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

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

ONTARIO

SUPERIOR COURT OF JUSTICE

b e t w e e n

 

Deirdre Moore   (plaintiff)

and

Addelman Baum Gilbert Robinson LLP   (defendant)

Snir Law Office   (defendant)

 

Fresh AMENDED AMENDED STATEMENT OF CLAIM for $3.5M plus costs

(link to court-enabled fraud as this Civil Action progresses)

 

TO THE DEFENDANTS

     A LEGAL PROCEEDING HAS BEEN COMMENCED AGAINST YOU by the plaintiff.  The claim made against you is set out in the following pages.

     IF YOU WISH TO DEFEND THIS PROCEEDING, you or an Ontario lawyer acting for you must prepare a statement of defence in Form 18A prescribed by the Rules of Civil Procedure, serve it on the plaintiff’s lawyer or, where the plaintiff does not have a lawyer, serve it on the plaintiff, and file it, with proof of service in this court office, WITHIN TWENTY DAYS after this statement of claim is served on you, if you are served in Ontario.

     If you are served in another province or territory of Canada or in the United States of America, the period for serving and filing your statement of defence is forty days.  If you are served outside Canada and the United States of America, the period is sixty days.

     Instead of serving and filing a statement of defence, you may serve and file a notice of intent to defend in Form 18B prescribed by the Rules of Civil Procedure.  This will entitle you to ten more days within which to serve and file your statement of defence.

     IF YOU FAIL TO DEFEND THIS PROCEEDING, JUDGMENT MAY BE GIVEN AGAINST YOU IN YOUR ABSENCE AND WITHOUT FURTHER NOTICE TO YOU.  IF YOU WISH TO DEFEND THIS PROCEEDING BUT ARE UNABLE TO PAY LEGAL FEES, LEGAL AID MAY BE AVAILABLE TO YOU BY CONTACTING A LOCAL LEGAL AID OFFICE.

     IF YOU PAY THE PLAINTIFF’S CLAIM, and $500.00 for costs, within the time for serving and filing your statement of defence you may move to have this proceeding dismissed by the court.  If you believe the amount claimed for costs is excessive, you may pay the plaintiff’s claim and $400 for costs and have the costs assessed by the court.

TAKE NOTICE: THIS ACTION WILL AUTOMATICALLY BE DISMISSED if it has not been set down for trial or terminated by any means within five years after the action was commenced unless otherwise ordered by the court.

 

Date …..July 29, 2022………………          Issued by   ………illegible signature……………………

                                                                                                          Local registrar

                                                                      Address of      ….161 Elgin Street………………………

                                                                      Court Office   ….Ottawa Courthouse…………………                                                                                                           

TO               Snir Law Office, 800-85 Albert Street, Ottawa, Ontario  K1P 6A4

AND TO     Addelman Baum Gilbert Robinson LLP, 800-85 Albert Street, Ottawa, Ontario  K1P 6A4

CLAIM

  1. The plaintiff claims:
    • Pecuniary damages from Gonen Snir Office (“Snir”) $1,750,000 due to its breach of fiduciary duty, defamation, intentional infliction of emotional suffering, negligent infliction of emotional suffering and/or malice.
    • Pecuniary damages from Addelman Baum Gilbert Robinson LLP (“Addelman”) $1,750,000 due to its breach of fiduciary duty, intentional infliction of emotional suffering, negligent infliction of emotional suffering and/or malice.
    • Other damages that the Court deems to be fair and just.
    • Costs on a full-indemnity basis.

