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MOTION FOR DIRECTION M42781                                                            Court file No.C56817

SUMMARY OF FACTS:

TAMPERINGING WITH and LOSS OF PUBLIC EVIDENCE

[1] Information or testimony on the missing DOCUMENTS and EXHIBIts can also be found in the AFFIDAVIT OF WAYNE FERRON(M42781).

·         PLEASE SEE PARA[24] – PARA[26] IN AFFIDAVIT OF WAYNE FERRON(M42781)

 

[2] On or about August 13, 2013, after Ms. Deborah Kirck returned COURT OF APPEAL FOR ONTARIO file C56817 to the RECORDS the Informant requested to view the same file. Upon checking C56817 at the COURT OF APPEAL FOR ONTARIO-Records it was discovered that MANDAMUS APPEAL HEARING TRANSCRIPT OF EVIDENCE (M61) bound in red covers was missing from COA file C56817.

 

[3]   The Private Prosecutor made an official requisition to the SUPERIOR COURT OF ONTARIO (TORONTO) to forward the aforementioned TRANSCRIPTION OF EVIDENCE (M61/M62/M98) to the COURT OF APPEAL FOR ONTARIO-RECORDS. The said TRANSCRIPT (M61) used as evidence at the appeal hearing at the lower courts is still missing or sanitized from court file C56817.

 

[4]     But Deborah Kirck (for the RESPONDENT(M42322)) also improperly removed public evidence (C56817) from the COURT OF APPEAL’S RECORD without a court order, without the Private Prosecutor's express given permission, without reasonable notice to the Informant,  without any court documentation to track the exhibits in question, and insure the integrity of the same original papers ,and EXHIBITS that were before the Honourable  Justice I.V.B. Nordheimer for review on March 11, 2013.

 

 

 

[55] Pursuant to Federal Courts Rules, SOR/98-106;

Inspection of files

26. (1) Where the necessary facilities are available, any person may, with supervision and without interfering with the business of the Court, inspect a Court file or annex

 

Removal of documents from file

(2) Nothing shall be removed from a Court file or annex except

(a) under an order of the Court;

(b) by an officer of the Registry acting in the course of his or her duties; or

(c) in accordance with rule 26.1.

Removal of files

(3) Unless otherwise ordered by the Court, no Court file or annex to a Court file shall be removed from the Registry by any person other than

(a) a judge, prothonotary or referee; or

(b) an officer of the Registry acting in the course of his or her duties.

SOR/2002-417, s. 3.

Definition

26.1 (1) In this rule, “appeal” includes an appeal of an order of a prothonotary, an application for leave to appeal and an appeal to the Supreme Court of Canada.

Removal of exhibits from file

(2) Subject to subsection (4), exhibits put into evidence shall remain in the Court file either

(a) until the time for an appeal has expired, if no appeal has been taken, or

(b) until the appeal is disposed of, if an appeal has been taken.

Return of exhibits

(3) On the expiry of the time for appeal or on the disposition of the appeal, the Administrator shall return the exhibits to the respective solicitors or the parties who put the exhibits in evidence.

Return on consent

(4) At any time following judgment, on requisition by the solicitor or party who put an exhibit in evidence or the person who produced it and on the filing of the consent of all parties, the Administrator shall return the exhibit to the person making the requisition.

SOR/2002-417, s. 4.

 

 

 

 [5]   In short, the public, and the Informant/Private Prosecutor was denied access to public evidence by Madame Deborah Krick, a Professional colleague of the alleged accuse. FURTHERMORE, a critical piece of evidence (Transcript(M61) bound in red covers) is missing, lost or disappeared from COURT OF APPEAL file C56817.

