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20231107 Statement of Claim:  Word Version  >  pdf with links to evidence  >  scan of document filed  (Fee Waiver Certificate)

20240826 Statement of Defence: pdf version > Errors, Omissions & Malicious Obfuscation (“EOMO”) Analysis 

2024082x Reply: pdf version 

EOMO Analysis started 20240827 || last updated 20240828 20:20 e.s.t.                                                                                                  CV-23-00061855

Counsel for the Children’s Aid Society of Ottawa served its Statement of Defence 20240826. My EOMO Analysis (below) will be used in my Reply. It will be served on Blaney McMurtry lawyer Brenda Gross. She will then need to decide how she will proceed (ie. how many crimes and/or civil laws that she is prepared to commit/violate in order to earn $xxx/hour). 

 

Defence

Para #

 

Statement

  

Type of error, omission &/or malicious obfuscation

  

Actor/Enabler Reference

  

Torts

   Crimes   Other
             
001 The defendant, The Children’s Aid Society of Ottawa (hereinafter, “the Society”), denies that the Plaintiff is entitled to the relief sought in paragraph 1 of the Statement of Claim, and except as expressly stated herein, further denies each and every other allegation contained in the Statement of Claim. Ridiculous. How can they deny paras. 1-146 when the evidence of each allegation has already been published (see online version of the Statement of Claim here: https://twb.rocks/organized-crime/entity/cas/cv-23-00061855?

(insert details re: pathological lying being a top characteristic of sociopathy and speculation as to reasons why (eg.  as linked at https://twb.rocks/resources)

        
  THE PARTIES          
002 The Society is and was, at all material times, an agency operating pursuant to the provisions of the Child, Youth and Family Services Act, 2017, S.O. 2017, c. 14, Sched. 1, as amended (hereinafter, the “CYFSA”) to promote the best interests, protection, and well-being of children located in the Ottawa area.  🤪 irrelevant 🤪         
003

The Plaintiff, Deirdre Moore (hereinafter, the “Plaintiff”), is the biological mother of S.K. and C.K. (hereinafter, the “Children”).

Their names are Sean and Cate. The only pictures I have are the ones that I’ve managed to keep in my wallet as all of the other ones were stolen during the theft of everything that we owned on, coincidentally, April 8, 2019. 

My name is Deirdre. You stole my children. Prepare to be put out of business.

        
004

The Children were the subject of a child protection investigation under the CYFSA and, as such, their identities are prohibited from being made public pursuant to section 87(8) of the CYFSA. The Plaintiff must amend the claim accordingly to protect the identities of the Children.

Says who? Canada’s Criminal Code s. 21(1) states, among other things:

“Every one is a party to an offence who (a) actually commits it; (b) does or omits to do anything for the purpose of aiding any person to commit it; or (c) abets any person in committing it.”

FYI, intimidation of a journalist is also a crime: see s. 423.1(1)(c) at https://criminalnotebook.ca/index.php/Intimidation_of_a_Justice_System_Participant_(Offence)#Offence_Wording

        
  THE SOCIETY’S INVOLVEMENT          
005

The Society has been involved with the Plaintiff and Children on various occasions since 2013.

This statement is true.

Note how despite the truth of this statement, they made a contradictory statement at their para. 18. One of our working theories regarding the demonstrably poor memory of sociopaths is summarized in the box labelled “Family Law Rules” at Form 22 Request to Admit #4* published at https://twb.rocks/domestic-terrorism/perpetrators/individuals/john-kiska/fc-15-2446/form-22-request-to-admit-20240710.

*Note how, pursuant to Rule 22(4), Kiska has admitted all 24 allegations to be true, not unlike the previous two Request to Admits.

        
006 Most recently, the Society became involved with the Plaintiff and Children on September 20, 2018, due to protection concerns. These concerns were investigated by the Society as is mandated under the CYFSA. The protection concerns were verified.

LOL. The CAS re-involved itself shortly after my 20180818 letter to the editor was published. (Insert details re: how my precedent-setting win likely angered Ottawa’s sociopathic legal-judicial services network.)

        
007 On January 22, 2019, the case was transferred to ongoing services.

On 201901xx, I hand-delivered a copy of my 20181231 Submission to Engelking (viewable under subheading 2018 at https://twb.rocks/organized-crime/vis/tracy-engelking) to the CAS’s Viana Ibrahim. She gave this evidence-laden document to Mohammed Said who (on 20190619) stated that he:

  • did not read it and
  • did not know what a narcissist was

(Then, I was threatened to be fined for trespassing.)

