This is the Motion Record of the Responding Party and Trustee/Executor of The Kingdom of Heaven Found a Sean (hereby, ‘the Trust’).
Introduction and Background:
None of the Respondents to the Claim should be surprised by the Claim because they were placed on Notice of Civil and Criminal Liability for Breach of Trust on May 29th, 2022, advising them that a Claim would be forthcoming if they did not reply before June 5th, 2022. Sean specifically Wished to know the status of Tanja’s application for CAET, and why the Courts had no Record of any Application hearing for Sean to respond or object to.
King Sean, House von Dehn (hereby ‘Sean’) finally brought a Claim against Tanja Johnson (Tanja), her lawyer, Hala Tabl (Hala), and Michael von Dehn (Michael) to put a stop to the economic and emotional harm being done to Sean and the Estate by his siblings in the application process, and to find out what was really going on with his Father’s (Joachim Heinrich von Dehn) Estate, on August 4th, 2022.
Each of the Respondents served and filed a Statement of Defense in response to the Trust’s Claim. The Statements of Defense were nothing more than a banquet of baseless, tasteless allegations and ad hominem attacks upon Sean’s Character, the integrity of his Trust, and the Solemn Promises Sean had made to his Father.
Michael even filed a Motion under Rule 2.1.01(6) to have the Claim dismissed, suggesting that Sean’s Trust is not a legal entity and that the Claims against Michael are frivolous and vexatious. Considering the lengths Sean learned Michael was Willing to go to trespass upon Sean’s determination to Honour the Promises he had made to his Father, Sean finds this Act to be especially distateful and cruel. Honourable Justice, Sally A. Gomery, had this to say about the request to dismiss.
“He alleges that the defendants Mr. von Dehn and Ms. Johnson have colluded to deprive the beneficiary of the plaintiff trust, Sean von Dehn, of his rightful share of his father’s estate. He alleges that the defendant Hala Tabl, a lawyer, breached her fiduciary duties towards the estate’s beneficiaries.”
Justice Sally A. Gomery – Denial Request to Dismiss
This was the second request to dismiss as ‘frivolous and vexatious or otherwise an abuse of the Court process’, the first was by Hala for Tanja, and by Way of a Rule 21 Motion. All the Respondent’s/Moving Party’s Statement of Defense pleadings were provided in the Motion Record.
- Hala Tabl – Rule 21 Motion Record, Factum, and Book of Authorities.
Sean authored a Reply Factum, addressed each of the Moving Party’s baseless allegations in chronological Order, called Christopher Christman-Cox out for his hearsay remarks and libelous Character attacks, advised the Court that Sean hasn’t been served with any documents in the Estate Application since March 24th, 2022, and informed the Court that every document Presented as evidence to the Court in the Respondent/Moving Party’s materials dated later than March 24th, 2022, is in fact the evidence Sean required to prove the Trust’s Claim.
The Record Shows by Way of her own testimony, that every hearing for a CAET Application that was obtained by Hala Tabl was made in violation of Rule 1.09, with intent to deprive Sean of his right to participate in the hearings for his father’s Estate Trustee Appointment, interfering with his prior right to Act as the Estate Trustee, and colluding with and for Tanja and Michael to deprive Sean of his right to disclosure of Matters concerning the Estate. Sean was the One who had Promised his father he would not let the mortgage go into default, Tanja and Michael were determined to ensure that it did, Hala Tabl made it happen.
Sean also clarified and defined his Supreme Claim of right upon his father’s Estate to dispell any further suggestions that Sean is trying to steal Tanja and Michael’s share of the Estate. Sean, on behalf of his father, Joachim, House von Dehn, asserts that Tanja Johnson has no legitimate legal or lawful Claim upon the von Dehn Estate; House von Dehn has no outstanding debts with the House of Johnson. Tanja’s Entitlement to a share in the Estate, is by the Good Graces of the Entitled Beneficiaries – her Brother’s, Michael and Sean, have agreed that Tanja should have an equal share. Tanja should be Mindful of this moving forward.
