By Dr. Bob Uttl (March 26, 2024)
On October 13, 2021, two “independent experts”, Dr. Mary Westcott, R. Psych. (Mandel & Associates Ltd) and Dr. J. Braxton Suffield, R. Psych. (J. B. Suffield and Associates) swore nearly verbatim identical affidavits (Dr. Mary Westcott’s Affidavit, Dr. John Braxton Suffield’s Affidavit) in support of the School District No. 5 application to adjourn a 10-day hearing scheduled for October 25, 2021 to November 5, 2021 before the British Columbia Human Rights Tribunal (BCHRT) in Ms. T’s matter. Dr. Westcott’s Affidavit and Dr. J. Braxton Suffield’s Affidavit were not only nearly verbatim identical, the two affidavits were also formatted the same way, sworn before the same notary public on the same day, and even included the same verbatim sworn statement that each affiant arrived to the identical conclusion over the same Thanksgiving holiday weekend. Moreover, both affidavits are formatted in similar if not identical ways as all other affidavits filed by the School District No. 5 lawyers in the same matter.
To illustrate, Dr. Westcott and Dr. Suffield swore verbatim identical statements, each in their respective affidavits:
Over the Thanksgiving holiday weekend, given all of the above, I concluded that the time required to respond to the Second College Complaint will interfere with my preparation for, assistance with and attendance at the Hearing.
Dr. Westcott’s Affidavit, dated October 13, 2021, para 19 & Dr. Suffield’s Affidavit, dated Octoer 13, 2021, para 18
Coincidence? Telepathy? Collusion? School District No. 5/their lawyers drafting the affidavits for both of their “independent” experts?
The two nearly identical affidavits
Here are Dr. Suffield’s and Dr. Westcott’s affidavits, side by side to demonstrate that they are nearly verbatim identical:
| Dr. Braxton J. Suffield’s Affidavit, sworn on October 13, 2021 | Dr. Mary Westcott’s Affidavit, sworn on October 13, 2021 |
| I, John Braxton Suffield, Ph.D., R. Psych, of [street address redacted], in the City of Calgary, Province of Alberta, MAKE OATH AND SAY AS FOLLOWS: | I, Mary Westcott, Ph. D., R. Psych, of [street address redacted], in the City of Calgary, Province of Alberta, MAKE OATH AND SAY AS FOLLOWS: |
| 1. I am a registered psychologist in the Province of Alberta. | also hold professional certifications with the Canadian Register of Health Service Providers in Psychology and a Certificate of Professional Qualification in Psychology issued by the Association of State and Provincial Psychology Boards. | maintain a private practice at Dr. J. B. Suffield & Associates, consisting primarily of medical-legal and insurance company referrals of brain injured persons. | 1. l am a registered psychologist in the Province of Alberta with the College of Alberta Psychologists. | am a Senior Psychologist and the Alberta Government Contracts Manager at Mandel and Associates, Ltd. In this role | provide psychological, vocational, psycho-educational, cognitive, and disability assessment services to adults living with a variety of mental health, developmental, learning, attention, social, intellectual, neurological, and/or mental challenges. |
| 2. | have been retained by the Respondent to provide expert evidence in the above-noted British Columbia Human Rights Tribunal complaint filed by the Complainant, Ms. T (the “Complaint’). My involvement in this matter includes both the submission of written reports and serving as a witness at the hearing currently scheduled from October 25, 2021 through November 5, 2021 (the “Hearing”). | 2. I have been retained by the Respondent to provide expert evidence in the above-noted British Columbia Human Rights Tribunal complaint filed by the Complainant, Ms. T (the “Complaint”). My involvement in this matter includes both the submission of written reports and serving as a witness at the hearing currently scheduled from October 25, 2021 through November 5, 2021 (the “Hearing”). |
| 3. | have submitted the following reports in this matter: a) December 30, 2011 Initial Report following my psychological assessment of the Complainant (the “December 30, 2011 Report”); and b) August 26, 2021 Response to Dr. L’s July 25, 2021 Report (the “August 26, 2021 Response”); and c) September 27, 2021 Reply to Dr. G’s September 8, 2021 Rebuttal Comments. | 3. | have submitted the following reports in this matter: a) September 15, 2010 Initial Report following my psychological assessment of the Complainant (the “September 15, 2010 Report”); b) August 25, 2021 Response to Dr L’s July 25, 2021 Report (the “August 25, 2021 Response”); and c) September 21, 2021 Reply to Dr. G’s September 8, 2021 Rebuttal Comments. |
| 4. On March 18, 2021, a 725-page complaint was filed against me with the College of Alberta Psychologists (the “College”) (the “First College Complaint”). The College complaint process is confidential, and therefore | am unable to disclose the materials in the complaint. However, | can generally state that it relates to the psychological assessment that formed the basis of the December 30, 2011 Report. This complaint remains pending before the College. | 4. On February 4, 2021, a complaint was filed against me with the College of Alberta Psychologists (the “College”) (the “First College Complaint”) The College complaint process is confidential, and therefore | am unable to disclose the materials in the complaint. However, | can generally state that it relates to the psychological assessment that formed the basis of the September 15, 2010 Report. This complaint remains pending before the College. |