 

 

 

 

 

[6]   The following material evidence or EXHIBITS for CR-70000061/62, which were before the Honourable  Justice I.V.B. Nordheimer at the SUPERIOR COURT OF JUSTICE are ANNEXED from file C56817, missing from file C56817, has been lost or has been sanitized from COURT OF APPEAL file C56817:

1.) *EXHIBIT A₁55532 –  JUSTICE CROLL’S ORDER (M61) ;

2.) *EXHIBIT A₂55532 - JUSTICE NORDHEIMER'S ORDER TO MICHAEL MACLEAN(MANAGER OF S.C.J. REGISTRAR (M61);

 

3.) *EXHIBIT M55532 – UNCERTIFIED / COURT FILED

                PRE-ENQUETTE TRANSCRIPT (M61);

i)     received by CROWN on June 28^th, 2012

ii) mailed on the 26^th of July 2012

iii)                received on Wednesday August 1^st, 2012

iv) filed in the S.C.J. - REGISTARAR on the  24^th of July 2012

v)   TRANSCRIPT ORDER DATE is blank

vi) TRANSCRIPT completion DATE is blank

vii)              TRANSCRIPT completion notification DATE is blank

viii)               no certification

ix)                signiture by Arlene Gorewicz FORM 2 is not present

 

 

4.) *EXHIBIT O55532 – NOT CERTIFIED IN FORM 2/ COURT FILED

                PRE-ENQUETTE TRANSCRIPT(M61) ;        

i.    received by CROWN on June 28^th, 2012

ii.  mailed on or about  9^th of August 2012

iii.received on or about August 15^th, 2012

iv. filed in the S.C.J. - REGISTRAR on the  24^th of July 2012

v.   TRANSCRIPT ORDER DATE is blank

vi. TRANSCRIPT completion DATE is blank

vii.               TRANSCRIPT completion notification DATE is blank

viii.             undated signature of  Arlene Gorewicz is present

ix. FORM 2 is not pressent, nor is it certified in FORM 2

 

5.) *EXHIBIT S55532 - C56817 PRE-ENQUETTE TRANSCRIPT (M61/M62) ;                            

i.     bound in red covers,

ii.   served on all parties,

iii.  filed in the S.C.J. - REGISTRAR on the on Jan  24^th, 2013

 

6.)  5 copies of the  JANUARY 18, 2008 TRIAL TRANSCRIPTION(07-02559/07-02500), which proves conclusively that the AFFIDAVIT OF GAIL HUGH, which was relied on in the Crown's RESPONDENT MOTION RECORD(M61), is a  FALSE AFFIDAVIT, containing manufactured evidence or false evidence, and points to possible fraud if the Crown's evidence is factual.

·         PLEASE SEE IN AFFIDAVIT OF WAYNE  EXHIBIT C-M42781/M43160 ON PAGE 87 – PAGE 95

 

[7]   3  of the 5 copies of the  JANUARY 18, 2008 TRIAL TRANSCRIPTION(07-02559/07-02500), were CERTIFIED reproduction by the COURT OF APPEAL-RECORDS, one copy was served on the Informant by the Crown and the last copy was a copy of the CROWN'S COPY which was ordered to be disclosed to the Informant  by the Honourable Justice Watt(C51190/M38706).

[55] Pursuant to Federal Courts Rules, SOR/98-106;

 

Definition

26.1 (1) In this rule, “appeal” includes an appeal of an order of a prothonotary, an application for leave to appeal and an appeal to the Supreme Court of Canada.

Removal of exhibits from file

(2) Subject to subsection (4), exhibits put into evidence shall remain in the Court file either

(a) until the time for an appeal has expired, if no appeal has been taken, or

(b) until the appeal is disposed of, if an appeal has been taken.

Return of exhibits

(3) On the expiry of the time for appeal or on the disposition of the appeal, the Administrator shall return the exhibits to the respective solicitors or the parties who put the exhibits in evidence.

Return on consent

(4) At any time following judgment, on requisition by the solicitor or party who put an exhibit in evidence or the person who produced it and on the filing of the consent of all parties, the Administrator shall return the exhibit to the person making the requisition.

SOR/2002-417, s. 4.

