Deirdre Moore and Ottawa Police Services Board

CV-21-00087056-000

Third-party Records Motion

Jump to OPSB Extortion  ||  #TDVCA  ||  OCL  ||  CAS  ||  Crown Attorney’s Office

Bell Baker LLP  ||  Victor Vallance Blais LLP  ||  Nelligan Payne O’Brien LLP  ||  Gardiner Roberts LLP

 (draft) Exhibit Book  

EO&MO re: Notice of Motion  ||  (insert text)  ||  (insert text)  ||  (insert text)

(last updated 20230606 08:30 e.s.t.)

How we got here:

  1. Aware that my ex’s circumvention of Canada’s Divorce Act was too much of a well-oiled machine for me and my children to be its only targets (or, victims), prior to the Statute of Limitations on OPSB’s 20190727 gross negligence (that led to my arrest, detention, a wicked non-Communication order and more), on 20210726, I issued a claim against Ottawa Police for the same amount that they extracted from the Ottawa tax base in 2020: $13.2M (see notes on City Hall vote here).
  2. Successfully enduring Ottawa’s crime Syndicate (the “Syndicate“) for 8 1/2 years, on 20211031, I gathered up some evidence and went to OPS to file a police complaint (see YouTube part 1 Arrival, part 2 Evidence, part 3 refusal to accept evidence/wait for call from investigator part 4 file was closed due to lack of evidence.
  3. On 20220301, I finally received consent from OPSB counsel, Michelle Doody of Borden Ladner Gervais LLP (“BLG”), to file my Fresh Amended Statement of Claim which included allegation of additional OPSB negligence, etc. mentioned at paragraph 1 above.
  4. Instead of proceeding with Discovery as previously consented, BLG threatened to bring an Application to have me declared vexatious and denied justice in civil court on all matters as well.
  5. As OPSB had re-started the two-year Statute clock, I offered to discontinue my Claim (for now); however, when BLG insisted that the terms of the discontinuance included my commitment to never suing OPSB for its participation in the Syndicate, I had no choice but to continue.
  6. OPSB is already well aware that I am not vexatious as I have evidenced the Errors, Omissions and Malicious Obfuscation (“EO&MO”) of the vexatious, vexatious 20230131 Notice of Motion here. 
  7. As OPSB has chosen to proceed which having knowledge that they are committing multiple crimes including, but not limited to, Defamatory Libel, Fraud (via Accessory After the Fact), Obstruction of Justice, Torture and more, I brought a 3rd-party records motion to be in a position to fully refute their allegations and further expose the Syndicate participants in the process.
  8. During a Case Management Conference held 20230509, BLG’s T.T. stated that BLG would not be opposing my motion with the exception of, perhaps, a couple of files that required confidentiality.
  9. I re-served my two Affidavits and Factum immediately and schedule the motion for 20230606: after conferring with BLG re: time required, they stated they need only 10-15 minutes so I requested 30 minutes of court time and filed my 202305xx Motion Confirmation.
  10. BLG waited until 20230531 to serve/file their practically non-existent list of documents (all redacted and therefore useless) as well as a 51-paragraph Factum that contained nothing but EO&MO (aka lies), evidencing their choice to continue to cover-up Ottawa’s massive, court-enabled Syndicate and bury me (and my children who remain unprotected from their sociopathic father, “Kiska”, and irreparably harmed both mentally and physically as they’ve been convinced that I abandoned them in 2019 when I was merely ripped from their lives by the sick&twisted Syndicate that most taxpayers unknowingly fund.
  11. I served/filed an Amended Motion Confirmation 20230605 and requested 90-minutes so I’d be in a position to fully refute their malicious arguments to have my motion dismissed; however, this request was denied.
  12. Here are OPSB’s 20230531 Factum and my responding 20230505 Affidavit #3 (which evidences only some of their lies and deception as I was busy battling another malicious Factum, the one served/filed 20230529 by another Syndicate member at Nelligan Payne O’Brien’s, Craig O’Brien).
  1. Accordingly, I request an adjournment of both this Motion and their vexatious, vexatious Application so that both matters can be properly heard by the court.
  2. (In anticipation of my request for an adjournment of both matters to be denied) Here are just a few of the highlights, in order of appearance, of BLG’s intentionally deceptive Factum:
        1. Para. 2: “Any further productions the Plaintiff is seeking from the OPSB Defendants are privileged or
          otherwise beyond the scope of what is plead in the statement of claim of the within action. FALSE: see below
        2. Para. 4: “… complex history with the legal system”. Clearly, this is what I am exposing #TDVCA. Co-own a $!m+ home and on welfare? Anti-charter Probation Order when no crime was committed?
        3. Para. 5-6(e): “…OPS … determined … a Civil matter”. Now, after following their direction, that same direction is being used to help them have me declared vexatious? Was this the plan all along? (rhetorical)
        4. Para. 9: “…Plaintiff seeks $5M …”. FALSE. See claim.
        5. Para 11: “… [Fresh Claim] changed defendant from OPS to OPSB” FALSE. Main purpose was to add in non-investigation of 20211031 report of Syndicate
        6. Para. 26-32 “Plaintiff is not entitled to complete unredacted records” FALSE. Already received some in 2017 (but they were stolen during the Eviction Scam and theft of my property).
  3. See para 3? If now position, then what the heck is para. 51 about?
  4. All other rebuttals with evidence attached available at www.pfi.rocks (currently tab 1: 20230606)
  5. I’ll yield in order to have an opportunity to refute whatever BLG is chosing to use to have my motion dismissed with costs.
  6. Close with Paradis, Kirady, Reesor: OPSB is organized crime: one can only wonder what else they do to Ottawa’s law-abiding men, women and children.
 

