House of Cards, The Tale of Two Cities - Part I

Background

In previous articles, I described how the Attorney General for Ontario, Doug Downey ("Downey"), has been orchestrating a long series of retaliation acts due to the concerns I raised about the administration of justice at:

• The Small Claims Court, in Toronto.
• The Superior Court of Justice (Divisional Court), in Ottawa.
• The Court of Appeal for Ontario.

Many of those details can be found at: Corruption, Collusion, and Abuse of Power

This is a two-part article where I describe how the largest two cities in Ontario, the City of Toronto and the City of Ottawa / Ville d’Ottawa , have been colluding with Downey in his corrupt practices

In addition, the following lawyers played a part in some of the events related to the long series of retaliatory acts orchestrated by Downey.

• Christopher Achkar of Achkar Law.
• Marc Kitay of Whitten and Lublin Employment Lawyers.
• Daniel Lublin of Whitten and Lublin Employment Lawyers.
• David Whitten of Whitten and Lublin Employment Lawyers.

Downey, or one of his staff, came up with a great idea of issuing fraudulent speeding tickets so that I would dismiss the proceeding that was underway at the time:

DC-23-2826 ?Madhoun v. Whitten & Lublin Professional Corporation

(Judicial Review, Divisional Court in Ottawa)

Downey and his staff didn’t expect that I had Google Maps Timeline enabled on my phone, which tracks, among other things, my travel time and distance (hence speed). All in all, the list of tickets I received was:

• 0460-99423E022082900 - for driving at 51 Km/hr. in 40 Km/hr. zone.
• 0460-99423E022117900 - for driving at 57 Km/hr. in 40 Km/hr. zone.
• 0460-99423E022125900 - for driving at 53 Km/hr. in 40 Km/hr. zone.
• 0460-99423E022166500 - for driving at 58 Km/hr. in 40 Km/hr. zone.
• 0460-99423E027B89900 - for driving at 62 Km/hr. in 40 Km/hr. zone.

I paid for the first ticket thinking that I might have been speeding, unknowingly. However, after getting the remaining tickets, it was clear that those tickets were fabricated, for multiple reasons:

1. The first four tickets allege that I was speeding on a street I pass by daily. The speed radar is visible, and it wouldn’t make sense for me or anyone else to speed up when passing through a radar on a familiar street.
2. When I suspected something was happening, I filed a complaint with the City of Ottawa / Ville d’Ottawa . While waiting for a response to my complaint, I avoided the street where I got the first four tickets until I figured out what was going on.
3. To my surprise, I received the fifth ticket while driving in a different area of the city, and the photo of my license plate appeared to have been put together using photo editing software.

Furthermore, when I checked Google Maps Timeline, the average speeds I was driving at were:

• 0460-99423E022117900 - 15.27 Km/hr. [ticket reported 57 Km/hr. in 40 Km/hr. zone]
• 0460-99423E022125900 - 31.1 Km/hr. [ticket reported 53 Km/hr. in 40 Km/hr. zone]
• 0460-99423E022166500 - 20.96 Km/hr. [ticket reported 58 Km/hr. in 40 Km/hr. zone]
• 0460-99423E027B89900 - 36.92 Km/hr. [ticket reported 62 Km/hr. in 40 Km/hr. zone]

The Timing

Upon reflecting on the dates of generating the fraudulent speeding tickets, I came to notice that each one of the tickets coincides with a milestone or a concern related to the proceedings I had before the courts:

 0460-99423E022082900 - Date of Deemed Service: October 3, 2023        

This came while I was preparing to file the Notice of Application to the Divisional Court for Judicial Review ("Notice"). This was also around the time I was trying to get a copy of the audio recording of two hearings that I had in the Toronto Small Claims Court.

 0460-99423E022117900 - Date of Deemed Service: October 27, 2023        

 0460-99423E022125900 - Date of Deemed Service: October 27, 2023        

One week after filing the Notice, and the same day I filed the AMENDED Notice of JR.

 0460-99423E022166500 - Date of Deemed Service: November 10, 2023        

I raised some concerns about the administration of justice at the Divisional Court in Ottawa, and communicating with , the Director of Court Operations for the East Region.

 0460-99423E027B89900 - Date of Deemed Service: December 14, 2023        

I was raising concerns about how the Settlement Conference for the claim against ACHKAR LAW was conducted, on December 8, 2023. And the fact that Christopher Achkar filed confidential information, protected by solicitor-client privilege, in an act of revenge and retaliation.

At that point, there was no doubt about why I was getting those tickets or who stood behind them. I ended up filing a Notice to Appear in Person for all four (unpaid) tickets.

The Complaint (City of Ottawa)

On November 13, 2023, I filed a complaint with the City of Ottawa / Ville d’Ottawa ; a month passed by without getting a response. I sent a follow-up email to [email protected]. Then, I received a response from Michael Ouellet, Coordinator, Channel Relationships (Service Ottawa). A copy of the response can be found here. The key points were:

If you have evidence that your vehicle did not proceed at the rate of speed indicated on your infraction and wish to contest the charge, you must request a trial by submitting a Notice of Intention to Appear for each infraction you wish to contest.

I can confirm that you are still currently eligible to request a trial for all three offences

That didn’t address my concerns. After following up on the response, I received another email from the City of Ottawa / Ville d’Ottawa , this time from Lisa Kilner, Team Lead, Admin Support (Legal Services).

A copy of the response can be found here. The key points were:

The Automated Speed Enforcement Processing Centre is located with the City of Toronto, and not as you suggest City of Ottawa staff.

The City of Ottawa, pursuant to an agreement with the Ministry of the Attorney General, administers the Provincial Offences Court and prosecutes matters that are contested for trial purposes.

Your assertion that the tickets have been issued fraudulently or with corrupt practice is a serious contention.

The Wrongful Conviction

Earlier this year, I was still preparing for the hearing of the Judicial Review, scheduled to take place on May 21, 2024. Downey, couldn't find a better way to advance his retaliation acts, other than by issuing a Provincial Offenses Act ("POA") conviction for one of the fraudulent tickets I received, 0460-99423E022117900. I received a letter by mail, titled Notice of Fine and Due Date, which stated:

The Notice said that I was convicted in a POA trial because I didn't attend the trial that took place on December 8, 2023. Like many things done by Downey and his staff, it was a sloppy and incompetent job. That is, I have already received an email from the City of Ottawa / Ville d’Ottawa , on December 13, 2023, indicating that I am still eligible to file a Notice of Intention to Appear, which I did, on December 18, 2023:

In other words, a trial couldn't have occurred on December 8, 2023, while I was still waiting for trial, based on a Notice dated December 18, 2023. Whoever fabricated the conviction in early 2024, didn't notice that I have a pending Notice of Intention to Appear in Person, still pending from 2023.

The Two Mayors

On December 18, 2023, I sent the following letter to Mayor Olivia Chow Mayo of the City of Toronto , and cc'd Mayor Mark Sutcliffe , the mayor of the City of Ottawa / Ville d’Ottawa .

This was one year ago. Neither of the two mayors bothered to have someone in their offices to respond to the serious concerns I raised in the letter.

To be continued...In Part II of this article, I will cover:

The Complaint (Justices of Peace Review Council)

The License Plate

Deja Vue

The Damage Control

Concluding Remarks