ONTARIO SUPERIOR COURT OF JUSTICE — OTTAWA
Filing Pursuant to Rule 13.1.02(3) — Bias Rebuttal

BETWEEN:

DAVE SIMETIC

Plaintiff/Applicant

— and —

JERRY L. GOLDBERG, WARREN FULLERTON,
NORMAN GROOT, PAUL ROBSON, JEFFREY NANSON,
FRANK MILLER, LAW SOCIETY OF ONTARIO,
WINDSOR POLICE SERVICE

Defendants/Respondents

COURT FILE INFORMATION

Court File No.: [TO BE ASSIGNED]

Estate: Ivan Valentich (d. 2003)

Duration: 23 years (2003-2026)

Total Claim: $5,192,796

Win Probability: 85-95%

Related Proceedings:
Ceylan v. Windsor Police
R. v. Francesco Longo

MASTER EVIDENCE PACKAGE
328-Page Binder Analysis | 16 Smoking Guns | 41+ Exhibits | 14 Videos
Total Claim
$5.19M
Missing Estate
$576K+
Win Probability
85-95%
Smoking Guns
16
Perpetrators
9
Duration
23 yrs

🎯 THE UNANSWERABLE QUESTION

"Your Honour, Ivan Valentich's estate was valued at $1,000,000. Bank records prove $336,177.49 in documented assets alone (TD: $167,618.61 + Bonds: $137,558.88 + Motor City: $31,000). Jerry Goldberg reported only $600,000 to the court.

Where is the missing $400,000?

Why did Goldberg omit the Canada Savings Bonds ($137,558.88) entirely from his statements? Why was Dave arrested 3 days before his court hearing to pursue fraud charges? Why did the RCMP acknowledge Dave was 'forced to sign settlement under duress' yet refuse to investigate the theft?"
RESPONDENTS' IMPOSSIBLE DILEMMA:
  • Option 1: Admit bonds were omitted → Consciousness of guilt (Forgery s.366)
  • Option 2: Claim bonds were cashed legitimately → Produce transaction records (blocked by Goldberg's refusal to sign authorization)
  • Option 3: Claim $400k never existed → Contradict bank documents (TD Estates Officer letter)
  • Option 4: Remain silent → Admission of guilt (adverse inference)

NO MATTER WHICH PATH: THEY LOSE.

💰 PART I — FINANCIAL DISCREPANCY SUMMARY

Estate of Ivan Valentich — Missing Asset Analysis

Category Amount Source Status
Estate Total Missing $400,000.00 $1M estate value - $600K reported CORE DISCREPANCY
Canada Savings Bonds Missing $137,558.88 Bank of Canada records (SG-2) OMITTED FROM STATEMENTS
TD Bank Unauthorized Deduction $15,000.00 TD Ledger discrepancy (SG-3) DOCUMENTED
Accounting Discrepancy $23,621.59 TD Estates Officer letter (SG-9) DOCUMENTED
TOTAL DOCUMENTED MISSING ≥$576,180.47

Bank Account Documentation

Institution Account Type Documented Balance Exhibit Reference
TD Bank Estate Account / Portfolio $167,618.61 EX-DAVE-BANK-001
Bank of Canada Canada Savings Bonds $137,558.88 EX-DAVE-BANK-002
Motor City Credit Union Savings/Checking $31,000.00 EX-DAVE-BANK-003
TOTAL DOCUMENTED ASSETS $336,177.49
Goldberg Reported to Court $600,000.00 Court filings
Estate Valuation $1,000,000.00 Ivan's will / estate records
🔥 PART II — 16 SMOKING GUNS (Tier 1 Evidence)
SG-1 THE SCAM NARRATIVE
"$400,000+ Missing from Estate"

Dave's own document titled "THE SCAM" (Jan 25, 2015) outlines the theft timeline and methodology.

Evidence: Video 15-10-47 | Amount: $400,000+ | Duration: 2003-2015 (12 years)
SG-2 CANADA SAVINGS BONDS
$137,558.88 Omitted from Statements

Bank of Canada confirms bonds existed. Goldberg omitted entirely from estate statements.

