Court File No. A-48-16

FEDERAL COURT OF APPEAL

BETWEEN:

DAVID RAYMOND AMOS

Appellant/Moving Party

and

HER MAJESTY THE QUEEN

Respondent/Responding Party

NOTICE OF MOTION TO REQUEST AN ORAL HEARING

TAKE NOTICE THAT the Plaintiff/Appellant, DAVID RAYMON AMOS will

make a motion to the Court at Fredericton, NB. on Thursday, April 28, 2016 at 12:30 P.M. or

as soon thereafter as the motion can be heard, at Fredericton, NB.

THE MOTION IS FOR:

1. To request that the Justices of the Federal Court of Appeal notify William Brooks (Brooks),

the Commissioner of Federal Judicial Affairs and Bob Paulson (Paulson), the Commissioner

of the Royal Canadian Mounted Police (RCMP), that they should finally uphold the law and

the mandates of their offices before HER MAJESTY THE QUEEN (CROWN) is subject

to lawsuits in the United States of America (USA) and Canada. The actions in the Federal

Court (File no. T-1557-15) by William Pentney QC, the Deputy Attorney General of

Canada, Prothonotary Richard Morneau and Justice Richard Southcott have caused the

CROWN to lose the right to claim sovereign immunity in the USA in defense of certain

actions that the Amos Clan plans to put before courts of law in the USA and Canada.

2. On December 14, 2015 Justice Richard Bell after studying the evidence properly filed in the

public record and discussing the issues with the Plaintiff/Appellant and the CROWN counsel

delivered his Order orally from the Bench recusing himself and referred to de Grandpré’s

dissenting judgment in Committee for Justice and Liberty et al v National Energy Board et

al, [1978] 1 SCR 369 at p 394 for the applicable test regarding allegations of bias. The

CROWN cannot deny the Plaintiff/Appellant had filed irrefutable evidence of his concerns

about financial crimes and a true copy of an American police surveillance wiretap tape.

3. Since December 14th

, 2015 the Plaintiff/Appellant has been in contact with the offices of the

Attorney General of the USA (USDOJ) and the Federal Bureau of Investigation (FBI). They

have been made well aware that a true copy of an American police surveillance wiretap tape

is on file in the public record of the Federal Court of Canada and of the recent judgment of

the Supreme Court of Canada (SCC), Wakeling v United States of America, 2014 SCC 72.

Officials with the USDOJ and the US Inspector General for Tax Administration are also well

aware that some of their documents pertaining to the Plaintiff/Appellant concerns about their

severe lack of integrity related to cross border taxation etc are also in the public record of the

Federal Court of Canada and they have failed to respond as if they are relying on the Deputy

Attorney General, William F. Pentney QC (Pentney to defend their unethical actions against

the Plaintiff/Appellant in the USA that are ongoing to this very day .Whereas the Attorney

General of General of Canada had the Attorney General of the USA for a client in Wakeling

v United States of America, 2014 SCC 72. and it defended FATCA before the Federal Court

of Canada in the Hillis et al v. Attorney General of Canada and the Minister of National

Revenue [2015] FC 1082 matter and no one will respond the Plaintiff/Appellant’s concern,

he has concluded that his suspicions of a continuing cover-up of his actions are valid.

4. The Deputy Attorney General, William F. Pentney QC (Pentney) acting as the solicitor for

the Defendant/ Respondent is not an infant or incompetent. He and the Crown attorneys

working under him have refused to confer with the Plaintiff/Appellant about the existence of

the copy of wiretap tape filed in the public record or discuss the content of the appeal book

pursuant rule 343(1) until they were duly notified on March 5th

, 2016 of the requirement of

the Plaintiff/Appellant to file a motion pursuant to rule 343(3) of the Federal Court Rules.

However within an unsigned motion record filed in Federal Court on December 10th

, 2015 on

behalf of the CROWN William F. Pentney QC and his associates do admit to the existence of

the wiretap tape properly filed in the public record of the matter. Pentney’s assistant Jill

Chisholm has refused to discuss anything with the Plaintiff/Appellant either on the phone or

in person or in writing. However she has witnessed the Plaintiff/Appellant discuss the

evidence and the wiretap tapes with Justice Bell on December 14th

, 2015 and Justice

Southcott on January 11th

, 2015. Jill Chisholm did not dispute the evidence as he displayed to

the court that he had brought several original wiretaps to the court and that he was willing to

play them for the court to listen to if the Justices doubted his sworn affidavit and his

complaint clearly stating that he was in passion of many American wiretap tapes and that he

had given many original tapes to the RCMP, the FBI and other Police Forces in the past.

Although many wiretap tapes have been stolen from him in the past, the Plaintiff/Appellant

still has in his possession in the USA and Canada many more that he may give to the

Americans recorded on them in order that they may file lawsuits against the USDOJ etc..

5. Since December 14th, 2015 the only responses the Plaintiff/Appellant has received from any

law enforcement authority in Canada or the USA were verbal denials that they knew nothing

of his concerns and snide suggestions that he file another lawsuit. The Plaintiff/Appellant

truly believes that the law enforcement authorities planned on his matter before the Federal

Court to continue to be dismissed. Since the day the Plaintiff/Appellant filed his appeal of

Justice Southcott’s decision it appears that they are planning to make the Plaintiff/Appellant

spend a great deal of money as they delay this appeal as long as possible.

THE GROUNDS FOR THIS MOTION TO REQUESTG AN ORAL HEARING ARE:

1. The Plaintiff/Appellant, David Raymond Amos makes this motion pursuant to rule 35(1)(2)(a)

of the Federal Court Rules which is as follows:

35 (1) Subject to rule 298 and paragraph 385(1) motions that can conveniently be heard at the

General Sittings of the Federal Court may be made returnable accordingly.

(2) A request may be made informally to the Judicial Administrator of the Federal Court of

Appeal or the Federal Court, as the case may be, for an appointment of a special time and place

(a) for sittings of the Federal Court of Appeal or of a judge of that court to hear a motion;

2. A portion of the mandate William Brooks the Commissioner of Federal Judicial Affairs id as

follows:

“In 1996, Federal Judicial Affairs (FJA) was given the responsibility by the Chief

Justice of Canada and the Federal Minister of Justice to coordinate the involvement of the

Canadian judiciary in international technical cooperation initiatives. The Commissioner

for FJA thus represents the principal instrument of intervention in the international

judicial arena on behalf of the federal government, the Minister of Justice and the

Canadian Judicial Council, ensuring that their participation in international activities does

not compromise judicial independence and impartiality. The Commissioner is supported

in the discharge of these responsibilities by the Judicial Advisory Committee on

International Engagement.”

“Since its inception and with the professional contributions of members of the judicial

community, judicial experts and Canadian institutional partners, the International

Programs Division (IPD) has implemented numerous international judicial cooperation

activities and coordinated the participation of Canadian experts to that end. IPD is guided

by the Canadian Judicial Council Policy on International Judicial Activities.”

___________________________

Dated , 2016 DAVID RAYMOND AMOS

P.O. Box 234

Apohaqui, NB E5P 3G2

Plaintiff/Appellant on his own behalf

TO: Administrator, Federal Court

AND TO: WILLIAM F. PENTNEY

Deputy Attorney General of Canada

per: JAN JENSEN

Department of Justice

Suite 1400-Duke Tower

5251 Duke Street

Halifax, NS B3J 1P3

Counsel for the Defendant