February 11, 2006
CONFIDENTIAL
SIRC File No. 1500-230
Hon. Mr. Gary Filmon
Security Intelligence Review Committee (“Committee”)
Via Facsimile (613) 990 5230
Toronto, ON,
Dear Chair:
1. This is my closing submissions. In this document “Service”” means: CSIS’ Directors,
Mary Mardall, Richard Stewart, and CSIS’ employees who obstructed fling of my complaints.
2. I filed with Committee my complaint against Service’s director, and its members Mardall
and Stewart. I testified against them. I filed 36 Exhibits. Committee and Service filed Exhibits too.
In this paragraph, I am relying in all said documents for your investigation and decision.
3. The First Point in my complaint is that Service did not had authority to conduct an interview with me on September 5, 2002 in the process of my application for citizenship under Section 19 of
the Citizenship Act, as Mardall emphasized in her unlawful interview.
The Second Point is a series of the Crown and CSIS’ wrongdoings and crimes against me that I disclosed them in the records such as misconduct, conspiracy, unlawful interception of my private communication, fraud, forgery, perjury, contempt, assault, sabotages, imprisonment etc.
4. In this document in reference to the Citizenship Act, CSIS Act and the Federal Court Act,
“Section 2” of said Acts requiring a professional interpretation to recognize the soul of law.
5. First Point: on August 8, 2002, the Citizenship Counselor Eve Buday send a letter to me
and requested an Interview for September 5, 2002 at Ministry of Citizenship; Nourhaghighi-12.
The legal words in this paragraph are:
a. Ministry of Citizenship (“CMI”) governed by the Citizenship Act.
The Federal Court has authority to review a complaint against CMI under Sections 14 of
Citizenship Act. However, the Federal Court is losing its jurisdiction IF the Committee
exercises its authority under Section 20 of the Citizenship Act [Appeal would be dismissed].
The Second Point is:
Whether MCI and Service attempted to abuse Sections 19 and 20 of the Citizenship Act to impair the authority of the Federal Court under Section 14 of Citizenship Act; or, attempted to abuse the authority of the Committee under ss. 19 & 20 for improper purposes against me?
IF the answer is the affirmative, then CSIS, Mardall, and Stewart have
committed the crime of the Contempt of Court under Rule 466(c) of the Federal Court
Rules and trespass the authority of the Committee under ss. 19&20.
The administrative words in this paragraph are:
a. What are the skills, training, duties, and jobs descriptions of a Citizenship Counselor
in contrast with same as CSIS’ employee Mardall as the Security Screening Investigator?
b. What are the elements of an Interview held by Minister of Citizenship in relation with
application for citizenship under Section 5 of the Citizenship Act in contrast with
interpretation of the Security Assessment under Sections 2, 13, and 15 of the CSIS Act?
Whether MCI and Service attempted to abuse legal and administrative definitions of
“Interview” “Security Assessment” “Security Screening” “Security Screening Interview”
“Citizenship Counselor” “Security Screening Inspector” for improper purposes against me?
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I was the employee of the Government of IRAN. I have knowledge of specific job titles. The fact that our governmental correspondences are emphasizing in ‘job title’ is transferring two points to citizens: a. your matter has handed by a professional; b. and within her/his jurisdiction. Canada is spending taxpayers’ money for its servants’ Business Cards for the said reassurance. Mardall and Stewart did not give me their business cards at the interview, nor did they disclose any document at the hearing that clearly identifying their jobs titles under which they had employment on ‘September 5, 2002’.
6. On September 5, 2002, I was shocked when CSIS conducted unlawful interview with me
instead of the ‘Citizenship Counselor’ Buday. I immediately asked Mardall and Stewart for their authority for conducting an interview with me. I complaint, filled affidavits, and testified that
Mardall stated “Section 19 of the Citizenship Act.” I demanded for excerpt of s.19. Mardall and Stewart refused to give me. They were at the Ministry of Citizenship and I am positive if they would ask for it, MCI would give them a copy. I testified that I reviewed s.19 before attending to MCI; therefore, I had trust that CSIS did not had jurisdiction. However, Mardall and Stewart misconduct with me and by harassments and abuse of office have unlawfully kept me locking up for more than three hours and half and invited my privacy for which you heard the particulars.
PROOF# 1: On November 21, 2005, “Service” Mardall at the commencement testified that:
CSIS Mardall: …One aspect of that is a security aspect. Under Section 19 of the Citizenship Act
that allows Citizenship to request CSIS to do a Security Assessment on the Applicant---
re: Transcript of Nov 21, 2005, p. 379:20-24
PROOF# 2: On November 22, 2002 “Service” Stewart testified that:
CSIS Stewart: With respect to the Citizenship Act, the Nourhaghighi matter is I believe the only
Citizenship Act, Security Assessment that I have been involved […] p.815:1-4
Mathieson: I would ask you look at Section 19 of that Act and specifically subsection (2) thereof
...WITHOUT reading IT LOUD or anything like that…what your understanding is...
CSIS Stewart: I believe the content of that legislation is that we [Service-CSIS] would be looking
To someone who might be a Threat to the National Security of Canada
re: Transcript of Nov 22, 2005, p. 815:1-17
PROOF# 3: On November 22, 2002 I cross examine the “Service” Stewart who testified that:
Complainant: Do you admit that CSIS does not have authority under section 19 of Citizenship Act?
CSIS Stewart: No. […] p.890:1-7
Complainant: …Please read it [s.19 of Citizenship Act] up to the words of “review committee”
CSIS Stewart: WHERE MIGHT ONE FIND THAT WORD?
Chair: It is the end of subsection (2) of 19.
CSIS Stewart: All right, I read it.
Complainant: …Is it correct that Section 19 of Citizenship Act has been given authority only to
the Review Committee?
CSIS Stewart: I don’t agree with that, no.
re: Transcript of Nov 22, 2005, p. 893:2-15
PROOF # 4: On November 22, 2002, you as the ‘Review Committee’ stated:
Filmon-Member of Review Committee: …Section 19 authorizes Citizenship to request from
CSIS a Security Screening…
re: Transcript of Nov 22, 2005, p. 891:12-13
There is no doubt whatsoever that the authority under Section 19 of the Citizenship Act given only to the “Review Committee”. Proof # 4 indicating that you-as Review Committee err in law
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That was one of reason that I asked you to allow a member of the Committee with skill in law be hear my complaint to avoid these kind of error in the final decision. However, you refused and notified me that your statements as Proof # 4 is not your decision and your mind remind open.
7. Proofs #1-4 requiring the following definitions under and the CSIS Act be considered:
a. What is the meaning of “Review Committee”?
CSIS Act:
s.2: In this Act …”Minister” means the Solicitor General of Canada
s.2: In this Act… “Review Committee” means the Security Intelligence Review Committee established by
subsection 34 (1);
s.2: In this Act… “Service” means the Canadian Security Intelligence Service established by subsection 3 (1)
s.2: In this Act… “Security Assessment” means an appraisal of the loyalty to Canada, and so far as it
relates thereto, to the reliability of an individual;
s.2: In this Act… “threats to the security of Canada “ means (a) espionage… (b) foreign influence activities...