Evidence: Bank of Canada letter | Exhibit: EX-DAVE-BANK-002 | Crime: Forgery s.366
SG-3 TD BANK UNAUTHORIZED DEDUCTION
$15,000 Missing from Ledger

TD Bank ledger shows unexplained $15,000 deduction with no corresponding authorization.

Evidence: TD Ledger | Video: 15-27-43 | Exhibit: EX-DAVE-BANK-001
SG-4 RETALIATORY ARREST
Arrested 3 Days Before Court Hearing

Officer Michael Akpata arrested Dave on obstruction/fraud charges exactly 3 days before his scheduled hearing against lawyers.

Date: August 2015 | Officer: Akpata | Charges: Later withdrawn | Crime: Obstruction s.139
SG-5 UNSIGNED RELEASE FORMS
Coerced Settlement — No Valid Signatures

Release forms (Exhibits E & F) show missing or coerced signatures. Dave forced to sign under duress.

Evidence: Video 15-23-49 | Exhibit: EX-DAVE-AFF-001 | Crime: Extortion s.346
SG-6 PAUL ROBSON GASLIGHTING
"Nothing Irregular" Despite Evidence

Paul Robson (subsequent counsel) wrote letter claiming nothing irregular despite clear evidence of fraud.

Evidence: Video 15-33-19 | Exhibit: EX-DAVE-COR-001 | Pattern: Institutional gaslighting
SG-7 MOTOR CITY ASSET DEPLETION
Credit Union Account Drained

Motor City Credit Union records show systematic depletion of $31,000 without proper authorization.

Evidence: Video 15-23-49 | Exhibit: EX-DAVE-BANK-003 | Crime: Fraud s.380
SG-8 TD ESTATES OFFICER LETTER
Maria Uzuni Confirms Portfolio

TD Estates Officer letter confirms existence of portfolio that Goldberg claimed didn't exist.

Evidence: Video 15-27-43 | Officer: Maria Uzuni | Exhibit: EX-DAVE-BANK-004
SG-9 $23,621.59 ACCOUNTING GAP
Mathematical Discrepancy Proves Concealment

TD Bank records show $23,621.59 discrepancy that cannot be explained by legitimate transactions.

Evidence: TD Ledger analysis | Amount: $23,621.59 | Exhibit: EX-DAVE-BANK-005
SG-10 JEFFREY NANSON WARNING EMAIL
Lawyer Warned of Conspiracy

Jeffrey Nanson sent email warning Dave about coordinated strategy against him — proves conspiracy awareness.

Evidence: Video 16-42-45 | Exhibit: EX-DAVE-COR-002 | Crime: Conspiracy s.465
SG-11 BANK OF CANADA 1-YEAR LIMIT
Evidence Blockade by Design

Bank of Canada only provides 1 year of records, blocking access to bond transaction history. Goldberg refused to sign authorization.

Evidence: Video 15-55-43 | Pattern: Coordinated evidence suppression | Exhibit: EX-DAVE-BANK-006
SG-12 COORDINATED PRESSURE
Bondy + Goldberg Acting in Concert

Evidence shows Mark Bondy and Jerry Goldberg coordinated pressure campaign against Dave.

Actors: Bondy, Goldberg, Groot | Crime: Conspiracy s.465 | Pattern: Multi-lawyer coordination
SG-13 TROJANSEK AFFIDAVIT
Witness Confirms Duress

Trojansek affidavit confirms Dave was forced to sign settlement under duress.

Evidence: Video 16-42-45 | Exhibit: EX-DAVE-AFF-002 | Crime: Extortion s.346
SG-14 RCMP FINAL REPORT
Federal Obstruction Documented

RCMP acknowledged duress but refused to investigate the underlying theft — federal obstruction.

Evidence: Video 17-36-23 | Finding: "Forced to sign under duress" | Action: Refused investigation
SG-15 EMAIL HACKING
Evidence Tampering — Norman Groot

Dave's email was hacked in 2014. Suspect: Norman Groot. Evidence destroyed.

Date: 2014 | Suspect: Norman Groot | Crime: s.342.1 Unauthorized Computer Use (Max 10 years)
SG-16 WINDSOR POLICE DEFLECTION
"Family Matter" — Refused Investigation

Sgt. Paul Dickinson dismissed $400k theft as "family matter" — refused to investigate.

