issued CAS $10M Civil Action || 2020 Summary Judgment Motion || 2021 CAS Appeal || CAS Main Page || #Mummygate, the screenplay || CAS Continuing Record || Divorce File Continuing Record  ||  John Kiska || Andeé Jak

Storing content for three civil actions: Doug Downey’s MAG, Michael Parsa’s Child Protection Services (aka Ottawa’s CAS crew) and OCL “Agent” Susan Galarneau.

 

 

A.  SUMMARY

1. The events leading up to the 2013 involvement of the Children’s Aid Society of Ottawa (“CAS”) in the lives of the Plaintiff (“Andeé”) and her two children, Sean Kiska and Cate Kiska (“Sean & Cate”) as described at paras. X-Y below, were:
   • Ignored,
   • Buried and/or
   • Discounted-to-a-value-of-zero

(“IBD”)’d¹ by multiple agents and employees of this taxpayer-funded, for-profit entity, as well as its Executive Director, Kelly Raymond.

2. The lack of involvement of the CAS between 2014 and 2016 is notable; especially, given the ease with which Andeé’s husband, John Kiska (“Kiska”) enjoyed involving them once Andeé had successfully separated from him for the third and final time in 2016: using “services” at The Ottawa Hospital, the Royal Ottawa Mental Health Centre (and elsewhere) to build a faux history of mental illness must have been a required pre-requisite to their eventual child and parental alienation plans—motivated by the City of Ottawa’s sick&twisted need for broken bodies in order to keep its hooker, addict, inmate and cheap labour industries operating.
3. Evidence of the 2017-2018, multi-faceted, severe domestic violence and child abuse by Kiska, that intensified following:
   • Justice Darlene K. Summers’ 2017 decision that permitted Andeé to seek damages for Kiska’s crimes and torts in her 2017 decision Kiska v. Moore, 2017 ONSC 6872 (CanLII) and
   • the 2018 report from Ontario’s Office of the Children’s Lawyer (“OCL”) that recommended Sean & Cate’s mum—not their father—receive sole custody of them.

as described at paras. X-Y below was also IBD’d by the CAS as evidenced by their unlawful 20190201 child abduction initiated by conscience-free, pathological lying, case worker Mohammad Said (“Said”) and equally, morally-bankrupt, lawyer Brian Fisher (“Fisher”).

4. The savagery of the CAS intensified as Andeé’s long-awaited divorce from Kiska approached: by June 2019, they had begun to weaponize other rogue entities including, but not limited to, the Ottawa Police Services Board (“OPSB”) and Ottawa’s Crown Attorney’s Office (“OCA”) throughout Ottawa to further demonize, criminalize and marginalize her as described at paras. x-y below as well as emotionally and psychologically torture and terrify Sean & Cate.
5. Court performances in 2020 and 2021 further evidenced their disregard for and/or support of domestic violence and child abuse to the detriment of Sean & Cate as evidenced when they IBD’d testimony and evidence that could have been used to protect Sean & Cate from Kiska during:
   • a 2020 Summary Judgment and
   • a 2021 Appeal and Motion to Adduce Fresh Evidence.

as described at paras. X-Y below.

6. The emotional and psychological abuse of Sean & Cate continued throughout 2023 as they’ve been denied the love and protection of Andeé for nearly five years; told that their mum:
   • abandoned them as she no longer wanted them,
   • was severely mentally ill and dangerous,
   • was a criminal,
   • refused to accept treatment or follow any rules to be able to see them and
   • who knows what else (apparently, at one point they were told she moved to Texas?!?).

7. As of [insert date of origination of claim], the CAS:
   • continued to enable, at a minimum, Kiska’s ongoing emotional and psychological abuse of Sean & Cate,
   • did nothing to mitigate their losses (despite having knowledge, or ought to be having knowledge of the torts and crimes in which they have been involved) and, likely,
   • continued to torture, traffic and terrorize other Ottawa citizens for pleasure and/or profit.

B.  20130301-20201110 CHRONOLOGY OF CAS-RELATED TORTS AND CRIMES

8. The marriage between Andeé and Kiska began to unravel by 2012, when:
   • arguments about lifestyle and estate planning escalated into a massive argument,
   • Sir Winston Churchill’s Vice Principal Greg Wyzynski chose to contact the CAS and
   • CAS’s Yvonne Munro drilled Andeé for several hours about “mental illness” until she arbitrarily chose to give sole custody to Kiska and
   • Kiska’s behaviour over the next 36 hours–with his newly-acquired power–resulted in Andeé’s hospitalization for a nervous breakdown (eg. defensive dysregulation also known as a psychotic break).
9. From 20130303-05, by covering his tracks and providing false collateral information² to The Ottawa Hospital’s Dr. Daniel Saul, Kiska ensured Andeé was mis-dignosed: she was released within 72 hours with a diagnosis of bi-polar disorder though she had zero symptoms of mania nor depression.
10. On 20130306, CAS’s  Jessica Henry (“Henry”) buried:
    • Andeé’s son’s teacher’s testimony that “Daddy hit Mommy” and
    • the testimony of their family doctor, Judy Chow (“Chow”) re: awesome mother.