Sean also called out every single one of the Respondents for continually attempting to gaslight the Trustee of an Express Trust, pretending they have no Idea what a Trust is, and suggesting there is no legislation for it when at least two of the lawyers Responding allegedly hold a Juris Doctorate in Law, and specialize in Trust and Estate Law? And they Wish to know why I Wish to see them fined for contempt?
None the less, a buffet full of tasteless lies must somehow seem sweeter when served on a Court because Justice Jaye Hooper took the bait, hook, line and sinker, feeding so frantically on fibs, the scales of justice were swallowed whole.
Sean has absolutely no Idea how a Judge of the Superior Court could ever come to such a conclusion considering the space time continuum as We know it makes the allegation of the Trust’s Claim being a ‘collossal attack on the Carusso (sic) Endorsement’, chronologically impossible.
Hooper also seems to have taken the ‘evidence‘ of the Casullo Endorsement and other documents Presented by the Respondents and Moving Party in the Rule 21 Motion under rather serious consideration, and Sean knows that no evidence was allowed to be considered in the Rule 21 Motion, or it doesn’t qualify for dismissal under Rule 21. Sean thought that was especially interesting. Even if Hooper were unable to read, surely she was able to hear Sean tell the Court that he had not been served with any documents in the Estate Application since March 24th, 2022. Sean maintained an Audio Recording for the Public Record of the Motion – just to be sure.
It didn’t take long to see how sick swallowing the scales of justice had made Hooper, though her retaliation for the poisonous lies clouding her judgment were wildly misdirected.
It was Jenny Bogod and Susan Sasks of RosenSack LLP that sent an email to the Court complaining about Sean’s audio Recording of the Motion, and it wasn’t long before Hooper was following up, threatening Sean with contempt or a ‘phonecall to the police’ if he did not immediately remove the Record.
Sean reminded Hooper that he came before these Courts for relief and remedy for trespass upon his right to a fair and impartial public hearing, and that he Will not be intimidated by threats for exercising his inherent right to provide uninhibited public access to the Courts by Way of this Blog. The audio remains.
Sean was served with a copy of Hooper’s Decision and Antione Brisbane requested confirm a Sean of receipt. Sean advised Antione that Hooper’s decision is unacceptable for fraud and perjury on a Court of Record, has accordingly been vacated, and the Justice was suspended from any further adjudication regarding this Matter. Sean also advised Antione to let him know if Hooper had any object-Sean’s.
No. The only objections came frome Jenny Bogod (hereby Jenny) and Susan Sacks (hereby Susy) for Hala, trying to tell Sean that he can’t vacate the order and suspend the judge. Of course they would say that – they need the decision to stand for any future gaslighting to have any judicial precedence, and they also helped Hala perpetrate her fraud on the Court, so they’re now also accomplices colluding with Hala, Tanja, and Michael, to perpetrate this fraud on Sean. It is imperative for the Moving Party that no Judge looks into this Matter seriously enough to determine it should procede to discovery. Sean advised Jenny and Susy that their opinion is irrelevant, fraud and perjury are never admissible on a Court of Record, and they don’t have the authority or jurisdiction to respond – only the judge can do that.
Jenny is persistently shameless in her fraud, Sean Will Give her that much. Jenny refused to take no for an answer and brought a Motion attempting to coerce Sean into consenting to Hooper’s unlawful decision. Sean reminded court clerk Derrick Bert that the Decision has been vacated and the justice has been suspended from any further adjudication regarding this Matter for conflict of interest. Once again, the hearing was Recorded for the Public Record.
Tanja and Michael now Wish to use this Motion to award summary judgment against Sean, dismissing the claims against each of them, hoping for a repeat performance of the fraud perpetrated by Hala and RosenSack LLP in the Rule 21 Motion, and relying on Hooper’s vacated decision to dismiss against Hala, as judicial precedence that fiction is fact if One can sell it to a judge. That’s precisely why the Decision was Vacated.