Para #

  

Statements made by BLG in OPSB Factum

  

Type of error, omission &/or malicious obfuscation

  

Actor/Enabler Reference

  

Torts

   Crimes   Other
             
  PART I  – INTRODUCTION          
1 The Plaintiff, Deirdre Moore (the “Plaintiff’) is seeking production of records from the Defendants, the Ottawa Police Services Board (the “OPSB Defendants”), and sixteen other entities. Of these entities, only the OPSB Defendants are parties to the action. Omission and Malicious Obfuscation. The Plaintiff (“Moore”) was forced to seek 3ʳᵈ party records in order to evidence the false allegations expected in their upcoming Affidavit to have her declared vexatious (see their Notice of Application at Appendix A) when she is merely a victim of Ottawa’s crime Syndicate (the “Syndicate”) which the OPSB would prefer to cover up.        
2 The OPSB Defendants have provided the Plaintiff with their Affidavit of Documents and Schedule A productions, which includes the documents the OPSB Defendants have in their care, control and power related to the within action.Any further productions the Plaintiff is seeking from the 0PSB Defendants are privileged or otherwise beyond the scope of what is plead in the statement of claim of the within action. Error. OPSB Affidavit of Documents only contained seven reports, all of
which were redacted (and therefore useless):
a) 2019-06-16 – OPS General Occurrence #19-809899 – Information (General) Partner
b) 2019-06-27 – OPS General Occurrence #19-162439 – Disobey Court Order
c) 2019-07-19 – OPS General Occurrence # l 9-186131- Harrass Crim Stalking – Spousal
d) 2019-07-23 – OPS General Occurrence# 19-I89868 – MHA – Other
e) 019-07-24 – OPS General Occurrence #19-190428 – Dispute- Disturbance
f) 2019-07-26 – 0 PS General Occurrence #19-193182 – Harass Crim Stalking
g) 20 I 9-11-04 – OPS General Occurrence#19-292589 – Dispute – Civil All redacted,They did not include many important documents, including, but not limited to:
h) Moore’s 20151015 complaint #2015-261835 of sexual assault committed by John Kiska (“Kiska”) (see Appendix B) and
i) Moore’s 20211031 complaint #2021-280183 of the #TDVCA Syndicate where they refused to accept any evidence (view in-person visit to OPS https://youtu.be/7wnBEvn9VFg and see partial evidence at Appendix C that they refused to accept) and then apparently closed the file for lack of evidence (insert youtube recording of OPSB stating file was closed),
j) Moore’s 20230221 NL complaint #2023-1244 l of fraud committed by Kiska and accomplices (see Appendix D) and transferred to OPSB for further investigation-which seems to have vanished and
k) Kiska’s bogus 20210407 allegations of Criminal Harassment (see Appendix E and note that all five charges were dropped; but, used to arrest/detain Moore and force her to remove her Kiska/CAS/OCL/OPS/OCA/OCJ/SCJ-related, evidence-laden website from public view (now password-protected at www.twb.rocks) laid the day after she originated her Civil Action noted at para. 5 below.How could any documents be “privileged” or “beyond … scope” when OPSB is falsely alleging that Moore is vexatious? Unredacted documents would easily prove that Moore is not vexatious yet, again, OPSB is choosing to ignore the evidence of her never-ending , demonstrable persecution that merely benefits and continues to harbour her “ex” (impossible-to-divorce John Kiska).		        
3            
           
  PART II – SUMMARY OF FACTS          
4            
5            
6            
7            
8            
9            
10            
11            
12            
           
  PART III – STATEMENT OF ISSUES          
13            
           
  PART IV – LAW & AUTHORITIES        
14            
15            
16            
17            
18            
19            
20            
21            
           
  PART V – ORDERS REQUESTED        
22            
23            
           

Why? Because it’s been  Years in the Making!