        
008 On February 1, 2019, the Children were brought to a place of safety. False. See paras. 14 and 18 below, for starters.        
009 On February 5, 2019, the Society filed a protection application, bearing Family Court File No.: FC-19-CP000008 (the “Protection Proceeding”).

Then, three weeks later, it obtained a restraining order against me: zero reasons given.

More on these scandalous events enabled by SCJ’s Justice J.A. Parfett will be published in due course.

        
010 On April 8, 2019, Macleod J. made a final order in the Protection Proceeding, finding the Children in need of protection and placing them in their father’s care.

This statement is arguable. Regardless, the matter was illegally-heard as no materials were properly served or even filed. My request for an adjournment was denied.

If there is one event in #Mummygate that evidences why MacLeod should be hauled off in handcuffs, this is it. Details and evidence will be published here: https://twb.rocks/organized-crime/vis/calum-macleod.

        
011 On August 1, 2019, a status review application was commenced by the Society.

This statement is true.

Following Kiska’s false allegations of criminal harassment against me on 20190726 (which resulted in my immediate 90-day incarceration which prevented me from defending myself*), the CAS advanced Kiska’s retaliatory maneuvres on his behalf (see (draft) Form 22 Request to Admit #5 being published at https://twb.rocks/domestic-terrorism/perpetrators/individuals/john-kiska/fc-15-2446/form-22-request-to-admit-20240828).

*Without merit, the charge was eventually withdrawn (after the damage was done).

        
012 The Society brought a summary judgment motion, which was heard on November 10, 2020. On December 11, 2020, Fraser J. granted the Society and the Children’s father summary judgment, finding that the Children continued to be in need of protection and placed them in the custody of their father.

This statement is true.

This event occurred despite the fact that “custody and access” of children from a marriage falls within the jurisdiction of the federal Divorce Act.

        
013 The Plaintiff appealed and a decision was made to dismiss the appeal on December 20, 2021 (D.M. v. The Children’s Aid Society of Ottawa, 2021 ONSC 8360).

This statement is true.

Note how despite the truth of this statement, they claimed that this action was “statute-barred” at their para. 46. Perhaps they are hoping that, in addition to not being able to read, the presiding judiciary official will not be able to do math either? 

        
014 The Children have remained in their father’s care since February 2019.

My children have been denied my love and protection from an undiagnosed, “covert”, malignant narcissist (ie. a high-functioning sociopath, their biological father) since they were illegally ripped from my living room on 20190201 by the CAS with their three Ottawa Police Service-positioned accomplices. No one has even sent to me a picture of them since that day.

I remain forcibly married to this man, living in shelters and in receipt of social assistance, as he remains in my $2,000,000 home with my 100% gaslit children, my dog and my cat … paying $0 in financial support.

Evidence of this seemingly never-ending divorce is being published at https://twb.rocks/domestic-terrorism/perpetrators/individuals/john-kiska/fc-15-2446 as well as distributed via multiple mail campaigns.

        
   

THE ACTION IS AN ABUSE OF PROCESS

         
015 The action herein is an abuse of process in that the Plaintiff is seeking to re-litigate the issues from the Protection Proceeding initiated in respect of the Children, which application was adjudicated by the Family Court on a final basis on December 11, 2020. The Plaintiff then appealed that decision which was dismissed by the Divisional Court. The herein action is an improper collateral attack on these decisions. Accordingly, the Society pleads that the action herein is an abuse of process and ought to be dismissed. This is a classic example of every sociopath’s classic modus operandi, that is, D.A.R.V.O.:

  • Deny
  • Attack
  • Reverse Victim Order

The reality is, however, that the 2020 Summary Judgment Motion was:

and the scandalous 2021 dismissal of my appeal by three other career-criminal, SCJ judges was [insert phrase of choice] (see partial evidence against taxpayer-funded [insert pluralized noun] Matheson, Perrel and Kristjanson by scrolling down at https://twb.rocks/organized-crime/vis/three-stooges-1).