 

·          

 

 [8]   All 5 copies of the  JANUARY 18, 2008 TRIAL TRANSCRIPTION(07-02559/07-02500), which proves conclusively that the AFFIDAVIT OF GAIL HUGH, is a FALSE AFFIDAVIT has been sanitized from COURT OF APPEAL file C56817, they just went missing!

·         PLEASE SEE PARA[24] – PARA[26] IN AFFIDAVIT OF WAYNE FERRON(M42781) AND EXHIBIT A-M42781/M43160 ON PAGE 72 – PAGE 79 AND  EXHIBIT C-M42781/M43160 ON PAGE 87 – PAGE 95

 

[9] Desire Viceral, a CLERK  at the COURT OF APPEAL-RECORD whom the Informant  reasonable believe to have acted under the directions of her manager, tried to covertly return the same evidence which was before the Honourable  Justice I.V.B. Nordheimer, to the Informant  byway of her manager's instructions, and with the message that the Informant had “already pay for” the said legal documents. For what purpose was the Informant being deceived?

 

 [10]  As soon as the Informant realized that the court documentations was the evidence placed before the Honourable  Justice I.V.B. Nordheimer ,  he boldly refuse all  5 copies of the  JANUARY 18, 2008 TRIAL TRANSCRIPTION(07-02559/07-02500), which is supposed to go before a reviewing court panel.

[55] Pursuant to Federal Courts Rules, SOR/98-106;

Proof of service

73. No document required to be served, other than an originating document, shall be filed without proof that it has been served within the time and in the manner provided for by these Rules.

Removal of documents improperly filed

·      74. (1) Subject to subsection (2), the Court may, at any time, order that a document that is not filed in accordance with these Rules or pursuant to an order of the Court or an Act of Parliament be removed from the Court file.

·        Opportunity for interested parties to be heard

(2) An order may be made of the Court's own initiative under subsection (1) only if all interested parties have been given an opportunity to be heard.

 

 

 

 [11]     THE MATERIALS TRANSFER EXHIBITS LIST(MO-7-061-12/C56817) which the COURT OF APPEAL FOR ONTARIO-RECORD'S Clerk refuse to certify on more than one occasion has the following discrepancies:

1.      The Informant appealed CR-70000061-12 from the SUPERIOR COURT OF JUSTICE to the COURT OF APPEAL FOR ONTARIO at the beginning of April 2013. He was not late in appealing the matter.

2.      The SUPERIOR COURT OF JUSTICRE release the MATERIAL EXHIBITS  for MO-061-12 on a undocumented date.

3.      The MATERIAL EXHIBITS  for MO-061-12 was released by Guiyab Sam on an undocumented date, in addition to Sam Guiyab neglecting to endorse  MATERIAL EXHIBITS  for MO-061-12 for  release to a lawful receiving authority or otherwise.

4.      The COURT OF APPEAL FOR ONTARIO received the MATERIAL EXHIBITS  for MO-061-12 on May 3^rd, 2013. 

5.    The MATERIAL EXHIBITS  for MO-061-12 was confirmed by Azra Parvok on the 17^th of July 2013 and filed under C56817.

6.      PLEASE SEE EXHIBIT G55532, MATERIALS/EXHIBITS TRANSFER LIST (MO-7-061-12/C56817).

 

·         PLEASE SEE PARA[24] – PARA[26] IN AFFIDAVIT OF WAYNE FERRON(M42781) AND EXHIBIT A-M42781/M43160 ON PAGE 72 – PAGE 79 AND  EXHIBIT C-M42781/M43160 ON PAGE 87 – PAGE 95

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

• [12]   Pursuant to the following RULES OF CIVIL PROCEDURE;
• RULE 4.08 – Requisition

·         REQUISITION

·         4.08  Where a party is entitled to require the registrar to carry out a duty under these rules, the party may do so by filing a requisition (Form 4E) and paying the prescribed fee, if any. R.R.O. 1990, Reg. 194, r. 4.08.

