09 August 2026

CONFIDENTIAL AND URGENT

Via Email: gsexton@lif.ca

The Lawyers Indemnity Fund
Attn: A. Gregory Sexton Director of Claims
The Law Society of British Columbia
845 Cambie Street
Vancouver, BC V6B 4Z9

Re: Ongoing Notice of Institutional Breach and Bad Faith Funding
LIF Claim/File Number: not provided, despite numerous requests
Court File Number: V-S-264675
Style of Cause: RB v. R. Nigel Beckmann and Meera Jain
Counsel Funded by LIF: David A. Joyce (QA Law)

Dear Mr. Sexton

Although you have masterfully ignored numerous correspondence, and perhaps have not accepted my invitation to view the public interest website defencelawyersreport.com , I write to formally place the Lawyers Indemnity Fund (LIF) on direct notice of a profound institutional breach, statutory violation, and ongoing bad faith funding. LIF is currently financing and maintaining a legal defense for David A. Joyce (Senior Counsel, QA Law) that is explicitly built upon, and actively promoting, a verified material falsehood in formal court pleadings.

LIF is funding a manufactured narrative designed solely to shield its appointed counsel from an un-waivable conflict of interest, directly undermining the administration of justice and breaching LIF's statutory mandate under the Legal Profession Act.

THE MATERIAL FALSEHOOD AND THE CONFLICT

As you have been apprised, in the underlying tort action the Defendants, Nigel Beckmann and Meera Jain, had formally pleaded that I am not an insured of INTACT Insurance, based upon a false, defamatory letter authored and published by Nigel Beckmann. David A. Joyce has advanced and promoted this false assertion within formal legal pleadings filed before the court, and he refuses to correct same.

This assertion is an absolute fabrication. My status as an Insured has been confirmed by INTACT Insurance since 2021.

The falsehood is highly material to these proceedings for two reasons:

1. It improperly isolates Mr. Joyce from a conflict. My legal status as an INTACT Insured is a confirmed fact, and Mr. Joyce and QA Law face an immediate, disqualifying conflict of interest under Chapter 3.4 of the BC Code of Professional Conduct.

2. Mr. Joyce's conduct constitutes an abuse of process. This fabrication has been strategically deployed to cut off my direct communication channels with INTACT, effectively trapping me under an abusive, retaliatory Strategic Lawsuit Against Public Participation (SLAPP).

SYSTEMIC AND STATUTORY BREACHES BY LIF

As an administrative arm of the Law Society of British Columbia, LIF operates under a statutory mandate to protect the public interest and uphold the integrity of the profession. By continuing to fund Mr. Joyce, after being put on notice of these facts, LIF is committing the following actionable breaches:

Funding the Deception of a Tribunal: Under Chapter 5.1-1 of the Code of Professional Conduct, a lawyer must not knowingly assert a fact that is untrue or misrepresent a material matter to a court. By subsidising a defense that relies entirely on a fabricated claims status, LIF is actively financing an attempt to deceive the Supreme Court.

Subsidising the Circumvention of Ethical Rules: LIF is weaponizing its financial resources to help an insured lawyer bypass the Law Society’s own strict conflict-of-interest regulations.

Institutional Bad Faith: An indemnity fund cannot contractually or ethically fund an intentional misrepresentation or an abuse of the court process, once the fraud has been exposed and brought to its attention.

DEMANDS AND IMMEDIATE NEXT STEPS

LIF can no longer claim ignorance of this misconduct. To mitigate further institutional liability and damage to the administration of justice, I hereby demand that LIF immediately undertake the following steps:

1. Initiate an expedited internal underwriting and claims review into the validity of the pleadings filed by David A. Joyce in this matter.

2. Freeze and suspend all financial backing, legal fees, and disbursements to David A. Joyce and QA Law pending the outcome of this investigation.

3. Immediately preserve all internal communications, claims notes, and authorization logs regarding the funding allocation for this file.

Please be advised that if LIF continues to fund this material fraud upon the Supreme Court, this correspondence will be filed as primary exhibit evidence in an upcoming interlocutory application to the B.C. Supreme Court for judicial disqualification, a stay of proceedings, and special costs directly against the parties, counsel, and the funder.

I look forward to your immediate written confirmation that an investigation has been launched and that funding has been suspended, upon confirmation of the facts as presented to you.

RB

06 August 2026

As detailed on public interest website, this lawyer, David A. Joyce has filed false pleadings in the BC Supreme Court, and refuses to correct same. Although the Plaintiff has no intention of ever filing any Complaint against Mr. Joyce with the LSBC, he most respectfully requests that Mr. Joyce comply with LSBC Rules of Court which require immediate correction of false pleadings, inter alia.