Meanwhile, following their long-awaited, beach holiday in Mexico, Kiska escalated his verbal, emotional and psychological abuse in order to trigger another nervous breakdown in time for Henry’s scheduled visit.

11. On 201304xx, after attempting to seek assistance from Ottawa Police Services, Andeé instead wound up being hospitalized: Kiska wasted no time in planning his exit as he began to conspire with Andeé‘s estranged sister, Moira Moore, while continuing to deceive her in multiple, sick&twisted ways. 
12. On 20140710, a similar hospitalization-resulting, verbal/emotional/psychological/psychiatric-abuse event was orchestrated when:
    • Kiska again lied to The Ottawa Hospital (“TOH”) in order to have her formed involuntarily (with zero actual evidence required),
    • TOH’s Yoland Charbonneau reduced Andeé’s testimony regarding domestic violence to a value of zero and claiming in a laughable Consent & Capacity Board hearing that Andeé was “too sick to remember what she had done”,
    • Andeé was forced to spend the entire summer in the hospital and
    • Kiska recruited Andeé’s other estranged sister, Eileen Moore, to sign a Community Treatment Order for the forced ingestion and/or injection of psychotropics for a mental illness that she didn’t have!
13. By this point, Andeé knew that somehow Kiska had learned how to cause her hospitalizations; however, she had not yet understood his machinations nor his motivations and upon release she sought a divorce lawyer; albeit, without success.
14. By mid-September 2014, Andeé was forced to abandon her plans for divorce and attempt a reconciliation.
15. Finally, after obtaining a complete copy of her TOH files and reviewing the ?1,000s? of pages contained within, on 20150926, Andeé:
    • discovered the evidence of Kiska’s psychiatric abuse that forced her mis-diagnosis and lengthy hospitalizations,
    • foolishly alerted Kiska that she would be seeking a divorce with grounds (ie. cruelty) and
    • initiated her second separation from Kiska by setting up a separate room in the basement of their matrimonial home.
16. Kiska’s gaslighting immediately escalated and by 20151012, after spending two days attempting to find assistance from OPSB, Gatineau Police and multiple shelters without success, Andeé drove herself back to the TOH desperate for help.
17. This time, nursing staff:
    • did not ignore Andeé’s testimony,
    • did not prescribe any anti-psychotics and
    • did follow her instructions regarding anxiety reduction in order to avoid a lengthy psychotic break.
18. While Andeé’s diagnosis of bi-polar disorder was removed, TOH’s Gary Kay refused to acknowledge Narcissistic Victim Syndrome or, its DSM-V equivalent, “Brief Psychotic Disorder with Marked Stressors”³. He diagnosed Andeé with “Psychosis, not otherwise specified” (Psychosis NOS”), asked her to stay voluntarily in order to attend their occupational therapy sessions^N regarding “anxiety management” and immediately provided her with virtually unlimited day passes.
19. As well as completing her contract at Carleton University, attending a Board meeting at the Canadian Mental Health Association and exercising at TOH’s on-site gym, Andeé ensured she was home every night to tuck in Sean & Cate.
20. As Andeé attempted to find a lawyer, Kiska found one first and on 201511xx served her with a Form 8: Application (for separation only) and a devious Urgent Motion for Sole Custody (that was served but never filed/pursued by him) laden with errors, omissions and malicious obfuscation in order to frame Andeé as an unfit parent and gain strategic advantage in their pending divorce proceedings.
21. Unbeknownst to Andeé, collusion between Kiska’s lawyer Wade Smith (“Smith”) and Jak’s lawyer Victor Vallance Blais (“Blais”) resulted in ongoing abuse that extended to include financial: by the end of April 2016, Andeé was forced to end the disastrous, 50-50 shared parenting, 2-2-3 “nesting arrangement” and return to the matrimonial home to better prepare financially.
22. By 201611xx, after Kiska’s everything-but-the-bruises abuse has re-emerged, Andeé notified the CAS, her family doctor Judy Chow (“Chow”) and Blais that she would be leaving Kiska for the third and final time: Chow also notified the CAS.
23. Jak secured a nearby condo and eventually (with the assistance of CAS’s Shawna McClemens (“McClemens”)) possession of her 3-bedroom rental propety; however, McClemens did zero to assist Andeé, Sean & Cate by way of protection from Kiska.
24. On 20170207, CAS’s Shawna McClemens discounted Andeé’s testimony regarding Kiska’s sexual, verbal, emotional, psychological and psychiatric abuse to a value of zero (see page 1 of 50: Investigation #2402084) and closed the file.
25. Attempting to co-parent with Kiska remained disastrous as all forms of abuse continued including, but not limited to technology-assisted stalking and harassment (“TASH”), technology-assisted Fraud and the non-stop emotional abuse and gaslighting of Sean & Cate. with examples too numerous to list in this statement of claim.
26. on 201803dd, following the “Best Buy incident”, with full knowledge of Kiska’s intentions, CAS’s Steven Tremblay recommended the worst possible safety plan possible if Andeé were feeling as if she were being abused into another psychotic break, she was to deliver Sean & Cate to Kiska!
27. Kiska is the psychological version of Paul Bernardo and, as of 2018, Andeé was now forced to rely on him as a safety plan! #PurelyDemonic, Kiska reveled in this heightened, documented power.
28. The first half of 2018 brought, among other things, more financial abuse from Kiska: with the assistance of Smith and SCJ’s Julie Audet, he was able to commit Fraud in family court in order to further abuse Andeé, Sean & Cate financially and emotionally; though Andeé attempted to shield her children from the abuse the best she could.
29. On 20180711, following their four-month investigation which included interviews of multiple healthcare professionals, Ontario’s Office of the Children’s Lawyer (“OCL“) produced a 42-page report that:
    • identified Andeé as the superior parent (see page 18, para. 4; page 12) and
    • stated that Andeé should have sole custody of Sean & Cate (see page 19).

