April 1, 1991

VIA FAX

Mr. Albert Cohen
Metropolitan Legal Department
1 Dundas Street West
22nd Floor, Box 16
Toronto, Ontario
M5G 1Z3

Attention: Mr. Albert H. Cohen

Dear Mr. Cohen:

Re:	Jane Doe v. William McCormack et al. OCGD - Action No. 18027/91U

      We have received your fax of March 28, 1991, wherein you confirmed, on behalf of the Defendants in the above - noted action, that the Defendants undertake not to disclose any information in their possession which would in any way identify the Plaintiff in respect of disciplinary proceedings against Sergeant Brian Whitehead, Badge No. 2821, before the Metropolitan Toronto Police Force Disciplinary Tribunal. You also confirmed that the Defendants undertook not to release to the public a transcript of proceedings involving Sergeant Brian Whitehead taken pursuant to the Police Act, unless all identifying references to the Plaintiff from that transcript are first deleted.

      We also note that both undertakings were subject to the Defendants being compelled by law to release the identity to the Plaintiff or compelled by law to release to the public a transcript of proceedings involving sergeant Brian Whitehead taken pursuant to the Police Act. While these qualifications go without saying, we would expect advance notice of any such action on the part of either Defendant in this action.

      We would also like to thank both you and Mr. Avinoam for the co-operation both of you have provided throughout this matter.

Yours very truly, McCarthy Tétrault Per: Bernard C. LeBlanc

BCL/bp