(c) activities…toward …of threat or use of violence or against persons or property for
the purpose of …religious …within Canada or a foreign state; (d) activities toward ….
covert unlawful acts...by violence… BUT DOES NOT include lawful advocacy, protest,
or dissent…
s. 3(1) the Canadian Security Intelligence Service is hereby established of Director […]
s. 13(1) Service may provide security assessment to departments of the Government of Canada
s. 14 The Service may
(a) advise any minister of the Crown on matters relating to the security of Canada;
(b) provide any minister of the Crown with information relating to security or criminals
activities, that is relevant to exercise of any power or the performance of any duty or
function by that Minister under the Citizenship Act or the immigration Act.
s. 15. The Service may conduct such investigation as are required for the purpose of security
assessments pursuant to section 13 or advice pursuant to section 14.
s. 34(1) There is hereby established a committee, to be known as the Security Intelligence Review
Committee…[…]
s. 38. The functions of the Review Committee are: […]
(c) to conduct investigations in relation to
(i) complaints made to the Committee under sections 41 and 42;
(ii) reports made to the Committee pursuant to section 19 of the Citizenship Act […]
Further section 19 of the Citizenship Act for the definition of “Review Committee” and “threats to the security of Canada” referring to the CSIS Act:
s. 19 In this section and section 20 “Review Committee” and “threat to the security of Canada”
have the meanings assigned to those expressions by the Canadian
Security Intelligence Service Act.
s. 19(2) Where the Minister is of the opinion that a person should not be granted citizenship under
section 5 ….because there are reasonable grounds to believe rgar person will engaged in
activity (a) that constitutes a threat to the security of Canada, or
(b) that is part of a pattern of criminal activities planned and organized by number of
persons acting in concert in ……
THE MINISTER may make a report to the REVIEW COMMITTEE. (3) …within Ten Days
After a report….cause a notice to be sent informing the person…(4) …Review Committee
Shall investigate…(5) The Review Committee shall AS SOON AS practicable ….send to the person …statement summarizing such information available to it …(6) The Review Committee shall .make a report…
s.20 (2) Where a person is the subject of a declaration under subsection (), any application that has been made by that person under section 5 …is deemed to be NOT APPROVED and any APPEAL made by him under subsection 14(5) is deemed to be DISMISSED.
Therefore, the “Service” is not “Review Committee”; they have different functions.
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8. On March 26, 2002, Ottawa CSIS’ Director sent a “Secret Memo” to Toronto CSIS’ Director for a Citizenship Interview under Section 19(1) and (2) of the Citizenship Act; while
the Secret Memo’ heading was relying in any authority under the CSIS Act.
SIRC Book of Documents, Tab 8, p.8
9. Further, the Secret Memo was asking for a Citizenship Interview. Firstly, there is no authority for a Citizenship Interview by CSIS otherwise that term had a definition under s.2 of the CSIS Act. Secondly, there is no provision for a Citizenship Interview by CSIS in any sections or subsections of the CSIS Act in particular in ss. 13, 14, & 15 or such term had a place in the CSIS Act, as the member complaint against, Mardall and Stewart were emphasizing.
10. Furthermore, the Secret Memo at is second page has info indicating that the Federal Court asked the RCMP to do a Security Assessment against me. PROOF#1-2 are indicating that Mardall and Stewart in their testimony also have used the legal term of Security Assessment. ss. 13 & 15 of the CSIS Act allowing the Security Assessment against a particular servants of the government who must have access to certain office or documents. You-as the Chair of Committee, confirmed this issue. re Transcript Nov 21 /05, p485:2024.
11. PROOF # 5: The member complaint against Mardall testified that had authority under s.14 and put the whole text on the record. re Transcript Nov 21 /05, pp.484, 485
Section 14 has instructed that: “Service may ADVISE to Minister”. The synonyms to the word of “Advice” at Microsoft Word are opinion, counsel, recommendation, and guidance. However, the synonyms to “Interview” are meeting, dialogue, talk, conference, consultation, interrogate etc.
The synonyms for the word of Security are safety safekeeping, defense, refuge, protection etc.
The synonyms for the word of Security are safety safekeeping, defense, refuge, protection etc.
The synonyms for the word of Assessment are appraisal, evaluation, measurement etc.
Therefore, s. 14 is neither allowing a Citizenship Interview as Ottawa asked in the Secret Memo nor allowing the “Security Assessment”.
As I described it in the hearing, Section 14 of CSIS Act is similar to ‘One Way Road that cars are allowed only to move in one direction. The only way that the law allows CSIS to have any kind of conduct with an applicant for citizenship is that “CSIS forward Information to the Minister”
In the other word, Ottawa and Toronto CSIS were obligated to send the Secret Memo to the Citizenship. Section 19 of the Citizenship Act is also like the same “One Way Road” as the Minister has obligation to send it “Report” to the “Review Committee”. There is no legal road from the Citizenship to CSIS at all. The Ottawa Secret Memo alleging the Citizenship requested is fraud in nature that I discovered it today February 9, 2006, in which Ottawa CSIS is now liable under the Crown Liability Act too.
12. Both Service employees Mardall and Stewart had over thirty years experience as the police, and even Mardall stated that had some course in the University of Toronto. Therefore, both they had minimum education to have knowledge of the Citizenship Act and the CSIS Act which were related to their duties. Then, they had knowledge that what is the jurisdiction of the Review Committee under Section 19 of the Citizenship Act. Proofs#1-5 are master evidence that Mardall and Stewart, deliberately, made false statements under the oath that the Review Committee be mislead on its decision that: “Service erred in law, Mardall and Stewart have acted negligently in reviewing the law”. However, I am not seeking that type of decision otherwise since 2002 I would not waste my money and times, the taxpayers and the judiciary resources to achieve to it.
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13. The Minister of Citizenship had knowledge that must send its repot to the “Committee”,
under s. 19 (2)(3). Then “Committee” was obligated to obey s.19 (3)(6) of the Citizenship Act that under s. 19(3)&(5) I had right “To Be Informed” and “Reply”. No. No. This was not MCI and CSIS’ plan that I get chance “To Be Informed” and “Reply”. The Canada never held a hearing against me or for me that I have “Chance of To Be in Formed” and “Reply” contrary to section 11 of the Canadian Charter of Rights and Freedoms (“Charter”). My daughter who saw the Shiners’ List and execution of Jewish by Nazi, testified: “There was NOT permission for him to talk, to speak, or to express himself. So that was something that was VERY difficult to watch…
it was VERY MILITANT… Lots of officers and police, you know, that kind of atmosphere…VERY Negative.” This is Canadian Justice System in Century 21, with no distinction with Nazism court as a witness may express those sites with the Canadian Courts. Transcript June 24/05, p.16.
14. One of judges and prosecutors’ main complaints against me is that: “You are appealing our decisions” [Ontario Prosecutor Allan Scott on his testimony before Judge Lampkin Jan/97].
