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No  112-51-974\nCOURT OF APPEAL FOR ONTARIO\nBETWEEN:\nTHE ATTORNEY GENERAL OF ONTARIO\n(Appellant)\n- and -\nNINO BROWN\n(Respondents)\n________________________________________________________\nAPPELLANT’S / RESPONDENT’S FACTUM\n(Select One)\n________________________________________________________\nNAME OF LAW FIRM\nAddress of law firm\nNames of Counsel (Include First and Last Names)\nOf Counsel for the Appellant / Respondent (select one)\nTelephone:\nFax:\nEmail:\nPART I:\nINTRODUCTION\nThis case is about [insert a short summary of the main issue raised by this appeal].\nPART II:\nSUMMARY OF THE FACTS [do not alter]\nOn August 1, 2020, Nino Brown was arrested outside of ‘The Old Jack’ and charged with assault with a weapon under section 267(a) of the Code and being in care or control of a vehicle while intoxicated contrary to section 320.14(1) of the Code.\nThe Crown opposed his release from custody on the basis that he was likely to commit further offences and that pre-trial detention was therefore necessary for the protection of the public. Following a contested bail hearing, Mr. Brown was granted interim judicial release under section 515 of the Code, subject to certain conditions as specified by the bail judge.\nMr. Brown’s release was subject to the following conditions:\nThe accused will post a no cash bail of $3000 and report to a bail supervisor within two days of release from the remand centre and thereafter as directed.\nThe accused will remain in the province of Ontario unless consent is granted by his bail supervisor.\nThe accused will not attend any licensed establishment that serves alcohol.\nThe accused will not possess or consume alcohol or any non-prescribed controlled substances during the term of his release, except within the confines of his home.\nThe accused will be subject to a curfew of 10:00 pm.\nThe accused will present himself at the door of his residence for any bail supervisor or peace officer who attends to confirm his compliance with his curfew.\nOn October 28, 2020, police attended “The Old Jack” on an unrelated matter and found Mr. Brown in breach of his condition to not attend licensed establishments and to abstain from alcohol outside his home under the terms of his release. Mr. Brown was arrested under section 145(5) of the Code and remanded into custody.\nIn December 2020, the Crown stayed Mr. Brown’s charge of assault with a weapon.\nMr. Brown pleaded not guilty to the charge of failure to comply with the conditions of his release. He argues that the conditions of his bail, and in particular the prohibition on possession or consumption of alcohol outside the home:\nViolate his equality rights under section 15 of the Charter;\nViolate his right not to be denied reasonable bail without just cause under subsection 11(e) of the Charter; and\nAre not reasonable limits prescribed by law that can be demonstrably justified in a free and democratic society, per section 1 of the Charter.\n[This is where you will need to summarize the trial judge’s decision, by explaining how Justice Siddiqui decided on each of the Charter issues.  All quotes should be indented and single-spaced (like this paragraph).  They must be referenced immediately after the paragraph, noting the page or paragraph number of the quote.]\nPART III\nGROUNDS OF APPEAL\nIssue 1: Do the bail conditions imposed under s. 515(4) of the Criminal Code violate Mr. Brown’s equality rights as a person with a disability under s. 15 of the Charter?\n[Insert your firm’s argument on this issue.  Refer to the explanatory notes, How to Prepare a Factum, for information on how to refer to cases and how to structure your argument.]\nIssue 2: Do the bail conditions imposed under s. 515(4) of the Criminal Code violate Mr. Brown’s right to reasonable bail as set out in s. 11(e) of the Charter?\n[Insert your firm’s argument on this issue.  Refer to the explanatory notes, How to Prepare a Factum, for information on how to refer to cases and how to structure your argument.]\nIssue 3: If the ","cbCain1N2tXs2u3u","https://ap.wps.com/l/cbCain1N2tXs2u3u","docx",22462,6,"English","# PART I: INTRODUCTION\n# PART II: SUMMARY OF THE FACTS\n# PART III: GROUNDS OF APPEAL\n## Issue 1: Equality rights under s. 15\n## Issue 2: Reasonable bail under s. 11(e)\n## Issue 3: Justification under s. 1\n# PART IV: ORDER REQUESTED\n# APPENDIX A: AUTHORITIES TO BE CITED","[{\"question\":\"What is the purpose of this factum template for C.A. No 112-51-974?\",\"answer\":\"It organizes an appellate argument for the Ontario Court of Appeal, covering introduction, facts, Charter-based grounds of appeal, and the requested order, with an appendix for authorities.\"},{\"question\":\"What key facts and bail conditions should be summarized in Part II?\",\"answer\":\"The template summarizes the arrest, the interim release under s. 515, the specific bail conditions imposed, and a later alleged breach leading to remand, along with any subsequent procedural developments.\"},{\"question\":\"What are the grounds of appeal outlined in Part III?\",\"answer\":\"It sets out three issues: equality rights under s. 15, reasonable bail under s. 11(e), and whether any infringement can be demonstrably justified under s. 1.\"}]","C.A. No 112-51-974 - Appellant’s / Respondent’s Factum Template | DOCX"]