It also documented, among other things, of how daughter Cate “pulled away” when Kiska attempted to hug her (see page 12, para. 4) .

30. Shortly thereafter, Kiska communicated with Andeé’s parents that he would be “going for the jugular” and “spend[ing] his last dollar” in order to destroy her during their divorce.
31. On 20180825, in addition to publishing gang-stalking crew Bittersweet’s interview on 20161122 (as noted at para. 23 above), the Ottawa Citizen published Andeé’s letter to the editor “Let’s support victims of domestic violence“; likely, to alert OPSB and other local gang-stalkers that “eliminating” Andeé was a “go”. (Kiska must have made another payment.)
32. By 20180905, while on a short trip to Mont Tremblant, Andeé had to inform Sean & Cate that they had to move again: Kiska and his accomplices’ ongoing financial abuse meant they had to sell the bungalow at 7 Vanson that they had grown to love … just to pay the bills.
33. By 20181031, Andeé, Sean & Cate had moved into a 3-bedroom townhouse. Their living expenses tripled; however, with access to some of her savings, Andeé could continue to shield them from Kiska’s abuse as she awaited the divorce trial.
34. On December 31, 2018—despite the ongoing stalking and harassment by Kiska and his accomplices—Moore prepared, filed and served a document (“2018 Submission to Engelking) which evidenced some of Kiska’s abuse of Andeé and her children. The contents were:
    • The Cover,  Table of Contents & Executive Summary which referred to the following evidence:
    • Tab 1: Exhibit A: Dr. Iris Jackson
    • Tab 1: Exhibits B to H
    • Tab 1: Exhibits I – M (pages 1-13, 22-28 only; Cate and Sean’s assessments removed)
    • Tab 1: Exhibits N – R (which includes testimony of Kiska’s infamous statement that he would “spend his last dollar” and “go for the jugular“. What … a … freak.)
    • Tab 2: Evidence REDACTED: I had to remove the “Daddy Hit Mommy“ exhibit as it was from the CAS file (buried in 2013 by previous CAS caseworker Jessica Henry as well as Victor Vallance Blais lawyer Michéle Blais in 2015-16) as evidencing the torts and crimes committed by the CAS has been criminalized via an illegally obtained, unlawful 20220524 Probation Order (viewable by scrolling down the left hand column here).
    • Tabs 3, 4 & 5
35. At the beginning of January of 2019, Jak hand-delivered her “2018 Submission to Engelking” to the assigned CAS “case worker”, Viana Ibrahim (“Ibrahim”), and arranged for it to be scanned into the OPSB CopsLogic database.
36. Within two weeks, Andeé’s Submission and the CAS file were transferred to CAS’s Mohammed Said (“Said”) who refused to provide to Andeé any details about how he wanted to “become involved with her family”.
37. Then, on 20190201, Said and three OPSB officers illegally removed Sean & Cate from Andeé’s living room and delivered them to Kiska: they had no warrant, Sean & Cate were in no danger and the only statement made by Said was “see you in court in five days”.
38. On 20190206–merely fifteen minutes prior to the scheduled hearing with ZERO opportunity to defend herself–at the Ottawa courthouse for the second day-in-a-row (as NO ONE would provide to Jak any date, time or materials), Andeé was handed what would be the beginnings of one of the most scandalous CYFSA files possible^{4, 5}:
    • a 20190205 Protection Application,
    • Notice of Motion,
    • Affidavit of Said which was laden with errors, omissions and malicious obfuscation (“EO&MO“), 
    • Affidavit of Ibrahim which was laden with EO&MO and
    • a for-Kiska-by-Kiska Plan of Care
39. On 20190212, knowingly served on Andeé’s sweet little boy, all of their defamatory bullshit accumulated thus far:
    • xx
    • x
    • x

Ergo, they likely served all the rest of their garbage on both Sean & Cate in 2021 to get them file Criminal Charges against their mum when she was simply trying to see their pictures following over 48 months of Kiska and his accomplices unbridled, intentional cruelty. How could Sean and Cate possibly know that their dad, the CAS, the OCL and all of the judges are nothing more than pro-pedophile, pro-human trafficking, demonic-managed carcasses with zero conscience. (May God have mercy on your poisoned souls.)

