NOTICE OF APPEAL TO AN APPELLATE COURT

 BETWEEN

 

DEIRDRE MOORE

and

OTTAWA POLICE SEVICES BOARD

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started 2025021x and last updated 20250226 at 17:02

NOTICE OF APPEAL

           

THE APPELLANT, Deirdre Moore, APPEALS to the Court of Appeal from the judgment of Justice Kerry Lee McVey dated January 27, 2025 made at the Superior Court of Justice in Ottawa, Ontario.

THE APPELLANT ASKS that the judgment be set aside and a judgment be granted as follows:

  1. An Order dismissing the order which states “should Deirdre Moore file material seeking to commence or continue a proceeding or any appeal in any court in Ontario without first filing an entered Order permitting her to do so, the proceeding shall be immediately stayed upon any person filing a copy of this Order in such a Court”.
  2. An Order dismissing the order for costs awarded against Deirdre Moore (“Whistleblower”[1])
  3. An Order for a Summary Judgment against the Ottawa Police Services Board (“TIPCUP”[ii]) as requested in Whistleblower’s CV-21-00087056[iii]
  4. An Order for costs on a full-indemnity basis.
  5. Any other Order that the court deems just; including, but not limited to:
    1. declaration of TIPCUP as a vexatious litigant that is:
      1. Insert restriction
      2. Insert restriction and
      3. Insert restriction.

The GROUNDS OF APPEAL are as follows:

  1. The judge erred in fact.  For example, while each of Her Honour’s sentences contained in her 20250127 decision (“Ruling”) at paragraph [5] were “technically correct”, the lack of acknowledgement of the seven Motions which occurred throughout 2023 render the paragraph—as a whole—an entirely false statement of fact.

The seven Motions included an attempt to obtain Third-party Records (“TPRs”) from TIPCUP which is normally a part of an Affidavit of Documents and/or Discovery process. Vexatious (and criminal) behavior by TIPCUP’s legal representatives at Borden Ladner Gervais LLP, however, resulted in the denial of these records. Undeniable evidence of this fact was long-ago published at https://twb.rocks/the-darkumentary. An Errors, Omissions and Malicious Obfuscation Analysis (“EO&MO”)[iv] of Ruling will evidence that more than 20 of Justice Kerry Lee McVey’s 35 paragraphs used to justify the Ruling’s conclusions were false statements of fact.

  1. The judge erred in law. For example, TIPCUP brought its vexatious, Vexatious Application on 20230131 which was prior to amendments made to s. 140 of Ontario’s Courts of Justice Act (“CJA”) via the Enhancing Access to Justice Act, 2024(“EAJA”). The EAJA amendments were not retroactive and, therefore, shall not be relied upon for TIPCUP’s CV-23-00091267. On 20250127, Her Honour erred by, among other things, imposing the court’s newly-expanded 2024 powers to TIPCUP’s 2023 Application (which, arguably, intentionally misquoted the then-existing legislation through its clearly poor use of grammar and/or punctuation … perhaps to mislead the 2023-appointed judge).
  2. The judge erred in mixed law and fact.  For example, Her Honour’s two-sentence interpretaton (at paragraph [16]) of her seven-point description (at paragraph [15]) included only:
    • a) that which TIPCUP need not demonstrate and
    • b) [unevidenced] “outside the courtroom” conduct which the court may consider.

Her Honour ignored her own leading-case requirement noted in her paragraph [15]:

“(e) … the Court must look at the whole history …” (insert rest of quote)

As stated in GROUNDS (item 1), exclusion by TIPCUP of any reference to Whistleblower’s seven 2023 Motions prevented the couret from looking at “the whole history”: scheduling its Application to be heard without Whistleblower’s involvement ensured the court would remain ignorant of “the whole history”.


THE BASIS OF THE APPELLATE COUIRT’S JURISDICTION is:

  1. X
  2. X
  3. X
  4. X
  5. X
  6. X
  7. X
  8. X
  9.  Ruling lacked jurisdiction in multiple ways including, but not limited to, its restriction Whistleblower’s ability to commence any Application, Certiorari or Appeal in the Ontario Court of Justice and/or Superior Court of Justice for her ongoing criminal matters which are entirely due to:
    • a) her husband’s false allegations, etc.,
    • b) TIPCUP’s negligent investigations, etc., and
    • c) Ottawa’s Crown Attorney’s Office perpetual malicious prosecution.

The violations of Canada’s Criminal Code (“CCC“) by Ottawa-based criminal court judges and justices of the peace require those who stand accused to be in a position to access those alternative avenues to justice.

(insert date of perfected appeal)  


Endnotes

[1] That is, (insert section from Certificate)

[ii] That is, T I P C U P

[iii] See Whistleblower’s Fresh Amended Statement of Claim against TIPCUP CV-21-00078056 at (insert link)

[iv] See sample of Whistleblower’s other EO&MOs published at   (regarding Moore v. CAS CV-23-xxx published at ), etc. etc.

to be continued

 

Congratulations.

 

(Insert Back Sheet)