Ramsden Place Uses Suicide Crisis to Force Permanent Relocation

Ramsden Place and David Ciobotaru were denying an ongoing and severe noise disturbance in my unit WHILE they were repairing it in other units. This was so extreme that it caused suicidal ideation and exacerbation of health conditions. Once I was able to verify with other tenants that repairs were being offered in their units, management and David stopped responding to me. I was denied similar repairs in my unit for weeks despite suicidal ideation and functional homelessness, of which management was aware. Text exchanges with affected tenants who also found their homes uninhabitable to follow.

Dear XXXX

Your assertions that the Landlord is not accommodating you couldn’t be farther from the truth. The Landlord has taken your complaint seriously as they have engaged various contractors and they have even offered to permanently relocate you to a different unit away from the area your apartment is located in. Given that you have filed a T2/T6 with the Landlord and Tenant Board this matter is now before the courts and I will be providing you with the appropriate evidence/disclosure following the Rules and Procedures as outlined by the Landlord and Tenant Board. Once the investigation of your complaint is completed, I will advise you.

Once again, I urge you to comply with my request to communicate with me and me only regarding your noise complaint as I am the legal representative of your Landlord and in charge of this process.

Best Regards,

David Ciobotaru
Paralegal, LSUC# P00586
D & D ASSOCIATES Paralegal Professional Corp.

385 Connie Crescent, Ste. 102
Concord, ON L4K 5R2
905-881-5575 Ext. 227
905-882-5934 (Fax)
http://www.danddassociates.ca
This message is intended for the addressees only. It may contain confidential or privileged information. No rights to privilege have been waived. Any copying, retransmittal, taking of action in reliance on, or other use of the information in this communication by persons other than the addressees is prohibited. If you have received this message in error, please reply to the sender by e-mail and delete or destroy all copies of this message.

From: XXXX
Sent: February 21, 2025 4:07 PM
To: David Ciobotaru <davidciobotaru@danddassociates.ca>
Subject: Re: Critical Human Rights Violation

Dear David,

I acknowledge your request, but I will continue communicating with building management as needed regarding maintenance and habitability concerns – including the escalating issues causing increased noise.

Regarding your statement that several contractors have investigated and found no source of noise:

Please provide copies of all reports from these investigations, including:
- The dates of each inspection.
- The methodology used.
- The units and areas assessed.
- Any decibel readings or technical findings.
The ESA compliance order, based on video evidence from my unit, contradicts your assertion that no issue exists.
- You cannot simultaneously claim to be investigating while also claiming there is no issue.
- A government agency has already determined that there is an issue requiring action.
Your claim that temporary relocations only occurred 10 years ago does not absolve the landlord of their current duty to accommodate me.
- Human rights accommodations are assessed on a case-by-case basis, and past policies do not override legal obligations.
- The fact that the landlord has relocated tenants before directly contradicts prior statements that relocation is never an option.

Finally, your refusal to engage in a meaningful discussion regarding a reasonable, temporary accommodation—while simultaneously refusing to acknowledge the ESA’s compliance order—only further exposes the landlord’s liability.

I expect the full documentation of your contractor investigations by Tuesday, February 25, 2025.

—- On Fri, 21 Feb 2025 15:37:27 -0500 David Ciobotaru <davidciobotaru@danddassociates.ca> wrote —

Dear XXXX

In response to your email below, I would like to point out that given that I am the Landlord’s legal representative I hereby request that all communication pertaining to your initial complaint about noise in your apartment is now directed to me. Please cease and desist from communicating with John Zam, Rosie Middleton and Andrus Kung directly regarding this issue. You are free to communicate with the building management with any other day-to-day maintenance issues such as the one’s mentioned in your latest email and of course in the event of an emergency.

Regarding the allegation that the Landlord has done temporary relocation in the past, although there may be some truth to this as it happened about 10 years ago, the circumstances were completely different as the Tenants who were temporarily relocated had no vital services in their apartment, i.e., heat, water and even some cases electricity. I am told by my client that on a case such as yours, where there is a noise complaint and the complaint has been taken seriously and have hired several contractors to try to identify the source of the noise that you are complaining about and to this point without any success of identifying any noise and by extension any source of the noise.

