Corrupt Federal Court Judges
The Contemnors David Near and Donald Rennie JJ
Must be removed from the Judiciary Office
The Contemnors David Near and Donald Rennie JJ
Must be removed from the Judiciary Office
Federal Court of Canada, Toronto
EXTREMELY URGENT
Dear Chief Justice Mr. Paul S. Carmpton:
RE: Major Nourhaghighi et al v. MCI; T- 478-12
1. This is a serious compliant as against two pervious servants of the Deparment of Justice and Attorney General (“Crown”) the Contemnors David Near and Donald Rennie JJ for violations of the rule of law, the Rules of the Federal Court and criminal actions as the officers of the Court in such a way as interfere with the orderly administration of justice and impaired the authority and dignity of the Federal Court of Canada by disobeying the Order and Direction of Justice Snider and defeated my lawful motions for contempt of the Court to support their own wrongdoing and failures when they had the Crown’s duty pursuant to Rules 466(a)(b)(c)(d) of the Federal Court Rules.
2. The records of employment show that Near and Rennie JJ from about 1996 to 2010 were servants of the Deparment of Justice. In 1999, Justice Campbell dismissed their counsels’ application T-1237-98 against me on June 2, 1999 and ordered that the Crown should not seek relief under Section 40 of the Federal Court Act (“S.40”) due to number of reasons such as requires definition and maintenance. The said application was supported by the office of Near and Rennie JJ solely to mislead the Ontario Court of Appeal in file C26841 by forwarding a copy of said application on May 7, 1999.
3. The office of Near and Rennie JJ has trespassed the Federal Court’s Data and changed Section 40 to Section 18 at the said file T-1237-98 to be able to mislead Justice O’Keefe in file No. T-1020-07, filed by three counsels of the Deparment of Justice in which, the Contemnor Roger Flaim had motive against me, because he was named Contemnor in my application before the Supreme Court of Canada; re 30350.
Justice O’Keefe dismissed T-1020-07, that vexatiously brought against me under S.40 with Costs against the Office of Near and Rennie JJ and counsels involved.
4. Now, both pervious servants have got as judges of the Federal Court, and by clear bias trying to revenge against my family and relative by abuse of judiciary office.
In investigation of this complaint I rely on audiotape of the hearing before the Contemnor Near Jon September 17, 2012 and his two vexatious and unlawful orders and a clear biased Direction of Rennie J dated September 20, 2012 in which unlawfully asked my motion as against the Contemnors Near et al
That was set to be heard on September 24, 2012 be removed and encouraging counsels to bring the THIRD APPLICATIONS under S.40 against me.
5. It is unlawful and conflict of impartiality to allow pervious counsels or politicians be hired as a judge. Thus, by legal actions I would asked the Contemnors Near and Rennie JJ be removed from the judiciary office.
5. It is unlawful and conflict of impartiality to allow pervious counsels or politicians be hired as a judge. Thus, by legal actions I would asked the Contemnors Near and Rennie JJ be removed from the judiciary office.
Major Keyvan Nourhaghighi
____________________________________________________________________________
File Number T- 478-12
FEDERAL COURT
BETWEEN:
MAJOR KEYVAN NOURHAGHIGHI
and FARZAD NOUR HAGHIGHI
and FARZAD NOUR HAGHIGHI
Applicants
-and-
THE MINISTRY OF CITIZENSHIP AND IMMIGRATION
Respondent
____________________________________________________________________
APPLICANTS’ MOTION RECORD
Pursuant to Provision of Rule 466 the Federal Court RulesCONTEMPT OF THE COURT
On Behalf of the Applicants: Major Keyvan Nourhaghighi
Senior Autodidact Legal Counsel
Dated on September 19, 2012
TO:The Contemnors Stephan STEBELSKY, the Visa Officer in TEHRAN, Redden ROSEMARIE, Jason KENNEY and the Minister of Citizenship and Immigration
The Solicitors Contemnors John LONCAR, Brad GOTKIN, Roger FLAIM, the Ontario Department of Justice, Myles KIRVAN and the Deputy Minister of Justice and Deputy Attorney General of Canada Robert Douglas Nicholson, the Minister of Justice and Attorney General of Canada3400- 130 King Street West,Box 36, Toronto,ON, M5X 1K6;Tel (416) 954 5205 Fax (416) 954-8982
The Contemnors Sean GOSNELL and Burden Ladner Gervals LLP
Scotia Plaza 40 King Street West Toronto ON M5H 3Y4
The Contemnors Helen A. DALEY and Wardle Daley Bernstein LLP;
The Contemnors Justice Donald Near, the Ottawa Hearings Coordinator, the Federal Court, Daniel GOSSELIN, Chief Administrator of the Courts Administration Service (“CAS”), the Toronto CAS Director Michael SWITZER, Senior Registry Officer, Mario SEPE, and Jake SCHUTZ180 Queen Street West, Toronto, ON TEL: (416) 973 3356 FAX: (416) 954 5068
Counsel Darrell Kloeze for the Contemnors Brian Eyolfson, Associate Chair David A. Wright , the Human Rights Tribunal of Ontario and the Social Justice Tribunals Ontario Heather MACKAY, the Crown Civil Law Office, John GERRETSEN and the Attorney General of Ontario and Her Majesty the Queen in Right of Ontario
TABLE OF CONTINENT
No. DESCRIPTIONS DATE PAGE
1. Notice of Motion September 18, 2012 1
2. Affidavit of Major Keyvan Nourhaghighi September 19, 2012
EXHIBIT “A” “Conflict of Interest” Issue
Indicates the Style of Cause in Action as Against
Contemnor Sean GOSNELL and its law firm referred to
in the contempt proceeding after Gosnell breached Madam
Justice Snider’s Direction, and in the court served a “Casebook”
that Major submitted there was a conflict of interest between
Gosnell’s law firm that entered into a contract to represent Major
as against the Toronto Police
Contemnor Sean GOSNELL and its law firm referred to
in the contempt proceeding after Gosnell breached Madam
Justice Snider’s Direction, and in the court served a “Casebook”
that Major submitted there was a conflict of interest between
Gosnell’s law firm that entered into a contract to represent Major
as against the Toronto Police
3. Supplementary Affidavit of Major Nourhaghighi September 19, 2012
4. Applicants’ Submissions September 19, 2012
File No.: T- 478 -12
FEDERAL COURT
BETWEEN:
MAJOR KEYVAN NOURHAGHIGHI
and FARZAD NOUR HAGHIGHI
and FARZAD NOUR HAGHIGHI
Applicants
-and-
THE MINISTRY OF CITIZENSHIP AND IMMIGRATION CANADA
Respondent
NOTICE OF MOTION
TAKE NOTICE THAT the Applicants will make a motion to a judge on Monday, September 24, 2012 at 9:30 AM, or as soon as thereafter the motion can be heard, at 180 Queen Street West , Toronto , Ontario
The Applicants are requiring two hours for the hearing of this motion.
The Applicants are requiring two hours for the hearing of this motion.
THE MOTION IS FOR AN ORDER UNDER THAT:(a) To set aside two Orders of this Court dated September 18, 2012 or alternatively to reconsider: (i) allowing relief sought in this judicial review application be granted by the Motion Judge that another Visitor Visa Officer reviews the application of the Applicant Farzad Nour Haghighi; or allowing continue this perfected judicial review application (ii) two contempt motions be set for the trial by an imperial judge who did not served the Deparment of Justice and/or the Attorney General.
(b) The Court condemns the Judge shopping by the Deparment of Justice and discriminatory practices in the services available by the Courts Administration Service as against the Applicant, Major Keyvan Nourhaghighi (“Major”).
(c) The Respondent be required to served and filed a certified transcripts of show cause motions on June 18, 2012, and September 17, 2012 with the audiotapes.
