Court File Number CV/06/33958

ONTARIO SUPERIOR CORT OF JUSTICE

BETWEEN:

Raymond Paquette, Plaintiff

-and-

CHILDREN’S AID SOCIETY OF THE COUNTY OF LANARK AND THE TOWN OF SMITH FALLS, Defendant

STATEMENT OF CLAIM

To:
CHILDREN’S AID SOCIETY OF THE COUNTY OF LANARK AND THE TOWN OF SMITH FALLS
8 Herriott Street, Perth, Ontario K7H 1S9
Phone: (613) 264-1500 Fax: (613) 264-0067
Lawyer for the Defendant: Ms. Nicky Edmundson-Mosher

Raymond Paquette (Plaintiff)
17 Cherly Road
Ottawa, Ontario K2G 0V5
Phone: (613) 228-0368

STATEMENT OF CLAIM
TO THE DEFENDANT’S

A LEGAL PROCEEDING HAS BEEN COMMENCED AGAINST YOU by the Plaintiff. The claim made against you is set out in the following pages.

IF YOU WISH TO DEFEND THIS PROCEEDING, you or an Ontario lawyer acting for you must prepare a statement of defence in Form 18A prescribed by the Rules of Civil Procedure, serve it on the Plaintiff lawyer or, where the Plaintiff does not have a lawyer, serve it on the Plaintiff, and file it, with proof of service in this court office, WITHIN TWENTY DAYS after this statement of claim is served on you, if you are served in Ontario.

If you are served in another province or territory of Canada or in the United States of America, the period for serving and filing your statement of defence is forty days. If you are served outside Canada and the United States of America, the period is sixty days.

Instead of serving and filing a statement of defence, you may serve and file a notice of intent to defend in Form 18B prescribed by the Rules of Civil Procedure. This will entitle you to ten more days within which to serve and file your statement of defence.

IF YOU FAIL TO DEFEND THIS PROCEEDING, JUDGMENT MAY BE GIVEN AGAINST YOU IN YOUR ABSENCE AND WITHOUT FURTHER NOTICE TO YOU. IF YOU WISH TO DEFEND THIS PROCEEDING BUT ARE UNABLE TO PAY LEGAL FEES, LEGAL AID MAY BE AVAILABLE TO YOU BY CONTACTING A LOCAL LEGAL AID OFFICE.

IF YOU PAY THE PLAINTIFF CLAIM, and $ 5000.00 for costs, within the time for serving and filing your statement of defence you may move to have this proceeding dismissed by the court. If you believe the amount claimed for costs is excessive, you may pay the Plaintiff claim and $400 for costs and have the costs assessed by the court.

Date: Monday, March 13, 2006 Issued by Local registrar, Ottawa Courthouse, 161 Elgin Street, Ottawa, Ontario

The Plaintiff claims:

  1. Punitive damages in the amount of fifty million dollars.
  2. Exemplary damages in an amount of fifty million dollars.
  3. Non-pecuniary damages to be accessed by a Jury.
  4. Intentional and malicious identity theft of the Plaintiff.
  5. Intentional and malicious brainwashing of the Plaintiff.
  6. Slander of the Plaintiff’s family sir names of Paquette/Kerr.
  7. Liable of the Plaintiff’s family sir names of Paquette/Kerr.

The Plaintiff says as a fact:

