000

    Dufferin Child and Family Services
    50 Fourth Avenue  Unit 13
    Orangeville Ontario L9W 4P1

    citation:  Ontario Court of Justice
               at 10 Louisa Street, Orangeville Ontario
               court file number 180/99
               Applicant:    Children's Aid Society of
                             Dufferin
               Respondents:  Robert T McQuaid
                             Linda Prosh

    Dear Sirs:

    Under a recent court action against our family, cited
    above, you received consent from us to exchange
    information with various persons regarding our family.
    On July 5, 2000 Judge Allen dismissed the entire court
    action.

    Please take notice that any authority from us under
    those consents is now canceled.

    /signed/  Robert T McQuaid
    /signed/  Linda Prosh
    RR 5
    Orangeville Ontario L9W 2Z2

    --------------------------------------------------------
   
    (Eight letters were sent, each to just one of the
    addressees shown below.  -RTMQ)

    July 10, 2000

    Deborah Launspach
    Sandbox Tech Child Care
    RR #8 Mono Mills
    Orangeville, Ontario L9W 3T5

    Ronald G Murphy
    Medical Arts Bldg
    15 Elizabeth Street Suite M 16
    Orangeville Ontario L9W 5X5

    Dr Diann Superina-Bell
    Toronto Western Division
    399 Bathurst St
    Toronto Ontario M5T 2S8

    Friends at Hand-in-Hand Day Care
    70 First Street
    Orangeville Ontario L9W 2E5

    Kindrey Rowland
    15 Elizabeth Street, Suite M-15
    Orangeville, Ontario L9W 3Z3

    Dr M Bakht
    WILLIAM OSLER HEALTH CENTRE
    Brampton Memorial Hospital Campus
    20 Lynch Street
    Brampton, Ontario L6W 2Z8

    Dufferin Association for Community Living
    14 Stewart Court Suite 100
    Orangeville Ontario L9W 3Z9

    Women's Resource Centre
    c/o Orangeville Alliance Church
    232 Broadway
    Orangeville Ontario

    Dear Mr/Dr etc:

    Children's Aid started a legal action against our family
    in November 1999.  Under that action we were required to
    authorize you to disclose information about us and our
    son Kenneth McQuaid to Dufferin Child and Family
    Services incorporated as the Children's Aid Society of
    the County of Dufferin.

    On July 5, 2000, judge Allen dismissed the entire action
    unconditionally.  Consequently, any authority you have
    from me or my wife Linda Prosh to exchange information
    with Children's Aid is now canceled.

    Robert T McQuaid
    RR 5
    Orangeville Ontario L9W 2Z2
    phone:  519-942-0565
    email:  robert.mcquaid@hurontario.net

    --------------------------------------------------------
  
    CAS letterhead

    July 12, 2000

    Mr R McQuaid and Ms L Prosh
    RR 5
    Orangeville Ontario L9W 2Z2

    Dear Mr McQuaid and Ms Prosh

    Enclosed please find copies to letters sent the
    providers who had been involved with you and Kenneth.

    Sincerely,

    /signed/

    Trish Cox, B Sc N, RN
    Child Protection and Family Services Worker

    ........................................................

    (There were eight letters enclosed, identical except
    for the addressees, all shown in the single copy below.
    -RTMQ)

    CAS letterhead

    July 12, 2000

    Ms Deborah Launspach
    Sandbox Tech Child Care
    RR #8  Mono Mills
    Orangeville Ontario L9W 3T5

    Ms Mary Lynne Richardson
    Women's Resource Centre
    Alliance Church
    232 Broadway Avenue
    Orangeville Ontario

    Nina Little Alcorn
    Parent Infant Program
    Dufferin Child and Family Services
    50 Fourth Avenue, Unit 13
    Orangeville Ontario L9W 4P1
 
    Kindrey Rowland
    Speech-Language Pathologist
    Orangeville Speech and Language Clinic
    15 Elizabeth St  Suite M-15
    Orangeville Ontario L9W 3X3

    Wil Weiner
    162 Broadway  Unit #5
    Orangeville Ontario L9W 1K3

    Dr R Murphy
    Paediatrician
    15 Elizabeth St
    Orangeville Ontario L9W 3X3