(d) The Court condemns the Ottawa Hearings Coordinator and be require to show cause for contempt of the Court for malicious delay in complying with Rules to set a half day hearing since June 5 or June 18, 2012 for this perfected application pursuant to Rule 466(b)(c)(d) and be required to pay $1000.00 costs to the Contemnors under the Court’s Order of September 18, 2012 as a the third party liability; not the Applicants.
(e) The Contemnors John LONCAR, Catherine VASILAROS and the Deputy Minister of Justice and the Attorney General of Canada; Michael SWITZER, Jake SCHUTZ, Mario SEPE, Daniel GOSSELIN and the Courts Administration Service (“CAS”); Helen DALEY and Wardle Daley Bernstein LLP 3, Sean GOSNELL and Burden Ladner Gervals LLP be required to show cause for contempt of the Court for inter alia
2
conspiracy, perjury, forgery and/or incomplete affidavits, and/or fraud in oral and written submissions, fraud in Courts’ Data and Judge Shopping pursuant to Rule 466(b)(c)(d).
(f) The Contemnor Justice Donald J. RENNIE (“Near J”) be required to show cause for contempt of the Court and the Motion Judge’s report his professional misconduct at the hearing to the Canadian Judicial Council for a conspiracy to defeat two contempt proceedings and by a slanderous order condemning Major and awarding costs to the Contemnors, where did not ask, unlawfully obstructed the lawful process of a perfected judicial application in such a way that brought the administration of justice in disrepute.
(g) The Costs of this motion to be paid forthwith in any event of the cause, to be fixed at $1500.00; and the costs of trial be awarded as a sanction.
THE GROUNDS OF THE MOTION ARE AS THE FOLLOWING THAT:
1. On March 5, 2012, the Registry Officer Andrew MURRAY has obtained an oral leave of a judge and then filed the Notice of Application.
Near J err in fact that the leave was not obtain1. Major submitted the same to Near J2
that the Leave of the Court is the Administrative process and the hearing of a perfected judicial review application shall not be disturbed for a written administrative leave.
Near J erred in law that multiplicities of legal proceedings are not condemned by law.
Section 138 of the Courts of Justice Act
2. There is nothing in the Respondent’s Submissions that shows what is the exact text of Section 72(1) of IRPA?
Near J erred in law that Major did not had right to full disclosure that be able to provide full answer. Near J clearly breached Major’s rights under Section 7 of the Charter.
R. v. Kalea (1995), 43 C.R. (4th) 368,102 C.C.C. (3d) 1 S.C.C.
Near J err in fact that the leave was not obtain1. Major submitted the same to Near J2
that the Leave of the Court is the Administrative process and the hearing of a perfected judicial review application shall not be disturbed for a written administrative leave.
Near J erred in law that multiplicities of legal proceedings are not condemned by law.
Section 138 of the Courts of Justice Act
2. There is nothing in the Respondent’s Submissions that shows what is the exact text of Section 72(1) of IRPA?
Near J erred in law that Major did not had right to full disclosure that be able to provide full answer. Near J clearly breached Major’s rights under Section 7 of the Charter.
R. v. Kalea (1995), 43 C.R. (4th) 368,102 C.C.C. (3d) 1 S.C.C.
3. During the hearing, Near J and the Contemnor Loncar had private style conversation. Near J was serving the Deparment of Justice for a long period and two colleagues were talking by using abbreviations, ignoring Major’s rights in totality. Major stated that he had right to know what Section 72(1) of IRPA is that he be able to reply. However, Near J with high-handed manner ignored Major’s objection. Near J err in law that a judge should not be impartial and breached s. 11(d) of the Charter.
R. v. Lippe (1990), 61 C.C.C.(3d) 127,64 C.C.C.(3d) 513 S.C.C.
R. v. Lippe (1990), 61 C.C.C.(3d) 127,64 C.C.C.(3d) 513 S.C.C.
4. Major relies on all materials that he filed since March 5, 2012. In particular, Major submits that six affidavits filed by the Contemnors in which they hold productive facts.
Near J clearly erred in fact finding and by obvious bias covered up all the Contemnors’ wrongdoing to promote his personal interest and tried his best to make Major the object of contempt in contempt of the Court proceeding for his brave and lawful actions. Then, by clear breach of Madam Justice Order of June 18, 2012 that unlawfully allowed the
1 Major Keyvan Nourhaghighi Supplementary Affidavit sworn on …..
2 Major’s Proofs are the Audiotape and the transcript of September 17, 2012
2 Major’s Proofs are the Audiotape and the transcript of September 17, 2012
2
Contemnor Loncar, to represent the Contemnor Gotkin, and while Contemnor Loncar did not purge his contempt. Near J unlawfully allowed Loncar to represent the Respondent and argue in motion to strike. Also Near J unlawfully allowed Gosnell in the courtroom serve a “CaseBook” contrary to Direction of Madam Justice Snider dated September 5, 2012 that all materials should be served and filed before or on September 14, 2012. Near J err in law that Major should be taken in surprise in his arbitrary court.
5. On May 28, 2012, the Respondent’s counsel, the Contemnor Brad Gotkin sent a letter via a regular mail (“Gotkin’s Letter”) that he had intention to file a motion, on the same week, to strike the perfected judicial review application. On June 5, 2012, the Contemnor Registry Officer John Schutz refused to file the Applicants’ Requisition of Hearing and alleged relied on the Gotkin’s Letter. The Applicant, Major Keyvan Nourhaghighi (“Major”) told him that a letter can not stop a process. Schutz argued. Major asked that Schutz call the Manager. Schutz talked with the Officer Andrew MURRAY. Murray
This vital fact is omitted from the Contemnors Schutz’ Affidavit, and Daley Submissions.
Major filed documents that the Gotkin’s Letter, the originated the conspiracy between the Contemnors the Deparment of Justice and the Toronto Registry, as the officers of the Court to defeat the Rules of the Federal Court.
6. On September 17, 2012, at 9:15 AM, Major saw the Contemnors Switzer and Sepe at fifth floor of the Federal Courts’ building. They committed crime by adding a drug to water of Major that caused him serious anxiety and confusion during hearing.
This vital fact is omitted from the Contemnors Schutz’ Affidavit, and Daley Submissions.
Major filed documents that the Gotkin’s Letter, the originated the conspiracy between the Contemnors the Deparment of Justice and the Toronto Registry, as the officers of the Court to defeat the Rules of the Federal Court.
6. On September 17, 2012, at 9:15 AM, Major saw the Contemnors Switzer and Sepe at fifth floor of the Federal Courts’ building. They committed crime by adding a drug to water of Major that caused him serious anxiety and confusion during hearing.
7. Six affidavits were filed by the Contemnors as against Major’s affidavit for contempt that only a trial judge has skill to conduct two motions for the contempt.
IN SUPPORT OF THIS MOTION THE APPLICANTS WILL RELY UPON:
1. Affidavit of Major Keyvan Nourhaghighi, sworn September 19, 2012;
2. The Transcript of June 18, 2012 before Madam Justice Snider;
3. The Transcript of September 17, 2012 and two audiotapes of the proceedings June 18, 2012 and September 17, 2012;
4. Justice Snider Order of June 18, 2012 and her Direction of September 5, 2012
5. Witness the Registry Officer Andrew Murray;
6. Motion Records filed by all parties since June 13, 2012, in particular all affidavits;
7. Rules 399(a)(b), 466(a)(b)(c)(d), 467, of the Federal Court Rules and
Rule 21 of theOntario
Rule 21 of the
DATED IN TORONTO
___________________________________________
Court File No: T- 478 -12
FEDERAL COURT
BETWEEN:
MAJOR KEYVAN NOURHAGHIGHI,
and FARZAD NOUR HAGHIGHI
Applicants
-and-
THE MINISTRY OF CITIZENSHIP AND IMMIGRATION CANADA
Respondent
AFFIDAVIT OF MAJOR KEYVAN NOURHAGHIGHI
I, MAJOR KEYVAN NOURHAGHIGHI, Senior Fighter Pilot and Commissioned Officer, the resident of 608-456 College Street , Toronto , Ontario
1. I am the Applicant in the perfected judicial review application and the moving party in this motion and as such have a personal knowledge of the matters hereinafter depose.
