Statement of Claim: Goodenowe and Lakeview Regional Wellness Centre v. Beck and Clarke

Note: This transcription covers the opening pages of the filing (the parties, overview, and case opening) and the Relief Sought section at the end. Paragraphs 9 through 45, which particularize the statements alleged to be defamatory and the plaintiffs’ theory of damages, are not reproduced here. They are available in the original document.

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Form 3-9 (Rule 3-9)

Court File Number: KBG-RG-00302-2026 Court of King’s Bench for Saskatchewan Judicial Centre: Regina

Plaintiff(s): Dr. Dayan Goodenowe and Lakeview Regional Wellness Centre Inc.

Defendant(s): Carla Beck and Jared Clarke

This Statement of Claim is issued at the above-named judicial centre on the 15th day of April, 2026.

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Statement of Claim

The Parties

1. The Plaintiff, Dayan Goodenowe (“Dr. Goodenowe”) is an individual residing in the City of Temecula, in the State of California, in the United States of America.

2. The Plaintiff, Lakeview Regional Wellness Centre Inc. (“LRWC”), is a corporation incorporated pursuant to the laws of Saskatchewan. LRWC’s registered office is located in Moose Jaw, Saskatchewan.

3. The Defendant, Carla Beck, is an individual residing in the Province of Saskatchewan. Ms. Beck is the leader of the Saskatchewan New Democratic Party (“NDP”). She is the Member of the Legislative Assembly (“MLA”) for the constituency of Regina Lakeview and the Leader of the official opposition.

4. The Defendant, Jared Clarke, is an individual residing in the Province of Saskatchewan. Mr. Clarke is a senior member of the NDP and reports to Ms. Beck in the NDP shadow cabinet, serving at her direction as the NDP Shadow Minister for Rural and Remote Health. He is the MLA for the constituency of Regina Walsh Acres.

Overview

5. Dr. Goodenowe is a Canadian citizen, born in Moose Jaw, Saskatchewan. Dr. Goodenowe holds a PhD in neurosciences. He is a well-established biochemist, synthetic organic chemist, inventor, and a clinical research expert with decades of experience.

6. Dr. Goodenowe is the principal of LRWC, which he established in Moose Jaw as part of his efforts to better his community. He has built a successful business in the United States and Canada offering advanced education and support for those with amyotrophic lateral sclerosis (“ALS”) and other illnesses. He is not and has never purported to be a medical doctor, or provide medical treatment.

7. LRWC operates a Restorative Health Center in Moose Jaw, Saskatchewan (the “RHC”). The RHC offers a structured, education and infrastructure-based support program focused on functional individualized health restoration. The support program is a self-directed program that each individual tailors to their own specific needs. The RHC is not, and has never purported to be, a medical centre, or to otherwise provide any medical treatment. Saskatchewan residents are able to access the RHC at no cost. No Saskatchewan resident has paid for the RHC, its services, or the supplements provided at the RHC.

8. As further particularized below, since at least June 2025, the Defendants, Ms. Beck and Mr. Clarke, have acted individually and conspired together to maliciously wage a defamatory campaign against the Plaintiffs, intended to ruin their professional reputation and business. This campaign, waged for personal political gain, has caused the Plaintiffs significant reputational harm and financial losses.

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The filing then sets out the particulars of the statements alleged to be defamatory, including the June 20, 2025 press conference statements, the December 2, 2025 letter to Moose Jaw Police Service and its republication, the December 1, 2025 speech in the Legislative Assembly, and related social media posts. These are set out in paragraphs 9 through 34 of the original document.

The filing also sets out the plaintiffs’ legal theories of defamation (paragraphs 35 to 38) and false light (paragraphs 39 to 41), and the plaintiffs’ claim for damages (paragraphs 42 to 45). These are available in the original document.

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Relief Sought

46. The Plaintiffs claim against the Defendants, jointly and severally:

(a) General damages for defamation in an amount to be assessed at trial;

(b) Special damages in an amount to be assessed at trial;

(c) Aggravated damages in an amount to be assessed at trial;

(d) Punitive damages in an amount to be assessed at trial;

(e) An interim, interlocutory, and permanent injunction restraining and preventing the Defendants from making, publishing, speaking, communicating, or causing to be made, published, communicated, or otherwise disseminated, any malicious, defamatory, fake or false statements or expressions about the Plaintiffs on any website, social media platform, or in any manner whatsoever;

(f) An interim, interlocutory, and permanent injunction requiring the Defendants to remove the defamatory comments and posts made about the Plaintiffs on social media;

(g) An interim, interlocutory, and permanent injunction requiring the Defendants to publicly retract their defamatory statements, through a method to be determined prior to trial;

(h) Pre-judgment interest in accordance with section 5 of the Pre-Judgment Interest Act, SS 1984-85-86, c P-22.2;

(i) Costs of this action on a solicitor-client basis; and

(j) Such further and other relief as counsel may advise and this Honourable Court may allow.

DATED at Toronto, Ontario, this 15th day of April, 2026.

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Lenczner Slaght LLP Lawyers for the Plaintiffs, Dayan Goodenowe and Lakeview Regional Wellness Centre Inc.

Name of firm: Lenczner Slaght LLP Name of lawyer in charge of file: Brian Kolenda Address of legal firms: 130 Adelaide St W #2600, Toronto, ON M5H 3P5 Telephone number: (416) 865-9500 E-mail address: Bkolenda@litigate.com