    Dr D Superina-Bell
    Paediatric Consultant
    Child Health Unit
    Toronto Western Hospital
    University Health Network
    399 Bathurst St  3rd Floor
    Toronto Ontario M5T 2F8
    fax:  1-416-603-5180

    Dr M Bakht
    Child and Adolescent Psychiatrist
    William Osler Health Centre
    Brampton Memorial Hospital Campus
    20 Lynch Street
    Brampton Ontario L6W 2Z8
    fax:  905-451-2690

    Re:  Kenneth McQuaid
         dob October 16, 1996

    Dear Mr/Ms etc:

    Please be advised that Kenneth McQuaid and his family
    are no longer involved with the Children's Aid Society
    under a Supervision Order.

    In the future, if there are any further concerns for the
    physical, sexual or emotional well being of Kenneth or
    concerns related to neglect or a pattern of neglect,
    that may lead to any of the latter, please contact
    Dufferin Child and Family Services at 941-1530

    Sincerely,

    /signed/
    Trish Cox, BScN, RN
    Child Protection and Family Services Worker

    /signed/
    Debbie Taylor, BA, BSW
    Senior Program Manager
    
    cc:  Mr R McQuaid
         Ms L Prosh

    --------------------------------------------------------

    John Baird letterhead

    July 28, 2000

    Mr Robert T McQuaid
    RR 5
    Orangeville Ontario L9W 2Z2

    Dear Mr McQuaid:

    Thank you for your letter of July 10, 2000 concerning
    the children's aid society.

    I have noted your concerns and appreciate the time you
    have taken to write about this matter.  I have asked Mr
    Vince Tedesco, who is the Regional Director of our
    Central West Region, to review your letter and provide
    you with a more detailed response.  You can expect a
    response within the next month.

    Once again, thank you for writing.

    Sincerely,

    /signed/
    John Baird, MPP
    Minister

    c:  Mr Vince Tedesco

    --------------------------------------------------------

    Ontario
    Ministry of Community and Social Services
    
    CENTRAL WEST REGION
    1140 Burnhamthorpe Rd W Suite 212
    Mississauga ON L5C 4E9

    Tel (905) 897-3112
    Fax (905) 896-0206

    August 10, 2000

    Dear Mr McQuaid:

    Thank you for your letter of July 10, 2000 regarding
    your concerns about the actions of the Children's Aid
    Society in Dufferin County and the impact of these
    actions on your family.  The Honourable John Baird,
    Minister of Community and Social Services asked that I
    look into your concerns and to provide a more detailed
    response to you.

    We acknowledge that the apprehension of a child is
    extremely distressing to families.  As you may know, it
    is the legislated mandate of Children's Aid Societies,
    such as Dufferin Child and Family Services to determine
    if a child is in need of protection.  It is the
    expectation of the Ministry of Community and Social
    Services that the societies give due consideration to
    reports and other relevant information that are received
    by them in carrying out their mandate.  If the situation
    is severe and a child is in urgent need of protection, a
    Children's Aid Society may proceed to apprehend the
    child.  Placement of the child outside the home may be
    for a short period of time during which the child's
    family has an opportunity to engage in activities that
    increase their capacity to care for the child.  The
    child also may be given certain opportunities that
    enhance this or her growth and development.  Not all
    apprehensions result in a child becoming a Crown Ward
    without access to the child by a parent.

    If the parents have made attempts to deal with the
    problems in the family through counselling or other
    activities, and the child is no longer considered to be
    in need of protection, the child may be returned to his
    or her home.  If the child is returned to the care of
    the parents, the judge may grant a supervision order for
    a period of time to ensure that the gains made continue.
    Once this is no longer required, the judge may terminate
    the supervision order and the case is closed.  I am told
    that the judge dismissed the request of Dufferin Child
    and Family Services for an extension of the supervision
    order on July 5, 2000 as, in his opinion, it was no
    longer required.