•  
• [13]   Pursuant to the following RULES OF CIVIL PROCEDURE;
• RULE 4:03 - Certified copies of court documents;

·         CERTIFIED COPIES OF COURT DOCUMENTS

·         4.03  On the requisition of a person entitled to see a document in the court file under section 137 of the Courts of Justice Act and on payment of the prescribed fee the registrar shall issue a certified copy of the document. R.R.O. 1990, Reg. 194, r. 4.03

•  
•  
• [14]   Pursuant to the following SECTIONS of the COURT OF JUSTICE ACT;
•     SECTION 137.(1) - DOCUMENT PUBLIC

·         Documents public

·         137.(1)On payment of the prescribed fee, a person is entitled to see any document filed in a civil proceeding in a court, unless an Act or an order of the court provides otherwise.

•  
•  
•  
• [15]   Pursuant to the following SECTIONS of the COURT OF JUSTICE ACT;
• SECTION 137.(3) - COURT LIST PUBLIC

·         Court lists public

·         (3)On payment of the prescribed fee, a person is entitled to see any list maintained by a court of civil proceedings commenced or judgments entered.

•  
• [16]   Pursuant to the following SECTIONS of the COURT OF JUSTICE ACT;
• SECTION 137.(4) - COPIES

·         Copies

·         (4)On payment of the prescribed fee, a person is entitled to a copy of any document the person is entitled to see. R.S.O. 1990, c. C.43, s. 137.

•  

 

 

 

 

 

 

 

 

[17]    Pursuant to Frederick E. Gibson in Toledo v. Canada (Minister of Citizenship and Immigration), 2005 FC 1572;

 

“[5]

  The issue of the impact of an incomplete transcript on the interests of an Applicant

 has often been before this Court in immigration judicial reviews in recent years. ^[1]  Typical of the

 reasoning of my colleagues in the cited authorities are the following comments of Justice

 Layden-Stevenson in the Randhawa matter, to the following effect:

 

Despite the capable and articulate arguments and submissions of counsel for the respondent, the

 applicant has persuaded me that the board's credibility findings with respect to the witnesses in

 question were fundamental to the decision. I am mindful of the comments of Evans J., as then

 was, in Hassan v. Canada ... that given the nature of a vacation hearing, an individual is entitled

 to the clearest assurance that the board has given full and fair consideration to the

 evidence.

 

[citations omitted]

 

[6]

  Although the hearing that is here under review was not a "vacation hearing", I am

 satisfied that the implications of the Convention refugee hearing here before the Court equally

 entitle an individual such as the Applicant to the clearest assurance that the RPD has given full

 and fair consideration to his evidence.

 

{…}

 

[8]

 Unfortunately, the "entire ruling" is not on the record. I am satisfied that, in the

 absence of the "entire ruling", this Court is substantially disadvantaged in ensuring a full and fair

 hearing, not only in the interests of the Applicant, but also in the interests of the presiding

 member himself.

 

 

[9]

  For the foregoing reasons, and without consideration of the merits of the substantive

 issues raised on behalf of the Applicant, this application for judicial review will be allowed. The

 decision under review will be set aside, and the Applicant's application for Convention refugee

 status or equivalent protection will be referred back to the Immigration and Refugee Board for

 rehearing and redetermination by a differently constituted panel.”

 

 

 

 

 

[18]  Pursuant to Justice Lutfy in Razm v. Canada (Minister of Citizenship and Immigration);

 

 

“[6] {…}

In this case, no meaningful judicial review can be achieved with the partial transcript, one which discloses potentially serious errors. The incomplete record does not allow me, in the words of Justice L'Heureux-Dubé in CUPE,13 "to properly dispose of this application for judicial review" on the substantive issues. “

 

 

 

 

 

 

 

 

[19]  Pursuant to Justice Hill in HER MAJESTY THE QUEEN v. CHRISTINE McNEILLY and KARLA ) ROY, CRIMJ(F) 7930/04;

 

[15]  In turn, personnel in the court reporters’ office have an obligation to

produce ordered transcripts as expeditiously as possible. Orders cannot simply

be ignored.  Indeed, whenever a transcript is ordered it is expected, as is

expressly dictated respecting appeals (Rule 40.06(11)), that the reporter “shall

proceed with reasonable diligence to prepare” the transcript.