 

        
016 The remainder of this pleading is made in the alternative.

The remainder of this pleading is a continuation of bold, unsupportable, desperate statements made only because the individuals positioned at Blaney McMurty LLP are fearless. Aware that the entire legal-judicial community in the Ontario’s Calum MacLeod*-led East Region is nothing but a front for organized crime, they expect to convert my valid Civil Action into a cost award for both the Defendant … with a healthy payout for themselves.

Details of how this type of court-enabled fraud is executed is best evidenced via multiple links published at:

(though, I have amassed other examples as well). 

*Partial evidence against this crooked judge is viewable at https://twb.rocks/organized-crime/vis/calum-macleod.

        
             
  NO LIABILITY ON THE PART OF THE SOCIETY          
017 The Society denies all allegations made against it in the Statement of Claim, or at all, and puts the Plaintiff to the strict proof thereof. It will be my absolute pleasure to evidence all allegations and, hopefully, bankrupt this entity in order to fund a healing centre that helps as many of its other targets/victims recover.        
018 On September 20, 2018, the Society became involved with the Children as a result of protection concerns. The Society conducted an investigation. On February 1, 2019, the Society determined that the Children needed to be taken to a place of safety. The Children remained in their father’s care thereafter. The Society became involved with my family in 2013 following weeks of verbal, emotional and psychological abuse by my husband. Instead of protecting my children from his torture, CAS Yvonne Munro somehow managed to give temporary sole custody to their abusive father. Already aware of CAS torts and crimes throughout Ontario, her gaslighting was recorded (hear this demon-managed carcass’s voice at https://www.youtube.com/watch?v=4xWTbUiXwsU)        
019 The Society states that, at all material times, its employees, servants and agents acted in good faith in the execution of their duties, in accordance with their statutory obligations under the CYFSA, the accepted standard of conduct of a children’s aid society in Ontario, and the law. Addressed below at paras. X – Y.        
 

 

NO DUTY OF CARE OWED BY THE SOCIETY

          
020 The Society denies that it owed any duty of care to the Plaintiff, fiduciary or otherwise, and puts the Plaintiff to the strict proof thereof. The Society states that, to the extent to which it owed any duty of care, it was owed solely to the Children. No duty of care was or is owed to the Plaintiff as a parent of the Children.

LOL:

1. Read paragraph 1 a) of the Statement of Claim (ie. I am seeking damages on behalf of Sean and Cate),

2. Being affiliated with a provincial CYFSA-related racket does not provide a passes on provincial tort law or “get out of jail free” cards from requirements detailed in Canada’s federal:

  • Criminal Code,
  • Divorce Act,
  • Evicence Act or
  • Charter of Rights and Freedoms.
        
021 In the alternative, if the Society owed any duty of care to the Plaintiff, which is not admitted but specifically denied, the Society denies that it breached any duty of care and/or fell below the standard of care of a children’s aid society in Ontario. At all material times, the Society and its employees, servants and agents acted in good faith in the execution of their duties, in accordance with their statutory obligations under the CYFSA, and in accordance with the accepted standard of conduct of a children’s aid society in Ontario, and the law.

LOL. My mountain of evidence against your division of DTRU is undeniable, well-organized and … already published. Worst-case scenario? Your choice to defend yourself against my civil action (instead of making a reasonable offer to settle) will simply expose more judicial corruption and further pave the way for a transition to Artificial Intelligence (“AI”) for your entire industry.

It’s already begun (see https://www.spellbook.legal/); and, with the digitization of all legislation and case law complete long ago, a simple change in public opinion is all that would be required to transition all branches of judicial services. Either that, or we should just fire all lawyers/judges and replace them with Arts students who have a conscience (vs. the sociopaths that have been screened into the industry as theorized here:

       
   

NO WILLFUL BLINDNESS AND/OR RECKLESSNESS

          
022 The Society denies the Plaintiff’s claims of willful blindness and/or recklessness. Neither willful blindness nor recklessness are actionable torts.

Note to self: amend pleading and change label of this crime so it better meets the jargon used by civil court judges/lawyers.

        
023 In the alternative, the Society denies that it was willfully blind and/or reckless in its investigation and conduct towards the Plaintiff and the Children.

LOL. I was being kind. Theses demon-managed carcasses bury as much evidence as:

Now, we will likely witness their legal counsel do the same; proving (once again) that civil litigators are not lawyers but criminal accomplices.