I testified that tens of my files were pending in the appellate courts when CSIS held unlawful interview with me, and as the result of CSIS’ malice, courts dismissed all my appeals.
PROOF#6: MCI, CSIS, and their parties intentionally have created ample fabricated evidence against me that the “Committee” exercises its power under s.20(1)(2) against me that I do not get chance of appeal under s.14 of the Citizenship Act. There is no doubt whatsoever that the Federal Court-Toronto (“FC”), CSIS, MCI, Transport Canada (“TC”), RCMP, and others have made ample fabricated information against me to make sure that I do not granted a citizenship.
However, CSIS’ crimes to impair the authority of FC constitute contempt of court. It is the FC authority to hear appeal, and other proceedings against MCI in relation to the citizenship matter.
The actins of CSIS’ Directors, Mardall and Stewart in bypassing our justice system and impairing its power are wanton and outrageous. We shall not allow anarchists govern our land.
15. Further, CSIS’ Directors, Mardall and Stewart have bypassed their own CSIS Act after they found that the Committee’s process is going to give me opportunity ‘To Be Informed’ and defend the allegations. 36 Exhibits that I filed with SIRC is a small sample of my good defence to satisfy the Committee that allegations under Section 19 of the Citizenship Act were pure accusations based on fabricated evidence. CMI, CSIS and their parties of conspiracy on March 2002 have discovered that with all evidence that I have it would be impossible for them to get a decision under s.20(1)(2) of the Citizenship Act against me by the Committee. Therefore, they planned to bypass the Committee too, which is outrageous, disregard of all my rights.
16. During testimony from Mardall and Stewart I tried to established that there is a difference
between Security Screening and its Inspector and “Citizenship Interview, Citizenship Counselor and Citizenship Judge”. I was Iranian Air Force Officer and I know that there is a distinction between “Security Screening Officer” with “Security Assessment Officer” as each officer having jurisdiction to access to certain data. I was trying to prove that by questioning from Mardall and Stewart that Mathieson objected as “National Security Issue”. I do not believe that is the case.
However, the Committee has power investigate that. CSIS may give both jobs to one officer. Yet there is difference from “Screening” and “Assessment”. Ottawa Secret Memo of March 26, 2002 addressed to the “Chief, Security Screening”. In the screening, usually each zone comparing its data with other zone. Further, the ‘Citizenship Interview” is the jurisdiction of a “Citizenship Judge” who has very limited area for asking the questions. The Citizenship Analyst Payette on his affidavit, paragraph 5 stated, “If the application is approved following the interview with the Citizenship Judge…” Nourhaghighi-9. And yet, Citizenship Counselor Eve Buday is liable for which must provide answer to FC for her letter August 8, 2002. Nourhaghighi-12
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17. THE FIRST POINT’S CONCLUSION: my answers to the questions in the First Point, by relying in on all said reasons, laws and exhibits thereto, are the Affirmatives.
18. THE SECOND POINT is the issue of the Crown’s Conspiracy against me since 1990.
I testified that Canada is second largest lands and its government extent from east cost to west, south to north, in this aspect I have a great respect to the servants of the government as they demonstrated standards in their conduct. I have directly pointed certain corrupt servants of the Crown in my complaints who mostly have jobs in few offices at west of downtown of Toronto. However, it is the corrupt servants’ tactic that generalizing my complaints to all servants of the Crown to get their sympathy and put a question mark on my credibility; this is their words that all Canadian Judges and Lawyers are corrupt to cover up the corrupt judges, lawyers and police who are engaged in smuggling of Heroin from Iran. It was after my complaints against them that RCMP and Police charged few judges, lawyers& police in Montreal and Toronto for smugglings.
19. The Committee should look to whole pattern of the Crown’s Conspiracy against me, all exhibits, and valuable information that has access to them [and I don’t] for your decision against CSIS’ members’ complaint against. Conspiracy is like a ‘marriage’ it needs a partner. Conspiracy has one cell; it was within the cell that the parties Mardall, Stewart, Buday, Payette, and others whose identities are known to SIRC made unlawful agreements and targeted me with malice, portrayed me in worst possible way. I know that I am not the person that they by fabricated evidence described me. I have obligation to prove CSIS’ Memos before you are all forged and Memos’ information are all fake, unlawful, and made with bad faith for objects of conspiracy.
Therefore, I have to go through the chronological facts in the period that CSIS was involved.
20. Nourhaghighi-1 is my affidavits of September 2000 against CHRC [Canadian Human Rights Commission], the Crown, Courts, banks, University of Toronto (“UofT”) and companies. Twelve lawyers represented them. My affidavits indicating the Federal Court (“FC”), Ontario Court of Appeal (“OCA”) and Supreme Court of Canada (“SCC”) committed forgery in the judgments and orders that shocked the law society. UofT created software for the Crown who trespass banks’ data and made fabricating NSF records against me. Sprint and Bell illegally allowed RCMP to intercept my communication. Transport Canada (“TC”) was involved in corruption of the Airline Transport Pilot License (“ATPL”) exams. During the hearing, I charged five lawyers for contempt. Justice Gibson ordered for affidavit that brought tears to the lawyers’ eyes. On January 19, 2001 FC-clerk, Mario SEPE did not obey Gibson Order and called RCMP [Royal Canadian Mounted Police] who assaulted me at the registry. I was admitted to the hospital. The charges dismissed in my absentia. I filed a complaint against RCMP for bribery which yet pending. RCMP and FC entered into conspiracy with the Minister of Citizenship (“MCI”) and CSIS.
21. . On December 2000 I gave my application for citizenship to Canada Post. I saw two males talked with staff and got my application. Since 1993 Police is stealing my mails from post, offices, and my home; forwarding to the Attorney General of Ontario (“AGO”) at 720 Bay Street, Toronto. AGO should make decision to what to do with my mail. In1995 I filed lawsuits against the Crown for thefts of my mails, even from Prime Minister and United Nations Offices by RCMP re: A-410-95. I traveled few times to Ottawa, solely, to file my documents due to said thefts; but AGO maliciously alarmed Police. My Privacy files show ample reports from Ottawa Region confirming my complaints that Police intercepted me. From August to December 2005, AGO obstructed SIRC service of documents to me, too
22. RCMP and CSIS intercepted my email nourhaghighi@hotmail.com and by forgery in my emails have created fabricated evidence against me to justify the warrant for the interception of my private communication. N#1: pp. 1,137 is a letter in Persian delivered to me from USA sent by my relative Senior Fighter Pilot Major… He wrote have created for you. I don’t know how I can be helpful?...If they blocked your Email, leave a message ... This is shame for Canada’s allegation of Freedoms
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23. Therefore, in 2001 I was watching the process of my citizenship application. Police obstructed my communications with MCI. Few times I went to MCI office that has inquiries’ lines. Firstly the staff denied that I filed application; later demanded my proof; I sent my receipt for registered mail. On November 2001 CMI-STEBELSKY sent email: No evidence that he’s applied for citizenship N#14, p.240/SIRC#7,p.4 This is my PROOF#1 that on November 29, 2001 the Crown trespass CMI’ data to not let the automatic action of computer such as “Application’s Time Elapsed” “Notice for Exam”…until other fabricated evidence to mislead CSIS be completed. N#14, p.2 indicating that finally data restored as December 6, 2000; Further N#14 indicating my original application was file in 1993 which was the pike to the federal government conspiracy against me; re: N#2, p.34, para13; p.104-5 Ministers’ Letters; p.163-171 My Evidence of Corruption in ATPL; p.190, 209:I PASS ATPL Exams.