A Case Conference was held to set a schedule for serving and filing documents related to this hearing, hosted by Justice Kaufman. Sean advised Justice Kaufman that he felt a summary judgment motion hearing to dismiss the Claims against Tanja and Michael seemed a little ambitious considering they both remain silent after Hooper’s decision, knowing that Sean hadn’t been served with any of the documents in the Estate Application, including the Casullo Endorsement.
Sean made it very clear to both Tanja, Michael, and their respective representative lawyers, Mr. Milton and Mr. Cox, that if Michael and Tanja did not confess, they better make sure they provide proof of service of the Casullo Endorsement on Sean prior to August 4th, 2022, or he would be as King for criminal charges to be laid in addition to the commercial Value of the Claim.
Sean further added that if Tanja and Michael do not confess, and if Sean does not receive proof of service of all documents on Sean required for the Estate Application, including the Casullo Endorsement in their forthcoming Motion materials, he Will not respond to any new information until those documents are provided to substatiate their baseless defamatory remarks, or be held to acount for their libel and slander of Sean’s Honourable Charcter on a Court of Record.
This is the Recording of the Case Conference hearing with Justice Kaufman for the Public Record, which was held before Hooper had made her incorrect, unreasonable, and unlawful decision. Tanja and Michael still had a chance to do the right thing.
“Thou Shall not bear false witness.”
Sometime thereafter, Sean received the Motion Record and Affidavit materials of the Moving Parties:
- Neil Milton: Motion Record for Tanja Johnson.
- Christopher Crisman-Cox: Motion Record for Michael von Dehn
Both of the moving Party’s Motion Records provide Sean with plenty of new inform a Sean, but none of the information he’s been as King for. They continue to ignore the legal and lawful rebutals that remain unanswered in Sean’s first Reply Factum to their initial pleadings, Jusice Gomery’s denial Endorsement of a request to dismiss (that properly Styles the document and correctly identifies the parties to the Claim), and deliberately and continuously gaslight Sean by pretending they have no Idea what a Trust or Trustee is, or what legislative Act Gives the Trust and Trustee it’s legal capacity in an Ontario Superior Court of Justice! It’s not just gaslighting, it’s abuse and contempt of Court.
Sean placed the parties on Notice for their contempt of Court, continued abuse of Court process, baseless accusations, refusing to provide information required for litigation, fraud with intent influence Justice, and advised the Moving Party that Sean Will not be wasting any more of his Valuable time responding to new documents until the Moving Parties respond to the legal and lawful arguments that Sean has already made, and which currently Stand unopposed on this Court of Record.
All Moving Parties and Respondents to the Claim were clearly advised that if proof of service of the Casullo Endorsement on Sean is not provided in their materials, he Will be as King for the Motion to be converted to a Motion of Default against the Respondents for Willful, criminal intent to interfere Justice and defame Sean’s Character and the integrity of his Trust.
- Response to Neil’s Motion Record for Tanja.
- Response to Christopher’s Motion Record for Michael:
Sean would like the Court to take a brief moment to review the email reply to each of the Respondents, and consider that Neil and Christopher told Justice Kaufman in the follow up Case Conference with Kaufman that Sean had not provided any kind of ‘meaningful‘ reply to their Motion Record! Is fraud, perjury and contempt of Court with intent to influence justice so commonplace in Canada’s Courts that being noted in contempt is now meaningless? Meaningless enough to the Respondents that they failed to reply in any meaningful Way, yet expect Me to waste My time drafting new documents when they have all failed to address a single legal argument Presented in Sean’s materials, and refuse to respond to provide information to support baseless allegations against him. Pretending that any lawful Estate Application took place and that Tanja was ‘duly’ appointed as Trustee is to Present an entire Motion built upon a foundation of Fraud.
And finally, their corresponding Factums.
- Neil for Tanja: Factum I, received August 14, 2023
- Christopher for Michael: Factum, received August 17, 2023
- Second Factum for Tanja, Factum II (received August 21, 2023)
And now We are up to date. Sean was literally Writing this section of his Blog for this Motion when he received the email from Erica Kapa.