  1. The Plaintiff has the copies of these grooming-brainwashing tapes listed below and has viewed them as an adult.
  2. The Plaintiff claims as a fact the Defendant committed a knowingly and maliciously “GROOMING-BRAINWASING” of the Plaintiff when he was 4 and 5 years old and he was GROOMED-BRAINWASHED and recorded on five audio/video tapes by the DEFENDANT on November 20, 1991 at the Ottawa-Carleton Police Station and again on April 13, 1992 at the home of Margo Hunter who the Plaintiff was illegally forced to live with for 14 years without the loving affection of his mother Lorena Kerr and again on April 27, 1992 at the home of Margo Hunter and again on December 2, 1992 at the home of Margo Hunter and again on December 14, 1992 at the home of Margo Hunter as documented in the defendant case notes which hand written case notes the Plaintiff has and they are signed by Ms. Denise Unhola an ex-employee of the defendant.
  3. As required by law everyone must be identified who is at a video taping of a child that was not done in the Plaintiffs videotaping.
  4. The Plaintiff claims as a fact that there are unidentified persons on these videotapes who worked to groom-brainwash the Plaintiff with the Defendants and are, as seen on the videotapes, actively grooming-brainwashing the Plaintiff.
  5. Furthermore the Plaintiff claims as a fact there are individuals who are not identified standing outside of the camera lens orchestrating the grooming- brainwashing of the Plaintiff.
  6. The Plaintiff claims as a fact the grooming-brainwashing contamination as shown on these videotapes is one illegal criminal act of many documented criminal acts that caused the Plaintiff to lose his identity and his love and affection of his mother Lorena Kerr and father Marc Paquette and the defendants are responsible and accountable for their malicious conduct of grooming-brainwashing the Plaintiff which grooming-brainwashing continued for 14 years.
  7. The Plaintiff claims as a fact the defendant maliciously and without just cause adopted the Plaintiff at 10 years old in December of 1998 when the Plaintiff’s mother Lorena Kerr and partner Jack Hepworth were involved in a Ottawa “cas” children allegedly in need of protection application filed by the Ottawa “cas” on May 7, 1998 for the Plaintiff’s, blood twin half brothers.
  8. The Plaintiff claims as a fact that in the Plaintiffs blood twin half brothers children allegedly in need of protection application file of May 7, 1998 case 229/93, the evidence entered by the Ottawa “cas” Ian Bates social worker and Hiedi Polowin “cas” lawyer in the May 7, 1998 sworn affidavit, Tabs A to W had the defendant case 114/91 evidence from October 31, 1991 to December 1998 and the illegal adoption, making it the same case 114/91 which was proven to be fraudulent and manufactured evidence and it was used to take the Plaintiff away from his mother Lorena Kerr and loss of his love and affection for his mother Lorena Kerr and father Marc Paquette needlessly.
  9. The Plaintiff claims as a fact that the evidence of the defendant and case history of seven years and two month was found to be, grossly and negligently fabricated and made-up by the defendant, by, Justice Robert Fournier from North Bay, Ontario on February 15, and the morning of the 16th, 1999, after just fours hours of the applicant, Ottawa “cas” case file number 229/93 scheduled five day trial and this with the Ottawa “cas” using the evidence from the defendant that took the Plaintiff away from his mother Lorena Kerr and father Marc Paquette causing 14 years of needless loss of love and affection and the identity theft of the Plaintiff.
  10. The Plaintiff claims as a fact the defendant was being pushed by telephone calls made in November 1998 by, Ottawa “cas” protection worker Mark Arnold advising the defendant to adopt out the Plaintiff and his sister and brother to Margo Hunter as quick as possible because the Plaintiff’s mother Lorena Kerr was winning the Ottawa “cas” application of May 7, 1998 for children allegedly in need of protection trial and Lorena Kerr and Jack Hepworth did win the case in a four hour trial, file number 229/93 on February 16, 1999 with no appeals taken by the applicant Ottawa “cas” on the written judgment of February 19, 1999 or on the one hour oral judgment dated February 19, 1999. The Plaintiff says as a fact the defendant maliciously and knowingly illegally adopted the Plaintiff in December 1998 so that the Plaintiffs mother could not get the Plaintiff back because of the alleged law of no adoption is reversible.
  11. The Plaintiff claims as a fact that the hand written case note entries of Ottawa “cas” social worker Brenda Williams confirms the malicious intention and in-spite adoption of the Plaintiff was to cover-up the defendants knowingly criminal activity of get rid of the evidence the identity theft and illegally adopt the Plaintiff out without giving the Plaintiffs mother Lorena Kerr notice of her right to object to the adoption in accordance CFSA section 64 which right would have stopped the illegal adoption in it’s tracks and the Plaintiff could have been returned to his mother by February 19, 1999 at the latest, this did not happen and for seven more years the Plaintiff has had to live with the pain and suffering of knowing his mom was there and he was somewhere else needlessly.
  12. The Plaintiff claims as a fact that the defendant and judge Jennifer Blishen on September 19, 1995 by Order my mother Lorena Kerr my Aunt Margo Hunter my blood Aunt my mother that caused the Plaintiff a widening of the Plaintiffs identity theft.
  13. The Plaintiff claims as a fact the defendant made a knowingly false and fraudulent victim of the Plaintiff by making a crime compensation application to the criminal injuries compensation board and had $7000.00 awarded in the Plaintiff’s name based on fraudulent material. The defendant intended on taking the money ordered for the Plaintiff’s, 18th birthday that was on November 20, 2005.
  14. The Plaintiff claims as a fact the Plaintiff has all the fraudulent material that the defendant used to make the Plaintiff a victim of a crime for $7000.00 with compounded interest added in over 14 years only for the benefit of the defendant.
