Notices to Counsel

Notice to Counsel regarding Schedule P Releases for Represented Claimants

November 13, 2013

A Schedule P Release is a legal document that Section 11.02 of the Settlement Agreement requires all Non-Resident Claimants, who wish to proceed in the Independent Assessment Process (IAP), to sign. Non-Resident Claimants who wish to resolve their IRS abuse claims in the IAP are required to sign a Schedule P Release so that, with the exception of their IAP claim, they too are “deemed to have released the Defendants for all claims arising from their IRS attendance or experience” Schedule D, Item 3 (a)(i) (page 7).

The Settlement Agreement at Section 11.02(1) states that “The Approval Orders will order and declare that Non-resident Claimants on being accepted into the IAP, must execute a Release in the form set out in Schedule “P” of this Agreement. To date, Canada and the Secretariat have agreed to put this into place by requiring a signed Schedule P immediately following admission to the IAP, before the claim can move to Case Management.

Given the pressing need to move claims through to hearing in a timely manner, Canada and the Secretariat have worked together to develop a process that allows represented files currently on hold for Schedule P to move to resolution.

Please be advised that for current and future represented Schedule P claims, the claim will no longer be put on hold pending production of a signed Schedule P. Instead, the claim will move forward to document collection and scheduling and the signed Schedule P Release can be provided any time prior to hearing or on the day of the hearing.

Counsel is advised that if a signed Schedule P release is not provided prior to the commencement of proceedings at the hearing, the postponement policy will be in effect, including implications on legal fees. Counsel will be reminded throughout the document collection process of the need to file a signed Schedule P at or before hearing.

As before, you can submit a signed copy of the Schedule P Release by fax to (604) 666-7068 or by email to The original signed copy of the Release must also be mailed to: IAP Secretariat, PO Box 1575, Stn “B”, Ottawa ON, K1P 0A9.

For questions please email

November 13, 2013