A to I Canadian Counter Dictionary and British Human Rights Violations in Canada

This is the first Wikipedia created by Major Nourhaghighi in 1995 in which it contains the name and profession of most of the Crown employees in Province of Ontario and Quebec who were engaged in his files, and their corrupt agents' names. It also give a new definition for many names such as CANADA, LAW is actual way that Major experienced during 27 years and that is the reason he name it " Counter Dictionary"

Tuesday 24 May 2016

Five Canadian Lawyers in Contempt In Face of Court PART III Arrested by RT Hon Major Nourhaghighi سرگرد نورحقیقی پنج وکیل کلاهبردار کانادائی را بجرم اهانت بدادگاه محاکمه کرد

Autobiography of the Lord of Law

Major Keyvan Nourhaghighi
July 19, 1990 to January 4, 2019
Major Nourhaghighi Encyclopedia 2019
Down With Queen & Corruption in Canada

Canadian Counter-Dictionary and British Human Rights' Violations in Canada

A B C D E F G H I J K L M N O P Q R S T U V W X Y Z

Contempt Process by the Lord of Law as against Five Canadian Corrupt Lawyers
before the corrupt Federal Court of Canada

Autobiography of Major Nourhaghighi

You Canadian Chickenshit Cowards
who didn't have the Balls
کانادائیهای بی ارزش ترسوی بی خایه

Hamilton commenced crying during Trial :)

Major Nourhaghighi: An Order under that Robert Jaworski, Arthur Hamilton,
Debra Armstrong, Steven Weisz, and Kate Broer be require to show cause for contempt.

________________________________________

Five Canadian Lawyers accused of Contempt in the Face of Court

Court File No: T-1535-2000

FEDERAL COURT- TRIAL DIVISION

BETWEEN:

KEYVAN NOURHAGHIGHI, Applicant

-and-

CANADIAN HUMAN RIGHTS COMMISSION, MERVIN WITTER, BOB FAGAN;
BELL CANADA, SPRINT CANADA, JENNIFER WILSON,
THE CANADIAN RADIO-TELECOMMUNICATIONS COMMISSION;
ROBERT BIRGENEAU, THE UNIVERSITY OF TORONTO; ROBERT PEARCE,
THE BANK OF MONTREAL, THE CANADIAN IMPERIAL BANK OF COMMERCE,
DENNIS OSBORNE, BANK OF NOVA SCOTIA,
THE MBNA CANADA BANK, TORONTO DOMINION BANK, NICOLE BARBE,
OFFICE OF THE SUPERINTENDENT OF FINANCIAL INSTITUTIONS CANADA;
ROYAL CANADIAN MOUNTED POLICE; RICHARD SCHOBESBERGER, TINA SOARES, THE TRANSPORT CANADA; BRUCE PRESTON, MICHEL LORTIE, ORLAND CARRYL, ANNE EDGE, ANNE ROLAND and
THE ATTORNEY GENERAL OF CANADA; Respondents

APPLICATION UNDER Rule 466 of the Federal Court Rules

NOTICE OF MOTION

Table of Content

Notice of Motion October 24, 2000 page 1
Affidavit of Keyvan Nourhaghighi sworn October 24, 2000 , page 3
Exhibit "A"
Affidavit of Keyvan Nourhaghighi sworn September 18, 2000, page 7
Exhibit "I" Nourhaghighi V. Ontario Judicial council et al 96-CU-104952, page 10
Pleading against Business Dept; re: Thefts & forgery P. 196-Sept 14/00
Exhibit "II" Bank of Nova Scotia did not honor a cheque from power line 11
IIa: LETTER; From: The City of Toronto, Revenue, Sept 21, 1998
To: K. Nourhaghighi; RE: Rejected by Bank
IIb: City of Toronto, Return Payment Notice, Sept 7 to 18, 1998, page 12
RE: Your $168.77 on Sept 8/98 dishonored by bank and marked
"Refused to Declare" than changed to "Edit Reject"
IIc: Copy from another Scotiabank cheque given to the City 12
RE: Mental Anguish in Appeal Hearing on Sept 21, 1998 against Torture
IId: Three NSF records in Applicant's account Nov &Dec 1999 13
in Condo by Bank of Montreal
IIe: LETTER; From: Property Manager Blair, January 24, 2000 14 To: Nourhaghighi; RE: Two return items are now property of Condo
To be used in defence for Frauds in the accounts by the AGO
RE: To obstruct contempt proceeding on Dec 16/99 against the AGO
IIf: Two Sprint Canada statements, August 28, 2000 15
no mailing address; RE: GILES ORDER September 1, 2000
Exhibit "III" Clerical Improper Influences as Discriminatory Practic 16
Nourhaghighi Affidavit in Ontario court of Appeal Sept 12, 1997, Theft of original file by Borden and Elliot and the Law Society in Court of Appeal in C26841, re: Respondent ROLAND Exhibit "4e"
Exhibit "B" Notice of CROSS Motion-Crown October 17, 2000 17
Exhibit "C" Letter, from Birthwright, to Clerk Yau September 18, 2000 20
Exhibit "D" Memo, From Clerk Yau, to all parties September 18, 2000 21
Exhibit "E" Nourhaghighi Complaint against Police September 18, 2000 22
Exhibit "F" Notice of CROSS Motion-Birgeneau October 19, 2000 23
Exhibit "G" Giles Order September 1, 2000 25
Exhibit "H" Affidavit of Debra Armstrong sworn October 19, 2000 27
Exhibit "I" Written Examination for Debra Armstrong October 23, 2000 29

Court File No: T-1535-00

FEDERAL COURT -TRIAL DIVISION

BETWEEN:

KEYVAN NOURHAGHIGHI Applicant

-and-

CANADIAN HUMAN RIGHTS COMMISSION, MERVIN WITTER, BOB FAGAN;
BELL CANADA, SPRINT CANADA, WENNIFER WILSON,
THE CANADIAN RADIO-TELECOMMUNICATIONS COMMISSION;
ROBERT BIRGENEAU, THE UNIVERSITY OF TORONTO; ROBERT PEARCE,
THE BANK OF MONTREAL, THE CANADIAN IMPERIAL BANK OF COMMERCE,
DENNIS OSBORNE, BANK OF NOVA SCOTIA,
THE MBNA CANADA, TORONTO DOMINION BANK, NICOLE BARBE,
OFFICE OF THE SUPERINTENDENT OF FINANCIAL INSTITUTIONS CANADA;
ROYAL CANADIAN MOUNTED POLICE; RICHARD SCHOBESBERGER, TINA SOARES, THE TRANSPORT CANADA; BRUCE PRESTON, MICHEL LORTIE, ORLAND CARRYL, ANNE EDGE, ANNE ROLAND and THE ATTORNEY GENERAL OF CANADA; Respondents

__________________________________________________

MOTION RECORD

__________________________________________________

Keyvan Nourhaghighi, 608-456 College Street Toronto, Ontario M6G 4A3 Tel: (416) 515 7263
TO: Administrator
And to RENE DUVAL, Solicitor for the respondents, Mervin Witter, Bob Fagan, the CHRC
ALLAN ROSENZVEIG, Solicitor for the respondent, J. Wilson, the CRTC
GIULIO D'ALESSANDRO, Solicitor for the respondent, BELL CANADA,
Michael Quenneville, Solicitor for respondent the Canadian Imperial Bank of Commerce
TAYLOR for Respondent the Toronto-Dominion Bank
Arthur Hamilton, Solicitor of the respondent, Bank of Nova Scotia
Kate Broer, Solicitor for the respondents, Sprint Canada, and The Bank of Montreal
Steven J. Weisz, Solicitor for the respondent, the MBNA Canada Bank
Debra Armstrong, the respondent, the MBNA, to be served via Weisz;

Page 1
Court File No: T-1535-00

FEDERAL COURT -TRIAL DIVISION
BETWEEN:
KEYVAN NOURHAGHIGHI, Applicant
-and-
CANADIAN HUMAN RIGHTS COMMISSION, MERVIN WITTER, BOB FAGAN;
BELL CANADA, SPRINT CANADA, WENNIFER WILSON,
THE CANADIAN RADIO-TELECOMMUNICATIONS COMMISSION;
ROBERT BIRGENEAU, THE UNIVERSITY OF TORONTO; ROBERT PEARCE,
THE BANK OF MONTREAL, THE CANADIAN IMPERIAL BANK OF COMMERCE,
DENNIS OSBORNE, BANK OF NOVA SCOTIA,
THE MBNA CANADA, TORONTO DOMINION BANK, NICOLE BARBE,
OFFICE OF THE SUPERINTENDENT OF FINANCIAL INSTITUTIONS CANADA;
ROYAL CANADIAN MOUNTED POLICE; RICHARD SCHOBESBERGER, TINA SOARES, THE TRANSPORT CANADA; BRUCE PRESTON, MICHEL LORTIE, ORLAND CARRYL, ANNE EDGE, ANNE ROLAND and THE ATTORNEY GENERAL OF CANADA; Respondents

NOTICE OF MOTION

THE APPLICANT will make a motion to a judge on Monday 30 day of October 2000 at 09:30 AM, at 330 University Avenue, Toronto; pursuant Rule 466 (b)(c)(d) of the Federal Court Rules.

THE MOTION IS FOR:
a. An Order under that Robert Jaworski, Arthur Hamilton, Debra Armstrong, Steven Weisz, and Kate Broer be require to show cause for contempt.
THE GROUND OF THIS MOTION ARE:
1. That defendants for contempt have violated the codes of professional conduct, acted in concert to disobey order of the Court, in such a way as to interfere with the orderly administration of justice impair the authority and dignity of the Court;
2. That Borden Lander Gervais LLP-(Borden and Elliot) who was accused of theft of the Applicant's documents, has committed theft of evidence before this Court which contains in the Applicant's Affidavit, that he provided on his Affidavit sworn on Sept 18, 2000;
3. That Jaworski, Hamilton, Armstrong and Weisz, in a concert act and pursuant to an agreement have omitted the Applicant's Affidavit sworn of September 18, 2000, on the material filed by them in the Court, with intent to mislead and obstruct the justice;
4. That Weisz, maliciously, acted in accordance to calculated objects to obstruct justice and confuse the process, by all kinds of harassing correspondences, personal law firm retaliations where its partner, Stephenson was accused of in another case;
Page 2
2
5. That Weisz, Jaworski, Hamilton are disobeying Giles Order made on Sept 1, 2000 who instructed the originating notice must be served in person to the party;
6. That Jaworski and Hamiton have brought motions in the names of the respondents who have not filed notice of appearance and failed to serve in person their appearance;
7. That Broer misrepresented two corporations, Sprint Canada and the Bank of Montreal and maliciously omitted Respondent Robert Pearce from record. Broer, with improper influences has maliciously abused the process and was successful to get a judgment on September 1, 2000 where Order does not refer to actual, cause for Broer's withdrawal, Findely created fabricating document to cover-up scandal after it discovered.
8. That Broer and Jaworski had irregular conduct with the administrators, and forwarded to requests to the judiciary, without any kind of motions, and have obtained two contradictory orders that have caused confusion for the judiciary;
9. As the result of the outrageous and dishonest conducts of defendants for contempt the main stream of the Applicant, URGENT, Application is obstructed with ample malicious
vexatious materials, to delay the court process for which they must show cause for the Criminal Contempt in the Face of Court and the Civil Contempt.
THE FOLLOWING DOCUMENTARY EVIDENCE will be presented:
(a) Affidavit of Keyvan Nourhaghighi;
(b) The Court Record: Three Affidavit of Nourhaghighi sworn September 14, 15, 18, 2000; Giles and Lafreniere Orders; ALL correspondences, Notice of Appearance, Affidavit Service filed by all parties; Irregularity in filing of documents by parties
(c) such further and other evidence that be available after service of this Notice of Motion.
Dated in Toronto, in the Province of Ontario October 24, 2000.
Keyvan Nourhaghighi
608-456 College Street
Toronto, Ontario
M6G 4A3
TO: Administrator Tel: (416) 515 7263
RENE DUVAL, Solicitor for the Respondents, Mervin Witter, Bob Fagan, the CHRC
ALLAN ROSENZVEIG, Solicitor for the Respondent, J. Wilson, the CRTC
GIULIO D'ALESSANDRO, Solicitor for the Respondent, BELL CANADA,
MICHAEL G. QUENNEVILLE, Solicitor for the Canadian Imperial Bank of Commerce
Arthur Hamilton, Solicitor of the respondent, Bank of Nova Scotia
Kate Broer, Solicitor for the Respondents, Sprint Canada, and The Bank of Montreal
Steven J. Weisz, Solicitor for the Respondent, the MBNA Canada Bank
Debra Armstrong, to be served via Weisz;
Taylor, for the Respondent, the Toronto-Dominion Bank
Robert H. Jaworski, Solicitor for the CROWN
The Applicant asking two hours for his arguments, fifteen minutes for each reply to counsels.
Page 3

