PDF version of this Affidavit (redacted)  ||  OPSB 20230131 Vexatious Application || Moore v. OPSB Civil Action Main Page ||  Simultaneous Motion against Shyster Gonen Snir

Organized crime enabled by law firms:  Borden Ladner Gervais, Nelligan Law, McCarthy Law, Bell Baker , Cavanagh & Victor Vallance Blais & more. Seriously, who’s not involved? 


Affidavit #1: Extensions, etc.

pdf version

b e t w e e n

Deirdre Moore   (moving party)


Ottawa Police Services Board et al.   (respondent)


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


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

  1. On 20210726, I originated a claim against the defendants (“OPSB”) to which they filed a (late) 20210914 Statement of Defense (see Exhibit A).
  2. On 20220301, while waiting for their response regarding our Discovery Plan and after receiving some assistance from a lawyer, I filed an improved Fresh Amended Amended Statement of Claim (see Exhibit B) to which no Amended Defense was filed.
  3. On 20220331, OPSB confirmed that they would “prepare an affidavit of documents and send … productions” (see Exhibit C).
  4. On 20220515, instead of receiving any affidavit of documents, OPSB notified me that they would bring an Application to have me declared a vexatious litigant[1] (“Vexatious Application”) and denied justice from Civil law[2] (see Exhibit D).
  5. Note that on 20221024, Mark Sutcliffe replaced Jim Watson (who was well aware of the crimes being committed against me by the Syndicate (see Exhibit E).
  6. On 20221221, I informed OPBS that their threat of Application combined with their self-serving, unlawful consent form (see Exhibit F) circumvented the requirements in the Courts of Justice Act (“CJA”) at Rules of Civil Procedure (“Rules”)

Rule 23.01(1)(c) which states that:

“A plaintiff may discontinue all or part of an action against any defendant …  at any time, by filing the consent of all parties.  R.R.O. 1990, Reg. 194, r. 23.01 (1); O. Reg. 427/01, s. 10.“ and

Rule 23.04(1) which states that:

“The discontinuance of all or part of an action is not a defence to a subsequent action, unless the order giving leave to discontinue or a consent filed by the parties provides otherwise.  R.R.O. 1990, Reg. 194, r. 23.04 (1).”

amounted to Extortion pursuant to S. 346(1) of the Criminal Code of Canada (“CCC”) which states that:

“Every one commits extortion who, without reasonable justification or excuse and with intent to obtain anything, by threats, accusations, menaces or violence induces or attempts to induce any person, whether or not he is the person threatened, accused or menaced or to whom violence is shown, to do anything or cause anything to be done.“  

  1. On 20230131, despite being aware that I am:
    1. not remotely vexatious but merely a Taxpayer-funded Domestic Violence and Child Abuse (“#TDVCA”) target (see illustration at Exhibit G, online at https://pfi.rocks/home and at pinned tweet https://twitter.com/CaeJak),
    2. a whistle-blower on government corruption and mental health fraud despite the wickedness of Ottawa’s Partner Assault Support Team (“P.A.S.T.”) (see residual evidence from the 2020 Canadian Domestic Violence Conference at Exhibit H) and
      1. seeking justice and the rescue of my once-perfect children Sean & Cate,

OPSB issued their Vexatious Application anyways (see Exhibit I).

  1. Note that on 20230426, Royal Ottawa Mental Health Services (“ROMHC”) Chief of Staff Gail Beck  was appointed to Chair of OPSB and I have evidence that two of her psychiatrists are involved in, at a minimum, #TDVCA; namely, Zeynep Selaman and Joel Watts who both signed a Not Criminally Responsible (“NCR”) Opinion following a bogus psychiatric assessment for a crime I never committed, was never found guilty and which was eventually dropped.
  1. (See:
    1. 20200505 NCR Opinion at Exhibit J (and partial EO&MO Analysis at https://pfi.rocks/organized-crime/vis/zeynep-selaman,
    2. 2022mmdd letter of opinion from defense attorney Alyssa Jervis at Exhibit K,
    3. 2022mmdd letter of opinion from social worker Catherine Sullivan at Exhibit L,
    4. 20220524 extorted Probation Order despite zero guilt at Exhibit M and
    5. partial evidence of nearly three additional years of OPSB-enabled #TDVCA, negligent investigation, conspiracy to prosecute, torture and human trafficking (see 20210409 Release Order at Exhibit N)

performed/executed all for the benefit of estranged, impossible to divorce John Kiska (“Kiska”), who:>

