Francesco did not stumble into this. He designed it. After firing Laura Joy on June 18, 2025 — removing the last protective barrier between him and the truth — he spent the next 16 days preparing what he calls the "July 4th Nuclear Deployment."
The trap had three layers:
Each motion below was served on the Crown Attorney's Office, 200 Chatham Street East, Windsor, Ontario. Each was stamped. Each was ignored. The Outcome column records what actually happened.
Application for permanent stay on grounds of: (a) abuse of process — fabrication of evidence by PC Gratton; (b) 4.5-year delay (189% beyond Jordan ceiling per R. v. Jordan, 2016 SCC 27); (c) institutional misconduct — coordinated suppression across 25+ agencies; (d) Charter ss.7, 9, 10(b), 11(b), 11(d), 15 violations; (e) malicious prosecution — Nelles v. Ontario [1989] 2 SCR 132.
Application to prevent dismissal of charges in absence of due process where Crown evidence is documented as fabricated. Cites Ward v. Vancouver (2010), Odhavji Estate v. Woodhouse (2003), Henry v. British Columbia (2015), Therrien v. Quebec (2001). Argues that dismissal without vacated conviction status effectively sanctions Crown misconduct.
Order sought requiring immediate preservation of: (a) all surveillance system recordings (24+ hours, including 47-minute gap); (b) original 911 call recording (35+ second tampering gap documented); (c) Crown disclosure files in their original form; (d) courthouse security logs for July 4 and July 7, 2025; (e) Crown carriage/assignment records; (f) any communications between Crown and police re: this case since 2021.
Compel attendance and testimony under oath regarding: (a) prior personal relationship with Steve and Hayley Zvaniga (the complainants); (b) unqualified damage assessment exceeding $5,000 without construction expertise or legal authority; (c) false statements in police reports about equipment that did not exist; (d) participation in 911 call editing and surveillance preservation decisions; (e) deceptive arrest procedure (calling Francesco to "talk" then arresting); (f) 12-minute response time despite normal response times.
Compel testimony re: her role as witness officer to PC Gratton's investigation, the property report (May 6, 2021 — no charges listed), and any communications with complainants prior to arrest.
Compel testimony re: approval of PC Gratton's fabricated reports despite physical evidence contradicting them (contractor receipt: "NO CONCRETE IN THE LINES"); the 2-month delay in filing the incident report; supervisory failure over 4.5 years.
Compel testimony under oath re: prior criminal record, the 911 call where his wife "did not witness" anything, his prior knowledge of PC Gratton (the "police officer friend"), the second contract Francesco signed, the firing without notice, the 47-minute gap between Francesco's departure and the 911 call.
Compel testimony re: the 911 call ("he left not even 10 minutes ago" — at 12:54 PM, 47 minutes after Francesco left at 12:07 PM); second-hand information from husband; non-emergency tone; husband "on his way home."
Compel testimony re: 4.5-year representation; the recorded admissions ("WE IN THE CROWN", "WE SHREDDED IT", "ATTORNEY GENERAL OBVIOUSLY WANTS", "IT'S DIGITAL SILLY", "I DON'T UNDERSTAND WHAT YOU MEAN FRANK"); the failure to file Charter motions despite obvious violations; retainer fees not returned upon termination.
Compel testimony re: prosecutorial misconduct; failure to disclose 911 call for 4.5 years; creation of two disclosure packages; coordination with PC Gratton prior to charges; knowledge of personal relationship between Gratton and complainants; fabricated damage estimates to reach $5,000 threshold.
Compel testimony re: deceptive arrest procedure (calling Francesco to say "needed to talk" then arresting); booking under badge 20812 that is "not found" in current WPS roster; voluntary attendance vs. arrest discrepancy.
Compel testimony re: chain of custody for the 911 call recording; the 35+ second gap between timestamps 2:35–3:01; the deleted dispatcher questions during evidence gathering phase; whether the recording provided to the defense on July 10, 2025 is the "amended redacted version" admitted by Crown (per email at 3:52 PM).
Compel testimony re: technical processing of the 911 call; whether the "amended redacted" version resulted from in-system editing or external manipulation; whether backup of the original 911 call exists; whether the deletion timestamps can be recovered.
Compel testimony re: motion-activated recording; why only 3 minutes of 24+ hours of video exists; why 47-minute gap between Francesco's departure and the 911 call; whether the surveillance system was forensically imaged by WPS; whether the homeowner and WPS had access to the system during the gap.
Application for appointment of independent digital forensics specialist to: (a) image the surveillance system in question; (b) recover any deleted footage; (c) verify the 47-minute gap; (d) compare file metadata to the 911 call metadata for consistency.
Compel testimony re: original 911 call handling; why 47 minutes elapsed between the alleged incident and the call; whether dispatcher was the same person who handled later calls; whether the call taker recognized Hayley's request for "Philip Gratton, he's a friend of ours."
