Autobiography of the Lord of Law
Major Keyvan NourhaghighiJuly 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 Zbefore 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
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.
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
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
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 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;
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
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
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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-
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
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
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
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
-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.
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
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 "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
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
"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"
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
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
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
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.
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,
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 [...].
"[...] 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.".
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
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 )
Toronto, in the Province of Ontario, ) Signed: KEYVAN NOURHAGHIGHI
This January 18th, 2001, Signed Kevin Kelly, Federal Court Registry Officer, Toronto )
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