    1. falsely accused me of criminal harassment (see OPSB charge sheet (where Kirady lied about the existing order) and last minute additions to have the non-communication order orchestrated by Crown’s Mike Boyce (“Boyce”) and OCJ’s J.P. Harris (“Harris”) at Exhibit O),
    2. arranged for the long-awaited divorce trial to be cancelled as planned (see Kiska’s 20190724 nearly blank Trial Scheduling Endorsement Form and Engelking’s 20190803 endorsement at Exhibit P),
    3. lied to OPSB by stating that I was schizophrenic (see excerpt from OPSB 20190726 transcript vs “selective” disclosure provided by OPSB at Exhibit Q),
    4. so he could claim I was both mentally ill and involved in crime during his malicious pursuit of sole custody and access of my children Sean Kiska and Cate Kiska (“Sean & Cate) (see Exhibit R),
    5. despite the 2018 report from the Office of the Children’s Lawyer (“OCL”) that recommended I be awarded sole custody (see Exhibit S)
    6. following advise he received from #TDVCA Syndicate member and CAS Executive Director Kelly Raymond (“Raymond”) and/or her associates (see Exhibit T)
    7. to achieve 100% parental and child alienation to further abuse Sean & Cate and torture me; which was the plan all along (again, see Exhibit U).

Events since OPSB’s scheduling of its Vexatious Application

  1. On 20230203, I was asked about the expected length of my materials and oral submissions so OPSB could schedule their Vexatious Application (see Exhibit V).
  1. On 20230308, the Vexatious Application was scheduled for 20231005 and my Affidavit-related materials—based on BLG’s estimates and information available to me at that time—were estimated to include:
    • 5 Affidavits
    • 100 documents totalling
    • 1,500-2,000 (see Master Fortier’s  Exhibit W).
  1. Since that time, however, several significant events have occurred. In reverse chronological order:
    1. As of 202307xx, a series of events have occurred which:
      1. forced me to apply for social assistance (see Exhibit X),
      2. resulted in me being denied social assistance (see Exhibit Y),
  • led to my moving to a women’s shelter for those fleeing domestic violence (see 7-page memo at Exhibit Z) and
  1. On 20230711, I was informed by Const. Stephanie Glenn that, in consultation with her supervisor Sgt. Matt Renic, the RNC file #2023-12441 (now OPS #23-161630) was closed as [the fraud occured in Family court; therefore,] it was deemed a Civil matter. LOL
  2. the Vexatious Application was scheduled for 20231005 and my Affidavit-related materials—based on BLG’s estimates and information available to me at that time—were estimated to include:
    • 5 Affidavits
    • 100 documents totalling
    • 1,500-2,000 (see Master Fortier’s  Exhibit W).
  1. resulted in my being forced to seek a NL-funded shelter (see Exhibit AA) all because
  2. Kiska stopped paying his fraudulently-obtained, below-poverty-level, 2018-court-ordered, spousal support of merely $1,230/month (see Exhibit AB)
  1. On 20230706, OPSB served a 48-para. Affidavit that consisted of so many errors, omissions and malicious obfuscation (“EO&MO”), I will be required to file more evidence with the court than anticipated to be in a position to properly refute it all (see draft EO&MO Analysis which contains an estimate of the number of Affidavits, documents and pages required simply for rebuttal at Exhibit W),
  2. From 2023mmdd-20230606, I endured endless shenanigans from SCJ regarding my attempt to secure the 3rd-party records to refute the OPSB’s Vexatious Application (see Exhibit X.
  3. On 20230531, OPSB served a last-minute, EO&MO-laden, 51-paragraph Factum for a 30-minute Motion that they previously claimed “no contest” in order to obfuscate my 3rd-party records Motion which, if successful, would have further evidenced the torts and crimes being committed by the #TDVCA Syndidate against me, Sean & Cate. (See Motion materials, EO&MO Analysis and resulting endorsement at Exhibit AI).
  4. On 20230221, due to events noted at para. b. v. above, as I was in a position to file another police complaint against Kiska, I did; this time, however, with the Royal Newfoundland Constabulatory (“RNC”) who:
    1. assigned a file number of 2023-12441 (see Exhibit AC) and
    2. tranferred the file to, you guessed it, OPSB for investigation and—at time of writing—assigned OPSB-employee Stepahnie Glenn has yet to return my calls regarding the status of said Fraud report.
  5. From 202302xx-20230608, co-defendants Addelman Baum Gilbert Robinson (“Addelman”) and Snir Law Office maliciously obfuscated my Civil Action via unnecessary Motions and EO&MO-laden Statements of Defense which—when one compares my evidence of allegations to their self-serving denial of same (see Exhibit AD)—further evidences that I am not vexatious but merely a target of Ottawa’s #TDVCA Syndicate.
  6. From 20230110-20230410, defendant Dr. Paule Kemgni (“Kemgni”) pretended to be waiting for a practically blank hospital file (see Exhibit AE) that she had for well over a year in order to further delay my civil action against her and force me to pursue it—using another province’s laws—while in a position of obviously Syndicate-orchestrated poverty and homelessness (see false statement of claim and evidence of same at Exhibit AF).
  7. On 2023mmdd, due to events noted at para. e., I was in the position to file another police complaint; this one against Kemgni (see Exhibit AG) which—at time of writing—has yet to be assigned.
  8. On 20230705, I learned that somehow Kiska managed to renew the mortgage on our $1M+ matrimonial home without my approval or signature which evidences either another count of forgery or, perhaps, theft of my half of the property known as 1244 Lampman Crescent, Ottawa, ON K2C 1P8. See attempt to seek renewal documents from BMO’s Erika Watson—who suddenly took leave following my second request—and copy of the deed at Exhibit AH and
  9. From 202305XX-XX one of Kiska’s other BellBaker accomplices, Cheryl Hess (“Hess”), refused to respond to my desperate pleas for consent to a proposed (required) Motion to send to my son, Sean, a birthday cake[3] for his 17th birthday … and fifth one-in-a-row without me.
  1. .
  2. In summary, this Syndicate simply refuses to stop producing self-incriminating evidence: for ease of reference, a list of 37 exhibits is listed in Appendix A on page X of this Affidavit.
  3. An estimation of the Affidavits, documents and pages that will be required to refute their 20230706 Affidavit are listed in Appendix B.


