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
William: "You Fucking American Whore! CockSucker!"
Autobiography of Major Nourhaghighi
Canadian Counter-Dictionary and British Human Rights' Violations in Canada
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
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
AFFIDAVIT OF KEYVAN NOURHAGHIGHI
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
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
The Respondents have Obtained Orders by frauds, Factum November 23, 2000
Statement of Case
POINTS IN THE ISSUE
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-
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
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
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
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. 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
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
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
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-
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