Day 31
Note: I am a poor note-taker and these summaries will contain errors and omissions which will reflect my limitations. My intention is to report on the facts as accurately as possible although a subconscious bias may creep in. I can only provide glimpses into what I see as relevant and interesting events. My goal is to capture the essence of the day’s events rather than be comprehensive.
Read the reference documents: The Legal Case and Events Leading to Trial to obtain an understanding of the case and its history. Names and terms are abbreviated and defined in Glossary.
Evidence of Dr. Cassandra Brown
Dr. Cassandra Brown was called as an expert witness for the Defendants to provide opinion evidence regarding the psychological and vocational harm allegedly suffered by Caylan as a result of the defamation. Her evidence stands in contrast to that of Dr. Mandel, the Plaintiff’s expert on the same issues. Both are psychologists with strong credentials and similar professional practices.
Direct Examination of Dr. Brown by Ms. Tiessen (Counsel for the Broadbent Institute and Defendants Lebrun and Magusiak)
Dr. Brown, PhD, practices in Calgary in the areas of neuropsychology, vocational psychology, and clinical psychology. Regarding her qualifications, she testified:
She has prepared five psycho‑vocational assessments for litigation.
She has prepared approximately twenty reports for litigation.
She has never previously been qualified as an expert witness in court.
The Court recognized Dr. Brown as an expert qualified to give opinion evidence in clinical psychology, neuropsychology, vocational psychology, disability assessment, cognitive function, psychological injuries and diagnosis, and the impact of such injuries on employment abilities. Her report was entered as an exhibit.
Background and Assessment
She worked with the late Dr. Pachet from 2013 to 2021.
Dr. Pachet conducted the first vocational assessment of Caylan; Dr. Brown was not involved in that assessment.
She completed a psycho‑vocational assessment of Caylan in 2025.
She conducted two interviews and administered a battery of psychological and cognitive tests.
Observations
Caylan was cooperative, verbally fluent, and provided accurate answers.
She appeared mildly depressed and became tearful at times.
She experienced fatigue and anxiety during testing and requested breaks when mentally fatigued.
Test Results
Caylan passed all validity tests, indicating adequate effort and no misrepresentation.
Working memory and verbal comprehension scores were very high.
Learning and memory scores were above average.
Caylan reported significant anhedonia.
She also reported sadness, low energy, and disengagement from normal activities.
She presented with clinically significant defensive avoidance.
Test results were consistent with her reported experience.
She exhibited depressive and trauma‑related symptoms, as well as fatigue.
Her intellectual functioning was extremely high, with no below‑average results and no indication of impairment.
Dr. Brown’s Conclusions
Caylan does not have cognitive difficulties that would preclude her from the vocational fields she is interested in.
From a cognitive standpoint, there is no indication of vocational limitations.
She has persistent psychological symptoms consistent with major depressive disorder.
Her depression is in partial remission.
Her symptoms are not persistent or severe enough to indicate ongoing major depression.
Several factors suggest a positive recovery trajectory: absence of pain, other health issues, childhood adversity, or personality disorders.
There is a possibility of recovery.
She did not experience a significant decline from her previous ability.
There is no compelling psychological reason why she could not earn at the top salary range for politicians, government employees, or professors.
Cross‑Examination of Dr. Brown by Mr. Harrison (Counsel for Caylan)
Dr. Brown testified:
She was not asked to and did not provide an opinion on whether reputational harm affected Caylan’s vocational potential.
She is not qualified to opine on the vocational impact of reputational damage.
She could not say whether Caylan could be hired as a deputy minister after being called a white supremacist.
She confirmed that Caylan has major depressive disorder in partial remission.
She explained the “practice effect,” whereby repeated testing can improve scores.
Caylan had taken some tests twice before Dr. Brown administered the same tests.
Caylan scored higher on the tests administered by Dr. Brown.
The practice effect may have contributed to improved scores, but the effect is not expected to be large.
