Civil Action #3: The 2019 $500,000 Eviction Scam
Deirdre Moore and Khaldoon Habib-Allah et al.
Moore’s Motion Record for June 7, 2022 Hearing
Doc# | Description/Nature | Date | Ref/Link |
1 | 2017 MPAC assessment and deed of Moore’s matrimonial home | 2017xxxx
20220601 |
Aff#1 Ex-V |
2 | OPSB files excerpt re: how sexual assault allegations are investigated | 20151015 | Factum T-17 |
3 | Interim Shared Parenting Agreement | 20161213 | Factum T-4 |
4 | Excerpt from corporate website re: evidence of bank-assisted fraud re RBC | 20171021 | Aff#2 ex-G |
5 | Precedent-setting decision of Madam Justice D. Summers re Amended Answer | 20171116 | Factum T-6 |
6 | Letter of support for Moore from multiple sources | 20180224 –
20220330 |
Factum T-22 |
7 | Office of the Children’s Lawyer Report – excerpt only | 20180718 | Factum T-5 |
8 | Sample Covert Fraud Strategy used by a spouse who intends to go for jugular | 20180816 | Aff#1 ex-E |
9 | Testimony: Kiska stated he would “go for the jugular”/“spend his last dollar | 20180816 | Factum T-8 |
10 | Moore’s SCJ Submission to Justice Tracy Engelking | 20181231 | Factum T-9 |
11 | E-mail 10 of 10 to CAS re: Submission to Engelking | 20181231 | Factum T-10 |
12 | Two CYFSA Orders against Moore despite their evidence of ongoing domestic violence | 20190206
20190227 |
Aff#1 ex-A |
13 | CYFSA endorsement, order and unserved/late-filed affidavit | 20190408 | Factum T-11 |
14 | NCR opinion based entirely of lies of Kiska and companion sister | 20190408 | Factum T-12 |
15 | RTA eviction of Moore from her home without her knowledge; theft of $500,000 in property | 20190408 | Factum T-13 |
16 | Kiska’s e-mail to eviction paralegal Stoll | 20190515 | Aff#1 ex-B |
17 | Unanswered May to June 2019 correspondence with RBC’s David McDonald | 20190603 | Aff#2 ex-F |
18 | Unanswered correspondence with supposed landlord “Allah” | 20190624
20191019 20191213 20210403 |
Aff#1 ex-D |
19 | Suzanne Sviergula’s Draft Discovery Plan re: Moore’s Civil Action against Victor Vallance Blais LLP | 20190701 | Aff#1 ex-R |
20 | E-mail from Kiska to CAS Executive Director Kelly Raymond looking for “guidance” | 20190715 | Factum T-14 |
21 | Excerpts from Kiska’s interview with OPSB re: criminal harassment | 20190726 | Factum T-15 |
22 | OPSB charge sheet, defamatory police report and interview transcript | 20190726/27 | Factum T-16 |
23 | Non-Communication Order preventing Moore from contacting children | 20190727 | Factum T-18 |
24 | E-mail from CAS to Kiska’s lawyer Smith celebrating Moore’s arrest | 20190730 | Factum T-19 |
25 | Justice Engelking reduces support order and cancels September divorce | 20190809 | Factum T-23 |
26 | OPSB’s Ottawa Police Victim Crisis Unit number, file and complaint | 20191104 | Aff#1 ex-C |
27 | Notice of Application served on Moore by OCA’s Savage to obtain an anti-Charter gag order for Kiska | 20191106 | Factum T-27 |
28 | Response to OCA’s Malcolm Savage’s Notice of Application for an anti-Charter gag order | 20191107 | Factum T-26a |
29 | Edited release order (i.e. gag order) granted against Moore using “broad judicial powers” | 20191108 | Factum T-25 |
30 | Order of Justice J. Audet — evidence of court-assisted fraud | 20191120 | Factum T-7 |
31 | Sample of Kiska’s mockery via e-transfer related to S. 300 of the Criminal Code | 20191128 | Aff#2 ex-C |
32 | $250,000 lien against Moore’s matrimonial home placed by lawyers Gonrn Snir & Joseph Addelman who work “working” for the CAS & the Crown, respectively, for Kiska’s benefit & my demise | 20191128 | Factum T-32 |
33 | E-mail from OPS Sgt. Alex Bender | 20191220 | Doc033 |
34 | Threat of legal action by RBC | 20200121 | Aff#2 ex-D |
35 | E-mail to RBC re: its threat of legal action, threat of legal action | 20200202 | Aff#1 ex-Q |
36 | Screenshot of SAQOTU Inc.’s website: pfi.ROCKS Archives! for the year 2020 | 20200330 | Aff#2 ex-B |
37 | February to March 2020 correspondence with RBC’s lawyer, Michael Cassone | 20200330 | Aff#2 ex-E |
38 | Orders resulting from scandalous CYFSA Summary Judgment Motion against Moore | 20201214
20210114 |
Factum T-20 |
39 | Moore’s cost submission which evidenced that Sviergula lied to the court | 20210321 | Aff#1 ex-S |
