1.

The Plaintiff Adam Josephs ("Josephs") claims against all Defendants:

1. general damages in the amount of $500,000.00;
2. aggravated damages in the amount of $500,000.00;
3. punitive damages in the amount of $250,000.00;
4. an interim and permanent injunction preventing the Defendants from publishing, or continuing to publish, pictures and statements disparaging Josephs, including without limitation, the "Officer Bubbles Cartoons" and "Posts" as hereinafter defined;
5. pre- and post-judgment interest pursuant to the provisions of the Courts of Justice Act, R.S.O. 1990, c. C-43, as amended;
6. costs of this action on a substantial indemnity basis, together with all applicable taxes thereon; and
7. such further and other relief as this Honourable Court may consider just.

2.

Josephs is an individual residing in the City of Whitby, Ontario. Josephs has been employed by the Toronto Police Services (the "TPS") continuously since 1990, and currently holds the rank of Constable. Josephs possesses an outstanding service record, which includes several commendations and awards, and in addition has assumed a leadership role in a number of charitable initiatives for at-risk youths in the Greater Toronto Area. Josephs enjoys an excellent reputation both at work and in the communities in which he lives and serves.

3.

The Defendant YouTube, LLC is a corporation existing pursuant to the laws of Delaware, with its head office in San Bruno, California. YouTube, LLC operates a popular website called www.youtube.com ("YouTube"), which permits users to publish videos which can be viewed by anyone with access to the Internet. YouTube also permits users to publish comments in response to videos.

4.

The Defendant John Doe No. 1 a.k.a. ThePMOCanada ("ThePMOCanada") is an individual whose identity is unknown to Josephs but known to YouTube, LLC. ThePMOCanada is the author of the "Officer Bubbles Cartoons" as herein defined.

5.

The Defendants John Doe Nos. 2 - 25, inclusive, are individuals whose identities are unknown to Josephs but known to YouTube, LLC. John Doe Nos. 2-25 are the authors of the "Posts" as herein defined.

6.

On June 26 and 27, 2010, the heads of the governments forming the G20 met for a summit in Toronto, Ontario (the "G20 Summit").

7.

During the G20 Summit, numerous radical groups held "protests" in Toronto's downtown core, ostensibly directed at the policies of the G20 countries. These "protests" resulted in massive property damage as "protestors" vandalized local businesses and burned police cruisers. Sizeable weapons caches were also seized from several of the "protestors". Many of the "protestors" at the G20 Summit belonged to the violent "Black Bloc" movement.

8.

On or about June 27, 2010, Josephs was on duty when he and several other TPS officers responded to a call that a chartered bus carrying a number of suspected Black Bloc rioters had been detained at a nearby intersection and was under investigation.

9.

When Josephs and his colleagues arrived at the investigation site, a large group of people had already assembled, including those suspected of belonging to the Black Bloc. There was a considerable amount of tension at the investigation site when Josephs arrived, with a number of individuals in the crowd attempting to provoke the police into a confrontation.

10.

While at the investigation site, Josephs encountered a female "protestor" blowing soap bubbles into the face of another female police officer in an effort to mock the police and diminish their authority in the eyes of her fellow "protestors".

11.

Josephs informed the female "protestor" that if she did not stop blowing bubbles into the face of his fellow officer immediately, he would arrest her for assault contrary to the Criminal Code, R.S.C. 1985, c. C-46. The female "protestor" (arrested later that same day by another police officer on a charge of possession of a weapon for a dangerous purpose) eventually stopped her bubble blowing, but she then proceeded to verbally mock Josephs. The encounter ended without incident, however it was captured on film by another member of the crowd and published on YouTube (the "Taped Encounter").

12.

On a date or dates unknown to Josephs, but subsequent to publication of the Taped Encounter on YouTube, ThePMOCanada published a series of eight cartoon video on YouTube depicting the likeness of Josephs, and in some cases specifically identified him by name. These videos were entitled

1. "Officer Bubbles - Touched by Love";
2. "Officer Bubbles - First Aid";
3. "Officer Bubbles - Secret 5 Meter Law";
4. "Officer Bubbles - Black Bloc";
5. "Officer Bubbles - City Hall";
6. "Officer Bubbles - Weapons Display";
7. "Officer Bubbles - The Kettle"; and
8. "Officer Bubbles - G20 Media", (the "Officer Bubbles Cartoons").

