This letter enumerates some of the irregularities inside the Ontario College of Pharmacists and the attempt of Ms. Angela Bates to cover up the wrongdoings inside the Organization.
To better explain the irregularities, I have attached a link that includes the index referred to in this letter.
Click here for the Appendix.
December 20, 2021
Ms. Angela Bates.
Director, Conduct VIA EMAIL
482 Huron Street
Toronto, ON M5R 2R4
CC: Ms. Karen Jones
Dear Ms. Angela Bates:
RE: Response to your letter Dated December 15, 2021.
Thank you for responding to my email dated December 8, 2021 (p. 062). I am responding to your letter dated December 15, 2021. I attached a copy of your letter for your reference (pp 001-002). I have extracted some excerpts of the letter to discuss the matter objectively.
Letter from Ms. Angela Bates Dated December 15, 2021 (p. 001):
First, I have reviewed the above-noted correspondence. I am also aware of the efforts you are making to connect with College staff on LinkedIn. In particular, I am aware of the comments you have made about Ms. Manji, who is investigating your practice at the appointment of the Registrar.
Ms. Manji is a conscientious and capable investigator who has many years of experience. She will continue to conduct your investigation,
My email dated December 3, 2021 (p. 069) was addressed to Ms. Shelina Manji in response to her email dated November 30, 2021 (p. 070). I have included an excerpt of her email.
An email thread between Ms. Shelina Manji Dated December 3, 2021 (pp 069-072)
I am writing in relation to your email to Lance Miller dated October 19, 2021, indicating that while Pharmasave Cadence Pharmacy is closed, inventory remains at the premises. Further to sections 141 and 157(2) of the Drug and Pharmacies Regulation Act, the College will be attending the premises where Pharmasave Cadence Pharmacy was located to remove all remaining patient records and drugs from the premises.
If you would like the patient records and drugs that will be removed by the College to be taken to another pharmacy, please submit a completed closing statement by December 6, 2021. If the College does not receive a closing statement, any items removed from the former Pharmasave Cadence Pharmacy will be maintained at the College.
In this email, Ms. Shelina Manji is acting on behalf of Mr. Lance Miller from Pharmacy Applications. This matter is not related to her scope as an investigator. Since April of this year, I have included correspondence with Mr. Lance Miller to put things in context. Similarly, you have communicated this matter in your letter.
Letter from Ms. Angela Bates Dated December 15, 2021 (p. 002):
Third, Ms. Manji advised you some time ago that there were drugs and patient records at Pharmasave Cadence Pharmacy. She had indicated that the College would be removing these drugs and records as the Pharmacy was closed. Ms. Manji also told you that if you wanted the drugs and records moved to another pharmacy, you would need to provide a closing statement to the College by December 6, 2021. You did not provide any closing statement.
As a result, the College has retrieved the drugs and patient records that were at the Cadence Pharmacy and they are being held in safekeeping by the College. When the College is satisfied that the records are not required for the investigation we will advise you and offer you the option of either having the inventory transferred to another pharmacy or sent to you. You will need to provide a closing statement for either option.
Since April 13, 2021, I have been communicating with Mr. Lance Miller regarding the assets of Cadence Pharmacy.
April 15, 2021, I have sent an email to Pharmacy Applications regarding the situation in Cadence Pharmacy (p. 003).
April 29, 2021, Mr. Lance Miller relayed a short excerpt of his correspondence with Trevor Hinds (p. 005).
Consequently, Mr. Miller decided to close the Cadence Pharmacy despite my expression of intent to reopen the pharmacy (pp 005-007). I have secured Cadence Pharmacy's name by ensuring that the business license is amended (p. 004).
Mr. Lance Miller told me over the phone that I will need to apply for New Accreditation for the new location, which is not consistent with the regulation that the pharmacy can change the address.
On the email thread between Mr. Trevor Hinds, Mr. Lance Miller, and me dated May 26, 2021. Multiple times, I attempted to have access to the prescriptions and files. However, Mr. Trevor Hinds refused, and Mr. Lance Miller did not invoke the regulations. I have broken down the correspondence into dates to make the information clearer.
