DAMAGES CALCULATOR

500-06-001298-245 — Perez c. Procureur Général du Québec

THE FORMULA (¶46 Modified Statement of Claim)

$1,500 × days deprived × members = compensatory

Plus $2,000,000 punitive damages (¶48)

⚖ ESTABLISHED FACTS — FROM THE COURT RECORD

EDM Daily Population
1,250–1,300 inmates
Sworn testimony, Director J-F Gagnon, Sept 14, 2023
Class Period
1,566 days
Jan 1, 2022 → present (Apr 16, 2026)
Proven Deprivation — Danny
65.9% (141/214 days)
Exhibit P-2, accepted by Court
Proven Deprivation — Post-Transfer
81.3% (26/32 days)
Exhibit P-7, B-8 sector Nov–Dec 2023
Habeas Corpus Orders Violated
2 orders
Sept 14, 2023 + Oct 27, 2023 — J. Perreault
Systemic Problem Documented Since
2016
Protecteur du citoyen annual reports (P-9, P-10)
Current Registered Members
~200
Examination of D. Perez, Feb 13, 2026
Section B-8 Capacity
~40 cells
"40 portes" — D. Perez testimony, Feb 13, 2026

⏱ DEPRIVATION TIMELINE

The class period runs from Jan 1, 2022 to the final judgment. Every day the violation continues, damages accumulate.

1,566 days and counting
Jan 1, 2022 Danny enters EDM (Mar 31, 2023) Habeas Corpus (Sept/Oct 2023) Today
Scenario 1 — Personal

Danny William Perez — Personal Claim

The representative plaintiff's individual compensatory damages.

Days deprived (proven, P-2) 141 days
Rate per day (¶46) $1,500
Danny's Compensatory $211,500
Scenario 2 — Sector B-8 Only

Proven Period × Section Capacity

~40 inmates in Danny's section, same 141 days of proven deprivation.

Section inmates ~40
Days deprived per inmate 141 days
Person-days of deprivation 5,640
Sector B-8 Compensatory $8.5 MILLION
Scenario 3 — As Currently Filed

~200 Registered Members + Punitive

Based on current membership roster, conservative average of 100 deprived days each.

Registered members 200
Average deprived days (conservative) 100 days
Compensatory (200 × 100 × $1,500) $30.0 MILLION
Punitive (¶48, as filed) $2,000,000
Current Exposure $32.0 MILLION
KEY INFLECTION POINT: Once the government provides the full list of all persons incarcerated at EDM since January 1, 2022 (as demanded in Undertaking E-7 of the Feb 13, 2026 examination), the membership rolls will explode from ~200 to potentially thousands. The next three scenarios show what happens.
Scenario 4 — Full Class, Conservative

All EDM × 50% Deprivation Rate × Full Period

Applying a conservative 50% deprivation rate to the entire facility for the full class period.

EDM daily population 1,275
Deprivation rate (conservative) 50.0%
Class period 1,566 days
Total person-days of deprivation 998,325
Compensatory (person-days × $1,500) $1.50 BILLION
Full Class Exposure (50%) $1.50 BILLION
Scenario 5 — Full Class, As Proven

All EDM × 65.9% Deprivation × Full Period

Using Danny's proven deprivation rate across the entire facility.

EDM daily population 1,275
Deprivation rate (proven, P-2) 65.9%
Class period 1,566 days
Total person-days of deprivation 1,315,593
Compensatory $1.97 BILLION
Full Class Exposure (65.9%) $1.98 BILLION
Scenario 6 — Full Class, Worsened Rate

All EDM × 81.3% Deprivation × Full Period

Using the worsened post-transfer rate documented in P-7. After two court orders and Danny's departure, the situation got worse.

EDM daily population 1,275
Deprivation rate (P-7) 81.3%
Class period 1,566 days
Total person-days of deprivation 1,622,278
Compensatory $2.43 BILLION
Maximum Exposure (81.3%) $2.44 BILLION
WHY IT GOES TO BILLIONS: The class definition covers every person at EDM since Jan 1, 2022. The EDM holds 1,250–1,300 inmates at any time. Every single day the deprivation continues, that's ~840 person-days added at the proven 65.9% rate. At $1,500/day, that's $1,260,146/day in accumulating damages.

The problem was documented by the Protecteur du citoyen since 2016. Two habeas corpus orders were issued and both violated. The government transferred Danny instead of fixing the problem. The deprivation rate after Danny left increased from 65.9% to 81.3%.

⚡ CUSTOM CALCULATOR

Adjust the inputs to model different scenarios.

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⚠ AGGRAVATING FACTORS FOR PUNITIVE DAMAGES

Two Court Orders Violated
Sept 14 + Oct 27, 2023
The government defied its own judiciary — twice
Retaliation by Transfer
Oct 31, 2023
Danny transferred to Sorel-Tracy days after second order
Systemic Negligence
10+ years documented
Protecteur du citoyen annual reports since 2016
Situation Worsened After Orders
65.9% → 81.3%
Deprivation INCREASED after two court orders
Government Admission
"l'article 10 n'est pas respecté"
AG Me Reny, Sept 14, 2023 habeas corpus hearing
International Law Violated
Nelson Mandela Rules 23 & 42
UN minimum standards for treatment of prisoners
THE PICTURE: Danny originally asked for $1,000/day during the first habeas corpus hearing (Sept 14, 2023). The Modified Statement of Claim raised it to $1,500/day. The punitive damages were filed at $2,000,000.

Danny told the court on Feb 13, 2026: "Les dommages punitifs vont changer, dès que j'ai le nouveau nombre de membres, vers la fin." ("The punitive damages will change once I have the new number of members, toward the end.")

The government was ordered to provide the complete list of all persons at EDM since January 2022 (Undertaking E-7). When that list arrives, the true scale of this case will be revealed.

📋 SOURCE DOCUMENTS

  1. Modified Statement of Claim — Jan 15, 2026, ¶46 ($1,500/day), ¶48 ($2M punitive)
  2. Exhibit P-2 — Compilation table: 141/214 days deprivation (65.89%)
  3. Exhibit P-7 — Post-transfer compilation: 26/32 days deprivation (81.25%)
  4. Habeas Corpus #1 — 760-36-000897-234, Sept 14, 2023 (J. Perreault)
  5. Habeas Corpus #2 — 760-36-000905-235, Oct 27, 2023 (J. Perreault)
  6. Sworn testimony — Director J-F Gagnon: 1,250–1,300 inmates, 531 agents
  7. Examination of D. Perez — Feb 13, 2026 by Me Marie-Hélène Hébert (PGQ)
  8. Protecteur du citoyen — Annual reports 2016-2017 (P-9) and 2022-2023 (P-10)
  9. Authorization judgment — Dec 12, 2024, J. Granosik (class definition)

Calculated by Alfred — lavocat.ca

All figures derived from the court record. Updated in real time as the class period extends.

Generated April 16, 2026 at 23:13 UTC

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Alfred
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