BACKGROUND

  1. On July 11, 2018—following years of verbal, emotional, psychological, psychiatric, sexual and/or financial abuse by Jonathan Kiska (“Kiska”) against multiple members of his family— Ontario’s Office of the Children’s Lawyer did a four-month investigation and produced a report that stated Deirdre Moore (“Moore”) should have sole custody of Sean Kiska and Cate Kiska (“the children”) (see Discovery Document 001 and 002).
  2. Shortly thereafter, Kiska communicated with Moore’s parents that he would be “going for the jugular” and “spend[ing] his last dollar” in order to destroy Moore during their divorce (see Discovery Document 003).
  3. 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 Moore and her children (see Discovery Document 004).
  4. In January 2019, the CAS case manager was changed from Viana Ibrahim (“Ibrahim”)—who had been sympathetic to Moore’s situation—to Mohammed Said (“Said”).
  5. By February 1, 2019, Kiska colluded with the Children’s Aid Society of Ottawa (“CAS”) in order to have the children illegally removed from her home (see Discovery Document 005).
  6. By April 8, 2019, Kiska and his many accomplices1 had succeeded in illegally:
    1. obtaining an unlawful “final” custody and access order as well as a restraining order (both via the Child, Youth and Family Services Act (“CYFSA”)) against Moore (see Discovery Document 006),
    2. emptying her and her children’s three-bedroom home (see Discovery Document 007) and
    3. obtaining a Not Criminally Responsible “NCR” opinion against Moore for a crime that she never committed—Flight from Peace Officer (see Discovery Document 008).
  7. On July 15, 2019, Kiska contacted CAS Executive Director Kelly Raymond (“Raymond”) asking for assistance in how he could ensure Moore remained ripped from her children’s lives (see Discovery Document 009).
  8. On July 26, 2019, Kiska lied to the Daniel Gervais (“Gervais”) of the Ottawa Police Services Board (“OPSB”) in order to orchestrate Moore’s arrest and detention—Kiska wanted to ensure, among other things, that their scheduled divorce would be cancelled and he would obtain sole custody and access of the children.
  9. At that time, Kiska alleged that Moore was schizophrenic and that he feared for the life of himself and the children: both statements were demonstrably false (see Discovery Document 010).
  10. Coincidentally, Moore attended the matrimonial home on that same day in an attempt to tell the children the truth about that which their father had done to them.
  11. She had had enough of both Kiska and the CAS being in contempt of the illegally-obtained, unlawful 20190408 CYFSA court order (see paragraph 7 a. above) and their collusive emotional and psychological abuse of the children.
  12. That day—July 26, 2019—Moore was arrested and interviewed by OPSB employee Alex Kirady (“Kirady”) who ignored:
    1. her verbal testimony (see Discovery Document 011),
    2. her 2018 Submission to Engelking that had been scanned into CopLogic earlier that year (see Discovery Document 012) and
    3. the evidence of taxpayer-funded domestic violence and child abuse that she had brought with her in case of arrest (see Discovery Document 013).
  13. Then, Kirady:
    1. lied in his police report (see Discovery Document 014) and
    2. charged Moore with Disobey a court order, Unlawfully in dwelling and Mischief (see Discovery Document 014).
  14. On July 27, 2019, OPSB employee Jean Benoit (“Benoit”) “self-assigned” to the file in order to add uninvestigated criminal harassment to Moore’s charges (see Discovery Document 015)
  15. Later that day, Crown prosecutor Mike Boyce (“Boyce”) committed perjury and defamed Moore in order to seek the anti-Charter of Rights and Freedoms (“anti-Charter”) detention of her (see Discovery Document 016).
  16. Despite Moore’s submissions, Justice of the Peace Paul Harris (“Harris”) denied her bail and also granted a child-abusing, non-communication order (“20190727 Non-comm Order) to ensure the children would not be able to learn the truth about Kiska (see Discovery Document 017)
  17. Moore spent the next 90 days in various correctional facilities being further tormented by multiple Crown prosecutors and judges including, but not limited to:
    1. Prosecutor John Ramsay (“Ramsay”) (eg. extortion (see Discovery Document 018)
    2. Prosecutor Malcolm Savage (“Savage”) (eg. obstruction of justice (see Discovery Document 019) and
    3. Justice Julie Audet (“Audet”) (fraud, domestic terrorism (see Discovery Document 020).
  18. On October 30, 2019, following hours of argument between Crown prosecutor Moiz Karimjee (“Karimjee”) and court-appointed Amicus Curiae John Hale (“Hale”), Moore was released on bail but forced to live in The Elizabeth Fry Society’s bail house, the Lotus House (“Lotus House”) under the “supervision” of John Howard Society (“JHS”) (see Discovery Documents 021 and 022)
  19. Moore was referred to Addelman by Lotus House in November 2019.
  20. Moore was referred to Snir by Addelman in November 2019.
  21. Both Addelman and Snir worked against Moore’s best interests and for Kiska’s best interests to the detriment of her and the children.