Court File No: T-1535-00

FEDERAL COURT- TRIAL DIVISION

BETWEEN:

KEYVAN NOURHAGHIGHI, Applicant

and-

AFFIDAVIT OF KEYVAN NOURHAGHIGHI

I, Keyvan Nourhaghighi, the Applicant, resident at 608-456 College Street, Toronto, Ontario, M6G 4A3, SWEAR THAT:

1. I am the Applicant as such have knowledge of the matters herein and after deposed to.
2. As a responsible citizen, I have right to have a motion and demand from the Court to stand for prosecution against the solicitors, Robert Jaworski, Arthur Hamilton, Debra Armstrong, Steven Weisz, and Kate Broer to show cause for civil and criminal contempt. My obligations restricted to point out material facts against the solicitors defendants brought the administration of justice into disrepute. The Court is obligated for professional prosecution against the contemptor.
3. Since August 18, 2000, that I filed the Notice of Application, the solicitors' defendants for contempt with tricks and dishonest conduct trying to obstruct and confuse the justice. The URGENT issues in my application required the Court be able to concentrate on the complex issues. They did not have proper representations in most of steps and violated of the codes of professional conduct. They acted in concert, with bad faith and dishonestly, in such a way as to interfere with the orderly administration of justice, to impair the authority and dignity of the Court. Exhibit "A" indicate that I gave evidence in my Affidavit sworn on September 18, 2000, that several documents were stolen at the print shop, in order to obstruct the justice.
2
4. On October 19, 2000, I found a document in the hallway of my condominium that titled "Notice of (Cross) Motion", Robert H. Jaworski, Solicitor for the respondents Nicole Barbe, The Office of Superintendent of Financial Institution Canada ("OSFI"), the Royal Canadian Mounted Police ("RCMP"), Richard Schobesberger, Tina Soares, the Transport Canada, Bruce Preston, Michel Lortie, Roland Carryl, Anne Edge, Anne Roland and the Attorney General of Canada; asking dismissing Application with costs on a solicitor-client basis against the said respondents;
Exhibit "B" Indicate the Notice of Cross Motion signed by Jaworski.
My evidence against Jaworski for Contempt in the Face of Court are as following:
A. Jaworski, fraudulently, did not disclose Exhibit "A" to Motion Record to deceive the Court from the crimes committed against evidence that I disclosed to the Court;
B. Jaworski did not serve me with notice of appearance for Barbe, the OSFI, the RCMP, and the Attorney General of Canada;
C. Jaworski, served me with appearance for the CROWN, that I request from the Court to
return his false document; and the Court did;
D. Jaworski did not move before the Court to ask extension of time to file his appearances;
E. Jaworski with improper conduct abused the process and without having a motion, illegally obtained an Order that confused whole proceeding;
F. Jaworski without legal basis in the Application Process, has brought illegal Motion to confuse the judiciary system.
Exhibit "C" is a letter dated September 18, 2000, signed by M. Birthright: " I am unable to recall serving the Respondents with this Notice of Appearance. " Why? She could ask for Affidavit of
Service, and why the Court should accept such contemptuous submission as a REASON.
Exhibit "D" is a Memorandum send by the Court on the same day of September 18, 2000 grant Jaworski's relives, without examining the records, without mentioning the name of Judge.
5. On October 20, 2000, Arthur Hamilton's processor server tried to serve me with Notice of Motion Birgeneau, the University of Toronto, Osborne who did not serve and file the Notice of Appearance. I refuse to accept, the processor left the document on the hallway floor.
I do not know how processor allowed himself to trespass my property where our condominium in equipped with access card. Jaworski's processor did the same. On September 18, 2000, my son forgot his access card and he stayed all night out, but strangers simply trespassing our property.
Exhibit "E" is my complaint against police for cause of action on September 18, 2000 where the
Crown's agent called police who harassed me to death just before I sworn Affidavit in Exhibit A.

My evidence against Hamilton for Contempt in the Face of Court are as following:
A. Hamilton, fraudulently, did not disclose Exhibit "A" to Motion Record to deceive the Court from the crimes committed against evidence that I disclosed to the Court;
B. Hamilton did not move before the Court to ask extension of time to file his appearances for respondents Birgeneau, the University of Toronto, Osborne.
3
C. Hamilton without legal basis in the Application Process has brought illegal Motion to confuse the judiciary system; to obtain an Order on the principle of Fraud.
D. Hamilton has relied on Jaworski's material, when he knew, or ought to have been known that Jaworski's material contains destructive facts [I served my Affidavit sworn September 18, 2000 in person to Hamilton.
Exhibit "F" is Notice of Cross Motion by Hamilton that is copy of Jaworski's Motion Exhibit B, that does not contain my affidavit sworn September 18, 2000-Exhibit A
6. On October 20, 2000, Steve Weisz' processor trespassed my property and pushed Affidavit of Debra Armstrong from under the door to inside of my property. While, Weisz never showed in his office to admit service for three Affidavits that I served to him; at the same time Weisz has instructed that neither his assistant, nor any staff of his law firm admits to the service.
They allow calling my home during mid might and continuously sending fax to my telephone line at from midnight to morning; caused all kinds of insulting nuisances for me and my family.
7. The appointment of the MBNA Canada Bank, for Weisz' law firm was the best chance for revenge who is accused of conspiracy. On September 6, 2000, Weisz commenced his illegal contacts, harassments and retaliation, when he had in possession Giles Order dated Sept 1, 2000.
I served the Notice of Application via facsimile to several respondents whose addresses were not known to me, and they were refusing to provide, like Sprint Canada, or they were in different cities across Canada. Weisz' knew that I served MBNA via facsimile.
8. On or about August 30, 2000, someone, told to Kate Broer that she was in breach of
fundamental of the Conflict of Interest Law; by representing two different corporations- the
Sprint Canada and the Bank of Montreal without their consents. Broer, instead of honest and professional conduct, preferred to have a private dishonest conduct with a clerk and alleged as far as her client, Sprint Canada was served with via facsimile, the Notice of Appearance that she filed jointly for both corporation be cancelled.
Exhibit "G" Indicate Giles Order dated September 1, 2000, that removed, Sprint Canada, for not being served personally with the Notice of Application. According to this Order all respondents who have not served, in person, their Notice of Appearance, are not party in this proceeding.
My evidence against Weisz and Broer for Contempt in the Face of Court are as following:
a. Broer and Weisz both has violated the conflict of interest law against their clients and have chosen to not be honest with the Court and their clients thorough a professional conduct that have caused complexity and confusion against the administration of justice;
b. Broer, maliciously, moved before the Court and obtained Giles Order for multiple malice objects, and have not admitted to all document served to her instructed her assistant also not admit to the services, to increase my load and costs;
c. Broer, maliciously, did not filed appearance for respondent, ROBERT PEARCE, to support his wrongdoing and conspiracy against my account in the Condominium; to mislead the justice from the facts that Pearce directly was involved;
d. Weisz, maliciously, abused his position as the counsel for the MBNA to mislead the justice by forwarding partial material to Armstrong and material for her Affidavit;
e. Weisz, maliciously, abused his position to commence, continuous, harassing communications with me that I fail to provide a complete Affidavit to support my Application to lead the justice [Weisz and his assistant letters dated August 29-twice
September 6, and his continuous calls and sending fax during 24 hours to my home]. Weisz, with fraudulent intent, asked from Armstrong to provide Affidavit to complete the
triangle of Jaworski and Hamilton's conspiracy against the administration of justice; when he knew that the Court is not going to file Armstrong Affidavit, but it will be used to mislead the Court that a respondent, has given evidence under the oath that there is not merit in the application; where that respondent-Armstrong-MBNA was send out by Giles
Order and has committed a perjury to obstruct the justice.
9. I read Armstrong Affidavit, amazingly, she did not referred to Exhibit "A" too, in paragraph 2 of her affidavit. This fact is a prove of a conspiracy between Weisz, Hamilton and Jaworski who made agreement to not mention anything about my Affidavit of Sept 18, 2000.
Weisz served me with Armstrong Affidavit on October 20, 2000, when the time expired to enjoy the provision of Rule 307. At the same time, Armstrong was telling clearly, " I have no knowledge of " my allegation, as a Chief Counsel of MBNA. I had deal with the customer service of MBNA, and it was proper that they provide affidavit against all my complaints.The Chief Counsel expected to review whole file before making an Affidavit before the Court.
Giles Order says. Armstrong, stated that had reviewed my Affidavit September 15, 2000, which contained Giles' Order and Broer's Notice of Appearance for Sprint Canada, the circumstances was same for MBNA too. Armstrong, knowingly, fraudulently, with intent have committed a perjury and omitted evidence from her Affidavit who which Armstrong, Hamilton, Broer and Jaworski must show cause for the Criminal Contempt in the Face of Court, or civil contempt.
Exhibit "H" is a perjured Affidavit of Armstrong sworn on October 19, 2000, whose commissioner was the Black, Cassaels & Graydon which means Armstrong had chance to see the whole file, which was including my Affidavit sworn September 18, 2000 Exhibit A
Exhibit "I" is my Written Examination that Weisz obligated to forward to her with this Motion.
KEYVAN NOURHAGHIGHI, SWORN before me in the City of Toronto, in the Province of OntarioThis October 24, 2000
COMMISSIONED BY THE COURT MANAGER IN TORONTO, Mr. ROBINSON

**************************

Contempt of Court by Five Canadian Lawyers

Supplementary Affidavit of Keyvan Nourhaghighi Against
Five Canadian Lawyers accused of Contempt in the Face of Court
Sworn January 18, 2001

Court File No: T-1535-2000

FEDERAL COURT- TRIAL DIVISION

BETWEEN:

KEYVAN NOURHAGHIGHI, Applicant
-and-
CANADIAN HUMAN RIGHTS COMMISSION, MERVIN WITTER, BOB FAGAN;
BELL CANADA, SPRINT CANADA, JENNIFER WILSON,
THE CANADIAN RADIO-TELECOMMUNICATIONS COMMISSION;
ROBERT BIRGENEAU, THE UNIVERSITY OF TORONTO; ROBERT PEARCE,
THE BANK OF MONTREAL, THE CANADIAN IMPERIAL BANK OF COMMERCE,
DENNIS OSBORNE, BANK OF NOVA SCOTIA,
THE MBNA CANADA BANK, TORONTO DOMINION BANK, NICOLE BARBE,
OFFICE OF THE SUPERINTENDENT OF FINANCIAL INSTITUTIONS CANADA;
ROYAL CANADIAN MOUNTED POLICE; RICHARD SCHOBESBERGER, TINA SOARES, THE TRANSPORT CANADA; BRUCE PRESTON, MICHEL LORTIE, ORLAND CARRYL, ANNE EDGE, ANNE ROLAND and
THE ATTORNEY GENERAL OF CANADA; Respondents

AFFIDAVIT OF KEYVAN NOURHAGHIGHI
Pursuant to Gibson Order, January 12, 2001; Reference Motion for Contempt
Dated in Toronto, Ontario, this January 19, 2001; Keyvan Nourhaghighi; 608-456 College Street Toronto, Ontario, M6G 4A3; Tel: (416) 515 7263.