Where a  monitor/reporter is unable to complete a transcript within a reasonable time he or she should notify a supervisor in order to have a workload assessment. At times, depending on the circumstances of the delinquency in completing the transcript, including the length of the delay or anticipated delay, the monitor/reporter should notify the ordering counsel. Again, any communications with counsel’s office  should be in writing to eliminate disputes as to representations or statements made and to ensure an accurate record is available to any reviewing court on an application for directions or at the hearing of the application itself.

 

 

 

{...}

[19]  From experience in past cases with similar problems (i.e. R. v. Williams,

S.C.J. Brampton Court File #7339/04, Feb. 20, 2004, page 1), it is a notorious

fact that some clerks in the Ontario Court of Justice the day before, or the

morning when, court convenes, endorse on the information the name of the clerk

and reporter expected to preside in a particular courtroom. Then, on occasion,

assignments and courtrooms change as staff are moved or cases traversed

without any amendment to the pre-endorsed names on the informations. The

As noted in R. v. M(R.), [2003] O.J. No. 2055 (S.C.J.) at para. 27-31, the first two- 11 -

 

monitor/reporter erroneously believing the person who took the evidence is the

individual whose name is endorsed incorrectly on the information.

This altogether too prevalent approach of the Ontario Court of Justice personnel pre-endorsing the identity of those in the courtroom without subsequent amendmentwhen circumstances change creates havoc and delay as in this case and others.

In this case, two of the court monitors recorded on the information as in court

taking the evidence on court days relating to two of the outstanding transcripts

were apparently not the monitors who took the evidence on the relevant dates.

With respect to one of these dates, the reporters’ office wrote counsel to say:

 

In the matter of Christine McNeilly, the transcript for the date of June 6/03 will not be completed unless the correct information is faxed to our office. The reporter has checked  her notes and it was not in the court that was provided. It was a P.O.A. Ct. on June 6/03.

 

While the reply was accurate it proved to be unhelpful when counsel has no way

of determining the identity of the monitor whose name was not recorded on the

information – a fact available to, and only discoverable by, government

personnel.”

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

ISSUES OF LAW:

 

THE MOTION IS FOR:

1.an order for supporting staff to the ADMINISTRATION OF JUSTICE or COURT SERVICES DIVISION(MINISTRY OF ATTORNEY GENERAL) , to forthwith cease and desist from impeding, obstructing, perverting, or attempting to defeat the course of justice;

2. an order of the court to secure and insure the integrity of documents and exhibit for COURT OF APPEAL file C56817;

3.an order of the court to compel the forthwith return of missing EXHIBITS(C56817), by whomever or whatever entity has improperly removed EXHIBITS  and COURT DOCUMENTS from C56817. The missing evidence are PUBLIC EVIDENCE and should be treated as such;

4.an order for unimpeded access to necessary court files for the preparation and and perfection of the appeal;

5.an order for Ms. Gorewicz(court Reporter) to disclose of the Order Date of Transcript(M61  & M62),  Completion Date of Transcript (M61  & M62), and Notification Date of two TRANSCRIPTS(M61 & M62) which were produced for the Crown by Ms Ms. Arlene Gorewicz, and filed at the lower courts by the CROWN on June 24^th,  2012;

6.an order for Ms. Arlene Gorewicz(court Reporter) to disclose  a copy of “COURT REPORTER'S NOTIFICATION OF TRANSCRIPT COMPLETION(C56817)” and a copy of the filed “CERTIFICATE OF COMPLETION(C56817)” for the March 6^th, 2012 PRE-ENQUETTE TRANSCRIPT(C56817);