Other rules include:

• Rule Rule 2.2‑1 — Integrity

• Rule 5.1‑1 — Candour

• Rule 5.1‑2 — Fairness to Opposing Parties

• Rule 5.1‑5 — Courtesy and Good Faith / No Sharp Practice

• Rule 5.1‑1 (Commentary) — Misleading the Court

• Rule 7.2‑1 — Communications / No Threatening or Unfair Conduct Toward SRLs

05 August 2026

Lawyer David A. Joyce continues with his coordinated set of tactics to sabotage the BC Supreme Court's formal Rule 1-3 protocol of setting a hearing date for a summary Application.

Joyce's tactics are particularly prejudicial and in open defiance of BC Supreme Court. The NSRLP’s national SRL Principles and Access to Justice BC’s SRL Principles require that SRLs not be overwhelmed or cornered by process, such as the Defendant’s scheduling pressure and procedural tactics. As an antidote to Joyce's methods, Courts must ensure that self‑represented litigants not be disadvantaged by procedural complexity or coercive tactics.

Chief Justice Marchand’s people‑centered justice framework further directs that judges must intervene where process is used as leverage rather than resolution. His Honour's people‑centered justice framework, strictly directs that self‑represented litigants not be overwhelmed or cornered by procedural tactics, and that judges must intervene where process is used as leverage rather than resolution.

Joyce's violations of Chief Justice Marchand's various people‑centered justice directives, that require that self represented litigants not be disadvantaged by procedural pressure or scheduling constraints, include, but not by way of limitation:

1. Under the guise of seeking a mutually convenient hearing date, Joyce restricted his proposed filing dates to 8, 9 or 10 September 2026.

2. Joyce improperly conditioned basic scheduling upon the delivery of Particulars,

3. Joyce demanded a grossly unrealistic 45‑minute short‑chambers estimate for a Summary proceeding, when issues that arise from his own false pleadings necessitate at least a day's hearing,

4. Joyce ignores that the Plaintiff had offered availability on any date in November 2026, which is subsequent to -

5. Joyce's Client Meera Jain has been ordered to attend a CPC, scheduled for 02 October 2026, and its defined purpose is to determine whether Jain's Client (the Plaintiff's insurer) INTACT must have its Customer Experience Team (CET) complete its administrative function before judicial resources be engaged. Until the CPC is heard, the court retains control over that subject matter, and no party can unilaterally bypass or pre‑empt it through short‑chambers scheduling or restricted dates.

6. Joyce pleaded positions that contradict his Client Jain’s Client INTACT's own administrative and litigation posture, infra,

7. Joyce refuses to respond to the Plaintiff's Offer to insulate Ms. Jain' from her legal exposure.

Although Mr. Joyce advertises himself as a self-styled expert in Insurance Law, it would behoove him to seek consultation with an expert of conflicts of interest law.

04 August 2026

Defence Counsel David A. Joyce has advanced a distorted, revisionist narrative by denying the Plaintiff's Insured status, a legal right that INTACT had already established in 2021, by its creation of two (2) separate claims files (1033684645 and 4033526840), for claims made by the Plaintiff. The claims were assigned to Claims Manager Amanda Myers and Claims Representative Breanna Gray. Claims files are not created on behalf of non‑insureds.

Mr. Joyce persists in attempting to override INTACT's operational record, by asserting a position that INTACT has never adopted. Joyce’s denial contradicts the only authoritative source of insured status: INTACT’s claims files.

Mr. Joyce's has cast his eternal struggle with the documented factual record onto the BC Supreme Court, by filing false pleadings, a topic addressed on this public interest website, infra.

03 August 2026

The Plaintiff has undertaken measures to prevent Counsel David A. Joyce's interference with the orderly function of the judicial system. It is respectfully suggested to Mr. Joyce that he study BC Supreme Court Rule 1-3.

06 August 2026

Disclaimer: This public interest website does not intimate that Defence lawyer David A. Joyce was the first lawyer in history to file false pleadings, nor that at the time of his filing of the false pleadings in the BC Supreme Court, on 13 July 2026, that he necessarily was aware of the falsities.

Nor is it suggested that Mr. Joyce was necessarily aware of the following facts, at the time of filing of his false pleadings:

(1) BC Strata Property Act § 155(b),

(2) The landmark case of The Owners, Strata Plan VR 2213 v. Schappert, 2023 BCSC 2080, presided over by British Columbia Supreme Court Judge, the Honourable Justice Simon R. Coval.