50. x
51.  
52. On 2019026, the CAS went so far as to request a restraining order to the demise of Andeé, Sean & Cate for no good reason other than to appease Kiska.
53. Allegedly, on 20190314, shortly after Andeé was unlawfully re-arrested in Quebec, without any proper process and with the assistance of SCJ-positioned crooked judge Mark Shelston, the CAS changed service protocol to electronic delivery. Andeé was maliciously detained by some of Kiska et al.’s Quebec-positioned accomplices: they were simply preparing for their new 20190408 hearing date and expecting (or arranging) for Andeé to be without any materials and/or in default of the proceedings. 
54. On 20190325, Said produced a false document which stated, among other things, that:
    • Andeé’s whereabouts were unknown,
    • she was “sending inappropriate text messages to the children” and
    • she “had suicidal thoughts”.

when they were well aware that her whereabouts were known, she was not in a position to send any texts and she was not suicidal! Kiska was simply busy feeding another crooked psychiatrist, Paule Kemgni (“Kemgni”) false collateral information so he could continue to expand Andeé’s fabricated history of mental illness.

60. Kemgni detained Andeé so that on 20190408:
    • an Eviction Scam could be completed via Kiska’s other accomplices without her knowledge,
    • she would be unable to defend herself in CAS’s malicious CYFSA “hearing” and
    • a bogus NCR opinion could be crafted for Kiska’s benefit.
61. On 20190408, the Final/not-Final protection order was issued by SCJ’s Calum MacLeod (“MacLeod”) without the actual service of a single document⁵ on Andeé. They weren’t even filed for the court in time for the hearing.
62. Likely not even received or read by MacLeod, the CAS-Kiska submissions were simply an extension of the defamatory libel already served two months previously and included:
    • x
    • x
    • x
    • x
    • x
63. Despite her request, MacLeod refused any adjournment claiming that Andeé has “never filed anything”, adjournment would harm Sean & Cate and she’d have another opportunity in four months; all statements which were dominated by obvious errors, omissions and/or a malicious misstatement of the truth.
64. On 20190428, after Kiska was ensured of Jak’s eviction, loss of custody of Sean & Cate and defamatory medical opinion regarding her mental health, Jak was fully acquitted as she never committed any crime in the first place.
65. Kiska continued to torture Andeé and abuse Sean & Cate following her acquittal:
    • 20190515  Kiska mocked Andeé regarding the theft of all of her possessions and his ultimate power; 
    • 20190516  Kiska continued to violate the 20190408 by refusing to co-operate with Andeé or letting her communicate with Sean & Cate;
    • x
    • x
    • x
    • x
66. CAS, and many others, were made well aware of the never-ending abuse of Andeé and her children that Kiska enjoyed as she circulated e-mail evidence to as many as possible throughout that torturous period when:
    • Andeé attempted to restore her damaged reputation and destroyed career in the United States, 
    • Kiska denied any meaningful communication with Cate^N and all communication with Sean (while under the illegally-obtained restraining order for same),
    • Kiska refused to notify Sean & Cate of the gifts she had couriered to him and her, for Sean’s 13th birthday,
    • OCDSB administration refused to let Andeé console her daughter Cate with a gesture of flowers and
    • CAS’s Jenn Campbell obfuscation of the scheduling of any visits.
67. As evidenced by his 20190619 interview, Said stated that:
    • he knew Jak was a loving mother,
    • he did not read Jak’s 2018 Submission to Engelking and
    • he did not know what a narcissist was.
    •  
68. On 20190626, CAS’s Campbell and Kiska colluded to create a new rule that would surely cancel Jak’s long-awaited visit with Sean & Cate: she was to hand over her evidence-laden phones to security.
69. As Jak had zero reason to trust any CAS employee or Kiska, Jak offered to turn off her phones and leave them in the hallway where she could see them; however, this suggestion was refused and the visit was cruelly cancelled.
70. Kiska exclaimed to CAS’s Said/Campbell: “the only way for her to see [Sean & Cate] now is if she violates the [illegally-obtained, unlawful, child-abusing] 20190408 CYFSA Order.
71. Concerned that Kiska would be forced to revert to shared custody of Sean & Cate with their mum, he circumvented formal process, contacted the CAS and asked for “help”: within two weeks, Jak was ignored by OPSB’s Alex Kirady, charged with criminal harassment by OPSB’s Jean Benoit, prosecuted by OCA’s Mike Boyce and denied bail by OCJ’s JP Paul Harris.
72. On 2019xxxx, CAS’s Tara MacDougall stated to Kiska’s lawyer, Smith, that “[now that she’s in jail, sole custody and access should be a snap! Great job team!]“.
73. Andeé securely detained and without access to neither her evidence nor legal counsel, on 20190808^N the CAS started a new Continuing Record (“C.R.”) in order to bury the fact that the entire file against her (evidenced in the original, 15-tab Continuing Record) was based on nothing but Kiska’s self-serving, malicious hearsay—just as was Paule Kemgni‘s scandalous 20190408 NCR opinion of exactly four months previously ( 🔥by design🔥 ).
74. On 20190806, according to Calum MacLeod‘s scandalous 🔥20190408 CYFSA endorsement🔥 and Final/Not Final, illegally-obtained, unlawful 20190408 CYFSA Order, a Status Review was to occur; instead, the CAS buried the whole file with [check files re: status review vs. new “Child Protection” application]. 
75. On 20190808, the CAS served on Andeé another set of scandalous documents and then lied about the service in the new Continuing Record as evidenced by Andeé’s journal notes, OCDC records and the SCJ-filed Affidavits of Service:
    • 20190801 
    • x
    • x
    • x
    • x
76. Andeé had no choice but to respond to their materials from a jail cell with zero evidence, resources or assistance; something the demons must have enjoyed immensely given characteristics of sociopaths #25.
77. Not yet aware that the entire system was a complete racket (and fortunate to have been defrauded so much that she abandoned credit cards was arrested with a significant amount of cash, the only way to purchase canteen items), she began her mail campaign. The documents sent are viewable at 2019 Mail Campaign and Jak also recorded the recipients via a Tracking Sheet.
78. Noteworthy, among other materials, was the 20190814 54-page fax sent to both⁵ the OCA and the CAS which included document:
    • (l)  Form 33B.1 Answer
    • (m)  Overview of offences committed to obtain Calum MacLeod’s 20190408 CYFSA Order 
    • (n)  Up-to-date Summary
    • (o)  Disclosure: Gervais-Kiska Notes
    • (j) 20190812 2-page letter to Crown
    • (p)  Hand-written copy of Calum MacLeod’s unlawful 20190408 CYFSA Order
    • (q)  Smith’s post-arranged-arrest 20190806 letter to Engelking
    • (r)  Engelking’s 20190809 endorsement.
79. By YYYYMMDD, CAS began threatening to appoint the OPGT (so Andeé would be denied the right to speak in court) and the Crown had already saddled her with utterly useless Amicus Curiae John Hale: when she was released on bail 20191030 following Moiz Karimjee‘s (hopefully) career-destroying performance, she had no choice but to attempt to find counsel in order to shake both of those.
80. Immediately after Andeé was released from OCDC, Said created his next piece of fiction: his 20191031 Affidavit which was again laden with EO&MO. For example, Said stated at para. 13 that:

“Ms Moore kidnapped the children in the year 2015 after which she was admitted to the hospital for six weeks. She was admitted for the total of about 21 weeks at the Civic hospital in the Spring of 2013, the Summer of 2014 and the Fall of 2015. In the Fall of 2015, there was an amber alert issued by police when Ms Moore kidnapped the children and took them away with their belongings” vs. … reality:

• As the CAS knew, or ought to have known: Andeé fled with Sean & Cate to the safest place she knew, the Hilton Lac Lemay, and sought assistance from shelters and police to no avail. She had to return; but, when the Jekyll & Hyde Kiska re-emerged, she waited for extended family to arrive so the children would be safe and fled to the TOH for assistance.
• As the CAS knew, or ought to have known: Andeé attended the OPS station that weekend with Sean & Cate and spoke to police about Kiska’s various forms of domestic violence.
• As the CAS knew, or ought to have known (as the evidence was included in the 2018 Submission to Engelking that Andeé hand-delivered to the CAS in January 2018 as detailed at para X above): OPS’s Sebastien Paradis failed to properly investigate her allegations of sexual assault and closed the file.
• As the CAS knew, or ought to have known, Moore stayed voluntarily at the TOH for four weeks (as detailed at para. X above) and provided to the CAS consent forms so they could speak with both Chow and Kay.

Mohammed Said is a pathological liar who was working for the benefit of Kiska, not Sean nor Cate, the ENTIRE TIME HE HAD THE FILE (like everyone else there).