7.an order for Alana Trumpy(court Reporter) to disclose  a copy of “COURT REPORTER'S NOTIFICATION OF TRANSCRIPT COMPLETION(C56817)” and a copy of the filed “CERTIFICATE OF COMPLETION(C56817)” for the February 4^th, 2013 TRANSCRIPT(C56817);

8.an order for Joy Webster(court Reporter) to disclose  a copy of “COURT REPORTER'S NOTIFICATION OF TRANSCRIPT COMPLETION(C56817)” and a copy of the filed “CERTIFICATE OF COMPLETION(C56817)” for the March 11^th, 2013  HEARING TRANSCRIPT(C56817);

9.an order for Sioban Neville(court Reporter) to disclose  a copy of “COURT REPORTER'S NOTIFICATION OF TRANSCRIPT COMPLETION(C56817)” and a copy of the filed “CERTIFICATE OF COMPLETION(C56817)” for the April 30^th, 2012 TRANSCRIPT(C56817);

10.an order for M. Waters(court Reporter) to disclose  a copy of “COURT REPORTER'S NOTIFICATION OF TRANSCRIPT COMPLETION(C56817)” and a copy of the filed “CERTIFICATE OF COMPLETION(C56817)” for the  February 11^th, 2013 TRANSCRIPT(C56817);

11.an order for M. Waters(court Reporter) to disclose  a copy of “COURT REPORTER'S NOTIFICATION OF TRANSCRIPT COMPLETION(C6817)” and a copy of the filed “CERTIFICATE OF COMPLETION(C6817)” for the  July 30^th, 2012 TRANSCRIPT(C56817);

12.an order for Orbe Santiago(court Reporter) to disclose  a copy of “COURT REPORTER'S NOTIFICATION OF TRANSCRIPT COMPLETION(C56817)” and a copy of the filed “CERTIFICATE OF COMPLETION(C56817)” for the  June 4^th, 201 TRANSCRIPT(C56817);

13.an order for Marc Lacroix(court Reporter) to disclose  a copy of “COURT REPORTER'S NOTIFICATION OF TRANSCRIPT COMPLETION(C56817)” and a copy of the filed “CERTIFICATE OF COMPLETION(C56817)” for the  June 18^th, 2012 TRANSCRIPT(C56817);

14.an order for Orbe Santiago(court Reporter) to disclose  a copy of “COURT REPORTER'S NOTIFICATION OF TRANSCRIPT COMPLETION(C56817” and a copy of the filed “CERTIFICATE OF COMPLETION(C56817)” for the  June 4^th, 2012 TRANSCRIPT(C56817);

15.an order for Orbe Santiago(court Reporter) to disclose  a copy of “COURT REPORTER'S NOTIFICATION OF TRANSCRIPT COMPLETION(C56817)” and a copy of the filed “CERTIFICATE OF COMPLETION(C56817)” for the  October 9^th, 2012 TRANSCRIPT(C56817);

16.an order to compell the COURT OF APPEAL FOR ONTARIO-RECORD'S to certify 2 copies of 5 copies of the  JANUARY 18, 2008 TRIAL TRANSCRIPTION(07-02559) that was before the Honourable  Justice I.V.B. Nordheimer, which proves conclusively that the AFFIDAVIT OF GAIL HUGH that was relied on in the Crown's RESPONDENT MOTION RECORD(M61), is a  FALSE AFFIDAVIT, in addition to at least one of the exhibits in the same RESPONDENT MOTION RECORD(M61) the crown was relying on in the hearing was fraudulent, or manufactured evidence, or maliciously instituted as evidence. The COURT OF APPEAL-RECORD'S refused to certify court produced copies of the 5 missing document in question which the Informant found in closed file C51190.

