Filed/Served (pdf) Fresh A-A Statement of Claim                                 CV-22-00089804-0000

Filed/Served Fresh Claim – online version with some links to evidence

Books of Documents: #1   #2   #3   #4                    



b e t w e e n


Deirdre Moore   (plaintiff)


Addelman Baum Gilbert Robinson LLP   (defendant)

Snir Law Office   (defendant)


pdf version – REDACTED

(link to court-enabled fraud as this Civil Action progresses) (link to evidence that OPSB is aware of this file)


My name is Deirdre Ann Moore, I live in Paradise, Newfoundland and Labrador (“NL”) and I swear that the following is true:


  1. Following years of severe domestic violence of all forms that did not leave any visible bruises, in 2019 the plaintiff (“Moore”) agreed to the placement of a $250,000 lien on her $1,000,000+ matrimonial home in order to retain the defendants (“Addelman” and “Snir”) in good faith.
  2. She did not, however, “agree” with the additional “extra fee” of $60,000 that was slipped into the retainer agreement (see para. 10 of 20191114 retainer agreement at page 3 of Exhibit A) before she arrived to sign it vs. the verbal arrangement that was made and confirmed by Snir (see page 1 of Exhibit A) and note that no retainer agreement was ever signed with Addelman.
  3. Moore signed the agreeement, despite her hesitations, due to the fervour with which she was being terrorized by multiple career criminals; partially described below.
  4. Moore believed that Addelman and Snir would protect the interests of her and her two children, Sean and Cate Kiska (“son, Sean, and daughter, Cate”), as she continued to endure the never-ending, court-enabled, retaliatory maneuvres of estranged spouse, John Kiska (“Kiska”) who had effectively weaponized:
    1. the Children’s Aid Society of Ottawa (“CAS”),
    2. the Office of the Children’s Lawyer (“OCL”),
    3. the Ottawa Police Services Board (“OPSB”),
    4. Ottawa’s Crown Attorney’s Office (“OCA”),
    5. the Ontario Court of Justice (Criminal Division) (“OCJ”) and
    6. the Superior Court of Justice (Family court) (“SCJ”)

as well as multiple accomplices operating as lawyers and legal assistants within the firms of Bell Baker LLP (“BellBaker”), Victor Vallance Blais LLP (“VVB”) and Nelligan Payne O’Brien (“O’Brien”, who had referred Moore to BellBaker’s co-accomplice VVB in November 2015).

  1. Addelman and Snir were well aware that:
    1. in 2017, Moore had received permission to seek damages for the multiple torts and crimes committed by Kiska (see excerpt from 20080108 Amended Answer at Exhibit B) in a family court setting.
    2. in 2018—following an extensive investigation which included the interviewing of all medical professionals involved in Kiska’s malicious mental health allegations—the OCL recommended that Moore receive sole custody of her son, Sean, and her daughter, Cate (see excerpt from 20180711 OCL report at Exhibit C) and
    3. Moore had publicized this novel approach to seek damages from an abusive spouse (noted at 5 a. above—which would have eliminated the need for civil litigation and a criminal conviction when seeking protection and justice via Canada’s Divorce Act (“Divorce Act”))—see Ottawa Citizen-published 20180825 Letter to the Editor at Exhibit D).
  1. Instead of serving the best interests of Moore (and her son, Sean, and her daughter, Cate), Addelman and Snir assisted:
    1. Kiska,
    2. taxpayer-funded, for-profit CAS and other
    3. other taxpayer-funded Syndicate members operating through, for example:
      1. the OPSB
      2. the OCA and
      3. the OCJ/SCJ

via multiple forms of deceit and negligent representation including, but not limited to, the crimes of Defamatory Libel, Conspiracy to Prosecute, Extortion and multiple crimes related to Obstruction of Justice.

