# 81 Full Affidavit #8 Supreme Court BC1. That I am the Plaintiff herein, and as such have personal knowledge of the matters and facts herein deposed to, except where stated to be based on information and belief, and where so stated I believe the same to be true. 2. On December 8, 2009 I received an email from D. Ross McGowan with a letter attached in which he purports to be writing at the behest of Gordon Johnson. Also attached to the email was a copy of the order of Madam Justice Dorgan for the trial, signed and filed on November 20, 2009, which had not been delivered to me previously by Gordon Johnson as I expected. According to publicly available information, Robert Dawkins works hand and glove with D. Ross McGowan and is in the same serious conflict of interest in representing the defendants and Gordon Johnson at the hearing scheduled for December 17, 2009. 3. Attached hereto and marked as Exhibit "A" is a series of emails from David Nicholson to Marcia Pavlis. I received information from David Nicholson that he is a former employee of HSBC Securities (Canada) Inc. I received information from him that his wife, his father-in-law, and a step-father are all lawyers and that he has a team of lawyers working to resolve the issues which remained following the end of his employment with HSBC (Securities) Canada Inc. I believe that he is responsible in part for the delivery of a falsified transcript to me on November 3, 2009. The falsified transcript contains enough correct information to know that whoever created the falsified documents must have had access to the recordings of the trial. I was informed by the Supreme Court that neither party ordered burned CDs of the trial. I believe that a female person who was in the audience for most of the trial was there as a court reporter on behalf of the defendants. I believe that Gordon Johnson is behind the production of the falsified transcript and that he conspired with the lawyers representing Dave Nicholson to create and to deliver the falsified transcript to me. 4. I make this affidavit in support of an application for the following order or orders: a) that Mr. Johnson comply with the Court order of November 20, 2007 forthwith; b) In the alternative, that Mr. Johnson be declared in contempt of court and remanded into custordy until the said order is complied with; c) That the defence forthwith file the following documents: i) Affidavit #1 of Angie Wong sworn on July 14, 2006, ii) Affidavit #2 of Angie Wong sworn on October 25, 2007, iii) Affidavit #3 of Angie Wong sworn on October 25, 2007, iv) Affidavit #3 of Angie Wong sworn on November 19, 2007, v) Affidavit #4 of Angie Wong sworn on November 27, 2007, vi) Affidavit #1 of Erika Banwait sworn on May 29, 2007, vii Affidavit of Arika Banwait sworn on May 30, 2007, viii) Affidavit #1 of Sarah McEachern sworn on November 27, 2007, ix) The defences' replies to my Notices to Admit of June 15, 2007 and July 13, 2007, x) All of the defences' responses to my Notices of Motion. d) That the Court provide the Plaintiff with direction regarding the filing of the orders referred to in her Affidavit #5; e) That the Court provide the Plaintiff with copies/burned cds of the Digital Audio Recordings (hereinafter, "DARS") of all of the hearings which were held in the Supreme Court regarding this matter; f) That the Court declare a mistrial; g) The defendants pay increased or special cost forthwith, in an amount this Honourable Court deems appropriated and just. code pour embarquer la vidéo : >>> http://www.youtube.com/embed/pr50adEW1pY <<< |