| 5. On October 1, 2021, a second, 197-page complaint was filed against me with the College (the “Second College Complaint”) by Ms. T. While | am unable to disclose the materials in the complaint, | can state that it raises allegations of unprofessional conduct surrounding my use of the December 30, 2011 Report at the Human Rights Tribunal hearing, and raises additional allegations of unprofessional conduct relating to my August 26, 2021 Response. | 5. On October 1, 2021, a second, 72-page complaint was filed against me with the College (the “Second College Complaint”) by Ms. T. While | am unable to disclose the materials in the complaint, | can state that the second complaint raises allegations of unprofessional conduct related to my use of the September 15, 2010 Report at the Human Rights Tribunal hearing and additional allegations of unprofessional conduct relating to the August 25, 2021 Response. |
| 6. The First College Complaint and the Second College Complaint (together, the “College Complaints”) are substantively very similar to Dr. L’s and Dr. G’s reports in this Complaint proceeding, in which they critique the December 30, 2011 Report and the August 25, 2021 Response. | 6. The First College Complaint and the Second College Complaint (together, the “College Complaints”) are substantively very similar to Dr. L’s and Dr. G’s reports in this Complaint proceeding, in which they critique the September 15, 2010 Assessment and Report and the August 25, 2021 Response. |
| 7. My response to the Second College Complaint is due on Monday, November 1, 2021. | 7. My response to the Second College Complaint is due on Monday, November 1, 2021. |
| 8. To respond to the Second College Complaint, | will need to prepare a written response to the College addressing each of the numerous allegations raised in the complaint. | 8. To respond to the Second College Complaint, | will need to prepare a written response to the College addressing each of the numerous allegations raised in the complaint. |
| 9. I may require between 30 and 60 days to adequately respond to the Second College Complaint given the breadth of allegations and material in the complaint. It cites voluminous reference materials that must be reviewed, and raises numerous allegations of unprofessional conduct which will require an extensive commitment of time to adequately address. | 9. | may require between 30 and 60 days to adequately respond to the Second College Complaint given my current caseload, the breadth of allegations and material in the complaint. It cites voluminous reference materials that must be reviewed, and raises numerous allegations of unprofessional conduct which will require an extensive commitment of time to adequately address. |
| 10. Following submission of my response to the Second College Complaint, the College will conduct an investigation into the allegations. | will be required to prepare for and attend an investigation interview with an assigned investigator and may be required to prepare additional supplemental responses and materials pursuant to information arising from the interviews or if requested by the investigator. Following conclusion of the investigation, | may be further required to prepare a response to the contents of the investigation report | 10. Following submission of my response to the Second College Complaint, the College will conduct an investigation into the allegations. | will be required to prepare for and attend an investigation interview with an assigned investigator and may be required to prepare additional supplemental responses and materials pursuant to information arising from the interviews or if requested by the investigator. Following the conclusion of the investigation, | may be further required to prepare a response to the contents of the investigation report. |
| 11. There are significant professional consequences that may arise relating to the Second College Complaint. Ms. T is seeking revocation of my practice permit, which is the most serious penalty that may be issued by a professional regulatory body. Other potential penalties include practice restrictions or a suspension of a practice permit. As a result, responding fully and completely to the Second College Complaint is of the highest professional priority. | 11. There are significant professional consequences that may arise relating to the Second College Complaint. Ms. T is seeking the revocation of my practice permit, which is the most serious penalty that may be issued by a professional regulatory body. Other potential penalties include practice restrictions or a suspension of a practice permit. As a result, responding fully and completely to the Second College Complaint is of the highest professional priority. |