13.

In general, the Officer Bubbles Cartoons depict Josephs mistreating people and abusing his authority as a police officer, and are highly defamatory of Josephs.

14.

On a date or dates unknown to Josephs, John Doe Nos. 2-25 each published posts in response to one or more of the Officer Bubbles Cartoons (the "Posts"). In general, the Posts impugn the integrity and character of Josephs, and are highly defamatory of Josephs.

15.

ThePMOCanada and YouTube, LLC are responsible for the publication and/or republication of the Officer Bubbles Cartoons. John Doe Nos. 2-25 and YouTube, LLC are responsible for the publication and/or republication of the Posts.

16.

The statements in the Officer Bubbles Cartoons and Posts about which Josephs complains are as follows:

17.

ThePMOCanada and YouTube published and/or republished a video entitled "Officer Bubbles - Touched by Love", which contained the following defamatory pictures and statements about Josephs:

1. A cartoon likeness of Josephs;
2. A depiction of a cartoon woman dancing, being confronted by Josephs, and being imprisoned;
3. "A. Josephs is Officer Bubbles";
4. (By Josephs): "If you don't stop that I will arrest you for breaching the peace";

   (By woman): "But I'm just dancing";

   (By Josephs): "Are you talking to me? I will arrest you for obstruction of justice too"

   (By Josephs, with cartoon hearts appearing): "I'm touched by your expression of love. You are under arrest for assault"; and

5. "Next week ... Officer Bubbles shoots kitten in tree".

18.

The following John Doe Defendants and YouTube published and/or republished the following Posts in response to the cartoon "Officer Bubbles - Touched by Love":