(3) INTACT Insurance internal records, confirming the Plaintiff’s legal status as an INTACT Insured since 2021.

08 August 2026

LEGAL NOTICE TO DAVID A. JOYCE

This correspondence serves to formally apprise you of Plaintiff's intent to call you as an adverse witness at trial. As you would know, opposing counsel may be required to testify where they possess material, first‑hand evidence that is not otherwise available, as recognized in the Evidence Act, including § 9, and in authorities such as MacDonald Estate v. Martin, R. v. Neil, and the commentary in Sopinka, Lederman and Bryant.

This Notice is further necessitated by the fact that your sworn pleadings in this action directly contradict pleadings and sworn Affidavits that your Clients filed in their SLAPP litigation against the Plaintiff.

This Notice is provided in advance as a matter of courtesy and is not a filed document.

30 July 2026

As detailed on this website, the Plaintiff of the tort action against David A. Joyce's Clients Meera Jain and Nigel Beckmann has offered legal immunities to Meera Jain, as well as her Clients Amanda Myers and Christa Cordick.

Joyce has not only ignored the Offers, he has refused to acknowledge such. Upon expiry of the above count down, the Offers will automatically be withdrawn, without further notice.

DEFENCE COUNSEL DAVID A JOYCE' HAS FILED MATERIAL FALSE PLEADINGS IN THE B.C. SUPREME COURT

31 July 2026

WITHOUT PREJUDICE/RESERVATION OF RIGHTS (Save as to Costs)

Response to Application Scheduling Request (copy to LIF)

Dear Mr. Joyce,

I acknowledge receipt of your request for a convenient hearing date for your proposed Application to Dismiss.

Before any hearing date can be confirmed, the Court requires that pleadings be properly framed and that Applications comply with the Supreme Court Civil Rule 1-3 objective of a just, speedy, and inexpensive determination. As I have brought to your specific attention on several occasions, your current pleadings contain material contradictions and false assertions that must be rectified before this matter may be ripe for adjudication.

1. Formal Demand for Particulars [Rule 3-7(22)]

Pursuant to Supreme Court Civil Rule 3-7(22), you are hereby required to deliver full written particulars regarding the following contradictory assertions in your pleadings, within seven (7) days:

1. The exact factual and legal basis upon which you assert that INTACT denied my status as an insured, as factually asserted in the Notice of Civil Claim.

2. The specific facts and legal authorities relied upon to assert that my status as an insured is "irrelevant" to these proceedings, while simultaneously pleading and relying upon INTACT's purported denial of that status.

2. Binding Admissions Regarding Insured Status (Notice to Admit)

Your pleadings asserting a denial or irrelevance of my insured status are directly contradicted by the record. Your clients have already formally acknowledged in Notice to Admit responses the authenticity of INTACT's 30 September 2021 letter, which unequivocally affirmed my status as an insured and even quoted Strata Property Act § 155(b).

Your advance of pleadings that directly contradict your own clients' binding admissions breaches pleading integrity and constitutes an abuse of process.

3. Hearing Estimate and Scheduling Terms

In light of the necessary threshold issues—including your deficient pleadings, the formal admissions on record, and the legal authorities regarding counsel misconduct (Garcia v. Crestbrook Forest Industries Ltd.)—this application cannot be heard in a short summary slot.

1. Hearing Duration: I require a one-day hearing estimate to adequately deal with these issues and the associated

   Application for special costs.

2. Prerequisite to Confirmation: I will not agree to set a hearing date until you either cease and desist your false representations to the Court, as detailed on the website devoted to your:

   • Provide the formal particulars demanded above under Rule 3-7(22); or

   • Amend your pleadings to align with your clients' binding admissions.

If you attempt to set this application unilaterally, without providing the required particulars or on deficient pleadings, I will immediately apply under Rule 3-7(23) to compel particulars and seek special costs payable forthwith against your clients and/or counsel personally.

Govern yourself accordingly.

RB, Plaintiff

In response to Counsel David A. Joyce's false pleadings, certain measures, protective of the integrity of the judicial system, have been implemented.

The above emails from Defence Counsel Joyce signal the anticipated, futile attempt to disassociate himself from the acts and omissions of his clients Beckmann and Jain, which inevitably compound the solemn, irreconcilable conflict of interest dilemma that Mr. Joyce faces.