  15. The Plaintiff claims as a fact on September 8, 2005 a person from the criminal injuries compensation board called to talk to the Plaintiff about the $7000.00 plus interest but after a friend of mine Mr. Jack Hepworth faxed out a letter, to the criminal injuries compensation board (CICB) chairperson Ms. Marsha Greenfield and the Attorney General of Ontario Mr. Michael Byrant, on September 8, 2005, the Plaintiff says as a fact > “no more calls have come from the CICB.”
  16. The Plaintiff claims as a fact the Ottawa Police investigated the defendants manufactured allegations made against Mr. Jack Hepworth and the Plaintiff’s mother Lorena Kerr starting on October 31, 1991 by the defendant, all the allegations made by the defendant where found to be untrue in November of 1991. The Ottawa Police information of this fact only became available in August of 2001 it was withheld by the defendant during the identity theft of the Plaintiff starting on November 18, 1991 ending on December 19, 1991 and the without notice or legal representation for my mother or father and further based on no facts the Order of Judge Allan Sheffield for, children in need of protection started my 14 years of my identity theft by the defendant and the loss of love and affection I had for my mother, Lorena Kerr and my father, Marc Paquette.
  17. The Plaintiff claims as a fact that the Order of adoption was a fraudulent Order and should never have been Ordered and the Plaintiff should have been returned immediately to his mother Lorena Kerr upon her arrival back in Canada on, Saturday, March 6, 1992. The application and Order was knowingly fraudulent and made by the defendant.
  18. The Plaintiff claims as a fact that on December 19, 1991 a judge made a protection order for the defendant’s fraudulent children in need of protection application without notice or service or legal representation for the parties in case number 109/91 which was changed to 114/91 when the Plaintiffs mother Lorena Kerr began to fight the defendant starting on June 18, 1992 at Smith Falls courthouse.
  19. The Plaintiff claims as a fact the transcripts from December 19, 1991 which the Plaintiff has reviewed, clearly shows, the knowingly malicious identity theft of a four year old child “the Plaintiff herein” from the start by, the defendant which became a knowingly protracted and continuing, crime against the Plaintiff for fourteen years.
  20. The Plaintiff claims as a fact the defendant’s December 19, 1991 fraudulent children in need of protection application case number 109/91 was against the Plaintiff’s father Marc Paquette as he lived in Quebec and if he took his children there and did not bring them back then the defendant had no jurisdiction to go and get them. The defendants case number 109/91 changed to case 114/91 on, March 6, 1992 when the Plaintiffs mother Lorena Kerr returned and wanted her children back, case 114/91 became a, manufactured violent sex abuse case allegedly perpetrated against the Plaintiff and his two siblings which caused the Plaintiff inexcusable pain and suffering and loss of love and affection of his mother Lorena Kerr and his father Marc Paquette. The Plaintiff states and says as a fact he was never abused by his mother Lorena Kerr or Jack Hepworth the only abuse suffered by the Plaintiff was by the criminal acts of the defendants.
  21. The Plaintiff claims as a fact that the manufactured story of the defendant about the Plaintiffs father and the defendant’s manufactured story of, sex abuse and about shooting the Plaintiff’s brother in the face with a shot gun and slitting the Plaintiff’s throat and leaving a six inch scar and burning the hair off the Plaintiff and his two siblings with a rainbow colored lighter where all malicious and intentional lies knowingly and calculatedly made-up by the defendant.
  22. The Plaintiff claims as a fact there is no six-inch scar on his neck and there never has been and there is no medical proof filed proving the assault on the Plaintiff.
  23. The Plaintiff claims as a fact that his hair was never set on fire and I do not have any burn scars on my scalp.
  24. The Plaintiff claims, as a fact that the damage that these manufactured fantasy stories have done to the Plaintiff’s short life is inexcusably criminally cruel and unusual punishment and manufactured by the defendant.
  25. The Plaintiff claims as a fact under Courts of Justice Act Section 96(2) the common law and equity, the Plaintiff reserves his right to amend this claim at anytime without consent after disclosure by the defendant to the Plaintiff of all the defendant’s documentation concerning the defendants court file numbers 109/91, 114/91, 229/93 and the defendants illegal adoption record.
  26. The Plaintiff claims as a fact that since he has become of age at eighteen and has this civil case for damages against the defendant it is the responsibility of the courts to protect the Plaintiff’s freedom and charter rights and constitutional rights and grant all the funds needed to the Plaintiff to prosecute this action.
  27. The Plaintiff claims as a fact he has his visitation videos showing the defendant abusing the Plaintiff mentally and physically over and over.
  28. The Plaintiff claims as a fact he has been traumatized and abused knowingly and the defendant has protracted the abuse for 14 years of his 18 years of life.
  29. The Plaintiff claims as a fact in case law, indexed as, Jack v. Jack Nova Scotia Supreme Court, an error in facts is an error in laws and in the Plaintiffs claim file that judgment speaks volumes of truth.
  30. The Plaintiff claims as a fact he has all the evidence to file and present to a jury and is 100% confident this claim will succeed in all expectations.
  31. The Plaintiffs statement of claim cannot possibly be lost in front of any reasonable competent jury.

The Plaintiff proposes that this action, be tried by a jury at the Ottawa Courthouse, 161 Elgin Street.

Date of issue: Monday, March 13, 2006
Raymond Paquette (Plaintiff)
17 Cherly Road
Ottawa, Ontario K2G 0V5
Phone: (613) 228-0368

back to article