81. Not yet aware of the motivations of some Elizabeth Fry staff, Andeé accepted their recommendations for two lawyers. As planned, the her retention of shyster #1, Joe Addelman, immediately led to the retention of shyster #2, Gonen Snir: that fiasco remains ongoing as both are now represented by career criminals including, but not limited to, Nelligan O’Brien Payne LLP’s Craig O’Brien and Gardiner Roberts LLP’s James Cook, as well as aided by two questionable judiciary officials, Sylvia Corthorn and Marie Fortier.
82. Addelman immediately worked on Andeé to convince her to volunteer for a psychiatric assessment from crooked pyschiatrist Zeynep Selaman (for Kiska’s benefit) and Snir immediately lost a Third-party records motion (heard by just-another-crooked-judge Pamela MacEachern) that handed over all of her confidential medical files and all police files to both the CAS and Kiska.
83. Noteworthy is the fact that not a single third-party document was used in any of their court submissions as all files evidenced Kiska’s domestic violence!
84. The only one who included hospital records and police files as evidence in court submissions was Andeé; however, every single Family court judge chose to remain willfully blind to the domestic violence and child abuse; just as Criminal court’s Kevin B. Phillips did when he illegally issued an anti-Charter gag order against her on 20191108 and Jonathan Brunet did when he sentenced Sean & Cate to an additional three years without their mum.
85. On 202011xx, mistaking Cedric Nahum for an attorney ignorant of non-physical domestic violence instead of a member of Ottawa’s white-/blue-/thug-collar crime ring (the “Syndicate”), Andeé released him as so she could produce her own materials.
86. On 20201105, to keep Andeé’s duped into believing he was a legitimate lawyer looking out for her best interests, Cedric Nahum, acknowledged that “there has been mass incompetence on her file at every level“.^{6, 7}
87. Despite the actions taken on two previous occasions to lie about Andeé’s mental fortitude and resilience (ie. via the appointment of the OPGT as detailed at para. X above), Souder took no such action for hearing that was about to occur. Likely, she was already aware that Mary Fraser had been assigned to hear the matter and their “win” was imminent.
88. On 2020110X, Kiska’s lawyer Smith illegally served a Notice of Motion to piggy-back the CAS’s Summary Judgment Motion in order to get a restraining order and, once again, Andeé had no time to prepare properly to defend herself: the court simply allowed the matter to be heard. Kiska’s self-serving materials were:
    • a Notice of Motion and
    • an x-para. Affidavit laden with EO&MO (as always).
89. The CAS did not object to this Motion: with full knowledge of Kiska’s long-term abuse of Andeé, his pathological lies and co-coercive control, the CAS was (once again) a party to, among other things, obstruction of justice^N –a violation of S. XXX of the Criminal Code of Canada.
90. On 20201110, the pieces of trash at CAS supported a Summary Judgment against Jak. As well as all evidence of domestic violence from 2013-2020 already in their possession, they also IBD’d the evidence she managed to provide in advance of the hearing (despite the shenanigans of Kiska’s OCA-related accomplices Mike Boyce and Cedric Nahum described at paras. x-y above):
    • Jak’s 20201105 10:00 Confirmation of Motion where she sought a Summary Judgement against Kiska and much, much more,
    • Jak’s 20201105 Factum (13 pages) with 3 exhibits A to C
    • Jak’s 20201105 Affidavit #1 (9 pages) which referred to 22 exhibits A to V:
      • A – 
      • B – 
      • C – 
      • D – 
      • E –
      • F –
      • G –
      • H – 
      • I – 
      • J – 
      • K – 
      • L – 
      • M – 
      • N – 
      • O – 
      • P – 
      • Q – 
      • R – 
      • S – 
      • T – 
      • U – 
      • V – 
    • Jak’s 20201106 Affidavit #2 (1 page) with 8 exhibits A to H
      • A – 
      • B – 
      • C – 
      • D – 
      • E –
      • F –
      • G –
      • H
    • x
    • x
    • x
    • x 

C.  20201110 SUMMARY JUDGMENT MOTION: GIVE SEAN & CATE TO THE ABUSER

91. On 20201110, the CAS proceeded to argue its position which was supported by nothing but hearsay, defamation and false allegations bundled as multiple legal documents:
    • x
    • x
    • x
    • x
    • x
    • x
92. x
93.  
94. It is fair to assume that Kiska and/or his accomplices compensated SCJ’s Justice Mary Fraser for her decision that stated, among other things, that there were no triable issues: hopefully this skank can share a cell with former CAS-employee, Tracy Engelking, who IBD’d volumes of evidence in the divorce file FC-15-2446 and to schedule the event on 20200828 in the first place.
95. On 2021xxxx, the pieces of trash opposed Jak’s Appeal despite being in possession of undeniable evidence of years of severe domestic violence and child abuse.
96. In addition to the standard materials required for Jak’s Appeal to be heard (ie. all materials included at paras. x-y above), the X, Y and Z, she also brought a Motion to Adduce Fresh Evidence which included:
    • insert the five affidavits and exhibits from https://twb.rocks/organized-crime/vis/three-stooges-1
97. The responding materials from the CAS? Scandalous. They included:
    • x
    • x
    • x
    • x
98. Note that OCL “agent” Susan Galarneau submissions were just as scandalous and she is being sued in a separate action for her involvement in child abuse and her Breach of Fiduciary Duty in a separate action viewable (in due course) at https://twb.rocks/organized-crime/vis/susan-galarneau.
99. On 20201110, the CAS proceeded to argue its position despite being in possession of evidence to the contrary including, but not limited to, that which was served as detailed at para. X above.
100.  
101. In summary, despite having a mountain of evidence of Kiska’s long-term abuse of her and her children, Jak lost both the Summary Judgment Motion and her Appeal against the CAS. The reason? A mental illness that she does not have.
102. The CAS, OCL and Kiska false testimony and misleading and/or fabricated evidence was so defamatory that SCJ’s Divisional court panel stated in their decision at para. [xxx]