Although it is not the intent of the Plaintiff to litigate by way of websites, it is recommended that Mr. Joyce seriously consider the following:

R. v. McDonald, 2018 BCCA 305

"Counsel must not knowingly allow the court to be misled."

A false insured-status assertion misleads the court. Therefore, counsel of record must correct it.

R. v. Felderhof, 2003 ONCA

"Counsel have a duty to the court that overrides their duty to the client."

Mr. Joyce's statement that "my retainer doesn't cover coverage issues" is irrelevant. The misrepresentation is in the pleading he is defending, irrespective of his retainer.

LSBC Code of Professional Conduct, Rule 5.1-1

Duty of candour:

"A lawyer must be honest and candid with the court."

A misrepresentation in a pleading, left uncorrected, violates this rule.

26 July 2026

DEFENCE COUNSEL DAVID JOYCE'S OBSTRUCTION OF PLAINTIFF'S INSURANCE CLAIM

In any insurance matter where a claim remains open, the insurer owes the insured a functional and lawful method of communication. This requirement is not discretionary. It arises from basic principles of procedural fairness, the duty of good faith, and the insurer’s obligation to permit the insured to advance or clarify the claim. When counsel interposes herself/himself between the insured and the insurer, she/he assumes responsibility for maintaining the communication channel that her/his own involvement has displaced.

INTACT has confirmed—through internal bifurcation—that the Plaintiff's claim remains active. The existence of an active claim creates corresponding procedural obligations. The insured must be accorded a lawful avenue to communicate with INTACT. Because INTACT’s Counsel's lawyer, David Joyce, has positioned himself as the exclusive intermediary, direct communication with INTACT no longer is permissible, since the Plaintiff insured is forbidden from contact with Joyce's Clients, and he is aware of this limitation.

The legal implications of this are straightforward. When counsel blocks the only permissible channel of communication, any resulting delay, prejudice, or impairment of the insured’s ability to pursue the active claim arises from counsel’s refusal to act in his legal role. If that refusal proximately causes loss, the resulting consequences may attach personally. Counsel is not insulated from civil liability when his own conduct creates foreseeable harm, particularly where the obstruction is willful, sustained, and directly connected to the impairment of an active claim file.

The Plaintiff will not breach representation boundaries. He will not contact represented parties. The responsibility for establishing and maintaining a lawful communication path rests entirely with Mr. Joyce.
If he chooses not to occupy that role, the consequences of that choice attach to him.

24 July 2026

LEARNED COUNSEL DAVID A . JOYCE'S STRUGGLE WITH THE FACTS CONTINUES.

22 July 2026

Defence Counsel Joyce persists in his untenable position of denial of the relevance of BC Strata Property Act § 155(b) and INTACT's letter of 30 September 2021, infra.

Per Court documents, it was Mr. Joyce's Client Beckmann who authored the defamatory letter of 07 December 2023, falsely accusing the Plaintiff of misrepresenting his status as an Insured of INTACT. The degree of Ms. Jain's overall exposure is substantially less than that of Mr. Beckmann, and the issue of retraction of said letter is beyond the control of co-Defendant Jain, since on 07 December 2023 co-Defendant Meera Jain was not yet in the employ of Whitelaw-Twining. Moreover, Mr. Joyce ignores the Plaintiff's Offer of immunity to Ms. Jain, showing Mr. Joyce's deference to Mr. Beckmann's interests, to Ms. Jain's direct detriment!

Mr. Joyce has generously advised that Plaintiff RB retain a lawyer. Of respect for Mr. Joyce, RB kindly suggests that Mr. Joyce seek the advice of a lawyer who specialises in the thorny issue of irreconcilable conflicts-of-interest. The law firm that authored the below-linked cautionary article might be of assistance.

20 July 2026

As evidenced on the public interest website, David A. Joyce, Esq has undertaken the defence of Defendants Meera Jain and Nigel Beckmann. It is respectfully requested of Mr. Joyce that the gravamen of the NOCC against his Clients is NOT whether or not they were de jure, de facto or any type of direct lawyers for RB, the confirmed Insured of their Client INTACT Insurance. The core of Jain's and Beckmann's tortious conduct was their weaponisation of their positioning to plot directly against the interests INTACT's Insured.