    If you continue to have concerns with the actions of the
    agency, there are procedures that Children's Aid
    Societies are required to have in place to hear
    complaints.  Under the Child and Family Services Act,
    each Children's Aid Society (CAS) must have a formal
    complaint procedure.  Individuals who are not satisfied
    with the services provided to them by the CAS may have
    their situation reviewed.  The first step is to discuss
    the matter with the social worker who was involved with
    you, then the Supervisor, and if the matter remains
    unresolved, with the Executive Director.  The fourth
    step is to request a hearing by the Board of Directors.
    If the situation remains unsettled at that point, then
    you may request a review by the Ministry of Community
    and Social Services under Section 68(3) of the Child and
    Family Services Act.

    Should you have questions reagarding the mandate of
    children's aid societies or the review process, please
    contact Kaye Rempel, Program Supervisor at 519-886-4222,
    ext 220.

    Thank you for writing and sharing your concerns with the
    Ministry of Community and Social Services.

    Sincerely,

    /signed/
    Vince Tedesco
    Regional Director

    --------------------------------------------------------

    Epilogue

    Examination of this and other cases suggests that all
    CAS affidavits are the work of a single composer working
    from notes supplied by caseworkers.  Nina Little Alcorn
    wrote her own memos candidly, all other caseworkers
    spoke through a composer skilled in journalistic smear
    without specific facts constituting libel.  In this
    case, and every other one I have seen, CAS asserts that
    any child in its custody is showing signs of
    improvement, taking full credit.  Disparaging his
    abilities at the start furthers the effect.  Here they
    took credit for getting Ken interested in toilet
    training, though that was not done until eight months
    later, and Ken's speech improvements, though rapid
    improvement in his speech began a month before the raid,
    for example, the first correct use of a verb with an
    object.

    We got onto the Child Abuse Register March 28, 2000, but
    new legislation, enacted by the Provincial Parliament in
    1999 and proclaimed into law March 31, 2000, abolished
    it.  Its replacement is a Canada-wide computer system
    containg a full verbatim record of all Children's Aid
    cases.

    The remaining legacies of Ken's abduction are the
    permanent Children's Aid record, a large number of other
    parents met through the internet but excluded from the
    court record, and the ongoing effort, which I am now
    calling Dufferin VOCA, to get CAS to change its policies
    politically.  In this effort, I am surprised by the
    silence of voices that ought to defend the family, such
    as the clergy.

    In my previous career I have been a party to every kind
    of lawsuit from squabbles over rent cheques to a hundred
    million dollar tort action against my company.  This
    litigation is for even larger stakes than a
    multi-million dollar suit, yet is conducted with less
    respect for the rights of the parties than a
    small-claims case.

    Here are some facts withheld during the litigation for
    strategic reasons.  During the year preceding the raid,
    Linda worked part-time outside the home, and I took care
    of Ken during the day.  This accounts for Linda's
    ignorance about Ken's care during the raid.  My story
    never got to court.  The construction of heating vents
    in our home allows Ken and me to talk to each other
    while he is in his room and I am in my office, so he was
    not isolated even when locked in.  In other cases where
    CAS finds bugs in a home, they ostentatiously report
    them.  We had none.

    A vital element to prevailing over CAS was the hardening
    of Linda's attitude.  While she was dead-set against a
    court hearing in January, by June she was willing to do
    whatever it took to get rid of CAS, including newspaper
    publicity.

    --------------------------------------------------------

    Name Index and Glossary


    Craig Abrams
        Constable, Shelburne OPP.  PC Abrams is his title.

    John B Allen
        Judge of the Ontario Court of Justice, who decided
        all three contested hearings in this case.  None of
        the websites critical of judges have any reports on
        him.

    John Baird
        Minister of Community and Social Services for the
        Province of Ontario.  His letterhead contains, in
        French and English:

        Ministry of Community and Social Services
        Office of the Minister
        Hepburn Block  Queens Park  Toronto ON M7A 1E9
        (416)325-5226

    M Bakht
        Child Psychiatrist, Peel Memorial Hospital,
        Brampton Ontario.

    Orangeville Banner
        A newspaper published twice a week in Orangeville.

    Irene Beazley
        Senior Administrative Assistant, CAS.