May 3, 2021, I sent an email to set up the relocation of assets of Cadence Pharmacy (p. 011), which Mr. Trevor Hinds refused.
May 12, 2021, I sent a follow-up email to secure the assets of the Pharmacy (p. 010)
May 13, 2021, Mr. Trevor Hinds refused to provide access to the files, inventory, and other pharmacy assets. (p. 009)
May 14, 2021, I have sent out an email to document the refusal of Mr. Trevor Hinds. (p. 008)
August 31, 2021, In an email, addressed to Dr. Tina Chanchlani regarding the ownership of Cadence Health Centre (p. 016). In this email, I was trying to verify the ownership of Cadence Health Centre as the business address of Dr. Tina Chanchlani is registered at 200 Spadina Avenue. October 17, 2018, Dr. Tina Chanchlani sent an email to all doctors and administrators of Cadence Health Centre. In this email, she is giving instructions on how the clinic should operate.
Similarly, I was inquiring about the business relationship of Mr. Trevor Hinds from British Columbia and Dr. Tina Chanchlani, who completed her training in British Columbia (pp 016-025).
Ms. Shelina Manji and Ms. Kattie Wonnell were cc'd on this email (pp 016-025). Included in this email are the general assets of Cadence Pharmacy (p. 019)
September 27, 2021, I sent an email to Ms. Shelina Manji to conduct a Pharmacy Audit at 290 Shuter Street, where the Narcotic Inventory of Cadence Pharmacy is stored (pp 039-041). Narcotics are missing and unaccounted for. Ms. Shelina Manji did not act on this concern.
September 30, 2021, Ms. Shelina Manji was cc'd regarding the missing narcotics and regular prescription inventory in Shuter St. Pharmacy, where Cadence Pharmacy narcotics were stored (pp 026-038). The above investigator did not address this concern despite the seriousness of the situation as it is a possible narcotic diversion.
October 19, 2021, Asking for the closing statement of Cadence Pharmacy. I responded in his email that Mr. Trevor Hinds did not respond to any request to access the assets of the Pharmacy (pp 043-044).
October 22, 2021, Mr. Lance Miller sent an email asking to provide a general list of the assets of Cadence Pharmacy (pp 045-046). The list of general assets was on the email thread dated August 31, 2021, where Ms. Shelina Manji was CC'd (p. 019)
November 10, 2021, I responded to the email sent by Ms. Shelina Manji dated November 3, 2021. In my email, I have mentioned that Mr. Trevor Hinds has no ownership of the assets of Cadence Pharmacy (pp 047-048)
November 30, 2021, Ms. Shelina Manji sent an email regarding the physical assets and closing statements of Cadence Pharmacy (pp 071-072).
December 2, 2021, I responded to the email inquiring on what capacity is Ms. Shelina Manji communicating on the matters of closing statements of Cadence Pharmacy as this matter falls under Pharmacy Applications Department headed by Mr. Lance Miller (p. 072).
I reached out multiple times to Mr. Lance Miller, and he did not provide any assistance. The correspondence between Mr. Miller and Mr. Hinds was kept confidential.
December 3, 2021, Ms. Shelina Manji sent an email quoting DPRA section 14 (pp 065-066).
On December 2, 2021 email, regarding Ms. Shelina Manji's capacity to act on behalf of Mr. Miller, which I call out as irregular action from the college. I have been asking for assistance from Mr. Lance Miller since April 13, 2021.
In this email, I inquired if there is a New Application for Pharmacy Accreditation at 200 Spadina Avenue; hence Ms. Manji and Mr. Miller were urging me to submit my closing statement. Mr. Miller and Ms. Manji did not respond to this inquiry.
I did my due diligence, and I have communicated with Mr. Lance Miller since April 13, 2021. Mr. Miller did not assist back then. The communications between him and Mr. Trevor Hinds were kept confidential. Despite the apparent violation of DPRA by Mr. Trevor Hinds.
In a follow-up email dated December 3, 2021 (p. 064), I enumerated my inquiries to the Ontario College of Pharmacists again. For clarity, I have put the email excerpt in this letter.
