ONTARIO CORRECTIONS STAFFING-RELATED LOCKDOWNS CLASS ACTIONS: NOTICE OF SETTLEMENT APPROVAL Please read this notice carefully. Your rights may be affected even if you do not take any action. This notice is for all Class Members in the Lapple and Dadzie Actions. You may be able to claim money in a Settlement that was approved in two class action lawsuits against Ontario and Canada (the “Defendants”). These lawsuits allege that the Defendants improperly subjected inmates and immigration detainees to chronic staffing-related lockdowns. The Defendants deny those allegations, and the Court did not decide who was right. The Parties have instead reached a voluntary Settlement. The Settlement was approved on October 22, 2025. Class Action Class Members Lapple et al v His Majesty the King in All current and former inmates of Ontario right of the Province of Ontario, Court correctional institutions as defined in the Ministry File No. CV-16-558633-00CP of Correctional Services Act (other than the Elgin- Middlesex Detention Centre, the Ontario (Inmates) Correctional Institute, or the St. Lawrence Valley Correctional and Treatment Centre) between May 30, 2009 and November 27, 2017, including those detained pending trial or other court appearance. Dadzie et al v His Majesty the King in All persons detained under the Immigration and right of Ontario et al, Court File No. Refugee Protection Act at Ontario correctional CV-16-558376-00CP institutions as defined in the Ministry of Correctional Services Act (other than the Elgin- (Immigration Detainees) Middlesex Detention Centre, the Ontario Correctional Institute, or the St. Lawrence Valley Correctional and Treatment Centre) between May 30, 2009 and November 27, 2017 (solely with respect to their detention under the Immigration and Refugee Protection Act). Une version française de cet avis est disponible sur le site web (ontjailstafflockdowns.ca) ou par courriel (info@ontjailstafflockdowns.ca). IMPORTANT: The deadline to make a Claim is December 1, 2026. SETTLEMENT BENEFITS: There is a Settlement Fund of $59 million available to pay eligible Class Members as well as certain fees and expenses, including Class Counsel Fees in the amount approved by the Court, and the Honoraria for the Representative Plaintiffs approved by the Court. 1 Class Members may be eligible to receive a payment under the Settlement if they submit a valid Claim before December 1, 2026. The Settlement provides compensation to Class Members who experienced 16 or more staffing- related lockdowns, calculated according to the Settlement Agreement. Most compensation available under the Settlement Agreement is limited to those who experienced staffing-related lockdowns: • between August 15, 2014 and November 27, 2017, for current or former inmates; or • between August 11, 2014 and November 27, 2017, for current or former immigration detainees. If you experienced 16 or more staffing-related lockdowns while you were: • an inmate at an Ontario Correctional Institution (not including the Elgin-Middlesex Detention Centre, the Ontario Correctional Institute, or the St. Lawrence Valley Correctional and Treatment Centre) between May 30, 2009, and August 14, 2014, or • an immigration detainee at an Ontario Correctional Institution (not including the Elgin- Middlesex Detention Centre, the Ontario Correctional Institute, or the St. Lawrence Valley Correctional and Treatment Centre) between May 30, 2009 and August 10, 2014, you may still qualify for compensation if: • you can show that you were legally incapable of starting a lawsuit during that time, or • you qualify under the Exceptional Circumstances Protocol. MORE INFORMATION: This notice includes detailed information about the Settlement, including about how to submit a Claim. If you still have questions after reading this notice, visit the Administrator’s website (ontjailstafflockdowns.ca) or contact the Administrator: Ontario Corrections Staffing-Related Lockdowns Class Actions Administrator c/o Deloitte LLP PO Box 7545 STN ADELAIDE Toronto, ON M5C 0C4 Toll-Free Telephone: 1-844-742-0825 Email: info@ontjailstafflockdowns.ca Website: ontjailstafflockdowns.ca 2 TABLE OF CONTENTS Table of Contents The Actions 4 1. What are these lawsuits about? 4 2. Who is a Class Member in these lawsuits? 4 3. Which correctional institutions are involved in the lawsuits? 5 4. What is a staffing-related lockdown? 6 The Notice 6 5. What is the purpose of this notice? 6 6. Why is there a Settlement? 6 The Settlement 6 7. What does the Settlement provide? How much money can I claim under the Settlement? ..........6 8. What is a Mental Disorder? 8 Participating in the Settlement 8 9. Am I eligible for compensation? 9 10. How do I make a Claim? 