THE RETAINER AGREEMENT

  1. In November 2019—desperate for a criminal lawyer following the forced appointment of John Hale by Justice Laliberté as Amicus Curiae (following the defamation and perjury presented to the Court by Crown prosecutor Malcolm Savage)—Moore retained Addelman following the Lotus House recommendation.
  2. Addelman claimed that his colleague Snir was a fabulous family lawyer with experience dealing with the CAS.
  3. Addelman walked Moore down the hall to meet with Snir (who was readily available) and Moore felt that she had no choice but to retain both of them as:
    1. her current criminal charges were ridiculous,
    2. the Crown was seeking a scandalous “NCR” finding,
    3. the CAS was ignoring all evidence of Kiska’s domestic violence and crime in order to pursue a Summary Judgment in his favour and
    4. she was broke and needed to have the fraudulently obtained, unlawful 2018 interim financial support amount order by Julie Audet changed.
  4. Addelman and Snir requested a retainer fee of $2,000 each which Moore paid immediately.
  5. As Moore had been “locked out” of her corporate savings and had been without meaningful income since 2016, Addelman and Snir offered to be compensated “later” if she “secured a second mortgage” on her matrimonial home (of which she owned and still owns half) and/or “named them in a lien”.
  6. Addelman stated that he required a flat fee of $25,000, regardless of whether or not Moore’s criminal matters went to trial.
  7. Snir stated that he charged $300/hour and would require security in the amount of $150,000 plus 20% of the value of Moore’s share of the home (therefore 10% or approximately $100,000) totalling $250,000.
  8. On November 12, 2019, Snir stated that he required security totalling $375,000; however, he also slipped in that his fee would be $300/hour plus 10% of the value of her home.
  9. When Moore went to Snir’s office to sign the retainer agreement, the arrangement had changed once again:
    1. the security required had changed to $250,000,
    2. in addition to hourly fees, Snir intended to charge “by the e-mail” and,.
  10. Then, Snir referred Moore to lawyer Thomas Windle to arrange the second mortgage/lien for $250,000 at a cost of $1,075: being demonized and criminalized by the CAS and Savage respectively, she did so under duress.