D.  2021MMDD CAS APPEAL: THE DELIVERY OF BEYOND A REASONABLE DOUBT

101.  Insert introduction:
     • x
     • x
     • x
     • x
     • x
     • x
102. Furthermore, the CAS permitted Kiska’s Motion (to obtain a restraining order against her) to be illegally heard: Kiska’s self-serving materials simply piggybacked the CAS hearing and, as the materials were served without any respect for the Rules, Jak was again denied the right to fully defend herself against Kiska’s:
     • Notice of Motion and
     • Affidavit even though they were illegally served, filed and laden with EO&MO (as always).
103.  
104. It is fair to assume that Kiska and/or his accomplices compensated SCJ’s Justice Mary Fraser for her decision that stated, among other things, that there were no triable issues: hopefully this skank can share a cell with former CAS-employee, Tracy Engelking, who IBD’d volumes of evidence in the divorce file FC-15-2446 and to schedule the event on 20200828 in the first place.
105. On 2021xxxx, the pieces of trash opposed Jak’s Appeal despite being in possession of undeniable evidence of years of severe domestic violence and child abuse.
106. In addition to the standard materials required for Jak’s Appeal to be heard (ie. all materials included at paras. x-y above), the X, Y and Z, she also brought a Motion to Adduce Fresh Evidence which included:
     • insert the five affidavits and exhibits from https://twb.rocks/organized-crime/vis/three-stooges-1
107. The responding materials from the CAS? Scandalous. They included:
     • x
     • x
     • x
     • x
108. Note that OCL “agent” Susan Galarneau‘s submissions were just as scandalous and she is being sued in a separate action for her involvement in child abuse and her Breach of Fiduciary Duty in a separate action, as is her counter-part Patric Senson via an action against Ontario’s Ministry of the Attorney General.
109. In summary, despite having a mountain of evidence of Kiska’s long-term abuse of her and her children, Jak lost both the Summary Judgment Motion and her Appeal against the CAS. The reason? A mental illness that she does not have.
110. The CAS, OCL and Kiska false testimony and misleading and/or fabricated evidence was so defamatory that SCJ’s Divisional court panel stated in their decision at para. [xxx]

AT PARA. [    ] “In her pursuit of access to justice, she is impeded by her mental illness and a costs award against an impecunious, homeless and impeded litigant is not in the interests of justice and would just be cold-hearted, meaningless, and just mean.”

so that Kiska could let Sean & Cate read that defamatory libel too. Likely, sealing in their minds that their mum was truly lost and accomplishing the 100% child alienation that Kiska—as the malignant, narcissist (aka “narcopath“) that he is and has been from day 1—so desired.

 

E.  UNLIMITED DAMAGES, IRREPARABLE HARM

100. Although Kiska’s OCA-positioned accomplices dropped most of its 14 bogus charges after Jak illegally lost custody of Sean & Cate, she remains saddled with an illegally-obtained, child-abusing, anti-Charter, three-year Probation Order…which never would have existed but for the CAS’s long-term, self-serving, incompetent and/or criminal handling of a mother’s child protection file.
101. As Kiska’s multi-faceted abuse continues to this day–while Jak’s mental fortitude evidences that she never suffered from any chronic illness in the first place, CAS’s inability to assist children in cases of non-physical domestic violence is beyond any reasonable doubt.
102. But for the negligent, defamatory, fraudulent, malicious, tortious and/or criminal behaviour of the CAS, Sean and Cate would not have been deprived from Moore’s protection of Kiska for nearly five years.
103. The CAS could have attempted to put an end to Moore and her children’s suffering by, at the latest, December 2018; instead, they chose to prolong it … into perpetuity.
104. Moore has been fully alienated from her two children and, even worse, Sean and Cate have sustained the irreparable harm that is associated with not only parental alienation but child alienation.
105. Due to the actions and inactions of the CAS (e.g. aiding and abetting multiple perpetrators involved in the demise of Moore and her children) between November 2019-August 2020, Moore has also endured:
     1. near-homelessness,
     2. below-poverty-level zero income,
     3. depletion of personal and corporate savings to zero,
     4. multiple unnecessary arrests and
     5. humiliation, demonization, ostracization, unemployability which continues to this day.
106. To further mock Moore, … the CAS’s “client”, aka Kiska, no longer even bothers to respond to requests to communicate with Sean and Cate: see notes under “Status of court-enabled Legal Quagmire & Other items” https://twb.rocks/ontario-works.
107.  
108. Moore has:
     1. …
     2. … and
     3. ….
109. She has …:
     1. torture,
     2. death,
     3. apprehension under a Mental Health Act,
     4. further unlawful incarceration and
     5. escalated fraud designed to force her into poverty, homelessness and despair.
110. ….
111.  
112. CHECK TESTS  …. ENSURE DAMAGES SOUGHT DO NOT entirely DUPLICATE KISKA’S re 201801 Amended Answer
113. SEND TO OPSB and ASK IF THEY ARE GOING TO WITHDRAW THEIR VEXATIOUS APPLICATION
114. COMPLETE ACTION AGAINST GALARNEAU
115. SEND TO OPSB and ASK IF THEY ARE GOING TO WITHDRAW THEIR VEXATIOUS APPLICATION
116. COMPLETE ACTION AGAINST MAG
117. SEND TO OPSB and ASK IF THEY ARE GOING TO WITHDRAW THEIR VEXATIOUS APPLICATION
118.  
119. On 20231019, CAS agent-come-employee Brian Fisher stated he would “vigorously defend” his group of court-enabled terrorists against this Civil Action: it is Jak’s hope that:
     • her action is successful,
     • the CAS is bankrupted and
     • all CAS-related perpetrators are denied bail, refused any plea deal and forced to pay for their own 20-year incarcerations.
120. One can only imagine how many other children this entity has destroyed as it IBD’d evidence of domestic violence and ripped the safe, devoted parent from the lives of her vulnerable children.
121. The likelihood that the CAS are members of Ottawa’s crime syndicate—as described at www.pfi.rocks/organized-crime/swimlanes—is highly probable and Ottawa’s Human Targeting/Human Trafficking Syndicate has had enough rope to hang itself.
122. Hopefully, this pleading is not “prolix” and does not offend the “principal of proportionality” as noted at paragraph 29 by Madam Justice D. Summers in her Honour’s 20171116 decision (see Kiska v. Moore 2017 ONSC 6872 (CanLII)) which permits Jak to seek multiple damages from Kiska for violations of both Civil Law and the Criminal Code of Canada in a … FAMILY … COURT … SETTING should the court-positioned members of the Syndicate ever permit her to schedule a divorce trial (see Let’s Support our Victims).
123. At time of writing, they have made no attempt to mitigate the impact of this action on their enterprise: they must be hoping for another crooked judge.