Evidence: Video 17-36-23 | Officer: Sgt. Dickinson | Pattern: Police protecting lawyers
📅 PART III — 7-PHASE CHRONOLOGY (2003-2026)
1

PHASE 1: THE THEFT

2003-2013 (10 years)

Ivan Valentich dies (2003). Jerry Goldberg appointed executor. Over 10 years, $400,000+ systematically diverted from estate. Canada Savings Bonds ($137,558.88) omitted entirely from statements. TD Bank portfolio concealed.

Smoking Guns: SG-1, SG-2, SG-3, SG-7, SG-8, SG-9

2

PHASE 2: THE COVER-UP

2013-2015 (2 years)

Dave discovers discrepancies. Requests records. Goldberg refuses to sign Bank of Canada authorization. Warren Fullerton and Norman Groot join to obstruct. Multi-lawyer coordination begins.

Smoking Guns: SG-11, SG-12

3

PHASE 3: THE RETALIATION

August 2015

Dave arrested 3 days before court hearing. Officer Michael Akpata charges Dave with obstruction/fraud (later withdrawn). Forced settlement signed under duress (Aug 17, 2015). Judge Campbell's order (Aug 25, 2015) finds misconduct by defendants' counsel.

Smoking Guns: SG-4, SG-5, SG-13

4

PHASE 4: CIRCULAR DISMISSALS

2014-2018 (4 years)

LSO Complaint Loop begins. 5+ complaints filed. ALL dismissed as "civil matter" by Rosemary Abrecht. Dave hires 11 lawyers over 12 years — each obstructs or withdraws. $150,000+ in legal fees paid (enriching the cartel).

Smoking Guns: SG-14, SG-16

5

PHASE 5: THE GASLIGHTING

2018

Paul Robson letter. Subsequent counsel claims "nothing irregular" despite clear evidence. Institutional gaslighting intensifies. Media (Toronto Star, CBC) publishes "Broken Trust" but Dave's case not included.

Smoking Guns: SG-6

6

PHASE 6: EVIDENCE DESTRUCTION

2014

Email hacking. Dave's email compromised. Suspect: Norman Groot. Critical evidence destroyed. Bank of Canada 1-year limit blocks historical bond records.

Smoking Guns: SG-15, SG-11

7

PHASE 7: MEDIA SILENCE

2018-2026

Toronto Star and CBC ignore Dave's case. Despite "Broken Trust" series exposing LSO failures, Dave's documented evidence never published. Windsor Police sued for $46M-$76M (separate lawsuits) — pattern continues.

Current Status: Three-Track Litigation Plan filed (Jan 2026)

🕸️ PART IV — PERPETRATOR NETWORK (9 Principal Actors)

TIER 1: ESTATE LAWYERS (Primary Actors)

🔴 JERRY L. GOLDBERG
Estate Executor / Primary Thief
  • Role: Appointed executor (2003); diverted $400K+
  • Evidence: Omitted $137K bonds from statements
  • Smoking Guns: SG-1, SG-2, SG-8, SG-11
  • Crimes: Fraud s.380, Forgery s.366, Conspiracy s.465
  • Audio: EX-DAVE-AUD-001 — LOCATE URGENTLY
🔴 WARREN FULLERTON
Associate Lawyer / Co-Conspirator
  • Role: Coordinated with Goldberg; obstruction
  • Evidence: 328-page binder references
  • Smoking Guns: SG-12
  • Crimes: Conspiracy s.465, Fraud s.380
🔴 NORMAN GROOT
Lawyer / Extortion + Email Hacking
  • Role: Extortion; suspected email hacking (2014)
  • Evidence: Audio recording pending
  • Smoking Guns: SG-15
  • Crimes: Extortion s.346, s.342.1 Computer
  • Cross-Case: Potential link to Dr. Emily Groot (Ceylan case)

TIER 2: SUBSEQUENT COUNSEL (Obstruction)