TO: Administrator
AND TO:
STEVEN J. WEISZ , Blake Cassels & Graydon LLP [MBNA]
DEBRA ARMSTRONG, Senior Solicitor for MBNA, via Weisz
ARTHUR HAMLLTON, Cassels Brooke & Blackwell LLP [Scotiabank]
KATE BROER, Fraser Milner Casgrain [Bank of Montreal]
ROBERT JAWORSKI [Crown]
RENE DUVAL, Solicitor for the Respondents, Mervin Witter, Bob Fagan, the CHRC
ALLAN ROSENZVEIG, Solicitor for the Respondent, J. Wilson, the CRTC
GIULIO D'ALESSANDRO, Solicitor for the Respondent, BELL CANADA,
MICHAEL G. QUENNEVILLE, Solicitor for the Canadian Imperial Bank of Commerce
Taylor, for the Respondent, the Toronto-Dominion Bank

TABLE OF CONTENTS

DESCRIPTIONS

Affidavit of Keyvan Nourhaghighi sworn January 18, 2001
EXHIBIT "A" Letter; From: Sprint Canada September 13, 2000 To: K. Nourhaghighi
RE: Termination of telephone service

EXHIBIT "B" Letter; From: KATE BROER, October 26, 2000 To: K. Nourhaghighi
RE: Pursuant to Giles Order Sprint Canada has not been served properly

EXHIBIT "C" Broer: Sprint Canada's Notice of Appearance: Giles Order! Jan 17, 2001

EXHIBIT "D" Metro Toronto Police Investigation About Sept 2000
RE: Photo of Nourhaghighi in the hands of the security of the court threaten to leave the room before appeal process

EXHIBIT "E" Letter; From: KATE BROER, January 11, 2001 To: Justice Gibson RE: Security of Costs

EXHIBIT "F" Letter; From: STEVEN J. WEISZ September 26, 2000 To: K. Nourhaghighi RE: At all times we acted in a professional manner!

EXHIBIT "G" Letter From: Ruth Promislow August 29, 2000 To: K. Nourhaghighi RE: Notice of Applications SENT to MBNA

EXHIBIT "H" Letter September 6, 2000 From: STEVEN J. WEISZ , Blake Cassels& Graydon To: K. Nourhaghighi RE: Due to Action against MBNA your credits services terminated! Effective September 15, 2000

EXHIBIT "I" (1)B: FALSE Pretence: Blake Cassels & Graydon Sept 15, 2000 Violation of Section 361 of the Criminal Code of Canada (2) Letter October 5, 2000, From: STEVEN J. WEISZ , Blake Cassels & Graydon To: K. Nourhaghighi RE: At all times we acted in a professional manner!

EXHIBIT "J" Promislow: MBNA Notice of Appearance: Giles Order! Jan 15, 2001,

EXHIBIT "K" Jaworski: Edge, Roland Notice of Appearance: Giles Order! Jan 18, 2001, Court File No: T-1535-00

AFFIDAVIT OF KEYVAN NOURHAGHIGHI

I, Keyvan Nourhaghighi, the Applicant, resident at 608-456 College Street, in the City of Toronto, Ontario, M6G 4A3, SWEAR THAT:

1. I am the moving party and as such has knowledge of the matters hereinafter deposed to.

2. On October 25 I filed the Motion Record and Affidavit for show cause against Kate Broer, Robert Jaworski, Steven Weisz, Debra Armstrong, Author Hamilton ("Contemnors"), who are solicitors in profession and with intention and knowledge, willfully misled and obstructed the justice and threats me and with bad faith and deliberation violated the Court's Rules, Order and undue influences in obtaining Orders and Direction committed crimes known as the Contempt against the administration of justice and the Contempt in the Face of Court.

3. The Contemnors' actions are outrageous that confused the judiciary by the ample complexities that even two days hearings on October 31 and January 12, 2001 could not put light to the darkness of issues; even by all prejudiced against the Federal Court Rules and me.

I rely upon all letters, factums and materials that the Contemnors filed with the Court and/or send to me, Orders and Directions issued since September 1, 2000 and all my letters, affidavits, replies, factums and complaints that I filed and send to the Court and/or the Contemnor and Respondents.

4. The cause of contempt raised on September 1, 2000, when Broer illegally obtained Giles Order, not by the way of motion, but by undue influence in the Registry of the Court-Toronto. My Affidavit of October 25 Exhibit G contains Giles Order; in addition, my Affidavit of September 15, is objection against Broer, Exhibit A indicate a copy of the Court Record that says clearly on Doc No. 6 says: "2001/09/01... certified copies sent to parties." The Court and I served Giles Order to solicitors so all Contemnors were aware of Giles Order and, intentionally, are disobeying it up to this date January 18, 2001. The Contemnors and their clients' Respondents did all kinds of threats and harassments against My businesses and Me, as the Witness in the Contempt Trial and the Applicant. Therefore, it is justices that the Respondents involved be cited for contempt too.

EXHIBIT "A" Is Sprint Canada's Letter dated September 13, 2000 that terminated my long- distance services, and fraudulently alleging that I requested for such termination. It is important to note that the letter is not signed and the person's name was not given. Sprint Canada, did not reply to my complaints against manipulations of my accounts and creating fabricating debts, due to pending my application for mandamus!

EXHIBIT "B" Is Broer's Letter dated October 26, 2000, that refer to Giles Order:
"Sprint Canada was not served properly....it has no standing..." However, Broer in her Factum alleged: "Sprint Canada is corporation...Notice...fails...against Sprint Canada"
BANK OF MONTREAL Cross Motion Record, Page 50, paras 3, 4, 7, 8, 15, & 28

Broer's Factum singed and dated October 27, 2000 which is disagree with her Letter Broer, knowingly and fraudulently, has made false assertion in the statement of fact:

(1) By refusal to reply How obtained GILES ORDER without any Motion? And Why did not informed any parties? Only one short ambiguous reply to the most serious allegations under the Rules of Professional Conduct of the Law Society of Upper Canada that a large numbers of lawyers lost their licenses for a single charge of fraud, conflict of interests and conspiracy as set in Affidavits of NOURHAGHIGHI.

BANK OF MONTREAL CROSS MOTION Paragraph 9, page 51, and Pages 7-12

(2) By omitting my affidavit against Broer from Bank of Montreal Motion Record.
COURT RECORD Applicant's Affidavit sworn on Sept 15/00, Para 9, Ex "B"

(3) By alleging that she is counsel for the Respondents Robert Pearce and Sprint Canada, where Broer did not had proof of lawful appearances for the said respondents, Rule 305.
Bank of Montreal Cross Motion Para (a), p. 49; 2, 3, P.50; 8, 15, p. 51; 17, p. 52; 28, p.54

(4) By misinterpretation of Rule 303 and relating it to mandamus; and adopting to Jaworski's Factum that he is accused of same types of frauds against Rules 303 and 305 Bank of Montreal Cross Motion Para 4, 5, 6, 7, page 50; 15, page 51, 16, 17, page 52

(5) By misrepresentations of the case of law with intention to cause uttered the false accusation against me in order to make me the object of ridicule and contempt; where
I-Canada v. Nourhaghighi was dismissed by Trial Division.
II- Nourhaghighi v. Canada dismissed due to conspiracy of the Registry Respondents
COURT RECORD Affidavit of Nourhaghighi-sworn Sept 14/00, page 22, 15G, H,I

III- Toronto Hospital et al v. Nourhaghighi where the order was obtain by conspiracy and fraud after the applicant was tortured by nine members of police which is the main cause of action against the Crown to the Human Rights Commissions.
COURT RECORD Affidavit of Nourhaghighi-sworn Sept 14/00, pages 45-to 51, 62-70

AFFIDAVIT OF NOURHAGHIGHI SEPT 14, Exhibits "D, F, E, O"

(6) By relying in Rule 8, as the Ground for her illegal Cross Motion, without any kind of explanation in the Notice of Motion and Factum that why asking Extension of Time, to get a leave for which purpose, without any supporting affidavit, and having strong reasons that why the Court should grant a leave for extension of time.

(7) By undue influence and getting Gibson Order of January 12, 2001, to file Notice of Appearances for Pearce and Sprint Canada, after 135 Days delays and interfering with timetable of Judicial Review Application that its total timetable is less than 135 days!

(8) By breach of Giles Order of September 1, 2000, and serving Sprint Canada Notice of Appearance to me on January 17, 2001; where Broer's Letter Oct 26/00-EXHIBIT B clearly indicate that Broer was fully aware of the strict Giles Order that removed Sprint Canada's appearance.

EXHIBIT "C" Is the Sprint Canada's Notice of Appearance, dated Jan 17/01; signed by Broer.

5. Broer and Jaworski relied upon Wilkins Order where Her Majesty the Queen in right of Ontario was the Counter-respondents in the Applicant's Counter-Application against the Attorney General of Ontario, the Law Society of Upper Canada; it is just and proper if the said Counter-respondents be required to show cause for contempt where all my evidence under the oaths indicate that they have committed serious harassments against me as the Witness for Contempt Trial against the Contemnors who are parties in a conspiracy against the administration of justice.

My Affidavit sworn of September 18, 2000 indicate my documents for this Court were stolen by their at Business Dept, located opposite to Canada Life Building; the False Pretence by the Blake Cassels & Graydon LLP, and harassment in the Canada Life and the Respondents' Building by the Securities ending to my Motion for Change of Venue all are the customary types
of felonies against the administration of justice of the Federal Court by the said respondents.

EXHIBIT "D" Is page 23 of Investigation by Metro Toronto Police, after I complained that police harassed me in the courtroom therefore, I left before my appeal be heard; which was the similar reason for dismissal of my action Nourhaghighi v. Canada by Sharlow J.
AFFIDAVIT OF NOURHAGHIGHI SEPT 14, Exhibit I, Exhibit 5d, Osborne ACJO,

The police Witness No.2 evidence indicates:
"[...] I observed Mr. Nourhaghighi sitting on a bench down the hallway from a PHOTO which I received from the supervisor [...] I was advised on parade by my supervisor to WATCH Mr. Nourhaghighi [...].

The Crown, its parties, Contemnors, Bank of Montreal, Toronto-Dominion Bank, Bank of Nova Social, the Canadian Imperial Bank of Commerce, Bell Canada, the Registry of the Court-Toronto, have given my photos to all offices of securities in the buildings and malls in the City of Toronto; and made order to them have aggressive attitudes toward me and obstruct my businesses with each office or store that I contact; Gibson Order has rejected my motion for Change of Venue on October 31; therefore, the parties where successful to accomplish all objects of Conspiracy until January 12, 2001, that I stated to the Court: "The cell of Conspiracy is discharged now, I withdraw my motion".