Endnotes

¹ From 2013 to 2021, the CAS’s collective IBD evolved from, arguably, willful blindness to negligence to malice to crimes including, but not limited to, violations of:

• S. 300 Defamatory Libel,
• S. 366 Forgery/Making False Document (directly and indirectly via S. 21(1) and/or S. 23(1)),
• S. 134 Giving A False Sworn Statement,
• S.  26(1) Disobey a Statute,
• S. 139(3) Offence of Obstructing Justice
• S. 269.1 Torture,
• S. 279.01 Human Trafficking,
• S. 83.19 Facilitating Terrorist Activity,
• S. 380(1)(a) Fraud against the Province of Ontario and/or its taxpayers; and,
• via S. 21(1) Parties to Offence and/or S. 23(1) Accessory After the Fact, S. 380(1)(a) Fraud against Andeé Jak      

² Lying to psychiatrists is also referred to as psychiatric abuse. It is also considered to be a form of psychological abuse known as “gaslighting” (ie. according to psychologist Dr. Iris Jackson (see para. X, page Y))    

³ How the psychiatric industry justifies labelling an abuse-induced psychotic break as any mental illness is beyond comprehension and says more about the motivations of taxpayer-funded, for-profit hospitals than it does the mental stability of its revenue-generating patients.      

⁴ See work-in-progress Continuing Record vs. CAS unredacted records and note that “custody and access” is supposed to be the jurisdiction of Canada’s federal Divorce Act which was totally circumvented by multiple pieces of [violated] provincial legislation; and, note that as of 20231028, Jak is still married to Kiska. Nothing but radio silence from Kiska’s accomplices at Bell Baker LLP and Family Court.

^N Andeé received only one call, ever: heavily supervised, Cate called to cry “Arent’ you even going to come to my graduation!!!” having no idea that her mum would be arrested if she tried. Then, she was forced to end the call. There is zero limit to Kiska’s cruelty.

^N They claim this was created 20190806; however, that’s impossible (or, illegal) as Andeé wasn’t served the documents until 20190808 as should be accurately recorded at the Ottawa-Carleton Detention Centre (“OCDC”) and consistent with Andeé’s own records for 20190808.

⁵ The fax confirmations are here.

⁶ Sadly, the “mass incompetence” extended to Nahum himself and he had to eventually be released and reported as a member of this crime syndicate as well; his comment to Savage being more of a “Great job!” than a “Shame on you”.

⁷ Note that Kiska was served the documents the night before on 20190205.  

⁷ When she realized that Nahum was also ruining her appeal, she released him again. She finally removed him from her criminal matters in YYYYMMDD. and included him in her 20210125 Small Claim SC-21-158306 following the orchestrated breach attempt that involved his law firm, the OCA and Ottawa courthouse staff. 

⁸ Note the date of filing on the Affidavit of Service as well as Calum MacLeod’s refusal to adjourn the hearing despite CAS’s total disregard for the Courts of Justice Act’s Rules of Civil Procedure.  

⁹ x      

^N Dr. Paule Kemgni, Dr. Zeynep Selaman, Dr. Benoit Dassylva

^N Shyster Joe Addelman & Craig O’Brien; Shyster Gonen Snir & Gardiner Roberts;

^N Insert other notes

^N Insert list of other crime to which CAS is a party & tie to para [87-ish]

October 31, 2023 (began 20231016 & last updated 20231029 at 10:16)

Deirdre Moore, (insert address) (613) 848-6832