Compel testimony re: chain of custody for all digital evidence in this matter; the relationship between MCMS 38 (May 22, 2021) and the original disclosure package; whether any digital certificate files were modified after creation; the September 23, 2025 modification timestamps on digi proof.cer and www.digitaldisclosure.mag.gov.on.ca.crt.
| # | Witness | Role | What they would have had to testify about |
|---|---|---|---|
| 1 | PC Phillip Gratton #19407 | Investigating officer | Personal relationship with complainants; false damage claims; deceptive arrest; evidence tampering participation |
| 2 | PC Sarah Fabiano #19674 | Witness officer | Property report (zero charges); 911 call handling |
| 3 | Sergeant Michael Fortune | Supervisor | Approval of false reports; 2-month delay; supervisory failure |
| 4 | Steve Zvaniga | Complainant (criminal record) | Prior knowledge of Gratton; second-hand witness account; firing without notice |
| 5 | Hayley Zvaniga | Complainant | "Not even 10 minutes ago" — 47-minute lie |
| 6 | Laura Joy | Former defense counsel | Recorded admissions; failure to file Charter motions; retainer fees not returned |
| 7 | Crown Attorney (Brandin/Dale/Krainz) | Prosecutor | Misconduct; 911 withholding; coordination with Gratton; $5,000 fabrication |
| 8 | Station Duty Officer (20812) | Arresting officer | Deceptive arrest procedure; badge "Not Found" in current roster |
| 9 | Evidence Custodian | Custody of 911 recording | 35+ second gap; chain of custody; "amended redacted" version admission |
| 10 | Digital Forensics Tech | 911 call processing | Technical processing; original backup existence; recovery of deletion timestamps |
| 11 | Surveillance System Custodian | Homeowner / WPS imaging | 3 min of 24+ hours recorded; 47-min gap; forensic imaging status |
| 12 | Independent Forensics Specialist | TBD | System imaging; recovery; metadata consistency check |
| 13 | Police Dispatcher | Original 911 call taker | 47-min delay; "friend" request recognition |
| 14 | Chain-of-Custody Officer | All digital evidence | MCMS 38 (May 22, 2021); Sept 23, 2025 timestamp tampering |
Francesco's strategy was simple: force them all to testify under oath, in open court, on the record, with the contradictions visible to every observer.
The Crown's response was simpler: don't let the trap fire.
Francesco arrived at 200 Chatham Street East. The 17 motions were stamped and filed. All 14 subpoenas were issued. The Crown was in possession. The judge was on the bench. Court staff were present.
Court records show no proceedings recorded for 2.5 hours on Francesco's scheduled day. Francesco waited. The complainants waited. PC Gratton waited. The Crown waited. 2.5 hours of unexplained judicial chamber time, with all 14 subpoenaed witnesses present outside.
"Mr. Longo, we need to reschedule. There is no time to hear your motions today. A prior 'murder trial' was referenced."
The court ran out of time to hear the motions that would have exposed a 4.5-year conspiracy to fabricate evidence. The court did not run out of time to hear anything else that day.
A Crown prosecutor in a Canadian courtroom, admitting on the record that he cannot participate in the proceedings because he is under investigation. Yet he is sitting beside the accused. Yet the judge allows him to remain. Yet the proceedings continue.
Per court transcript the following day, Judge Bazylko directly admitted: "He cannot be the prosecutor because based on his legal obligations... but the investigation's been held by the Crown themselves." Translation: the Crown is investigating its own prosecutor, and the judge knows.
Kristine Krainz (replacement Crown) attempted to schedule future court dates for Brandin despite his alleged investigation status. When confronted, she said: "Mr. Brandin can be available this night." Francesco responded: "Why are you making fictitious dates? You know damn well that man is never going to practice again — he's losing his license, he's under investigation."
Francesco filed the 17 motions on July 4, 2025. The court would not hear them. The Crown would not respond to the disclosure demand.
On July 10, 2025 at 3:22 PM, the Crown's office sent an email that ended 4.5 years of denial:
The 911 call — the one Laura Joy claimed for 4.5 years did not exist — was now ready to be viewed. The day after Francesco's 17 motions were filed. The day after the 14 subpoenas were issued. The day after the mandatory disclosure demand was stamped.
Francesco asked the obvious question: "Is this the original unedited version cuz I already listened to the 911 call"
The Crown's response at 3:52 PM: "It is an amended redacted version of the 911 Call."
The Crown's own email admitted, on the record, that the 911 call had been "amended redacted" — a euphemism for tampered with — before being provided to the defense. This is the Crown admitting, in writing, to evidence tampering.
On September 15, 2025 — 73 days after the trap was sprung — the case was dismissed via "higher ups" directive. A Windsor Police officer off-record confirmed the institutional cover-up. The dismissal was not the product of due process. It was the product of a system that could not sustain the scrutiny Francesco's 17 motions would have produced.
OCJ Form 1 — Application (s.24(1)) — R. v. Longo (OCJ Windsor).pdf
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