9 11. When do I have to submit by Claim by? 11 12. Do I need a lawyer to make a Claim? 11 13. What supporting documents do I need to prove my Claim? 11 14. Who will review my Claim? 11 15. What if I do not make a Claim? 12 16. Can I submit a Claim on behalf of someone else? 12 The Lawyers Representing the Class 13 18. Do I have a lawyer in this case? 13 19. How will the lawyers representing the Class be paid? 13 Getting More Information 13 20. Are there more details about the Settlement? 13 21. How do I get more information? 14 3 The Actions 1. What are these lawsuits about? These lawsuits allege that the Defendants improperly subjected inmates and immigration detainees to chronic staffing-related lockdowns. The lawsuits allege that the lockdowns were negligent and breached inmates’ and immigration detainees’ rights under sections 7 and 12 of the Canadian Charter of Rights and Freedoms (the right to life, liberty and security of the person and the right not to be subjected to any cruel and unusual treatment or punishment). The Defendants deny these allegations. The Court did not decide who was right. The Parties have instead reached a voluntary Settlement. The Settlement was approved on October 22, 2025. 2. Who is a Class Member in these lawsuits? The Class in the Lapple Action (the “Lapple Class” or “Lapple Class Members”) is: (a) all current and former inmates of correctional institutions as defined in the Ministry of Correctional Services Act, RSO 1990, c M.22 (“Correctional Institutions”) between May 30, 2009 and November 27, 2017 who are or were remanded, except the Excluded Lapple Persons; and (b) all current and former inmates of the Correctional Institutions between May 30, 2009 and November 27, 2017 who are or were serving a sentence at a Correctional Institution or who have violated parole and are or were imprisoned at a Correctional Institution as a result, except the Excluded Lapple Persons. “Excluded Lapple Persons” are: • all inmates detained only in accordance with the Immigration and Refugee Protection Act, SC 2001, c 27; and • all inmates of the Elgin-Middlesex Detention Centre, the Ontario Correctional Institute and the St. Lawrence Valley Correctional and Treatment Centre (solely with respect to their incarceration at those Correctional Institutions). The Class in the Dadzie Action (the “Dadzie Class” or “Dadzie Class Members”) is: (a) all persons detained under Division 6 of the Immigration and Refugee Protection Act, SC 2001, c 27 at Ontario correctional institutions as defined in the Ministry of Correctional Services Act, RSO 1990, c M.22 (“Correctional Institutions”) between May 30, 2009 and November 27, 2017 (solely with respect to their 4 detention under Division 6 of the Immigration and Refugee Protection Act), except the Excluded Dadzie Persons. (b) “Excluded Dadzie Persons” are all persons who were detained at the Elgin-Middlesex Detention Centre, the Ontario Correctional Institute and the St. Lawrence Valley Correctional and Treatment Centre (solely with respect to their detention under the Immigration and Refugee Protection Act at those Correctional Institutions). 3. Which correctional institutions are involved in the lawsuits? The lawsuits (and Settlement) involve the following Correctional Institutions: • Algoma Treatment and Remand Centre • Brantford Jail • Brockville Jail • Central East Correctional Centre • Central North Correctional Centre • Chatham Jail (closed 2014) • Fort Frances Jail • Hamilton-Wentworth Detention Centre • Kenora Jail • Maplehurst Correctional Complex • Mimico Correctional Complex (closed 2011) • Monteith Correctional Complex • Niagara Detention Centre • North Bay Jail • Ottawa-Carleton Detention Centre • Owen Sound Jail (closed 2011) • Quinte Detention Centre • Sarnia Jail • South West Detention Centre (opened 2014) • Stratford Jail • Sudbury Jail • Thunder Bay Correctional Centre • Thunder Bay Jail • Toronto East Detention Centre • Toronto Jail (closed 2014) • Toronto South Detention Centre (opened 2014) • Toronto West Detention Centre (closed 2014) • Vanier Centre for Women • Walkerton Jail (closed 2011) • Windsor Jail (closed 2014) 5 The Elgin-Middlesex Detention Centre, Ontario Correctional Institute, and the St. Lawrence Valley Correctional and Treatment Centre are not covered by these lawsuits or the Settlement. 