17.an order to compell the COURT OF APPEAL FOR ONTARIO-RECORD'S to certify 2 copies of  the MATERIALS TRANSFER EXHIBITS LIST(MO-7-061-12/C56817) in accordance with a past precedence, the RULES OF THE COURT, and the COURT OF JUSTICE ACT; the COURT OF APPEAL FOR ONTARIO-RECORD'S Clerk has refuse to certify the same court document on many many occassions in addition to failing to reply to two formal written requestions  for a certified copy the MATERIALS TRANSFER EXHIBITS LIST(MO-7-061-12/C56817) on more than one occasion;

18.to give any relief or remedy this Honourable Court deems just and reasonable.

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

THE GROUNDS FOR APPEAL ARE:

1.      Absence of evidence of written “COURT REPORTER'S NOTIFICATION OF TRANSCRIPT COMPLETION(C56817)” in accordance with RULE 40.06(11) AND RULE 8(16) of THE RULES OF CRIMINAL PROCEDURE;

2.    Absence of evidence of filed copies of the  “CERTIFICATE OF COMPLETION(C56817)” for all TRANSCRIPTS;

3.    Section 1. of the HUMAN RIGHT'S ACT, Section 15(1) of the CHARTER, Section 482 of the CRIMINAL CODE;

4.    RULE 1, RULE 2, RULE 8(16), RULE 40.06, and  RULE 40.08;

5.    SECTION 1, SECTION 3, SECTION, 4, SECTION 9, SECTION 10, SECTION 44   of R.S.Q CHAPTER C-12 CHARTER OF HUMAN RIGHTS AND FREEDOMS

6.      ARTICLE 1, ARTICLE 2, ARTICLE 3, ARTICLE 14, ARTICLE 26, ARTICLE, 50, ARTICLE 51 of the INTERNATIONAL COVENANT OF CIVIL AND POLITICAL RIGHTS;

7.      PROCEDURAL FAIRNESS RIGHTS

8.    BILL OF RIGHTS

9.    Such further other grounds as counsel may advise and this Honourable Court may permit.

 

 

 

Monday, May 25, 2015

 

     _____________________________

Wayne FERRON(Informant)

1-18 Earlscourt Ave. Toronto,

 ON,    Postal Code     M6E 4A6

Tel: 416 420 1353, Email: wayneferron@gmail.com

TAKE NOTICE: I JUST RECENTLY CAME OFF THE STREETS OF TORONTO AS LIVING AS A VAGABOND. MY RECIDENCE FLOODS AND IS INFECTED WITH BLACK MOLD; I AM FORCED TO LIVE INHUMAINLY AND EXPECTED TO BRING MY DAUGHTER WHOM I HAVE FULL CUSTODY FOR, TO LIVE THERE. I am left to die in the said conditions by ONTARIO-WORKS. PLEASE SEND ANY LEGAL SERVICE  MATERIAL BY REGISTERED MAIL, TO BE PICKED UP AT THE POST OFFICE; THERE IS NO ASSURANCE THAT  MATERIAL SERVED AT THE ABOVE ADRESS BY REGULAR MAIL WILL BE RELAYED TO MY PERSON, IN ADDITION TO THE SMALL POST BOX CONTENTS BEING EXPOSED TO THE NATURAL ELEMENTS. I AM NOT HOME IN THE DAY TIME, I MOSTLY ONLY SLEEP AT THE ABOVE ADDRESS.

 

All of which is respectfully submitted.