24. In 2001 my son married on May. I and my daughter have sent several invitations for our relatives. MCI rejected to give any visa to our relatives. The Crown trespass Bell’s data ending my telephone services disconnected on April. The Crown committed sabotages in our air conditioning when we had guests from States; and did crimes during wedding such as my son was assaulted and injured, his properties were stolen at the same night of wedding. The Crown did not let my son get into the UofT Medical School and asked his professor to have the most abusive conduct toward him, and by their agents insulted to my personality to affect my son’s self esteem; solely as my son filed a complaint that the Toronto Police tortured me.
*The Iranian Civil Police during my prosecution against them for corruption in 1987 obstructed my son’s admission to a special school, and by telephone harassed us.
**The German Board has accepted the said grounds for granting me a Political Asylum.
25. On October 2001 after attack to WTC, the Crown and the Iranians’ Gangs asked from an agent in USA to sent $10,000 to my Scotiabank account. Then I got ambiguous call from my brother to transfer that money to Europe [Sweden]. The money was lost and there was a lot of communications on that issue. After September 11 banks were obligated to make a report to the Government on any transaction above $10,000. So, there were many transactions. From October 2001 to August 2002 banks breached all their privacy codes in dealing with my accounts. In sudden the banks commenced communications with me about my accounts, left details of my private information on my answering machine or in ordinary mail where I did not asked tem to do; or without cause called me and discussed issues that they never did since 1990. Chair promised to me to look to confidential info in my files: Please look for info by GM VISA Card, Scotiabank, TD etc in which the Crown’s trick was that banks gave me Cash for my GIC from one bank to another to satisfy the requirement of section 19(2) of the Citizenship Act ‘Criminal Activities’.
26. On November 29, 2001 CMI-Stebelsky made comment against my Web site from Tehran and wrote: “Given his outspokenness, perhaps he’d be interest to the Service or the RCMP”. SIRC#7,p.4 is my PROOF#2 that CMI was not sure of CSIS’ jurisdiction.
On December 17, 2001 Chief Judge Defendant Roy McMURTRY-N#33 breached s.11(d) of Charter and I saw McMurtry passed copy of my Web site to panel and dismissed my both appeals pending in court from 1997 against convictions by Judge V. LAMPKIN-N#33. RCMP dismissed my complaint and Federal Court of Appeal dismissed my appeal related to N#1 all in same day of December 17, 2001. On January 2002 the Ontario Human Rights Commission (“OHRC”) and then QHRC have dismissed tens of my complaints.
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27. Since 1988 the Crown’s misrepresentation caused me huge damages. For example, the authority for the oppressive and vexatious conduct of McMurtry CJO was the Judges Defendants Bigelow and Lampkin’s transcripts and judgments while AGO forged them to sound the said decisions were lawful. Nourhaghighi-13 indicating that my vehicle speed was ten k/h that Bigelow convicted me and suspended my driver licenses. Since 1982 I am single parent, Canada did not help my child and me any assistants. The driver license was the sole occupational license that I had to support my children. Judge Bigelow suspend it, to support Parsons-Toronto Police who was drunk; Nourhaghighhi-34. While Mardall and Stewart misrepresented the facts that I give them as “10 Km above limit, and brought the text of the criminal code for dangerous driving and false story about Iranian police” to justify Bigelow’s decision. Further, Judges McMurtry and Lampkin in 1996 were defendants in my action, re Nourhaghigh-33. Stewart told me “There was conflict of Interest, Lampkin in 1997 and McMurtry in 2001 could no make decisions against you as they were defendants”.
I regret that Stewart did not testify the same.
28 Two months after attacks to WTC, on November 14, 2001, CSIS and TC have created fabricated information against me to sound their actions lawful by wrongly alleging that I was “Former TC Employee…LEFT TC” SIRC#8,p.7. I testified that I never had any employment with TC. TC made fabricated evidence to justify CSIS’ jurisdiction under s. 13(1) of CSIS Act. If TC was furnishing correct information that I was an applicant for a license in 1993 then CSIS did not had jurisdiction. My PROOF# 3 is that TC and CSIS’ Director fabricated evidence that I was Former TC Employee to sound CSIS’ action lawful.
29. The said information by TC stating that: TC has an extensive file on Nourhaghighi which is available to CSIS requested that CSIS directly liaise with… later this week to obtain access to file.” My PROOF#4 is that if CSIS Director was not corrupt would ask for proof that I was ‘Farmer TC Employee’ as the Want of CSIS’ Jurisdiction. The following are the simple question that CSIS’ Director could ask from TC: When Nourhaghighi hired by TC? In which province he worked? What was his job title? How much was his salary? When he left TC? How many years/months he worked? Resigned or discharged?
30. There is no doubt that information on SIRC#8,p.7 are false and malicious “Disgruntled Former TC Employee…a former Iranian fighter pilot… maintains an anti-USA web site…left TC after he failed to obtain his commercial aviation pilot’s license.”
N#14 indicating my original application for citizenship was file in 1993. 1993 was the pike to the federal government conspiracy against me; re: N#2, p.34, para13; p.104-5 Ministers’ Letters; p.163-171 My Evidence of Corruption in ATPL; p.190, 209:I PASS ATPL Exams.
31. SIRC did not gave me an opportunity, contrary to ss. 48(2) &50(a)(c) of the CSIS Act, to complete my cross examine of Mardall and Stewart and call other witnesses to testify about document alleged generated by TC located at SIRC#8,p.7. In particular, you canceled SIRC Hearings scheduled for of December 13 and 20, 2005. While you were witness of out bursts by Mathieson and his harassment, intimidation, and abusive conduct. Mathieson, in accordance to plan of conspiracy was repeating “do not threat me; you have threaten me” as according to the section 183 of the Criminal Code police has authority to intercept my private communication. This is Toronto’s prosecutors and lawyers’ trick against me to cause unlawful interceptions just to not let my brothers, relatives, friends, or other people who want to have businesses with me to call me since June 2005; isolation and sanction is the Crown’s tactic.
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14. Further TC report contain destructive facts: “maintains an anti-USA web site…left TC after he failed to obtain his commercial aviation pilot’s license.” SIRC#8,p.7. I testified that I passed all exams for ATPL. However TC did not issue my aviation licenses due to my lawsuit; re N#33, and N#2, p. 6, 8, 104, 134, 138, 142, 168, 206-Pass; 209-%89 Pass.