4. What is a staffing-related lockdown? A staffing-related lockdown is a lockdown in which individuals detained at a Correctional Institution are confined to their cells due to shortages of staff at the Correctional Institution. The Notice 5. What is the purpose of this notice? The purpose of this notice is to inform you that the Ontario Superior Court of Justice has approved the Settlement reached in two class action lawsuits against the Defendants in relation to staffing-related lockdowns at Ontario Correctional Institutions between May 30, 2009 and November 27, 2017: • Lapple et al v His Majesty the King in right of the Province of Ontario, Court File No. CV-16-558633-00CP; and • Dadzie et al v His Majesty the King in right of Ontario et al, Court File No. CV-16- 558376-00CP. You might have already received notice of certification of these lawsuits, or notice about the October 22, 2025 Settlement Approval Hearing. However, this notice is to update you on the Settlement’s approval and to let you know how to make a Claim and the deadline for doing so. 6. Why is there a Settlement? The Parties believe that the Settlement provides Class Members with reasonable compensation in exchange for releasing the Defendants from liability. The Settlement does not mean that the Defendants did anything wrong, and the Court did not decide who was right. The Parties entered into a Settlement Agreement. The individuals who filed the Actions (called the “Representative Plaintiffs”) and Class Counsel believe that the Settlement is fair, reasonable, and in the best interests of the Class, and the Court has agreed. The Settlement Agreement was approved by the Court on October 22, 2025. The approval became final on November 24, 2025. The Settlement 7. What does the Settlement provide? How much money can I claim under the Settlement? Under the Settlement, the Defendants will pay $59 million. This amount includes payments to compensate successful Claimants, as well as certain fees and expenses associated with the Settlement, including Class Counsel Fees in the amount approved by the Court, the Class Proceedings Fund Levy (the Class Proceedings Fund provided funding so that this litigation 6 could be pursued), Administration Costs, and the Honoraria for the Representative Plaintiffs approved by the Court. The Settlement provides the following types of compensation to Eligible Claimants: Who is Eligible How Amount Is Determined Possible Award Amount Basic Recovery Award All Eligible Claimants (those who Determined by the Administrator $2,000 to experienced 16 or more staffing-related through the use of the Basic Recovery $28,000* lockdowns, calculated in accordance with Grid, based on the total number of the Compensation Protocol) staffing-related lockdowns that the Claimant experienced, calculated in accordance with the Compensation Protocol Differential Impact Award Eligible Claimants who have at least one Determined by the Administrator $3,000 to mental health alert or suicide alert in their through the use of the Enhanced $15,000* OTIS record that does not post-date the Recovery Grid, based on the total last staffing-related lockdown that they number of staffing-related lockdowns experienced that the Claimant experienced, calculated in accordance with the Compensation Protocol Serious Harm Award – Level One Eligible Claimants who experienced, Determined by the Adjudicator on a $20,000* within 120 days of a staffing-related paper record, which will include the lockdown, substantial degradation in an Claimant's written statement and existing Mental Disorder, development of supporting documents a new Mental Disorder, or self-injurious behaviour (not including body modification or protest actions, such as hunger strikes), or, during a staffing- related lockdown, violence causing serious physical injuries requiring medical attention. Serious Harm Award – Level Two Eligible Claimants who experienced Determined by the Adjudicator on a $40,000* either a documented suicide attempt paper record, which will include the during or within 120 days of a staffing- Claimant's written statement and related lockdown, or violence causing supporting documents permanent impairment during a staffing- related lockdown 7 * All awards will be subject to pro rata reductions, if the total money awarded is more than the amount available to pay successful Claimants. Eligible Claimants who qualify may receive either a Differential Impact Award or a single Serious Harm Award (either at Level One or Level Two), but not both. The maximum amount available under the Compensation Protocol is $68,000. Some Class Members may be eligible for additional compensation from the Exceptional Circumstances Fund, assessed by the Administrator in accordance with the Exceptional Circumstances Protocol. 