    Diane Benoit
        Psychiatrist, Hospital for Sick Children, Toronto.
        Many parents assessed by her have lost their
        children.

    Tina Berryman
        The employee of Molly Maid whose report initiated
        this action.

    Karen Bowers
        Friends at Hand-in-Hand Day Care (qv).

    Marianne Breadner
        Director, CAS.

    Lillian Brewer
        Resident of Orangeville, grandmother whose son had
        his children removed by CAS, a case that has taken
        up of weeks of trial time at the Orangeville
        courthouse.  She became a candidate for CAS
        director.

    G D (Greg) Brodhagen, badge 7184, Sergeant
        Shelburne Detachment,
        Ontario Provincial Police
        phone 519-925-3838
        One of two police officers conducting the raid

    caregiver
        A politically correct word for anyone looking after
        a child.  Use of this term avers that a salaried
        worker has the same value as a parent.

    CAS letterhead (for external correspondence)

                DUFFERIN Child and Family Services
        (Logo)  (Incorporated as The Children's Aid Society
                of the County of Dufferin)

        Gary Putman BA MSW  Executive Director
        Tel 519-941-1530
        Fax 519-941-1525
        50 Fourth Ave Unit 13
        Orangeville Ontario L9W 4P1
        www.headwaters.com/dcafs/
        dcafs@headwaters.com
        Child Protective Service
        Children's Mental Heath Service
        Developmental Support Service
        Dufferin Children's Fund

    CAS memohead (for internal correspondence)

                DUFFERIN Child and Family Services
        (Logo)  (Incorporated as The Children's Aid Society
                of the County of Dufferin)

    Chedoke McMaster Hospital
        Hospital offering Child Advocacy & Assessment
        Program.  The first syllable is pronounced shed.
        Their website gives a department called the Canadian
        Centre for Studies of Children at Risk, disclosing
        their bias.  Their website is:
        http://www-fhs.mcmaster.ca/cscr/

    Child Abuse Register
        A statutory list of child abusers in Ontario.  There
        is no provision for judicial review before entry
        onto the reigster.

    Child Abuse Review Team (CART)
        A committee required by statute in each Children's
        Aid Society, to decide on entry to the Child Abuse
        Register.

    Child Advocacy and Assessment Program (CAAP)
        A program at Chedoke-McMaster Hospital to assess
        parents of children at risk.

    Child and Family Services Act (CFSA)
        Legislation giving powers to CAS.

    Cathy Chmilnitzky
        Director, CAS.

    John Christie
        Director and Vice President, CAS.

    Orangeville Citizen
        A newspaper published once a week in Orangeville,
        circulation 11,000.  Web page:  www.citizen.on.ca

    Katherine Clauser (or Catherine)
        13 Hawthorne Road, Orangeville Ontario, phone
        519-942-2912.  Foster mother of Ken McQuaid in
        November 1999

    Community First
        A drop-in children's centre.

    Joyce Cook
        Employee of Dufferin Association for Community
        Living.  She tested Ken and found him too advanced
        for treatment.

    Catharine Cote
        Founder of VOCA, a citizen's group opposing abuse by
        Children's Aid Societies throughout Ontario

    Patricia Louise (Trish) Cox
        The second CAS caseworker for Kenneth McQuaid.

    John Creelman
        Mayor of Mono Township, Dufferin County Ontario.

    crown wardship
        The term in Ontario law for termination of parental
        rights.

    Jill Cutter
        Client of Women's Resource Centre.

    Jim Dickson, badge 6627
        Shelburne Detachment,
        Ontario Provincial Police
        phone 519-925-3838
        One of two police officers conducting the raid.

    Dufferin Association for Community Living (DACL)
        14 Stewart Court Suite 100
        Orangeville Ontario L9W 3Z9
        phone:  519-941-8971
        fax:    519-941-9121

    Dufferin County
        A county in Ontario containing Orangeville and Mono
        Township, 279 square km, population 45,657 by 1996
        census.

    echolalia
        Involuntary repetition of words or phrases just
        spoken by others

    euthymic
        Mood in the normal range, not depressed or elevated.

    Kimberley Evans
        Program Manager, CAS.  Supervisor of all intake
        workers in Dufferin CAS.