NEGLIGENT, FRAUDULANT, MALICIOUS &/OR CRIMINAL REPRESENTATION BY ADDELMAN

  1. On November 10, 2019, Moore sent to Addelman an e-mail with a link to a dropbox account that contained massive amounts of exculpatory evidence as well as evidence of severe domestic violence and child abuse.
  2. On November 11, 2019, Addelman responded “If you want to come at 5 pm today we can talk and see what we can do”.
  3. Shortly thereafter, Moore provided to Addelman the link to a dropbox account which contained an abundance of evidence against the complainant (impossible-to-divorce John Kiska), his lawyers at Bell Baker LLP, the Children’s Aid Society of Ottawa, the Ottawa Police Service, Ottawa’s Crown Attorney’s Office and others.
  4. Addelman spent the next few weeks badgering Moore about how much trouble she was in.
  5. By December 6, 2019—while in possession of an abundance of evidence of Moore’s innocence and status as a severely abused spouse of the complainant, John Kiska—Addelman was encouraging Moore to volunteer for a psychiatric assessment.
  6. By January 2020, Addelman duped Moore into agreeing to a psychiatric examination even though she had committed no crime and had not been found guilty of anything.
  7. On January 8, 2020, she prepared and signed a consent form for Addelman’s use.
  8. On January 9, 2020, SCJ Justice Catherine Aitken (“Aitken”) ordered a psych assessment; however, she did so in manner that was detrimental to Moore; not a reflection of her voluntary co-operation.
  9. For the next few weeks, Moore attempted to get Addelman to prepare and file a Bail Variation Application: he refused.
  10. Accordingly, she prepared one herself with an abundance of evidence regarding the ridiculous charges, malicious prosecution and unwarranted bail conditions.
  11. On or about January 30, 2020, Moore mistakenly alerted Addelman to the fact that he would be removed as counsel: later that morning, she was re-arrested based on false allegations of Lotus House manager, Lorie Fuentes, who had re-situated from the United States following charges related to human trafficking.
  12. One of Addelman’s associates, Ariya Sheivari (“Sheivari”), stepped in for him during her Bail Hearing and Moore was released.
  13. Moore attempted to switch her retainer to Sheivari; however, he refused.
  14. By the end of February 2020, Moore finally released Addelman; however, the damage was done: the wheels were in motion for Savage to obtain an NCR finding for Kiska’s benefit.
  15. On May 5, 2020, Dr. Zeynep Selaman (“Selaman”) produced a fraudulent, defamatory NCR Opinion: this begs the question, “Can NCR Opinions be Purchased?”
  16. (Interestingly, shortly after this report was released to the court, Snir began to ask Moore to be released from the Family and CAS files; thus, triggering the $60,000 lump sum payment of his scandalous retainer agreement following six months of sub-optimal, tortious and/or criminal behaviour.)
  17. One of Addelman’s other accomplices, Savage, refused to release Selaman‘s psychiatric assessment to Moore until after she was re-arrested in September 2020.
  18. It wasn’t until Moore received Selaman’s scandalous NCR Opinion that Moore suspected Addelman was merely another “gang-stalker”.
  19. For additional context I: On October 10, 2020, Savage’s colleague, Mike Boyce (“Boyce”), argued for Moore’s ongoing detention for hours; however, Moore was once again released on bail as she agreed to wear (and was somehow able to afford) a GPS-monitoring Ankle Bracelet.
  20. For additional context II: Why all this effort to keep Moore detained and frame her as severely mentally ill and/or dangerous? She had just a few short weeks left to prepare for the CAS Summary Judgment Motion which had been rigged by ex-CAS lawyer, Justice Tracy Engelking (“Engelking”), for Kiska’s benefit.
  21. Early in 2021, Moore finally received access to the remaining corporate funds held in AdvisorOnTrack Inc., her consulting firm, which immediately purchased a fixed-income security from her other company, SAQOTU Inc.—a whistle-blowing/advocacy media firm.
  22. With this fresh injection of cash, Moore was in a position to:
    1. purchase multiple transcripts,
    2. obtain a copy of the deed to her house and
    3. retain a lawyer who did not reside in Ottawa.
  23. This lawyer scoffed at all of Moore’s criminal charges and stated: “there is actually nothing here to which you can plead guilty as your name is on the deed of the house and you were court-ordered to communicate with Kiska. These other allegations do not qualify for criminal harassment.”
  24. It was upon receipt of this confirmation that I realized Addelman had not only committed multiple torts against me, Sean and Cate; but, he had committed multiple crimes as well including, but not limited to, conspiracy to prosecute.
  25. The shenanigans that Moore endured since first being unlawfully arrested in March 2019 would require an entire book to articulate: suffice it to say that she finally found a legitimate lawyer who advised her to “get it over with”, leave Ontario and find a jurisdiction with some semblance of justice.
  26. On May 24, 2022, Moore agreed to a Probation Order under duress so she could flee the Province of Ontario (“Ontario”) in order to seek justice in another jurisdiction.
  27. All of the charges were withdrawn, with the exception of one as Justice Jonathan Brunet:
    1. ignored Moore’s written submissions/evidence which supported an absolute discharge,
    2. ignored Moore’s oral testimony which requested an absolute discharge and
    3. granted another unlawful order which contained, among other things, anti-Charter conditions.