| 12. While | am hopeful the College Complaints will be dismissed by the College, the complexity of the complaints requires a significant investment of professional and personal time to adequately defend. | 12. While | am hopeful the College Complaints will be dismissed by the College, the complexity of the complaints require a significant investment of professional and personal time to adequately defend. |
| 13. After receiving and reviewing the Second College Complaint, | consulted with counsel, reviewed my ongoing professional obligations, considered the amount of time it will take to respond to the Second College Complaint, and took into account the time | would need to devote to preparing for and attending the Hearing in this matter. | 13. After receiving and reviewing the Second College Complaint, | consulted with counsel, reviewed my ongoing professional obligations, considered the amount of time it will take to respond to the Second College Complaint and took into account the time | would need to devote to preparing for and attending the Hearing in this matter. |
| 14. | have significant concern about my ability to prepare for the Hearing and assist the Respondent in its preparation for the Hearing given the complexity of the Second College Complaint and the time required to adequately prepare my response | 14. I have significant concern about my ability to prepare for the Hearing and assist the Respondent in its preparation for the Hearing given the complexity of the Second College Complaint and the time required to adequately prepare my response. |
| 15. Given my experience in this matter, | estimate it will require 60 hours to prepare for the Hearing.This estimate includes: a) reviewing the three reports | drafted and the data, materials and assessments on which | relied in forming my opinions; b) reviewing Dr. L’s and Dr. G’s responses to my initial report, and the underlying data and materials on which each relied: c) meeting with Respondent to prepare for my testimony and for the cross examinations of the Complainant’s experts. | 15. Given my experience in this matter, I estimate it will require 15 hours to prepare for the Hearing. This estimate includes: a) reviewing the three reports | drafted and the data, materials and assessments on which | relied in forming my opinions; b) reviewing Dr. L’s and Dr. G’s responses to my initial report, and the underlying data and materials on which each relied; and c) meeting with Respondent to prepare for my testimony and for the cross examinations of the Complainant’s experts. |
| 16. I also have numerous ongoing obligations to my practice that also must occur in this time frame. In the next month, my additional obligations require approximately 40 hours of work per week. | |
| 16. My involvement during the Hearing will also require significant time, including: a) Being available during the testimony of Dr. XXX and Dr. XXX on October 26, 27 and 28, respectively, in order to provide assistance to Respondent in preparation for cross-examination; and b) Testifying on direct and cross examination during the week of November 1, 2021, which is the same time my response to the Second College Complaint is currently due. | 17. My involvement during the Hearing will also require considerable amount time, including: a) Being available during the testimony of Dr. XXX and Dr. XXX on October 26, 27 and 28, respectively, in order to provide assistance to Respondent in preparation for cross-examination; and b) Testifying on direct and cross examination during the week of November 1, 2021, which is the same time my response to the Second College Complaint is currently due. |
| 17. Further, | have significant professional concerns about testifying in this matter. | will be testifying while the College Complaints remain pending against me and simultaneously with the submission of my response. | will be examined by the representative for the individual who filed these complaints against me. | also acknowledge the potential for further complaints based on my testimony. | 18. Further, | have significant professional concerns about testifying in this matter. | will be testifying while the College Complaints remain pending against me and simultaneously with the submission of my response. | will be examined by the representative for the individual who filed these complaints against me. | also acknowledge the potential for further complaints based on my testimony. |
| 18. Over the Thanksgiving holiday weekend, given all of the above, | concluded that the time required to respond to the Second College Complaint will interfere with my preparation for, assistance with and attendance at the Hearing. | 19. Over the Thanksgiving holiday weekend, given all of the above, | concluded that the time required to respond to the Second College Complaint will interfere with my preparation for, assistance with and attendance at the Hearing. |
| 19. I make this affidavit in support of the Respondent’s Adjournment Application. | 20. I make this affidavit in support of the Respondent’s Adjournment Application. |
The two affidavits are nearly verbatim identical. The probability that these two affidavits were written independently by Dr. Westcott and Dr. Suffield, respectively, is essentially zero.