2. In this paragraph, I confirm all materials that I filed and all my oral submissions were the truth. Thus, herein, I apply them to avoid repeating. Also, on September 17, 2012, as soon as, I came home, I researched and found the following information at the Federal Court’s website:
Justice Near was “Legal Counsel (1990-2001) and Senior Counsel (2002-2009), Department of Justice assigned to Legal Services, Environment Canada
Then I discovered good reason that explained Near J professional misconduct .I commenced writing this affidavit, and notice of notice to file it on same day of September 17. However due to serious illness that I suffered due to toxic poison and extreme anxiety before Near J, I was unable to file it. Last night I felt that I am going to have heart attack and while I am writing this paragraph I have abnormal heart beats; yet, I hope to serve and file my documents today.
3. Brad Gotkin sent a letter via a regular mail (“Gotkin’s Letter”) 1 that he had intention to file a motion, on the same week, to strike the perfected judicial review application.
1 On May 28, 2012, the Respondent’s counsel, the Contemnor Brad Gotkin sent a letter via a regular mail that he had intention to file a motion, on the same week, to strike the perfected judicial review application. On June 5, 2012, the Contemnor Registry Officer John Schutz refused to file the Applicants’ Requisition of Hearing and alleged relied on the Gotkin’s Letter. Major told him that a letter can not stop a process. Schutz argued. Major asked that Schutz call the Manager. Schutz talked with the Officer Andrew MURRAY. Murray
2
4. On September 17, 2012, about 9:15 AM, I saw the Contemnors Switzer and Sepe rushed at fifth floor of the Federal Courts’ building in Toronto Canada
5. On September 17, 2012, Near J numerously stated that he carefully read all documents. He did not ask the Contemnors to reply. Even the Contemnor Daley stood to have submissions. Near J told Daley that he read her materials and not requiring her submissions. Whereas Near J knew that the charge of contempt against Daley was due to fraud in Daley Written Submissions of August 3, 2012 by omitting the Gotkin’s Letter, as the first productive fact by allowing perjury of her client, the Contemnor Schutz in his Affidavit. However, during the hearing Near J maliciously tried to confuse I by scattering issues. Then, in sudden, Near J fraudulently tried to obtain a false reply from I in the contrary with the vital fact of the Gotkin’s Letter at the presence of the Court Reporter, Lisa NGUYEN. The following are my recollections:
Near J: So Schutz rejected the Requisition because you were late.
I: No, Gotkin’s Letter was the first issue. Why you are mixing two different issues? Schutz rejected the Requisition and argued. I saw that he talked with Mr. Murray who confirmed I was correct. Thus, Schutz disobeyed the Rules.
Near J: So Schutz rejected the Requisition because you were late.
I: No, Gotkin’s Letter was the first issue. Why you are mixing two different issues? Schutz rejected the Requisition and argued. I saw that he talked with Mr. Murray who confirmed I was correct. Thus, Schutz disobeyed the Rules.
6. On September 17, 2012 at 9:30 AM they were several lawyers in the courtrooms.
The Contemnor Gosnell gave a copy of “Casbook” for the Law Society Contemnors to me. Today, I got a letter dated September 14, 2012, sent by Gosnell via regular to me. Today, I also reviewed the Courts’ Entries, and I saw the Toronto Registry Contemnor, again, unlawfully and maliciously entered the Gosnell’s Letter into the records, where according to the Rules must be filed on September 23, 2012. The Contemnors Gosnell and the Toronto Registry, both are in breaches of Justice Snider’s Direction of September 5, 2012. During the hearing Gosnell handed a copy to Near J and omitting the material facts from his submissions, inter alia, such as that Gosnell and his law firm were named as the defendants
The Contemnor Gosnell gave a copy of “Casbook” for the Law Society Contemnors to me. Today, I got a letter dated September 14, 2012, sent by Gosnell via regular to me. Today, I also reviewed the Courts’ Entries, and I saw the Toronto Registry Contemnor, again, unlawfully and maliciously entered the Gosnell’s Letter into the records, where according to the Rules must be filed on September 23, 2012. The Contemnors Gosnell and the Toronto Registry, both are in breaches of Justice Snider’s Direction of September 5, 2012. During the hearing Gosnell handed a copy to Near J and omitting the material facts from his submissions, inter alia, such as that Gosnell and his law firm were named as the defendants
3
in my lawsuit and were in conflict of interest to represent the Law Society; or all my actions were dismissed in the Ontario Court, and relied on Wilkins Order of February 6, 1997. Near J, without interrupting Gosnell, maliciously allowed him to rely in all Judgments of the Ontario Courts that the Federal Court has no jurisdiction over them. In addition all the said judgments were obtained by frauds, harassments and physical and mental tortures against me as a new immigrant and unrepresented before the Court. Thus, the existence of the Judgments of the Ontario Courts by Wilkin, Bigelow, Lampkin and Epstein JJ are proofs beyond a reasonable doubt that the said Judges have clearly violated my rights that have guaranteed under the Charter, such as right to counsel and right to be heard by independent and impartial tribunal; re Section 11 of the Charter. According to the rule of law, I had right to reply. However, Near J oppressively was trying to obstruct me. However, I established that I had right to reply to Gosnell’s fraudulent misrepresentation; and Near J allowed. I submitted that Gosnell was named defendant in my pending lawsuit, and there was a conflict of interest disqualifying him to represent the Law Society. Then, I read the Judgment of Mr. Justice CADSBY of the Ontario Court as against the Justice Defendant V. LAMPKIN. Gosnell at tab 5 of “Casebook” page 2, paragraph 10, relied on the Lampkin’s Order. I commence reading how nine members of Toronto Police tortured me and broken my ribs that Jennie J, with heartlessness and cruel eyes stare at me and interfered. I stated: “I have right to make my points in reading this judgment”. Finally, hardly, Near J allowed and I stated that on February 6, 1997, at the presence of Justice Wilkins, I was suffering from physical and mental serious injuries of torture. Thus, I was unable to defend myself properly. However, I stated that Gosnell and lawyer Eric Hoaken have committed perjury and fraud in affidavit [of August 26, 1996] and conspired against Justice COO Order [of June 16, 1995]. I added that “Justice Wilkins with anger looked at Gosnell and added in his Order: “4. THIS COURT ORDERS that Respondent [I] shall not be penalized by the passage of time in the even leave to continue is obtained with respect to any pending action” . And I saw that Near J read the said order. Then I added that in my pending action against the Law Society Gosnell is defendant on the same action, and I would commence the prosecution as soon as the Contemnor Marion BOYD be removed from the Law Society. As Boyd’s unlawful influence over the Judiciary system would not allow a fair trial.
EXHIBIT “A” indicates the style of cause in file 96-CU-113026 that Gosnell and his law firm were named defendants in my pending lawsuit before the Ontario
7. Since 1995 I have presentation before the Federal Courts. Near J is the sole Judge that continuously interrupted me and reminds me all tricks that Bigelow J used against me in malicious prosecution of September 1994, that I pleaded the details in my action against him for conspiracy with the Transport Canada; re; A-410-95, that herein I am relaying on all those pleadings against Near J. As soon as I learned that Near J was a counsel with the Contemnor the Deparment of Justice and got awards from it that I fully understand why the Judge misconduct himself with the process. I was satisfied beyond a reasonable doubt that the whole proceeding of September 17, 2012 was a conspiracy as against the contempt of the Court’s charges and my lawful perfected judicial review application. Thus, I commenced preparing the Notice of Motion and this Affidavit against him and his parties Contemnors.