NEGLIGENT, FRAUDULANT, MALICIOUS &/OR CRIMINAL REPRESENTATION BY SNIR

  1. On November 11, 2019, Moore sent to Snir an e-mail with a Summary of Facts, her 2018 Amended Answer and reference to Summers’ 2017 precedent-setting decision. (See DocBook2 #0xx)
  2. On November 12, 2019, Snir directed Moore to contact Thomas Windle to arrange for the lien on her home as discussed above at paras 23-33. (See DocBook2 #0xx)
  3. Shortly thereafter, Moore provided to Snir the link to a dropbox account which contained the Orders, Endorsements, Correspondence and Continuing Record for both the Family file #FC-15-2446 and the CAS file.
  4. On November 27, 2019, Moore provided to Snir a commissioned Affidavit so he could prepare Motion materials to change the illegally-obtained, fraudulent support order that Kiska orchestrated in 2018 with his former attorney, Wade Smith (“Smith”) of Bell Baker LLP.
  5. The 20191127 Affidavit contained 17 commissioned exhibits A-Q:
    1. Moore loving life as a professional mum in February 2013,
    2. The Big February 2013 Fight with Kiska,
    3. Kiska does not tell docs about any fight,
    4. Arguments, Hospital Lies, Lawyer, Promises,
    5. Kiska prepares for 2014 summer break,
    6. 2014 Forced summer hospitalization by Kiska,
    7. 20150926 Discovery, Separation, Grounds for Divorce,
    8. Article – Macleans, We are the Dead by Anne Kingston,
    9. 20151012 TOH, Moore seeks counsel, Kiska serves 1st,
    10. Lead up to third and final separation of Nov 2016,
    11. Restore reputation, LMR, Kiska to go for jugular,
    12. Jackson C.V., 2017 Report, Gaslighting article,
    13. Kiska v. Moore, 2017 ONSC 6872; Lone Star,
    14. Pathological lying and Kiska court documents,
    15. 2018 Report from Office of the Children’s Lawyer,
    16. Financial abuse, false reports, protection orders and
    17. Eviction Scam
  6. Snir ignored Moore’s Affidavit and brought no Motion.
  7. Snir then lost a Motion to the CAS: all of her medical files were court-ordered to be sent not just to the court; but, to the CAS and Kiska!
  8. Noteworthy is that not one single medical file has ever been used by Kiska or the CAS to support their wild, malicious allegations of Moore’s “mental health issues”.
  9. The behaviour of Snir and Addelman had been so bizarre that Moore decided to take a working vacation and went to Cuba in March 2020.
  10. COVID-19 hit while she was at the resort, however, so she decided to continue on to Ireland, where she is also a citizen, in an effort to seek assistance with the rescue of her children from the Irish Embassy.
  11. This triggered another series of bizarre events that resulted in a warrant for her re-arrest!
  12. On or about March 19, 2020, Snir sent to Moore an invoice for $1,356.00, even though the agreement was that his compensation would come from the sale of the matrimonial home.
  13. Between March 31 and April 10, 2020, Snir continued to attempt to gaslight Moore by:
    1. claiming he was preparing legitimate offers to settle, of which there were none,
    2. requesting that he not receive additional evidence of Kiska’s accomplices’ crimes and torts,
    3. threatening termination of representation if Moore did not send him more money above and beyond that which was contained in the retainer agreement and
    4. accusing her of not requesting e-transfers for support payments instead cheques.
  14. He then stated that Moore would “do a better job” and asked her to remove him from her files—thus triggering his illegally-obtained, unlawful retainer clause which would result in an additional lump-sum payment of $60,000 to him.
  15. She refused and repeatedly asked him to simply do what he was hired to do: assist Moore with the Family file and the CAS
  16. Instead, on May 25, 2020, Snir served and filed multiple court documents which:
    1. violated the Courts of Justice Act in multiple ways,
    2. contravened the Criminal Code of Canada in multiple ways and
    3. evidenced his multiple torts against Moore and her children, Sean and Cate. (See doc 0xx, doc 0xx and doc 0xx)
  17. Initially, Justice Mark Shelston attempted to schedule the hearing; however, after Moore informed the court that the process was illegal, the matter was temporary postponed.
  18. Then Justice Pamela MacEachern scheduled Snir’s Motion: it was to be illegally heard in Family Court versus Civil Court.
  19. On August 27, 2020, Justice Marc E. Smith (“Smith”) illegally heard the Motion and ordered Snir off both the Family and the CAS file—however, he refused to order that the lien be removed from Moore’s house.
  20. On August 28, 2020, Engelking maliciously scheduled a Summary Motion Judgment against Moore and encouraged CAS to bring a motion to have Ontario’s Public Guardian and Trustee appointed!
  21. Broke, a warrant out for her arrest and stuck in quarantine in Toronto, by September 2020, Moore was once again without any legal representation whatsoever.
  22. Soon after release from quarantine, Moore was re-arrested so that she would not be able to properly prepare for the upcoming Summary Judgment Motion.
  23. This series of events resulted in Moore being forced to retain yet another Ottawa-based incompetent and/or criminally-inclined lawyer, Cedric Nahum (“Nahum”), who also ignored all of Moore’s evidence.
  24. Noteworthy: the benefit of Nahum’s brief retention for Moore’s CAS matter was that the CAS was so desperate to have the court orders illegally granted prior to the 2020 year end—when both Bell Baker’s Smith and the Office of the Children’s lawyer Debra Scholey “Scholey” were due to retire*—that they went ahead with their SJM after Nahum’s release; in direct contradiction to and/or violation of their previous court submissions and the CJA and/or the CYFSA, respectively.