Who plagiarized their sworn testimony from whom?
On their face, the two affidavits raise a question: Who plagiarized their sworn testimony from whom?
Did Dr. Westcott plagiarize her testimony from Dr. Suffield? Did Dr. Suffield plagiarize his testimony from Dr. Westcott? Did Dr. Suffield and Dr. Westcott plagiarize their testimony from someone else? Did someone else prepare their testimony for them to swear? Did Dr. Westcott and Dr. Suffield parroted testimony prepared for them by someone else, for example, by the School District No. 5 or perhaps by the School District No. 5 lawyers? Neither affidavit indicated that the testimony was copied verbatim from someone else or somewhere else. Neither affidavit quoted nor cited sources of the sworn testimony.
Drs. Westcott and Suffield hired a lawyer, Ms. Shayla Stein, from Gowling WLG (Canada) LLP. According to the letter written by Ms. Stein on May 16, 2022, on behalf of Dr. Westcott, School District No. 5 “assisted Dr. Westcott with drafting an affidavit”:
… SD5 [School District No. 5] assisted Dr. Westcott with drafting an affidavit in support of an adjournment of the BCHRT hearing. Dr. Westcott swore her affidavit in support of an adjournment on October 13, 2021.
Letter from Ms. Shayla Stein, dated May 16, 2022, on behalf of Dr. Westcott
Similarly, according to another letter written by Ms. Shayla Shein on May 16, 2022, on behalf of Dr. Suffield, School District No. 5 “assisted Dr. Suffield with drafting an affidavit”:
… SD5 [School District No. 5] assisted Dr. Suffield with drafting an affidavit in support of an adjournment of the BCHRT hearing. Dr. Suffield swore his affidavit in support of an adjournment on October 13, 2021.
Letter from Ms. Shayla Stein, dated May 16, 2022, on behalf of Dr. Suffield
Ergo, more than six months after swearing their affidavits Ms. Stein disclosed that the School District No. 5 “assisted” both Dr. Westcott and Dr. Suffield “with drafting an affidavit” — verbatim nearly identical affidavits. One may wonder how independent these two “independent” experts are from each other as well as from the School District No. 5. It may be that Drs. Westcott and Suffield’s testimony was prepared for them by the School District No. 5, word by word, and that Drs. Westcott and Suffield swore them to be true regardless of what those two affidavits actually stated. The similarity of text, formatting, font, etc. strongly suggests that that is what happened, that both affidavits were prepared by the School District No. 5 or by the School District No. 5 lawyers, provided to Drs. Westcott and Suffield, and Drs. Westcott and Suffield hurried to the same notary public and swore them there on October 13, 2021.
Falsely sworn statements in Dr. Westcott and Dr. Suffield’s affidavits
Dr. Westcott’s and Dr. Suffield’s affidavits included numerous falsely sworn statements:
- Dr. Westcott swore (para 4): “On February 4, 2021, a complaint was filed against me with the College of Alberta Psychologists (the “College”) (the “First College Complaint”)…” Dr. Westcott’s sworn statement was false. The first complaint against Dr. Westcott was filed on January 14, 2021, that is, about three weeks earlier.