The Landlord will endeavor to continue to try and identify the issue that you are complaining about and of course, if your complaint is verified it will be rectified, if possible.

Once again, thank you for your email and please comply with my request to communicate with me directly regarding the allegation of noise in your apartment.

Best Regards,

David Ciobotaru
Paralegal, LSUC# P00586
D & D ASSOCIATES Paralegal Professional Corp.

Sent: February 21, 2025 10:24 AM
To: jzam
Cc: Rosie Middleton ; akung David Ciobotaru
Subject: Re: Critical Human Rights Violation

John,

You need to consult a qualified human rights lawyer immediately. You also need to make sure they’re aware of building history because having a lawyer make verifiable false statements in writing is going to hurt your case when this goes before the LTB and the HRTO.

I do not accept a permanent relocation—your team has temporarily relocated tenants before, including Kat for pipe maintenance. This is legally documented in LTB records, so you cannot claim otherwise.

You also cannot deny that you are aware of serious issues affecting multiple units in my quadrant, including my own. The order to comply from the Electrical Safety Authority was issued based on video evidence from my unit. I have written confirmation of this from the ESA investigator, Steven Hermetz where he mentions the noise as part of the reason for the compliance notice.

A leading administrative authority is aware of problems within my unit based on evidence I presented, but you aren’t? And yet you claim to be working diligently on investigating? Do you genuinely not see the contradictions here? The tribunals will. There is no more denying a disturbance in my unit.

Tenants have reported concerns, I have witnesses, video evidence, and even your own lawyer’s assurances that you are ‘working on it.’ And an ESA compliance order based on evidence from my unit.

Why are so many other tenants reporting extreme disturbances similar to mine, including the tenant in ?
Why does the noise coincide with heating failures?
Why are half the tenants in the building without heat?
Why is my ceiling cracking?
Why did my bathroom sink pop out of the granite countertop?

There are undeniable and well-documented issues in the building, one symptom of which is noise. I have two medically documented and recognized disabilities that are exacerbated by noise. I also have documented impacts on my health directly linked to this issue. You have no excuse not to accommodate me. It doesn’t matter how bad you think the noise is. It matters how badly the noise is affecting me. And it is affecting me so severely that it is making me suicidal because of the way it’s exacerbating my neurological conditions and impacting my quality of life and ability to earn a living.

Forcing Me to Surrender My Lease Under Extreme Duress is Cruel

Attempting to coerce me into giving up my home while I am experiencing a housing crisis of your making is both cruel and illegal and is not a reasonable attempt at accommodation for what should be a temporary maintenance issue.

The only reason I need accommodation in the first place is because of your failure to maintain the building. Now, rather than addressing the problem, you’re trying to exploit my situation to permanently remove me from my apartment.

The fact that you’re trying to get me to give up my unit is also evidenced in your delay in addressing other maintenance issues, like the flooring and the cracked ceiling.

You are not offering me a solution, nor are you engaging in the accommodation process in good faith—you are attempting to take advantage of my desperation.

My Accommodation Request is Simple and Does Not Cause Undue Hardship

I am asking for a temporary relocation to a vacant unit while you resolve a deeply disruptive maintenance issue.

If you don’t want to move me within the building, then you can pay for accommodations elsewhere.

There is no undue hardship to the landlord in allowing me temporary access to an unoccupied unit—especially when you have temporarily relocated tenants in the past. Nor would it be undue hardship for the landlord to put me up in temporary accommodations outside the building.

Legal Violations

Forcing me to permanently vacate my unit in exchange for an accommodation is a direct violation of the Residential Tenancies Act (RTA) and my human rights.

This situation is already being documented with supporting evidence. If you continue blocking a reasonable, temporary accommodation, it will only increase the damages I am owed, including for alternative accommodations, harm, and discrimination.

Stop playing games that are harming me and ultimately the landlord and engage in a meaningful discussion about accommodation, which in this case would be a temporary move within the building or compensation for accommodations elsewhere. Permanently forcing me from my home and into a lower quality unit is not accommodating a disability. It is further discrimination at the sole benefit of the landlord. This is illegal.