How the Collusion Binds the Tortfeasors Together:

As evidenced by the above image of 22 September 2021, obtained from INTACT's internal records, Claims Manager Breanna Gray, who formally confirmed RB's status as an insured in her letter of 30 September 2021, infra, instantly triggers INTACT's high-standard duty of good faith. However, in order to avoid the financial exposure of funding independent, insurer-funded defense counsel, Gray mischaracterised the General Common Property (CP) ledge as Limited Common Property (LCP). (this subject is thoroughly analysed below)

Armed with Gray's manufactured LCP exclusion, Jain and Beckmann step in. Instead of acting neutrally or protecting the confirmed INTACT's Insured's position, they actively work against his interests, operating as adversarial agents within the claim structure, in order to insulate INTACT from its contractual obligations of indemnity.

When called out, Attorney David Joyce steps in to defend Jain and Beckmann, with a strategy to gaslight the record by rewriting history—claiming that Plaintiff RB was never an insured to begin with, directly contradicting voluminous Statutory and documentary evidence of RB's legal status as an INTACT Insured.

The Clear-Cut Bad Faith Line

By working against a confirmed Insured of their Client INTACT, to uphold a false property boundary, Jain and Beckmann didn't just commit malpractice; they acted as the functional tools for INTACT's bad-faith evasion of independent, insurer-funded defense counsel. This coordinated effort to protect the corporate insurer's bottom line at the direct expense of a confirmed insured—proximately resulting in your forcible eviction—is the foundational anchor of the Amended Counterclaim, seeking damages for, inter alia, forcible eviction for lack of a defence at the RTB hearing.

Yet another fallacy, of which Mr. Joyce should be aware, because it exacerbates the conflict of interest dilemma:

INTACT did not retain Nigel Beckmann in any defence role. INTACT retained him to pressure an INTACT Insured into deactivation of a website, based upon alleged defamatory content. This was not defence work; it was an insurer‑initiated offensive action against an insured. When INTACT-appointed counsel engaged with an insured in this manner, the interaction is not protected by litigation advocacy, and it engages the insurer’s obligations toward its insured. The significance of this insured status remains central, regardless of whether any formal tripartite defence relationship was created or not.

The below Consent Order awaits Counsel David A Joyce's signature, at his earliest convenience.

22 July 2026

Yet another of the myriad acts and omissions committed by Defence lawyer David Joyce's Client R. Nigel Beckmann relates to (the images to the left), the title and page 3 of INTACT's Amended Civil Claim against its insured, RB.

This Amendment, which was 'hand-crafted' by Mr. Beckmann, even implicateds INTACT lawyer Christa Cordick, who misrepresented to the Provincial Court that RB was not an Insured of INTACT.

INTACT's confirmed Insured, RB, hereby demands that Mr. Joyce ensure that his Client, Mr. Beckmann, appropriately notify the Supreme Court to rectify the false assertion that “Intact’s position in the Small Claims Action is that Mr. B was not an insured.”

In that Mr. Joyce represents Mr. Beckmann in the Supreme Court, the rectification of this material misrepresentation is essential to Court procedure of the case against Mr. Beckmann, and must adhere to Rule 1-3.

Page 3 of INTACT's Amended NOCC — Misrepresentation to the Supreme Court of Insured Status.

.

17 July 2026

INTENTION TO AMEND NOTICE OF CIVIL CLAIM

The Plaintiff in BC Supreme Court, Vancouver Registry action no. S-264675 hereby publishes this public summary, detailing his intention to amend the Notice of Civil Claim (NOCC) pursuant to Rule 6-1(1)(a) of the Supreme Court Civil Rules.

The forthcoming Amendments will explicitly expand and refine the legal basis of the claim to address the specific, systemic actions and omissions of the Defendants, R. Nigel Beckmann and Meera Jain.

Core Areas of Amendment

The Amended Notice of Civil Claim will focus upon three key pillars of liability:

1. De Facto Tripartite Relationship & Culpability: The Plaintiff was contractually and statutorily entitled to a legal defense under the INTACT Insurance policy. While INTACT wrongfully refused to formally instruct the Defendants to defend the Plaintiff at the Residential Tenancy Branch (RTB) hearing, the Plaintiff was and remained a de facto Tripartite Client. The Defendants possessed actual knowledge of the Plaintiff’s insured status and deliberately chose to exploit INTACT’s refusal by taking steps completely adverse to the very Insured whom they were structurally required to protect, irrespective of whether RB was a de jure, de facto or not technically, a Tripartite Client.

2. Abuse of Insider Proximity & Inducing Breach of Contract: As retained counsel for Intact, the Defendants held a position of unique economic and procedural influence. They abused this position of trust to feed known, fabricated falsehoods to the insurer—namely the letters of 07 December 2023 and 13 December 2023—with the deliberate intention of inducing INTACT to breach its contractual and statutory duties of utmost good faith to the Plaintiff.