- Dr. Suffield swore (para 4): “On March 18, 2021, a 725-page complaint was filed against me with the College of Alberta Psychologists (the “College”) (the “First College Complaint”).’ Dr. Suffield’s sworn statement was false. The first complaint against Dr. Suffield was filed on March 8, 2021 via email to the College of Alberta Psychologists, that is, 10 days earlier than Dr. Suffield swore.
- Dr. Westcott swore (para 5): “On October 1, 2021, a second, 72-page complaint was filed against me with the College (the “Second College Complaint”) by Ms. T. …” Dr. Westcott’s sworn statement was false. The second complaint against Dr. Westcott was filed on September 27, 2021, that is, several days earlier.
- Dr. Suffield swore (para 5): “On October 1, 2021, a second, 197-page complaint was filed against me with the College (the “Second College Complaint”) by Ms. T. …” Dr. Suffield’s sworn statement was false. The second complaint against Dr. Suffield was filed on September 23, 2021, about a week earlier.
- Dr. Westcott swore (para 6): “The First College Complaint and the Second College Complaint (together, the “College Complaints”) are substantively very similar to Dr. L’s and Dr. G’s reports in this Complaint proceeding, in which they critique the September 15, 2010 Assessment and Report and the August 25, 2021 Response.” Dr. Westcott’s sworn statement is false. For example, the first college complaint was filed against Dr. Westcott months before Dr. L and Dr. G filed their reports critiquing Dr. Westcott’s reports. Second, the first and second college complaints raise many more issues than the issues raised in Dr. L’s and Dr. G’s reports.
- Dr. Suffield swore (para 6): “The First College Complaint and the Second College Complaint (together, the “College Complaints”) are substantively very similar to Dr. L’s and Dr. G’s reports in this Complaint proceeding, in which they critique the December 30, 2011 Report and the August 25, 2021 Response.” Dr. Suffield’s sworn statement is false. For example, the first college complaint was filed against Dr. Suffield months before Dr. L and Dr. G filed their reports critiquing Dr. Suffield’s reports. Second, the first and second college complaints raise many more issues than the issues raised in Dr. L’s and Dr. G’s reports.
Why all of these falsehoods in Dr. Westcott’s and Dr. Suffield’s affidavits?
False statements or an “error in terminology”?
In letters to the College of Alberta Psychologist’s investigator, Ms. Shayla Stein falsely asserted that Drs. Westcott and Suffield’s falsely sworn statements were not false, they were “error[s] in terminology.” For example, Ms. Stein wrote:
Dr. Suffield consulted with myself [Ms. Shayla Stein] and counsel for SD5 regarding strategy for navigating the parallel human rights hearing and CAP [College of Alberta Psychologists] complaint processes… Accordingly, SD5 assisted Dr. Suffield with drafting an affidavit…
…
Ms. T’s allegations in her January 4, 2022 materials are frivolous and vexatious. The affidavit sworn by Dr. Suffield was not ‘false’. It is standard practice to have legal counsel prepare an affidavit on behalf of an affiant. Dr. Suffield accurately cited dates he received complaint materials from Ms. T, albeit the term ‘filed’ was incorrectly used in relation to these dates. This error in terminology is frivolous and inconsequential…
Letter from Ms. Shayla Stein, dated May 16, 2022
Ms. Stein appears to have some difficulties in understanding the English language, understanding factual information, and/or expressing herself in plain English.
First, Dr. Suffield swore, for example: “On February 4, 2021, a complaint was filed against me with the College of Alberta Psychologists (the “College”) (the “First College Complaint”)” Since the complaint was not filed on February 4, 2021, Dr. Suffield’s sworn statement was factually false. In Ms. Stein-speak, a factually wrong date was used “in relation” to the event of filing the complaint. In plain English: Dr. Suffield’s sworn statement was false.