 

 

        _____________________________

Wayne FERRON(Informant)

 

1-18 Earlscourt Ave. Toronto,

 ON,    Postal Code     M6E 4A6

Tel: 416 420 1353,

Email: wayneferron@gmail.com

TAKE NOTICE: I JUST RECENTLY CAME OFF THE STREETS OF TORONTO AS LIVING AS A VAGABOND. MY RECIDENCE FLOODS AND IS INFECTED WITH BLACK MOLD; I AM FORCED TO LIVE INHUMAINLY AND EXPECTED TO BRING MY DAUGHTER WHOM I HAVE FULL CUSTODY FOR, TO LIVE THERE. I am left to die in the said conditions by ONTARIO-WORKS. PLEASE SEND ANY LEGAL SERVICE  MATERIAL BY REGISTERED MAIL, TO BE PICKED UP AT THE POST OFFICE; THERE IS NO ASSURANCE THAT  MATERIAL SERVED AT THE ABOVE ADRESS BY REGULAR MAIL WILL BE RELAYED TO MY PERSON, IN ADDITION TO THE SMALL POST BOX CONTENTS BEING EXPOSED TO THE NATURAL ELEMENTS. I AM NOT HOME IN THE DAY TIME, I MOSTLY ONLY SLEEP AT THE ABOVE ADDRESS.

 

TO:  

        The Clerk of the Court--Registrar

                COURT OF APPEAL FOR ONTARIO

Osgoode Hall

130 Queen Street West

Toronto, Ontario, M5H 2N5

Tel:           416 327 5020

Fax:          416 327 6032

AND TO:

Attn. Deborah Krick

The Attorney General of Ontario

CRIMINAL LAW BRANCH

6th floor

720 Bay Street

Toronto, Ontario M5G 2K1

 

fax: 416 326 4015

 

TO:     

The Clerk of the Court--Registrar

COURT OF APPEAL FOR ONTARIO

Osgoode Hall

130 Queen Street West

Toronto, Ontario, M5H 2N5

Tel:                  416 327 5020

Fax:                416 327 6032

 

AND TO:

 

Crown Attorney

Criminal - Crown Attorney’s Office

Superior Court of Justice

361 University Avenue

Toronto, ON M5G 1T3

Telephone: 416-327-5917

 

AND TO

 

The Attorney General of Onta

Constitutional Law Branch

4th floor

720 Bay Street

Toronto, Ontario M5G 2K1

 

fax: 416 326 4015

 

AND TO:

 

The Attorney General of Canada

Constitutional Law Branch

Suite 3400, Exchange Tower

Box 36, First Canadian Place

Toronto, Ontario M5X 1K6

 

fax: 416 973 3004

 

 

 

 

 

COURT OF APPEAL FOR ONTARIO

 

Wayne Ferron -versus- HER MAJESTY THE QUEEN

C56817 / M 42781

COURT OF APPEAL FOR ONTARIO   PROCEEDING COMMENCED AT Osgoode Hall 130 Queen Street West Toronto, Ontario, M5H 2N5   AFFIDAVIT OF WAYNE FERRON ___________________________ FACTUM FOR CONSTITUTIONAL APPLICATION (PRIVATE PROSECUTOR/ INFORMANT) ____________________________________________ Wayne FERRON 1-18 Earlscourt Ave. Toronto, ON, M6E 4A6 Tel: 416 420 1353, Email: wayneferron@gmail.com TAKE NOTICE: I JUST RECENTLY CAME OFF THE STREETS OF TORONTO AS LIVING AS A VAGABOND. MY RECIDENCE FLOODS AND IS INFECTED WITH BLACK MOLD; I AM FORCED TO LIVE INHUMAINLY AND EXPECTED TO BRING MY DAUGHTER WHOM I HAVE FULL CUSTODY FOR, TO LIVE THERE. I am left to die in the said conditions by ONTARIO-WORKS. PLEASE SEND ANY LEGAL SERVICE  MATERIAL BY REGISTERED MAIL, TO BE PICKED UP AT THE POST OFFICE; THERE IS NO ASSURANCE THAT  MATERIAL SERVED AT THE ABOVE ADRESS BY REGULAR MAIL WILL BE RELAYED TO MY PERSON, IN ADDITION TO THE SMALL POST BOX CONTENTS BEING EXPOSED TO THE NATURAL ELEMENTS. I AM NOT HOME IN THE DAY TIME, I MOSTLY ONLY SLEEP AT THE ABOVE ADDRESS.