1. (By John Doe No. 2 a.k.a 19632407) "great video but that cop is an ass hole shame on him for being a jerk off;
2. (By John Doe No. 3 a.k.a. MrJlamblO) "LMAO! thats some funny shit right there. I hope he gets convicted for being an asshole";
3. (By John Doe No. 9 a.k.a. MrTrinidaddyl) "hmm Officer A. Josephs . . . bet the "A" stands for Asshole";
4. (By John Doe No. 4 a.k.a. b0008749) "What psychological test did this clown pass to become a cop? They must have been very comprehensive. This is the type of yoyo that give cops who do their work in a professional and respectful manner a bad name.";
5. (By John Doe No. 5 a.k.a. sahandl 93) "fuck officer bubbles";
6. (By John Doe No. 6 a.k.a. crazymonkey883) "true - probably wears the sunglasses while looking at himself in the mirror!!!";
7. (By John Doe No. 7 a.k.a. Pussymcfats) "officer bubbles probably looks at himself in the mirror a lot";
8. (By John Doe No. 8 a.k.a. IseeDumbPeopieOO) "What a sissy boy! I bet he cries himself to sleep every might!";
9. (By John Doe No. 10 a.k.a. KeyboardPacifist) "You really believe that the streets should have pig cops like "bubbles" full of aggressive rage, barely kept behind that "rule of law" and ready to pounce on anyone who does to question him. You want to give the bullies more guns and more money. And you tell the rest of us to "play nice"";
10. (By John Doe No. 11 a.k.a. heyyou788) "bubbles seems like a fuckin psychopath...";
11. (By John Doe No. 12 a.k.a. sweeteventhorizon) "Remarkably, this is also the same sort of behavior displayed with great enthusiasm by another brand of jack-booted thugs who, some 60 years ago, between bites of bratwurst and steins of beer, tried to stuff an entire race of people headfirst into ovens. Officer Adam Josephs is an embarrassment to not only the city of Toronto, the province of Ontario and to all Canadian citizens but to decent, competent and professional law enforcement everywhere.";
12. (By John Doe No. 12 a.k.a. sweeteventhorizon) "This is the same sort of jack-booted thug that could be seen stomping the life out of a Polish tourist at the Vancouver airport. This is the behavior and attitude of an arrogant, incompetent, provocative and overzealous punk who, with badge and the authority and protections provided him through legislation and the designation of "peace officer", deliberately created an adversarial confrontation where none existed and he did this for his own rogue sense of satisfaction and legal propriety";
13. (By John Doe No. 12 a.k.a. ecofrogl) "The thing is this cop is from 52 division (downtown TO). 52 division cops are involved in raketeering (shaking down club owners for protection). The 52 division drug squad is well know to have beat up drug dealers and stole their money and drugs... Lots of evidence but the proscuters took so long to bring it to trial it got thrown out (what a shock). 52 divison cops are well known bullies who beat up homelsspeople. If Officer bubbles is just an asshole, he is the best cop in the division!";
14. (By John Doe No. 13 a.k.a. TheCanuckSailor) "It's a shame that the police are becoming uniformed bullies. It's bad when the local people tell them to leave their community.";
15. (By John Doe No. 14 a.k.a. avzett) "Nice going Officer Josephs, you are a real hero and a true testament to the sorry state of law enforcement here in Canada, and a fine example of the kind of policing peaceful people had to endure during the G20 farce.";
16. (By John Doe No. 15 a.k.a. djskinnychris) "That's what happens when a police force cares more about diversity than ability to do the job. This guy clearly does not have the temperament to be an officer of the law. I have been on the receiving end of more than a few cops hatred of white folks. This guy is a loser who will no doubt be promoted ahead of other cops based solely on the colour of Ins skin. Cry racism if you will but it is most likely the truth";
17. (By John Doe No. 16 a.k.a. theforcebewithme) "If this steroid addicted Nazi has children, they must be sooooo embarassed.";
18. (By John Doe No. 17 a.k.a. wazza33racer) "officer bubbles your my NAZI hero!";
19. (By John Doe No. 19 a.k.a. dryflyguyok) "Good Work!! Lets See as much of that asshole as possible.";
20. (By John Doe No. 18 a.k.a. GayGawd) "That's the idiot from Toronto G20. lol That dude had a serious attitude problem or a chip on his shoulder. He's the worst kind of cop. The female officer was calm and collected"; and
21. (By John Doe No. 20 a.k.a. satomiwa) "Awesome. Almost didn't recognize Human Garbage Collecter Bubbles with long pants on instead of those nifty shorts he likes so much, but there was no doubt who I was looking at once he started flexing and threatening. And glaring. And being a general first-class douchebag. Are there more? I hope so!"

19.

The pictures and statements contained in "Officer Bubbles - Touched by Love" and the associated Posts are false and devastatingly defamatory. These malicious pictures and statements impugn the reputation of Josephs, and were intended and understood to mean inter alia that:

1. Josephs is a police officer who abuses his position of authority;
2. Josephs is an unjust and unfair police officer;
3. Josephs falsely arrests people;
4. Josephs mistreats members of the public;
5. Josephs is incompetent and unfit to be a police officer;
6. Josephs would engage in animal cruelty;
7. Josephs is a person of despicable character;
8. Josephs has psychological problems;
9. Josephs is a narcissist;
10. Josephs presents a danger to public safety;
11. Josephs engages in cruel and draconian conduct comparable to the Nazis under Adolph Hitler;
12. Josephs is a corrupt police officer; and
13. Josephs bullies members of the public.

20.

ThePMOCanada and YouTube published and/or republished a video entitled "Officer Bubbles - First Aid", which contained the following defamatory pictures and statements about Josephs:

1. A cartoon likeness of Josephs;
2. A cartoon likeness of a physician in a police interrogation room, being confronted by Josephs, and being imprisoned;
3. "A. Josephs is Officer Bubbles";
4. (By Josephs) "You're charged with wearing a disguise"

   (By doctor) "But I am a doctor. You arrested me in my doctor's office!"

   (By Josephs) "You talking to me?? You are charged with obstructing justice."

   (By Josephs) "What's in your bag?" (By doctor) "Bandages" (By Josephs) "Weapon!" (By physician") "Gauze" (By Josephs) "Weapon!"

   (By physician") "Aspirin"

   (By Josephs) "You are charged with drug trafficking!"; and

5. "Next time .. . Officer Bubbles tackles blind woman."