There is no denying there is a problem in my unit given the ESA’s compliance order coming from evidence I submitted from my unit. You’ve already documented that you have a vacant unit immediately available. There are no excuses left. Move me today or further increase your damages. It’s that simple.

—- On Fri, 21 Feb 2025 08:53:49 -0500 David Ciobotaru <davidciobotaru@danddassociates.ca> wrote —

WITHOUT PREJUDICE

Dear XXXX

Thank you for the email. Please be advised that the offer is for a permanent relocation. We will not have you moving back and forth. This would be a relocation on a permanent basis otherwise the offer is going to be withdrawn.

We have yet to identify any issue in your unit and this offer was solely made in good faith by the Landlord. If you do not wish to accept the Landlord’s offer for a permanent relocation, then my client is hereby withdrawing the offer.

Let us know if you accept the offer for permanent relocation. The paperwork for permanent relocation must be completed before you can receive the keys to unit 1404.

Best Regards,

David Ciobotaru
Paralegal, LSUC# P00586
D & D ASSOCIATES Paralegal Professional Corp.

From: XXXX
Sent: February 21, 2025 12:03 AM
To: jzam Rosie Middleton akung
Cc: David Ciobotaru
Subject: Re: Critical Human Rights Violation

John,

I will be at the management office at 11:30 AM on Friday, February 21, 2025. Assuming there are no signs of the ongoing building issues in the unit you’re offering, I expect access to the unit by end of day. I will be working from 1:00 pm until approximately 9:00 pm. If there’s a need for paperwork documenting the temporary relocation, I expect this to be done via email if we can’t resolve it before 12:30 pm. I then expect access granted by security or maintenance when I get back to the building shortly after 9:00 pm.

This has gone on long enough and the harm caused has been extreme and well-documented. The landlord and building management are already liable for the harm caused – any further delays will only compound that liability.

If this accommodation request were being handled in good faith, there would be no need for legal involvement. It is in everyone’s best interest for you to stop deflecting responsibility and move forward with my reasonable accommodation request immediately.

To be clear:

This is a temporary relocation, not a surrender of my apartment at .
I will not sign anything that absolves management of liability for the harm I have suffered as a result of these ongoing failures. A waiver of liability is not a legal requirement for an accommodation. Any attempt to make me sign away my rights in exchange for something you are already legally obligated to provide would be considered coercion and further evidence of bad faith, especially in light of my deteriorating health.
Your claim that you do not relocate tenants is demonstrably false. Management has regularly moved tenants within the building—including offering relocations from unrenovated to renovated units for higher rent. Additionally, the Landlord and Tenant Board has records of a case where management paid to move a tenant for temporary maintenance work, covering full moving costs both ways. If management is willing to relocate tenants when it benefits them financially, but refuses to accommodate me despite my disabilities and extreme hardship, that is blatant discrimination. I haven’t even asked for a full move. I merely asked for temporary access to a vacant apartment where I could put my mattress on the bedroom floor, and even that simple written request was ignored for almost six weeks.

I am asking for what is legally required under both tenant and human rights laws. The landlord’s only defense for refusing is undue hardship, and there is no universe in which being asked for a temporary move to a vacant apartment while you diligently work on repairing a deeply disruptive maintenance issue would meet that standard.

This situation is already at a critical stage, and further delays will only increase liability. I expect your full cooperation in ensuring a smooth relocation without unnecessary obstacles.

For clarity and transparency, I will be recording my visit to document the process, ensure accuracy in communication, and confirm the condition of the unit. Given the ongoing disputes and lack of clear responses in writing, I believe this is in everyone’s best interest.

—- On Thu, 20 Feb 2025 14:55:37 -0500 wrote —

WITHOUT PREJUDICE and without absolving any liability or wrongdoing.

Dear David,

Thank you for your response. I appreciate that the Landlord is considering a temporary relocation, as this is something I’ve been requesting since December. However, before I can agree, I need confirmation of the following:

Unit 1404’s Condition

I need assurance that Unit 1404 does not have the same or similar issues. Given the increasingly deteriorating conditions in the building, I’d like to see for myself that this proposed solution truly addresses the problem. I’m able to view the unit tonight after 9:00 pm if maintenance can let me in. Otherwise, I’m available tomorrow at 11:30 am.

