165 Dufferin Street
Toronto, Ontario, M6K 1Y9
Telephone 531-2411
Fax 531-0885

July 11, 1991

CONFIDENTIAL

Mr. Murray Segal
Director of Crown Law Office - Criminal
Ministry of the Attorney General
Clara Brett Martin Building
720 Bay Street, 7th Floor
Toronto, Ontario
M5G 2K1

Dear Mr. Segal:

As you are aware, our client is concerned that should some degree of protection not be available and should The Metropolitan Toronto Police learn of her request, she will be at even greater risk. She believes that this would indicate to the Police that she has not given in to the intimidation, and intends to testify.

Thus, after reviewing the attached, should you believe assistance is not likely, please speak with us prior to forwarding anything to the O.P.P. As I advised, I am out of town as of July 13th for three weeks. Dianne Martin, the Academic Director of Parkdale and senior counsel to our client at the Inquiry, returns to Toronto on July 15th. Ray Kuszelewski, also counsel to Jane Doe, will be available until July 19th.

Thank you for your consideration of this request and for your information respecting witness protection.

Yours truly,

PARKDALE COMMUNITY LEGAL SERVICES INC.

Phyllis Gordon
Clinic Director