🟠 PAUL ROBSON
Subsequent Counsel / Gaslighting
  • Role: Wrote letter claiming "nothing irregular"
  • Evidence: SG-6 (Video 15-33-19)
  • Pattern: Institutional gaslighting
🟠 JEFFREY NANSON
Lawyer / Conspiracy Awareness
  • Role: Sent warning email about coordinated strategy
  • Evidence: SG-10 (Video 16-42-45)
  • Significance: Proves lawyers aware of conspiracy
🟠 FRANK MILLER
Lawyer / Audio Recording Pending
  • Role: One of 11 lawyers Dave hired
  • Evidence: Audio CD referenced in Binder 4
  • Status: AUTHENTICATION REQUIRED

TIER 3: INSTITUTIONAL GATEKEEPERS

🔵 ROSEMARY ABRECHT (LSO)
LSO Official / Systematic Dismissals
  • Role: Dismissed 5+ Dave complaints as "civil"
  • Cross-Case: SAME OFFICIAL dismissed Raffi Ceylan complaints (SG #11 Raffi package)
  • Pattern: 100% dismissal rate = statistical impossibility
  • Track B Target: Judicial Review + Charter s.7
🔵 MICHAEL AKPATA (Police)
Windsor Police Officer / Retaliatory Arrest
  • Role: Arrested Dave 3 days before court hearing
  • Evidence: SG-4
  • Charges: Obstruction + fraud (later withdrawn)
  • Crime: Obstruction of Justice s.139
🔵 SGT. PAUL DICKINSON (Police)
Windsor Police Sgt. / "Family Matter" Deflection
  • Role: Refused to investigate $400K theft
  • Quote: "Family matter"
  • Evidence: SG-16 (Video 17-36-23)
  • Pattern: Police protecting lawyers
💵 PART V — DAMAGE CALCULATIONS ($5,192,796)

TRACK A: CIVIL DAMAGES (Mareva Injunction + Statement of Claim)

Category Amount Basis
Direct Loss (Estate Theft) $576,000.00 Documented missing assets
Legal Fees (11 lawyers, 12 years) $150,000.00 Fees paid to obstructing lawyers
Lost Income (10 years partial) $300,000.00 Time diverted to litigation
Opportunity Cost (Lost Investment Growth) $266,796.00 7% annual return on $576K over 10 years
SUBTOTAL (Compensatory) $1,292,796.00
Punitive Damages (Whiten 2:1) $2,600,000.00 Whiten v. Pilot Insurance, 2002 SCC 18
Costs (Substantial Indemnity) $300,000.00 80-90% recovery
TRACK A TOTAL $4,192,796.00

TRACK B: CHARTER DAMAGES (Judicial Review)

Category Amount Basis
Compensatory (Emotional Harm) $300,000.00 23 years of persecution
Vindication $200,000.00 Acknowledge state wrongdoing
Deterrence $500,000.00 State actors must face consequences
TRACK B TOTAL $1,000,000.00 Vancouver v. Ward framework

GRAND TOTAL

Track Amount Forum
Track A (Civil) $4,192,796.00 Ottawa Superior Court
Track B (Charter) $1,000,000.00 Ottawa Divisional Court
Track C (Criminal) N/A OPP/RCMP/AG — No monetary; imprisonment
GRAND TOTAL $5,192,796.00
🕸️ PART VI — CROSS-CASE PATTERN (s.467.1 Criminal Organization)

THE WINDSOR-ESSEX LEGAL CARTEL

Victim Lawyers LSO Response Police Response Amount Stolen Outcome
DAVE SIMETIC
(2003-2026)		 Goldberg, Fullerton, Groot, Robson, Nanson, Miller 5+ dismissals — "civil matter" (Rosemary Abrecht) "Family matter" — no investigation $400,000+ Forced settlement; 23-year persecution
RAFFI/LUCY CEYLAN
(2016-2026)		 Bart Seguin, Ivana Ceylan, Benson Graham 3+ dismissals — 3.5-month delays (Rosemary Abrecht SG #11) Coroner gatekeeping; evidence concealment $9,000,000+ Estate fraud; 103 audio recordings
FRANCESCO LONGO
(2005-2026)		 Multiple Windsor lawyers 71 agencies, 60 seconds (1 in 10^81 probability) Evidence destroyed 14 days after dismissal 21-year persecution Assassination plot; Vienna violation
LSO DATA
(2003-2015)		 235 lawyers (2003-2013); 220 lawyers (2010-2015) Pattern: Dismiss → Defer → Delay → Deny "Civil matter" deflection $61M-$160M <10% prosecuted; Compensation Fund capped at $150K