Second, Ms. Stein made false statement herself in a failed attempt to explain Dr. Suffield’s falsehoods and wrote: ” Dr. Suffield accurately cited dates he received complaint materials from Ms. T.” The factual reality is that Dr. Suffield never received “complaint materials from Ms. T”. Dr. Suffield received “complaint materials” from the College of Alberta Psychologists, sometime after Ms. T filed the complaints against Dr. Suffield with the College of Alberta Psychologists.
Using the Stein-speak, one may imagine a lawyer explaining her client’s falsely sworn alibi to the Court as follows (this example is fictitious for illustrative purposes only):
Your Honour my client’s sworn alibi that on the date of the murder she was in Germany [and not in Calgary] was not false, albeit the term “Germany” was incorrectly used in relation to the date of murder. On the date of the murder, my client was in fact in Calgary. This error in terminology is frivolous and inconsequential.
Stein-speak like explanation for falsely sworn murder alibi (a fictitious example)
Falsely-sworn affidavit statements are almost always consequential
Explicitly relying on the false but at the time not yet sworn affidavits, the SD5 lawyer made the following statements in his submissions to the Tribunal on behalf of the SD5:
16. On February 3, 2021, the Respondent [SD5] filed its Witness List with the Tribunal, and provided a copy to Dr. Uttl. On its Witness List, the Respondent indicated that it would be calling the Expert Witnesses [Dr. Westcott and Dr. Suffield were on the list but they were NOT identified as expert witnesses]
17. On February 4, 2021 and March 18, 2021, shortly after receiving the Respondent’s Witness List, the Complainant filed complaints (the “First College Complaints”) with the College against Dr. Suffield as well as Dr. Westcott…
Application to Adjourn, dated October 12, 2021, signed by the SD5 lawyer
Quite clearly, the SD5 submission was false. The Complainant filed the First College Complaint against Dr. Westcott three weeks earlier, and not “shortly after receiving the Respondent’s Witness List” as falsely submitted by the SD5 lawyer to the Tribunal.
Relying on the SD5 false submissions and Dr. Westcott’s and Dr. Suffield’s falsely sworn affidavits, the Tribunal ended up confused by the false submissions and affidavits and wrote:
In February 2021, the District filed and exchanged its witness list wherein the District indicated it would be calling the Expert Witnesses [Drs. Westcott and Suffield] to testify at the hearing.
Upon receiving the District’s witness list [emphasis added], Ms. T filed complaints with the College of Alberta Psychologists [College] against the Expert Witnesses in January and March 2021 [First College Complaints]…
The Tribunal’s Decision, dated October 19, 2021
Ms. T filed the 1st complaint against Dr. Westcott on January 14, 2021, that is weeks before she received the SD5’s witness list in February 2021, and months before the SD5 informed the Tribunal and Ms.T that Drs. Westcott and Suffield would be called as “expert witnesses”. Accordingly, Ms. T did not file the 1st complaint against Dr. Westcott “Upon receiving the District’s witness list….” but weeks before. Misled by the SD5’s submissions and Dr. Westcott’s affidavit, the Tribunal’s finding was simply incorrect.
Moreover, Drs. Westcott and Suffield were on notice that the complaints against them would be forthcoming since 2018. For example, Ms. T attempted to meet with Dr. Westcott in 2018 to give her a chance to correct her errors or retract her report. Unfortunately, Dr. Westcott made herself unavailable. Ms. T even sent a copy of her email to Dr. Westcott to the College of Alberta Psychologist at that time, detailing many errors that Dr. Westcott made. At the time, back in 2018, Dr. Westcott advised Ms. T that she would not correct her report, would not issue any addendum, and that Ms. T is welcome to subpoena Dr. Westcott to testify and be cross-examined. Verbatim, Dr. Westcott wrote:
September 27, 2018
Dear Ms. T,
Thank you for your email dated September 18, 2018. I confirm that the report dated 15 September, 2010 accurately reflect my professional opinion. I am not in a position to change my report or my opinion nor provide an addendum. My report serves as my opinion. If you feel it is relevant to your legal proceedings, you are welcome to subpoena me to testify and to be cross-examined under oath regarding my opinion.
