Filed/Served: Fresh 202302xx pdf A-A Statement of Claim (& online version with links to evidence of allegations)                      CV-23-91267  

Snir‘s 202302xx Statement of Defense: Statement of Defense (& my EOMO Analysis)


work-in-progress > Books of Documents: #1   #2   #3   #4                    

(back to w-i-p court-enabled fraud as this Civil Action progresses)


202309xx Factum

pdf version

Ottawa Police Services Board et al.   (defendant/moving party)

Deirdre Moore   (plaintiff/responding party)



Para #






Case Law



  Crimes   Other
  Heading #1          
A. Tests re: vexatious litigation

Case law has identified a number of common attributes of a vexatious litigant under section 140 including, but not limited to, the following:

n/a Gao v. Ontario WSIB, 2014 ONSC 6497 (CanLII)      

(a)        Bringing multiple proceedings to try to re-determine an issue that has          already been determined by a court of competent jurisdiction;

There does not seem to be a competent jurisdiction available: this is the underlying problem. If Family court were competent in the first place, they would have been no … other … proceedings.

MASSIVE FRAUD against not only the targeted spouse but the taxpayers who pay the salaries of all dirty cops, crooked lawyers and bought judges.

Re Lang Michener et al. and Fabian et al., 1987 CanLII 172 (ON SC) at pp. 5 and 6Landmark Vehicle Leasing Corporation v. Marino2011 ONSC 1671 (CanLII), at para. 38.      
  (b)        Rolling forward grounds and issues from prior proceedings to repeat and    supplement them in later proceedings including bringing proceedings against counsel who have acted for or against them in earlier proceedings; The syndicate is intertwined and explaining context/evidencing collusion is necessary to isolate specific grounds. Tricky without the ability to wire-tap, analyze bank accounts/credit card statements and obtain e-mail and phone records.        
  (c)        Persistent pursuit of unsuccessful appeals; Divisional dismissal #1 ignored federal paramountcy and Divisional dismissal #2 ignored obvious fraud … and committed more.        
  (d)      Failure to pay costs awards of prior proceedings; There wouldn’t be any cost awards but for the:

  • “bad faith” of impossible-to-divorce John Kiska and his divorce team (see Continuing Record at Exhibit X),
  • ignorance of domestic violence by the Children’s Aid Society of Ottawa, Ontario’s Office of the Children’s Lawyer and Superior Court of Justice-Family (see SJM)
  • Superior Court of Justice-Divisional (see CAS Appeal and MacEachern Appeal docs)
  • pathological lying of Kiska + incompetence of Kemgni

Also, Moore would be able to pay costs if she weren’t enduring so much fraud, theft and defamation regarding her mental health, lack of employment and denial of spousal support.

  (e)        Bringing proceedings for a purpose other than the assertion of legitimate    rights, including to harass or oppress others; LOL. Classic D.A.R.V.O.        
  (f)        Bringing proceedings where no reasonable person would expect to obtain   the relief sought. Any reasonable person unaware that Canada’s judicial system was a front for tax evasion and organized crime would have expected to win every proceeding that Moore has brought thus far. (see examples of laws judges break to reward perpetrators)        
  Is Moore vexatious? Or merely resilient: complete, intentional circumvention of the federal Divorce Act using multiple provincial acts and how they did it.          
  Is OPSB and the City of Ottawa malicious … with an unlimited budget … and a lot to hide?