4
8. There are ample documents including file T-1020-07 indicating that my Contempt Charges as against the Contemnors Roger FLAIM and the University of Toronto for trespassing the Federal Court Data in 2006 and changing “Section 40 of the Federal Court Act to Section 18.1 on file T-1237-98” to be able to file the vexatious application of T-1020-07, where Near J was fully responsibility on the Deparment of Justice.
On the hearing of several motions on October 2000, in file T-1535-00, Mr. Justice O’Keefe refused to hear any motions and when asked the learned judge stated “I am in conflict of interest” as he was a partner in one of the law firms before the Court. And if he was not voluntary admitting certainly no one could understand or even if few knew would never object, as everyone wants a ‘judge’ take their side. However, on September 17, 2012, Near J with a tone of language that I found offensive addressed me: “Why you named the Minister of Justice and Attorney General ofCanada Tehran
9. The Contemnor Prothonotary Kevin AALTO made a direction on June 7, 2012 that I never served with it, and I never saw it in the file. However, in the said direction alleged that he said my Requisition shall be dealt with the Respondent’s Motion to Strike. And after I filed a motion for contempt proceeding, again the Respondent’s motion to strike heard by him and ordered that should be heard with the motion for contempt, and denied my written submissions that the Court should not hear the Contemnors till they purged their contempt. As the result of combing two contradictory motions in which the contempt motion was lawful according to the “Show Cause Order” of Justice Snider, and it was in the public interest and judiciary interest to not be delayed, with a vexatious motion to strike a perfected judicial review application the Contemnors Loncar, Daley, and the Ottawa Hearing Scheduling Office got an opportunity to delay my lawful motion and refusing to set a date for my perfected judicial review application.
On the hearing of several motions on October 2000, in file T-1535-00, Mr. Justice O’Keefe refused to hear any motions and when asked the learned judge stated “I am in conflict of interest” as he was a partner in one of the law firms before the Court. And if he was not voluntary admitting certainly no one could understand or even if few knew would never object, as everyone wants a ‘judge’ take their side. However, on September 17, 2012, Near J with a tone of language that I found offensive addressed me: “Why you named the Minister of Justice and Attorney General of
9. The Contemnor Prothonotary Kevin AALTO made a direction on June 7, 2012 that I never served with it, and I never saw it in the file. However, in the said direction alleged that he said my Requisition shall be dealt with the Respondent’s Motion to Strike. And after I filed a motion for contempt proceeding, again the Respondent’s motion to strike heard by him and ordered that should be heard with the motion for contempt, and denied my written submissions that the Court should not hear the Contemnors till they purged their contempt. As the result of combing two contradictory motions in which the contempt motion was lawful according to the “Show Cause Order” of Justice Snider, and it was in the public interest and judiciary interest to not be delayed, with a vexatious motion to strike a perfected judicial review application the Contemnors Loncar, Daley, and the Ottawa Hearing Scheduling Office got an opportunity to delay my lawful motion and refusing to set a date for my perfected judicial review application.
10. The Contemnors have filed six affidavits by Schutz, Heeney, Switzer, Vasilaros, Sepe and Gosselin. None of the affidavit are complete, and have defects, required to be cross-examine as I wrote to the Court, on September 14, 2012. Near J did not allow me to address my motion the way that I thought it would be in the best interest of justice and instead the contempt proceeding conducted by the way of addressing me scattering questions, with a very low voice and a tone that sounds funny: “What Kirvin did to you?” then “What Marion Boyd got to do with your nephew’s visitor visa?” and soon by this kind of reply made me object of contempt: “Oh! Because the Law Society sometimes in past let them in the bar, then you think they are liable under the contempt proceeding.” Herein I admit that all words may not be exactly the same words as Near J addressed me. However this is way I understood. Near J intentionally talking with very low voice that few times I asked him to
5
repeat, but he did it in the pervious way that I did not understood a word. So, for the first time I stated: “Sorry, English is my second language and the Respondent. The Applicants and I would reject any kind of liability that may risen by our actions. We plead that the Contemnors, in particular, the Visitor Visa Officer in Tehran , the Respondent’s Counsel Gotkin and the Hearing Coordinator in Ottawa Canada
11. Today, I saw in the Federal Court’s website that Near J rendered his Order. There is no information about the nature of the order.
12. I have a perfected judicial application and three motions in which I am entitled to be heard fully and decisions be rendered on their merits. I have all rights during my presence at all Offices to serve documents, the Toronto Registry and at the Court be treated respectfully and professional by all staff of the Contemnors. In the enforcing all my rights and the Contemnors and their agents, including police and securities threat, cruel and unusual treatments can not stop me to pursue my rights.
12. I have a perfected judicial application and three motions in which I am entitled to be heard fully and decisions be rendered on their merits. I have all rights during my presence at all Offices to serve documents, the Toronto Registry and at the Court be treated respectfully and professional by all staff of the Contemnors. In the enforcing all my rights and the Contemnors and their agents, including police and securities threat, cruel and unusual treatments can not stop me to pursue my rights.
13. Since 1990 that I landed, the Government and the Courts have conducted ample malicious prosecutions as against I. In 1996 I asked from the Ontario Court to declare the Attorney General of Ontario as the vexatious litigant for ample charges that the Police and countless malicious prosecution. Thus since 1997 no prosecution is made as against I by the Crown. However, the Federal Government, by denying my very basic rights to the services, maliciously, has put me in the position to file applications with the Court and waste valuable judiciary resources since 1998 for no good reason whatsoever, such as two applications
T-1237-98 and T-1020-07 that the Contemnors Counsels of the Deparment of Justice under management of Near J have brought as against me, or stealing my citizenship application in 1993 that finally in 2003 I got it by a mandamus application T-768-03, and asking CSIS conduct investigation against me ended to two years waste of my life, although I was successful, and this application rejecting a visitor visa to a British Citizen because he is my nephew. The Court shall make an Order that if a similar case be repeated by the Contemnors would award costs against them as the sanctions.
T-1237-98 and T-1020-07 that the Contemnors Counsels of the Deparment of Justice under management of Near J have brought as against me, or stealing my citizenship application in 1993 that finally in 2003 I got it by a mandamus application T-768-03, and asking CSIS conduct investigation against me ended to two years waste of my life, although I was successful, and this application rejecting a visitor visa to a British Citizen because he is my nephew. The Court shall make an Order that if a similar case be repeated by the Contemnors would award costs against them as the sanctions.
AFFIRMED before me in the City of )
Toronto, in the Province of Ontario ) MAJOR KEYVAN NOURHAGHIGHI
This 19th day of September 2012 )
Toronto, in the Province of Ontario ) MAJOR KEYVAN NOURHAGHIGHI
This 19th day of September 2012 )
Commissioner of the Federal Court, the Toronto Registry Officer Shirley ACIRO
______________________________________________
Court File No: T- 478 -12
FEDERAL COURT
BETWEEN:
MAJOR KEYVAN NOURHAGHIGHI
and FARZAD NOUR HAGHIGHI
and FARZAD NOUR HAGHIGHI
Applicants
-and-
THE MINISTRY OF CITIZENSHIP AND IMMIGRATION CANADA
Respondent
___________________________________________________________________
MAJOR NOURHAGHIGHI’ WRITTEN SUBMISSIONS
ON BEHALF OF THE APPLICANTS
MAJOR NOURHAGHIGHI’ WRITTEN SUBMISSIONS
ON BEHALF OF THE APPLICANTS
PART I - FACTS
1. Major relies in all documents that he filed, lawfully, for the perfected judicial review application (“Application”) and for the contempt motions.
The issue in the Application is that a decision of a Visitor Visa Officer be set aside and another officer made a decision according to the law.
2. The cause of action for contempt rose after the Respondent intentionally did not comply with all Application’s Rules and filed no record before the visa officer.
2. The cause of action for contempt rose after the Respondent intentionally did not comply with all Application’s Rules and filed no record before the visa officer.