*and perhaps receive some under the table bonus from Kiska

IRREPARABLE HARM CAUSED BY ADDELMAN AND SNIR

  1. Despite having a mountain of evidence against Kiska, Moore lost both the Summary Judgment Motion and her Appeal against Kiska and the CAS.
  2. Accordingly, Moore “lost” sole custody and access to Sean and Cate to Kiska:
    1. on December 11, 2020 in Ontario’s Superior Court of Justice—CYFSA “branch” and
    2. on December 20, 2021 in Ontario’s Superior Court of Justice—Divisional court when a crooked, three-judge panel violated multiple laws and had the nerve to state:

“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.”

  1. Both orders were unlawful for multiple reasons including, but not limited to, the fact that Moore and Kiska remain married and the future of the children of that marriage fall under the jurisdiction of the federal Divorce Act—the entire “smoke and mirrors” court-enabled, legal bullying since CAS’s unlawful 20190201 child apprehension was criminal.
  2. Kiska also managed to obtain a restraining order by “piggy-backing” the CAS SJM: even though Moore was short-served and could not have possibly responded properly to materials that were served after her materials were due, Justice Mary Fraser disobeyed the CJA and granted him one.
  3. Moore is also now burdened with an illegally-obtained, child-abusing, anti-Charter, three-year Probation Order that Ottawa’s Newfoundland-based accomplices have already tried once to use in order to arrange for her re-arrest.
  4. But for the negligent, defamatory, fraudulent, malicious, tortious and/or criminal behaviour of Addelman and Snir, the children would not have been without Moore for over four years.
  5. Addelman and Snir could have attempted to put an end to Moore and her children’s suffering by January 2020; instead, they chose to prolong it.
  6. 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.
  7. Due to the actions and inactions of Addelman and Snir (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 income,
    3. depletion of personal and corporate savings,
    4. multiple unnecessary arrests and
    5. humiliation, demonization, ostracization and unemployability which continues to this day.
  8. To further mock Moore, on December 28, 2022, Snir sent to her an unsupported invoice for $88,631.55, even though the agreement was that his compensation would come from the sale of the matrimonial home—not that he deserves a dime. 

CONCLUSION

  1. Moore has:
    1. made multiple requests that Snir and Addelman remove the lien from her home in advance of originating this claim,
    2. offered Snir and Addelman multiple opportunities to settle for damages suffered in advance of originating this claim and
    3. offered Snir and Addelman multiple opportunities to settle for damages suffered since originating this claim.
  2. She has yet to receive any response from them; however, Moore has received threats of:
    1. torture,
    2. death,
    3. apprehension under a Mental Health Act,
    4. unlawful incarceration and
    5. escalated fraud designed to force her into poverty, homelessness and despair.
  3. In addition, exactly one week after Moore served her Claim on the defendants, OPSB issued a scandalous Application to have Moore declared a vexatious litigant—despite being in possession of an abundance of evidence that she has endured nothing but court-enabled, organized crime since 2013—because … they are complicit.
  4. If not for the mental fortitude, resilience and sheer perseverance of Moore—as well as support from psychologist Dr. Iris Jackson, Eastern Ottawa Resource Centre’s VAW counsellor Jessica Poloz, Social Worker Catherine Sullivan and lawyer Alyssa Jervis over the years—Moore would have surely perished long before now.
  5. The likelihood that Snir and Addelman are members of Ottawa’s crime syndicate—as described at www.pfi.rocks/organized-crime/swimlanes—is highly probable.
  6. Ottawa’s Human Targeting/Human Trafficking Syndicate has had enough rope to hang itself.
  7. 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 Moore to seek multiple damages from Kiska for violations of both Civil Law and the Criminal Code of Canada in a … FAMILY … COURT … SETTING should Addelman and Snir’s syndicate ever permit her to schedule a divorce trial. (see Let’s Support our Victims: where complicit media, Ottawa Citizen, alerted Ottawa’s legal community that Moore was a target.)

Endnotes

1 Dr. Paule Kemgni, Patrick Cardinal, Lamah El-Rayes , Diego Fernadez Stolls, Khaldoon Habib-Allah, Justice Ryan Bell , Lamah El-Rayes , Lamah El-Rayes , Lamah El-Rayes , Lamah El-Rayes , Lamah El-Rayes 

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

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

 July 29, 2022

(last amended 07-FEB-23)

 

   Deirdre Moore, 215 Montreal Road, Ottawa, ON  K1L 6C8

(insert address) Paradise, NL  (insert postal code)

(613) 848-6832