As per usual, Sean is ambushed by new information Presented to him four days after the deadline of August 17th for serving and filing Tanja’s Factum, and only three days before Sean’s deadline to serve and file his Reply Factum.
Last week, Tanja swore that she no knowledge that any Will existed, and only learned about it because they were contacted by Greg McConnell, Tiffany’s lawyer. Now Tanja claims to have known about the Will prior to her first Application! Now Tanja says she was under the impression it had been revoked, and now confirms that it has in fact been revoked by Tiffany, yet Tanja intends to administrate the Estate ‘according to the Will’ because she has ‘no reason’ to believe the Will is not valid?
Does any of this make more sense to a Judge than it does to Sean? If Tiffany revoked the Will, then why is Greg McConnell still retaining the file if he was never officially retained by Tiffany? How did Greg know Tanja had been awarded the Certificate if there is no public Record of Tanja’s appointment and Joachim Heinrich von Dehn is still ‘unrepresented’ on the Court Registry? It’s not Tiffany’s lawyer, just a lawyer with a Holograph Copy of a revoked Will conspiring with opposing counsel to Keep this Estate Matter off the Record to hide the Claims waiting to proceed against it:
This is the real reason Tiffany Singh’s copy of a hand Writ Will is revoked – Tiffany Singh has caused $3 million in damages to the Estate, and Will be required to address the outstanding debts before she can receive any Benefit from the Estate. This is why Tiffany Singh is unfit to Give any opinion whatsoever until she explains the three million dollars in damages she’s responsible for.
This is the same reason Tanja is not filing her documents with the Court and why none of the documents sitting at the Bracebridge Courthouse have been ‘processed’ yet. It has nothing to do with covid delays, it’s fraud with intent to interfere with the judicial process to hide the assets from other credits, only One of which happens to be Sean.
And they Wonder why I did not Wish to waste My time responding to 253 more pages of a continually evolving Story? This is absolutely typical of their contempt. Neil had seven months to prepare Tanja’s factum and she tells a completely changes her story three days before Sean’s deadline to prepare his Reply Factum?
So Sean was as King Erica Kapa if he would also be provided with and additional four days to prepare his materials after being ambushed with the new Story.
Of course, they expect Sean to provide enough Grace and Courtesy to accept their doucments four days late, but they can’t even reply to let Sean know if they Will provide him with same.
Sean decided he Will use this opportunity to see if he can also find out why Tanja has failed to produce any of the documents she was required to Sign off on to receive the remainder funds, and to ensure that Noah Potechin for the National Bank had an ETDL appointed before proceeding with the sale of the home.
Sean believes National Bank is at the heart of the fraud because they had the greatest motive to Keep the Estate off the Record so that they wouldn’t have to compete with the insurance claims in Court.
Sean also finds it suspicious that Tanja produces a monthly bank statement but not the transfer showing when the funds were received. Sean also finds it suspect that Tanja has deposited the funds into an account registered to 83 Winston Crescent because (to the best of Sean’s knowledge) neither Tanja or Michael live at that address, and Sean has no Idea who does.
Sean waits a day for Erica to reply and follows up to let Erica know that these are important questions that are time sensitive.
We Will see how long Sean waits to hear back from Erica, or if she even has the decency to respond at all…
Well, it’s now 5:03 PM on the eve Sean is required to have his documents prepared, served and filed with the Court. After as King Sean to accept documents four days late, Erica does not even respond to Sean’s request for additional time to respond.
Sean follows up one more time to let Erica know what documents he Will be requesting to support the allegations Tanja has made in her Affidavit materials, and advising Erica that Sean considers this behaviour contempt of Court and Will be producing these email requests in support of a Motion for Contempt.
And finally Niel replies to say he can’t offer Sean an extension because he doesn’t have the authority to offer extensions. So then why would Neil be as King Sean for one, expecting him to receive documents late?
So I guess the first factum is Tanja’s ‘actual’ Truth – Neil insists it does not make any difference to his Motion or Tanja’s Story, so I guess We can choose whatever version of facts is most convenient for Neil and Tanja in the moment.