40 | E-mail thread re: Moore’s attempts to obtain the eviction documents | 20210322 | Factum T-30 |
41 | Excerpt from my 202204 Release Order (following the Crown’s new anti-Charter conditions) | 20210409 | Aff#1 ex-F |
42 | Endorsement dismissing defendants’ Rule 2.1.01 Requisitions | 20210510 | Aff#1 ex-G |
43 | E-mail from civil lawyer re: guidance on how to improve claim | 20210521 | Aff#1 ex-H |
44 | First invoice (redacted) from new defence attorney who is not “working” for Kiska | 20210616 | Aff#1 ex-J |
45 | Fresh Amended Statement of Claim | 20210924 | Aff#1 ex-I |
46 | Extract from SCJ’s scandalous dismissal of my CYFSA Appeal | 20211220 | Aff#1 ex-U |
47 | Excerpt from SCJ Divisional courts scandalous dismissal of Moore’s CYFSA appeal | 20211220 | Factum T-28 |
48 | E-mail from VVB’s lawyer Susanne Sviergula to Allah’s lawyer Moore re: unpaid costs awarded for an illegally-brought/deceptively argued Rule 21 Motion (w cost award) | 20220117 | Factum T-24 |
49 | Decision-free endorsement from another SCJ panel denying me leave to appeal Justice Pamela MacEachern’s scandalous 20210609 Family court order | 20220121 | Aff#1 ex-T |
50 | Scandalous dismissal of Moore’s Family court appeal without reasons but with some arbitrary cost award. | 20220121 | Factum T-29 |
51 | Affidavit of OPSB: false statements of fact, refusal to investigate | 20220223 | Factum T-33 |
52 | Endorsement scheduling the dates for my materials and requesting Reply Affidavits and Reply Factums from the Moving Parties | 20220328 | Aff#1 ex-L |
53 | Decision to Adjourn Rule 21 20220308 Motion due to inadequate scheduling | 20220328 | Factum T-2 |
54 | Endorsement of Justice H.J. Williams staying Kemgni’s Action one week before it becomes statute-barred in the Province of Quebec | 20220401 | Aff#1 ex-M |
55 | Letter from Moore’s defence attorney stating that most charges withdrawn | 20220401 | Factum T-21 |
56 | Letter from defence attorney re: status of criminal proceedings | 20220405 | Aff#1 ex-K |
57 | Retainer agreement with Quebec civil lawyer | 20220406 | Aff#1 ex-N |
58 | Draft Amended Statement of Claim against Kiska re: collusion with Quebec-based psychiatrist prior to my house being emptied | 20220406 | Aff#1 ex-O |
59 | Affidavit #1 of Moore | 20220407 | Aff#1 and list of exhibits |
60 | List of Rules being used to terminate this claim by defendant | 20220407 | Aff#1 ex-P |
61 | Illustrative Overview of Ottawa’s Organized Crime Syndicate re: The Ottawa Ticket | 20220408 | Factum T-1 |
62 | Originating document against Dr. Paule Kemgni in the Quebec | 20220408 | Factum T-31 |
63 | Affidavit of Service for Affidavit #1 | 20220419 | Aff1 Aff of Service |
64 | Supplemental Affidavit of Moore | 20220419 | Aff#2 and list of exhibits |
65 | Affidavit of Service for April 7th Affidavit | 20220419 | Aff#2 Ex-A |
66 | Transcript from previous 20220308 hearing adjourning the Rule 21 Motion to June 7, 2022 | 20220422 | Factum T-3 |
66.1 | Factum with list to tabs (not linked) | 20220505 | Factum and list |
67 | Excerpt: Cost Submission re: Kemgni | 20220506 | Doc067 |
68 | Letter to sentencing judge from social worker Catherine Sullivan | 20220509 | Doc068 |
69 | Correspondence with Civil Desk | 20220511 | Doc069 |
70 | Threat from OPSB re: vexatious litigant | 20220519 | Doc070 |
71 | Letter re: Conditional Discharge | 20220525 | Doc071 |
72 | Revised Factum for inclusion in Motion Record | 20220531 | Revised Factum w links |
73 | Invitation to Caselines day before deadline with stark warning: “You must follow the rules” (see Doc #13 and tell that to Calum MacLeod) | 20220531 | Doc073 |
74 | Affidavit of Service (Revised Factum) w proof of filing nonsense | 20220601 | Doc074 |
75 | Affidavit of Service (re-service of Affidavits, original Factum) with evidence of labelling/filing nonsense | 20220601 | Doc075 |
76 | Affidavit of service on “landlord” missed in e-mail thread | 20220601 | Doc076 |
77 | Revised Affidavit #1 with hyperlinks for inclusion in Motion Record | 20220601 | Revised Aff#1 w Links |
78 | Revised Affidavit #2 with hyperlinks for inclusion in Motion Record | 20220601 | Revised Aff#2 w Links |