        
 

 

NO INTENTIONAL TORT OR INFLICTION OF EMOTIONAL SUFFERING

         
024 The Society denies that it intended to or negligently caused the Plaintiff’s alleged emotional suffering, as pleaded in the Statement of Claim, or at all, and puts the Plaintiff to the strict proof thereof.  

Proof of emotional suffering? Piece of cake. It’s called defensive dysregulation as described in draft article posted at  https://twb.rocks/blank-00/living/safety/00000022_mental-health-industry-echko-audit-002.

        
025 At all material times, the Society executed its duties in the best interests of the Children, with an aim to promoting the Children’s safety, protection and well-being. The Society pleads that it acted in good faith in the execution of its duties, in accordance with their statutory obligations under the CYFSA, the accepted standard of conduct of a children’s aid society in Ontario, and the law. Admitted, all involved were acting the entire time: that’s what sociopaths do. For more information about sociopathy that may help you to identify these demon-managed carcasses, see https://twb.rocks/resources.        
  NO INTRUSION ON SECLUSION          
026 The Society denies the Plaintiff’s allegation of intrusion upon seclusion and puts the Plaintiff to the strict proof thereof.

Child protection services is the perfect cover for a child-trafficking network that is:

  • publicly and/or donor funded,
  • for profit,
  • without accountability and
  • without oversight

They can and will illegally rip your children from your home with the help of local law enforcement for no reason whatsover other that to traffic them for pleasure and/or profit. This model exists throughout Ontario, throughout Canada, throughout North America: it is a “Five Eyes” business model.

        
027 The Society specifically denies that it intruded upon the Plaintiff’s private affairs without lawful justification. On the contrary, the Society is mandated under the CYFSA and law to investigate child protection concerns. Any actions taken by the Society were taken in the exercise of its duties under the CYFSA and law to promote the safety, well-being and best interests of children in need of protection LOL – see above        
   

NO DEFAMATION BY THE SOCIETY

          
028 The Society denies the Plaintiff’s allegation of defamation, which allegation is plead without any particulars, and puts the Plaintiff to the strict proof thereof. Piece of cake! Start with just a small portion of the undeniable evidence that was used for the Summary Judgment Motion at https://twb.rocks/organized-crime/swimlanes/entities/cas and then work your way over to all of the materials submitted for the appeal.        
029 The Society denies that any one of its employees published any words which could be characterized as defamatory and/or, if such words were published, either orally or in writing, such words were not communicated to any third party and, as such, are not actionable.

LOL. They’re called court documents including, but not limited to, affidavits and factums. There are also:

  • recordings/transcripts from hearings ✔️ ,
  • e-mails ✔️,
  • CAS-watermarked files ✔️ and
  • hand-written threats. ✔️ 
        
030 In the alternative, the Society states that, if any defamatory words were published by its employees, which is not admitted but denied, the words complained of were published by them without malice in the course of their duties as employees of the Society and were received by individuals who had a corresponding interest or duty to receive the matter communicated. As such, the Society states that the words complained of were communicated on an occasion of qualified privilege and, as such, are not actionable.

LOL. Malice trumps “qualified privilege” and proving malice,

including but not limited to the intentional and/or negligent disregard for evidence of severe domestic violence (against which Sean and Cate should have been protected pursuant to multiple pieces of legislation) by its “client”, John Kiska (which continues to this day),

… will be simple. 

        
031 In the further alternative, the Society states that, if any defamatory words were published by its employees, which is not admitted but denied, the words complained of were published in the course of a judicial proceeding, i.e., the Protection Proceeding. As such, the Society states that the words complained of were protected by absolute privilege and are not actionable.

Canada’s Criminal Code (“CCC“) s. 21(1) Parties to an Offence trumps your pithy, provincial, CYFSA-related clauses designed to circumvent the protections guaranteed by:

  • Canada’s federal Divorce Act and/or
  • Canada’s Charter of Rights and Freedoms

unless, of course, your argument is that those three pieces of federal legislation are not worth the paper that they’re written on?

        
   

NO COMPLICITY TO OBSTRUCT JUSTICE

          
032 The Society denies the Plaintiff’s claim for complicity to obstruct justice, and puts the Plaintiff to the strict proof thereof.

Simple:

CCC‘s s. 139

(1) Every one who wilfully attempts in any manner to obstruct, pervert or defeat the course of justice in a judicial proceeding,

(a) by indemnifying or agreeing to indemnify a surety, in any way and either in whole or in part, or
(b) where he is a surety, by accepting or agreeing to accept a fee or any form of indemnity whether in whole or in part from or in respect of a person who is released or is to be released from custody,
is guilty of
(c) an indictable offence and is liable to imprisonment for a term not exceeding two years, or
(d) an offence punishable on summary conviction.