8. What is a Mental Disorder? For a Serious Harm Award, “Mental Disorder” means the diagnosis by a medical doctor, psychologist, or nurse practitioner (or the identification by a social worker, counsellor, therapist or registered nurse of a diagnosis by a medical doctor, psychologist or nurse practitioner) of the existence of one of the following disorders, as defined in the relevant Diagnostics and Statistics Manual of Mental Disorders, either the Fourth Edition (“DSM-4”) or Fifth Edition (“DSM-5”): • schizophrenia (all sub-types) • delusional disorder • schizophreniform disorder • schizoaffective disorder • brief psychotic disorder • substance-induced psychotic disorder (excluding intoxications and withdrawal) • psychotic disorder not otherwise specified • major depressive disorders • bipolar disorder I • bipolar disorder II • neurocognitive disorders and/or delirium, dementia and amnestic and other cognitive disorders • post-traumatic stress disorder • obsessive compulsive disorder, or • borderline personality disorder Substance use disorder is not considered a "Mental Disorder" in this Settlement. Participating in the Settlement Class Members can participate in the Settlement by making a Claim. The period for making a Claim runs until December 1, 2026. During that period, you may make a Claim by filling out the Claim Form (and Statute-Barred Claim Form, if applicable) and submitting it (and any supporting documents) to the Administrator online, by mail, or by email, on or before December 1, 2026. 8 9. Am I eligible for compensation? If you are a Class Member in one of these class action lawsuits, you must submit a Claim Form (and Statute-Barred Claim Form and supporting documents, if applicable) before December 1, 2026. The Administrator, or the Adjudicator, if applicable, will determine if you are eligible to receive compensation according to the procedures and criteria set out in the Settlement. Compensation is only available under the Settlement if you experienced 16 or more staffing- related lockdowns, calculated according to the Settlement Agreement. Most compensation available under the Settlement Agreement is limited to those who experienced staffing-related lockdowns: • between August 15, 2014 and November 27, 2017, for current or former inmates; or • between August 11, 2014 and November 27, 2017, for current or former immigration detainees. If you experienced 16 or more staffing-related lockdowns while you were: • an inmate at an Ontario Correctional Institution (not including the Elgin-Middlesex Detention Centre, the Ontario Correctional Institute, or the St. Lawrence Valley Correctional and Treatment Centre) between May 30, 2009, and August 14, 2014, or • an immigration detainee at an Ontario Correctional Institution (not including the Elgin- Middlesex Detention Centre, the Ontario Correctional Institute, or the St. Lawrence Valley Correctional and Treatment Centre) between May 30, 2009 and August 10, 2014, you may still qualify for compensation if: • you can show that you were legally incapable of starting a lawsuit during that time, or • you qualify under the Exceptional Circumstances Protocol. You will not be eligible if you previously and validly opted yourself out (excluded yourself), in writing, from the Lapple Action and/or Dadzie Action (as applicable to you). 10. How do I make a Claim? To be eligible to receive money from the Settlement, you must make a Claim by submitting a fully completed Claim Form (and Statute-Barred Claim Form and supporting documents, if applicable) to the Administrator on or before December 1, 2026. To make a Claim: To make a Claim, you must complete the Claim Form. You may also need to provide supporting documents – details are provided at question 13 below. To complete your Claim Form and submit documents easily online, please visit the online claims portal: portal.ontjailstafflockdowns.ca. 9 If you cannot use the online claims portal, you can get a copy of the Claim Form (and Statute- Barred Claim Form) as follows: If You Are Online or By Email By Phone or Mail At Ontario Currently Probation and Incarcerated Parole Offices If you are currently Complete the Claim Form Write or call the Ask for a copy of incarcerated in an through the online claims portal, Administrator to the Claim Form and Ontario correctional download the Claim Form from request a copy of the postage-paid return institution or at a the settlement website, or request Claim Form by envelope from your Canadian federal a copy of the Claim Form by mail: Ontario probation correctional email: and parole office. institution, or Telephone: detained at a Online Claims Portal: 1-844-742-0825 Canadian portal.ontjailstafflockdowns.ca Immigration Mail: Holding Centre, you Settlement website: Ontario Corrections can get a copy of the ontjailstafflockdowns.ca Staffing-Related Claim Form and a Lockdowns Class postage-paid return Email: Actions envelope from the info@ontjailstafflockdowns.ca Administrator common areas in the c/o Deloitte LLP institution. PO Box 7545 STN ADELAIDE Toronto, ON M5C 0C4 You can complete your Claim Form electronically or