And after the application was perfected and attempt made to set for the hearing, in sudden wrote to the Registry that had intention to bring a motion to strike, falsely, alleged inter alia the leave of court was not obtained by the Applicants for filing where as on March 5, 2012, the Registry Officer Andrew MURRAY has obtained an oral leave of a judge and then filed the Notice of Application. Near J err in fact that the leave was not obtain1. Major submitted the same to Near J2 that the Leave of the Court is the Administrative process and the hearing of a perfected judicial review application shall not be disturbed for a written administrative leave.
3. Pursuant to the Order of Honourable Madam Justice Judith SNIDER, dated June 18, 2012 (“Snider Order”) the Respondent’s Counsel Contemnor Bred GOTKIN
and the Toronto Registry Officer Contemnor Jake SCHUTZ were ordered to show cause why not be held in contempt of the Court. The Hearings Coordinator did not set a date for hearing in three months.
4. As soon as the said Contemnors were named in the Notice of Motion dated June 13, 2012, they have lost their office capacity to represent the Respondent and were obligated to defend themselves. Thus, they have instructed two counsels, John LONCAR and Helena DALEY, to represent them professionally that they be able to purge their contempt; and they were hopeful to suffer the minimum punishment.
However, the crimes committed by the Contemnors Loncar and Daley were so outrageous that not only have seriously put Schutz and Gotkin in a serious danger of the maximum punishment and fine, but all their Officials were named as the Contemnors to appear before this Honourable Court and reply to the Trial Judge’s questions that why they should not be held for contempt of the Court for providing certificates and licenses to the Counsels and Registrars Contemnors to practice the law and have duties as the Officers of the Court in the administration of Justice ?
3. Pursuant to the Order of Honourable Madam Justice Judith SNIDER, dated June 18, 2012 (“Snider Order”) the Respondent’s Counsel Contemnor Bred GOTKIN
and the Toronto Registry Officer Contemnor Jake SCHUTZ were ordered to show cause why not be held in contempt of the Court. The Hearings Coordinator did not set a date for hearing in three months.
4. As soon as the said Contemnors were named in the Notice of Motion dated June 13, 2012, they have lost their office capacity to represent the Respondent and were obligated to defend themselves. Thus, they have instructed two counsels, John LONCAR and Helena DALEY, to represent them professionally that they be able to purge their contempt; and they were hopeful to suffer the minimum punishment.
However, the crimes committed by the Contemnors Loncar and Daley were so outrageous that not only have seriously put Schutz and Gotkin in a serious danger of the maximum punishment and fine, but all their Officials were named as the Contemnors to appear before this Honourable Court and reply to the Trial Judge’s questions that why they should not be held for contempt of the Court for providing certificates and licenses to the Counsels and Registrars Contemnors to practice the law and have duties as the Officers of the Court in the administration of Justice ?
5. Since June 13, 2012, Major has filed two notices of motion with three affidavits as against the Contemnors. He has given the particulars of the crimes committed by the Contemnors. In the Affidavit of September 5, 2012 (“Major Affidavit”) at paragraph 2, first line, he has conformed: “the grounds on the Notice of Motion are truth, nothing then truth.” Thus, Major relies on each and every facts in all documents that he filed as against the Contemnors, and respectfully request herein all the said facts be accepted to avoid multiplicity.
6. Major at the last paragraph of the Major Affidavit respectfully submitted that has in possession a better particular to lead the justice, if this Honourable Court make an order to be served and filed. Major at the said last paragraph, as a sample, has presented Questions requiring the Contemnor Schutz to answer as his Affidavit is constructive and shall be strike in whole or in all paragraphs that the Contemnor Counsel Daley maliciously put the name of the Honourable Registry Senior Officer along with the Registry Officer Wrongdoer Contemnor Schutz to mislead the Court.
Major Affidavit, at paragraph 2 admitted “I admit that the CAS Senior Officer Denise HEENEY performed her duty professionally.” Whereas Schutz is accuse of purjery and conspiracy with Sepe, Gotkin, Loncar and Daley to defeat the Court in the contempt proceeding and this is the main reason that it is just the show cause order as against the Contemnors Daly and Loncar be issued.
7. Finally, the most important issue before the Court on September 12, 2012, is the Contempt in the Face of Court by the Contemnors Counsels Gotkin and Loncar that there are ample evidence to prove beyond a reasonable doubt that the said member of the LAW SOCIETY, as the OFFICERS of THE COURT, met, planned and conspired as against Madam Justice Snider to make her, intentionally, nervous, upset, and worry which is emotional abuse of a female judge. The contempt charge as against the Chair of Law Society Contemnor Marion BOYD is that she as the weakest Attorney General of Ontario and Chair disrepute in the
8. On September 5, 2012, Madam Snider made a direction that all parties must file their records before or on September 14, 2012. The Contemnor Gosnell breached the said direction and in the courtroom served a “casebook” for the Contemnor the Law Society. Major was shocked that was not given chance to review several orders. Near J also obstructed Major in reply to Gosnell’s fraudulent misrepresentation. Major stated that Gosnell was involved in a conspiracy, when nine members of the Toronto Police tortured him. However, Near J interrupted Major and during the hearing by his comments made Major object of contempt ending to laughs by the Contemnors.
PART II
POINTS IN ISSUE
POINTS IN ISSUE
9. It is respectfully submitted that there two issues before this Honourable Court:
(a) Perfected judicial review application
(b) Contempt Proceedings.
(a) Perfected judicial review application
(b) Contempt Proceedings.
PART III
ARGUMENT
ARGUMENT
10. Major respectfully that submits that the law condemns the multiplicities of legal proceedings. Section 138 of the Courts of Justice Act instructed that:
“As far as possible, multiplicity of the legal proceedings shall be avoided.”Near J err in law that the oral leave of judge of this court on March 5, 2012 was not valid and the action of the professional Registry Officer in filing the Notice of Application was incorrect. Major requests that the process of a visitor visa hearing not be disturbed and this Honourable Court, or an application judge grant that another visa officer grants a multi entry visa to the British Citizen Applicant, Farzad Nour Haghighi on his Iranian passport.
IN ADDITION:
IN ADDITION:
Near J clearly breached Major’s rights under Section 7 of the Charter.
R. v. Kalea (1995), 43 C.R. (4th) 368,102 C.C.C. (3d) 1 S.C.C.
R. v. Kalea (1995), 43 C.R. (4th) 368,102 C.C.C. (3d) 1 S.C.C.
Near J with high-handed manner ignored Major’s objection. Near J err in law that a judge should not be impartial and breached s. 11(d) of the Charter
R. v. Lippe (1990), 61 C.C.C.(3d) 127,64 C.C.C.(3d) 513 S.C.C.
It is respectfully submitted that under the Judicial Ethics and Judges’ principles it was clearly wrong that Near J heard contempt as against the Deparment of Justice when he was its counsel for many years and had hostility against Major. Also under the Law Society Rules of Professional Conduct Gotkin, Loncar and Gosnell’s actions constitute a professional misconduct:
2.04 (1) In this rule A “conflict of interest” or a “conflicting interest” means an interest:(a) that would be likely to affect adversely a lawyer's judgment on behalf of, or loyalty to, a client or prospective client, or (b) that a lawyer might be prompted to prefer to the interests of a client or prospective client. (2) A lawyer shall not advise or represent more than one side of a dispute. (3) A lawyer shall not act or continue to act in a matter when there is or is likely to be a conflicting interest unless, after disclosure adequate to make an informed decision, the client or prospective client consents 6.05 (1) A lawyer who holds public office shall, in the discharge of official duties, adhere to standards of conduct as high as those that these rules require of a lawyer engaged in the practice of law. (2) A lawyer who holds public office shall not allow professional or personal interests to conflict with the proper discharge of official duties. (3) If there may be a conflict of interest, a lawyer who holds or who held public office shall not represent clients or advise them in contentious cases that the lawyer has been concerned with in an official capacity.