I also testified that in 1996 I published my autobiography in the Internet and I titled it as “Testimony” to be considered like evidence under the Oath. I wrote my recollections of the massacres that I saw committed by CIA and Shah Regime in Iran. My biography was indicating the change of power to the Islamic fundamentalist was the Regime’s corruption, as the similar factors in Canada. The Government is organizing the poisonous propaganda against Muslims in many media, community and the judiciary system. I filed complaints and lawsuits against CRTC, Police and media for insulting to my religion. My complaint is yet pending before CRTC for the latest insults to Muslims from Iranian radio in Toronto. It is my concern that these kinds of organized hatred propaganda are harmful for our National Security. It is my faith that people having duty to care about our National Security.
I did my duty. I do not wish the religious war occurring in Canada, as the history recorded.
15. On November 14, 2001 TC sent the said fabricated info against me to CSIS and on November 15, 2001, a day after: “RCMP advised that they have a great deal of info on Nourhaghighi. Approximately six months ago, Nourhaghighi was involved in a Federal Court proceeding (nfi) and was noted to be violently animated. As a result, the Federal Court asked the RCMP to do a security assessment of Nourhaghighi. They assessed subject to be “mentally disturbed”. However, Nourhaghighi was not interviewed by the RCMP. They advised that an interview of Nourhaghighi by CSIS may be appropriate.
I as senior military officer do not see a great deal of info in the said info, even not a tiny info that concerns CSIS whose main mandate is protection of our National Security.
Further, where is the jurisdiction of FC, CSIS & RCMP under the Federal Court Act, CSIS Act or RCMP Act? The answer should be highlighted in the Chair’s decision by reference to the statute; SIRC#8,p.7. NOTE #1: This paragraph is the continuation of frauds by TC, FC, CSIS, & RCMP for the obstruction of justice; re: para # 2 & 8.
16. On February 14, 2002 I tried to send to SCC my application for leave against McMurtry’s Order by Canada Post; re: para#8. I saw those thieves who stolen my citizenship application, at the post office; re; para#3. So, I traveled to Ottawa by my car and filed my very important public and judiciary interest issue application with SCC.
My application contained prima facie evidence of forgery in transcripts, torture, perjury and other corruption in the Ontario Criminal Justice System for which Judges Lampkin, and McMurtry were liable. I had a great chance of success in SCC. I served the said application to McMurtry’s office who was concern the said materials not be filed with SCC.
RCMP installed spaying device “bug” in my car in Toronto that caused RCMP, Ottawa and Montreal Police to intercept and harass me. I heard the signals on cops’ radio. [In aviation we have a similar device using it to ‘locate pilots’ who ejected. I learned in Iran in 1967.] Many Police did not know what the signal was, stopped me and did strip search on me in Montreal that became ground of my complaint. Few ‘Dates’ that CSIS’ Privacy forwarded to me like ” DATE 2001 10 15 “and “Date 2002 10 04” indicate in my diary that I was at Montreal Eaton Center and University of McGill where their securities assaulted me have caused my prosecutions against them. AGO sent documents against me to Quebec Attorney General (“QAG”). I filed mandamus v QAG. My affidavits said they planned to mislead CSIS&MCI-even before CSIS get involve with me. I used my web sites’ documents over twenty judges and lawyers were shocked of smuggling of heroin by the Government.
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17. At the most critical time that the Crowns’ corrupted servants and parties did not had any hope, in sudden, on March 26, 2002 CSIS sent a Memo to its Toronto Director that is unlawful and breach of jurisdiction in each word at SIRC#8,p.7 (“Memo”).
18. The Memo has two pages; each page has about 30 lines in context in which most information are omitted in both pages. The Memo does not have the name and signature of a person authorized it and signs it, as the main requirement for the disclosure & Memo.
19. The Memo on its heading does not indicated under which authority has been issued. IF the Toronto Director had honor and dignity would returned the Memo instantly demand want of jurisdiction.
20. The Memo containing abbreviations “U ISS IMM”. I know IMM means Immigration. The first line says: “…enclosed a copy of the application for Citizenship submitted by the above individual…” It is the Chair’s to demand a clear answer from CSIS that:
A. What are the legal proofs of the duties of the Analyst U ISS IMM Citizenship Security Screening (”UISSIMM”)?
By the proofs I mean act, regulation, practice direction, rule etc that instructed UISSIMM has jurisdiction to conduct security screening on my Application for Citizenship under s.5(4) of the Citizenship Act. The absent of the proofs, will prove that such title UISSIMM was made up arbitrary to abuse the office and process.
B. The Analyst’s skills in March 26, 2002? Such as education, experience etc.
C. The Analyst and Head’s internal memos, emails, telephone messages on January to March 2002 for discovery of improper influences for issuance of such ridicules Memo which does not have any lawful justification.
21. The Memo in second paragraph asking for: “citizenship interview… to section 19(1) and (2) of the Citizenship Act.” And shockingly the Citizenship Act is underlined indicating the Toronto CSIS Director’s knowledge is as poor as its employees Mardall and Stewart that during three days scandalous testimonies admitted not having a basic knowledge and they have got salaries for over thirty years because they were just ‘White Canadian’ entitle to all kinds of benefits. Mardall testified that Buddhism, Christian, and even Jews must all OBEY the FATVA of Terrorist Bin Laden! Stewart after several times reading Subsections 19(1),(2)(3) of the Citizenship Act yet testified that: “Yes CSIS has jurisdiction under s.19 of the Citizenship Act and yet was not able to recognize the word of “Committee” and its meaning on the text. The Toronto CSIS Director certainly was worst in stupidity than Mardall and Stewart. The Crown’s trick is to assign stupid and/or corrupt parties on top to be able to abuse the offices. Otherwise, if there was not improper influence, the Toronto Director would say that did not have jurisdiction under section 19(1) and (2) of the Citizenship Act. The Chair several times, erred in law, erred in fact, and erred in law and fact, and with falsification stated that CSIS had jurisdiction under Section 14 and 15 of the CSIS Act, to justify the wrongdoings of CSIS and SIRC. Where is the proof in the Memo, as originating document, which authorized the interview? Or where is the authorization for Interview? Or where is the proof that Section 19 of the Citizenship Act has given jurisdiction to CSIS for interview? Or where s.14 &15 of the CSIS Act has given a jurisdiction to CSIS for an ‘interview’ with a ‘citizenship’s applicant’; the jurisdiction is between Minister and CSIS, NOT between the Citizenship Applicant and CSIS!