6. In this affidavit, I focused mostly on Rule 466(c)(d) that clearly instructed: "A person is guilty of contempt of Court who: acts in such a way as to interfere with orderly administration of jus to impair the authority or dignity of the Court; is an officer of the Court and fails to perform his or her duty.". The Contemnors have violated both Subrules 466(c) and 466(d), in addition to Subrule 466(a)-Giles Order. In material that I filed with the Court on January 10 as Reply to the CIBC Motion, at page 11 I attached a cÐóÐóÐóÐóopy of Section 29 of the Law Society Act that clearly instructed to all solicitors to be aware: " Every member is an officer of every court of record in Ontario. R.S.O. 1980, c.233, s. 29." to confirm that Subrule 466(d) shall be enforced.

7. The Canadian Judicial Counsel on July 1989 provided a guideline on the use of Contempt Power in Part One it has instructive command: "(1) Contempt is the mechanism which the law provide for protection of the authority of the court from improper interference." The Contemnors with improper interference have brought Eight Illegal Cross Motions and pushed them before the Court, and occupied the moving part of the courtroom and Jaworski and Hamilton commenced illegal attacks to my lawful application that: "(d)...interferes with the court's process or wrongly and seriously threatens the proper administration o justice". The Contemnors have refused to reply to my factums professionally particularly they never answered to the instruction of Rule 303(1)(a), and they did not replied to my motion for show cause by explanation why they are NOT obeying Giles Order: "(1) Contempt in the Face of the Court...Refusing to Answer a proper Question;" while all delays in punishments against the Contemnors have caused serious harms to the administration of justice and have given them chance of all kinds of threats against me and my businesses with the banks and telephones services, malls and stores. The level of threats was so high that I brought a motion for the Change of Venue.ÿU said case of Law Noel JA[at the time was at Trial Division] has dismissed similarBound1 to perform its role? Because, the justice was obstructed and misled, intentionally, with precise calculation K The Contemnors had knowledge of Lutfy ACJ Order or reasonably they have had such knowledge that Lutfy ACJ instructed: "Both parties must follow Rules 300".
In addition, the Contemnors did Application-Rules 300 for Cross Motions; where Lutfy ACJ* instructed: "Rules do not contemplate cross-application.".

*W. R. Meadows Ind. et al v. U.S.E. Hickson Products Ltd; Reply to the CIBC Cross Motion.

10. The Contemnors, as the officers of the Court, are the main part of the Administration of Justice; when they interfere with orderly administration of justice their licenses must be removed. The mandate of the Court is not to award the Costs to the parties,the mandate of the Court is to administrate, to govern, to rule the Justice, Fairness, Integrity in the Society. Therefore when the Contemnors all emphases, is in the Costs; than the Costs is: "Picketing a court house constitute Criminal Contempt. B.C.G.E.U. v. British Columbia (A.G.)(1988), 44 C.C.C.(3d) 289(S.C.C.)

EXHIBIT "E indicate Letter dated January 11, 2001, to Gibson J. in regard of Adjournments of of a Motion for Security of Costs which has fatal effects on my presentation of Jan12/01as the main of Conspiracy that cause a me a the most serious harm and prejudiced.

11. The Contemnors interfered with orderly administration of justice by intentional breach of the timetable of my application for judicial review. January 19, 2001, is extremely late to file appearances for the Attorney General of Canada Respondents and MBNA, which was expired on August 2000; in addition by refusing to provide a proper mailing address for services that caused the said conflicting orders. The Contemnors committed all possible kinds of crimes and wrong to in admission to service of documents that I delivered by all kinds of possible insults, felonies, avoid service of documents by nuisances, tricks, frauds, slanders, obstructions, assault, harassments by the security officers of the buildings, intentional verbal aggressive arguments to cause battery and false identifications and pretence to avoid the service of the legal documents.

EXHIBIT "F" Is letter dated September 26, 2000 signed by the Contemnor Steven J. Weisz referring to my complaint against his law firm to the Associate Chief Justice of the Federal Court: "[...] At all times, I and members of my firm have acted in a professional manner in our dealing with you. As a result I deny and object to accusations made against me, my firm [...] you will refrain from such scandalous accusation .

EXHIBIT "G" Is a letter dated August 29, 2000, signed by Ruth Promislow that clearly stated: "The Notice of Application was sent [by facsimile] to MBNA" that Giles Order affected the MBNA Canada Bank too; therefore, Weisz and Promislow both are in Contempt of Order. And all material that I filed indicate Promislow's letter contains fatal errors of law.

EXHIBIT "H" Is letter dated September 6, 2000 [Six Days after Giles Order]signed by the Contemnor Weisz: EXHIBIT "A" Is Weisz' letter dated September 6, 2000, that terminated my $11000 credit: "In an action+ that you have commenced... effective Sept 15/00 your agreement with MBNA is terminated and you have no further credit... David Bull Laboratories v. Pharmacia :"Rule 419 does not directly authorize the striking out of a notice of motion. An Application commenced by notice of motion is not an "action" and the notice of motion is not a 'pleading' ".- Promislow's Letter +David Bull Laboratories v. Pharmacia :"Rule 419 does not directly authorize the striking out of a notice of motion. An Application commenced by notice of motion is not an "action" and the notice of motion is not a 'pleading' * ".- Promislow's Letter.

12. On September 15, 2000, at 03:30 PM Michael Peckoo the employee of the Contemnor Weisz' Firm in accordance to Weisz and Permilow's instructions refused to admit service to two my Affidavits of September 14 and 15 that I had intend to serve. Peckoo, after having telephone conversations with Weisz and Permilow's stated to that the lawyers instructed him to not admit service, however they instructed to give his name that I file Affidavit of Service. Therefore, I asked him to write his name for me. Peckoo, then took a piece of yellow paper and fraudulently has given False Pretence as "Jeff HASSE, Service Clerk, 3:30 P.M.".
IT IS IMPORTANT to note that my Affidavit of September 15/00 was contained Giles Order in

Exhibit A-the Court Record that Weisz and Promislow had intend to pretend that they did not saw it, as Giles Order has removed the MBNA. Canada Bank. Promislow on January 15, 2001, served me with Notice of Appearance for the MBNA that I which to have motion to cite her for contempt of Giles Order September 1, 2000.

EXHIBIT "I" Indicates the law firm Black, Cassels & Graydon LLP employee, Michael Peckoo's handwriting. At "B" Peckoo committed serious crimes of False Pretence

EXHIBIT "J" Indicates Notice of Appearance for MBNA signed by Contemnor, Propmilow.

EXHIBIT "K" Indicates appearances for Nicole Barbe, OSFIC, RCMP, Bruce Preston, Anne Edge, Anne Roland; while who were served by facsimiles and could not file Appearances pursuant to Giles Order, Sept 1/00 singed by Condemner Jaworski

13. The Memorandum of Fact and Law is the most important part of each proceeding that the judiciary is going to rely upon it. The Contemnors by frauds in their factums have inverted the facts in the Action and have drawn fraudulent conclusion for the Application and relied upon a case of law of David Bull Laboratories v. Pharmacia that has instructed clearly: "Rule 419 does not directly authorize the striking out of a notice of motion. An Application commenced by notice of motion is not an "action" and the notice of motion is not a 'pleading'." Jaworski, was fully aware of the facts in the case of law, therefore, intentionally, did not put that on its Cross Motion Record and just handed to Gibson J. and me on fraudulent conclusions. I shocked and surprised.

14. On October 26, the Contemnor Weisz has delivered his illegal Cross Motion Record contained of 423 pages and 11 cases of law. On October 27, Broer served me with her illegal Cross Motion Record contained of 120 pages and 6 cases of law. Jaworski's illegal Cross Motion Record contains 385 pages and 5 cases of law. Bell Canada, TD Bank, the Scotiabank, served their records on the same week all returnable on hearing of Monday October 30. I was shocked and surprised how I could review all these material on top of my own materials to lead the justice to the facts. The Contemnors were well aware of the issue well a head if time-August and had penalty of times in whole 31 days of September and early weeks of October. However they did not act until last days and, suddenly, surprised the judiciary and me by massive materials filed with the Court as Gibson J. had reference to them on January 12, 2001 and addressed: "NO party shall surprised other party.". I provided this affidavit with good faith and honestly.

SWORN before me in the City of )
Toronto, in the Province of Ontario, ) Signed: KEYVAN NOURHAGHIGHI
This January 18th, 2001, Signed Kevin Kelly, Federal Court Registry Officer, Toronto )

Proofs of Ontario Judges and Lawyers felonies against Justice System and Public

Autobiography of the Lord of Law

Major Keyvan Nourhaghighi
July 19, 1990 to January 4, 2019
Major Nourhaghighi Encyclopedia 2019
Down With Queen & Corruption in Canada

William: "You Fucking American Whore! CockSucker!"

British Motherfuckers in Toronto

Autobiography of Major Nourhaghighi

Canadian Counter-Dictionary and British Human Rights' Violations in Canada

A B C D E F G H I J K L M N O P Q R S T U V W X Y Z

Conspiracy, Theft and Forgery in file T-1535-00
Respondents Obtained Orders by Frauds

REQUISITION FOR INTERVENTION

AMNESTY INTERNATIONAL

REQUISITION FOR HEARING

_________________________________________

Conspiracy, Theft and Forgery in file T-1535-00

Court File No: T-1535-2000

FEDERAL COURT- TRIAL DIVISION

BETWEEN:

KEYVAN NOURHAGHIGHI, Applicant

-and-

AFFIDAVIT OF KEYVAN NOURHAGHIGHI

I, Keyvan Nourhaghighi, the Applicant, resident at 608-456 College Street, Toronto,
Ontario, M6G 4A3, SWEAR THAT:
1. I am the applicant; as such have knowledge of the matters deposed to.
2. The respondents with retaliations and professional misconducts are trying to obstruct the justice from the issues by a wave of harassments, insults professional misconduct, and refusing to provide services to confuse the judiciary This affidavit has been provided with absolute rush, due to malicious defects in my Affidavit sworn of September 14, 2000 ("Main Affidavit") by the Business Dept at 375 University Avenue in the City of Toronto who is defendant in my action for maliciously causing defects in my documents that I must file with the Court; who did the same wrong against document that I filed served to all parties with the Court on September 15.
Exhibit "I" Indicate paragraph 192 and 193 against the Business Dept that was defendant with the
Ontario Judicial Council et al in Action 96-CU- 104952 for the tort of conspiracy;
Since 1996, I did not gave my document to this dishonest agent to perform a job;
however due to absolute rush on Friday, September 15, I have asked my Affidavits be
printed and soon I served and filed with the Court. On September 17, I went to receive
the rest of documents that I observed the similar unseal movements and harassments of
staffs and noises in the store that I observed on last Thursday and Friday.
2
I interpreted that they are trying to mislead me from a fact. I observed that one of staff,
Lori Lorraine, with a clear nervousness changing some pages and removing the others.
I asked her if she misplace the pages; she said "NO!" and demand payment; I asked let
me see your job; as soon as I start looking to the pages, she left immediately.
I found numbers of pages were misplaced and page 190 seems to me was forged by a line
above zero to 195 was placed there. Page 195A was stolen, page 197 misplaced and so.
Ms. Lorraine did not show for a while; I asked from other staff to check the trash that she
hardly allowed; I find several pages of my documents, without any damage, and I saw
several other customer important fresh bounded documents in the rush and many photos.
3. The banks respondents in this application have acted in a group with the discriminatory practices to deny my access to the standard of services and isolationisms of my basic financial requirement; and at all material times, with dishonestly have abused my trust in having accounts with them to cerate series of the fabricating documents and put my credibility under serious jeopardy in North America, that have good credit is one of main requirements for success.
Series of this dishonest misconduct are related to the creations of fabricating certificate of the Not Sufficient Found ("NSF") and refusing to honor my payments thought the credit lines, when at all material times I had outstanding credits. I gave evidence in this regard in my Main Affidavit, particularly in paragraph 13, Exhibit 11L, to demonstrate the dishonest misconduct as an element of the discriminatory practices.
EXHIBIT "II" indicate how th egroup are protecting each others in wrongdoing against me with
high-handed manner and dishonestly:
IIa. is letter of City of Toronto, Revenue Clerk, Murata that indicate the respondent
the payment of my cheque was not honored; my Main Affidavit has evidence that
the City Revenue Manager refused to returned my cheque.
IIb. Second document is the Return Payment Notice by the City of Toronto that under
the line of "your bank marked "Edit Reject"; however the original note was
"REFUSED TO DECLARE" that was fraudulently changed by the City of
Toronto to cover up the wrong. Although none of the two document has the
name of the Bank Nova Scotia; and the City illegally hold my document, and the
bank did not reply to my complaint, the respondent Manager GONCALVES,; the
IIc. Third document indicate that in year 1998 I paid all my property taxes through
my Power Line Cheque that bank does not have ANY EXCUSE to not honor my
cheque, as it did several times in past. I covered the account number.
IId. Indicate my account with Condominium 935 that fraudulently three times
Repeated "NSF" cheques; this forged document was used in confidential process
before the Court of Appeal in December 16, 1999, to satisfy the court to drop my charge of contempt against the Attorney General of Ontario and its lawyers.
IIe. Is letter dated January 24, 2000 by the dishonest Property Manger, Leza Blair
that refusing to return MY Bank of Montreal Master Card cheque which was not
honored by the bank as said: "That are now the property of MTCC 935.
Blair's letter three time referring to "Returned " she does not say "Closed" or
"NSF", than fraudulently putting on me that" Notify our offices of any changes
in your banking arrangements PRIOR to your cheques being deposited.
I know Blair, she does have that must education to right this letter that protect all
3
parties of the group and puts and responsibility on my shoulder; I HAVE TRUST
that this letter is written by the Law Firm defendant for frauds and dishonestly in
my action; Gardinder Blumberg, and Mark Arnold, accused of forgery :Page 180
of My Application record , Exhibit 11F.
IIf. Sprit Canada statement dated August 28, 2000:
"Payment Adjustment: July 28, REJECTED ITEM; $22.99" The Bank of Nova
Scotia was paying to Sprint via per authorized; here the Sprint Canada who is
accused of breach of trust in withdrawing without permit, has got the Consent of
the Bank of Nova Scotia to create this false document to mislead the CRTC that
investigating my complaint with reference number 000831cc711L
4. Exhibit IIa originally I was numbered "195A" against the Bank of Nova Scotia, was stolen at the Business Dept; Exhibit IId, originally I was numbered "195B" against the Bank of Montreal Master Card fabricating "NSF" Records against my account in the Condominium, and a copy of cheque that fraudulently marked the "Account Closed" the number is changed to "196".
5. I have evidence to believe that the Bank of Nova Scotia and the Attorney General of Canada having main role to obstruct the justice. In the similar case, the Attorney Genera of Ontario and the Borden and Elliot were involved in the theft an original file that end to their success in the Court of Appeal for them; I have pleaded in action T-942-99.
Exhibit "IV" is a page of my affidavit before the court that indicate how the government's clerks with dishonestly was covering up the crimes of theft of original file to be delivered from the Court House, 361 University Avenue to its neighbor building Osgoode Hall.
6. Once a learned judge in a similar complex frauds and thefts after the commencement of a proceeding, calmly address us: "Still I am on control"; today, I which to relay upon this wise statement that noting can change the course of issues before the Court, which is issuance of Write of Mandamus that the Commission be able with confident pull these bullies before its tribunal.
SWORN before me in the City of )
Yotonto, in the Province of Ontario, ) KEYVAN NOURHAGHIGHI
This September 18th, 2000 )
___________________________________________
Respondents Obtained Orders by Frauds

FEDERAL COURT- TRIAL DIVISION

BETWEEN:

KEYVAN NOURHAGHIGHI, Applicant

-and-

The Respondents have Obtained Orders by frauds, Factum November 23, 2000
Statement of Case
POINTS IN THE ISSUE

MOTION RECORD

Keyvan Nourhaghighi, 608-456 College Street, Toronto, Ontario, M6G 4A3 Tel: (416) 515 7263
TO: Administrator
RENE DUVAL, Solicitor for the Respondents, Mervin Witter, Bob Fagan, the CHRC
ALLAN ROSENZVEIG, Solicitor for the Respondent, J. Wilson, the CRTC
ARTHUR HAMILTON, Solicitor of the respondent, Bank of Nova Scotia
GIULIO D'ALESSANDRO, Solicitor for the Respondent, BELL CANADA,
MICHAEL G. QUENNEVILLE, Solicitor for the Canadian Imperial Bank of Commerce
KATE BROER, Solicitor for the Respondents, Sprint Canada, and The Bank of Montreal
STEVEN J. WEISZ, Solicitor for the Respondent, the MBNA Canada Bank
Taylor, for the Respondent, the Toronto-Dominion Bank
Robert H. Jaworski, Solicitor for the CROWN
*Nov 23/00, was a day that the Applicant was obligated to Perfect his Applicant's Record, owing to frauds and Conspiracy of the counsels defendants for Contempt, he was prejudiced seriously.

CONTENTS

DESCRIPTION and Page
Notice of Motion dated September 25, 2000 1
Applicant's Submission, pursuant to Gibson Order 4
1. Statement of Case 4
1.1.1: Statement of Facts as Against the Attorney General of Canada's Respondents, 4
1.1.2: Violation of Rule 8 5
1.1.3: Violation of Rule 8 and Prothonotary Lafreniere's direction obtained by FRAUD 5
1.1.4: Prothonotary Lafreniere's Direction that was obtained by FRAUD violated Giles Order 6
1.2: Violation of Rule 8 and Giles Order by the respondents MBNA Canada Bank and Weisz 6
1.3: The respondent MBNA-removed
1.4: Violation of Rule 8 by the respondents Birgeneau, the University of Toronto and Osborne 7
1.5.1: Rule 8 and the respondent, Toronto-Dominion Bank 7
1.5.2: Double Standards and the Crown's Conspiracy: 7
1.5.3: Mandamus and Abuse of Judicial Power by the Federal Court of Canada: 7
1.5.4: Violations of Rules 8 or 304, or partiality and bias 8
1.6: COSTS Rules 400(2)(3)(g)(h)(i)(j)(k)(i)(ii)(6)(d), and 404 (a) v. Solicitors 8
2 POINTS IN THE ISSUE 9
3 ARGUMENT 9
3.1.1 The Respondents' Solicitors Negligence and Professional Misconduct: 9
3.1.2 Rule 303 and the Commencement of the Proceeding by a Respondent: 9
3.1.3: Violations of Rule 8 and 358s by all Counsels' defendants for Contempt: 9
3.1.4: Does the respondents obtained Giles Orders and Lafreniere Direction by Frauds 10
3.2: Apprehension of bias in the judgment seats and administration 10
of the Court in Toronto:
3.5 COSTS: 11
4. ORDER REQUESTED 11

Page 1

Court File No: T-1535-00

FEDERAL COURT -TRIAL DIVISION

BETWEEN:

KEYVAN NOURHAGHIGHIm Applicant

-and-

NOTICE OF MOTION

THE APPLICANT will make a motion to a judge on Monday 30 day of October 2000
at 10:00 AM 330 University Avenue, Toronto pursuant to provisions of the rules 51 of the Federal Court Rules, 1998 appealing Giles Order dated September 1, 2000, and Order dated September 18 where no name of judge is provided in the memorandum that both Orders were served on September 18, 2000 and seeking directions for the issues raised by the respondents.
THE MOTION IS FOR:
a. 1- An Order under that Giles Order be set aside and the respondent, Sprint Canada's
Notice of Appearance be validated from August 31, 2000 that was filed.
2- An Order under that the Order made on September 18, 2000 be set aside and the
respondents, Richard Schobesberger, Tina Soares, Anne Edge and Anne Roland's the
Notice of Appearance be retuned to their solicitor.
3- An Order under that the motions brought by the respondent, the Toronto-Dominium
Bank, Dennis Osborne, Robert Birgeneau and the University of Toronto be dismissed.
IN THE ALTERNATIVE:
I. An Order under that the Applicant does not prejudiced for the errors that committed by
the judiciary and the respondents in the court process till date of hearing of this motion.
II. An Order under that the Applicant does not prejudiced for the judiciary errors and the
respondents and their solicitor professional negligence and the Application be heard in
accordance to the timetable set in the Federal court Rules, 1998 from its originating
date, August 18, 2000.
b. I- An Order under that the issue of costs fully and clearly be determined in accordance to
the customary and standard of conducts, when a single party sued several parties.
2- His Costs on the same amount that if he be obligated to pay to the respondents.
Page 2
2
THE GROUND OF THIS MOTION ARE:
1. That Mr. Giles ASP erred in conflict of interest law in making a decision in the applicant
proceeding when he was named defendant in his action, and Mr. Giles was aware of fact.
Mr. Giles ASP erred in law that the Notice of Appearance was not properly served
when the respondent, Sprint Canada has appointed Solicitor Broer to serve and file the
Notice of Appearance; burden is upon Broer. There is no evidence that Solicitor Broer ad any motion before the Court, this fact is clear indication of bias at the Toronto Region,
where its manager and two clerks are respondents, in which none of them have filed
Notice of Appearance .
2. That an ambiguous Memorandum signed by Registry Officer, Donna Yan, dated
September 18, 2000, was delivered to the applicant without proper explanation indicate
illegality and irregularity in the court process to take the side of servants and offices
respondents, which is violation of Section 11 of the Charter. The said Memorandum,
erred in referring to Rule 73 of the Federal Court Rules, which does not provide any
provision to the Court to allow with illegality parties enter to the proceeding; and due to
following ground the said Memorandum is void:
a. There is no evidence that Notices of Appearances were served properly;
b. There is no evidence that Notices of Appearances were filed on August 31,2000;
c. The Court erred in law that could provide direction in the issues that the parties interests are involved; the proper remedy was through Notice of Motion to be
served to all parties that no one be prejudiced.
d. The only Notice of Appearance served to the applicant was named the "Crown"
;and the Crown means : Her Majesty the Queen in Right of Canada that is not
respondent in this application; therefore, there is noting in the record as the Notice of Appearance for respondents the Attorney General of Canada and other
Servants and offices respondents (Re: Applicant's Letter dated August 30, 2000).
e. The servants named respondents in the face of application and were required to
serve via personal service the Notice of Appearance, and file with the Court
within 10 days after were served with the Notice of Application therefore, the
Notice of Appearance of the respondents, Richard Schobesberger, Tina Soares,
Anne Edge and Anne Roland's are void and must be removed from file.
3. That the Notice of Application was served to Mr. Taylor, Director of Litigation in person
for the respondent, the Toronto-Dominium Bank. On September 14 and 15, 2000 the
applicant called and talked with Mr. Taylor who did not had intend to response.
Therefore, the Affidavit Hyla SCHWEBEL is contradicting with Mr. Taylor, desires. The
respondents, Dennis Osborne, Robert Birgeneau and the University of Toronto, in first
step have tried teir best to avoid the service of Notice of Application, than did not used
the sufficient time that rule has provided, nor have moved properly.
3 Page 3
THE FOLLOWING DOCUMENTARY EVIDENCE will be presented:
(a) Affidavits of Keyvan Nourhaghighi and his Letter dated August 30//00 marled Objection;
(b) the proceeding within; and
(c) such further and other evidence that be available after service of this Notice of Motion.
Dated in Toronto, in the Province of Ontario this 25th day of September, 2000.
Keyvan Nourhaghighi
608-456 College Street
Toronto, Ontario M6G 4A3
TO: Administrator Tel: (416) 515 7263
AND TO: RENE DUVAL, Solicitor for the Directors Respondents,
Mervin Witter, Bob Fagan and The Canadian Human Rights Commission;
Fax: (613) 993-3089; Transmission confirmed at 2:41 AM on Sept 25/00.
AND TO: MORRIS ROSENBERG, Deputy Attorney General of Canada;
Robert H. Jaworski, Solicitor for the Crown, who is not respondent
Fax: (416) 973-5004; Transmission confirmed at 2:48AM on Sept 25/00.
AND TO: ALLAN ROSENZVEIG, Solicitor for the Respondent, J. Wilson,
the Canadian Radio-television, and Telecommunications Commission;
Fax :(819) 994 0218; Transmission confirmed at 3:00AM on Sept 25/00.
AND TO: COLIN C. TAYLOR, Director, Litigation; Solicitor for the Toronto-Dominion
Bank; Fax: (416) 982 6166; Transmission confirmed at 2:38 AM on Sept 25/00.
AND TO: Michael Quenneville Solicitor for the respondent, the Canadian Imperial Bank of Commerce; Fax: (416) 861 3853 & 368 9826 Both facsimiles did not replied
Transmission was not confirmed from 2:49 to 2:56 AM on Sept 25/00
Transmission confirmed at 3:46 AM on Sept 25/00; after numerous attempts.
AND TO: ARTHUR HAMLLTON, Solicitor for respondents the Bank of Nova Scotia The
Dennis Osborne, Robert Birgeneau and the University of Toronto
Fax: (416) 640 3009; Transmission confirmed at 3:16 AM on Sept 25/00.
AND TO: GIULIO D'ALESSANDRO, Solicitor for the Respondent, BELL CANADA,
LSUC #34226J;
Fax: (416) 585 2130; Transmission confirmed at 3:12 AM on Sept 25/00
AND TO: KATE BROER, Solicitor for the Respondents, Sprint Canada, and The Bank of Montreal FRASER MILNER CASGRAIN
Fax: (416) 863 4592 Transmission confirmed at 3:08 AM on Sept 25/00
AND TO: STEVEN J. WEISZ, Solicitor for the Respondent, the MBNA Canada Bank,
BLAKE, CASSELS & GRAYDON LLP, Barristers and Solicitors
Fax: (416) 863 2653; Transmission confirmed at 3:04 AM on Sept 25/00