11. Major submits that the law of the contempt is clear in the Federal Court Rules:
Rule 466. Subject to rule 467, a person is guilty of contempt of Court, this fact proves that Judges may be charged for contempt of the Court too; thus, it is requested that the Show Cause Order as against the Contemnor Near J be issued as there is a transcript to prove beyond a reasonable doubt that Near J did his best to make the contempt proceeding as an object of contempt in the eyes of the Contemnors.
12. The contempt rules against Loncar and Gotkin is clear too (a) At a hearing fails to maintain a respectful attitude, remain silent or refrain from showing approval or disapproval of the proceeding; The Contemnors Gotkin and Loncar’s actions, with intent to disturb Justice Snider, had knowledge that the noise disturbance amounts to mental and emotional abuse of the Judge or even if deny conspiracy to disturb the sensitive female judge to direct her anger toward Major; their recklessness amount to the criminal offence. In addition there are six affidavits filed by the Contemnors requiring be cross-examined.
Rule 466. Subject to rule 467, a person is guilty of contempt of Court, this fact proves that Judges may be charged for contempt of the Court too; thus, it is requested that the Show Cause Order as against the Contemnor Near J be issued as there is a transcript to prove beyond a reasonable doubt that Near J did his best to make the contempt proceeding as an object of contempt in the eyes of the Contemnors.
12. The contempt rules against Loncar and Gotkin is clear too (a) At a hearing fails to maintain a respectful attitude, remain silent or refrain from showing approval or disapproval of the proceeding; The Contemnors Gotkin and Loncar’s actions, with intent to disturb Justice Snider, had knowledge that the noise disturbance amounts to mental and emotional abuse of the Judge or even if deny conspiracy to disturb the sensitive female judge to direct her anger toward Major; their recklessness amount to the criminal offence. In addition there are six affidavits filed by the Contemnors requiring be cross-examined.
Rule 466(b) Disobeys a process or order of the Court;The Contemnors Gotkin and Sepe in particular Schutz, and with much more liability the Contemnor Flaim for Contempt Order of Justice Campbell, forgery by his party the Contemnors Jacobs, Moate, David Naylor and the University of Toronto in the Courts’ Data, including file T-1237-98 and committing perjury in his Affidavit and Notice of Application in file T-1020 -07; and having main role as party of the conspiracy as against administration of justice in the pending judicial review application and in the contempt proceeding before Justice Snider by forwarding the personal information of Justice Snider and Major to Loncar and teaching him how to use the tricks in the Court that be most effective. Furthermore, the CAS Contemnors Gosselin, Switzer and Hearings Coordinator are guilty of “Contempt Order” of Justice Snider for maliciously refusing to set a date for hearing of the pending contempt proceeding.
Rule466(c) acts in such a way as to interfere with the orderly administration of justice, or to impair the authority or dignity of the Court;
All Contemnors are liable under provision of Rule 466(c); however their punishment vary from maximum five year in jail for crimes such as perjury: the Contemnors Schutz and Sepe; fabricating evidence: Schutz, FRAUD in “Submissions before the Contempt Proceeding Judge” the Contemnors Loncar and in particular Daley; and the Contemnors Visitor Visa Officer in Tehran and Stebelsky for twelve years continuous interference with orderly administration of justice; and with a lesser punishment the Contemnors of the University of Toronto, the Law Society, and the Government of Ontario; in particular Onen, Jankovic, MacKay, Eyolfson, Jacobs and Moate.
All other Contemnors are guilty without a reasonable doubt under this rule, in particular Gotkin, Schutz, Loncar, Switzer and with much more liability Daley for allowing Schutz and Sepe make fake story in the Affidavit before the “Contempt Proceeding Judge”.
Rule 466 (d) is an officer of the Court and fails to perform his or her duty
Rule466(c) acts in such a way as to interfere with the orderly administration of justice, or to impair the authority or dignity of the Court;
All Contemnors are liable under provision of Rule 466(c); however their punishment vary from maximum five year in jail for crimes such as perjury: the Contemnors Schutz and Sepe; fabricating evidence: Schutz, FRAUD in “Submissions before the Contempt Proceeding Judge” the Contemnors Loncar and in particular Daley; and the Contemnors Visitor Visa Officer in Tehran and Stebelsky for twelve years continuous interference with orderly administration of justice; and with a lesser punishment the Contemnors of the University of Toronto, the Law Society, and the Government of Ontario; in particular Onen, Jankovic, MacKay, Eyolfson, Jacobs and Moate.
All other Contemnors are guilty without a reasonable doubt under this rule, in particular Gotkin, Schutz, Loncar, Switzer and with much more liability Daley for allowing Schutz and Sepe make fake story in the Affidavit before the “Contempt Proceeding Judge”.
Rule 466 (d) is an officer of the Court and fails to perform his or her duty
All Lawyers and the CAS staff Contemnors are liable to show cause. It is submitted that the Ministers Contemnors Nicholson, Kirvan, and Kenney are obligated to show cause under Rule 466(b)(c) and (d).
13. Major respectfully submits that the law of Show Cause Order instructed:
Rule 467. (1) Subject to rule 468, before a person may be found in contempt of Court, the person alleged to be in contempt shall be served with an order, made on the motion of a person who has an interest in the proceeding or at the Court's own initiative, requiring the person alleged to be in contempt
13. Major respectfully submits that the law of Show Cause Order instructed:
Rule 467. (1) Subject to rule 468, before a person may be found in contempt of Court, the person alleged to be in contempt shall be served with an order, made on the motion of a person who has an interest in the proceeding or at the Court's own initiative, requiring the person alleged to be in contempt
(a) to appear before a judge at a time and place stipulated in the order;
(b) to be prepared to hear proof of the act with which the person is charged, which shall be described in the order with sufficient particularity to enable the person to know the nature of the case against the person; and
(c) to be prepared to present any defence that the person may have. A motion for an order under subsection (1) may be made ex parte.
(3) An order may be made under subsection (1) if the Court is satisfied that there is a prima facie case that contempt has been committed.
An order under subsection (1) shall be personally served, together with any supporting documents, unless otherwise ordered by the Court.
Contempt in presence of a judge 14. It respectfully submitted that the law allows the Contemnors provide immediate proper explanations for professional misconduct of June 18, 2012 at the presence of Honorable Justice Snider:
468. In a case of urgency, a person may be found in contempt of Court for an act committed in the presence of a judge and condemned at once, if the person has been called on to justify his or her behaviour.
15. It is respectfully submitted that there is no doubt that a skillful honest experience lawyer of the Attorney General can be assistance in the complex contempt proceeding that the most powerful corporations with their top officials were named Contemnors and have obligated in law to reply:
Rule 471. Where the Court considers it necessary, it may request the assistance of the Attorney General of Canada in relation to any proceedings for contempt.
16. It is respectfully submitted that Rule 472 in details provide the jurisdiction of the Court that on September 24, 2012, convict the Contemnors Gotkin and Loncar on spot and sentence that no other lawyer ever think to step into the courtroom with plan to make the judge object of contempt, nuisance and emotional abuse, in particular when the Judge was female the Court must use its utmost power.
PART IV
ORDER SOUGHT
ORDER SOUGHT
17. Major requests all following orders or any order be granted that by Order:
(a) To set aside two Orders of this Court dated September 18, 2012 or alternatively to reconsider: (i) allowing relief sought in this judicial review application be granted by the Motion Judge that another Visitor Visa Officer reviews the application of the Applicant Farzad Nour Haghighi; or allowing continue this perfected judicial review application (ii) two contempt motions be set for the trial by an imperial judge who did not served the Deparment of Justice and/or the Attorney General.
(b) The Court condemns the Judge shopping by the Deparment of Justice and discriminatory practices in the services available by the Courts Administration Service as against the Applicant, Major Keyvan Nourhaghighi.