21.

The following John Doe Defendants and YouTube published and/or republished the following statements in response to the cartoon "Officer Bubbles - First Aid":

1. (By John Doe No. 21 a.k.a. CheckerGirl42) "officer bubbles is a douchebag, he should go die in a hole or something, seriously who the f*ck would arrest someone for blowing freaking bubbles, like seriously Josephs, get a life."; and
2. (By John Doe No. 22 a.k.a. maskedtruther) "A lot of police today were originally criminals."

22.

The pictures and statements contained in "Officer Bubbles - First Aid" and the associated Posts are false and devastatingly defamatory. These malicious pictures and statements impugn the reputation of Josephs, and were intended and understood to mean inter alia that:

1. Josephs is a police officer who abuses his position of authority;
2. Josephs is an unjust and unfair police officer;
3. Josephs falsely arrests people;
4. Josephs mistreats members of the public;
5. Josephs is incompetent and unfit to be a police officer;
6. Josephs is a person of despicable character;
7. Josephs presents a danger to public safety;
8. Josephs would assault disabled people; and
9. Josephs is a criminal.

23.

ThePMOCanada and YouTube published and/or republished a video entitled "Officer Bubbles - Secret 5 Meter Law", which contained the following defamatory pictures and statements about Josephs:

1. A cartoon likeness of Josephs;
2. A cartoon likeness of U.S. President Barack Obama being confronted by Josephs and being imprisoned;
3. "A. Josephs is Officer Bubbles";
4. (By Josephs) "Five meter law!"

   (By President Obama) "What 5 meter law?"

   (By Josephs) "It's a secret! Papers please!"

   (By President Obama) "But I'm the president!"

   (By Joseph) "You're under arrest for obstructing justice!"; and

5. "Next time ... Officer Bubbles takes child's wheelchair".

24.

The pictures and statements contained in "Officer Bubbles - Secret 5 Meter Law" are false and devastatingly defamatory. These malicious pictures and statements impugn the reputation of Josephs, and were intended and understood to mean inter alia that:

1. Josephs is a police officer who abuses his position of authority;
2. Josephs is an unjust and unfair police officer;
3. Josephs falsely arrests people;
4. Josephs mistreats members of the public;
5. Josephs is incompetent and unfit to be a police officer;
6. Josephs is a person of despicable character;
7. Josephs presents a danger to public safety; and
8. Josephs would steal from disabled children.

25.

ThePMOCanada and YouTube published and/or republished a video entitled "Officer Bubbles - Black Bloc", which contained the following defamatory pictures and statements about Josephs:

1. A cartoon likeness of Josephs;
2. A cartoon likeness of a black-clad man, Osama bin Laden, and an space alien passing by Josephs without being confronted by him;
3. A cartoon likeness of Santa Clause being confronted by Josephs, and being imprisoned;
4. "A. Josephs is Officer Bubbles";
5. "Hold it right there! You're under arrest!"; and
6. "Next time ... Office Bubbles impounds school bus".

26.

The following John Doe Defendants and YouTube published and/or republished the following Posts in response to the cartoon "Officer Bubbles - Black Bloc"

1. (By John Doe No. 14 a.k.a. avzett) "Hey Adam Josephs, how does it feel to be famous for being a douchebag?"; and
2. (By John Doe No. 23 a.k.a. Joel0277) "Adam Josephs is a Famous Asshole!! Lool"

27.

The pictures and statements contained in "Officer Bubbles - Black Bloc" and the associated Posts are false and devastatingly defamatory. These malicious pictures and statements impugn the reputation of Josephs, and were intended and understood to mean inter alia that:

1. Josephs is a police officer who abuses his position of authority;
2. Josephs is an unjust and unfair police officer;
3. Josephs falsely arrests people;
4. Josephs mistreats members of the public;
5. Josephs is incompetent and unfit to be a police officer; and
6. Josephs is a person of despicable character.

28.