Email dated December 3, 2021 (p. 064)
For Transparency purposes, why was the correspondence between Mr. Lance Miller and Mr. Trevor Hinds kept confidential?
If It is a matter of pharmacy assets that I owned. Is there any arrangement that Mr. Miller made that should not be on the record?
Why was this matter passed on to Ms. Shelina Manji?
If this is not a matter of investigation?
Why is Mr. Trevor Hinds enjoying the protection of the College?
Despite the allegation of Data Breach in Cadence Health Centre.
Why is Ms. Shelina Manji turning a blind eye to the breaking in of the pharmacy and the Narcotic inventory discrepancy of Shuter St Pharmacy?
Despite glaring evidence and thorough documentation.
Why did the ICRC panel rush the decision about my fitness to practice?
The decision made was not even based on the structured clinical interview.
It took three weeks to provide me with a copy of the report.
Where is the Transparency and Integrity that the College should uphold?
Ms. Shelina Manji should inhibit herself regarding my cases. She outrightly told me that in the initial process of ICRC, I would not need to be represented by a lawyer. She provided the wrong information so that I would not get legal protection. The hasty decision of ICRC created an impact and put concern on my license to practice.
It is the second time that a pharmacy on 200 Spadina closed down due to a malicious shakedown of Mr. Trevor Hinds. Mr. Lance Miller seems not to be concerned about these Irregularities. The demand of the College is questionable as it entails moving the assets of the pharmacy to be stored in the college, which is not stipulated in college regulation.
I have attached a screenshot of the pharmacies that Mr. Trevor Hinds closed down (p. 163).
These are valid concerns that until now are not addressed. I anticipate clarifications on your end as Director of Conduct of the Ontario College of Pharmacists. I have asked that Ms. Shelina Manji inhibit in my case as clearly, she cannot deliver a credible and transparent investigation. Not addressing the concern will not make it go away.
Letter from Angela Bates Dated December 15, 2021 (p. 001):
I would like you to communicate only with myself (Angela Bates) during the investigation.
Keeping the communication confidential is the opposite of transparency.
Letter from Angela Bates Dated December 15, 2021 (p. 001):
The expectation of the College is that, while Ms. Manji does her job, she will not be subject to harassment from you. I am concerned that your comments about Ms. Manji, particularly on LinkedIn, where you have called for her resignation, and in emails where you question her honesty and integrity, are both unwarranted and abusive. I appreciate that it is difficult to be the subject of an investigation, but as a regulated health professional, the College's expectation is that you will conduct yourself in an ethical and professional manner while the is taking place.
I have done my due diligence, waited patiently, went through different channels. Until now, none of my inquiries have been addressed. The College is free to review my emails and communication with Ms. Shelina Manji and other officials of the College. All of my concerns are valid and supported by documentation. The core values of OCP are Accountability, Integrity, and Transparency. None of the emails are intimidating.
As a public official, you have to be open to criticism. The allegations of wrongdoings against the investigators are not baseless. Evidence was provided to support the allegations.
If the investigator fails to provide a transparent process, this investigator should not serve as a college official and investigate cases. Suppose there is a question on the investigator's interest, and the interest is not for the safety and welfare of the public. In that case, this investigator should be subjected to investigation and relieved from their duties.
When the College made the concerns on my file public, it made the issue a public problem. I should be able to defend and protect myself publicly.
Letter from Angela Bates Dated December 15, 2021 (pp 001-002):
I would appreciate your taking down all posts on LinkedIn relating to Ms. Manji by no later than December 20, 2021, and that you stop making demeaning and negative comments about her or any other staff at the College on LinkedIn or other social media platforms. If you fail to remove all such posts by December 20, 2021, we will file a complaint with LinkedIn as we believe that your posts may violate their terms of service.
I have not violated any terms. I have expressed valid concerns that your leadership has not addressed until now. You are free to address those concerns on the LinkedIn platform of OCP. Reporting my posts and not addressing the allegations will not make them disappear. Instead of finding ways to silence my concerns, The College should focus on answering my inquiries.