on paper. Once you have done so, you must: (1) include any supporting documents specified on the Claim Form (including the Statute-Barred Claim Form, if applicable); and (2) submit the Claim Form and supporting documents to the Administrator on or before December 1, 2026: (a) by mail (at the address listed on the Claim Form); (b) by Canada Post (at the address listed on the Claim Form); or (c) by email (claims@ontjailstafflockdowns.ca). Keep a copy of your Claim Form and all supporting documents for your records. If you submit your Claim Form by mail via Canada Post, request your post office to apply a postmark (the date stamped by Canada Post) on the envelope. This will be considered as the day the Claim Form was submitted to the Administrator. If you were legally incapable of starting a lawsuit prior to August 2014, you must submit a Statute-Barred Claim Form with your Claim Form. Please contact the Administrator, using the information above, to obtain a Statute-Barred Claim Form. 10 11. When do I have to submit by Claim by? You must submit your Claim Form on or before December 1, 2026. If you fail to submit your Claim Form on or before December 1, 2026, you may not receive any payment from the Settlement. The Administrator will have limited ability to consider late Claims received within forty-five (45) days after December 1, 2026. In addition to the other requirements of the claims process, if you submit a Claim Form within forty-five (45) days after December 1, 2026, you must provide written reasons for failing to submit your Claim Form on time. The Administrator will consider your written reasons and decide whether to assess your late Claim. After January 15, 2027, it will be too late for your Claim to be considered. 12. Do I need a lawyer to make a Claim? You do not need to hire a lawyer in order to make a Claim for compensation under the Settlement, but you may find it helpful to have one. The Administrator and Class Counsel can answer any general questions you may have about the claims process at no charge. Their contact information is available under questions 18 and 21 below. 13. What supporting documents do I need to prove my Claim? The supporting documents that you need to include with your Claim depend on what you are claiming. If you are claiming Basic Recovery only or Basic Recovery and a Differential Impact Award, you do not need to provide any supporting documents with your Claim Form. If you are claiming a Serious Harm Award, you must provide any documents in your possession that support your Claim for a Serious Harm Award. Examples include hospital records; medical records; or a letter from your doctor, psychologist, nurse practitioner, social worker, counsellor, therapist, or registered nurse setting out that professional’s knowledge of the nature of the harm caused to you by staffing-related lockdowns and/or any diagnosis of a Mental Disorder and the date and duration of that diagnosis. If you were legally incapable of starting a lawsuit prior to August 2014, you must submit a Statute-Barred Claim Form with your Claim Form, and must provide medical or psychological evidence demonstrating your incapacity (for example, a court order or other record of a determination on capacity by a court or authority of competent jurisdiction). 14. Who will review my Claim? A third-party Administrator (Deloitte LLP) was appointed by the Court to administer the Settlement and the claims process. The Administrator will review and decide Claims according to the Compensation Protocol and Exceptional Circumstances Protocol. 11 A third-party Adjudicator (Crawford & Company (Canada) Inc.) will decide some Claims: • certain Claims for Serious Harm Awards (where the Defendants require an adjudication); and • for Claims under the Compensation Protocol with respect to staffing-related lockdowns that occurred prior to the Presumptive Limitation Periods, to determine whether the Claimant has shown legal incapacity. 15. What if I do not make a Claim? If you do not make a Claim, you will not be able to get any money from the Settlement and you will be forever releasing any legal claims you may have had against the Defendants in relation to staffing-related lockdowns at the Correctional Institutions between May 30, 2009 and November 27, 2017. Unless you opted out, you will not be able to sue the Defendants independently for your experiences with the staffing-related lockdowns. Even if you previously provided information to Class Counsel or to another lawyer, you must still submit a fully completed Claim Form specifically for this Settlement to be eligible to receive money. 