Court File No: T-1535-00

Page 4

FEDERAL COURT -TRIAL DIVISION

BETWEEN:

KEYVAN NOURHAGHIGHI

Applicant

-and-

CANADIAN HUMAN RIGHTS COMMISSION, MERVIN WITTER, BOB FAGAN;

BELL CANADA, SPRINT CANADA, WENNIFER WILSON,

THE CANADIAN RADIO-TELECOMMUNICATIONS COMMISSION;

ROBERT BIRGENEAU, THE UNIVERSITY OF TORONTO; ROBERT PEARCE,

THE BANK OF MONTREAL, THE CANADIAN IMPERIAL BANK OF COMMERCE,

DENNIS OSBORNE, BANK OF NOVA SCOTIA,

THE MBNA CANADA, TORONTO DOMINION BANK, NICOLE BARBE,

OFFICE OF THE SUPERINTENDENT OF FINANCIAL INSTITUTIONS CANADA;

ROYAL CANADIAN MOUNTED POLICE; RICHARD SCHOBESBERGER, TINA SOARES, THE TRANSPORT CANADA; BRUCE PRESTON, MICHEL LORTIE, ORLAND CARRYL, ANNE EDGE, ANNE ROLAND and THE ATTORNEY GENERAL OF CANADA;

Respondents

APPLICANT'S SUBMISSIONS

1. Statement of Case:

1. This written submissions is served and filed by the Applicant to comply with Gibson Order in page 5, paragraph 2, to confirm that the first motion ("this motion") is perfected.
2. The Applicant received Reply with reference to Gibson Order in page 6, paragraph 4.
The issue in this motion, as against the applicants in the second motion, is that the applicants did not serve and filed the notices of appearances, as commanded by Rule 305 of the Federal Court Rules 1998 ["Rule(s)"]. The Applicant's submissions contain a response to the said Reply too.
3. This submissions relied on documents served and filed. The burden of proof is up on the respondents to file an affidavit as a response, in case disagreed. The Court provided a defective Summery of RECORDED ENTRIES of documents, which referred therein in chronological order.
1.1.1: Statement of Facts as Against the Attorney General of Canada's Respondents:
4. On August 30, 2000, the Crown served a false document to the Applicant that says:
"The Crown intends to oppose this application." On the same day, the Applicant, immediately, wrote a letter to lead the registry and explained that Her Majesty the Queen in right of Canada was not named the respondent in this application and its notice of appearance shall be returned.
See Applicant's letter marked Objections at RECORDED ENTRIES after document number 10.
2 Page 5
1.1.2: Violation of Rule 8:
5. The Registry returned the false document to the Crown on September 18, the Crown's Assistant, Birthwright, wrote a brief letter to the Registry Officer YAU in Toronto, and misrepresented the facts by alleging that the Registry has returned the Crown's notice of appearance due to "LATE FILING" ; and in alleged: "I am unable to recall serving the Respondents with this Notice of Appearance". Birthwright did not send a copy of her letter to the applicant and other parties, her letter located at RECORDED ENTRIES after document
number 25. The Crown's Counsel, Jaworski, falsity alleged representing many respondents too.
6. RECORDED ENTRIES after document number 25 contains a direction that indicate the Officer YAU at same day of September 18, 2000 forwarded to the Prothonotary Lafreniere:
" The Notice of Appearance filed on behalf of Anne Edge, Anne Rowland, Anne
Rowland, Tina Soares and Richard Schobesberger on August 31, 2000, shall be accepted for filing effective on the date they were submitted to the Registry. This direction shall be communicated to the parties by the Registry by way of faxed correspondence."
1.1.3: Violation of Rule 8 and Prothonotary Lafreniere's direction obtained by FRAUD:
7. The circumstances of facts in paragraphs 4, 5, and 6 indicate the Attorney General of Canada 's Respondents did not have any valid appearance as required by Rule 305 that be able to participate in the proceeding as Form 301 commanded. Neither the Crown's Cross Motion is valid nor its reply, as Birthwright's conduct with the Officer Yau was in accordance to an object of the Crown's Conspiracy by violation of under Rule 8, to confuse the proceeding; AS A RESULT,
Prothonotary Lafreniere's direction obtained by FRAUD and falls within Rule 399(2)(b).
8. In addition, the Court exceeded its jurisdiction on making a decision, which Rule 358s instructed must be made by a Motion Judge. Furthermore Prothonotary Lafreniere's was in conflict of interests with the Applicant and there was a reasonable apprehension of bias. The Court was aware of the issue and, intentionally, dud not brought his name in a letter dated September 18, made by Officer Yau. Nourahghighi Affidavit sworn October 24, Exhibit "D"
9. It is submitted that the Applicant's right to reply, which is the principles of fundamental justice and guaranteed under the Canadian Charter of Rights and Freedom (Charter") oppressively was denied by the Crown who was neither the party, nor has an appearances for the Respondents, the Attorney General of Canada.
3 Page 6
1.1.4: Prothonotary Lafreniere's Direction that was obtained by FRAUD violated Giles Order:
10. On September 1, 2000, Giles ASP made Order that:
" ...An appearance is to be served and filed within 10 days after being properly served[..]
Sprint Canada cannot file an appearance. The appearance document should be returned
to the solicitor who submitted it.[..] copies sent to all parties "
Giles Order has affected all respondents who were served via facsimiles, including respondents Roland, Edge and the MBNA Canada Bank. The Crown's counsel did not attempt to bring a
Motion under Rule 8 to correct all its mistakes by asking the following orders:
a. To remove the appearance of the Crown.
b. To file appearances for ALL Attorney General of Canada's Respondents.
On October 31, the Applicant submitted that there is not any legal basis that the Attorney General of Canada's Respondents have any authorities under Rule 300s to participate in this application;
and they shall not be allowed to have any kind of presentations, unless they respect the Rules.
1.2: Violation of Rule 8 and Giles Order by the respondents MBNA Canada Bank and Weisz :
11. The statement of facts are similar as against the respondent MBNA Canada Bank: the LATE FAILING of Notice of Appearance, however, the condition is worst for Weisz who is the defendant for contempt, due to the following reasons upon the Applicant's Affidavit of Service:
A. that the MBNA Canada Bank was served on August 19, where it filed appearance on
September 5; Six Days after expiration of limitation by Rule 305, on August 29, 2000;
RECORDED ENTRIES, Applicant's Affidavit of Service, document numbers 3 and 17.
B. that the MBNA was served on August 19 via facsimile, where on September 1, Giles
Order removed Sprint Canada appearance due to same cause and informed all parties
Nourhaghighi Affidavit, September 15, Exhibit A
RECORDED ENTRIES Giles Order: "SENT TO ALL PARTIES " document number 16.
C. Giles Order means MBNA appearance was invalid on September 1; therefore, the filth motion referred in Gibson Order does not have any legal ground to be heard.
D. that MBNA's appearance was valid up to August 29, to be filed simply; or Weisz could
have motion on August 30, 31 under Rule 8. However, the evidence indicate that on
August 29 Weisz has joined to the Crown's multiple objects of conspiracy. All dated are material facts, as proof of the agreements between the parties for a trial judge
Nourhaghighi Affidavit, September 14, Weisz' acts as object of conspiracy Exhibit "4a"
E. on September 6, Weisz, counsel for the MBNA without having any instruction has
terminated the Applicant's $11,000 credits. On November 20, 08:55 PM Evan Thompson
from MBNA called the Applicant and maliciously, was trying to put on the Applicants
that: "Are you canceling your account?" The Applicant's reply was Negative.
4 Page 7
1.4: Violation of Rule 8 by the respondents Birgeneau, University of Toronto and Osborne:
12. Hamilton, solicitor for the said respondents did not filed a motion for extension of time to file appearance for his clients. He does not have valid Cross Motion to be heard. On October 31, Hamilton submitted that he was representing the said respondents on the Cross Motion, which constitute misrepresentation where there is no evidence that any Order exist that the said respondents be allowed to file appearance, which are grounds on third motion for contempt.
1.5.1: Rule 8 and the respondent, Toronto-Dominion Bank:
13. The respondent, Toronto-Dominion Bank, is a solo respondent that had a motion for extension of time, without serving its motion to all other respondents. The ground of appeal against Giles Order in last motion filed by the Applicant on October 27, seeking change of venue due to continuous hostility by the clerks and judiciary officers of the Court which is clear breach of Section 11 (d) of the Charter.
1.5.2: Double Standards and the Crown's Conspiracy:
14. Giles ASP was named defendant in the Applicant's action and for the same cause of conflict of interest he was disqualified to make decision on application T-1237-98 that the
Crown brought against the Applicant pursuant to a conspiracy by the Crown in right of Ontario.
15. In each step on this Application, the violations of the Rules cane be noticed. The Court's clerks demanding affidavit of service, to all parties from the Applicant, but Banks have filed a large numbers of documents without proof of service to all parties. There is no reason that why the MBNA, the Bank of Montreal, the University of Toronto, Schobesberger, Roland, Edge, and Soars' appearances were accepted without a motion under Rule 8, and why the Toronto-Dominion Bank did not filed its appearance immediately after served to the Applicant and waited until a date that the defendant Giles ASP be able to put all kinds of abusive and slanderous allegations against the Applicant in his Order for the Toronto-Dominion Bank. Double Standards are illegal practice.
1.5.3: Mandamus and Abuse of Judicial Power by the Federal Court of Canada:
16. The Mandamus historically brought against the Abuse of Judicial Power by the judges and officers of the courts and it is a great shame that in this Application for Writ of Mandamus
the Toronto Office numerously is abusing the judicial power, where the Writs shall instruct that the Canadian Human Rights Commission investigate discriminatory practice of the Court.
5 Page 8
1.5.4: Violations of Rules 8 or 304, or partiality and bias:
17. There is not any document in the file to indicate there was a motion before Giles ASP, or a written request by Broer, Solicitor for Sprint Canada, or any party became aware of such proceeding before Giles ASP. In addition, Affidavit of Service indicates Sprint Canada was served with notice of application on August 19, that 10 day was due of August 29; RECORDED ENTRIES document number 3.
18. On August 31, 2000, Broer submitted the Notice of Appearance for Sprint Canada, which was Two Days Late for filing; RECORDED ENTRIES document number 23. Broer knew that was not allowed, legally, to file the Notice of Appearance for Sprint Canada, and misrepresented the facts ending to errors in Giles Reasoning that service via facsimile was not proper.
AS A RESULT, Giles Order obtained by FRAUD and falls within Rule 399(2)(b).
19. In addition, Giles ASP did not referred to a real fact the respondent, Sprint Canada and alleged that Sprint Canada was not properly served with the Notice of Application, moving the burden upon the Applicant's shoulder; where there was not any objection from the Sprint Canada that was not served in personally and appointed a counsel to reply to the Application,
On June 18, 1998, the Crown has installed a Notice of Application on the Applicant's property that was stolen by the Crown in right of Ontario's agent, due to conflict of proceedings; however the Court accepted the service. Canada v. Nourhaghighi T-1237-98, Fed (T.D.)
Nourhaghighi v. Canada T-668-95, Fed (T.D.) Giles Order
Conspiracy against Mr. Justice Douglas COO- Nourhaghighi v. Toronto Hospital
Nourhaghighi Affidavit September 14, 2000, para 19-Exhibit 15 Indicate that
The Federal court of Canada has demonstrated the outrageous, callous,
arrogant attitudes and sever discriminatory practices against
The Applicant, among all other courts in Canada
1.6: COSTS:
20. The Applicant seeking costs against all solicitors who have not admitted to service the documents served up on them that caused extra amount of work for drafting and commissioning of the Affidavits of Services And seeks sanction against the MBNA Canada Bank's Solicitor, Weisz who has abused the service process for the object of conspiracy. In addition, the Applicant seeking costs against the respondents, the Crown, Sprint Canada, the bank of Montreal, Toronto-Dominion Bank for the actions committed in this application ending to the Applicant's Motions pursuant to Rules 400(2)(3)(g)(h)(i)(j)(k)(i)(ii)(6)(d), and 404 (a).
6 Page 9
2. POINTS IN THE ISSUE:
21 It is submitted that there are four issues before the Court to support the Orders Requested:
A. The Respondents' Solicitors Negligence and Professional Misconduct.
B. Apprehension of bias in the judgment seats and administration of the Court in Toronto.
C. COSTS
3.1.1 ARGUMENT: The Respondents' Solicitors Negligence and Professional Misconduct:
22. The Respondents' Solicitors have misconduct themselves with the court process with negligence and breached to rule of law in accordance to the objects of conspiracy; therefore, the will remain liable for the torts raised and professional misconduct before other courts and tribunal in addition to the Contempt charges, disregard of any kind of out comes from this application.
3.1.2 Rule 303 and the Commencement of the Proceeding by a Respondent:
23. On October 31, the Applicant was expecting the Court support his argument and dismiss all cross motions with costs as Rule 303(1)(a) referring to the words of "every person directly affected by order sought in application, other than a tribunal" the words of person means every human being and tribunal means court that indicate the persons can be named respondents in a judicial review application.
24. A respondent must file an appearance if he wishes to participate in the proceeding. In the Ontario Court there is about $110 fees for registration of the Notice of Appearance to indicate this step, is a mandatory step for a respondent as a commencement of the proceeding on his behalf. The Counsels' defendants for Contempt did not take this major step for the respondents.
Korompay v. Ontario Hydro (November 7, 1990) Fed. Ct. No. T-377-88
A motion need not be accomplished with a affidavit where the relevant
facts appear from the court record
3.1.3: Violations of Rule 8 and 358s by all Counsels' defendants for Contempt:
25. The statement of fact was made in accordance to the Court Record that indicate Late Filing was a major negligence, and disobeying the Rules for the Motions to request Order under Rule 8 by supporting Affidavits were professional misconduct. There is nothing in the file to indicate why the respondents who did not filed motions for extension of time should be example from compliance with the Rules.
Thermionics Ltd v. D.L. Kepler [1938] ex. 324
No Special circumstances were shown whereby the Court should excuse
compliance with the Rule
7 Page 10
3.1.4: Does the respondents obtained Giles Orders and Lafreniere Direction by Frauds:
26. The respondents' conducts do not fall within any Rule and the Ethical Code. There is not any kind of proper explanation, excepted they have obtained the orders by corruptions and frauds.
The have received, illegally, special treatments and have ignored all Rules and the Ethical Codes;
which is required the issue be tried by a trial judge pursuant to Rule 399(2)(b) will apply.
FRAUD = A false misrepresentation of a matter of fact, whether by words or by conduct,
by false or misleading allegations, or by concealment of that which should have been disclosed [...] An intentional perversion of truth...m
"The Ontario Court of Appeal stated that: It is not necessary for the Crown to demonstrate an actual dollar loss. It ned only show conduct that is dishonest and resulted in deprivation[...] Dishonestly is not technical term, it is what a reasonable person would consider to be a dishonest act. R. V. Ruhland 109 OAC, 326
Imperial Oil Ltd v. Lubrizol Corp (1997) 74, C.P.R., (3d) 162 (Fed. C.A.)
Where a motion to set aside a judgment is based on allegation of FRAUD,
a trial of the issue should be ordered.
3.2: Apprehension of bias in the judgment seats and administration of the Court in Toronto:
27. The obligations of the enforcements of the Rules are in the shoulders of all judiciary officers, administrators and managers of the Court who have been trained and instructed to do so.
Five different violations have committed by five counsels for a single cause under Rule 8.
Even if all counsels fathers were the judges would not end to such contempt; however the bias and hostility of the Toronto Office can be visible in the Giles Orders, Lafreniere Direction, several Letters by clerks and counsels in the court record.
28. Since 1995, the Toronto Office of the Court is involved in conspiracy and frauds against the Applicant's proceedings; which is pleaded in numerous actions and affidavits brought by the Applicant- T-2464-95, T-942-99, or application against him by the Crown, T-1237-98, A-653-98.
The Supreme Court of Canada stated: "Since the offence if conspiracy only requirres an intention to commit the substantive offence, and not the commission of offence itself, it does not matter from the objective point of view, commission of the offence may be
impossible. It is the objective point of the view which is important, and from a subjective perspective, conspirators who intend to commit an indictable offence, intent to do everything necessary to satisfy the condition of the offence USA v. Cory
Nelles v. Ontario [1989], 2 S.C.R., 170, 49, C.C.L.T.217,37,C.P.C.(3d), 358, 60, D.L.R. (4th) 609, 98 N.R. 321, 69 O.R. (2d) 448(note), 35 O.A.C. 161, 42 C.R.R.,1/41 Admin L.R.1
The Attorney General was allowed to stand as a party defendant. However it was
Uncertain if the Supreme Court of Canada had determine whether or not the Crown
Would enjoy immunity from a conspiracy to injure action
8 Page 11
29. It is submitted that conspiracy is an outrageous misconduct and shall be ceased in the Canadian Judiciary Systems. In addition, the Court must take judicial that the Crown involved in serious felonies and corruption that makes, impossible, anyone in any position be able to enjoy immunity. However support the wrong, he will puts his personal and office capacity on liability.
The rule of law is everyone national wealth and heritage that were obtained by slashing the heads of corrupted and oppressive kings until each word of the Crown Liability Act was written.
Neither the hostility of Giles ASP nor the harassments of the RCMP and the Toronto Police could have any affect on prosecutions of all criminals, in the name of God and Rule of Law.
3.3: COSTS:
30. In the reading of the memorandums of facts and laws and material filed by all counsels, the Applicant have got full confidence that his memorandum of fact and law and material filed are much more professional and legal than the said counsels. Therefore, there is not any reason that why he should not be awarded for continuous hourly works and other costs since Aug 18/00.
31. On June 1998, the Crown brought Application T-1237-98 Against the Applicant. There was an introductory order to it that he appealed under A-635-98. The Applicants was successful to dismiss the Crown's Application in 1999; no costs were awarded to him; while his appeal yet have not been heard that he seeks all his costs, due to bias of the he Toronto Office.
R. V. James Lortimer & Co.,[1984], 1.F.C., 1065, 77, CPR, (2nd) 262(C.A.)
The time when the Crown neither asked for nor paid costs is long past. Today the position of the Crown is no more relevant to awarding of costs than the color of a litigant's hair.
4. ORDER REQUESTED:
32. The Applicant requests that all the Order requested in the Notice of Motion be granted with Costs of this motion and all other motions to the Applicant.
ALL OF WHICH RESPECTFULLY SUBMITTED
Dated, in Toronto, Ontario, November 23*, 2000
Keyvan Nourhaghighi
608-456 College Street
Toronto, ON, M6G 4A3
Tel: (416) 515 7263
*Nov 23/00, was a day that the Applicant was obligated to Perfect his Applicant's Record, owing to frauds and Conspiracy of the counsels defendants for Contempt, he was prejudiced seriously.

_______________________________________-

Court File No: T-1535-2000

FEDERAL COURT- TRIAL DIVISION

BETWEEN:

KEYVAN NOURHAGHIGHI, Applicant

-and-

REQUISITION FOR INTERVENTION
URGENT VIA FAX (514) 875 6115 The President of the Federation of Law Societies of Canada Transmission confirmed at 4:41 PM on September 22, 2000