ThePMOCanada and YouTube published and/or republished a video entitled "Officer Bubbles - City Hall", which contained the following defamatory pictures and statements about Josephs:

1. A cartoon likeness of Josephs;
2. The cartoon likenesses of three people debating a matter in a legislative setting, and one of them being imprisoned;
3. "Officer Bubbles";
4. (By first debater): "Order! Order!"

   (By first debater): "The police can't protect the public and . . . um . . . police at the same time!

   (By second debater): "We need a review!"

   (By first debater): "Um .. ."

   (By Josephs, holding an assault rifle): "See this?"

   (By first debater): "Um, I move to commend the police!"

   (By second debater): "Before the investigation? How will we know what happened?"

   (By Josephs, holding an assault rifle): "Are you talking about me??"; and

5. "Next time ... Officer Bubbles tazers puppy.".

29.

The following John Doe Defendants and YouTube published and/or republished the following Posts in response to the cartoon "Officer Bubbles - Black Bloc"

1. (By John Doe No. 24 a.k.a. HabsCanada) "Adam Josephs eats poop";
2. (By John Doe No. 25 a.k.a. ytgv3fc7) "I think an awesome hallowe'en costume would be a roid-raging A-Josephs costume. Any takers on that plan?"

30.

The pictures and statements contained in "Officer Bubbles - City Hall" and the associated Posts are false and devastatingly defamatory. These malicious pictures and statements impugn the reputation of Josephs, and were intended and understood to mean inter alia that:

1. Josephs is a police officer who abuses his position of authority;
2. Josephs is an unjust and unfair police officer;
3. Josephs falsely arrests people;
4. Josephs mistreats members of the public;
5. Josephs is incompetent and unfit to be a police officer;
6. Josephs is a person of despicable character;
7. Josephs presents a danger to public safety;
8. Josephs would use a gun to silence criticism of the police; and
9. Josephs takes illegal steroids and exhibits rage as a result of doing so.

31.

ThePMOCanada and YouTube published and/or republished a video entitled "Officer Bubbles - Weapons Display", which contained the following defamatory pictures and statements about Josephs:

1. A cartoon likeness of Josephs showing a cache of seized "weapons" (consisting of a cake, a teddy bear, a bottle of wine, a camera, and an assault rifle) to an audience;
2. A cartoon likeness of a woman questioning Josephs about the "weapons" cache, and then being imprisoned;
3. "Officer Bubbles";
4. (By Josephs): "Here are the seized dangerous weapons" (By woman): "Is that a cake?"

   (By Josephs): "Traces of Nuts! I'm allergic"

   (By woman): "A Santa teddy bear?"

   (By Josephs): "Santa's on the no-nice list"

   (By woman): "The wine?"

   (By Josephs): "Very bad year"

   (By woman): "Is that gun related?"

   (By Josephs): "Oh that? No ... How did that get there?"

   (By woman): "Isn't that your gun?"

   (By Josephs): "Urn ... I..."; and

5. "Next time ... Officer Bubbles Strip Search".

32.

The pictures and statements contained in "Officer Bubbles - Weapons Display" and the associated Posts are false and devastatingly defamatory. These malicious pictures and statements impugn the reputation of Josephs, and were intended and understood to mean inter alia that:

1. Josephs is a police officer who abuses his position of authority;
2. Josephs is an unjust and unfair police officer;
3. Josephs falsely arrests people;
4. Josephs mistreats members of the public;
5. Josephs is incompetent and unfit to be a police officer;
6. Josephs is a person of despicable character; and
7. Josephs presents a danger to public safety.

33.

ThePMOCanada and YouTube published and/or republished a video entitled "Officer Bubbles - The Kettle", which contained the following defamatory pictures and statements about Josephs:

1. A cartoon likeness of Josephs speaking to a crowd on a basketball court enclosed by a fence, with the crowd later being imprisoned;
2. "A. Josephs is Officer Bubbles";
3. (By Josephs): "Everyone must leave the area!"

   (By crowd, booing): "But we are surrounded!... Go where?"

   (By Josephs): "You should've listened to me! When you had the chance!"

   (By crowd, booing): "But you just told us!.. , Peaceful protest!"