  1. As a result, Moore remained (and remains): 
    1. Snir refused to bring a Motion to have her fraudulently-obtained, unlawful, below-poverty-level, measly spousal support of $1,230/month amended to the amount to which she was legally entitled (see 20191126 e-mail to both Snir and Addelman with attached:
      1. Notice of Motion and
      2. ii. 20191127 Commissioned Affidavit with 17 exhibits at Exhibit E, merely one of Moore’s multiple requests (see links to related exhibits A-Q provided in attached tables).
    1. criminalized—Addelman refused to acknowledge, among other things:
      1. the specifics of the illegally-obtained, unlawful, Child, Youth and Family Services Act (“CYFSA”) 20190408 court order of which Moore had been accused of violating while both Kiska and the CAS had been in contempt of same order for five months at time of arrest (see copy of CYFSA order where Moore and Kiska were ordered to communicate for the benefit of her son, Sean, and her daughter, Cate,  at Exhibit F),
      2. that Moore co-owned the home of which she was accused of Break and Enter when she stole nothing, had zero criminal intent and attended the home for lawful purposes; in particular, to attempt to end Kiska’s abuse of her son, Sean, and her daughter, Cate, who had been told their mum had abandoned them. (see copy of deed, MPAC statement and mortgage statement at Exhibit G) and
      3. that the two charges of Mishief required zero defense as they were permitted pursuant to Section 430(7) of the Criminal Code of Canada (“CCC”)

(See copy of 20191030 SCJ Release Order at Exhibit H, letter from subsequent defense attorney regarding the validity of the OCA’s charges at Exhibit I and eventual extorted, child-abusing, torturous 20220524 Probation Order at Exhibit J.)

  1. Addelman and Snir were merely posing as legitimate legal counsel when, in fact, they were merely part of Ottawa’s network of taxpayer-funded organized crime. (See over-simplified illustration of this network at Exhibit K and more details by scrolling through various portions of Moore’s corporate whistle-blowing/advocacy site: www.pfi.ROCKS).
  2. Now that the so-called “child protection” matter has illegally and unlawfully “concluded”—via:
      1. three, SCJ-stationed crooked lawyers operating under the guise of judges sitting in Divisional court (see excerpt from scandalous 20211220 appeal decision at Exhibit L in tandem with the mountain of evidence they had at their disposal (stored in Dropbox account:[redacted] and
      2. that multiple, career-criminal lawyers that represented Kiska, the CAS and the OCL

—Moore is finally in a position to re-initiate the divorce proceedings and attempt to rescue her children—over four years later—via the protections provided by Canada’s Divorce Act which require the judge to consider domestic violence—including, but not limited to, financial abuse and psychological abuse—when determining parenting time and decision making (see excerpt at Exhibit M).

  1. In other words, Kiska’s ability to circumvent the Divorce Act by exploiting CYFSA, the CCC and the multiple career criminals that have infiltrated multiple aspects of the law enforcement/legal/judicial system has run its course: Moore literally could not have more evidence of Kiska’s wickedness (see recent examples described in NL police complaint #1 re: court-enabled (Family) Fraud at Exhibit N and NL Police Complaint #1 and NL police complaint #2 re: court-enabled (Civil) Fraud at Exhibit O and NL Police Complaint #2).