    Dawn Franks
        Intake worker, CAS.

    FRCP
        Fellow of the Royal College of Physicians.

    Friends at Hand-in-Hand
        70 First Street  Orangeville Ontario L9W 2E5
        phone:  519-942-3337
        Daycare centre in Orangeville attended by Kenneth
        for three weeks.

    Gwen Funston
        Justice of the Peace who signed warrant.

    Linda Harris
        Program Assistant, Child Advocacy & Assessment
        Program.

    Evelyn D Huber
        Huber & Heersche
        184 Broadway Orangeville ON L9W 1K3
        (519)940-4500 phone
        (519)940-4502 fax
        Lawyer for Robert McQuaid and Linda Prosh.  CAS
        never got her address correct, nor the spelling of
        Heersche.

    Trevor Hunt
        paediatrician, Alliston Ontario

    ib
        Initials of typist Irene Beazley

    Kimberly James
        Intake worker
        Dufferin Child and Family Services
        50 Fourth Ave Unit 13
        Orangeville Ontario L9W 4P1
        phone 519-941-1530 ext 238
        E-mail:  dcafs@headwaters.com
        The above was copied from her business card during
        the raid.

    Janice Jordan
        Director, CAS

    Kelsey's
        A restaurant in Orangeville.  The typical meal,
        beverage and tip is $15 Canadian per person.

    Deborah (Debbie) Launspach
        Sandbox Tech Child Care (qv)

    Nina K Little Alcorn
        CAS employee, Parent-Infant Program.  Little is her
        primary surname.

    Jennifer Long-Moore
        The CAS annual report shows no employee with this
        name, but does show Jennifer Moore and Jennifer
        Longmore, both intake workers.

    Patti Lowe
        Daughter-in-law of Lillian Brewer.

    Dorothy McLachlan
        Program Manager, Clinical Services, CAS, supervisor
        of Nina Little Alcorn.

    Kenneth Daryl McQuaid
        born Oct 16, 1996, child whose abduction started
        this case.  CAS misspells his name Darryl.

    Robert T McQuaid
        father of child abducted in this case
        RR 5  Orangeville Ontario L9W 2Z2
        phone:  519-942-0565
        email:  rtmq@hurontario.net

    Molly-Maid
        A franchised cleaning-service company.  See:
        http://www.mollymaid.com/canada.html
     
    Mono
        Township in Dufferin County Ontario, 279 square km,
        population 6552 by census of 1996.  Rhymes with
        Sonny Bono.

    Jennifer Moore
        CAS intake worker, but see Jennifer Long-Moore.

    Ms
        Title for a woman, used in this text only in
        verbatim transcripts, and for women who specifically
        request to be so identified.

    Ronald G Murphy
        Medical Arts Bldg
        15 Elizabeth Street Suite M 16
        Orangeville Ontario L9W 5X5
        (519) 942-3501
        Pediatrician for Ken engaged by CAS.

    Orangeville
        A town in Dufferin County Ontario, 70 km northwest
        of Toronto, population 21,498 by 1996 census.

    Parent-Infant Program(me)
        Name for the activities of Nina Little Alcorn.

    parenting capacity assessment
        A recent fad in child care originated at the
        Hospital for Sick Children in Toronto.  See Diane
        Benoit.

    Louise (Lou) Potter CPC
        Covenant Community Church,
        3 Zina Street, Orangeville
        941-2707, pastor

    Eric Prosh
        Brother of Linda Prosh, uncle of Kenneth McQuaid.

    Linda Prosh
        mother of child abducted in this case
        RR 5  Orangeville Ontario L9W 2Z2
        phone 519-940-9847

    Gary Putman
        Executive Director, CAS.  CAS is organized under the
        same law as any non-profit corporation, with members
        electing a board of directors, and the directors
        electing the management:  president, secretary,
        treasurer.  There is a statutory office called
        "local director" for Children's Aid Societies only
        that must be occupied by a senior social worker, and
        exercises a number of unique powers.  Executive
        Director is a pretentious term for local director.

    Mary Lynn Richardson
        Client of Women's Resource Centre and member of the
        Board of Directors of CAS.