   (By Josephs): "We're going to pack you into a small space, make you stand in the rain for a few hours, then arrest everyone .. .so we can get our arrest totals up"

   (By crowd, booing): "But we haven't done anything! ... Civil rights!"

   (By Josephs): "You talking to me?? You are all charged with obstruction of justice!"; and

4. "Next time ... Officer Bubbles storms seniors' home".

34.

The following John Doe Defendants and YouTube published and/or republished the following Posts in response to the cartoon "Officer Bubbles - The Kettle":

1. (By John Doe No. 14 a.k.a. avzett) "Adam Josephs is a joke"; and
2. (By John Doe No. 3 a.k.a. MrJlamblO) "Officer Bubbles your one sick egotistical piece of shit. Get honest and resign. You have no business in that capacity."

35.

The pictures and statements contained in "Officer Bubbles - The Kettle" and the associated Posts are false and devastatingly defamatory. These malicious pictures and statements impugn the reputation of Josephs, and were intended and understood to mean inter alia that:

1. Josephs is a police officer who abuses his position of authority;
2. Josephs is an unjust and unfair police officer;
3. Josephs falsely arrests people;
4. Josephs mistreats members of the public;
5. Josephs is incompetent and unfit to be a police officer;
6. Josephs is a person of despicable character;
7. Josephs is egotistical; and
8. Josephs is dishonest.

36.

ThePMOCanada and YouTube published and/or republished a video entitled "Officer Bubbles - G20 Media", which contained the following defamatory pictures and statements about Josephs:

1. A cartoon likeness of Josephs confronting the cartoon likeness of a female photographer, with the photographer later lying on the ground after the sound of punches being thrown, and then being imprisoned;
2. "Officer Bubbles";
3. (By Josephs, speaking into telephone): "Just let the patrol cars burn until they get on TV ...";
4. (By Josephs to photographer): "Stop right there! No photos!"

   (By photographer): "But I'm media! I'm wearing my G20 media card!"

   (By Josephs): "You think that plastic card protects you??"

   (By photographer): "Yes actually"

   (By Josephs): "Are you talking to me??"

   (By Josephs, after sound of punches being thrown): "You are charged with assaulting a police officer!"; and

5. "Next time ... Officer Bubbles eats donuts".

37.

The pictures and statements contained in "Officer Bubbles - G20 Media" are false and devastatingly defamatory. These malicious pictures and statements impugn the reputation of Josephs, and were intended and understood to mean inter alia that:

1. Josephs is a police officer who abuses his position of authority;
2. Josephs is an unjust and unfair police officer;
3. Josephs falsely arrests people;
4. Josephs mistreats members of the public;
5. Josephs is incompetent and unfit to be a police officer;
6. Josephs is a person of despicable character;
7. Josephs presents a danger to public safety; and
8. Josephs would assault others, including members of the media.

38.

All of the publications in this action refer to Josephs and contain defamatory pictures and statements concerning Josephs and are untrue.

39.

All of the publications in issue in this action were made maliciously.

40.

Joseph states that as a result of the defamatory publications in issue in this action, he has been brought into ridicule, scandal, and contempt both personally and as a member of the TPS. In particular, but without limitation, as a direct result of the Officer Bubbles Cartoons and the Posts, Josephs has received threats of physical harm against both himself and his family.

41.

The Defendants' conduct towards Josephs has been malicious, reckless, callous, and reprehensible and in complete and total disregard for his personal reputation and his reputation as a member of the TPS.

42.

A Notice of Libel has been served on YouTube, LLC requesting removal of the Officer Bubbles Cartoons and the Posts, as well as an apology to Josephs, however YouTube, LLC has failed or refused to do either. Instead, YouTube, LLC has continued the dissemination of the Officer Bubbles Cartoons and Posts, thereby aggravating Josephs's damages.

43.

The Defendant's misconduct has been malicious, oppressive, and highhanded to a degree that offends the Court's sense of decency warranting an award of punitive damages.

44.

In relation to the service of this Statement of Claim outside of Ontario, Josephs pleads and relies on R. 17.02(g) and 17.02(h) of the Rules of Civil Procedure, R.R.O. 1990, Reg. 194.

45.

Josephs requests that this action be tried in the City of Toronto.