  1. Moore would like to be in a position to retain a legitimate family law lawyer and defence attorney so that she can: 
    1. bring an Application to have her scandalous, extorted, 20220524 Probation Order revoked, rescue her son, Sean, and her daughter, Cate, from Kiska’s years of psychological and emotional abuse,
    2. receive the hundreds of thousands of dollars in retroactive financial support and occupational rent owed to her since 2016 (see Exhibit P) so she can once again be in a position to provide for them a warm, safe and loving home such as the one that was emptied without her knowledge (see partial evidence of eviction scam at Exhibit Q and work-in-progress Victim Impact Statement re: SCJ-operating Ryan Bell) while Moore was falsely accused and detained from March to April 2019 (see never-ending civil action, cost awards, evidence and allegations at Exhibit R and partial evidence at work-in-progress Victim Impact Statement re: McCarthy Tétrault-employed Céleste Perrault-Lévesque) and and
    3. finally divorce Kiska after over 10 years of taxpayer-funded, system-enabled torture.
  1. The current lien of $250,000 (see Exhibit S) against Moore’s portion of her $1,000,000+ matrimonial home is ridiculously excessive for multiple reasons including, but not limited to: 
    1. Addelman’s, at a minimum, negligent performance (partially described above),
    2. Addelman’s failure to issue any invoice for said performance despite his release early in 2020. (Note that Moore was not aware that Addelman was colluding with the OCA for Kiska’s benefit—vs. plain incompetence—until she received the bogus 20200505 “Not Criminally Responsible” opinion (see Exhibit T and partial Errors, Omissions and Malicious Obfuscation Analysis at from OCA-postioned Malcolm Savage following her re-arrest in September 2020.
    3. Snir’s, at a minimum, negligent performance (partially noted above),
    4. Snir’s scandalous 20221228 invoice given:
      1. over 2/3 of it was due to his self-triggering of his unlawful, extorted, “required” $60,000 payment when he illegally and unlawfully removed himself from Moore’s divorce and CAS files via a temporary Order in Family Court (instead of via a Rule 15.04, Rules of Civil Procedure (“Rules”) of the Courts of Justice Act (“CJA”) ) as evidenced by:
        • 20200522 14B Motion Form at Exhibit U,
        • 20200522 Affidavit at Exhibit V with nine exhibits; all improperly commissioned and, therefore, not only defamatory but perjurious and inadmissable) and
        • 20200821 Affidavit at Exhibit W with another nine exhibits; all improperly commissioned and, therefore, also defamatory and perjurious)
      1. ———-
      2. the transcript from the hearing which evidenced that he orally stated that his believer that “[there was nothing wrong with my mental fortitude]” vs. his Motion materials (see Exhibit T) and
      3. the 20200827 endorsement of SCJ-employed judge Marc E. Smith (see Exhibit U) which ordered Snir’s removal from Moore’s files—without addressing the exorbitant fee that would be triggered or the $250,000 lien that would remain, as requested (see Moore’s responding Affidavit at Exhibit V and her Factum at Exhibit W).
  1. Due to continued fraudulent/criminal activities by Kiska and his many accomplices: 
    1. Moore has once again been forced to receive social assistance (see Exhibit X) while Kiska continues to:
      1. reside in Moore’s matrimonial home,
      2. drive his Volvo,
      3. wear Hugo Boss,
      4. earn (likely) $200,000-300,000/year as he has since 2015,
      5. fully gaslight her son, Sean, and her daughter, Cate, and completely “ghost” Moore so he can more easily convert them to a future with “a new mom” (see Exhibit Y)—likely one with a government pension—and
      6. pay zero dollars of his court-ordered spousal support.







[1] Interestingly, Nelligan Payne O’Brien LLP was the firm that recommended Moore retain nightmare-of-a-firm Victor Vallance Blais LLP to assist with her divorce in 2015. Why could they not represent Moore? They had represented Kiska in the past for an employment-related matter. Why did they not represent Kiska? They were the back-up firm for when Bell Baker LLP was going to be sued (details available upon request).

In 2015, Nelligan continued to look out for Kiska by sending Moore to Michéle Blais whose firm colluded with Kiska’s Bell Baker LLP accomplices who continue to commit crime with reckless abandon to this day.

(What. A. Racket.) Ottawa is nothing but organized crime, taxpayer-funded fraud, human trafficking, court-enabled torture and domestic terrorism.

[2] Note how Gomery awarded Blais $7,500 in costs though aware that the entire Motion was illegal! It was not brought promptly as prescribed in the CJA (see pages 2 and 5 of Appendix V); another violation of CCC’s S. 126 by the SCJ.


1 Dr. Paule Kemgni

2Filed/Served pdfs Original Statement of Claim | Amended Statement of Claim | Fresh A-A Statement of Claim           

PS. Shyster, Shyster, please come out; ’cause we have beyond a doubt. Too bad you were born so dim. Hugs & Kisses, your Goyim. Good Luck, Gonen!

    Deirdre Moore, Paradise, NL

May 24, 2023