Until then, Sean Will continue war King on the rest of his materials as best he can.
Summary of Facts:
- The Moving Party’s own testimony Shows that every requisition Hala made to the Court was made in violation of Rule 1.09 and a direct Court Order advising Hala that Sean’s consent is required for any Application to proceed.
- Hala Tabl served Sean with an unfiled application on March 24th, 2022, along with the Woodley Endorsement to Tanja’s previously withdrawn Application insisting that ‘Tanja was of the belief’ that the Endorsement is binding on Tanja’s new application, which was three times the Value. They told Sean that no further hearings or Endorsements were required or forthcoming
- Sean replied and advised Tanja that she was wrong and that her lawyer is engaged in fraud. Tanja (and Hala’s) opinion that an Endorsement is binding upon an Application Woodly hasn’t seen yet, is (clear and obvious) fraud
- To this day, the Court has no Record of Tanja Johnson or any other person being appointed by the Court to Act as the Estate Trustee for Joachim Heinrich von Dehn
- There are three million dollars in outstanding Claims waiting to proceed against the Estate whenever a Trustee is duly appointed by the Court.
- No ETDL was appointed by the Court by the National Bank to enforce their power of sale on the mortgage.
- No One was appointed to Act as Estate Trustee until at least November 7th, 2022, so any legal action that took place against the Estate prior to that date was perpetrated in fraud to hide assets from creditors without any judicial oversight.
- The National Bank has been conspiring with Tanja and Michael to sell the house under power of sale, telling them no application (for CAET) is required because Tanja and Michael are the majority share holders. National Bank had motive to Keep the application off the Record so they would not have to compete with the $3 million in insurance claims (still) waiting to proceed.
- There was never any intent to file or ‘process’ the Application, the entire production was just to convince Sean that Tanja had been duly appointed.
- A Trust (by any name) is a legal and lawful entity, effectively legislated by the Trustee Act of Ontario – any suggestion to the contrary by any so-called legal ‘professional’, is nothing less than an attempt to gaslight and demoralize its Trustee
- Application of the Act:
“this Act applies to all trusts whenever created and to all trustees whenever appointed.”
Trustee Act of Ontario
Issues, Law, and Analysis:
Sean is still trying to figure things out but now believes that Tanja received the remainder funds shortly after the house was sold under power of sale and before Christmas, 2021!
Sean wrote Tanja and Michael over Christmas to tell them how furious he was about the bank selling the house under power of sale without first having an ETDL appointed to represent their father’s Estate and its intended Beneficiaries in Court. Sean told Tanja and Michael that especially because We know the bank has first hand knowledge of who the intended Beneficiaries are and how to reach them, the bank had a legal duty and obligation to immediately let the Beneficiaries know there are remainder funds available (or deposit them with the Court)! Sean told Tanja and Michael that the Actions of the bank are criminal and that they had no legal right to do anything without having an ETDL appointed by the Court, and if Noah (lawyer/liar for National Bank) tries to tell them otherwise, he is lying to them.
Sean earnestly Promised Tanja and Michael that he’s never had any intention of Claiming the entirely of the Estate to him Self, only his Supreme Claim of right to Act as Trustee so that he can Honour the Promises he had made to his Father to protect the Estate assets for whomever their Father had named in his Will.
Sean also Promised Tanja and Michael that he would place the bank on Notice in the New Year, and Demand they provide disclosure of the power of sale and remainder assets available to each of them.
Sean also provided each of them with a copy of the Trust Declare-a-Sean, Showing that each of them were named Beneficiaries of the Trust, and that Sean has a duty and obligation to Act in their best interest. Sean Promised to follow up with a Claim against Noah if he does not respond to Sean’s Notice and Letter of Demand.
The bank sold the house in late August or early Septemeber and failed to contact any of the Beneficiaris to let them know (allegedly). No One had heard from the bank at all since November of 2020! When Sean was as King Tanja and Michael about this, they told Sean that because no One was appointed as Estate Trustee, they presumed the house would get sold under power of sale and the remainder funds would just evaporate. No One was going to get anything because Sean won’t consent to Tanja’s Application, and Tanja and Michael won’t consent to Sean’s.