3. Independent Intentional Torts: The Amendments NOCC will more precisely articulate the independent, actionable torts of Defamation, Injurious Falsehood, and Tortious/Intentional Interference with Economic and Contractual Relations stemming from the Defendants' extrajudicial conduct.

Note on Discoverability & Damages: The Plaintiff’s cause of action was not discoverable, and the limitation period did not begin to run, until 08 July 2024—the date on which the Defendants actively deployed these manufactured falsehoods in litigation, thus triggering direct, compensable economic loss and legal costs.

This summary is published for public information and transparent record-keeping regarding the ongoing proceedings.

16 July 2026

As the below Response to the Plaintiff's NOCC, as well as two (2) emails indicate, Attorney Joyce has reviewed the documentary evidence, infra, and has come to abandon his original misrepresentation that the Plaintiff was not an Insured of INTACT.

However, Mr. Joyce now asserts that the Plaintiff's legal status as INTACT Insured is "irrelevant". With all due respect to Mr. Joyce, the entire case against his Clients Meera Jain and Nigel Beckmann, is predicated upon the legal reality that the Plaintiff was an Insured of their client INTACT, and that they defamatorily and falsely accused the Insured of misrepresenting himself as an INTACT Insured, and that they committed 2 1/2 years of professional errors and omissions against the Insured.

As for Mr. Joyce's threat to Apply for Dismissal of the Plaintiff's NOCC, the Court would impose sanctions against him for an arrantly frivolous Application, violative of Rule 1-3!

________

Attorney Joyce's conflict of interest becomes all the more irreconcilable when one applies the following facts:

The below (right) image is of a letter of 30 September 2021, wherein Claims Manager Amanda Myers and Claims Representative Breanna Gray unambiguously confirmed Plaintiff RB's statutory and legal status as an Insured of INTACT.

More than four (4) years later, along comes Defendant Nigel Beckmann, who, in his below email of 13 January 2026 lied (1) that Plaintiff RB was not an Insured of INTACT, and (2) that no one had claimed that RB occupied the (inaccessible CP ledge).

Defence lawyer Mr. Joyce's ethical challenges include:

(1) His other Client, Meera Jain, does not necessarily assert Beckmann's lies, which accords her a unique defence, which Mr. Joyce must pursue, for Jain's protection, but at the expense of exposure of Nigel Beckmann's tortious conduct.

(2) Defendant Beckmann's concatenation of lies are yet another example of INTACT’s bad faith by having retained Beckmann, who engaged in numerous acts and omissions completely adverse to RB, the very Insured whom they were structurally required to protect.

18 July 2026

To the left are pages of the self-explanatory Consent Order that Attorney Joyce's Client, Meera Jain draughted and forwarded to Defendant (in the SLAPP litigation) RB, on or about 15 December 2025. RB has indicated that he is prepared to sign the Consent Order, and awaits instructions from Mr. Joyce, as Ms. Jain's lawyer.

Defendant Jain's Consent Order directly protects her for three reasons:

1. Mitigates Her Financial Exposure: If the flawed "ledge decision" is corrected, the ongoing operational and financial damages to Plaintiff RB are directly mitigated. In tort law, a Plaintiff's mitigated damages directly reduce the

   Defendant's (Jain's) potential financial liability.

2. Defeats the Proximate Cause of Litigation: Resolving the underlying dispute over the physical accessibility of the ledge eliminates the ongoing necessity—and associated legal costs—of the SLAPP lawsuits in which Jain participated. Without ongoing litigation, damages cannot continue to accumulate.

3. Weakens the Bad Faith Claim: If Defendant Jain signs her own Consent Order, it tends to undermine the allegation that she is actively continuing to weaponise known falsehoods, infra. It repositions her conduct as a remediable legal error rather than active, ongoing

   tortious acts and omissions.

19 July 2026

Since 07 December 2023, Defendant Beckmann's SLAPP litigation has been largely predicated upon his contrived, false interpretation of Strata Plan LMS 2343, persistently using the designation "B" as an absolute indicator of exclusive use Limited Common Property (LCP), consciously ignoring the explicit legal qualifier established in the plan's legend:

"B denotes balcony, limited common property for use of adjacent strata lot, unless otherwise indicated."

By maintaining an assertion in a Supreme Court pleading that directly contradicts an unassailable public record, such as the registered Strata plan, Beckmann's lawyer, Mr. Joyce, is in violation of specific rules and authorities governing BC civil procedure.