(c) The Respondent be required to served and filed a certified transcripts of show cause motions on June 18, 2012, and September 17, 2012 with the audiotapes.
(d) The Court condemns the Ottawa Hearings Coordinator and be require to show cause for contempt of the Court for malicious delay in complying with Rules to set a half day hearing since June 5 or June 18, 2012 for this perfected application pursuant to Rule 466(b)(c)(d) and be required to pay $1000.00 costs to the Contemnors under the Court’s Order of September 18, 2012 as a the third party liability; not the Applicants.
(e) The Contemnors John LONCAR, Catherine VASILAROS and the Deputy Minister of Justice and the Attorney General of Canada; Michael SWITZER, Jake SCHUTZ, Mario SEPE, Daniel GOSSELIN and the Courts Administration Service; Helen DALEY and Wardle Daley Bernstein LLP 3, Sean GOSNELL and Burden Ladner Gervals LLP be required to show cause for contempt of the Court for inter alia
conspiracy, perjury, forgery and/or incomplete affidavits, and/or fraud in oral and written submissions, fraud in Courts’ Data and Judge Shopping pursuant to Rule 466(b)(c)(d).
(f) The Contemnor Justice Donald J. RENNIE be required to show cause for contempt of the Court and the Motion Judge’s report his professional misconduct at the hearing to the Canadian Judicial Council for a conspiracy to defeat two contempt proceedings and by a slanderous order condemning Major and awarding costs to the Contemnors, where did not ask, unlawfully obstructed the lawful process of a perfected judicial application in such a way that brought the administration of justice in disrepute.
(g) The Costs of this motion to be paid forthwith in any event of the cause, to be fixed at $1500.00; and the costs of trial be awarded as a sanction.
ALL OF WHICH RESPECTFULLY SUBMITTED
Major Keyvan Nourhaghighi
Dated in the City of Toronto
_____________________________________________________
THIS IS EXHIBIT ‘A’ to Affidavit of Major Keyvan Nourhaghighi in the [Motion Record of T-478-12]Dated September 19, 2012
Commissioner of the Federal Court, the Toronto Registry Officer Shirley ACIRO
Court File No: 96-CU-113026
KEYVAN NOURHAGHIGHI; PLAINTIFF
Political Asylum Seeker as a Canadian-Since 1994
Political Asylum Seeker as a Canadian-Since 1994
-and-
BELL CANADA
THE SECRETARY GENERAL CANADIAN RADIO-TELEVISION
AND TELECOMMUNICATION COMMISSION; CANADA TRUST, THE BANK OF NOVA SCOTIA, CANADIAN IMPERIAL BANK OF COMMERCE,
OFFICE OF SUPERINTENDENT OF FINANCIAL INSTITUTIONS CANADA;
DAVID TRAVIS, METROPOLITAN LICENSING COMMISSION,
DIAMOND TAXI, CO-OP TAXI, TAXI NEWS; RICHARD SCHOBESBERGER; GREG LONG, EMPLOYMENT AND IMMIGRATION CANADA; THE EATON, THE EATON’S CENTER; CARLOS M. MONSALVE, ANGUS McTAVISH, AIRLINE TRAINING RESOURCES; BRIAN CARLICK, JOAN WILLIAMS, TORONTO AIRWAYS LIMITED; PAUL J. BOND, AVIATION INTERNATIONAL (CANADA) INCORPORATION; BRAMPTON FLYING CLUB; ALICOS; RUI GREGORIO, JULIE KNIGHT, MARK WALSH, GARG BILLINGTON, CHRISTOPHERFERNANDEZ, SCOTT STEPHENS, JOHN BADOWSKI, PETER DOLAMORE, JOHN DENNIS, DONALD MANTLE, PUBLIC COMPLAINTS INVESTIGATION BUREAU, HOMES and ACCUSE DAVID BOOTHBY, METROPOLITAN TORONTO POLICE; OFFICE OF THE POLICE COMPLAINTS COMMISSIONER; PETER M. BLECHER, PAUL J. MULLER, E. T.FORMAN, MAUREEN GANS,
THE COLLEGE OF PHYSICIANS AND SURGEONS; DOCTOR’S HOSPITAL;
SEAN L. GOSNELL, ERIC R. HOAKEN, BORDEN and ELLIOT; GRAEME MEW, SMITH LYONS; JACQUELINE WIGLE, H.W.O. DOYLE; JENNIFER WYATT, JASON KRAFT, GRAHAMBORTON, CHERUL McCACMONT, GAIL DOBENY, ALLAN SCOTT, SUZANNE LaVIGNE, JOHN KROMKAMPT,
JOSEPH CIRASO, T.E. BURTON, MICHAEL CODE, MARIE CARDNO, DONNA JOHANSTON, HUGETTE MALYON, MANDEL, KAIM MADIGAN, IAN MCNISH, J. JOSEPH, CHARLES HARNICK, MINISTRY OF ATTORNEY GENERAL OF ONTARIO; JANICE MACKINTOSH, FERN KIRSCH, ONTARIO INSURANCE COMMISSION, ALFRED SHUAL, PAMELA THOMSON, ACCUSED VIBERT A. LAMPKIN, RAMEZ KHAWLY, DONALD GRAHAM, ACCUSED ROBERT G. BIGELOW, ACCUSED HENRY N.R. JACKMAN,OFFICE OF THE CHIEF JUDGE OF ONTARIO COURT, OFFICE OF THE LIEUTENANT GOVERNOR OF ONATRIO; MICHAEL D. HARRIS, BURCE C. HAWKINS, ACCUSED AURTHOR C.WHEALY, OFFICE OF THE ASSOCIATE CHIEF JUSTICE OF ONTARIO COURT OF JUSTIICE, MARC DAMBORT, JEAN L. MACFARLAND, KEITH GIBSON, DONNA HALEY,
OFFICE OF THE REGIONAL SENIOR JUSTICE OF ONTARIO COURT OF JUSTICE,
ACCUSED DAVID H. DOHERTY, JOHN W. BROOKE, JEAN MARC LABROSSE ,
ACCUSE ROY McMURTRY and OFFICE OF CJIEF JUSTICE OF ONTARIO;
ACCUSED ANTONIO LAMER and OFFICE OF CHIEF JUSTICE OF CANADA;
ACCUSED ALLAN ROCK, MINISTRY OF JUSTICE AND ATTORNEY GENERAL OF CANADA, THE CROWN IN RIGHT OF ONTARIO, THE CROWN IN RIGHT OF CANADA, ROGER P. PARKINSON, THE GLOBE and MAIL; DEFENDANTS
BELL CANADA
THE SECRETARY GENERAL CANADIAN RADIO-TELEVISION
AND TELECOMMUNICATION COMMISSION; CANADA TRUST, THE BANK OF NOVA SCOTIA, CANADIAN IMPERIAL BANK OF COMMERCE,
OFFICE OF SUPERINTENDENT OF FINANCIAL INSTITUTIONS CANADA;
DAVID TRAVIS, METROPOLITAN LICENSING COMMISSION,
DIAMOND TAXI, CO-OP TAXI, TAXI NEWS; RICHARD SCHOBESBERGER; GREG LONG, EMPLOYMENT AND IMMIGRATION CANADA; THE EATON, THE EATON’S CENTER; CARLOS M. MONSALVE, ANGUS McTAVISH, AIRLINE TRAINING RESOURCES; BRIAN CARLICK, JOAN WILLIAMS, TORONTO AIRWAYS LIMITED; PAUL J. BOND, AVIATION INTERNATIONAL (CANADA) INCORPORATION; BRAMPTON FLYING CLUB; ALICOS; RUI GREGORIO, JULIE KNIGHT, MARK WALSH, GARG BILLINGTON, CHRISTOPHERFERNANDEZ, SCOTT STEPHENS, JOHN BADOWSKI, PETER DOLAMORE, JOHN DENNIS, DONALD MANTLE, PUBLIC COMPLAINTS INVESTIGATION BUREAU, HOMES and ACCUSE DAVID BOOTHBY, METROPOLITAN TORONTO POLICE; OFFICE OF THE POLICE COMPLAINTS COMMISSIONER; PETER M. BLECHER, PAUL J. MULLER, E. T.FORMAN, MAUREEN GANS,
THE COLLEGE OF PHYSICIANS AND SURGEONS; DOCTOR’S HOSPITAL;
SEAN L. GOSNELL, ERIC R. HOAKEN, BORDEN and ELLIOT; GRAEME MEW, SMITH LYONS; JACQUELINE WIGLE, H.W.O. DOYLE; JENNIFER WYATT, JASON KRAFT, GRAHAMBORTON, CHERUL McCACMONT, GAIL DOBENY, ALLAN SCOTT, SUZANNE LaVIGNE, JOHN KROMKAMPT,
