The Criminal Code of Canada-




Affirmed the day of March, 2009

I, LINDA JAMES, of the City of Winnipeg, in the Province of Manitoba,

1. THAT I am the mother of the Applicant herein, and as such have personal
knowledge of the facts and matters hereinafter deposed to by me, except where same are stated to be based on information and belief, in which case I verily believe same to be true.
2. THAT I have paid all of the Applicant's legal expenses regarding this matter totaling $__________


THAT I was in attendance on October 27, 2007, at the police station, and I was informed and verily believe that police repeatedly threatened my son that they would turn him over to Minneapolis authorities immediately.


THAT it is my belief that the police illegally entered the Applicant's suite and

searched it without a warrant, on October 27, 2007.


5. “That it is my belief that the police’s actions in seizing the said

property during an illegal search constitutes a criminal offence and that the police committed theft and break, enter commit theft, *assault with a weapon/armed assault, criminal trespass and forcible confinement* on October 27,07, in violation of section 8 of the Charter of Rights and Freedoms

which clearly states “Everyone has the right to be secure against unreasonable search and seizure”. Violation Section 7 of the Charter which “ guarantees every person’s right to life, liberty and the security of the person.”

THAT I am advised by counsel for the Applicant and do verily believe that one of the officers, Const. James Peter Sushnyk #2450, who was present on October 27,2007, subsequently was charged with the offence of being unlawfully in a dwelling house in relation to another unrelated incident, a crime identical that having been committed herein.

THAT it is my belief that after breaking and entering and committing theft in the Applicant's suite, the police acted improperly when they chose to proceed further with unwarranted legal proceedings against the Applicant forcing myself to incur legal costs to defend him, That police exploited false pretense for the need to issue notice of service, effecting repeat trespass and criminal harassment with an aim unto abduction of said applicant. That notice of service had been satisfied as indicated in Winnipeg Police disposition application, by Dec 26/08. That police deliberately withheld notice of service from the court until the first proceeding Feb 13/08 in order to continue to effect said harassment. That continued trespass and criminal harassment via police continued well beyond notice of service as acknowledged by the court.

11. Consistent evasion of the court and the law while engaging in further criminal harassment That police have displayed a consistent pattern of evasion of the court and the law while engaging in further criminal harassment. As per a seven week delay period prior to acknowledgement of our attorney, As per Failure to inform the court about satisfaction of notice of service, which is marked satisfied as of Dec26/07 within their application for disposition of our property, such that notice of service was brought to the attention of the court only upon the first hearing, as of Feb 13/08, facilitating further onset of police criminal harassment and incidents of trespass. As per, criminal harassment via police trespass without warrant or charges on but not limited to the following dates: Nov 30, Jan 7/08, Jan 19/08,Jan 26/08 , Feb 2/08, July 4/08 , July 9th, July10th/08, Aug 31/08, Sept 17/08, Oct 10/08, noting that this harassment extends well


3 beyond the date of notice of service established within the court Feb 13/08. As per repeated failure to provide disclosure of evidence at hearings Feb18/08, March 15/08, April 10/08, June 9th/ 08, Sept.3/08 delaying hearings further and facilitating further opportunity for said criminal harassment. “ An example of such deliberate stonewalling evident within statement of Crown as per attempt at denial of documentary police notes evidence from Oct 27/07 police assault as per following comments made in June 9th hearing: “Your honor we may even find the police notes from Oct 27/07 do not exist 12. That continued repeat criminal harassment and abuse by Winnipeg Police had drawn the necessity of formal letter drafted by our council, July 31st /08, as sent to all sergeants and the Winnipeg Police Chief Keith McCaskill, warning police of *further charges to be brought upon them in the event of any further attempts of kidnapping upon our persons, noting that there are those amongst them already criminally charged as detailed in the afore. 13. THAT I make this Affidavit bona fide and in support of the application herein.

AFFIRMED before me at the City of) Winnipeg, in the Province of ) Manitoba, this day of ) ¬¬¬¬¬¬¬¬¬¬________________________________________ March, 2009. )