Sean placed the bank on Notice January 1st, as he Promised his brother and sister he would do, carbon copying them on the Notice. The bank responded to disclose Noah was holding remainder funds in the amount of three hundred and six thousand dollars (approximately, $306,000) remainder funds with the letter included in the evidence Neil Presents in his Motion Record today.
As far as Sean knows prior to this, Tanja and Michael had abandoned their interest! They both seemed to think it was absolutely fine for the bank to take everything without any One ever being appointed to represent their father’s interests in Court! Neither Tanja or Michael seemed to have any concern whatsoever and believed they were getting nothing (allegedly).
Noah says he Will release the funds to whomever is appointed a Certificate by the Court, and advises that if they don’t make an Application within twenty-eight (28) days, he Will desposit the funds into the Court. Perfect.
Sean tells Michael that’s exactly what they Wish for Noah to do because he Will not be able to do so without the required paperwork to Show he had a Trustee appointed before moving foward with power of sale. Noah doesn’t have the required doucments because he’s guilty of fraud and several other crimes.
Sean is as King of Michael to Trust him, wait out the twenty-eight days, let Noah deposit the funds into the Court, just to see if he can. At least that Way they know the money Will be distributed fairly. A Court is one of the most secure places to store the money until some One is duly appointed.
If Noah failed to follow through on his threat and doesn’t deposit the funds, Sean was as King of Michael to support his application so that he can receive what’s available, Promising to follow up with a Claim for damages for the unlawful sale of the property, the irrevocable economic harm that was done to the property, and for the emotional and economic harm done by Noah’s interference and lack of judicial oversight to the Estate’s intended Beneficiaries. Michael said he thought that sounded like a Good Plan.
Michael also said he had not heard much from Tanja since the first application, and said that to the best of his knowledge, she had no intention of making another Application. Sean told Michael that was Good to hear because Sean was anticipating that if Noah can’t deposit the funds, he Will solicit Tanja. Sean told Michael it’s because Tanja doesn’t know what’s required in the Way of receipts necessary to receive the funds, and whoever Signs off on them Will be liable for the unlawful sale.
Sean was as King of Michael to Trust him and support his application if Noah doesn’t deposit the funds, Michael said that he would.
Less than a week later, Tanja calls Sean as King him once again to support her application, advising Sean she has obtained Michael’s consent.
Sean was furious and articulated the matter in an email as follows:
Sean now believes that Tanja received the funds long before the fraudulent Certificate was produced. Tanja never had any intention of making an Application to the Court for a CAET. The whole purpose was to convince Sean that she had, so she would have reason to be in receipt of the remainder funds. Sean believes Tanja already had the money and that he would never have heard another Word about it if he did not file this Claim on behalf of the Trust.
The National Bank of Canada Wished to Keep the CAET Application off the Record so they would not have to compete with other creditors with Claims against the Estate.
Singh, is Tiffany. This is also why Tiffany can’t make an application without answering to this Claim. Sean is curious to know if Tanja Will be taking on this Claim for Tiffany, too.
To suggest that Tanja now believes the Hand Writ Will Presented by Tiffany Singh is legal and binding, while refusing to acknowledge that Sean’s Hand Writ Promise to Honour his Father is even worth consideration by a Court is cruel.
The fact that Michael found this document on the property, proving that Sean had made Promises to his father and kept his knowledge of it Secret from Sean and the Court, suggests Michael knew damn well it was a Testamentary Instrument and was only keeping it from Sean to blackmail Sean (threatening to destroy the letter if Sean makes an application), and to withhold information from Sean necessary to support his own application.
Sean had to place Michael on Notice, demanding $20,000 if Michael had destroyed the letter, and if it is not in Sean’s mailbox within two weeks.
Sean immediately sent a copy to Hala for Tanja, advising that Sean had a Testamentary Instrument on Record that he Wishes to Present to the Court. You Will Notice Tanja makes no mention of Sean’s Letter.
