Filed/Served: Fresh 202302xx pdf A-A Statement of Claim (& online version with links to evidence of allegations) CV-22-89804
Snir‘s 202302xx Statement of Defense: Statement of Defense (& my EOMO Analysis) || Addelman’s 20230320 Statement of Defense (& my EOMO Analysis)
My 20230628 Combined Reply (& my two, now-required, separate 20230629 versions re: Snir and Addelman) || Follow 20230801 Motion for Extension
Addelman’s 20230608 Motion to Set Aside Default || Back to intro: Craig O’Brien (& a fun limerick!) || work-in-progress > Books of Documents: #1 #2 #3 #4
(back to w-i-p court-enabled fraud as this Civil Action progresses)
ONTARIO
20230629 Notice of Motion
pdf version
b e t w e e n
Deirdre Moore (plaintiff)
and
Addelman Baum Gilbert Robinson LLP (defendant)
Snir Law Office (defendant)
| Statement | Related documents, evidence | Co-accomplice(s) | ||
|---|---|---|---|---|
| The Plaintiff, Deirdre Moore (“Moore”), will make a motion to the court on August 1, 2023 at 11:30 a.m.; or, as soon as the motion can be heard, at 161 Elgin Street, Ottawa, Ontario.
PROPOSED METHOD OF HEARING: The Plaintiff proposes that the motion be heard by videoconference. |
||||
| THIS MOTION IS FOR: | ||||
| a) | AN ORDER THAT the court provide leave to Moore to serve and file her Reply to the Statement of Defense filed by Snir Law Office (“Snir”) | The Reply pdf for Snir is here & the Reply for Addelman is here. The online version of COMBINED REPLY (with links to evidence) that was rejected by Snir is here. | ||
| b) | AN ORDER FOR COSTS of this Motion on a full indemnity basis (I only charge $125/hour; but, despite winning several motions over the years, I only the perpetrator ever gets awarded costs; even the precedent-setting motion that I won in 2017) and | (Funny, that decision was made by Justice Darlene Summers & Bell Baker LLP‘s managing partner is Jonathan Summers. Go figure.) | ||
| c) | Any other order that this court deems fair and just (in its limited capacity as the entire operation is run by conscience-free sociopaths &/or compromised individuals). | See work-in-progress Ottawa Swimlanes to get a taste of how the capital of Canada operates. Also, see Jack Pendergrass’s work regarding the cesspool that Ottawa reports to by viewing The Crown Corporation and related links. | ||
| THE GROUNDS FOR THE MOTION ARE: | ||||
| a) | Moore’s Reply would not have been required but for the severity of the errors, omissions and malicious obfuscation contained in the defendants’ statements of defense; | See EO&MO Analysis on Statements of Defense with links to evidence by scrolling down to Affidavit #2, Exhibits B and D here. | ||
| b) | Moore’s Reply was obfuscated by multiple events including, but not limited to:
|
i. See NL Police Complaint #1 re Fraud: https://twb.rocks/organized-crime/20230221_police-complaint_crime-in-progress_court-enabled-fraud ii. See work-in-progress OPSB Application to have me declared vexatious https://twb.rocks/organized-crime/vis/michelle-doody despite having TONS of evidence of the Ottawa Syndicate: iii. See another crooked psychiatrist https://twb.rocks/organized-crime/vis/paule-kemgni and another set of crooked lawyers at: https://twb.rocks/organized-crime/vis/celeste-perrault-levesque iv. See additional billing suddenly pursued by another set of lawyers here. v. See Addelman delay/obfuscation/fee ramping tactics at https://twb.rocks/organized-crime/vis/craig-obrien/20230608-motion_joe-addelman_gonen-snir_deirdre-moore |
||
| c) | the service and filing of Moore’s Reply is more efficient than would be her service and filing of another amended Statement of Claim which would simply permit the defendants to pad their statements of defense with even more errors, omissions and malicious obfuscation in an attempt to avoid liability for damages caused; | Presumption made due to grounds discussed at a) above. | ||
| d) | Moore would be further prejudiced by another delay in proceedings; | See letter of rejection from NL Social Services and letter from NL Emergency Women’s Shelter. | ||
| e) | it is in the publics interest that the matter move on to the Discovery Process in order to restore some level of confidence in the “playground for sociopaths” that the Ottawa courthouse has become and/or | See projects by Jeff Fenton (#ExposeYourJudge), Sharon Zehr (#SqueelOnYourPig), Jack Pendergrass (#MaximusStink) and others raising awareness on international taxpayer-funded crime listed here: https://twb.rocks/organized-crime/maximus | ||
| f) | pursuant to Courts of Justice Act (“CJA”) Rules of Civil Procedure (“Rules”):
|
as stated | ||
| THE FOLLOWING DOCUMENTARY EVIDENCE will be used at the hearing of this motion: | ||||
| a) | Moore’s Affidavit(s) to be drafted for this Motion, | See Affidavit #1 and (reply) Affidavit #2 | ||
| b) | Moore’s Factum to be drafted for this Motion and | See Factum | ||
| c) | Such further and other documents as the Plaintiff may advise and the Court may permit. | (Everyone adds this phrase; but, in my experience, judges only let the crooked lawyers add “such further and other documents”. Like, the time Sally Gomery permitted Susanne Sviergula to tally up the torts with which I accused both Michéle Blais and John Kiska (because they were colluding with the help of Wade Smith and some bogus mediator who’s name escapes me at the moment, so they could be effectively ?removed from my claim? Who knows. The (jam-packed with MAG employees and Ottawa-based lawyers) Ottawa Courthouse should have a barbwire fence placed around it as soon as possible.) | ||
| Deirdre Moore 29-JUN-23 |