New Reality

  1. Given the amount of new evidence that various #TDVCA Syndicate participants have produced since the scheduling of their Vexatious Application earlier in the year, the five-Affidavit, 100-document, 1,500-to-2,000-page limitation is no longer sufficient to submit a full defence against OPSB’s Vexatious Application.
  2. Avoiding grounds for appeal including, but not limited to, a motion for leave to adduce fresh evidence should be one of the goals of any lower-court judge; that is, any lower-court judge that isn’t supportive of the human trafficking that keeps then entire playground-for-socipaths we call a judicial system operating at full capacity for maximum tax-dollar siphoning and sadistic pleasure.
  3. Furthermore, merely two hours allotted to refute their 48-paragraph Affidavit plus present my own arguments is clearly even more unreasonable now.
  4. Obviously, OPSB’s Vexatious Application is nothing more than yet another way to deny me a fair settlement or trial for my action against them (see Exhibit B) which is the same modus operandi that was used by:
    1. Kiska to avoid the 2019 divorce,
    2. the CAS to avoid a fair CYFSA trial via an illegally-scheduled, unlawful Summary Judgment to rip Sean & Cate from my life and
    3. the MAG’s Savage et al. to avoid my likely acquittal of their bogus, Kiska-caused charges.
  5. It’s also similar to the Rule 21 Motions used by:
    1. Michéle Blais of Victor Vallance Blais LLP, even though the hearing of her Motion was illegal (see Exhibit AJ) and
    2. [Fictitious landlord] Khaldoon Habib Allah et al., even though I had enough evidence against each of the defendants—including OPSB—to proceed to discovery on the 2019 Eviction Scam and theft of all of my, Sean & Cate’s valued possessions while I was, again, falsely accused and detained (see Exhibit AK).
  6. Given the amount of evidence now in OPSB’s records, that they are even choosing to continue with their Vexatious Application demonstrates, in my opinion, that they and their legal counsel are—beyond any reasonable doubt—involved in organized crime that goes beyond the #TDVCA that Sean & Cate and I have experienced thus far.
  7. As for our capital city’s Mayor Mark Sutcliffe, City Councillors Cathy Curry, Marty Carr (and others) and newly appointed Chair Dr. Gail Beck who all oversee OPSB? No comment.
July XXXX, 2023         Deirdre Moore, 110-1539 Topsail Road, Paradise, NL

(613) 848-6832     dmoore@pfi.rocks










Michelle Doody

Borden Ladner Gervais LLP, 1300-100 Queen St., Ottawa, ON K1P 1J9

counsel for the Ottawa Police Services Board


[1] xxx

[2] xxx

[3] xxx

  1. In r
Deirdre Moore   last updated  15:16 NL    Date  July 10, 2023




01     A      
02      B      
03     C      
04     D      
05     E      
06     F yes    
07     G      
08     H      
09     I      
10     J      
11 20180322 ENDORSEMENT 1_For Oral Reasons Given_Spousal Support DENIED-AUDET K      
12     L      
13     M      
14     N