1. Falsehood and Abuse of Process:

   Under Rule 9-5(1) of the Supreme Court Civil Rules, the court may order the striking or amendment of any pleading that discloses no reasonable defence, is unnecessary, or is an abuse of the process of the court.

2. Mr. Joyce's denial of status that is mathematically and geographically disproven by a registered land title document constitutes a frivolous, vexatious, and abusive pleading.

3. The Duty to Correct Pleadings to "Determine the Real Issues"

   The Duty of Candour: Lawyers owe a strict duty of candour to the court. Under Law Society Rules (such as the BC Code of Professional Conduct), a lawyer must never knowingly mislead the court, present false evidence, or misrepresent material facts.

4. The Duty to Correct: If a lawyer later discovers that he inadvertently filed a pleading or submitted evidence containing a material falsehood, he has an immediate ethical obligation to correct the record.

5. Rule 11/Abuse of Process: In Canadian civil procedure, filing a pleading that a lawyer knows is false or has no evidentiary foundation can be penalised as an abuse of process, resulting in personal costs awards against the lawyer or severe court sanctions.

6. The binding authority on amending pleadings in British Columbia stems from the Court of Appeal and is reaffirmed under the modern rules. These authorities establish that the fundamental objective of the rules is to ensure the "just, speedy and inexpensive determination of every proceeding on the merits."

7. A party cannot force the court to litigate a known fiction. When new, indisputable evidence emerges—such as the registered Strata plan proving statutory status under the Strata Property Act—the pleading must be amended so the court can focus solely upon the real issues in dispute.

8. The Ethical Hurdle: Presenting a Knowingly False Statement of Fact: While a lawyer has a duty to advocate for his client, he is also an officer of the court. Under BC practice, Mr. Joyce cannot knowingly present or maintain a statement of fact in a pleading that has been conclusively falsified by a public record.

Now that Mr. Joyce has been formally notified of the Strata plan, as well as other material contrary to fact assertions in his legal pleadings, he has a legal and procedural obligation to take remedial action. There is no intimation that he will shirk his solemn responsibility!

In his below email, Defence lawyer David Joyce commences his representation of Defendants Meera Jain and Nigel Beckmann by attacking the legitimacy and credibility of INTACT personnel Claims Manager Amanda Myers and Claims Representative Breanna Gray, by falsely claiming that Plaintiff RB is not an Insured of INTACT, despite the documented facts of the below letter of 30 September 2021, and other copious internal records from INTACT, which clearly confirm RB's status as an INTACT Insured, even with citation of the statutory authority of Strata Property Act § 155(b).

RB followed Mr. Joyce's recommendation to seek legal advice, and although the defence lawyer whom he consulted had never heard of Mr. Joyce, she explained the LSBC prohibition of acceptance of dual Clients with such irreconcilable, unwaivable conflicts of interest.

IRRECONCILABLE, UNWAIVABLE CONFLICTS OF INTEREST

Defendants have filed a joint Response through a single lawyer. Any issues arising from joint representation fall within the Law Society’s conflict‑of‑interest framework, which governs counsel’s obligations when representing two (2) Clients with structural conflicts of interest, which arise from three independent legal axes.

1. Divergent Defences

A conflict exists whenever each Defendant’s best defence requires blaming the other.

With reference to the Defendants' Response to the NOCC, it contains the following statement:

“The Plaintiff caused his own injury, loss, damage or expense…” (Response, Division 2, para. 6)

But nothing in the Response explains:

• who made decisions,

• who gave instructions,

• who communicated with Intact,

• who acted first,

• who relied upon whom.

If Jain’s best defence is:

• “I acted under Beckmann’s direction,”

and Beckmann’s best defence is:

• “Jain acted independently,”

then one lawyer cannot ethically run both defences. This is the classic LSBC conflict.

2. Divergent Claims Exposure

If the allegations imply that:

• one Defendant’s conduct is primary,

• the other’s conduct is secondary,

• one Defendant’s exposure is higher,

• one Defendant’s conduct triggers insurer reporting obligations, then their interests diverge.

The Response states:

“At all material times, the Defendants were adverse in interest to the Plaintiff.” (Response, Division 2, para. 2)

But that does not resolve the conflict between Defendants Jain and Beckmann.

If one Defendant is even slightly more exposed, a single lawyer cannot ethically represent both.

3. Divergent Insurance Positions

This is the irreconcilable conflict.

