• TURMEL: Crown pushes for separate Harris-Mozajko appeals

    From John KingofthePaupers Turmel@1:229/2 to All on Sun Mar 24 14:17:19 2019
    From: johnturmel@gmail.com

    TURMEL: Crown pushes for separate Harris-Mozajko appeals

    JCT: Even though the Crown pointed out the identical issues
    in the Harris and Mozajko appeal to the Court, when Igor
    asked the Court to be joined with the Harris appeal, the
    Crown now tries to ignore. In a letter from Jon Bricker on
    March 21:

    Department of Justice
    March 21 2019
    Igor Mozajko

    Dear Mr. Mozajko

    Re: MOZAJKO, Igor and Attorney General of Canada
    File No: A-339-18

    I confirm receipt of your March 13 2018(!) letter.

    It appears from your letter that you do not intend to file a
    memorandum of fact and law as respondent and cross-
    appellant. Accordingly, and pursuant to rule 347(1), can you
    kindly provide me a list of dates remaining in March, April
    May or June when you are unavailable to attend a hearing of
    this matter in Toronto. I propose we request a three-hour
    hearing. However, please advise if you believe that a longer
    or shorter hearing is required.

    Kindly provide me with this information by end of day Friday
    March 22 in order that I may file a Requisition for hearing
    by March 26 filing deadline.

    Finally, be advised that I reserve the right at the oral
    hearing to object to any arguments by you on the grounds
    that the arguments have not been raised in a memorandum of
    fact and law as respondent and cross-appellant.
    Yours truly,
    Jon Bricker


    JCT: So Igor faxed back his response:

    Igor Mozajko
    Respondent (Cross-Appellant)

    Monday March 25 2019
    VIA FACSIMILE

    Jon Bricker
    Fax: 416-973-0809

    RE: Mozajko v. HMTQ No: A-339-18

    In your March 21 letter, you wrote:
    It appears from your letter that you do not intend to
    file a memorandum of fact and law as respondent and
    cross-appellant.

    It also appears that I intend to rely on the memorandum of
    fact and law of Allan J. Harris. My own memorandum would
    simply be following his template.

    Accordingly, and pursuant to rule 347(1), can you kindly
    provide me a list of dates remaining in March, April May
    or June when you are unavailable to attend a hearing of
    this matter in Toronto.

    I have asked the Court to expedite my appeal to that of
    Harris whose Requisition for hearing is filed. I proffered
    the same dates for my hearing with his as you did for his.

    Finally, be advised that I reserve the right at the oral
    hearing to object to any arguments by you on the grounds
    that the arguments have not been raised in a memorandum
    of fact and law as respondent and cross-appellant.

    The Court hasn't yet decided whether I will be heard with
    Harris. Why would I request a hearing on my own without any
    Memoranda yet filed when you ask to object to my arguments
    on the grounds that the arguments have not been raised in a
    memorandum? If I am not expedited to join Harris to rely on
    his Memorandum, I'll file my own copy of his Memorandum
    before we request any hearing.
    ________________
    Igor Mozajko

    JCT: Imagine asking him to help them with their Request for
    Hearing before he gets a decision his original request to
    the Court to join the Harris appeal and before his
    Memorandum is filed.

    --- SoupGate-Win32 v1.05
    * Origin: www.darkrealms.ca (1:229/2)