Court File No.: C-1290-03
I, PETER RINGROSE, of the Township of Wellesley, and Province of Ontario, MAKE OATH AND SAY AS FOLLOWS:
1. I am one of the plaintiffs in this action and as such have knowledge of the matters hereinafter deposed to.
2. I am the executive director of the Children's Aid Society of the Regional Municipality of Waterloo also known as Family and Children's Services of the Waterloo Region.
3. On Thursday, January 27, 2005, Mr. Justice Reilly granted to me and to Mr. Duane Boles, the other plaintiff in this action, a permanent injunction restraining Aneurin Ellis from publishing, circulating, distributing, communicating or otherwise transmitting libelous or slanderous words or allegations against the plaintiffs or the Children's Aid Society of the Regional Municipality of Waterloo also known as Family and Children's Services of the Waterloo Region or any of its staff members. A true copy of the judgment which was granted in the presence of Mr. Ellis is attached hereto as Exhibit "A" to this my affidavit.
4. A true copy of the reasons of Justice Reilly given in the presence of Mr. Ellis is attached hereto as Exhibit "B" to this my affidavit.
5. On or about June 20, 2005, I became aware that Mr. Ellis had, on or about the 8th day of June, 2005, sent an email to the Prime Minister referring to the Family and Children's Services of the Waterloo Region as the "Children's Gestapo (FCSWR) of New Berlin (Kitchener)". In that email, he alleged that Family and Children's Services had subjected his family to "criminal harassment" and compared Family and children's Services to "La Cosa Nostra". In that same email, he alleged that the Family and Children's Services operates in complete secrecy very much like the German Gestapo during the Second World War. In that email, he also alleged that Mr. Kevin Chalk, who is the president of the board of directors and a police officer were guilty of illegal activity and suggested that his actions were similar to that of the Nazi Gestapo.
6. Mr. Ellis has falsely suggested that I am the executive director of an organization with operates in complete secrecy very much like the German Gestapo and, further, suggests that I, in collaboration with Mr. Chalk, are in charge of a "very secretive charitable organization with power to enter private residence without warrant and apprehend without court order, create a situation that is unbearable, oppressive, and conducive to corrupt and criminal abuse of power and authority of otherwise a legitimate and democratically elected government".
7. He further suggests that the arrangement between me and Mr. Chalk has "lead (sic) to unchecked abuse of his family and countless other families in the Region".
8. I consider these statements false, defamatory and a flagrant breach of the injunction granted by Justice Reilly on January 27, 2005.
9. A true copy of that email is attached hereto as Exhibit "C" to this my affidavit.
10. I was advised by a member of my staff that Mr. Ellis was handing out the documents which are attached hereto as Exhibit "D" to this my affidavit at the Frederick Street court house on July 26, 2005. All of the derogatory allegations set forth in Mr. Ellis' emails are false and untrue and I am offended by them.
11. I make this affidavit in support of a motion to find Mr. Ellis in contempt of the judgment of Mr. Justice Reilly and for no other or improper purpose.
/signed/ PETER RINGROSE
SWORN before me at the
City of Waterloo, in the
Regional Municipality of
Waterloo, this 8th day
of August, 2005.
A commissioner etc.
Kimberly Ann Anger, a Commissioner, etc.,
Regional Municipality of Waterloo, for
Keller & Morrison, Barristers and Solicitors,
Expires September 6, 2005.