16. Can I submit a Claim on behalf of someone else? Yes, if you have legal authority to do so. If you are submitting a Claim on behalf of someone else, you must explain on the Claim Form why you have the authority to act and you must attach a copy of any Certificate of Appointment of Estate Trustee, Continuing Power of Attorney for Property, or other document(s) establishing that authority. 17. What is available from the Exceptional Circumstances Protocol? As part of the $59-million Settlement Fund, the Defendants have agreed to pay a $2-million Exceptional Circumstances Fund. The Exceptional Circumstances Fund will be distributed according to the Exceptional Circumstances Protocol. The Exceptional Circumstances Protocol provides limited compensation for staffing-related lockdowns that occurred between August 11, 2010 and August 2014. It also provides additional compensation to Class Members who were incarcerated at the Toronto South Detention Centre. Compensation is available from the Exceptional Circumstances Protocol for: • eligible immigration detainees who experienced at least 16 staffing-related lockdowns between and August 11, 2010 and November 27, 2017, at least some of which occurred on or before August 10, 2014; • eligible immigration detainees and inmates who experienced 101 or more staffing-related lockdowns, at least some of which occurred: o between May 30, 2009 and August 14, 2014 (for inmates); o between May 30, 2009 and August 10, 2010 (for immigration detainees); 12 • eligible immigration detainees and inmates who were incarcerated at the Toronto South Detention Centre for at least six months after August 2014. For more details about eligibility for the Exceptional Circumstances Protocol, visit ontjailstafflockdowns.ca. The Lawyers Representing the Class 18. Do I have a lawyer in this case? The law firms representing the Class are listed below. Lapple Class (Inmates) Dadzie Class (Immigration Detainees) Koskie Minsky LLP Koskie Minsky LLP Email: ontarioprison@kmlaw.ca Email: idclassaction@kmlaw.ca Toll-Free Telephone: 1-866-777-6339 Toll-Free Telephone: 1-866-777-6309 McKenzie Lake Lawyers LLP Henein Hutchison Robitaille LLP Email: ont.detention.centres@mckenzielake.com Email: idclassaction@hhllp.ca Toll-Free Telephone: 1-855-772-3556 Toll-Free Telephone: 1-855-525-3403 Champ & Associates Email: lockdownclass@champlaw.ca Toll-Free Telephone: 1-833-333-6608 You will not be charged for contacting these lawyers with questions about the Settlement. If you want to be represented by your own lawyer, you may hire one at your own expense. 19. How will the lawyers representing the Class be paid? Class Counsel worked on a contingency-fee basis, meaning that no fees were charged at any stage of the lawsuits until after the Settlement was approved. After the Court approved the Settlement, the Court approved Class Counsel’s fees in the amount of $17,700,000, plus HST of $2,301,000, and disbursements (out-of-pocket expenses) of $997,489.62. The Court determined that this amount was fair and reasonable. This amount will be deducted from the Settlement Fund. Getting More Information 20. Are there more details about the Settlement? This notice summarizes the Settlement as well as how to make a Claim and the deadline for doing so. More details are in the Settlement Agreement and its schedules, which you can view at ontjailstafflockdowns.ca. Neither the Parties nor their lawyers make any representation regarding the tax effects, if any, of receiving any benefits under the Settlement. Consult your tax advisor for any tax questions you may have. 13 The court offices will be unable to answer any questions about the matters in this notice. If you have any questions regarding the Settlement or about the class action lawsuits in general, more information is available at ontjailstafflockdowns.ca or by reaching out to the Administrator at the contact information below. Please do not contact the court offices. Ontario Corrections Staffing-Related Lockdowns Class Actions Administrator c/o Deloitte LLP PO Box 7545 STN ADELAIDE Toronto, ON M5C 0C4 Toll-Free Telephone: 1-844-742-0825 Email: info@ontjailstafflockdowns.ca Website: ontjailstafflockdowns.ca 21. How do I get more information? The court offices will be unable to answer any questions about the matters in this notice. If you have any questions regarding the Settlement or about the class action lawsuits in general, more information is available at ontjailstafflockdowns.ca or by reaching out to the Administrator at the following contact information: Ontario Corrections Staffing-Related Lockdowns Class Actions Administrator c/o Deloitte LLP PO Box 7545 STN ADELAIDE Toronto, ON M5C 0C4 Toll-Free Telephone: 1-844-742-0825 Email: info@ontjailstafflockdowns.ca You may also contact Class Counsel directly at the contact information listed under question 18. 14