Temporary, Not Permanent

I have no intention of permanently vacating my current unit. I’ve invested significant time and resources—painting, mouldings, and a hand-painted mural—to make it my home. It’s also on a higher floor with a better view.

Moving Only Necessities First

Given that you’re working diligently to resolve the issue, I expect this relocation to be short-term. Initially, I only need assistance moving my bed and kitchen essentials. However, if this situation extends beyond the end of the month, we will need to plan for moving more of my belongings.

Costs Covered by Landlord

All costs associated with this move should be borne by the Landlord. If the Landlord refuses to provide relocation assistance, I will add it to my outstanding claim for damages with the Landlord and Tenant Board. Additionally, since the Landlord has paid to move other tenants within the building while repairs were ongoing, refusing to do the same for me would serve as further evidence of discrimination.

Curtain Rod Installation

A curtain rod will be installed in the bedroom of the temporary unit. This is a basic necessity for privacy and sleep.

No Waiver of Rights

My willingness to consider this offer is purely practical and does not waive any rights. Nor does it absolve the Landlord of liability for the significant wrongdoing that has led to my displacement, health deterioration, and ongoing hardship. I fully reserve my legal rights and any potential claims in this matter.

Please confirm these details today so I can make an informed decision. I appreciate your prompt attention and look forward to your reply.

Best regards,

—- On Thu, 20 Feb 2025 11:15:06 -0500 David Ciobotaru

WITHOUT PREJUDICE and without admitting any liability or wrongdoing.

Hello XXXX

The Landlord forwarded me your below email and instructed me to advise you of the following:

As you are aware the Landlord is taking your complaint very seriously and is actively trying to identify the source of your complaint.

Nonetheless, the Landlord is willing to offer you another unit to use at the same rent in a different part of the building. My client says that they have apartment 1404 available for an immediate move. My client is doing so in order to assist you as they typically do not allow movement within the building, where it is a tenant from one apartment to another. If you are interested in this action, please contact the management office at the building to arrange a time for you to view apartment 1404.

If you choose to make this move, all the terms and conditions of your original lease will remain in place save and except for an addendum as to the identification of the apartment number.

Please advise in writing, to me, if you are interested or not in this move and if the answer is yes then the office will take care of the paperwork and the moving date.

Best Regards,

David Ciobotaru
Paralegal, LSUC# P00586
D & D ASSOCIATES Paralegal Professional Corp.

From: XXX
Sent: Wednesday, February 19, 2025 1:15 AM
To: John Zam ; Rosie Middleton ; Andrus Kung
Subject: Critical Human Rights Violation

John,

I need you to fully understand the severity of this situation. This is no longer just about noise—it is about my ability to survive in a livable space.

Last night, my Airbnb heater failed. Rather than return to my unit, I chose to sleep on the floor of my shop. The reason for this is simple: I cannot physically or mentally endure another night in that unit with the ongoing noise issues.

Tonight, when I attempted to return, I immediately suffered a severe panic attack. The ongoing and worsening noise, the displacement, the uncertainty, and the discrimination I am experiencing due to your refusal to engage in the accommodation process pushed me into such distress that I seriously considered ending my life. I was only able to leave after calling a family member for help.

Because of this issue and the associated displacement, I have already required daily prescription medication for anxiety, been referred back to a sleep clinic due to worsening sleep disruption, and will soon have an abdominal ultrasound to address stress-induced pain. My physician is aware of these escalating health impacts and can provide documentation confirming the necessity of a safe, quiet living environment.

I cannot continue to pay for alternative housing while you actively refuse to accommodate me. This situation has gone beyond a housing issue—it is now a direct threat to my health and safety.

Immediate Action Required

I require an immediate, temporary move to a quiet, livable apartment within the building while this issue is resolved. I cannot survive in my current unit. If you fail to act without delay, I will revise my Landlord and Tenant Board (LTB) and Human Rights Tribunal of Ontario (HRTO) filings to reflect your callous disregard for your duty and my safety.

This is an emergency. You need to act now. Please initiate discussions on temporary accommodations today.

Briarlane Tenants

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