Sincerely,
Mary Westcott, Ph.D. R. Psych. (AB#3405),
Dr. Mary Westcott, September 27, 2017
Senior Psychologist, Alberta Government Contracts Manager [in Mandel & Associates Ltd.]
Of note, as of now, Dr. Westcott is halfway through her cross-examination.
Critically, the College of Alberta Psychologists requires registrants to keep records for ten years from the last client contact. Dr. Westcott’s September 15, 2010 Report set the first milestone to count 10 years from. However, when Ms. Cynthia Stuart (SD5) asked Dr. Westcott for advice on how to deal with another psychologist’s report that came to opposite conclusions to that of Dr. Westcott, the milestone to count ten years from was moved to February 2011. Accordingly, Ms. T filed the first college complaint on January 14, 2021, approximately 14 days short of the ten years requirement for Dr. Westcott to keep her records. Clearly, Ms. T could not wait any longer for Dr. Westcott to come to her senses and either make extensive correction to her September 15, 2010 Report or to withdraw it.
The SD5 and their lawyers’ submission that Ms. T filed her complaints “shortly after receiving the Respondent’s Witness List.” were false.
Coincidence, telepathy, or collusion?
Both Dr. Westcott and Dr. Suffield swore that they arrived to the same conclusion over the same Thanksgiving holiday weekend:
Over the Thanksgiving holiday weekend, given all of the above, I concluded that the time required to respond to the Second College Complaint will interfere with my preparation for, assistance with and attendance at the Hearing.
Dr. Westcott’s Affidavit, para 19, and Dr. Suffield’s Affidavit, para 18
Did Dr. Westcott and Suffield arrive to the same conclusions over the same Thanksgiving holiday weekend due to coincidence, telepathy, or collusion? Coincidence appears unlikely given the nearly identical wording of Drs. Westcott’s and Suffield’s affidavits and given identical wording of Drs. Westcott’s and Suffield’s “conclusion” paragraph. The coincidence explanation is about as likely as observing a cow jumping over the moon. Furthermore, if Ms. Stein’s statements are true, Ms. Stein’s statements that School District No. 5 assisted both Dr. Westcott and Suffield in drafting their affidavits make the coincidence explanation also extremely unlikely.
The telepathy explanation also appears extremely unlikely. No one has yet scientifically demonstrated “communication from one mind to another by extrasensory means” (https://www.merriam-webster.com/dictionary/telepathy)
Accordingly, the only viable explanation appears to be some type of collusion among School District No. 5, Dr. Westcott and Dr. Suffield. According to the letters by Ms. Shayla Stein, Dr. Westcott’s as well as Dr. Suffield’s lawyer, Dr. Suffield and Dr. Westcott consulted with both Ms. Shayla Stein and “counsel for the SD5” “regarding strategy for navigating the parallel human rights hearing and CAP complaint processes” and “SD5 assisted” both Dr. Suffield and Dr. Westcott “with drafting” their affidavits. Were Dr. Suffield, Dr. Westcott, Ms. Stein, the SD5, and the SD5 lawyer on one zoom call strategizing? Presently, the nature of the meeting or meetings among these parties resulting in the SD5 assisting “with drafting” Dr. Westcott and Dr. Suffield’s affidavits is unknown. Does it amount to collusion, that is, “secret agreement or cooperation” among Dr. Westcott, Dr. Suffield, and the SD5? It appears so. However, Ms. Stein herself lacks credibility given that she falsely stated that Drs. Westcott and Suffield “received the complaint materials from Ms. T [patently false].”
Perhaps Dr. Westcott and Dr. Suffield will come up with some other ingenious explanation for their verbatim nearly identical affidavits.