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22. The second page of Memo at SIRC Book of Documents, Tab 8, page 8, has five lines; then omitted info about 18 lines; and then a paragraph starting with underlined caution “Do not render a decision in this case. What is CSIS’ jurisdiction in making ‘Decision’ for me or against me an applicant for citizenship under s. 19 of he Citizenship Act or ss. 14 or/and 15 of CSIS Act? -None! There is no doubt that CSIS has misconception of the SIRC’ authority for itself. The law has give power to SIRC under ss.19 and 20 of Citizenship Act to make decision for or against an applicant for citizenship, not to CSIS. [re: CSIS#3, page 2]
23. The Memo is concluded by Please submit a detailed interview report…as soon as possible…Diary Date: 2002-07-26. I testified that one of the Crown and CSIS’ objects was to obstruct justice in SCC. On or about July 2002, SCC scheduled to hear my applications on September 5 and October 2002. Therefore the Crown asked the Citizenship to schedule September 5, 2002 for interview with me. At the same time, the Crown asked the Quebec Courts schedule few days in September 2002 to hear my mandamus application against judges and police who did crimes against me on February 2002. re; paragraph 16. It is important to note that at the same period, few files under nature of s. 19 of Citizenship Act were pending before the SCC, such as Iranian case of Mansoor Ahani v. Canada. I testified that Ahani was the Crown’s agent in furnishing info against me on December 11to 20,1996;
The Crown pretended Ahani deported like many Canada’s secret agents around the World.
NOTE#1: On July 1994 the Ontario Deputy Judge Defendant Palma Thomson made order that I prepare a list of all my legal proceedings that the judiciary be able to organize them. Since then an office by administrative order has power ‘to ‘set a date’ for all governments’ offices, courts, commissions, and board. The person responsible ‘to set a date’, maliciously, setting several dates in a short period that I do not get opportunities to reply properly. As the result, most of my files were dismissed due to failure to perfect them on time.
24. On August 8th 2002, the Citizenship Counselor Eve BUDAY wrote a letter and requests an interview with me on September 5, 2002, at 9:30 AM regarding processing of my Citizenship.
Buday asked for two documents only ‘record of landing and passport’.
During my testimony on June 23 and 24, 2005 before SIRC, I referred to Buday’s letter few times and I well recall that the Chair asked for my ‘proof’, initially it was hard for me to find it; however, finally I find it and show it to the Chair as the proof THAT:
A: The Citizenship Counselor asked for interview with me, not CSIS-Mardall or Stewart;
B- There was no reference to CSIS’ interview in Buday’s letter;
C- CSIS did not have any authority for interview;
D- CSIS conspired with the Crown and MCI in which details located at SIRC, Tab 8, pages1-6.
E- CSIS asked from officials in USA to obstruct refuse my trip in USA;
F- Citizenship asked for two documents; CSIS took my driver license, visa, pilot licenses etc.
Mardall and Stewart have failed to explain why they obtained the photocopy of all my documents containing my personal information and disclosing them to the CSIS’ report, alleging fraudulently that they were taken ‘for identification purpose’. In all government and civil offices in Canada officials examining the person’s IDs. Mardall’s Memo dated September 11, 2002, at paragraph #12 has full info of my driver license and mentioned in her Memo and testimony that I was anti American. Mardall testified and disclosed documents that ‘informed CSIS’ security for my approval at her office [re First page of attachment to SIRC Letter November 8, 2005]. CSIS, Mardall and Stewart intentionally, pursuant to object of a conspiracy with the Crown, portrayed me is such that USA officials refused to allow me to have a trip in USA on September 25, 2003. CSIS committed sabotages in my car to violate my Mobility Rights guaranteed under the Charter that since 2003 my car is inoperative. My lawsuits are indicating ample Crowns’ sabotages in my cars and airplanes.
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25. N#12 is Buday’s letter which is my PROOF# 4 that I had an interview with the ‘Citizenship & Immigration Counselor’ not with CSIS. The burden of proof is upon CSIS that in five steps prove to SIRC THAT:
A. the ‘Citizenship & Immigration Counselor’ had jurisdiction under the Citizenship Act to ask an interview with me as an ‘applicant for citizenship’.
B. In N#12 the ‘Citizenship & Immigration Counselor’ is asking for an interview for processing of my ‘application for citizenship’. CSIS must prove ‘what are the elements in the processing of an interview with a ‘citizenship applicant’ as the Citizenship Act and its Regulations have instructed.
C. CSIS must prove that the said powers that the Citizenship Act and its Regulations have given to the Minister of Citizenship and Immigration and to the ‘Citizenship & Immigration Counselor’ were transferable powers to the Minister of Solicitor General of Canada and to the CSIS’ Directors on March to December 2002.
D. CSIS must prove that the said transferable powers have justification under the CSIS Act, Directions and ss. 2, 6, 7, 8, 9, 10, 11, 12, 14, 15 of the Canadian “Charter” of Freedoms and Rights.
E. CSIS must prove that in its interview with me has obeyed the said laws and directions from the administrative stage to the interview conduct, and to its Memos, and Reports.
26. From February to September 2002, in sudden, I got few calls from the Crown, Police and Banks in which their conversations were breaching my privacy. I never had that type of breach of my personal information and banking business on the phone in which I filed numerous complaints against them. I noted that all said conversations were constructive and recorded by CSIS.
On September 2, 4, & 6, 2002, I had calls from the Toronto Police Constable Christen FARRELL.
I had never has such calls from police. Farrell was extremely rude with me. Police never investigate my complaint against Farrell and never explain why she called me on those three days.
However, Farrell calls was a clear indication for me that there would be a ‘conspiracy’ against me on September 5, 2002 at Citizenship. Therefore, I spend times in reviewing cautiously the Citizenship Act in which I was shocked its ss.19 &20. So I read the CSIS Act, F C Act and all other acts that they reference to them. I had rights that my application for citizenship be considered under s.5(4) of the Citizenship Act for torture and all hardship that I suffered and my extra ordinary contributions to Canada and Canadian in thirteen years legal fights against the corruptions of the Crown and Courts.
Therefore, up to 5AM on September 5, 2002, I worked on my presentation under s.5(4). I put this document as an Exhibit on the record. However SRIC did not provide me with its number.
27. I testified that on September 5, 2002, Police and MCI security harassed me. These kinds of harassments by police are known to me as one of the main elements that judges or investigators are considering an examination for mental health. This kind of constructive harassments by Government of Canada had the most harmful affects on my presentations, stress level, and fatal effect on short memory, mood, and concentration. It was before CSIS that ‘N mentally disturbed” SIRC#8,p8; or: N#7 “that he is mentally unstable”. Tens of police and securities are my witnesses that the Crown abusing police force in getting decisions against me. My daughter has given the best testimony in abusing ‘Police Force’ in the administration of justice and the Crowns’ offices as she witnessed in Defendants Police and Judge Lampkin trials against me: “.it was VERY MILITANT, seeming VERY MILITANT“. The Iranian Islamic Revolutionary Court held a trial against me in a period that everyday hundreds of oppositions were executed. During trial, there was no police or security in the courtroom. The prosecutor and judge were extremely polite and professional in comparing with Canadian judges and lawyers who were mostly crooks and extremely dishonest. During defense I stated: “God bless Shah, he never did injustice that Khomeini did against me!” However judge never used it as against me at acquitted me while Canadian judges used these kinds of evidence for convictions against me. Tens of Canadian judges, police and lawyers insults me, my religion and nationality in worst possible ways.