Letter from Angela Bates Dated December 15, 2021 (pp 001-002):
You will have an opportunity to make a fulsome written submission in response to the investigation when it is completed. Any concerns you have about the process can be brought to the attention of the Inquiries, Complaints and Reports Committee ("ICRC") in your written submission.
If the investigator I expressed my concerns about remains the investigator of my case, it puts a question on the Credibility and Integrity of the investigation process. OCP should have initiated an investigation on the officials involved.
Letter from Angela Bates Dated December 15, 2021 (pp 001-002):
Second, I am requesting that you send any communications regarding the investigation into your practice to me (Angela Bates) only. While Ms. Manji will be completing the investigation into your practice, we prefer that you not communicate with her directly because of the tone and content of your prior communications relating to Ms. Manji.
This request is irregular. I cannot intimidate an investigator, but keeping the communication confidential makes this investigation not transparent.
December 8, 2021, I sent an email to you regarding my case. I have requested that the concerns on my profile be removed as the evidence used by Mr. Trevor Hinds to launch the complaint is fraudulent (p. 062). You have not addressed this issue. According to you, the investigation has not been concluded; why did the college make the concerns on my practice public if the investigator is not even confident with the facts of the allegations.
Letter from Angela Bates Dated December 15, 2021 (p. 002):
Also, as you know, Karen Jones is acting for the College in your Fitness to Practise matter, and any communications you have about those proceedings should be sent to her alone. No one at the College other than Ms. Jones and I will be responding to your emails or correspondence.
If this case is not irregular, my case should be handled by the lawyers of OCP. How can OCP objectively prosecute and investigate an issue if the body does not follow its standard process?
December 17, 2021, I received an email from Ms. Karen Jones (p.103). In her email, she mentioned that I didn't have the courtesy to send a copy of my letter dated December 15, 2021. I have included an excerpt of her email.
Email from Karen Jones Dated December 17, 2021 (p. 103):
I understand you have sent an email to a large number of people regarding your Fitness to Practise proceeding but didn't have the courtesy to send it to me, although I am the person who is dealing with your health matter on behalf of the OCP.
If you have any questions or concerns about your Fitness to Practise matter, please let me know. I am the only person who is dealing with it, so it is of no assistance to you to send out broadcast emails or other communications.
Since November 11, 2021, I have been communicating with Ms. Karen Jones from Paliare Roland Barristers and with Ms. Jennifer Dolling from OCP. (pp 049-054) I have sent emails and inquiries on November 11 (pp 051-052), November 12 (pp 049-051), November 15 (pp 059-060), November 16 (pp 056-058), November 17 (p. 055), December 6 (pp 082-089) and December 7, 2021 (pp 096-102 ). None of my inquiries were addressed or answered.
Similar concerns were raised to Ms. Jennifer Dolling on December 4, 2021 (pp 073-076), but in her response, she redirected my concern to Ms. Karen Jones (p. 076)
I have been patiently waiting for the College and Ms. Karen Jones to answer my inquiries. Instead of providing a response, she is more concerned that other OCP officials can see the documentation. If the College can address these allegations and there are no cover-ups, regardless of whether the document is made public or not, it should not be a concern as one of the core values of OCP is Transparency.
The College retained the investigator with a questionable interest in my case and retained a counsel outside OCP.
The only guarantee that you have offered is:
Ms. Manji is a conscientious and capable investigator who has many years of experience.
Integrity and Credibility should not be measured by years of experience. If this is the case, the College should not investigate pharmacists with years of experience.
I have adequately attached my emails and documentation to this letter for your reference. None of it contains intimidating or harassing messages, all concerns that I have raised are valid. Again, Ms. Shelina Manji should inhibit in my case.
I attached the last email dated December 15, 2021 (pp 104-162) for your reference.
The purpose of CC'ing other OCP officials is to keep the investigation transparent and free from corruption. In my post to LinkedIn, My inquiries are directed to specific officials of OCP and not the entire College.
I have done everything in my capacity in the hopes of getting the entire body to see the events from my point of view. I may have sent far too many emails to far too many people to get a transparent investigation and protect my professional practice. I was hoping to get answers from these emails, which, unfortunately, I never got despite my best efforts.
Sincerely,
James Bulaclac
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