JOSEPH CIRASO, T.E. BURTON, MICHAEL CODE, MARIE CARDNO, DONNA JOHANSTON, HUGETTE MALYON, MANDEL, KAIM MADIGAN, IAN MCNISH, J. JOSEPH, CHARLES HARNICK, MINISTRY OF ATTORNEY GENERAL OF ONTARIO; JANICE MACKINTOSH, FERN KIRSCH, ONTARIO INSURANCE COMMISSION, ALFRED SHUAL, PAMELA THOMSON, ACCUSED VIBERT A. LAMPKIN, RAMEZ KHAWLY, DONALD GRAHAM, ACCUSED ROBERT G. BIGELOW, ACCUSED HENRY N.R. JACKMAN,OFFICE OF THE CHIEF JUDGE OF ONTARIO COURT, OFFICE OF THE LIEUTENANT GOVERNOR OF ONATRIO; MICHAEL D. HARRIS, BURCE C. HAWKINS, ACCUSED AURTHOR C.WHEALY, OFFICE OF THE ASSOCIATE CHIEF JUSTICE OF ONTARIO COURT OF JUSTIICE, MARC DAMBORT, JEAN L. MACFARLAND, KEITH GIBSON, DONNA HALEY,
OFFICE OF THE REGIONAL SENIOR JUSTICE OF ONTARIO COURT OF JUSTICE,
ACCUSED DAVID H. DOHERTY, JOHN W. BROOKE, JEAN MARC LABROSSE ,
ACCUSE ROY McMURTRY and OFFICE OF CJIEF JUSTICE OF ONTARIO;
ACCUSED ANTONIO LAMER and OFFICE OF CHIEF JUSTICE OF CANADA;
ACCUSED ALLAN ROCK, MINISTRY OF JUSTICE AND ATTORNEY GENERAL OF CANADA, THE CROWN IN RIGHT OF ONTARIO, THE CROWN IN RIGHT OF CANADA, ROGER P. PARKINSON, THE GLOBE and MAIL; DEFENDANTS
JURY NOTICE
___________________________________________________________________Additional Public Information on Court File No: 96-CU-113026
This is pending lawsuit before the Ontario Court, in Toronto
STATEMENT OF CLAIM
1. The Plaintiff Claims:(a) An interim and permanent injunction and orders preventing the Defendants and their parties and agents from the following criminal acts against the Plaintiff and his family:
(1)- assault and battery;
(2) interferences and interceptions of the Plaintiff's:
I- communications, telephone, mails, businesses with Courts and Lawyers, doctors and banks, and others;
II- medical cares, banks accounts, services to be render;
III- domestic relations and contracts;
IV- files at offices and abuse of court process
V- files at hearings and abuse of administration of Justice
VI- files at trials and conspiracy with his witnesses;
VII- employment relations;
(3)- continuous malicious prosecutions and conspiracies for planting new causes of offenses and charges:
(4)- continuous arbitrary and unwarranted discretion of officials and judges;
(5)- continuous harassment and intimidation by frivolous and vexatious applications;
(6)- continuous intentional infliction of nervous shock, malicious false arrests and false imprisonments;
(7)- continuous organized deceits, robberies, frauds, conversions, detinues, clapping, misrepresentations;
(8)-continuous maintenance and champerty;
(9)-continuous gossiping and defamations against the Plaintiff;
(10)- trial of this action by a jury against the Crown Defendants as one cause of action of chains of conspiracies
(b) General Damages $2,000,000.00
(c) Aggravated and Emotional Damages $5,000,000.00
(d) Special Damages $200,000.00
(e) Punitive and Exemplary Damages $5,000,000.00
(f) Interest on the aforesaid sums from the date that notice was given to the Defendants, until Judgment, pursuant to provisions of the Court of Justice Act, R.S.O. 1990, Chapter C.43 and amendments
(g) His costs of this action on a solicitor and client bases;
(h) Such further and other relief as to this Honourable Court may seem Just.
2. The Plaintiff is a single parent with two children and landed immigrants as conventional refugees who resides in one bedroom apartment under exercise room of the corrupted Metropolitan Toronto Condominium Corporation Number 935 ("Condo 935"), in the City of Toronto, in the Municipality of Metropolitan Toronto, and was at all material times a Senior Fighter and Transport Pilot and officer of Iranian Air Force and Army, whose decisions and plans for joining to the Canadian Aviation Industries, Air Force and Transport Canada, were maliciously destroyed by conspiracies. ("Hereinafter "The Plaintiff Competition")
3. The Defendants, Her Majesty the Queen in the Right of Ontario (the Crown in the right of Ontario") and e Defendants, Her Majesty the Queen in the Right of Canada (the Crown in the right of Canada") had constitutional power to run Canada in "Peace, Order, and good Government", that at all material times, are ignoring the nature of Canadian Federalism, and creating "Fights and Disorders" for personal illegal benefits as the worse corrupted Governments TRAITOR to the Canadian Confederation.
4. The Defendants, ACCUSE Allan Rock and Ministry of Justice and Attorney General of Canada (the "Ministry of Justice"), ACCUSE Antonio Lamer and Office of Chief Justice of Canada, Charles Harnick and Ministry of Attorney General of Ontario (the "Ministry of Attorney"), ACCUSE R. Roy McMurtry and Office of Chief Justice of Ontario (the System"); is responsible in law to administrate the courts and justice systems according to rule of law; who has spent, fraudulently and maliciously about $100 Billion Dollars in last ten years, for Administration of Justice; while, in "CANADA" with this level of high education, the total costs should not exceed more than one Billion Dollars. The System, works in the same principle as a atomic reactor may operate; in 1991, a fraud in the accounts of Condo 935, has created tens of other actions to mislead the fact of frauds, a noise by-law charge against Condo 935, has created tens of proceedings, a motor vehicle accident was ended to uncountable trials and TORTURES and POISONING of the Plaintiff at Toronto Jail, and Old City Hall Jail. The System, is VERY aggravator.
Notice Paragraphs 5 to 99 omitted
100. The System, is in breaches of the Canadian Constitutional Law, and all other Laws, Codes, Acts, Procedures, Regulations and Practice Direction, that may effects its, or its DISHONEST and CRIMINAL Parties. The System, is acting in the name of "Elizabeth the Second" and has destroyed the total lawfulness in Canada and Ontario, for which THE PUBLIC ELECTION with GRACE OF GOD WILL CHANGE THE FUTURE OF THIS LAND AS A "HOME" FOR EVERYONE AS IT WAS PROMISED TO BE.
101. THE DEFENDANTS' ACTIONS CONSTITUTE A GREAT DISASTERS FOR WHOLE HUMANITY and SO HIGH-HANDED, CALLOUS, BRUTAL, UNREASONABLE, WANTON AND SO OUTRAGEOUS disregard of the Plaintiff's rights, for which the Plaintiff entitle to an award of aggravated, punitive and exemplary damages.
MAJOR KEYVAN NOURHAGHIGHI