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The Witnesses’ Credibility
28. The Witnesses’ Credibility is one of the main mandates in this investigation. The Chair has promised to me to be impartial in his disposition: “I can assure you that my mind remains open as whether each of your allegations are supported” re: Filmon’s letter Nov 29/05, p.3.para2.
Four witnesses presented evidence under the oaths, me and my daughter, Mardall and Stewart; the Crown and CSIS’ Credibility are also the major part of SIRC’ mandate.
29. My credibility could be established by over Seventy Judgments, Orders, Summons that I got against the Crown and its parties in which few of them are in the record, such as Judgments against Ontario & Toronto Police at N #1 p. 61; against Canada at p.105; against CIBC at p.169; against tens of motions brought by fifty Crown defendants and their parties at p. 192; against the Crown’s party-Co-Op p.207; against the Crown’s party-Condo at p. 222 and at N#? at p. 25;
The most important facts in the Judgments that I obtained against the Crown and its parties are the judges’ expression and reasoning against them. AGO forced to forged few reasoning to avoid the Crown for liability. Such as Judgment of Ontario Provincial Judge Cadsby that I was in the court when he stated: “I am satisfy with Nourhaghighi’ testimony that Judge Lampkin and Follert-police have conspired against him to Torture him” re N#1, at p. 73, Para 45; or Cadsby PJ showed sympathy: “What happened in this case is very sad and very unfortunate” as objection to Torture, re p. 68 or Cadsby PJ had honestly to consider evidence “His tie which was torn as result of force. sat upon him by a court officer weighed 250 pounds” re p. 67; N#32, my tie as evidence of Torture before SIRC.
30. Further, FC Justice Campbell referred in his judgments to the conspiracy of the government and courts against me and other misconduct by them, re N#1, at p.106, para [4]. Judges Cadsby and Campbell both could render judgments against the Crown without specifically referring to the Crown’s wrongdoings and crimes. In that case, their judgments did not have any value for the public. I called them as brave judges, because they highlighted the Crown and Police crimes as the fact not accepted by the public and justice system.
31. Furthermore, in finding my credibility, judge Donnelly who had over fifty years experience as judge of Ontario Court clearly stated: “I making a finding of credibility I have really no hesitation in saying that the evidence of plaintiff much more credible than the evidence of Miss Lalonde…his manner in witness box is quite good…Now Miss Lalonde’s evidence is entirely different. I am not specifically saying that she deliberately lies.” Re N#1 at p. 208. On November 23, 24 and December 12, 2005 Mardall and Stewart “Deliberately Lied” to this Committee. This is a crime of perjury. It is the Chair and SIRC counsel having duties to make sure that their dishonestly are highlighted in the disposition. Mardall & Stewart by “Deliberately Lying” in the first instance have directly insulted to the ‘personal capacity and intelligent of “Gary & Emily”. Secondly, Mardall & Stewart by “Deliberately Lying” have insulted to the “Dignity of the Committee & SIRC” and to the “office capacity of “Filmon & Crocoo”. The Chair according to the law has only jurisdiction to forgive or close his eyes toward all insults to ‘his personal capacity’ and has legal obligation to defend the Dignity of SIRC & its process.
32. As against the Crown and CSIS incredibility I filed few Exhibits as countless documents that I have against them, re this document and Exhibits that I filed with SIRC. I reported against TC and its corruption at ATPL. TC own document indicating that my report was correct; re: para5; N#2, at p.164.
I complained that Ontario Judge Ian McNISH during trial has stolen my master evidence; N#1, p.205;
Judge Defendant Silverman, re N#1, p.151, arbitrary stated: “nor is there any evidence of any theft on the part of the learned Justice of Peace” p. 177:9. Silverman PJ exceeded his jurisdiction. He was not a trial judge to examine the evidence of me, ‘McNish’ and other witnesses in finding that if “Judge McNish’ have committed ‘Theft of Exhibit’ or not. Silverman PJ was appellate judge not a trial judge.
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33. Further, the Government of Canada by tortures, aggravated assaults, thefts, malicious prosecutions, wrongful imprisonments, transfer of all kinds of toxic to my home, food, drinks, and cars before trials, conspiracy with judges, prosecutors and police was able to obtain few orders against me which is a real shame for Canadian Justice System, such as conviction for dangerous driving for 10Km/h speed after police car rammed to my car and caused permanent injuries to me; N#1 p. 51-59, N# 13, 34&5; while Judge Cadsby, after trial and obtaining evidence from police offenders Edward Follert and Scott Stephens, found that police were involved in tortures and aggravated assault against me; the Toronto Police Complaint Review, Don Mantle, made decision I find no evidence to support the allegations you have made; re N#1, p.60; similar to SIRC’ decision of March 14, 2004 in my complaint against CSIS. The Crown’s evil soul wants to WIN a Case not to Serve a Justice. N#19 is my PROOF#5 that the Government has grown toxic mould and gases over my kitchen and since 1991 obstructing justice be served. It is important for the Chair to take a Notice that I and poor owners of my condo were forced by AGO to pay over $100,000 legal costs in 2004 in Ontario Court that FC dismiss my application against SIRC. In the other word the Lemieux Order against SIRC costs for ‘our condo’s owners and me over $100,000!
Furthermore, several hospital records indicating that since 1993 the Government of Canada using toxic gases against me I the courtrooms; re N#13&1-p.101 is the Ontario College of Physicians’ investigation for poison served to me in the hearing that I was taken with ambulance to a hospital.
According to the Canadian Conditional Act only a ‘Good Government’ has right to serve this nation.
I have evidence to prove beyond a reasonable doubt that the Government of Canada is worse than any Evil Government that ever history has recorded. Therefore, in 1994 I asked as political asylum from the United Nations, as I testified, due to the felonies of the Crown, Judges, Lawyers and Police.
34. I testified that all documents were forwarded to me pursuant to provision of the Privacy Act and I filed part of them as Exhibits with SIRC, re N7, 10, 17, 20 & 24. The crown retaliated against me and asked from all offices to deny my requests under the Privacy Act since June 2005; this is one of the damages that I suffered by testifying before SIRC; re Transcript of June 23/06, page 149: “So those CSIS records that Privacy has given to me, all these documents are there, and it is written”.
Further, since June 2005 my brothers in Tehran and friends in Toronto were all harassed by the CSIS and the Crown and Canadians’ secret agents in Iran. As the result, CSIS and the Crown fully isolated me from my relative and community; I got no call from them, and all my telephone calls were disconnected by illegal interception of CSIS and the Crown contrary to s. 50 of the CSIS Act.
” Chair: I take the responsibility seriously. That’s why we are here.[…] I think if we go into our own investigation, we have greater powers than you do to seek answers, SO WE WILL TAKE THAT UP.”
re Transcript of June 23/05, pp. 162 & 163.