The Applicant, Keyvan Nourhaghighi, non-citizen and conventional refugee is applying to the Federation of Law Societies of Canada for the Requisition of Intervention against the respondents for ten years continuous breaches of the Human Rights Codes and the Canadian Charters of Rights and Freedom against him and his family.
1- The Applicant, is a skilled landed immigrant that since 1990 the respondents with discriminatory practices did not allow him to enter to any kind of employment that be able to have minimum income to support his single family; due to discovery of corruption in the Airline Transport Pilot Licensing, where the Government was involved. He is continuously arrested and tortured by the Police and maliciously prosecuted by the Systematic Judiciary Racisms in the Ontario and Canada Criminal and Civil Justice Systems; where his access to the basic public medical cares were obstructed and with dishonesty series of forged evidences have created against him to deny all his physical disabilities due to torture by the Police: www.geocities.com/nourhaghighi/pilottable.html www.geocities.com/nourhaghighi/1535a1.html
2- The Respondent, the Canadian Human Rights Commission, with arbitrary decisions has refused to enter into the investigation against the respondents who are mostly the Government offices and servants of the Canadian Administration of Justice, who have obstructed his access to all judiciary services and legal rights: www.geocities.com/nourhaghighi/humanindex.html
3- The Applicant has moved before the Federal Court of Canada for the Writs of Mandamus that the Commission be able to have confidence to enter into the investigation [T-1535-00].
www.geocities.com/nourhaghighi/1535.html
4- Since August 18, 2000 that the Notice of Application served to the respondents, the Federal Court of Canada, with all its abilities trying to obstruct the Applicant access to the Court; and by full support of the respondents up to this date violated most of the Federal Court Rules.
www.geocities.com/nourhaghighi/1535a2.html
2
5- Ten largest law firms of Canada are representing the respondents; but he is not allowed to appoint a counsel who be obligated to follow his instruction, as the Government and Judiciary always have improper influences with his lawyers asking them to act against Applicant's benefits.
www.geocities.com/nourhaghighi/11dictionary.html see Judge John Wilkins in the Law Society of Upper Canada for Province of Ontario, Toronto Hospital et al v. Nourhaghighi
6- Many judges and lawyers are accused of dishonestly misconduct as the main tactic to inhabit the Applicant to seek and obtain the justice. Several Judges have committed thefts of his evidence to make sure that he would not be served with justice, where a large numbers of judges and lawyers have violated all principles of Laws, Rules, the Ethical Code and Conflict of Interest. www.geocities.com/nourhaghighi/conflict.html - www.geocities.com/nourhaghighi/bell.html*
7- Since September 14, 2000, several counts of irregularities and illegality have committed by judges and clerks of the Federal Court of Canada-Toronto, against his Application T-1535-00; judges who were named defendants in his action, maliciously, have rendered two decisions against him and for powerful respondents; several counts of thefts of documents and at least two counts of forgeries have been committed by few respondents' lawyers who are intercepting the applicant's full communications; with all these irregularity, illegality and dishonestly in the most credited legal process, as the Mandamus, it is required that this Law Society move before the Federal Court for leave to intervene as an added party, as an interest in the subject matter of the proceeding to obligate the Governments of Canada and Ontario to cease violations the Holy Bills of the Human Rights. www.geocities.com/nourhaghighi/yu.html ;and vass.html.
8- The Applicant certainly would be adversely affected by the judgment if this Law Society does not move for leave to intervene; or without becoming a party to the proceeding can intervene as a friend of the court for purpose of rendering assistance to the court by way of argument on the issue of the respondents Human Rights obligations toward the Applicant, as the refugee and as the non-citizen; where Mandamus contains the public interest issue that the Intervention of This Honourable the Federation of Law Societies of Canada may be benefited to all refugees.
ALL OF WHICH RESPECTFULLY SUBMITTED
Dated in Toronto This September 22, 2000 MAJOR KEYVAN NOURHAGHIGHI
Political Asylum Seeker as tortured
Resident of Canada, since 1994
Legal Ontario Separatist, since 1996*
608-456 College Street
Toronto, Ontario
M6G 4A3
CC Chief Judge of the Supreme Court of Canada
Chief Judge of the Federal Court of Canada Fax: 973 2154
Chief Judge of the Ontario Courts and judges of Court of Appeal
cc MORRIS ROSENBERG, Deputy Attorney General of Canada Robert H. Jaworski,
Tel: (416) 973-9638; Fax: (416) 973 0810
CC RENE DUVAL, Associate General Counsel
Solicitor for the Directors Respondents, Mervin Witter, Bob Fagan and the
Canadian Human Rights Commission, Tel: (613) 943-9156, Fax (613) 993 3089
CC ALLAN ROSENZVEIG, General Counsel, Telecom, Legal Directorate Solicitor for the
Respondent, J. Wilson, the Canadian Radio-television, and Telecommunications
Commission Fax :(819) 994 0218
CC ARTHUR HAMLLTON ;CASSELS BROCK & BLACKWELL LLP
Solicitor for Osborne Bank of Nova Scotia, BIRGENEAU and the University of Toronto
Tel: (416) 860 6574; Fax: (416) 640 3009
CC MICHAEL G. QUENNEVILLE, Solicitor for the Canadian Imperial Bank of Commerce
Tel: (416) 980 4291; Fax: (416) 861 3853 & 368 9826 FAILED
CC GIULIO D'ALESSANDRO, Solicitor for the Respondent, BELL CANADA,
Tel: (416) 353 4220; Fax: (416) 585 2130
CC KATE BROER, Solicitor for the Respondents, Sprint Canada+, and The Bank of Montreal
FRASER MILNER CASGRAIN Tel: (416) 863 4574; Fax: (416) 863 4592
+ Federal Court Judge, Defendant GILES, maliciously, removed Sprint Canada that be
able to continue its harassments against the Applicant
CC CCSTEVEN J. WEISZ, Solicitor for the Respondent, the MBNA Canada Bank,
BLAKE, CASSELS & GRAYDON LLP, Barristers and Solicitors
Fax: (416) 863 2653
CC BORDEN LADNER GERVAIS LLP, Barristers and Solicitors
Ted Murphy, and Eric ROHER, Solicitors for the Respondents, Scotiabank
Fax: (416) 367 6749
CC COLIN C. TAYLOR, Director Litigation Solicitor for respondent, Toronto-Dominion
Bank FAX: (416) 982 6166
CC The United Nations High Commissioner for Refugees Legal Project
Fax: (416) 973 7149
CC The Canadian Judicial Council
Fax: (613) 998 8889
CC Inter-Church Committee for Refugees
Fax: (416) 921 9967
CC Hon Lloyd Axworthy and The Ministry of Foreign Affairs
Fax: (613) 996 3443
CC Hon Sheila Maureen Copps and the Ministry of Canadian Heritage
Fax: (613) 994 1267
CC The Law Society of Upper Canada for Province of Ontario,
Fax: (416) 947 3335
________________________________________

URGENT Fax 44 171 956 1157 Amnesty International, London, The United Kingdom File Number

AMNESTY INTERNATIONAL

BETWEEN:

KEYVAN NOURHAGHIGHI, Applicant

-and-

Requisition to Intervention and Investigation

1- The Applicant, is a skilled landed immigrant that since 1990 the respondents with discriminatory practices did not allow him to enter to any kind of employment that be able to have minimum income to support his single family; due to discovery of corruption in the Airline Transport Pilot Licensing, where the Government was involved. He is continuously arrested and tortured by the Police and maliciously prosecuted by the Systematic Judiciary Racisms in the Ontario and Canada Criminal and Civil Justice Systems; where his access to the basic public medical cares were obstructed and with dishonesty series of forged evidences have created against him to deny all his physical disabilities due to torture by the Police: www.geocities.com/nourhaghighi/pilottable.html www.geocities.com/nourhaghighi/1535a1.html
2- The Respondent, the Canadian Human Rights Commission, with arbitrary decisions has refused to enter into the investigation against the respondents who are mostly the Government offices and servants of the Canadian Administration of Justice, who have obstructed his access to all judiciary services and legal rights: www.geocities.com/nourhaghighi/humanindex.html
3- The Applicant has moved before the Federal Court of Canada for the Writs of Mandamus that the Commission be able to have confidence to enter into the investigation [T-1535-00].
www.geocities.com/nourhaghighi/1535.html
4- Since August 18, 2000 that the Notice of Application served to the respondents, the Federal Court of Canada, with all its abilities trying to obstruct the Applicant access to the Court; and by full support of the respondents up to this date violated most of the Federal Court Rules.
www.geocities.com/nourhaghighi/1535a2.html
2
5- Ten largest law firms of Canada are representing the respondents; but he is not allowed to appoint a counsel who be obligated to follow his instruction, as the Government and Judiciary always have improper influences with his lawyers asking them to act against Applicant's benefits.
www.geocities.com/nourhaghighi/11dictionary.html see Judge John Wilkins in the Law Society of Upper Canada for Province of Ontario, Toronto Hospital et al v. Nourhaghighi
6- Many judges and lawyers are accused of dishonestly misconduct as the main tactic to inhabit the Applicant to seek and obtain the justice. Several Judges have committed thefts of his evidence to make sure that he would not be served with justice, where a large numbers of judges and lawyers have violated all principles of Laws, Rules, the Ethical Code and Conflict of Interest. www.geocities.com/nourhaghighi/conflict.html - www.geocities.com/nourhaghighi/bell.html*
7- Since September 14, 2000, several counts of irregularities and illegality have committed by judges and clerks of the Federal Court of Canada-Toronto, against his Application T-1535-00; judges who were named defendants in his action, maliciously, have rendered two decisions against him and for powerful respondents; several counts of thefts of documents and at least two counts of forgeries have been committed by few respondents' lawyers who are intercepting the applicant's full communications; with all these irregularity, illegality and dishonestly in the most credited legal process, as the Mandamus, it is required that this Amnesty move before the Federal Court for leave to intervene as an added party, as an interest in the subject matter of the proceeding to obligate the Governments of Canada and Ontario to cease violations the Holy Bills of the Human Rights. www.geocities.com/nourhaghighi/yu.html ;and vass.html.
The Applicant certainly would be adversely affected by the judgment if the this Amnesty does not move for leave to intervene; or without becoming a party to the proceeding can intervene as a friend of the court for purpose of rendering assistance to the court by way of argument on the issue of the respondents Human Rights obligations toward the Applicant, as the refugee and as the non-citizen; where Mandamus contains the public interest issue that the Intervention of This Honourable Amnesty International may be benefited to all refugees by moving before the United Nations Court of Justice to Charge the Canadian Government for the Crimes Against Humanity.
ALL OF WHICH RESPECTFULLY SUBMITTED
Dated in Toronto This September 25, 2000 MAJOR KEYVAN NOURHAGHIGHI
Political Asylum Seeker as tortured
Resident of Canada, since 1994
Legal Ontario Separatist, since 1996*
608-456 College Street
Toronto, Ontario lM6G 4A3
CC Hon Keith C. Northon the Chief Commissioner of Ontario Human Rights Commission
Chief Judge of the Supreme Court of Canada
Chief Judge of the Federal Court of Canada Fax: 973 2154 at 1:13 PM ^^
Chief Judge of the Ontario Courts
CC: MORRIS ROSENBERG, Deputy Attorney General of Canada Robert H. Jaworski,
Tel: (416) 973-9638; Fax: (416) 973 0810 ++ at 1:08 PM ^^

REQUISITION FOR HEARING

Pursuant to provision of Rule 314 of Federal Court Rules, 1998

THE APPLICANT REQUESTS that a date be set for the hearing of this application.
THE APPLICANT CONFIRMS:
1. The requirements of subsection 309(1) pf the Federal Court Rules, 1998 have been complied
with.
2. A notice of constitutional question has been served in accordance with section 57 of the
Federal Court Act.
(Or) There is no requirement to serve a notice of constitutional question under section 57 of the
Federal Court Act.
3. The Hearing should be held at........................
4. The hearing should last no longer than three days
5. The representatives of all parties to the application are as follows:
(a) on behalf of the applicant: self-represented who can be reached at: 608-456 College Street,
Toronto, Ontario, M6G 4A3, telephone number (416) 515 7263
(b) on behalf:
(1) the respondents, the Canadian Human Rights Commission, Mervin Witter and
Bob Fagan; solicitor RENE DUVAL, Associate General Counsel 344 Slater
Street, 9th Floor, Ottawa, Ontario, KIA 1E1; telephone number(613) 943-9156 and fax number (613) 993-3089.
(2) the Crown+ respondents, solicitor Robert H. Jaworski, Department of Justice,
Exchange Tower; Suite 3400, Box 362 First Canadian Place, 130 King Street
Toronto, Ontario, M5X 1K6; Tel: (416) 973-9638; Fax: (416) 973-5004.
(3) the respondent, J. Wilson, the Canadian Radio-television, and telecommunications Commission Canadian; solicitor ALLAN ROSENZVEIG, General Counsel, Telecom, Legal Directorate; Les Terrasses de la Chaudiere Central Building; 1 Promenade du Protage, Hull Quebec J8X 4B1; Telephone: (819) 953 3992; Fax :(819) 994 0218.
(4) the respondent Toronto-Dominion Bank, solicitor Colin C. Taylor Director,
Litigation; 12 Floor, P.O. Box 1; Toronto-Dominion Bank Tower, Toronto-