Idem
(2) Every person who intentionally attempts in any manner other than a manner described in subsection (1) [obstructing justice – re surety] to obstruct, pervert or defeat the course of justice is guilty of

(a) an indictable offence and liable to imprisonment for a term of not more than 10 years; or
(b) an offence punishable on summary conviction.

Idem
(3) Without restricting the generality of subsection (2) [obstructing justice – other conduct], every one shall be deemed wilfully to attempt to obstruct, pervert or defeat the course of justice who in a judicial proceeding, existing or proposed,

(a) dissuades or attempts to dissuade a person by threats, bribes or other corrupt means from giving evidence;
(b) influences or attempts to influence by threats, bribes or other corrupt means a person in his conduct as a juror; or
(c) accepts or obtains, agrees to accept or attempts to obtain a bribe or other corrupt consideration to abstain from giving evidence, or to do or to refrain from doing anything as a juror.

        
033 Complicity to obstruct justice is not a recognized tort and therefore cannot succeed as a cause of action as against the Society. Note to self: amend pleading and change label of this crime so it better meets the jargon used by civil court judges/lawyers.        
   

NO COMMISSION OF TORTURE

          
034 The Society denies the Plaintiff’s claim of torture, and puts the Plaintiff to the strict proof thereof.

Simple:

CCC‘s s. 269.1 (1) Every official, or every person acting at the instigation of or with the consent or acquiescence of an official, who inflicts torture on any other person is guilty of an indictable offence and liable to imprisonment for a term not exceeding fourteen years.

Definitions
(2) For the purposes of this section,
“official” means

(a) a peace officer,
(b) a public officer,

and

CCC‘s s. 23 (1) An accessory after the fact to an offence is one who, knowing that a person has been a party to the offence, receives, comforts or assists that person for the purpose of enabling that person to escape.

        
035 The allegation is frivolous and/or scandalous, and ought to be struck pursuant to Rule 25.11 of the Rules of Civil Procedure, R.R.O. 1990, Reg. 194.          
036 The Society denies the Plaintiff’s allegation that it engaged in human trafficking.

Of course it does: criminals do not like to get caught.

Soon, their legal counsel will also be guilty due to s. 21(1) and s. 23(1) of the Criminal Code of Canada (“CCC“), for starters. I sure hope they’re aware of all of the crimes listed at https://twb.rocks/domestic-terrorism/perpetrators/individuals, s. 22 of the CCC (and understand the definition of proceeds from crime), too.

        
037 The allegation is frivolous and/or scandalous, and ought to be struck pursuant to Rule 25.11 of the Rules of Civil Procedure, R.R.O. 1990, Reg. 194. Hardly. Evidence will be framed to describe exactly how the CAS is involved in the crime of Trafficking in persons … and more. Draft reverse-engineering of the entire business model is viewable here: https://twb.rocks/organized-crime/swimlanes.         
   