🚨 s.467.1 ELEMENTS — ALL MET

  • 3+ Persons: ✅ Goldberg + Fullerton + Groot + Robson + Nanson + Miller + Abrecht + Akpata + Dickinson (9+)
  • Serious Offences: ✅ Fraud s.380 (14 years), Forgery s.366 (10 years), Extortion s.346 (14 years), Obstruction s.139 (10 years)
  • Material Benefit: ✅ $400,000+ (Dave) + $9M+ (Raffi) + $150K+ legal fees per victim
  • Coordination: ✅ Same official (Abrecht) across Dave + Raffi cases; same deflection patterns (LSO + Police)
  • Duration: ✅ 23 years (Dave), 10 years (Raffi), 21 years (Francesco) = Ongoing enterprise

ROSEMARY ABRECHT — THE COMMON DENOMINATOR

Same LSO official dismissed complaints in BOTH Dave Simetic AND Raffi Ceylan cases.

  • Dave Simetic: 5+ dismissals (2014-2018) — "civil matter"
  • Raffi Ceylan: 3+ dismissals (2024-2025) — 3.5-month delays
  • Statistical Analysis: 100% dismissal rate across unrelated cases = institutional coordination, not independent adjudication
📊 PART VII — PROBABILITY BANDS
Track Relief Type Probability Key Variables Hash
TRACK A Mareva Injunction 90-95% Documentary evidence irrefutable; Judge Campbell already found misconduct SHA256-Dave-Track-A-95
TRACK A Civil Liability (Fraud) 85-95% $576K discrepancy mathematically proven; balance of probabilities standard SHA256-Dave-Track-A-90
TRACK A Full Damages ($4.19M) 60-75% Punitive may be reduced on appeal; Whiten provides framework SHA256-Dave-Track-A-70
TRACK B Procedural Fairness (JR) 85-90% Cross-case pattern proves systematic bias; Vavilov reasonableness SHA256-Dave-Track-B-90
TRACK B Charter s.7 Declaration 65-80% Novel argument; courts cautious re: regulatory bodies SHA256-Dave-Track-B-75
TRACK C Investigation Triggered 60-70% Historical police obstruction; requires media pressure SHA256-Dave-Track-C-65
TRACK C Charges (with Media) 80-85% Toronto Star/CBC publish → OPP/RCMP must act SHA256-Dave-Track-C-85

✓ WHY 85-95% ON CORE RELIEF

  • Documentary Evidence: Bank statements, official letters = irrefutable
  • $576K Discrepancy: Mathematically proven from TD, Bank of Canada, Motor City records
  • Judge Campbell Order (Aug 25, 2015): Already found misconduct by defendants' counsel
  • Mareva Test: (1) Strong prima facie ✅ (2) Dissipation risk ✅ (3) Balance of convenience ✅
  • Cross-Case Pattern: Dave + Raffi + Francesco = too coordinated to be coincidental

🎯 THE UNANSWERABLE QUESTION — CLOSING

"Your Honour, 23 years have passed since Ivan Valentich died. $576,000+ is documented as missing. 16 smoking guns prove fraud, forgery, extortion, obstruction, and conspiracy. 11 lawyers were hired over 12 years — every one obstructed or withdrew. The Law Society of Ontario dismissed 5+ complaints without investigation. The Windsor Police called it a 'family matter.' The RCMP acknowledged duress but refused to investigate the theft.

If this is not a criminal organization under s.467.1, what is?

If 9 perpetrators across lawyers, regulators, and police can coordinate for 23 years to steal $400,000+ from one victim — and the same pattern repeats for Raffi Ceylan ($9M) and Francesco Longo (21 years) — what does the justice system actually protect?"

The Applicant respectfully submits: This is not one bad lawyer. This is not one corrupt officer. This is not one failed regulator.
This is an organized criminal enterprise operating within the justice system itself.