35. On September 5, 2002, I asked Mardall & Stewart for authority. Mardall stated: “Section 19 of the Citizenship Act”. I complained, filed affidavits [T-768-03, p. 271:7] and testified that Mardall said s. 19. My complaint v. CSIS, my affidavits before FC in files T-768-03, & T-762-04 and my testimony all reads with CSIS’ document dated March 26, 2002, re para 17-23, re SIRC Tab 8, p.7 CSIS clearly mentioned Section 19 (1) and (2) of the Citizenship Act. On September 5-11, 2002 AGO has forged Mardall’s Memo-re N#3 and wrote s. 15 of CSIS Act. AGO asked Mardall & Stewart to testify the said story. On November 22, 2005 Mardall testified s. 15 of the CSIS Act as her authority [re Transcript Nov 22/05, p.681, l.17,18.]. Stewart repeated the same. Neither Mardall nor Stewart had any note except AGO’s forged Memo-re N#3 that was dated after the interview. My PROOF # 5 is that Mardall reviewed and had in mind CSIS’ Memo dated March 26, 2002 referring to Section 19 (1) and (2) of the Citizenship Act. Therefore, On September 5, 2002 in reply to my question relied on CSIS’ Memo and said “Section 19 of the Citizenship Act.” Furthermore, Stewart finally testified on December 12, 2005 that Mardall referred to Section 19 of the Citizenship Act. re transcript Dec12/05, p.1116:19-24.
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AS AGAINST AGO’S FORGERY IN CSIS-MARDALL & STEWART’S MEMO:
Chair: This is the KEY piece. So it will be a major consideration in my decision as to
whether or not I call the witnesses that you have asked for…So if you don’t make
your case tomorrow, then you run the risk of not having these people called”
re Transcript June 23//05, p.165
36. On June 24, 2005, I was successful to present particular for the crime of conspiracy as required by law to satisfy the Chair that AGO, CSIS, Mardall and Stewart conspired against me, and my files before the courts; that AGO committed “Forgery” in CSIS’ document that the Chair named it as the “KEY piece” and issued summons for Mardall and Stewart in which they have been named in the transcripts as “defendants”, “respondents”, and “Contemnors”.
Tour-mate Technologies Corp v. Syntronix System Ltd [1993] BCWLD 1082 SC
The Court held that the Plaintiffs met the standard of particularity which imposed
on a party prior to discovery, namely, that the Plaintiffs had alleged the conspiracy,
the overt acts in furtherance of the conspiracy and damages flowing as a result.
37. I testified that since 1992 AGO-720 Bay Street Toronto is committing forgery in orders and judgments, transcripts and official letter, trails and motions scheduling to satisfy its unlawful objects of ‘none judicial conspiracy’. My reviews of legal documents indicate that in Canada judges granting immunity for conspiracy arise out of the charge or purported discharge of responsibilities of a judicial nature. However, the Crown and judges’ conspiracy against me rooted to smugglings of Heroin from Iran which is fatal for our children and other felonies that the Crown and judges in Toronto and Montreal are making huge unlawful profits. There fore, I am named it as none judicial conspiracy’.
AMUNRO v. CANADA (1992), 11 O.R. (3d) 1, 98 DLR (4th) 662 (Gen. Div)
A former federal cabinet minister brought actions in conspiracy to injure,
malicious prosecution, abuse of process, negligence, breach of contract
and breach of fiduciary duty against, inter alia, The Queen in right of
Canada and in right of Ontario, the Attorneys General of Canada
and Ontario, and the Commissioner of the RCMP.
NELLES v. ONTARIO [1989] . SCR, 170, 49
It was uncertain if the SCC had determined whether the Crown in right
of Ontario would enjoy immunity from conspiracy to injure action where the conspiratorial
actions of its servants could be said arise out of the charge or purported discharge of
responsibilities of a judicial nature.
38. The Crown and courts have obligations to obey the Canadian Laws; one of the most basic rights of citizens recognized by Charter -s.11 is “To Be Informed” The Crown has charged billions dollars for costs of process just to make sure that the citizens “To Be Informed” of various issues, giving them chance to response. It is impossible that the Justice System make any decision unless a party satisfies a judge that the opposite party was “Informed”. This is the sole reason that our courts are holding millions documents titled as “Affidavit of Service” as proofs that the party was “Informed” of allegations. CSIS-Mardall &Stewart did not sent me any kind of notice, letter, or a simple call that “I Be Informed” that “CSIS” is going to have interview with me. Seventh Years continuous legal fights with the Crown has given me ample evidence to prove that whenever the Crown does not have jurisdiction is not going to issue any kind of notice, letter etc to the opposite party as its aware that subsequently such document would be used against it. For example: N#33, contain a defendant name as “David Travis-City of Toronto Employee who did not Informed me in 1991” at the commencement of interview I established he did not had jurisdiction. Travis was Toronto Police constable before and assaulted me. I charged him under the Criminal Code.
Dated in the City of Toronto, in the Province of Ontario in this 13th Day of February 2006
MAJOR KEYVAN NOURHAGHIGHI
Iranian Senior Fighter & Transport Pilot
Tortured by Toronto Police
Political Asylum Seeker as Canadian
The aforesaid is my official signature which has been recorded under large numbers of my filed documents
AUTHORITIES
February 9, 2006 in reviewing document I discovered additional evidence of fraud in the Secret Memo
And shockingly the Citizenship Act is underlined indicating the Toronto CSIS Director’s knowledge is as poor as its employees Mardall and Stewart that during three days scandalous testimonies admitted not having a basic knowledge and they have got salaries for over thirty years because they were just ‘White
8. I testified against torture and malicious prosecutions against me in Canada just to satisfy the Committee that the Crown had motive against me to subject me under section 19.
Nourhaghighi-4 [Transcript of December 11, 1996, Judge Lampkin]13, 32-Tie & Torture.
9. I testified against toxic mould and gases in my home, trespass of my banks, condo, and telephone accounts, intentional police accident with my vehicle, torture, aggravated assaults, constant unemployment to satisfy the Committee that the Crown had motive to cause a serious injuries to my children and me.
The “Criminals” that I am fighting with them since 1990 having in the most evil-minded servants of the Crown whose plans are “complex”. They caused countless legal fights between the Crown and it parties and me in which 36 Exhibits that I filed are less than 1% of documents that holding by the federal and provincials governments under my name.
Therefore, my answer to question in the First Point is the affirmative. I have also 100% trust to you and SIRC Counsel-Crocoo that would do all your best, to best of your skills and knowledge to discover better proofs for establishing abuse of
a. “Service” [Mardall] erred in law that Minister of Citizenship has jurisdiction under Section
19 of the Citizenship Act
Forged Memo on its heading is alleging “Authority; Section 15, CSIS Act” as reply to my objection at the interview. IF s. 15 of CSIS Act was the actual authority that Mardall was exercising her authority on it for many years; then the name of “s. 15 of CSIS Act” was in Mardall’s heart and at the beginning would refer to “Section 15 of CSIS Act”.
that on September 5, 2002, at the Ministry of Citizenship, I asked from CSIS for their authority to conduct an interview with me. Mardall stated” Section 19, of the Citizenship Act.” I asked from
5. On December 6, 2000, I filed application for citizenship. The Minister of Citizenship (“MCI”) informed me that its process would take about eight months. On 2001 the
4. I testified that on August 8, 2002I got a l