    Lee Rivoire
        Employee of Friends at Hand-in-Hand daycare.

    Stephen G Ross
        Tottenham Medical Centre, Tottenham Ontario.
        Physician for Kenneth McQuaid for three years prior
        to the raid.

    Kindrey Rowland
        15 Elizabeth Street  Suite M-15
        Orangeville Ontario L9W 3Z3
        Phone/Fax 519-941-1314
        Speech Therapist.  I spell her name correctly,
        but most documents in this case incorrectly call
        her Rowlands.

    Sandbox Tech Child Care
        RR #8 Mono Mills, Orangeville Ontario L9W 3T5.

    Paulette Smith
        Owner of Orangeville Molly-Maid franchise.

    Toronto Sun
        A daily newspaper, circulation 235,000.

    Debbie Taylor
        Senior Program Manager, CAS.  She supervises all
        caseworkers.

    Vince Tedesco
        Regional Director, Central West Region of the
        Ministry of Community and Social Services

    David G Thwaites
        lawyer for Children's Aid
        Wardlaw, Mullin, Carter, Thwaites and Ward
        His resume from his website appears below:

        PRACTICE:  In Orangeville since 1981, partner since
        1991

        EXPERIENCE:  Mr.  Thwaites' practice is as a
        litigation lawyer providing counsel in the areas of
        insurance law, employment law, Church discipline,
        family law and criminal law.  He has provided
        counsel to numerous Church and para-Church
        organizations and to individuals in the Christian
        marketplace.  He is counsel to the Children's Aid
        Society of the County of Dufferin.  He has lectured
        at numerous seminars sponsored by the Law Society of
        Upper Canada, The Canadian Council of Christian
        Charities and the Canadian Bar Association and has
        contributed articles to the Church and the Law
        Update regularly on topics including Church
        Liability, Employment Law and Human Rights, as well
        as articles on Sexual Abuse and Liability Insurance
        for the Law Society and the Canadian Bar Association
        of Ontario.  He is a member of Council for the
        Canadian Bar Association of Ontario, the Charity and
        Not-for-Profit Law Section of the Canadian Bar
        Association and the Christian Legal Fellowship.

        EDUCATION:  LL.B., University of Western Ontario,
        1979

        Call to Bar, 1981

    David Tilson
        MPP, the elected representative of Dufferin County
        in the Ontario Provincial Parliament.

    Mark Van Horne
        President, CAS.

    Alice Veenman
        Deputy-Mayor of Mono Township.

    VOCA
        See Catherine Cote.

    Carol Wale
        Clerk of Court, Ontario Court of Justice, 10 Louisa
        Street, Orangeville Ontario.

    Wardlaw, Mullin, Carter, Thwaites & Ward
        The following profile of the law firm (and Thwaites
        qv) came from the firm website at
        http://www.wardlaw.on.ca/ as of June, 2000.

        Firm Profile

        With a history dating back to 1896, Wardlaw, Mullin,
        Carter, Thwaites & Ward is a full service law firm
        located in Orangeville on the northwest perimeter of
        Toronto, Ontario, Canada.

        As the largest law firm in the region, the firm
        consists of five lawyers serviced by experienced
        staff.  The staff and lawyers ensure that the firm
        is able to provide full legal services for our
        clients.

        The firm is divided into the solicitor's practice
        with an emphasis on charities and not-for-profit
        organizations as well as corporate-commercial, real
        estate, estate law, intellectual property, and the
        litigation practice with its emphasis upon civil,
        family, employment and criminal litigation.  Both
        the solicitors and barristers practice
        administrative and municipal law as well.

        The firm is committed to being pro-active in working
        with clients to develop immediate and long term
        strategic plans to avoid legal problems before they
        occur.  This is accomplished through an effective
        Legal Risk Management approach to the practice of
        law.

    William Weiner
        Child and Family Counsellor
        162 Broadway  Suite 5  Orangeville Ontario L9W 2Y8
        519-942-0566  wweiner@sympatico.ca

    Women's Resource Centre
        c/o Orangeville Alliance Church, 232 Broadway,
        Orangeville Ontario

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