The Response states:

“The Plaintiff was not an Intact Insurance ‘insured’…” (Response, Division 2, para. 4)

In the SLAPP litigation, Defendant Beckmann falsely and defamatorily claimed that RB had lied about being an Insured of INTACT, despite the letter of 30 September 2021 from Claims Manager Amanda Myers and Claims Representative Breanna Gray, infra, as well as other letters and Affidavits, which unambiguously confirmed RB's status as an INTACT insured, infra!

Unlike Defendant Beckmann's tainted approach, Jain was merely following the directives of her boss.

This is the conflict addressed in various Sections of the BC Code of Professional Conduct.

Summary

The conflict between Jain and Beckmann arises from:

• divergent defences,

• divergent exposure,

• divergent insurance positions.

A single lawyer can represent both only if:

• their defences align,

• their exposure aligns,

• their insurance positions align,

• and they both gave informed consent, but by law under these circumstances the right to separate defence lawyer may not be waived!

  Defence lawyer David Joyce's Ethical Trap: Lying to Evade a Conflict

  In British Columbia, a lawyer attempting to dodge a conflict of interest by fabricating or lying about a party’s insured status is a severe, actionable breach of the BC Code of Professional Conduct.

  By deliberate misrepresentation of the gravamen of the NOCC against his Clients, Joyce not only has failed to resolve the conflict of interest prohibition, he has exacerbated such conflict by attacking the veracity of the INTACT personnel who had confirmed Plaintiff RB's legal status as an Insured of INTACT.

  Although Joyce has advised that the Plaintiff seek legal advice, perhaps it is Joyce who should seek legal advice regarding violations of the LSBC code of conduct:

• Duty of Integrity (Rule 2.1-1): A lawyer must discharge her/his duties with integrity and honor. Manufacturing a false factual narrative to escape a conflict is dishonest and constitutes professional misconduct.

• Duty of Candor & Honesty (Rule 2.2-1): Lawyers are strictly prohibited from misleading the Court, other counsel, or self-represented litigants. Joyce's misrepresentation as "fact" that INTACT claims that Plaintiff RB is not an INTACT Insured, despite all evidence to the contrary, supra, is a direct violation.

• The Conflict of Interest Rules (Section 3.4): A lawyer cannot cure a conflict of interest by simply pretending the conflict does not exist. Joyce's blatant misrepresentation that INTACT does not consider the Plaintiff to be an Insured is nothing more than a desperate attempt to cover up Joyce's initial breach.

THIS PUBLIC INTEREST WEBSITE HAS BEEN CREATED FOR THE PURPOSE OF PRESENTATION OF DOCUMENTED FACTS REGARDING CIVIL ACTION, VANCOUVER REGISTRY NO. S-264675.

As evidenced on website CLAIMSMANAGERREPORT.COM, INTACT Claims Manager Breanna Gray had found coverage for appointment of defence counsel at its Insured's eviction hearing at the Residential Tenancy Branch (RTB). However, INTACT simultaneously utilised that very same proceeding to build a defense narrative, later using those findings to its Insured's detriment. Such is a textbook breach of the insurer’s duty of good faith and the duty to defend.

In the academic text "Navigating the Tripartite Relationship in Liability Insurance Claims" by Professor Elizabeth Adjin-Tettey (University of Victoria), it is explicitly established that because the insurer selects counsel, "defence counsel will be in a joint representation situation if they are acting on behalf of both the insurer and the insured."

In Canadian insurance law, the duty to defend is triggered entirely by the mere possibility that the claim falls within coverage (the "pleadings rule"). INTACT acknowledged RB was an Insured, yet by failing to appoint defence counsel for the RTB hearing, INTACT completely severed the "tripartite" safety net. INTACT left its Insured exposed while its investigators and counsel Nigel Beckmann and Meera Jain gathered information against their own Client.

In Chersinoff v. Allstate Insurance Co. (1968 CanLII 671 (BC SC), the British Columbia Supreme Court explicitly held that defense counsel appointed by an insurer to defend an insured is operating under a "joint retainer". The Court ruled:

"The position of the solicitors in my view is that they must be regarded as having been jointly retained to represent both parties..."The Office of the Information and Privacy Commissioner for BC (OIPC) explicitly stated in decisions like Order F23-17 and Order F18-33, wherein the Adjudicator clarified:

"Previous OIPC orders and court decisions have determined that 'when a lawyer is hired to represent an insured and an insurer, the lawyer is regarded as being jointly retained to represent both parties.' In such situations, the relationship between the insured, the insurer and the lawyer has been referred to in past OIPC orders as a 'tripartite relationship.'"