These lawyers seem to believe that their Word is God. If Tanja believes a document is binding, Tanja believes that makes it so – it doesn’t. It makes a document contentious which requires adjudication and a hearing.
Tanja and Michael knew that both Sean and Tiffany had Testamentary Instruments they Wished to Present to the Court in support of their Application. Tanja and Michael kept this information secret to protect their own Self interest. At no time has Tanja Johonson been Acting in any Way that ‘benefits’ any One but her own Self.
Tanja ‘exiled’ her father and brother from her life, saying she Wishes for each of them to know nothing about Tanja’s Life, yet the moment her father dies, she Wishes to be Trusted with his Estate, and to Act in the best interest of a brother she hates.
Michael knows Tanja is a manipulative, emotional bully with a vendetta against her brother and father. Michael as King Sean to Trust some One he knows harbours resentment for Sean and his father, was unfair. Harassing, intimidating, and coecing Sean to Trust Tanja after he said no, is emotional abuse.
If Sean had Given his consent, he could only Give it under duress and protest as he was coerced, intimidated, and emotionally and economically bullied to comply. That’s not consent, that’s sibling abuse.
Perhaps one of the biggest lies of Hala Tabl and Niel Milton, is that they are lawyers representing Tanja Johnson – they’re not. Milton’s Estate Law was retained by Merovitz Potechin LLP of National Bank to solicit Tanja Johnson to keep the Estate off the Court of Record. Milton’s Estate Law is paying their Self from the Estate and was never retained by Tanja Johnson, they are vultures preying on her greed and were never Acting in Tanja’s best interest – they were coercing Tanja to engage in their fraud.
Order Requested:
Sean is requesting exactly what he was as King for in the Rule 21 Motion. Under Rule 37.13, any Motion may ‘in proper case’ be converted to a Motion for default against the moving party.
Sean Will be as King for default Judgment to be awarded against the moving party in accordance with the terms and conditions of the Reply Factum from the Rule 21 Motion.
All parties are jointly and severally liable, as they are conspiring together to knowingly perptrate fraud on the Court. Every single document Hala claims to have filed with the Court, is a testimony of perjury. Every single document Hala presented to the Court, and every meeting Hala had with agents of the Court, were submit or made in violation of Rule 1.09, without the consent or knowledge of any other party with an interest in the outcome of the proceeding, and with criminal intent to interfere with Justice, and to prevent Sean’s testimony and documents from being heard in the fraudulent Application.
All parties were duly placed on Notice of civil and criminal liability, none have responded or provided any lawful excuse or legal arguments for their criminal Acts. They were advised that failing to do so, would result in a Motion of contempt of Court and criminal prosecution.
All the applicable Laws, Rules, codes, statutes, and relevant Acts have already been cited in the Reply Factum that provide for this Court to award default judgment against the defendants in accordance with the Trust Instrument and Canada’s Criminal Code.
Although the Trust protects Tanja and Michael from criminal liability, if they do not concede to their fraud, apologize to Sean, and accept the very generous terms afforded to them in the Reply Factum, Sean Will be as King to have the powers, rights, and immunities of the Trust revoked for the purpose of criminal prosecute-Sean as stated in the Reply Factum.
Sean Will also be as King for all the lawyers to be charged with contempt for their continuous attempts to gaslight a Trust and its Trustee, pretending they have no idea what a Trust is, and or what legislation Trust Law is governed by.
All participating firms are jointly and severally liable for the full commercial value of the claim as of September 7, 2023, including all applicable interest.
Sean Will also be as King for costs equal to what the Moving Party is as King for from Sean, multiplied by three. Sean is one Man defending his Honour against a total of five powerful law firms, (Miltion’s Estate Law, Rosen Sack, Miller Thompson, Merovitz Potechin, and Fleury Comery) responding to hundreds of hours of legal and lawful arguments, alone.
Sean does not have secretaries and legal assistants, Sean is war King three times as hard, and believes his time and Energy is equal to at least three times the amount spent against him.
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