Dr. Brown’s report stated that Caylan was less focused on entrepreneurial interests.
One question used to assess entrepreneurial interest was whether Caylan wanted to open a nail salon.
A “no” answer to the nail salon question is taken as indicating less entrepreneurial interest.
Caylan’s symptoms had impacted her capacity to work, but she is able to perform at a high level.
Dr. Brown disagreed with Dr. Mandel’s prognosis that Caylan’s depression was “likely to remain present.”
She found reasons for optimism that reduced efficiency and productivity may not be permanent.
She agreed that chronic depression has vocational implications.
She agreed that Caylan has a history of major depression with anxious distress and other trauma‑related disorders.
However, that history does not mean she is unsuited to most vocational opportunities.
The exception may be “public facing” roles, such as:
elected official,
deputy minister,
professor (which “would be difficult”),
author (which could also be public facing).
Despite this, Dr. Brown had concluded that there was no reason Caylan could not earn at the top salary range for politicians, government employees, and professors.
Dr. Mandel had concluded that Caylan would suffer a 20%–30% lifetime loss of earnings.
Dr. Brown stated she would need to review Dr. Mandel’s studies more closely to comment on that conclusion.
Q: “If her symptoms do persist, would you agree that this would likely impact her future employability and earnings potential?” A: “Yes. Chronic depression, one would expect vocational implications. The degree of impact is variable. But even in a chronic course, I wouldn’t expect it to remain static.”
She agreed it is possible that Caylan could perform at a higher vocational level if she had no depressive symptoms.
Similarities and Differences Between Dr. Brown and Dr. Mandel
Both psychologists are highly qualified and conducted similar assessments. Their reports, however, differ significantly in interpretation and prognosis.
Examples from Their Reports
Dr. Brown:“Ms. Ford is a 39‑year‑old woman who is alleged to have been the victim of a campaign of defamation and harassment, resulting in psychological trauma, reputational harm and vocational disruption.”
Dr. Mandel:“Because of allegedly false information that was spread about her, she was forced to resign her candidacy, became a political pariah, endured repeated personal attacks on her integrity, suffered material damage to her reputation, and developed significant negative psychological reactions…”
Dr. Brown:“Overall, her current presentation is not strongly indicative of a current major depressive episode, but lingering concerns were apparent.”
Dr. Mandel:“It is very concerning that these conditions remain present to the degree that they do… the duration of her symptoms reflect a chronic course, and suggest a poor future prognosis.”
Dr. Brown:“There is no occupation for which she would not be suited due to general ability.”
Dr. Mandel:“It would appear that Ms. Ford’s ability to pursue a career in politics or in any type of high‑level policy work… has been nullified for the foreseeable future.”
Dr. Brown:“There would be no limitations expected in her ability to be successful in any educational endeavour she should choose to undertake.”
Dr. Mandel:“While Ms. Ford is without doubt capable of attaining a tenured position… it remains unclear whether any university would risk hiring her given her defamed reputation.”
Dr. Mandel (re earnings): He concluded that Caylan will suffer a 20%–30% lifetime loss of earnings due to ongoing depression and compromised cognitive functioning.
Comment on Dr. Brown’s Evidence
Caylan underwent extensive testing by multiple professionals—psychiatrists, psychologists, and psychotherapists—and all results indicated she was accurately and credibly self‑reporting, neither exaggerating nor minimizing her symptoms.
Despite this, Dr. Brown repeatedly referred to Caylan’s difficulties as “perceived inefficacy,” “perceived poor performance,” “perceptions of diminished mental ability,” and “perceptions of diminished capacity.”
Dr. Brown stated she had no reason to doubt Caylan’s credibility, yet suggested that Caylan’s perceptions may not reflect actual limitations. This approach effectively allowed Dr. Brown to discount Caylan’s reported impairments despite objective testing supporting them.
Conclusion of Defence
Dr. Brown was the final witness called by Press Progress and the Broadbent Institute. With her testimony, the defence of those Parties is concluded.