NO ABUSE OF TAXPAYER MONIES

aaaaahahahahahahhhhhaaahahahhahaaahahahahahahahaha        
038 The Society denies the Plaintiff’s claim that it abused taxpayer monies. The Society denies the Plaintiff’s claim that it abused taxpayer monies.        
039 The Plaintiff loosely alleges that the appropriate use of the Court process to adjudicate protection concerns pertaining to the Children was an abuse and/or waste of
taxpayer monies.		 The Plaintiff loosely alleges that the appropriate use of the Court process to adjudicate protection concerns pertaining to the Children was an abuse and/or waste of taxpayer monies.        
040 The Plaintiff does not have standing to bring an action on behalf of all taxpayers in Ontario. Perhaps, I should split my Action into two and carve out the class action? As pleadings are not yet closed, I can still amend my Statement of Claim without consent or leave of the court. Surely, that would just be a waste of valuable court resources and any reasonable judge would prefer to hear both matters as one? Alas, one requires only a few plaintiffs to commence a class action: rounding up other CAS targets wouldn’t take long.        
041 Furthermore, the Society is statutorily mandated to investigate protection concerns involving children under the CYFSA and law. Any actions it took were in the interests of promoting the safety, protection and well-being of the Children.          
042 The Society denies that the Plaintiff suffered any losses, injuries, and/or damages as alleged in the Statement of Claim, or at all, and puts the Plaintiff to the strict proof thereof.          
043 In the alternative, if the Plaintiff has suffered any losses, injuries, and/or damages, which are not admitted but denied, the Society denies that any such losses, injuries, and/or damages were caused by or are in any way the result of any acts undertaken or omissions made by it, or any Society employee, or anyone for whom the Society is in law responsible.          
044 In the alternative, the Society states that any losses, injuries, and/or damages claimed are excessive, exaggerated, remote, and unforeseeable, and the Plaintiff has failed to mitigate same. LOL. “…. failed to mitigate same”? See evidence of attempted “mitigation” at https://twb.rocks/the-darkumentary. (Can y’all not read either?)        
045 The Society states that if the Plaintiff suffered any losses, injuries, and/or damages, which are not admitted but denied, such losses, injuries, and/or damages relate to incidents which pre-date or post-date those described in the Statement of Claim. LOL. The demon-managed carcasses entered our lives in 2013 and didn’t exit stage left until 2021. Over eight years were invested in ripping my perfect children from my life for sociopath husband’s benefit. Partial details evidenced here: https://twb.rocks/domestic-terrorism/perpetrators/individuals/john-kiska/fc-15-2446.        
 

 

THE ACTION IS STATUTE-BARRED

          
046 The Plaintiff’s claim is statute-barred by reason of an expired limitation period. The Plaintiff issued the herein action on November 7, 2023. The action was therefore issued more than two years after the Society’s investigation and involvement with the Children. The claim ought to be dismissed on this basis. LOL. Arguably, the Statute of Limitations’ date is 20231220, you silly goose. (See details at https://twb.rocks/wp-content/uploads/2024/08/001569KJ-20240827-0735_Email-to-Blaney-McMurty-re-CV-23-61855_Moore-v-CAS_Mistakes.pdf).        
047

The Society pleads and relies upon the provisions of the following statutes and their corresponding regulations:

(a) Child, Youth and Family Services Act, 2017, S.O. 2017, c 14, Sch 1;
(b) Libel and Slander Act, R.S.O. 1990, c. L.12;
(c) Negligence Act, R.S.O. 1990, c.N.1;
(d) Courts of Justice Act, R.S.O. 1990, c C.43;
(e) Limitations Act, 2002, S.O. 2002, c 24, Sch B;
(f) Rules of Civil Procedure, R.R.O. 1990, Reg. 194; and
(g) Criminal Code, R.S.C. 1985, c C-46.

Perhaps the “expired limitation period” to which you referred at para. 46 was the six months within which I was supposed to serve on your group my Statement of Claim pursuant to Rule 14.08(1) of the Courts of Justice Act (“CJA“). That, sadly, was overtly prevented by the OPS-Crown-OCJ branch of Domestic Terrorists R Us (“DTRU”). Partial details and evidence are published at https://twb.rocks/domestic-terrorism/perpetrators/entities/blaney-mcmurtry/brenda-gross.

All involved should be behind bars and forbidden from practicing #TDVCA ever again. Should CAS’s counsel at Blaney McMurtry LLP?

        
048 The Society requests that this action be dismissed as against it with costs payable by the Plaintiff to the Society on a substantial indemnity basis. Of course you do. All shysters do.        
 

August 26, 2024

TO: Deirdre Moore, SAQOTU Inc.
c/o YWCA Women’s Shelter
6135 Culp Street, Niagara Falls, ON L2G 2B6
Tel: (613) 848-6832  ||  Email: dmoore@pfi.rocks

1244 Lampman Crescent, Ottawa, Ontario K2C 1P8

yet … NFA & in receipt of social assistance

dmoore@twb.ROCKS & ascjak@outlook.com

Self-presenting litigator for the Plaintiffs: my children Sean and Cate, myself and Ontario taxpayers (who unknowingly fund your terrorist organization).

 

FROM: Blaney McMurtry LLP, Barristers and Solicitors
1500 – 2 Queen Street East, Toronto, ON M5C 3G5

Brenda Gross (LSO#: 45667F)
Tel: (416) 596-2875  ||  Fax: (416) 594-2504  ||  Email: bgross@blaney.com

Lawyers for the Defendant,
The Children’s Aid Society of Ottawa